Straight to implementation

Straight to implementation is a water quality improvement tool. It allows us to clean up a watershed in advance of using the Total Maximum Daily Load (TMDL or water quality improvement plan) process. The goal is to meet water quality standards faster. 

Straight to implementation can be useful for water cleanup when we know what the pollutant sources are in a waterbody and what we need to do about them.

How we begin the process of getting to clean water

We assess polluted water bodies to determine the sources of pollution. We then decide whether straight to implementation is the best approach to clean up the water body.

Straight to implementation cannot be used in watersheds where there are wastewater treatment plants or other point source dischargers that need more rigorous effluent limits in order for the water to meet water quality standards.

How straight to implementation works

If we decide to use a straight to implementation, then we need to determine which best management practices (BMPs) to use to address the pollutants. It generally takes a number of BMPs to fully address the pollution. However, in some cases, a single BMP may be sufficient.

Our goal is to eliminate pollution from all identified sources. To do this, our staff work with landowners and various groups in the project area. We provide information about pollution problems, identified solutions, and technical assistance. We may also help with identifying sources of financial assistance.

What about TMDLs?

TMDLs are useful to identify sources of pollution and set targets for reducing pollution. They remain the primary tool we use to clean up watersheds. However, there are times when the sources of pollution and the steps to prevent it are obvious, so moving straight to implementation can get water quality improvements on the ground faster.

This happens most often in watersheds with a small set of similar land uses. In these situations, we may choose to work directly with landowners and other partners in the watershed to implement management practices that will eliminate the pollution problem. Impaired waters for which we are pursing a straight to implementation to achieve water quality standards remain on the CWA 303(d) list and still require TMDLs until water quality standards are met.

During implementation, we periodically check our progress to see if our approach will help us meet water quality standards sooner than a traditional TMDL. If not, the approach we are using should be re-evaluated to determine if we should assign a higher priority to develop a TMDL as part of the next integrated reporting cycle.