Watershed Impact - for Public Lands

About This Guide
Purpose
This guide is for state and local public works managers who are
interested in integrating watershed management into their strategic
municipal asset management process.1 Using this guide, these
managers can
ƒ identify municipal infrastructure assets and activities that can
adversely affect the surrounding watershed (reducing asset
values) and
ƒ mitigate these potential effects.
Using the guide’s step-by-step approach, municipal managers can
integrate watershed management into strategic asset management,
using current asset management techniques to achieve municipal
strategic goals.
The guide addresses the key environmental conditions within a
municipality’s watershed that influence strategic asset management
decisions. The guidance consists of a series of self-assessment forms,
which, when completed, create a municipal watershed impact
assessment and action plan. This plan, which should be incorporated
into the strategic municipal asset management process, includes the
following:
ƒ A description of the designated uses for the municipality’s
waterbodies and associated impairments
ƒ A baseline of municipal land-use categories and activities that
can contribute to the waterbody impairments or adversely affect
general watershed health
ƒ A prioritized inventory of discrete municipal activities that can
impact the environment and contribute to known impairments
within the watersheds
1 Property owners interested in assessing their property’s impact on the
watershed will also find this guide useful.
Watershed Impact Assessment Guidance for Public Lands and Facilities iii

ƒ Project-based solutions for cost-effectively mitigating the
environmental burden of each activity—with a focus on low-impact
development, bioengineering, and pollution prevention—
in an easy-to-use format with all the necessary information (such
as justification, benefits, regulatory drivers, appropriate funding
sources, cost estimates, schedules, and potential project
partners)
ƒ A baseline from which to monitor progress over time.
Note: Watershed assessment approaches vary. Municipal managers
can integrate the results of other watershed assessment approaches
into their asset management approach as long as the assessment
results in a prioritized list of activities and projects derived from a
quantitative scoring method.
Organization
Chapter 1 explains how to integrate watershed management into
strategic asset management. It begins with an overview of typical
municipal asset management issues and their impacts on watersheds.
It then examines the strategic asset management approach, explains
why watershed management is a critical dimension, and describes how
to integrate watershed management into the strategic process.
Chapters 2 through 6 contain a series of self-assessment forms and
technical information, which give municipal managers the tools
necessary to develop a municipal watershed impact assessment and
action plan that can be incorporated into their strategic municipal asset
management process. Text in sidebars emphasizes action items, tips,
and useful tools.
Chapter 7 tells how to implement the action plan, track its progress, and
update watershed projects as required.
iv Watershed Impact Assessment Guidance for Public Lands and Facilities

WATERSHED IMPACT
ASSESSMENT GUIDANCE
FOR PUBLIC LANDS
AND FACILITIES
An Approach for Municipal Managers
to Integrate Watershed Management
and Asset Management Strategies
April 2005

Contents
Preface…...............................................................................xi
Acknowledgments…. ........................................................... xiii
Chapter 1. Integration of Watershed Management and
Strategic Asset Management.....................................1-1
1-1 INTRODUCTION................................................................................1-1
1-2 OVERVIEW OF MUNICIPAL ASSET MANAGEMENT AND STRATEGIC
ASSET MANAGEMENT..................................................................1-2
1-2.1 Municipal Asset Management .............................................1-2
1-2.1.1 HOW MUNICIPAL ASSET MANAGEMENT RELATES TO
FINANCIAL MANAGEMENT...................................................1-3
1-2.1.2 GASB 34 AND MUNICIPAL ASSET MANAGEMENT
SYSTEMS..........................................................................1-5
1-2.1.3 PREVENTIVE MAINTENANCE ..............................................1-9
1-2.2 Strategic Asset Management .............................................1-10
1-2.2.1 STEPS OF STRATEGIC ASSET MANAGEMENT ....................1-11
1-2.2.2 IMPLEMENTING STRATEGIC ASSET MANAGEMENT IN
MUNICIPAL MANAGEMENT ................................................1-11
1-3WHY WATERSHED MANAGEMENT SHOULD BE INTEGRATED INTO
STRATEGIC ASSET MANAGEMENT ..............................................1-12
1-3.1 Drivers for Watershed Approach and Assessments ...........1-13
1-3.2 Impact of Watershed Regulatory Approaches on
Municipal Activities............................................................1-14
1-3.3 Incorporating Watershed Management into Strategic
Assessment Management ................................................1-15
1-3.4 Evaluating Watershed Improvement Projects in
Strategic Asset Management............................................1-17
Chapter 2. Steps to Integrate Watershed Management
and Strategic Asset Management..............................2-1
2-1 OVERVIEW OF THE MUNICIPAL WATERSHED IMPACT ASSESSMENT
PROCESS...................................................................................2-1
2-2 OTHERWATERSHED ASSESSMENT PROCESSES ................................2-3
Watershed Impact Assessment Guidance for Public Lands and Facilities v

2-3 LIMITED INTEGRATION WITH STRATEGIC ASSET MANAGEMENT ............2-4
2-4 FUTURE RESEARCH TO FURTHER INTEGRATE WATERSHED
MANAGEMENT WITH STRATEGIC ASSET MANAGEMENT ..................2-4
Chapter 3. Identify Your Watershed and Assess Its
Current Condition.......................................................3-1
3-1 INTRODUCTION................................................................................3-1
3-1.1 Using Your Existing Information ...........................................3-1
3-1.2 Using the Municipal Watershed Impact Assessment
Process...............................................................................3-2
3-2 IDENTIFY MUNICIPALITY’S WATERSHED AND ITS KEY
CHARACTERISTICS......................................................................3-2
3-2.1 Form 1—Identify the Watershed Name and
Hydrological Unit Code (HUC)............................................3-3
3-2.2 Form 2—Calculate WPS for Each Waterbody Listed on
Form 1 ................................................................................3-8
3-3 CREATE WATERSHED MAP.............................................................3-11
3-4 SELECT GOALS AND PERFORMANCE METRICS .................................3-13
3-5 CONCLUSION ................................................................................3-14
Chapter 4. Assess Potential Impact of Municipal Land
Use and Activities ......................................................4-1
4-1 INTRODUCTION................................................................................4-1
4-2 FORM 3—DEVELOP AN INITIAL LIST OF ACTIVITIES .............................4-2
4-3 FORM 4—DEVELOP A SUMMARY OF MUNICIPAL LAND USE
CATEGORIES (COMPARED WITH WATERSHED AVERAGES OR
TARGET VALUES) .......................................................................4-2
4-4 FORM 5—IDENTIFY KEY PHYSICAL CHARACTERISTICS AND
ACTIVITIES .................................................................................4-5
4-5 FORM 6—MUNICIPAL ACTIVITY DATA SHEET .....................................4-8
4-5.1 Form 6, Part 1—Describe the Activity, Its Potential
Impacts, and Identify the Watershed or Waterbody ............4-8
4-5.2 Form 6, Part 2—Quantify the Activity’s Impact and
Determine the Total Activity Burden Score .........................4-9
4-5.3 Form 6, Part 3—Assess Potential for Pollution
Prevention Opportunities ..................................................4-15
vi Watershed Impact Assessment Guidance for Public Lands and Facilities

Contents
Chapter 5. Select Migration Projects for High Priority
Activities ....................................................................5-1
5-1 INTRODUCTION................................................................................5-1
5-2 IDENTIFYING BEST MITIGATION EFFORTS OR BEST MANAGEMENT
PRACTICES ................................................................................5-1
5-2.1 Form 6, Part 4—Determine Project Objectives.....................5-2
5-2.2 Factors in Developing Project Objectives .............................5-4
5-3 SELECTING THE BEST SOLUTION ......................................................5-5
5-4WHAT TO DO IF MULTIPLE MITIGATION EFFORTS ARE POSSIBLE .........5-7
Chapter 6. Develop Project Partnerships............................6-1
6-1 INTRODUCTION................................................................................6-1
6-2WHY FORM PARTNERSHIPS?............................................................6-1
6-3WHAT ARE THE STEPS?...................................................................6-2
6-3.1 Identify Opportunities ...........................................................6-3
6-3.2 Identify Potential Partners ....................................................6-3
6-3.3 Develop Partnerships ...........................................................6-5
6-3.4 Collaborate to Implement Projects .......................................6-5
6-3.5 Share Success and Praise with Outside Stakeholders.........6-5
6-4WORKING WITH OTHER MUNICIPALITIES ............................................6-5
6-5WORKING WITH REGULATORS ..........................................................6-5
6-5.1 Working with Regulators During TMDL Determinations .......6-5
6-5.2 Working with Regulators to Establish Effluent Trading .........6-6
Chapter 7. Implement Solutions and Track Progress .........7-1
7-1 PLANNING AND BUDGETING FOR HIGH PRIORITY PROJECTS................7-1
7-1.1 Estimating and Projecting Project Costs...............................7-1
7-1.2 Integrate Project in Municipal Budget...................................7-1
7-1.3 Identify Available Funding Sources ......................................7-2
7-1.4 Update Zoning and Ordnance Requirements.......................7-2
7-2 SOURCES OF FUNDS FOR IDENTIFIED PROJECTS................................7-2
7-3 OBLIGATING FUNDS, DEVELOPING SCOPES OFWORK, AND
LETTING CONTRACTS..................................................................7-3
Watershed Impact Assessment Guidance for Public Lands and Facilities vii

7-4 PRODUCE SUMMARY REPORTS TO TRACK PROJECTS.........................7-4
7-5 MAINTAINING AND UPDATING YOURWATERSHED RESTORATION
PROJECTS .................................................................................7-5
Appendix A Abbreviations
Appendix B Laws Affecting Watershed Management
Appendix C List of Typical Municipal Activities
Appendix D Data Entry Form for Typical Municipal
Activities
Appendix E References for Best Management
Practices
Appendix F Sample Forms
Appendix G Sample Project Sheet Format
Forms
FORM 1. SUMMARY OF THE MUNICIPALITY’S RECEIVING WATERSHEDS
AND ASSOCIATED WATERBODIES .................................................3-4
FORM 2.WATERSHED PRIORITY SCORE (WPS): A SENSITIVITY
SCORING AND DATA COLLECTION FORM FOR
WATERBODIES/WATERSHEDS......................................................3-9
FORM 3. SUMMARY LIST OF MUNICIPAL ACTIVITIES THAT POTENTIALLY
AFFECT THE WATERSHED............................................................4-3
FORM 4. SUMMARY OF MUNICIPAL LAND USE CATEGORIES ......................4-4
FORM 5. SUMMARY QUESTIONS TO IDENTIFY KEY PHYSICAL
CHARACTERISTICS AND ACTIVITIES THAT MAY POTENTIALLY
IMPACT THE WATERSHED ............................................................4-6
FORM 6. MUNICIPAL ACTIVITY DATA ENTRY SHEET ................................4-17
Exhibits
1-1 ASSET PERFORMANCE CURVE AND BENEFITS OF PREVENTIVE
MAINTENANCE............................................................................1-5
1-2 BASIC FLOW OF AN ASSET MANAGEMENT SYSTEM.............................1-8
viii Watershed Impact Assessment Guidance for Public Lands and Facilities

Contents
1-3 ASSESSING BUDGETING ATTRACTIVENESS OF INFRASTRUCTURE
INVESTMENTS.............................................................................1-9
1-4 ALIGNING STRATEGIC GOALS AND MUNICIPAL ASSET
MANAGEMENT ..........................................................................1-11
1-5 EXAMPLEWATERSHED ..................................................................1-12
1-6 FEDERAL LAWS, POLICIES, AND PLANS RELATED TOWATERSHED
MANAGEMENT AND NON-POINT SOURCE REGULATIONS...............1-14
1-7 HOW WATERSHED MANAGEMENT IS PART OF STRATEGIC ASSET
MANAGEMENT APPROACH.........................................................1-15
1-8 INTEGRATING ENVIRONMENTAL BURDEN INTO ASSET
MANAGEMENT SYSTEMS ...........................................................1-17
1-9 BUDGET ATTRACTIVENESS OF WATERSHED IMPROVEMENT
PROJECTS ...............................................................................1-18
3-1 SAMPLE HYDROLOGICAL UNIT CODES...............................................3-3
3-2 EXAMPLE EPA SURF YOUR WATERSHED LOCATOR ...........................3-5
3-3 EXAMPLE OF EPA WATERS MAP....................................................3-7
3-4 EXAMPLE EPA TMDLWEBSITE ....................................................... 3-7
4-1 DEFINITIONS OF LIKELIHOOD OF OCCURRENCE OR FREQUENCY OF
EVENT CATEGORIES .................................................................4-10
4-2 DEFINITIONS OF SEVERITY CATEGORIES FOR POTENTIAL IMPACTS
TO SURFACE WATER QUALITY ...................................................4-11
TO GROUNDWATER QUALITY......................................................4-12
TO AIR QUALITY........................................................................4-13
4-5 DEFINTIONS OF SEVERITY CATEGORIES FOR POTENTIAL IMPACTS
TO QUESTIONS 17–19 ..............................................................4-13
TO MUNICIPAL COMPLIANCE BURDEN .........................................4-14
4-7 DEFINITIONS OF IMPACT SCORES IN FORM 6....................................4-14
5-1 TYPICAL BMPS AND MITIGATION EFFORTS FOR HIGH PRIORITY
ACTIVITIES .................................................................................5-7
6-1 REGIONAL PARTNERING TEMPLATE...................................................6-4
Watershed Impact Assessment Guidance for Public Lands and Facilities ix

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x Watershed Impact Assessment Guidance for Public Lands and Facilities

Preface
Over the 30 years since the enactment of the Clean Water and Safe
Drinking Water Acts, federal, state and local government agencies,
citizens, and the private sector have worked together to make dramatic
progress in improving the quality of U.S. surface waters and drinking
water. Before these regulations, roughly two-thirds of the surface waters
assessed by states were not attaining basic water quality goals and
were considered polluted. Some of the Nation’s waters were acting as
open sewers, posing health risks; many water bodies were so polluted
that traditional uses, such as swimming, fishing, and recreation, were
impossible.
Through a massive investment of federal, state, and local funds, a new
generation of sewage treatment facilities provides “secondary” treatment
or better. In addition, sustained federal and state efforts to implement
“best management practices” have helped reduce runoff of pollutants
from diffuse, or “nonpoint,” sources. Much of the dramatic progress in
improving water quality is directly attributable to investment in municipal
infrastructure—the land, pipes, and facilities that treat sewage, convey
stormwater and sustain healthy habitat.
This job, however, is far from over. In 2000, the EPA reported that one
or more designated uses are impaired in
ƒ 39 percent of rivers and streams (miles),
ƒ 46 percent of lakes (acres),
ƒ 51 percent of estuaries (square miles), and
ƒ 78 percent of the Great Lakes (shoreline miles).
Furthermore, 14 percent of rivers and 16 percent of lakes did not
support their drinking water use designation.
Addressing these challenges over the next decade requires more than
technologies and regulations—it requires municipal managers to
integrate an environmental ethic into all municipal asset management
activities. Municipalities face the challenge of improving watershed
conditions with limited fiscal resources—funds that are also required to
plan, replace aging infrastructure, meet growing infrastructure demands
fueled by population growth, rehabilitate urban habitat, and secure their
infrastructure against threats.
This report presents a framework for municipal managers to integrate
environmental stewardship (using a watershed management approach)
into its strategic municipal asset management process. Municipal asset
management is primarily a financial approach to managing municipal
Watershed Impact Assessment Guidance for Public Lands and Facilities xi

infrastructure. Strategic asset management augments the municipal
asset management approach by integrating municipality strategic goals,
such as environmental stewardship, into the management of its
infrastructure asset portfolio. The approach provides a mechanism for
municipalities to integrate strategic environmental planning with capital
budgeting and infrastructure management.
The focus of strategic asset management is to evaluate the cost
effectiveness of infrastructure investments. Why focus on cost
effectiveness? Optimally, municipalities would have access to unlimited
funds to construct or improve any infrastructure asset that would
increase public benefit. However, the reality is that municipalities have
limited resources for infrastructure investment. The challenge will be to
invest these limited resources to generate the greatest net public benefit
(that is, to focus on cost effectiveness).
The U.S. Environmental Protection Agency (EPA) made this document
possible via a grant. We acknowledge the efforts of the many people
who participated in the development and completion of this guidance. In
particular, we are grateful to the staffs of the American Public Works
Association, the Low Impact Development Center, and EPA’s Office of
Water.
xii Watershed Impact Assessment Guidance for Public Lands and Facilities

Acknowledgments
LMI prepared this document under a grant (83050601-0) from the U.S.
Environmental Protection Agency (EPA) Office of Water. Research staff from
our Facilities and Asset Management Group led this effort. The team was
comprised of Emil Dzuray, Julian Bentley, Erica Rohr, Heather Cisar,
Lisa Powell, Emily Estes, and Diana Lanunziata. We acknowledge the efforts
of the many other people who participated in the development and completion
of this document. In particular, we are grateful to Ms. Ann Daniels from the
American Public Works Association, Mr. Neil Weinstein from the Low Impact
Development Center, and Mr. Robert Goo from the EPA Office of Water.
The views, opinions, and findings contained in this document are those of LMI
and should not be construed as an official agency position, policy, or decision,
unless so designated by other official documentation. Furthermore, LMI makes
no warranty, expressed or implied, with the respect to the use of any
information, apparatus, method, or process disclosed in this document or
assumes any liabilities with respect to the use of, or damages resulting from
the use of, any information, apparatus, method, or process disclosed in this
document.
LMI is a not-for-profit government consulting firm, dedicated exclusively to
advancing the management of the government. We help managers in public
agencies make decisions that enable immediate action, achieve desired
outcomes, and deliver enduring value. We provide a broad range of services
across six mission areas: acquisition, logistics, facilities and asset
management, financial management, information and technology, and
organizations and human capital. (For more information about LMI, visit
www.lmi.org.)
Watershed Impact Assessment Guidance for Public Lands and Facilities xiii

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xiv Watershed Impact Assessment Guidance for Public Lands and Facilities

Chapter 1
Chapter 1
Integration of Watershed
Management and
Strategic Asset
Management
1-1 Introduction
Municipal managers constantly struggle to balance the conflicting goals
of investing in municipality improvements and maximizing future asset
value under the restrictions of limited budgets. How can municipal
managers successfully budget to enhance current municipality welfare
and increase long-term asset value? An approach that integrates
watershed management with strategic asset management solves the
dilemma of concurrently improving public services, enhancing local
environmental conditions, and investing in the long-term value of the
municipality assets.
Furthermore, municipal managers must achieve these objectives while
cost-effectively complying with numerous federal, state, and local
environmental laws and regulations. This management role has become
increasingly difficult because requirements of major environmental laws
have increased exponentially over the past few decades while municipal
environmental budgets have remained flat. Specific revisions to the
rules promulgating the Clean Water Act (CWA) and Safe Drinking Water
Act (SDWA) have the potential to not only result in more stringent limits
for existing environmental permits, but to impose operational limits on
currently unregulated activities that adversely affect the quality of
surface water, groundwater, habitat, or air.
This guide provides a consistent, cost-effective decision-making
approach that state and local managers can use to integrate watershed
management into their strategic municipal asset management process.
It enables them to identify municipal infrastructure assets and activities
that can adversely affect the surrounding watershed (reducing asset
values) and to find ways to mitigate the effects.
Watershed Impact Assessment Guidance for Public Lands and Facilities 1-1

1-2 Overview of Municipal Asset Management
and Strategic Asset Management
Municipalities share a similar mission: to proactively enhance the health,
safety, and welfare of current and future generations through
responsible stewardship of municipality infrastructure, development, and
What is maintenance functions. Municipalities endeavor to
infrastructure?
Long-lived,
normally
stationary capital
assets—such as
roads, bridges,
tunnels, drainage
systems, water
and sewer
systems, dams,
and lighting
systems—
preserved for
significantly more
years than most
capital assets.
Buildings, which
have a shorter
service life, are
not considered
infrastructure,
except those that
are an ancillary
part of an
infrastructure
facility (such as a
wastewater
treatment
building).
„ create safe and livable communities,
„ fuel economic growth,
„ build cohesive communities,
„ support human growth and development,
„ develop public infrastructure systems that adequately and efficiently
serve communities, and
„ enhance and protect the environment.
Achieving these goals requires that municipalities simultaneously
optimize three independent asset dimensions: condition, functionality,
and environmental impact. Few would argue that current management
approaches attempt to optimize asset condition and functionality. In fact,
most infrastructure investments are made using a purely financial asset
management approach. Most current asset management techniques,
however, fail to integrate municipal strategic goals, including
environmental conditions, in the decision-making process.
Integrating watershed management into strategic asset management
enables municipalities to simultaneously optimize condition,
functionality, and environmental impact; as a result, they can
concurrently optimize financial, environmental, health, community, and
service aspects of infrastructure investments. However, before we can
show how the watershed assessment approach can be integrated into a
strategic asset management approach, we need to review both
traditional asset management and strategic asset management
approaches.
1-2.1 Municipal Asset Management
Municipalities rely on an extensive infrastructure, consisting of
transportation networks, power supply, water supply, drainage,
sewerage, solid waste management services, and other assets. These
assets represent an immense investment built over many generations,
made to fulfill anticipated benefits such as increased productivity and
enhanced citizen welfare. Municipalities face the constant challenge of
maximizing net public benefit with a limited amount of resources.
1-2 Watershed Impact Assessment Guidance for Public Lands and Facilities

Integration of Watershed Management and Strategic Asset Management
The concept of asset management is in its infancy, with varying
definitions. The American Public Works Association’s (APWA’s) asset
management task force created a common asset management
definition, “to efficiently and equitably allocate resources amongst valid
and competing municipal asset goals and objectives,”1 from its review of
various asset management methods. The APWA further defines asset
management to include the following:
What is asset
management?
The APWA’s
definition of asset
management is to
efficiently and
equitably allocate
resources
amongst valid and
competing
municipal asset
goals and
objectives.
„ Efficiently allocate funds: The allocation of funds must be
efficient within a particular class of assets (like roads or
bridges), and within the entire reservoir of assets being
managed (roads versus water networks versus buildings
versus parks versus…). The latest engineering and economic
principles, like value engineering and life cycle cost analysis
or similar concepts are part and parcel of the asset
management policy.
„ Equitably allocate funds: The allocation of funds must be
equitable as well as efficient. In this context, equitability refers
mostly to constraints, limitations, or orientations that an
administration needs to impose on the process in order to
avoid being faced with solutions that fail to take in all factors,
that are beyond its means, or that are unrealistic or
unacceptable. In this context also, equitability allows for the
consideration of expressed user needs and of any particular
overriding one-time need.
„ Valid and competing needs: This refers to all the needs of a
community. Needs are valid if they are determined by
individual management systems or if they are expressed to
and accepted by the managers through any recognized
approval process. The needs can be past unsatisfied needs
(deferred maintenance), current maintenance needs, current
capital improvement needs validated by a value engineering
analysis, or future maintenance needs as determined in life
cycle cost analyses. They are linked directly to the service
levels demanded by the community. The needs are
competing against one another in each class of assets as well
as competing between different classes of assets. Even when
funding is not an issue, competition must still exist to ensure
that the extra dollars are spent in the most efficient way
possible.2
1-2.2 How Municipal Asset Management Relates
to Financial Management
Asset management focuses on the evaluation of the cost-effectiveness
of infrastructure investments. Optimally, municipalities would have
1 N. Danylo and Andrew Lemer, Asset Management for the Public Works Manager:
Challenges and Strategies: Findings of the APWA Task Force on Asset Management,
August 31, 1998. Available from www.apwa.net/documents/resourcecenter/ampaper.rtf.
2 See note 1.

access to unlimited funds to construct or improve any infrastructure
asset that would increase public benefit. However, the reality is that
municipalities have limited resources. The challenge is to invest the
limited resources to generate the greatest net public benefit (that is,
focus on cost-effectiveness).
The optimization of net public benefit is commonly measured by asset
valuation expressed in two ways, functionality and condition:
„ Functionality is the net benefit to the public of the asset’s
function. Functionality measures the asset’s maximum potential
value and depends on the public use of the asset. Not all assets
within the same class have similar functional value. For example,
a critical thoroughfare road has a higher functional value than a
rarely used rural road.
„ Condition is the ability of the asset to provide function over time.
Condition measures the percentage of the maximum functional
value provided during the asset’s life. It can depend on the level
of preventive maintenance. The asset performance curve, shown
in Exhibit 1-1, graphs the relationship between asset
performance, condition, and preventive maintenance, as well as
the benefits of preventive maintenance. As the asset ages, its
condition deteriorates from requiring preventive maintenance to
more costly maintenance and rehabilitation. Once the condition
reaches a minimum level, the asset is unusable and requires
costly reconstruction. However, if the asset receives preventive
maintenance, the rate of deterioration decreases, thereby
extending its life.

Exhibit 1-1. Asset Performance Curve and Benefits of
Preventive Maintenance
Source: Federation of Canadian Municipalities and National Research Council Canada, National Guide to
Sustainable Municipal Infrastructure: Innovations and Best Practices
Depreciation
approach
1-2.3 GASB 34 and Municipal Asset Management Systems
Accurately quantifying the public benefit of infrastructure is a complex
task, one of the greatest challenges in asset management. For example,
there is no simple financial analysis for placing a value on the net benefit
of the presence of a sewer system or road.
ƒ Reduces asset value
over the estimated
useful life.
ƒ Does not value assets
based on condition.
ƒ Focuses on
addressing
infrastructure needs
through new
infrastructure
development.
ƒ Often fails to address
life-cycle costs of
maintaining,
operating, and
renewing assets.
In June 1999, the Government Accounting Standards Board (GASB)
established GASB Statement 34 (GASB 34) to assist in this effort. The
rule requires municipalities to account for the value of major capital
assets (including bridges, roads, water systems, and dams) in their
financial statements. GASB 34 serves as the basis for today’s municipal
asset management systems.
GASB 34 provides two methods for reporting infrastructure assets,
depreciation and the modified approach:
„ Depreciation involves completing an extensive inventory of
assets, including their costs and the dates when they were
created or purchased. Each asset’s value is then calculated on
the basis of depreciation over the estimated useful life. The
method does not value assets on the basis of condition.

„ The modified approach incorporates condition assessments of
infrastructure assets and includes the following requirements:
¾ Maintain an up-to-date inventory of eligible infrastructure
assets.
¾ Assess the condition of the eligible infrastructure assets
every 3 years and summarize the results using a
measurement scale.
¾ Annually estimate the costs to maintain and preserve the
eligible infrastructure assets at the condition level established
and disclosed by the government entity.
Under the modified approach, the municipality reports the actual costs of
maintaining and preserving infrastructure assets at a determined
condition level instead of calculating depreciation charges. The
depreciation method, the easier of the two approaches to implement,
instead focuses on replacing or developing new infrastructure to
address infrastructure needs rather than addressing the life-cycle costs
of maintaining, operating, and renewing these infrastructure assets. The
APWA endorses the modified approach since it enables municipalities to
incorporate the benefits of maintenance into municipal asset valuation.3
Exhibit 1-2 outlines the basic flow and components of an asset
management system, which are as follows:
1. Inventory of Infrastructure Assets. The first stage is to
conduct an inventory of infrastructure assets. Data collected
include location, construction cost, physical characteristics,
usage information, accident history, and maintenance
performed.
2. Infrastructure Asset Valuation. Next, a municipality must
place a value on the asset. Valuation begins by assessing
the condition of all infrastructure assets. GASB 34 requires
municipalities to do so using a replicable measurement
method every 3 years.
The municipality also must estimate the useful asset life. For
each year of the infrastructure’s life, the net public benefit of
the asset is determined from the current predicted condition
levels and planned maintenance. Asset value is then
calculated as the sum of these annual benefits discounted at
the cost of capital.
Asset values are calculated based on functional value and
condition. The modified approach uses a productivity-realized
asset valuation method in which the asset value is
calculated as the “net present value of the benefit stream for
3 American Public Works Association, APWA Policy Statement—GASB 34,
November 2000.

the remaining service life.”4 The net present value captures
the functional value over the lifetime of the asset as well as
the benefits of maintenance on improving the function of the
asset and extending its life (reflected in condition).
3. List of Potential Infrastructure Improvements. At the top of
any municipality’s wish list is having the resources to
complete an infrastructure improvement that has a “return on
investment” greater than the capital cost.
However, municipalities, faced with limited resources, must
develop a list of potential infrastructure improvements that
best allocates their limited funds. The list includes all
potential new infrastructure investments as well as asset
maintenance, retrofitting, or modifications not currently
planned or funded.
4. Resource Allocation Model. Employing a resource allocation
model enables municipalities to rank potential infrastructure
investments and establish funding requirements. The
resource allocation model serves as the heart of municipal
asset management and incorporates the municipality’s key
asset management decision-making method. The primary
inputs to the model are infrastructure improvement cost
estimates, current and future asset condition estimates, and
current and future functional value estimates. The model
calculates a net present value of each infrastructure
improvement using (1) the annual cost expenses for the
improvement, (2) the estimated annual benefits (calculated
using the difference of the current and future asset values),
and (3) the predicted current and future asset life. The most
important output is a ranking of the potential infrastructure
improvements based on return on investment and total cost.
These variables are the primary input to the infrastructure
budgeting process.
5. Infrastructure Budget. Though decision-making logic is
incorporated in the research allocation model, decisions are
ultimately made through infrastructure budgeting. Selecting
infrastructure investments for funding is largely a subjective
process. Though return on investment and total cost provide
decision-making criteria, there is no exact science to
developing an infrastructure budget. On the basis of these
criteria, we have developed nine primary categories of
infrastructure investments. Exhibit 1-3 shows the
attractiveness to municipalities for funding infrastructure
investments within these categories.
4 Sue McNeil, “Asset Management and Asset Valuation: The Implications of the
GASB Standards for Reporting Capital Assets,” Proceedings of the Mid-Continent
Transportation Symposium, 2000.

Exhibit 1-2. Basic Flow of an Asset Management System
Current Asset
Condition
Current Asset
Functional
Value
Infrastructure
Asset
Valuation
List of Potential
Infrastructure
Improvements
Resource
Allocation
Model
Infrastructure
Budget
Forecast Asset
Condition
Improvement
Forecast Asset
Functional
Value
Improvement
inventory of
Infrastructure
Assets
Return on Investment
- Net Asset Value Improvement
- Total Infrastructure
Improvement

Exhibit 1-3. Assessing Budgeting Attractiveness of Infrastructure Investments
Return on
investment Total cost Budgeting attractiveness
1 High Low High: Almost always funded; very cost-effective
2 High Medium High: Generally funded, except when budgets are very tight
3 High High Medium/Low: Although these investments have high returns, limited
resources mean only a handful can be funded
4 Medium Low High: Generally funded, except when budgets are very tight
5 Medium Medium Medium: Most subjective of budgeting decisions; depends on
attractiveness of other investments
6 Medium High Low: High cost, high return investments are likely funded instead of
these
7 Low Low Medium/Low: Projects with higher returns are funded
8 Low Medium Low: Projects with higher returns are funded
9 Low High Low: Projects with higher returns are funded
1-2.4 Preventive Maintenance
Much of the municipal core infrastructure is aging, overused, and lacking
investment in maintenance (repair, rehabilitation, and replacement)—all
of which severely strain the assets. To add to the problem, citizens
demand additional new infrastructure to address growth. Although
municipalities attempt to maximize the returns on their infrastructure
investments, their asset management practices often hinder meeting
these objectives. The primary impediment is budgeting. Few
municipalities can split their capital budgets between new projects and
renewal/maintenance. As a result, they fuel inefficiency, investing in
costly new infrastructure while failing to address asset deterioration.
A solution to the problem, in lieu of additional resources, is to perform
preventive maintenance. Preventive maintenance is a best management
practice that optimizes the public’s benefit from infrastructure
investment.
Preventive maintenance is the most cost-effective approach to
increasing asset values. It reduces the rate of asset condition
deterioration over time, extends the asset life, and increases functional
value. Municipal asset management must shift from a “dire need”
maintenance approach to a preventive system of maintenance and
renewal.5 Preventive maintenance focuses on providing sustained value
to citizens at the lowest cost over the asset life cycle.
5 CartêGraph Systems, Inc., Getting Started in Public Works Asset Management,
2004. Available from www.cartegraph.com.

Other asset management best practices include
„ understanding the requirements of the citizens,
„ understanding the cost of sustaining the value of assets for at
least 15 years,
„ understanding demand for new assets and services,
„ constructing new assets and services only with appropriate
allocations of real operating costs, and
„ selecting an optimal strategy for the municipality, ratepayers, and
social community.
1-2.5 Strategic Asset Management
Strategic asset
management Asset management is a financially based approach to infrastructure
investment. Although effective at managing the economic health of a
municipality, the approach is only loosely linked to serving the
municipality goals, that is, optimizing citizen welfare. Thus, the approach
cannot achieve strategic goals because municipalities often fail to
evaluate infrastructure investments on the basis of their alignment to
municipal strategy. They fail to incorporate in funding decisions the
ability of the asset to (1) create safe and livable communities, (2) build
cohesive communities, (3) support human growth and development, (4)
adequately and efficiently serve communities, and (5) enhance and
protect the environment.
Strategic asset
management
augments the
municipal asset
management
approach by
integrating
municipality
strategic goals into
the management of
its infrastructure
asset portfolio.
Strategic asset management augments the municipal asset
management approach by integrating municipality strategic goals into
the management of its infrastructure asset portfolio. It provides a
mechanism for municipalities to integrate long-term strategic planning
with capital budgeting and infrastructure management. The focus is on
the evaluation of the cost-effectiveness of infrastructure investments.
Exhibit 1-4 presents an evaluation of the financial and strategic
performance of municipalities based on different management
approaches. Municipalities that focus on achieving strategic goals
through a poor or non-existent asset management approach fail to
optimize the financial performance of asset investments. Similarly,
municipalities that make infrastructure investment decisions solely on
the basis of financial returns fail to realize their strategic goals. Only the
best performing municipalities employ a strategic asset management
approach to align infrastructure management and investment with
municipal strategic goals.

Exhibit 1-4. Aligning Strategic Goals and Municipal
Asset Management
Poor Financial
Performance
Poor Financial
and Strategic
Performance
Best Performing
Municipalities
None Best Practices
Asset Management
Little Strategic
Direction
Aligned
Alignment with Strategic Goals
Not
Aligned
1-2.6 Steps of Strategic Asset Management
Strategic asset management consists of the following four steps:
1. Evaluate projects. The municipality evaluates how the project
results align with the municipal goals (mission need).
2. Perform a cost analysis. The municipality analyzes the cost
of the projects, evaluating the design, implementation, and
operating and maintenance costs.
3. Quantify and qualify the project benefits. It quantifies and
qualifies the benefits of the project in improving municipality
asset value (the difference between value before and after
the implementation of the project).
4. Select projects. The municipality selects projects on the basis
of the greatest net financial benefit and associated mission.
1-2.7 Implementing Strategic Asset Management
in Municipal Management
Critical to the implementation of strategic asset management is an asset
management system that integrates strategic goals into final decisions.
Current asset management systems focus on optimizing asset condition
and functionality. The goal is to maximize the net present value of the
benefit streams from infrastructure investments, rather than to achieve
strategic goals.

Municipalities can concurrently manage the financial viability of
infrastructure investments and strive to achieve strategic goals. The
implementation of strategic asset management requires them to
integrate variables that measure the realization of strategic goals into
asset management decisions. They can do so by modifying current
asset management systems to include additional variables in their
evaluation of infrastructure investments. For example, when evaluating
the investment in constructing a bridge, the asset management system
should provide the project’s net economic benefit as well as different
measures of its alignment with a number of strategic goals. The
manager weighs both variables in making an investment decision.
1-3 Why Watershed Management Should Be
Integrated into Strategic Asset Management
Watershed management is the most comprehensive approach to
environmental stewardship. A watershed is simply the land that water
flows across or through on its way to a common stream, river, or lake, as
shown in Exhibit 1-5. A watershed can be very large (thousands of
square miles that drain to a major river, lake, or ocean) or very small (20
acres that drain to a pond). A small watershed that nests inside of a
larger watershed is referred to as a subwatershed. Watersheds,
geographical areas defined by natural hydrology, are the most logical
basis for managing the impacts of human activity on the environment
(air, water, and habitat). Focusing on the natural resource, rather than
the specific sources of pollution, enables municipalities to evaluate the
overall conditions in a geographic area and manage the stressors that
A watershed is affect those conditions.
simply the land
that water flows
across or through
on its way to a
common stream,
river, or lake.
Watersheds can be
any size, from a
few acres to
thousands of
square miles.
River mouth
Watershed
boundary
Groundwater recharge
(aquifer)
What is a
watershed?
Exhibit 1-5. Example Watershed

Watershed management is a critical dimension of strategic asset
management. Minimizing environmental impact (i.e., watershed
management) and enhancing local environmental conditions are integral
to achieving one of the key municipality strategic goals: enhancing the
welfare of future generations by maximizing long-term asset value.
What is
watershed
management?
A framework to
ƒ assess a
waterbody’s
ability to meet its
intended use,
ƒ determine the
pollutants and
potential
sources of
impairments,
ƒ incorporate
assessment
results into a
plan aimed at
achieving water
quality
objectives, and
ƒ foster
collaboration
with all
landowners in
the watershed
1-3.1 Drivers for Watershed Approach and Assessments
Watershed management approaches are particularly important to
municipal managers. Over the past 10 years, municipalities have faced
increasingly complex regulations as the U.S. Environmental Protection
Agency (EPA) has revised much of its legislation. Working to better
integrate watershed approaches, the EPA revised the Clean Water Act,
Safe Drinking Water Act, and other regulations concerning water quality,
effluent standards, source water protection standards, and stormwater
management. These changes, along with the move by regulators to
issue permits by watershed, require municipal managers to reevaluate
how municipal activities impair water resources and to develop action
plans to prevent or correct the identified impairments.
The main compliance drivers behind adopting a watershed approach
and completing watershed assessments to manage water issues are as
follows:
„ Clean Water Act. National pollutant discharge elimination system
(NPDES), total maximum daily loads (TMDL), spill prevention
control and countermeasures (SPCC), wetland 404 permits and
mitigation, sludge disposal or reuse, and point and non-point
stormwater management programs.
„ Safe Drinking Water Act. Source water assessment and
protection program (which includes wellhead protection), and
underground injection control (UIC) program.
„ Coastal Zone Management Act. Required the 29 states with
federally approved Coastal Zone Management Act programs to
develop coastal NPS programs.
Exhibit 1-6 shows the relevant federal laws, policies, and plans related
to watershed management. Appendix B summarizes the key federal
laws and policies governing water resources that provide the basis for
watershed protection activities.

Exhibit 1-6. Federal Laws, Policies, and Plans Related to Watershed
Management and Non-Point Source Regulations
Category Title
Clean Water Act (CWA) and amendments
Part 130 of Title 40 of the Code of Federal Regulations Water Quality
Planning and Management
Safe Drinking Water Act (SDWA) and amendments
Coastal Zone Management Act of 1972 (CZMA)
Clean Air Act (CAA) and amendments
Comprehensive Environmental Restoration, Compensation and Liability Act
(CERCLA)
Emergency Planning and Community Right-to-Know Act (EPCRA)
Endangered Species Act (ESA)
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
Resource Conservation and Recovery Act (RCRA)
Federal laws
Toxic Substances Control Act (TSCA)
EPA’s National Water Program Strategic Plan 2004 -2008, April 2004
EPA’s Watershed-Based NPDES Permitting Policy, January 2003
EPA Memo, Committing EPA's Water Program to Advancing the Watershed
Approach, December 2002
Policies and
plans
EPA’s Draft Watershed-Based NPDES Permitting Implementation Guidance,
August 2003
1-3.2 Impact of Watershed Regulatory Approaches
on Municipal Activities
What is a
TMDL?
A written
quantitative
analysis of an
impaired
waterbody, which
is established to
ensure that the
waterbody’s
designated uses
are attained and
maintained in all
seasons.
The CWA’s TMDL and stormwater regulations are the primary
regulations directing the development of watershed management
policies. However, in their efforts to restore an impaired waterbody,
regulators are increasingly using the broad scope of these regulations,
among others:
„ Modifying a municipality’s NPDES, RCRA, or CAA (in the case of
CAA, it would be pollutants found in a waterbody that are directly
related to air deposition) discharge permits to
¾ require monitoring or limits for new pollutants,
¾ reduce discharge limits of existing pollutants, or
¾ prohibit discharges of particular pollutants
„ Requiring stormwater control devices that provide flow control,
treatment, or both

„ Requiring a permit for or modification of activities that may be
generating non-point sources of pollution and are not typically
covered under the NPDES program
„ Requiring sites to implement best management practices (BMPs)
for construction, agriculture, timber operations, and other
ground-disturbing activities
„ Implementing land use controls or restrictions on activities
located on properties surrounding waterbodies
„ Requiring development of additional riparian buffer zones,
stream bank stabilization, or additional wetlands
„ Restricting the site use of surface water and groundwater.
1-3.3 Incorporating Watershed Management into Strategic
Assessment Management
management (Exhibit 1-7); it is integral to achieving one of the key
municipality strategic goals: enhancing the welfare of future generations
by maximizing long-term asset value. Ignoring the environmental impact
of an asset decision may only have a minimal impact on the value of the
municipality assets in the short term. However, in the long term, a
degraded surrounding environment can reduce asset value and impede
an asset’s functional use.
Exhibit 1-7. How Watershed Management Is Part of Strategic Asset
Management Approach
Current municipal
asset management
techniques fail to
incorporate other
strategic goals in
infrastructure
investment
decisions
Strategic Goal:
Create safe and
livable communities
Strategic Goal:
Strategic Goal:
Support human
growth and
development
Strategic Goal:
Optimize
environmental
condition
Optimize return
on investment
(i.e., minimize
costs)
The watershed
assessment approach
addresses
environmental
condition as part of
the entire strategic
management
approach

Environmental impact factors into all four strategic asset management
steps. First, enhancing and protecting the environment is one of the
pillars of the municipality mission. Second, the cost analysis must
include quantifying the financial consequences of environmental
degradation. Finally, projects that improve environmental conditions
improve asset value. Net financial impact would be incomplete without
integrating environmental condition.
Current management approaches attempt to optimize asset condition
and functionality. They do not address minimizing the environmental
impact. Achieving environmental strategic goals requires municipalities
to simultaneously optimize three independent asset dimensions:
condition, functionality, and environmental burden. By concurrently
evaluating the environmental impacts (as measured by environmental
burden) and financial performance (as measured by functional value
and condition), municipalities can manage infrastructure investments to
reach both financial and environmental strategic goals. Environmental
burden measures the impact of an infrastructure investment on the
receiving environment. Infrastructure investments where the main
purpose is not to improve the environment (such as roads and bridges)
have a negative environmental burden, and investments designed to
improve the receiving environment have a positive environmental
burden.
Environmental burden fits nicely within the current asset management
system, integrated as a component of asset condition. This technique
reduces the value of infrastructure investments that have a negative
impact on the receiving environment. This approach also allows
municipalities to evaluate funding for projects designed only to improve
environmental condition compared with other infrastructure investments
(weigh the benefits environmental projects generate from improvements
to condition compared with project costs). Exhibit 1-8 shows the impacts
of integrating environmental burden on each component of the asset
management system.

Exhibit 1-8. Integrating Environmental Burden into Asset Management Systems
Component Current system
Impact of integrating
environmental burden
Inventory of
infrastructure
assets
List all infrastructure assets and
associated data managed by the
municipality, including location,
construction cost, physical
characteristics, and usage
Collect environmental condition (that is,
watershed condition) data as part of
infrastructure inventory management
system
Infrastructure
asset valuation
Conduct condition assessments of all
infrastructure assets and calculate net
present value of asset benefits over
useful life
Factor environmental burden into asset
condition calculation
List of potential
infrastructure
improvements
List all infrastructure improvements that
have a return on investment greater than
the cost of capital
Add environmental condition
improvement projects to list
Resource
allocation
model
Rank the potential infrastructure
improvements on the basis of return on
investment and total cost
Incorporate environmental burden as a
variable in the model to evaluate the
effects of environmental condition on
investment returns
Infrastructure
budget
Select infrastructure investments for
funding
Integrate environmental impacts in
budgeting decisions
1-3.4 Evaluating Watershed Improvement Projects in Strategic
Asset Management
Evaluation of watershed improvement projects begins with a baseline
valuation assessment. Municipal managers calculate baseline asset
value based on optimal functional value discounted by condition, as
measured by both watershed condition (i.e., environmental burden) and
ability of the asset to provide functional use.
Municipal managers then evaluate and rank potential watershed
improvement projects based on two factors, return on investment and
total project cost. Return on investment is calculated using the increase
in future asset value (from improved environmental burden) measured
against the total project cost.
Finally, municipal managers select watershed improvement projects for
funding. Although the process is often subjective, return on investment
and total cost are the primary decision-making criteria. Exhibits 1-3 and
1-9 outline the attractiveness for funding projects based on return on
investment and total cost.

Exhibit 1-9. Budget Attractiveness of Watershed
Improvement Projects
High Priority
Projects
Return on Investment
Low or
Negative
Secondary
Priority
Projects
Lower
Priority
Projects
High
Low
Total Project Cost
High

Chapter 2
Steps to Integrate
Watershed
Management and
Strategic Asset
Management
2-1 Overview of the Municipal Watershed Impact
Assessment Process
The remainder of this guide describes the steps you can take to
integrate watershed management into your strategic asset management
process. These steps, the Municipal Watershed Impact Assessment
Process, are organized in an easy-to-use format. Using this guidance,
you can assess the impact of your municipality on the local waterbodies
and develop a prioritized list of solutions that can be integrated into your
municipality’s strategic asset management goals and process. The six
major steps of the Municipal Watershed Impact Assessment Process are
as follows:
„ Step 1. Establish and refine strategic asset management
goals. Review current municipal goals, laws, and regulations
and any watershed restoration action plans. You will use this
information to establish or refine integrated goals and
associated performance objectives.
„ Step 2. Calculate the watershed condition score for each
watershed using Forms 1 and 2. Assess the condition and
vulnerability of watersheds, subwatersheds, and
waterbodies; determine designated uses; and identify
impairments of concern. You complete Forms 1 and 2 to
identify and prioritize the watersheds, subwatersheds,
waterbodies, and regional watershed partners located on or
along the municipal boundary on the basis of current
conditions, future vulnerability, and compliance requirements.
The guide walks you through the process of documenting the
designated uses and impairments of concern. At the end of

this step, you will have developed a watershed priority score
(WPS) for each significant waterbody on or surrounding your
municipality.
„ Step 3. Calculate the total burden score for each significant
infrastructure asset or municipal activity using Forms 3, 4, 5,
and 6 (Parts 1, 2, and 3). Assess the potential impact of
municipal activities. This part of the process is divided into
three sections:
1. Using the checklist of typical municipal activities found in
Appendix C, identify those in your municipality that may
contribute to the impairments of concern.
2. Complete Form 3 to create a baseline of municipal activities
by land uses. Use Form 4 to compare your municipality’s
land use with that of the watershed. Use Form 5 to
summarize the municipality’s land-use characteristics.
3. For each activity, use Form 6, Parts 1–3, to calculate the
activity’s impact score, and to create a total activity burden
score (TABS). The TABS is a sum of the activity impact
score (AIS) and WPS. The guide pays particular attention to
the amount of impervious surfaces in your municipality.
„ Step 4. Identify cost-effective solutions to mitigate high
priority impacts using Form 6 (Parts 4 and 5). Identify
whether the municipality needs additional projects to mitigate
high priority activities or land-use conditions. Compare the
prioritized list of activities and their associated impairments
with available BMPs. This guide contains references to
sources of cost-effective BMPs and innovative projects that
can help you mitigate an activity’s potential impact on the
watershed. Integrate project criteria into the municipality
strategic asset management framework to rank projects.
Compare improvement in asset condition (and value) and
project costs to select the most cost-effective projects.
Develop a project description, justification, and cost. Track
funding requests and the project through completion.
„ Step 5. Identify partnerships and funding sources using Form
6 (Part 6). Identify and develop partnerships with other
stakeholders to implement the selected BMPs and other
watershed restoration efforts that reduce the municipality’s
impact on the watershed. Form 6 allows you to list partners,
agreements, benefits, addresses, and points of contact for
tracking purposes. This guide provides links to groups active
in watersheds around the country as well as types of groups
that may provide assistance and support. Chapter 6 contains
a partnership template for tracking regional and project
partners.

Steps to Integrate Watershed Management and Strategic Asset Management
„ Step 6. Implement solutions, track progress, and reassess as
part of strategic asset management. Incorporate the solutions
into your municipality’s strategic asset management
decisions, implement the identified solutions, track their
progress, and update the plan and project requests as
required to adjust management direction as new information
becomes available.
The majority of the information needed to complete the Municipal
Watershed Assessment Process should be readily available from existing
records and federal or state regulatory agencies. In particular, the EPA
has created a database and interactive map site containing a wealth of
information about the nation’s watersheds. The database is available
through the EPA’s Surf Your Watershed website at http://cfpub.epa.gov/
surf/locate/index.cfm. It also has created the Watershed Assessment,
Tracking & Environmental Results (WATERS) website, located at
http://www.epa.gov/waters/enviromapper/index.html. WATERS is a tool
that unites water quality information previously available only on individual
state agency homepages and at several EPA websites. It is a web-based
geographic information system (GIS) that shows watershed delineations,
waterbodies, permitted discharges to all media, TMDL status, and water
quality standards. You can quickly identify the status of individual
waterbodies and generate summary reports on all waters that influence
your municipality.
2-2 Other Watershed Assessment Processes
Other watershed assessment processes available for municipal
managers include the following:
„ The Watershed Protection Audit establishes a baseline of
current strategies and practices within a municipality’s
watershed. The audit can be used to determine the
watershed tools currently available in a watershed. The audit
is located at http://www.cwp.org.
„ The Watershed Vulnerability Analysis provides guidance
on delineating subwatersheds, estimating current and future
impervious cover, and identifying factors that would alter the
initial classification of individual subwatersheds. This
guidance outlines a basic eight-step process for creating a
rapid watershed plan for either a large watershed or a
jurisdiction. The Watershed Vulnerability Analysis is located
at http://www.cwp.org.
„ The Retrofit Assessment includes the Eight Steps to
Stormwater Retrofitting, which outlines the eight steps of
performing a retrofit inventory. This involves examining
existing stormwater management practices and pinpointing
locations that might benefit from additional practices. Details

on retrofit implementation are included. The Retrofit
Assessment is located at http://www.cwp.org.
„ The Codes and Ordinances Worksheet is a simple
worksheet used to compare local development rules in a
community with the model development principles outlined in
the Better Site Design. The worksheet is located at
http://www.cwp.org.
2-3 Limited Integration with Strategic
Asset Management
Although this Municipal Watershed Impact Assessment Process is
designed to be integrated into your strategic asset management
process, the integration is not seamless. Municipalities may use the
outputs of the process, environmental burden improvement and project
costs, as inputs to their strategic asset management systems. These
inputs are then used in those systems to evaluate and rank projects
based on “return on investment” (as calculated by increase in long-term
asset value) and total cost (see Exhibit 1-8).
The strategic asset management approach is in its infancy, especially
the use of condition assessments to value assets. The lack of a
standardized asset valuation method that incorporates environmental
(and watershed) burden complicates a seamless integration of the
process with strategic asset management.
Over the next few years, the strategic asset management approach will
mature and standardized systems are expected to be available for
implementation by municipalities. At that time, we suggest updating the
Municipal Watershed Impact Assessment Process to seamlessly
integrate it with your strategic asset management process.
2-4 Future Research to Further Integrate Watershed
Management with Strategic Asset Management
We suggest further research into incorporating environmental burden
into strategic asset management systems. As more municipalities
become familiar with GASB 34 and its modified approach, we expect
techniques for valuing assets on the basis of environmental burden to
improve and become more available. More research is needed to
determine the best method to factor environmental burden into asset
condition (and valuation) calculations.
Once a standardized method is established for valuing assets on the
basis of environmental burden, we suggest revising the Municipal
Watershed Impact Assessment Process to include asset valuation in
evaluating watershed projects. In addition, the process may be updated
for integration with any new standardized strategic asset management
tools that become available to municipalities.

Chapter 3
Identify Your Watershed
and Assess Its Current
Condition
Summary
This chapter walks
you through the
completion of
Forms 1 and 2.
The information
contained in
Forms 1 and 2
enables you to
identify your
watershed and its
characteristics.
3-1 Introduction
In this chapter, you learn to identify your municipality’s watersheds
and determine their current conditions by completing Forms 1 and 2. It
also presents an approach for developing goals and selecting key
performance metrics to measure progress. The instructions help you
ƒ identify watershed names and hydrological unit codes (HUCs);
ƒ create a map of the watershed and its boundaries;
ƒ prepare a list of regulatory and local designated uses,
impairments of concern, and an overall watershed condition
score using available information;
ƒ calculate a condition score for each receiving waterbody;
I already have
my watershed
information
You may have
already identified
the watersheds and
waterbodies to
which your
municipality drains.
If so, ensure you
have all of the infor-mation
in Forms 1
and 2 and that you
have quantitatively
scored their
condition.
ƒ identify key stakeholders active in the watershed; and
ƒ identify key goals and performance metrics to guide the
prioritization of projects and enable the tracking of progress
over time.
3-1.1 Using Your Existing Information
In addition to the one this guide describes, other methods and
sources are available for determining the conditions of your
watershed:
ƒ Environmental office documentation. The municipal
environmental office may have already identified the
watersheds and assessed the conditions of the waterbodies to
which your property drains.
ƒ Watershed vulnerability analysis. This analysis provides
guidance on delineating subwatersheds, estimating current
and future impervious cover, and identifying factors that would

alter the initial classification of individual subwatersheds. The
document outlines a basic eight-step process for creating a
rapid watershed plan for either a large watershed or
jurisdiction. It is available at http://www.cwp.org/Vulnerability
Analysis.pdf.
ƒ Watershed protection audit. This audit establishes a
baseline of current strategies and practices within the
watershed. By understanding the current state of
development, watershed groups can assess strategies,
practices, strengths, and weaknesses and can better plan
future efforts. This document can help watershed
organizations audit the watershed protection tools currently
available in their watershed. It is available at
http://www.cwp.org/Community_Watersheds/Watershed
Protection_Audit2.pdf.
If you already have the watershed background information, you have
already begun the first step of the watershed assessment process.
You need to ensure you have all of the information in Forms 1 and 2
and that you have quantitatively scored the condition of your
municipality’s receiving waterbodies. You can convert your
information into Forms 1 and 2 or leave them in their original format.
3-1.2 Using the Municipal Watershed Impact
Assessment Process
The remainder of this chapter walks you through the steps for
completing Forms 1 and 2. Complete Forms 1 and 2 by relying on
existing information and tools primarily available in municipal
documents and from EPA, state, and local regulators. Form 1 enables
you to create a summary of key watershed information—including the
name of the watershed, its HUC, the significant municipal
waterbodies, and their condition and vulnerability scores—using
existing information related to watershed indicators. Complete a Form
2 for each significant waterbody identified in Form 1, and then use the
results of Form 2 to select key performance metrics to serve as the
baseline for measuring your municipality’s progress.

Identify Your Watershed and Assess Its Current Condition
3-2 Identify Municipality’s Watershed
and Its Key Characteristics
Locate your
EPA, states, and local groups have established extensive online tools watershed
to help you identify the watershed in which your municipality resides
and assess its characteristics. The two most relevant sites are
Locate your
municipality and
its watershed
using the locator
function on EPA’s
Surf Your
Watershed Internet
site at http://
cfpub.epa.gov/surf/
locate/index.com, or
contact your state
water permitting
program.
ƒ EPA’s Surf Your Watershed site at http://cfpub.epa.gov/surf/
locate/index.cfm and
ƒ EPA’s WATERS website at http://www.epa.gov/waters/. The
WATERS system is a tool that unites water quality information
previously available only on individual state agency
homepages and at several EPA websites. It can also be used
to generate summary reports on all waters of a state.
Both applications provide links to a GIS mapping tool and to related
water program information, including a list of impaired waters from the
303(d) list, water quality standards, and designated uses.
The following sections provide instructions on using these sites to
locate and document key characteristics of your watershed and print
out a map.
3-2.1 Form 1—Identify the Watershed Name and Hydrological
Unit Code (HUC)
The first step is to fill in Form 1 about your municipality’s watershed
and its 8-digit HUC using information provided by EPA, your state,
and other resources. A HUC is a numbering system the U.S.
Geological Survey (USGS) developed, which uniquely identifies all
watersheds in the United States. The HUC, commonly called a
"watershed address," ranges from 2 to 16 digits—the higher the
number is, the smaller the watershed. Exhibit 3-1 shows examples of
2- to 12-digit HUCs.
Exhibit 3-1. Sample Hydrological Unit Codes
Description Proper name HUC Digits
Region Ohio River 05 2
Subregion Wabash and White Rivers 0512 4
Basin Wabash River 051201 6
Subbasin Vermilion River 05120109 8
Watershed North Fork Vermilion 0512010909 10
Subwatershed Lake Vermilion 051201090905 12
A HUC is a
watershed’s
address
The watershed's
HUC is commonly
called its "watershed
address." The U.S.
Geological Survey
provides access to
watershed GIS
boundary files on its
Internet site at
http://water.usgs.gov/
GIS/huc.html.

Form 1. Summary of the Municipality’s Receiving Watersheds and Associated
Waterbodies
Instructions: Complete this form for each 8-digit HUC watershed. Enter watershed priority scores (WPS) from
Form 2. Please attach your watershed map to all Form 3s.
1. Name 2. State and County 3. Zip Code(s)
4. Name of 8-digit HUC watershed(s) 5. 8-digit HUC(s)
6. List of the Receiving Watersheds or Waterbodies Listed as Impaired by the Federal or State
Regulators
Name of waterbody
HUC, 8- to 16-digit,
or state identifier
List of impaired
designated uses
Summary of impairments
of concern (from Form 2)
WPS
(from Form 2)
Regulators
Name of waterbody
or state identifier
List of designated
uses
Summary of impairments of
concern (from Form 2)
WPS
(from Form 2)

Complete Form 1 as follows:
ƒ Blocks 1 through 3. Enter the municipality’s name, state, and
zip code.
ƒ Blocks 4 and 5. Go to EPA’s Surf Your Watershed site at
http://cfpub.epa.gov/surf/locate/index.cfm as shown in Exhibit
3-2. Enter your municipality’s zip codes into the “Locate by
geographic unit” box. This provides the “Watershed Profile” (at
the 8-digit HUC) for your municipality. Enter the watershed
name and 8-digit HUC into blocks 4 and 5.
Exhibit 3-2. Example EPA Surf Your Watershed Locator
Enter Zip
Code
You may also use the “search by map” function at the top of
the screen to locate the watershed. If using the mapping
function, select the state your municipality is in, and drill down
to your general location until the “watershed profile” page is
returned.

ƒ Block 6. To obtain the 303(d) listed waterbodies, use one of
the following sources:
¾ State Water Management Agency. Call your state water
management agency or visit their website, which usually
includes the latest 303(d) report. The 303(d) report lists
the impaired waterbodies. If your waterbody is not listed,
then it is not impaired.
Current
303(d) list
List
States are required
to update their list
of impaired waters
every 2 years.
When identifying
whether your
municipality’s
waterbodies are
impaired, make
sure you are using
the latest 303(d)
list
¾ WATERS Website. Use the WATERS website at
http://www.epa.gov/waters/enviromapper/index.htm.
Select the area on which you would like information, such
as by zip code, and enter the appropriate information.
Then click on the “Zoom to Selected Area” button. A map
of that area will appear. Select the “Update Map” button.
A map of the impaired waterbodies in that area will
appear. Select “identify active feature” and click on the
“Update Map” button. Information on the impaired
waterbodies appears below the map (Exhibit 3-3). You
may need to use the zooming tools to identify the impaired
waterbodies.
¾ TMDL Website. Use the TMDL website at
http://www.epa.gov/owow/tmdl (Exhibit 3-4). Click on your
state, then the waters listed by watersheds, and then your
watershed. This will return a list of the 303(d)-listed
waterbodies in the watershed. Click on your waterbody.
For each listed waterbody, the website provides the
following information: name, parameters (pollutants) of
concern, priority for TMDL development, and potential
sources of impairment.
Copy the listed waterbodies, HUC, and parameters of concern
to the appropriate column under block 6. The priority score, or
WPS, you enter in column 4 under block 6, is determined in
Form 2.
ƒ Block 7. Identify and list the waterbodies not listed as impaired
but that are still a priority for your municipality. For each
waterbody listed in block 7, complete a separate Form 2. Form
2 enables you to develop a WPS for each waterbody.
ƒ Block 8. Identify potential regional watershed partners by
referring to http://www.epa.gov/win/contacts.html. List each
potential partner in block 8. You will also be asked to use this
information to complete the Regional Partnering Template
located in Chapter 6.

Exhibit 3-3. Example of EPA WATERS Map
Exhibit 3-4. Example EPA TMDL Website

3-2.2 Form 2—Calculate WPS for Each Waterbody Listed
on Form 1
Complete a separate Form 2 for each waterbody listed in Form 1. Use
the information provided by EPA on its Surf Your Watershed site to
assess the WPS. The WPS is the sum of the watershed indicator
condition and vulnerability scores, plus points applied to the TMDL
and compliance-based questions found in Form 2. Calculating a WPS
enables you to prioritize the sensitivity of your waterbodies and thus
the activities that occur in their drainage basin. The higher the WPS
is, the more sensitive the watershed is to municipal activities.
Use the following instructions to complete Form 2:
ƒ Block 1. Enter the name and HUC for the waterbody listed in
blocks 6 or 7 of Form 1.
ƒ Block 2. For the waterbody listed in block 1, answer questions
2a through 2i, which determine the designated uses of the
waterbody and whether it meets them. Go to the state
regulator or EPA’s state 305b reports to determine the
waterbody’s designated uses. The designated uses are from
EPA’s national use support categories, Guidelines for
Preparation of the Comprehensive State Water Quality
Assessments (305(b) Reports) and Electronic Updates. Your
state may have state-specific subcategories, which you can
enter in block 2i. For each designated use, check the degree
to which it meets the use, the impairments, and the causes or
stressors of them. For example, if the waterbody does not fully
support the water use classification of fishing and non-point
source pollution from urban runoff is the cause of the
impairment: check “partially supporting” for 2b and enter non-point
source pollution as the impairment and urban runoff as
the cause. If you do not know the answer for the specific
waterbody, enter the default value for the corresponding 8-digit
HUC.
ƒ Block 3. List the state 303(d)-listed pollutants of concern
(impairment) from block 2. Note whether or not the state has
developed a TMDL for the waterbody. EPA and the states
provide this information for most waterbodies on EPA’s TMDL
tracking site at http://www.epa.gov/waters/tmdl/ and the 303(d)
list. If the TMDL is in place, note the effective date.

Form 2. Watershed Priority Score (WPS): A Sensitivity Scoring and Data Collection Form
for Waterbodies/Watersheds
Complete a Form 2 for each waterbody listed Form 1. Record the WPS and pollutants of concern into Form 1 for each waterbody.
1. Name of the Watershed and Corresponding 8- to 16-Digit HUC Code (or State Identifier):
2. Waterbody/Watershed Impairment Score for the watershed listed in Block 1. Go to the State regulator or EPA’s State 305b reports to
determine the waterbody’s designated uses and if they are being met. For each designated use, check the degree it meets the use, the
impairment(s), and the causes/stressors.
Designated Use Impairment Cause/Stressor
Not
Supporting
= 3 pts
Partially
Supporting
= 2pts
Fully
Supporting
= 1pt
Not a
Designated
Use= 0 pts
a. Aquatic life use
b. Fish consumption use
c. Shell fishing use
d. Swimming use
e. Secondary contact use
f. Drinking water use
g. Agriculture use
h. Cultural/ceremonial use
i. State/municipal specific use
_______________________
3. Transfer the State 303(d) listed pollutants of concern (impairments) from TMDL in place?
question 2 and note if the State has developed TMDL. Yes = 3 pt No = 0 pts
Enter TMDL Effective
Date
a. 303(d) Impairment 1:
b. 303(d) Impairment 2:
c. 303(d) Impairment 3:
d. 303(d) Impairment 4:
e. 303(d) Impairment 5:
4. Waterbody/Watershed Vulnerability Score for the watershed listed in Block 1.
Yes
= 1 pt
No
= 0 pts
a. Are the impervious surfaces above 25% of watershed land area (for either current or projected land use)?
b. Is the population growth rate of the watershed above 7%?
c. Does waterbody contain impounded water (e.g., dams and fish barriers)?
d. Is the receiving water listed as a protected estuary?
5. Has EPA, individual service, state, water authority, or local group listed restoration goals for the waterbody in
Block 1? If so, list the specific goals.
Yes
= 1 pt
No
= 0 pts
a. Biodiversity and habitat loss. If yes, list goal:
b. Riparian buffer strip loss. If yes, list goal:
c. Imperviousness/uncontrolled SW runoff. If yes, list goal:
d. Invasive species. If yes, list goal:
e. Wetlands. If yes, list goal:
f. Other: If yes, list goal:
6. Has an enforcement official requested the municipality to monitor/sample the waterbody?
7. Have water withdrawal/use restrictions been imposed for the waterbody?
8. Have potential impacts to human health been identified as a significant concern for the waterbody (e.g., air
deposition of a pollutant to the waterbody, or pollutants in the water are causing a risk to drinking water)?
9. Is this watershed or waterbody designated as a special water resource under the American Heritage River
Program, Great Lakes Program, Scenic Waters Program, or another special program?
10. Watershed Priority Score (WPS) = impairment score (blocks 2 a-i) + TMDLs (blocks 3 a-e) + vulnerability
score (block 4 a-d) + goal score (blocks 5 a-f) + answers on blocks 6 to 9.

ƒ Block 4. For the waterbody listed in block 1, answer “yes” or
“no” to questions 4a through 4d to determine the waterbody’s
vulnerability.
¾ Question 4a. Is the percentage of impervious surfaces
above 25 percent of the watershed land area for either
current or projected land use? This information can be
obtained by contacting your state water program point of
contact or from EPA’s watershed indicators site at
http://www.epa.gov/iwi/.
¾ Question 4b. Is the projected population growth rate of
the watershed above 7 percent? This information can be
obtained from your watershed’s profile page on EPA’s
watershed indicators site at http://www.epa.gov/iwi/.
¾ Question 4c. Does the waterbody contain impounded
waters such as dams or fish barriers? This information can
be obtained from your watershed’s profile page on EPA’s
watershed indicators site at http://www.epa.gov/iwi/.
¾ Question 4d. Is receiving water listed as a protected
estuary? This information can be obtained from EPA’s
National Estuary Program site at http:// www.epa.gov/
owow/estuaries/find.htm.
ƒ Block 5. Has EPA, an individual service, state, water authority,
or local group listed restoration goals for the watershed or
waterbody? If so, list the specific waterbody or watershed
restoration goals associated with each category. These goals
can serve as potential watershed restoration performance
metrics. Information about the active groups in the watershed
can be obtained from your watershed’s profile page on EPA’s
Surf Your Watershed site under the “Environmental Websites”
heading.
ƒ Block 6. Has a federal, state, or local enforcement official
requested that the municipality monitor or sample the
watershed or waterbody? Contact your state water program
point of contact for environmental permits.
ƒ Block 7. Have water withdrawal or use restrictions been
imposed on this waterbody? Contact your state drinking water
point of contact.
ƒ Block 8. Have potential impacts to human health been
identified as a significant concern for the waterbody? Contact
your state drinking water point of contact.

ƒ Block 9. Is this watershed or waterbody designated as a
special water resource under the American Heritage River
Program, Great Lakes Program, Scenic Waters Program, or
other special program established to protect the water
resource? Refer to EPA’s Surf Your Watershed site at
http://cfpub.epa.gov/surf/locate/index.cfm for more information.
ƒ Block 10. Calculate the total WPS for the waterbody by adding
the overall watershed condition score (blocks 2 a-i), TMDL
score (3 points for each yes in blocks 3 a-e), vulnerability
score (1 point for each yes in blocks 4 a-d), watershed goal
score (1 point for each yes in blocks 5 a-f), plus 1 point for
each yes to answers on blocks 6 to 9.
ƒ Remember to complete a separate Form 2 for each waterbody
listed in blocks 6 and 7 of Form 1. After completing each Form
2, record the WPS on Form 1, blocks 6 and 7, as a summary
sheet.
3-3 Create Watershed Map
Aerial and
topographic maps
are available
online
The following
Internet sites
contain various
digital and
topographic maps
that can assist with
watershed efforts:
ƒ USGS provides
digital,
topographic, and
HUC maps.
ƒ WATERS is an
Internet-based
GIS mapping tool.
ƒ Montana State
University
maintains an
extensive online
collection of HUC
maps backed up
with digital maps.
To continue the assessment process, you need to create a map of the
municipality in relation to the watershed and waterbodies. Creating a
map that models hydrologic conditions and land use can identify
watershed areas with the greatest potential impact on source water
quality.
Many state and municipal agencies have in-house GIS capabilities.
Most maintain a GIS map of the municipality that contains various
data layers that will be helpful in creating the watershed map. A GIS is
an effective way to develop a map of the municipality. It presents
selected data layers from the watershed assessment process into an
easily interpreted format.
You should create a municipal map that shows the following data
layers:
ƒ Watershed (e.g., 8 digit HUC) and subwatershed (e.g., 10-16
digit HUC) boundaries
ƒ Municipal boundaries
ƒ Topography
ƒ All major NPDES discharge points
ƒ Vegetative cover
ƒ Waterbodies and points flowing on- and off-site
ƒ Major structures, utility lines, and roads.

You may need to create the watershed boundary layer. Delineating
watersheds is generally a straightforward process, but it may not be
the easiest step, depending on the type and number of sub-watersheds
involved in the municipality. The delineation involves
identifying the drainage area above municipal boundaries on a
topographic map. In some cases, the total watershed area may be
very large, thus prohibiting the investigation of all contributions from
pollutant sources over such a wide area. The watershed drainage
area must still be defined in order to identify the total area contributing
to the water quality in the watersheds affected by the municipality and
to eventually consider all potential contributors to any identified
impairment.
As assessments are completed for other water systems upstream,
that information will be available for review and incorporation into your
assessment and protection plan. The USGS provides detailed
guidance and hard-copy maps on delineating surface watersheds on
their User's Guide for Source Water Assessment and Protection at
http://water.usgs.gov/usaec/tools.html.
A number of federal, state, and local government agencies may
already have topographic data in digital form, including the delineation
of various watersheds and aquifer boundaries. These sources should
be contacted first to reduce duplicate effort. State or regional geologic
agencies should be the first source for hydrogeologic conditions of the
area, and will most likely have studied the conditions in great detail.
State agencies also know the information available in digital or other
format such as reports and studies. A listing of state agencies is
available at http://www.epa.gov/OGWDW/source/contacts.html.
In addition, digital and topographic maps of 8-digit HUCs are available
from the following sources:
ƒ Web-based watershed mapping tools
► EPA’s WATERS site at http://www.epa.gov/waters/
► The Montana State University website at
http://www.esg.montana.edu/gl/huc/index.html.
ƒ Digital USGS topographic maps. The USGS identifies many
places to get topographic maps and aerial photos. Access the
USGS site at http://mapping.usgs.gov/. It also provides access
to watershed GIS boundary files on its site at
http://water.usgs.gov/GIS/huc.html.

3-4 Select Goals and Performance Metrics
Having systems in place to measure and communicate progress is a
critical part of improving a watershed’s health and ensuring
environmental burden is integrated into asset management.
Therefore, this guide includes a block on Form 1 to identify measures
of progress (often referred to as “performance metrics”) for a specific
watershed. Appropriate measures not only keep watershed issues on
management’s mind, but, as they are met, they allow stakeholders to
share successes and highlight new challenges to the watershed.
Make sure that the appropriate measures of progress are selected
and that information on these measures is shared with relevant
stakeholders.
Measurements of progress should be associated with achieving goals
set for the municipal watershed effort. Work with your municipality’s
environmental office to develop specific watershed restoration goals.
Then determine how they tie into asset management. For example,
you may choose meeting water quality measurements (such as
decreasing the percentage of dissolved oxygen, bacteria levels, or
fecal coliform) or less direct water-quality based results (such as
number of feet of wastewater collection pipes retrofitted, number of
miles protected from erosion, or number of trees planted). To make
sure that progress does indeed occur, the watershed restoration goals
should be incorporated into the asset management plan.
For many watersheds around the country, different stakeholders,
including regulators, have identified specific restoration goals. For
example, the Chesapeake Bay Program has set various goals to
improve the Chesapeake Bay watershed. One such goal is to have ”a
Chesapeake Bay free of toxics by reducing or eliminating the input of
chemical contaminants from all controllable sources to levels that
result in no toxic or bioaccumulative impact on living resources that
inhabit the Bay or on human health.” The Puget Sound Water Quality
Action Team has set a variety of goals, including reducing non-point
source pollution and nuisance species. Most of these goals are
voluntary, but the trend is for them to become mandatory. For
example, the Estuaries and Clean Waters Act of 2000 requires federal
agencies in the Chesapeake Bay Watershed to comply with
previously voluntary Chesapeake Bay agreements. Thus, you should
clarify your goals so that they focus the municipality’s actions on the
impacts they have on the watershed, the resources they control, and
the specific property within municipality boundaries.

3-5 Conclusion
The previous sections provide instructions for completing Forms 1 and
2. At this point, you should have
ƒ identified the watershed name and HUC number,
ƒ created a map of the watershed and its boundaries,
ƒ identified overall watershed conditions and potential
impairments,
ƒ prioritized the condition and vulnerability of municipality’s
watersheds, and
ƒ identified key goals and performance metrics to guide the
prioritization of projects and enable you to track progress over
time.
The next chapter provides you with instructions on how to identify and
prioritize specific municipal land-use conditions and activities that may
be contributing to the watershed impairments listed on Form 1.

Chapter 4
Assess Potential
Impact of Municipal
Land Use and
Activities
4-1 Introduction
Summary
This chapter helps
you complete Forms
3 through 6. In this
chapter, you will
ƒ identify specific
land use;
ƒ assess baseline
land use
conditions and
industrial
activities;
ƒ create a list of
priority municipal
activities with the
potential to
contribute to
watershed
impairments; and
ƒ create a relative
total activity
burden score
(TABS) for each
activity.
The next step in the watershed assessment process is to identify the
municipality’s physical characteristics (such as land uses, soil types,
and structures) and associated activities. This chapter provides
instructions for completing the following forms:
„ Form 3, Summary List of Priority Municipal Activities (see
Appendix C for a checklist of typical activities)
„ Form 4, Summary of Municipal Land Use Categories
„ Form 5, Summary of Questions to Identify Key Municipal
Physical Characteristics and Activities
„ Form 6, Parts 1–3, Municipal Activity Data Entry Sheet.
You should find most, if not all, of the information to complete these
forms in existing sources. When complete, these forms enable you to
do the following:
„ Validate a list of activities occurring across your municipality.
„ Create a list of priority municipal activities that have the
potential to contribute to specific watershed impairments of
concern.
„ Identify baseline land-use conditions that may be contributing
to general watershed impairments.
„ Create a relative TABS for each activity to assist in quantifying
its potential impact relative to the condition of the watersheds
identified in Form 1.

4-2 Form 3—Develop an Initial List of Activities
Appendix C provides an initial inventory of the activities that may
significantly impact the watershed or that may be affecting the state’s
TMDL process. The first step is to refer to the summary checklist of
typical activities in Appendix C. Check each activity on the list that
occurs at your municipality and enter its name and location onto Form
3. Enter the receiving waterbody in Question 4. You will develop a
Form 6 for each activity listed in Form 3, transferring your answers
from Form 6 to questions 5–8 once you have completed it.
4-3 Form 4—Develop a Summary of Municipal
Land Use Categories
Watershed management involves gaining an understanding of the
municipality’s land use and hydrological processes that govern the
flow, quality, and velocity of water running onto and off the lands.
Understanding this process requires, among other things, current data
on the amount and type of land cover. Local watershed groups or
regulators also use these measurements as targets for watershed
restoration goals (for example, the percentage of stream miles
containing adequate riparian buffer zones).
To complete Form 4, which creates a snapshot of your municipality’s
land-use averages, you may have to review the municipal master plan
or land-use plan, GIS layers, zoning maps, and stormwater pollution
prevention plans. Once you complete Form 4, compare the results
with the surrounding watershed. Pay particular attention if the
percentage of impervious areas on your municipality is greater than
the average value in the watershed. This may indicate that you need
to investigate additional storm water control mechanisms. Various
studies have shown that as the amount of impervious areas increases
in a watershed, its quality decreases. Therefore, municipalities should
consider ways to mimic the site’s natural hydrology by further
minimizing impervious areas, which reduces stormwater runoff to
predevelopment.
To complete Form 4, you should also
„ refer to Form 3 to determine the total number of activities in
each land-use category,
„ determine the total acres for each land-use category,
„ calculate pervious and impervious percentages, and
„ obtain land-use goals, municipal sustainability goals, or
watershed goals found in the land-use plan and expressed by
EPA, the state, or public and private watershed groups.

Assess Potential Impact of Municipal Land Use and Activities
Form 3. Summary List of Municipal Activities That Potentially Affect the Watershed
4. Potential activity
watershed impact
Activity ID #
1. Activity name
2. Activity
location
3. Waterbody
or sub-watershed
affected
a. Contributes the following
regulated impairments
(e.g., TMDLs)
b. Contributes the following
other impairments
5. Compliance burden
(e.g., governing laws, regulations,
and required permits or plans)
6. Total Activity Burden Score
(TABS=WPS+AIS)
7. Pollution prevention or
enhancements possible?
(Yes or No)
Date Baseline Completed: Page ___ of ____

Form 4. Summary of Municipal Land Use Categories
Description of Land Use Categories
Total # of Activities in
each category
(Refer to Form 3)
Total acres in each
category
Total # impervious
acres
Total # pervious acres
Total % impervious
Total % pervious
Acres covered by
SWP3 or other plan
(specify)
Land use
improvement goal (%)
% of goal
accomplished
Industrial: (Including: Facility
Operations & Maintenance Areas,
Motor Pools, Equipment & Material
Storage Areas, Truck Parking, Wash
Racks, Fueling Points, Industrial
Treatment Plants, Fumigation Areas,
or Shipping/Receiving Areas)
Urban (Including: Commercial –
Shopping Centers, Grocery Stores,
Restaurants, Banks, Parking;
Residential – Housing and Parking;
Office Buildings and Parking; and
roads)
Mixed Use: (including gravel areas,
low impact parking lots, total semi-maintained
open grounds (e.g.,
operational buffers and firebreaks),
and recreational grounds (e.g., ball
fields, horse stables, golf courses)
Paved Roadways
Construction
Agricultural Operations
Natural Areas
Non-riparian forest
Riparian forest and buffer strip
Wetlands
Grasslands or prairie
Endangered species conservation
areas
Waterbodies (stream, pond, or
other)
Coastal area or estuary
Other natural areas (e.g., beaches
and deserts)
Acres of natural areas slated as
protected critical areas
Total for municipality:
Baseline conducted by: Date:

4-4 Form 5—Identify Key Physical Characteristics
and Activities
Complete Form 5 using the list of municipal activities developed in
Form 3. Form 5 contains a series of questions that help you identify
only the activities that have the highest potential to impact water
resources. Form 5 also provides the screening questions that help you
complete Form 6.
To complete
Form 5, users
should review
Before answering the questions in Form 5, obtain and review the the following:
following information:
1. Forms 3 and 4.
2. Meteorological,
soil, and
topography data.
3. Environmental
permits, plans,
and compliance
status.
4. Environmental
management
system (EMS).
„ Municipal master plan or land-use plan containing size, location,
land use, natural resources, and nature of current and planned
activities
„ Meteorological, soil, and topography data, including average
rainfall, soil characteristics, types of ground cover, and
topography
„ Municipal environmental permits, plans, compliance status, and
environmental management system (EMS).
The questions on Form 5 are self-explanatory. Respond to each with
“yes,” “no,” or “unsure.” If yes, note the estimated number of activities
or the approximate area (such as number of acres) affected. If unsure,
describe your reasons. You can also provide additional comments to
clarify answers or describe the location of the activities of concern.

Form 5. Summary Questions to Identify Key Physical Characteristics and Activities
That May Potentially Impact the Watershed
Question about municipality
characteristics or activities
Yes
Unsure
No
Typical
impacts or
concerns with
activity
Number of
activities
(on-site) Comments
1. Does the municipality contain
streams or rivers that have
visible signs of bank erosion,
scouring, or unstable stream
banks? If yes, note if caused
by municipal or off-site
activities.
Aquatic habitat
degradation,
sedimentation,
and flooding
barriers to fish spawning? If
yes, note if caused by
municipal or off-site activities.
Aquatic habitat
degradation,
sedimentation,
and flooding
areas that exhibit uncontrolled
flooding during rain events? If
Aquatic habitat
degradation,
sedimentation,
and flooding
streams or rivers without
adequate riparian buffer (as
defined by watershed goals or
local zoning requirements)?
Aquatic habitat
degradation
and
sedimentation
steep slopes or other areas
that exhibit visible signs of
erosion? If yes, note if caused
activities.
Sedimentation
and flooding
impervious areas (roads,
parking lots, buildings, etc.)
that drain directly to receiving
waters without retention or
detention controls?
Flooding and
aquatic habitat
degradation
7. Do any upstream properties
or activities drain onto the
municipality that may affect
water quality or cause on site
flooding or stream scouring?
Flooding, toxic
or
conventional
pollutants,
TMDLs, and
aquatic habitat
degradation
septic systems or other
underground injection wells?
Toxic or
conventional
pollutants to
aquifers and
TMDLs
Note: For each question answered yes or unsure, list a specific activity or area on Form 3. For each activity listed on Form 3,
complete a Form 6.

That May Potentially Impact the Watershed (Continued)
Question about municipal
Yes
Unsure
No
Typical
impacts or
concerns with
activity
Number of
activities
(on-site) Comments
9. Does the municipality
produce its own drinking
water? If yes, note if using
ground or surface waters
Regulatory
burden such
as source
water
protection,
wellhead
protection, or
conservation
plans
10. Does the municipality conduct
industrial activities that
require NPDES wastewater,
pretreatment, or storm water
discharge permit?
Toxic or
conventional
pollutants,
TMDLs,
sedimentation,
spills, and
regulatory
burden (e.g.,
plans)
maintain bulk storage of
POLs or EPRCA chemicals in
USTs or ASTs?
Spills to
surface or
ground waters
and regulatory
burden
12. Does the municipality conduct
fleet fueling operations or
operate fueling stations?
Toxic
pollutants,
TMDLs, spills,
and regulatory
burden
13. Does the municipality have
uncovered bulk storage of
industrial chemicals,
materials, wastes, or
equipment (e.g., salt or coal
piles)?
Toxic or
conventional
pollutants,
TMDLs, spills,
and regulatory
burden
14. Does the municipality apply
fertilizers or pesticides on its
property?
Toxic or
conventional
pollutants,
TMDLs, spills,
and regulatory
burden
15. Is the municipality
undertaking or planning major
construction or ground
disturbing activities?
Sedimentation
and regulatory
burden
Note: For each question answered yes or unsure, list a specific activity or area on Form 3. For each activity listed on Form 3, complete
a Form 6.

4-5 Form 6—Municipal Activity Data Sheet
Form 6 allows you to record all the information needed to assess each
activity’s impacts on the watershed identified in Form 3. It contains 6
parts to include:
„ Part 1. Describe the activity, its potential impacts, and identify
its receiving waterbody.
Electronic
Version of
Form 6
The electronic
version of this
protocol contains
an electronic
version of Form 6.
The scores are
automatically
calculated using
an MS Excel
spreadsheet.
„ Part 2. Quantify the activity’s potential impact.
„ Part 3. Assess potential pollution prevention (P2) opportunities.
„ Part 4. Determine project objectives.
„ Part 5. Select BMPs, estimate costs, and identify sources of
funds.
„ Part 6. Identify project lead and potential project partners.
Complete a separate Form 6 for each activity validated in Form 3. This
chapter provides detailed instructions for completing Parts 1, 2, and 3
of Form 6. Chapter 5 provides instructions for Parts 4 and 5 of Form 6.
Chapter 6 provides instructions for Part 6 of Form 6. The electronic
version of this protocol contains an electronic version of Form 6. The
form automatically calculates the activity’s scores.
Although most of the information required to complete Form 6 may
already be available in existing reports, you may want to walk around
the municipality to document current conditions at each of the activity
sites, as well as to talk to personnel in charge of each activity.
4-5.1 Form 6, Part 1—Describe the Activity, Its Potential Impacts,
and Identify the Watershed or Waterbody
The following instructions will help you complete Part 1 of Form 6 (the
instruction number corresponds to the block numbers on the form):
1. Enter name of activity. This name should be clear and
concise.
2. Provide a detailed description of the activity and its
operations. Note how often the site is used for the activity:
continuous, daily, monthly, sporadically, etc. The amount
helps you rate the activity’s impact.
3. Enter the location of the activity. Refer to the watershed map
quadrants or latitude and longitude, if applicable.
4. List the office responsible for operating the activity.

5. Enter a tracking number unique to the activity: a tracking
number you currently use, a Standard Industrial Classification
(SIC) number, or other number.
6. Describe current mitigation efforts or past restoration efforts in
place at each activity. This can include a description of the
type of equipment, the structural controls, or the management
practices in place.
7. Estimate the annual operation and maintenance (O&M) costs
for mitigation efforts described in Block 6. If exact figures are
not available, provide a rough estimate.
8. Check all laws and regulations that regulate or permit the
operation of the activity or its discharges. Refer to Appendix
B, which contains a list of the environmental laws and
regulations associated with typical municipal activities.
9. List the specific environmental permits or plans required by
law that the activity must have to operate.
10. List the waterbody’s name and 8-, 10-, or 12-digit HUC from
Form 1.
11. Enter the WPS for that waterbody as determined on Form 2.
12. List the TMDL pollutants or 303(d) listed pollutants of concern
that may be released by the activity. For each pollutant,
choose “yes” if the TMDL exists or is planned to be online
within 2 years. This information is available from Form 2. For
each pollutant, also note if its release is based on an estimate
(such as professional judgment) or if it has been determined
from sampling results.
13. Check all of the activity’s other potential impacts (“K” for
known or “P” for potential). Refer to Appendix C, which
contains a list of common activities and the typical
environmental impacts associated with each.
4-5.2 Form 6, Part 2—Quantify the Activity’s Impact and Determine the
Total Activity Burden Score
The AIS enables you to develop a quantitative baseline of current
activities that may contribute to waterbody impairments. This
information is particularly useful for municipalities in areas where the
state is developing TMDLs. In addition, the process also supports
users who are attempting to develop an EMS by creating a prioritized
list of municipal activities that have an environmental aspect and
impact.
The scoring approach is based on EPA, DoD, and Department of
Energy (DOE) risk ranking systems. The user develops the activity

impact “score” by considering the severity of the impact and its
frequency. In general, users first, estimate the likelihood that a specific
impact will occur (such as 1 chance in 100 events) or the frequency of
an activity (such as number of car washes conducted in a year).
Exhibit 4-1 contains four categories of likelihood or frequency (LF) and
assigns a LF value (LF0, LF1, LF2, or LF3). Then, users estimate the
severity (negligible to significant) of the impact if the event occurred
using the severity (S) matrixes for each media (Exhibits 4-2 through
4-6) and select a corresponding S value (S0, S1, S2, or S3). Then
using the selected LF value and S value, users can assign an activity
impact score as shown in Exhibit 4-7. Mark the corresponding box for
each applicable question on Part 2 of Form 6.
Users should rely on existing studies or professional judgment when
selecting a score in Part 2 of Form 6. The following instructions provide
the detailed steps for scoring the municipal activity’s impact to surface
water, groundwater, air quality, critical habitat, cultural resources,
health and safety, and compliance burden.
Exhibit 4-1. Definitions of Likelihood of Occurrence or Frequency
of Event Categories
LF0 Negligible likelihood (such as one chance in a million events) of
release or impact occurring, no known plan exists to conduct the
activity, or the activity occurs less than once a decade
LF1 Improbable likelihood or low frequency (such as 1 chance in 100)
of release or impact occurring, or the activity takes place less than
once a year
LF2 Probable likelihood or low frequency (such as 1 chance in 10
events) of release or impact
LF3 Very likely or high frequency (at least 1 chance every 2 events or
continuous) release or impact, such as a constant discharge
14. Surface water impact. For each activity, estimate the
likelihood of impact occurring using Exhibit 4-1 and estimate
the severity of the consequence using Exhibit 4-2 to select the
appropriate AIS using Exhibit 4-7 for questions 14a–j. Then
enter the corresponding answer on Form 6:
a. Does the activity result in a direct point source discharge
to surface water that is regulated under the CWA (do not
include a discharge from storm water runoff)?
b. Is the activity out of compliance with CWA regulations
because it does not have an individual permit or is NOT
included on the municipality’s permit?
c. If the activity is permitted, is it currently out of compliance
with the permit standards?
d. Has the activity had past recurring non-compliance with
permit standards and/or conditions?

e. Does the activity have a discharge of storm water runoff
from a “regulated” point source?
f. Does the activity have storm water runoff from non-point
sources?
g. Are the pollutants discharged from this activity to surface
water the same as those pollutants listed on the
state/EPA 303(d) list (TMDL) for this waterbody?
h. Does the activity drain to a waterbody that is a source of
drinking water?
i. Is the activity located in a State-identified Source Water
Protection Zone?
j. Does the activity adversely affect flow of a waterbody
through restrictions on water withdrawal or discharge
volumes?
Exhibit 4-2. Definitions of Severity Categories for Potential
Impacts to Surface Water Quality
S0 The activity has no impact on surface water
S1 Minimal impact. The activity results in a discharge of pollutant or other
impairment that has minimal negative impact on surface waterbodies:
it is temporary, contained immediately around activity, and does not
result in a release of a 303(d) listed impairment to waters of the state
S2 Moderate impact. The activity causes discharge of pollutant or other
impairment that has moderate impact on surface water, and the
pollutant(s) of concern or impairment(s) is
ƒ listed as a 303d pollutant or cause of waterbody impairment, and
the impact is local in scale; or
ƒ not listed as a 303d pollutant or cause of waterbody impairment,
and the impact is temporary and contained within the activity
boundaries; or
ƒ not listed as a 303d pollutant or cause of waterbody impairment,
and the impact is temporary and contained immediately around
the activity, but the waterbody is a source for potable water
S3 Significant impact. The activity discharges a pollutant(s) or causes
another impairment(s) that has a significant impact on surface water,
including
ƒ a discharge of a 303d or State listed impairment or causes an a
303d or state listed impairment that is persistent or an off-site
impact; or
ƒ the impact prevents a waterbody from meeting its intended uses

15. Groundwater impact. Use Exhibit 4-3 in conjunction with
Exhibit 4-1 to select the appropriate color in Exhibit 4-7 for
questions 15a–d. Then enter the corresponding answer on
Form 6.
a. Does the activity inject or have infiltration of a pollutant to
groundwater?
b. Does the activity discharge pollutants that violate drinking
water maximum contaminant limits (MCLs) or water
discharge permit limits to groundwater (if permitted)?
c. Does the activity drain to groundwater that is a source of
drinking water (aquifer or well)?
d. Is the activity within 300 feet of a drinking water well or
within a wellhead protection zone?
Impacts to Groundwater Quality
S0 Activity reduces amount of parameter released to groundwater
S1
Minimal impact. The activity causes discharge of pollutant or
negatively impacts flooding or water supply, but the discharge
amount or negative impact is minimal
S2
Moderate impact. The activity causes discharge of pollutant or
negatively impacts flooding or water supply, but the discharge or
negative impact is on post, temporary in nature and parameter, and
not listed as a 303d pollutant or cause of waterbody impairment
S3
Significant impact. The activity causes discharge of pollutant or
negatively impacts flooding or water supply, but the discharge or
negative impact is listed as a 303d pollutant, the aquifer is source
water, the scale of damage is off-post, or the impact prevents the
waterbody from meeting its intended purposes
16. Air quality impact. Use Exhibit 4–4 in conjunction with
Exhibit 4-1 to select the appropriate color in Exhibit 4-7 for
questions 16a–b. Then enter the corresponding answer on
Form 6:
a. Does the activity have non-permitted discharges to air that
are also TMDL regulated pollutants?
b. Does the activity have a permitted discharge to air that is
also considered a TMDL regulated pollutant? If so, is this
air discharge in compliance with the CAA permit?

Impacts to Air Quality
S0 The activity reduces amount of parameter released to air
S1
Minimal impact. The activity causes discharge of pollutant or
negatively impacts air quality, but the discharge amount or negative
impact is minimal
S2
Moderate impact. The activity causes discharge of pollutant or
negatively impacts air quality, but the discharge does not migrate off-post
and complies with air standards
S3
Significant impact. The activity causes discharge of pollutant that
negatively impacts air quality, the discharge migrates off-post, and
the discharge is beyond guidelines set by air standards
Use Exhibit 4-5 in conjunction with Exhibit 4-1 to select the appropriate
color in Exhibit 4-7 for questions 17–19. Then enter the corresponding
answer on Form 6.
17. Critical habitat impact. Does the activity disturb
sensitive/critical habitat or endangered species habitat?
18. Cultural resources impact. Does the activity adversely affect
cultural resources or historic property?
19. Health and safety impact. Does the activity discharge
pollutant(s) that pose a risk to worker/public health and/or
safety?
Impacts to Questions 17–19
S0 The activity positively impacts the ecosystem, cultural resources, or
health and safety parameters
S1 Minimal impact. The activity causes minimal negative impact
S2 Moderate impact. The activity causes moderate negative impact, but
only on post
S3
Significant impact. The activity causes significant negative impact,
regional in scale, or affects sensitive areas or endangered species on
post, or the impact is on off-post habitats
20. Municipal compliance burden impact. Use Exhibit 4-6 in
conjunction with Exhibit 4-1 to select the appropriate color in
Exhibit 4-7 for question 20a–c. Then enter the corresponding
answer on Form 6.
a. Will a new operation cause the activity to have a new
pollutant discharge to water resources that will increase
compliance requirements or liability?

b. Does the activity require an environmental plan that calls
for management of discharges to water resources? If yes,
has the plan been implemented? If so, has the plan been
unsuccessful in reducing discharges of pollutants to water
resources?
c. Is the activity currently out of compliance with other
environmental laws or regulations (e.g., RCRA, FIFRA,
CERCLA), or has it had recurring non-compliance for any
discharge, spill, or injection of a pollutant to water
resources?
Impacts to Municipal Compliance Burden
S0 No impact. The activity has no compliance requirement and requires
no permit or plan
S1 Minimal impact. The activity is governed by environmental regulations,
but has no regulatory requirement for a permit or plan to operate
S2
Moderate impact. The activity is governed by environmental
regulations but has no regulatory requirement for a permit to operate,
only a plan
S3
Significant impact. The activity is governed by environmental
regulations and has a regulatory requirement for a permit and a plan
to operate
Exhibit 4-7. Definitions of Impact Scores in Form 6
Combined “S” and “L” response Answer for
Form 6
Yes or known significant impact (S3+L3 or S3+L2 or
S2+L3) 3 points (red)
High probability or uncertain impact (S1+L3 or S2+L2 or
S3+L1) 2 points (pink)
Low probability but uncertain impact (S3+L0, S2+L1 or
S1+L1 or S1+L2) 1 point (yellow)
No known or negligible impact (L0 or S0 in any
combination) 0 points (green
21. Identify other activity regulatory concerns or issues and
rate the impact.
22. Calculate the AIS by adding your answers to questions
14–21. Record the total in this block.
23. The TABS equals the sum of the WPS you recorded in
Block 13 of Form 2 and the AIS. This approach is based
on the hypothesis that an activity’s total burden increases
as the vulnerability of the ecosystem in which it operates
increases.

Once you have calculated an activity’s AIS and TABS, transfer these
scores back into Form 1 to create a summary sheet of all activities
and scores.
4-5.3 Form 6, Part 3: Assess Potential for Pollution Prevention
Opportunities
This part of Form 6 allows you to identify activities that are candidates
for elimination, outsourcing, consolidation, process reengineering,
material substitution, or other P2 approaches. Candidate activities are
ones that exhibit a relatively higher burden-to-municipal-need ratio. In
other words, they cause a high environmental burden, but have a low
municipal need. These are the activities that you should review for
opportunities to reduce their impact by
„ eliminating the activity,
„ consolidating multiple activities,
„ reengineering the activity, or
„ implementing other pollution prevention approaches.
24. Determine the Municipal Need Score (MNS) by selecting the
appropriate score:
¾ Score of 1. The activity is unrelated to the municipal
functions or municipal operations would not be
adversely impacted at all if the activity ceased
operations.
¾ Score of 5. The activity is somewhat related to the
municipal functions or municipal operations would be
slightly adversely impacted if the activity ceased
operations.
¾ Score of 10. The activity is critical to the municipal
functions or municipal operations.
25. To determine the burden-to-municipal-need ratio, divide the
TABS from Block 25 by the MNS from Block 23.
26. Check all the P2 options that may be appropriate for mitigating
the impacts or compliance burden of the activity. Refer to Block
20 when making your selections.
The following chapters of this guide provide instructions on how to
complete the remainder of Form 6.

Form 6. Municipal Activity Data Entry Sheet - Part 1
Part 1. Describe the Activity, its Potential Impacts, and Identify its Watershed or Waterbody
1. Name of activity: 2. Describe activity:
3. Location(s):
4. Responsible office: 5. Unique activity ID# or SIC#:
6. Describe current mitigation efforts and past restoration efforts (Existing
or Planned):
7. Estimate annual cost of mitigation
efforts:
8. Check the laws that regulate/permit the operation of the activity:
□CWA □RCRA □CAA □SDWA □EPCRA □ NCA □NHPA
□TSCA
□FIFRA □ESA □CZMA □ NEPA
□ State:_________________________
□ Local:_________________________
□ Other:_________________________
9. List required permits and plans:
a. _______________________________
b. _______________________________
c. _______________________________
d. _______________________________
10. Receiving waterbody name and 10th–12th level HUC #, Form 1:
11. WPS from Form 2:
Pollutant of Concern TMDL? Sampled Estimated
303(d) Impairment 1: yes no
12. List the TMDL
regulated pollutants
or 303(d) listed
pollutants of
concern released
by activity from
Form 2
13. Check activity’s
other known or
potential pollutant
releases or
impairments
(Check K for Known
or P for Potential
and check all that
apply.)
K/P
Release nutrient
Release BOD/COD
Release inorganic
Release metals
Release POLs
Uncontrolled storm
water runoff
Release pesticides
K/P
Release TSS
Cause erosion
Cause thermal pollution
Release pathogens
Disrupt potable supply
Release explosives
Potential spill
Release VOC/SVOC
K/P
Release SOx to air
Release NOx to air
Hazardous air pollutants
Greenhouse gas
emission
Release PM 10 to air
Violate noise standards
K/P
Decrease riparian
buffer
Introduce invasive
species
Decrease wetlands
Decrease fish
spawning range
Cause in-stream
scouring
Cause flooding

Form 6. Municipal Activity Data Entry Sheet (Continued) - Part 2
Part 2. Quantify the Activity’s Impact and Determine the Total Activity Burden Score
Answer the following questions to develop the activity's impact score (AIS):
(Use your own professional judgment, technical studies, monitoring data, and the instructions to answer
the questions.)
Yes or known
significant impact = 3
pts
High probability or
uncertain impact =2 pts
Low probability but
uncertain impact =1 pt
No or negligible impact
= 0 pt
a. Does the activity result in a direct point source discharge to surface waters that
is regulated under the CWA (do not include a discharge from storm water runoff in
this question)?
b. Is the activity out of compliance with CWA regulations because it does not have
an individual permit or is NOT included on the municipal permit?
c. If the activity is permitted, is it currently out of compliance with the permit
standards?
d. Has the activity had past recurring non-compliance with permit standards and/or
conditions?
e. Does the activity have a discharge of storm water runoff from a “regulated” point
source?
f. Does the activity have storm water runoff from non-point sources?
g. Are the pollutants discharged from this activity to a surface water the same as
those pollutants listed on the state/EPA 303d list (TMDL) for this waterbody?
h. Does the activity drain to a waterbody that is a source of drinking water?
i. Is the activity located in a state identified Source Water Protection Zone?
14. Surface Water Impact
j. Does the activity adversely affect flow of a waterbody with restrictions on water
withdrawal or discharge volumes?
a. Does the activity inject or have infiltration of a pollutant to groundwater?
b. Does the activity discharge pollutants that violate drinking water maximum
contaminant limits (MCLs) or water discharge permit limits to groundwater (if
permitted)?
c. Does the activity drain to groundwater that is a source of drinking water (aquifer
or well)?
15. Groundwater Impact
d. Is the activity within 300 feet of a drinking water well or within a wellhead
protection zone?
a. Does the activity have non-permitted discharges to air that are also TMDL
regulated pollutants?
16. Air Quality Impact b. Does the activity have a permitted discharge to air that is also considered a
TMDL regulated pollutant? If so, is this air discharge in compliance with the CAA
permit?
17. Critical Habitat Impact Does the activity disturb sensitive/critical habitat or endangered species habitat?
18. Cultural Resource Impact Does the activity adversely affect cultural resources or historic property?
19. Health and Safety Impact Does the activity discharge pollutant(s) that pose a risk to worker/public health
and/or safety?
a. Will a new municipal operation cause the activity to have a new pollutant
discharge to water resources that will increase compliance requirements or liability?
b. Does the activity require an environmental plan that requires management of
discharges to water resources? If yes, has the plan been implemented? If so, has
the plan been unsuccessful in reducing discharges of pollutants to water
resources?
20. Compliance Burden
Impact
c. Is the activity currently out of compliance with other environmental laws or
regulations (e.g., RCRA, FIFRA, CERCLA) or has it had recurring non-compliance
for any discharge, spill, or injection of a pollutant to water resources?
21. Identify other activity a.
regulatory concerns or issues
and rate the impact. b.
22. AIS Sum scores from questions 14 to 21
23. Total Activity Burden Score (TABS) = AIS+WPS (from Form 2):

Form 6. Municipal Activity Data Entry Sheet (Continued) - Parts 3–6
Part 3. Assess Potential for Pollution Prevention Opportunities
24. Activity’s Municipal Need Score. Select either 1 (the activity is unrelated to the municipality or municipal
operations would not be adversely impacted at all if the activity ceased operations), 5 (the activity is somewhat
related to the municipal or municipal operations would be slightly adversely impacted if the activity ceased
operations), or 10 (the activity is critical to the municipal operations)
10 5 1
25. Calculate the activity’s current Burden to Municipal Need Ratio which equals the TABS from Block 23 /
MNS from Block 24. [Higher ratios identify high burdens, but activities with lower importance. These activities are
excellent candidates for the P2 evaluations listed in Block 26].
26. Check the following P2 options that are appropriate for mitigating the impacts or compliance burden of the activity:
eliminate activity consolidate activity outsource activity implement process change change materials
Part 4. Determine Project Objectives
27. Are enhanced mitigation efforts needed for this activity? Specifically, do you want to: yes no
a. Reduce the amount of pollutants entering receiving waters? yes no
b. Reduce runoff velocities or mimic predevelopment runoff flow volumes? yes no
c. Improve reliability and ease of maintenance of existing BMPs? yes no
d. Comply with permit requirements (for pollutant removal or flow control)? yes no
e. Reduce lifecycle costs of existing operations or BMPs? yes no
f. Restore natural habitat yes no
g. Other (describe)_____________________________________________________ yes no
Part 5. Select Project BMP, Estimate Costs, and Source of Funds
29. Cost Data $
Estimated total startup costs
a. Estimated planning, design permitting costs
b. Estimated purchase/construction costs
28. Describe selected mitigation project or BMP: If yes to
#27, provide title of proposed BMP or control technology:
Estimated OM costs
30. Estimate a reduction in TABS, assuming successful implementation of the enhanced mitigation
effort uses the same scoring sheet as your original TABS (Part 2). Enter new TABS here.
31. Calculate cost effectiveness of proposed project = revised TABS score / total start costs
32. Provide reference to detailed project sheet
33. List most appropriate source of funds (e.g., OM):
34. Is project eligible for other funds (e.g., state grants, EPA grants, grants from other organizations, etc.):
Part 6. Identify Project Lead and Potential Project Partners
35. Project lead office: 36. Contact phone:
37. Point of contact name: 38. Contact e-mail:
39. List potential partners
Organization name: Point of contact: Contact phone: Role in project:
40. Attach a picture of the location, impairment, or activity
Form created by: Date form created: Form revised by: Date form revised:

Chapter 5
Select Mitigation
Projects for High
Priority Activities
5-1 Introduction
Once users have created an inventory of activities occurring on a
property, described the current mitigation efforts in place (Forms 3 and
6), and identified whether there is an opportunity to apply P2 solutions
(Form 6, Part 3), the next step is to determine whether enhanced
mitigation efforts are necessary and, if so, identify the best solution to
achieve the site objectives. This chapter provides instructions on how
to complete Parts 4 and 5 of Form 6 by
„ assessing the feasibility of implementing enhanced mitigation
projects, such as structural or nonstructural BMPs;
„ selecting the performance objectives for the potential BMP;
„ selecting the most appropriate BMP;
„ identifying performance, design, construction, maintenance,
and cost factors for the selected BMP; and
„ developing cost estimates.
This chapter also lends additional assistance in identifying and
selecting BMPs for typical activities. Appendix D contains an expanded
list of available BMP guidance.
5-2 Identifying Best Mitigation Efforts or Best
Management Practices
Identifying the best BMP or group of BMPs for an activity or site can be
difficult, especially in the project’s conceptual phase. In general, a BMP
should be chosen on the basis of its ability to cost-effectively achieve
site-specific objectives.

The following factors should be considered when selecting appropriate
BMPs:
„ Watershed
„ Terrain
„ Stormwater treatment suitability
„ Physical feasibility
„ Community and environment
„ Location and permitting.1
More detail on a step-by-step screening process is provided below.
5-2.1 Form 6, Part 4—Determine Project Objectives
This part of Form 6 helps you determine whether enhanced mitigation
efforts are needed at the activity. From your answers, you can also
determine the BMP objectives. The following instructions help you
complete Part 4 of Form 6 for each priority activity. In answering the
questions in Part 4, you should review your answers to Parts 1 and 2.
„ Question 27a. Does the municipality want to reduce the amount
of pollutants entering receiving waters? At a minimum, if you
noted in Blocks 14, 15, 16, or 19 of Form 7 that the activity
discharges a pollutant of concern, answer “yes.”
„ Question 27b. Does the municipality want to reduce runoff
velocities or mimic predevelopment runoff flow volumes? At a
minimum, if you answered “yes” in Block 14, or checked “cause
erosion” or “uncontrolled storm water runoff” in Block 13 of
Form 7, answer “yes.”
„ Question 27c. Does the municipality want to improve reliability
and ease of maintenance of existing BMPs? To answer this
question, you should confer with the maintenance staff.
„ Question 27d. Does the municipality want to achieve permit
requirements (for pollutant removal or flow control)? At a
minimum, if the activity has a NPDES permit, answer “yes.”
1 This approach is based on the Center for Watershed Protection and Maryland
Department of the Environment Water Management Administration Maryland
Department of Environment’s 2000 Maryland Stormwater Design Manual Volumes I
and II available at http://www.mde.state.md.us/environment/wma/stormwatermanual/
Manual_CD/Introduction.pdf.

Select Mitigation Projects for High Priority Activities
„ Question 27e. Does the municipality want to reduce life cycle
costs of existing operations or BMPs? To answer this question,
you should confer with the activities maintenance staff for
suggested improvements.
„ Question 27f. Does the municipality want to restore natural
habitat? To answer this question, determine whether the activity
affects natural habitat and whether an opportunity exists to
restore the natural habitat on or surrounding it.
„ Question 27g. Does the municipality have other objectives?
Describe any other objectives not addressed above.
Other factors that influence project objectives include the
following:
¾ State, local, or other special considerations. Is the project
located in a part of the municipality or watershed that has
special design objectives or constraints that must be met?
Table 4-1 of the Maryland Stormwater Design Manual,
outlines BMP restrictions or additional design requirements
that should be considered if a project lies within a critical
area, a coldwater watershed, a sensitive watershed, an
aquifer protection area, a water supply reservoir, or a
shellfish or beach protection zone. (Your state may have
specific requirements that must be met; check your state’s
regulations.)
¾ Terrain. Is the project located in a portion of the state that
has particular design constraints imposed by local terrain or
underlying geology? The Maryland Stormwater Design
Manual details BMP restrictions for regions that have karst,
mountainous terrain, or low relief.
¾ Stormwater treatment suitability. Can the BMP meet
stormwater sizing criteria at the site, or is a combination of
BMPs needed? The solution should meet sizing criteria.
Designers can screen the BMP list using local sizing criteria
for volume and flow to determine whether the solution will
work.
¾ Physical feasibility. Do any physical constraints at the
project site restrict or preclude the use of a particular BMP?
In this step, designers can determine whether the soils,
water table, drainage area, slope, or head conditions
present at a particular development site might limit the use
of a BMP.

¾ Community and environment. Do the remaining BMPs have
any important community or environmental benefits or
drawbacks that might influence the selection process? The
Maryland Stormwater Design Manual contains a checklist to
compare BMP options in regard to maintenance, habitat,
community acceptance, cost, and other environmental
factors.
¾ Location and permitting. What environmental features must
be avoided or considered when locating the BMP system at
a site to fully comply with local, state, and federal
regulations? In this step, designers can use Table 4.6 of the
Maryland Stormwater Design Manual, as a checklist that
asks whether any of the following are present at the site:
wetlands, waters of the United States, stream or shoreline
buffers, floodplains, forest conservation areas, and
development infrastructure. The manual provides guidance
on how to locate BMPs to avoid impacts to sensitive
resources.
5-2.2 Factors in Developing Project Objectives
When developing objectives, you should be fully aware of the situation
for which the BMP is being considered. Municipalities start the BMP
selection process for different reasons, including the following:
„ New construction or activity. BMPs are selected to control the
estimated runoff rates or pollutant loadings as part of a site
development plan for new construction or a new activity. In
these situations, municipalities usually have longer planning
horizons and more influence in layout and BMP selection.
However, most states provide minimum design and regulatory
standards for BMPs proposed as part of new construction.
„ Retrofitting existing activities or developed areas.
¾ BMPs are selected to control known (sampled) runoff flow
rates or pollutant loadings as a retrofit to an existing single
industrial activity. Municipalities usually have shorter
planning horizons due to the compliance agreements and
less latitude in selecting BMPs due to space and operational
constraints. All states provide regulatory criteria for
controlling point source discharges from existing industrial
activities. In addition to regulating point source discharges,
some states provide regulatory criteria for controlling runoff
flows.

¾ BMPs are selected to control known (sampled) runoff flow
rates or pollutant loadings as a retrofit to an existing
multiple-use developed site (such as one containing both
industrial activities and typical urban land uses).
Municipalities usually have medium planning horizons due
to the complex nature of the solutions and more latitude in
selecting BMPs or groups of BMPs.
„ Restoring water bodies or watersheds to achieve designated
uses. BMPs are selected to achieve a waterbody’s or
watershed’s designated use, such as lowering the temperature
of a discharge to allow the receiving water body to meet
temperatures necessary for fish survival.
„ Restoring natural habitat. BMPs are selected to modify habitat
(such as in streams, wetlands, or riparian buffers) to restore
natural predevelopment conditions or mitigate the impacts on
current development conditions. Municipalities should only
implement these types of BMPs after upstream flows and
pollutant loadings are controlled.
„ Changing or creating operating and maintenance procedures
for existing assets. For example, a municipality may switch from
applying road salt to sand during winter weather conditions.
Refer to Parts 1 and 2 of Form 6 to review the impacts caused by a
specific activity.
5-3 Selecting Best Solution
Using the strategic asset management approach, BMP solutions are
evaluated on the basis of their return on investment and whether they
are achievable with municipal resources. Municipalities determine each
solution’s return on investment by calculating the change in asset
valuation—the difference between asset values based on the current
environmental burden (TABS score) and future environmental
burden—per unit cost. Municipalities then rank potential improvements
on the basis of their return on investment and municipal budgetary
constraints.
Strategic asset management and asset valuation techniques are still in
their infancy. Therefore, the Municipal Watershed Impact Assessment
Process only provides environmental burden improvement and project
costs rather than change in asset valuation. We suggest that
municipalities use the environmental burden improvement and project
costs as inputs to their strategic asset management systems to
evaluate and rank projects on the basis of return on investment and
total cost.

Use the following steps in filling out Form 6, Part 5, to select the BMPs,
determine costs, and determine sources of funds:
„ Review Exhibit 5-1, which summarizes innovative BMPs that
are low cost, low impact, low maintenance, and effective in
reducing pollutants in water bodies. Consider the site’s physical
characteristics (refer to Form 5) when selecting a BMP.
„ From your assessment, select mitigation efforts that provide the
most cost-effective impact reduction. Enter the name and a
description of the proposed mitigation effort in Block 28.
Describe the proposed BMP or control technology that can
better mitigate the activity’s impact.
„ For each mitigation project considered, calculate its planning,
design, and permitting costs, and enter the amount in Block
29a. Estimate purchase price or construction costs, and enter
the amount in Block 29b. Estimate annual OM costs, and
enter the amount in Block 29. (Appendix E contains references
for costing BMPs.)
„ Rescore the activity’s baseline score using the same scoring
approach used in Part 2 of Form 6. Estimate your answers as if
the proposed BMP was in place. Enter the new TABS in Block
30.
„ Calculate the cost-effectiveness of the project by dividing the
revised TABS score (Block 30) by the total start costs (Block
29). Enter the cost-effectiveness in Block 31. We suggest that
municipal managers use the TABS scores for the pre-BMP
condition (Block 23) and post-BMP condition (Block 30) and
total costs (Block 29) as inputs to their strategic asset
management system to evaluate projects. The project return on
investment may be determined using the TABS scores to
calculate the change in asset valuation and the project costs to
provide expense cash flows. If the municipality does not have a
strategic asset management system, the cost-effectiveness in
Block 31 may be used to rank potential projects.
„ In Block 32, note the project sheet number that contains the
detailed project description. Since Exhibit 5-1 contains just a
summary description, you need to prepare a detailed project
summary sheet or project description. (Appendix G contains a
sample project summary write-up sheet.)
„ In Block 33, enter the appropriate source of funds.
„ In Block 34, enter whether the project is eligible for other
funding sources, such as state revolving loans or grants.

5-4 What to Do if Multiple Mitigation Efforts
Are Possible
If multiple mitigation efforts are possible for a particular activity, select
the alternative that provides the greatest reduction in TABS per dollar
spent.
Exhibit 5-1. Typical BMPs and Mitigation Efforts for High Priority Activities
Typical activity Typical mitigation activities References for additional BMP data
Buildings ‚ Use low impact development
technologies
‚ Use proper erosion and sediment
controls during construction operations
‚ Install sand filters
‚ Redirect roof runoff
‚ Whole Building Design Guide for
environmentally sound site layout at
http://www.wbdg.org/index.asp
‚ EPA’s Watershed Academy Module
on Land Development at
http://www.epa.gov/watertrain/ -
management
‚ The Stormwater Manager’s Resource
Center at
http://www.stormwatercenter.net/
‚ Low Impact Development Center at
http://lowimpactdevelopment.org/
links.htm - bmp_gen
Construction and
other ground-disturbing
activities
‚ Control erosion—stabilizing exposed
soils prevents storm water run-on and
runoff (use geotextile materials where
appropriate to prevent erosion)
‚ Use dry detention basins
‚ Cover excavated soils
‚ Remove contaminated soils and dispose
of properly
‚ NRCS Planning and Design Manual
for the Control of Erosion, Sediment,
and Stormwater at
http://abe.msstate.edu/csd/p-dm/
index.html
Dams, culverts, or
dredging
‚ Regularly check effectiveness of dams
and culverts
‚ Ensure proper placement of fill activities
for dredging
Center at
Deicing material
application
‚ Reduce use or replace with
environmentally friendly materials
‚ Collect and reuse materials (such as in
aircraft deicing)
‚ DoD Joint Services P2 Library at
http://p2library.nfesc.navy.mil/
Fact_Sheets/DSDATA/sortbysection.
html#10
‚ NASA water pollution control at
http://www.wff.nasa.gov/~code205/
Services/Water Pollution/water_
pollution_control.htm
‚ New Hampshire Department for
Environmental Services at
http://www.des.state.nh.us/wmb.htm

Exhibit 5-1. Typical BMPs and Mitigation Efforts for High Priority Activities (Continued)
Drainage wells and
canals
‚ Construct vegetative strip and filters to
catch sediment before it reaches the
infiltration device
‚ Perform required maintenance and
cleaning, primarily to prevent clogging
‚ EPA’s general BMPs at
http://www.epa.gov/seahome/inject/src/
gbest.htm
Fixed-wing and
rotary-wing aircraft
maintenance
activities
‚ Use separate containers for disposal
of wastes
‚ Recycle scrap metal
‚ Dispose of degreasing and other
solvent materials properly
‚ Store containers on an impervious
surface and properly cover against
weather
‚ Provide equipment training
‚ NASA Water Pollution Control at
http://www.wff.nasa.gov/~code205/
Services/Water Pollution/water_
pollution_control.htm
‚ Aerospace Industry Notebook at
http://www.epa.gov/compliance/
resources/publications/assistance/
sectors/notebooks/aerospace.html
http://p2library.nfesc.navy.mil/index.htm
Fueling stations and
operations
‚ Connect drains from vehicle washing
areas to the municipal sewer or
sanitary sewer system
‚ Provide temporary protection of storm
drains (temporary placement of
absorbent material, storm drain
covers, or shutoff valves)
‚ Equip fueling equipment with
automatic shutoff nozzles
‚ Discourage topping off and unattended
fueling
‚ Install oil-water separators or sand
filters
‚ EPA BMP Database at
http://www.bmpdatabase.org/
Center at
‚ Maryland Stormwater Management
Program at http://www.mde.state.md.us/
environment/wma/stormwatermanual/
http://www.epa.gov/seahome/inject/
src/gbest.htm
Motor pools and
vehicle maintenance
centers
‚ Park tank trucks or delivery vehicles
away from unprotected storm drains
and manholes or provide temporary
protection
‚ Install sand filters, oil-water separators,
or other BMPs that treat the runoff
‚ Perform maintenance inside or in an
outside area where spills cannot enter
storm drains
‚ EPA Solutions to Pollution at
http://www.epa.nsw.gov.au/
small_business/autoservicing.htm
NPDES-permitted
industrial point
source discharges
‚ Participate in basinwide management
plans that allow tradeoffs for maximum
ecological and economic benefits
(Great Lakes and Chesapeake Bay
programs are examples of major
holistic plans)
‚ Involve community, schools, and other
citizens in water sampling
‚ EPA Industrial Activities at
http://www.cfpub.epa.gov/npdes/
stormwater/indust.cfm
‚ EPA BMP database at
http://www.bmpdatabase.org/
Non-permitted
mobile sources
‚ Establish shared and alternative
transportation programs to reduce air
emissions, traffic congestion, and
conserve energy
‚ Increase use of parking spaces and
pedestrian crossings
‚ Air Pollution Prevention (P2) Guide at
https://www.denix.osd.mil/denix/DOD/
Library/Air/Airmgt/aqtoc.html

NPDES storm water
discharges
‚ Implement stormwater BMPS,
including bioengineered and low
impact development approaches that
combine hydrologically functional site
designs with pollution prevention
measures to reduce negative impacts
on hydrology and water quality. (Low
impact development projects apply a
“natural remedy” to prevent potential
problems, thereby reducing high costs
of some conventional types of
construction techniques)
‚ EPA’s Office of Wastewater’s Storm
Water BMP Fact Sheets at
stormwater/menuofbmps.cfm
‚ State of Maryland Storm Water BMP
Design Manual at
http://www.mde.state.md.us/
environment/wma/stormwatermanual/
index.html
‚ EPA Industrial Activities at
stormwater/indust.cfm
‚ Planning and Design Manual for the
Control of Erosion, Sediment, and
Stormwater at
http://abe.msstate.edu/csd/ p-dm/
index.html
Paved roads,
parking lots,
railroads, curbs, and
sidewalks
‚ Use low impact development
technologies
‚ Replace impervious materials with
pervious materials (such as permeable
pavers or pavement)
‚ Install sand filters to treat stormwater
runoff from large buildings, access
roads, and parking lots
‚ Eliminate curbs
‚ Treat runoff in vegetated swales
‚ Increase pervious areas—replace
shoulder area with pervious materials
such as gravel
Center at
Permitted stationary
sources
‚ Implement air pollutant control BMPs ‚ Air Pollution Prevention (P2) Guide
https://www.denix.osd.mil/denix/DOD/
Library/Air/Airmgt/aqtoc.html

Septic systems or
Class V wells
‚ Recycle and reuse wastewater
‚ Collect and recycle petroleum-based
fluids, coolants, and battery acids
drained from vehicles
‚ Wash parts in self-contained,
recirculating solvent sink, with spent
solvents being recovered and replaced
by the supplier
‚ Use absorbents to clean up minor
leaks and spills and place used
materials in approved waste
containers, disposing of them properly
‚ Use a wet vacuum or mop to pick up
accumulated rain or snow melt
‚ Regularly pump, inspect, and maintain
wells
‚ Connect floor drains to permitted
publicly owned wastewater treatment
plant
‚ Replace with advanced treatment
technologies or hook up to POTW
‚ EPA at http://www.epa.gov/safewater/uic/
classv.html
‚ Minnesota's Individual Treatment
Systems Program at
http://www.pca.state.mn.us
programs/lsts/index.html
‚ EPA BMPs Class V wells at
src/best.htm
‚ Rhode Island Checkup at
http://www.state.ri.us/dem/pubs/regs/
regs/water/isdsbook.pdf
Unpaved and
service roads
‚ Keep vegetative cover
‚ Conduct scheduled maintenance of
grounds
‚ Use environmentally friendly low-water
crossing designs
‚ EPA’s Recommended Practices Manual:
A Guideline for Maintenance and Service
of Unpaved Roads at
http://www.epa.gov/owow/nps/
unpavedroads.html
‚ Road Management Engineering
Journal at
http://www.usroads.com/journals/rmej/
9806/rm980604.htm
‚ Seneca Mineral at
http://www.senecamineral.com/
dustcontrolproducts.htm
‚ Corps of Engineers Construction
Engineering Research Laboratory Soil
and Erosion Control at
http://www.cecer.army.mil/td/tips/
products/details.dfm?ID=489TOP=1
Underground
storage tank (UST)
leaks
‚ Meet UST requirements—certify that
tanks and piping are installed properly
according to industry codes; install
devices that prevent spills and
overfills; protect tanks and piping from
corrosion; and install leak detection
systems
http://p2library.nfesc.navy.mil/ index.htm

Water supply or
ground water
withdrawal wells
treatment
‚ Consider the effects of the cone of
depression on adjacent users and
uses
‚ Consider the downstream effects of
the pumped water and soil salinity
‚ Implement water conservation efforts,
including facility and grounds areas
‚ U.S. Army Source Water Protection
Guide at http://water.usgs.gov/usaec/
src/gbest.htm

THIS PAGE

Chapter 6
Develop Project
Partnerships
6-1 Introduction
Many municipalities are short staffed and have too many initiatives and
too little funding. Developing partnerships can help you accomplish your
projects cost-effectively. Municipalities can partner with regulators, other
municipalities, federal agencies, state and local governments, and
citizen groups to accomplish various environmental objectives, share
resources, access expertise, and resolve regulatory issues. In addition,
public works offices can partner with other municipal offices, such as
emergency management, to accomplish complex or integrated projects.
6-2 Why Form Partnerships?
A partnership is the easiest way to develop and implement successful
projects because everyone is involved from the onset. This upfront
involvement means the ultimate plan will truly have the consensus of all
parties with a stake in the watershed and assets. In general, forming
partnerships with others can help do the following:
ƒ Lower project costs. If other parties are already involved in the
project, you can reduce the time it takes for approvals, improve
logistical support, and obtain volunteer labor or technical
assistance. Saving time also means saving money.
ƒ Build good community relations. Partners relay their positive
experiences to others within the community.
ƒ Build advocates for your program. Other municipal offices or the
public can be powerful advocates for change if involved from the
beginning of projects.

ƒ Obtain additional funds (subject to county and state fiscal legal
restraints). Other offices, federal agencies, state and local
governments, local businesses, or citizen groups may be
interested in sharing costs on projects.
ƒ Receive grants and awards. EPA, state agencies, and other
organizations offer grants and awards to help promote watershed
management.
ƒ Coordinate volunteers to conduct monitoring, stream cleanup,
and stream or watershed restoration days.
ƒ Provide technical expertise for demonstration projects.
ƒ Coordinate and conduct field trips and tours.
ƒ Establish and run meetings and workshops.
ƒ Develop focus groups.
ƒ Conduct opinion surveys.
ƒ Provide media relations.
ƒ Support and develop educational programs for schools, civic
groups, and other local organizations.
Partnerships can be challenging: it takes time and skill to create
successful ones. Maintaining motivation and enthusiasm is another
challenge, especially if positive results do not happen quickly. All
relevant stakeholders must believe their efforts are necessary. As you
build partnerships, you will encounter these and other challenges. Keep
in mind, however, that the benefits of partnerships usually far outweigh
the challenges.
6-3 What Are the Steps?
There are some basic steps in forming and building partnerships:
ƒ Identify opportunities that lend themselves to partnering.
ƒ Identify potential partners.
ƒ Develop partnerships.
ƒ Collaborate to implement the projects.
ƒ Share success and praise with outside stakeholders.

Develop Project Partnerships
6-3.1 Identify Opportunities
The first step is to identify opportunities for partnering. By completing the
forms, you have already identified activities and solutions that could
benefit from partners.
6-3.2 Identify Potential Partners
Ways to identify potential project partners vary. For example, EPA and a
variety of non-governmental organizations have developed a catalog of
organizations involved in protecting local waterbodies, including
government agencies, formal watershed alliances, national groups, local
groups, and schools that conduct activities such as volunteer
monitoring, cleanups, and restoration projects.
In addition, many websites offer access to organizations that can assist
your efforts:
ƒ EPA hosts a Catalogue of Watershed Groups website at
http://www.epa.gov/adopt/network.html. This website contains
the
¾ group name and Internet site (if available);
¾ contact name, address, e-mail address, and phone number;
¾ watershed and locations of interest;
¾ description of activities; and
¾ number of volunteers.
ƒ EPA hosts the River Corridors and Wetlands Restoration
(RCWR) Partnership, at http://www.epa.gov/owow/wetlands/
restore/rpart.htm. The RCWR partnership is an ad hoc team
consisting of public agencies and private organizations that
engage in wetland and watershed restoration efforts, share
information, and find opportunities for collaboration. The team
promotes and supports community-based projects that improve
the quality of life of the community and the health of its
watersheds. EPA recognizes that restoration efforts require a
team approach and welcomes any national organization with
similar interests to join the RCWR partnership.
You can use Exhibit 6-1 as a template for tracking potential regional
partners (refer to http://www.epa.gov/win/contacts.html). You can use
Form 2, Block 8, if you want to track potential partners at a project-specific
level.

Exhibit 6-1. Regional Partnering Template
Project Partnering Opportunity Template
Project title: Project description:
Municipal project lead office
Municipal project lead office: Contact phone:
Point of contact name: Contact e-mail:
List potential regulatory agency, citizen group, other partners
Organization name: Point of contact:
Contact
phone/
e-mail:
POC
address: Potential role in project:

6-3.3 Develop Partnerships
Successful partnerships should include the following key elements:
ƒ Clear communication of objectives and identification of
opportunities for shared interests in project write-ups and
execution.
ƒ Establishment of clear roles and responsibilities.
ƒ A written agreement between partners.
For detailed guidance on building local partnerships, review Building
Local Partnerships: A Guide for Watershed Partnerships at the Know
Your Watershed website of the Conservation Technology Information
Center at www.ctic.purdue.edu/KYW/Brochures/BuildingLocal.html.
6-3.4 Collaborate to Implement Projects
The next step is to collaborate with the identified partners to implement
projects.
6-3.5 Share Success and Praise with Outside Stakeholders
The last step is to share the success of the partnership effort and project
success with outside stakeholders.
6-4 Working with Other Municipalities
Just as important as forming partnerships with citizen groups, is the
formation of a good working relationship with other municipalities. You
can work with other municipalities to obtain technical assistance,
establish standard approaches, and share resources.
Summary
You can and
should participate
in the TMDL
determination
process. Your
completed forms
provide all the
necessary
information for the
TMDL
determination
process.
6-5 Working with Regulators
You can work with your state and local regulators to determine
appropriate TMDLs and establish and participate in an effluent trading
program.
6-5.1 Working with Regulators During TMDL Determinations
Municipalities may have the opportunity to work with EPA and state
regulatory officials during the state TMDL determination process. A
TMDL provides the water quality analysis and planning process for
determining the specific pollution reductions necessary to attain or
maintain water quality standards. The TMDL process includes legal
requirements for public participation and implementation through
NPDES permits.

By working with regulators during the TMDL determination process, you
may have the opportunity to negotiate a tradeoff between reduced
NPDES point source permit limits with changes in land management or
non-point source management practices. Therefore, you can and should
participate in the TMDL determination process. Your completed forms
provide all the necessary information for the TMDL determination
process.
6-5.2 Working with Regulators to Establish Effluent Trading
Since the early 1990s, EPA has been promoting the use of effluent
trading to achieve water quality objectives and standards within
watersheds. EPA issued a Final Water Quality Trading Policy in 2003,1
which encourages states, interstate agencies, and tribes to develop and
implement water quality trading programs for nutrients, sediments, and
other pollutants where opportunities exist to achieve water quality
improvements at reduced costs. More specifically, the policy
encourages voluntary trading programs that facilitate implementation of
TMDLs, reduce the costs of compliance with CWA regulations, establish
incentives for voluntary reductions, and promote watershed-based
initiatives. A number of states are in various stages of developing
trading programs.
To take advantage of trading, you must have a point source that is in
compliance and remains in compliance with applicable technology-based
limits. Intra-plant trades must also have a technology-based floor,
while the technology floor for pretreatment trading is determined by the
categorical standards. EPA expects that most trades will be covered by
TMDL or similar watershed-based analysis.
The items you can trade are the pollutant reductions or water quality
improvements. Under trading, a source that can more cost-effectively
achieve greater pollutant reduction than is otherwise required would be
able to sell or barter the credits for its excess reduction to another
source unable to reduce its own pollutants as cheaply. To ensure that
water quality standards are met throughout a watershed, an equivalent
or better water pollutant reduction would need to result from a trade.
EPA’s implementation framework for effluent trading under the TMDL
program is a companion to its effluent trading policy. It encourages
trading and assists in evaluating and designing trading programs. The
framework provides the following:
ƒ Background information on effluent trading and its benefits.
ƒ The conditions necessary for trading, including those that ensure
protection of water quality comparable to the protection that
would be provided without trading.
1 The Final Water Quality Trading Policy can be downloaded from the EPA website
at http://www.epa.gov/owow/watershed/trading/tradingpolicy.html.

ƒ A template of regulatory, economic, data, technical, scientific,
administrative, accountability, and enforcement issues that
facilitate identification and evaluation of trading opportunities.
ƒ Worksheets and checklists to evaluate whether potential trades
meet threshold conditions.
You can download a copy of this framework from the EPA’s website at
http://www.epa.gov/owow/watershed/trading.htm.

THIS PAGE

Chapter 7
Implement
Solutions and
Track Progress
The last phase of the watershed assessment process includes
implementing the identified solutions, tracking their progress, and
updating your projects as required. Implementation is the “doing” stage,
a critical component of watershed restoration. It brings together all of the
activities necessary to reach your watershed restoration goals and puts
them to work.
Tip
Review your plan
at least annually
to reassess and
reprioritize your
projects.
7-1 Planning and Budgeting for
High Priority Projects
To implement watershed restoration projects and activities, you must
budget the funds needed to obtain equipment, provide training, perform
services, and conduct specific projects under the plan. Your watershed
assessment plan should cover at least 8 years. However, the plan will
be implemented based on the priority of projects and initiatives identified
as well as the funds available for implementation. Therefore, you should
review and update your plan at least annually to reassess and
reprioritize projects.
7-1.1 Estimating and Submitting Project Costs
For every project you want to implement (regardless of its funding
source), you need to develop a cost estimate for budgeting and
requesting funds. Appendix E contains a description of potential BMP
websites, which cover associated unit cost factors for some projects.
7-1.2 Integrate Project in Municipal Budget
The next step in implementation is incorporating your projects into the
municipal budget as part of strategic asset management. Selecting
projects for funding is largely a subjective process, with tight budgetary
limits, and often influenced by politics. Municipalities may use return on
investment and total costs to select watershed restoration projects as
part of their infrastructure budget. However, developing an infrastructure
budget is not an exact science. Exhibit 1-3 shows an assessment of the

budgeting attractiveness of infrastructure investments on the basis of
return on investment and total cost.
7-1.3 Identify Available Funding Sources
Municipalities can implement desirable projects that are not included in
the budget by identifying and developing partnerships with other
stakeholders. Form 6 allows you to list partners, agreements, benefits,
addresses, and points of contact for tracking purposes. This guide
provides links to groups active in each watershed around the country as
well as types of groups that may provide assistance and support.
Chapter 6 has a partnership template for tracking regional and project
partners.
7-1.4 Update Zoning and Ordinance Requirements
Municipalities will need to evaluate and potentially update zoning and
ordinance requirements to implement some watershed restoration
projects.
7-2 Sources of Funds for Identified Projects
The funds you need to accomplish the projects you have identified can
come from four sources: municipal budget funds, other municipal
funding sources, partnerships, and outside sources (including federal
funding).
The following publications are other sources of funding information
related to wetlands and watersheds:
ƒ Catalog of Federal Funding Sources for Watershed Protection:
Second Edition. The catalog (EPA841-B-97-008) includes
funding source descriptions and department and agency statute
and title indexes. It is available on the EPA’s Watershed
Academy website at http://www.epa.gov/OWOW/watershed/
wacademy/fund.html. The website also offers online education
and training for a wide range of issues related to watersheds.
ƒ EPA’s Watershed Information Network’s (WIN) List of Federal
Catalogs of Financial Assistance. This website contains links to
over 20 different references. It is available through the WIN
website at http://yosemite.epa.gov/water/surfah.nsf/ financial?
OpenViewStart=1Count=30Expand=1 - 1.
ƒ Funding for Habitat Restoration Projects: A Compendium of
Current Federal Programs with Fiscal Year 1996–1999 Funding
Levels: A Citizens Guide. Updated versions are available at
http://www.estuaries.org/funding.html. The listings include the
type of support, authorities, funding levels, activities, and
eligibility requirements.

Implement Solutions and Track Progress
ƒ River Restoration and Community Revitalization: A Digest of
Select Federal Programs for Rivers. This digest is published by
American Rivers, Inc., and is available through their website at
http://www.amrivers.org, or by e-mailing them at
amrivers@amrivers.org. The booklet includes descriptions and
contact information for select federal programs that involve river
restoration (directly or indirectly). It features case studies for
cities currently engaged in funded projects.
ƒ An Introduction to Wetland Restoration, Creation, and
Enhancement. This document was developed by the Interagency
Workgroup on Wetland Restoration, which includes EPA,
National Oceanic and Atmospheric Administration, Army Corps
of Engineers, Fish and Wildlife Service, and Natural Resources
Conservation Service. The guide includes technical resources,
contacts, and funding sources. The document is available at
http://www.epa.gov/owow/wetlands/restdocfinal.pdf.
7-3 Obligating Funds, Developing Scopes of Work,
and Letting Contracts
The following steps summarize the process of obligating funds through
an existing mechanism:
ƒ Step 1: Identify a potential mechanism for obligating funds.
This can include an existing contract or cooperative agreement.
You should have a copy and understand its provisions fully.
ƒ Step 2: Understand all relevant review and approval
procedures. For example, approval for a project may require a
series of reviews through the municipal organization.
ƒ Step 3: Notify your accounting and finance office. Once a
project has been approved for funding, the accounting and
finance office requires advance notice of your intention to
obligate funds. You must obtain certification of funds available
before you can contract for services or obligate funds. Note
where funds will be transferred from other offices to the
installation.
ƒ Step 4: Prepare a statement of work (SOW). The SOW
describes the types of work to be performed and materials to be
used or submitted. It should identify the point of contact within
the military and contractor's organization and should specify the
period of performance and specific deliverables. You may want
to obtain and review good models or examples of other SOWs
from your contracting office that have been prepared for the type
of project you are considering.

ƒ Step 5: Verify that funds are available. Ensure that the
accounting and finance office has control of the funds you plan to
obligate.
ƒ Step 6: Submit the form to transfer funds for obligation.
Obtain the appropriate form from your accounting and finance
office that will formally commit funds obligated by contract.
Funds are not obligated until the receiving organization acknowledges
receipt of the funding document. Again, you should ensure that the legal
office and contracting office guide you through this process. You should
anticipate that the obligation of funds may require 6 weeks or more from
the time funds are certified and the contracting office gets an acceptable
SOW.
Summary
Tracking and
monitoring your
watershed
assessment plan’s
efforts are central
to maintaining
accountability,
documenting what
you have done,
and
demonstrating
that your efforts
have been
thoughtful and
responsible.
When a suitable contracting mechanism is unavailable, you may want to
consider a source selection process to obtain the services of a
contractor. Keep in mind that this is a complex and time-consuming
process, which can take 6 months or more to complete. Should you
choose this avenue, we strongly advise against third-party contracting or
other arrangements that create distance between you and the
contractor.
Remember, when managing government funds, only certain individuals
have the authority to obligate funds. The contractor cannot begin work
until contracts have been finalized and funds are obligated. If you are
the point of contact or project manager for the government, you are
responsible for monitoring the contractor's technical progress. You
should ensure that you have obtained all necessary training and
guidance required to perform this role.
7-4 Produce Summary Reports to Track Projects
A final consideration when implementing your watershed restoration
projects is measuring success, reporting, and sharing information.
Tracking and monitoring progress toward watershed goals and
objectives also allows you to adapt to feedback from monitoring efforts
and reprioritize projects, if necessary. These types of efforts are central
to maintaining accountability, documenting what you have done, and
demonstrating that your efforts have been thoughtful and responsible.

7-5 Maintaining and Updating Your Watershed
Restoration Projects
management. Optimizing environmental condition and asset valuation is
not a one-time event; municipalities should continually evaluate
watershed conditions and potential watershed restoration projects to
maximize asset value. At a minimum, municipalities should conduct this
Municipal Watershed Impact Assessment Process annually to prioritize,
budget, and reallocate priorities as necessary.
Tip
An updated list of
priorities has the
following
benefits:
■ Newly elected
officials,
managers,
staff, and
others can
quickly assess
the status of
environmental
compliance
and the asset
management
program.
■ It links to the
planning and
budget
processes.
■ It helps in
monitoring
successes and
failures.
Evaluating your management actions and using monitoring information
to readjust project priorities and initiatives is proactive management;
proactive management is integral to watershed and strategic asset
management and is the reason for inherent flexibility in implementing
this process. Most goals and objectives may be relatively set, but how
and when you achieve them are subject to many internal and external
forces. Keeping an updated list of watershed restoration project priorities
helps newly elected officials, managers, staff, and others quickly assess
the status of environmental compliance and the asset management
program. An updated priority list also feeds directly into the planning and
budgeting processes and helps identify successes as well as failures.
Use the information from your tracking and monitoring data to determine
what needs to be updated and reprioritized. Monitoring data may
indicate that some initiatives need to be reallocated to subsequent
funding years, placed on accelerated schedules, or shelved indefinitely.
External issues—such as increases in development, reprogramming of
funds, or new compliance requirements—may also require you to
reprioritize projects and adjust your budget requests. A review of
monitoring data may also indicate that a particular objective has not yet
been met and that follow-on steps should not be initiated as originally
scheduled in the plan. Even climate or weather conditions can adversely
affect project and initiative implementation

THIS PAGE

Appendix A
Abbreviations
ABIS activity baseline impact score
AIS activity impact score
ASAP Army Sampling and Analysis Plan for Small Arms Ranges
AST above ground storage tank
BMP best management practice
BOD biological oxygen demand
CAA clean air act
CERCLA Comprehensive Environmental Restoration, Compensation and
Liability Act
COD chemical oxygen demand
CWA clean water act
CWAP clean water action plan
CZA Coastal Zone Act
DoI Department of Interior
CZMA Coastal Zone Management Act
ECMP erosion control management plan
EMS environmental management system
EO executive order
EPA Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
ESA Endangered Species Act
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
GIS geographic information system
GMP grounds management plan
HUC Hydrological Unit Code
ID identification
LID low-impact development
MNS mission need score
MOU memorandum of understanding
NASA National Aeronautics and Space Administration
NCA Noise Control Act
NEPA National Environmental Policy Act
NHD national hydrography dataset
NHPA National Historic Preservation Act
NMFS National Marine Fisheries Service
Watershed Impact Assessment Guidance for Public Lands and Facilities A-1

NPDES National Pollutant Discharge Elimination System
NPS nonpoint source or National Park Service
OM operation and maintenance
P2 pollution prevention
POL petroleum, oil, and lubricant
RCRA Resource Conservation and Recovery Act
RCWR River Corridors and Wetlands Restoration
SDWA Safe Drinking Water Act
SOx sulfur oxides
SPCC spill prevention, control and countermeasures
SVOC semivolatile organic chemical
SW stormwater
SWAP source water assessment and protection
TABS total activity burden score
TMDL total maximum daily load
TRI toxic release inventory
TSCA Toxic Substances Control Act
TSS total suspended solids
UIC underground injection control
USFWS United States Fish and Wildlife Service
UST underground storage tank
UWA Unified Watershed Assessment
VOC volatile organic compound
WATER Watershed Assessment, Tracking Environmental Result
WPS watershed priority score
WSS watershed sensitivity score
A-2 Watershed Impact Assessment Guidance for Public Lands and Facilities

Appendix B
Laws Affecting
Watershed Management
This appendix provides a summary (and links to additional information)
of key federal laws governing water resources (http://www.epa.gov/
win/law.html) in the United States that provide the basis for watershed
protection activities, as well as information that can be used for
protecting a watershed. For each item, we provide a summary of the
legislation, its impact or relationship with watershed planning, and links
to additional information.
Clean Water Act
The Federal Water Pollution Control Act, or Clean Water Act (CWA) (full
text can be located at http://www.epa.gov/win/law.html), is the principal
law governing pollution in the nation’s streams, lakes, and estuaries.
Originally enacted in 1948, it was totally revised by amendments in 1972
(P.L. 92-500) that gave the act its current form and spelled out ambitious
programs for water quality improvements that are now being put in place
by industries and cities. Congress made certain fine-tuning amendments
in 1977 (P.L. 95-217) and 1981 (P.L. 97-117).
The CWA prohibits the discharge of any pollutant to waters of the United
States from a point source unless the discharge is authorized by a
National Pollutant Discharge Elimination System (NPDES) permit. The
NPDES permitting program is designed to track point sources, monitor
the discharge of pollutants from specific sources to surface waters, and
require the implementation of the controls necessary to minimize the
discharge of pollutants.
Initial efforts to improve water quality under the NPDES program
primarily focused on reducing pollutants in industrial process wastewater
and discharges from municipal sewage treatment plants.
As pollution control measures for managing these sources were
implemented and refined, studies showed that more diffuse sources of
water pollution were also significant causes of water quality impairment,
specifically, stormwater runoff draining large surface areas, such as
agricultural and urban land. This fact led the EPA to adopt a watershed
approach that is based on determining the total maximum daily load
(TMDL) of a particular pollutant that a waterbody can accept and still
meet its water quality standards.
Watershed Impact Assessment Guidance for Public Lands and Facilities B-1

The Basis for Watershed Management Efforts—Water Quality
Standards and Total Maximum Daily Loads
EPA’s TMDL program is the main driver behind the adoption of
watershed approaches to managing water issues. Under CWA Section
303(d), states are required to identify waters that do not meet water
quality standards—even after the implementation of nationally required
levels of pollution control technology. The law further requires states to
develop TMDLs (with oversight from Environmental Protection Agency
(EPA)) and establish a priority ranking for the identified impaired waters.
These TMDLs allocate pollutant loadings among pollution sources in a
watershed and provide a basis for identifying and establishing controls
to reduce both point source and nonpoint source (NPS) pollutant
loadings.
Water quality standards are a fundamental component of the CWA and,
specifically, watershed management. These standards are adopted by
states and tribes to protect public health; restore chemical, physical, and
biological integrity of waters; and provide water quality for the protection
and propagation of fish and wildlife and for recreation
(“fishable/swimmable”). Standards consider the use and value of state
and tribal waters for public water supplies, agricultural and industrial
purposes, and navigation. Water quality standards depend on the
designated uses of the water body and are based on water quality
criteria established by EPA.
State TMDL programs are required to use all “existing and readily
available” information in developing Section 303(d) lists. This information
may include source water assessments and endangered species act
information. For example, since TMDLs are developed for specific
pollutants or stressors, identification of these pollutants as a result of a
source water assessment could provide an important indicator to states for
verifying the need for developing a TMDL. States prepare section 303(d)
lists that identify waters not meeting water quality standards because of a
particular pollutant or stressor. This type of information is helpful for
identifying contaminants of concern for watersheds and source waters
(refer to EPA’s website—http://www.epa.gov/owow/tmdl/—for 303(d) lists,
by state, of impaired waters). TMDLs for particular water bodies generally
provide more detailed information about the sources of the pollution and
can be used to develop allocation scenarios for pollutant loadings among
pollution sources in a watershed.
State TMDL programs are generally managed by state water quality
agencies. At the local level, a variety of stakeholders may be involved
including local and regional governing agencies, point sources, farmers,
foresters, land developers, city and state planners, and local
environmental organizations. For the latest status on the federal TMDL
program, visit EPA’s homepage—http://www.epa.gov/owow/tmdl/
index.html.
B-2 Watershed Impact Assessment Guidance for Public Lands and Facilities

Laws Affecting Watershed Management
Managing Stormwater Discharges Through NPDES Permits
The 1987 amendments to the CWA mandated that EPA develop a tiered
implementation strategy for the NPDES Stormwater Program. The
second phase of the strategy was the Final Stormwater Phase II Rule,
which was signed by Administrator Browner on October 29, 1999, and
published in the Federal Register on December 8, 1999. The rule
regulates two classes of storm water dischargers on a nationwide basis:
ƒ Operators of small MS4s located in urbanized areas as defined
by the Bureau of the Census (termed a “regulated” small MS4). A
“small” MS4 is any MS4 not already covered by Phase I of the
NPDES stormwater program. Waivers from coverage are
available.
ƒ Operators of construction activities that disturb equal to or more
than one and less than five acres of land. Waivers from coverage
are available.
Additional small MS4s (outside of urbanized areas) and construction sites
(disturbing less than one acre of land), along with other sources that are
significant contributors of pollutants to U.S. waters (e.g., as identified via a
TMDL process), may be brought into the NPDES Stormwater Program by
the NPDES permitting authority.
Operators of Phase II regulated small MS4s and small construction
activities are required to apply for NPDES permit coverage (most under
a general rather than an individual permit) and implement stormwater
discharge management controls (often referred to best management
practices (BMPs)) that effectively reduce or prevent the discharge of
pollutants into receiving waters.
The Phase II rule also revised the Phase I stormwater regulation.
Specifically, EPA revised the original no exposure provision, found at 40
Code of Federal Regulations (CFR) 122.26(b)(14), to be a conditional
exclusion. This conditional exclusion applies to all categories of
industrial activity (except construction activity) with no exposure of
industrial materials and activities to storm water. The Phase II revision,
found at Section 122.26(g), requires industrial operators claiming no
exposure to submit written certification that a condition of no exposure
exists at their facility/site. The final rule includes a No Exposure
Certification Form that is intended to serve as the required written
certification in areas where EPA is the NPDES permitting authority. For
more information concerning the no exposure revision, see the
Stormwater Phase II Rule: Conditional No Exposure Exclusion for
Industrial Activity fact sheet located on the EPA web site at
(cfpub.epa.gov/npdes/stormwater/ swphases.cfm), or call EPA’s
Stormwater Phase II Rule Hotline at (202) 260-5816, or send an e-mail
to sw2@epa.gov.

Nonpoint Source Controls
Section 319 of the CWA delegates the regulation of NPS pollution to the
states and establishes the Nonpoint Source Management Program. EPA
recognized the need for greater federal leadership to help focus state
and local NPS efforts. Under Section 319 of the 1987 CWA
amendments, states are:
ƒ required to conduct statewide assessments of their waters to
identify those that were either impaired (did not fully support
state water quality standards) or threatened (presently meet
water quality standards but are likely not to continue to meet
water quality standards fully) because of NPS pollution;
ƒ required to develop NPS management programs to address the
impaired or threatened waters identified in their nonpoint
assessments; and
ƒ entitled to receive annual grants from EPA to assist them in
implementing their NPS management programs once EPA had
approved the assessments and programs.
Although Section 319 does not include an enforcement mechanism to
ensure that states actually develop and implement programs, CWA
Section 303 requires that states identify all activities that cause a
waterbody to be impaired—including NPSs—and develop mitigation
plans. This provision enables the states to regulate the runoff from
NPSs of pollution. These requirements are explained in the Proposed
Federal Consistency Guidelines, which can be downloaded from the
EPA website at http://www.epa.gov/owow/nps/Section319/
319guide03.html.
State NPS pollution control programs vary considerably. Most states
encourage landowners to adopt voluntary NPS control methods. Some
states, including North Carolina, New Jersey, Hawaii, and Washington,
require consideration of NPSs through detailed erosion control plans
and implementation of BMPs for ground-disturbing activities. North
Carolina, for example, requires erosion control plans 30 days before any
land-disturbing activities are started. Other states have empowered local
jurisdictions to create and enforce their own erosion control measures.
Wetlands Program
Section 404 of the CWA, which is administered by the U.S. Army Corps
of Engineers, establishes a program to regulate the discharge of
dredged or fill material into U.S. waters. While the Section 404 program
regulates the discharge of dredged or fill material on a case-by-case
basis, provisions found within this authority can allow for the regulation
of aquatic resources in a more comprehensive manner. Some examples
include watershed planning, special area management planning, and
advanced identification.

EPA’s wetlands program attempts to integrate wetlands protection into
existing EPA programs (e.g., CWA). In addition, some states have
developed or are developing State Wetlands Conservation Plans to
provide a framework for integrating wetland programs across many state
programs. EPA’s wetlands program has experience in providing
assistance for the development of comprehensive wetlands plans,
participating in efforts to develop such plans, and reviewing plans for
other state and local programs.
Wetland protection programs often need to assess the overall health of
watershed ecosystems in order to estimate the impacts of proposed
man-made changes. Assessments undertaken by federal, state, and
local governments for protecting wetlands can provide information that
may be useful for watershed assessments.
Wetlands can provide a wide range of different functions and benefits to
local communities, including the interception and filtration of pollutants,
thereby improving source water quality and possibly reducing treatment
costs. Constructed wetlands can improve source water quality for
downstream rivers. Integrating wetlands protection and restoration into
watershed programs can highlight the importance of targeting wetlands
as high priority areas for protection and can reduce duplication of efforts
and conflicting actions.
More information is available at http://www.epa.gov/owow/wetlands/.
Spill Prevention, Control, and Countermeasure Requirements
The CWA also includes provisions to prevent spills of certain
substances from reaching navigable waters. Section 311 of the CWA
provides EPA and the U.S. Coast Guard with the authority to establish a
program for preventing, preparing for, and responding to oil spills that
occur in navigable waters of the United States. EPA implements
provisions of Section 311 of the CWA through a variety of regulations,
including the National Contingency Plan and the Oil Pollution Prevention
regulations.
As a cornerstone of its strategy to prevent oil spills from reaching our
nation’s waters, the EPA requires that certain facilities develop and
implement oil spill prevention, control, and countermeasures (SPCC)
plans. Unlike oil spill contingency plans that typically address spill
cleanup measures after a spill has occurred, the goal of an SPCC plan
is to ensure that facilities put in place containment and other
countermeasures to prevent oil spills from reaching navigable waters.
Under EPA’s Oil Pollution Prevention regulation, facilities must detail
and implement spill prevention and control measures in their SPCC
plans. A spill contingency plan is required as part of the SPCC plan if a
facility is unable to provide secondary containment (e.g., berms
surrounding the oil storage tank). These plans are an essential element
of a watershed impact analysis and a source water impact analysis

because they list the types, quantities, and spill controls for oils and
hazardous substances stored at municipal facilities.
Spills are also regulated under the Oil Pollution Act (OPA). The OPA
was signed into law in August 1990, largely in response to rising public
concern following the Exxon Valdez incident. The OPA increased
penalties for regulatory noncompliance, broadened the response and
enforcement authorities of the federal government, and preserved state
authority to establish laws governing oil spill prevention and response.
Safe Drinking Water Act
Section 1453 of the Safe Drinking Water Act (SDWA), as amended in
1996, requires all states to complete assessments of their public
drinking water supplies. By 2003, each state and participating tribe will
delineate the boundaries of areas in the state (or on tribal lands) that
supply water for each public drinking water system, identify significant
potential sources of contamination, and determine how susceptible each
system is to sources of contamination.
These drinking water source protection areas include federal lands that
support non-federally owned public water systems (PWSs) as well as
non-federal lands that support federally owned PWSs. For each area,
the source water assessments synthesize existing information about the
sources of each drinking water supply to provide a national base line on
the potential contaminant threats and help guide future watershed
restoration and protection. Source water protection plans and wellhead
protection are discussed in the following subsections.
Source Water Protection Plans
The SDWA Amendments of 1996 required states to develop Source
Water Assessment and Protection (SWAP) programs. A SWAP program
includes a strategic approach to conducting the source water
assessments, delineates the area of influence from which a contaminant
may enter a PWS, inventories sources of potential or known
contaminants within the delineated zone, and determines the
susceptibility of a PWS to such contaminants.
Information needed for source water assessments may be available
from watershed assessments conducted for other programs (such as
TMDL assessments). SWAPs can be integrated into other watershed
protection efforts like point and NPS pollution control, wetlands
protection, waste management, air pollution, and pesticide
management. This integration of efforts will allow various watershed
stakeholders to look for opportunities to leverage limited resources to
meet common goals. For more information about SWAP, see
http://www.epa.gov/owow/watershed/.

Wellhead Protection Program
The SDWA amendments of 1986 (P.L. 99-339) established the
Wellhead Protection (WHP) program to protect the recharge areas of
PWS wells from all sources of contamination. Like the SWAP, the WHP
provides information municipalities need to develop an overall
watershed baseline impact assessment.
Underground Injection Control Program (UIC)
If the regulator finds that an underground injection activity, such as a
leaky septic system, is contributing to surface water quality concerns,
the regulator can impose restrictions on the activity to prevent further
environmental degradation.
Coastal Zone Management Act of 1972
The Coastal Zone Management Act was amended through the Coastal
Zone Act Reauthorization Amendments (CZARA) of 1990 and P.L. 104-
150, and the Coastal Zone Protection Act of 1996. In 1990, as part of
the CZARA, Congress required the 29 states with federally approved
Coastal Zone Management Act programs to develop coastal NPS
programs. These programs provide for implementation within coastal
watersheds of management measures specified by EPA and incorporate
policies and mechanisms, enforceable at the state level, to ensure
implementation of the specified measures. EPA and the National
Oceanic and Atmospheric Administration (NOAA) jointly approve the
programs. For more information, see http://www.ocrm.nos.noaa.gov/
czm/.
Other Federal Laws
Clean Air Act
The Clean Air Act (CAA) requires the prevention or control of air
pollution from stationary and mobile sources. The CAA includes
provisions for control of air toxins, acid rain, chloroflourocarbons (CFCs),
and halons. It provides for a national air quality permit program and
increased enforcement.
CAA permits and air emissions inventories of stationary sources can
assist in watershed planning by quantifying material that can enter the
watershed via air deposition. These emission inventories provide
excellent information about the sources of watershed pollutants that may
be coming from air deposition.
Comprehensive Environmental Response, Compensation, and
Liability Act
The Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA)—also known as the Superfund law—regulates
the cleanup of leaking hazardous waste disposal sites. It also

establishes liability for hazardous substance releases—producing
facilities are liable for cleanup of their releases and restitution costs.
Furthermore, states may identify clean up of these sites as applicable or
relevant and appropriate requirements for its water quality standards.
At the municipal level, restoration planning (CERCLA) documents
provide a list and description of sites that are slated for restoration.
When conducting a watershed baseline impact study, you should
consider these sites as they may contribute, via runoff or ground water,
to the impairment of a particular waterbody.
Emergency Planning and Community Right to Know Act
The Emergency Planning and Community Right to Know Act (EPCRA)
requires personnel to participate in the emergency planning process. If
a site has extremely hazardous substances (EHS) above its threshold
planning quantities, EPCRA requires the site to notify and provide
information to the local emergency planning committees (LEPCs) and
state emergency response commissions (SERCs). The site must notify
the SERCs and LEPCs if a CERCLA hazardous substance or EHS is
released.
EPCRA requires that site managers provide information to emergency
planners and the public on hazardous substances used at the site,
including the hazards posed by these chemicals and how they are
handled on-site. A toxic release inventory (TRI) of toxic chemical
releases must be conducted and submitted annually to EPA and the
appropriate state agency (TRI Form R). This report must include
information on the release and off-site transfer of toxic chemicals.
EPCRA documents provide excellent information about the location of
stored hazardous materials that should be incorporated into a watershed
impact assessment document.
Endangered Species Act
The Endangered Species Act (ESA), 16 USC 1531 et seq., was enacted
in 1973. The ESA establishes a procedural framework, substantive
mandates, and prohibitions to ensure that it conserves species federally
listed as threatened and endangered (TE). Under the substantive
mandates, a person is prohibited from undertaking actions that are likely
to jeopardize a federally listed TE species, destroy or adversely modify
the designated critical habitat of such a species, or “take,” without
authorization, a listed TE species.
Federal Insecticide, Fungicide, and Rodenticide Act
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (see 7
USC 136 as amended) and the Food Quality Protection Act of 1996
were promulgated to protect citizens from hazardous effects of
pesticides. Enforcement authority for FIFRA rests with the EPA, which
regulates the production, distribution, storage, use, and disposal of
pesticides within the United States. (See 40 CFR parts 150–171.) FIFRA

requirements that most influence current operations at municipalities are
found in 40 CFR Part 171, which specifies certification requirements for
pesticide applicators. FIFRA regulations for pesticide storage and
disposal in 40 CFR 165 (subparts C and D) have been deleted and are
superceded in part by regulations enacted under the Resource
Conservation and Recovery Act (RCRA).
Resource Conservation and Recovery Act
RCRA, 42 USC 6901 et seq., was enacted by Congress in 1976 as a
comprehensive regulatory program for the management of hazardous
waste (HW) from “cradle to grave.” Under RCRA, HW is treated, stored,
and disposed of in ways that minimize risk to human health and the
environment. RCRA has been amended several times since its
enactment, most importantly by the Hazardous and Solid Waste
Amendments of 1984 (HSWA). The HSWA mandated changes to
RCRA, such as HW minimization, land disposal restrictions, and
provisions for regulation of underground storage tanks (USTs) that
contain petroleum products or hazardous substances. HSWA provides
management and technical standards for generators and transporters of
HW and for owners and operators of treatment, storage, and disposal
(TSD) facilities and USTs.
RCRA operating permits and closure plans provide a list and description
of sites that have discharges to groundwater, surface water, and to air.
When conducting a watershed baseline impact study, you should
consider these sites as they may contribute, via runoff or ground water,
to the impairment of a particular waterbody. Furthermore, you should be
aware that states may revise a RCRA operating permit or closure plan to
establish stricter discharge limits if that site is identified as an activity
causing an impairment to a waterbody.
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA), 15 U.S.C. 2601 et seq.,
authorizes EPA to screen existing and new chemicals used in
manufacturing and commerce to identify potentially dangerous products
or uses that should be subject to federal control. As enacted, TSCA also
included a provision requiring EPA to take specific measures to control
the risks from polychlorinated biphenyls (PCBs) [Section 6(e)].
Subsequently, three titles have been added to address concerns about
other specific toxic substances—asbestos in 1986 (Title II, P.L. 99-519),
radon in 1988 (Title III, P.L. 100-551), and lead in 1992 (Title IV, P.L.
102-550).
EPA may require manufacturers and processors of chemicals to conduct
and report the results of tests to determine the effects of potentially
dangerous chemicals on living things. Based on test results and other
information, EPA may regulate the manufacture, importation,
processing, distribution, use, and/or disposal of any chemical that
presents an unreasonable risk of injury to human health or the
environment. A variety of regulatory tools are available to EPA under

TSCA ranging in severity from a total ban on production, import, and use
to a requirement that a product bears a warning label at the point of
sale. TSCA directs EPA to use the least burdensome option that can
reduce risk to a level that is reasonable given the benefits provided by
the chemical product or process.

Appendix C
List of Typical
Municipal Activities
The following table provides a summary list of the typical municipal
activities. Table C-1 contains a listing of typical activities and the
environmental impacts typically associated with each.
Watershed Impact Assessment Guidance for Public Lands and Facilities C-1

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C-2 Watershed Impact Assessment Guidance for Public Lands and Facilities

List of Typical Municipal Activities

Appendix D
Data Entry Form for Typical
Municipal Activities
The following tables provide a summary list of the typical municipal
activities. Table D-1 contains a data entry form for recording the actual
municipal activities and the environmental impacts typically associated
with each.
Watershed Impact Assessment Guidance for Public Lands and Facilities D-1

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D-2 Watershed Impact Assessment Guidance for Public Lands and Facilities

Data Entry Form for Typical Municipal Activities
Form 6. Municipal Activity Data Entry Sheet - Part 1
Part 1. Describe the Activity, its Potential Impacts, and Identify its Watershed or Waterbody
1. Name of activity: 2. Describe activity:
3. Location(s):
4. Responsible office: 5. Unique activity ID# or SIC#:
6. Describe current mitigation efforts and past restoration efforts (Existing
or Planned):
7. Estimate annual cost of mitigation
efforts:
8. Check the laws that regulate/permit the operation of the activity:
□CWA □RCRA □CAA □SDWA □EPCRA □ NCA □NHPA
□TSCA
□FIFRA □ESA □CZMA □ NEPA
□ State:_________________________
□ Local:_________________________
□ Other:_________________________
9. List required permits and plans:
a. _______________________________
b. _______________________________
c. _______________________________
d. _______________________________
10. Receiving waterbody name and 10th–12th level HUC #, Form 1:
11. WPS from Form 2:
Pollutant of Concern TMDL? Sampled Estimated
12. List the TMDL
regulated pollutants
or 303(d) listed
pollutants of
concern released
by activity from
Form 2
13. Check activity’s
other known or
potential pollutant
releases or
impairments
(Check K for Known
or P for Potential
and check all that
apply.)
K/P
Release nutrient
Release BOD/COD
Release inorganic
Release metals
Release POLs
Uncontrolled storm
water runoff
Release pesticides
K/P
Release TSS
Cause erosion
Cause thermal pollution
Release pathogens
Disrupt potable supply
Release explosives
Potential spill
Release VOC/SVOC
K/P
Release SOx to air
Release NOx to air
Hazardous air pollutants
Greenhouse gas
emission
Release PM 10 to air
Violate noise standards
K/P
Decrease riparian
buffer
Introduce invasive
species
Decrease wetlands
Decrease fish
spawning range
Cause in-stream
scouring
Cause flooding

Form 6. Municipal Activity Data Entry Sheet (Continued) - Part 2
Part 2. Quantify the Activity’s Impact and Determine the Total Activity Burden Score
Answer the following questions to develop the activity's impact score (AIS):
(Use your own professional judgment, technical studies, monitoring data, and the instructions to answer
the questions.)
Yes or known significant
impact = 3 pts
High probability or
uncertain impact =2 pts
Low probability but
uncertain impact =1 pt
No or negligible impact
= 0 pt
a. Does the activity result in a direct point source discharge to surface waters that is
regulated under the CWA (do not include a discharge from storm water runoff in this
question)?
b. Is the activity out of compliance with CWA regulations because it does not have
an individual permit or is NOT included on the municipal permit?
c. If the activity is permitted, is it currently out of compliance with the permit
standards?
d. Has the activity had past recurring non-compliance with permit standards and/or
conditions?
e. Does the activity have a discharge of storm water runoff from a “regulated” point
source?
f. Does the activity have storm water runoff from non-point sources?
g. Are the pollutants discharged from this activity to a surface water the same as
those pollutants listed on the state/EPA 303d list (TMDL) for this waterbody?
h. Does the activity drain to a waterbody that is a source of drinking water?
i. Is the activity located in a state identified Source Water Protection Zone?
14. Surface Water Impact
j. Does the activity adversely affect flow of a waterbody with restrictions on water
withdrawal or discharge volumes?
a. Does the activity inject or have infiltration of a pollutant to groundwater?
b. Does the activity discharge pollutants that violate drinking water maximum
contaminant limits (MCLs) or water discharge permit limits to groundwater (if
permitted)?
c. Does the activity drain to groundwater that is a source of drinking water (aquifer
or well)?
15. Groundwater Impact
d. Is the activity within 300 feet of a drinking water well or within a wellhead
protection zone?
a. Does the activity have non-permitted discharges to air that are also TMDL
regulated pollutants?
16. Air Quality Impact b. Does the activity have a permitted discharge to air that is also considered a
TMDL regulated pollutant? If so, is this air discharge in compliance with the CAA
permit?
17. Critical Habitat Impact Does the activity disturb sensitive/critical habitat or endangered species habitat?
18. Cultural Resource Impact Does the activity adversely affect cultural resources or historic property?
19. Health and Safety Impact Does the activity discharge pollutant(s) that pose a risk to worker/public health
and/or safety?
a. Will a new municipal operation cause the activity to have a new pollutant
discharge to water resources that will increase compliance requirements or liability?
b. Does the activity require an environmental plan that requires management of
discharges to water resources? If yes, has the plan been implemented? If so, has
the plan been unsuccessful in reducing discharges of pollutants to water resources?
20. Compliance Burden Im-pact
c. Is the activity currently out of compliance with other environmental laws or
regulations (e.g., RCRA, FIFRA, CERCLA) or has it had recurring non-compliance
for any discharge, spill, or injection of a pollutant to water resources?
21. Identify other activity a.
regulatory concerns or issues
and rate the impact. b.
22. AIS Sum scores from questions 14 to 21
23. Total Activity Burden Score (TABS) = AIS+WPS (from Form 2):

Data Entry Form for Typical Municipal Activities
Form 6. Municipal Activity Data Entry Sheet (Continued) - Parts 3–6
Part 3. Assess Potential for Pollution Prevention Opportunities
24. Activity’s Municipal Need Score. Select either 1 (the activity is unrelated to the municipality or municipal
operations would not be adversely impacted at all if the activity ceased operations), 5 (the activity is somewhat
related to the municipal or municipal operations would be slightly adversely impacted if the activity ceased
operations), or 10 (the activity is critical to the municipal operations)
10 5 1
25. Calculate the activity’s current Burden to Municipal Need Ratio which equals the TABS from Block 23 /
MNS from Block 24. [Higher ratios identify high burdens, but activities with lower importance. These activities are
excellent candidates for the P2 evaluations listed in Block 26].
26. Check the following P2 options that are appropriate for mitigating the impacts or compliance burden of the activity:
eliminate activity consolidate activity outsource activity implement process change change materials
Part 4. Determine Project Objectives
27. Are enhanced mitigation efforts needed for this activity? Specifically, do you want to: yes no
a. Reduce the amount of pollutants entering receiving waters? yes no
b. Reduce runoff velocities or mimic predevelopment runoff flow volumes? yes no
c. Improve reliability and ease of maintenance of existing BMPs? yes no
d. Comply with permit requirements (for pollutant removal or flow control)? yes no
e. Reduce lifecycle costs of existing operations or BMPs? yes no
f. Restore natural habitat yes no
g. Other (describe)_____________________________________________________ yes no
Part 5. Select Project BMP, Estimate Costs, and Source of Funds
29. Cost Data $
Estimated total startup costs
a. Estimated planning, design permitting costs
b. Estimated purchase/construction costs
28. Describe selected mitigation project or BMP: If yes to
#27, provide title of proposed BMP or control technology:
Estimated OM costs
30. Estimate a reduction in TABS, assuming successful implementation of the enhanced mitigation
effort uses the same scoring sheet as your original TABS (Part 2). Enter new TABS here.
31. Calculate cost effectiveness of proposed project = revised TABS score / total start costs
32. Provide reference to detailed project sheet
33. List most appropriate source of funds (e.g., OM):
34. Is project eligible for other funds (e.g., state grants, EPA grants, grants from other organizations, etc.):
Part 6. Identify Project Lead and Potential Project Partners
35. Project lead office: 36. Contact phone:
37. Point of contact name: 38. Contact e-mail:
39. List potential partners
Organization name: Point of contact: Contact phone: Role in project:
40. Attach a picture of the location, impairment, or activity
Form created by: Date form created: Form revised by: Date form revised:

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References for Best
Management Practices
The following references provide a wide variety of best management
practices that you can review when developing solutions to your identi-fied
impacts to a watershed.
General Best management practices
Title, description, and reference and WWW link
Planning
Monitoring and
assessment
Indicators of
performance
General
applicability
Design
information
Effectiveness
Cost information
Maintenance
issues
Location case
studies
American Society of Civil Engineers (ASCE) National
Stormwater BMP Database at website
www.bmpdatabase.org. This www site contains an on-line
database of BMPs that users can search based on type,
pollutant treated or location used. For most cases, it
presents detailed information on the effectiveness of each
urban BMPs in removing pollutants. The database only
contains studies that conform to established protocols.
x x x x x x
Center for Watershed Protection’s Stormwater Manager’s
Resource Center. The Stormwater Manager's Resource
Center is designed specifically for stormwater practitioners,
local government officials, and others that need technical
assistance on stormwater management issues. Created and
maintained by the Center for Watershed Protection, the
SMRC has everything you need to know about stormwater
in a single site: http://www.stormwatercenter.net
Also, the Center publishes the guide, titled Watershed
Protection Techniques. Center for Watershed Protection,
Silver Spring, MD. It can be ordered at http://www.cwp.org
x x x x x x x x x
U.S. EPA provides a www site that contains a variety of
stormwater and wastewater BMPs:
http://www.epa.gov/seahome/inject/src/gbest.htm
x x x x x x
U.S. EPA, Nonpoint Source Pollution from Urban Sources
BMP Resources, http://www.epa.gov/owow/nps/urban.html x x x x x x x x x
U.S. EPA, National Management Measures to Control
Nonpoint Source Pollution from Marinas and Recreational
x x x x x x x x x
Boating, http://www.epa.gov/owow/nps/mmsp/index.html
U.S. EPA, National Management Measures to Control
Nonpoint Source Pollution from Agriculture, Draft,
http://www.epa.gov/owow/nps/agmm/index.html
x x x x x x x x x
Appendix E
Watershed Impact Assessment Guidance for Public Lands and Facilities E-1

Planning
Monitoring and
assessment
Indicators of
performance
General
applicability
Design
information
Effectiveness
Cost information
Maintenance
issues
Location case
studies
U.S. EPA. January 1993. Guidance Specifying Management
Measures for Sources of Nonpoint Pollution in Coastal
Waters. EPA 840-B-92-002. U.S. Environmental Protection
Agency, Office of Water, Washington, DC
x x x x x x x x x
U.S. EPA, 1998. Techniques for Tracking, Evaluating, and
Reporting the Implementation of Nonpoint Source Control
Measures - Urban Field Test Version. EPA841-B-937-011.
Helps local officials focus limited resources by establishing
statistical sampling to assess, inspect, or evaluate a
representative set of BMPs, erosion and sediment controls,
and on-site wastewater treatment systems
x x x x x x x x x
U.S. EPA, 1997. Monitoring Guidance for Determining
Effectiveness of Nonpoint Source Controls, Final. EPA/841-
B-96-004. U.S. EPA Nonpoint Source Control Branch.
Addresses design of monitoring programs to assess water
quality to determine impacts of nonpoint sources and
effectiveness of practices used as controls
x x x x x x x x x
Effects of Land Use Change on Hydrology and Nonpoint
Source Pollution, Version 1.1,
http://danpatch.ecn.purdue.edu/~sprawl/LTHIA2/
x x x x x x x x x
Horner, R.R., J.J. Skupien, E.H. Livingston, and H.E.
Shaver. August 1994. Fundamentals of Urban Runoff
Management: Technical and Institutional Issues. Terrene
Institute, Washington, DC (in cooperation with U.S. EPA).
(703) 548-5473
x x x x x x x x x
Livingston, Shaver, Horner, and Skupien, May 1997.
Institutional Aspects of Urban Runoff Management: A Guide
for Program Development and Implementation. The
Watershed Management Institute, Inc. (WMI) (in cooperation
with U.S. EPA), WMI (850) 926-5310. A comprehensive
review of the institutional framework of successful urban
runoff management programs at city, county, regional, and
state levels of government. Recommendations are provided
(based on surveys) that can help in all aspects of urban
runoff program development and management
x x x x x x x x x
Municipal Technologies,
http://www.epa.gov/owmitnet/mtb/mtbfact.htm x x x x x x x x x
Maryland Stormwater Management BMP Design Manual,
http://www.mde.state.md.us/environment/wma/stormwaterm
x x x x x x x x x
anual/
Maine Department of Environmental Protection/MA Office of
Coastal Zone Management, Stormwater Management
Handbook, March 1997
x x x x x x x x x
Natural Resources Defense Council, May 1999. Stormwater
Strategies: Community Responses to Runoff Pollution.
Natural Resources Defense Council
http://www.nrdc.org/water/pollution/storm/stoinx.asp
x x x x x x x x x
E-2 Watershed Impact Assessment Guidance for Public Lands and Facilities

References for Best Management Practices
Planning
Monitoring and
assessment
Indicators of
performance
General
applicability
Design
information
Effectiveness
Cost information
Maintenance
issues
Location case
studies
Prince George’s County, Maryland, Department of
Environmental Resources Program and Planning Division,
Low Impact Development Design Strategies: An Integrated
Design Approach, January 2000
x x x x x x x x x
Services and Departments,
http://www.slac.stanford.edu/esh/epr/stormwater.BMP1.html x x x x x x x x x
Terrene Institute. March 1996. A Watershed Approach to
Urban Runoff: Handbook for Decisionmakers. Terrene
Institute, Washington, DC (in cooperation with U.S. EPA
Region 5). (703) 548-5473 or terriinst@aol.com. An
informative primer for local decision makers and watershed
organizations on assessing the water quality of watersheds,
x x x x x x x x x
identifying contributing sources, and prioritizing watershed
resources to implement effective nonstructural and structural
BMPs. BMPs are summarized, and a list of resources to
obtain additional information is provided
U.S. Department of Agriculture (USDA). Award-winning
interagency Stream Corridor Restoration Handbook
www.usda.gov/stream_restoration
x x x x x x x x x
USDA’s List of Agricultural Stormwater BMPs,
http://www.ncg.nrcs.usda.gov/nhcp_2.html x x x x x x x x x
U.S. Natural Resources Conservation Service; various
erosion control and streambank stabilization drawings.
http://www.wa.nrcs.usda.gov/technical/eng/cad_support/
x x x x x x x x x
standard_dwgs/index.html
U.S. Geological Survey's website for its water quantity and
water quality data (NAWQA), both archival and real-time,
surface and ground water. http://water.usgs.gov/nwis.
x x x x x x x x x
U.S. Natural Resource Conservation Service.
http://www.wa.nrcs.usda.gov/technical/eng. Good concept
designs and other engineering support material.
x x x x x x x x x
Watershed Impact Assessment Guidance for Public Lands and Facilities E-3

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E-4 Watershed Impact Assessment Guidance for Public Lands and Facilities

Appendix F
Sample Forms
This appendix contains blank copies of Forms 1–5 which are presented
in this report.
Watershed Impact Assessment Guidance for Public Lands and Facilities F-1

Form 1. Summary of the Municipality’s Receiving Watersheds and Associated
Waterbodies
Instructions: Complete this form for each 8-digit HUC watershed. Enter watershed priority scores (WPS) from
Form 2. Please attach your watershed map to all Form 3s.
1. Name 2. State and County 3. Zip Code(s)
4. Name of 8-digit HUC watershed(s) 5. 8-digit HUC(s)
Regulators
Name of waterbody
or state identifier
List of impaired
designated uses
Summary of impairments
of concern (from Form 2)
WPS
(from Form 2)
Regulators
Name of waterbody
or state identifier
List of designated
uses
Summary of impairments of
concern (from Form 2)
WPS
(from Form 2)
F-2 Watershed Impact Assessment Guidance for Public Lands and Facilities

Sample Forms
Form 2. Watershed Priority Score (WPS): A Sensitivity Scoring and Data Collection Form
for Waterbodies/Watersheds
Complete a Form 2 for each waterbody listed Form 1. Record the WPS and pollutants of concern into Form 1 for each waterbody.
1. Name of the Watershed and Corresponding 8- to 16-Digit HUC Code (or State Identifier):
2. Waterbody/Watershed Impairment Score for the watershed listed in Block 1. Go to the State regulator or EPA’s State 305b reports to
determine the waterbody’s designated uses and if they are being met. For each designated use, check the degree it meets the use, the
impairment(s), and the causes/stressors.
Designated Use Impairment Cause/Stressor
Not
Supporting
= 3 pts
Partially
Supporting
= 2pts
Fully
Supporting
= 1pt
Not a
Designated
Use= 0 pts
a. Aquatic life use
b. Fish consumption use
c. Shell fishing use
d. Swimming use
e. Secondary contact use
f. Drinking water use
g. Agriculture use
h. Cultural/ceremonial use
i. State/municipal specific use
_______________________
3. Transfer the State 303(d) listed pollutants of concern (impairments) from TMDL in place?
question 2 and note if the State has developed TMDL. Yes = 3 pt No = 0 pts
Enter TMDL Effective
Date
a. 303(d) Impairment 1:
b. 303(d) Impairment 2:
c. 303(d) Impairment 3:
d. 303(d) Impairment 4:
e. 303(d) Impairment 5:
4. Waterbody/Watershed Vulnerability Score for the watershed listed in Block 1.
Yes
= 1 pt
No
= 0 pts
a. Are the impervious surfaces above 25% of watershed land area (for either current or projected land use)?
b. Is the population growth rate of the watershed above 7%?
c. Does waterbody contain impounded water (e.g., dams and fish barriers)?
d. Is the receiving water listed as a protected estuary?
5. Has EPA, individual service, state, water authority, or local group listed restoration goals for the waterbody in
Block 1? If so, list the specific goals.
Yes
= 1 pt
No
= 0 pts
a. Biodiversity and habitat loss. If yes, list goal:
b. Riparian buffer strip loss. If yes, list goal:
c. Imperviousness/uncontrolled SW runoff. If yes, list goal:
d. Invasive species. If yes, list goal:
e. Wetlands. If yes, list goal:
f. Other: If yes, list goal:
6. Has an enforcement official requested the municipality to monitor/sample the waterbody?
7. Have water withdrawal/use restrictions been imposed for the waterbody?
8. Have potential impacts to human health been identified as a significant concern for the waterbody (e.g., air
deposition of a pollutant to the waterbody, or pollutants in the water are causing a risk to drinking water)?
9. Is this watershed or waterbody designated as a special water resource under the American Heritage River
Program, Great Lakes Program, Scenic Waters Program, or another special program?
10. Watershed Priority Score (WPS) = impairment score (blocks 2 a-i) + TMDLs (blocks 3 a-e) + vulnerability
score (block 4 a-d) + goal score (blocks 5 a-f) + answers on blocks 6 to 9.

Form 3. Summary List of Municipal Activities That Potentially Affect the Watershed
4. Potential activity
watershed impact
Activity ID #
1. Activity name
2. Activity
location
3. Waterbody
or sub-watershed
affected
a. Contributes the following
regulated impairments
(e.g., TMDLs)
b. Contributes the following
other impairments
5. Compliance burden
(e.g., governing laws, regulations,
and required permits or plans)
6. Total Activity Burden Score
(TABS=WPS+AIS)
7. Pollution prevention or enhance-ments
possible?
(Yes or No)
Date Baseline Completed: Page ___ of ____

Sample Forms
Form 4. Summary of Municipal Land Use Categories
Description of Land Use Categories
Total # of Activities in
each category
(Refer to Form 3)
Total acres in each
category
Total # impervious
acres
Total # pervious acres
Total % impervious
Total % pervious
Acres covered by
SWP3 or other plan
(specify)
Land use improve-ment
goal (%)
% of goal accom-plished
Industrial: (Including: Facility
Operations Maintenance Areas,
Motor Pools, Equipment Material
Storage Areas, Truck Parking, Wash
Racks, Fueling Points, Industrial
Treatment Plants, Fumigation Areas,
or Shipping/Receiving Areas)
Urban (Including: Commercial –
Shopping Centers, Grocery Stores,
Restaurants, Banks, Parking;
Residential – Housing and Parking;
Office Buildings and Parking; and
roads)
Mixed Use: (including gravel areas,
low impact parking lots, total semi-maintained
open grounds (e.g.,
operational buffers and firebreaks),
and recreational grounds (e.g., ball
fields, horse stables, golf courses)
Paved Roadways
Construction
Agricultural Operations
Natural Areas
Non-riparian forest
Riparian forest and buffer strip
Wetlands
Grasslands or prairie
Endangered species conservation
areas
Waterbodies (stream, pond, or
other)
Coastal area or estuary
Other natural areas (e.g., beaches
and deserts)
Acres of natural areas slated as
protected critical areas
Total for municipality:
Baseline conducted by: Date:

That May Potentially Impact the Watershed
Question about municipality
Yes
Unsure
No
Typical
impacts or
concerns with
activity
Number of
activities
(on-site) Comments
visible signs of bank erosion,
scouring, or unstable stream
banks? If yes, note if caused
activities.
Aquatic habitat
degradation,
sedimentation,
and flooding
barriers to fish spawning? If
Aquatic habitat
degradation,
sedimentation,
and flooding
areas that exhibit uncontrolled
flooding during rain events? If
Aquatic habitat
degradation,
sedimentation,
and flooding
streams or rivers without
adequate riparian buffer (as
defined by watershed goals or
local zoning requirements)?
Aquatic habitat
degradation
and
sedimentation
steep slopes or other areas
that exhibit visible signs of
erosion? If yes, note if caused
activities.
Sedimentation
and flooding
impervious areas (roads,
parking lots, buildings, etc.)
that drain directly to receiving
waters without retention or
detention controls?
Flooding and
aquatic habitat
degradation
7. Do any upstream properties
or activities drain onto the
municipality that may affect
water quality or cause on site
flooding or stream scouring?
Flooding, toxic
or
conventional
pollutants,
TMDLs, and
aquatic habitat
degradation
septic systems or other
underground injection wells?
Toxic or
conventional
pollutants to
aquifers and
TMDLs
complete a Form 6.

Sample Forms
That May Potentially Impact the Watershed (Continued)
Question about municipal
Yes
Unsure
No
Typical
impacts or
concerns with
activity
Number of
activities
(on-site) Comments
produce its own drinking
water? If yes, note if using
ground or surface waters
Regulatory
burden such
as source
water
protection,
wellhead
protection, or
conservation
plans
conduct industrial activities
that require NPDES
wastewater, pretreatment, or
storm water discharge
permit?
Toxic or
conventional
pollutants,
TMDLs,
sedimentation,
spills, and
regulatory
burden (e.g.,
plans)
maintain bulk storage of
POLs or EPRCA chemicals
in USTs or ASTs?
Spills to
surface or
ground waters
and regulatory
burden
conduct fleet fueling
operations or operate fueling
stations?
Toxic
pollutants,
TMDLs, spills,
and regulatory
burden
13. Does the municipality have
uncovered bulk storage of
industrial chemicals,
materials, wastes, or
equipment (e.g., salt or coal
piles)?
Toxic or
conventional
pollutants,
TMDLs, spills,
and regulatory
burden
14. Does the municipality apply
fertilizers or pesticides on its
property?
Toxic or
conventional
pollutants,
TMDLs, spills,
and regulatory
burden
15. Is the municipality
undertaking or planning
major construction or ground
disturbing activities?
Sedimentation
and regulatory
burden
complete a Form 6.

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Appendix G
Sample Project
Sheet Format
While it is important to document each activity’s affects to the watershed
conditions, having the project information in separate locations makes it
difficult to summarize the work plan efforts or to identify opportunities for
coordinating watershed management efforts. Thus, this Appendix
contains the following recommended format for summary information,
which users can use to enter their activity impact and project information
for different management purposes such as prioritizing budget requests
and tracking project implementation progress and results.
Watershed Impact Assessment Guidance for Public Lands and Facilities G-1

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G-2 Watershed Impact Assessment Guidance for Public Lands and Facilities

Sample Project Sheet Format
Project Title
Activity/Site Name
Project Priority:
Site Photo
Location: (latitude and longitude, building number, or description)
Problem Description
Proposed Project
Objective and Benefits
Proposed Project Concept
Design
Design Concept
Maintenance Requirements
Permits and Legal Requirements
Proposed Budget and
Schedule
Cost
Schedule
Cost Benefit Data
Proposed Funding
Sources
FUNDING PROPOSAL
Project Title
Budget Justification
Other Potential Funding Sources
Potential
Partners/Stakeholders
Responsible Municipal Office
Other Partners
Additional References
Technical Documents
POCs at other locations that have im-plemented
similar projects
Watershed Impact Assessment Guidance for Public Lands and Facilities G-3

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G-4 Watershed Impact Assessment Guidance for Public Lands and Facilities

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