Tips for Developing a TMDL Work Plan

Minnesota Pollution Control Agency Session 6c: A TMDL training program for local government leaders and other water resource managers wq-iw3-56c

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In this presentation „ The importance of good pre-project planning „ Your roles as Project Manager in development

of a work plan „ Work plan contents „ The essential work of documenting your project from beginning to end

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Begin your project with a general work plan Pre-project planning is essential to the completion of a good quality, defensible TMDL study Planning is as important to TMDLs as it is to engineers planning for construction of a bridge, road or building

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What is a work plan? Describes the overall approach to completing the TMDL study, including schedules, deliverables and roles and responsibilities for all involved If needed, separate work plans can be developed for different components, e.g.: a. Monitoring (collecting water quality or land use data) b. Public participation c. Modeling, etc.

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What role does a Project Manager play in developing a work plan?

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Project managers play many roles in work plan development „

Be involved from the earliest stages „ Take charge of the work plan and its contents „ Assume responsibility for developing and executing contracts and work orders to complete work plan tasks

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Ensure state or federal dollars are used wisely to accomplish the desired goals „ Ensure deliverables are delivered „ Ensure scientifically defensible TMDL study is completed

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Project managers play many roles in work plan development MPCA Project Managers must manage all aspects of TMDL projects, including local partners or consultants develop the TMDL study! „

Be an assertive partner „ Don’t be afraid to raise concerns „ Manage, manage, manage, while keeping a partnership perspective

Scrutinize the work!

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Project managers play many roles in work plan development „ Consider whether local

partners have the expertise and jurisdiction to do the work or to oversee the project „ If not, consultants may be needed „ Consultants work should be overseen by an experienced local partner or MPCA

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Project managers play many roles in work plan development As Project Manager, you must be a 1. planner 2. partner 3. administrator

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Your role as Planner Don’t be tempted to immediately jump from a initial project proposal to contract development

IT A W Take time to consider whether more planning is needed (Time spent scrutinizing early project plans typically pays off many times over)

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Your role as Planner Have you filled out project worksheets (see manual) to determine full project scope? If not, take time to do it now! (You could avoid extra work later by being thorough up front)

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Your role as Partner „ Local involvement is essential, powerful,

necessary „ All need to be supportive, full partners in the process „ Keep in mind, however, that MPCA must ultimately supervise the process „ MPCA is held accountable for results by EPA and MN Legislature

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Your role as Partner „ In addition, be a partner with your

MPCA staff team (technical, contracts and program staff) in the planning process „ Team members can share experiences, knowledge from similar projects

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Your role as Partner Project team members can help with „ pre-planning „ work plan development & review „ technical assistance „ review of draft documents „ etc.

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Your role as Administrator „ You are the keeper of the public’s

trust regarding the use of taxpayer dollars „ You are responsible if work plan and contract rules are not adhered to (otherwise a 16A form goes in your file!) „ Your careful management ensures a positive outcome for all parties involved

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Your role as Administrator „ Major activity is to develop the

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work plan for a TMDL study and the contract that will allow work to be completed Know your funding source(s) Know requirements of each funding source Set deadlines and get deliverables Submit invoices in timely manner

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Your role as Administrator „ Pay attention to the contract

end dates, whether work is getting done in a timely way, and whether funds are being spent „ Notify program administration staff if your project will not spend all funds (allows MPCA to redirect funds to other projects before the grant ends)

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Your role as Administrator „ TMDL monies dispersed on

reimbursement basis only „ Projects need to produce specific deliverables before money can be reimbursed One critical deliverable = TMDL study However. . . interim products are as important from a state auditor’s standpoint

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THE WORK PLAN

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Elements of a TMDL work plan „ Project description

„ Deliverables and a

„ Goals and expected

completion schedule „ A budget that matches tasks and which adds up! „ Subcontracts must be detailed, too

outcomes „ Detailed outline of project activities by task „ Description of roles and responsibilities

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Work plans should be specific, while also flexible „ Work plans should be as specific

as possible, but can be changed as circumstances change „ Change order and amendments language need to be in contract „ Work plans must be revised to document the changes „ Changes in work plan scope or budget must be approved BEFORE work is performed

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Why do work plans change? Possible reasons „ monitoring activities increased or decreased „ modeling scenarios added or changed as more information is discovered „ monitoring locations are changed to gather additional information on potential sources „ public outreach activities increased or decreased depending on interest or response

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Is one work plan enough? „ Some projects are very complex,

requiring more than one work plan „ For simpler, less complex projects, one work plan may be adequate „ Work plan activities may be completed using more than one contract type „ State contracts are available to perform certain activities (e.g. monitoring, modeling)

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Complex, large projects may need several work plans A phased approach makes sense for 1. Projects covering a large geographic area or basin 2. Complicated projects, multiple impairments, situations where numerous consultants are required Include deliverables and schedules in all!

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Smaller, less controversial projects can have a simple work plan Examples: 1. Projects with small geographic areas 2. Single pollutants 3. Projects where LGUs have expertise 4. Projects with limited scope of work All need deliverables and budget

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If an approved work plan needs changes 1. Complete required paperwork,

including a revised work plan and a change order or amendment 2. Determine whether EPA approval is needed 3. Work with program staff to get EPA approval

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Use experts appropriately „ Consultants may not have the

expertise you need for all tasks „ Local or MPCA staff may not have the expertise needed for all tasks „ Use MPCA staff where appropriate and available „ Carefully match consultant skills with specific work plan activities (monitoring, modeling, data analysis, etc.)

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Work plan – technical details „ Carefully plan your project and,

as possible, anticipate technical needs (data, labs, equipment, models, etc,) „ Work plan should explain what

will be accomplished, define deliverables, schedule, roles and responsibilities „ Be prepared to estimate costs (hours, subcontractors, etc.)

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Work plan – non-technical activities „ Work plan must include plans

for stakeholder and public participation „ Generally describe how it will be accomplished „ Public outreach and stakeholder involvement is a critical part of any TMDL. Carefully select the right person(s) for the job

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Dispelling the myth Myth 10% Rule: A work plan does not have to be amended if changes amount to less than 10% of proposed project budget

Truth Work plan must be amended even if changes represent less than 10% of proposed project budget!!

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Documentation is essential „ Your TMDL project must be

carefully documented, from beginning to end „ The work plan is one important type of documentation, but each major decision made should be easy to track within project files

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Summary 1. There is no substitute for good project planning! Everyone benefits, as does the resource! 2. Manage and document your project from early planning stages to completion. Don’t be afraid to question and scrutinize work of partners and consultants

3. Work early and often with MPCA contracts staff to ensure wise use of government funds!

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MPCA Contacts Celine Lyman – Work plans Kurt Soular – Work plans Jayne Stilwell-Lamb – TMDL Master Contract