Advance Restoration Plans
The Vision for the Clean Water Act Section 303(d) Program (“vision”) identifies five goals, including the Restoration Goal, which encourages the identification, development, and implementation of the most effective tool for restoring waters – be it a total maximum daily load (TMDL) or other approach. In most cases, a TMDL is the first step in restoring these waters, providing the pollution budget that serves as a foundation for implementation plans, regulatory activities, and/or on-the-ground restoration. The Restoration Goal recognizes there are cases in which pursuing restoration approaches in advance of developing a TMDL may provide a more immediately beneficial or practicable path to restore water quality. These plans were discussed in the 2013 Vision and 2016 IR memo under the “Alternatives” Goal but in order to address the potential misconception that these plans are alternatives to a TMDL, EPA is discontinuing the use of the term “alternatives” moving forward and recommends that states, territories, and authorized tribes discontinue the use of the term as well.
An advance restoration plan (ARP) is a near-term plan, or description of actions, with a schedule and milestones, that is more immediately beneficial or practicable to achieving WQS. Impaired waters for which a state, territory, or authorized tribe pursues an ARP to achieve water quality standards would remain on the CWA 303(d) list and still require TMDLs until water quality standards are attained. Once developed, states, territories, and authorized tribes should periodically evaluate ARPs to determine if such approaches are still expected to be more immediately beneficial or practicable in achieving WQS than pursuing a TMDL approach in the near-term. If not, the ARP should be re-evaluated to determine whether a higher priority for TMDL development should be assigned as part of the next integrated reporting cycle.
EPA does not take action to approve or disapprove ARPs under CWA 303(d); however, EPA does review and take into account a state's, territory's, or authorized tribe’s description of its ARP to determine whether it is appropriate to include the plan under CWA 303(d) performance measures.
EPA has created a recommended subcategory under Category 5— subcategory 5r —as an organizing tool to clearly articulate which listed waters have ARPs, and to provide transparency to the public. In addition, this subcategory will facilitate tracking ARPs in CWA 303(d) listed waters on a national basis.
As of April 2025, EPA has accepted 115 advance restoration plans from 28 states.
The Compendium of Approaches to Addressing Water Quality Problems , developed in 2016 as part of a Cooperative Agreement with the Environmental Law Institute (ELI), organizes examples of successful water quality restoration efforts where waters now meet standards or are significantly improved and did not have (or were not influenced by) a TMDL developed for the pollutant in question when the approach was implemented. These examples were intended to provide a conceptual starting point for states to consider when developing advance restoration approaches, as described in the long-term program Vision.