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overall budget - though table 33 identifies many additional programs and includes categories for administration and capital improvement projects. Only about 10% of the budget is dedicated towards priority projects and these priorities are generally based on yet -to -be started studies or are unidentified /untargeted projects. • Education and Outreach Program, page 141: Considering the number of education and outreach activities identified in Chapter 6 and table 33 as well as the opportunities to partner with other entities on education, the description of the education program here is weak and the funding limited. At a minimum, describe how the WMO will measure changes in stewardship for evaluation of the program. • Cost Share Incentive Program, page 142: Further description of the program is needed including criteria used for project selection, an outline of program processes and administration, and details of the budget; i.e. amount available for cost share, amount for technical assistance, and amount for administering the program. • Monitoring Program, page 142: See comments on 6.3.2 Monitoring and Data Assessment and Activity 2.1f and 6.1a above. Additionally, funding does not appear to be sufficient or consistent enough to implement the scale of monitoring identified. • 7.6 Implementation Plan Table, 7.7 District Financing Approach and table 33: • Priority items were selected based on input from 2 stakeholder meetings and are not based on any monitoring data, trend information, or past studies. • The cost of activities identified as Option 1 is more than double the historic funding level indicated. While BWSR understands the WMO's desire for the higher level of funding, and that the WMO and member cities have been discussing alternative financing approaches; these approaches are not yet in place and the option 2 activities are only vaguely described. We request the table be revised to more clearly show the activities and programs the WMO will reasonably implement based on the current funding mechanism, the activities /programs that will be implemented only if the alternative funding source identified is implemented, and the activities /programs that will be implemented only if grant or other outside funding sources are found. See also comments on page 149 below. • The majority of activities identified as capital improvements in this section of the table are too generic and do not have the information required to be considered capital improvements. Additionally, while we appreciate the WMO's commitment to coordinate and collaborate with the MPCA on the upcoming watershed assessment /TMDL, this study has not started yet and will not likely be completed for 2- 4 years. As a third generation plan, the WMO should be able to specifically identify structural practices that could be implemented in the interim, and once the study is completed, the plan will need to be amended to specify the elements of the study that the WMO will be implementing. • We suggest cross - reference back to the activities identified in Chapter 6 and consistent use of the terminology ('initiative' in this chapter versus 'implementation activity' in chapter 6). 8.0 Administration • Page 148, Evaluation and Accountability: While the PRAP table in Appendix E provides a tabulation of compliance with performance standards, this table is not a measure of progress towards the WMO's stated goals as described in the text. Additionally, this table is modified annually and portions may or may not be applicable over the lifetime of the plan. We suggest more detail as to how the WMO will measure success of each goal and program and that the Page 5 of 6