The DNR issued a guidance document on the adaptive management compliance option for the phosphorus water quality based effluent limits. The guidance document is intended to help sources identify whether they are a good candidate for adaptive management and if so, how to develop a successful adaptive management plan. The DNR readily admits that it is an evolving process subject to change as more experience is gained through implementation and development. The guidance covers permit requirements, interim limits and what are the necessary components of an adaptive management plan. If you have a WPDES and are contemplating adaptive management for potential compliance, I highly recommend this document as a starting point.