Implementing nonpoint source pollution programs: Insights from interviews with agency professionals

Abstract

Nutrient pollution from agriculture remains a leading cause of water quality impairments in the United States despite decades of policy interventions. The authority to implement water quality policies falls to states, with significant variation in the development and execution of programs designed to reduce nutrient pollution. Few studies have evaluated how states implement these programs, limiting insights into how policy actors can improve the design and delivery of water quality policies. State agency professionals have unique insights into the implementation of programs designed to address nutrient runoff. Here we report on interviews with agency staff involved in six water quality programs across three US states. We asked interviewees to reflect on the implementation of each program and share recommendations for how policies could be adapted to other states or contexts. Respondents identified several insights relevant to successful policy implementation. They stressed the need for strong partnerships between state and local agencies, robust technical tools for monitoring and compliance, and adaptable strategies that account for regional and operational differences. Agency staff noted that voluntary policies are more politically feasible but less effective, while mandatory policies can achieve broader compliance when robust enforcement mechanisms are in place. In addition to implementation challenges, agency staff were asked to reflect on the equity implications of agricultural policies. Many programs fail to account for barriers faced by small-scale, minority, and underrepresented farmers, including limited access to land and resources. This research provides actionable insights for policymakers, emphasizing the importance of balancing flexibility and resource allocation to create more effective and sustainable water quality programs.

ReseaRch aRticle
Journal of Soil and Water ConServation
Implementing nonpoint source pollution programs: Insights from
interviews with agency professionals
Bonnie l. Keeler , taylor hohensee, Meghan anderson, and erin Niehoff
Center for Science, technology, and environmental Policy, Humphrey School of Public affairs, university of Minnesota, Minneapolis,
Minnesota, uSa
ABSTRACT
Nutrient pollution from agriculture remains a leading cause of water quality impairments in
the United states despite decades of policy interventions. the authority to implement water
quality policies falls to states, with significant variation in the development and execution of
programs designed to reduce nutrient pollution. Few studies have evaluated how states
implement these programs, limiting insights into how policy actors can improve the design
and delivery of water quality policies. state agency professionals have unique insights into
the implementation of programs designed to address nutrient runoff. here we report on
interviews with agency staff involved in six water quality programs across three Us states. We
asked interviewees to reflect on the implementation of each program and share
recommendations for how policies could be adapted to other states or contexts. Respondents
identified several insights relevant to successful policy implementation. they stressed the
need for strong partnerships between state and local agencies, robust technical tools for
monitoring and compliance, and adaptable strategies that account for regional and operational
differences. agency staff noted that voluntary policies are more politically feasible but less
effective, while mandatory policies can achieve broader compliance when robust enforcement
mechanisms are in place. in addition to implementation challenges, agency staff were asked
to reflect on the equity implications of agricultural policies. Many programs fail to account for
barriers faced by small-scale, minority, and underrepresented farmers, including limited access
to land and resources. this research provides actionable insights for policymakers, emphasizing
the importance of balancing flexibility and resource allocation to create more effective and
sustainable water quality programs.
INTRODUCTION
Despite years of effort, policies to reduce non-
point source pollution have had limited success
in improving water quality (Dubrovsky and
Hamilton 2010; Lintern et al. 2020). More than
half of US stream and river miles and 40% of
lakes are still considered impaired (US EPA
2024b). Agricultural runoff is the largest source
of pollution to rivers and streams and the third
leading source for lakes in the United States (US
EPA 2024a).
States have implemented voluntary and regu-
latory approaches to reduce the impacts of agri-
culture on water quality. These include
encouraging farmers to adopt best management
practices (BMPs) such as cover crops and riparian
buffers (Liu et al. 2017; Schramm et al. 2024;
Shahady 2022) and regulating nutrient manage-
ment by mandating the quantity or timing of
fertilizer application. Efforts to document the
impact of state-level nonpoint source pollution
programs have proven challenging due to the
inability to identify specific sources of water pol-
lution, lag times between policy interventions and
measurable nutrient reduction impact, and the
resources required to monitor water quality out-
comes (Tomczyk et al. 2023). Additional chal-
lenges include insufficient monitoring or
enforcement, low adoption rates, limited resources
to oversee or execute programs, and investments
in practices that are ultimately ineffective.
© 2026 the author(s). Published with license by taylor & francis Group, llC
CONTACT Bonnie l. Keeler keeler@umn.edu
Supplemental data for this article can be accessed online at https://doi.org/10.1080/00224561.2025.2597160.
https://doi.org/10.1080/00224561.2025.2597160
this is an open access article distributed under the terms of the Creative Commons attribution-nonCommercial-noderivatives license (http://creativecommons.org/licenses/by-nc-nd/4.0/),
which permits non-commercial re-use, distribution, and reproduction in any medium, provided the original work is properly cited, and is not altered, transformed, or built upon in
any way. the terms on which this article has been published allow the posting of the accepted Manuscript in a repository by the author(s) or with their consent.
ARTICLE HISTORY
received March 12, 2025
revised June 23, 2025
accepted July 8, 2025
KEYWORDS
best management practices;
compliance; implementation;
nonpoint source; nutrient
pollution; semistructured
interviews

2 B. l. KeeleR et al.
Existing policy implementation research on
agricultural water quality has focused on the per-
spectives of farmers and producers. Scholars have
used focus groups (Irvine et al. 2024), surveys
(Denny, Marquart-Pyatt, and Houser 2019), inter-
views (Reimer, Denny, and Stuart 2018), mixed
methods (O’Connell and Osmond 2022; Osmond
et al. 2015), and meta-analyses (Baumgart-Getz,
Prokopy, and Floress 2012) to assess farmer per-
spectives on program adoption and participation.
Research has assessed farmer perspectives on cli-
mate change (Arbuckle et al. 2014), adoption of
climate change adaptation practices (Soubry,
Sherren, and Thornton 2020), and motivations
to reduce nutrient inputs (Young et al. 2022).
Insights from this work have identified the
importance of trusted sources in enhancing par-
ticipation in conservation programs and motivat-
ing farmer behavior and adoption of BMPs.
Relatively less attention has been devoted to
the perspectives of agency staff and the practi-
tioners who implement water quality policies.
Policy scholars use the terms “street-level bureau-
crats” or “policy entrepreneurs” to describe actors
who interact with the public and have consider-
able autonomy in decisions that affect policy and
program implementation (Lipsky 1980). Policy
implementation research in this area explores
questions related to the impact and influence of
street-level bureaucrats in determining policy out-
comes (Sætren 2024). In the context of state
nutrient reduction policies, these actors include
agency staff who oversee the implementation of
state and federal nutrient management programs,
as well as local soil and water conservation dis-
trict (SWCD, or its equivalent) professionals. In
contrast to farmers and producers who are often
the target of nutrient reduction programs,
street-level bureaucrats offer unique perspectives
on the details of policy design, implementation,
and enforcement.
Previous research found that street-level
bureaucrats impact policy outcomes through their
discretionary power and allocation of resources.
Wardropper (2018) surveyed SWCD staff in the
Upper Mississippi River basin, finding variation
in how staff integrated environmental perfor-
mance information in watershed planning. Reimer
and Prokopy (2014) interviewed USDA Natural
Resources Conservation Service (NRCS) staff
involved in the implementation of the USDA’s
Environmental Quality Incentives Program
(EQIP), identifying ways that agency staff adapted
federal programs to accommodate local contexts.
In a study of Missouri agroforestry programs,
Kronenberg et al. (2023) found that uptake of
recommended practices was hindered by a lack
of in-depth knowledge by conservation officials
overseeing program implementation. These exam-
ples demonstrate the potential influence of agency
staff on program effectiveness.
Much of the existing research on water policy
has focused on the empirical evaluation of policy
design and associated outcomes, often supported
by coupled hydrologic and economic modeling
(Keiser and Shapiro 2019). Research of this type
has contributed greatly to our understanding of
the return on investment in water quality pro-
grams and informed evaluation of alternative
designs including market-based versus regulatory
approaches (Olmstead and Stavins 2009). However,
quantitative analyses of policy outcomes can over-
look key institutional and political factors that
are key to policy implementation (Sevä and Jagers
2013; Sætren 2024). Street-level bureaucrats are
the primary implementers of environmental pol-
icy and therefore offer unique insights related to
the monitoring, evaluation, and enforcement of
water programs (Holstead, Funder, and
Upton 2021).
Qualitative research also provides an opportu-
nity to investigate the equity implications of envi-
ronmental and agricultural policies (Layman and
Civita 2022). Guidance from the Biden adminis-
tration required federal agencies to consider the
equity and distributional impacts of federal pro-
grams (Federal Register 2023). In recent years,
state water quality funds have also added require-
ments to consider how investments “celebrate
cultural diversity or reach diverse communities,
including reaching low- and moderate-income
households” (Minnesota Legislature 2024). These
efforts are often motivated by a recognition that
discriminatory practices have led to differential
outcomes in access to land or exposure to envi-
ronmental harms. For example, scholars have
highlighted how USDA policies negatively
impacted access to land and farm programs by

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Policy	State	State agency	Year in effect	Mandatory or voluntary	Program summary
Buffer Law	Minnesota	Board of Water and Soil Resources	2017	Mandatory	Requires vegetative buffers along state-designated public waters, including 50 ft vegetative buffers along lakes, rivers, and streams, and 16.5 ft buffers along ditches, or approved alternative practices.
Groundwater Protection Rule	Minnesota	Dept. of Agriculture	2019	Voluntary and mandatory	Restricts the application of nitrogen fertilizer in the fall and on frozen soils in areas vulnerable to contamination. Responds to elevated nitrates in public groundwater supplies through four possible actions that ramp from voluntary to regulatory; for example, encouraging adoption of BMPs when nitrate is measuring at 5.4 to 8 mg L⁻¹, and then requiring landowners to implement practices beyond BMPs when nitrate exceeds 9 mg L⁻¹ for any three samples in a 10-year period.
Minnesota Agricultural Water Quality Certification Program (MAWQCP)	Minnesota	Dept. of Agriculture	2013	Voluntary	Whole-farm conservation planning that provides regulatory certainty, recognition, and priority for technical and financial assistance to those who meet or exceed water quality risk assessments and sign an enrollment contract with the state.
Adaptive Management	Wisconsin	Dept. of Natural Resources	2010	Voluntary	Voluntary compliance option for WPDES-permitted point source dischargers to comply with Wisconsin’s Phosphorus Rule (NR 217). The facility works with other point source facilities, nonpoint source landowners, municipalities, and other partners within the watershed to reach the required effluent phosphorus limits, often through the increased adoption of agricultural BMPs. Plans are often financed through cost savings from avoided facility upgrades for the point source facility.
Nutrient Management Plans	Wisconsin	Dept. of Agriculture, Trade, and Consumer Protection	2003	Mandatory	Requires farm-specific plans to reduce nutrient runoff, either developed with a local certified crop advisor or written after completing a training course. Cost-share is available through Soil and Water Resource Management and county land conservation departments. Participants can qualify for the Farmland Preservation Program tax credit.
Partners for Conservation Program	Illinois	Dept. of Agriculture	1995	Voluntary	Provides funding to SWCDs to distribute as cost-share to farmers implementing preapproved conservation practices aimed at reducing soil loss on cropland.

State	Policy	Department of Agriculture (MN-DA, IL-DA, WI-DATCP)	Department of Natural Resources (DNR)	Board of Water and Soil Resources (MN BWSR)	Pollution Control Agency (MPCA)	Total interviewees
		State agencies
Minnesota	Buffer Law	—	3	1	1*	5
	Groundwater Protection Rule	3	—	—	1*	3
	Minnesota Agricultural Water Quality Certification Program (MAWQCP)	4	—	—	1*	4
Wisconsin	Adaptive Management	—	3^†	—	—	3
Wisconsin	Nutrient Management Plans	1	1^†	—	—	1
Illinois	Partners for Conservation	1	—	—	—	1
Total interviewees		9	6	1	1	17

State	Policy	Tools	Developer
Minnesota	Buffer Law	Public Waters GIS map	Minnesota Department of Natural Resources
		Online Public Waters comment tool	Minnesota Department of Natural Resources
		Satellite imagery
	Groundwater Protection Rule	Soil and Water Assessment Tool (SWAT) and Environmental Policy Integrated Climate (EPIC) model	University of Minnesota
	Groundwater Protection Rule	Vulnerable Groundwater Area Map	Minnesota Department of Agriculture
	Minnesota Agricultural Water Quality Certification Program (MAWQCP)	GIS map of participant growers	Minnesota Department of Agriculture
		Assessment tool (model)	Minnesota Department of Agriculture
		Prioritize, Target, and Measure Application (PTMApp)	Minnesota Board of Water and Soil Resources, Minnesota Geospatial Office (MNGEO), Houston Engineering Inc., International Water Institute
		NRCS COMET (GHG emissions)	US Department of Agriculture
Wisconsin	Adaptive Management	Soil Nutrient Application Planner (SNAP+)	University of Wisconsin
		Erosion Vulnerability Assessment of Agricultural Lands (EVAAL)	Wisconsin Department of Natural Resources Bureau of Water Quality
		Satellite imagery
	Nutrient Management Plans	Soil Nutrient Application Planner (SNAP+)	University of Wisconsin
Illinois	Partners for Conservation	Revised Universal Soil Loss Equation 2 (RUSLE 2)	USDA Agricultural Research Service (ARS), USDA Natural Resources Conservation Service (NRCS), University of Tennessee

State	Policy	Quote
Minnesota	Buffer Law	“You need to build up enough support to get some type of law passed and you need to be flexible.”
		“From a map and implementation perspective, I think more lead time would be really helpful to plan through how that implementation is going to occur.”
		“You gotta sell it. You’re gonna get resistance, of course. Get people used to the idea, kind of promote what other states have done, and kind of enumerate some of the benefits they’d see.”
		“Find friends and keep them close and expect opposition, but try, you know, be persistent and articulate the benefits.”
		“You need to be transparent about what it is you’re doing and you need to base your arguments for doing it on both science and economics. And you need to include a good cross section of everybody.”
Minnesota	Groundwater Protection Rule	“We have karst geology, and of course, textured soils and soils with shallow bedrock here. So we’ve designed the rule to address those issues.”
		“And another thing I would have to suggest they look at is their policy, because in Minnesota MPCA’s got the authority for manure feed lots. We’ve got authority for nitrogen fertilizers. So our role mainly addresses nitrogen fertilizer, and we can address manure rates. But if a different state has a different setup in their manure and fertilizer regulation is in one agency, then they might have a little bit different rule that addresses it all in one aspect of the rule.”
		“Funding is critical. When you really get into these areas, some of these practices are expensive, and so our ability to leverage our Clean Water Fund has just been a game changer for us.”
		“As you begin to develop something similar to the Groundwater Protection Rule, keep the science central to it, making sure that we’ve got that strong technical background.”
		“I think it’s been very helpful that we have a strong relationship with our University of Minnesota and having that technical partner has been very important. And so this doesn’t stand in isolation.”
Minnesota	Minnesota Agricultural Water Quality Certification Program (MAWQCP)	“Yes, do this program. I just think it’s particularly effective. I think it’s actually readily transferable.”
		“I think that kind of stakeholder process is really good, though, to, you know, not just drop it on people. Bring them in. Bring him into the process.”
		“One of the fascinating things I learned from California is like, oh, we don’t have any of those fertilizer recommendation rates.… So those challenges exist for other states.”
		“The most important, I think, is to know their delivery model. Who’s delivering the program? Is it going to be SWCD, is it going to be, say, department of ag, or whoever?”
Wisconsin	Adaptive Management	“Defining your goals clearly.”
		“Don’t underestimate the staff it takes to support the development of the program and the time it takes to develop the program. It’s not just an off-the-shelf solution. It takes time. And other states can benefit from our existing program, but there will have to be things that will probably have to be tailored.”
		“Have clear measurement tools in mind.”
Wisconsin	Nutrient Management Plans	“I’m always good to advocate, for, like locally led voluntary conservation just in general. Because I see a lot better buy-in.”
Wisconsin	Nutrient Management Plans	“I would caution trying to adopt it one for one. But it’s gonna require a lot of local buy-in, I think, from people, and not just anti-farm or pro-farm groups or industry groups.”
Illinois	Partners for Conservation	“Keep the soil and water districts in check.… Make sure they’re following the rules and your guidelines and carrying the program out.”

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