Clogging of subsurface flow (SSF) treatment wetlands from excess biofilm growth is a design problem for which only empirical guidelines exist. A method is proposed to systematically analyse this type of clogging as a design tool. In recognition of the physical reality that most SSF treatment wetland processes are a function of biofilm surface area, a Damköhler number (Da) definition based on aggregate specific surface area is used to investigate a method of predicting clogging induced by heterotrophic biofilms growing on treatment media.