§319 Watershed Project Grants

Overview

This page is intended to guide users through the watershed proposal process. We highly recommend that you review all of the sections before submitting your watershed project proposal. Friends of the Cheat published a Watershed Project Implementation Guide, supported by AGO funding.This guide describes in detail, successful methods and procedures used to implement watershed projects. The focus is on AMD projects; however it is useful for all types of watershed project.

In 2014, USEPA revised its §319 program guidance. In late 2016 USEPA required that all mining remediation construction projects include a contingency plan (CP). This requirement is effective as of March 2017 - it includes projects going to construction in 2017.

You should discuss your proposal with the Basin Coordinator in your region prior to any submissions. LOIs and full proposals are accepted from September 30 - March 31. The deadline for submitting the full workplan for your watershed project proposal is May 1. AGO proposals have no specific deadline; they depend on availability of funds and the announcment can be made at anytime during the federal fiscal year.

The NPS Program emphasizes management strategies and programs to address nonpoint pollution problems. These management programs are balanced between two priorities. One is to implement, on a statewide basis, the overall NPS Program, which includes technical and financial assistance, staff, planning and educational efforts. These efforts are funded through nonpoint funds. A second is narrower and involves targeting specific watersheds to improve degraded water quality. This funding is referred to as watershed project funds. This is designated for specific projects intended to restore impaired watersheds to water quality standards. All projects must follow USEPA guidelines established for the use of §319 funds.

Before project grants can be approved a watershed based plan (WBP) must developed through local stakeholder involvement. Projects within a watershed must be designed to implement the plan. The WBP will identify all the partnerships, projects, funding sources, follow-up monitoring, and timelines. WBPs can be based on a watershed strategy, a TMDL (or both), and more clearly defines the specific responsibilities of each stakeholder group in implementing efforts to restore a watershed to compliance with water quality standards. The ultimate goal of §319 WBPs and projects is to remove the imparied water body (however it was listed) from the 303(d) list. Once your plan and all of its projects are complete your organization must work closely with WVDEP's NPS Program, TMDL Program and WAB to evaluate the stream for de-listing

All grant recipients must have a FEIN, DUNS and a W-9 (Tax payer ID number), and be able to verify that the appropriate accounting, procurement and purchasing procedures, as well as other business and organizational standards (e.g. board of director charter, budget documents, meeting minutes etc.) are in place. We use a financial history checklist to verify the capacity of an organization to manage federal grants.

See Also

• Is The Stream Restored?

  When a watershed based plan (WBP) is complete or nearly so, it must be determined if the targeted stream(s) within the WBP are restored.

• Total Maximum Daily Load (TMDL)

  A Total Maximum Daily Load is a plan of action used to clean up streams that are not meeting water quality standards.

• Watershed Based Plans

  Development of a watershed based plan is the key step in the efforts to restore our rivers and streams from the impacts of nonpoint sources of pollution.

• Water Quality Standards

  The Clean Water Act required states to develop water quality standards to protect all water uses and to designate uses for each waterway.

Contents

• Developing Project Proposals
• Project Proposal Format
• Background Information
• Goals, Objectives, and Project Description
• Monitoring
• Milestone Schedule
• Budget and Match
• Reporting Requirements
• Final Inspection and Final Report
• Grant Awards and Timelines
• Request for Funds
• Timely Reports and Reimbursements

Resources

• §319 Program Guidelines

  Highlights of the revised §319 guidelines.

• Additional §319 Grant Opportunities

  Additional Grant Opportunities (AGOs) can focus on nonpoint issues in water bodies that may not be impaired or provide monies for special projects not typically funded through watershed project grants.

• Applying for and Administering CWA Section 319 Grants

  The purpose of this manual is to provide an overview of federal requirements that will help guide state and territory nonpoint source agency staff when applying for and administering grants awarded under Section 319(h) of the Clean Water Act (§319).

• Submit a Letter of Inquiry

  A web-based form to submit a Letter of Inquiry for your §319 proposal

• Watershed Project Implementation Guide

  WPIG describes the methods and procedures that Friends of the Cheat (FOC) use to implement watershed projects.

• West Virginia's §319 Contingency Plan Policy

  For every mining remediation project funded by §319, there must be a contingency plan.

• What Is an LOI?

  What should be included in a letter of inquiry?

Timothy Craddock, NPS Program Coordinator
West Virginia Department of Environmental Protection
601 57th Street SE
Charleston, WV 25034
Phone: (304) 414-3868
Email: DEP319@wv.gov

Additional Contacts

• Basin Coordinators
• Watershed Improvement Branch Staff Contacts

Developing Project Proposals

Project proposals seeking funding from §319 funding must follow specific guidelines in order to be eligible for such funding. The project must support the NPS Program in accomplishing its goals and objectives as stated in the Management Plan. The project must also meet all the requirements of the CWA and USEPA's guidelines for §319.

Organizations eligible to recieve funding include but are not limited to the following:

• State agencies
• Cities, counties and local governments
• Public colleges and universities
• Non-profit entities with 501(c)(3) status
• Other non-governmental organizations

Proposal Development Resources

• EPA Region 3 Guidelines for CWA §319(h) Workplans

  This document is to ensure that USEPA regional reviews of Clean Water Act §319(h) workplans are consistent among reviewers and with CWA §319(h), the 2014 Nonpoint Source Program and Grants Guidelines.

• West Virginia NPS Management Plan

  ​​​Clean Water Act §319 guidelines require that all State NPS Programs revise their Nonpoint Program management plan every five-years.

Eligible Projects

• The project contributes to the implementation of our Management Plan.

• The project is located in a watershed with a TMDL or in a watershed listed on the 303(d) List with a TMDL scheduled.

• The project addresses nonpoint source water quality impairment. The goal of the project must be to reduce the loading of one or more nonpoint pollutants.

• BMP implementation, education, and load reductions are the major purposes of most NPS projects. Efforts to publicize the project and get local stakeholder involvement are required.

All watershed project proposals must be a part of a comprehensive watershed based plan (WBP). Requests for proposals are targeted toward priority watersheds where a WBP has been or is being developed.

Ineligible Projects

Any activities that control pollution from point source discharges, and are regulated by NPDES permits. These include sewage treatment plants, industrial facilities, concentrated animal feeding operations (CAFOs), active mines or mines abandoned after 1977, urban storm water activities required by a MS4 Phase I or II permit, and construction activities greater than one acre.

Project Criteria

• Linked to the objectives of the NPS Program and corresponding WBP.

• Includes appropriate and effective measures of success.

• Recruits and facilitates partnerships, support and involvement from governmental entities, educational institutions, business and citizens groups.

• Obtains funds and develops efforts to continue nonpoint management after §319 funding ends.

• Project is cost effective. Funds are targeted to provide maximum control. Requested funds for administration and other non-implementation activities are kept to a minimum and cannot exceed 20%

• Entity requesting §319 funds must support the project with a 40% match of the total project cost. In-kind support from the requesting entity is acceptable. The 40% match cannot come from other federally funded programs or funds.

• Incorporates an effective public education and outreach component.

• Project activities can be achieved within an identified and reasonable time period.

Cover Page

The cover page identifies the project, the “lead agency” and the budget summary. The project title, located near the top of the page, should be consistent throughout the entire proposal. There should be an identification that this proposal is for a CWA §319 project.

State the entity (lead agency) that is implementing the project and requesting the money and thier contact information (organization name, mailing address, phone and email). Include the date of submittal and a budget summary. The budget summary lists only the requested amount of §319 funds, the amount of match and the total project amount. Finally, include the 303(d) stream list code and TMDL sub-watershed (SWS) number.

Proposal Format Resources

• Example Proposal Cover Page

Project Summary

The project summary is a brief description (abstract) of the project. The project summary should be presented in narrative form, not as a list. Be brief - each component should only contain a few sentences.

The summary should provide the following information:

• Background (overview and problem descriptions)
• Goals and objectives
• Methods employed

Watershed Information and Location

All proposed projects must provide the following information:

• Name of the specific sub-watershed and its HUC-code
• TMDL sub-watershed (SWS) number and 303(d) list stream code

Submitting a map with the proposal is very helpful.

Background

This section lays out the foundation for the entire proposal. From this section any reviewer should be able to learn the “where, what, when, why and who” of the entire project. This section establishes the need for the project, its justification and the credibility of the organization applying for the funds.

Background Information

Background information on the watershed is important in order to set the nonpoint problem and the justification for the project. Examples of watershed background information can include but is not limited to: ecology, geology, land uses, water quality, TMDL status, economic and recreational uses and public support within the watershed.

The applying entity must describe their organization and provide contact information. Briefly describe the purpose and goals of the organization and any operational information that may be pertinent to the proposal. A very brief description of past accomplishments that may illustrate the competency of the organization to successfully implement the project should be included.

Nonpoint Problems and Sources

§319 incremental projects must be focused on solving some kind of nonpoint pollution problem. In order to set achievable goals and objectives anyone submitting a proposal must have prior knowledge of the problems and their causes. Clearly state what the problem is and how it affects water quality. Describe the sources or causes of the nonpoint pollution and how this project will address those aspects.

Type of Project

Nonpoint projects should address the focus areas of the program. Briefly describe the type of project being proposed and how it relates to the NPS focus areas. For example, is the project an agricultural project intended to protect riparian zones by fencing livestock out of the stream? Or, is it an acid mine drainage project using passive treatment systems to raise pH and remove metals? In other words, this part should not be a detailed description of the project, which will come later. This part is only intended to categorize the project and its area of focus.

Lead Agency and Contacts

The “lead agency” is defined as the entity that is coordinating or implementing the project. The NPS normally works through some kind of government agency however it is not necessary that the “lead agency” be a government agency. However any entity that receives program funds must be listed as a registered vendor with the State of West Virginia. Private businesses are not eligible for applying for §319 funds. Not for profit groups may apply but it helps facilitate the process if they coordinate through a local Conservation District or government.

Goals and Objectives

This important section outlines the anticipated load reductions, educational outputs and restoration benefits of the project. USEPA guidelines for §319 grants requires that each proposal estimate the nonpoint load reductions the project should achieve. When models are used to make these estimates the name and description of the model must be included. Any project that seeks to reduce nutrients, restore and protect streambanks to reduce sediment, or reduce the influence of pollution from metals or acidity must provide a numerical goal for the project. In some cases a project may have multiple load reductions and these should be accounted for. Load tracking tables are a useful tool and should be added to your project proposal and watershed plan when possible.

If applicable estimate the acres of wetlands restored or created, the feet of streambank restored or stabilized and the length of stream restored. All benefits expected from the project should be explained. Goals for the educational components of the project should be noted. This may include, but is not limited to, the number of workshops planned; the number of people trained or educated the number of public relations/education events planned, etc.

Resources

• Pollutant Loads

  Information for calculating pollutant loads.

• Watershed Based Plans

  Development of a watershed based plan is the key step in the efforts to restore our rivers and streams from the impacts of nonpoint sources of pollution.

• Load Tracking

  Example document of load tracking tables showing BMPs by goal year and load reductions by pollutant.

Project Description

In this section the applicant defines the project site and the activities that will occur with the implementation of the project. The dimensions of the site, problem area or the area to be placed under management should be given.

Resources

• Workplans

  A workplan is an outline of all tasks that need to be completed in order to finish an entire project.

Project Work Plan

Describe the activities, structures, BMPs and technologies employed to implement the project. This should provide enough detail to illustrate that a viable plan has been developed. Submitting drawings of a conceptual design is optional and may be helpful but do not submit blueprints unless requested. Requesting §319 funds for engineering and design is permitted.

Partner Involvement

Describe how the various partners involved in the project will contribute to its completion.

Education and Outreach

Describe any efforts to educate the public, public officials or industry by the project. If applicable and agreeable by the landowner a sign designating the project and the sponsors (i.e. NPS, US EPA and any partners) should be placed at the site during the project and if possible for a short period afterwards.

Monitoring

In this section the applicant must describe how the success of the project will be measured and reported. All entities receiving §319 funds must file semi-annual reports to the NPS Program. The measures must relate to the goals and objectives of the plan. For water quality projects monitoring for load reductions or water quality improvements may be required depending on the project. In addition to monitoring, data gaps may be fillied in using a vareity of models.

A summary of all monitoring results must be submitted to the NSP on a semi-annual bases on or before the appropriate reporting time. All water quality data must be entered into the WQX exchange.

Nonpoint projects must have reductions in pollutant loads but can also include:

• Measurable improvement in the chemical, physical or biological integrity of the stream, river or other water body.
• The number of developed plans for erosion and sediment control, nutrient management, pesticide management, etc.
• Photographs or videos to document improvements
• Number of BMPs installed.
• The number of presentations, workshops, trained individuals, etc.
• Improvements in fisheries.

Quality Assurance Project Plans

In accordance with 40 CFR 30.54 and 31.45, the recipient must develop and implement quality assurance and quality control procedures, specifications and documentation that are sufficient to produce data of adequate quality to meet project objectives. The Quality Assurance Project Plan (QAPP) should be prepared in accordance with EPA QA/R-5: Requirements of Quality Assurance Project Plans. QAPPs must be submitted to the WVDEP-WIB at least 90 days prior to the initiation of data collection or data compilation. It must be approved by WVDEP and the USEPA.

Impaired streams can be removed from the 303(d) list if the data shows water quality standards have been achieved. However, additional steps are needed to ensure de-listing.

Monitoring and QA Resources

• WQX Exchange

  The Water Quality Exchange (WQX) is the mechanism for data partners to submit water monitoring data to EPA.

• EPA QA/R-5

  Outlines requirements for QA plans for organizations that conduct environmental data operations for EPA through contracts, financial assistance agreements, and interagency agreements.

• Pollutant Loads

  Information for calculating pollutant loads.

• 40 CFR 30.54 and 40 CFR 31.45

  40 CFR 30.54 / 40 CFR 31.45 - Quality assurance

• Integrated Water Quality Monitoring and Assessment Report

  The West Virginia Integrated Water Quality Monitoring and Assessment Report (IR) fulfills the reporting requirements under the federal Clean Water Act, Section 303(d) to provide a list of impaired waters and Section 305(b) to provide an overall assessment of West Virginia's waters to the U.S. Environmental Protection Agency.

The milestone schedule provides an estimated timeline for the life of the project. The milestones include all project activities and interim steps needed to implement the project. The schedule should include milestones for the planning, development, construction, evaluation and reporting of the project’s implementation. The milestone dates are only projected dates based on an anticipated grant award. Those dates may change depending on the timing of the grant award.

Milestone Resources

• What Are Milestones in Project Management?

  A project milestone is a management tool that is used to delineate a point in a project schedule.

• Milestone Schedule

  Information on milestone schedules from Project Management Knowledge.

Budget

A detailed budget must be provided that shows a breakdown of anticipated expenses by category and by §319 funds and matching funds. The most effective format for showing the budget is a spreadsheet format with rows being the budget categories and columns showing the funding sources and totals. The maximum §319 reimbursement for a project is 60% of the total project cost. There must be a 40% non-federal match for each project. The match is calculated from the total project costs not from just the amount requested.

The budget must be included in the body of your proposal (workplan) and submitted as a seperate Excel file.

Budget Resources

• §319 Budget Calculator

  A spreadsheet tool that will help you calculate your project's match.

Budget Categories

Budget categories are dependent on the project type and specifics but may include:

• Personnel
  List the position titles (not names of individuals) and the amount of anticipated time that will be contributed to the project. No position included in this item can be a federally funded position. Personnel costs should be divided between administration and implementation or project management.

• Supplies
  Identify supplies that are over $500 or are significant to the project such as monitoring supplies.

• Equipment
  Identify any equipment purchased or leased whose value exceeds $500. Donated equipment may be used as match.

• Contractual
  List all anticipated costs for services to be contracted. This would include construction costs even if construction will be done “in-house”.

• Travel
  Any entry for travel must pertain to the project implementation within the state.

• Operating Costs
  Include any indirect/overhead items such as building space, utility costs, incidental supplies, insurance etc.

• Other
  Include any additional categories specific and necessary to the project.

Miscellaneous

Other information can be included in the proposal if it is necessary or contributes significantly to the proposal.

Some examples of other information are:

• Literature Cited
  Studies or other references that are quoted or used to support statements of fact should be listed.

• Obstacles
  Anticipated obstacles or difficulties could be mentioned in the background section; for example: local resistance to installing BMPs could be used to justify an educational component.

• Other Efforts
  Providing a connection between a § 319 project and other state, private or federal projects intended to improve water quality from nonpoint source pollution in the watershed should be explained.

Non-Federal Match

Many federal, state and foundation grants require a match. Although the percent match required for each grant may vary (25, 40, 50 percent etc.), many of the rules governing what can be counted as a match are consistent. Since these rules tend to vary by funding source it is always a good idea to check with the funding source first.

Note: Match percentage is based on the total cost of the project.

There are two kinds of match, a cash match and in-kind match. A cash match is the direct project expense you or your non-federal partner provides as your contribution to the project – your cash expenditures for costs related to this specific project, such as project-related staff salaries, consultant’s fees, equipment rentals and travel costs. In-kind match are materials and services, secretarial services, space and utilities, equipment and technical assistance provided by your organization or donated by a non-federal third party specifically for this project.

Matching Resources

• Match Guidance

  This guidance is an attempt to identify some of the basics for tracking matching funds or in-kind matches.

• Match FAQs

  Frequently asked questions regarding matches.

Definition of Non-Federal Share

A non-federal share is the portion of the total costs of the program provided by the grantee agency in the form of in-kind donations or cash match received from third parties or contributed by the agency. In-kind contributions must be provided and cash expended during the project period along with Federal funds to satisfy the matching requirements.

Example Match Determination

• Project funds requested [$125,000]
• A federal 60% contribution is [$125,000 ÷ 0.6] = $208,333
• A 40% match is [$208,333 x 0.4] = $83,333

Administative Costs

The administrative costs may not exceed 10 percent of section 319 funding (CWA section 319(h)(12); 40 CFR 35.268). Administrative costs include salaries, overhead, or indirect costs for services provided and charged against general activities and programs carried out with the grant.

The costs of enforcement and regulatory activities, education, training, technical assistance, technology transfer and demonstration projects are not subject to the 10 percent limitation. This requirement does not apply to a PPG that includes section 319 funds (40 CFR 35.134(c)).

Applicable Laws and Regulations

• 40 CFR 35.268

  40 CFR § 35.268 - Award limitations

• 40 CFR 35.134(c)

  40 CFR § 35.134 - Eligible recipients

Reporting Requirements

All state §319 Programs report to the USEPA through the Grants Reporting and Tracking System (GRTS). Projects are tracked within the GRTS using multiple fields and GIS files. Specific practices installed are matched to water quality improvements in a specific reach of the stream or portion of the watershed. The minimum reporting unit is the SWS scale.

In order to comply with the USEPA's reporting requirements all §319 grant recipients are required to report their progress to the NPS Coordinator semi-annually. The goal of the report is to tell the story of a project. It must contain elements (milestones, loads etc.) that allow for quantitative tracking.

Reporting Resources

• EPA Grants Reporting and Tracking System

  319 Grant data entry for for states and territories

• §319 Financial Report Template

  Save this spreadsheet and use it to submit a seperate financial summary report.

• Summary of §319 Reporting Requirements

  A downloadable PDF summary of §319 Reporting Requirements

Reporting Deadlines

§319 grants are timed to the federal fiscal year. The first semi-annual report documents progress and activities between October 1 - March 31 and is due May 1. The second semi-annual report documents progress and activities between April 1 - September 30 and is due November 1. If reports are not submitted in a timely manner current and future grant awards will be compromised for your organization and others. Reporting matters!

When the project is completed the Basin Coordinator, NPS Coordinator or designee conducts a final inspection with the local project manager. In addition to the inspection a final report is required. The final report is a summary of the projects life cycle. It is submitted to WVDEP and USEPA, and becomes part of the project record in GRTS.

Final Inspection

Final inspections must be completed for each project in which BMPs are implemented. The site visit is scheduled with the regional Basin Coordinator, NPS coordinator or a designee. The simple final inspection form (FIF) is completed on-site and emailed to the NPS Coordinator. Photos showing as-built conditions should also be included. Review the example included here for more information.

The inspection should occur prior to completing the final report. The FIF can be submitted seperately or with the final report.

Final Inspection Resources

• Final Inspection Form (FIF)

  Final Inspection Form (FIF) as a fillable PDF

• Basin Coordinators

  List of watershed basin coordinators in West Virginia.

Final Report

When the project is complete the Basin Coordinator, NPS Coordinator or designee performs a site visit and final inspection (FI) with the local project manager.Final inspections occur only on construction projects with BMP implementation. In addition to the inspection a final report is required.

The final report summarizes the project and its results (e.g. goals and objectives accomplished, pollutant load reductions, expenditures, challenges etc.). Final reports are also required for non-construction projects but may not include the same elements.

The final report is similar in style/format to USEPA Success Stories, and must contain the following information:

1. Title/Cover page
2. Brief overview/summary/abstract - that includes the location description
3. Problem description (When was the stream listed)
4. Project highlights (What was accomplished; how does that compare to the workplan)
5. Results (BMP numbers/types, component dimension, area treated, load reductions, outreach goals etc.)
6. Partners and funding (Table comparing orginnal budget to what was actually spent)

Final Report Resources

• Example Final Report (Construction)

  Example final report for a construction project. Lambert Run Passive Treatment Installation: Site 7 Lambert Run

• Example Final Report (Non-Construction)

  Example final report for a non-construction project. West Virginia Safe Water

• USEPA Success Stories

  Success Stories About Restoring Water Bodies Impaired by Nonpoint Source Pollution

Request for Funds

§319 grant funds are reimbursable only. You must provide adequate justification for any request for funds reimbursement. Grant recipients must submit the request for funds (RFF) form along with supporting documentation in order to obtain reimbursement for allowable expenses. Supporting documentation includes a complete breakdown of expenses incurred (invoice) during the specified budget period. The budget period is not the same as the performance period.

Read all instructions and become familiar with allowable cost before submitting your RFF form. The RFF must be submitted within your grants performance period in order to be eligible for reimbursement. The funding period is not the same as the grant's performance period. Typically it is a much shorter window and occurs when transactions take place. Your organization should pay the bills prior to the end of the grant performance period.

All grant recipients must have a SAM/UEI, FEIN, DUNS, W-9 (Taxpayer ID number), Oasis vendor number, and be able to verify that the appropriate accounting, procurement and purchasing procedures, as well as other business and organizational standards (e.g. board of director charter, budget documents, meeting minutes etc.) are in place.

Reimbursements

All reimbursements must have an itemized invoice attached that matches the amount on the reimbursement form. Backup documentation must support both documents. Examples of supporting documentation include: Anything that you usually send (e.g. QuickBook reports, budget analysis, consultant reports, match documentation, updated workplan, receipts, cancelled checks, signed award etc.).

Fund Request Resources

• WVDEP Sub Grant Invoice

  Request for funds form (Excel spreadsheet)

• Sub Grant Invoice Funds/Reimbursement Instructions

  To ensure consistency with all requests, please follow these instructions.

• Procurement Standards

  Title 2: Grants and Agreements Part 200 -- Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards -- Subpart D — Post Federal Award Requirements

• Financial History Checklist

  Checklist of financial information required to be in place.

• §319 Grant Conditions

  General grant conditions for §319

• 2 CFR Part 200

  Specifics regarding allowable costs. For more details, see Subpart E, "Cost Principals" and "Provisions for Selected Items of Costs".

• Sub Grant Payment Procedures

  We have amended the payment processing procedures to comply with the revised guidelines of the State Auditor's Office.