DEEP Section 319 Request for Proposals for Non-Point Source Pollution

General Eligibility and Focus

Currently, the Connecticut Department of Energy and Environmental Protection (DEEP) is not accepting proposals for the Clean Water Act Section 319 grants. The Fiscal Year (FY) 2022 Request for Proposals was opened on October 20, 2021 and closed on December 22, 2021, proposals received during this process are currently under review.  Federal approval and grantee notice of FY 2022 awards is anticipated in summer 2022. Please sign-up to receive future notices. Section 319 of the Federal Clean Water Act is a federal program to control nonpoint sources (NPS) of water pollution. Connecticut receives funds from the U.S. Environmental Protection Agency (EPA) for Section 319 grants that can be passed onto communities, local conservation groups, and other organizations for NPS implementation projects, plans, and statewide NPS management efforts. Proposals may be submitted by any interested public or private organization. Applicants should recognize DEEP is interested in awarding project funding to five to ten larger projects rather than many small projects.

EPA defines NPS pollution as pollution that is caused by diffuse sources that are not regulated as point sources, and are normally associated with land use and runoff from the land. Common NPS pollutants include: bacteria, nutrients, sediment, salt, petroleum products, heavy metals, pesticides, and debris. These pollutants are typically carried by stormwater runoff into streams, lakes, and estuaries from diffuse land use and other activities that are not regulated as point source discharges (end of pipe). Projects intended to meet mandated requirements of stormwater permits are not eligible for Section 319 grants. However, proposals that provide stormwater mitigation above and beyond permit requirements may be considered.

Applications that include financial or in-kind contributions demonstrate a commitment to the project that is considered by DEEP when ranking applications. In recent years, DEEP was able to cover the 40% match requirement for the Section 319 NPS grant by using state dollars for other NPS projects, but commitments of non-federal match are encouraged.

An example of the application for the Section 319 Grant Program is available here: FY 2022 DEEP Section 319 Grant application. Any questions for the CT DEEP Section 319 NPS Grant Program should be submitted by email to DEEP.watershed@ct.gov

Project Priorities for FY 2022

Non-federal Matching Funds
Projects that identify match with non-federal funds will be recognized in the competitive review process.  

Watershed Based Plan Implementation Projects
Project priorities will continue to stress implementation projects in watersheds that have approved Watershed Based Plans (WBP) which lead to targeted pollutant load reductions and/or restoring impaired waters.  Implementation projects should have a clear connection to the management goals and objectives of the WBP and show progress towards attaining water quality goals.  Such implementation projects may include but are not limited to: habitat improvements, dam removal, improved stormwater runoff management, and improved agricultural practices.  

Implementation Projects Not Associated with WBPs
DEEP may consider implementation projects that are not connected to an existing WBP, but the project must target an impaired water(s).  Applicants must be able to document benefits toward pollutant load reduction and attainment of water quality standards. For implementation projects not covered under a WBP, applicants may be required to document how the 9 Elements of the Watershed Based Planning process will be addressed. 

WBP Development
DEEP will focus on WBP development for impaired waters which are prioritized in DEEP’s Integrated Water Resource Management (IWRM).  WBP development is considered an Action Plan in the IWRM strategy. DEEP may consider WBP development for impaired waterbodies that are not identified by DEEP’s IWRM strategy (see State of Connecticut Integrated Water Quality Report).  DEEP may also consider a WBP proposal when the impairment is not specific to a pollutant, or when addressing a small scale water quality problem, or for development of a protection plan as a Healthy Watershed Based Plan (see DEEP WBP website). EPA has provided detailed guidance on WBP structure and content (see EPA requirements and guidance).

Project Requirements  
The following items should also be considered by the applicant when planning a project budget and timeline.
 
EPA Clean Water Act Section 319 Grant Requirements
The proposals must comply with the EPA Nonpoint Source Program and Grants Guidelines for States and Territories issued on April 12, 2013.
 
Grant Reporting Tracking System (GRTS) and Pollutant Load Reduction Estimates  
For all 319 grants, the grant recipients (grantees) will be required to complete a spreadsheet for the EPA Grant Reporting Tracking System (GRTS). A grantee will accomplish this task by completing and submitting the GRTS worksheet to DEEP electronically. A copy of the GRTS worksheet is available at the DEEP Nonpoint Source Management page.

Pollution Load Reductions Estimates for GRTS 
For implementation projects that involve constructing structural best management practices (BMPs):

• The grantee will provide the pollutant load reduction estimates for each BMP(s) after construction.

• The grantee will identify which pollutants and their respective units of measure will be calculated for each constructed BMP. 

• The grantee will consider and specify the method to estimate the load reductions such as: site-specific calculations, peer-reviewed literature or a publicly available model (models such as the Watershed Treatment Model, EPA STEPL model or EPA Region 5 Model for Estimating Pollutant Load Reductions). The GRTS spreadsheet assists grantees to provide pollutant load reduction estimates that are required for all NPS implementation projects. 

NPS Site Report and Operation & Maintenance Plan (O&M)
For projects that involve constructing structural BMPs, the grantee will be responsible for developing a NPS Site Report and an O&M Plan. Additionally, an O&M Plan will be required for each constructed structural BMP. The plan will identify the responsible party(s) for ensuring the practices are regularly maintained and continue to function for the expected lifespan to reduce NPS pollution. The grantee will also be required to review the O&M documents with the responsible party(s) and provide appropriate training. DEEP will provide a format for the Site Report and O&M plan as part of the grant agreement.

Funding Acknowledgement
For all 319 grants, the grantee will be required to provide credit to the 319 NPS Grant Program with any publication or sign produced or distributed or any publicity conducted for the project. For projects that involve constructing structural BMPs, the grantee will be required and responsible for providing onsite signage to identify the project and provide credit to the 319 NPs Grant Program. The onsite signage will require approval by DEEP and EPA prior to installation. 

Quality Assurance Project Plan (QAPP)
For projects that are collecting, analyzing or manipulating data, the grantee will be required to develop a QAPP for DEEP and EPA approval. The QAPP must be approved before any data-related work can occur. The grantee should account for the QAPP develop and approval process when planning the project timeline. See EPA guidance for a QAPP: https://www.epa.gov/quality/quality-assurance-project-plan-development-tool 

Grant Agreement and Project Duration
DEEP will notify the selected grantees after receiving grant approval from EPA, which is typically the summer after the RFP has closed. DEEP will work with each grantee to develop a grant agreement (contract) for the project. The process is lengthy to establish a signed grant agreement, and all project work cannot be paid for until a signed grant agreement is established. The grantee should account for ample time in the develop and approval of the grant agreement when planning the project timeline.

DEEP will generally limit the project duration to a two-year contract period (longer terms for completion of larger, more complex projects would be at the discretion of DEEP).  DEEP recommends that applicants examine their needs for permits and other factors that may cause delays as early as possible.

Funding for projects that are not promptly initiated or fall substantially behind schedule may be considered for reprogramming to other Section 319 priority projects.  

If the proposed project is a multi-year or phased project, applicants should provide rough estimates of the complete cost of restoring the water body.  DEEP is receptive to a phased approach, with each year’s funding allotment representing an individual phase.  However, applicants should recognize that each year or phase of funding will be competitive.  DEEP does not automatically agree to fund future phases by committing to the initial phase.  Proponents shall establish a schedule for the additional phases and costs needed to complete the project, which will be considered in the proposal evaluation for this fiscal year.
 
Any questions for the CT DEEP Section 319 NPS Grant Program should be submitted by email to DEEP.watershed@ct.gov

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Content Last Updated May 25, 2022