Section 319 funding round

The MPCA anticipates about $1.4 million will be available this round for projects that will reduce nonpoint source pollution in Minnesota’s lakes, rivers, and streams. Funding for selected projects will be provided by Section 319 grant funds, contingent upon Congressional appropriation.

Closed: Application deadline was March 2, 2018

Posted application materials are subject to updates. Applicants should review posted questions and answers and look for addenda that may affect the process.

PDF icon 2018 Request for Proposals - Federal Clean Water Act Section 319 grant program (wq-cwp7-20c)

The RFP assists applicants in applying for and managing state grants. This document describes the federal Clean Water Act Section 319 (Section 319) Grant, including information on who may apply for funding, the funding priorities for the federal Fiscal Year 2018 grant round, match requirements, and other information that will help applicants plan their project and submit a competitive application. (last update 1/26/2018)

Microsoft Office document icon 2018 application form - Federal Clean Water Act Section 319 grant program (wq-cwp7-20d)

Microsoft Office document icon Section 319 sample agreement (wq-cwp7-20i)

Sample agreement for federal Section 319 funding between the Minnesota Pollution Control Agency and a project sponsor.

Background information

PDF icon Overview of MPCA nonpoint source funding (wq-cwp1-16a)

A presentation on funding available through MPCA for nonpoint source water pollution projects: Clean Water Partnership loans and Clean Water Act Section 319 grants.

PDF icon Federal Section 319 funding (wq-cwp1-16)

MPCA’s federal Clean Water Act Section 319 (Section 319) grant program provides funding and technical assistance to groups and individuals who work with citizens to develop locally based solutions to nonpoint source (NPS) pollution that reduce NPS and implement total maximum daily load (TMDL) solutions in critical source areas. (Last update 1/25/2018)

Grant application questions and answers

This is the agency’s most current list of questions and answers and addendums about the federal fiscal year 2018 Clean Water Act Section 319 grants. This is the only source of questions and answers and addendums. It is an applicant’s responsibility to check the MPCA website for the most current information regarding a grant, including questions and answers or addendums.

Applicants who have any questions regarding this RFP must email questions to 319.Grant.PCA@state.mn.us, subject line: “FFY 18 Section 319 Grant,” no later than 4:30 pm Central Time on Tuesday, February 27, 2018. Questions and answers will be posted here within two working days of receipt.

A final list of all questions answered during the open Question and Answer period will be posted on the MPCA website by 4:30 pm Central Standard Time on Thursday, March 1, 2018.

MPCA personnel are not authorized to discuss this RFP with applicants. Contact regarding this RFP with any MPCA personnel may result in disqualification.

Q24. I am unable to embed a map into the grant application. Does the MPCA accept maps as an attached document?
A24. Yes, maps are attached separately and submitted with your application.

Q23. With the reduced 319 funding available this year, how many awards are anticipated and what would be the average award total? In years previous, what is the average number of awards and average award amount?
A23. While Section 319 funding is always dependent on Congressional appropriation, we have historically estimated that the awards will be at the same level as the previous year’s funding. Last year’s final appropriation was $2,776,412. There were 24 applications, ten were funded, with an average grant award of $298,222.

Q22. To clarify Q1 on the application regarding the presence of an EPA-approved nine-element watershed-based plan, is it true that no entity in Minnesota meets this criteria and therefore no application is eligible for the 30 points on the scoring rubric? Our EPA-approved TMDL covers the entire watershed, not just select waterbodies.
A22. That is correct, no entity in Minnesota meets this criteria at this point. Please see A21 and A2 on this page for complete information.

Q21. Is the EPA-approved nine element watershed based plan the same as a EPA approved TMDL?
A21. No. At this time, there are no EPA-approved watershed based plans in Minnesota. The EPA requires a specific plan that meets all nine-key elements and would be named an EPA watershed-based plan (full details can be found here: https://www.epa.gov/nps/handbook-developing-watershed-plans-restore-and-protect-our-waters). Although there are no watershed-based plans in Minnesota at this time, the EPA required this question for this and future funding rounds.

Q20. I would appreciate clarification on questions 4-6. We are considering modifications to a stormwater pond to improve TP removal. The pond and conveyance are within a MS4 community. Currently a stormwater pipe discharges to the pond, and the pond outlet discharges back to the conveyance system. Is the pond considered part of the conveyance system and therefore ineligible?
A20. As stated in the Federal Clean Water Act Section 319 Funding fact sheet, if this activity is a permit requirement it is not eligible (p. 2). If the stormwater pond is manmade as part of the conveyance system, it would not be eligible. If the pond in question existed prior to the conveyance system or is a wetland then it may be eligible.

Q19. I want to make sure that I’m calculating the 40% match correctly; if I need $240,000 grant cash to complete the work that is needed, how much in-kind match would be required?
A19. According to the RFP, “Grantees are required to contribute at least 40% of the total project cost as a cash or in-kind match. The grant award may cover no more than 60% of the total project cost. For example, if the total project cost were $100,000, the maximum amount of grant funds this project could receive would be $60,000; grantee must provide a match of at least $40,000.” (p. 2). If you’ve determined that the grant will fund $240,000 of the project, the total project cost would need to be at least $400,000. Minimum match would be cash or in-kind of at least $160,000.

Q18. Can the EPA 319 grant fund novel BMP designs if they are part of one of the major BMPs listed in the approved WRAPS plan? We want to look at a new approach to improve the performance of a certain BMP type for phosphorus removal.
A18. Yes, if the practices are an iteration of a BMP design listed in a TMDL, WRAPS or local water plan, they are considered eligible if they will improve water quality. Please be advised that the Section 319 Grant program no longer funds research projects.

Q17. Could 319 funds pay for equipment installed to measure the stability of the slope during and after BMP installation? For up to 2 or 3 years after BMP installation?
A17. According to the Federal Clean Water Act Section 319 funding factsheet, “Equipment*, including monitoring equipment, less than $5,000 per unit, required specifically to perform work plan duties and pre-approved by the MPCA.” If the equipment was less than $5,000, it would be considered on a case-by-case basis.

Q16. How much and what type of data is needed to prove a critical area is contributing NPS? A proposed critical area was monitored, modeled and shown to be an unstable slope but sediment contribution and loading rates was not modeled or measured? Is the former monitoring and modeling sufficient proof of a critical area?
A16. According to the Federal Clean Water Act Section 319 funding factsheet, the “critical source areas are geographic areas identified by a watershed model or similar tool (and ultimately confirmed by field observation and/or confirmed by local partners or stakeholders) that show areas disproportionately contributing pollutant loads or excess flow to surface waters.” It does not specify a threshold of data or modeling; however, building clear connections from the proposed project to the critical area makes a stronger application.

Q15. Would a slope failure adjacent to a river be considered a non-point source pollution and would a slope stabilization project be eligible for funding?
A15. Yes, a slope failure adjacent to a river is a nonpoint source. Streambank stabilization can be an eligible activity, if identified in a TMDL, WRAPS, or other local water plan as a strategy to improve water quality.

Q14. Could a 501(c)(3) established for the restoration of an impaired water body apply for 319 funds?
A14. Yes, according to the According to the Federal Clean Water Act Section 319 funding factsheet, local nonprofit organizations are one of the eligible entities.

Q13. In the application form, Question 4a “Please fill out table for each waterbody”. There is no space for entering the Lake ID or stream AUID and how do I add additional columns/rows for additional waterbodies?
A13. The application form has been updated to allow for these additional fill-ins. There is a blank for the Lake ID or stream AUID and you may add additional lines in the table by hitting enter at the end of the line. We apologize for the inconvenience.

Q12. I understand that NPDES permitted feedlots are not eligible for practices using 319 funding. If a feedlot does not require a NPDES permit, are there any other animal unit restrictions for using 319 funds? Are Waste Facility Closures (NRCS FOTG-Practice Code 360) eligible practices under the 319 program?
A12. According to the fact sheet (Federal Section 319 funding wq-cwp1-16, p. 1) feedlots not covered under a NPDES permit are eligible, if they have a Manure Management Plan, which is an additional restriction as per your question. If the Waste Facility Closure is at a permitted site, it is not eligible. If the Closure is because of an enforcement action, it is not eligible. Otherwise, Waste Facility Closures can be eligible as long as the existing Waste Facility is at risk of negatively impacting water quality. “In general, the likelihood of water pollution caused by these facilities increases with proximity to surface waters like lakes, streams or waterways, or in areas with shallow aquifers easily contaminated by seepage of pollutants from the surface. …. Partial confinement facilities and open lots have areas where precipitation can come into contact with manure. Runoff may carry manure away to surface waters, or seep into the soil. Manure is sometimes stored in areas where runoff to surface waters or seepage to ground water may occur. This poses the same types of hazards to water quality as animal confinement areas.” (NPMSP, 2013, pp. 7-160/161; https://www.pca.state.mn.us/sites/default/files/wq-cwp8-15.pdf).

Q11. Are letters of support and/or board resolutions required to be submitted with the application?
A11. No, there is no requirement in the RFP for letters of support or board resolutions.

Q10. Would this be considered state or federal money if used as match to leverage other, non-MPCA, grant sources.
A10. The grants are considered federal dollars and can be used to leverage other state and local dollars. Other federal funds cannot be used as match for Section 319.

Q9. Is this considered a federal source or a state source of money since it comes from the federal government, but through state hands?
Q9. Section 319 grant dollars are considered federal dollars.

Q8. Are state loan dollars that are used for septic system upgrades in the project area eligible project match?
A8. No, match dollars must match projects that are eligible for the 319 funds and supplement the work of proposed project.

Q7. If we have a biotic impairment and the source of impairment are stressors that are not themselves impairments (yet), can you apply for 319 funding to address these stressors? Examples of these stressors include lack of habitat/poor habitat, nitrate, turbidity/TSS, dissolved oxygen, temperature.
A7. Yes, the biotic impairment can be addressed through identified stressor pollutant(s) as described in the TMDL study. If the stressor is identified and a strategy is suggested in another water plan, such as a WRAPS or TMDL implementation plan, it may be addressed with Section 319 funds.

Q6. If you intercept non-point runoff before it enters a pipe, but it’s within an MS4 community with required reductions under a TMDL, is that project eligible?
A6. Yes. The stormwater runoff intercepted before entering a conveyance system of a regulated MS4 may be eligible.

Q5. If the answer to question Q4 is yes, then can you explain how non-point source runoff that is upstream of a pipe is different than the same runoff after it enters the pipe?
A5. Stormwater runoff before it enters a conveyance system of a regulated MS4 is nonpoint source. Once it enters a conveyance system of a regulated MS4, it becomes point source because it is governed under a permit.

Q4. If non-point source runoff enters a pipe within an MS4 community, is it no longer eligible for a grant to treat that water with a BMP?
A4. A BMP within the stormwater conveyance system of a regulated MS4 community is not eligible for Section 319 funding because the conveyance system is governed by a permit.

Q3. If an EPA-approved TMDL covers more than one water resource, are we allowed to address more than one HUC12 if these HUC12 are within the HUC8 we are trying to restore? For example, our TMDL covers 4 small streams that impact the River. The 4 small streams and the River are all listed for the same impairments.
A3. For this round, there is no limit to the area as long as the BMPs directly affect the TMDL. In Exhibit A, 2b. asks the applicant to describe the distance of the BMPs from the TMDL. Ideally, a shorter distance is preferred.

Q2. Question 1 on the application asks if the watershed has an “EPA-approved watershed based plan.” The EPA-approved TMDL is just for one lake, however, the implementation strategies, evaluation, monitoring etc.  are incorporated into the state-approved watershed plan that together with the TMDL meet the nine elements. Should I answer “Yes?”
A2. No. At this time, there are no EPA-approved watershed based plans in Minnesota. The EPA requires a specific plan that meets all nine-key elements and would be named an EPA watershed-based plan (full details can be found here https://www.epa.gov/nps/handbook-developing-watershed-plans-restore-and-protect-our-waters). Although there are no watershed-based plans in Minnesota at this time, the EPA required this question for this and future funding rounds.

Q1: Can you confirm the eligibility requirements for this round of 319 funding? We are interested in working in watersheds that are identified as impaired, but do not yet have an approved TMDL plan or WRAPS completed. Are these locations eligible for funding or not?
A1: As per the request for proposal, “Eligible projects must be in an identified critical area of the watershed and have an EPA-approved total maximum daily load (TMDL) for the waterbody. The projects must have an EPA-approved TMDL by Friday, March 2, 2018.” (p. 2)