Priority Area 10:
Clean Water Act (CWA) Section 319 Grant Reporting

 

Congress amended the Clean Water Act (CWA) in 1987 to establish the Section 319 Nonpoint Source Management Program. Under the program, state, territories, and tribes receive grant money to support a wide variety of activities including technical assistance, financial assistance, education, training, technology transfer, demonstration projects, and monitoring to assess the success of specific non-point source implementation projects. More information on the allocation of these grants is available online. 

Several states made recommendations to modify Section 319 reporting requirements.  EPA’s response to these recommendations is two-fold.  At the national level, EPA’s Office of Grants and Debarment (OGD) issued an Agency-wide state grant reporting policy (PDF) (6pp, 65K) that applies to CWA Section 319 reporting, as well as all other EPA grants and assistance agreements.  Among other things, this policy:

• Reduces quarterly grant progress reports to a frequency of no greater than semi-annually, except in instances of poor performers or where regions and states have otherwise agreed.  For Section 319 grants, the policy states "frequencies may range from annual to semi-annual depending on fund utilization and other relevant factors."

• Reduces financial status reporting requirements to no more than annually.

Furthermore, the grant reporting policy addresses reporting requirements within a state’s Performance Partnership Grant (PPG), which sometimes includes Section 319 grants.  If a state uses a PPG and the PPG encompasses only those grants/agreements with annual reporting requirements, then a progress report is due annually (except in instances of poor performance or where otherwise agreed).  If the PPG encompasses some grants/agreements with a semi-annual frequency and some with an annual frequency, then the state has the option to either a) report semi-annually on the entire PPG or b) report semi-annually on only those portions of the PPG that require twice yearly reporting. 

The draft policy was circulated for review by members of the Environmental Council of the States’ (ECOS) State Grants Workgroup.  See Priority Area 16 for more information. 

In addition to this national response, EPA’s Regions responded to the recommendations of their respective states:

• Recommendation W15 - Annual Summary of Quarterly Section 106 and 319 reports – Maryland recommended eliminating annual summaries of the Section 106 and 319 quarterly reports.  Region 3 clarified that Section 106 annual summaries are no longer needed and Section 319 annual summaries were never required.

• Recommendation W18 – Reporting in the Section 319 Grant Reporting and Tracking System - EPA’s Grant Report and Tracking System (GRTS) provides EPA with an electronic means of accessing information on the use of Section 319(h) funds by state agencies. The information extracted from GRTS is used to respond to Congressional and OMB inquiries; support the Agency's non-point source budget request; and provide a feedback loop on states' compliance with Agency guidance and policy. Four states – Maryland, Massachusetts, Montana, and North Dakota – requested that EPA make it easier to submit information into GRTS, require Section 319 implementation project reports at an annual frequency, and provide guidance for Section 319 financial status reports (FSRs). Read EPA's response to W18 for more information.

• Recommendation W36 – Reduce Section 319 Reporting Frequency – Three states – Indiana, Minnesota, and Rhode Island – recommended that EPA reduce Section 319 reporting frequency from quarterly to annually. As mentioned above, OGD’s national grant reporting policy has implemented this suggestion in part.