Detailed Information on the
Nonpoint Source Pollution Control Grants Assessment

To continue to improve this program and meet its long-term goals, EPA will focus on ensuring its funds are used for the most beneficial projects.

EPA will consider contracting for an independent evaluation of the program that can serve as the basis for further improvements.

Measure: Number of waterbodies identified by States (in 2000 or subsequent years) as being primarily NPS-impaired that are partially or fully restored.

Explanation:The 2000 Baseline of primarily NPS-impaired waters is estimated to be 5,967 waterbodies. However, since the Agency does not have a precise number of primarily NPS-impaired waters, the estimate is rough. Furthermore, the many waters listed on State 303(d) lists where the cause of impairment is unknown or unlisted makes up a majority of all listed waters. These waters are unaccounted for in the baseline. "Partially restored" means that the waterbody will cease to be impaired by one or more -- but not all -- particular pollutants that have caused a 303(d) listing, or that one or more -- but not all -- uses are now being met. "Fully attaining" means all designated uses are being met. Please note that where a state did not turn in a 2000 303(d) list, the 1998 list is used as the base year. Waters both listed and then restored after the baseline year are still counted against this measure. EPA is only counting waters where states have provided documented evidence of restoration. If a water has been delisted from the state's 303(d) list but has not yet provided EPA evidence for why the water was delisted (waters may be delisted for reasons other than actual restoration) and what happened to restore the water, EPA is not counting that water under this measure. Information on each of the restored waters can be found at: http://www.epa.gov/owow/nps/Success319/ EPA has instituted a system where the list of partially/fully restored waters can be continually updated. EPA expects that the true number of waters restored to be greater than currently listed under actual, but the Agency has not yet compiled information on all of these waters, and is therefore not yet counting them. The "actual" number as of November, 2005 is 14. The Agency is now seeing a larger number of watershed-based plans meeting NPS program criteria being developed and implemented. These plans are geared largely towards restoring impaired waters. As these plans move further down the path of implementation, our rate of restoring waters should greatly increase over time, thereby helping us to meet the 250 goal by 2008.

Measure: Estimated annual reduction in million pounds of phosphorus from nonpoint sources to waterbodies (Section 319 funded projects only).

Explanation:This measure tracks the amount of phosphorus loading reduced through CWA section 319 funded projects. (FY 2002 baseline is 0, FY 2003 actual results are a partial two-year composite, reflecting an initial lag in data collection).

Measure: Estimated annual reduction in million pounds of nitrogen from nonpoint sources to waterbodies (Section 319 funded projects only).

Explanation:This measure tracks the amount of nitrogen loading reduced through CWA section 319 funded projects. (FY 2002 baseline is 0, FY 2003 actual results are a partial two-year composite, reflecting an initial lag in data collection).

Measure: Estimated annual reduction in thousands of tons of sediment from nonpoint sources to waterbodies (Section 319 funded projects only).

Explanation:This measure tracks the amount of sediment loading reduced through CWA section 319 funded projects. (FY 2002 baseline is 0, FY 2003 actual results are a partial two-year composite, reflecting an initial lag in data collection).

Measure: Section 319 funds ($million) expended per partially or fully restored waterbody.

Explanation:The long-term outcome efficiency measure for the national nonpoint source program will be achieved through the focused expenditure of $700 million dollars ($100 million annually during the years 2000-2006) to restore impaired waters. [It is assumed that expenditures during 2007 and 2008 will not lead to attainment by 2008.] Thus the amount of Section 319 dollars to be expended for each of the 250 waterbodies to be restored by 2008 is $2.8 million ($700m/250). We anticipate that the expenditure of $2.8 million of Section 319 funds will generally not be sufficient to restore waterbodies. The long-term outcome measure is based upon the expectation that Federal, State, and local partners will provide additional personal and monetary resources to achieve the long-term outcome measure. In addition, while we have provided an average figure as an efficiency measure, we expect that the costs to restore waterbodies will vary greatly, perhaps by orders of magnitude in some cases. Factors contributing to such variability include watershed size, climatological and hydrological factors, and the types of nonpoint sources contributing to the water quality impairment. As of 11/05, we are dividing number of partially/fully restored waters by $500 million, because we have not yet reached 2008. However, we expect a drastic increase in efficiency as watershed plans meeting strict EPA criteria are implemented over the the next few years. The "actual" number as of November, 2005 is $35.7 million.

Is the program purpose clear?

Explanation: The Clean Water Act establishes a "national policy" to develop and implement nonpoint source (NPS) programs expeditiously to achieve the goals of the Act.

Evidence: Section 319(h)(7) of the CWA Section 101(a)(7) of the CWA EPA's grants/PPG regulation in 40 C.F.R. Part 35

Does the program address a specific and existing problem, interest or need?

Explanation: The Section 319 program (319) addresses NPS pollution, which is the largest remaining cause of water quality impairments.

Evidence: 1998 National Water Quality Inventory NAWQA

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: 319 is the only program to address all sources of NPS pollution. 319 can be used for monitoring and watershed planning, for which USDA funds cannot be used. The program focuses more on targeting resources for water quality results than USDA programs (e.g. EQIP) that are somewhat similar.

Evidence: EPA 319 guidelines (various) State NPS Management Programs State Annual Reports Section 319(h)(7) of the CWA

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The Clean Water Act does not allow the program to fund best management practices, only demonstration projects. Allowing funding for best management practices could improve the program's effectiveness and efficiency.

Evidence: Section 319(h) of the CWA

Is the program effectively targeted, so that resources will reach intended beneficiaries and/or otherwise address the program's purpose directly?

Explanation: Each year $100 million of CWA Section 319h grants are targeted towards addressing impaired watersheds.

Evidence: EPA 319 guidelines (various)

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The program has a new long-term outcome performance measure that tracks improvement in water quality in NPS-impaired waters and a new long-term outcome efficiency measure that tracks cost effectiveness in reaching that goal.

Evidence: See measures tab EPA Strategic Plan (PAM matrix) Grants Reporting and Tracking System (GRTS) Assessment Database 2004 303(d) Listing Guidance Consolidated Assessment Listing Methodology TMDL Tracking System

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: Waterbodies take a long time to improve, with numerous factors affecting water quality. However, given this limitation, the program has established ambitious targets for partially or fully restoring significantly NPS-impaired waters. Over the next year, the program should determine the 2003 baseline for the efficiency measure.

Evidence: See measures tab EPA Strategic Plan (PAM matrix)

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: The program has three output measures that track the reduction of key pollutant loadings to NPS-impaired water. These measures support the long-term goal of improving water quality in the nation's waters.

Evidence: See measures tab EPA Strategic Plan (PAM matrix)

Does the program have baselines and ambitious targets for its annual measures?

Explanation: The program should re-evaluate its annual performance measure targets in future years.

Evidence: See measures tab

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: To ensure that States' efforts support the goals of the program, EPA requires each State to submit nonpoint source management plans for review and approval. As a condition of funding, States are also required to provide project-specific load reduction and stream restoration data consistent with the program's annual goals.

Evidence: Clean Water Act Sec. 319 (b) 319 program guidelines

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: Although independent evaluations have been conducted for the program, the assessment methodologies do not meet the quality criteria for determing the impact of the program.

Evidence:  

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: The Agency estimates and budgets for the full annual costs of operating its programs, taking into consideration any changes in funding, policy and legislative changes. All spending categories and the resource levels and activities associated with them are included in the annual Congressional Justification. Presentation to Congress of the Agency's budget, including resources for the 319 program, include alignment to its Strategic Plan goals.

Evidence:  

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: EPA has worked with a joint State-EPA workgroup to develop outcome and output-based goals that collectively reflect most of what the program addresses.

Evidence:  

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: EPA uses the upgraded GRTS and WATERS to review how States are progressing with respect to achieving load reductions for nutrients and sediment, protecting shorelines, restoring streambanks, and restoring water quality. States also submit annual NPS reports to EPA.

Evidence: GRTS WATERS

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: States are required to submit annual reports that demonstrate progress towards meeting NPS goals. Inadequate progress towards the program's goals may result in the withholding of the grant, consistent with the Clean Water Act. EPA will track progress towards meeting the national goals, and will re-evaluate how the program is being implemented if progress towards meeting targets is inadequate. States also are required to submit semiannual Financial Status Reports and project reports to ensure fiscal responsibility. Additionally, the Office Director's performance standards include grants management activities specified in the personnel evaluation. Federal regional grant project officers also are held accountable for ensuring that all policies and procedures of the EPA Grants Administration Division are followed.

Evidence: Section 319(h)(8) and 319(h)(11) of CWA Office Director's performance standards

Are funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: EPA includes a standard condition in each grant that the State will obligate its funds within one year of the grant award. On infrequent occasions, delays may occur due to State staffing shortages or because a State has difficulties getting a local project underway, etc. For the most part, however, this is not a problem.

Evidence: FY 03 319 funds were approximately 95% obligated by the end of the year Single Audit Act reports

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The program recently developed a long-term efficiency measure which will help it improve program efficiency and effectiveness. The program also recently upgraded its GRTS server to reduce the amount of time required to fulfill reporting requirements. Additionally, most States use a competitive process to award 319 funds.

Evidence: See Measures tab for efficiency measure Server upgrade procurement request State RFPs

Does the program collaborate and coordinate effectively with related programs?

Explanation: The program worked closely with USDA to ensure the new EQIP rule addresses nonpoint source pollution in a manner consistent with EPA's approach. Many EPA NPS projects are joint efforts with USDA and/or other State/local/tribal agencies. Additionally, each State agency administering 319 funds has committed in its recently upgraded NPS program to strengthening their working partnerships and linkages to appropriate State, interstate, Tribal, regional, and local entities (including conservation districts), private sector groups, citizens groups, and Federal agencies.

Evidence: Nonpoint Source Program And Grants Guidelines State survey of 319 agricultural projects. 7 CFR 1446.4 (EQIP Rule--National Priorities)

Does the program use strong financial management practices?

Explanation: Financial status reports are submitted by States on a semiannual basis. Spending for particular projects is reported in GRTS. Regional grants project officers often review the reports and follow up as appropriate. No material internal control weaknesses have been reported by auditors.

Evidence: CFR Section 31.41(b). FY 2004 grants guidelines. FY 2001 EPA Integrity Act report.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: EPA's Inspector General has conducted detailed, independent reviews of Regional and State 319 programs in Regions 7 and 8, and the Regions have made adjustments in response to those reviews. Few management deficiencies were identified by these reviews. Adjustments based on EPA Regional reviews of States are ongoing. EPA has also given feedback from on-site reviews of Regions, and Regions have adjusted to the feedback. Furthermore, EPA has made broad program policy improvements to improve the focus of the program and broad grants management changes to improve feedback capability and mechanisms.

Evidence: FY 2001 Section 319 expenditure survey Inspector General Reports on Regions 7 and 8 EPA HQ's review of Regions 1 and 7

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: Under Section 319(h)(11), States submit to the Regions annual reports. These are required to articulate States' progress towards implementing their overall State NPS management programs. Project reports are mandated semiannually. These are in addition to numerous onsite visits (most Regions visit their States one or more times per year to discuss grantee activities). EPA uses the upgraded GRTS and WATERS to review how States are progressing with respect to achieving load reductions for nutrients and sediment, protecting shorelines, restoring streambanks, and restoring water quality

Evidence: State NPS management programs. Project reports. FY 2004 grants guidelines. GRTS

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: As of FY 2002, States report load reduction estimates (for nutrients and sediment) as well as additional outputs. EPA will be able to link Section 319 projects to actual water quality improvements by tagging Section 319 projects to WATERS. WATERS is already publicly accessible, and a replica of GRTS will be accessible to the public by 2005.

Evidence: 'ModifiZZcations to Nonpoint SourceReporting Requirements for Section 319 Grants'WATERS

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: Consistent with the EPA Strategic Plan, progress on the NPS program's long-term goal will first become available in September 2005 and then be reported in the first PART after that date.

Evidence: See Measures tab.

Does the program (including program partners) achieve its annual performance goals?

Explanation: Partial results for the three annual performance measures show progress toward meeting these goals. The results represent a two-year composite, reflecting an initial lag in data collection.

Evidence: See Measures tab.

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: The program installed a new server to reduce the administrative burden on States. It also has consistently targeted its funds to impaired waters.

Evidence: Server upgrade procurement request 319 program grant guidelines

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: EPA's NPS program can better demonstrate performance and results than similar programs at USDA.

Evidence: FY 2004 Budget Common Measures exercise

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: Although evaluations have been performed, they do not meet the criteria for independence, scope and quality.

Evidence: