IDEM and its NPS partners recognize the increasing magnitude of statewide NPS needs set against the backdrop of limited financial resources. To satisfy Key Element No. 5 and to effectively meet the NPS program goal and objectives, the State of Indiana has begun linking the approval of local NPS project funding to a hierarchy of priorities. These priorities include recognizing the importance of successful watershed planning and continued focus on restoring waters impaired by NPS pollution. In some cases, the result is NPS implementation project funding targeted to priority watersheds. In other cases, NPS implementation project funding is linked more directly to the environmental benefit and/or the appropriate connection to specific recommendations in a state-endorsed watershed plan or federally-approved TMDL. IDEM has identified NPS activities that are prioritized to receive Section 319 funds:

• management planning and implementation in watersheds with waterbodies on the Section 303(d) list of impaired waters where the impairment is NPS;
• management planning and implementation in watersheds with approved TMDLs; and,
• implementation of watershed plans that meet the requirements identified in the IDEM checklist, which includes U.S. EPA’s Nine Key Elements.

Developing comprehensive watershed management plans is an effective way to focus efforts and resources in a watershed. Problems can be identified and effective solutions can be developed. In the process, local stakeholders join together to develop plans that address conditions found in that watershed. Linkage between NPS project implementation, watershed planning, and TMDLs is an additional step that allows the State of Indiana to more effectively focus limited funding on projects that can result in the elimination of known NPS causes of impairment. The state can also focus on the restoration of impaired waters and ultimately improve water quality.

Before a watershed management plan can be implemented using Section 319(h) funds, it must meet the required elements of IDEM’s Watershed Management Plan Checklist. The checklist incorporates U.S. EPA’s Nine Key Elements of a watershed-based plan and is provided in IDEM’s Watershed Management Plan Guidance document [PDF].

Approved NPS management program funded activities or projects must lead to accomplishing the objectives stated in the approved NPS Management Plan. Table 3-1 highlights the NPS management program objectives from Chapter 2 and briefly updates the status of each objective. While many of the objectives are early in their implementation phase and some have not yet been implemented, the majority are being actively pursued by the state’s NPS staff. While all of the objectives are the responsibility of the state’s NPS Program, the fourth objective is primarily achieved through the work of grant projects. Grant work plans must link the funded activities or projects to the relevant elements of Indiana’s NPS Management Plan. Work plans should indicate which federal, state, and local agencies are responsible for implementing each project or activity.

As IDEM meets objectives in the NPS plan, there will be more data and resources to make further objective decisions regarding funding priorities. These current priorities are based primarily on experiences gathered from partners who have completed watershed management plans (WMPs) and WMP implementation projects. Those experiences not only show that certain categories provide greater pollutant load reduction potential than others, but also that there are categories of projects that are not easily addressed at the local watershed level with Section 319 funds. The state also recognizes that certain categories are regulated under other programs and/or have funding through other sources. The overriding desire in creating funding categories is to provide a cost-effective approach to ensuring load reductions at the watershed level. The funding categories, which in effect will exclude some projects from funding, are defined as follows:

Category 1: Categories with this ranking are eligible for inclusion in Section 319 grant applications as the category historically has produced reliable load reductions, potentially has a high impact on water quality, and can reasonably be addressed at a local watershed level. Activities in the given category would be chosen first to address NPS pollution in critical areas.

Category 2: Categories with this ranking are potentially eligible for inclusion in Section 319 grant applications, provided applicants can demonstrate within a given watershed that all Category 1 priorities have been addressed by previous activities. The high cost of individual projects in these categories, when compared with Category 1 projects, makes these categories less desirable. IDEM will consider funding of these on a case-by-case basis.

Category 3: Categories with this ranking are likely not eligible for inclusion in a Section 319 application, even if applicants can demonstrate within a given watershed that all Category 1 and 2 projects have been addressed by previous activities. Many NPS sources in these categories are the responsibility of other state agencies or programs, or will require statewide solutions or expenditures of funds that far exceed the capacity of the 319 program. These categories could be counted as match towards grant activities, provided load reductions are ensured and a clear link is documented between the activity and the NPS problem that will be addressed.

For each category, a range of methods to address the target source of NPS pollution can be utilized. Education and outreach plays a critical role in addressing NPS pollution and is fundable by Section 319 funds in all categories, if it addresses a documented problem. The list of project activity categories described below is listed in alphabetical order, not in order of priority.

Agricultural Management (Category 1)

The goal of these project activities is to reduce sediment, nutrient, pesticide, and pathogen loading from crop and livestock production areas. Projects should utilize practices, measures, and management methods that will eliminate or reduce sediment delivery to surface waters and reduce loadings of nutrients, pesticides, and pathogens into surface and ground water. Projects should also provide educational opportunities to promote new sediment reduction and new pollution control technologies. Farms that participate in a watershed project and wish to receive Section 319 funds must have a conservation plan for their operations.

Note: Farms that require National Pollutant Discharge Elimination System (NPDES) permits, approvals required under the state’s confined feeding rule, or any subsequent rules, are not eligible for cost share from a Section 319 grant for any practices required by the permit or any other requirements of federal, state, or local permits. IDEM has additional guidance on agricultural practices and Section 319 eligibility that should be consulted.

Atmospheric Deposition (Category 3)

The goal of these project activities is to reduce the transfer of pollutants between air and water media and abate deposition of NPS pollutants through atmospheric transport. The primary responsibility for air quality falls on IDEM’s Office of Air Quality. The Section 319 program does not currently have a set of practices, measures, and/or management methods that will reduce the transfer of pollutants between air and water media. Therefore, atmospheric deposition is not likely to be funded.

Closed Landfills and Solid Waste Disposal Sites (Category 3)

The goal of these project activities is to reduce polluted run-off from solid waste disposal activities. Projects should utilize practices, measures, and management methods that will reduce pollutants in run-off from landfill sites. Since primary responsibility for solid waste oversight falls on IDEM’s Office of Land Quality, this category is not a high priority of the Section 319 program and is not likely to be funded.

Note: Grants may not be used to fund attainment of any permit requirements or to treat end of pipe discharges. Project sponsors are encouraged to explore linkages with the IDEM Office of Land Quality and local solid waste management districts.

Ground Water (Category 2)

The goal of these project activities is to prevent the discharge of NPS pollution to ground water, aid in the reduction of NPS pollution discharges to ground water, and aid in the cleanup of NPS pollution in ground water. Projects should use practices, measures, and management methods that will reduce the transfer of NPS pollution to ground water.

Hydromodification (Category 2)

The goal of these project activities is to improve water quality and aquatic ecosystems through the assessment, research, and remediation of anthropogenic activities that have altered the pre European settlement hydrology of Indiana streams and lakes. This extends broadly to dams, channelization, hydraulically inadequate structures, impediments to fish passage, alteration of normal water levels due to increased or decreased flows, and water removals. In all cases, a clear link to NPS pollution must be demonstrated. Possible activities could include dam removal, channel redesign, or modifications to existing structures. Research and assessment of the effects and possible solutions to hydromodification are eligible activities. Funding for activities in this category will be contingent on the scope of the project and the potential water quality benefits within a given watershed or a large geographic area. In addition, upstream NPS problems need to have been addressed so the proposed project can be managed.

Land Application of Non-Agricultural Wastes (Category 3)

The goal of these project activities is to reduce polluted run-off from land application of non-agricultural wastes. In most circumstances, land application of non-agricultural wastes needs a permit from IDEM’s Office of Land Quality. When this is the case, Section 319 cannot fund projects in this category. Projects should incorporate practices, measures, and management methods that will reduce pollutant loading from land application of non agricultural wastes. Project plans must take into account soil characteristics, soil conditions, and hydrogeologic vulnerability.

Urban Issues (Category 1)

The goal of these project activities is to prevent or reduce polluted run-off and habitat degradation resulting from urban areas. Projects should incorporate practices, measures, and management methods that will preclude or reduce erosion and pollutant loading from existing development, land development, or redevelopment of brownfields or other contaminated sites. Projects may provide education opportunities to promote technologies that avert or reduce the environmental impact of urbanization. Projects should include consideration of present and planned impervious areas, storm water run-off, quality of run-off water, ground water quality, storm water management, and effects on all waters of the state. Project sponsors are encouraged to explore linkages with other grant sources and other agencies that have jurisdiction or provide assistance in the area. Projects that promote innovative planning techniques and practices are encouraged and green infrastructure and low impact development techniques are preferred activities. Projects that conflict with NPDES permits will not be funded.

Note: Grant funds cannot be used for measures required by any permit.

Natural Resource Extraction (Category 2)

The goal of these project activities is to reduce polluted run-off into streams and lakes from present and past coal extraction activities, oil and gas production, and non energy mineral extraction. Projects should utilize practices, measures, and management methods that will reduce sediment, acid drainage, and other pollutant loading from these activities. This includes oil and gas waste products, sediment, and brine. Projects may also provide education opportunities leading to remediation of abandoned mines and well sites. Project sponsors should work with the IDNR Division of Reclamation, IDNR Division of Oil and Gas, and, where possible, the federal Office of Surface Mining, as these programs play a larger role in natural resource extraction than IDEM.

Note: Grant funds cannot be used for measures required by any permit.

On-Site Sewage Disposal (Categories 1 & 3)

Remediation of on-site sewage pollution in Indiana is complicated by three facts:

1. a funding source to address the scope of the problem does not exist;
2. the state Board of Health does not permit alternative systems; and,
3. local health departments have different priorities, resources, and budgets.

The Section 319 program will not fund physical practices, measures, and management methods that will reduce pollutant loading to surface or ground water from improper disposal of residential wastes. These activities fall with Category 3. The Section 319 program will fund educational opportunities that promote new technologies that reduce pollutants from residential waste and teach the public about septic system maintenance as a Priority 1 activity. Project plans should consider soil type, hydrogeologic vulnerability, applicable rules and regulations, and economic factors. Project sponsors are encouraged to collaborate with local health departments in developing proposals.

Sediment Removal (Category 3)

The goal of these project activities is to reduce pollutant loading to waters of the state from the accumulation of sediments that, either on their own or due to the presence of NPS pollutants, are adversely affecting water quality. Dredging projects intended to remove contaminated sediments that are hindering the development of a healthy aquatic ecosystem are considered eligible under Section 319. However, dredging to improve drainage for flood control, to increase reservoir capacity, or to improve navigation are not eligible. In addition, dredging will not be funded in wetlands or coastal areas. Due to the high cost of dredging, it is unlikely that Section 319 will fund this activity.

Stream Bank/Shoreline Erosion (Category 2)

The goal of these project activities is to reduce or remediate the erosion of stream banks and lake shorelines and the associated loss or degradation of aquatic habitat by addressing the cause of erosion. Projects should utilize practices, measures, and management methods that will reduce stream bank and shoreline erosion from agricultural practices, land development, transportation, or other causes. Methods to establish riparian vegetation, improve aquatic habitat, and provide educational opportunities to promote new habitat protection or enhancement technologies should also be utilized. Other aspects of a project could include innovative drainage maintenance practices, such as two stage ditches. Projects may include the promotion of in-stream and riparian habitat, vegetation preservation, and restoration of critical habitat types such as wetlands. Stream bank and shoreline erosion control project plans must take into account the hydrologic system of the watershed above the project area, any planned or existing hydrologic modifications, land use and land use trends, and applicable laws and restrictions. Aquatic habitat enhancement projects should be coordinated with the Lake and River Enhancement Program of the IDNR, as well as other programs and resources that can assist in project design.

Timber Management (Category 2)

The goal of these project activities is to reduce polluted run-off from timber harvesting. Projects should utilize practices, measures, and management methods that will reduce pollutant loading from timber harvesting activities, or reduce loss of forests due to land use changes. Practices may include establishing, restoring, or protecting riparian vegetation and improving aquatic habitat. Projects should provide educational opportunities to promote new timber harvesting technology with environmental benefits. Project plans should take into account forest management activities associated with timber harvesting, grazing of woodlands by livestock or overabundant wildlife populations, and forestation practices.

Transportation (Category 2)

The goal of these project activities is to reduce polluted run-off from transportation facilities and transportation facility construction that are not specifically required to address run-off under state and federal water pollution laws. Projects should incorporate practices, measures, and management methods that will reduce pollutants in storm water run-off originating from transportation-related facilities. The focus of the project may be on either transportation-related construction or existing transportation facilities. Project sponsors are encouraged to explore linkages with the Indiana Department of Transportation (INDOT) for funding and project design. Applicants should take into account the IDNR rules written for boating activities for lakes.

Note: Grant funds cannot be used for measures required by any permit.