United States Environmental Protection Agency

Office of Water

Nonpoint Source Control Branch–4503(T)

1200 Pennsylvania Avenue, NW

Washington, DC 20460

EPA 841-B-10-001

February 2010

Foreword

Congress amended the Clean Water Act (CWA) in 1987 to establish the section 319 Nonpoint 

Source Management Program in recognition of the need for greater federal leadership to help 

focus state, tribal, and local nonpoint source efforts. Under section 319, states, territories, and 

Indian tribes receive grant money that supports a wide variety of activities including technical 

assistance, financial assistance, education, training, technology transfer, demonstration 

projects, and monitoring to assess the success of implementing management practices that 

address pollution from nonpoint sources.

As of the time of publication of this document, 159 tribes have approved nonpoint source 

programs. Tribal water quality programs continue to increase in number and to mature in 

their capacity to understand and improve the condition of reservation lakes, rivers, streams, 

wetlands, and coastal waters. In support of the continued growth and sophistication of tribal 

participation in the CWA section 319 program, the U.S. Environmental Protection Agency 

(EPA) is pleased to release this Handbook for Developing and Managing Tribal Nonpoint Source 

Pollution Programs Under Section 319 of the Clean Water Act.

EPA is committed to restoring and protecting our waters through a watershed approach, and 

it is encouraging to see a number of tribes electing to pursue funding to develop watershedbased plans. Cooperative, on-the-ground, watershed-based efforts among tribal and nontribal 

water resource managers and staff are helping to improve the prospects for solving water 

quality problems that know no boundaries, and affect the health and quality of life of all 

Americans. 

This handbook is meant to be a practical and accessible guide for tribes to answer key 

questions such as

 How do I develop a nonpoint source assessment report and management program 

that meet 319 program eligibility requirements and set the stage for effective program 

implementation?

 What sorts of activities are eligible for funding under CWA section 319?

 How do I develop and successfully implement a watershed project that will help restore 

the quality of our water for drinking, fishing, and other uses?

The handbook explains the role of both EPA and the tribes in working together to help solve 

water quality problems caused by nonpoint source pollution. All aspects of the grants-funding 

process are broken down for you in simple steps, showing you how tribes can use section 

319 program funds to implement programs and projects to reduce pollution and restore 

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Foreword | iii
water quality. At the same time, it takes you the next level by providing a great deal of useful 

technical information regarding nonpoint source pollution, how you can develop and assess 

available data to develop a plan of action, and what management practices and activities are 

needed to solve the problem. 

EPA is proud of the many excellent projects that tribes have already implemented with section 

319 funds. Many impressive tribal on-the-ground projects are available for you to review on 

www.epa.gov/nps/tribal. It is our hope that tribes will find this handbook a useful tool in 

helping to achieve many more water quality successes in the future.

Benita Best-Wong 

Director of the Assessment and Watershed Protection Division 

Office of Water

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

iv | Foreword
Contents

Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xi

What this Document Contains . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xi

Key Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xi

What Is NPS Pollution? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xi

What Is the Status of Our Nation’s Waters? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xii

What Are Management Measures or Best Management Practices? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xii

What Is the Watershed Approach? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiii

How Can I Integrate My NPS Program with Other Water Quality Programs? . . . . . . . . . . . . . . . . . . . . . . . . . . xiv

History of the CWA Section 319 Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xvi

Part I: The Clean Water Act Section 319 Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1

Section 319 Program at a Glance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1

Activities Eligible for Funding under CWA Section 319 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-2

Activities Ineligible for Funding under CWA Section 319 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-3

Summary of Eligibility Requirements for an NPS Grant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-3

Detailed Guide to the 319(h) Grant Eligibility Components . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-5

Federal Recognition and Treatment in the Same Manner as a State for 319(h) Funding Eligibility . . . . . . . . . . I-5

Federal Recognition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-6

Substantial Governmental Duties and Powers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-6

Reservation Waters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-6

Tribal Capability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-6

Nonpoint Source Assessment Report for 319(h) Eligibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-8

What Is an Assessment Report? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-8

Format of an NPS Assessment Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-10

Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-11

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-13

Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-17

Land Use Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-20

Surface and Ground Water Quality Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-24

Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-27

Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-30

Selection of Best Management Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-33

Existing NPS Control Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-39

Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-42

Nonpoint Source Management Program Plan for 319(h) Eligibility . . . . . . . . . . . . . . . . . . . . . I-44

Components of a Nonpoint Source Management Program Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-44

Format for the Management Program Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-46

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Contents | v
Overview Section . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-46

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-48

Management Program Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-49

Management Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-51

Public Notice and Comment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-60

EPA Regional Approval Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-62

Section 319 Funding Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-62

Base Funding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-62

Competitive Funding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-64

Cost-Share/Match Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-65

Performance Partnership Grants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-67

Grant Timeline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-68

Work Plan Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-68

In-Depth Detail on the Five Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-69

Work Plan Components . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-69

Work Plan Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-69

Estimated Work Years and Funding Amounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-71

Reporting Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-71

Roles and Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-72

Establishing Quality Assurance and Quality Control Protocols . . . . . . . . . . . . . . . . . . . . . . . . I-75

Statutory Requirements of Section 319 Grants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-78

Satisfactory Progress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-78

Administrative Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-79

Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-79

Performance and Financial Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-79

Annual Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-80

Summary and Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-81

Climate Change Considerations: The Earth Is Warming . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-82

Part II: Watershed-Based Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1

The Watershed Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1

Implementing the Watershed Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-6

1. Build Partnerships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-6

When Should We Start Engaging Stakeholders? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-8

Who Should We Include? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-8

How Do We Build Support in the Watershed? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-9

Which Stakeholders Might Be Able to Assist Monetarily? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-10

2. Characterize Your Watershed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-11

3. Finalize Goals and Identify Solutions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-16

4. Design an Implementation Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-18

5. Implement Your Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-19

6. Measure Progress and Make Adjustments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-20

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

vi | Contents
Nine Elements of a Watershed-Based Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-22

Element a. An identification of the causes and sources or groups of similar sources that will 

need to be controlled . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-25

Element b. Description of NPS BMPs to achieve water quality-based goals . . . . . . . . . . . . . . . . . . . . . . . . . II-28

Element c. An estimate of water quality-based goals expected to be achieved . . . . . . . . . . . . . . . . . . . . . . . II-33

Element d. An estimate of the amounts of technical and financial assistance needed, associated 

costs needed to implement your plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-35

Element e. An information and education component that will be used to enhance 

public understanding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-38

Element f. A schedule for implementing the NPS BMPs identified in the plan that is 

reasonably expeditious . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-42

Element g. A description of interim, measurable milestones for determining whether NPS BMPs 

or other control actions are being implemented . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-43

Element h. A set of criteria that can be used to determine whether the water quality-based 

goals are being achieved over time and substantial progress is being made toward 

attaining water quality-based goals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-47

Element i. A monitoring component to evaluate the effectiveness of the implementation 

efforts over time . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-49

Regional Review of Watershed-Based Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-51

Leveraging Funding Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-52

Tribal CWA 106 Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-52

State CWA 319 Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-54

Wetlands Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-55

Solid Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-56

Drinking Water and Clean Water State Revolving Fund Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-57

Clean Water State Revolving Funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-57

Drinking Water State Revolving Fund: Source Water Protection Funding . . . . . . . . . . . . . . . . . . . . . . . . . . II-58

General Assistance Program (GAP) Funding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-59

Environmental Quality Incentive Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-60

Other Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-60

Part III: Additional Resources for Tribes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-1

List of Contacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-1

EPA Regional Offices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-3

Online Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-4

GIS Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-5

Additional Internet Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-7

Acronyms and Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-13

Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-16

References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-21

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Contents | vii
Figures

Figure i-1. Illustration of a watershed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiii

Figure i-2. Water quality program integration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xv

Figure I-1. Eligibility and application requirements for base vs. competitive grants . . . . . . . . . . . . . . . . . . . . I-4

Figure I-2. Location of Port Madison Indian Reservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-15

Figure I-3. General Shotley Brook watershed land use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-23

Figure I-4. Land use in Sequim/Dungeness Valley (JST 2007) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-24

Figure I-5. Dungeness watershed planning area (JST 2007) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-25

Figure I-6. Summary template . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-33

Figure I-7. Newly planted native grasses (UMUT 2005) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-40

Figure I-8. Map showing First Lake seeding areas (UMUT 2005) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-40

Figure I-9. Tranferring flannel mouth suckers (UMUT 2005) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-41

Figure I-10. Reintroducing fish with tribal/state teamwork (UMUT 2005) . . . . . . . . . . . . . . . . . . . . . . . . . . I-41

Figure I-11. Total annual tribal section 319 funding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-63

Figure I-12. Grant timeline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-68

Figure I-13. The role of planning and QAPPs in data collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-76

Figure II-1. How a WBP relates to reservation-specific water resource plans and projects . . . . . . . . . . . . II-3

Figure II-2. Foundation of the nine elements of a WBP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-5

Figure II-3. Potential stakeholder groups for your consortium . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-7

Figure II-4. Hierarchy of entities within a watershed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-9

Figure II-5. HUC code levels used to define watershed size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-12

Figure II-6. The iterative process of the watershed approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-21

Figure II-7. Source of the nine required elements of a Watershed-Based Plan . . . . . . . . . . . . . . . . . . . . . II-23

Figure II-8. Simplified conceptual model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-27

Figure II-9. Role of deductive process in program planning and implementation . . . . . . . . . . . . . . . . . . . . II-27

Figure II-10. Implementation schedule for high-priority AMD sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-42

Tables

Table I-1. Size and status of land owned by Confederated Tribes of Grand Ronde (CTGR 2008a) . . . . . I-12

Table I-2. Land use in Ute Mountain Reservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-21

Table I-3. Basic land use patterns in the Shotley Brook watershed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-22

Table I-4. Categories and subcategories of NPS pollution identified in assessment plan from the 

Red Lake Band of Chippewa Indians (RLBCI 2008a) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-23

Table I-5. Results table for streams on the Red Lake Reservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-29

Table I-6. Surface waterbody summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-30

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

viii | Contents
Table I-7. Identified pollutant concerns in reservation waters and likely nonpoint sources . . . . . . . . . . . . I-32

Table I-8. Minimum in-stream flows for Grovers Creek . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-33

Table I-9. Core participants for BMPs (SBLI 2007) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-35

Table I-10. Existing agriculture BMPs by NPS category . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-37

Table I-11. NPS category and associated information (RLBCI 2008a) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-38

Table I-12. General program milestones (UMUT 2005b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-52

Table I-13. Categories of NPS and their applicability to the Ute Mountain Tribe (UMUT 2005b) . . . . . . . I-53

Table I-14. Reservation waters: levels of specific impairment criteria (UMUT 2005b) . . . . . . . . . . . . . . . . . I-54

Table I-15. Plan for management of hydromodification (PTOI 2008) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-56

Table I-16. Schedule of milestones (RLBCI 2008b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-58

Table I-17. Urban runoff/stormwater (ST 2008) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-58

Table I-18. Base funding parameters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-63

Table I-19. Match calculation table for tribes eligible for $50,000 of base funding (>1,000 mi2) . . . . . . . . . I-65

Table I-20. Match calculation table for tribes eligible for $30,000 of base funding (<1,000 mi2)......... I-65

Table I-21. Match funding requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-66

Table I-22. Sample work plan NPS pollution control program (CWA section 319) . . . . . . . . . . . . . . . . . . . I-73

Table II-1. Components of assorted plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-4

Table II-2. Impairment sources and associated pollutants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-13

Table II-3. Translating watershed goals into management objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-17

Table II-4. Common pollutant types and sources found in watersheds . . . . . . . . . . . . . . . . . . . . . . . . . . . II-26

Table II-5. Online resources for BMPs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-29

Table II-6. Example of a BMP effectiveness table . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-30

Table II-7. Summary of NPS management measures in the strategy and implementation plan . . . . . . . . . II-31

Table II-8. Overview of estimated costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-37

Table II-9. Milestones for implementation and measurable criteria for evaluating progress . . . . . . . . . . . II-44

Table II-10. Stressors and indicators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-47

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Contents | ix
Introduction | xi

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Introduction

There is a deep spiritual connection between Native American people and the earth. Tribal 

communities are strongly committed to the restoration and protection of the natural environment, including surface and ground water resources. These rivers, lakes, streams, reservoirs, 

wetlands, estuaries, and coastal waters sustain fish and shellfish, provide recreational 

opportunities, supply drinking water, and allow ceremonial uses for many tribal communities. 

However, many water resources are threatened or impaired by polluted runoff, also known as 

nonpoint source (NPS) pollution. The goal of this handbook is to provide tribes with guidance 

and other information that will help them to protect and restore water resources. 

What this Document Contains

This edition is an update of the Tribal Nonpoint Source Planning Handbook (EPA document 

no. EPA-841-B-97-004), which was issued in September 1997. It contains new information 

and additional features. The handbook has three parts. Part I describes the Clean Water 

Act (CWA) section 319(h) grant application process and explains in detail how tribes can 

demonstrate their eligibility and prepare the necessary documentation for successful 319 grant 

applications. New tribal examples showcase useful approaches for protecting or restoring 

water quality, and Internet resources provide tools for tribes interested in growing their NPS 

programs. Part II provides detailed information about the watershed-based approach to 

solving NPS problems, as well as ideas for leveraging funds. Additional resources for tribes are 

provided in Part III, which offers useful links to various resources, online management tools, 

and a list of contacts. 

Key Questions

What Is NPS Pollution?

NPS pollution—polluted runoff—occurs when rainfall, snowmelt, or irrigation water runs 

over land or through the ground, picks up pollutants, and transports them into surface waters 

or ground water. Though the relative impact from a few nonpoint pollution sources might be 

small, the cumulative effect from many nonpoint sources degrades water quality. In fact, NPS 

pollution is the leading source of water quality problems in the United States. Major nonpoint 

sources of pollution often include agricultural practices; unrestricted livestock grazing; poor 

siting and design of roads, highways, and bridges; forestry; urban runoff; abandoned mines; 

construction sites; channelization of streams; and hydromodification, such as building 

and maintaining dams and levees. Other sources include lawn and garden maintenance, 

malfunctioning septic systems, constructing marinas, boating, and storm drain dumping. 
Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

xii | Introduction

Atmospheric deposition of pollutants originating from power plants, factories, trucks, and 

automobiles is also considered NPS pollution. 

What Is the Status of Our Nation’s Waters?

The Wadeable Streams Assessment, a national survey of streams conducted by EPA and 

the states and published in December 2006, found that 42 percent of U.S. stream miles 

are in poor biological condition, 25 percent are in fair condition, and 28 percent are in 

good condition. The most widespread stressors observed across the country and in each 

major region are nitrogen, phosphorus, riparian disturbance and clearing, and streambed 

sediments. These stressors are often associated with polluted runoff. The survey also found 

that 30 percent of the nation’s streams have elevated levels of nitrogen and phosphorus, and 

25 percent have elevated levels of sediment. For more information, see the Wadeable Streams 

Assessment at www.epa.gov/owow/streamsurvey.

In addition, the latest published summary of state water quality assessments found that 

agricultural activities were the leading source of impairment in assessed rivers and streams, 

associated with more than 94,000 impaired stream miles. Other leading nonpoint pollution 

sources in streams include hydromodification (e.g., streambank destabilization and flow 

alteration), riparian habitat alteration, and urban runoff. For more information, see the 

National Water Quality Inventory: Report to Congress, 2004 Reporting Cycle, January 2009, at 

www.epa.gov/owow/305b/2004report. 

In assessed lakes, ponds, and reservoirs, agricultural activities ranked near the top of the 

identified pollution sources, associated with more than 1.6 million impaired lake acres. 

Hydromodification was associated with more than 1.2 million impaired lake acres; urban 

runoff was associated with 701,000 impaired lake acres; and unspecified nonpoint sources 

affected nearly 500,000 impaired lake acres. For the full report, see the National Water Quality 

Inventory: Report to Congress, 2004 Reporting Cycle at www.epa.gov/owow/305b/2004report. Note 

that only about 16 percent of U.S. streams miles and 39 percent of lake acres were assessed 

for this report; some states did not report on sources of impairment in their waters, and more 

than one source might impair any given waterbody.

What Are Management Measures or Best Management 

Practices?

NPS pollution can be addressed using various management measures, which are the best 

available economically achievable practices needed to solve a water quality problem. Another 

common term used is best management practices (BMPs). A BMP can be a particular technique, 

measure, or structural control used to manage the quantity and improve the quality of 

runoff to the maximum extent possible and most cost-effectively. The U. S. Department of 

Agriculture (USDA) and others have identified a number of BMPs to address pollution from 
Introduction | xiii

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

different sources. Such management practices vary widely, and they must be tailored to 

specific conditions. For example, BMPs to protect waters from agricultural pollution, such 

as sediment from row crop land, are different from urban runoff BMPs, such as those that 

address sediment from construction sites. BMPs can be structural, such as fences to prevent 

livestock from entering a stream, or nonstructural, such as an ordinance that specifies 

vegetated buffer zones between certain activities and the water’s edge. For more information 

on BMPs, visit EPA’s Web site at www.epa.gov/nps and click on NPS Categories. Each NPS 

category will lead you to a series of guidance documents for your category of interest. For even 

more information, visit the Natural Resources Conservation Service (NRCS) Web site at

www.nrcs.usda.gov/technical/efotg. Another excellent resource to view various BMPs and learn 

what they do has been compiled in an appendix available at www.waterquality.utah.gov/

TMDL/Virgin_River_Watershed_Implementation_Appendix.pdf.

What Is the 

Watershed Approach?

EPA and other entities 

both inside and outside the 

government believe that the 

watershed approach is the 

most promising means of 

addressing NPS pollution and 

the challenging condition of our 

water resources. The watershed 

approach focuses efforts on a 

particular watershed, which is 

the area of land that drains to 

a specific point, such as the 

confluence of two rivers, a lake, 

or a coastal estuary (Figure i-1). 

The watershed approach is 

characterized by these unique 

features:

1. It is hydrologically defined. 

	Has a geographic focus 

based on hydrologic 

connections (i.e., a 

watershed or drainage area)

Figure i-1. Illustration of a watershed.
Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

xiv | Introduction

	Includes all stressors/causes and pollutant sources within that geographic area 

2. It involves all stakeholders. 

	Includes public (federal, tribal, state, local), private, and nongovernmental sectors 

	Is community-based 

	Includes a coordinating framework

3. It strategically addresses priority water resource goals.

	Integrates multiple regulatory and voluntary programs 

	Is based on sound science 

	Uses adaptive management for continual improvement

The watershed approach provides a framework for working on a watershed basis and is 

used to generate a watershed-based plan that addresses impairments and threats to water quality. 

States are already required to show that they are working toward achieving elements of a 

watershed-based plan in order to receive a certain portion of their CWA section 319 funding 

(i.e., the incremental funds). Although developing and implementing watershed-based plans 

are not requirements for tribal section 319 funding as of the date of this publication, EPA 

strongly encourages tribes to develop such plans to comprehensively understand and plan for 

protection and restoration of water quality. EPA believes that using the watershed approach is 

usually more effective than addressing impaired waters piecemeal, such as one segment of a 

river or stream reach at a time. In addition to 319 funding, tribes can explore the use of other 

funding, such as General Assistance Program (GAP) funding and CWA section 106 (Water 

Pollution Control Program) funding, to support the development of watershed-based plans. 

This does not mean that previous assessment work that has been done is obsolete. The 

information you have compiled in your assessment report and management plan (to be 

discussed later), or in any other previously developed planning document, will feed easily 

into a more comprehensive watershed plan. For example, the watershed-based plan might 

span a 5-year time frame and include all lands that are part of a tribal watershed, such as 

surrounding federal, state, and private lands and their associated pollutant sources and 

stressors. To effectively be this inclusive, tribes will need to work with all the stakeholders in 

their watersheds, both tribal and nontribal. This might seem tricky at first, but these efforts 

will result in significant progress toward reaching your water quality goals.

How Can I Integrate My NPS Program with Other Water 

Quality Programs?

Because the federal government has steadily moved toward a watershed approach for 

addressing water quality protection and restoration issues, there is now a greater need to 

communicate across various environmental programs. EPA programs include water quality 
Introduction | xv

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

standards, CWA section 106, CWA section 303(d), National Pollutant Discharge Elimination 

System (NPDES) wastewater discharge permitting, monitoring, source water protection, and 

solid waste management. Figure i-2 shows how these water programs relate to and support 

each other. EPA encourages tribal NPS program staff to interact with their counterparts in 

other programs to coordinate activities and leverage funding resources to reach common water 

quality goals. Part II of this handbook also provides information on some of these programs. 

Figure i-2. Water quality program integration.
Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

xvi | Introduction

History of the CWA Section 319 Program

In 1987 Congress amended the CWA to add sections 319 and 518. That provided support 

for states, territories, and tribes to address NPS pollution. NPS pollution is increasingly 

recognized as the most pervasive source of water quality impairments in the nation, far 

outweighing problems from wastewater treatment plant, industrial facilities, stormwater 

runoff, and other discharges in most areas.

CWA section 319 authorizes EPA to award grants to eligible tribes, states, and intertribal 

consortia to implement EPA-approved NPS management programs developed pursuant to 

section 319(b). The primary goal of an NPS management program is to control or prevent 

NPS pollution. This is accomplished by implementing BMPs that reduce pollutant loadings to 

waterbodies from each NPS category or subcategory identified in the tribe’s NPS assessment 

report. The NPS assessment report is developed pursuant to section 319(a). 

CWA section 518 authorizes EPA to treat federally recognized Indian tribes in a similar 

manner as states (“treatment as a state,” or TAS). EPA recognizes that TAS does not necessarily 

capture the true relationship between tribes and the federal government. For example, 

EPA Region 9 uses the term Financial Assistance Eligibility (FAE) instead of TAS to describe 

eligibility status. For the purposes of this handbook, TAS will be used, given its prominence 

in statute and regulation. 

CWA section 518(f) states that no more than one-third of one percent of the total amount of 

section 319 funds appropriated for any fiscal year may be used to make grants to tribes. EPA 

recognizes, however, that this statutory cap would most likely substantially affect tribes’ ability 

to establish and maintain NPS programs. There is an understanding that Indian tribes need 

more financial support to implement NPS programs. In addition, more tribes are receiving 

TAS status under the 319 program and receiving funds. For those reasons, since 2000 

Congress has approved EPA’s annual requests to exceed the statutory cap. For a complete list 

of section 319-eligible tribes, see the document listed under Funding at www.epa.gov/nps/tribal. 
Part 1: The Clean Water Act Section 319 Program | I-1

Section 319 Program at a Glance

What it does: Requires tribes and states that wish to receive section 319 funding to prepare an 

assessment of their NPS pollution problems and develop a management program 

to address the problems identified in their assessment report. Also creates a grant 

program for states and tribes to implement their approved programs, including 

implementation of on-the-ground projects to reduce NPS problems.

What it funds: NPS program staff, outreach and education activities, travel and training associated 

with NPS activities, NPS ordinance development, and various on-the-ground 

BMPs. Proposed activities must implement management measures identified in the 

management plan.

Who is eligible: Tribes and states are eligible to receive direct funding from EPA through 

congressional appropriations. Tribes must have TAS and an approved NPS 

assessment report and NPS management program to receive 319 funds. Tribes and 

states must make satisfactory progress to continue receiving 319 funds every year, as 

well as develop approved work plans. Although eligibility varies from state to state, 

tribes (along with other entities) are also eligible to apply to the state to receive 

319 funding.

How it is funded: Congress appropriates funds every year for the section 319 program. In the past 

few years (as of 2010), this appropriation has been approximately $200 million 

on an annual basis, but the amount varies from year to year (to view annual 

appropriations, visit www.epa.gov/nps/319hhistory.html). Tribes have a statutory 

limit of receiving only one-third of one percent of that appropriation; however, 

since 2000 Congress has annually allowed EPA to exceed this statutory cap. States 

receive base and incremental funds (i.e., funds used to develop and implement 

watershed-based plans that address NPS impairments in watersheds that contain 

303(d)-listed waters) to support their NPS management program. Tribes receive 

base funds that support their NPS management program, and they are eligible 

to compete nationally for additional funds to implement projects to restore and 

protect their waters.

PART I The Clean Water Act Section 319 Program
Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

I-2 | Part 1: The Clean Water Act Section 319 Program

Activities Eligible for Funding under 

CWA Section 319 

Activities eligible for funding under section 319 are quite extensive and cannot be listed 

in their entirety, but the following list illustrates some of the activities funded under 

this program. A tribe must propose activities that are discussed in its EPA-approved 

NPS management plan, which is described further in the section titled Nonpoint Source 

Management Program Plan for 319(h) Eligibility, which begins on page I-44.

 NPS training for tribal staff

 Developing NPS education programs

 Hiring an NPS coordinator

 Developing watershed-based plans 

 Road stabilization/removal

 Riparian planting

 Stream channel reconstruction

 Wetland development for sediment/toxic substance removal

 Low-impact development projects/stormwater mitigation

 Riparian livestock exclusion fencing/off-site watering

 Springs protection

 Outhouse removal/rehabilitation

 Large woody debris placement

 Lake protection and restoration activities

 Ground water activities

 Urban stormwater activities; remediation of abandoned mine lands; or activities related 

to animal waste storage, treatment, and disposal not specifically required by NPDES 

permits

 Invasive/nonnative species removal (must demonstrate link to water quality 

impairment)

 Project monitoring (pre-project, post-project)

 NPS ordinance development
Part 1: The Clean Water Act Section 319 Program | I-3

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

For more examples of activities eligible under section 319, see EPA’s NPS success stories at 

www.epa.gov/nps/success. That Web site features stories about restoration efforts that have led 

to documented water quality improvement of NPS-impaired waterbodies. 

Activities Ineligible for Funding under 

CWA Section 319

Although a multitude of NPS activities may be funded through the 319 program, other NPSrelated activities are typically ineligible within the context of the grant. For example, some of 

these prohibitions are based on statutory limitations on the use of 319 funding. 

If you have questions regarding any of these activities, contact the EPA tribal NPS coordinator in your 

region. In addition, you can find information on the following ineligible activities in the most 

recent 319 guidelines at www.epa.gov/fedrgstr/EPA-WATER/2003/October/Day-23/w26755.htm.

 General monitoring unrelated to assessing the control of nonpoint sources of pollution 

 Implementing specific requirements of NPDES point source or stormwater permits

 Implementing the permit application requirements of EPA’s stormwater regulations 

(e.g., mapping stormwater systems, identifying illicit connections, characterizing 

stormwater discharges, or monitoring or BMP treatment required by an NPDES permit)

 Operation and maintenance of NPS implementation projects

 NPS activities not identified in your NPS management program

Summary of Eligibility Requirements for

an NPS Grant

Four eligibility conditions must be met before tribes or intertribal consortia may submit a 

work plan for funding under an NPS (section 319(h)) grant. (Work plans are discussed in 

detail in the section titled Work Plan Development, which begins on page I-68.) To receive 

funding, the tribe must do the following:

1. Be federally recognized

2. Have an approved NPS assessment report in accordance with CWA section 319(a)

3. Have an approved NPS management program in accordance with CWA section 319(b)

4. Be approved for treatment in a similar manner as a state (TAS) in accordance with CWA 

section 518(e)
Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

I-4 | Part 1: The Clean Water Act Section 319 Program

The flowchart in Figure I-1 describes eligibility requirements, eligible activities for the two 

levels of 319 funding (base and competitive, which are explained in detail in the section titled 

Section 319 Funding Process, which begins on page I-62), and the general grant process. 

The treatment as a state (TAS) section of this handbook, which begins on page I-5, discusses 

section 518 of the CWA, which authorizes EPA to treat federally recognized Indian tribes in 

the same manner as states. It also contains an overview of what is needed for TAS status and 

provides information on the process of applying for TAS. Because federal recognition is an 

integral part of the TAS process, those topics are discussed together below.

Figure I-1. Eligibility and application requirements for base vs. competitive grants.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Detailed Guide to the 319(h) Grant 

Eligibility Components

Federal Recognition and Treatment in the Same 

Manner as a State for 319(h) Funding Eligibility

For tribes to receive treatment as a state (TAS) authorization for implementing 

certain CWA programs, they must demonstrate that

1. They are federally recognized. 

2. They have a governing body capable of carrying out substantial 

governmental duties and powers. 

3. The functions they seek to exercise pertain to the management and protection of water 

resources on tribal lands. 

4. They are reasonably expected to be capable of carrying out the functions in a manner 

consistent with the CWA and its regulations. 

Statutory and regulatory text regarding these requirements can be found in section 518(e) of 

the act and at Title 40 of the Code of Federal Regulations (CFR) sections 35.633 and 130.6(d). 

The following sections outline examples of the documentation tribes may use to show that 

they meet these requirements. Tribes submitting information to EPA should clearly label it and 

attach to the front of the package a list of the attachments, exhibits, or supporting documents. Taos Pueblo, New Mexico

Benefits of 

restoration, 

Rio Pueblo.

In this section, you will find

• The documentation tribes 

need to provide to become 

federally recognized and 

obtain treatment in a similar 

manner to a state (TAS)
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I-6 | Part 1: The Clean Water Act Section 319 Program

Federal Recognition

Federally recognized tribes are those on the list of Indian Entities Recognized and Eligible to 

Receive Services from the United States Bureau of Indian Affairs, which is published in the Federal 

Register by the Department of the Interior. In 2009 a total of 564 tribes were on the list. To 

meet the requirements for federal recognition, tribes should provide a Federal Register citation 

to their presence on the current list.

Substantial Governmental Duties and Powers

Tribes must demonstrate that they carry out substantial governmental duties and powers to 

administer and implement an NPS program. Some examples of information a tribe can submit 

follow:

 A description of the form of tribal government, including its executive, legislative, and 

judicial powers 

 A list of functions or programs the tribal government currently performs 

 A description of the source of tribal government authority, such as the tribal 

constitution, by-laws, or ordinances 

The activities that tribes can describe include those that promote the public health, safety, 

and welfare of the people, such as acquiring land, adopting and implementing ordinances, 

exercising police power, and so on. Descriptions of governmental functions or programs can 

include Web site references for key documents, such as the tribal constitution and ordinances. 

EPA prefers summary descriptions of this information over copies of the referenced 

documents, and a tribal organizational chart is helpful.

Reservation Waters

Tribes should provide a certification statement from the tribal attorney demonstrating that 

the activities they will carry out pertain to the management and protection of reservation 

water resources (which includes water resources of tribal trust lands even if those lands 

have not been designated formally as reservations). Such information should include maps 

or legal descriptions of the reservation areas (or both), descriptions of the water resources of 

the reservation areas, and descriptions of how the activities will pertain to management and 

protection of those water resources. That statement should also cite the treaty or other history 

of the tribe establishing the reservation and its current boundaries, or any other authority by 

which the tribe’s trust lands were established.

Tribal Capability

Tribes must have the capability to manage a section 319 program. To demonstrate capability, 

tribes should include information supporting their existing ability to carry out functions 

such as planning; identifying staff and other resources; budgeting; developing work plans 
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

and schedules; carrying out the identified work tasks; assessing their impact or results; 

and handling financial disbursements, reports, and other actions through a system with 

appropriate controls. Tribes may demonstrate their capability to manage and implement an 

NPS pollution control grant by describing the organization that will carry out the program, 

any existing or current environmental programs being carried out, mechanisms in place for 

carrying out the governmental functions of the tribe, and the technical and administrative 

capabilities of the staff that will manage the program.

Tribal Management Experience

Supporting documentation may include brief descriptions of federal, tribal, and other 

programs managed by the tribe, including those involving natural resources, environmental 

issues, drinking water, or others. This documentation may overlap somewhat with tribal 

responses regarding capability, existing programs, and technical/administrative capabilities of 

the staff. Examples for addressing this requirement include quarter-page, half-page, or pagelong summaries of programs currently managed by the tribe, a list of programs managed by 

the tribe over the past three years, or a summary report of tribal operations that conveys a 

sense of the tribe’s management experience.

Existing Programs

In conjunction with the requirement, the tribe may provide a list of current programs 

managed by the tribe. The existing programs list may include supplemental information, such 

as number of staff, total budget, and so on. Programs to list include health clinics and related 

programs, Bureau of Indian Affairs programs, fish and game programs, agricultural and land 

management programs, tribal administrative office functions, and others.

Mechanisms for Governmental Functions

Supporting documentation may include a summary of tribal operating procedures, tribal 

constitutions or by-laws, or other documents that describe how decisions are made, how 

rules or ordinances are established, how governmental affairs are handled, and the like. The 

tribe should clearly and succinctly describe how its government functions, with references 

to charters, constitutions, by-laws, or other documents that establish the mechanisms 

for governmental functions. If that information is already provided in the description of 

governmental functions portion of the application, the information may be referenced, without 

repeating it, in this section.

Accounting and Procurement Systems

The tribe may include descriptions of its accounting and procurement systems, sections from 

the tribal charter or by-laws or other documents describing the tribe’s financial system, copies 

of the tribal financial operating procedures, or similar documents that demonstrate that the 

tribe has a workable system in place, with adequate controls to prevent poor accounting 
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I-8 | Part 1: The Clean Water Act Section 319 Program

practices or misconduct. The summary should be brief and should clearly lay out how the 

accounting and procurement systems function.

Technical and Administrative Capabilities of the Staff

This section should include staff resumes, number of years of relevant experience, brief 

summaries of the technical and administrative experience and qualifications of staff that 

will be involved in the NPS pollution management program, or personal descriptions 

of qualifications and experience that convey an ability to manage the program. Include 

summaries for nontribal technical assistance and other personnel if they will be involved in 

the tribe’s NPS pollution management program. 

Generally those documents can also be found in the CWA 106 applications, so there is no 

need to duplicate efforts if you already have TAS for section 106. However, many of the 

CWA 106 applications are several years old, and updated forms might be appropriate. You 

may develop TAS documentation independently or in parallel with the NPS assessment 

report and management program, also required for 319(h) eligibility (discussed below). Each 

EPA Regional office has an approval process and time frames within which these critical 

documents are processed. For assistance, contact your Regional Tribal NPS coordinator. 

Nonpoint Source Assessment Report 

for 319(h) Eligibility

What Is an Assessment Report?

The assessment report is a comprehensive technical 

summary of the condition of tribal water resources. The 

report provides the foundation for the scope and direction 

of the NPS pollution management program, discussed in the 

next section. It is important to characterize all waterbodies, 

including, if possible, those that might lie partly on nontribal 

lands, making partnerships with external parties important 

to the overall process. Two types of information that will 

determine the scope and direction are:

1. Actual NPS-related impairments, to target restoration 

efforts 

2. Waterbodies of high quality or cultural significance that need protection from existing 

or future sources of polluted runoff 

In this section, you will find

• A detailed explanation of the 

next eligibility requirement—

an approved NPS assessment 

report

• A suggested format for the 

assessment report

• Excerpts from successful tribal 

assessment reports

• References and resources to 

help you write your assessment 

report
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

The NPS assessment report must include four types of information (which are also referred to 

as the four legislative conditions):

1. An identification of waters that cannot be expected to attain or maintain tribal water 

quality standards without the control of NPS pollution. If the tribe does not have water 

quality standards, state standards or tribal water quality goals may be used as guides 

for evaluation of water quality. This is a place to use your 106/303/GAP data and 

information and any others sources of data that meet established quality assurance/

quality control (QA/QC) criteria.

2. An identification of the categories and subcategories of NPS pollution that contribute 

to the water quality problems for the individual waters identified in number 1 

above. For a listing of major NPS pollution categories and subcategories, refer to the 

latest Guidelines for the Preparation of State Water Quality Assessments (305(b) Reports), 

published by EPA. Tribes may also use the reference information provided by EPA’s 

Web site at www.epa.gov/nps/categories.html. 

Look at the activities identified that impair or threaten water quality and link them 

back to these categories/subcategories. Many states have their 303(d) and 305(b) 

reports online, and those could provide an initial resource. 

3. A description of how the tribe will identify the BMPs needed to control each category and 

subcategory of NPS pollution identified in number 2 above, as well as a description of 

how the management practices will be used to reduce the level of pollution resulting 

from these sources. Such factors as public participation and inter/intragovernmental 

coordination should be included. Many tribes use state or federal tools and resources, 

such as Internet databases or publications, to identify the kinds of BMPs that will 

address or prevent the NPS issues identified in their waters. 

The assessment report should include a description of how those sources were 

identified and how the specific practices were chosen. 

It will be important to carefully consider the pollutant 

sources, so that the appropriate management practices 

can be selected. An efficient and effective way to 

address this category of information is to establish 

a technical committee to review the BMPs already 

identified in the surrounding region. If the tribe 

has worked with NRCS and is using that agency’s 

technical specifications, that information could be 

included.

4. A description of any existing tribal, state, federal, and 

other programs that might be used for controlling 

NPS pollution. This section should include federal, 

The following is a sample list of subcategories 

for agricultural NPS pollution.

Agriculture

 non-irrigated crop production 

 irrigated crop production 

 specialty crop production 

 pastureland 

 rangeland 

 feedlots (all types) 

 aquaculture 

 animal holding/management areas

 manure lagoons
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state, tribal, local, and nonprofit programs that provide (or could provide) funding or 

technical support for NPS work on tribal lands. The tribe should describe programs 

that are in use, as well as those that are available to the tribe but have not yet been 

actively pursued. Doing a bit of research for this information might identify new 

programs that could provide partnerships and assistance for new NPS programs.

Although there might be many sources of water quality data, data used to develop the 

assessment report must meet QA/QC requirements or be selected through an approved 

secondary data analysis protocol. Data sources could include data collected using 

section 106 and other federal agency funds, as well as data collected by other agencies, 

such as the U.S. Geological Survey (USGS). Where monitoring data are not available, 

visual observations, such as the NRCS Stream Visual Assessment Protocol described at 

www.nrcs.usda.gov/technical/ecs/aquatic/svapfnl.pdf, may be used. 

It is preferable for data to be geo-located and to show mean, median, ranges, and 

thresholds. The data need to be presented in a manner that documents impairments or 

threats based on water quality standards, narrative criteria, or water quality goals. The 

tribe’s analysis of the data will be the guide for prioritizing the places and watersheds 

to work in, and the kinds of BMPs that will be needed to control NPS impacts or 

protect high-value waters.

Format of an NPS Assessment Report

Section 319(a) of the CWA specifies the information that must be included in tribal NPS 

assessment reports (the four types of information described above). To facilitate the 

preparation of these reports, a suggested outline for an NPS assessment report follows. The 

notice and opportunity for public review and comment are covered in the section entitled 

Public Notice and Comment, which begins on page I-60; they are requirements for both 

assessment and management reports.

 Cover Page—Title and the date (month and year) of the assessment

 Table of Contents (but labeled simply as Contents)—A listing of the major sections of 

assessment report, lists of figures and tables, appendices, and corresponding page 

numbers

 Text (body of the report)—According to the headings of each major section of the 

assessment report and corresponding page numbers

	Overview

 Introduction

 Methodology

 Land Use Summary

 Surface and Ground Water Quality

 Results
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

 Discussion

 Selection of BMPs

 NPS Control Programs

 References/Sources of Information—Some tribes might already have collected data that 

will help them develop an NPS assessment report. With that information, tribes can 

assess NPS pollution problems and determine baseline water quality data without 

completing additional water quality surveys. Tribes can also use data collected with 

CWA section 106 funds to help identify high-priority problems. 

 Appendices

 Acronyms and Abbreviations List

The next section describes and provides examples for each component of an assessment 

report. Many of the examples that follow have been drawn from approved tribal NPS 

assessment reports. When developing and writing an assessment report, a tribe should take 

the time to make sure the report is well-documented, readable, and understandable by many 

different audiences, including tribal and EPA staff, tribal partners, and the public.

Overview

In the overview, state the purpose of the report and explain the need for an NPS assessment 

report for the tribal waters. The section should include a brief description of the reservation or 

other tribal lands, key NPS issues (why the report is being written, e.g., to establish baseline 

data for program, provide direction for the management program plan, or to meet some goal(s) 

that the tribe has for natural resources) and key conclusions. Also provide a general summary 

of the analysis that will follow, stressing major conclusions and broad areas of concern. Be 

sure to mention which categories and subcategories of NPS pollution were identified through 

your assessment. Discuss only significant data and general findings in this section. The section 

should be concise and ideally should not exceed one page. It is recommended that you write 

this section last so that it accurately reflects the rest of the report. 

Example from the Confederated Tribes of Grand Ronde 

(CTGR 2008a)

This report has been created to assess nonpoint source water quality on or upstream of 

lands owned in Trust by the Confederated Tribes of Grand Ronde (hereafter, the Tribe) 

and provide background information for a nonpoint source management plan. The Tribe 

currently owns approximately 10,871 acres of land in Reservation or Trust Status, with 

an additional 129 acres pending conversion into Trust status (Table I-1).

Section 319 of the federal Clean Water Act provides authority to states, territories, and 

tribes to address problems associated with nonpoint sources of pollution. Furthermore, 

the U.S. Environmental Protection Agency uses section 319 as the primary source of 
Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

I-12 | Part 1: The Clean Water Act Section 319 Program

funding to address nonpoint source problems. In order to qualify for section 319 grants, 

the Tribe must complete a nonpoint source assessment report and a nonpoint source 

management plan that are approved by the U.S. Environmental Protection Agency.

The goal of this assessment is to focus attention on water quality parameters and issues 

that point to significant or potentially significant nonpoint sources of pollution and 

provide guidance on how to monitor effectively and alleviate significant sources.

Table I-1. Size and status of land owned by Confederated Tribes of Grand Ronde 

(CTGR 2008a)

Map ID Tract name County Acres Status

1 Reservation Yamhill 10,051.32 Reservation

2 Stimson Yamhill 160.00 Trust

3 Risseeuw Yamhill 78.14 Trust

4 Eastman Yamhill 9.99 Trust

5 Natural Resources Yamhill 36.61 Trust

6 King Yamhill 11.93 Trust

7 AGZ Yamhill 9.13 Pending Trust

8 Camping Yamhill 8.90 Reservation

9 Elders’ Housing Yamhill 19.55 Reservation

10 Mahurin Yamhill 10.26 Pending Trust

11 Smith Yamhill 31.31 Pending Trust

12 Tribal Headquarters Polk 118.92 Reservation

13 Procurement Polk 2.00 Trust

14 Multi-family housing Polk 19.73 Trust

15 Family housing 2 Polk 20.21 Trust

16 Cemetery Polk 7.52 Reservation

17 Grand Meadows Polk 10.76 Reservation

18 Windsor Polk 7.90 Trust

19 I.P. Polk 54.21 Pending Trust

20 Round Valley Polk 24.33 Pending Trust

21 Old Depot Polk 2.24 Reservation

22 Casino HR Polk 4.69 Reservation

23 Casino Polk 84.45 Reservation

24 Gould Polk 6.68 Reservation

25 C-Store/RV Park Polk 12.40 Reservation

26 North Busswell Polk 58.47 Reservation

27 Fort Yamhill Park Polk 113.53 Trust

28 New Pow-wow grounds Polk 25.55 Trust
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Example from the Shakopee Mdewakanton Sioux Community 

(SMSC 2008)

Fee and Trust lands of the Shakopee Mdewakanton Sioux Community (SMSC) consist of 

approximately 2,625 acres in Scott County, Minnesota. SMSC lands contain various types 

of surface waters including lakes, streams and wetlands, and three groundwater wells 

that provide drinking water for the community. Rapid urban development on SMSC lands 

impacts waters via nonpoint source pollution (NPS) such as nitrogen, phosphorous, salts, 

oil, heavy metals, and sediment. Potential sources of NPS pollution include agricultural 

runoff; commercial runoff from buildings and parking lots; urban runoff from roadways, 

turf areas and construction activities; and residential runoff from driveways and lawns.

The principal goal of this pollution assessment is to evaluate current NPS pollution 

impacts on SMSC water and outline measures to ameliorate future impacts.

Surface water quality data, biological data, and groundwater well testing data with an 

ArcView Geographic Information System database were used to evaluate individual 

SMSC surface waters. NPS pollution has negatively impacted all surface waters located 

on SMSC lands. Impacts include degraded water quality, reduced fisheries and wildlife 

habitat potential and reduced aquatic species richness and diversity. Most SMSC 

waterbodies are moderately impacted, and provide partial support of primary and 

secondary contact, fisheries use, and full support for agricultural use based on State of 

Minnesota standards. However, one stream site located adjacent to the Reservation is 

seriously impacted by agricultural use, and does not support use categories for which 

it is classified. Proposed future land use changes as specified in the SMSC long-term 

comprehensive plan indicate more areas could become seriously impacted by NPS 

pollution. The SMSC adopted a Stormwater Management and Erosion Control ordinance 

in March 2003 to help protect water quality from development.

Introduction

The reader should come away from the introduction with an understanding of the reservation 

size, location, and fee/trust relationships and a summary of key water information—surface 

NPS pollution problems, the probable sources, and actions that can be taken to control 

them. The section should include a description of the tribe, including historical and land use 

development context and cultural issues. If the tribe has current land planning or other natural 

resources management programs, those programs should be described and related to the 

water quality assessment in this section. An example of that would be CWA section 106 goals. 

The introduction should also cover the goals and objectives of the report and describe the 

public comment process. A goal is a general statement of purpose; objectives are specific, 

measurable actions or intentions that lead to achieving the goal(s). 
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Examples:

 Goal statement: to identify and assess the nature and extent or threat of NPS pollution 

on reservation lands and waters

 Objective: to quantify and qualify the impairments to tributary X from pollutant Y 

The introduction is an excellent place to include maps of reservation lands and waterways. It 

is vital to establish a spatial context for pollution control activities, and maps are one of the 

quickest ways to do that. A map will allow the reader to quickly see where impaired waters 

are and what areas and communities they will affect. Tribes can include a regional map, a 

map of reservation lands, or a map of the watershed. If the tribe does not have map-making or 

geographic information system (GIS) capabilities, look for partners that can help, such as local 

universities.

Example from the Santa Ynez Band of Chumash Indians 

(SYCR 2006a)

The Santa Ynez Chumash Reservation is located in the south-central portion of Santa 

Barbara County, California. The Tribal lands consist of 148.28 acres in the Santa 

Ynez Valley and are inhabited by approximately 287 residents. The Santa Ynez Band 

of Chumash Indians (SYBCI, or Tribe) is annexing an additional 6.9 acres from Santa 

Barbara County for development of a museum, cultural center, and park. Zanja de 

Cota Creek, a perennial tributary to the Santa Ynez River, runs through the length 

of the Reservation. Residences flank the Creek on both sides, and a small amount of 

commercial development exists in the northern area. The Reservation sits atop the 

Upper Santa Ynez groundwater basin, which supplies a portion of drinking water to the 

Santa Ynez River Water Conservation District. The Tribe is concerned with improving 

and maintaining surface water and groundwater quality for future generations, as well as 

for the Zanja de Cota Creek watershed.

Accordingly, the Santa Ynez Band of Chumash Indians began the process of developing 

a Water Pollution Control Program (WPCP, or Program) in accordance with the Clean 

Water Act (CWA) and the Tribe’s original goals of ensuring fishable, swimmable, and safe 

waters. The ultimate goal of the WPCP is the development and implementation of water 

quality standards for future protection and sustained use of valuable Reservation water 

resources, protection of public health and welfare, and the enhancement of water quality.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Example from the Suquamish Tribe (ST 2008)

The goal of this assessment and management program is to create a general reference 

which the Suquamish Tribe can use to coordinate and maximize the effectiveness of its 

internal and external efforts to prevent, reduce and mitigate nonpoint source pollution 

of the waters within and adjacent to the Port Madison Indian Reservation. The objectives 

of the assessment and management program are: (1) Provide a description of the 

present status of Reservation waters, (2) to describe some of the processes that have 

a deleterious impact on those waters, and to (3), outline a range of options that can 

address current and foreseeable negative impacts. We understand that funds provided 

through section 319 of the Clean Water Act are to be used only to address nonpoint 

source pollution as it impairs or threatens the quality of Reservation waters.

The Port Madison Indian Reservation was established for the Suquamish Tribe under 

the terms of the Treaty of Point Elliott of 1855. The 7,392 acre Reservation is divided 

into “fee land” and “trust land.” Fee land, also known as “fee simple,” is land within the 

external boundaries of the Reservation that was principally sold to non-Indians and 

taken out of trust status under the General Allotment Act; fee land can be owned by 

Tribal members or other Native Americans. Trust land is held in trust by the federal 

government for the benefit of the tribe or tribal member; this land cannot be subject to 

municipal, county, state, or federal taxation.

Figure I-2. Location of Port Madison Indian Reservation.
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The general water use and criteria classification of surface waters within the basin has 

until recently been classified as AA (extraordinary). Characteristic uses for AA waters 

include water supply for domestic, industrial, and/or agricultural purposes; salmon and 

other fish rearing, spawning, and harvesting; shellfish (i.e., clam, oyster, mussel, crab) 

rearing, spawning, and harvesting; wildlife habitat; and, stock watering. The revised water 

quality standards for Washington State now simply regard the waters of the PMWRB 

as protected for the designated uses of: salmonid spawning, rearing, and migration; 

primary contact recreation; domestic, industrial, and agricultural water supply; stock 

watering; wildlife habitat; harvesting; commerce and navigation; boating; and aesthetic 

values (WAC 173-201A-600). This change appears to relax the dissolved oxygen and 

temperature criteria DO was 8.5 mg/L and is now 8.0 mg/L; temperature was 16 °C and 

is now 17.5 °C.

The climate of the study area is a marine zone with narrow temperature ranges and 

moist air. The average daytime low and high temperatures of the area ranges from 30s 

to 40s °F in the winter and 70s to 80s °F in the summer. The average annual rainfall 

is approximately 35 inches, with about 70% of the precipitation occurring during the 

period of October to March. Streamflow characteristics in the basin closely correspond 

with seasonal precipitation patterns. High flows are usually found during the higher 

precipitation periods of November to March. The lowest streamflows are normally 

found during the period of July to September (USGS 1979).

The primary objectives to achieve this goal are

 To perform water quality sampling and watershed evaluation;

 To evaluate beneficial uses and develop water quality standards for the protection 

of reservation water resources;

 To address specific modifications to correct degradation and improve conditions;

 To facilitate education and outreach programs; and

 To continue current monitoring and reevaluation as necessary.

This Non-point Source Pollution Assessment Report identifies possible sources of 

nonpoint source (NPS) pollution and describes the processes and programs needed 

for the Reservation to address NPS pollution. Upon approval of this report, the Tribe 

plans to apply for Clean Water Act Section 319(h) funding to establish and continue 

these programs, including “technical assistance, financial assistance, education, training, 

technology transfer, demonstration projects, and regulatory programs” (U.S. EPA 2000).
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Methodology

The methodology section describes the assessment methods used. The information in this 

section should include:

 How and when field data were collected (surface and ground water) 

 Timelines (years in which data were collected) 

 Spatial analysis units if GIS was used 

 Sources of historical data (for example, from state or other federal agencies) 

 The level of the quality of your data 

 Sampling design 

 Sampling parameters 

 Standards used 

 Any observations or assumptions made during data collection or analysis

 Data management

Example from the Confederated Tribes of Grand Ronde 

(CTGR 2008a)

The assessment area encompasses the Willamina Creek and Upper South Yamhill River 

5th-field watersheds with an emphasis on the Grand Ronde Reservation and Tribal 

Trust lands within these watersheds. Data used for the analysis of nonpoint sources of 

pollution within the assessment area came from a variety of sources, depending on the 

parameter. Since the Tribe has not established water quality standards of its own, the 

State of Oregon’s water quality standards are used. Included are:

 Streamflow. U.S. Geologic Survey streamflow gauging of Willamina Creek 

(#14193000) and South Yamhill River (#14192500). Both of these stations are 

below Tribal Trust lands. Data displayed are monthly averages of July, August, and 

September flows from 1934 to the early 1990s. No other long-term flow monitoring 

stations exist within the assessment area.

 Water temperature. Continuous summer monitoring by the Tribe at 32 sites and 

by the Yamhill Basin Council at 3 sites between 1999 and 2003 within and near Tribal 

lands. In order to obtain representative values for all stations for a common year 

(2003), station values missing in 2003 were estimated using a correlation between 

2003 and 2001 values.

 Bacteria. Monthly data for three stations (DEQ) in or near the assessment area 

from August 1986 to February 1988. Stations include; #10954 South Yamhill River 

upstream of Grand Ronde (near Midway), #10969 Willamina Creek downstream of 
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Willamina (near mouth), #10951 South Yamhill River at Rock Creek Road (upstream 

of Sheridan). Monthly data for five Tribal testing stations in the assessment area 

from March through June 2008. Stations are located on Coast Creek (as passes out 

of Parcel #1), Cosper Creek (as passes through Parcel #28), South Yamhill River (as 

passes through Parcel #23), Agency Creek (as passes through Parcel #12), and Wind 

River (as passes out of Parcel #1).

 Turbidity. Monthly data for three stations (DEQ) in or near the assessment area 

from August 1986 to February 1988. Stations include; #10954 South Yamhill River 

upstream of Grand Ronde (near Midway; upstream of Tribal Trust lands), #10969 

Willamina Creek downstream of Willamina (near mouth), #10951 South Yamhill 

River at Rock Creek Road (upstream of Sheridan).

 Nutrients. Total phosphorus and nitrate nitrogen at monthly intervals for three 

stations (DEQ) in or near the assessment area from August 1986 to February 

1988. Stations include; #10954 South Yamhill River upstream of Grand Ronde (near 

Midway), #10969 Willamina Creek downstream of Willamina (near mouth), #10951 

South Yamhill River at Rock Creek Road (upstream of Sheridan). Monthly data for 

five Tribal testing stations in the assessment area from February through June 2008.

Stations are located on Coast Creek (as passes out of Parcel #1), Cosper Creek 

(as passes through Parcel #28), South Yamhill River (as passes through Parcel #23), 

Agency Creek (as passes through Parcel #12), and Wind River (as passes out of 

Parcel #1).

 Macroinvertebrates. Fall monitoring by the Tribe from 1998 to 2002 at 35 sites; 

all sites were on or upstream of Tribal Trust lands. Not all sites were sampled each 

year. Results used in this report include general biotic integrity, EPT taxa richness 

(E = Ephemeroptera, P = Plecoptera and T = Trichoptera), and percentage of 

organisms that are intolerant EPT.

Some of this information might be included in your Quality Assurance Project Plan (QAPP), 

which should also be referenced in this section. Provide a timeline and explain how the data 

were collected (for example, field-collected or observational), the spatial analysis units, the 

sampling design, the parameters measured, and the standards/narrative criteria employed. 

Describe whether the tribe has its own standards or uses standards from another agency. 

Tribes could also use criteria from other sources based on the literature (e.g., nutrient levels 

for wild rice production).
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Example from the Santa Ynez Band of Chumash Indians 

(SYCR 2006a)

The Tribe is currently developing water quality standards with which to compare surface 

water monitoring results; they are also developing beneficial uses, numeric and narrative 

criteria, and an Antidegradation Policy. Eventually, Tribal narrative and numeric criteria 

will provide the Tribe with its own objectives for Reservation water resources. For the 

purpose of this assessment report, Central Coast RWQCB standards (State Water 

Resources Control Board 1994) have been utilized for evaluating the impact of nonpoint 

source pollution.

A habitat assessment and water quality sampling were performed in January 2005 by 

the Tribe. A historical review was conducted, which included (1) discussion with Tribe 

members and Tribal elders; (2) a review of historical photographs to determine changes 

in land use and fluctuations in the riparian canopy, and to identify significant mass 

wasting events within the watershed; and (3) a review of data collected since May 2004 

from surface water monitoring at the Chumash Wastewater Treatment Plant for the 

National Pollutant Discharge Elimination System (NPDES) permit number CA0050008.

The physical habitat survey was performed at locations ZDC-2, ZDC-3 and ZDC-5, and 

summarized in detail in the Draft Final Preliminary Water Quality Assessment Report, Zanja 

de Cota Creek (SYBCI 2005a).

The survey included the following elements:

 Use of geographic information system digital elevation data to delineate watershed 

boundaries and to map key features within the watershed;

 A walking reconnaissance of the entire length of the Zanja de Cota Creek from its 

confluence with the Santa Ynez River through Tribal lands to the community park 

above State Route (SR) 246;

 A driving tour with several stops to evaluate headwater conditions northeast of the 

City of Santa Ynez, land use, and other potential impacts within the watershed; and

 A review of historical photographs to determine changes in land use, fluctuations 

in the riparian canopy, and to identify significant mass wasting events within the 

watershed.

Monthly surface water sampling began December 2005, as outlined in the Sampling 

and Analysis Plan and Quality Assurance Project Plan (SYBCI 2005b). These water quality 

data are collected to create baseline standards for the Creek and to identify watershed 

characteristics, potential health concerns, and possible detection of contaminants within 

Zanja de Cota Creek for an overall assessment of water quality and system health.

Results from these events are summarized in the Draft Final Preliminary Water Quality 

Assessment (SYBCI 2005b) and in Sections 4.0, 5.0 and 6.0 of this report. Results of 

continued water quality monitoring will be discussed in quarterly monitoring reports.
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Monitoring includes the collection of in-situ parameters (DO, SC, temperature, turbidity, 

and pH) and grab samples from four sampling locations, ZDC-3, ZDC-5, ZDC-7, and 

ZDC- 8, which are analyzed for total dissolved solids (TDS), TSS, chloride, sulfate, 

phosphorus, total Kjeldahl nitrogen, nitrates, nitrites, ammonia, dissolved metals, boron, 

sodium, and bacterial indicators (total coliform, fecal coliform, and Enterococcus). After 

collection, the grab samples are preserved with ice and transported to the appropriate 

State-certified laboratory. Standard U.S. EPA analytical methods are used for all grab 

samples collected (SYBCI 2005).

Surface water samples taken from the January 2005 and current monitoring events were 

compared to the water quality objectives set by the Central Coast RWQCB within the 

Basin Plan. The levels set for TDS, chloride, sulfate, boron, sodium, nickel, and fecal 

coliform are based on yearly averages; therefore, a year’s worth of data needs to be 

collected to effectively compare the results. Constituents such as TSS, phosphorus, 

and dissolved metals (cadmium, chromium, copper, lead, mercury, and zinc), except 

nickel, have no maximum level set by the Central Coast RWQCB and will be contrasted 

between sampling locations and sampling events.

A comprehensive and detailed methodology will give your study credibility. Accurately 

reporting the methods will validate the data in the eyes of the reviewers. The tribe needs to 

show that it has collected samples using predetermined methods to ensure the accuracy of 

results. 

Land Use Summary

The land use summary explains existing land uses and the characterization of ecological 

conditions on reservation lands. When possible, use maps and identify watersheds at 

the 12 Hydrologic Unit Code (HUC) level, describing any subbasins appropriate to your 

assessment and management needs. Some of the physical characteristics to include are 

acreage, predominant land types and uses, topography, and information on soils and general 

geology. Be sure to highlight any characteristics or trends that affect water quality; for example, 

Karst topography (which allows runoff to easily enter ground water sources), a tendency for 

alternating flash flooding and droughts, or porous soils that trap and hold pollutants.

In addition, include a description of land uses and socioeconomic conditions in this section. 

Place emphasis on characteristics that factor into water quality, such as population density, 

economic activities, or unique challenges faced by residents. Use online resources, EPA 

Regional staff, and local or tribal authorities to gather information for this section. Some tribes 

have successfully partnered with state agencies, universities, volunteer groups, and other 

entities to gather land use and water resource information. Such partnerships help to lay the 

groundwork for later efforts to assess and manage water quality in areas where tribal and 

nontribal lands intersect.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

For this section and subsequent sections, EPA recommends that tribes present data in charts 

or tables to the extent possible. However, do not force the information into a format for which 

it is not suited. Tables and charts are recommended because they are an easy way to present a 

lot of information to the reader. 

Example from the Ute Mountain Ute Tribe (UMUT 2005a)

In the Four Corners region, rangeland and forest account for roughly 85 percent of the 

entire area, and they cover large areas of the Ute Mountain Ute Reservation as well.

Most of the Ute Mountain Ute land is either non-commercial timber land (forest) or 

rangeland used for open grazing (Table I-2). The Weeminuche Construction Authority 

uses several acres as an equipment yard for storage and maintenance of equipment and 

construction materials. Other uses include recreational use (e.g., Tribal Park), resource 

extraction activities, and irrigated agriculture. Outside of Towaoc, urban land use is 

essentially non-existent.

Accordingly, primary land uses on the Ute Mountain Ute Reservation include housing 

for tribal members, oil, natural gas, and sand and gravel extraction, grazing for Tribal 

livestock, and the Farm and Ranch Enterprise south of Sleeping Ute Mountain. In addition, 

the Ute Mountain Utes operate several tourism facilities, including the 125,000-acre Ute 

Mountain Tribal Park, the Ute Mountain Casino Hotel/Resort, the Sleeping Ute RV park, 

and Ute Mountain Pottery. Table I-2 summarizes the current land use on the reservation.

Table I-2. Land use in Ute Mountain Reservation

Use Area

(acres)

Irrigated farm land: Farm and Ranch Enterprise

Mancos Creek Farm

7,127

157

Timber land: Commercial

Non-commercial

0

163,767

Livestock Range 401,433

Other uses (non-agricultural) 1,614

Source: Tribal Land Use Commission, as cited in Ute Mountain Ute Tribe, 1999a.

The Ute Mountain Ute Tribe Farm and Ranch Enterprise is an irrigated agricultural 

project designed for 7,634 acres of Ute Mountain Reservation land in southwest 

Colorado (UMU 1999b). In addition, the Ute Mountain Ute Resources Department 

operates the smaller Mancos River Farm, which irrigates a few hundred acres. The Farm 

and Ranch Enterprise grows triticale and alfalfa hay and small grains including corn, 

wheat, and barley. The Mancos River farm grows hay and provides irrigated rangeland.

The Farm and Ranch Enterprise primarily grows crops, but also owns ~1,200 head of 

cattle. The purpose of the project is to operate a profitable agricultural enterprise, in 

addition to providing skilled year-round employment to Tribal members. The enterprise 
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was established, in part, following a dispute in the 1950s over the completion by the 

Bureau of Reclamation (BOR) of a project that diverted water away from the reservation 

to non-Indian ranches. Settlement of the water rights issues raised by this project 

eventually led to the creation of the Dolores Project and Ute Mountain Ute Farm and 

Ranch Enterprise.

The Farm and Ranch Enterprise uses water entitled to the Ute Mountain Utes by the 

Colorado Ute Water Settlement Act of 1988, which facilitated the importation of water 

for irrigation, municipal and industrial, recreation, and wildlife uses. The Dolores Project 

is a water storage and delivery project that resulted, in part, from the water rights 

settlement. Water is stored in McPhee Reservoir, located 10 miles north of Cortez, 

Colorado and 20 miles from the Ute Mountain Ute Reservation. Water for irrigation, 

wildlife and recreation is transported from the reservoir through the Towaoc Highline 

Canal, and municipal water is transported by pipeline from Cortez to Towaoc. The Farm 

and Ranch Enterprise is designed to encompass roughly 7,600 acres of irrigated cropland, 

primarily south of Sleeping Ute Mountain, and to use on the order of 23,000 acre-feet 

per year of water.

Oil and gas leases cover 61,745 acres in the south and east part of the reservation, 

54,195 acres of which are actively producing (UMU 1999a). An additional 290,000 acres 

of reservation is available for oil and gas exploration and development. The lands in Utah 

consist mainly of residential use and livestock use. Traditional plant gathering and limited 

gardening is practiced in Allen Canyon, the historical home of the Tribal Members who 

now live in White Mesa.

Example from the Red Lake Band of Chippewa Indians 

(RLBCI 2008a)

The following land use summary begins with a general narrative of land use organized by 

watershed, followed by a pie chart with the most common land uses (>1%) included as 

groups. Detailed maps with information about land use in all watersheds flowing onto 

and off of the diminished Reservation are shown below each narrative.

Shotley Brook Watershed

Shotley Brook is mostly an undeveloped watershed, primarily consisting of wetlands 

with interspersed upland forest stands. Basic land use is summarized in Table 1-3 and 

Figure 1-3.

Table I-3. Basic land use patterns in the Shotley Brook watershed

Area: 34,938 acres

Data Source: Red Lake DNR Land Use (Unpublished)

Wetland/Open Water Forest Farmland Urban Residential Other

22,237 acres 9,617 acres 1,812 acres 181 acres 40 acres 1,050 acres
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Figure I-3. General Shotley Brook watershed land use.

An important component of the land use summary is identifying your NPS categories at the 

subcategory level. Doing this will enable you to focus your remediation efforts and select 

appropriate BMPs. Table I-4 illustrates how you might summarize that information in this 

section. Note that the subcategories are self-described by the tribe.

Table I-4. Categories and subcategories of NPS pollution identified in assessment 

plan from the Red Lake Band of Chippewa Indians (RLBCI 2008a)

Category Subcategory Impairment level*

Acid Mine Drainage 4

Agriculture Crop-related 2

Grazing-related 2

Animal holding areas 1

Streambank erosion 3

Forestry Vegetated buffers 4

Streambank erosion 3

Hydromodification/Habitat Alteration Channelization 3

Vegetated buffers 3

Marinas/Boating 4

Roads, Highways, and Bridges Maintenance runoff 3

Urban Construction 3

Stormwater runoff 3

Wetland Riparian Management 4

Other Failing septic systems 4

Illegal dumping 3

* Scale of Impairments:

Level 1. Confirmed impairment currently exists.

Level 2. Possible impairment: not yet confirmed by monitoring data.

Level 3. NPS pollution occurring with no current impairment to waterbodies.

Level 4. No known NPS pollution occurring or impairment to waterbodies at this time.
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Example from Jamestown S’Klallan Tribe (JST 2007)

Figure 1-4 uses GIS mapping technology to illustrate land use in the Sequim-Dungeness 

Valley.

Figure I-4. Land use in Sequim/Dungeness Valley (JST 2007).

Surface and Ground Water Quality Summary

The intent of this section is to present a summary description of the condition of surface water 

and ground water on the reservation in terms of size, hydrology, and use. All water should 

be described, including rivers, creeks, lakes, reservoirs, wetlands, and canals. Be consistent 

in characterizing each waterbody: If it is a stream, call it a stream each time the waterbody 

is discussed. Frame the discussion of the waterbodies around the hydrology, water quality, 

and flow conditions. Include intermittent and ephemeral waterbodies as appropriate. Give the 

length of stream/river miles and lake acreage within the reservation boundaries or areas under 

tribal jurisdiction. Ground water should also be described.

Detailed maps and other graphics should be used to display the information if possible, 

including those freely available from Web sites. Including a few pictures of reservation 

waterbodies in this section is highly recommended. The following example, from the 
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Jamestown S’Klallam Tribe’s watershed-based plan, shows the Dungeness Tribe’s watershed 

planning area boundary (Figure I-5).

Figure I-5. Dungeness watershed planning area (JST 2007).
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This section should include enough information to create a picture of reservation waters for 

the reader. Presenting waterbody information on a watershed basis is encouraged. Ideally, 

the information is presented in a general way for the entire reservation and in detail for each 

watershed. It is important to include the following: 

 Water types (e.g., river, stream, wetland, reservoir, lake, etc.)

 Waterbody size/length 

 Watershed size 

 Pollution types (this includes existing pollution and potential pollution) 

 Usage information (i.e., cold-water fishery or recreation) 

 Historical water quality information, if available 

EPA recommends including hydrologic unit code (HUC) numbers in watershed descriptions. 

A HUC is a 2- to 12-digit number assigned by the USGS as part of its surface waterbody 

classification system. The United States is divided and subdivided into successively smaller 

hydrologic units, which are classified into four levels: regions, subregions, accounting units, 

and cataloging units. The hydrologic units are nested, from the smallest (cataloging units) to 

the largest (regions). Each hydrologic unit is identified by a unique HUC on the basis of the 

four levels of classification in the hydrologic unit system, http://water.usgs.gov/GIS/huc.html. 

It is easy to obtain your watershed’s HUC on EPA’s Surf Your Watershed Web site, 

www.epa.gov/surf. Once you have the HUCs, you will be able to link your information with 

other data storage programs. 

Tribes might not need to collect new raw data. The tribal ambient or drinking water 

monitoring programs, as well as other federal and state agencies might have already collected 

data that can be used and incorporated into the assessment report. Most of that information is 

posted on agency Web sites, and can be easily located and downloaded for tribal use. Cite the 

source of the data in your report.

Example from the Shakopee Mdewakanton Sioux Community 

(SMSC 2008)

Shakopee Mdewakanton Sioux Community (SMSC) lands, located entirely within the 

Lower Minnesota River Watershed, contain two shallow lakes, three shallow, perennial 

and intermittent streams and numerous temporary to semipermanently flooded 

wetlands. The two lakes and three streams are partially located on SMSC land; most 

wetlands occur within property boundaries.

Land Department staff has collected surface water quality data since 1999 as part of 

CWA Section 106 grant funding. Sample sites have remained constant for the most 

part; however, a few sites have been eliminated while others have been established.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Parameters collected vary by site; all include nutrients: total phosphorus (TP), ortho 

phosphorus (OP), nitrite+nitrite (NO2+NO3), total kjeldahl nitrogen (TKN), ammonia 

(NH4), chlorophyll-a; some include heavy the metals of copper, lead and zinc as well 

as chloride. Land Department staff has also completed MNRAM function and value 

assessments on both lakes and many wetland areas.

SMSC waterbodies are degraded compared with pristine waterbodies located in the 

North Central Hardwood Forest ecoregion. Agriculture and urban impacts to lakes, 

streams, and wetlands are evident by inferior water quality and loss of vegetative 

diversity and wildlife habitat.

SMSC drinking water derives from the Prairie du Chien-Jordan and Franconia-IrontonGalesville aquifers. The Public Works Department completed and passed all tests 

required by the US EPA which includes daily testing of chlorine, fluoride, iron and 

manganese and regular testing of bacteria, pesticides and other contaminants. Both 

wells contain few contaminants, and both fully support drinking water use. Land staff 

designates SMSC groundwater as good water quality.

Results

The purpose of this section is to clearly define the status of reservation waters using 

presentation, analysis, and interpretation of available data for each waterbody. At the 

beginning of this section, it might be helpful to reiterate the most important NPS pollution 

problems or threats on the reservation. Although all significant pollutants should be 

addressed, special emphasis can be given to the most important pollutants by presenting 

more data and providing more in-depth interpretations for them. A general status of the 

waters should be presented in a narrative overview, which should be supported by a table 

summarizing the status of all waters of the reservation by waterbody. The information 

presented in your narrative section should include the following: 

 Waterbody name

 Area or length

 Each major type of biological, physical, or water quality parameter or pollutant 

measured or observed (e.g., fecal coliform, pH, Biotic Index, sedimentation, flow) 

 Any nonpoint causes or sources of concern (categories and subcategories) 

 Water quality parameters indicating impairments or threats and the severity of impact 

or threat (such as slightly impacted, moderately threatened, severely threatened or 

impacted)

 An assessment of the overall water quality condition (such as good, fair, poor)

 The type of information used to make the assessment (monitored or evaluated)
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This section should contain a summary of the data collected. The actual data should be 

included in an appendix, or a Web site or document should be referenced. Data analysis 

should be saved for the Discussion section that follows. When presenting collected data, it 

might be helpful to use subsections, including those for water quality data, beneficial use 

designations, and use impairment determinations. 

Monitoring data from the tribe’s water quality monitoring program, as well as data from 

other sources (USGS, state, others), should be summarized and presented by watershed in 

this chapter because watersheds are the basis for NPS management planning. Watershedscale maps would support this approach. Data should be presented in summary form and 

interpreted in this chapter, including data collected by the tribe, USGS, state agencies, and 

other entities. These data should be described in terms of date sampled or year/season 

assessed, number of years data were collected, and reliability/associated QA. It is important 

to indicate whether there are any significant data gaps, i.e., gaps that lead to major questions 

regarding the current status or condition of a waterbody.

Water quality standards or goals (approved or draft), if available, should be included in the 

data tables to assist in making use impairment determinations. Exceedances of maximum 

values presented in established standards could be presented as maximums, minimums, 

and averages for each sampling site. The number of exceedances needs to be expressed in 

relationship to the total number of samples and the sampling period. 

The section should conclude with a determination of which waterbodies are threatened or 

impaired by NPS pollution, and the general nature of the impairment or threat.

Example from the Red Lake Band of Chippewa Indians 

(RLBCI 2008a)

Waters on the Red Lake Reservation that have been historically monitored are generally 

only slightly impacted or in pristine condition. Many Reservation lakes and streams have 

never been sampled. This is due to the fact that the Reservation is extremely large with 

a water resources staff that is relatively small. It is likely that with continued monitoring 

new pollutants and sources will be discovered.

The tribe does not currently have official water quality standards in place. Minnesota 

state and/or EPA standards were used to determine whether waters were polluted 

or not. Although all major streams have been included in Table 1-5, lakes were only 

included if data existed in our databases.
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Table I-5. Results table for streams on the Red Lake Reservation

Waterbody Miles Monitored

Known 

pollutants Source Severity

Mosquito Creek 3 miles No None N/A N/A

Manomin Creek 10 miles Once (1990) None N/A N/A

Tamarac River 20 miles 1990-2006 None N/A N/A

Shotley Brook 8 miles Once (1990) None N/A N/A

Sucker Creek 3 miles No None N/A N/A

Battle River 51 miles 1990-2006 P Possible agricultural input and 

natural runoff

Unknown

Blackduck River 320 miles 1990-2006 P Possible agricultural input and 

natural runoff

Unknown

Hay Creek 17 miles No None N/A N/A

Wending Creek 8 miles No None N/A N/A

Mud River 25 miles 1990-2006 None N/A N/A

Shemahgun Creek 2 miles No None N/A N/A

Pike Creek 51 miles 1990-2006 FCB

P

Feedlot

Natural and agricultural runoff

Unknown

Little Rock Creek 12 miles No None N/A N/A

Big Rock Creek 11 miles No None N/A N/A

Sandy River 48 miles 1992-2006 None N/A N/A

Red Lake River 193 miles 1992-2006 None N/A N/A

Clearwater River 44 miles 1992-2006 TSS Agricultural Runoff Unknown

Example from the Soboba Band of Luiseño Indians (SBLI 2007)

The status of known and potential impairments to surface water bodies on or 

adjacent to Reservation Trust lands is summarized in Table I-6. The chemical quality 

of surface water on the Reservation, so far as is known, fully supports the existing 

uses of groundwater recharge, plant and wildlife habitat, and recreation. The overriding impairment to support of the existing surface water uses on the Reservation is 

the reduction of flows by off-Reservation diversions and groundwater pumping. This 

impairment has been considered by the Tribe primarily in the context of water rights.

Little information is available on water quality on the Reservation, although elevated 

coliform counts have been observed in Indian Creek and the San Jacinto River. There 

is no evidence to suggest any deterioration in the chemical quality of surface waters 

entering the Reservation, but few data are available from which to support this assertion.

Because of this lack of information, implementation of a formal program for monitoring 

of surface water quality and flows on a long-term basis is necessary to properly assess 

surface quality conditions on the Reservation.
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Table I-6. Surface waterbody* summary

Waterbody

Stream 

(miles) Impairment Source category Severity

San Jacinto River 4.5 Coliform Unknown Unknown

Sediment Natural and roads (erosion) Unknown

Pesticides Agriculture Unknown

Nitrate Waste water recharge 

(septic systems)

Unknown

Petroleum 

hydrocarbons

Casino parking lot runoff Unknown

Reduced flow Off-Reservation diversion 

and pumping

Severe

Indian Creek 3.8 Coliform Possibly agriculture 

(livestock)

High

Sediment Natural and roads, including 

stream crossings (erosion)

Unknown

Nitrate Waste water recharge 

(septic systems)

Unknown

Reduced flow Off-Reservation diversion 

and pumping

Severe

Poppet Creek 2.2 Sediment Natural and roads (erosion) Unknown

Pesticides Agriculture Unknown

Nitrate Agriculture (fertilizer) 

and waste water recharge 

(septic systems)

Unknown

Unknown Landfills (unpermitted) Unknown

Reduced flow Off-Reservation diversion 

and pumping

Severe

* Type of waterbody: rivers and streams on or adjacent to Reservation Trust lands.

Discussion

The purpose of this section is to interpret your results. This is where you discuss the 

relationship between the information presented in the Results section and the impacts on 

water quality (by NPS category) on the reservation. NPS pollution sources should be linked 

to water quality impairments and threats. It is here, for example, where the report could show 

that the fertilizer runoff that enters Stream X at area A is contributing to high nutrient levels at 

points B, C, and D. 

Identify the categories of NPS pollution (e.g., agriculture, silviculture, construction) that are 

causing the majority of the impaired water uses, and rank them by the amount of quantifiable 

impairment. Highlight the waters that are impaired by each category of pollution, and include 
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a description of the relationship between NPS pollution and specific impaired water quality 

parameters, as well as any subsequent effects. 

Finally, include a summary discussion of the interpretation and analysis of the data. In 

some cases, the linkages between water quality conditions captured through your data and 

observed conditions (categories and subcategories of NPS pollution) on the reservation lands 

or upstream might not be clear. In those cases, additional data may be needed to fully assess 

pollutant sources, or you might need to begin with a best professional judgment until those 

linkages can be better confirmed. Identifying causes and sources of NPS pollution is an 

ongoing process that becomes clearer with time. This section should conclude with your best 

determination of waterbody impairments by NPS pollution. 

Example from the Red Lake Band of Chippewa Indians 

(RLBCI 2008a)

Water quality on the Red Lake Reservation is generally very good. Lake TSI values are 

remaining stable with only a few exceptions that have shown a slight decrease in the past 

decade. The Red Lakes continue to fall into the Eutrophic category but remain a healthy 

walleye fishery. A large number of lakes have not been sampled and will require future 

monitoring.

Fecal coliform bacteria in Pike Creek are increasing the risk of human health issues 

on the Reservation. The major known input of FCB comes from a feedlot located just 

outside the Reservation.

High levels of nutrients and total suspended solids in streams are threatening aquatic 

life in Reservation waters. The major inputs of these pollutants are likely related to off 

Reservation agriculture and naturally high nutrient levels in organic soils.

Example from the Suquamish Tribe (ST 2008)

The Washington State DOE proposed 303(d) listings provide a succinct way to identify 

some of the effects of NPS pollution. Several of the streams are currently listed, among 

them, Grovers Creek, the largest within the PMWRB.

Table I-7 pulls together the stream, impervious area, identified pollutant concerns, 

typical NPS sources that contribute to the identified concern, and how much the NPS is 

likely to contribute to degradation of the stream. Red identifies the parameters that are 

proposed to be listed as category 5.

We have concerns about low flows in Grovers Creek. Table I-8 shows how the Minimum 

In-stream Flow increments change over time and repeat in the spring and fall of the year.

In the leftmost column are the Minimum In-stream Flow increments; the right hand side 

shows the time periods subject to the specific flows with time moving in a clockwise 

direction.
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Table I-7. Identified pollutant concerns in reservation waters and likely nonpoint sources

Stream 

subwatershed TIA %

Indentified pollutant concerns

Parameter (303(d) Category)

Nonpoint 

sources

Likely 

contribution

Stoljah 17.8 Dissolved Oxygen (5)

Fecal Coliform (5)

4000 High

7600 High

4500 Moderate

7000 High

7550 Moderate

8920 High

Kitsap 17 Dissolved Oxygen (5)

Fecal Coliform (4B)

4000 High

7600 High

4500 Moderate

7000 Moderate

7550 Moderate

7800 Moderate

8710 High

7700 High

Cowling 14.4 Dissolved Oxygen (5)

Fecal Coliform (5)

4000 High

7550 Moderate

7600 High

Indianola 13.4 Dissolved Oxygen (5)

Fecal Coliform (4B)

pH (2)

4000 High

7600 High

4500 High

7550 Moderate

7000 High

Kleabel 10.4 Dissolved Oxygen (2)

Fecal Coliform (5)

4000 High

7600 High

4500 Moderate

7550 Moderate

7000 Moderate

Grovers 10.2 Dissolved Oxygen (5)

Fecal Coliform (5)

Temperature (2)

Turbidity (2)

Low Flow

4000 High

7600 High

4500 High

7000 Moderate

7550 High

7800 High

8920 High

Sam Snyder 9.1 pH (5)

Low Flow

4500 High

7000 High

7550 Moderate

8600 Low

8920 High

Doe-Kag-Wats 6.9 2000 Moderate

7550 Moderate
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Table I-8. Minimum in-stream flows for Grovers Creek

Minimum 

in-stream 

flow (cfs)

Period

(colored cells indicate periods when the stream basin is closed to further appropriation.)

5.5 → → December 1st to April 14th → ↓

4.5 ↑ November 15th to November 30th April 15th to April 30th ↓

4 ↑ November 1st to November 14th May 1st to May 14th ↓

3.5 ↑ October 15th to October 31st May 15th to May 31st ↓

3 ↑ October 1st to October 14th June 1st to June 14th ↓

2.5 ↑ September 15th to September 30th June 15th to July 14th ↓

2 ↑ ← July 15th to September 14th ← ←

The following template illustrates a suggested method of displaying a summary of your results 

and the conclusion of your analyses as narrated in your discussion.

Discussion of NPS Pollution/Sources in Watershed/Subwatershed

 NPS pollution categories and subcategories of concern

 Impairments identified from water quality data analysis

 Location of NPS problems: In (Name) and (Name) subwatersheds; in marine subwatersheds only; 

throughout the reservation

Example: St. Mary’s Creek Watershed 

NPS Pollution Category: Agricultural Runoff

Subcategory: Cattle Grazing and Ranching Operations

 Soil slumping on streamside and other slopes in grazing areas (sediment)

 Loss of riparian vegetation from cattle grazing in and out of streams (sediment and temperature 

problems) 

 Contaminated runoff and direct deposition of manure and urine to streams (pathogens, ammonia)

Figure I-6. Summary template.

Selection of Best Management Practices

The purpose of this section is to identify how you will choose BMPs to address the NPS issues 

identified in your assessment report. Tribes should not discuss the implementation of the 

BMPs in this section because that information will be required in the management program 

plan (management plan). In this section, the tribe establishes only that there is an appropriate 

system for choosing which BMPs to implement on reservation lands. This section includes

1. Core participants. In addition to listing the agency(ies), organization(s), or task 

force(s) responsible for BMP selection, briefly describe their mission statements and 
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membership composition. Also identify the level of participation for each agency, 

organization, or task force. Here you should also discuss any specific programs (e.g., 

U.S. Department of Agriculture [USDA] cost-share programs) that have been contacted 

for BMP selection assistance. Types of participation in BMP selection include:

 Technical assistance

 Education 

 Demonstration projects

 Financial assistance

Example from the Ute Mountain Ute Tribe (UMUT 2005a)

Best management practices (BMPs) for the control of nonpoint sources of pollution will 

be selected based on various factors including information provided by the Non Point 

Source Task Force and decisions made by the Task Force. The Nonpoint Source Task 

Force consists of representatives from the following Tribal departments and enterprises 

and government: Environmental Programs Department, Farm and Ranch Enterprise, 

Energy Department, Weeminuche Construction Authority, Tribal Park, Planning 

Department, Natural Resources Department, Tribal Council and Executive Director’s 

Office. Non-tribal agencies represented periodically at the Nonpoint Source Task Force 

meetings include: Bureau of Indian Affairs, USDA-Natural Resources Conservation 

Service, U.S. Bureau of Reclamation, and the Indian Health Service.

Implementation of BMPs will be accomplished through a number of nonpoint source 

pollution programs, funding mechanisms, and educational programs conducted by the 

Tribe in conjunction with federal and state agencies. Some of the federal government 

agencies that can contribute to a nonpoint source pollution control program include:

 U.S. Department of Agriculture

 Bureau of Indian Affairs, Department of Interior

 Bureau of Reclamation, Department of Interior

 U.S. Environmental Protection Agency

 Indian Health Service

Additional discussion of funding sources and program requirements of each of these 

agencies is included in the Ute Mountain Ute Nonpoint Source Pollution Management 

Program Plan.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Example from the Soboba Band of Luiseño Indians (SBLI 2007)

Table I-9. Core participants for BMPs (SBLI 2007)

Participant Role

Tribal Council, Soboba Band 

of Luiseño Indians

Lead participant. Sets strategic policies and provides legal 

authorization for activities.

Environmental Department, 

Soboba Band of Luiseño 

Indians

Provides operational lead to surface water monitoring and 

pollution control activities. Conducts and oversees funding, 

implementation, and evaluation of monitoring programs and 

BMPs. Conduct and oversee educational programs for pollution 

reduction.

Public Works Department, 

Soboba Band of Luiseño 

Indians

Provide operational lead for road and firebreak construction, 

repair, and maintenance.

Soboba Water Utilities, 

Soboba Band of Luiseñio 

Indians

Provides monitoring of groundwater quality in Tribal wells.

San Jacinto River Watershed 

Council

Interagency coordination.

Riverside County Fire Control 

and Water Conservation 

District

Policy coordination, program review, and fire control 

coordination.

Lake Hemet Metropolitan 

Water District

Policy coordination and program review.

Eastern Metropolitan Water 

District

Policy coordination and program review.

U.S. EPA Technical and funding resource. Provides oversight of drinking 

water quality monitoring.

U.S. National Forest Service Fire control coordination and technical resource.

U.S. Bureau of Land 

Management

Fire control coordination and technical resource.

2. Public participation and governmental coordination. In this section, highlight the 

use of public participation and public comment in the process of selecting BMPs and 

any inter/intragovernmental coordination.
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Example from the Suquamish Tribe (ST 2008)

The model for the tribal decision making process regarding choosing BMPs most suitable 

to address each category and subcategory of nonpoint source pollution identified in our 

NPS assessment is as follows: 

1. Identify all BMPs that are appropriate to each type of NPS pollution through 

research and consultation.

2. Determine which of the above BMPs are suitable for the PMWRB in terms of scale, 

environment, and existing infrastructure.

3. Determine likely effectiveness of locally appropriate BMPs in reducing NPS loading 

through research, modeling, and consultation. Rank them based upon likely 

performance.

4. Consult with other relevant agencies and jurisdictions to determine which of 

the BMPs may best be used in coordination with their efforts. Develop formal 

cooperative agreement(s) when indicated. Identify multiple funding options where 

possible.

5. Determine which BMPs will have the most favorable results per unit cost.

6. Present options to public meeting of tribal council to allow tribal leadership, 

tribal members and nontribal public an opportunity to consider options, provide 

comment, and shape the implementation of the proposal.

7. Implement BMP with adequate resources to perform necessary maintenance and 

monitor performance.

8. Provide regular updates on BMP status and effectiveness for tribal council and 

other relevant agencies.

Example from the Shakopee Mdewakanton Sioux Community 

(SMSC 2008)

The above is, of course, an idealized version and it would most resemble our actual 

process in larger, more significant programs and projects, those requiring the greatest 

commitment and coordination of resources. For these, the Tribal Council will provide 

opportunities for public comment and review and may or may not grant approval 

as warranted. Where other governments are involved, appropriate government to 

government protocols will be adhered to and will be an integral part of the process.

Smaller proposals, such as low impact, inexpensive, site specific projects, or relatively 

minor publicity efforts that could be accomplished within our base funding level will 

typically undergo an internal review including the departments of fisheries, natural 

resources, and community development.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Section 319 of the CWA requires tribes to assess NPS pollution on SMSC surface 

waters and determine a management strategy for preventing current and future pollution 

problems. This report will be sent to federal, state, and local agencies including Scott 

County SWCD, NRCS, Minnesota DNR, MPCA, and the Cities of Shakopee and Prior 

Lake. Comments and recommendations on pollution prevention and implementation of 

BMPs will be incorporated into a final version of this document.

3. Existing BMPs. Describe existing BMPs and organize them by category of NPS 

pollution. A table is a straightforward way of listing the existing BMPs (an example 

table follows).

Table I-10. Existing agriculture BMPs by NPS category

NPS 

category

Nonpoint 

source

NRCS conservation practice 

standards Partners

Potential 

funding

Hydrologic 

and Habitat 

Modification

Historic 

Overgrazing, 

Erosion 

and Habitat 

Destruction 

and Natural 

Geologic

322 Channel Vegetation Tribal EPA/

NRCS

CWA 319

390 Riparian Herbaceous 

Cover

Tribal EPA/

NRCS

CWA 319

395 Stream Habitat 

Improvement and 

Management

Tribal EPA/

NRCS/ USFW/ 

University

CWA 319/

USFW

584 Stream Channel 

Stabilization

Tribal EPA/

NRCS

CWA 319

4. Pollution reduction. Include a description of the process that will be used to select 

BMPs aimed at reducing the level of pollution resulting from identified nonpoint 

sources of pollution. 

Example from the Red Lake Band of Chippewa Indians 

(RLBCI 2008a)

Table I-11 shows the BMPs that RLDNR Waters has identified as appropriate based on 

the pollutant sources addressed in this assessment as well as sources not yet resulting 

in impairment. These BMPs were chosen with input from RLDNR Forestry and Wildlife 

programs. The majority of the BMPs selected are intended to prevent NPS pollution 

rather than to remove it.
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Table I-11. NPS category and associated information (RLBCI 2008a)

NPS category Source BMP(s)

Responsible 

party

Potential 

funding 

sources

Agriculture Nutrients NRCS-590 

Nutrient 

Management

Private-off 

Reservation

USDA

Erosion NRCS-528 

Prescribed 

Grazing

Private-off 

Reservation

USDA

Pathogens NRCS-528 

Prescribed 

Grazing

Private-off 

Reservation

USDA

Pathogens NRCS-634 

Manure Transfer

Private-off 

Reservation

USDA

Forestry Erosion, Nutrients MN Voluntary 

Site-level Forest 

Management 

Guidelines

Tribe/Private 

Logging 

Operations 

On and Off 

Reservation

Tribe, 319, 

USDA

Hydromodification/

Habitat Alteration

Erosion Streambank 

Stabilization

USACE USACE, 319

Erosion Restoration 

of River 

Morphology

USACE USACE, 319

Roads, Highways, 

and Bridges

Run-off NRCS-570 Runoff ManagementBIA, Tribe, 

MNDOT

MNDOT, 

USDA, 319, BIA

Construction Run-off, Erosion NRCS-570 Runoff ManagementBIA, Private 

Contractors, 

Tribe

BIA, Tribe, 319, 

Contractors

Example from the Santa Ynez Band of Chumash Indians 

(SYCR 2006a)

The pollutants of highest threat to Zanja de Cota Creek fall under the “Urban” U.S. EPA 

NPS category. Corrective action will be taken to identify and/or resolve NPS pollution 

sources. Short-term goals include attempting to locate the source of bacterial inputs in 

Reservation waters. Long-term goals include continued public outreach and education, 

continued water quality monitoring, reduced future construction project impacts, and 

sustained land stewardship.

A microbial source tracking study should be conducted to ascertain the current sources 

of bacterial contamination so they may be mitigated. Bacterial Source Tracking is a 

tool that determines the DNA fingerprints of five colonies of E. coli and statistically 

differentiates it as being from human or animal sources. The primary benefits of using 
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

this tool are (1) it increases the ability of the Tribe to locate the source(s) of the 

contamination with some specificity and (2) blind samples can be used (i.e., a separate 

DNA fingerprint library does not have to be developed for the Zanja de Cota Creek).

An additional source tracking tool is to use Human Fecal Virus Tracking. Detection of 

human viruses in water samples can serve as an indicator of human contamination. The 

primary benefit to using this tool is its ability to isolate human-borne viral pathogens 

and provide a very sensitive indicator for potential human illnesses caused by contact 

with or consumption of contaminated surface water. Existing coliform data should be 

used to “isolate” trouble areas and then the DNA tracking techniques should be used 

to determine whether the source of the observed contamination is human (e.g., failed 

septic tanks or cesspools, leaking sanitary sewer pipelines, recreational use) or animal 

(e.g., concentrated animal facilities, wildlife, etc.). With this information, the Tribe could 

implement BMPs to eliminate or contain the source of contamination.

Existing NPS Control Programs

For each category of NPS pollution (e.g., agriculture, silviculture, urban), identify and describe 

all available programs for controlling nonpoint sources of pollution regardless of whether 

they are currently being used on reservation lands. These could include pollution prevention, 

public outreach, and education programs. Make sure to include programs that are beyond 

current direct tribal use but that affect the area of concern, such as federal, state, and local 

government programs, as well as any voluntary or nongovernment programs. This information 

can come from local sources, online sources, or your Regional EPA coordinator. You can also 

refer to the partners listed in your existing BMP table or your pollution reduction tables. 

Existing NPS pollution-reduction programs for reservation lands should be identified and 

generally discussed in this section. If there are no available programs, the tribe should identify 

that as a gap or development need. If possible, the tribe should list the efforts being made 

and any future plans to fill this gap. These programs might be tribal, local, state, or federal 

programs that deal with NPS management on tribal lands. This information gives the reader 

an idea of how the proposed activities fit into the water quality work already in progress. 

Example from the Ute Mountain Ute Tribe (UMUT 2005a)

Several programs and projects have been undertaken to address nonpoint source 

impacts to water quality on the Ute Mountain Ute Reservation, and more are currently 

underway. One project undertaken in 1999 was to plug an old well that was adding 

approximately 1 ton of salt per day to the lower San Juan River watershed. The well was 

plugged using CWA Section 106 Special Studies funding, and the salt load was removed 

from the system. Another project undertaken in 2002 was to reduce erosion in the 

greater Towaoc, Colorado area, particularly where a fuels-reduction, forest-thinning 

project had been undertaken. CWA section 106 Special Studies funds were used to 
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I-40 | Part 1: The Clean Water Act Section 319 Program

purchase grass seed in order to seed the disturbed area to stabilize soils and prevent 

sediment movement. Despite drought conditions, the grasses took hold and the project 

was successful.

Figure I-7. Newly planted native grasses

(UMUT 2005). Figure I-8. Map showing First Lake seeding areas 

(UMUT 2005).

Figure I-7 shows newly planted native grasses (completing with cheat grass) on Special Studies Project—

note slash pile to be burned during wetter conditions and steep hill with moderately successful seeding. 

Previously clear-cut steep hillside was not part of the fuels reduction project, but it was also seeded to 

prevent erosion. Figure I-8 is the project map for seeding done with the CWA Section 106 Special Studies 

money to prevent soil erosion after fuels treatment.

Funding from the Bureau of Reclamation is currently being used to enhance two 

reservoirs that support sport fisheries. First Lake and Horsheshoe Lake have both leaked 

severely in the past five years, causing the demise of those fisheries. Dirt work has been 

completed on each reservoir, and a polymer-based sealant or bentonite clay will be used 

to prevent further leakage in 2004. If this project is successful, fish will be stocked in each 

lake in 2005 or 2006.

A partnership with the Colorado Division of Wildlife, the Tribe’s Brunot Wildlife 

Department and Environmental Programs Departments, and Mesa Verde National Park 

has provided a significant ecological restoration to the Mancos River Watershed. The 

combination of massive, severe-intensity forest fires in the watershed in 2000 and a 

5-year drought caused the demise of most of the Mancos River fish. This stream segment 

is unique because it is populated by almost entirely native fish because of a barricade to 

migration of San Juan River fish upstream of the Tribe’s irrigation diversion dam near 
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Highway 491/666 in Colorado . An effort was 

made in 2002 to salvage some of the last Mancos 

River roundtail chubs—a fish species of “special 

concern” in Colorado, and listed as threatened 

in New Mexico . Through a successful captive 

breeding program, thousands of these fish were 

returned to the Mancos in September 2003 . 

Also, in April 2004, two other native Mancos 

River fish species were reintroduced to the 

river, the flannel mouth sucker and the blue head 

sucker .

Various other programs have been and are 

being developed to address nonpoint source 

pollution . The Tribe’s Ground Water Protection 

Plan was adopted in early 2005 . The Ground 

Water Protection Plan addresses various 

aquifers, the pollutants and/or land use practices 

that may degrade the quality of the resources, 

and how the Tribe intends to prevent that 

from happening . A major component of the 

Ground Water Protection Plan is a pesticide 

management plan that describes preventative 

measures and how to respond to the detection 

of those chemicals at various levels . Another 

preventative measure being undertaken for the 

protection of ground water in Utah is a solesource aquifer designation for the White Mesa, 

UT community drinking water aquifer . This 

designation will allow the Tribe to undertake 

more intensive preventative measures to ensure 

that the aquifer will meet Safe Drinking Water Act Standards . Two monitoring wells, 

sponsored by the Bureau of Reclamation, have been drilled into an overlying bedrock 

aquifer in White Mesa in order to monitor any pollution that may emanate from the 

White Mesa Uranium Mill, 3 miles north of the White Mesa Community of Utes . These 

wells will intercept any perched ground water that may be affected by the mill, indicate 

the level of pollution and allow a substantial time to mitigate the situation before any 

pollution reaches the sole-source aquifer 800–1000 feet below it .

Figure I-9. Tranferring flannel mouth suckers 

(UMUT 2005).

Figure I-10. Reintroducing fish with tribal/state 

teamwork (UMUT 2005).
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I-42 | Part 1: The Clean Water Act Section 319 Program

Example from the Red Cliff Band of Lake Superior Chippewa 

(RCBLSC 2008a)

The Tribe does not currently have a nonpoint source control program in place. The goal 

is to begin coordination within the Reservation and Tribal Departments, and between 

the Tribe and other agencies within the Bayfield Peninsula. The Assessment Report and 

the Management Plan are the first steps in implementing nonpoint source prevention and 

controls.

Reservation Forestry 

The Red Cliff Tribe does not have a Forestry Department. The Bureau of Indian Affairs 

handles sales of timber. A Forestry Management Plan is currently being drafted by the 

BIA and Environmental Department. The document will include BMPs to be utilized in 

forestry on Tribal lands. These BMPs will be incorporated into the Nonpoint Source 

Management Plan.

Tribal Roads

There are currently no formally adopted nonpoint source control measures. There 

is occasional cooperation between the Roads Department and the Environmental 

Department on such issues as weed control measures. Attempts are being made to use 

native seed mixes for revegetation and the most environmentally safe herbicides for 

weed control. Waters impacted by nonpoint source pollution are more susceptible to 

aggressive, non-native species entering the ecosystem. Invasive species can impair quality 

wildlife habitat, and are very difficult to eradicate once they are incorporated into an 

aquatic system.

Septic Inventory

A septic inventory is currently being completed and will be assessed by WISCAP.

The inventory is being carried out through an EPA grant facilitated by WISCAP with 

cooperation from Red Cliff staff. The project is entitled “The Red Cliff Septic and Repair 

Project”. After the inventory is complete, suspect systems will be inspected by a licensed 

inspector to determine which are in need of repair or replacement. The future goal 

is to obtain funding to implement repair and replacement, thus protecting the Tribe’s 

groundwater and surface water resources.

Conclusions

In this section, provide a summary of the key findings and recommendations of the NPS 

assessment report by watershed and list special concerns. Identify the categories of NPS 

pollution that are most detrimental and will be targeted through the section 319 program. 

Also discuss what is currently being done and plans for the future. This section should 

provide information on the priority order of the NPS issues on which the tribe will work. Also 
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

include a brief discussion regarding how the tribe has met the four eligibility requirements for 

receiving CWA 319 funding.

Example from the Consolidated Tribes of Grand Ronde 

(CTGR 2008a)

Formally, the streams in the Upper South Yamhill and Willamina 5th-field watersheds 

are listed as water-quality limited for flow modification and temperature due to forest 

practices in the upper watersheds and less protective agricultural practices in the 

lower watersheds. Despite the listings, evidence from macroinvertebrate and other 

data suggest that there is still a reasonably healthy ecosystem in place, especially in 

the headwaters of the two 5th-field watersheds that this assessment covers. When 

compared to the Portland and Salem metro areas, land use practices are relatively benign 

and of the type that yet-undiscovered problems are not likely to come to the surface.

Management of water quality by the Tribe, using progressive forestry practices and lowimpact development in the community, has generally been effective and more innovative 

than efforts on surrounding private land. So while we are concerned about the listings 

and do have evidence of reduced water quality lower in the watersheds, there are no 

major water quality issues within the assessment and none are expected in the near 

future. However, the Tribe wishes to work with neighboring landowners to modify land 

use practices that degrade water quality (such as removing or reducing riparian zones) 

and maintain the areas of existing good water quality.

Example from the Ute Mountain Ute Tribe (UMUT 2005a)

As described in this assessment, various watersheds on the Ute Mountain Ute 

Reservation have nonpoint source pollution issues. These include erosion and 

sedimentation, bacteria loading, nutrient enrichment, salinity leaching and loading, 

selenium enrichment, and radionuclide contamination. Sources and causes of these 

problems vary from overgrazing and road building to historic mining activities and 

irrigation of marine shale soils. Each issue will be addressed in the long term using 

existing regulatory and management programs, a CWA Section 319 Nonpoint Source 

Management Program, and on-the-ground projects funded by various sources including, 

but not limited to, CWA Section 319(h) funding. Working with the Nonpoint Source 

Task Force to identify new problems not identified in this assessment and solutions 

to them and the issues herein, management changes will be incorporated into day to 

day operations to minimize and mitigate nonpoint source pollution. Implementation of 

a CWA Section 319(b) Nonpoint Source Management Program Plan will provide the 

framework for selection and implementation of best management practices and nonpoint 

source pollution mitigation strategies.
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Nonpoint Source Management 

Program Plan for 319(h) 

Eligibility

The management program plan (management plan) 

describes how the tribe will use the information contained 

in the assessment report to address identified water quality 

impairments and threats. The management plan elaborates 

on the specific activities to be undertaken to improve or maintain conditions as documented 

in the assessment report. It is important to note that the CWA requires that the management 

plan cover at a minimum a 4-year period, with the expectation that it will be updated in 

the fifth year. EPA encourages tribes to develop management plan periods longer than 5 

years, where the first 4 years have specific details and future years are more general and are 

then updated as part of the fifth-year update. However, if major changes need to be made 

before the fourth or fifth year, it is acceptable to revise the management plan. Public notice 

and opportunity to comment are also required for the plan and may be done separately or 

in conjunction with the assessment report. The section titled Public Notice and Comment, 

beginning on page I-60, provides more information regarding the topic of public participation.

Components of a Nonpoint Source Management Program Plan

This section describes what the CWA requires in a 

management program plan. The CWA specifically requires 

the following minimum components in an approvable 

program plan, and they must be covered in the program 

plan document. Following this section is a suggested format 

for writing the plan; the format integrates the required 

information and allows tribes to describe additional 

conditions and issues as desired.

1. Identification of BMPs and other measures to reduce 

NPS pollutant loadings by category and subcategory. 

The categories and subcategories are those found in your 

assessment report. Although you should have a list of 

possible BMPs, you should identify those that will be 

used to address specific polluted runoff sources.

2. Identification of programs that can help you to 

implement your NPS management program. These could 

include, as appropriate, nonregulatory or regulatory 

programs for enforcement, technical assistance, financial 

assistance, education, training, technology transfer, and

Checklist for Applicants

What you need to have in your management 

plan

 Identification of BMPs you plan to use

 Identification of programs you will use 

to implement BMPs

 Schedule for implementing BMPs, with 

annual milestones

 Certification of tribal authority

 Sources of federal and other financial 

assistance programs

 Existing programs to ensure no conflict

 List of local and private experts who will 

assist the tribe in implementing BMPs

 Plan should be developed on a 

watershed basis (encouraged, not 

required)

In this section, you will find

• Components and format 

required for a management 

plan

• Recent tribal examples for 

each component
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

demonstration projects. At a minimum, the programs listed in this section must 

also be on the program list in the assessment report, but the list could include other 

programs to be engaged or developed in the future. This process will assist you 

in identifying all potential resources available, including those that might not be 

immediately apparent to the tribe. 

3. A schedule containing annual milestones for using the program implementation 

methods identified in 1 and 2 above. There should be an annual schedule for the first 

four years. This schedule should reflect the implementation of BMPs identified in 2 

above. The schedule should address the most important NPS conditions or gaps in 

priority order. For example, the most critical sources should be addressed in the first 

year. In addition to the time frame, each milestone should include the measure/criteria 

that will be used to document achievement of the milestone.

4. Certification from the tribal legal counsel that the tribe’s laws provide adequate 

tribal authority to implement the program. Any relevant information from the TAS 

application may be referenced. This certification may also be a part of the management 

plan submittal or an appendix. This certification is sometimes elaborated on in the text 

by including descriptions of tribal ordinances, constitutional powers, and the like.

5. Identification of all potential sources of federal and other financial assistance programs 

and funding that might support your NPS program. You may use the information from 

the assessment report.

6. Identification of the federal financial assistance programs and federal development 

projects that affect tribal water resources. These might include individual assistance 

applications or development projects. Tribes conduct this review to ensure that work 

being done under the section 319 program is not being undone or duplicated by some 

other federally funded project.

7. Identification of local and private experts (e.g., range conservationists, fish and wildlife 

staff, hydrologists, agricultural experts) to be used in developing and implementing 

a management program. EPA strongly encourages tribes to involve local and public 

agencies and organizations that have expertise in control of NPS pollution to the 

maximum extent practicable. This reinforces the importance of water resource 

partnerships, public notice and comment periods, and the cooperation requirement in 

the administrative section of the statute (per CWA section 319 (c)). 

8. Development on a watershed basis. To the maximum extent practicable, tribes should 

develop and implement the management program on a watershed basis. For a tribe, 

this might mean developing a strategy for implementing the program on a watershed 

basis. EPA’s handbook for watershed planning (www.epa.gov/nps/watershed_handbook) 

could be used as a framework to organize activities on the basis of watershed 

boundaries. Working on a watershed basis would also help tribes when seeking section 

319 tribal competitive funding.
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Format for the Management Program Plan

Your management program plan should contain the following components, which address 

each of the numbered plan components described above. Each of the main body components 

is explained in detail below.

 Cover Page—Title and the date (month and year) of the plan

 Table of Contents (but labeled simply as Contents)—A listing of the major sections of 

management program plan, lists of figures and tables, appendices, and corresponding 

page numbers

 Text (body of the report)—According to the headings of each major section of the 

management program plan as listed in the table of contents

 Overview

 Introduction

 Summary of Tribal Management Program

 Contents of the Management Program Plan 

 Identify possible BMPs, programs, and funding to support your implementation 

activities. (As part of this section, identify watershed-based activities, if done). 

 List of local and private experts who will help you to implement your program

 Schedule for BMP implementation

 Certification of tribal authority

 References/Sources of Information

 Appendices

 Acronyms and Abbreviations List

Overview Section 

Provide a summary of the water resources, uses, and impairments/threats from NPS pollution 

from your assessment report. Describe the need for an NPS program and the environmental 

setting. Are there special features, needs, or cultural issues that will affect your program? Use 

a map to describe the water resources that will be addressed. Describe where the certification 

of tribal authority is found. For example, the certification could be found in the TAS 

documentation, the assessment report or in an appendix. The same approach can be taken for 

the public notice information.

Example from the Stillaguamish Tribe of Indians (STOI 2008)

The Stillaguamish Tribe of Indians (Tribe) is a signatory to the Treaty of Point Elliot, 

which secures the Tribe’s right to harvest fish. The treaty fishing right includes both the 

right to harvest fish in the Tribe’s Usual and Accustomed (U&A) manner and the right 
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

to have fish to harvest. Therefore, the Tribe’s treaty rights also reserve the right to 

protect the habitat upon which fish depend within the Tribe’s U&A, which is the entire 

Stillaguamish Watershed. It is therefore important to the Tribe that fish and fish habitat 

be protected to their fullest extent in order to assure productivity of the resource 

and the continued livelihood of tribal members. Healthy fish habitat is dependent upon 

the quality of the surface water resources that fish inhabit. Nonpoint source (NPS) 

pollution continues to degrade water quality of surface waters on the Tribe’s informal 

“Reservation” and outside of the “Reservation” but within the Tribe’s U&A, which in 

turn leads to impacts on ecosystems including fish habitat and human health.

The Stillaguamish Tribe has been managing NPS pollution through various programs 

for well over 20 years. However, only recently has the Tribe begun to assess NPS 

pollution specifically on Tribal land. This NPS assessment report and management 

plan serve as the beginning point to provide a greater focus on the management of 

NPS pollution in Tribally managed waters. The NPS Assessment Report provides an 

understanding of the major sources of NPS pollution affecting Tribal waters, which 

include development, forest practices, agricultural practices and hydromodification. This 

plan will describe the various aspects of the Tribe’s NPS management initiatives, including 

a description of actions, priority for their implementation, and estimated budgeting 

requirements. Elements of these programs were developed to address NPS pollution 

problems identified from the assessment of Tribal waters, and to provide long-term, 

comprehensive planning recommendations for watershed protection.

Example from the Confederated Tribes of Grand Ronde 

(CTGR 2008b)

The purpose of this document is to describe the components of a nonpoint source 

pollution management program for lands owned and managed by the Confederated 

Tribes of the Grand Ronde (hereafter, the Tribe). The management program will help 

assure that nonpoint sources of pollution do not become a problem on Tribal lands. In 

addition, the program will assist with coordinating with adjacent landowners to minimize 

their effects on water quality.

Existing data suggest that Reservation streams have relatively high water quality, 

especially on forestland where a comprehensive Forest Practices Ordinance has been 

in effect for many years. The cumulative environmental effects of forest activities are 

addressed in a Biological Assessment for the 10-year Natural Resources Management 

Plan (Confederated Tribes of Grand Ronde 2002 and 2002). Best Management Practices 

on land being developed in the town of Grand Ronde and at the Casino site include 

a progressive plan to collect and re-use runoff water. A Wetland Management Plan 

describes the treatment of wetlands that are surrounded by developed land or are soon 

to be developed (Adolfson Associates 2005).
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Recommended additions to the nonpoint pollution management program include 

collecting more complete and up-to-date water quality data to determine if best 

management practices need to be altered to avoid nonpoint pollution problems. This 

monitoring will also provide data to inform adjacent forest landowners about stream 

protection needs. Existing data indicate that stream temperatures increase rapidly for 

some streams that flow through adjacent private lands.

Introduction 

Describe the goals and objectives for the NPS program. These might be water quality 

restoration for impaired areas and the protection of high-quality waters, as well as controlling 

NPS pollution. Identify strategies that the tribe is now employing or will employ to ensure 

a successful program. Describe the geographic extent of where the program will be 

implemented. Sometimes a tribe might focus on a portion of the reservation or want to work 

outside the reservation in a cooperative manner to solve a water quality problem in reservation 

waters. Describe how both reservation and fee lands will be addressed.

Example from Red Lake Band of Chippewa Indians (RLBC 2008b)

The primary goal of the NPS management program is to prevent and control pollution 

from nonpoint sources and protect or improve water quality on the Reservation. This 

will be accomplished through emphasis on preventative education in order to protect 

and preserve tribal waters. These goals will be accomplished by devoting the Section 319 

program funding to the following objectives:

1. Implement watershed Best Management Practices (BMPs) and work toward 

watershed management in an effort to preserve water quality.

2. Environmental Education

a) Continue to educate the public by organizing the annual water festival.

b) Work with Riverwatch.

c) Develop a citizen/student monitoring program on the Reservation.

3. Develop a general habitat protection policy and environmental protection 

ordinance.

a) Ordinances will include shoreline development requirements and riparian zone 

requirements for development, silviculture, and agriculture.

4. Install detention/treatment ponds, rain gardens, sediment basins, etc., to treat 

major stormwater discharge points not subject to NPDES requirements.

5. Expand baseline monitoring in areas of current or likely future NPS pollution input.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Example from the Suquamish Tribe (ST 2008)

The goal of the management program is to create a general reference which the 

Suquamish tribe can use to coordinate and maximize the effectiveness of its internal 

and external efforts to prevent, reduce and mitigate nonpoint source pollution of the 

waters within and adjacent to the Port Madison Indian Reservation. The objectives of the 

assessment and management program are: (1) Provide a description of the present status 

of Reservation waters, (2) to describe some of the processes that have a deleterious 

impact on those waters, and to (3), outline a range of options that can address current 

and foreseeable negative impacts.

We will focus on protecting sub-watersheds and catchments that have the lowest 

percentage of TIA, and work to preserve the integrity of those stream systems. At the 

same time, we will prioritize remediation, restoration, and mitigation efforts in the subwatersheds with the highest percentages of TIA. As the PMWRB is a fairly small area and 

there can be much variation within each stream basin, protection and restoration efforts 

may simultaneously be applied to a single stream system.

We will rank the streams themselves based on available data regarding physical, chemical 

and biological parameters. Our methodology will be that described by Scholz and Booth, 

(2001), or another appropriate to the characteristics of streams in the PMWRB. They 

describe an efficient way to evaluate the functioning level of stream reaches in order to 

better focus management efforts.

Management Program Summary 

Describe tribal authorities, resource plans, ordinances, and other policies. Provide a 

description of the administrative location of the program within the tribal government and 

relationships with other tribal governance structures. Is there an anticipated staffing structure? 

Will the program be watershed-based? Why or why not? Describe the approach for using local 

experts, managing cooperative reporting, and conducting consistency reviews of other federal 

projects the tribe is undertaking. 

Example from the Confederated Tribes of Grand Ronde 

(CTGR 2008b)

The Tribe’s Natural Resources Division manages the nonpoint pollution management 

program. Programs within the Division include timber and roads, silviculture and 

fire protection, fish and wildlife, environmental resources, and recreation. The staff 

responsible for nonpoint pollution control maintains ties to managers that are in charge 

of infrastructure planning and construction for Tribal lands within the town of Grand 

Ronde and at the Casino. For infrastructure planning and construction, the primary 

nonpoint pollution management issue is the routing, collection, and re-use of runoff and 

other wastewater.
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The Tribal Council provides ultimate oversight on decisions concerning nonpoint 

pollution management. Tribal documents that help guide their decisions on nonpoint 

pollution management issues include:

1. The Environmental Protection Ordinance (Tribal code 651)

2. Forest Practices Ordinance (Tribal code 6.20)

3. Natural Resources Management Plan (2003 to 2012)

4. Wetlands Management Plan (2005)

5. Noxious Weed Inventory and Management Plan (2005)

No Tribal ordinances currently exist that are specific to nonpoint source management 

issues related to infrastructure planning and construction. The best management 

practices outlined by the federal Department of Housing and Urban Development for 

construction currently serve as the minimal standards that apply to Tribal projects.

The legal authority for the proposed nonpoint source management program is based on 

a 1934 decision regarding the powers of Indian Tribes and a section of the Constitution 

for the Confederated Tribes of the Grand Ronde. On October 25, 1934, the Solicitor of 

the Department of the Interior issued an opinion describing the powers of Indian Tribes 

that is still cited today. A number of powers in that opinion relate directly to the question 

of Tribal regulatory authority. Within the Constitution for the Confederated Tribes of 

Grand Ronde is a section (Article I, Section 1) that describes the jurisdiction of the Tribe.

It reads:

“The jurisdiction of the Confederated Tribes of the Grand Ronde Community of Oregon 

shall extend, to the fullest extent possible under Federal Law, over all lands, waters, 

property, airspace, minerals and other natural resources, and any interest therein, either 

now or in the future, owned by the Tribe or individual members held in trust status or 

located within the boundaries of the tribal reservation which will be established pursuant 

to the Grand Ronde Restoration Act, notwithstanding the issuance of any existing or 

future patent or right-of-way.”

Excerpt from the Puyallup Tribe of Indians (PTOI 2008)

The legal authority for the administration of the Tribe’s proposed nonpoint management 

program is the 319 Treatment-as-a-State application that is concurrently under review 

by EPA legal counsel. This application relied on the 1994 WQS TAS application under 

Section 303 and 518 of the CWA that was approved by EPA in 1994 and the federal 

TAS simplification rule. The designated tribal department that is responsible for 

program implementation is the Environmental Department with three full-time water 

program staff and the Tribal Natural Resources Director, in coordination with Tribal 

Fisheries. These staff are also responsible for coordination with agencies. Full program 

implementation will require the hiring of additional staff.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Identification and selection of BMPs that will achieve the Tribe’s goals and objectives 

outlined above were selected by Tribal Environmental staff with approval from the 

Tribal Natural Resources Director. The Director reports daily to the Tribal Council.

Best professional judgment of the staff and coordination and consultation with tribal and 

agency biologists, tribal members, and planners have and will continue to validate, and if 

necessary, adjust BMP selection to address major stressors and sources of impairment 

on the Reservation and throughout the watershed. The Tribal Natural Resources 

Director, Water Program Manager and technicians have over 50 years of experience 

working for the Tribe, addressing environmental issues.

BMP selection and program development depends on land ownership, jurisdiction, and 

funding. The Tribe recognizes the importance of continuing to acquire lands, particularly 

in the floodplain and along riparian corridors. Controlling land use in the floodplain and 

adjacent to streams is crucial to preventing and mitigating nonpoint pollution. The Tribe 

will provide technical support in the development and implementation of BMPs for those 

lands and waters that we do not have jurisdiction.

Funding plays a crucial role in BMP implementation. The Tribe’s Environmental Department 

is mostly grant funded, thus resources are limited. Tribal BMP priorities don’t always 

align with available funding. Section 106, and GAP funds are currently used to develop 

environmental programs, monitor and implement water pollution control projects.

Continued reliance on outside sources of funding for NPS program implementation is 

expected.

Management Program Description 

This section describes in detail the scope, structure, and functions of the program, including 

all work anticipated under the NPS pollution control program.

In this section, describe the NPS pollution categories and subcategories to be addressed and 

relate them back to the specific information on the nature and scope of the issue presented 

in the assessment report. Tribes may choose to address each category of NPS pollution in 

a separate subsection in the plan. Each category should have a goal, as well as short- and 

long-term objectives, covering the five-year cycle of the program plan. Also outline mid-cycle 

goals/milestones for the next five to ten years that would provide scope and direction for the 

program update to be undertaken during the fifth year. It might also be important to establish 

a long-term set of milestones or outcomes looking forward more than 10 years. Some tribes 

use their general natural resources management documents to define long-range projections 

for resource improvements.

Elaborate upon specific actions to be taken for each year in the program plan. The actions 

proposed should relate to the problems identified in the assessment report. These actions will 
Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

I-52 | Part 1: The Clean Water Act Section 319 Program

be your schedule of work and the basis for annual work plans submitted for CWA section 319 

funding. Include specific information on the type, location, and size of BMPs to be used and 

the rationale for these decisions. Identify the entity responsible for implementing the BMPs; 

for example, tribal staff, NRCS personnel, or contractors. If there are cooperators or multiple 

funding sources for any of the practices, identify and describe them. Describe any plans for 

long-term operation and maintenance of the management practices. Discuss how success will 

be measured, such as the number of BMPs installed, their impact on water quality, and so on; 

these will become your measurable milestones.

Also, describe your polluted runoff issues in a way that clearly identifies nonpoint sources and 

differentiates them from point sources that might be controlled under stormwater permits. 

Ensure that you review other programs that might affect the NPS program.

Example from Ute Mountain Ute Tribe (UMUT 2005b)

General Management Plan Information

The overall goal of the management program is to improve water quality on Ute 

Mountain Ute lands. By establishing water quality standards, the Ute Mountain Ute Tribe 

has recognized a goal of ensuring that all water sources meet water quality standards 

for their designated uses. The nonpoint source pollution management program, in 

conjunction with other Ute Mountain Ute programs, will contribute to this objective.

General program milestones can be seen in Table I-12.

Table I-12. General program milestones (UMUT 2005b)

Activitya

Frequency/ 

end year

Submit NPS assessment report to EPA 2005

Submit management program to EPA 2005

Submit application for Treatment as a State for CWA Section 319 2005

Propose NPS Management plan to Tribal Council 2005

Appoint NPS committee and convene first meeting Assembled in 

2003/04 

Again in 2005

Update management program as needed and review with NPS committee and 

Tribal Council

Annually

Submit annual status reports to EPA Annually

Convene NPS committee to review projects and the overall program and set 

priorities for next fiscal year

Annually

Incorporate priorities into work plan for NPS program and submit to funding 

agencies (Tribal, EPA, State, USDA, IHS, BIA)

2005 and 

beyond

a

 Completion of nonpoint source activities will be contingent on program funding

NPS = Nonpoint source

EPA = U.S. Environmental Protection Agency, 

Region 8

USDA = U.S. Department of Agriculture

IHS = Indian Health Service

BIA = Bureau of Indian Affairs
Part 1: The Clean Water Act Section 319 Program | I-53

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

The Ute Mountain Ute Nonpoint Source Assessment report lists categories of nonpoint 

source pollution that have been confirmed or are potential sources, as shown on 

Table I-13 . The specific management programs for these categories will focus on 

prioritizing pollution problems, identifying appropriate BMPs, and implementing BMP 

demonstration projects . The following considerations will be used in making final 

management decisions regarding priorities and BMPs:

 Severity of pollution problem and extent of impairment of beneficial uses

 Potential for effectively addressing the pollution problem, given technical and 

financial constraints (i .e ., optimizing economic benefits)

 Public participation and landowner cooperativeness

Table I-13. Categories of NPS and their applicability to the Ute Mountain Tribe 

(UMUT 2005b)

EPA NPS category

Impairment to Ute 

Mountain 

Ute Reservation 

waters

Possible 

impairment to 

off-reservation 

Confirmed Possible ranch water a

Agriculture

Crop-related sources: Non-irrigated crop

production

Irrigated crop production 

Specialty crop production 

Grazing-related sources  

Intensive animal feeding operations

Silviculture

Harvesting, restoration, residue management  

Forest management  

Logging road construction/maintenance  

Construction

Highway/road/bridge construction  

Land development 

Urban Runoff/Storm Sewers

Nonindustrial permitted

Industrial permitted

Other urban runoff 

Illicit connections/illegal hookups/dry weather flows 

Highway/road/bridge runoff 
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Table I-13. Categories of NPS and their applicability to the Ute Mountain Tribe 

(UMUT 2005b) (continued)

EPA NPS category

Impairment to Ute 

Mountain 

Ute Reservation 

waters

Possible 

impairment to 

off-reservation

Confirmed Possible ranch water a

Erosion and sedimentation n

Resource Extraction

Surface mining nb

Subsurface mining nb

Placer mining

Dredge mining

Mill tailings

Mine tailings

Petroleum activities n

Acid mine drainage

Abandoned mining n

Inactive mining n

Source: USEPA 1997, Table I-3. a

 Source inferred because the facility or activity is present on or near Ute Mountain Reservation

b Use under consideration by tribal council

Priorities for implementation are based on the Nonpoint Source Assessment for the 

Ute Mountain Reservation of Colorado, New Mexico, and Utah. Future priorities may be 

identified and addressed as they come to light and are confirmed by monitoring data.

Specifically, the priorities that have been identified in the assessment are:

Table I-14. Reservation waters: levels of specific impairment criteria (UMUT 2005b)

Waterbody Issue

Level of 

impairment/

priority

Navajo Wash Selenium, Salinity, Nutrient 

enrichment

SEVERE/HIGH

Cottonwood Wash, UT Radionuclide contamination SEVERE/HIGH

All < 8000’ Tamarisk/Russian Olive Infestation SEVERE/HIGH

Mancos River, San Juan River, Navajo Wash Bacteria levels Moderate

Mancos River, McElmo Creek, Navajo Wash Sedimentation/Erosion Moderate

McElmo Creek Nutrient Enrichment Moderate

Mancos River Metals—Ag, Cu Moderate

~50% ephemeral streams Sedimentation/Erosion Moderate
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Excerpt from Puyallup Tribe of Indians (PTOI 2008)

General Management Plan Information

As discussed in the nonpoint assessment, the major nonpoint impacts on the Reservation 

are the result of activities associated with urbanization—hydromodification (i.e.

channelization, dikes, rip rap), habitat alteration (i.e. siltation of stream beds, shoreline 

development, alteration of riparian areas), and prolifieration of impervious surfaces (i.e.

increasing rate and volume of runoff, flow alterations, construction and road building, soil 

compaction). These activities have resulted in elevated temperatures, siltation of stream 

beds, low dissolved oxygen, nuisance plant growth, elevated nutrients (high nitrate), and 

ubiquitous pathogens. Although the chemical parameters of these streams are altered 

by these activities, the most profound effects are physical and biological. That is, channel 

cross-sections are enlarged through widening or downcutting, habitat structure is 

simplified with loss of pools and riffles and little to no riparian cover, low carbon inputs, 

and aquatic diversity and abundance is poor. Connection of rooftops, gutters, parking 

lots, roads, and storm sewers to streams has profoundly altered the hydrograph, with 

most streams exhibiting “flashiness.”

Consequently, the hydraulic connectivity of stormwater infrastructure and impervious 

surface to streams must be addressed. A shift in the focus of stormwater management 

toward zero connectivity (or disconnection of impervious surfaces) of stormwater 

infrastructure to streams is necessary if enhancement and recovery activities are going 

to be successful. Additional activities (i.e. maximizing infiltration, flow control and 

treatment, better site design and minimization of soil compaction) will serve to more 

closely mimic natural runoff patterns and result in less nonpoint pollutant impacts to 

Reservation streams.

As recommended in the guidance, proposed actions are organized by nonpoint source 

category. Management measures proposed for each source are comprehensive. In 

general, activities that result in on-the-ground projects and improvements are the 

priority. Characterization and monitoring to close data gaps, and identify restoration and 

retrofit opportunities to restore channel form, processes and riparian complexity will be 

addressed first. This will be done on a sub-watershed basis. Many proposed management 

measures are ongoing, including enforcing existing agreements with local jurisdictions 

(i.e. riparian management), coordination and integration with other federal, state and 

local agencies and programs (TMDLs, salmon recovery planning and implementation, 

environmental, permit, and plan reviews and consultation).
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Table I-15. Plan for management of hydromodification (PTOI 2008)

NPS Impacts/pollutants Management measures

Hydromodification • Disturb stream equilibrium

• Disrupt riffle and pool 

habitats

• Create Changes in stream 

velocities

• Eliminate flood functions 

to control channel-forming 

processes

• Alteration of streambed 

elevation

• Increase erosion and 

sediment loads (EPA 2007)

• Hyporheoic modulation

• Elevated thermal regimes

• Uncontrolled stormwater 

loads 

• Siltation of stream beds

• Restore sinuosity, floodplain connectivity, 

and modulate stream temperature by 

re-connecting historic side-channels

• Enforce levee management agreement with 

ACOE and Pierce County

• Develop and implement O&M programs 

to avoid or mitigate physical and chemical 

impacts, including instream controls (grade 

control, band stabilization, levee setbacks, 

non-eroding roadways, streambank, 

protection, instream sediment load 

controls, and vegetative cover

• Evaluate impacts of surface water quality 

and in-stream and streamside habitat 

during dam operation and surface water 

withdrawal

• Work with Ecology to impose flow duration 

controls/standards to minimize sediment 

and other pollutants

• Preserve the natural hydrologic conditions 

and protect sensitive hydrologic features, 

sediment sources, and habitats where 

possible

• Develop watershed–based (sub-watershed 

basis) hydromodification management 

plans(s) to address geomorphic and 

hydrologic impacts of hydromodification on 

beneficial uses of streams

• Where stream bank or shoreline erosion 

is a nonpoint source problem, stabilized 

eroding streambanks and shorelines using 

vegetative methods wherever possible

• Protect streambank and shoreline features 

such as wetlands and riparian zones.

Urban Growth

(including on-site 

sewage systems, 

construction, and 

maintenance of 

roads and highways

• Altered hydrology—

Increased volumes and rate 

of stormwater runoff, low 

baseflows

• Increased downcutting, 

channel widening

• Reduce channel and 

floodplain connectivity

• Promote and implement management 

measures that maintain natural hydrologic 

and geomorphic processes, protect riparian 

corridors, and integrate stormwater 

control measures into tribal permitting and 

environmental review processes, emphasize;

o Maintaining natural rainfall-runoff ratios

o Maximized infiltration

o Protection hydrologically sensitive areas, 

sediment sources, and sensitive
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Excerpt from Red Lake Band of Chippewa Indians (RLBCI 2008b)

Excerpt from NPS Category: Agricultural Pollution

Agriculture is the number one source of NPS pollution in Reservation waters, especially 

in the Blackduck River, Pike Creek, and Battle River Watersheds. Primary pollutants 

include bacteria and phosphorus. These pollutants come from lands off the Reservation 

and are carried to local waters. The tribe has been actively cooperating with the 

Minnesota Pollution Control Agency (MPCA), Natural Resource Conservation Service 

(NRCS), and local Soil and Water Conservation Districts (SWCDs) to abate these 

problems. Agriculture on diminished Reservation lands is minimal, consisting of only a 

few small family farms (estimated at just over 2000 acres total) and does not contribute 

significantly to NPS pollution. The Red Lake Band owns and operates a medium sized 

wild rice operation located outside the diminished Reservation. The farm currently 

follows many BMPs including making use of rotational grazing, riparian zones, and 950 

acres of CRP lands. The NPS management program will assist in the development of 

farm plans for these small farms to prevent degradation. An updated inventory of these 

lands and their uses with more specific information about types of agriculture will also be 

a priority.

Short term goals: Reduce the levels of nutrients and bacteria in Reservation waters in 

the Blackduck River, Pike Creek, and Battle River watersheds.

Objectives: 

1. Work with MPCA to enforce feed lot regulations and promote sound management 

practices such as prescribed grazing and manure transfer on animal feeding 

operations on lands adjacent to the Reservation.

2. Work with small family farms located on the Reservation to develop riparian zones 

on farms adjacent to lakes and streams. Assist in voluntary enrollment of these 

farms into NRCS programs dealing with nutrient management and prescribed 

grazing where necessary.

3. Work with NRCS to encourage the use of BMPs on lands located in these 

watersheds with grazing, animal holding, or crop related activities. BMPs will 

include prescribed grazing, nutrient management and manure transfer.

Short term goals: Determine the contribution of the Red Lake wild rice farm to the 

impairments in the Clearwater River and reduce the contribution.

Objective: Work with NRCS, the Farm Service Agency, MPCA, and EPA to determine 

appropriate BMPs (tiling, sedimentation ponds, etc.) and acquire financial assistance to 

implement them.

Short term goals: Develop accurate, up-to-date, GIS dataset of agricultural land use 

on the Reservation.
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Objective: Delineate exact boundaries of agricultural land use on the Reservation and 

determine precise land uses: Bison/Cattle pasturing, specific crops, rotations, etc.

Long term goals: Measurable reductions in bacteria, temperature, and fine sediments 

(TSS) resulting from agricultural activities.

Funding sources will include federal programs, such as the Environmental Quality 

Incentives Program, Wetland Reserve Program, and Conservation Reserve Enhancement 

Program which can be used to promote the establishment and protection of riparian 

zones on farmland.

Table I-16. Schedule of milestones (RLBCI 2008b)

Activity Year 1 Year 2 Year 3 Year 4

Develop agriculture GIS for lands on Reservation X X

Develop an education and outreach program to work 

with farmers on and off the Reservation

X X

Assist in application for assistance and implementation of 

BMPs for agriculture on the Reservation

X X X

Monitor Project Areas for NPS Improvements X X

Increase monitoring for NPS pollution from offReservation sourcesX X X X

Excerpt from Suquamish Tribe (ST 2008)

Excerpt from Plan for Urban Runoff/Stormwater

Table I-17. Urban runoff/stormwater (ST 2008)

Code Description Primary pollutants % land use

% NPS

pollution

4000 Urban Runoff/Stormwater All

- Municipal All 8.4 5.2

- Commercial All 0.3 2.1

- Residential (e.g., noncommercial automotive, pet 

waste, etc.)

All 75 52.5

4500 Highway/Road/Bridge Runoff All 4 15.4

4600 Post-Development Erosion 

and Sedimentation All Sediments: 95

milestones

Year 1 Year 2 Year 3 Year 4

Draft CAO code language.

Design CAO public process.

Assess opportunities for 

joint public information 

campaign with a neighboring 

jurisdiction.

Implement one 

demonstration project.

Conduct at least one 

joint public information 

campaign.

CAO public process

Adopt CAO.

Implement 

formal process to 

review permits 

and applications 

with neighboring 

jurisdictions.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

This is by far the greatest contributor to NPS pollution within the Port Madison 

Water Resources Basin (PMWRB) with more than 50% of the loading of nutrients, 

sediments, and bacteria deriving from this category. The post-development erosion 

and sedimentation subcategory may provide as much as 95% of the total sedimentation 

load of the PMWRB. The following general BMP categories will be broadly used to 

address aspects of the NPS categories and subcategories listed subsequently. We will 

describe them in greater detail in this section than later sections unless there are specific 

applications not mentioned here.

Adequate Regulation and Enforcement 

Supplement Tribal Code—Formally establish “Critical Areas” within the PMIR. Formalize 

tribal project review process. Establish protocols with neighboring jurisdictions to 

review land use and building permits for entire PMWRB. Improve design specifications 

for tribally sponsored development projects to address stormwater and other NPS 

issues. Work with neighboring jurisdictions to implement new standards on PMIR.

[The Suquamish Tribe’s Legal Department would take the lead in formalizing a project 

review process, developing language codifying critical areas, and establishing protocols 

with neighboring jurisdictions. The Department of Community Development (DCD), 

Fisheries Department, and DNR would serve as cooperating agencies, reviewing 

projects, permits, and improving designs. 1-1.5 FTE.] 

Education

Review efforts already being implemented by local governments—target supplemental 

materials for residents of PMWRB. These will include current materials for pet waste 

management, septic maintenance, lawn and yard care, household toxics, and water 

use. Do the same with programs for business owners and managers, targeting for the 

PMWRB area. Develop materials to give presentations in order to provide information 

for policy makers within the tribe and other governments. Develop demonstration 

projects to simultaneously increase awareness, provide useful information, and provide 

services to local residents and businesses. These may include providing bins for backyard 

composting and supplying rain-barrels to capture and slowly infiltrate rooftop rainwater.

Additional demonstration projects could include coordinating plant salvage operations 

and establishing one or more native plant nurseries. [DNR would serve as the lead 

agency; cooperating agencies would include DCD, Fisheries, Education, and many other 

departments within tribal government. Funding schedule difficult to estimate as it 

depends upon success and scale of a wide variety of projects. Possibly start with 1.5 FTE 

then add 0.5 for each year afterwards ending with 3 FTE in year 4.] 
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Structural BMPs

Infiltration—Reduce effective impervious area through various BMPs such as using 

pervious alternative paving materials, establishing infiltration space between impervious 

surfaces when possible, planting native vegetation, amending and aerating soils to reduce 

compaction.

Detention—Attempt to simulate natural flood hydrograph, increasing the interval 

between the onset of precipitation and the flood crest while reducing the height of the 

crest, Where possible, restore or construct wetlands and multiple pond systems to 

capture and detain runoff.

Filtration—Where suitable, engineer solutions to filter sediments through processes 

such as grassy swales, filtration basins, sand filters, and even vaults with commercial 

stormwater filtration devices.

Retrofit Existing Structures—Divert roof runoff to dry wells and rain-barrels, replace 

culverts and redesign ditches with smaller scale detention structures, route waters to 

regraded and revegetated areas designed to temporarily store water.

Riparian Restoration—Reestablish native vegetation in riparian corridors, expand the 

width of the corridor where possible, fence areas to be protected, and use plantings 

where possible for streambank stabilization. [DCD would be the lead agency concerning 

structural BMPs, with DNR, Fisheries, and Legal serving as the primary cooperating 

agencies. This would probably start off more slowly, at about 0.5 FTE, with 0.5 FTE the 

second or third year for 1 FTE by the 4th year.]

Public Notice and Comment

As part of the process of submitting the NPS assessment 

report and management plan to EPA for approval, a tribe is 

also required to submit documentation that adequate public 

notice and opportunity for comment were given (See section 

319(a)(1) and (b)(1)). Section 319 does not provide specific 

guidance on providing public notice and opportunity for 

comment; however, the following recommendations are 

offered to assist tribes in that process.

Tribes should work with Regional EPA staff to decide what 

is appropriate public notice and opportunity for comment.

EPA Regional staff, through consultation with the EPA Office of Regional Counsel, will 

work with tribes to determine what constitutes adequate public notice and opportunity for 

comment on the basis of a particular tribal situation. As a general matter, public notice and 

In this section, you will find

• EPA’s recommendations on 

how tribes should conduct 

public outreach and provide 

public notice so that others 

can comment on proposed 

tribal activities

• The requirements for tribes 

regarding public notice and 

opportunity for comment
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comment should be extended to nontribal members living on fee lands within a reservation. 

In some cases, it would be advisable to extend public notice and comment to entities outside 

the reservation boundaries if an NPS management plan proposes to implement practices that 

would very likely affect those outside entities. Another consideration to discuss in determining 

whether to pursue outside public notification is the benefit the tribe could receive from 

the process. For example, it could be to the tribe’s advantage to provide notice to adjacent 

properties as a way of promoting its management program and, perhaps, leveraging funding 

and assistance from other groups doing similar NPS work. 

There are no specific rules for determining the length of a comment period. A 30-day 

comment period might be sufficient, but a longer period might be appropriate as well, 

depending on the tribal communication structure, the size of the reservation, and whether 

outside notification will be given.

Tribes must include a statement that they have provided notice and an opportunity for 

public comment regarding their assessment report and management program and a brief 

description of how that notice was provided.

Tribes should consult with Regional EPA staff to determine the appropriate time frame for 

conducting public notice and providing opportunity for comment. For example, conducting 

public notice after Regional review of the NPS management program could be appropriate. If 

public comments are received, the tribe must provide the response to comments as part of this 

documentation. 

The recommendations above also apply to cases where tribes have revised an NPS assessment 

report or management plan. The example below was provided by Red Lake Band of Chippewa 

Indians (RLBCI 2008).

A public comment period for the Red Lake Nonpoint Source Assessment and Red 

Lake Nonpoint Source Management Plan took place between the dates of 3/24/08 and 

4/23/08. Public notices were posted at all local businesses and government offices.

A copy of the notice and a letter were sent to surrounding local government units 

and interested parties. Interested parties included local Soil and Water Conservation 

Districts, Minnesota Pollution Control Agency staff, and Minnesota Department 

of Natural Resources staff. Although a high level of interest was shown in viewing 

the documents, only one comment was submitted. The Beltrami Soil and Water 

Conservation District submitted a letter of support as a comment to the documents.
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EPA Regional Approval Process

Each EPA Regional office has a tribal contact who can best describe the process that the 

Region uses to review assessment reports and management plans, as well as TAS eligibility 

requirements. For a list of EPA tribal NPS coordinators, see www.epa.gov/nps/tribal. 

Early in the calendar year, tribes should let the Region know they are interested in becoming 

eligible for the section 319 program. Furthermore, the intent to apply for CWA 319 funding 

should already be in the tribe’s CWA 106 or GAP work plans if those programs are to be used 

to work toward 319 eligibility. 

Regions can provide comments on draft documents to ensure that the approval on final 

program documents moves smoothly. This should happen in spring and summer. Remember 

to build in time for a public notice and comment period, as well as potential need for 

document revisions to address comments. Regional approvals must be completed by the 

second Friday of every October if you wish to be eligible to receive funds for work in the 

subsequent fiscal year. The earlier in the year you have your documents ready, the more likely 

the process will be completed by the deadlines established by the Federal Register notice. 

Section 319 Funding Process

Every year, Congress appropriates funds dedicated to the 

section 319 program for tribes, states, and territories. A 

portion of the tribal funds is dedicated to funding work plans 

that have been approved under the base NPS program. Such 

funds are commonly referred to as base funds. The remaining 

dollars are competed nationally to fund NPS on-the-ground 

projects. That money is commonly referred to as competitive 

funds. Figure I-11 shows total tribal set-aside dollars for fiscal 

years 2000 through 2010. The increases in funding levels over 

the years have reflected the increase in the number of tribes 

that have entered the program, the demonstrated need, and 

continued congressional support for the section 319 program 

in general and the tribal 319 program in particular.

Base Funding

In 2009 tribes were eligible to receive either $30,000 or $50,000 according to reservation 

area. Although there are other factors that influence nonpoint sources of pollution, EPA uses 

land area as the deciding factor for allocation of base funds because NPS pollution is strongly 

related to land use. 

In this section, you will find

• The difference between base

and competitive funds, and 

potential dollar amounts 

associated with each type of 

funding

• Where to find information on 

how to apply for funding

• The cost-share/match 

requirements associated with 

funding

• How tribes may combine 

section 319 funding with 

Performance Partnership 

Grants (PPGs)
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Figure I-11. Total annual tribal section 319 funding.

Base funds are commonly used for funding an NPS coordinator, updating the NPS 

management program plan, developing a watershed-based plan, or funding activities related to 

training and outreach. Tribes may also implement on-the-ground projects with these funds if 

adequate funding exists.

Tribes must refer to the most recent 319 base guidelines when applying for funding because 

the guidelines are not published annually. They are updated only as necessary. The base 

guidelines are under Funding at www.epa.gov/nps/tribal. It is important for tribes to follow 

application directions to receive base funding. 

Tribes are generally required to provide tribal or other nonfederal funds as a cost-share/match 

for section 319 funds. For purposes here, the terms cost-share and match are synonymous and 

do not equate to a dollar-for-dollar match. For information on calculating cost-share/match 

and determining sources of match, see the section titled Cost-Share/Match Requirements on 

page I-65, and the Work Plan Development section 

that begins on page I-68. EPA Regional tribal 

coordinators or assigned grants project officers 

are responsible for review and approval of work 

plans, and they can assist applicants in work plan 

development. For EPA contact information, see the 

list of contacts under Part III, Additional Resources 

for Tribes, or visit www.epa.gov/nps/tribal.

Table I-18. Base funding parameters

Maximum 

Area funding

Less than 1,000 mi2 $30,000

(less than 640,000 acres)

Greater than 1,000 mi2 $50,000

(greater than 640,000 acres)

EPA strongly encourages tribes to use either base or competitive section 319 

grants to develop and/or implement watershed-based plans containing the 

nine minimum planning elements (nine elements).
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Competitive Funding

The amount of funds available each year for the competitive portion of the tribal 319 program 

depends on the total funds available for tribal 319 grants and the number of tribes applying 

for base funds. The annual Request for Proposals (RFP) provides information on the total 

amount of funds available for competitive tribal 319 grants and the maximum amount of 

federal funds that an eligible tribe can include in its proposal. In 2009, eligible tribes and 

intertribal consortia were able to submit a proposal for up to a maximum of $150,000 in 

federal funding through the national tribal 319 competitive process. Tribes are required to 

provide tribal or other nonfederal funds as a cost-share/match for section 319 funds. For 

information regarding cost-share/match, see the section titled Cost-Share/Match Requirements 

on page I-65 and the Work Plan Development section that begins on page I-68.

Typically, EPA solicits proposals from eligible tribes and intertribal consortia to develop 

or implement watershed based plans and other on the ground projects, or to develop NPS 

ordinances that will result in significant steps toward solving NPS impairments or protecting 

waters from NPS pollution. Detailed information regarding the RFP is not discussed here, 

because submission requirements and selection criteria can change from year to year. 

Applicants for competitive tribal 319 grants must refer to the annual RFPs posted to 

grants.gov at www.grants.gov and to the tribal NPS Web site at www.epa.gov/nps/tribal. 

Applicants should carefully read the annual RFP to ensure that their proposals fully address 

all requirements, including eligibility threshold criteria and evaluation factors. EPA Regions 

will review each proposal to ensure that threshold eligibility criteria are met. Applicants 

deemed ineligible for funding consideration as a result of the threshold eligibility review 

will be notified by the EPA Regions. Proposals that meet the threshold eligibility criteria 

are submitted to EPA Headquarters for review and ranking by a selection committee. Each 

proposal is scored by the committee members on the basis of the factors and point system 

described in the annual RFP. The ranked list is provided to EPA’s selection official, who makes 

final funding decisions.

All aspects of the competitive process are guided by EPA Order 5700.5A1, Policy for 

Competition of Assistance Agreements. It is important to note that EPA will not discuss draft 

proposals with applicants, provide informal comments on draft proposals, or provide advice 

to applicants on how to respond to selection criteria. As part of the annual RFP process, 

applicants are provided the opportunity to submit questions in writing to the EPA Regional 

contacts regarding threshold eligibility criteria, administrative issues related to the submission 

of the proposal, and requests for clarification about the RFP. EPA’s responses to questions are 

posted to EPA’s Tribal Nonpoint Source Web site. The Tribal Nonpoint Source Web site is a 

helpful resource for tribes to access during their proposal preparation.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Cost-Share/Match Requirements

Section 319(h)(3) of the CWA requires that the cost-share/match for NPS grants be at least 

40 percent of the total project cost. Match can include:

 Allowable costs incurred by the grantee, subgrantee, or a cost-type contractor, 

including those costs borne by nonfederal grants

 Cash donations from nonfederal third parties

 Value of third-party in-kind contributions

 Tribal in-kind contributions, such as salary and equipment

To calculate the cost-share/match funds for the total project, the following tables demonstrate 

a 40 percent (section 319-required cost-share/match), 10 percent (if undue hardship 

requested), or 0–10 percent (if the work plan is combined in a Performance Partnership Grant 

[PPG]) cost-share/match on a section 319 base funding request of $50,000 and $30,000. 

Table I-19. Match calculation table for tribes eligible for $50,000 of base funding 

(> 1,000 mi2)

Total 

project cost

Nonfederal 

match Federal share

Nonfederal 

Match Federal share

$83,333 40% 60% $33,333 $50,000

$55,556 10% 90% $5,556 $50,000

$52,632 5% 95% $2,632 $50,000

Table I-20. Match calculation table for tribes eligible for $30,000 of base funding 

(< 1,000 mi2)

Total 

project cost

Nonfederal 

match Federal share

Nonfederal 

match Federal share

$50,000 40% 60% $20,000 $30,000

$33,333 10% 90% $3,333 $30,000

$31,579 5% 95% $1,579 $30,000

Example Calculation:

a. If you know the total project costs: 

(1) Multiply the total project costs by the cost-share/ match percentage needed. 

(2) The total is your cost-share/match amount. 
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I-66 | Part 1: The Clean Water Act Section 319 Program

For example: 

If you are requesting $30,000 of base funding, and your total project cost = $50,000, and 

you need 40 percent cost-share/match, so $50,000 × .40 = $20,000 (cost-share/match). 

OR

b. If you know the total federal funds requested ($30,000 for this example): 

(1) Divide the total federal funds requested by the maximum federal share allowed. 

(2) Subtract the federal funds requested from the amount derived in step 1.

(3) The amount derived from step 2 is the nonfederal match. 

For example:

(1) If the federal funds requested = $30,000 and the recipient cost-share/match is 10 

percent, the federal share = 90% or 0.90. $30,000 ÷ 0.90 = $33,333 (total project cost). 

(2) $33,333 − $30,000 = $3,333

(3) The nonfederal match = $3,333

Table I-21. Match funding requirements

Grant request Cost-share/match required

Section 319 match requirement 40%

Undue hardship 10%

Performance Partnership Grant* 0%–10%

* Different funding in a PPG have different match requirements

Applicants should be aware that funds originating from the Bureau of Indian Affairs may be 

used as cost-share/match for section 319 (pursuant to 25 U.S.C. section 458cc). These funds 

are treated as nonfederal funds for purposes of meeting cost-share/match requirements. 

EPA’s regulations also provide that EPA may decrease the cost-share/match requirement to as 

low as 10 percent (or in certain circumstances as low as 5 percent with respect to tribal 319 

funds that have been included in PPGs). Tribes must demonstrate in writing to the Regional 

administrator that fiscal circumstances within the tribe (or within each tribe that is a member 

of the intertribal consortium) are constrained to such an extent that fulfilling the cost-share/

match requirement would impose undue hardship (see 40 CFR 35.635). 
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Performance Partnership Grants

Section 319 grants are eligible to be included in PPGs (see 40 CFR 35.530). PPGs enable tribes 

and intertribal consortia to combine funds from more than one environmental program grant 

(e.g., section 106, General Assistance Program [GAP]) into a single grant with a single budget. 

The purpose of PPGs is to strengthen planning and priority setting through better deployment 

of resources, flexibility in directing resources to where they are most needed, linking 

activities to overall environmental goals and outcomes, fostering innovation, and streamlining 

administrative requirements. 

If a tribe includes a section 319 grant as a part of an approved PPG, the cost-share/match 

requirement may be reduced to 5 percent of the allowable cost of the work plan budget for 

the first 2 years in which the tribe receives a PPG. After 2 years, the cost-share/match may be 

increased to up to 10 percent of the work plan budget. This determination of a tribe’s ability 

to meet match is made by the EPA Regional administrator after various socioeconomic factors 

of the tribe are taken into consideration (see 40 CFR 35.536). The Regional administrator also 

has the regulatory authority to waive all cost-share requirements for the PPG if socioeconomic 

factors show that meeting match would impose an undue hardship (see 40 CFR 35.536(d)). 

EPA is developing a consistent, standardized approach to assist Regional administrators in 

determining tribal match waiver eligibility. The socioeconomic criteria will be based on 

publicly available, nationally consistent data. 

Recipients are not required to account for 

PPG funds in accordance with the funds’ 

original funding program, although total PPG 

expenditures need to be accounted for. If a 

tribe proposes a PPG work plan that differs 

significantly from any of the approved 319 

work plan components, the EPA Regional 

administrator must consult with the NPS 

national program manager before the 319 

grant may be included in the PPG. Tribes 

interested in combining 319 dollars into a 

PPG should consult with their EPA Regional 

tribal coordinator to determine whether a 

PPG is an appropriate option. 

Participants at a regional tribal NPS 

Workshop view native species revegetation 

project. (New Mexico 2008)
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I-68 | Part 1: The Clean Water Act Section 319 Program

Grant Timeline

The base and competitive timeline has been developed to coordinate proposal submissions 

and the receipt of fiscal year appropriations, and to avoid busy summer schedules when 

the bulk of project implementation occurs. Deadlines vary from year to year; however, the 

timeline in Figure I-12 generally outlines the process.

Figure I-12. Grant timeline.

Work Plan Development

Eligibility to receive a section 319 grant is complete once the 

tribe has obtained TAS and approval of its assessment report 

and management plan. The next requirement before receiving 

CWA section 319(h) grant funds is an approved work plan. A 

work plan outlines the goals and objectives of the grant with a 

schedule and budget breakdown to be carried out with CWA 

section 319 grant funds. To begin developing a work plan, 

refer back to the NPS assessment report and determine the 

priority NPS problems to be addressed in the upcoming grant 

cycle. Then refer to the NPS management program plan to determine the BMPs to implement 

to address the priority NPS problem identified in the NPS assessment report. The work plan 

should align with the schedule in the NPS management program. Next, develop a work plan 

and estimated budget using the priority NPS problem and selected BMPs.

All work plans funded with federal grant funds must, at a minimum, include the work plan 

information required at 40 CFR 35.507. For additional work plan requirements for base and 

competitive grants, see the most recent guidelines or RFPs online at www.epa.gov/nps/tribal.

In this section, you will find

• What is a work plan?

• What are the five 

requirements of a work plan, 

and what must a tribe do to 

meet them?

• What does a work plan look 

like?
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There are five requirements for a work plan at 40 CFR 35.507:

1. Work plan components to be funded under the grant (you may also show some 

components that are funded by other sources).

2. Work plan commitments for each work plan component, and a time frame for their 

accomplishment.

3. Estimated work years and estimated funding amounts for each work plan component.

4. Reporting schedule and a description of the performance evaluation process.

5. Roles and responsibilities of the recipient and EPA in carrying out the work plan 

commitments.

EPA recommends including a short introduction or background section to remind the 

reviewer where the activities came from (e.g., assessment report on X river or management 

plan commitments for year Y). It is advisable to also provide a brief physical description of the 

reservation land and waters. EPA project officers change over time, so including that type of 

information helps EPA to coordinate programs with greater understanding.

In-Depth Detail on the Five Requirements

Work Plan Components

The first requirement is to identify the work plan 

components to be funded under the grant. Identify the 

major goals to be carried out in the work plan that addresses 

the NPS problem (as outlined in the management program 

plan). A typical NPS work plan would have about three to 

five components depending on activities to be carried out 

with the available resources.

Work Plan Commitments

The second requirement is to identify the work plan 

commitments (tasks) for each work plan component, along 

with a time frame (milestones) for their accomplishment. 

Identify the tasks to be carried out that will meet the goals 

of the work plan. Identify how progress toward carrying 

out the commitments will be measured. Identify the start 

and end dates for each component. Identify the anticipated 

environmental outputs and outcomes, and the plan for 

tracking and measuring progress toward achieving the 

expected outputs and outcomes. Apache Crown Dancer I (Allan Houser Haozous), 

Albuquerque.

Barry Tonning
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Environmental Results (per EPA Order 5700.7)

The underlying principle of EPA Order 5700.7, Environmental Results under EPA Assistance 

Agreements, is to ensure that assistance agreements (grants, cooperative agreements) 

administered by EPA, such as section 319 grants, are results-oriented and align with EPA’s 

strategic goals. Providing linkage to strategic plan goals, as well as developing measurable 

outputs and overall goal outcomes, provides a way of measuring the environmental benefits 

that could be achieved through a grant award. Given the importance of this principle, it is 

required that grant awardees state the outputs and outcomes that are the expected results of 

their work plan activities/components. 

An environmental output (or deliverable) is an environmental activity, effort, or associated work 

product related to an environmental goal or objective that will be produced or provided over a 

period of time or by a specified date. Outputs can be quantitative or qualitative, but they must 

be measurable during an assistance agreement funding period. Examples of environmental 

outputs include:

 Development of a nine-element watershed-based plan

 Miles of fence line installed

 Feet of stream bank planted

 Amount of large, woody debris placed

 Number of stream meanders restored

 Percent reduction in road density 

Tribal NPS planning meeting at the Region 6 Tribal NPS Workshop, 2008.
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An environmental outcome is the result, effect, or consequence that will occur from carrying 

out an environmental program or activity that is related to an environmental or programmatic 

goal or objective. Outcomes could be environmental, behavioral, health-related or 

programmatic in nature; must be quantitative; and might not necessarily be achieved within 

an assistance agreement funding period. Outcomes may be short-term (changes in learning, 

knowledge, attitude, skills); intermediate (changes in behavior, practice, or decisions); or longterm (changes in condition of the natural resource). Examples of environmental outcomes 

include: 

 An increased number of NPS-impaired waterbodies that have been partially or fully 

restored to meet water quality standards or other water quality-based goals established 

by the tribe

 An increased number of waterbodies that have been protected from NPS pollution

 Increased abundance and diversity of fish or macroinvertebrate species

 Increased NPS knowledge on the part of community members

 Increased knowledge on the part of trained staff in the 319 program 

Estimated Work Years and Funding Amounts

The third requirement is to identify the estimated work years and estimated funding amounts 

for each work plan component. This requirement has two parts. First, identify the percentage 

of time that a full-time equivalent (FTE) is estimated to carry out each work plan component. 

For example, a 100 percent FTE is 1.00 work-year. If the employee will carry out work plan 

component #1 part-time or about 25 percent of a full-time workload, the estimated work-years 

for work plan component #1 would be 0.25 work-year/FTE. 

The second part is to identify the estimated funding amount to carry out each work plan 

component, which includes salary, fringe, travel, equipment, supplies, contractual, and other 

expenses. The required cost-share/matching funds may also be included in the estimated 

funding amount for each work plan component. 

Reporting Schedule

The fourth component of the work plan is to identify the reporting schedule and to describe 

the performance evaluation process, required according to 40 CFR 35.515, Evaluation of 

Performance. This information will meet the regulatory requirements for 

 A discussion of accomplishments as measured against the work plan

 A discussion of the cumulative effectiveness of the work performed under all work 

plan components

 A discussion of existing and potential problem areas
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 Suggestions for improvement, including, where feasible, schedules for making 

improvements

To best address this requirement, the required 40 CFR 35.515 information for the 

performance evaluation process may be copied directly into the work plan. This evaluation 

provides the basis for the tribal progress reports.

§35.515 Evaluation of Performance

(a) Joint evaluation process. The applicant and the Regional Administrator will develop a 

process for jointly evaluating and reporting progress and accomplishments under the work plan 

(see section 35.507(b)(2)(iv)). A description of the evaluation process and reporting schedule 

must be included in the work plan. The schedule must require the recipient to report at least 

annually and must satisfy the requirements for progress reporting under 40 CFR 31.40(b).

(b) Elements of the evaluation process. The evaluation process must provide for: 

(1) A discussion of accomplishments as measured against work plan commitments; 

(2) A discussion of the cumulative effectiveness of the work performed under all work plan 

components; 

(3) A discussion of existing and potential problem areas; and 

(4) Suggestions for improvement, including, where feasible, schedules for making 

improvements.

(c) Resolution of issues. If the joint evaluation reveals that the recipient has not made sufficient 

progress under the work plan, the Regional Administrator and the recipient will negotiate a 

resolution that addresses the issues. If the issues cannot be resolved through negotiation, the 

Regional Administrator may take appropriate measures under 40 CFR 31.43. The recipient may 

request review of the Regional Administrator’s decision under the dispute processes in 

40 CFR 31.70.

(d) Evaluation reports. The Regional Administrator will ensure that the required evaluations 

are performed according to the negotiated schedule and that copies of evaluation reports are 

placed in the official files and provided to the recipient.

Roles and Responsibilities

The fifth work plan component is to identify the roles and responsibilities of the recipient 

and partners in carrying out the work plan commitments. Specify who will carry out which 

components and who has the lead to carry out each component.

Table I-22 is a work plan template that includes the five requirements of a work plan per 

40 CFR 35.507. For base funding, some EPA Regions require a more narrative work plan 

than the one shown in the table. For more information, consult with your Regional NPS tribal 

coordinator.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Table I-22. Sample work plan NPS pollution control program (CWA section 319)

Work plan components with commitments and 

environmental results

Dates 

start end

Outputs/

deliverables

Responsible 

staff and 

work-years

Estimated 

cost* Status

1 COMPONENT: Decrease livestock access to 

riverbanks of XX River.

Commitment 1(a): Purchase fencing supplies.

Commitment 1(b): Fence (X) yards of riverbank.

OUTCOMES/ENVIRONMENTAL RESULT: Water 

quality will be improved through a decline in 

sediments in the river by preventing livestock access 

to the river.

10/01 

10/30

11/01 

12/30

Submit before

and after photos 

with quarterly 

report.

WQS 0.20

Crew

$15,000

2 COMPONENT: Revegetate project area with native 

vegetation.

Commitment 2(a): Purchase trees, shrubs, and 

grasses.

Commitment 2(b): Plant trees, shrubs, and grasses.

Commitment 2(c): Install watering system for 

vegetation.

OUTCOMES/ENVIRONMENTAL RESULT: The 

growth of native vegetation at the project site will 

stabilize the riverbank and reduce the amount of 

sedimentation entering the river.

2/1 2/28

3/1 4/30

4/01 5/30

Submit before

and after photos 

with quarterly 

reports.

WQS 0.20

Crew

$10,000

3 COMPONENT: Provide alternative water sources 

for livestock.

Commitment 3(a): Purchase solar panels and 

troughs.

Commitment 3(b): Install solar-powered water 

system.

OUTCOMES/ENVIRONMENTAL RESULT: 

Providing alternative water resources for livestock 

will prevent them from going into the river, 

leading to a decline in sedimentation and pathogen 

introduction.

11/01 12/30

1/01 2/30

Submit photos 

of new water 

system with 

quarterly report.

WQS 0.16

Crew

$8,000

4 COMPONENT: Educate tribal community on the 

importance of water quality protection and NPS 

pollution control program.

Commitment 4(a): Develop water quality education/

outreach program.

Commitment 4(b): Hold public outreach meetings 

and conduct site visits to project area.

Commitment 4(c): Contribute articles to the 

Environmental Department’s monthly newsletter.

OUTCOMES/ENVIRONMENTAL RESULT: Changes 

will occur in awareness and understanding of the 

status of water quality and the effects of NPS 

pollution problems as demonstrated by direct 

participation in workshops, meetings, and site visits.

10/01 12/31

Semiannually

Monthly

- Submit to EPA 

an education 

and outreach 

program 

description.

- Include in 

quarterly 

reports a 

summary of 

public meetings 

and site visits.

- Provide copies 

of newsletters.

WQS 0.10 $3,000
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Table I-22. Sample work plan NPS pollution control program (CWA section 319) (continued)

Work plan components with commitments and 

environmental results

Dates 

start end

Outputs/

deliverables

Responsible 

staff and 

work-years

Estimated 

cost* Status

5 COMPONENT: Develop draft watershed-based 

plan for the XX watershed.

Commitment 5(a): Review guidelines and checklists 

for development of a watershed-based plan.

Commitment 5(b): Meet with stakeholders in 

watershed.

Commitment 5(c): Develop draft watershed-based 

plan.

OUTCOMES/ENVIRONMENTAL RESULT: The 

watershed-based plan will allow for NPS problems 

and pollutants of concern to be addressed and 

reduced at a watershed level.

6/01 6/15

6/01 7/30

8/1 9/30

- Document 

activities in 

quarterly 

reports.

- Document 

meetings in 

quarterly 

reports.

- Submit draft 

watershedbased plan for 

EPA review.

WQS 0.14 $7,000

6 COMPONENT: Provide training for NPS staff.

Commitment 6(a): Attend the annual NPS 

Workshop

Commitment 6(b): Attend workshops on BMPs and 

other nonpoint source issues as they become 

available.

OUTCOMES/ENVIRONMENTAL RESULT: Staff 

knowledge will be increased, as demonstrated by 

staff through on-the-job implementation.

10/01 9/30 Provide status 

and summary 

of training 

in quarterly 

reports along 

with copies 

of training 

certificates, if 

available. 

WQS 0.10

Crew

$5,000

7 COMPONENT: Establish quarterly reporting to 

self-evaluate and joint-evaluate annual performance 

under the grant, including

• A discussion of accomplishments as measured 

against the work plan

• A discussion of the cumulative effectiveness 

of the work performed under all work plan 

components 

• A discussion of existing and potential problem 

areas

• Suggestions for improvement, including, where 

feasible, schedules for making improvements.

OUTCOMES/ENVIRONMENTAL RESULT: The 

tribe will evaluate and report on performance under 

the grant.

Quarterly:

1/30

4/30

7/30

10/30

Submit quarterly 

reports to EPA.

WQS 0.10 $2,000

WQS: Water Quality Specialist at 1.00 FTE. Lead for all work plan components.

Crew: NPS Crew. Contractual crew to carry out on-the-ground work for components #1–#3.

EPA will have no role in carrying out the work plan commitments except to review quarterly reports 

submitted.

* This reflects the totals of all COSTS for each component, including salary, fringe, equipment, contractual, 

supplies, travel, other direct costs (ODC), etc. Refer to budget breakdown for more detailed information.

TOTAL: $50,000

EPA: $30,000

MATCH: $20,000
Part 1: The Clean Water Act Section 319 Program | I-75

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Establishing Quality Assurance 

and Quality Control Protocols

NPS pollution is usually addressed by collecting information 

on water quality, physical habitat, biological communities, 

land uses, land cover, and land management practices, and 

then using that information to select, size, design, install, 

operate, and maintain management practices that will 

intercept, treat, or otherwise reduce pollutant inputs and 

habitat degradation in a waterbody. Information quality is important because significant 

resources are often required to implement BMPs. Given that importance, tribes and other 

non-EPA organizations need to develop and implement quality systems to support their 

environmental programs and projects funded or regulated by EPA. 

EPA has produced guidance on approaches for ensuring and controlling the quality of 

environmental data and project management. The guidance documents provide useful 

templates for establishing and maintaining QA/QC. Posted at www.epa.gov/quality/

qa_docs.html, they include program/organization tools, such as guidance for quality 

management plans, quality system audits, and QA training and reporting. In addition, there 

is guidance for projects such as producing data quality objectives, QA project plans, standard 

operating procedures, technical assessments, data validation and verification, and data 

quality assessments.

In general, EPA requires that recipients of funds for work involving environmental data 

collection comply with Specifications and Guidelines for Quality Systems for Environmental 

Data Collection and Environmental Technology Programs (ANSI/ASQC 2004). To 

demonstrate conformance, EPA requires two forms of documentation: (1) documentation 

of the organization’s quality system (usually called a quality management plan) and 

(2) documentation of the application of quality-related activities to an activity-specific effort 

(usually called a quality assurance project plan or QAPP). For grants, contracts, and other 

agreements that consist of a single project or task, these two documents may be combined into 

a single document that describes the organization’s quality system and the application of the 

system to the work performed under the grant or contract. This may be done only with the 

permission of the EPA QA manager, who will identify the elements that should be addressed 

in a combined document.

Tribes usually produce a QAPP that covers all aspects of project management and 

environmental data collection. The QAPP, which is usually developed and implemented to 

cover water quality monitoring and other activities supported by CWA section 106 funding, 

should be designed to address all data collection, including that funded by CWA section 319. 

In this section, you will learn

• What EPA requires in terms 

of QA/QC

• Elements of a QAPP

• Links for additional 

information
Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

I-76 | Part 1: The Clean Water Act Section 319 Program

For example, a tribe with an approved QAPP for CWA section 106 monitoring can modify the 

QAPP so that it covers post-project monitoring of specific BMPs or the effects of several BMPs 

on water quality at a selected location downstream. 

In general, the QAPP describes environmental data collection activities—through direct 

measurement or acquisition of databases—and explains who will be involved, what will be 

done, and how quality will be maintained. QAPPs (and modifications to QAPPs) must be 

prepared and approved before data collection begins. The QAPP will contain four basic sections:

 Project Management

 Data Generation and Acquisition

 Assessment and Oversight

 Data Validation and Usability

It will define and describe: who will use the data; what the project’s goals/objectives or issues 

are; what decisions will be made from the information obtained; how, when, and where 

project information will be acquired or generated; what possible problems might arise and 

what actions can be taken to address them; the type, quantity, and quality of data desired; 

how good the data have to be to support the decisions to be made; and how the data will be 

analyzed, assessed, and reported. Figure I-13 depicts the role of the QAPP in data collection.

Figure I-13. The role of planning and QAPPs in data collection.
Part 1: The Clean Water Act Section 319 Program | I-77

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Tribes should ensure that data collection among CWA 106 and 319 programs is coordinated 

so that duplication of effort and overlap between programs are avoided. For example, a 

tribe can conduct all its data collection, including the CWA 319 efforts, under its CWA 

106 program QAPP by modifying the QAPP to cover the NPS pollution activities. It will be 

important to ensure that the information collected applies to the specific objectives of the 

program or project. For example, collecting ambient samples to measure suspended sediment 

at strategic locations for the purpose of characterizing general water quality is different from 

collecting suspended sediment samples to measure the effects of a sediment-trapping BMP. 

The sampling locations, timing, and frequency will likely be different. These issues can be 

addressed in the QAPP by including separate sections for ambient monitoring and BMP 

performance monitoring. 

EPA’s Guidance for Quality Assurance Projects Plans is available at www.epa.gov/quality/

qs-docs/g5-final.pdf.

Quality Assurance and Quality Control

Quality Assurance (QA): an integrated system of management 

activities involving planning, implementation, assessment, reporting, and 

improvement to ensure that a process, item, or service is of the type and 

quality needed. QA is typically applied by managers or technical personnel 

assigned to a specific oversight role. Example QA activities include 

technical and management assessments of field and analytical operations.

Quality Control (QC): an overall system of technical activities that 

measure the performance of a process, item, or service against defined 

standards to verify that the performance meets the stated requirements.

QC is typically applied by technical personnel. Example QC activities 

include the use of control samples during sample collection, handling, and 

analysis, and activities such as data review.

Source: ANSI/ASQC 2004
Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

I-78 | Part 1: The Clean Water Act Section 319 Program

Statutory Requirements of 

Section 319 Grants

The generally applicable award and administration process for 

assistance agreements funded under section 319 are governed 

by regulations at 40 CFR Part 31 (states, tribes, interstate 

agencies, intertribal consortia, and local governments). In 

addition, legal requirements, including EPA’s regulations 

on environmental program grants for tribes (see 40 CFR 35.500 to 35.735) and regulations 

specific to NPS grants for tribes (see 40 CFR 35.630 to 35.638), apply to section 319 grants. 

A description of EPA’s substantial involvement in the cooperative agreement must also be 

included in the final agreement. In addition, the following statutory requirements must be 

met to receive assistance funding.

Satisfactory Progress 

For a tribe that received section 319 assistance agreements in the preceding fiscal year, 

section 319(h)(8) of the CWA requires that the EPA Region determine whether the tribe 

made satisfactory progress during the previous fiscal year in meeting the schedule of activities 

specified in its approved NPS management program to receive section 319 funding in the 

current fiscal year. The Region bases this determination on an examination of tribal activities, 

In this section, you will find

• The requirements to obtain 

319 funds

• What reports are required by 

EPA

Tour of a box 

timber weir 

installed at 

a culvert 

inlet to slow 

water before 

entering a 

rain garden. 

2007 NPS 

Workshop, 

Region 5.
Part 1: The Clean Water Act Section 319 Program | I-79

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

reports, reviews, and other documents and discussions with the tribe. Regions must include 

in each section 319 grant award (or a grant-issuance cover letter, signed by the EPA grant 

official) a written determination that the tribe has made satisfactory progress during the 

previous fiscal year in meeting the schedule of milestones in its NPS management program. 

Regional staff must include a brief explanation that supports the determination.

Administrative Costs

Pursuant to CWA section 319(h)(12), administrative costs in the form of salaries, overhead, 

or indirect costs for services provided and charged against activities and programs carried 

out with the grant may not exceed 10 percent of the grant award, regardless of whether 

the funding is base or competitive. The costs of implementing enforcement and regulatory 

activities, education, training, technical assistance, demonstration projects, and technology 

transfer are not subject to this limitation. It is common for work plans to include many of 

the above-stated exceptions to administrative costs. For example, most BMPs implemented 

by tribes are considered demonstration projects and would fall under the administrative cost 

exemption. Note that indirect cost rates are set by Department of Interior for the tribe and are 

independent of indirect costs mentioned in CWA.

Reporting

Performance and Financial Reports

All section 319 workplans must include a set of reporting requirements and a process for 

evaluating performance consistent with 40 CFR 31.40, 31.41, 35.507, 35.515, and 35.638. 

Tribes are required to submit performance reports and financial reports according to the 

schedule (at least annually, but no more than quarterly) determined by the EPA Regions. 

Regardless of the funding distribution vehicle, tribes are responsible for managing the dayto-day operations and activities supported by the funding, ensuring compliance with federal 

requirements, and ensuring that milestones and performance goals are achieved. Tribes must 

submit performance reports and financial reports according to the schedule (at least annually, 

but no more than quarterly) in their assistance agreement. Copies of the performance reports 

are placed in the official files and provided to the recipient. Performance reports and financial 

Water is the most critical resource issue of our lifetime and 

our children’s lifetime. The health of our waters is the principal 

measure of how we live on the land. —Luna Leopold
Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

I-80 | Part 1: The Clean Water Act Section 319 Program

reports are due 30 days after the reporting period. The final report, sometimes called a closeout 

report, is due 90 days after the assistance agreement expires. Tribes are required to report 

direct and indirect environmental results from the work accomplished through the award. 

Annual Reports

Section 319(h)(11) requires tribes to report annually on their progress in meeting the schedule 

of milestones contained in their NPS management programs. They must also report available 

information on reductions of NPS pollutant loadings (if available) and on improvements to 

water quality resulting from implementation of NPS management programs. 

Annual reports should contain cumulative accomplishments, as well as how the management 

program goals are being met. Most tribes will not have information on load reduction 

estimates from NPS projects; however, staff should report on the following topics:

 A brief summary of progress toward meeting approved milestones and the goals and 

objectives identified in the NPS management program plan.

 A milestone matrix displaying information, such as description of project/program, 

scheduled project completion date, and percent completed.

 A description of how other federal, state, and tribal departments, community 

programs, and the like are supporting the NPS program.

 A summary of any water quality improvements or improvements to aquatic habitat as 

a result of the NPS program. Surrogate measures for water quality improvements, such 

as environmental indicators, may be used if water quality improvements are not yet 

available.

To simplify reporting, some tribes could choose to combine their last performance report with 

their annual report, as long as it also meets the requirements of the annual report and includes 

progress in meeting the schedule of milestones contained in their NPS management programs. 

Some tribes have chosen to include additional information in the annual report. For example, 

the report may discuss any needs to modify a program, provide case studies of particular 

projects, or convey information to a broader audience on the activities being conducted by 

the tribe. Tribes can choose to include this additional information as a way of marketing the 

successes of their program to tribal leaders and decision makers, or to the general public; this 

is, however, optional.
Part 1: The Clean Water Act Section 319 Program | I-81

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Summary and Conclusions

This section concludes Part I of the handbook. Although there are certainly many facets of the 

NPS program, some important take-away points include the following:

 Work with your EPA project officer or tribal NPS program coordinator (or both) 

throughout the eligibility process. They are responsible for reviewing the NPS 

assessment report and management program documents and for guiding you through 

the TAS process. Find out if there are Regional deadlines, in addition to national 

deadlines, to receive next year’s fiscal year funding.

 Link work plan components to priorities in the NPS management program plan. All 

your NPS work and documentation—the assessment report, the management program 

plan, the 319 work plan, and so on—should “hang together” in an integrated manner 

and make sense to reviewers. Here is the key question regarding your assessment, 

program, and funding documentation: If you and all your staff left their jobs tomorrow 

and new people took over the program, could they pick up where you left off just by 

reviewing your work?

 Develop strong work plans that provide detailed information on each commitment and 

associated outputs and outcomes. Doing so will make tracking progress and reporting 

on environmental results easier for you and for EPA.

 It’s a challenge for many small tribal environmental departments to maintain viable 

programs given the lack of resources and staff turnover. To the extent possible, partner 

with local, state, and federal agencies, as well as the nonprofit and private sectors, to 

leverage technical and financial assistance. Section 319 funding alone will not be able 

to solve all your NPS problems.

In September 2008, EPA’s Office of Water released the National Water Program Strategy: Response 

to Climate Change. That document identifies potential effects of climate change on clean water and 

drinking water programs and defines actions that the National Water Program will take to address 

the effects. One of those actions is to integrate climate change information into existing training 

programs for water professionals. Given the magnitude and seriousness of the issue and the intent 

of the strategy document, EPA has included a special insert at the end of this part that addresses 

the effects of climate change on tribal NPS programs, including what managers and practitioners 

alike can do to incorporate climate change considerations into their programs and plans.

Part II of this handbook moves beyond the programmatic side of section 319 and provides more 

in-depth discussion of the technical aspects of improving water quality conditions through 

the use of watershed-based planning. Watershed-based planning incorporates all pollutant 

sources within a specific watershed geographic scale, rather than focusing on ownershipbased boundaries. Unless a reservation is large enough to encompass entire watersheds, it is 

very likely that tribal water program staff will need to communicate with their neighbors to 

develop effective plans that cover entire watersheds.
Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

I-82 | Part 1: The Clean Water Act Section 319 Program

rotection 

Climate Change Considerations: The Earth Is Warming

and restoration of tribal waters, 

watersheds, and the resources they support are 

increasingly important in light of changing climate.

According to the Intergovernmental Panel on 

Climate Change (IPCC) 2007 report, the earth is 

warming. According to the global climate models, 

the warming will very likely cause changes in atmospheric 

circulation and increase evaporation and water vapor, 

which will result in precipitation increases, more intense 

precipitation, more storms, and sea level rise. The regional 

and local precipitation, temperature, and weather intensity 

are much harder to predict, but future projections suggest 

the following (IPCC 2008, 2007b; Burkett et al. 2001):

 Annual average precipitation will increase in the 

northeastern United States and decrease in the 

Southwest.

 In the Midwest and Great Lakes, lake and river levels will 

be lower.

 In the Great Plains, there will be intensified springtime 

floods and summertime droughts, and agricultural 

productivity will likely shift northward as the droughts 

increase.

 Projected warming in the western mountains by the 

mid-21st century is very likely to cause large decreases 

in snowpack, earlier snowmelt, more winter rain events, 

increased peak winter flows and flooding, and reduced 

summer flows.

Why does climate change matter to 

tribal NPS managers? 

In addition to many cultural uses of the land and subsistence 

living, climate change is likely to affect many water-related 

issues depending on the location of your reservation. In 

general, warmer air temperature is expected to alter water 

in many ways.

 Changes in the location, timing, form, and amount of 

precipitation could result in

– Reduced rainfall 

– More frequent wildfires (and land areas where 

wildfires have occurred are more vulnerable to soil 

erosion)

– More frequent, more intense flooding

– Increases in tropical storm intensity

 Hydrologic changes, presenting as

– Shrinkage of the drainage network

– Earlier peak runoff and lower summer flows in rainsnow watersheds

 Chemical and physical changes in oceans and coastal 

regions, including

– Rising sea levels

– Increasing erosion rate

– Displacement of coastal wetlands

– Inundation of coastal wetlands, deltas, and mangrove 

forests

– Increases in the salinity of both surface water and 

ground water through saltwater intrusion 

 Increases in water temperature, resulting in

– Higher dissolved oxygen, pathogens, nutrients, 

ammonia, pentachlorophenol, and other pollutant 

levels

– Increased algal blooms and invasive species 

– Loss of aquatic species whose survival and breeding 

are temperature-dependent 

– Change in the abundance and spatial distribution of 

coastal and marine species

– Increased rates of evapotranspiration, shrinking waters 

such as lakes

 Increased evaporation from soils, leaving soils less able to 

support plant life and less able to absorb rain that does 

fall

 Protected wetlands and other water bodies may lose their 

relevance for species of concern because the protected 

areas will no longer provide the climate required

What should we be doing under the 

Tribal 319 Program? 

Tribal NPS managers need to consider future threats as 

well as current sources of pollution when managing their 

resources, watersheds, and watershed processes. When you 

are developing your assessment report and management 

plans, developing watershed-based plans, and implementing 

BMPs, ask what would allow your practices and plans to be 
more resilient in the face of climate change. Below are just 

a few things you can do to adapt to and minimize the effects 

of climate change through your NPS program.

 When assessing and prescribing watershed management 

actions, project forward what the needs might be.

 Choose activities that protect or restore the resiliency of 

ecosystems and watersheds.

 Ensure your floodplains and hyporheic zones are 

maintained.

 When designing, selecting, and placing BMPs, consider 

that there might be more water flowing through the 

system during storms and less during summer. Fencing 

might need to be set back farther. Maybe headwater 

wetland restoration will take a higher priority than other 

projects so as to maximize storage from storm events.

 Do not assume that the protections and protected areas 

you have in place will be adequate for species as climate 

changes habitat.

 Plant trees. Retain and expand forests as much as 

possible; the extent of forests might shrink over time.

 Work with other tribal offices to consider climate 

change when permitting practices and developing codes/

ordinances for forests, agricultural lands, developed areas, 

and water usage.

 Minimize increases in water temperature through shading 

and ground water recharge by protecting and restoring 

riparian areas and wetlands.

 Ensure that fish have access to seasonal habitat (e.g., offchannel and cool-water refugia).

	Disconnect impervious cover and road discharge from 

streams to soften discharge peaks during rain events.

 Use Green Infrastructure and Low-Impact Development.

Green Infrastructure includes an array of products, 

technologies, and practices that use natural systems—or 

engineered systems that mimic natural processes—to 

enhance overall environmental quality and provide utility 

services. Green Infrastructure practices recharge ground 

water, reduce the need for watering vegetation, and 

reduce and slow excessive stormwater to streams.

 Reduce the reintroduction of carbon from stored carbon 

sources by minimizing soil and wetland disturbances and 

forest clearing.

Much of the information above came from EPA’s climate 

change training materials, EPA Regional staff, Ecological 

Impacts of Climate Change (COEICC NRC 2008), and the 

University of Washington’s Climate Impact Group. For the 

most current information about climate change research and 

adaptations and mitigation activities, see the climate change 

Web sites recommended in Part III.

Part 1: The Clean Water Act Section 319 Program | I-83

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act
Part 1I: Watershed-Based Planning | II-1

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act PART II Watershed-Based Planning

In this section of the handbook, we discuss additional resources for tribes that might be useful 

in the context of water resource management and program planning. The topics covered are 

 Watershed approach and watershed-based plans (WBPs) 

 Online tools 

 Funding resources

 Environmental results 

 Ideas for building partnerships to leverage resources and success

The Watershed Approach

The watershed approach is a holistic approach that can help tribes restore land and water 

resources. It is a framework that is particularly useful for preventing or correcting 

environmental problems caused by nonpoint source (NPS) pollution. It is important to 

distinguish between the watershed approach, which is the process or mechanism for planning, 

and the WBP, which is the action-oriented, end product of the planning process. This section 

outlines the six-step iterative watershed plan development process and the nine basic elements 

that are included in WBPs. 

A few other distinctions should be made before launching into the steps of the watershed 

approach and the components of a WBP. There are many ways a WBP can be developed. 

Sometimes the plan is developed by a watershed group, university, local government, or 

nonprofit. For tribes, the tribal government might undertake the development of the plan 

directly or work in partnership with others. Tribal organizations bring a lot to the table during 

the plan development process, and they can work effectively with nontribal entities to create 

strategies to protect and restore the waters that flow through Indian Country and surrounding 

areas. Section 319 base or competitive funding can be used for best management practices 

(BMPs) and project work; in either case, the benefit to tribes is that a WBP plan builds the 

partnerships and collects the information critical to protecting and improving water resources. 
II-2 | Part 1I: Watershed-Based Planning

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

The watershed approach has four characteristics:

1. Planning is conducted by a consortium of people working in diverse, well-integrated 

partnerships.

2. The focus for planning is a specific geographic area (the watershed).

3. Any actions that are included in the plan are based on sound science and technology.

4. The plan presents coordinated priority setting and integrated solutions.

It has been well documented that the watershed approach is the best means for preventing 

and resolving NPS problems and threats. The list below describes some of the benefits tribes 

will gain from using the watershed approach:

1. It yields results. Many people have achieved great results through this method, which 

endorses robust partnerships, a clear geographic focus, using sound science, and 

prioritizing issues. 

2. It helps prioritize. What you submit in your grant application work plans will be derived 

from your WBP. The WBP is like a long-term improvement plan for the waters of 

the reservation, and adjacent waters if you are doing the plan based on a subbasin. 

The projects that you submit in annual work plans should be based on your NPS 

management plan document, but specific activities will come from the WBP as well. 

3. WBPs are supported by EPA and other federal agencies. The U.S. Environmental Protection 

Agency (EPA) believes watershed-based planning is the most effective method to 

manage multiple water resource issues.

WBPs are like any other environmental project with up-front costs (time, people, and funding) 

that demonstrate results once implemented. WBPs are also beneficial in places where there is 

staff turnover—the next person can pick up the plan and read it, know who is who and what 

the long- and short-term goals and activities are, and be ready to go.

There is another distinction to be made—the difference between a WBP and the NPS 

management program required for 319 funding. Figure II-1 demonstrates how these documents 

work together. There are two main differences in the scope of the two documents: 

1. The WBP focuses on a watershed, which is typically the drainage basin for a river 

or lake, and might be large-scale (8-digit Hydrologic Unit Code (HUC)) and contain 

areas outside tribal authority or smaller (16-digit HUC), which might be entirely on 

reservation lands. EPA’s 319 program supports watershed planning at the 12-digit 

HUC or smaller level. However, the NPS management program focuses on all the 

waters of a reservation. 
Part 1I: Watershed-Based Planning | II-3

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Watershed Project Scenarios Using 319 Funding

A. Implementing a watershed project on reservation land

B. Implementing a watershed project off reservation land (needs to pertain to the 

management and protection of reservation waters, and landowner permission is required)

C. Implementing a WBP on reservation land

D. Implementing a WBP off reservation land (needs to pertain to the management and 

protection of reservation waters, and landowner permission is required)

Note: Watershed projects are those projects that do not necessarily contain all nine components of a 

WBP but contain many aspects of the watershed-based planning framework.

Figure II-1. How a WBP relates to reservation-specific water resource plans and projects.
II-4 | Part 1I: Watershed-Based Planning

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

2. The WBP takes into account all potential sources of pollution, both point source 

and nonpoint source, whereas the plan required for 319 funds covers only nonpoint 

sources. 

The foundation of a tribal NPS program is the NPS management program and the NPS 

assessment report. Those documents provide overall program guidance to address NPS 

pollution on tribal lands. Tribal lands can include several portions of watersheds or can contain 

entire watersheds depending on the scale definition. As an output of the NPS management 

program, the WBP helps to focus NPS planning on a particular watershed identified as a 

priority in the NPS management program. Information gathered during the development of 

the NPS assessment report and management program plan therefore feeds into the WBP. Like 

the management program plan, the WBP will be a multiyear planning document; however, it 

is much more detailed than the 319 

program plan and covers a longer period. 

The NPS management program and the 

assessment report are the foundation 

to help you begin watershed planning, 

and the final plan document should be 

consistent with those reports. There are 

many other sources of information you 

will find helpful in writing your plan. 

You can use this handbook as a starting 

point to find these resources.

Once you have a WBP, it can simplify 

annual work plan development. Work 

plans identify portions of the WBP 

to be carried out. In the case of work 

plans submitted as part of a 319 grant 

application, the focal point would 

still be on NPS pollution even though 

point sources are identified in the WBP. Nevertheless, knowing all the potential sources of 

pollution is extremely helpful in planning a robust water resource management program for 

all reservation waters. 

This section begins by going into detail regarding the six steps involved with watershed 

planning (i.e., the approach). It then takes you through each of the nine required components 

of the WBP (highlighted in white in Figure II-2). To understand how these fit together, see 

Figure II-2. Each of the nine components required in a WBP is derived from one of the six 

planning and implementation steps. This section also takes a look at the many resources 

available to help you develop a watershed plan. 

Table II-1. Components of assorted plans

Component

NPS mgmt 

plan WBP

Work 

plan

Focus on 

watershed

optional x optional

Focus on 

reservation 

waters

x x

NPS 

pollution

x x x

All pollution x

Multiyear 

document

x x

Annual 

(1- to 2-year) 

document

x
Part 1I: Watershed-Based Planning | II-5

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Figure II-2. Foundation of the nine elements of a WBP.
II-6 | Part 1I: Watershed-Based Planning

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Implementing the Watershed Approach

As explained below, the watershed planning and implementation process (the approach) has 

six major steps. The process is the mechanism that yields a WBP as its end product. The six 

steps are: 

1. Build partnerships

2. Characterize the watershed to identify problems 

3. Finalize goals and identify solutions

4. Design an implementation program and assemble a watershed plan

5. Implement the watershed plan

6. Measure progress and make adjustments 

(which lead to an improved plan)

This diagram illustrates the six steps associated 

with watershed planning and 

implementation. Note 

that the diagram 

is shaped like 

a feedback 

loop. This is 

intentional: 

like any good 

management 

process, 

the watershed planning and 

implementation process strives for continual improvement. The management of a watershed 

requires continual self-evaluation and adjustment to reach the goals that have been set for 

water quality. Each of the six steps is composed of numerous smaller steps. This section 

discusses the utility and flow of the watershed planning and implementation process, with 

an emphasis on how these steps might apply in a tribal setting. The nine elements, required by 

EPA for WBPs, are discussed in the next section. 

1. Build Partnerships

Bringing people, policies, priorities, and resources together through a watershed approach 

blends science and regulatory responsibilities with social and economic considerations. 

Because building partnerships is the first step and a critical one for ensuring the ongoing 

success of your efforts, EPA has included in this section a good amount of detail regarding 

identifying stakeholders and nurturing those relationships. 
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Watershed planning is often too complex and too expensive for one person or organization 

to tackle alone. To work effectively at the watershed level (as opposed to limiting the efforts 

to only tribal lands), tribes will want to work with stakeholders within and outside the tribe 

and watershed. A stakeholder is a person or organization that has a stake in the outcome of the 

watershed planning process—a stakeholder can make and implement decisions, is affected 

by the decisions made, or has the ability to assist or impede implementation of the decisions. 

Figure II-3 offers a starting point for thinking about which tribal and nontribal stakeholder 

groups to include in your consortium. Note that key individuals might be the impetus within 

each stakeholder group.

Figure II-3. Potential stakeholder groups for your consortium.

A tribe might be faced with the issue that its reservation constitutes only a very small portion 

of the watershed; land titling issues might be complex; or lands might be “checker-boarded.” 

In all such cases, land-based activities occurring on nontribal lands are likely to account 

for a portion—and perhaps even the majority—of the NPS pollution affecting tribal lands. 

For example, tribal lands might be downstream of agricultural operations or heavily paved 

urban areas. This is why partnering with nontribal entities is so important. Tribes might not 

be able to solve their water pollution problems without the cooperation of their neighbors in 

the watershed. By the same token, the nontribal groups will likely need tribal involvement to 

address the water quality problems they’re facing.

Note that tribal 319 funding generally applies to waters on the reservation, though the 

watershed might cover a much larger geographical area. If your work plan tasks include 

implementing 319 projects outside tribal reservations, you will need to make the case that 

these projects in upstream or downstream waters pertain to the management and protection 

of reservation waters. In addition, approval from those property owners will be needed to 

implement such projects off the reservation. 
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When Should We Start Engaging Stakeholders? 

It is critical to build partnerships with key interested parties at the outset of the watershed 

planning effort. A common mistake is engaging stakeholders after much of the planning has 

already been done. That can lead to disagreements or lack of enthusiasm, which might have 

been avoided if stakeholders had been brought on board earlier.

Who Should We Include? 

All categories of potential stakeholders—not just those that volunteer to participate—should 

be identified and invited. It is essential that you identify all these categories of potential 

stakeholders. Stakeholders also include those that can contribute resources and assistance 

to the watershed planning effort, and those that work on similar programs that can be 

integrated into a larger effort or have access to lands or waters to be addressed. Keep in mind 

that stakeholders are more likely to get involved if you can show them a clear benefit to their 

participation. 

Begin by contacting the people and organizations that have an interest in water quality or 

might become partners that can assist you with the watershed planning process. Consider 

who would be the most appropriate person to contact the potential partner. Make sure you 

have a means to encourage the partners you are working with to invite others. This approach 

extends your network and possible resources. Those who might have a stake in the watershed 

plan should be encouraged to share their concerns and offer suggestions for possible solutions. 

Also try to match your needs with your stakeholders’ resources and capabilities. The box 

below lists some skills you might seek to complement tribal resources and knowledge.

Skills in Stakeholder Group

 Accounting

 Graphic design

 Computer support

 Fundraising

 Public relations

 Technical expertise (e.g., GIS, water 

sampling)

 Facilitation

 Consensus-building, outreach

Resources Available from Stakeholders

 Contacts with media

 Access to volunteers

 Access to datasets

 Connections to local organizations

 Access to meeting facilities 

 Access to equipment 

 Access to field trip locations

 Access to upstream locations

Remember that partners should come from both tribal/intertribal entities and nontribal 

entities. Other agencies within tribes might be able to help tap into outreach demographics 

previously untargeted by tribal water quality efforts. Working with tribal leaders can lead 

to swifter governing policies that support the water quality plan. Nontribal entities provide 
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access to outside resources that bolster research and legislative efforts. A good place to start 

when thinking about possible partners is making a list of the expertise and resources that will 

be needed to ensure success. Needs range from technical data to meeting space for gatherings. 

A list will help target your partnership efforts.

How Do We Build Support in the Watershed? 

Watershed plans and water quality management programs also contribute to stakeholders by 

addressing their needs and concerns. Listing issues relevant to the local community will help 

with buy-in from tribal members and organizations. Restoring clean water and preserving 

natural resources are ways that the tribe can benefit from a WBP. Restored areas might be less 

prone to flash flooding during large 

storm events. Encouraging responsible 

development can help spur economic 

growth, yet minimize contribution to 

the degradation of reservation waters. 

Water quality management efforts, 

monitoring sites, and BMP installations

also preserve the land for tourism 

and may be marketed to green tourists 

interested in environmental protection.

Very few watersheds exist within a 

single political jurisdiction. Many 

different regulatory agencies are 

involved in any watershed plan simply 

because of the large area affected 

and the cross-cutting nature of water 

quality issues—and those agencies 

do not always agree on the best course of action. Creating partnerships with state and federal 

agencies can facilitate consensus in your watershed planning. When all groups are on the 

same page about what a watershed needs, where funding will come from, who will maintain 

any infrastructure or testing protocol, and what the benefits will be, projects are approved 

more quickly and run more smoothly. Without reaching out to partners, the effort to improve 

reservation waters can seem like an uphill battle. In actuality, water quality is important to 

everyone and good communication can make that clear.

When you begin to contact stakeholders, consider how you will approach them about your 

watershed planning effort and the expected outcome. Think about what will encourage that 

stakeholder to buy in to your process, and focus your approach on issues important to that 

stakeholder or group. For community organizations, you can cite the resolution of problems 

like erosion of stream banks, habitat and green space deterioration, and flash flooding. 

Figure II-4. Hierarchy of entities within a watershed.
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Policy organizations will be focused on what your 

watershed plan can do for the legislative process: 

Will it help streamline environmental policy? Does it 

contribute data required by local or state ordinances, 

or does it eliminate the need for deliberations 

on community issues because it addresses these 

issues? Try to contact the most appropriate person 

in the organization (based on how you approach 

that stakeholder’s buy-in to the project). Water 

quality contacts are naturally good contacts, as are 

environmental committee members, school excursion 

leaders, or community government officials.

Which Stakeholders Might Be Able to 

Assist Monetarily? 

Funding is one of the most important parts of 

the watershed planning process. Many federal 

programs have funding opportunities that can be 

used in your watershed plan. Look for funding in 

these topics: wetlands restoration, water quality 

restoration, community development and aid, 

historical preservation, solid waste cleanup, land 

reclamation and revegetation, abandoned mine 

reclamation, and other programs targeted toward 

the needs in your watershed. When contacting 

federal and state agencies, it is best to research your 

local branch. Bureau of Indian Affairs, Bureau of 

Land Management, U.S. Department of Agriculture 

(USDA)–Natural Resources Conservation Service 

(NRCS), U.S. Geological Survey, and EPA have 

information on local representatives on their 

respective Web sites. Getting in contact with these 

local branches can have positive results because 

they can be untapped resources. In addition, if you 

are working with local universities, encourage your 

partners to apply for federal research grants that will 

support their work on your watershed plan. For links 

to online federal funding resources, see Part III, 

Additional Resources for Tribes.

Amber Marriott
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Included below is a list of example stakeholders in the watershed planning process. A more 

comprehensive list is provided in EPA’s Handbook for Developing Watershed Plans to Restore and 

Protect Our Waters (www.epa.gov/nps/watershed_handbook), Chapter 3.

Local Stakeholders

 Community service organizations

 Local cooperative extension 

offices

 Local elected officials

 Local lake associations

 Local landowners

 Parks and recreation 

departments

 Planning and zoning programs

 Regional planning councils

 Soil and water conservation 

districts and NRCS offices

 Solid waste programs

 Stormwater management 

programs

 Volunteer monitoring programs

 Water and sewer programs

 Watershed organizations

State and Regional Programs

 Source Water Assessment and 

Protection (SWAP) programs

 State and interstate water 

commissions

 State coastal zone management 

programs

 State departments of 

transportation

 State fish and wildlife programs

 State health departments

 State TMDL (total maximum daily 

load) programs

 State NPS programs

 State water protection initiatives

 State wetland programs

 Regional geographic watershed 

initiatives

Federal Programs and 

Organizations

 Abandoned mines programs

 Agricultural conservation programs

 Agricultural support programs

 Bureau of Indian Affairs

 Bureau of Land Management

 Coastal programs

 Federal transportation programs

 Indian Health Service

 NRCS

 Public lands management 

 Threatened and Endangered 

Species Protection Programs

 U.S. Fish and Wildlife Service

 U.S. Forest Service

 Wetland protection programs

 Wildlife protection programs

2. Characterize Your Watershed

Characterizing your watershed can be considered the heart of the preparation process for 

WBPs. The process is very similar to producing the NPS assessment report for the tribal 

Clean Water Act (CWA) 319 program, but it also includes point sources of pollution, such as 

wastewater treatment plants, industrial facilities, and stormwater discharges permitted under 

the National Pollutant Discharge Elimination System (NPDES). During this phase, you will 

gather existing data and create a data inventory, analyze gaps and collect additional data if 

needed, and analyze your data. The goal of this data analysis for the watershed is to identify 

the causes and sources of pollution affecting your waterbody. At the end of this characterization 

process, you should be able to state what kinds of pollution are affecting the waterbody, where 

that pollution is coming from, and what you might not know about the pollutant source.

The first step of watershed characterization is determining the scope of your effort, in terms of 

both geographic size and the number of pollutant causes and sources you will address. 
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Areas are defined by two-digit codes, so watersheds will be at the 2-, 4-, 6-, 8-, 10-, and 

12-digit level. An easy way to remember the relationship between HUCs and the land they 

represent is this: The smaller the number, the larger the geographic area. For that reason, 

effective plans tend to focus at the 12-digit HUC (or smaller), level. The 12-digit level, or 

subwatershed, usually has 10,000 to 40,000 acres; some are as small as 3,000 acres. EPA 

encourages plans at the 12-digit level or smaller.

The key to determining the 

appropriate scale of planning is 

that you must ensure that the 

area is small enough to manage 

but large enough to address 

water quality impairments and 

the concerns of stakeholders. 

If the scale is too small, 

significant sources of pollution 

that are outside the planning 

area might be mistakenly 

ignored, and then you cannot 

fully address the problem. If 

the scale is too large, you might 

be overwhelmed. Remember 

that your scope is both 

geographic and topical—where 

you want to work and on 

what parameters. The greater 

number of pollutants, the 

smaller the geographic scale 

and vice versa. 

Once you have delineated the area within which you will work, set out to gather as much 

relevant information on that area as possible, with the end goal of identifying the causes and 

sources of pollution. In addition to meeting with stakeholders, you will want to thoroughly 

review the data that have already been collected. Often, likely causes of pollution have already 

been identified. For example, stakeholders might be aware of a large construction project, 

paved roads, or extensive agricultural operations near their waterbody. Table II-2 lists the 

pollutants that might correspond with those sources. The process of characterizing your 

watershed leads from generalities to specifics, so tailor the identification to what is applicable 

in your delineation. Your chart will most likely differ from that in Table II-2. 

Figure II-5. HUC code levels used to define 

watershed size.
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Table II-2. Impairment sources and associated pollutants

Source Common associated pollutants

Cropland Turbidity, phosphorus, nitrates, temperature, total suspended 

solids

Forestry harvest Turbidity, temperature, total suspended solids

Grazing land Fecal bacteria, turbidity, phosphorus, nitrates, temperature

Industrial discharge Temperature, conductivity, total solids, toxic substances, pH

Mining pH, alkalinity, total dissolved solids, metals

Septic systems Fecal bacteria (e.g., Escherichia coli, enterococci), nitrates, 

phosphorus, dissolved oxygen/biochemical oxygen demand, 

conductivity, temperature

Sewage treatment plants Dissolved oxygen and biochemical oxygen demand, turbidity, 

conductivity, phosphorus, nitrates, fecal bacteria, temperature, 

total solids, pH

Construction Turbidity, temperature, dissolved oxygen and biochemical 

oxygen demand, total suspended solids, toxic substances

Urban runoff Turbidity, total suspended solids, phosphorus, nitrates, 

temperature, conductivity, dissolved oxygen and biochemical 

oxygen demand

Types of Data to Review to Characterize Your Watershed

Physical and Natural Features 

 Watershed boundaries

 Hydrology

 Topography

 Soils

 Climate

 Habitat

 Wildlife

Land Use and Population 

Characteristics 

 Land use and land cover

 Existing management practices

 Demographics

Waterbody Conditions

 Water quality standards/ designated uses

 305(b) report

 303(d) list

 Integrated report

 TMDL reports

 Source Water Protection Areas

Pollutant Sources 

 Point sources

 Nonpoint sources

Waterbody Monitoring Data 

 Water quality data

 Flow data

 Biological data
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Where might you find these existing data? A number of entities regularly collect all kinds of 

information in your watershed (see list below). A good place to start is with federal and state 

agencies, as well as any documents prepared during your 106 and 319 application processes. 

For example, you have probably uploaded data collected for your 106 reports into EPA’s 

STORET database.

 Federal agencies (U.S. Geological Survey [USGS], U.S. Fish and Wildlife Services, 

U.S. Forestry Service, Bureau of Land Management, U.S. Army Corps of Engineers, 

EPA, EPA/STORET)

 State agencies (water, fish and game, forestry, agriculture)

 Colleges and universities

 Watershed groups (volunteer monitoring programs, local knowledge)

 Lake and river associations

 Local agencies (water/wastewater, health, planning and zoning, and the like)

 Regional planning agencies

 EPA’s Surf Your Watershed at www.epa.gov/surf

If you do not already have a data inventory, create one so that all relevant information can 

be easily accessed and revisited in the future. The types of information to include in your 

inventory are:

 Type of data (e.g., monitored, geographic)

 Source of data (agency)

 Quality of data (quality assurance/quality control documentation, quality assurance 

project plan [QAPP])

 Representativeness of data (number of samples)

 Spatial coverage (location of data collection)

 Temporal coverage (period of record)

 Data gaps

You can find sample inventories in EPA’s Handbook for Developing Watershed Plans to Restore and 

Protect Our Waters. Once you have created the data inventory, you will move on to the next 

phase in characterization: identify gaps and collect new data. As you review the data, you might 

realize that you need to gather additional existing information. If so, go back, add additional 

information to your data inventory, and then proceed, filling any gaps in your data. You will 

know that you have collected enough data once you are able to (1) identify the causes and 

sources of the pollution in your waterbody of concern and (2) verify that the quality of your 

data is adequate for making those determinations. 
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A watershed survey, or visual assessment, is one of the most rewarding and least costly means of 

collecting the additional data needed to understand the pollutants of concern in the watershed. 

By walking, driving, or boating the watershed, you can observe water and land conditions, 

uses, and changes over time that might otherwise be unidentifiable. These surveys can help 

you identify and verify pollutants, sources, and causes, such as streambank erosion delivering 

sediments into the stream and illegal pipe outfalls discharging various pollutants. They can 

also be used to familiarize local stakeholders, decision makers, citizens, and agency personnel 

with activities occurring in their watershed. Additional monitoring of chemical, physical, and 

biological conditions will be required to determine whether the pollutants observed are actually 

affecting the water quality. In addition, aerial photos are an excellent resource for viewing NPS 

impacts. For general information on visual surveys, read section 3.2, The Visual Assessment, in 

EPA’s Volunteer Stream Monitoring: A Methods Manual (EPA 841-B-97-003), www.epa.gov/owow/

monitoring/volunteer/stream/vms32.html. Included is a Watershed Survey Visual Assessment 

form, www.epa.gov/owow/monitoring/volunteer/stream/ds3.pdf.

Several agencies and organizations have developed visual assessment protocols that you can 

adapt to your own situation. For example, NRCS has developed a Visual Stream Assessment 

Protocol (VSAP). The VSAP is an easy-to-use assessment tool that evaluates the condition of 

stream ecosystems. Go to www.nrcs.usda.gov/technical/ECS/aquatic/svapfnl.pdf to download a 

copy of the tool.

For more information and detailed descriptions of water quality sampling methods and 

sampling plan designs, see the USGS National Field Manual for the Collection of Water-Quality 

Data at water.usgs.gov/owq/FieldManual and EPA methods at 

www.epa.gov/quality/qs-docs/g5s-final.pdf. 

At this point you have inventoried and evaluated existing information and collected new data if 

necessary, partnering with other entities to the extent possible to get the information you need. 

The outcome of this process for tribes is to “identify causes and sources of pollution.” This 

fulfills the first of the nine elements discussed in more detail in the subsequent section called 

Nine Elements of a Watershed-Based Plan. At this point you should be able to characterize your 

causes and sources on the basis of the following: 

 Source type (e.g., nonpoint, point)

 Location (e.g., subwatershed)

 Land use type

 Source behavior (e.g., direct discharge, runoff, seasonal activities)

Tribes also have the option at this stage of estimating the quantities (loads) of the pollutants 

of concern entering their waterways. Two general types of techniques for estimating pollutant 

loads can be used. First, you can directly estimate loads from monitoring data or literature 
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values. Such techniques are best suited to conditions where fairly detailed monitoring and 

flow gauging are available, and the major interest is in total loads from a watershed. To obtain 

literature values for estimating pollution loads, see EPA’s Handbook for Developing Watershed 

Plans to Restore and Protect Our Waters, figure 8.1. Second, where resources allow, you can select 

from a number of different watershed modeling techniques. Models can be used to forecast 

or estimate future conditions; many do, however, require extensive expertise. One simple 

model that might be of help is EPA’s Spreadsheet Tool for Estimating Pollutant Loads (STEPL). If 

the pollutants of concern are sediment, nitrogen, or phosphorus, you can use EPA’s STEPL 

spreadsheet tool to estimate loads and load reductions. The model uses simple algorithms 

to calculate nutrient and pollutant sediment loads from different land uses and the load 

reductions that would result from implementing various BMPs. To download the model or read 

its documentation, visit http://it.tetratech-ffx.com/stepl. 

3. Finalize Goals and Identify Solutions

During this part of the planning process you will: set goals on the basis of your data analysis; 

identify your management objectives; and select your indicators to measure progress toward 

achieving water quality improvements. Now that you have characterized and quantified 

the problems in the watershed, you are ready to refine the goals and establish more detailed 

objectives and targets that will guide you in developing and implementing a management 

strategy. Those goals will guide the identification and selection of management practices to 

meet the targets and, therefore, the overall watershed goals.

Table II-3 provides some examples of translating watershed goals into management objectives 

(From EPA’s Handbook for Developing Watershed Plans to Restore and Protect Our Waters, 

chapter 9).

The indicators are measurable parameters that will be used to link pollutant sources to 

environmental conditions. The specific indicators will vary depending on the designated 

use of the waterbody (e.g., warm-water fishery, cold-water fishery, recreation) and the water 

quality impairment or problem of concern. For example, multiple factors might cause 

degradation of a warm-water fishery. Potential causes include changes in hydrology, elevated 

nutrient concentrations, elevated sediment, and higher summer temperatures. Each of these 

stressors can be measured using indicators like peak flow, flow volume, nutrient concentration 

or load, sediment concentration or load, and temperature.

A specific value can be set as a target for each indicator to represent the desired conditions 

that will meet the watershed goals and management objectives. Targets can be based on 

water quality criteria or, where numeric water quality criteria do not exist, on data analysis, 

reference conditions, literature values, or expert examination of water quality conditions to 

identify values representative of conditions that support designated uses. If a total maximum 

daily load (TMDL) already exists for pollutants of concern in your watershed, you should 
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Table II-3. Translating watershed goals into management objectives

Preliminary goal Indicators Cause or source of impact Management objective

Support designated uses 

for aquatic life; reduce 

fish kills

Dissolved oxygen

Phosphorus

Temperature

Elevated phosphorus 

causing increased algal 

growth and decreased 

dissolved oxygen

Cropland runoff

Reduce phosphorus loads 

from cropland runoff and 

fertilizer application

Reduce flood levels that 

might cause water quality 

problems

Peak flow volume and 

velocity

Inadequate stormwater 

controls, inadequate road 

culverts

Minimize flooding impacts 

by improving peak and 

volume controls on urban 

sources and retrofitting 

inadequate road culverts

Restore aquatic habitat Riffle-to-pool ratio, 

percent fine sediment

Upland sediment erosion 

and delivery, streambank 

erosion, near-stream land 

disturbance (e.g., livestock, 

construction)

Reduce sediment loads 

from upland sources; 

improve riparian vegetation 

and limit livestock access to 

stabilize streambanks

Improve aesthetics 

of lake to restore 

recreational use

Algal growth, 

chlorophyll a

Elevated nitrogen causing 

increased algal growth

Reduce nitrogen loads to 

limit algal growth

Restore wetland Populations of wetlanddependant plant and 

animal species; nitrogen 

and phosphorus

Degradation of wetland 

causing reduced wildlife and 

plant diversity and increases 

in nitrogen and phosphorus 

runoff because of a lack of 

wetland filtration

Restore wetland to 

predevelopment function 

to improve habitat and 

increase filtration of runoff

Conserve and protect 

critical habitat

Connectivity, areal 

extent, patch size, 

population health

Potential impacts could 

include loss of habitat, 

changes in diversity, etc.

Maintain or improve 

critical habitat through 

conservation easements 

and other land protection 

measures

review the TMDL to identify appropriate numeric targets. TMDLs are developed to meet 

water quality standards, and when numeric criteria are not available, narrative criteria (e.g., 

prohibiting excess nutrients) must be used to develop numeric targets. 

Because tribes are not required to base improvements on load reductions, they have the 

discretion to set a wide range of water quality-based goals. Examples include the following: 

 Meet state or tribal water quality standards for one or more pollutants or uses

 Improve measurable water quality conditions or parameters, such as in-stream 

reductions in a pollutant or improvements in a parameter that indicates stream health 

(e.g., macroinvertebrate counts)

 Enhance/restore fisheries
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 Stabilize stream banks

 Restore ceremonial waters 

Once you have selected your water quality-based goals, you can begin to think about the 

techniques, also called BMPs, to meet those goals. You can find in-depth information on 

various BMPs at www.waterquality.utah.gov/TMDL/Virgin_River_Watershed_Implementation_

Appendix.pdf.

Given the wide range of BMP choices, how do you know which ones will be right for 

you? Which will give you the results you need and also be acceptable to stakeholders and 

reasonably affordable? Look to see what people are already using in your area that is working, 

and then determine whether something different is needed. One useful tool is the BMP 

effectiveness tables in the document National BMPs to Control Nonpoint Pollution from Agriculture

available at www.epa.gov/nps/agmm. The table on page 16 of that document lists various 

agricultural management practices in the left column. The other columns provide some 

relative effectiveness information, for each BMP, for controlling runoff volume, phosphorus, 

nitrogen, sediment, and bacteria. Tables like that one, which aggregate BMP performance, can 

be used to screen various management practices and provide information on what might work 

in a particular situation to reduce the effects of NPS pollution. 

4. Design an Implementation Program

Now that you have identified watershed BMPs that when implemented should meet your 

objectives, it is time to develop the remaining elements of your implementation program. 

Designing the implementation program generates several of the basic elements needed for 

effective watershed plans:

 An information/education component to support public participation and build 

management capacity related to adopted BMPs

 A schedule for implementing BMPs 

 Interim milestones to determine whether BMPs are being effectively implemented

 Criteria by which to measure progress toward meeting water quality-based goals

 A monitoring component to evaluate the effectiveness of implementation efforts

 An estimate of the technical and financial resources and authorities needed to 

implement the plan from both your organization and partners

 An evaluation framework

Thus, the end of this process of information gathering and analysis should yield a WBP 

that you can use as a tool for the next 5 or so years. The required elements of this plan are 

discussed in detail in the next section.
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5. Implement Your Plan

Although many watershed planning handbooks end with development of the plan, the 

plan is just the starting point. The next step is to implement the plan in your watershed. 

Implementation can begin with an information/education component or with on-the-ground 

BMPs and projects that implement BMPs. The plan should prioritize which steps are the most 

important so you will know where to begin.

When implementation begins, the dynamic of your watershed partnership, and stakeholders’ 

level of participation, might change. After the plan is completed, you need to determine how 

you want to continue to operate. Implementing a watershed plan involves a variety of expertise 

and skills, including project management, technical expertise, group facilitation, data analysis, 

communication, and public relations. Your watershed plan implementation team should include 

members who can bring such skills to the table. The BMPs you selected, the schedules and 

milestones you set, the financial and technical resources you identified, and the information/

education programs you developed in the course of assembling your plan provide a road map 

for implementation. Follow it. Take advantage of the partnerships you formed during plan 

development to work toward efficient plan implementation.

Key implementation activities include the following:

 Ensuring technical assistance in designing and installing BMPs

 Providing training and follow-up support to landowners and other responsible parties 

in operating and maintaining the BMPs 

 Managing the funding mechanisms and tracking expenditures for each action and for 

the project as a whole

 Conducting land treatment and water quality monitoring activities and interpreting 

and reporting data

 Measuring progress against schedules and milestones

 Communicating status and results to stakeholders and the public

 Coordinating implementation activities among stakeholders, among multiple 

jurisdictions, and within the implementation team

To keep the implementation team energized, consider periodic field trips and site visits to 

document implementation activities in addition to the necessary regular team meetings.

Other tasks associated with implementing the watershed plan include preparing work plans. 

These plans will outline the implementation activities in annual or even 2- to 3-year time 

frames. Think of your watershed plan as a strategic plan for long-term success. Annual grant 

work plans are the specific to-do lists to achieve the vision expressed in your watershed plan.
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As you work through various tasks, share your results. Continuous communication is 

essential to building the credibility of and support for the watershed implementation 

process. Lack of communication can impede participation and reduce the likelihood of 

successful implementation. This is especially critical if you are using a stakeholder-driven 

process. Transparency of the process builds trust and confidence in the outcome. Regular 

communication also helps to strengthen accountability among watershed partners by keeping 

them actively engaged. 

Progress and implementation results can be shared through various media formats, such as 

press releases, ads in local newspapers, television or radio public service announcements, or 

presentations at community meetings such as those of homeowner associations and local civic 

organizations, Parent Teacher Association meetings, or other gatherings of members of the 

watershed community. You could secure time on the local cable access station to discuss the 

watershed plan and share monitoring results with the public. You might also consider hosting 

a press conference with local officials and the stakeholders as a way to thank them for their 

participation, and to inform the larger community about the plan’s contents and how they can 

participate in implementing the plan. 

6. Measure Progress and Make Adjustments

Remember to publicize the project team’s accomplishments to tribal councils or decision 

makers, county commissioners, elected local and state officials, funders, watershed residents, 

and other stakeholders. In Part I, you learned that 319 annual reports may include a list of 

accomplishments to share with interested stakeholders. The project team might also wish to 

issue a watershed report card or develop a fact sheet or brochure to highlight its successes. 

Report cards let the community know whether water quality conditions are improving overall. 

They also allow people to compare results across specific areas to see if things are improving, 

whether some aspects seem to be connected, and whether a change in direction is needed to 

bring about greater improvements. This is an effective way to build awareness of the watershed 

issues and the progress of watershed plan implementation. In addition, when people see 

progress, they will continue to work toward making the plan a success.

Figure II-6 demonstrates how the watershed approach is an iterative process with continual 

improvement as its main goal (adapted from EPA’s Handbook for Developing Watershed Plans to 

Restore and Protect Our Waters, diagram 13-2).

Think of your watershed plan as a strategic plan for long-term success. 

Annual grant work plans are the specific to-do lists to achieve the vision 

expressed in your watershed plan.
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Figure II-6. The iterative process of the watershed approach.

Note: I/E = information and education

WQS = water quality standards

As part of developing your implementation plan, you devised a method for tracking progress. 

Using that tracking system, you should review the implementation activities outlined in your 

work plan, compare results with your interim milestones, provide feedback to stakeholders, 

and determine whether you want to make any corrections. 

In addition, you will have to analyze your monitoring data. At a minimum you should conduct 

a routine summary analysis that tracks progress; assesses the quality of data relative to 

measurement quality objectives (i.e., whether the data are of adequate quality to answer the 

monitoring question); and provides early feedback on trends, changes, and problems in the 

watershed. Routine data analysis in this context does not have to be complex or sophisticated. 

The primary goals are to make sure that your monitoring effort is on track and that you get a 

general sense of what’s going on in the watershed.

Because many watershed activities can affect NPS loads, you should pay attention to broad 

watershed land use patterns such as overall land use change (e.g., abandonment of agricultural 

land, timber harvest, large urban development); changes in agriculture, such as acres 
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under cultivation or animal populations; and changes in watershed population, wastewater 

treatment, stormwater management, and so forth. An annual look at watershed land use is 

probably enough in most cases.

If it is determined that you are not meeting the implementation milestones or interim targets 

that you set for load reductions and other goals, what should you do? There are many reasons 

why you might not see the results you were hoping for, and many of them are easily remedied. 

Consider the following questions before making any changes to your watershed plan: 

 Did weather-related causes postpone implementation?

 Was there a shortfall in anticipated funding for implementing BMPs?

 Was there a shortage of technical assistance?

 Did we misjudge the amount of time needed to install some of the practices?

 Did we fail to account for cultural barriers that prevented implementation?

 Are we implementing and using the BMPs correctly?

 Has the weather been unusual?

 Have there been unusual events or surprises in the watershed?

 Are we doing the right things?

 Are our targets reasonable?

 Are we monitoring the right parameters?

 Do we need to wait longer before we can reasonably expect to see results?

If you have ruled out all the above possibilities, you need to consider whether the plan has 

called for the right BMPs. It is possible that identifying the causes and sources of pollutants 

earlier in the planning process was not completely correct or that the situation has changed. 

Nine Elements of a Watershed-Based Plan

As earlier mentioned, EPA has identified nine elements considered essential for WBPs. 

Figure II-7 shows how the nine elements fit into the six steps in the watershed planning and 

implementation cycle. Why these nine elements? Historically, implementing WBPs with these 

nine minimum elements has been successful because the plans contain the right balance of 

scientific input, public outreach, and long-term monitoring. Implementing an effective plan 

requires tribes and other entities to address all nine elements. The components highlighted in 

white in the diagram are the nine elements that EPA considers essential in an effective WBP.
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Figure II-7. Source of the nine required elements of a Watershed-Based Plan.

Language related to these nine elements that is specific to tribes is in both the most recent 

guidelines for tribes and in the annual competitive RFPs. To access these guidelines, go to 

www.epa.gov/nps/tribal.

Note that the requirements established by EPA for tribes and states differ slightly. States 

are required to estimate pollutant loads and set load reductions. Tribes have the option of 

estimating pollutant loads and associated reductions or basing their plans on water qualitybased goals. EPA has incorporated this flexibility for tribes recognizing that not all tribes 

have yet developed water quality standards, and many tribes might need additional time 

or technical assistance to develop more sophisticated estimates of the NPS pollutants that 

need to be addressed. However, EPA encourages tribes to develop load reductions where that 

information is available. 
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For easy reference, the following is the exact language describing the nine essential elements 

of WBPs, taken from the most recent EPA guidance document at the time of printing.

a. An identification of the causes and sources or groups of similar sources that will need to 

be controlled to achieve the goal identified in element (c) below. Sources that need to be 

controlled should be identified at the significant subcategory level with estimates of the 

extent to which they are present in the watershed (e.g., X number of dairy cattle feedlots 

needing upgrading, including a rough estimate of the number of cattle per facility; Y acres of 

row crops needing improved nutrient management or sediment control; or Z linear miles of 

eroded streambank needing remediation).

b. A description of the NPS BMPs that will need to be implemented to achieve a water qualitybased goal described in element (c) below, as well as to achieve other watershed goals 

identified in the watershed-based plan, and an identification (using a map or a description) of 

the critical areas for which those measures will be needed to implement the plan.

c. An estimate of the water quality-based goals expected to be achieved by implementing 

the measures described in element (b) above. To the extent possible, estimates should 

identify specific water quality-based goals, which may incorporate, for example: load 

reductions; water quality standards for one or more pollutants/uses; NPS total maximum 

daily load allocations; measurable, in-stream reductions in a pollutant; or improvements in a 

parameter that indicates stream health (e.g., increases in fish or macroinvertebrate counts).

If information is not available to make specific estimates, water quality-based goals may 

include narrative descriptions and best professional judgment based on existing information.

d. An estimate of the amounts of technical and financial assistance needed, associated costs, 

and/or the sources and authorities that will be relied upon to implement the plan. As 

sources of funding, Tribes should consider other relevant Federal, State, local and private 

funds that may be available to assist in implementing the plan.

e. An information and education component that will be used to enhance public understanding 

and encourage early and continued participation in selecting, designing, and implementing 

the NPS BMPs that will be implemented.

f. A schedule for implementing the NPS BMPs identified in the plan that is reasonably 

expeditious.

g. A description of interim, measurable milestones for determining whether NPS BMPs or 

other control actions are being implemented.

h. A set of criteria that can be used to determine whether the water quality-based goals are 

being achieved over time and substantial progress is being made towards attaining water 

quality-based goals and, if not, the criteria for determining whether the watershed-based 

plan needs to be revised.

i. A monitoring component to evaluate the effectiveness of the implementation efforts over 

time, measured against the criteria established under element (h) above.
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Remember, each of the nine elements contained in your watershed plan comes from one of the 

six steps of watershed planning and implementation discussed above. Some of the elements 

are stepwise and others you do not need to do in order. The key is to have them all in your 

WBP. Also, if you are working on NPS programs, many of those elements are things you 

are already doing. You do not have to reinvent the wheel. Borrow as much as you can from 

existing documents. For example, you probably are already monitoring, and you already have 

set milestones, but you might not yet have a formalized education and outreach program. 

Many of the elements include pieces that you are most likely already undertaking for other 

programs when you embark on a 319 project. The remainder of this section takes a close look 

at each of the nine elements and offers examples for the reader. 

The goal of this section is to demonstrate that WBPs are worth the effort and that resources 

exist to help tribes successfully develop and implement them. In addition, EPA encourages 

tribes to develop partnerships both within the tribe and beyond, in the name of making real, 

positive changes to their water quality. 

Element a. An identification of the causes and sources or groups of 

similar sources that will need to be controlled 

For the first of the nine elements, you will need to identify the causes and sources of pollutants 

or groups of similar sources that you will aim to control to achieve load reductions, and any 

other water quality goals identified in the watershed plan. As you work through step 1 of the six 

steps of the watershed planning and implementation process, assembling existing and possibly 

new data and conducting analyses on your data, you will be working toward this element. Such 

an analysis will evaluate spatially (e.g., where are the problems?) and temporally (e.g., are the 

impacts seasonal?). What other trends and patterns, such as land use activities, are occurring?

Perhaps at the beginning of the process, you will be aware of only the broadest categories 

of NPS pollution that might be responsible for your water impairments—urban runoff, 

silviculture, construction, or agriculture, for example. At the end of the process, you will able 

to go beyond the basic categories and state with some certainty that your impairments can be 

traced to pastureland, rangeland, feedlots, irrigated crop production, forest management, or 

land development. All these are examples of subcategories of NPS pollution.

But how might you arrive at not only knowing what the pollutants are (the causes) but also 

where the pollutants are from (the sources)? The idea is to start with the basics and work your 

way to specifics. Are you aware of cattle having access to the stream? Is a major construction 

project going on? Have you seen fish kills in certain tributaries of the waterway? In the initial 

stages of watershed planning, many of the links might not be thoroughly understood; they 

will more likely be educated guesses that generate further analyses to determine validity. The 

key in this step is to work with stakeholders to gather enough information that you can begin 

to make some educated guesses about where the problems are coming from. Table II-4 lists 
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some of the most common stressors, or pollutants, experienced in watersheds and the likely 

sources for those stressors. As you would expect, they include some of the most common 

problems: nutrients, sediment, pathogens, and the like. If you have done an NPS assessment 

report, this information is already available for reservation waters.

Table II-4. Common pollutant types and sources found 

in watersheds

Stressors Sources

Sediment Row crop land 

Timber harvest areas 

Eroding stream banks Construction

Nutrients Livestock feeding areas 

Fertilized cropland 

Septic systems

Bacteria Livestock feeding areas 

Septic systems 

Geese and other wildlife

As you move through the watershed planning process, it is often useful to diagram the links 

and to present them as a picture or as a conceptual model (see Figure II-8). These diagrams 

provide a graphic representation that you can present to stakeholders, helping to guide the 

subsequent planning process. In many cases, there will be more than one pathway of cause 

and effect. You can also present that concept to stakeholders verbally, as “if..., then...” links. 

For example, “If the area of impervious surface is increased, flows to streams will increase. 

If flows to streams increase, the channels will become more unstable.” Or, in the simplified 

conceptual model below, if forest is converted to crop land, more sediment will become 

available and wash into the river. 

The conceptual model can be used to start identifying relationships between the possible 

causes and sources of impacts seen in the watershed. You do not have to wait until you have 

collected additional information. In fact, the conceptual model can help identify what types 

of data you need to collect as part of the characterization process. You will want to make sure 

that as part of the characterization process you take a trip with the stakeholders for a visual 

inspection of the waterway. Take pictures and document what you see.

It is critical to go through the process of identifying causes and sources to the best of your 

ability for a few reasons:

 To increase confidence that costly remedial or restoration efforts are targeted at factors 

that can truly improve biological condition

 To identify causal relationships that are otherwise not immediately apparent

 To prevent biases or lapses of logic that might not be apparent until a formal method is 

applied
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Figure II-8. Simplified conceptual model.

Figure II-9 demonstrates how this deductive 

process fits into the overall planning and 

implementation program and illustrates the 

importance of this step to the overall result.

For a detailed description of the stressor 

identification process, see EPA’s Stressor 

Identification Guidance Document (www.epa.gov/

waterscience/biocriteria/stressors/stressorid.

html). In addition, two stressor identification 

modules originally developed as part of EPA’s 

2003 National Biocriteria Workshop are 

available online. The SI 101 course contains 

several presentations on the principles of the 

stressor identification process: www.epa.gov/

waterscience/biocriteria/modules/#si101.

Figure II-9. Role of deductive process in program 

planning and implementation.
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Example: Identification of Causes and Sources (JST 2007):

Causes and sources of pollution in the Dungeness Watershed area include most of the 

eight major categories of nonpoint source pollution in the waterways of the United 

States identified by the Environmental Protection Agency: Agriculture; Forestry; 

Hydromodification/Habitat Alteration; Marinas and Boating; Roads, Highways and 

Bridges; Urbanization; and Wetland/Riparian Management; with subcategories specific to 

each. Of the EPA’s major categories, all but one (mining) are relevant to the Dungeness 

Watershed. The history of collaborative watershed planning in the Dungeness region has 

resulted in an extensive collection of data regarding the sources and trends of pollution 

in each of these categories.

The Agriculture category in EPA’s nonpoint source classification system contains three 

sub-categories relevant to the Dungeness watershed: irrigated crop production, animal 

operations, and aquaculture. Of the three, animal operations present the most significant 

risk to water quality and human health in the Dungeness Watershed. The Clallam 

Conservation District conducted a comprehensive farm inventory in 2006 utilizing air 

photos and visual inspection of farms from the road. Of the 125 farms in Clallam County 

that were rated as having a medium or high potential to impact surface water quality, 23 

were located in the Dungeness drainage covering 495 acres.

Element b. Description of NPS BMPs to achieve water 

quality-based goals 

Once you have identified the causes and stressors, you can select the optimal ways to address 

the problems. BMPs can be structural, such as silt fences, or nonstructural, such as changing 

grazing patterns. 

It is critical that your BMPs correspond to the sources of your impairments and that they are 

measurable. Specify where in the watershed they will be placed, and carefully consider access 

to property and other factors when you determine the locale of your BMPs. For example, your 

plan might say that BMPs will be implemented “on all abandoned mine sites with dry-weather 

flows” or “on all stream banks along upper reaches” or “on all livestock facilities on Willow 

Run.” A map will be very useful in demonstrating where BMPs will be used or installed and 

relocated, if possible.

What does it mean to say that BMPs should be linked to (or otherwise address) stressors and 

sources? It means that water quality goals or estimates for pollutant removal rates should be included 

in your BMP design. If you are not estimating load reductions, these can be based on typical 

ranges, i.e., percentage removed or treated and other reasonable estimates.
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So how do you select the best BMPs for your site? Select BMPs that 

make sense for solving the problem you have identified at your 

location. There are numerous resources to draw on in determining 

which BMPs will achieve the best results for the site, stressors 

present, and sources identified. The cover of one popular source, 

EPA’s National Management Measures for the Control of Nonpoint 

Pollution from Agriculture is featured to the right. On the Web 

site www.epa.gov/nps/pubs.html there are also manuals for 

hydromodification control BMPs, urban area BMPs, BMPs for 

restoring wetlands, and much more (see direct links in Table II-5). 

Nearly all the resources you need are on the Internet. Both EPA 

and USDA have comprehensive BMP manuals that are available 

online. Another excellent source of BMP information, including 

photos, are at www.waterquality.utah.gov/TMDL/Virgin_River_

Watershed_Implementation_Appendix.pdf. Many other states 

also have information on BMPs.

Table II-5. Online resources for BMPs

BMP technical area Online resource

Agriculture www.epa.gov/nps/agmm 

Forestry www.epa.gov/nps/forestrymgmt 

Hydromodification www.epa.gov/nps/hydromod

Marinas and recreational boating www.epa.gov/nps/mmsp

Urban areas www.epa.gov/nps/urbanmm

Wetlands and riparian restoration www.epa.gov/nps/wetmeasures

Coastal waters www.epa.gov/nps/MMGI

It is often recommended that you evaluate which BMPs to use by ranking them. Take a look 

at the BMPs that exist for your subcategory of sources of NPS pollution, and then narrow 

the list down from many to a few until you find the ones that have the right combination of 

effectiveness and ease of utility for your particular site. Consider factors like those listed below 

when selecting BMPs:

 Importance of waterbody: Is it a drinking water source or a cultural or recreational 

resource?

 Magnitude of impairment(s)

 Level of effort needed
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 Existing loads (causes and sources)

 Magnitude, spatial variation, clustering

 Ability of BMPs to reduce loads

 Certainty of success of your BMP

 Feasibility of implementation: Do you have willing partners? Public support? Is the 

landowner willing to do this? 

 Additional benefits, recreational enhancements, demonstration

Another tool that can be useful for selecting your BMPs is a BMP Effectiveness Table. Shown 

below (Table II-6) is one of the BMP effectiveness tables in the agricultural BMPs document 

described above and posted on EPA’s Web site. It lists various agricultural management 

practices in the left column. The other columns provide some relative effectiveness 

information for each BMP (as an individual unit) for controlling runoff volume, phosphorus, 

nitrogen, sediment, and bacteria. Tables like that, which aggregate BMP performance, can 

be used to screen various management practices and to provide information on what might 

work in a particular situation to reduce effects of agricultural operations. Remember that they 

are estimates per unit and that actual effectiveness on the ground will be determined by the 

effectiveness of placement and operation of all the BMP units collectively. Nevertheless, tables 

like this one offer examples of the effectiveness of certain BMPs (called Practice Category in 

the example below) on reducing total phosphorus, total nitrogen, sediment, and fecal coliform. 

Information like that can help you visualize which BMP might be the most effective; however, 

you must still weigh other factors and determine what is right for your program. 

Table II-6. Example of a BMP effectiveness table

Source: www.epa.gov/nps/agmm
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A key point to keep in mind: See what groups are already doing in your watershed. Maybe 

they are doing something that is working well already. Once you have reviewed ongoing 

activities, take a look at those online references. You will want to be familiar with what 

activities are already underway before embarking on resource-intensive projects. Also 

remember to always consider:

 What is essential to achieving objectives?

 Which options do the stakeholders prefer?

 Which options have greatest chance for long-term success and sustainability? 

Not every BMP will be right for everybody. Consider the unique factors in your watershed and 

choose accordingly.

Example: BMP Table (JST 2007) 

The following table illustrates the activities that the Jamestown S’Klallam Tribe will 

undertake to implement its BMPs:

Table II-7. Summary of NPS management measures in the strategy and 

implementation plan (adapted from Streeter and Hempleman 2004)

General strategies Identified actions

Strategies to Address Human Waste

Expansion of septics operation and Assessment and monitoring

maintenance programs Inspect septics of concern

Followup repair, replacement

Purchase of land and conservation River’s End area targeted for restoration due to septic failures 

easements in sensitive areas . and critical salmon habitat .

Land/easement purchase, building demolition, septic removal .

Conversion to community systems Identified areas are 3 Crabs Road, Golden Sands 

where appropriate Development, Carlsborg

Feasibility, design, implementation

Landowner Education Septics 101 class on basic septic system maintenance .

School water quality curriculum

Talks and displays at River Center, displays at area festivals and 

events

Stormwater Management

Sub-area plans for stormwater Focus areas are Marine Drive, 3 Crabs Area

management Restoration of hydrological function in Meadowbrook Creek

Capital facilities, retrofits, standards for new development, 

and basic BMPs based on soil characteristics, topography, and 

development patterns . 
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Table II-7. Summary of NPS management measures in the strategy and 

implementation plan (adapted from Streeter and Hempleman 2004)

General strategies Identified actions

Low Impact Development CCD stormwater management manual for small-scale 

development (rural residential) in progress. The manual 

includes a series of pre-engineered stormwater management 

practices for builders, developers and citizens which can be 

installed without the aid of an engineer. 

The North Peninsula Builders Association has developed a 

Built Green Checklist 

Landowner education.

Agriculture and Livestock Waste

Treatment of irrigation ditch tailwaters Pilot projects completed, biofiltration, constructed wetlands.

Marine Drive specifically identified for treatment.

Ditch piping Reduction of bacterial contamination through piping of open 

ditches, based on priorities identified in CCD monitoring

Individual conservation plans and BMPs CCD activities based on 2006 farm inventory.

Outreach and education Workshops and presentations

Brochures such as “Living on a Ditch”

Web page information

Enforcement WA Dept of Ecology per MOU with Clallam County and 

Clallam Conservation District

Domestic Animals and Pet Waste

Public outreach Waste disposal information via brochures, advertisements and 

presentations; signage

Installation of pet waste stations Areas of high pet use adjacent to surface waters

Cleanup Coordination of volunteer cleanup crews

Regulatory and Policy Approaches

Stormwater ordinance or designation 

of stormwater sensitive areas

Revisions to draft; proceed to adoption (Clallam County)

Critical Areas Update maps and regulatory constraints per Federal ESA 

listings and WA Legislature action

Review development regulations Encourage use of LID, remove disincentives.

Establish Tribal regulations Adopt ordinances to regulate activities on Tribal reservation/

trust lands

Research and Monitoring

Freshwater Develop overall freshwater monitoring for wet season/storm 

events for streams, ditches

Continued fresh water monitoring

BMP effectiveness monitoring

Data analysis of monitoring

Microbial source identification

Streamkeeper voluntary monitoring program

(continued)
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Table II-7. Summary of NPS management measures in the strategy and 

implementation plan (adapted from Streeter and Hempleman 2004) (continued)

General strategies Identified actions

Marine and estuarine areas Continued marine monitoring

Beach and Beachwatcher voluntary monitoring programs

Microbial source identification

Additional research on Dungeness Bay (basic ecological 

studies, nutrients, circulation, fecal coliform assessment in 

water and sediment, wildlife usage)

Feasibility for remediation of Meadowbrook/Cooper/

Matriotti/Gierin creek estuaries

Marine shoreline soft armoring techniques

General Analysis of impervious surfaces

GIS analysis, map fecal nutrient and temporal trends

Education and Outreach

General outreach Public workshops

Newspaper reports

Continuation of school age water quality classes and field trips

Displays and activities in booths, fairs and festivals

Permanent displays at River Center

Web pages at Tribe and River Center

Element c. An estimate of water quality-based goals expected 

to be achieved

Now that you have selected what you consider to be the best BMPs to address your issues in 

an acceptable, feasible, and efficient manner, what kinds of results do you expect to see?

States typically think of load reductions in terms of setting goals. A load estimate tells you how 

much of each pollutant, such as sediment, phosphorus, or nitrogen, is being loaded into the 

waterbody by each group of sources, such as row crops or forest roads. Usually this is done 

using computer modeling programs. That information is used to determine by how much each 

pollutant type entering the waterbody must be reduced.

Tribes are not required to comply with the load estimation aspects of the nine elements. 

Therefore, for tribes that do not choose to go the route of estimating or quantifying pollutant 

loads, the process is somewhat different. After identifying causes and sources of the stressors, 
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instead of estimating loads, tribes are required to produce an estimate of their water qualitybased goals (quantitatively or narratively). These can be defined as the following: 

 Load reductions 

 Water quality standards for one or more pollutants/uses

 NPS TMDL allocations 

 Measurable, in-stream reductions in a pollutant 

 Improvements in a parameter that indicates stream health (e.g., increases in fish or 

macroinvertebrate counts, habitat improvements)

If information is not available to make specific estimates, water quality-based goals may 

include narrative descriptions and best professional judgment based on existing information. 

When you are setting goals and identifying solutions, you will need to tell EPA what you want 

to achieve, where it is that you want to achieve it (your critical areas), and how you want to do 

so (your BMPs).

To summarize, in the last section you identified stressors and sources to be controlled and 

estimated how much of your pollutant of concern was entering a selected waterbody. Once 

you have identified your particular stressors, you can check what the water quality-based goals 

for those pollutants are. These can be general goals, such as reducing the amount of sediments 

in a portion of the waterway, or specific load reductions if available. The next step is to match 

the right BMPs to mitigate the problems and to prioritize your critical areas.

Example from Karuk Tribe, Department of Natural Resources 

Eco-Cultural Resources Management Plan (KT 2006)

The Karuk Tribe desires the implementation of methods to limit and/or mitigate for the 

sediment transport or delivery of materials which degrade water quality and fisheries 

habitat. Where feasible, areas contaminated with mercury or other toxins should be 

located, decontaminated, and restored. Additionally, inactive mines should be properly 

contained to prevent off-site transport of material or contamination of ground and 

surface waters. Limit the used of suction dredging in rivers and creeks at times that 

threaten fisheries or water quality.

There is also a need to restore hydraulic mine areas in many instances, these areas are 

directly adjacent to watercourses. These areas do not maintain a significant vegetation 

component and subsequently can contribute to excess heating of adjacent streams.

Objectives:

Implement restoration measures that mitigate damaged areas affected by past hydrologic 

mining to minimize soil erosion, reconfigure topographic contours and drainage, 
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and manage vegetation to enhance the structure and composition to accommodate 

natural processes (fire, hydrologic connectivity, and nutrient cycling). Remove and/or 

reduce the presence of toxins such as mercury, sulfuric acid and cyanide in sediment 

deposits and watercourses. Monitor and reduce the effects and activities associated 

with suction dredge mining along the Klamath and Salmon River watersheds. Inventory 

rock sources and mitigate for erosion potential and off site sediment delivery. Develop 

economically and environmentally low impact methods of aggregate removal to supply 

for local upgrade, maintenance and restoration activities. Work with Federal, State, and 

County Agencies, and community groups to ensure cultural/natural resource protection 

measures are adequate and in place.

Element d. An estimate of the amounts of technical and financial 

assistance needed, associated costs needed to 

implement your plan

A critical factor in turning your watershed plan into action is the ability to fund 

implementation. Funding is needed for all the activities in the WBP, such as management 

practice installation, information and education activities, monitoring, and administrative 

support. In addition, you should document the types of technical assistance needed to 

implement the plan and the resources or authorities that will be relied on for implementation, 

in terms of both initial adoption and long-term operation and maintenance (O&M). For 

example, if you have identified adoption of tribal ordinances as a management tool to meet 

your water quality goals, you should involve the local authorities that are responsible for 

developing those ordinances and outline their short-term and long-term roles.

The estimate of financial and technical assistance 

should take into account the following:

 Administration and management services, 

including salaries, regulatory fees, and 

supplies, as well as in-kind services efforts 

such as the work of volunteers and the 

donating of facility use

 Information/education efforts

 The installation, operation, and 

maintenance of BMPs

 Monitoring, data analysis, and data 

management activities

Haaku Water Office restoration project near Sky City, 

Acoma Pueblo.
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Some of the costs of implementing your watershed plan can be defrayed by leveraging existing 

efforts and seeking in-kind services. Some examples follow.

Use existing data sources. Most geographic areas have some associated background spatial 

data in the public domain, such as digital elevation models, stream coverages, water quality 

monitoring data, and land cover data. Note that the EPA Quality System (EPAQA/G-5; 

www.epa.gov/quality) recommends that a QAPP be prepared for using existing data and for 

collecting new data.

Use existing studies. Many agencies have reports of previous analyses, providing useful baseline 

information and data, such as delineated subwatersheds or a historical stream monitoring 

record. The analyses might have been done for another purpose, such as a study on fish health 

in a stream, but they can contribute to an understanding of the background of the current 

concerns.

Use partnerships. State, county, or federal agencies working as technical assistance providers 

and implementing natural resource program initiatives can offer computer services and 

expertise, such as performing GIS analysis or weaving together elements of different programs 

that might apply to the local area. They might be in a position to write part of the overall 

watershed plan if they have existing generalized watershed characterization studies.

Cover incidental/miscellaneous costs through contributions. For example, staff time to assemble 

needed elements, supplies, and meeting rooms for a stakeholder or scoping meeting can all 

be donated. As a start, refer back to the checklist you compiled from your stakeholder group 

earlier to determine what resources are available in the group. 

Locating Federal Funding

For a complete list of federal funding 

sources, visit the Catalog of Federal 

Domestic Assistance (www.cfda.gov). That 

Web site provides access to a database 

of all federal programs available.

Also visit www.epa.gov/watershedfunding

to view the Catalog of Federal Funding 

Sources for Watershed Protection. That 

interactive Web site helps match 

watershed project needs with funding 

sources.

Amber Marriott
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Example: Excerpt from the Dungeness WBP Estimated Budget 

(JST 2007)

Table II-8. Overview of estimated costs

Notes on this table: Cost estimates are organized by Tribal sub-goal and were obtained from a variety of 

sources including the Tribal NPS Management Plan, Clean Water Strategy/DIP, Comprehensive Irrigation 

Water Conservation Plan, Salmon Recovery Plan, and partner organizations such as Clallam Conservation 

District and Dungeness River Audubon Center. Some estimates represent ongoing program costs, while 

others are one-time project costs, thus they have not been added together to present a total annual or 5-year 

estimate. Where appropriate, the estimates have been separated for Tribal and partner NPS programs.

Activities by tribal goal

Estimated 

costs

Time 

frame Comments

Funding 

sources

WATER QUALITY MANAGEMENT MEASURES 

Tribal NPS Programs

Staff and office supplies 

to oversee monitoring of 

water and shellfish, septic 

programs, stormwater planning, 

revegetation and other BMPs for 

protecting and improving water 

quality. 4.75 FTE

$522,000 annual 

costs, 

ongoing

details in Tribal 

NPS plan; 

includes staff, 

office supplies, 

travel, training, 

overhead, and 

engineering/

tech 

consultation

EPA, BIA/

OSG, Ecology, 

WDFW, Tribal 

Funds

Projects for channel restoration, 

stormwater facilities, 

revegetation, agriculture BMPs, 

septic remediation

$325,000 annual 

costs, 

5 year 

plan

project 

construction 

costs

Public education programs $30,000 annual, 

ongoing

EPA, Ecology, 

Foundations

Monitoring supplies, 

transportation, laboratory costs

$30,000 annual, 

ongoing

EPA, BIAOSG, Ecology, 

WDFW, Tribal 

Funds

Land acquisition where other 

water quality remediation is not 

feasible (acquisition and removal 

of structures and septic systems)

$250,000 2-10 

years

Land and Water 

Conservation 

Fund, RCFB, 

Private

Partner NPS Programs

Clean Water Strategy

Ongoing actions for septic 

inspection and education 

programs, public outreach, 

stormwater planning, livestock 

plans, monitoring, streamkeepers

$2,900,000 5 years Clean Water 

Strategy/DIP 

has detailed 

breakout

Centennial 

Fund, EPA, 

Special 

Assessments, 

County Fees, 

WRIA 18 

implementation 

funds, other 
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Element e. An information and education component that will be 

used to enhance public understanding

An important aspect of pollution prevention is to think ahead and make people aware of their 

impacts on water quality. When people are made aware of the consequences of their actions, 

they might start to think about what they can do to mitigate their impacts. The best way to go 

about raising awareness is to implement a public outreach, education, and involvement plan. 

The information discussed in this section is from the River Network’s Training for Watershed 

Trainers, Communications Planning Session, December 2007 (www.rivernetwork.org).

An outreach, education, and involvement plan will help you and your 

organization educate people on water quality concerns in your area and 

their effects on declining water quality. Many people might not realize 

that their actions can affect water quality. For example, allowing cattle 

to graze along a nearby spring can cause E. coli contamination, and 

driving across a stream to collect plants for medicinal purposes can 

cause sedimentation in the stream. 

An outreach and education plan can also be used to give the public 

a heads-up about upcoming NPS projects that they will be seeing 

throughout the reservation or watershed. If a passer-by sees a fencing 

project being implemented at a popular fishing spot, he is more likely to 

respond positively to the project if he already knows about it.

Before developing an outreach plan, ask yourself the following questions:

 What do we have? For example, polluted runoff in waterways from unrestricted 

livestock grazing.

 What do we want to change? For example, less runoff equals cleaner water quality.

 What is on our wish list? For example, raise awareness to change actions and practices.

 What is our budget? How much money do we have? (Be realistic.)

 What are our communication goals? For example, use mailings, attend public 

meetings, and have a booth at the Environmental Department Annual Earth Day Fair.

Audience Development

An important part of your audience is the stakeholders. A stakeholder is a group or individual 

who has the responsibility for implementing the decision, is affected by the decision, or has 

the ability to impede or assist in implementing the decision. Stakeholders are an important 

part of the audience because you want to ensure that their concerns are factored into the 

decisions made to address water quality pollution. In addition, they have the ability to impede 

the effectiveness of any projects carried out if their concerns are not considered.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Once you have determined your outreach plan, focus on a segment of your targeted 

audience. Ask yourself these questions:

 Who needs to hear your message?

 Who has influence over your targets?

Then get to know your audience by listening to them. Invite a select group of people from 

your targeted audience, such as elders or tribal council members, to a meeting or a dinner. 

Also, use this opportunity to ask if they have their own priorities and issues and see if 

you can meet somewhere in the middle.

Message Development

Next, develop your message using feedback from your stakeholder group and use one of four 

ingredients of a good message: value, barrier, ask, or vision.

	 Value For example, a tribal elder reminisces about how long ago as a little boy he used 

to swim at a nearby swimming hole with his grandfather, but now he cannot 

swim with his grandchildren because the water is so dirty. The poor water 

quality is from cattle overgrazing at the swimming hole and lack of vegetation 

and shade around the swimming hole. The water quality has declined because 

of high water temperature from lack of shade and high levels of fecal coliform 

bacteria from cattle. The value message helps the audience to relate and care 

about the issue because it touches on a family value.

	Barrier For example, a tribal elder reminisces about how long ago as a little boy he used 

to swim at a nearby swimming hole with his grandfather, but now he cannot 

swim with his grandchildren because cattle waste has rendered it too dirty. The 

barrier message helps the audience relate and realize that something can be done 

about it.

	 Ask For example, a tribal elder reminisces about how long ago as a little boy he used 

to swim at a nearby swimming hole with his grandfather, but now he cannot 

swim with his grandchildren because cattle waste has contaminated the water. 

The tribal elder asks the audience, “Wouldn’t you want your grandchildren to 

stop playing video games at home and go out and spend some time swimming 

with you?” The ask message helps the audience to start thinking about what can 

be done to fix this problem and what the positive effects could be.

	 Vision For example, a tribal elder reminisces about how long ago as a little boy he used 

to swim at a nearby swimming hole with his grandfather, but now he cannot 

swim there with his grandchildren because the cattle that use the swimming 

hole for drinking leave the water too dirty for swimming. He imagines how it 

would be fun to teach his grandchildren how to swim and to be there when 
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

they start to swim on their own. The vision message helps the audience clearly 

envision what it would be like to have clean water again.

When you develop a message to use in your outreach activities, remember to use words your 

targeted audience will understand. Avoid using technical terms. For example, not many people 

know what nonpoint source pollution means, so use polluted runoff in your message instead. 

Delivering Your Message

After you have developed your message, you will want to practice it. Meet with a couple 

people from your stakeholder group and ask them to listen for the following when you practice 

your message:

 Content: Is it relevant to them?

 Words used: Are they able to understand?

 Engagement: Are you captivating their interest?

 Impact or pressure: Is the amount just right or too much pressure?

 Organization: Does your message make sense?

 Timing: Is it too long or too short?

Now that you have developed your message and know your audience, you are ready to deliver 

your message. Many methods to deliver your message are available. Develop brochures, fact 

sheets, and door-to-door materials to be used for in-person outreach such as fairs, events, 

hands-on demonstration projects, school presentations, tribal council presentations, and 

public tours of project sites. Media resources—Web site postings, newsletters, articles in the 

newspaper, and radio spots—can also be used as methods of delivering your message. If one 

method does not work, use another until you find something that works.

Where to Get More Help on Information/Education 

Activities

For more information on planning and implementing outreach 

campaigns, refer to EPA’s Getting in Step: A Guide for Conducting Watershed 

Outreach Campaigns. This comprehensive guide will walk you through 

the six critical steps of outreach—defining your goals and objectives, 

identifying your target audience, developing appropriate messages, 

selecting materials and activities, distributing the messages, and 

conducting evaluation at each step of the way. You can download the 

guide at www.epa.gov/owow/watershed/outreach/documents/getnstep.pdf

or order it by calling 1-800-490-9198. 

Ask for publication number EPA 841-B-03-002.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Don’t Reinvent the Wheel

EPA has developed a Nonpoint Source Outreach Digital 

Toolbox, which provides information, tools, and a 

catalog of more than 700 outreach materials that 

state, tribal, and local agencies and organizations 

can use to launch their own NPS pollution 

outreach campaigns. The toolbox focuses on six 

NPS categories: stormwater, household hazardous 

waste, septic systems, lawn care, pet care, and 

automotive care, with messages geared to urban 

and rural settings. Outreach products include 

mass-media materials, such as print ads, radio and 

television public service announcements, and a 

variety of materials for billboards, signage, kiosks, 

posters, movie theater slides, brochures, factsheets, and everyday object giveaways that help 

to raise awareness and promote non-polluting behaviors. The outreach products can be easily 

modified for use in raising awareness about other NPS categories not discussed here. The 

toolbox is available online and as a CD at www.epa.gov/nps/toolbox.

Example: Karuk Tribe’s Plan (KT 2006)

Environmental Education has been very important to the Karuk Tribe since program 

inception. Environmental Education projects serve to inform Tribal and local community 

members about the Department’s mission. Projects such as Fall Salmon Spawning 

Surveys, during which students collect data that is used by the California Department 

of Fish and Game, not only give these students hands-on training, but encourage a 

deeper appreciation of natural resources and ecological processes. The Department’s 

Environmental Education Program provides opportunities for people to correlate 

current science with traditional knowledge and cultural practices.

Objectives:

Instill in students and adults a life-long desire to learn about and care for their 

environment. Provide opportunities for youth to learn from Tribal elders about 

traditional Karuk land and resource management practices. Work with local schools, 

agencies, organizations, community groups and Tribal members to enrich student and 

adult knowledge of local environmental and watershed issues to ensure protection of 

cultural/natural resources. Implement and assist with projects on recycling, community 

gardening, salmonid spawning and habitat needs, ethnobotany, and other relevant 

environmental issues to teach students to be good stewards of their local resources and 

ecological processes. Train students and adults to put their knowledge into practice by 

providing hands-on activities both in classrooms and outdoors.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Element f. A schedule for implementing the NPS BMPs identified 

in the plan that is reasonably expeditious

The schedule component of a watershed plan involves turning goals and objectives into 

specific tasks. The schedule should include a timeline showing when each phase of the step 

will be implemented and accomplished, as well as the agency/organization responsible for 

implementing the activity. In addition, the schedule should be broken down into increments 

that you can reasonably track and review. For example, the time frame for implementing tasks 

can be divided into quarters. You will prepare more detailed schedules as part of your annual 

work plans.

In developing schedules, it helps to obtain the input of those who have had previous 

experience in applying the recommended actions. Locate experienced resource agency staff 

and previous management practice project managers where possible to identify the key steps. 

Be sure to note sequence or timing issues that need to be coordinated to keep tasks on track. 

For example, your project might require applying for permits, which should be accounted 

for in the implementation schedule. As part of your implementation program, you should 

set some criteria by which to determine whether you are achieving load reductions or water 

quality goals over time and making progress toward meeting your overall watershed goals. 

These criteria can also support an adaptive management approach by providing mechanisms 

by which to reevaluate implementation plans if you are not making substantial progress 

toward meeting your watershed goals.

Figure II-10. Implementation schedule for high-priority AMD sources.

Source: Watershed Based Plan for the Deckers Creek Watershed, Preston and Monongalia Counties, 

West Virginia, August 2006.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Element g. A description of interim, measurable milestones for 

determining whether NPS BMPs or other control 

actions are being implemented 

One means of supporting detailed scheduling and task tracking is to identify interim, 

measurable milestones for determining whether management practices or other control actions 

are being implemented. What do you want to accomplish by when? It usually helps to think of 

milestones in terms of relevant time scales. For example:

 Short-term (1 to 2 years)

 Mid-term (2 to 5 years)

 Long-term (5 to 10 years or longer)

It is also helpful to think of the milestones as subtasks, or what needs to be accomplished over 

time to fully implement the practice or BMP. When determining time scales and subtasks for 

actions, milestones should be placed in the context of the implementation strategy. Given the 

selected practices and the available funds or time frame for obtaining grants, estimate what 

can be accomplished by when. 

First, outline the subtasks involved and the level of effort associated with each to establish a 

baseline for time estimates. Next, identify the responsible parties associated with the steps so 

that you can collectively discuss milestones and identify those that are feasible and supported 

by the people who will do the work.

Watershed restoration 

activities: creating a rock 

check dam with two rain 

gardens up and downstream 

of a dam, with planted 

sedges (EPA Region 5 NPS 

workshop, 2007).
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Example: Dungeness WBP (JST 2007)

Table II-9 contains an excerpt from the Implementation schedule of the Dungeness 

Watershed Based Plan (JST 2007) .

Table II-9. Milestones for implementation and measurable criteria for evaluating 

progress

Note: This table has been organized around Jamestown S’Klallam Tribal natural resources sub-goals, shown in the shaded areas, 

and the NPS categories addressed . Under each goal, the table summarizes management strategies, milestones for implementation, 

anticipated timing (subject to funding), key watershed partners, how our outputs will be measured, and the criteria to be used to 

evaluate progress . There is a considerable amount of overlap between tribal goals, and the management strategies might address 

more than one source of NPS pollution . Thus, some of the major milestones and evaluation criteria might apply to more than one 

goal and NPS category . 

TRIBAL SUB-GOAL: Ensure water quality that protects fish and wildlife resources and provides 

safe food and water.

NPS Categories Addressed: Agriculture, Hydromodification & Habitat Alteration, 

Urbanization, Marinas & Vessels

NPS 

management 

strategy

Milestones for 

implementation Timing

Key 

partners Measureable outputs

Measureable 

criteria for 

evaluating progress 

(outcomes)

Human 

Waste 

Management

Support county 

programs for 

septic O&M, septic 

inspection and 

remediation

ongoing County # septic systems 

pumped

Reductions in fecal 

coliform loading to 

Matriotti Creek, 

Dungeness River & 

Bay: achieve 80% of 

required reduction 

by 2010, meet water 

quality standards by 

2012

Database tracking of 

septic O&M

# systems inspected 

and repaired

# classes Septics 101

Suppport the 

development of 

community systems 

for areas of concern

5 years County Feasibility studies 

completed for 3 

systems, and at least 

one to design & 

construction phase .

Buyout remaining 

parcels at 

Rivers End and 

decommission 

septic systems

3 years Tribe, 

County, 

WDFW, 

NOLT

Parcels purchased 

and septics 

decommissioned .

Stormwater 

Management

Treatment of 

irrigation ditch 

tailwaters

5 years CCD, 

WUA

Installed treatment 

sites

Achieve net 

reductions in nitrates 

for Carlsborg and 

other elevated 

areas; achieve net 

reductions in bacteria; 

achieve public health 

standards

No increase in metals 

or hydrocarbons for 

baseline streams .

Piping of irrigation 

ditches

20 years WUA # feet ditch lined

Increase use of LID 

methods

5 years Tribe, 

County, 

CCD

County approval of LID 

techniques

Reduce stormwater 

impacts 

1 .5 years County, 

Tribe

County approval of 

upgraded stormwater 

manual; County Roads 

Dept install LID in 

roadside ditches

5 years Tribe Retrofit tribal facilities

Raise public 

awareness

5 years Volunteers Signage program at 

stormwater drains
Part 1I: Watershed-Based Planning | II-45

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Table II-9. Milestones for implementation and measurable criteria for evaluating 

progress

NPS 

management 

strategy

Milestones for 

implementation Timing

Key 

partners Measureable outputs

Measureable 

criteria for 

evaluating progress 

(outcomes)

Animal 

Waste 

Management

Implement pet waste 

program

1 year Tribe, EPA, 

volunteers

Mailings and posters 

distributed

Reductions in fecal 

coliform loading per 

TMDLs

2 years County 

parks

Install pet waste stations

Reduce domestic 

animal waste

5 years CCD Complete farm plans 

with BMPs

Enforce animal waste 

violations

ongoing Ecology Last resort after 

outreach and technical 

assistance.

Monitoring

Shellfish sampling ongoing Tribe, 

DOH

Bi-weekly for intertidal 

harvest during PSP 

season; weekly for 

geoduck harvest

Safe consumption 

of shellfish by tribal 

citizens and general 

public 

Marine waters ongoing Tribe, 

DOH

Monthly sampling Achievement of 

certified shellfish beds 

in Dungeness Bay by 

2012

Freshwater ongoing Streamkeepers, 

Baywatchers, 

Tribe, 

County

Monthly sampling; 

quarterly for some 

parameters

Safe wading/swimming 

for tribal citizens and 

general public; attain 

temperature/DO 

targets for fish bearing 

streams 

Complete annual 

data analysis

annual Clean 

Water 

Work 

Group

Annual review of results

Adaptive mgt of 

strategies based on 

results.

Achieve capacity 

to monitor all 

nine parameters 

required under CWA 

Section 106

Tribe Trained staff, 

all equipment 

available, funding 

for staff, materials, 

transportation, lab costs

Attain water quality 

standards for all nine 

parameters

Research

Microbial source 

identification

1 year Tribe, 

Battelle, 

Ecology, 

County

Identification of 

controllable sources of 

bacterial contamination.

Adaptive mgt of 

strategies based on 

results.

Evaluate D Bay 

for nutrients and 

wildlife contribution

5 years Tribe, 

Ecology, 

DOE, 

WDFW

To be developed

Evaluate culture 

methods for 

oysters, clams etc

ongoing Tribe, 

volunteers

Shellfish gardens 

completed

GIS analysis and 

remote sensing

ongoing Tribe, 

CCD, 

County

Annual airphotos, 

updated maps

Evaluate 

effectiveness of 

BMPs

ongoing Tribe, 

County, 

CCD

Progress reports Adjustment of BMPs 

to achieve water 

quality standards

(continued)
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Table II-9. Milestones for implementation and measurable criteria for evaluating 

progress

NPS 

management 

strategy

Milestones for 

implementation Timing

Key 

partners Measureable outputs

Measureable 

criteria for 

evaluating progress 

(outcomes)

Research 

(continued)

Investigate 

restoration of 

pocket estuaries 

at Meadowbrook, 

Cooper, Casselary, 

Gierin Creeks

5 years CCD, 

Tribe, 

WDFW

Complete feasibility 

analysis and identify 

restoration options

Regulatory

Upgrade city and 

county ordinances

1 to 5 

years

County, 

Ecology

Adopt stormwater 

manual

Improved water 

quality(bacteria, 

nutrients, chemicals)

MRC, City Designate nearshore 

critical areas

Revisions to CAO

County, 

Tribe, 

CCD

Identify barriers to 

improved water quality 

in ordinances

Updated ordinances 

leading to improved 

water quality

Develop/update 

Tribal ordinances

1 to 5 

years

Tribe Improve jurisdictional 

control over tribal 

waters

Updated/new 

ordinances leading 

to improved water 

quality

Education 

and 

Outreach

Public workshops 

on water quality 

issues

annual County, 

CCD, 

River 

Center, 

Tribe

# Workshops 

conducted; # individuals 

attending

Behavior change 

leading to improved 

water quality; 

participant feedback

Prepare written 

material for public 

outreach

annual County, 

CCD, 

Tribe

Newspaper articles 

and mailings; annual 

milestones report of 

DRMT; 

# publications 

distributed

Booths, fairs and 

festivals

biannual All 

partners

Dungeness River 

Festival; attendance and 

participation

Behavior change 

leading to improved 

water quality; 

participant feedback

annual Variable booths, exhibits, fairs 

—attendance and 

participation

Design and 

implementation of 

interpretive displays

5 years River 

Center

Permanent displays at 

River Center

5 years River 

Center, 

Tribe, 

WDFW, 

County 

parks

Interpretive trail signs

Information for 

recreational boaters

1-5 years WDFW, 

County 

parks, 

Tribe

Interpretive signs and 

brochures for boaters 

at launch sites.

Behavior change 

or continued 

stewardship by vessel 

owners.

In-class and in-field 

school programs

ongoing River 

Center; 

Tribe; 

CCD; 

County

# of students reached;

# of accompanying 

adults reached 

Evaluate student 

understanding of 

watershed processes 

and impacts from 

actions; participant 

feedback; teacher 

feedback 

(continued)
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Element h. A set of criteria that can be used to determine whether 

the water quality-based goals are being achieved over 

time and substantial progress is being made

The criteria can be expressed as indicators and associated interim target values. You can 

use various indicators to help measure progress. You will want to select indicators that will 

provide quantitative measurements of progress toward meeting the goals and can be easily 

communicated to various audiences. It is important to remember that the indicators and 

associated interim targets will serve as a trigger: If the criteria indicate that you are not 

making substantial progress, you should consider changing your implementation approach.

The indicators might reflect a water quality condition that can be measured (dissolved oxygen, 

nitrogen, total suspended solids) or an action-related achievement that can be measured 

(pounds of trash removed, number of volunteers at the stream cleanup, length of stream 

corridor revegetated). In other words, the criteria are interim targets in the watershed plan, 

such as completing certain subtasks that would result in overall pollutant reduction targets. Be 

sure to distinguish between programmatic indicators that are related to the implementation of 

your work plan, such as workshops held or brochures mailed, and environmental indicators 

used to measure progress toward water quality goals, such as phosphorus concentrations or 

sediment loadings.

Table II-10. Stressors and indicators

Stressor Measurable indicator

Sediment Total suspended solids (TSS), turbidity

Eutrophication Chlorophyll a, nitrate/ nitrite/ total phosphorus/ nitrogen, ammonia, dissolved oxygen 

Pathogens Fecal coliforms, E. coli

Metals Copper, lead, zinc

Habitat Temperature, physical habitat assessed by rapid bioassessment

General water 

quality

Total dissolved solids (tds), conductivity, pH, oil and grease

Flow Dry-weather flow, peak flow, flood event frequency

Biology Diversity and richness indices, biological indices, macroinvertebrates, basic habitat

In the case of scientific indicators, remember that your measurable criteria or indicator links 

your stressors with your goals. The indicator will tell you whether a BMP is sufficiently 

addressing the source and achieving your goal. The indicators you selected (e.g., riparian 

buffers/canopy cover, nutrient concentrations, suspended solids) will serve as the yardstick for 

providing baseline and post-project information. You will also need to select a target value for 

your project monitoring indicators, so you can measure progress toward your management 

objectives.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

As an example:

Source/Stressor = excessive turbidity of river water.

Indicator (criteria) = nephelometric turbidity units (NTUs), as read on a 

calibrated digital probe.

Water quality goal = Turbidity must not exceed 5 NTUs over natural 

background levels when the natural background is 50 NTUs or less, or have 

more than a 10 percent increase in turbidity when the natural background 

level is more than 50 NTUs.

Example: Indicators in the Dungeness WBP 

(JST 2007)

Criteria for evaluating progress are ... organized by Tribal 

sub-goal as follows:

Water Quality: Interim criteria have been developed as part 

of the TMDLs for the Lower Dungeness River/Matriotti 

Creek and Dungeness Bay. Over the long term, it is the 

Tribe’s intent that bacteria levels are reduced sufficiently that 

all shellfish beds in the Dungeness area are certifiable. The 

Detailed Implementation Plan contains tables of the required 

reductions in fecal coliform concentrations for tributaries to 

Dungeness Bay, marine sites, Dungeness River, and irrigation 

ditches to the inner Bay. The interim targets of the Clean 

Water Workgroup are:

 Achieve target bacteria reductions in the Dungeness 

River and Matriotti Creek Fecal Coliform Bacteria Total 

Maximum Daily Load Study (Sergeant 2002)

 For the Dungeness Bay Fecal Coliform Bacteria Daily 

Load Study (Sergeant 2004), the targets are as follows:

l Approximately 80% of required reduction by 2010

l Achievement of standards and restored shellfish 

harvest by 2012

In addition to the interim targets based on fecal coliform concentrations, it is the goal 

of the Clean Water Work Group to meet all other water quality standards by 2012 and 

maintain them thereafter. These include all the parameters required under the Clean 

Water Act section 106 program.

The following are some factors you might 

want to consider when selecting your 

indicators:

Validity

 Is the indicator related to your goals and 

objectives?

 Is the indicator appropriate in terms of 

geographic and temporal scales?

 Is the indicator measurable?

Clarity

 Is the indicator simple and direct?

 Do the stakeholders agree on what will be 

measured?

 Are the methodologies consistent over time?

Practicality

 Are adequate data available for immediate 

use?

 Are there any constraints on data 

collection?

Clear Direction

 Does the indicator have clear action 

implications, depending on whether the 

change is positive or negative?
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Element i. A monitoring component to evaluate the effectiveness 

of the implementation efforts over time

As part of developing your watershed plan, you need to develop a monitoring component to 

track and evaluate the effectiveness of your implementation efforts using the criteria developed 

in the previous section.

Monitoring programs can be designed to track progress in meeting tribal water quality goals, 

which can include load-reduction goals and attaining water quality standards. As in any 

environmental program, there are significant challenges to overcome. Clear communication 

between program and monitoring managers is important to specify monitoring objectives that, 

if achieved, will provide the data necessary to satisfy all relevant management objectives. The 

selection of monitoring designs, sites, parameters, and sampling frequencies should be driven 

by the agreed-upon monitoring objectives, although some compromises are usually necessary 

because of factors such as site accessibility, 

sample preservation concerns, staffing, 

logistics, weather and costs. If compromises 

are made because of constraints, it is 

important to determine whether the 

monitoring objectives will still be met with 

the modified plan. There is always some 

uncertainty in monitoring efforts, but to 

knowingly implement a monitoring plan 

that is fairly certain to fail is a complete 

waste of time, effort, and resources. Because 

statistical analysis is usually critical to the 

interpretation of monitoring results, it is 

usually wise to consult a statistician during 

the design of a monitoring program. 

Consider a range of objectives like the 

following when developing your monitoring 

program:

 Analyze long-term trends 

 Document changes in management 

and pollutant source activities in the 

watershed

 Measure the performance of 

specific management practices or 

implementation sites

Water blessing ceremony on the Winnebago Reservation 

in Nebraska.
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 Calibrate or validate models

 Fill data gaps in the watershed characterization

 Track compliance and enforcement in point sources

 Provide data for educating and informing stakeholders

When developing a monitoring design to meet your objectives, it is important to understand 

how the monitoring data will be used. Ask yourself questions like the following:

 What questions are we trying to answer?

 What assessment techniques will be used?

 What statistical power and precision are needed?

 Can we control for the effects of weather and other sources of variation?

 Will our monitoring design allow us to attribute changes in water quality to the 

implementation program?

Remember that you might not see success the very first time that you try new BMPs. That is 

why the watershed approach includes a feedback loop for continual improvement. Set realistic 

goals that you can achieve, keep your stakeholders enthusiastic, and make improvements 

where and when needed!

Example: Monitoring Activities identified in the Dungeness WBP 

(JST 2007)

In addition to water quality parameters (temperature, turbidity, bacterial, nitrates, 

metals, etc.), the Tribe and partners have extensive baseline and ongoing monitoring of 

ecological processes, habitat conditions, and the status of plant and aquatic biological 

communities. It is the goal of the Tribe and partners to monitor all nine parameters 

required under the Clean Water Act Section 106 programs by 2012. This will require 

additional staff training, equipment, laboratory services, data analysis, and preparation 

of new and updated Quality Assurance Project Plans. Ongoing monitoring and adaptive 

management is dependent upon adequate funding for these activities.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Regional Review of Watershed-Based Plans

Tribes that would like EPA to review their WBPs should submit their plans to their EPA 

project officer. The project officer or another EPA staff member will review each WBP to 

determine whether the plan has the nine minimum elements required in EPA watershed 

plans. For an example of a WBP checklist for EPA Region 10, see http://yosemite.epa.gov/R10/

ecocomm.nsf/Watershed+Collaboration/State+Tribal+NPS/$FILE/Tribal-319-Checklist.pdf. Other 

EPA regions might use different types of checklists in reviewing WBPs. For more information, 

contact your Regional Tribal NPS coordinator.

The review is not a regulatory or legal requirement for tribes. The primary purpose of 

the review is to work with tribes to develop plans that can greatly increase the chances 

of improving water quality within reservation waters, as well as waters upstream and 

downstream of reservation boundaries. Tribes may also implement a WBP that was not 

developed by the tribe. For example, some tribal reservation watersheds might reside in a 

small portion of the reservation. The remainder of the watershed is on land where a WBP was 

developed by another organization. In such cases, tribal water staff could submit to EPA the 

WBP developed by the nontribal group to help determine its impact on reservation waters.

Although EPA strongly recommends developing WBPs, a tribe could still receive funding for 

projects not part of a WBP, as long as it shows that the project contains many aspects of a 

watershed planning process and will contribute to improving water quality conditions on a 

watershed scale. Priorities and requirements for tribal NPS implementation projects in the 

annual RFPs could change over time, so applicants should read the most recent publication for 

current information.

Amber Marriott

First National Tribal NPS Workshop, September 2009, Morongo Reservation, CA.
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Leveraging Funding Resources

The base and competitive funding provided by EPA through the national NPS pollution 

control program will not usually be sufficient to address all the polluted runoff and aquatic 

habitat problems on tribal lands. The tribes having the most success with improving water 

quality are usually those that are able to leverage other resources, such as assistance from 

technical service providers, support from other programs interested in water resources, inkind labor provided by volunteers or students, other departments in the tribe with available 

funds or means of support such as equipment, or funding from outside sources. This section 

describes some approaches for acquiring technical, labor, funding, or other resources to 

support tribal NPS management programs and projects. The topics below start with those 

resources that are probably closest to the tribe’s NPS pollution program and move outward to 

other related resources.

Tribal CWA 106 Program

Section 106 of the CWA authorizes federal grants to assist state and interstate agencies in 

administering water pollution control programs. Federally recognized tribes that have applied 

for and received treatment in a manner similar to a state (TAS) and meet the requirements 

of CWA section 518(e) can receive CWA section 106 funding. That funding allows tribes to 

address water quality issues by developing monitoring programs, water quality assessment, 

standards development, planning, and other activities designed to manage reservation water 

resources.

Most tribes use staff supported by their CWA section 106 grants to develop their CWA section 

319 assessment reports and management program plans. EPA also encourages tribes to use 

106 funding to develop WBPs. Section 106 funds can also be used for inventorying nonpoint 

sources, attending NPS meetings and training, and forming partnerships to address NPS 

issues. After the CWA section 319 funding is received and the tribal NPS pollution program is 

established, the CWA section 106 program provides an important source of support for 

technical and other services, which can be integrated with the nonpoint program into the 

tribe’s overall water resource management agency or program. Section 106 funds focus on 

Clean water is not an expenditure of federal funds; clean 

water is an investment in the future of our country. 

—Bud Shuster, U.S. Representative

quoted in The Washington Post, January 9, 1987 
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

The Upper Sioux Community conducts water resource outreach (EPA Region 5 NPS workshop, 2007).

planning and management activities and may not be used to implement WBPs or for on-theground projects. Any pre- and post-project monitoring efforts should be incorporated into 

319-funded projects; however, 106 funds can be used for this monitoring if needed. Tribes 

should contact their EPA section 106 coordinator for further information. Information on the 

overall section 106 program is at www.epa.gov/owm/cwfinance/pollutioncontrol.htm. 

Information specific to the section 106 tribal guidance is at www.epa.gov/owm/

cwfinance/106tgg07.htm.
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State CWA 319 Programs

Tribes and states are authorized under CWA section 319 to implement approved NPS 

management programs. Generally, 319 funding supports nonregulatory or regulatory 

programs for enforcement, technical assistance, education, training, technology transfer, and 

demonstration projects (per 319(b)(2)(B)). Tribes and states also receive funding under section 

319 to support special projects that result in developing or implementing WBPs and other 

activities that support NPS pollution control, such as stream restoration, public education, 

septic system repair/replacement, rangeland management, and agricultural practices to control 

soil erosion. 

In many states, tribes may apply for the federal pass through CWA section 319 funds disbursed 

by state water resource agencies. States have been especially interested in funding NPS 

pollution projects that include multi-stakeholder groups, such as tribes, agricultural agencies, 

producer groups, and environmental organizations. The match requirements for projects 

in most states are high—40 percent—but in many cases, more funding is available than 

that offered by the national tribal NPS program. Because each state develops its own rules 

regarding CWA section 319 grants, tribes interested in applying for state funding should 

contact that state’s NPS pollution 

program coordinator. A list of state CWA 

319 program administrators and their 

contact information is posted at 

www.epa.gov/nps/state_nps_coord.pdf. 

Meeting the higher state matching 

support requirements can be challenging, 

but there are many examples of how to 

address the need for in-kind and cash 

support. Below are some approaches to 

consider:

 Labor. Volunteers who work on 

a project by attending meetings, 

planning sessions, training 

events, volunteer monitoring 

programs, or contributing field 

work represent value to the 

project that can be considered 

in-kind match. Volunteer time 

can be valued at actual pay rates, 

including fringe and other costs, 

or it can be estimated according 

Barry Tonning
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

to similar pay for similar work. General information on the value of volunteers’ time is 

at www.independentsector.org/programs/research/volunteer_time.html.

 Equipment Usage. The value of having a piece of equipment such as a chain saw, 

tractor, or backhoe can be estimated. Usually, such services are valued on a per-hour 

basis, at a rate that includes the time of the operator of the equipment. For example, 

average hourly rates for an operator and a small, medium, or large tractor can be 

estimated at $30, $40, and $50 or more, respectively. Average rates for a backhoe and 

operator range from $30 to $60 per hour, depending on the location and equipment. 

A worker with a chain saw can be valued at $15 to $30 per hour, depending on the 

worker’s skill and efficiency. 

 Easements. Projects that involve temporary or permanent use of a piece of land 

derive value from the use of that land, and the value can be measured. Valuation of 

an easement that is being used to address polluted runoff or the degradation of a 

waterbody can be done by comparing the cost for acquiring a similar easement for 

commercial or other purposes. For example, the value of an easement along a river or 

stream that has been granted as part of a project to plant riparian buffer vegetation can 

be measured in acres and compared to the cost of renting similar acreage on an annual 

or other basis. 

 Funding. Direct funding or other cash support provided as part of an NPS pollution 

abatement project is always accounted for in actual terms. For example, if a county, 

nonprofit organization, or other entity donates a sum of money or directly pays for 

activities that support a project, that amount can be considered project matching 

support.

Wetlands Program

What do wetlands have to do with NPS pollution control? Each wetland is a part of a 

watershed. The actions upstream can affect a wetland through surface or ground water. For 

example, excessive erosion upstream can fill in a wetland with too much sedimentation. A 

wetland can also reduce the impact of NPS pollution by taking up nutrients or filtering out 

sediments, if it is not overwhelmed. Wetland monitoring and assessment might also give you 

more information on polluted runoff and water quality improvements.

The CWA section 104(b)(3) Wetland Program Development Grants provide eligible 

applicants an opportunity to improve wetland programs by conducting projects that 

promote the coordination and acceleration of research, investigations, experiments, training, 

demonstrations, surveys, and studies relating to the causes, effects, extent, prevention, 

reduction, and elimination of water pollution. States, tribes, local governments, interstate 

associations, intertribal consortia, and national nonprofit, nongovernmental organizations are 

eligible to apply.
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The eligible development activities are based in the Four Core Elements of a State/Tribal 

Wetlands Program found at www.epa.gov/owow/wetlands/initiative/estp.html. They include the 

following:

 Develop and refine a wetland protection program

 Develop a comprehensive monitoring and assessment program

 Improve the effectiveness of compensatory mitigation

 Refine the protection of vulnerable wetlands and aquatic resources

 Complete a wetland restoration demonstration project using a new method, monitor 

the change in wetland condition and water quality, and incorporate lessons learned 

into a new wetland program plan

 Use existing wetland data to figure our priorities for wetlands restoration and 

protection

 Develop an official definition of a wetland

 Train staff to monitor wetland condition and water quality associated with wetlands

For more information on the Wetland Program Development Grants, EPA Regional priorities 

and contacts, and tools for monitoring wetlands, go to the EPA Web site at 

www.epa.gov/wetlands.

Solid Waste

Solid waste is detrimental to reservation water resources and community health. Runoff 

from illegal dump sites can contain hazardous chemicals that can pollute ground water and 

drinking water. This is especially detrimental in tribal communities that depend on wells 

as a main source of freshwater. Illegal dumping on the sides of streams can destroy fish and 

wildlife habitat. Many tribes depend on these habitats to foster wildlife that play important 

environmental, spiritual, and economic roles in community life. Even backyard waste 

burning, which seems as if it would not directly affect water quality, can be damaging to 

tribal water sources. Runoff through burn sites can pick up chemicals and carry them to water 

sources; in addition, outfall from the burning process is released into the air and can be a 

factor in the contamination process. 

Solid waste management program activities that contribute to water quality restoration 

can be funded by CWA section 319 base and competitive grants. Funds may cover a range 

of activities, including dump site cleanup, collection platform construction, solid waste 

management training, post-project water quality monitoring, and outreach activities within 

the local communities. Supplies and vehicle procurement can be funded under the section 

319 program, but federal grant programs generally do not allow funds to be used for program 
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

or facility operation and maintenance. For more information, check with your EPA Regional 

representative on allowable activities. For more general information on tribal solid waste 

management programs, refer to EPA’s Tribal Solid Waste Management page at www.epa.gov/

epawaste/wycd/tribal. Another resource is the Tribal Decision Maker’s Guide at www.epa.gov/

osw/wycd/tribal/tribalguide.htm. The guide provides an overview of solid waste management 

program development and includes information on solid waste planning, regulations, 

collection, disposal, recycling, and education, along with tribal case studies.

Drinking Water and Clean Water State Revolving Fund 

Programs

Clean Water State Revolving Funds 

The Clean Water State Revolving Funds (CWSRF) program provides low-interest loans that can 

spread project costs over a long term repayment period. Repayments are then cycled back into 

the fund and used to pay for additional clean water projects. Although the majority of the fund 

has traditionally been used to finance CWA section 212 projects, such as wastewater treatment 

and collection facilities, financing is also available for NPS projects under the authorities of 

CWA sections 319 and 320. Eligible NPS problems to address include the following:

 Agriculture runoff

 Leaking on-site septic systems and underground storage tanks

 Urban NPS pollution, including stormwater runoff and hazardous waste contamination 

(for more information see www.epa.gov/brownfields)

 Forestry issues

 Hydromodification 

 Estuary protection

 Atmospheric deposition

 Runoff from closed landfills and abandoned mines

 Source water protection

Public or private entities, including tribes, local governments, watershed groups, agricultural 

organizations, farmers, and other eligible borrowers may apply for CWSRF loan funding. Each 

state controls its own CWSRF program and determines project eligibility requirements for 

the loans and sets interest rates. To be eligible under the broad authority of CWA sections 319 

and 320, a project must help implement the state’s NPS management plan (CWA section 319) 

or be consistent with actions and priorities contained in a National Estuary Program 

Comprehensive Conservation Management Plan (CWA section 320). In some instances, 

Congressional appropriations allow some portion of these funds to be awarded as a direct 

grant. For more information, contact CWSRF staff. For a list of CWSRF contacts, go to 

www.epa.gov/owm/cwfinance/cwsrf/cwnims.
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Drinking Water State Revolving Fund: 

Source Water Protection Funding 

Like the CWSRF, the Drinking Water State Revolving Fund (DWSRF) Set-Aside program also 

provides low-interest loans to communities for addressing threats to drinking water sources.

Tribes in watersheds that have drinking water treatment plants might want to consider the 

Source Water Protection Program as a possible source of support for projects that protect 

the quality of surface or ground water. Under the federal Safe Drinking Water Act, water 

utilities with at least 15 service connections or that regularly serve at least 25 or more people 

per day must have a source water assessment, which includes delineation of the source 

water protection area (the portion of a watershed or ground water recharge area that might 

contribute water and possibly pollutants to the water supply), identification of all significant 

potential sources of drinking water contamination within the protection area, a determination 

of the water supply’s susceptibility to contamination from those sources, and making the 

source water assessment results available to the public. Tribes are not required to develop 

source water assessments, but EPA Regions 

with direct implementation responsibility for 

tribal public water systems are completing 

such assessments for tribes in their Regions. 

Tribal publicly and privately owned and 

nonprofit, non-community water systems 

are eligible to receive DWSRF funding from 

the state to address source water protection 

efforts. Tribes can contact their DWSRF 

loan fund managers to check on eligibility 

requirements and other details. For more 

information, see www.epa.gov/safewater/dwsrf.

Source water protection measures that address 

the potential contaminants identified by the 

assessment are largely the responsibility of 

local drinking water utilities. The information 

in the assessment often represents a 

significant source of data regarding possible 

nonpoint sources of pollution in the area, 

and public interest in protecting the drinking 

water supply can provide a very powerful 

incentive for addressing those sources. 

Drinking water utilities often support a 

variety of source water protection structural 

Restoration project field trip, Region 6 Tribal NPS 

Workshop.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

and nonstructural practices, which can include regulatory and nonregulatory land use 

controls, waste site cleanups, acquiring or planting buffer areas, purchasing development 

rights, developing design standards, good housekeeping practices, public education, septic 

system improvement projects, and measures targeted at animal waste, pesticide application, 

and fertilizer use. Nearly all these have been identified as practices that control nonpoint 

sources of water pollution.

General Assistance Program (GAP) Funding

The primary purpose of the GAP is to support the development of a core tribal environmental 

protection program. To achieve this goal, the tribes, with EPA’s assistance, use GAP to do the 

following:

 Identify baseline environmental needs to build capacity to administer an 

environmental program or develop a tribal environmental program that is tailored to 

individual tribal needs

 Establish the administrative, legal, technical, and enforcement capability of tribes to 

develop and implement a tribal environmental program, including the capacity to 

manage EPA-delegated programs

 Foster compliance with federal environmental statutes by developing appropriate tribal 

environmental programs, ordinances, and public education and outreach programs

 Establish a tribal communications capability to work with federal, state, local, tribal 

and other environmental officials 

 Establish the tribal capacity to develop and implement management programs through 

program-specific assistance 

Although GAP funds may be used to develop program capacity, they may not be used for 

program implementation. GAP guidance documents are at www.epa.gov/indian/gap.htm.

Humankind has not woven the web of life.

We are but one thread within it.

Whatever we do to the web, we do to ourselves.

All things are bound together. All things connect.

—Chief Seattle, 1854
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Environmental Quality Incentive Program

The Environmental Quality Incentives Program (EQIP) administered by the U.S. Department 

of Agriculture is a voluntary program that provides financial and technical assistance to 

farmers and ranchers who face threats to soil, water, air, and related natural resources on 

their land. Through EQIP, USDA’s Natural Resource Conservation Service provides financial 

incentives to producers to promote agricultural production and environmental quality as 

compatible goals, optimize environmental benefits, and help farmers and ranchers meet 

federal, state, tribal, and local environmental regulations. Tribal owners of land in agricultural 

production or members who are engaged in livestock or agricultural production on eligible 

land may participate in EQIP. National EQIP priorities include the following:

1. Reductions of NPS pollution, such as nutrients, sediment, pesticides, or excess 

salinity, in impaired watersheds as required by TMDLs, where applicable, as well as 

the reduction of ground water contamination and reduction of point sources such as 

contamination from confined animal feeding operations 

2. Conservation of ground water and surface water resources 

3. Reduction of emissions, such as particulate matter, nitrogen oxides, volatile organic 

compounds, and ozone precursors and depleters, that contribute to air quality 

impairment violations of the National Ambient Air Quality Standards 

4. Reduction in soil erosion and sedimentation from agricultural land 

5. Promotion of at-risk species habitat conservation 

For more information on EQIP and applying for funds, see 

www.nrcs.usda.gov/PROGRAMS/EQIP. 

Other Programs

In addition to EQIP funding, many tribes partner with the U.S. Fish and Wildlife Service, 

Bureau of Land Management, U.S. Forest Service and other federal and state agencies in 

developing watershed protection programs, technical assistance and education projects, 

cost-share program priorities, and other activities. Those partnerships are extremely helpful 

to tribes, which can benefit directly from technical and financial support, and to the partner 

groups, which often seek tribal input in addressing polluted runoff issues in watersheds where 

tribal lands might be. Pooling resources usually involves coordination of staff activities under 

a formal or, in most cases, an informal plan. That can include efforts to conduct water quality 

monitoring activities, sharing data to produce a watershed assessment, developing technical 

assistance programs for farmers or ranchers, promoting cost-share signups for livestockexclusion stream fencing, septic system inspection/repair projects, stabilizing unpaved roads, 

restoring stream corridors, removing invasive species, and other efforts. In general, such 

funding sources seek to support projects that are clearly explained, have a measurable water 

quality or public health benefit, draw support from several programs or partners, and are 

sponsored by organizations with a successful track record.
Part 1II: Additional Resources for Tribes | III-1

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act PART III Additional Resources for Tribes

List of Contacts

For current contacts for EPA tribal NPS coordinators and state NPS coordinators, as well as 

NPS coordinators from each state and territory, see www.epa.gov/nps/contacts.html. That site is 

updated often and provides links to state NPS programs. For general EPA tribal contacts and 

Regional tribal program information, see www.epa.gov/tribal/contactinfo.

General EPA tribal nonpoint source contact information

Headquarters

Tribal Coordinator, USEPA

1200 Pennsylvania Avenue, NW (MC 4503T)

Washington, DC 20460

202-566-1155

www.epa.gov/owow/nps/tribal/index.html

Region 1 (CT, ME, MA, NH, RI, VT)

Tribal Coordinator

USEPA - Region 1

5 Post Office Square, Suite 100 (MC: OEP06-1)

Boston, MA 02109-3912

617-918-1840

www.epa.gov/region1/govt/tribes/index.html

Region 6 (AR, LA, NM, OK, TX)

Tribal Coordinator

USEPA - Region 6

1445 Ross Avenue, Suite 1200 (MC: 6WQ-AT)

Dallas, TX 75202

214-665-6684

www.epa.gov/region6/water/at/tribal/index.htm

Region 2 (NJ, NY, PR, VI)

Tribal Coordinator

USEPA - Region 2

290 Broadway Avenue, 24th floor (MC: DEPP: WPB)

New York, NY 10007

212-637-3788

www.epa.gov/region02/nations/intro.htm

Region 7 (IA, KS, MO, NE)

Tribal Coordinator

USEPA - Region 7

901 North 5th Street

Kansas City, KS 66101

913-551-7003

Toll-free: 1-800-223-0425

www.epa.gov/region07/tribal/index.htm

Region 3 (DE, DC, MD, PA, VA, WV)

Nonpoint Source Coordinator 

(No federally recognized tribes have been registered in Region 3.)

USEPA - Region 3

1650 Arch Street

Philadelphia, PA 19103

215-814-5753

www.epa.gov/reg3wapd/nps/index.htm

Region 8 (CO, MT, ND, SD, UT, WY)

Tribal Coordinator

USEPA - Region 8

1595 Wynkoop Street (MC EPR-EP)

Denver, CO 80202

303-312-6895

www.epa.gov/region8/tribes/contacts.html
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General EPA tribal nonpoint source contact information

Region 4 (AL, FL, GA, KY, MS, NC, SC, TN)

Tribal Coordinator

USEPA - Region 4

Atlanta Federal Center

61 Forsyth Street, SW

Atlanta, GA 30303

404-562-9451

www.epa.gov/region4/indian/contacts.htm

Region 9 (AZ, CA, HI, NV, AS, GU)

Tribal Coordinator

USEPA - Region 9

75 Hawthorne Street (MC WTR-10)

San Francisco, CA 94105

415-972-3402

www.epa.gov/region09/water/tribal/

tribal-cwa.html#nps

Region 5 (IL, IN, MI, MN, OH, WI)

Tribal Coordinator

USEPA - Region 5

77 West Jackson Boulevard (MC WS-15J)

Chicago, IL 60604

312-353-2000

www.epa.gov/region5/water/wshednps/topic_nps.htm

Region 10 (AK, ID, OR, WA)

Tribal Coordinator

USEPA - Region 10

1200 Sixth Avenue, Suite 900 (MC OWW-137)

Seattle, WA 98101

206-553-1050

yosemite.epa.gov/R10/ecocomm.nsf/

Watershed+Collaboration/

State+Tribal+NPS#Tribes%20Section

(continued)
Part 1II: Additional Resources for Tribes | III-3

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EPA Regional Offices
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Online Tools 

EPA offers a host of online tools to help with the process of conducting a watershed 

assessment. To develop the scope of a watershed planning effort or waterbody restoration 

project, the watershed must be characterized. The characterization process allows for 

(1) defining of issues of concern, the key pollutants, and the sources of pollution; (2) assessing 

watershed geographic conditions, economic activities, and discharges that could affect 

water pollution; and (3) selecting target restoration efforts. The following Web sites provide 

watershed characterization information.

Surf Your Watershed

www.epa.gov/surf 

Watersheds and watershed resources can be located through an interactive map or through 

drop-down lists. Eight-digit Hydrologic Unit Codes (HUCs) can also be found through this 

resource.

Assessment TMDL Tracking and Implementation System (ATTAINS)

www.epa.gov/waters/ir 

ATTAIN’s tables and charts summarize state-reported data for the nation as a whole, 

individual states, individual waters, and the 10 EPA Regions. It provides the full story of 

assessed waters that are impaired, are being restored, or have been restored.

EPA’s Watershed Assessment and Tracking Environmental Results 

(WATERS)

www.epa.gov/water 

The EPA Office of Water manages numerous programs that collect and store water qualityrelated data in separate databases. WATERS is an integrated information system that 

generates reports on the nation’s surface waters from multiple, independent databases (e.g., 

Water Quality Standards Database, STORET, ATTAINS, Permit Compliance System, Clean 

Watersheds Needs Survey). 

Storage and Retrieval (STORET)

www.epa.gov/storet

STORET is EPA’s main repository of water quality monitoring data, including chemical, 

biological, and physical data. It contains water quality information from a variety of 

organizations across the country, from small volunteer watershed groups to state and federal 

environmental agencies. Data stored in STORET are accessible to anyone with a Web browser 

and Internet access, and query results can be e-mailed to the user in an Excel format. 
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Enforcement and Compliance History Online (ECHO)

www.epa-echo.gov/echo

ECHO focuses on facility compliance and EPA/state enforcement of environmental 

regulations. Roughly 800,000 regulated facilities under the following environmental statutes 

and regulations are included in ECHO: Clean Air Act Stationary Source Program, Clean 

Water Act, National Pollutant Discharge Elimination System, and Resource Conservation and 

Recovery Act. Through ECHO, site visitors can find inspection, violation, enforcement action, 

informal enforcement action, and penalty information about facilities for the past three years.

For introductory instructional materials on how to use the above EPA Internet tools, visit 

www.epa.gov/watershed/wacademy/epatools and download the course materials for Key EPA 

Internet Tools for Watershed Management.

GIS Tools

MyEnvironment (Formerly, Window to My Environment)

www.epa.gov/myenvironment

MyEnvironment is designed to improve access to useful community-based environmental 

information. MyEnvironment represents a concerted effort to develop a geographic portal

for integrating that environmental information by local geography to help answer common 

questions, examine critical problems, and discover potential solutions for environmental 

protection and human health issues. 

MyEnvironment’s features include

 Interactive Map: Shows the location of regulated facilities, monitoring sites, 

waterbodies, population density, perspective topographic views and more with 

hotlinks to state/federal information about these items of interest. 

 Your Window: Provides selected geographic statistics about the area of interest, 

including estimated population, county/urban area designations, local watersheds/

waterbodies, and so forth. 

 Your Environment: Links to information from federal, state, and local partners on 

environmental issues like air and water quality, watershed health, Superfund sites, 

fish advisories, impaired waters, as well as local services working to protect the 

environment in your area. 
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Tribal Windows to the Environment

http://oaspub.epa.gov/tims/twe.html

The American Indian Environmental Office (AIEO) coordinates and integrates all the tribal 

programs at EPA. To track the progress that these programs are making toward protecting the 

environment and public health in Indian Country, AIEO has linked the various regulatory and 

environmental monitoring databases of EPA into a single window to the environment for tribes. 

The AIEO windows are essentially the same as the popular “MyEnvironment.”

EnviroMapper for Water 

www.epa.gov/waters/enviromapper 

EnviroMapper for Water is a Web-based geographic information system (GIS) application 

that dynamically displays water quality and other environmental information about bodies 

of water in the United States. This interactive tool allows you to create customized maps that 

portray surface waters along with a collection of water quality-related data from the national 

level down to community level. Enviromapper for Water provides the ability to: 

 Geographically display a variety of EPA water program data (e.g., water quality 

standards, ATTAINS, and STORET)

 Pan, zoom, label, and print maps 

 Link to water program Web reports after identifying specific features of interest 

 Generate specific water quality-related reports based on an area of interest 

Watershed Plan Builder

www.epa.gov/owow/watershedplanning 

The Watershed Plan Builder is designed for users who are just beginning to develop a 

watershed plan, are in the process of developing a watershed plan, or are updating an existing 

plan. The Watershed Plan Builder provides a step-by-step process to begin developing a 

watershed plan. Through a series of questions related to eight categories such as location, 

pollutants, and stakeholders, the Plan Builder collects information about your specific 

watershed area and produces a customized watershed outline. This outline can be used as 

a roadmap for the watershed planning process to create a comprehensive watershed plan. 

Specific instructions on how to develop a watershed plan can be found in the section devoted 

to the watershed planning process.

Watershed Central and the Watershed Wiki 

www.epa.gov/watershedcentral

EPA has a new Web site called Watershed Central to help watershed organizations and 

others find key information they need to implement watershed management projects. The 

primary purpose of the Watershed Central Web site is to make it easy for organizations 

to find the information that they need to help protect and restore their water resources. 
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Watershed Central helps users find environmental data, watershed models, nearby local 

organizations, guidance documents, and other information depending on the task at hand. It 

also contains links to watershed technical resources, funding sources, mapping applications, 

and information specific to named watersheds. The site includes a Watershed Central Wiki 

for collaboration and information sharing. EPA encourages watershed practitioners to use the 

new Watershed Central Wiki to share tools, scientific findings, expertise, and local approaches 

to watershed management. Watershed Central not only links to EPA Web resources, but also 

links to other valuable funding, guidance, and tools on the Web sites of state, tribal, and 

federal partners, universities, and nonprofit organizations. 

Tools of the Trade 

www.epa.gov/watershed/wacademy/epatools

Tools of the Trade are publicly available, GIS-based tools to help with effective watershed 

management. 

Additional Internet Resources

EPA 

Information

Tribal Nonpoint Source Information

www.epa.gov/nps/tribal

Section 319 Information

www.epa.gov/nps/cwact.html

Tribal Portal Federal Funding Eligibility

www.epa.gov/tribalportal/laws/tas.htm

Treatment in the Same Manner as a State Information

www.epa.gov/tribalportal/laws/tas.htm

Tribal Portal 

www.epa.gov/tribalportal 

American Indian Tribal Portal: Where You Live

www.epa.gov/tribalportal/whereyoulive 
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Clean Water Act Tribal Training

www.epa.gov/water/tribaltraining

Nonpoint Source Success Story Web Site

www.epa.gov/nps/Success319

This Web Site features stories about primarily nonpoint source-impaired waterbodies where 

restoration efforts have led to documented water quality improvements.

Healthy Watersheds Initiative

www.epa.gov/healthywatersheds

The objective of the federal CWA is to “restore and maintain the chemical, physical, and 

biological integrity of the nation’s waters.” While other EPA programs focus on restoring 

impaired waters, the Healthy Watersheds Initiative augments the watershed approach with 

proactive, holistic aquatic ecosystem conservation and protection. The Healthy Watersheds 

Initiative includes both assessment and management approaches that encourage tribes, states, 

local governments, watershed organizations, and others to take a strategic, systems approach 

to conserve healthy components of watersheds and, therefore, avoid additional water quality 

impairments in the future.

Green Infrastructure

www.epa.gov/greeninfrastructure

Green infrastructure is an approach to wet weather management that is cost-effective, 

sustainable, and environmentally friendly. Green Infrastructure management approaches and 

technologies infiltrate, evapotranspire, capture, and reuse stormwater to maintain or restore 

natural hydrologies.

EPA Grant Finding Resources

Clean Water Indian Set-Aside Program 

www.epa.gov/owm/mab/indian/cwisa.htm 

Coastal Program

www.epa.gov/owow/estuaries

Drinking Water State Revolving Fund Indian Set-Aside Program

www.epa.gov/safewater/dwsrf/allotments/tribes/index.html

Federal Funding Database

www.epa.gov/epawaste/wycd/tribal/finance.htm
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Grant Writing Resources

www.epa.gov/epawaste/wycd/tribal/pdftxt/grant.pdf

Guide to Federal Grant Resources for Community Organizations, 

Tribal Organizations, and Tribal Governments 

www.epa.gov/epahome/grants.htm

Tribal Portal Grants and Funding

www.epa.gov/tribal/grantsandfunding 

Tribal Resource Directory for Drinking Water and Wastewater 

Treatment

www.epa.gov/owm/mab/indian/tribal-resource-directory.htm

PDF version: www.epa.gov/owm/mab/indian/pdfs/tribal-complete.pdf

Watershed Funding

www.epa.gov/owow/funding.html

Wetlands Protection Programs

www.epa.gov/owow/wetlands

Federal Grant Finding Programs

Federal Grants Database 

www.grants.gov

U.S. Bureau of Reclamation

www.usbr.gov

U.S. Department of Agriculture Farm Service Agency Programs 

www.fsa.usda.gov/pas/default.asp

U.S. Department of Agriculture Natural Resource Conservation Service 

Programs 

www.nrcs.usda.gov/programs

U.S. Department of Agriculture Watershed Program 

www.nrcs.usda.gov/programs/watershed
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U.S. Department of Health and Human Services Indian Health Services 

Wastewater Program

www.ihs.gov/nonmedicalprograms/dsfc 

U.S. Department of the Interior Abandoned Mines Program 

www.osmre.gov/aml/aml.shtm

U.S. Fish and Wildlife Partners for Fish and Wildlife Program 

www.fws.gov/partners

Nonfederal Grant Finding Programs 

Rural Community Assistance Partners

www.rcap.org

The Environmental Finance Center 

www.efc.umd.edu/host.html

Other 

Informational

Catalogue of Federal Domestic Assistance

www.cfda.gov

Conservation Technology Information Center

www.conservationinformation.org

Federal Register

www.gpoaccess.gov/fr

Indian Health Service

www.dsfc.ihs.gov 

Climate Change Information

EPA’s Climate Change Web site

www.epa.gov/climatechange

EPA’s Office of Water Climate Change Web site

www.epa.gov/water/climatechange
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

EPA Watershed Academy—Climate Change and Water 

Training Module

This module was designed to educate water program managers, as well as the general public, 

on the expected effects of climate change on water resources and water programs 

www.epa.gov/watertrain/climate_water/

ENERGY STAR

www.energystar.gov

WaterSense

www.epa.gov/watersense

Low Impact Development

www.epa.gov/nps/lid

Intergovernmental Panel on Climate Change (IPCC)

www.ipcc.ch

U.S. Climate Change Science Program 

www.globalchange.gov

National Oceanic and Atmospheric Administration’s 

Climate Program Office

The Regional Integrated Sciences and Assessments provides links to university networks 

developing information at the regional level. 

www.climate.noaa.gov/index.jsp?pg=./cpo_pa/cpo_pa_index.jsp&pa=risa

A Few Web Links to Notable Documents on Climate Change 

and Ecosystems

Preliminary Review of Adaptation Options for Climate-Sensitive Ecosystems and Resources, June 2008. 

www.globalchange.gov/publications/reports/scientific-assessments/saps/sap4-4

This report from the U.S. Climate Change Science Program focuses on adaptation options for 

climate-sensitive ecosystems and resources on federally owned and managed lands.

Climate Ready Estuaries: Synthesis of Adaptation Options for Coastal Areas, 2009.

www.epa.gov/cre/downloads/CRE_Synthesis_1.09.pdf

This guide provides a brief introduction to key physical effects of climate change on estuaries 

and a review of on-the-ground adaptation options available to coastal managers to reduce their 

systems’ vulnerability to climate change impacts.
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Synthesis Report from the International Scientific Congress, Climate Change: Global Risks, Challenges 

& Decisions, March 2009.

http://climatecongress.ku.dk

The Climate Congress was organized to update the state of scientific knowledge regarding 

climate change since the 2007 IPCC Report, in preparation for the United Nations’ Conference 

on Climate Change to be held in Denmark in December 2009.

Intergovernmental Panel on Climate Change Fourth Assessment Report: Climate Change 2007.

www.ipcc.ch/publications_and_data/publications_and_data_reports.htm

Of particular note for ecosystems, see IPCC Working Group II, Climate Change Impacts, 

Adaptation, and Vulnerability.

Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and 

Thomas C. Peterson (eds.). Cambridge University Press, 2009.

www.globalchange.gov/usimpacts

This report summarizes the science of climate change and the impacts of climate change 

on the United States, now and in the future. It is largely based on results of the U.S. Global 

Change Research Program, and integrates those results with related research from around the 

world. This report discusses climate-related impacts for various societal and environmental 

sectors and regions across the nation. It is an authoritative scientific report written in plain 

language, with the goal of better informing public and private decision making at all levels.

Best Management Practices Implementation Appendix

www.waterquality.utah.gov/TMDL/Virgin_River_Watershed_Implementation_Appendix.pdf

This appendix is a manual designed to assist landowners, managers, and technicians in 

adopting effective and appropriate practices to reduce NPS pollutants entering streams and 

watercourses. Practices are defined as actions taken by a landowner or manager to reduce 

pollutant loads from nonpoint sources. In general, practices described in this manual are 

meant to be implemented in areas immediately adjacent to the stream channel or waterbody. 

However, many of the treatments can be used effectively in uplands and other areas. This 

document is a great resource to view photos of various BMPs, and it includes additional 

information on BMP purpose, pollutants addressed, load reduction potential, and expected 

maintenance.

Another widely used source that is applicable to agricultural areas is the USDA-NRCS Field 

Office Technical Guide: www.nrcs.usda.gov/technical/efotg.
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Acronyms and Abbreviations

oC degrees Celsius 

oF degrees Fahrenheit

μg/L micrograms per liter

ANSI/ASQC American National Standards Institute

ASQC American Society for Quality Control

ATTAINS Assessment TMDL Tracking and Implementation System

BIA Bureau of Indian Affairs

BMP best management practice

CFR Code of Federal Regulations

CFS cubic feet per second

CRP Conservation Reserve Program

CWA Clean Water Act

CWSRF Clean Water State Revolving Fund

DNR Department of Natural Resources

DO dissolved oxygen

DWSRF Drinking Water State Revolving Fund

E. coli Escherichia coli

e.g. for example

ECBI Eastern Cherokee Band of Indians

ECHO Enforcement and Compliance History Online

EPA U.S. Environmental Protection Agency

EQIP Environmental Quality Incentives Program

FCB fecal coliform bacteria

FTE full-time equivalent (staff)

GAP General Assistance Program

GIS geographic information system

HUC Hydrologic Unit Code

i.e. in other words; that is

MDNR Minnesota Department of Natural Resources

mg/L milligrams per liter
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MNDOT Minnesota Department of Transportation

MPCA Minnesota Pollution Control Agency

N nitrogen

NA not applicable

NPDES National Pollutant Discharge Elimination System

NPS nonpoint source (pollution)

NRCS Natural Resources Conservation Service

NTU nephelometeric turbidity unit 

O&M operation and maintenance

P phosphorus

pH co-logarithm of the activity of dissolved hydrogen ions 

PPG Performance Partnership Grant

QA quality assurance

QA/QC quality assurance/quality control

QAPP quality assurance project plan

RCBLSC Red Cliff Band of Lake Superior Chippewa

RFP request for proposal

RLBCI Red Lake Band of Chippewa Indians

RWQCB Regional Water Quality Control Board

SI Stressor Identification

STEPL Spreadsheet Tool for Estimating Pollutant Load

STORET STOrage and RETrieval System

su standard units

SWAP Source Water Assessment and Protection

SWCD Soil and Water Conservation District

SYBCI Santa Ynez Band of Chumash Indians

TAS Treatment in the same manner as a state

TMDL total maximum daily load

TSI Trophic Status Index

TSS total suspended solids

USACE U.S. Army Corps of Engineers
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

USDA U.S. Department of Agriculture

USFW U.S. Fish and Wildlife (Service)

USGS U.S. Geological Survey

VSAP Visual Stream Assessment Protocol

WATERS Watershed Assessment and Tracking Environmental Results

WBP watershed-based plan

WisCAP Wisconsin Community Action Program

WPCP Water Pollution Control Program

WQS water quality standards/water quality specialist
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Glossary

Antidegradation – A federal water quality requirement prohibiting deterioration where 

pollution levels are above the legal limit.

Base funding – $30,000 or $50,000 depending on size of reservation.

Beneficial uses – Designations made by states or tribes regarding how a particular waterbody 

is expected to be used and for what it is to be managed. Examples: cold water fishery, 

drinking, swimming.

Best management practices (BMPs) – Practices, measures, or actions that are commonly 

recommended to prevent, reduce, or mitigate pollution from nonpoint sources.

Competitive funding – Funding allocated to projects as established through a national 

request for proposals. 

Cultural issues – Knowledge, belief, behavior, or set of shared attitudes, values, goals, and 

practices of a specific group. For Native American cultures, some attributes to consider: 

respect for the natural world, spirituality, elders and children, clans and kinship, leadership 

and decision-making, history, governance structures, protocols, and laws. 

CWA section 104(b)(3) – A granting authority under which awards are made to state water 

pollution control agencies, interstate agencies, other public or nonprofit private agencies, 

institutions, organizations, and individuals, for the purpose of research, investigations, 

experiments, training, demonstrations, surveys, and studies relating to the causes, effects, 

extent, prevention, reduction, and elimination of pollution.

CWA section 106 – A granting authority under which awards are made to states, tribes, and 

interstate agencies to assist them in administering programs for the prevention, reduction, 

and elimination of pollution, including enforcement. May fund a wide range of water quality 

activities, including water quality planning and assessments, development of water quality 

standards, ambient monitoring, development of total maximum daily loads, issuing permits, 

ground water and wetland protection, and NPS control activities (including nonpoint source 

assessment and management plans).

CWA section 303(d) – Section under which states, territories, and authorized tribes are 

required to develop lists of impaired waters that do not meet water quality standards or use 

designations that have been set for them. The section requires establishing priority rankings 

for waters on the lists. 
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

CWA section 305(b) – Requires states and territories to report every two years on the water 

quality and use designations of all navigable waters, surface waters, and ground water and 

impacts from both point and nonpoint sources of pollution. (Tribes are not required to submit 

305(b) reports.)

CWA section 401 – Water quality certification needed to show that an applicant for a federal 

license or permit to conduct activities that could result in any discharge into the navigable 

waters will provide to the licensing or permitting agency a certification from the state/tribe or 

interstate agency having jurisdiction over those waters that any such discharge will comply 

with the applicable water quality regulations and effluent limits.

CWA section 404 – Establishes permits for disposal of dredged or fill material at specified 

disposal sites into navigable waters, including notice and opportunity for public hearings.

CWA section 518 – Establishes that Indian tribes will be treated as states for the purposes of 

title II (grants for treatment works) and sections 104, 106, 303, 305, 308, 309, 314, 319, 401, 

402, and 404.

E. coli (Escherichia coli) – A gram negative bacterium that is commonly found in the lower 

intestine of warm-blooded animals.

Fee lands – Land parcels that are owned by nontribal individuals or entities and are within 

the reservation boundaries.

Green space – Open spaces that serve as natural assets for the community, such as parkland 

or naturalized areas necessary for the protection of the waterbody.

Hydrologic Unit Code (HUC) – A 2- to 12- digit number assigned by the U.S. Geological 

Survey as part of its surface waterbody classification system.

Impaired waters – Those waters that do not meet water quality standards for one or more 

pollutants and for which the use designation therefore cannot be fulfilled.

Impairments – The kinds of pollutants that creates a condition, by means of amount or type, 

where water quality standards are exceeded. 

Indicator – Entity, process, or community whose characteristics show the presence of specific 

environmental conditions.

Inputs – When referring to pollution sources, identifying where they come from.

Intertribal consortium – Consortium to promote cooperative work among tribes; partnership 

between two or more tribes that is authorized by the governing bodies of those tribes.
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Karst – A geologic formation of irregular limestone deposits with sinks, underground streams, 

and caverns.

Landscape scale – Traits, patterns, and structure of a specific geographic area, including its 

biological composition, its physical environment, and its anthropogenic or social patterns. A 

geophysical space where interacting ecosystems are grouped and have similar attributes.

Legislative conditions – The requirements as found in the authorizing legislation for a 

program.

Milestones – Key dates when certain measurable outcomes are expected.

Mitigation – Measures that are taken to reduce adverse effects on the environment and can 

provide a method of compensation for unavoidable impacts.

Narrative criteria – Statements that describe the desired water quality goal, such as waters 

being free from pollutants or substances that can harm people and fish; an approach used for 

pollutants for which numeric criteria are difficult to establish because of inherent subjectivity. 

Nonpoint source pollution – Pollution not discharged from a point source. This generally 

consists of pollution from diffuse sources (i.e., without a single point of origin or not 

introduced into a receiving stream from a specific outlet). The pollutants are generally carried 

off the land as a result of precipitation events (rainfall, snowmelt).

Nonprofit/nongovernmental organizations – Sometimes seen as NPO or NGO. A group 

organized for purposes other than generating profit and in which no part of the organization’s 

income is distributed to its members, directors, or officers. This is established at the time 

of formation, and only approved activities under this designation are allowed; no official 

governmental representatives are governing members.

Numeric criteria – A number standard for limiting a particular pollutant that protects a 

specific use designation; can be load- or concentration-based. 

Outcomes – The conditions that result from an action.

Outputs – The results of activities undertaken to achieve the outcomes.

Partnership – A cooperative relationship between people or groups that agree to share 

responsibility for achieving some specific goal.

Performance goals – Numerical or statistically measured achievements against a target.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

Permitting/Enforcement authority – Any entity at the local, state, or national level that has 

the capability to execute a permit or take an enforcement action.

Point source – A stationary location or fixed facility from which pollutants are discharged 

through a conveyance system; any single identifiable source of pollution, such as a pipe, ditch, 

ship, ore pit, or factory smokestack.

Public participation – A principle or practice that seeks out and facilitates the involvement 

of those potentially affected by or interested in a decision. The full range of actions employed 

to engage people in current or proposed activities. Implies that the public’s contribution will 

influence the decision-making process.

Remediation – Cleanup, restoration, or other methods used to ensure that the location will be 

able to fully function from an ecological and human health perspective.

Restoration/rehabilitation – Measures taken to return a site to a previous condition.

Riparian areas – Areas adjacent to rivers and streams with a differing density, diversity, and 

productivity of plant and animal species relative to nearby uplands.

Sampling design – The method employed to collect adequate and appropriate data to support 

accurate analysis. See www.epa.gov/quality/qksampl.html.

Schedule – Weekly, monthly, seasonal, or quarterly array of activities or actions needed to 

carry out a work plan.

Section 319 base funding – The funding that is provided by CWA section 319 as the core 

funding to support the 319 program with the broadest ability to accomplish program goals 

and activities.

Spatial context (units) – The areal extent or scale at which analysis is given or information 

collected. A description of the nature of the physical setting in which activities occur.

Stakeholder – Any organization, governmental entity, or individual that has a stake in or 

could be affected by a given approach to environmental regulation, pollution prevention, 

energy conservation, and the like.

Stressor – Physical, chemical, or biological entity that can induce adverse effects on 

ecosystems or human health.

Subbasins – Usually, catchments that are smaller than a 12-digit Hydrologic Unit Code and 

are determined to be a more useful planning and implementation unit for water resources 

protection or can be contained within the jurisdiction of the tribe.
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Trust lands – Lands held in trust by the U.S. government for a tribe.

Water quality criteria – Levels of water quality expected to render a body of water suitable 

for its designated use. Criteria are based on specific levels of pollutants that would make 

the water harmful if used for drinking, swimming, farming, fish production, or industrial 

processes.

Water quality goal – A long-term perspective on the evaluation of water resource conditions 

that describes an eventual desired future condition and implies actions toward meeting a 

targeted improvement in or maintenance of current high quality of the waters.

Water quality standards – State/tribe-adopted and EPA-approved ambient standards for 

waterbodies. There are four parts to an individual water quality standard: designated use, 

numeric criteria, narrative criteria, and antidegradation provisions. The standards prescribe 

the use of the waterbody and establish the water quality criteria that must be met to protect 

designated uses.

Waterbody – Any surface water resource.

Watershed – The land area that drains into a stream, wetland, lake, or coastal waterbody. The 

watershed for a major river could encompass a number of smaller watersheds that ultimately 

combine at a common point.

Work plan (commitments, tasks, components) – Usually an annual detailed discussion of 

the goals and objectives to be addressed through specific actions or activities to implement a 

program. Components are the areas of focus; commitments are the activities that support the 

accomplishment of the components; and tasks are the specific actions needed to ensure the 

commitments are completed on time.
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Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

References

ANSI/ASQ (American National Standards Institute/American Society for Quality). 1994. 

Specifications and Guidelines for Quality Systems for Environmental Data Collection and 

Environmental Technology Programs. ANSI/ASQ E4-1994. American Society for Quality, 

Milwaukee, WI.

Burkett, V., J.O. Codignotto, D.L. Forbes, N. Mimura, R.J. Beamish, and V. Ittekkot. 2001. 

Coastal Zones and Marine Ecosystems. In Climate Change 2001: Impacts, Adaptation 

and Vulnerability. Contribution of Working Group II to the Third Assessment Report of the 

Intergovernmental Panel on Climate Change. [McCarthy, J.J., O.F. Canziani, N.A. Leary, 

D.J. Dokken, and K.S. White (eds.)]. Cambridge University Press, Cambridge, U.K. and 

New York, NY. 

<www.grida.no/climate/ipcc_tar/wg2/index.htm>. Accessed August 31, 2009. 

Christ, M., and M. Pavlick. 2006. Watershed Based Plan for the Decker Creek Watershed, Preston 

and Monongalia Counties, West Virginia. Friends of Deckers Creek, Dellslow, WV.

COEICC NRC (Committee on Ecological Impacts of Climate Change, National Research 

Council). 2008. Ecological Impacts of Climate Change. The National Academies Press, 

Washington, DC. 

CTGR (Confederated Tribes of Grand Ronde). 2008a. Confederated Tribes of Grand Ronde Nonpoint 

Source Assessment Report. Confederated Tribes of Grand Ronde, Grande Ronde, OR.

CTGR (Confederated Tribes of Grand Ronde). 2008b. Confederated Tribes of Grand Ronde Nonpoint 

Source Management Plan. Confederated Tribes of Grand Ronde, Grande Ronde, OR.

IPCC (Intergovernmental Panel on Climate Change). 2007a. Climate Change 2007: Impacts, 

Adaptation and Vulnerability. Contribution of Working Group II to the Fourth Assessment 

Report of the Intergovernmental Panel on Climate Change [Parry, M.L., O.F. Canziani, J.P. 

Palutikof, P.J. van der Linden, and C.E. Hanson (eds.)]. Cambridge University Press, 

Cambridge, U.K. 

<www.ipcc.ch/publications_and_data/publications_ipcc_fourth_assessment_report_

wg2_report_impacts_adaptation_and_vulnerability.htm>. Accessed August 31, 2009. 

IPCC (Intergovernmental Panel on Climate Change). 2007b. Climate Change 2007: Synthesis 

Report. Contribution of Working Groups I, II and III to the Fourth Assessment Report of the 

Intergovernmental Panel on Climate Change [Pachauri, R.K, and A. Reisinger (eds.)]. IPCC, 

Geneva, Switzerland.

<www.ipcc.ch/publications_and_data/publications_ipcc_fourth_assessment_report_

synthesis_report.htm>. Accessed August 31, 2009. 
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IPCC (Intergovernmental Panel on Climate Change). 2008. Climate Change and Water. IPCC 

Technical Paper VI. 

<www.ipcc.ch/pdf/technical-papers/climate-change-water-en.pdf>. Accessed August 31, 

2009. 

JST (Jamestown S’Klallam Tribe). 2007. Protecting and Restoring the Waters of the Dungeness: 

A Watershed-Based Plan Prepared in Compliance with Section 319 of the Clean Water Act. 

Jamestown S’Klallam Tribe, Sequim, WA.

KT (Karuk Tribe), Department of Natural Resources. Eco-Cultural Resources Management Plan. 

Karuk Tribe, Happy Camp, CA.

PTOI (Puyallup Tribe of Indians). 2008. Puyallup Tribe of Indians Nonpoint Management Plan. 

Puyallup Tribe of Indians, Puyallup, WA

RCBLSC (Red Cliff Band of Lake Superior Chippewa). 2008a. Tribal Nonpoint Source Assessment 

Report. Red Cliff Band of Lake Superior Chippewa, Environmental Department, Red 

Cliff, WI. 

RCBLSC (Red Cliff Band of Lake Superior Chippewa). 2008b. Tribal Nonpoint Source 

Management Plan. Red Cliff Band of Lake Superior Chippewa, Environmental 

Department, Red Cliff, WI.

RLBCI (Red Lake Band of Lake Superior Chippewa). 2008a. Nonpoint Source Assessment of 

Streams, Lakes and Wetlands. Red Lake Band of Chippewa Indians, Red Lake, MN.

RLBCI (Red Lake Band of Lake Superior Chippewa). 2008b. Nonpoint Source Management Plan. 

Red Lake Band of Chippewa Indians, Red Lake, MN.

SBLI (Soboba Band of Luiseño Indians). 2007. Nonpoint Source Assessment Report and 

Management Program. Soboba Band of Luiseño Indians, San Jacinto CA.

SMSC (Shakopee Mdewakanton Sioux Community). 2008. Nonpoint Source Assessment Report. 

Shakopee Mdewakanton Sioux Community, Prior Lake, MN.

ST (Suquamish Tribe). 2008. Nonpoint Source Assessment and Management Program. Suquamish 

Tribe, Suquamish, WA.

STOI (Stillaguamish Tribe of Indians). 2008. Stillaguamish Tribe of Indians Nonpoint Source 

Management Plan. Stillaguamish Tribe of Indians, Arlington, WA.

SYBCI (Santa Ynez Band of Chumash Indians). 2006a. Non-point Source Assessment Report. 

Santa Ynez Band of Chumash Indians, Santa Ynez, CA. 
Part 1II: Additional Resources for Tribes | III-23

Handbook for Developing and Managing Tribal Nonpoint Source Pollution Programs Under Section 319 of the Clean Water Act

SYBCI (Santa Ynez Band of Chumash Indians). 2006b. Non-point Source Management Plan. 

Santa Ynez Band of Chumash Indians, Santa Ynez, CA.

UMUT (Ute Mountain Ute Tribe). 2005a. Nonpoint Source Assessment for the Ute Mountain Ute 

Reservation of Colorado, New Mexico and Utah. 2005 Revision. Ute Mountain Ute Tribe, 

Towaoc, CO.

UMUT (Ute Mountain Ute Tribe). 2005b. Ute Mountain Ute Tribe Nonpoint Source Management 

Program Plan for the Ute Mountain Ute Reservation of Colorado, New Mexico and Utah. 

2005 Revision. Ute Mountain Ute Tribe, Towaoc, CO.