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The Federal Clean Water Act Section 319(h) provides funding for various types of practices that work to reduce nonpoint source water pollution. Section 319 grant projects in Indiana that are implementing best management practices (BMPs) are required by Indiana’s Nonpoint Source Program to develop a cost-share program. Details of the cost-share program must be submitted to the Indiana Department of Environmental Management (IDEM) Project Manager prior to implementing the program, including information requested in the Section 319 Cost-Share Program Development Guidelines. The approved cost-share program allows Section 319 funds to be used to pay a portion of the cost of implementing BMPs that reduce sediment, nutrients and other pollutants from nonpoint sources in the watershed.
This guidance document provides general program information, suggested BMPs, funding restrictions, definitions of basic terminology, and frequently asked questions related to the distribution of cost-share and demonstration funds for BMPs implemented on agricultural land. Agricultural land is defined for these purposes as land that is currently in production such as cropland, pastureland, rangeland, native pastureland, other land used to support livestock production, and tree farms. This is a living document, and as such, the policies and guidance within are subject to change. Please make sure that this is the most current version of the document (see date below). Any questions may be directed to an IDEM Section 319 Project Manager.
Section 319 funds may be used to implement BMPs for the purpose of implementing a watershed management plan (WMP) that meets IDEM’s Watershed Management Plan Checklist or to demonstrate new technology. BMPs should be selected based on the goals of the WMP, and must be implemented in critical areas as described in the Plan. For cost-share practices, Section 319 funds may be used to pay up to a maximum of 75% of the total BMP cost. At least 25% of the cost must be provided by the landowner or other non-federal source as match. For demonstration practices Section 319 funds may be used to pay up to 100% of the total cost of the BMP. BMPs must comply with standards and specifications developed by: the Natural Resources Conservation Service (NRCS), such as the NRCS Field Office Technical Guide (FOTG); the Indiana Department of Natural Resources (IDNR); or other recognized standards (see definition of BMP for more information).
Please note that not all BMPs outlined in the FOTG are eligible through 319, and all proposed BMPs should be discussed with your IDEM project manager to verify funding eligibility.
A Conservation Plan must be in place and followed in all fields that receive cost-share funds. The Conservation Plan, which is eligible for 90% cost share, must be signed by a Certified Conservation Planner, and a copy of the Plan must be kept in the project sponsor’s office. Projects should not assume that NRCS can provide technical assistance on BMP standards and specifications or Conservation Plan development. A list of Certified Conservation Planners may be found on the NRCS web site.
Design costs may be included in the total cost of the BMP, and will be reimbursed after the BMP is implemented. BMPs must be installed in accordance with the WMP, Conservation Plan, any applicable Nutrient Management Plan (NMP), Pesticide Management Plan (PMP), Manure Management Plan (MMP) and/or Comprehensive Nutrient Management Plan (CNMP), and be necessary to improve or maintain water quality by reducing off-site sedimentation, and/or nutrient, pesticide or pathogen loads to receiving waters. All BMPs installed with these grant funds must be maintained as follows: vegetative and land management practices 5 years, structural practices 10 years.
U.S. EPA has determined that all Animal Feeding Operations (AFOs) receiving Section 319 funding must have a CNMP in place. Section 319 funds may be used to pay up to 90% of the total cost of developing a CNMP (based on the Technical Service Provider (TSP) Payment Rates). Any AFO that is subject to National Pollutant Discharge Elimination System (NPDES) permit requirements or is designated to be a Concentrated Animal Feeding Operation (CAFO) under 40 CFR Section 122.23 is ineligible for Section 319 funding.
When BMPs are implemented that will directly reduce sediment and/or nutrient runoff, grant recipients must utilize the spreadsheet application entitled Region 5 Model or the Spreadsheet Tool for Estimating Pollutant Load (STEPL) or other approved method to provide, when applicable, estimated sediment and nutrient load reductions for each BMP implemented during the project.
In order to receive reimbursement for BMPs that have been implemented, an invoice for payment must be submitted to IDEM by the project sponsor along with the completed 319-A Agriculture Cost-Share Form (available on the IDEM Forms page) and the following enclosures:
When using cost-share to implement a BMP, project sponsors must ensure that the practice is in a critical area as defined by an approved WMP, addresses a water quality problem outlined in the WMP, and follows the project’s approved cost-share program. These three conditions ultimately determine if a practice is reimbursable. However, there are two other related criteria that a Section 319 group should consider when implementing a BMP and that Project Managers may need to explore if aspects of the three conditions above are not clear:
The BMP should address the goal(s) of the WMP and be appropriate for the NPS pollution in the critical area where the practice site lies. Further, IDEM will not fund BMPs that are ‘bandages’, or spot fixes of much larger issues. For example, stabilizing streambanks without first addressing the source of the extra flow and sediment causing the bank instability is not a high value practice or an IDEM funding priority.
IDEM expects Section 319 groups to consider the ratio of BMP cost to pollutant/flow reduction and to make judicious use of their limited grant funding. IDEM’s first priority is to improve water quality through the reduction of pollutant loads. Practices that can’t demonstrate a load and/or runoff reduction will not be funded (exceptions can be made if a method for estimating a BMP’s reductions does not exist).
Because storm water runoff delivers additional pollutants to streams and contributes to bank destabilization, stopping runoff from reaching streams is important. This does not mean that Section 319 funds can address flooding concerns or remove flow from a stream channel. Rather, a practice decreasing polluted runoff before it reaches a Water of the State may be considered eligible. Examples would include:
Every watershed and WMP’s goals are different and IDEM does not require that projects focus on any BMPs except those outlined in their approved cost-share program. However, there are BMPs and other practices which IDEM believes provide significant pollutant load and/or flow reductions for their cost and encourages Section 319 Projects to implement whenever possible.
Conservation tillage saves soil and can result in less fertilizer use. In most cases, it also is a relatively inexpensive BMP when compared to the acreage it benefits and pollutant load reductions it creates.
Conservation easements provide lasting protection to land and can be a valuable watershed management tool. While Section 319 cannot reimburse property owners for property value lost due to an easement, certain administrative costs associated with creating the easement are eligible. Likewise, certain administrative costs associated with purchasing land so it can be permanently protected are eligible. See IDEM’s Urban BMP Guidance for details and more information.
By planting cover crops, producers protect their topsoil during the winter months, see an increase in soil nutrient levels—and a decrease in fertilizer needs—and protect their fields from weeds and insects. The economic incentive of cover crops can be calculated by weighing their cost against the nutrients and herbicides a landowner would typically apply.
U.S. EPA strongly recommends using a systems approach to a site whenever possible. When creating a system of BMPs, the goal is to position two or more BMPs on the landscape so they complement each other and create the maximum water quality benefit. For instance, reduced tillage combined with a water level control structure for drainage tiles not only reduces soil runoff but also decreases the flow of storm water and nutrients to streams.
When a ditch is modified to a two-stage design, benches are added to both sides of the stream. These benches create room for water to collect during high flows and the stream to more naturally meander. As water flows onto the benches and slows down, pollutants drop out, scouring decreases, and the soils and vegetation on the benches cleanse the water. Benefits to the landowner include a more stable stream with less undercutting of trees (due to reduced scouring during high flow) and increased wildlife habitat (due to reduced sedimentation). Two-Stage Ditches may also significantly decrease the need to dredge the ditches. Information on Two-Stage Ditches can be found at: NRCS’ Stream Restoration Design Manual, Chapter 10 and G. E. Powell, et. al. “Two stage channel systems: Part 1, a practical approach to sizing agricultural ditches” Journal of Soil and Water Conservation. Volume 62, Number 4, pgs. 277-296.
Educational projects should be an important part of any watershed project. Considering the small pool of funds available for BMPs, education can be a means to extend a project’s reach to a larger segment of a watershed’s community and hopefully encourage people to take action or change their behavior. Educational projects must address a problem or goal outlined in the WMP. Educational projects are not funded through cost-share and can take many forms including demonstration practices, educational events, training, and local environmental policy education. Educational events, training, and local environmental policy education do not have to be held within a critical area but must focus on an issue pertinent to a critical area. Watershed groups are encouraged to review U.S. EPA's Getting in Step manual [PDF], which focuses on conducting watershed education campaigns.
Demonstration projects are BMPs that introduce new NPS reduction/removal techniques in the watershed and encourage buy-in from landowners. Section 319 will fund up to 100% of the projects with the following stipulations:
Please note: Section 319 groups are welcome to hold demonstrations of BMPs that were cost-shared on. In such a case, only numbers 2 and 5 above are applicable.
Major changes in behavior require that people shift their mindsets, which takes education. Education gives an individual the needed knowledge regarding an issue to make sound decisions that will ultimately benefit the environment. Education also helps identify the specific skills that an individual needs to implement or act on the subject, but does not develop those skills. Some examples of educational events are public meetings, displays at county fairs, field days, and workshops on nonpoint source pollution and water quality. To be considered an ‘educational event’ an event must meet all of the following conditions:
If a person is performing work required by the educational event (i.e., laborer, classroom aide, presenter, etc.), services CAN be counted as match (or reimbursed with grant funds). If the person’s involvement is solely in a learning capacity, they are not providing a service, but are a beneficiary of the project and time or other expenses can NOT be counted as match.
Training is an activity that imparts knowledge to a participant and allows them to develop the skills necessary to complete or over-see work that will reduce nonpoint source pollution and that is reasonably expected to be carried out during watershed planning or implementation (as documented in either the grant agreement or watershed management plan). Training includes activities where participants can earn Continuing Education Units (CEUs) and learn to install BMPs in the watershed.
To be considered training, the event must meet one of the following criteria:
If approved, expenses related to the training may be counted as match for participants who are watershed stakeholders. Expenses related to participants in training activities may only be reimbursed with grant funds when the participant is performing work required by the project (i.e., presenter).
Section 319 groups are encouraged to create working relationships with local officials and to educate those officials about new ideas and concepts that reduce nonpoint source pollution as long as those actions help achieve a goal in the WMP. Examples of this strategy include:
In addition to these examples, Section 319 groups can work with local officials on ordinances as long as 319 funds are not spent on ordinance development or revision. Ordinances are an especially important tool in urbanizing watersheds and can be used to protect prime farmland and the streams running through it. Section 319 funds can be spent on:
Section 319 grant funds may not be used for the items listed below, nor may they be counted as match for the project:
Land that is currently in production such as cropland, pastureland, rangeland, native pastureland, other land used to support livestock production, and tree farms.
An agricultural operation where animals are kept and raised in confined situations. It is a lot or facility (other than an aquatic animal production facility) where the following conditions are met:
A structural or management practice that is used to reduce the quantity of pollutants generated and/or delivered from a source to a receiving water body. A structural BMP is something that is built or involves changes in landforms or equipment. A managerial BMP involves a specific way of using or handling infrastructure or resources. Management practices control the delivery of NPS pollutants to receiving water resources by 1. minimizing pollutants available (source reduction) or 2. retarding the transport and/or delivery of pollutants, either by reducing water transported and thus the amount of the pollutant transported, or through deposition of the pollutant. To be considered a best management practice, a practice must have been selected through a planning process designed to inventory resources and needs, determine available alternatives, and weigh the alternative’s benefits against the practice’s. All BMPs except Low Impact Development (see IDEM’s Urban BMP Guidance) and Conservation Easements require regular inspection and maintenance as part of the IDEM cost-share or demonstration project agreement.
Primary sources for standards and specifications for BMPs appropriate to Indiana are listed below:
A method of construction combining live plants with dead plants or inorganic materials, to produce living, functioning systems to prevent erosion, control sediment and other pollutants, and provide habitat. Bioengineering techniques can often be successful for erosion control and bank stabilization, flood mitigation, and even water treatment. It is commonly used to restore vegetation on river banks to enhance natural decontamination of runoff before it enters a stream. Bioengineering is Section 319’s preferred method of stabilizing streambanks.
A plan that identifies actions or priorities that will be followed to meet clearly defined nutrient management goals that protect water quality at an agricultural operation. CNMPs should address, as necessary, feed management, manure handling and storage, land application of manure, land management, record keeping, and other utilization options. While nutrients are often the major pollutants of concern, the plan should address risks from other pollutants, such as pathogens, to minimize water quality and public health impacts from AFOs. The NRCS FOTG is the primary technical reference for the development of CNMPs.
An operation must meet the definition of an AFO before it can be defined or designated as a CAFO. Previous U.S. EPA regulations based the definition of CAFOs on the number of "animal units" confined. U.S. EPA no longer uses the term "animal unit," but instead refers to the actual number of animals at the operation to define a CAFO. View a brief summary here of how the regulations define Large, Medium, and Small CAFOs [PDF]. The NPDES program regulates the discharge of pollutants from point sources to waters of the United States. CAFOs are point sources, as defined by the CWA [Section 502(14)], and are ineligible for Section 319 funding.
As defined by the State of Indiana, is any AFO engaged in the confined feeding of at least 300 cattle, or 600 swine or sheep, or 30,000 fowl, such as chickens, turkeys or other poultry. The IDEM regulates these confined feeding operations, as well as smaller operations which have violated water pollution rules or laws, under IC 13-18-10.
A legal agreement between a landowner and a land trust that places specific land-use restrictions on a property according to the landowner’s express wishes. The easement stays with the title to the property, allowing the property to remain in private ownership and to be used for purposes consistent with the conservation values of the property. The terms of the easement remain intact if the property is sold or bequeathed, thus requiring all future owners to abide by the terms of the agreement. The land trust’s responsibility is to monitor and ensure that the terms of the agreement are observed. Land Trusts cannot put conservation easements on land they own.
A written record of a landowner’s management decisions and the conservation practices and systems that will be used and maintained on the farm. Carrying out the Plan will achieve the goals of protecting the environment on and off the farm. The Plan includes soil maps and descriptions, resource inventory data, treatment decisions, location and schedule for conservation practices and a plan of operation and maintenance of the conservation systems or practices.
Recognized units earned for participation in qualified continuing education programs that may be used for professional advancement or as evidence of increased abilities, not for college credit.
According to the 2009 IDEM WMP Checklist, Critical Areas are defined areas where WMP implementation can remediate NPS sources in order to improve water quality and/or can mitigate the impact of future sources in order to protect water quality. Guidance on selecting Critical Areas is located in the 2009 IDEM WMP Checklist.
BMPs used to introduce new techniques in the watershed and to encourage landowners to install the practice. The BMP must: 1. be located on public land or any area where the public has access on a regular basis. Examples of locations suitable for demonstrations include parks, shopping plazas, and common areas in subdivisions. Locations must be approved by IDEM before grant funds are allocated to the BMP project. 2. be located in a critical area as defined in the WMP, 3. not have been cost-shared on before in the watershed with Section 319 funds, and 4. be used/showcased as part of an education and outreach event. Demonstration projects must be authorized in the project’s Grant Agreement, and implemented and maintained according to the instructions on the 319-A or 319-U form.
An event that conveys general information about watersheds, improving water quality, nonpoint source pollution, or BMPs, etc. The desired effect of an education event is a change in the participant’s behavior. Behavior change does not reflect the gaining of any particular skills on the part of the participants.
An education event that provides on-site information about a BMP or practice.
Man-made changes to a stream, usually through channelization or damming, which change a water body's physical structure as well as its natural function. These changes can cause problems such as changes in flow, increased sedimentation, higher water temperature, lower dissolved oxygen, degradation of aquatic habitat structure, loss of fish and other aquatic populations, and decreased water quality.
Practices that require primarily management techniques and methods to implement the practice (such as nutrient management, pest management, residue management, prescribed grazing).
A tool for producers to use when they plan their nutrient placement to optimize crop production. A MMP helps producers identify the amount of manure being produced, the nutrient concentration in the manure, the number of acres that are required for land application and the amount that will be applied to each available acre. It should include procedures for soil and manure testing and soil survey maps of manure application areas.
Nonpoint source water pollution is so named because the pollutants do not originate at single point sources, such as industrial or municipal waste discharge pipes. Instead, NPS pollutants such as fertilizer, road salt, sediment, pesticides, nutrients and bacteria are carried over fields, lawns, and streets by rainwater or snowmelt. These pollutants then enter lakes and streams or seep into groundwater. While some NPS pollution is naturally occurring, most of it is a result of human activities.
Using accumulated research and recommendations to draft new ordinance language. Whether done by a Section 319 group, a stakeholder, or a subcontractor, ordinance development and/or revision is not 319 eligible.
A BMP that is constructed and operated to treat a problem or address an issue from a surrounding area. They are typically designed to remove water from a stream, treat it, and then return it to the stream. Section 319 funds must be focused on keeping pollutants from reaching a stream, not removing those pollutants once they have entered the stream. Regional water quality features are not Section 319 eligible.
A performance-based regulation designed to reduce pollutants that are associated with construction and/or land disturbing activities that disturb one acre or more. It overlaps with the MS4 rule in that, the MS4 rule requires MS4 entities to develop ordinances for the Construction and Post-Construction Minimum Control Measures, and those ordinances must meet the minimum requirements of Rule 5. Rule 5 applies statewide, but the ordinances developed by the MS4s are specific to each MS4 jurisdictional area. Section 319 funds cannot be spent on Rule 5 requirements unless the proposed project is above and beyond the rule’s requirements. The codified version of Rule 5 may be found in the Indiana Administrative Code [PDF].
A watershed resident (or group) who is responsible for making or implementing a management action, who will be affected by the action, or who can aid or prevent its implementation.
Practices that involve constructing designed (engineered) features using heavy machinery (such as waterways, erosion control structures, and WASCOBs).
A system of BMPs, also known as a treatment train, is any combination of BMPs that are used together to comprehensively control a pollutant from the same source.
Individuals, entities, or public agencies certified by NRCS and placed on the approved list to provide technical services to program participants or the Department. You may Locate Technical Service Providers for each state on the NRCS website.
An activity that imparts knowledge to a participant and allows him/her to develop the skills necessary to complete or oversee work that is reasonably expected to be carried out during watershed planning or implementation.
Practices that only involve seeding or planting to establish or re-establish plant cover (such as pasture and hay seeding, cover crop, filter strip, and tree planting).
Accumulations of water, surface and underground, natural and artificial, public and private; or a part of the accumulations of water; that are wholly or partially within, flow through, or border upon Indiana. The term does not include:
The term includes all waters of the United States, as defined in Section 502(7) of the federal Clean Water Act (33 U.S.C. 1362(7)), that are located in Indiana.
A strategy and implementation plan for achieving water resource goals which provide assessment and management information for a geographically defined watershed. It includes the analyses, actions, participant input, and resources related to development and implementation of the plan.
An education event that involves a seminar, lecture, or group discussion.
This section attempts to address frequently asked questions regarding agricultural cost-share and eligibility. If additional information or clarification is needed, please contact an IDEM Section 319 Project Manager.
Section 319 cost-share funds will not be released until the practice is fully implemented. For instance, a landowner who modifies his planter for no-till cannot receive reimbursement until the modified planter has been used to implement no-till. Once the BMP or practice is complete the project sponsor may invoice IDEM, at which point reimbursement will take about 4 weeks.
All eligible BMPs (see Program Information and Restrictions) may be funded as long as there is a CNMP in place. CNMP development may also be funded up to a maximum of 90% of the total cost of development (based on the TSP Not to Exceed Rate).
Since CFOs are regulated by IDEM, BMPs that go above and beyond the Confined Feeding Operation Rule requirements are eligible. (In addition, a CNMP is required since they are also considered AFOs). For example, technology (including equipment modifications) that reduces or eliminates surface application of manure or that increases application efficiency such as no-till manure injection, variable rate controllers, and Geographic Positioning Systems go above and beyond the rule and are eligible for cost-share through Section 319. Section 319 funds may only be used to pay for the additional costs of these practices. Also included are NMPs that address the whole farm, mortality composting, manure composting, and covered buildings for the purpose of staging manure for distribution (as opposed to manure storage at a production facility).
Not eligible for funding: development of MMPs, land application of manure, run-on and run-off control, and other requirements of the CFO Rule.
CAFOs are not eligible for 319 funding.
No, but they are recommended. A Conservation Plan is required for all cost share recipients. A CNMP is required for AFOs.
Section 319 funds may be used to implement MMPs, PMPs, NMPs, and CNMPs.
When requesting reimbursement for eligible best management practices (BMPs) installed on agricultural land - defined for these purposes as land that is currently in production (i.e., working land) such as cropland, pastureland, rangeland, native pastureland, other land used to support livestock production, and tree farms. Please note that the 319-A form requires that a Conservation Plan be developed and followed on all fields that receive cost-share funds. The following must be submitted with the 319-A form: a plan map showing the location of all practices, copies of bills or receipts showing the total cost, pollutant load reduction estimations for each applicable BMP (see Program Requirements), and the applicable NRCS checklist if cost-share funds are used to develop a MMP, NMP, PMP, or CNMP.
Yes, Conservation Plan development may be funded up to a maximum of 90% of the total cost of development (based on the TSP Not to Exceed Rate).
Yes, CNMP development may be funded up to a maximum of 90% of the total cost of development (based on the TSP Not to Exceed Rate). The NRCS Comprehensive Nutrient Management Plan Review Checklist must accompany the 319-A Cost-Share Form for reimbursement of funds for the development of a CNMP.
Yes, unless the applicant has power of attorney for the landowner.
No, manure hauling (which falls under FOTG 634 Waste Transfer) is not an eligible BMP in the cost-share program.
Yes, if the operation is not a CFO, and if at least 50% of the field is in the project watershed; the manure is applied in accordance with a MMP or CNMP for the field and the overall WMP; and the manure is not simply surface applied. 319 funds can be used for technology or activities that reduce or eliminate surface application of manure (and runoff) or increase application efficiency such as equipment modifications for manure injection, variable rate controllers, etc. Section 319 funds may only be used to pay for the additional costs of these practices. If a producer hires someone to land apply their manure, the additional costs associated with manure injection as opposed to surface application would be eligible.
Yes, as long as the landowner is a stakeholder in the project watershed.
Yes. All structural practices must be maintained for ten (10) years. Vegetative and land management practices—even those which must be repeated every year such as conservation tillage and the planting of cover crops—must be implemented for five (5) years. These requirements are listed in the 319-A Form.
Yes, as long as the equipment is used on his land inside the watershed.
No. If manure and organic by-products will not be generated, handled, stored or applied on the crop land for the required maintenance of the BMP (vegetative and land management practices 5 years, structural practices 10 years). (A CNMP should address all land units that the AFO owner and/or operator owns or has decision-making authority over and on which manure and organic by-products will be generated, handled, stored, or applied).
There is no set limit, but any equipment over $5,000 in value at the end of the project is considered the property of the State when the contract term ends. The Contractor may continue to utilize the equipment on loan with the following stipulations:
These funds may be combined as long as the total funds provided to the landowner do not exceed 75% of the total cost of the practice. EQIP funds may not be counted as match since match cannot come from federal funds. The combining of 319 and EQIP funds will need to be documented on the 319A Cost-Share Form.
The cost of the BMP includes actual costs associated with materials and labor (excluding tax). If a landowner is contributing labor, it should be calculated based on the reasonable and customary price in that area for the work being done.
Yes, if it is part of developing a CNMP or NMP that addresses the whole farm.
No, unless the participant is a watershed stakeholder and is attending a training which meets the training criteria above.
The STEPL Model can calculate load reductions from multiple BMPs. If STEPL does not have information for your BMPs, calculate the load reduction associated with the dominant (the one practice in the system that will have the greatest impact on loading reduction) practice and add 10%.
No. Section 319 will not fund the creation, development, or revision of an ordinance. Section 319 will fund efforts researching ordinances, creating recommendations, and sharing those recommendations with relevant stakeholders if the ordinance would potentially benefit a critical area.
No. In this example, the BMP would be classified as a ‘regional water quality feature’ which is an unfundable practice. Section 319 funds must be focused on keeping pollutants from reaching a stream, not removing those pollutants once they have entered the stream.
Traditional ‘hardscape’ streambank stabilization will only be funded on rare occasions which are decided by the NPS/TMDL Section Chief on a case-by-case basis. Streambank stabilization is easier to fund with Section 319 if bioengineering is used, the excess flow causing the instability is being addressed, and the project’s schedule is sufficient for all necessary permits to be gathered.
Yes, in certain circumstances. In brief, this would fall under site preparation, not invasive species removal. If, in the process of prepping a site for BMP installation, invasive plants were removed, this would be permissible. However, the primary purpose of the BMP cannot be the removal of invasive species, as this is not eligible for funding by Section 319 grants.
Yes, match can be counted for projects done within the watershed but independent of the Section 319 funded organization. For example, if the watershed group learns that a neighborhood association is installing BMPs, the time, energy, and cost associated with that practice is match eligible as long as the BMP addresses the goals of the WMP, does not fulfill a permit or rule requirement, will improve water quality and reduce sedimentation or nutrient, pesticide or pathogen loads to receiving waters, and the following information is submitted to IDEM:
Submit the revised cost-share program guidelines to the IDEM Project Manager for approval.