Coastal Bend Bays & Estuaries Program, Inc.
615 N. Upper Broadway, Suite 1200, Corpus Christi, Texas 78401 • 361-885-6202 • 361-881-5168 (fax)
December 9, 2015
TO: CBBEP Board of Directors
FROM: Leo Trevino
RE:
FY2016 CBBEP Project 1627- Bays Plan Update and Schedule
The National Estuary Program FY 2015 and FY 2016 Clean Water Act §320 Funding Guidance stipulates
the requirements for receiving CWA §320 funding. Amongst several changes and clarifications that the
EPA has included in the guidance document are the following topics:
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CCMP Revisions and Updates
Required National Meeting Attendance
NEP Program Evaluation
Use of §320 Funds for Land Purchase
Fund-raising vs. Grant Writing
Prohibition on Use of Clean Water Act §320 Funds by Association of National
Estuary Programs
The CBBEP Bays Plan was approved in 1998 and, although it continues to serve the program well,
CBBEP is will need to update the plan by 2020 so we have initiated the process of planning for the
update.
The updating of the plan is a significant undertaking requiring participation from most of the CBBEP
staff, Implementation Teams, Bays Council and Community involvement. CBBEP has identified a
contractor who will serve to provide writing, facilitating and coordination of the plan update working
through the Mission Aransas National Estuarine Research Reserve.
NEP CCMP Revision and Update Guidelines
7-24-15
Background
The FY 15 -16 NEP Funding Guidance broadly communicates expectations for CCMP Revisions and
Updates, in addition to HQ Concurrence. Provided below is EPA’s CCMP Content Checklist and
Concurrence Process to navigate you through the CCMP Revision and Update process, beginning with
general definitions and principles.
Scope of CCMPs – All CCMPs goals and actions must be consistent with Section 320. Some actions
will be funded by 320, while others will not. It’s important to distinguish actions in the CCMP that will
be eligible for 320 funding and those that will be implemented by other partners.
CCMP Revisions versus Updates – The Funding Guidance describes when a CCMP Revision or an
Update would apply. Revisions involve a significant change. For example, a CCMP Revision could be
driven by new CCMP goals, as directed by the Management Conference, or by new information
obtained through monitoring that would require revisiting and changing the actions in a CCMP. A
Revision may also be necessary with an increase in the study area, or in the case of an original CCMP.
Minor changes to action plans or insertion of a few actions would be considered an Update.
Reformatting, streamlining or reorganizing core actions to reflect new ways of accomplishing original
CCMP goals would also be considered Updates. Changes to a finance plan or outreach strategy would
be considered an Update.
CCMP Formats – EPA is not prescribing any particular format, just that the CCMP meets the Content
Checklist.
Concurrence Process – The Region is in the lead with respect to CCMP Revisions and Updates. HQ will
work in concert with the Region, and use the CCMP Content Checklist and the NEP Funding Guidance,
as a basis for providing comments during the concurrence process. HQ expects that the NEP will make
the changes necessary to the CCMP and associated documents to reflect the Content Checklist. HQ
Coordinators will need to honor the CCMP review schedule, while Regional Coordinators need to share
documents for review in a timely fashion. Collaboration and communication between the HQ and
Regional NEP Coordinators throughout the process is key.
Non-Concurrence – HQ does not anticipate providing a non-concurrence on CCMP Updates and
Revisions, assuming that Regional and HQ Coordinators are regularly communicating and collaborating
about the CCMP update and revision process for their assigned NEP. A HQ non-concurrence would
occur in instances when the CCMP Content Checklist was not followed (e.g. pieces are missing), or in
cases when the CCMP contains actions intended for Section 320 funding but those actions do no clearly
tie back to the intent of CWA Section 320. In rare instances of a non-concurrence, EPA will give the
NEP a 30 to 45-day notice of non-concurrence to give the NEP time to work with its Management
Conference and key stakeholders to make necessary changes for compliance with the CCMP Content
Checklist and Section 320.
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Program Evaluations – Program Evaluations should address the need for appropriate changes to the
CCMP, whether for Revisions or Updates, to ensure integration. State of the Bay Reports should also be
linked to CCMP Revisions and Updates.
Content Checklist - Essential Components of a Revised CCMP (major changes)
A Revised CCMP should:
1.____ Identify clearly the changes between the existing and draft CCMP so that reviewers can easily
determine what has changed and why; e.g., - key changes (if any) in priority problems and
program priorities, goals, objectives; any new information that suggests more promising
approaches or currently unaddressed issues, etc. Keep in mind the need for continuity in CCMP
implementation. A summary table listing the prior CCMP’s actions completed, revised, ongoing,
and those deemed obsolete can be included.
2.____ Describe how the NEP has contributed to or supported activities that helped develop new
information, if applicable, when highlighting major changes due to new information. Major
changes could be informed by Status and Trends or State of the Estuary Reports, Indicator
Reports, and associated monitoring programs. This is where a discussion of climate change
assessments and adaptation strategies should appear.
3.____ Include a map of the study area. If there are any proposed changes, provide and the reasons for
the changes.
4.____ Describe the NEP’s program structure and membership with any proposed changes and explain
how the structure will support the NEP’s ability to oversee and promote CCMP implementation.
This would include a discussion about the NEP’s approach to achieving financial sustainability
and for involving the public and stakeholders in its programs. The public involvement
discussion would describe how the NEP will engage stakeholders to ensure community
involvement and ownership in the CCMP implementation.
Discussion of the NEP’s program structure and membership can be represented as a stand-alone
document, chapter, or a series of actions in the CCMP that includes: a) a vision statement; b)
guiding principles, or goals and objectives; c) a target audience(s); d) a narrative description of
activities, such as branding and messaging though social media; e) leads for those activities; and
f) a budget and schedule for implementing the activities.
5.____ Discuss proposed changes in CCMP Actions, including their relationship to previously stated
goals and priority problems, the probable causes and sources they address, and measurable
objectives to attain the goal. Each CCMP Action must identify the key activities expected to be
implemented to address the priority problem. It would be very helpful to include a table
comparing the old and new actions in the CCMP which could appear upfront in the document, or
within each chapter.
CCMP Actions need to be clear, understandable, and plainly link to Section 320 (purpose #4).
They should: a) describe the activity/what will be done; b) where the action will take place or
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location it will affect; c) the lead entity responsible for implementing the action; d) include an
approximate timeline and milestones for completion; e) estimate the range of potential costs of
the action and sources of funding; and f) address performance measures (quantitative measures
and environmental results wherever possible).
Those CCMP Actions eligible for funding under Section 320 (through the EPA funding
agreement) will be fleshed out and included in the NEP workplan submitted to EPA. CCMP
Actions not funded by Section 320 should be clearly identified along with the other potential
funding source.
6.____ Include a Monitoring approach* that will track protection of and/or improvements in the study
area and effectiveness of CCMP Actions. This can be a separate brief higher level document or
chapter in the CCMP that identifies within the study area: a) data the NEP and partners are
collecting for which parameters; b) the party/parties responsible for collecting the data; c)
timetable for collecting and reporting the monitoring data; d) how the data is shared, who it is
reported to, and how it is used; e) data gaps; and f) additional funding needed for monitoring
activities. This section should explain how monitoring has/will change as a result of
new/modified actions and priorities, and any new environmental indicators. Monitoring should
be tied to the State of the Bay Report and the NEP Quality Management Plan which has similar
components. Please note: A QAPP can supplement the Monitoring Plan, but does not in and of
itself meet this requirement.
7.____ Include a Finance strategy* that will establish long-term financial sustainability to implement the
CCMP through diverse sources and partners. The strategy can be a separate document or chapter
in the CCMP that includes: a) funding objectives; b) current funding sources; c) priorities for
funding; and d) proposed actions or strategies to garner new funding for CCMP implementation.
The strategy should be at least a “case for support” piece that can be shown to potential funders
highlighting the environmental results achieved by that NEP and how funds would be used if
received.
8.____ Include a Habitat Protection/Restoration strategy.* The strategy can be separate document or
chapter/section of the CCMP and should include or contain: a) a description of habitat types and
key species in the study area; b) goals and measurable objectives; c) priority habitats and species
for protection and or restoration efforts; and d) actions that reflect a climate change vulnerability
assessment.
NOTE: Make sure to include a public review process for CCMP Revisions (that must extend
beyond the Management Conference members). Response to comments should be summarized
and be made publically available.
*If these sections (Monitoring, Finance and Habitat) are being carried forward from the former
CCMP, they can be incorporated into the Revised CCMP via cut and paste.
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Content Checklist - Essential Components of an Updated CCMP (minor changes)
An Updated CCMP can take the form of: 1) an Addendum to the Current CCMP, 2) a Strategic Plan or
updated Implementation Plan that serves as a companion piece to the CCMP, or 3) changes to select
Action Plans in the current CCMP. An updated CCMP should:
1.____ Describe clearly the priorities, goals, objectives (objectives should be measurable), and Action
Plans. Changes made from the previous CCMP should be described in the document. This could
include a summary table listing the prior CCMP’s actions completed, revised, ongoing, and those
deemed obsolete.
2.____ Clarify whether Action Plans are replacements for or enhancements of former/previous Action
Plans. Clearly articulate how CCMP and Actions relate to previous CCMP. (This enables the
reader to determine what changed and why, as well as which actions are new, what was
completed and why actions were not implemented, etc.). The discussion of changes may be
contained in the Introduction or an Appendix that might include a comparative table of original
and revised actions.
3.____ Be clear, understandable, and linked to Section 320 (purpose #4). Action plans should: 1)
describe the activity/what will be done; b) where the action will take place or location it will
affect; c) indicate which entities will serve as lead implementers; d) include a timeline and
milestones for completion; e) provide the potential cost of the action (can be a range) and sources
of funding; and f) address performance measures (quantitative/environmental results measures
wherever possible). Those CCMP Actions eligible for funding under Section 320 (through the
EPA funding agreement) will be fleshed out and contained in the NEP Workplan submitted to
EPA. CCMP Actions not funded by Section 320 should be clearly identified along with the
potential funding source.
4.____ Describe any other changes to your existing CCMP. This may be done in an Appendix.
5.____ Depending on the extent and magnitude of the changes, stakeholder involvement could simply
involve an internal Management Conference member discussion. If the NEP decides to send the
Updated CCMP out more broadly for public comment, response to comments should be
summarized and be made available.
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HQ Concurrence Process for CCMP Revisions and Updates
Regional and Headquarters Coordinators will collaboratively review updated and revised CCMPs so that
EPA can respond with one voice to the proposed changes. A key element of this cooperation is early
communication between Coordinators as the process unfolds. The Regional Coordinator will take the
lead in identifying potential issues in a timely manner and securing the endorsement of Regional
management in providing the final CCMP for Headquarters concurrence. Note that delivery and review
of CCMP documents will be through email or other digital means.
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Regional Coordinator shares early drafts of the CCMP and associated documents with the HQ
Coordinator. Coordinators confer and discuss initial feedback on documents. Regional
Coordinator shares feedback with NEP Director and may choose to extend an invitation to the
Headquarters Coordinator to participate in discussions.
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Regional Coordinator sends final draft CCMP and associated documents to HQ Coordinator. HQ
provides comments reflecting the current NEP Funding Guidance and the CCMP Revision
Checklist, to the Region. Region prepares and sends integrated EPA comments to the NEP
Director.
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The NEP addresses EPA comments. If any issues remain, the Regional Coordinator will work
with the NEP Director, Management Conference and Regional Managers to resolve as necessary.
The Regional Coordinator may choose to invite the HQ Coordinator in these discussions, as
necessary.
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Regional Coordinator provides the final draft CCMP and associated documents to the HQ
Coordinator. The draft will reflect HQ comments, the NEP Funding Guidance, CCMP Checklist
and the intent of Sec. 320.
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HQ Coordinator drafts an email for HQ Manager highlighting the minor or major changes in the
document and recommending final concurrence.
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The Regional NEP manager will send the final draft CCMP Revision, indicating conformance
with CWA Sec. 320, to the HQ Division Director. The HQ Division Director acknowledges
receipt of CCMP.
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For CCMP Updates, the Regional NEP manager sends a message to the CMB Branch Chief
certifying that the final CCMP Update conforms with CWA Sec. 320. CMB Branch Chief
acknowledges receipt of the updated CCMP.
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December 9, 2015
CBBEP - CCMP (Bays Plan) Revision Process
Estimated Timelines
CCMP Revision Steps
Description
Internal staff meeting
Staff prepares for Revision of
Plan
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Staff Recommends Consultant to
assist in writing the Revision plan
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Staff Recommends Outline for
CCMP
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Staff coordinate meeting of
Implementation Teams
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Staff begin review of action plans
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Staff coordinate and support
meetings of teams to review
action items
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Page 1 of 3
Discuss scope, process and staff role
Include purpose, scope, process for Revision
Recommend that the Implementation
Teams review and recommend changes
needed in the plan
Recommend that Bays Council act as
Steering/Oversight Committee
Consultant Meets with Staff prior to
participating in the Implementation Team
Meetings
Staff and consultant work to identify
additional Chapters (i.e., Coastal Resiliency
and Climate Change Vulnerability Section,
Invasive Species, Contaminants and/or
Emerging Issues) and incorporate these into
a comprehensive outline
Send outline to EPA regional office for
review
Explain scope and process to teams
Explain that staff will be seeking to obtain
input throughout the process
Determine if any new priority areas should
be added based on staff recommendations
Staff can begin reviewing action plans so
that when the time comes to make
recommendations they are prepared
Staff will work with consultant to coordinate
and host team meetings to discuss
particular components of the plan
Minimum of 1 meeting; Maximum of 3
meetings
Purpose: Develop list of action items
Provide staff recommendations via email
before meeting
Ask for new action items from members
before meeting
At meeting, review criteria for
removing/adding action items
Discuss potential partners, timelines, and
Estimated
Timeline
Fall 2015
Fall 2015
December 2015
December 2015 January 2016
January 2016
December 2015 February 2016
February - March
2016
December 9, 2015
CCMP Revision Steps
Staff work with consultant to
review list of recommended
action items to be considered for
approval and discuss supporting
information
Description
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Draft writing
Draft review
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Draft revised
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Draft posted
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Public meeting/forum for input
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Bays Council meeting
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Revise draft
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Page 2 of 3
funding mechanisms as well
Staff review actions to ensure they are not
overlapping
Ensure that actions are measurable,
achievable, and relevant
Approve or recommend changes to action
items
Also determine what information should be
in action item pages, what introductory
information should accompany each action
plan, and what introductory chapters are
needed
Consultant and Staff determine initial
graphics and design
Consultant to draft pages for action items
Consultant to draft introductions to action
plans
Consultant to draft introductory chapters
Staff reviews draft, approves or
recommends changes
Draft provided to Teams for information
purposes
Staff reviews changes provided by the
Teams and Consultant makes changes
Consultant and Staff finalize graphics and
design
Draft provided to EPA regional office for
review
Draft posted online for public comment (45
days)
Also make 1 hard copy available at CBBEP
that public can come and review
Host public meeting for input into CCMP
Staff and consultant organize public meeting
Staff and consultant consolidate all
comments into package for Steering
Committee (including online)
Provide general overview of changes made
to the plan
Review public input into plan
Make a list of changes based on public input
Consultant revises draft based on input
received from public consultation
Estimated
Timeline
March - April 2016
April - July 2016
August 2016
September 2016
October 2016
October 2016
October 2016
November 2016
December 9, 2015
CCMP Revision Steps
Description
Final draft of CCMP Revision to
Steering Committee
Final draft of CCMP Revision to
Bays Council
Final draft of CCMP Revision to
Board of Directors
Staff send approved CCMP
Revision to Texas Officials and
EPA
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For approval
Estimated
Timeline
December 2016
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For approval
December 2016
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For approval
December 2016
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December 2016