Presenter outlines Category A and B coverage and NPO timing under the nonpoint-source order

Presenter said Unit 3 of the training "presents the requirements and deliverables for the 2 main components of order coverage," defining project-level and watershed-level responsibilities under the order.

The training front-loaded the distinction between the two project categories. "Category A projects pose a low threat to water quality and typically include activities that result in no or minimal ground disturbance near surface waters," Presenter said. By contrast, "Category B projects pose a greater threat to water quality and have greater monitoring and reporting requirements," especially when proposed activities traverse multiple watercourses or include pesticide application.

The presenter outlined NPO timing and content for Category B: permittees must submit an NPO annually and within 15 days of commencing project activities, and the NPO should include a map identifying the NEPA project area, proposed treatment areas for that year, roads within the NEPA project area, CSDS sites, watercourses, and water-drafting locations. Presenter noted that an NPO "can be considered a 1 year work plan or work clearance" for Category B activities.

The training also emphasized ongoing requirements that apply across categories: compliance with NEPA documentation where applicable, adherence to agency-specific best management practices, maintenance of training certificates for those responsible for permit activities, adaptive management (using feedback loops to revise measures), and retention of records for at least five years after project completion. Presenter warned that even Category A activities remain subject to discharge incident reporting; if a discharge meets the CSDS definition it triggers the CSDS requirements.

Why it matters: the session clarifies which projects require formal NPO submittals and when, and highlights that some Category A projects with approved NEPA documentation are automatically covered without an NPO, while Category B projects must provide planned maps and CSDS inventories. That distinction affects permitting timelines and monitoring obligations for agencies and land-managing permittees.

Next steps noted in the training: later units will provide more detail on monitoring, pesticide notification procedures and the specific content of NPOs and annual reports.