Innovative Nutrient And Sediment Reduction Grants 2022 Request For Proposals

Full Proposal Due Date: November 29, 2021


OVERVIEW


The National Fish and Wildlife Foundation (NFWF), in partnership with the U.S. Environmental Protection Agency (EPA) and the federal-state Chesapeake Bay Program (CBP) partnership, is soliciting proposals to restore water quality and habitats of the Chesapeake Bay and its tributary rivers and streams.

NFWF is soliciting proposals under the Innovative Nutrient and Sediment Reduction Grants (INSR) program to accelerate the rate and scale of water quality improvements specifically through the coordinated and collaborative efforts of sustainable, regional-scale1 partnerships in implementing proven water quality improvement practices more cost-effectively. Projects proposing to implement water quality improvement projects or practices at the pilot or demonstration scale, through ad-hoc project-scale partnerships, or via small-scale applications of new or innovative technologies are encouraged to apply for funding through the separate Small Watershed Grants (SWG) program (Request for Proposals anticipated for release in early 2022).

NFWF estimates awarding $7-10 million in grants through the INSR program in 2022, contingent on the availability of funding. Major funding comes from the EPA Chesapeake Bay Program Office, with other important contributions by Altria Group, the U.S. Department of Agriculture Natural Resources Conservation Service (NRCS)  U.S. Forest Service, and the U.S. Fish and Wildlife Service. 

All prospective applicants are required to consult with NFWF prior to submitting an application and no later than November 15, 2021. The NFWF program staff will confirm the applicant’s eligibility and provide initial feedback on the proposed project’s alignment with the INSR program priorities. Prospective applicants should contact Jake Reilly at jake.reilly@nfwf.org to schedule project consultations. 


GEOGRAPHIC FOCUS

All projects must occur wholly within the Chesapeake Bay watershed and directly result in the implementation of water quality improvements across multiple sites within a defined regional project focus or service area, to be specified by program applicants. Special consideration will be provided to projects located within priority subwatersheds where NFWF has identified significant needs for additional nutrient and sediment pollution reduction; applicants should consult links in this Request for Proposals and NFWF’s online Chesapeake Bay Business Plan mapping portal for more information on priority areas. 


PROGRAM PRIORITIES

As the CBP partnership initiates the critical final phase of implementation efforts under the Chesapeake Bay Total Maximum Daily Load (TMDL), NFWF, EPA and CBP partners are intentionally targeting INSR program funding towards the accelerated implementation of proven water quality improvement practices2 and approaches to achieve the level implementation necessary to achieve remaining pollution reductions by the TMDL’s 2025 deadline. The desired result of INSR funding is a cost-effective, measurable increase in the rate and/or scale of implementation for priority water quality improvement practices, as identified through the Chesapeake Bay TMDL and associated Watershed Implementation Plans (WIPs), in a defined regional project focus or service area.

NFWF is specifically soliciting proposals from existing partnerships, collaboratives and networks (“partnerships”), which are an especially effective mechanism for achieving and sustaining desired water quality improvement efforts by strategic leveraging of capacities, skills, and resources of diverse stakeholders. Such partnerships can take many forms3 and may include nonprofit organizations, public agencies, institutions and/or businesses4 with a shared focus on water quality restoration and protection. 

NFWF will competitively award funding under the INSR program to partnership projects that simultaneously (1) cultivate the growth and enhancement of existing regional-scale partnerships working on watershed restoration, and (2) measurably accelerate the geographic scale and/or rate of implementation for priority water quality improvement practices identified through the Chesapeake Bay TMDL and associated WIPs:

Cultivating Partnership and Network Growth and Enhancement: Consistent with program goals for accelerating near-term water quality improvements, the INSR program will focus primarily on efforts to enhance and expand the capacity and impact of existing partnerships for water quality restoration and protection. Projects seeking to establish new partnerships are encouraged to apply for funding through the separate SWG program Request for Proposals. 

Proposals must summarize both the current composition, structure, and function of the existing partnership(s) included in the proposal, citing formal and informal mechanisms for coordination and collaboration, as well as enhancements in these partnerships that will be achieved through the proposed project activities. Proposals must also establish a clear connection as to how proposed changes in coordinated and collaborative structures and/or functions will help to accelerate water quality improvements, a quantification of those water quality improvements, address key implementation and adoption barriers for priority practices, and improve long-term sustainability and durability of associated partnerships. 

NFWF, in partnership with University of Virginia’s Institute for Engagement and Negotiation, has identified four key areas for investment based on an extensive review of successful ecosystem restoration collaboratives, both in the Chesapeake Bay region and nationally, completed in 2019. Successful proposals will address these characteristics of effective collaboratives in describing their proposed project, work plan and collaborative structure. 

  • Building and Sustaining Motivation: Shared strategic planning processes, learning agendas, stakeholder engagement and recruitment initiatives, and leadership development activities can play important roles in building and sustaining inspiration and motivation for collaborative action. These processes and activities help to maintain an evident and transparent shared collaborative vision and purpose and further attract diverse stakeholders, organizations and individuals for a comprehensive and inclusive vision given unique local or regional needs.

  • Establishing and Improving Effective Collaborative Processes: Clear, consistent and explicit agreements on internal and external communication protocols, coordinative roles and responsibilities, decision-making processes and conflict management approaches can help to build trust and contribute to more effective and transparent processes for collaborative conservation action. Ensuring effective and consistent communication and convening of partnerships often plays a central role in clarifying and refining appropriate processes. 

  • Enhancing Core Capacities: Partnership-based funding of collaborative coordination activities, building of requisite technical expertise, “mapping” of technical and financial resources, and professional development efforts can enhance the collective capacity and development towards greater efficacy of collaboratives to effect on-the-ground outcomes and leverage shared or pooled funding opportunities.

  • Promoting Continuous Evaluation: Continued self-assessment and evaluation of collaborative process and performance can ensure adaptive management of collaboratives to meet emerging needs and opportunities. 

Accelerating the Scale and/or Rate of Water Quality Improvements: The ultimate goal of the INSR program is to measurably increase the geographic scale and/or rate of implementation for priority water quality improvement practices, as identified through the Chesapeake Bay TMDL and associated WIPs, in a defined regional project focus or service area. 

Proposed improvements to grow and enhance existing partnerships must reasonably and demonstrably result in accelerated water quality improvement and practice implementation efforts. NFWF also acknowledges that additional grant investments beyond these direct improvements to collaborative structures and functions are likely necessary to further accelerate on-the-ground implementation efforts, for example by directly funding new regional-scale outreach and implementation programs, piloting or adapting regional-scale incentive programs, and demonstrating joint restoration project financing and implementation approaches. INSR funding may be used to support these efforts. However, consistent with the program’s goals to establish more sustainable mechanisms for future efforts, NFWF expects projects to clearly demonstrate how partners will pivot towards more sustainable, non-grant funding sources to finance ongoing implementation in the future.

NFWF is especially interested in efforts that accelerate water quality improvements associated with nonpoint source agricultural pollution, small and medium agricultural operations, and stormwater runoff from small and/or unregulated communities. All proposals must document how their proposal aligns with relevant state and local WIPs. Proposals that measurably increase implementation of priority practices and/or practices that are needed for accelerated implementation will be prioritized.

Special consideration will be afforded to proposed partnerships or networks that address one or more of the following specific strategies with the potential to advance transformational water quality improvement approaches:



Managing Upland Agricultural Runoff through Farm-Scale Conservation Systems and Solutions: Includes efforts to reduce water quality impacts while simultaneously maintaining or increasing profits, reducing costs, and enhancing financial performance of the region’s farms through the implementation of best management practices that reduce pollution at the farm scale, increase cost-efficiency, and increase performance. 
For projects managing agricultural runoff, the most competitive applications will seek first to utilize existing federal, state, and local cost-share and incentive programs to finance implementation of water quality improvement practices, with NFWF funding for practice implementation used to strategically fill gaps in existing funding programs. Where NFWF funding is sought to cover all or a portion of costs for practice implementation, applicants must describe why other public programs are insufficient or otherwise inappropriate for financing proposed practice implementation. 

Managing Upland Urban Runoff through Green Stormwater Infrastructure Improvements (GSI): Includes efforts to assist local governments, nonprofit organizations, and community associations to improve urban and suburban stormwater management by implementing upland, green stormwater infrastructure practices that capture, store, filter, and treat stormwater runoff. In limited cases, NFWF may also support urban floodplain and stream restoration for water quality improvement where existing or planned green stormwater infrastructure initiatives that meaningfully contribute to the control of stormwater runoff from upland sources. 

Restoring Riparian and Freshwater Habitats through Forested Buffers, Floodplain and Wetland Reconnection, Stream Restoration and Habitat Improvements: Includes efforts to restore degraded riparian systems to improve water quality, enhance aquatic habitat, and increase fish populations across the Chesapeake Bay region through a variety of actions including but not limited to: establishment of riparian forested buffers, livestock exclusion fencing, and associated practices like stream crossing and off-stream watering; reconnection of stream channels with historic floodplains and adjacent wetlands to further promote nutrient removal, attenuate erosive stormflows and increase resiliency of  riparian systems, and restore streams in both urban and rural landscapes to control streambank erosion, increase in-stream nutrient processing, and provide food, cover, and habitat for priority species.

Conservation Finance and Market Development to Accelerate Water Quality Improvements: U.S. EPA and the Chesapeake Bay Program partnership are increasingly looking towards conservation finance and environmental market development as strategies to help meet Bay TMDL goals by bringing additional or new revenues for watershed restoration, streamlining or reducing costs of restoration, and increasing cash flows and liquidity for on-the-ground implementation efforts. Selected examples include pay-for-performance and pay-for-success models, functional environmental credit markets, revolving funds, and consumer-funded models for sustainable food and fiber production, among others. Collectively, these approaches seek to advance novel and non-traditional transactions, payors, and capitalization approaches to enhance the pace and scale of watershed restoration efforts.

NFWF will utilize the Market Development Framework (Figure 1) developed by the Conservation Finance Network to better understand and evaluate proposals that incorporate conservation finance and market development under the INSR program.

A table displaying the Market Development Framework developed by the Conservation Finance Network. For a full text description of this table, please email nicole.thompson@nfwf.org .

 
NFWF is specifically soliciting proposals under the INSR program to advance Pilot and Early Market stage efforts (see Figure 1) supporting water quality improvement in the Chesapeake Bay region. Applicants for these efforts must provide additional information through the Conservation Finance and Market Development narrative supplement in addition to the standard INSR project narrative in order to demonstrate that key elements from a successful Market Formation and Development phase have been accomplished, including:

  • Has the market opportunity been defined, including specific payors (e.g., consumer, corporate, municipal)? As a general rule, NFWF will not fund Pilot or Early Market efforts unless applicants can specifically identify at least one committed payor/buyer (via Letters of Support, match contributions, and/or project participation).

  • Have potential cash (from payors) and benefit flows (from on-the-ground projects/practices) been modeled and do results support market viability?

  • Have sufficient protocols and “rules” been identified to guide market functions?

  • Has the unit of measure/transaction been defined and is this unit consistent with NFWF’s CBSF priorities and business plan?

  • Have sufficient data management processes and systems been identified or proposed to measure and account for benefit flows?

In addressing the standard INSR project narrative, applicants for projects incorporating conservation finance and market development should further clarify how core constituents have been engaged in market development efforts to date, including potential landowners and land managers, relevant nonprofits, government agencies, technical assistance providers, and payors. The project narrative should further describe how key partnerships and collaborative models will be utilized to ensure success and maximize on-the-ground implementation outcomes.  


PROJECT METRICS


To better gauge progress on individual grants and to ensure greater consistency of project data provided by multiple grants, NFWF has provided a list of metrics in Easygrants for grantees to choose from for reporting. For the INSR program, awardees will be required to report both project-level metrics via Easygrants and more detailed site and practice-level data via FieldDoc.org (see below for additional details), as applicable. NFWF understands that applicants may utilize a variety of tools and methods to estimate proposed nutrient and sediment load reductions other than FieldDoc and simply requires sufficient justification in either the project narrative or Easygrants metrics interface detailing the basis for estimated load reductions. 

For a complete list of applicable metrics, see Appendix A. We ask that applicants select only the most relevant metrics from this list for their project. It is in the applicant’s best interest to be selective of the most meaningful and well-aligned metrics with the project objectives and outcomes. If you do not believe an applicable metric has been provided, please contact Nicole Thompson at nicole.thompson@nfwf.org or (202) 857-0166, to discuss acceptable alternatives.


ELIGIBILITY

Eligible and Ineligible Entities

  • Eligible applicants include non-profit 501(c) organizations, state government agencies, local governments, municipal governments, Tribal governments and organizations, and educational institutions.
  • Ineligible applicants include U.S. federal government agencies, businesses, unincorporated individuals, and international organizations.

Ineligible Uses of Grant Funds 

  • Applicants are encouraged to rent equipment where possible and cost-effective or use matching funds to make those purchases. NFWF acknowledges, however, that some projects may only be completed using NFWF funds to procure equipment. If this applies to your project, please contact the program staff listed in this RFP to discuss options.
  • NFWF funds and matching contributions may not be used to support political advocacy, fundraising, lobbying, litigation, terrorist activities or Foreign Corrupt Practices Act violations.
  • NFWF funds may not be used to support ongoing efforts to comply with legal requirements, including permit conditions, mitigation and settlement agreements. However, grant funds may be used to support projects that enhance or improve upon existing baseline compliance efforts, for example in achieving municipal separate storm sewer system requirements.
  • Federal funds and matching contributions may not be used to procure or obtain equipment, services, or systems (including entering into or renewing a contract) that uses telecommunications equipment or services produced by Huawei Technologies Company or ZTE Corporation (or any subsidiary or affiliate of such entities) as a substantial or essential component, or as critical technology of any system. Refer to Public Law 115-232, section 889 for additional information.

FUNDING AVAILABILITY AND MATCH


NFWF will award a total of $7-10 million in grants through the INSR program in 2022. Awards will range from $500,000 to $1 million each, for an estimated 8-12 individual grant awards. These grants require non-federal matching contributions equal to the grant request. All 2022 INSR grants must be completed within three years of grant award.


EVALUATION CRITERIA


All proposals will be screened for relevance, accuracy, completeness and compliance with NFWF and funding source policies. Proposals will then be evaluated based on the extent to which they meet the following criteria:


Criteria #1 – Conservation Outcomes

  • Project clearly and demonstrably increases the rate and/or scale of implementation of priority water quality improvement practices identified through the Chesapeake Bay TMDL, jurisdictional Watershed Implementation Plans, and local pollution reduction plans. Where possible and appropriate, the proposal contributes measurably to other, non-water quality outcomes outlined in the 2014 Chesapeake Watershed Agreement.
  • Project results in meaningful growth and/or enhancement of existing partnerships working to improve water quality and outlines specific efforts to build and sustain motivation, efficient processes, core capacities, and ongoing evaluative efforts. 
  • Project incorporates plans and approaches to implement, verify and sustain pollution load reductions and plan for their continuance beyond the timeframe of the grant.
  • Project conveys a clear communications plan that will actively transfer and disseminate project-related information to appropriate audiences and relevant stakeholders within the Chesapeake Bay watershed, with the goal of expanding adoption of successful approaches.

Criteria #2 – Budget

  • The quality and level of detail in the budget and budget narrative provide a clear and detailed understanding of the proposed funding request. 
  • Proposal demonstrates cost-effectiveness in achieving its proposed outcomes, considering both direct and indirect costs in the proposed budget.
  • Proposed costs are reasonable based on the work plan, local or regional costs for similar activities, and commensurate with project outcomes.
  • Budget clearly indicates the degree of partnership in conducting the proposed work.
  • Proposed funding request is well leveraged by the partners and other contributors through cash-, in-kind, and other match. 

Criteria #3 – Technical

  • Proposal provides specific goals that correlate with a clear, logical and achievable work plan, milestones, and timeline.
  • Proposed project team has the core competencies necessary to implement the proposed activities and achieve the proposed outcomes as well as the commitment to engage technical experts necessary to ensure activities are scientifically and technically sound and feasible. 
  • Proposal demonstrates an understanding of necessary permitting and environmental compliance requirements and the ability to obtain necessary approvals consistent with the proposed work plan and timeline. 
  • Applicant organization has demonstrated an ability to manage and implement similar projects on time and within budget


OTHER


Nutrient and Sediment Load Reductions: All INSR proposals must demonstrate reductions of nutrient and sediment pollution to local rivers and streams, and ultimately the Chesapeake Bay. To assist applicants in generating credible and consistent nutrient and sediment load reduction estimates, NFWF has partnered with the Chesapeake Commons and Maryland Department of Natural Resource to develop FieldDoc, a user-friendly tool that allows consistent planning, tracking, and reporting of water quality improvement activities and associated nutrient and sediment load reductions from proposed grant projects. 

FieldDoc currently includes functionality for a significant share of water quality improvement practices approved by the Chesapeake Bay Program for the purposes of TMDL crediting. When setting up proposed projects in FieldDoc, please be sure to list your application’s 5-digit Easygrants number in the FieldDoc project title. 

Upon grant award, NFWF will require all projects submitted under this solicitation to utilize FieldDoc for tracking and reporting of applicable water quality improvement activities during the course of their grant project. For technical support on FieldDoc utilization during proposal development, please contact Chesapeake Commons at support@chesapeakecommons.org. 

Monitoring – NFWF may implement independent monitoring efforts in the future to measure the environmental outcomes from projects funded under this solicitation. Award recipients may be asked to facilitate granting of access to project sites for NFWF or its designees for future environmental monitoring purposes. 

Budget – Costs are allowable, reasonable and budgeted in accordance with NFWF’s Budget Instructions cost categories.  Federally-funded projects must be in compliance with OMB Uniform Guidance as applicable.

Cost-Effectiveness – Project includes a cost-effective budget that balances performance risk and efficient use of funds. Cost-effectiveness evaluation may include, but is not limited to, an assessment of either or both direct and indirect costs in the proposed budget. The federal government has determined that a de minimis 10 percent indirect rate is an acceptable minimum for organizations without a NICRA, as such NFWF reserves the right to scrutinize ALL proposals with indirect rates above 10 percent for cost-effectiveness.  

Matching Contributions – Matching Contributions consist of cash, contributed goods and services, volunteer hours, and/or property raised and spent for the Project during the Period of Performance. Larger match ratios and matching fund contributions from a diversity of partners are encouraged and will be more competitive during application review.

Procurement – If the applicant chooses to specifically identify proposed Contractor(s) for Services, an award by NFWF to the applicant does not constitute NFWF’s express written authorization for the applicant to procure such specific services noncompetitively. When procuring goods and services, NFWF recipients must follow documented procurement procedures which reflect applicable laws and regulations.  

Publicity and Acknowledgement of Support – Award recipients will be required to grant NFWF the right and authority to publicize the project and NFWF’s financial support for the grant in press releases, publications and other public communications. Recipients may also be asked by NFWF to provide high-resolution (minimum 300 dpi) photographs depicting the project.

Receiving Award Funds – Award payments are primarily reimbursable. Projects may request funds for reimbursement at any time after completing a signed agreement with NFWF.  A request of an advance of funds must be due to an imminent need of expenditure and must detail how the funds will be used and provide justification and a timeline for expected disbursement of these funds.

Compliance Requirements – Projects selected may be subject to requirements under the National Environmental Policy Act, Endangered Species Act (state and federal), and National Historic Preservation Act. Documentation of compliance with these regulations must be approved prior to initiating activities that disturb or alter habitat or other features of the project site(s). Applicants should budget time and resources to obtain the needed approvals. As may be applicable, successful applicants may be required to comply with additional Federal, state or local requirements and obtain all necessary permits and clearances.

Quality Assurance – If a project involves monitoring, data collection or data use, grantees will be asked to prepare and submit quality assurance documentation. This includes any data collection activities described in the proposal as provided by match and partner activities. Examples of data collection or use which likely require a Quality Assurance Project Plan (QAPP):

  • New data collection
  • GIS or secondary data analysis
  • Data collection and analysis associated with development or design of plans and projects, e.g., fish passage, watershed or water quality/habitat restoration project plans, etc. 
  • Site assessments for prioritization and decision making
  • Water or other environmental media monitoring
  • Model development or use
  • Volunteer or community based scientific data collection, monitoring, etc.

Applicants must budget time and resources in their CBSF proposal to complete this task. Reimbursement for project activities, including non-data collection activities, may be delayed until quality assurance compliance requirements are complete. Plan to submit the draft QAPP to NFWF at least three months in advance of starting your data driven activity for review and comment. The timeline for receiving review feedback and comments and subsequent submittal for EPA approval is dependent upon the quality of the draft QAPP submission and may involve several iterations. General assistance will be available to grantees to help with scoping and review of the draft QAPPs. For more information, follow the link to EPA QA and CBSF Quality Assurance Project Plan Guidance. Please contact Stephanie Heidbreder (stephanie.heidbreder@nfwf.org) if you have any questions about whether your project would require a QAPP.

Permits – Successful applicants will be required to provide sufficient documentation that the project expects to receive or has received all necessary permits and clearances to comply with any Federal, state or local requirements. Where projects involve work in the waters of the United States, NFWF strongly encourages applicants to conduct a permit pre-application meeting with the Army Corps of Engineers prior to submitting their proposal. In some cases, if a permit pre-application meeting has not been completed, NFWF may require successful applicants to complete such a meeting prior to grant award.

Federal Funding – The availability of federal funds estimated in this solicitation is contingent upon the federal appropriations process. Funding decisions will be made based on level of funding and timing of when it is received by NFWF.

TIMELINE


Dates of activities are subject to change and contingent on the availability of funding. Please check the Program page of the NFWF website for the most current dates and information (http://www.nfwf.org/chesapeake).

Applicant Webinar (Registration)   Wednesday, September 22, 2021, 1:00-2:00 PM
FieldDoc Webinar (Registration) Thursday, September 30, 2021, 1:00-2:00 PM
Full Proposal Due Date Monday, November 29, 2021, 11:59 PM EST
Awards Announced March 2022 (anticipated)

 

 

 

 

 

HOW TO APPLY


All full proposal materials must be submitted online through National Fish and Wildlife Foundation’s Easygrants system.

  1. Go to easygrants.nfwf.org to register in our Easygrants online system. New users to the system will be prompted to register before starting the application (if you already are a registered user, use your existing login). Enter your applicant information. Please disable the pop-up blocker on your internet browser prior to beginning the application process. 
  2. Once on your homepage, click the “Apply for Funding” button and select this RFP’s “Funding Opportunity” from the list of options.
  3. Follow the instructions in Easygrants to complete your application. Once an application has been started, it may be saved and returned to at a later time for completion and submission.

APPLICATION ASSISTANCE 


A PDF version of this RFP can be downloaded in the Related Content Section.

A Tip Sheet is available for quick reference while you are working through your application. This document can be downloaded in the Related Content Section. Additional information to support the application process can be accessed on the NFWF website’s “Applicant Information” page (http://www.nfwf.org/whatwedo/grants/applicants/Pages/home.aspx).

For more information or questions about this RFP, please contact Jake Reilly (jake.reilly@nfwf.org), Stephanie Heidbreder (stephanie.heidbreder@nfwf.org), or Nicole Thompson (nicole.thompson@nfwf.org) via e-mail or by phone at (202) 857-0166.

For issues or assistance with our online Easygrants system, please contact:
Easygrants Helpdesk

Email:   Easygrants@nfwf.org
Voicemail:  202-595-2497
Hours: 9:00 am to 5:00 pm ET, Monday-Friday. 
Include: Your name, proposal ID #, e-mail address, phone number, program to which you are applying, and a description of the issue.

 

 

 

 

 

 

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1 For the purposes of this RFP, NFWF is exercising a flexible definition of what constitutes an appropriate “regional scale” partnership based on the unique aspects of relevant nutrient and sediment pollution source sectors, geographic focus, priority best management practices and identified barriers to adoption or implementation, and existing individual and collaborative organizational structures and service areas, among other considerations. In general, NFWF expects applicants to demonstrate how project partnerships and networks will achieve a measurable increase in the geographic scale and/or rate of water quality improvement not otherwise possible without enhanced coordination, collaboration, and integration between organizational resources, capacities, and programs.

2 For the purposes of the INSR program, eligible water quality improvement practices include practices approved by the Chesapeake Bay Program for crediting under the Chesapeake Bay TMDL. For a complete list of approved practices, please visit CBP’s Quick Reference Guide for Best Management Practices (BMPs). 

3 A brief, non-exhaustive summary of selected examples includes regional authorities for the delivery of stormwater program funding and management at a multi-municipality scale, coalitions of conservation districts working for the delivery of technical assistance and coordinated implementation for priority agricultural conservation practices at multi-county scales, multi-sector partnerships working to address a variety of pollution sources at the small watershed scale, and watershed-based partnerships for stream, wetland, and floodplain restoration.

4 While NFWF encourages partnerships that engage private businesses, please note that for-profit entities are not eligible applicants for the INSR program.