Round 2-12: State/Tribal Superfund Block Funding
Superfund Block Funding offers ways for States and Tribes to realize greater flexibility in their use of Cooperative Agreement (CA) resources. EPA, working in conjunction with States and Tribes, has developed recommendations to enhance State and Tribal involvement through improved administration of assistance agreements.
The benefits of this reform include:
- Allowing States and Tribes to direct CA funds between sites and activities to the extent allowed by the Advice of Allowance.
- Providing for the transfer of funds from among sites and activities, within the approved tasks for the cooperative agreement, without prior EPA approval.
- Reducing specific administrative budget and reporting requirements, where appropriate, which can produce resource saving for both levels of government.
Implementation of this reform is complete.
EPA will continue to collect information from EPA Regions and States to evaluate and develop lessons learned from the pilots.
In March 1995, EPA formed the Superfund Block Funding Workgroup, a group of 50 members with representatives from 17 States and Tribes. The Workgroup explored ways in which States and Tribes could realize greater flexibility in their use of Cooperative Agreement (CA) resources. EPA currently enters into several types of site- and non-site-specific CAs with States to conduct or assist Superfund response actions. The Workgroup developed recommendations to enhance State involvement in Superfund through improved administration of assistance agreements. The objective of the initiative is to incorporate block funding recommendations into program operating procedures.
Block Funding Pilot projects launched under the Workgroup's recommendations are already manifesting resource savings to both levels of government. For example, the State of Illinois reports an 85 percent reduction in preparation and processing of paperwork due to regulatory deviations received under its Block Funding Pilot. At one Superfund site, additional regulatory deviations allowed Illinois to cut at least three months out of the remedial process, and ensured that construction would not be delayed until the next construction season.
To fully realize benefits from the Block Funding recommendations, OSRTI has developed an implementation plan that includes the following activities:
- Working with the Office of the Comptroller to ensure that Regions may shift funds from existing CAs to block funding CAs. FY98 deobligation guidance allows for this procedure.
- Submitting Class Deviations from parts of 40 CFR Part 31 and 40 CFR Part 35. Over 60 deviation requests have been received and approved pursuant to the Block Funding Pilot.
- Monitoring, evaluating, and refining implementation of pilot projects.
Documenting Agency-wide and State government savings in full-time equivalents as well as in increased improvement of program implementation.
40 CFR Part 35, Subpart 0, the regulation that governs Superfund Cooperative Agreement Funding, is being revised and Block Funding Concepts are being incorporated into this revision.
The Block CA also has allowed Illinois EPA to go from quarterly reporting to bi-yearly reporting. While Illinois EPA continues to send quarterly financial statements for cost recovery purposes, project status updates are now sent on a bi-yearly basis. This has resulted in a 50 percent drop in the effort expended in reporting.
The Block CA allows Illinois EPA to transfer money from one project to another based on need and changing program priorities. Illinois EPA is required to report on each budget shift, but prior U.S. EPA approval is not needed and delays associated with CA application preparation and processing are substantially reduced.
Illinois EPA has recently decided to use the Block CA's flexibility to transfer additional money into the Parsons Casket project. The Parsons Casket ROD was completed by Illinois EPA in September 1996. U.S. EPA decided at that time to pursue a settlement with a former owner of the site. In October 1997, U.S. EPA announced a tentative cash-out settlement with the PRP. Instead of waiting until the next fiscal year for available funds, this settlement allows Illinois EPA to immediately begin design work on the remedy. The Block CA's use has cut at least three months out of the remedial process and has insured that the remedy is constructed in the next construction season. Without the Block CA, design and contractor procurement would have prevented construction in FY98.
Illinois EPA continues to believe that the Block CA is important to the State role in a reauthorized Superfund program. [FY97 Success]
Title: Block Funding Report
Date: December 2, 1997
Document #: OSWER 9200.0-27
Synopsis: This report is intended to be a resource for EPA Regions, States, and Tribes as they work to achieve their goals of enhancing State and Tribal involvement in Superfund through improved administration of assistance agreements. The report identifies options for enhancing the current process for awarding and administering Superfund cooperative agreements that have been piloted by some States and Regions.
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