USTfields Qs & As: Contents of USTfields Pilot Proposals
Q1: We filled out an SF-424A form with our cooperative agreement. Do we need to do a new one? As a state, we've already put this application in and don't want to redo it if it's not necessary.
A: All USTfields Pilot proposals must have a completed SF-424A form attached to the entire application, regardless of whether the proposal is an amendment to an existing cooperative agreement or a new cooperative agreement. It is up to each Regional office to decide whether the USTfields Pilot will be an amended or new cooperative agreement.
Q2: What form must the state match be in?
A: EPA is flexible as to how states can meet their 10% match requirement as long as the match is consistent with 40 CFR 31.24. The match may be actual dollars or in-kind resources. As footnote 2 in the proposal guidelines states: "Please note that EPA does not have a preference requiring how states will meet their matching requirement as long as those resources are used for eligible activities."
Q3: Can we use the USTfields funding to match other funds provided by the private sector to leverage the funding?
A: Yes. Please note, however, that LUST funds cannot be used to match other federal funds unless specifically authorized by law. The statutory authority for LUST funding does not provide authorization to allow USTfields funds to match other federal funds [40 CFR 31.24(b)].
Q4: Our cities do not have the money to do the work needed to prepare a proposal. What do we do about that? And, the rural areas are trying to get the states to do the proposal paperwork for them-they want this.
A: The state is the official applicant for the USTfields Pilot proposal, and it is at the state's discretion how a proposal is prepared. A state's proposal preparation costs are allowable under OMB Circular A-87, Attachment B, Item 34, as indirect costs. However, EPA will not approve the charging of proposal preparation costs directly to USTfields awards.
Q5: How does the EPA Region handle the 10% match for states?
A: Subject to the policies and procedures in 40 CFR 31.24, the Region would handle it the same way as it does for current LUST Trust fund cooperative agreements.
Q6: Must the application come from the state, not the local area?
A: Yes, the pilot proposal must come to EPA from the state, not the local area. We hope local areas will come to the state with ideas so the state can work with them and decide which of the possible pilot proposals would be the best for the state to develop and send to EPA.
Q7: Under Criteria #2, first bullet, it states: "Preference will be given to pilots with community involvement throughout the life of the pilot." Two of our five candidate communities have already spent municipal funds to demolish the abandoned gas station buildings. These buildings were eyesores that also posed health and safety hazards. We think this is an excellent measure of community involvement and concern. Would communities that have taken prior action on their own--such as paying for demolition or tank removal--get any preference during the scoring process?
A: The proposal guidelines require a description of a community's current and expected long-term involvement throughout the life of the pilot. If there is community involvement before the preparation of the pilot proposal, that should be described in the USTfields proposal because it is directly indicative of the current level of community involvement. However, the proposal must also demonstrate that community involvement will continue in the future until the pilot reaches its goals. It is possible more competitive scores could result for proposals with earlier community involvement in that these pilots could not only score well in Criteria #2, Community Involvement, but also in other criteria such as Criteria #5, Project Planning and Schedule, where they may have shorter time frames.
Q8: Can the state in-kind match be state staff time?
A: Yes, to the extent authorized by 40 CFR 31.24. Please note that matching costs must be allowable under the terms of the agreement with EPA. Therefore, the standards set forth in the proposal guidelines for "Eligible Properties" and "Eligible Activities" must be met for any costs to count towards the matching requirement.
Q9: Must the state match be spent on the specific pilot proposal, or can it be spent on general LUST activities?
A: Yes, the match must be spent to carry out the specific pilot proposal. As required by 40 CFR 31.24, the match must be spent on activities that are allowable costs for carrying out the pilot proposal that EPA funds. Otherwise, the costs would not be allocable to the funded project and thus fail one of the tests for allowability under OMB Circular A-87. Again, the standards set forth in the proposal guidelines for "Eligible Properties" and "Eligible Activities" must be met for any costs to count towards the matching requirement.
Q10: Do you want to see the state matching funds in the budget section?
Q11: In the budget section, is the dollar amount $90K + $10K = $100K or $100K + $10K = $110K?
A: It would be $110K ($100K EPA and $10K state) if the state is seeking the maximum award from EPA. The matching process for the USTfields Pilots is the same as for the existing LUST Trust fund cooperative agreements between EPA and the states.
Q12: Can I submit my proposal early and have the EPA Regional Office review it?
A: Yes, with an important qualification. EPA could make a cursory review of the proposal for threshold requirements set forth in the "Eligibility and Threshold Requirements" of the proposal guidance (for example, eligibility of costs, etc.). However, no substantive review of the merits of the proposal can be performed as that could possibly provide an unfair advantage to that applicant. This is a competitive grant, and EPA intends to keep the process fair and equitable.
Q13: Can matching funds be spent on a site prior to award of the grant? In other words, we are currently funding a scope of work at one site and we will have spent money on this site before December. Does this count toward our 10% match?
A: Maybe. Matching costs must be allowable under OMB Circular A-87 and 40 CFR 31.24 and eligible for funding under the proposal guidelines. There are limits on the allowability of pre-award costs. On page 6 of the proposal guidance, it states: "USTfields Pilots recipients are authorized to incur pre-award costs. Pilot recipients may be reimbursed for pre-award costs they incur up to 90 days prior to the award without prior concurrence of the EPA Project Officer or Award Official provided that such costs are included in the application and the application is approved in its entirety. Pre-award costs incurred more than 90 calendar days prior to award are incurred at the pilot recipient's own risk; however, pilot recipients may be reimbursed with the approval of an EPA Award Official and the concurrence of the EPA Project Officer." To obtain EPA approval for costs incurred more than 90 days prior to award, the recipient must demonstrate that the costs would be eligible and allowable under the standards set forth in the proposal guidelines for "Eligible Properties" and Eligible Activities" to count towards the matching requirement. Again, including the pre-award costs in the application will allow EPA to evaluate eligibility and allowability.
Q14: On a multi-site proposal, can the 10% match (for the total $100,000 grant) be spent at one site and not on the other sites?
Q15: How do Tribes complete the SF-424A (Cooperative Agreement application form) if the Regional offices will assist with some of the USTfields work?
A: The Tribes need to complete the entire SF-424A. In their budget proposal (Item 15 of the SF 424A), the Tribes need to put in the gross dollar amount of financial assistance they are requesting from EPA. Depending on the nature of the other assistance the regional office will provide, the Region may need to account for the assistance in the "EPA In Kind" section of the "Funding Information" chart on page 2 of EPA's "Grant Agreement" form. The expected value of services or products provided to a tribe by an EPA contractor must be reported as in kind assistance. Actual costs are charged to a grant object class as required by EPA Order 5700.1. However, the value of technical assistance provided by EPA employees is not included in the in-kind amount, and staff time is charged normally.