Frequently Asked Questions on Brownfields Training, Research and Technical Assistance Grants and Cooperative Agreements Program Proposal Guidelines

1.Q  If a non-profit organization with a larger fiscal sponsor incurs cost for reporting on the grant through compliance with OMB circular requirements, how do they bill/report this cost to EPA? How do they quantify that specific financial component when the fiscal sponsor normally combines it with what is considered unallowable indirect costs under the confines of this grant?

A.  Reporting costs attributable to a specific Brownfields grant may be billed on a fee for service basis or other acceptable means which ensure that only the direct costs of reporting are charged to the Brownfields grant. Please note that these costs may not also be charged as indirect costs on other grants. EPA will work with successful applicants to resolve accounting issues arising from the administrative cost prohibition during negotiations for the final scope of work and terms and conditions.

2Q.  How are proposals compared to each other?

A.  Proposals are scored by the review panel against the ranking criteria provided in the Request for Applications and placed in ranking order under the seven subject areas described in the Request for Applications. The highest ranking proposals will be reviewed by EPA senior management and selected, based on rankings and other policy considerations such as geographic diversity, project diversity, avoiding duplication of effort, and applicant diversity (ie types of organizations) in deciding which applicants to approve.

3Q.  Will EPA consider offering only partial funding?

A.  Yes. the Agency does reserve the right to offer partial funding to applicants.

4Q.  Do the grant services (i.e., training, research, technical assistance) need to target current brownfields pilot/grantee communities?

A.  No. Any community impacted by brownfields can be targeted in the proposals.

5Q.  Must the proposals include all three services (i.e., training, research, technical assistance), or just one type of service?

A.  No. The applicant can make proposals for one or any combination of the service types.

6Q.What is the intended target of the grant proposals, site specific or population based?

A.  These grants are intended to address environmental and human health conditions in low income communities and socio-economically disadvantaged communities unable to draw on alternative sources of funding for assessment or clean up of Brownfields sites and their subsequent redevelopment and to provide technical assistance to communities which will enable them to stimulate economic and other beneficial reuse of these sites. Proposals need not be site specific.

7Q.  Under the past performance section of the ranking criteria, how does an applicant respond to the request for federal funding experience?

A.  EPA is interested in your experience managing Federal funds generally from a financial stewardship perspective, and EPA brownfields or other environmental grants from a programmatic perspective. In the first area, EPA is interested in the management of federal funds and audits, including any adverse or positive audit findings. If the applicant has no previous federal funding management experience, then non-federal funding management experience should be provided. In the second area, EPA is interested in descriptions of the products and outcomes of previous funding by EPA in the brownfields or other environmental programs. Experience with State or local, foundation or private funding for environmental projects would also be relevant.

8Q.  Can computers and printers be programmatic costs?

A.  If purchasing a computer or printer is necessary to carry out the specific project receiving funding the costs would be allowable. The equipment must be used and disposed of under the applicable provisions of 40 CFR Part 30 or 31.

9Q.  Can a percentage of rent be an acceptable programmatic cost?

A.  Facility rental costs are normally considered part of the indirect cost base, and are unallowable. If a leased facility is devoted 100% to activities carried out under an EPA Brownfields grant, and charged directly to the Brownfields grant, the costs would not be subject to the statutory administrative cost prohibition. However, such a cost may not be considered reasonable under the applicable OMB Circular and may raise questions during the review process relating to cost effectiveness.

10Q.  Does the length of performance matter?

A.  Yes. The Agency will fund projects with performance periods ranging from 1 to 5 years. EPA commitments to fund multi-year grants are subject to the availability of appropriations, and satisfactory grantee performance.

11Q.  What is the timeline for the award?

A. The applications are due November 16, 2004, and the plan is to make the awards and provide funding by the February 2005.

12Q.  Is the competition for 2004 Brownfields Training, Research and Technical Assistance Grants and Cooperative Agreements Program Proposal Guidelines limited to specific subject matter descriptions ?

A.  Yes. The subject matter descriptions are:

• Community Involvement in Low-income and Socio-Economically Disadvantaged Communities
• Integrated Approaches to Brownfields Cleanup and Redevelopment in Low-income and Socio-Economically Disadvantaged Communities
• How the Economics of Brownfields Cleanup and Redevelopment Impact Low-income and Socio-Economically Disadvantaged Communities

13Q.  Can these grants be used to provide assistance to states and tribes?

A.  Yes.

14Q.  If Congress makes a change to the administrative cost prohibition, how will this affect the grants awarded in Fiscal Year 2004?

A.  Whether the change applies prospectively (i.e., after FY 04) or retroactively depends upon the statutory language Congress uses in making the change. EPA would not apply the change retroactively without clear evidence that a retroactive change was intended by Congress.

15Q.  Are there funding limitations in the Proposal Guidelines for the 2004 Research, Training and Technical Assistance Grants and Cooperative Agreements Proposals?

A.  Yes. EPA estimates that $800,000 will be available to fund successful applications under this funding announcement. EPA expects to award 2-3 assistance grants under this solicitation. Applicants may propose single or multi-year projects with funding periods ranging from 1-5 years. EPA expects to award funds in February 2005. EPA will only consider applications for $100,000 or less in the first year of funding, and no more than $300,000 over the entire funding period. The Agency will reject applications that exceed these amounts.

16Q. If multi-year projects are proposed, does the applicant need to provide a yearly and total budget for each project?

A.  Yes. Also, if EPA awards a multi-year grant the recipient need not re-apply every year-such grants will be incrementally funded. As noted above, the Agency is only obligated to fund the first year of the project. EPA commitments to fund multi-year grants are subject to the availability of appropriations, and satisfactory grantee performance.

17Q.  Do the proposals for multiple years funding request need to specify projects for all years covered by the application?

A.  Yes. EPA cannot give out funds for unspecified items. A new sub-task could be added later within the original scope of the work, but no new work outside of the original scope will be considered. The proposals must be specific. Adjustments will be allowed, but the basic project must not change in subsequent years.

18Q.  Is there a set curriculum for training assistance?

A.  No. EPA does not have standard, off-the-shelf training programs for brownfields. The applicant must propose a curriculum along with details about the type of training they propose to provide.

19Q.  Is the proposal budget negotiable?

A.  Yes. EPA may work with the applicant to adjust the budget for eligible and allowable costs and has reserved the right to fund part of a proposed project.

20Q.  Is EPA planning on being involved in the projects?

A.  Yes, if the Agency awards a cooperative agreement. The exact terms of EPA involvement will be negotiated with the successful applicant, and described in the terms and conditions of the award. EPA involvement will be mostly at the Headquarters level, though there will be some EPA Regional involvement, as appropriate.

21Q.  Can existing Brownfields research, training and technical grants be supplemented by these grants?

A.  Yes. Applicants may seek supplemental funding that expands on previously funded Brownfields research, training and technical grants as long as the proposal falls under one or more of the 3 subject areas specified in the Request for Applications.

22Q.  How many grants will be awarded?

A.  EPA estimates that 2-3 grants may be awarded.

23Q.  Under a cooperative agreement, does EPA provide additional resources?

A.  Yes. The Agency provides resources in the form of technical assistance from EPA personnel, relevant data and publications. EPA may also, at its discretion provide in-kind assistance through contractor support in lieu of additional funding.

24Q.  Do applicants need to state if they are applying for a grant or cooperative agreement?

A.  No. EPA will determine the type of legal relationship that the Agency will have with the awardee. Applicants may express a preference for a grant or cooperative agreement if they choose to do so. EPA anticipates that most of the proposals will be cooperative agreements, as usually only discrete research projects are designated as a grant. Each project selected will either be a grant or cooperative agreement; EPA will not mix both types of assistance agreements.

25Q.  What is the difference between matched funds and leveraged funds?

A.  The Brownfields research, technical assistance and training grants are not subject to a mandatory match. Matched funds must be provided as part of the agreement are subject to specific rules in 40 CFR Parts 30 and 31 and the same statutory restrictions as grant funds (e.g., no indirect/administrative costs). If EPA accepts a grantee's voluntary offer to provide matching funds, the recipient will be legally obligated to provide the match. Leveraged funds, on the other hand, further Brownfields goals but do not become part of the assistance agreement. For example if the potential applicant has capacity to raise money for its overhead costs, that is allowable and can be stated as a leveraged capacity in the proposal. A recipient may use leveraged funds for other aspects of a project even if the costs are not allowable under the grant (e.g. marketing properties).

26Q.  Can a grantee use EPA fund to raise private donations to the project?

A.  No. The grantee may not use any of its money from EPA to pay for fund-raising. However, grantees may advise potential donors that it has received a grant from EPA.

27Q.  If there are multiple projects should there be multiple applications?

A.  No. Please create different sections and budgets within one proposal. For activities that cross all three services (i.e., training, research, technical assistance) use your judgment and provide an explanation as to why it has been put in one section or another. EPA may offer partial funding for specific projects.

28Q.  Is there a page limit?

A. Yes. The application must not exceed 15 single-sided pages in length, not including the Cover Page and Budget/Budget Narrative information requested below. Pages in excess of this limit will be removed and not evaluated. Applicants who exceed the 15 page limit bear the risk that their proposal will be rejected on threshold grounds or ranked low if important information is included on the pages which reviewers do not consider.

29Q.  Is there a formal peer review for the research proposals?

A. No. Brownfields research grants under this Request for Applications are not subject to the same formal peer review policies applicable to research funded by EPA's Office of Research and Development and other EPA Offices.

30Q.  To substantiate community need or stakeholder involvement, should news articles and letters of support be included as an attachment? Is this advantageous?

A. Yes. Letters of support and news articles will be considered if submitted with an application. Whether this material is advantageous depends on the nature of the information provided in relation to the proposed project. Attachments must be kept to a minimum, and cannot include photographs. Applicants must make their own strategic decisions on what is the best approach to presenting their proposal.

31Q.  Should a copy of the proposal be sent to the Regional Brownfields coordinator?

A. No. Three copies of the proposal should be submitted to the EPA Headquarters address given in the Request for Applications.

32Q.  Is this a new grant program or have there been awards made in the past?

A. No. EPA awarded Brownfields research, training and technical assistance grants in FY 2003.

33Q.  Is a support letter required from our Congressman?

A. No. A letter of support from your Congressman is not required. However, all letters of support will be considered in review of the applications.

34Q.  The proposal guidelines require the inclusion of Standard Form 424, "Application for Federal Assistance". Does this include forms 424A, 424B, 424C, and 424D?

A. Applicants must submit SF424A and SF424B.

35Q.  The proposal guidelines appear to prohibit reimbursements for administrative expenses deemed reimbursable under OMB Circular A-122 which are necessary to meet the requirements of federal and business activities. Is this interpretation correct? Additionally, the proposal guidelines appear to invite an expanded interpretation of Programmatic Costs. If this is correct, does EPA have any guidance as to what this new standard is and how it should be applied?

A. Yes. The Brownfields law contains a statutory prohibition on using all or part of a Brownfields grant for administrative costs. CERCLA 104(k)(4)(B)(i)(III). Most Brownfields grants are awarded to governmental units. As noted in OMB Circular A-87, Attachment A, Paragraph F., Item 3.a., statutory limits on administrative or indirect costs are in addition to those contained in that Circular. This same principle would apply to costs allowable under OMB Circular A-122 or A-21. Guidance on EPA's interpretation of programmatic costs for this solicitation is found in Appendix A of the Request for Applications.

36Q.  Are for-profit companies completely excluded from being a part of an eligible respondent's proposal? Can a for-profit entity be a sub-contractor on a team led by an eligible responder?

A. For-profit companies are ineligible for funding as a grant recipient or a sub-grantee. The applicant may choose to contract for services or products to a for-profit company. However, as noted in the Request for Applications, recipients must follow the competitive procurement procedures in 40 CFR Part 30 or Part 31 when contracting for products and services. Identifying a specific contractor in your proposal does not exempt that transaction from competitive procurement requirements.

37Q.  The RFA asks for a description of "your history of managing federal funds generally". In the case of a university with a professor submitting a proposal, should the applicant provide their own history with federal funds, or the entire University's history?

A. Since the University will be legally accountable for financial management, it should submit information about its history of managing federal funds. EPA would be interested in audit findings and other indicators of financial stewardship. The applicant should also provide programmatic information regarding the professor's qualifications. That is, the University should provide information about the types of projects the professor has managed with federal funding, including project results.

38Q.  Does a copy of an organization's 501(c)(3) status or other documentation of non profit status need to be included in the proposal?

A. No. However, nonprofit applicants must describe how they are eligible for funding. Applicants may choose to provide documentation of non-profit status to EPA as part of their application. EPA may also request additional documentation of nonprofit status.

39Q.  Does this grant program replace EPA's Brownfields Job Training Grant Program?

A. No. The Agency issues a separate Request for Applications for this program. Please note that job training is not one of the three subject areas by this Request for Applications.

40Q.  What is the allowable rate for consultants paid under EPA grants.

A. EPA participation in the salary rate (excluding overhead) paid to individual consultants is limited to the maximum daily rate for a Level IV of the Executive Schedule, which is currently $513.60 per day and $64.20 per hour. This is a statutory restriction that EPA cannot waive.