Clarifications on the Request for Application for Brownfields Training, Research, and Technical Assistance Grants and Cooperative Agreements

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 costs under the confines of this grant?

Reporting costs attributable to a specific Brownfields grant may be billed on a fees 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.

How are proposals compared to each other? Are they categorized by proposal amount?

Proposals are scored by the review panels 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 distribution of funds, avoiding duplication of other EPA financial assistance programs, and ensuring that the needs of state, local, and tribal co-implementors of the Brownfields law are met.

Proposals are not categorized by proposal amount.

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

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

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

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

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

These grants are not intended to be site specific. Applicants may target particular brownfields sites, communities or constituencies or population groups.

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

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 foundation or private funding for environmental projects would also be relevant.

Can computers and printers be programmatic costs?

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 solely for activities related to the project. When this equipment is no longer needed for the Brownfields grant, it must be disposed of under the applicable provisions of 40 CFR Part 30 or 31.

Can a percentage of rent be an acceptable programmatic cost?

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, 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.

Does the length of performance matter?

No. EPA traditionally awards multi-year grants. EPA commitments to fund multi-year grants are subject to the availability of appropriations, and satisfactory grantee performance.

What is the timeline for the award?

The applications are due April 14, 2003, and the plan is to make the awards and provide funding by the end of the fiscal year (i.e., September 30, 2003). This is the typical EPA grant cycle.

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

Yes.

If Congress makes a change to the administrative cost prohibition, how will this affect the grants awarded in Fiscal Year 2003?

Whether the change applies prospectively (i.e., after FY 03) 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.

Are these grants similar to GSA's MOBIS contracts?

No. MOBIS is a contractual vehicle that the Government uses to obtain services for its direct use or benefit. Grants and cooperative agreements are used to stimulate and support public purposes: the principal purpose of Brownfields research, training and technical assistance grants is to develop information, products and services for the use and benefit of non-Federal Brownfields stakeholders.

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

Yes. Also, if a multi-year proposal is awarded 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.

Does EPA have a database of information on current pilots/grantees?

Yes. EPA has a database of pilot/grantee information for its assessment, cleanup, job training and Revolving Loan Fund grants that it plans to post on the web within the year with read-only access.

Do the proposals for multi year funding requests need to address projects for all years covered by the application?

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 should be specific. Adjustments will be allowed, but the basic project must be well defined.

Is there a set curriculum for training assistance?

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.

Is the proposal budget negotiable?

Yes. EPA may work with the applicant to adjust the budget and fund part of a proposed project.

Is EPA planning on being involved in the projects?

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.

Is there a mine-scarred land database?

Not specifically, only if they are an existing Brownfields pilot/grantee. Currently, there are pilot grants in Colorado and Pennsylvania. EPA has received 40 new grant applications from communities with mine-scarred lands but have not yet chosen those to be awarded.

Can existing research grants be supplemented by these grants?

No. These grants will be awarded under new agreements that reflect the purposes and limitations of the new Brownfields grant authority. However, applicants may discuss how a project furthers or expands on previously funded Brownfields research grants in an effort to demonstrate why funding a new grant would be appropriate.

How many grants will be awarded?

There is no set number, it depends on the mix of proposals received.

How many assessment grants will be awarded this year?

Approximately 95 assessment grants will be awarded this year. In addition, approximately 50 Revolving Loan Fund grants will be awarded.

As it is a cooperative agreement, does EPA provide additional resources?

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.

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

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.

What is the difference between matched funds and leveraged funds?

The Brownfields research, technical assistance and training grants are not subject to a mandatory match. Matched funds 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, 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. The applicant may not use any of its money from EPA to pay for fund-raising.

If there are multiple projects should there be multiple applications?

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.

What is the definition of research?

EPA will use the definition of research found at 40 CFR 30.2(dd). Please note that for the purposes of Brownfields grants, EPA has interpreted "research" to include study that extends to socioeconomic, institutional, and public policy issues as well as the "natural" sciences.

Is there a page limit?

No. There are no limits, but page lengths have been suggested in the Request for Applications (i.e., 1-3 pages for the overview, 2 pages for response to threshold criteria, and 15 pages for response to ranking criteria not including attachments for the project plan, technical assistance approach, training approach, and letters of support).

Is there a formal peer review for the research proposals?

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.

Please provide a more detailed description of the Budget Categories.
The budget categories are broad due to the nature of the projects. The applicant should enumerate tasks and activities that correspond with the budget categories so that the reviewer may get an idea of how the federal funds will be used.

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

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. Applicants must make their own strategic decisions on what is the best approach to presenting their proposal.

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

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

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

This is a new grant program authorized by the recently enacted Small Business Liability Relief and Brownfields Revitalization Act.

Is a support letter required from our Congressman? Is this advantageous?

No. A letter of support from your Congressman is not required. All letters of support will be considered in review of the applications. Whether this material is advantageous depends on the nature of the information provided in relation to the proposed project. Applicants must make their own strategic decisions on what is the best approach to presenting their proposal.

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

Applicants should submit SF424A and SF424B.

The proposal guidelines appear to prohibit reimbursements for 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?

Yes. The new 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.

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?

For-profit companies are excluded from being 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 Proposal Guidelines, 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.

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?

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.

Does a copy of an organization's 401(c)(3) need to be included in the proposal?

Yes, an organization should provide a copy of the 401(c)(3) documentation as an attachment to the proposal.

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

No.

If we are proposing to implement Brownfields training under Community Involvement, can we use the funds to support the following types of activities: life skills/employability skills training, participant supportive services (e.g., transportation, safety glasses, work clothes, physicals, etc.), case management, job coaching and follow-up support, and employer assistance services?

The funds cannot be used for life skills/employability skills training.

The other activities listed would be considered to be within the terms of the Request for Applications. However, EPA also published "Proposal Guidelines for Brownfields Job Training Grants". The Brownfields Job Training Grants program provides successful applicants financial assistance to provide job training to residents in communities impacted by brownfields and to empower local community residents. Ultimately, whether the proposal is funded depends on how it is scored against the ranking criteria.

What is the allowable rate for consultants paid under EPA grants?

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.

How should sub-grantee budgets be presented? Does EPA have a preferred budget format for coalition applications?

Sub-grantee budgets should be incorporated into the primary applicant's budget. The grantee can provide an explanation of which organization will be responsible for the various tasks and activities in the budget narrative section of the proposal. As noted above, applicants must follow competitive procurement procedures to obtain services and products. The fact that an organization is a non profit does not automatically mean that the transaction is a sub-grant. The nature of the transaction must be one of assistance to support the sub-grantee's own program-sub-grants cannot be used to acquire commercial services or products that the recipient will use primarily to support its own organization. See 40 CFR 30.2(ff) and CFR 31.3 Grant, Subgrant, and Subgrantee; OMB Circular A-133, Section ___.210.