Learn the Issues
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How do I request a regulatory exception to use an expired ‘fixed rate with carry-forward’ IDC agreement?
For rates that have expired, EPA may approve a regulatory exception to allow a recipient with a fixed rate with carry-forward to continue to use the fixed rate for up to four additional fiscal years after the rate's expiration date. Please note you must submit a regulatory exception to continue…
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How should contractual costs be captured and estimated?
The following details should be included in project narrative Section 3: Identifying Key Personnel and Associated Roles, Responsibilities, and Qualifications, if a proposed project includes a contractor or individual consultant: anticipated project roles and responsibilities, the planned method of acquisition, and the planned method of vetting to ensure the selected…
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Can the entirety of a proposed project’s budget just be contractor costs? Are there any additional requirements?
In the case that 100% of requested funds will be distributed as a contract or subaward, applicants must explain how these transactions will be managed in compliance with applicable Federal requirements without project funding for personnel costs. In other words, how will the applicant pay for management of the contract…
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Contractors often provide estimates based on milestones e.g., data migration. Is it okay to provide that, rather than the hourly rate that the budget narrative requests that we use?
Our standard format for how contractual costs can be captured is hourly rate times the number of hours. If you are able to do so, please just work this table backwards to fit our standard rate. So, if the total amount is $30,000, you could put in an estimated [standard]…
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Can an applicant propose grant funds for inclusion on a known EN contract through in-kind funding?
In-kind grant support via an EPA contract is allowable; however, the availability of this option varies from EPA program to EPA program and is contingent upon there being an available EPA contract. EN Project Opportunities include a section on available in-kind funding; if this section is missing from the opportunity…
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Can you give more direction on the non-competitive procurement?
EPA approves noncompetitive or sole-source procurement only under very specific circumstances according to 2 CFR 320(c) : The aggregate amount of the procurement transaction does not exceed the micro-purchase threshold (see paragraph (a)(1) of 2 CRF 200.320(c)); The procurement transaction can only be fulfilled by a single source; The public…
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Can you give an example of an allowable use of non-competitive procurement?
An existing relationship or a history of prior work completed by a contractor or vendor does not justify the use of non-competitive procurement. Similarly, proximity of a contracting firm to an applicant’s organization is not sufficient reasoning. One example of a potential valid use of non-competitive procurement may be: “After…
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Is use of the contractor, Enfotech, and their products allowable for our project? Their product isn't freely shared, but other states that have purchased it will benefit from what we build. It will become part of the "off the shelf" system that others can use.
This is allowable, assuming the requirements for procuring a contractor as detailed within the SN are met; see SN Section 4B ‘Applicants Using Contractors’.
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Are there any restrictions regarding the partnership with other agencies or entities?
There are multiple requirements as related to EN Partnerships that must be met to be considered for award. For example, eligible partners must be separate units of government; EPA will not consider partnerships formed from within a single state, territorial, or Tribal government as eligible. Please carefully read the eligibility…
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Could two federally recognized Tribes in the same geographic region comprise an eligible partnership?
Yes, two different federally recognized Tribes in the same geographic region may apply for funding as an EN partnership, as these are two distinct governments. Additionally, a noneligible Tribe (e.g., one that is not federally recognized) may partner with an eligible one in the same geographic region, if the eligible…
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If we partner with another state, would we have the opportunity to apply for this grant on our own in future years? Can we apply again next year and if not, when would we be eligible to apply again?
In a partnership agreement, there is a lead applicant and the partner or partnering organization(s). The lead applicant cannot have more than four active Exchange Network assistance agreements as of December 31 of the prior calendar year (so 12/31/24 for FY25 grants). Therefore, you can apply in subsequent years as…
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What sections of the SN should I familiarize myself with, if I am interested in applying as an EN partnership?
Applicants interested in applying as a formal EN partnership should review the following sections of the SN: Section 3A: Purpose, Priorities, and Activities, to see any EN Project Opportunity and/or activity restrictions for partnership awards; Section 3D: Funding Type, for information on subawards; and Section 4C: Coalition (EN Partnership) Applications…
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What are the reporting requirements for a partnership agreement?
Per the Exchange Network Terms and Conditions, partnering organizations must report on their sub-awardee activities in both the semi-annual reports and final reports. This includes: Summaries of results of reviews of financial and programmatic reports. Summaries of findings from site visits and/or desk reviews to ensure effective subrecipient performance. Environmental…
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Can you clarify who is confirming partner participation in ‘Additional Attachment C: Formal Project Partners?
For each participating partnering organization, there should be a letter provided by the partnering agency that confirms that organization’s participation in the project. That letter can be addressed to either the lead applicant or EPA, and the content is standardized. We just need to see something on that organization’s/agency’s letterhead…
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What constitutes "an overview" of subaward budget as requested in Additional Attachment C: Formal Project Partners?
A spreadsheet with line items is fine – basically, if money is going to be passed to the partnering organization via a subaward, that subaward amount should be explained. So, if $100K is going to be given to the partner as a subaward, what will that money be used for…
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Do the restrictions on non-competitive procurement for contractors also apply to sub-awardees (EN partners)?
Contractual procurement restrictions do not apply to partnering organizations receiving funds from the lead applicant in the form of a subaward under the Exchange Network grant program. If you are working with another organization as part of a EN partnership assistance agreement, you are required to submit 'Additional Attachment C…
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For a partnership grant, is it okay to have part of the work be for the partnership and the rest for one of the participating organizations only?
The goals and outputs for the proposed project may include work for just one of the organizations, in addition to goals and outputs that encompass both organizations. The EN Grant Program would just caution that the work must be in alignment with the requirements of the EN Grant Program (supporting…
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What is a node?
A Node or Network Node is a server running specialized software that initiates and responds to requests for environmental information from Exchange Network partners. The requests and responses use common formats expressed in eXtensible Markup Language (XML) and conform to the Exchange Network protocol and specifications. A Node can initiate…
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What is a node client?
A node client is a software application that allows a user to send data to Exchange Network nodes using Exchange Network services but cannot listen to requests or other messages coming from nodes. It allows for human-to-machine communication as opposed to machine-to machine communication. Node clients are easy to install…
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Can you expand on the funding restriction around ‘operations and maintenance (O&M)’?
During O&M an asset is in operation and produces the same product or provides a repetitive service. Maintenance is the activities necessary to keep an IT asset functioning as designed. This includes operating system upgrades, technology refreshes, and security patch implementations. Maintenance excludes activities that expand the capacity of an…