Tribal Exchange Network FAQs FY23
Exchange Network Grants
- What is the Exchange Network (EN)?
- How does the EN support tribal environmental management?
- How can a tribe get involved in the EN?
- How have tribes used Exchange Network (EN) Grants in the past?
- How do I apply for an EN grant?
- What projects are eligible for an EN grant?
- Which tribal entities are eligible to apply for EN grant funds?
- What is an 'instrumentality of a tribe'?
- What Are Intertribal Consortia?
- How Can My Tribe Apply for an EN Grant?
- What types of entities qualify as Mentors? What types of support can a mentor provide?
- Can tribes request basic grants training from EPA? If so, what is the process for requesting training?
- If I have questions while completing my EN grant application, who can I contact?
- Are tribes limited to a percentage of EN grants funding annually?
- How many EN grants have tribes received?
- If I am a Federally recognized Tribe can I charge indirect costs?
- What documents are required to charge an indirect cost?
- How do I obtain an indirect cost rate agreement?
- What if my agency does not have an approved indirect cost rate agreement?
- Can I use an expired indirect cost rate agreement?
- Does the EN grants program fund Operations & Maintenance costs?
- What has EPA done to address Operations & Maintenance concerns regarding EN grants? Where can I find additional information on this topic?
- As the EN Grants Program does not fund Operations & Maintenance related costs, is there any information to assist tribes with planning for software investments and long-term costs to sustain the work developed under EN grants projects?
- How can I find IT Component Resources that are available for reuse in my EN grant project application?
- Where can I find information about Past Exchange Network Grant Projects?
- What's New in the FY23 SN?
Exchange Network Technical Topics
- What is a node?
- What is a node client?
- What is the Exchange Network Services Center?
- What is the E-Enterprise Digital Strategy?
- What are the three principles of the Digital Strategy?
- Why is the Digital Strategy important when building my project?
- What are Virtual Exchange Services or VES?
- How does the VES approach assist with development and maintenance of data exchanges?
- Are there limitations on who can implement VES?
- What is the difference between Exchange Network Services Center (ENSC) and VES? Which should I use?
- Can I choose to build my own node and not use VES or ENSC?
- If I have a traditional node, can I continue to use it and receive grant funding under the EN Grant Program? If not, how do I transition to a virtual node and virtual services?
- Would an expense such as node maintenance or server upgrades (operations & maintenance) be considered allowable costs under another funding program (e.g., for an air monitoring project under Clean Air Act 103 grant funding)?
Cybersecurity
- What is the Cybersecurity term and condition for EPA assistance agreements?
- How does this term and condition affect tribal EN grant recipients?
Questions Asked During Previous SN Webinar Sessions
- A requirement of the new ‘Individual Capacity Building with Mentorship’ opportunity is that the applicant cannot be a former EN grantee. What if your tribe has received previous EN grants, but not you or your current group of employees. Are we still not allowed to apply for this opportunity?
- Is a current Indirect Cost Rate (IDC) required to apply?
- For Tribal Partnership Grants, should the lead Tribal Nation's Indirect Cost Rate be used and how is it applied for both Tribes?
- If an employee under a Tribal Partnership Grant works full-time for one tribe under the partnership grant and part-time for another tribe under the same partnership grant, would it be acceptable to cover that employee’s salary for each tribe? Or should the employee’s hours be covered under the costs for the lead tribal nation?
- Is there a list or resources available for tribes to find suitable mentors?
- Would two federally recognized tribes in the same geographic region comprise an eligible partnership?
Exchange Network Grants
What is the Exchange Network (EN)?
The Environmental Information Exchange Network (EN) is a partner-inspired, developed, implemented and governed information network for environmental data sharing among EPA, states, tribes and territories. The EN:
- Facilitates the sharing of environmental data, especially through shared and reusable services;
- Streamlines data collection and exchanges to improve timeliness for decision making;
- Increases the quality and access to environmental data;
- Reduces burden and costs for co-regulators and the regulated community; and
- Supports better decisions on environmental and health issues.
How does the EN support tribal environmental management?
The EN can help tribal partners to:
- Increase capacity to collect, analyze, manage, and share data
- Increase access to environmental and health related information to assist the tribe with planning, decision-making, and addressing environmental issues more broadly
- Improve ability to characterize environmental conditions on tribal land and identify resources needed to address issues
- Facilitate information sharing within a tribe's agencies, with other tribes, states and the federal government
- Expedite sharing of environmental data with emergency managers and community members
- Identify and take advantage of tools and resources already created by other EN partners to meet their Information Technology/Information Management needs
- Support compliance with federal regulations
How can a tribe get involved in the EN?
There are many ways for tribes to get involved in the Exchange Network. Tribes in any stage of information management program maturity may apply for Exchange Network grants to build the tribe's capacity to share environmental information with EPA, other EN partners, and the public. Tribes can apply for individual projects or can partner with a more experienced tribe. Tribes can also visit http://www.tribalexchangenetwork.org/ for more information, subscribe to the Tribal EN alerts or subscribe to EN alerts. Tribal representatives can seek assistance from or volunteer to join the Tribal Exchange Network Group (TXG). Tribes may also contact Lydia Scheer (lydia.scheer@nau.edu) with the Institute for Tribal Environmental Professionals (ITEP) or TXG@tribalexchangenetwork.org with EN questions. Interested tribes can also participate in open calls or EN-related meetings and conferences on topics of interest hosted by the TXG or announced via Tribal EN alerts.
How have tribes used Exchange Network (EN) Grants in the past?
Tribes use EN grants to develop the Information Technology (IT), Information Management (IM), and sharing capabilities needed by their tribe to support and improve environmental decision-making. Find out more about the types of activities in which states, tribes and territories are involved by reviewing Previous Exchange Network Grant Projects that were awarded from 2002 to 2020. Below are also some examples of how tribes have used EN grants:
- Provide training and support to participating tribes to submit new data for Quality Assurance/Quality Control, data analysis and upload, geospatial features, and share open dump data via the exchange network
- Provide understandable summaries of water quality data to citizens and partner with a local school to empower and create future environmental leaders
- Collect data using Unmanned Aerial System flight imagery and process, interpret, and store those data
- Provide the foundation to collaborate with other tribal nations to help build tools that allow for better environmental management within each tribe's jurisdiction
- Develop tools to manage and monitor water quality as well as facilitate data exchange and analysis to help examine how environmental stressors are affecting wild rice resources across the region
- Develop geospatial data layers and an application to allow for faster and more effective data sharing for quicker emergency response and recovery
- Focus on air data gathering and transmissions through the Air Quality System to improve data submissions and reduce submission costs and burden
- Build the capacity of 23 tribal programs to consolidate, validate, analyze and share their water quality data to the EPA's Water Quality Exchange (WQX), in order to reduce program workload through more efficient processes and mechanisms
How do I apply for an EN grant?
Tribes interested in applying for an EN grant should download the Solicitation Notice (SN) from the EPA Exchange Network website. The SN identifies EPA's grant funding areas and the types of assistance agreements that are available, provides application instructions, optional templates, and includes evaluation criteria used to score the applications. In addition to the SN, EPA has posted additional documents on the EPA Exchange Network website to assist applicants in preparing successful applications. These documents provide an overview of the notice, as well as tips and tricks for preparing an application that meets all requirements.
What projects are eligible for an EN grant?
Section I-B of the Solicitation Notice summarizes funding areas and general categories of projects that are eligible for funding in the current grant cycle. Specific funding opportunities are listed in Appendix A, Appendix B, and Appendix C.
- Appendix A contains opportunities designed to help agencies adopt innovative business processes, data management practices and services to support their workflows.
- Appendix B includes opportunities designed to eliminate paper submittals and expand e-reporting required as part of EPA programs. Opportunities within Appendix B are created by EPA National Program Offices to help their stakeholders submit and share programmatic data for fourteen EPA programs.
- Appendix C has opportunities intended to support applicants in building the IT and data management capacity to manage their environmental programs and enable increased participation in the EN.
- Examples of capacity-building projects include developing a back-end database or implementing an intra-tribal data exchange.
Grant funds are intended for the development of IT and data management activities and cannot be used for Operations & Maintenance.
Which tribal entities are eligible to apply for EN grant funds?
Eligible applicants for the Exchange Network Grant Program include federally recognized Indian tribes, Alaska Native Villages, and inter-tribal consortia of federally recognized tribes (e.g., the Northwest Indian Fisheries Commission). Other entities, such as regional air pollution control districts and some public universities may apply for assistance if they are agencies or instrumentalities of a tribe under applicable laws. Entities asserting they are instrumentalities of a tribe must provide a certification and supporting documentation from the tribal council or other appropriate tribal government official certifying they are an instrumentality of the tribe. EPA will not accept or review an application which does not include the required documentation.
What is an 'instrumentality of a tribe'?
An instrumentality is an organization created by or pursuant to state statute or tribal laws and operated for public purposes.
What Are Intertribal Consortia?
An intertribal consortium is a coalition of two or more separate federally recognized Indian tribes that join for the purpose of applying for a grant. An intertribal consortium is eligible to receive a grant or Cooperative Agreement from EPA only if the intertribal consortium demonstrates that all members of the consortium meet the eligibility requirements for the Cooperative Agreement, and all members authorize the consortium to apply for and receive assistance.
How Can My Tribe Apply for an EN Grant?
Tribes can apply for resources as an individual applicant or as a partnership. The funding limit on individual grants for FY 2023 cycle is $300,000. For FY 2023, tribes can also apply for Individual Capacity Building with Mentorship which is available to individual applicants who have never been awarded an EN grant. Under this opportunity the tribe identifies a mentor to help them with their capacity building project and may receive up to $15,000 for mentorship support costs on top of the $300,000 threshold for individual capacity building grants (for a possible total of up to $315,000).
Tribes and inter-tribal consortia can also apply for partnership grants which include one or more partners. The funding limit for partnership grants for the FY 2023 cycle is $500,000. Eligibility requirements for partnership grants can be found in Section III-D of the SN.
What types of entities qualify as Mentors? What types of support can a mentor provide?
Mentors should be a tribe, state, or territory that has successfully completed an EN grant and that currently reports or publishes data for one or more environmental programs using an EN node, Virtual Exchange Services (VES), or APIs. Mentoring activities may take place by phone, over web conferencing, or in person, as needed.
Support activities of a mentor may include:
- Demonstrating the mentor's implemented system;
- Providing technical assistance to set up the data exchange;
- Training on data entry, data analysis, and report generation;
- Giving ongoing support after installation:
- Addressing data and exchange questions;
- Providing guidance on submitting reports and completing close-out activities;
- Offering guidance on how to actively participate in the Exchange Network, as well as Tribal Governance Group trainings and assistance.
Can tribes request basic grants training from EPA? If so, what is the process for requesting training?
YES. EPA's Office of Grants and Debarment offers training opportunities for tribal grantees and potential applicants online throughout the year. Sessions include topics related to grants management, new regulations, EPA policies, and more. Training opportunities for grant applicants and recipients can be found here.
EN Grants Specific training: After posting the Exchange Network Grant Program Solicitation Notice, EPA holds webinars on writing an Exchange Network (EN) grant application. EPA's Regional Exchange Network Coordinators hold conference calls and meetings with grantees throughout the year. Information about upcoming trainings and webinars will be posted to this web page. EPA also has a cooperative agreement with the Institute for Tribal Environmental Professionals (ITEP) to support tribal participation in the EN and conduct webinars and trainings on data management. Tribes may also contact Lydia Scheer, ITEP, by email at: lydia.scheer@nau.edu or TXG@tribalexchangenetwork.org with any EN questions.
If I have questions while completing my EN grant application, who can I contact?
Applicants with questions about eligibility can contact EN Grant Program Manager, Erin McGown at ENGrantProgram@epa.gov.
Are tribes limited to a percentage of EN grants funding annually?
No. However, for Fiscal Year 2023, EPA remains committed to awarding at least 20% of the appropriated funds being used to award EN grants to tribes. The amount awarded to tribes may be greater than this, depending on the final appropriated amount for grant programs, the number of applicants, proposed project budgets, the merit of tribal applications, and on the competitive review of all applications. In addition, EPA reserves the right to increase or decrease (including decreasing to zero) the total number and amount of awards under this set-aside, or change the ratio of assistance agreements awarded.
How many EN grants have tribes received?
Since 2002 EPA has awarded 222 Exchange Network grants for a total of approximately $44.7 million to tribes.
If I am a Federally recognized Tribe can I charge indirect costs?
Tribes must have an approved indirect cost rate agreement from the Department of the Interior's National Business Center to apply an indirect cost rate.
What documents are required to charge an indirect cost?
If you wish to include indirect costs in your proposed budget when applying for a grant or cooperative agreement, you must (1) Provide a copy of your current approved indirect cost rate agreement valid until at least September 30th of the current year, or (2) Provide a copy of documentation showing that you have submitted an indirect cost rate proposal to the Bureau of Indian Affairs for approval if you do not have a current approved indirect cost rate or if it expires after September 30th.
How do I obtain an indirect cost rate agreement?
If you do not have a previously established indirect cost rate (IDC), you must prepare an indirect cost rate proposal in accordance with 2 CFR 200 Subpart E, "Special Considerations for States, Local Governments and Indian Tribes." Submit your indirect cost rate proposal to:
National Business Center
Indirect Cost Services
U.S. Department of the Interior
2180 Harvard Street, Suite 430
Sacramento, CA 95815-3317
What if my agency does not have an approved indirect cost rate agreement?
If you have not submitted a proposal for an indirect cost rate (IDC) agreement you may choose one of the following options for including indirect costs in your proposed budget: (1) Select the EPA 10% Default Indirect Cost Rate for the life of the agreement, or (2) Choose not to charge the indirect cost rate for the life for the agreement.
Can I use an expired indirect cost rate agreement?
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 to use an expiring/expired fixed rate with carry-forward request to EPA for approval. Instructions follow below on how to continue to use an Expiring/Expired fixed rate with Carry-Forward:
The applicant/recipient should email the exception request to OMS-ARM-OGDWaivers@epa.gov, copy the Grants Managment Officers (GMOs) when submitting the exception request, and:
- The email subject should be "IDC Regulatory Exception." Include grant numbers for all current grants with the EPA. These numbers are available on the EPA grant award documents, and will start with the Program Code (such as "GA" for a GAP grant) and then eight alphanumeric characters (such as J0110962)
- Include the Recipient Organization's Name, as shown in www.SAM.gov
- Include the Recipient Organizations Unique Entity Identifier (currently the Dunn and Bradstreet or DUNS) Number
- Include the recipient Organization's Contact Information (email address, mailing address, and phone number)
- Include a statement that the applicant/recipient is requesting an exception to the requirement at 2 CFR 200.414© that it charge indirect costs based on an approved rate
- Include a justification for the exception (description of why the exception is needed, any extenuating circumstances that may prevent compliance with the requirement to obtain an approved fixed rate with carry forward prior to expiration)
- Include a copy of the most recent IDC rate agreement; and
- Include any additional information that may help EPA to make a determination
Does the EN grants program fund Operations & Maintenance costs?
EN grants do not fund operations and maintenance costs because these costs would overwhelm the program's grant resources. Instead, EPA encourages EN partners to investigate the possibility of using media program grant funds to support operations and maintenance. EPA understands that operations and maintenance expenditures are of concern to tribes and EPA has tried to address those concerns by leveraging existing Virtual Exchange Services (i.e., virtual node) to minimize the need. The following costs are also not allowable: construction costs, workshops and conferences, pre - award costs, management fees, or the development and deployment of physical partner nodes. EPA includes definitions of operations and maintenance in the solicitation notice.
What has EPA done to address Operations & Maintenance concerns regarding EN grants? Where can I find additional information on this topic?
EPA realizes that Operations and Maintenance is a main concern of our tribal stakeholders. While we cannot fund activities that are considered operations and maintenance, we provide existing Virtual Exchange Services or VES (i.e., virtual node) for select dataflows. VES are free to use and grantees would not have to develop their own node to exchange data. Also see answer to FAQ directly above.
As the EN Grants Program does not fund Operations & Maintenance related costs, is there any information to assist tribes with planning for software investments and long-term costs to sustain the work developed under EN grant projects?
Yes. The resources listed below were developed to help tribal professionals navigate and plan for recurring software costs.
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- Addresses common issues or questions that Tribes experience when they are purchasing software;
- Provides definitions on common terminologies, suggestions on how to fund short- and long-term software needs through the grant process
- Gives suggestions and informational links on technical assistance available to tribal partners.
A Software Procurement Roadmap for Tribes
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- Examines the entire life cycle of the software licensing process as part of the grants work planning process creates efficiencies, less waste, and less burden.
Outlines the steps to consider when purchasing a software license to support grant workplan activities.
How can I find IT Component Resources that are available for reuse in my EN grant project application?
Searchable IT Component and Project Registration Forms. This web area, new in FY23, provides a table of prior EN assistance agreements which met the EN term and condition to complete an ‘IT Component and Project Registration Form’ at the time of grant close-out (see Section VI-B). These forms help to ensure that products and services continue to be available for use and/or collaboration in future EN projects. To reflect an understanding of this registration requirement, applicants must commit to register any newly developed resources (required since 2011) and must also commit to register the reuse of existing resources (required since 2018). Applicants should include these as two explicit commitment statements within the ‘Commitment to Reuse’ section of their project narrative.
Applicants are encouraged to view and explore previously completed IT Component and Project Registration Forms for project ideas and to identify IT components which can be reused in their proposed project. To view these forms:
- Visit the EN website at: https://www.epa.gov/exchangenetwork/searchable-it-component-and-project-registration-forms.
- Use the filters available on the page to search for projects that fit your interest area(s).
- View your results in the page’s populated table, including the grantee organization name, grant number, award year, award amount, and a short project description.
Click the hyperlinked grant number in the project table to view available IT Component and Project Registration Form PDFs that meet your search parameters.
Where Can I Find Information about Past Exchange Network Grant Projects?
Visit the Previous Exchange Network Grant Projects and select a link for the fiscal year you would like to search.
What's New in the FY23 SN?
Potential applicants are encouraged to review the new FY23 Solicitation Notice (SN) in full, as significant updates have been made throughout the document. Notable updates to the FY23 SN include, but are not limited to:
- Increase in the commitment to tribal assistance agreements from 10% to 20% of appropriated funds. (Actual award amounts and number of tribal assistance agreements awarded under the set-aside described in Section I may differ from the estimated amounts for many reasons including the number of meritorious applications received, agency priorities, and funding availability.)
- EPA remains committed to awarding tribal assistance agreements equal to at least 20 percent of the appropriated funds. The actual award amounts and number of tribal assistance agreements awarded under the set-aside described in Section I of the Solicitation Notice may differ from the estimated amounts for many reasons including the number of meritorious applications received, agency priorities, and funding availability. In addition, EPA reserves the right to increase or decrease (including decreasing to zero) the total number and amount of awards under this set-aside, or change the ratio of assistance agreements awarded.
- Increase in funding thresholds:
- Individual Grants: from $200,000 to $300,000
- Applicants applying specifically under the ‘Individual Capacity Building with Mentorship’ opportunity can therefore request up to $315,000 to support mentorship activities (previously $215,000).
- Partnership Grants: from $400,000 to $500,000
- Individual Grants: from $200,000 to $300,000
- Appendix B: Substantial changes made to two funding opportunities: 1) Advanced Water Quality Monitoring Using Sensor Technologies (previously known as the ‘Continuous Water Quality Monitoring’ opportunity) and 2) Safe Drinking Water Information System (SDWIS) - update includes the ‘Drinking Water State-Federal-Tribal Information Exchange System (DW-SFTIES)’).
- Appendix B: Removed Air Quality System (AQS) funding opportunity for FY23
- Appendix D: Removed Shared Services Resources Catalog (SSRC) language and provided new guidance on identifying items for reuse
- Appendix D: Expanded E-Enterprise Digital Strategy Guidance
- Appendix D: Expanded, Streamlined, and revised Budget Guidance
- Appendix E: Updates include:
- Improvements to the format of the project narrative guidance for better clarity;
- Streamlined formatting for the overview of all attachments; and
- New application submission guidance
- Appendix F: Expanded optional pre-submission checklist to help applicants avoid common errors.
- Updated optional templates for the cover letter, project narrative, and budget narrative attachment form
- NOTE: if an applicant wishes to use the optional templates, they should use the FY23 versions
- A new Budget Calculation Tool has been developed for FY23
Exchange Network Technical Topics
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 the submission of data, request data from another node, and respond to a request for data from another node or an application making a data query over the network. Sending data in response to a query is known as publishing. Nodes allow for machine-to-machine communications, which means that data exchanges can be automated. A node has an administrative interface that lets its owner configure and operate it.
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 and use and are available in .NET and JAVA versions. A Node Client Developer Kit (SDK Software) simplifies integrating Node client functions (web service calls) into any software application with just a few lines of script. Examples of clients include:
- Exchange Network Service Center
- Windsor Client
- CDX JAVA Client
- Homeland Emergency Response Exchange (HERE)
What is the Exchange Network Services Center?
The Exchange Network Services Center (ENSC) is a browser-based portal that provides Exchange Network users to a broad range of Network services. Users are able to easily submit data, monitor status of data submissions,, get, and download information from other partners on the Exchange Network. This portal is a:
- "No Frills" web access to Exchange Network services
- Simple, easier-to-use and more intuitive site designed for the less technical program user and more advanced technical users
- Requires no software to install or configure
- Can be accessed from any computer with a browser and internet access
- More personalized experience that allows you to quickly access the services and data that you use most often
What is the E-Enterprise Digital Strategy?
The E-Enterprise Digital Strategy (EEDS) (PDF) (14 pp, 2.3 MB) reflects the evolution of IT and services and, as a living document, will continue to be updated to incorporate new technological developments and changing programmatic needs. The EEDS serves as a high-level framework for an environmental enterprise that is Customer-Centric, Information-Centric, and based on Shared Platforms and Services. The funding opportunities (as detailed in Appendix A, B, & C) within this Solicitation Notice (SN) encompass these principles and will continue to do so in future versions.
What are the three principles of the Digital Strategy?
The three principles of the E-Enterprise Digital Strategy (EEDS) include the 'Information Centric Approach', the 'Shared Platform Approach', and the 'Customer Centric Approach'; click the link in the section above to access the full EEDS text and learn more. An applicant’s guide to the E-Enterprise Digital Strategy has been included in Appendix D of the FY23 Exchange Network Grant Solicitation Notice.
Why is the Digital Strategy important when building my project?
The SN’s Evaluation Criteria (see Section V-A) were updated to better align with the three principles of the E-Enterprise Digital Strategy (EEDS). Seven application scoring points are now directly associated with an application's adherence to the EEDS.
What are Virtual Exchange Services or VES?
Virtual Exchange Services are EPA cloud-based services that support all the functions of a traditional Exchange Network Node but eliminates the need for partners to create and maintain a node server. EPA developed VES in response to requests from EN partners needing more cost- efficient ways to manage and maintain their nodes.
VES can host any number of state, tribal, and territory partner data exchange activities and provide all the same services as a traditional Exchange Network node for the data flows listed in Table 1 below. The VES environment is maintained by EPA while each partner can be provided a secure tenant to configure and implement fully functional data flows with no coding required. Currently, there are no costs to Exchange Network partners for the use of VES other than the charges incurred for partners to implement data flows in their environment (e.g., mapping data, database enhancements, local security requirements). EPA maintains the dataflow templates that allow users to import each dataflow and avoid coding, installation and hardware and software costs for the data exchange process.
For this opportunity, grantees will have to complete the following tasks:
- Create a staging database (format and install code provided on the site)
- Push data into the staging database that is to be exchanged
- Set-up the Internet service bus connection (documented on the site). For more information, see: Virtual Exchange Services
Table 1: Data Flows Supported by VES |
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Air Quality System (AQS) 3.0 |
Integrated Compliance Information System - AIR (ICIS-AIR) |
Emissions Inventory System (EIS) |
Integrated Compliance Information System - National Pollutant Discharge Elimination System (ICIS-NPDES) |
Integrated Compliance Information System – Digital Services (ICIS-DA) |
Water Quality Exchange (WQX v2.1) |
How does the VES approach assist with development and maintenance of data exchanges?
The VES approach simplifies development and maintenance of data exchanges using inheritance features and plug-in support. It eliminates software licensing costs, server costs and much of the administration costs for partners, while providing a simplified development model and greater economies of scale. State, tribal or territorial administrators retain complete control of all aspects of their VES, their data flows and access to their staging tables or databases. VES is currently in production with large and small states, tribes, and air districts. Some states are using VES for new flows listed in Table 1 above and keeping their physical nodes for existing flows.
Are there limitations on who can implement VES?
Certain technical requirements are necessary for successful implementation of VES. Technical Requirements are a Machine Windows 64-bit Internet connected computer with a modern web browser, a Database SQL Server Express Edition, an SQL Server, an Oracle Connectivity Internet Service Bus (ISB) Technical Skill Database processing to move data from source(s) into the staging database. There needs to be an additional Tool or process to map data into the staging table.
What is the difference between Exchange Network Services Center (ENSC) and VES? Which should I use?
To help determine which is the right option for your organization, the VES/ENSC Decision Tree (PDF) (1 pg, 178 K) was created to guide partners to the select the best solution. More information and resources to help your organization decide are available on the Virtual Exchange Services website.
Can I choose to build my own node and not use VES or ENSC?
YES. EPA, however, no longer provides grant funding to build and deploy physical nodes. Furthermore, the Agency does not provide funding for node operation and maintenance.
If I have a traditional node, can I continue to use it and receive grant funding under the EN Grant Program? If not, how do I transition to a virtual node and virtual services?
EN Partners that have their own nodes can apply for grant funding to deploy new data exchanges or for data publishing projects that use their own node. EPA, however, provides funding for partners to leverage existing services for the dataflows supported by Virtual Exchange Services (VES). Please see Appendix A of the FY 2023 EN Grant Solicitation Notice for VES funding opportunities.
Would an expense such as node maintenance or server upgrades (operations & maintenance) be considered allowable costs under another funding program (e.g., for an air monitoring project under Clean Air Act 103 grant funding)?
Some EPA program grants, but not all, allow funds they provide to defray IT/data management or maintenance, and reporting to EPA. A decision on applying funds for Operations & Maintenance in these areas needs to be obtained from the National Program Office to whom the tribe is reporting.
Cybersecurity
What is the Cybersecurity term and condition for EPA assistance agreements?
Cybersecurity includes policies, procedures and technologies that ensure data confidentiality, integrity and availability. As part of EPA's cybersecurity efforts, the Agency wants to ensure that its partners are protecting their data and ensuring that network connections between partners and EPA are also secure. Consequently, EPA has added a Cybersecurity Term and Condition to all assistance agreements, including agreements with tribes. The tribal term and conditions require that the recipient follow all applicable tribal law and policy cybersecurity requirements to protect environmental data it collects and/or manages. (It does not, however, require tribes to establish cybersecurity requirements, only to adhere to requirements that already exist.) Second, recipients that connect with EPA information systems must ensure that machine to machine connections meet EPA security requirements and enter into Interconnection Service Agreements as appropriate. The second requirement does not apply if the tribe is connecting to EPA through EPA's Central Data Exchange, as they already have their own security in place.
How does this term and condition affect tribal EN grant recipients?
This Term and Condition requires tribes to follow applicable cybersecurity requirements. It does not, however, require tribes to establish cybersecurity requirements, only to adhere to requirements that already exist. EPA, however, encourages tribes that do not currently have such requirements to develop them. The second requirement, which concerns connections with EPA, does not apply to EN grants because tribes will be connecting to EPA through the Exchange Network. The Exchange Network already has its own security in place.
Questions Asked During Previous SN Webinar Sessions
A requirement of the new ‘Individual Capacity Building with Mentorship’ opportunity is that the applicant cannot be a former EN grantee. What if your tribe has received previous EN grants, but not you or your current group of employees. Are we still not allowed to apply for this opportunity?
If your tribe has received a previous EN grant award, your organization is not eligible to apply under the Individual Capacity Building with Mentorship opportunity. However, prior grantees should visit the Tribal Exchange Network Group (TXG) website supported by the Institute for Tribal Environmental Professionals (ITEP): Tribes and the Exchange Network to request free technical assistance and training.
Is a current Indirect Cost Rate (IDC) required to apply?
An Indirect Cost Rate is not required to apply for a grant. However, if you wish to include indirect costs in your proposed budget, you must provide a copy of your current approved indirect cost rate agreement in your application package. Please review the Budget Guidance in Appendix D, particularly the section titled “How to Capture Indirect Costs” for more information on this topic and for additional options that are available specifically to tribal applicants.
Please note that all applicants may also elect to use the De Minimis Rate of 10% of modified total direct cost to charge indirect costs in a proposed project.
For Tribal Partnership Grants, should the lead Tribal Nation’s Indirect Cost Rate be used and how it is applied for both Tribes?
Both organizations can charge indirect costs, but each organization must adhere to its own rate agreement (and allowable costs under the base) and you would capture each organization’s indirect costs in separate cost categories.
In the proposed project’s budget:
- The lead organization’s indirect costs would be captured in the cost category of ‘indirect costs’ by applying the current IDC rate (from that (lead) organization’s IDC rate agreement) to the costs allowable under that agreement’s base. This cost is included in the project narrative, budget narrative, and Indirect Charges in the Standard Form 424a
- Indirect costs for a partnering organization should be calculated using their own IDC rate agreement and the allowable base according to that agreement. Please include the IDC agreement of partnering organizations charging indirect costs as an additional application attachment. These IDC costs should be included within the ‘subawardee’ cost under the cost category ‘Other’ and in Section H in the Standard Form 424a.
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- To clarify, all funds that would be going to the partnering organization (including indirect costs) should be captured under a single cost as a subaward under the cost category of ‘other’. So, in the example below, this might include 17,500 towards the two project goals that will be completed by the partner and 2500 in indirect costs for the partnering organization, per their own IDC rate agreement and base.
- The details on how the subawards funds will be distributed to the partnering organization (and how amounts like the partner’s indirect cost was calculated) should be included in the application attachment titled “Formal Project Partners – Roles and Responsibilities and Distribution of Funds’. See the Exchange Network Grants Solicitation Notice Appendix E for more information on this.
If an employee under a Tribal Partnership Grant works full-time for one tribe under the partnership grant and part-time for another tribe under the same partnership grant, would it be acceptable to cover that employee’s salary for each tribe? Or should the employee’s hours be covered under the costs for the lead tribal nation?
You have the option to split your costs across the two organizations, if you choose, but like the response above on indirect costs – you need to ensure that you have costs in the right cost category.
Therefore, in the proposed project’s budget:
- Your costs as associated with the lead organization would be captured in the cost categories of ‘personnel’ and ‘fringe’ (if applicable).
- This would be Sections A: Personnel and B: Fringe Benefits in the 424a Form.
- Your costs as associated with the partnering organization would be captured as part of your overall subaward under the cost category of ‘other’.
- This would be Section H: Other in the Standard Form 424a.
- This subaward should include ALL funds that would be going to the partnering organization, captured as a single ‘subaward’ cost under the cost category of ‘other’.
- In the example below, this might include $15,000 towards a project goal, $3,000 towards personnel and fringe costs not included in the goal cost, and $2,000 in indirect costs.
Important:
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- Indirect costs should be calculated per that (partnering) organization’s IDC rate and base.
- Any fringe costs (if applicable) should likewise be calculated using the fringe rate for this organization/position.
- The details on how the subawards funds will be distributed to the partnering organization (and how amounts like the partner’s personnel/fringe/indirect costs were calculated) should be included in the application attachment titled “Formal Project Partners – Roles and Responsibilities and Distribution of Funds’ (see the Exchange Network Grants Solicitation Notice Appendix E).
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NOTE:
- If you choose to only associate your costs under the lead organization, you would simply capture your cost under ‘personnel’ and ‘fringe’ (if applicable).
- If you choose to only associate your costs under the partnering organization, you would simply add your cost to the overall subaward amount and capture it under ‘other’.
Is there a list or resources available for tribes to find suitable mentors?
For assistance in finding an appropriate mentor, applicants should consider contacting the:
- Institute for Tribal Environmental Professionals (ITEP)
- For suggestions on potential tribal mentors
- Contact Lydia Scheer, Project Manager, at lydia.scheer@nau.edu or Ashley Gries, Senior Program Coordinator - Tribal Exchange Network, at ashley.gries@nau.edu
- Environmental Council of the States (ECOS)
- For suggestions on potential state or territorial mentors
- Contact Kurt Rakouskas, Program Manager, at krakouskas@ecos.org
- Applicants may also find the following websites helpful for identifying potential mentors:
- E-Enterprise Community Inventory Platform (EECIP)
- Previous Projects Page of the EN Website
Would 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 entity is the lead applicant.