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Pollution Prevention (P2)

Frequent Questions FY18 - FY19 Grant Request for Proposal

Below are the responses to questions asked during and after the P2 Grant Program Webinar held March 21, 2018. Questions are divided among the following six categories:

  1. Definitions
  2. P2 National Emphasis areas and regional focus areas
  3. Eligible Applicants
  4. Proposal Submission Process
  5. Funding
  6. Resources

1. Definitions

Please define "PPA"?

Answer: PPA refers to the “Pollution Prevention Act”. In 1990, Congress passed the Pollution Prevention Act which states: "the Environmental Protection Agency must establish a source reduction program which collects and disseminates information, provides financial assistance to States, and implements the other activities...."

EPA is responsible for implementing the law passed by Congress. The law can be found online at https://www.epa.gov/p2/pollution-prevention-act-1990.

What is pollution prevention?

Answer: Pollution prevention or P2 is also referred to as source reduction. These terms are considered by the P2 Program to be synonymous. They are defined to mean reducing or eliminating waste at the source by modifying production processes, promoting the use of nontoxic or less toxic substances, implementing conservation techniques, and/or reusing materials rather than putting them back into the waste stream. 

Carrying out P2 or source reduction may involve: equipment or technology modification, process or procedure modification, reformulation or redesign of products, substitution of raw materials for more environmentally-preferable materials, offering training or technical assistance to reduce or eliminate waste at the source, implementing inventory control to secure chemicals from being released into the environment, etc.

What is the definition of hazardous waste for these grants?

Answer: The P2 program uses the term hazardous materials.  The term hazardous materials is used in a broad sense to include federally or state regulated pollutants, including Clean Air Act criteria pollutants and Clean Water Act water quality criteria pollutants and conventional pollutants, but excludes items generally considered of low hazard, recyclable or divertible, such as paper products, cans, iron and steel scrap and construction waste. Hazardous releases to air, water and land are included in hazardous materials.

How does EPA define technical assistance/training?

Answer: EPA’s P2 grant program interprets technical assistance/training to mean encouraging adoption and implementation of source reduction which may include, but is not limited to:

  • Best Management Practices – Identifying, developing and documenting P2 best management practices or new P2 tools for businesses and disseminating the approaches and outcomes for others to replicate;
  • On-site Technical Assistance – Conducting on-site technical assistance for businesses/facilities on source reduction approaches; 
  • Safer Chemical Use – Helping businesses assess and then redesign their operations, processes and supply-chain practices by replacing harmful toxic chemicals with safer chemical alternatives;
  • Training – Conducting rudimentary, intermediate and/or advanced P2 trainings on use of P2 tools, adopting P2 approaches on preventing or reducing the release of hazardous materials or adopting environmental management system protocols; 
  • Community-based P2 –Enhancing existing or creating new community-initiated or community-based projects focused on P2 to help businesses decrease their environmental footprints; and,
  • P2 Themed Roundtables and Meetings – Organizing business or community collaborations where P2 opportunities and solutions are identified, developed, enhanced, shared and follow-up is conducted with participants to track and record behavioral change.    

2. P2 National Emphasis Areas                                  

Should the proposal address all three National Emphasis Areas (NEAs) or is it ok to address just one?

Answer: Proposals do not need to address all three NEAs, and it is OK for a proposal to address only one NEA.  Proposals must address one or more of the NEAs.

Under this competition, the three NEAs are: 

  1. Business-Based Pollution Prevention Solutions Supporting Toxic Substances Control Act (TSCA) Priorities and Chemical Safety
  2. Food Manufacturing and Processing
  3. Hazardous Materials Source Reduction in States or Communities

NEA #3 Hazardous Materials Source Reduction in States or Communities, discusses leveraging government resources to address community issues using P2. However, the example of activities in the Appendix A relates more to business rather than cities.  Would a proposal that focuses on leveraging government resources to address city P2 efforts be considered?

Answer: The primary focus of the project must be about providing technical assistance or training to businesses on or about using pollution prevention. Leveraging of resources from project partners or stakeholders (e.g., cities, townships, local governments, etc.) to help carry out the technical assistance and/or training is allowable.

When will the P2 grant and TSCA NEA webinar be held?

Answer: The GoTo Webinar was scheduled on March 29, 2018.  A recording of the webinar will be posted to EPA’s P2 Grant Program page.  

Can you give an example of measurable outcomes for National Emphasis Areas (NEAs) besides pounds of hazardous material prevented?

Answer: The program addresses four outcomes measures each of which are measurable under the NEAs:

  1. Reductions in pounds of hazardous material inputs and of hazardous pollutants released to air, water, and land;
  2. Reductions in greenhouse gas releases (measured in metric tons of carbon dioxide equivalent (MTCO2e);
  3. Reductions in gallons of water used; and
  4. Dollars of cost savings associated with reducing hazardous pounds, MTCO2e and water usage. 

The grantee and the EPA Regional Office may also agree to include other outcome measures, as appropriate, such as measures of changed behavior or knowledge. 

3. Eligible Applicants

Can you clarify who is eligible for P2 grants?

Answer: Eligible applicants under the Pollution Prevention (P2) Grant Program include ONLY the following entities:  State agencies, colleges and universities (that are instrumentalities of the states); federally-recognized tribes and intertribal consortia.

Would a regional planning agency be eligible to apply?

Answer:  No. The Pollution Prevention Act of 1990 authorizes EPA to award P2 grants to states but does not provide a specific definition of what a State means within the statute.  However, the code of federal regulations (CFR) for EPA assistance agreements defines a State to mean, “….any state of the United States, the District of Columbia, the Commonwealth of Puerto Rico, U.S. Virgin Islands, Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, and any agency or instrumentality thereof exclusive of local governments.” 2 CFR 200.90.  Please note however that ineligible applicants may serve as partners or stakeholders on proposed grant projects provided any financial arrangements comply with regulatory requirements and EPA policies.  Please refer to Engaging Partners in Technical Assistance/Training in Section I.F of the grant announcement.

Can the P2 Grant be applied to city governments?

Answer: City governments cannot directly apply for Pollution Prevention (P2) grant funding. Only eligible applicants may apply – refer to the FAQ on eligible applicants.  However, city governments may partner with eligible applicants as subrecipients or otherwise and can be indirect beneficiaries of P2 grant funding. 

Are Alaska Tribal Communities eligible under this program?

Answer: If tribal communities are federally-recognized (as described in 40 CFR 35.663) or serve in intertribal consortia (that meet the requirements in 40 CFR 35.504) they are eligible to apply for funding.

Are for-profit grassroots or similar organizations eligible for these grants?

Answer: No. These groups are not eligible to apply for the P2 Grants.  

4. Proposal Submission Process:

How are proposals to be submitted?

Answer: Proposals must be submitted via Grants.gov or an accepted alternative submission method. For more information, please refer to Section IV of the grant announcement.

What is the page limit for P2 grant proposals?

Answer: The page limit is 13 pages which includes the cover page and the proposal narrative. Resumes, letters of support, budget and timeline tables ARE NOT included in the 13 page limit.

Does the match have to come from the applying organization or can it come from other partners?

Answer: The match can come from the eligible applicant or can come from partners or stakeholders that contribute cash, in-kind goods and services (such as volunteered time, photocopying and printing services, etc.), or third-party contributions consistent with 2 CFR 200.306. Also, university faculty time or effort can be offered as a cash contribution as long as the cost sharing occurs during the assistance agreement project period and while the faculty member is under a continuing contract with the university.

Why does the P2 grant program require a 50 percent match?

Answer: The Pollution Prevention Act of 1990 gives EPA the grant authority to award P2 grants requires applicants to provide a 50 percent match: www.epa.gov/p2/pollution-prevention-act-1990#grants.

Are federally-recognized tribes and intertribal consortia subject to the 50 percent requirement?

Answer: Yes, but there are exceptions. Tribal applicants applying for P2 grant funding will need to document in their proposal how they will address the 50 percent match requirement.  The complete 50 percent match does not need to be applied at the time of award, rather it may be applied at specified intervals during the entire grant period as long as the match requirement is met before the end of the performance period for the grant. 

However, an exception to the match requirement can be made available to tribal P2 grant recipients.  When a tribal P2 grant recipient receives their award, and places their P2 grant within a performance partnership grant (PPG) agreement, the required match for the P2 grant gets reduced from 50 percent to 5 percent.  Only when a P2 grant is placed within a PPG agreement may the match be reduced from 50 percent to 5 percent.

Note:  If the P2 grant should run longer than two years the match will be reassessed by the applicable EPA Regional Administrator to determine if an undue economic hardship continues to exist for the tribe to meet the match requirements. For more information on exceptions to the match requirement, please consult Sections III.C-D of the grant announcement.

Is the 50 percent match required for Insular Area applicants?

Answer: Under the Pollution Prevention Grant Program, the U.S. Virgin Islands, American Samoa, Guam and the Northern Mariana Islands are considered to be Insular Area applicants. If Insular Area applicants request less than $200,000 in total federal grant funding the match requirement is waived, per the Omnibus Territories Act of 1977, as amended, 48 U.S.C. Section 1469a. For more information, please refer to Section III.B of the grant announcement.

Are proposals required to address all of the strategic plan objectives identified in the grant announcement? The threshold criteria noted in the announcement states that applicants are to explain a linkage? Can you please clarify?

Answer: Applicants’ proposals are required to describe the link between proposed grant work and one or more of the agency’s strategic plan objectives noted in the grant announcement.

May contractors/subawardees and/or subcontractors be used?

Answer: Yes.

For Contractors - Grant recipients may hire for-profit firms and individual consultants as contractors provided they comply with the Procurement Standards of 2 CFR Part 200.  (Subcontractors are firms or individuals hired by prime contractors). States follow their own procurement procedures for the most part as provided by 2 CFR 200.317, but are subject to EPA’s 40 CFR Part 33 Disadvantaged Business Enterprise rule. For other P2 grant recipients (eligible tribes, colleges and universities), the Procurement Standards require competition for purchases in excess of $3500 unless the recipient has an acceptable sole source justification.  It is very unlikely that EPA will accept a sole source justification for products and services that are available in the commercial market place such as environmental consulting.  Applicants are advised to not specifically name a contractor or consultant on a grant application UNLESS that contractor or consultant has been selected in compliance with the Procurement Standards. Instead, the applicant should indicate what experience or expertise they intend to contract for to meet the objectives of the project. If a specific contractor or consultant is named, applicants should be able to demonstrate how securing the contractor’s or consultant’s services WILL meet the Procurement Standards.  EPA encourages applicants to review  our Best Practice Guide for Procuring Services, Supplies, and Equipment Under EPA Assistance Agreements for additional information on EPA’s policies on competitive procurement by recipients.

For Subcontractors – Prime contractors may hire subcontractors.

For Subrecipients (a.k.a. Subawardees) – Recipients may provide financial assistance to eligible subrecipients to carry out part of their EPA funded project.  Eligible subrecipients include tribes, intertribal consortia, local governments, non-profit organizations, and institutions of higher education that are either state or tribal institutions or operate on a nonprofit basis.  For-profit organizations or individuals, with few exceptions, are not eligible subrecipients.  An example of an eligible for-profit subrecipient is a manufacturing firm that receives financial assistance to adopt source reduction practices at its facility although recipients may also subsidize such practices as participant support costs when all the firm does is purchase equipment.

Note that as a pass-through entity, a recipient that makes subawards must comply with the subrecipient monitoring and management requirements at 2 CFR 200.330 through 200.332. Among other things, subrecipients must comply with the 2 CFR Part 200 Procurement Standards when hiring contractors.  Refer to Grant Policy Issuance 16-01: EPA Subaward Policy for EPA Assistance Agreement Recipients and applicable provisions of 2 CFR Part 200.

Should I describe subrecipients in my grant proposal?

Answer: Applicants may name specific subrecipents that could represent local governments, non-profits, institutions of higher education, or other groups that would receive some of the money through a subaward (or a pass-through).  Applicants may describe the types of subrecipient they intend to make subawards to as well.  Refer to Grant Policy Issuance 16-01: EPA Subaward Policy for EPA Assistance Agreement Recipients and applicable provisions of 2 CFR Part 200.

5. Funding

What is the budget limit (maximum allowed) per applicant per year?

Answer: Individual grant awards may potentially be in the range of $40,000-$500,000 for the two-year funding period (between $20,000 - $250,000 incrementally funded per year).  The estimations offered pertain ONLY to the federally-funded portion of the grant, not to the total allowable project cost.  If a federal grant award is issued, future incremental federal funding will be contingent on satisfactory performance, funding availability, congressional appropriations and/or other applicable considerations.

Notes:

  • Regions 1, 2, 3, 4 and 7 have set lower federal award funding caps. The capped amounts are noted in Section II of the grant announcement.
  • If an applicant from a region without a funding cap proposes to perform work within a region with a funding cap, then funding cap from the awarding region will be applicable.
  • The match requirement must be applied to the federally-funded portion of the grant.

6. Resources

For additional information, please contact EPA Headquarters or the applicable Regional P2 Grant Program Contact noted below.

EPA Headquarters
Michele Amhaz
Phone: 202-564-8857
Email: amhaz.michele@epa.gov

EPA Region 1 - CT, MA, ME, NH, RI, VT
Lee Fiske
Phone: 617-918-1847
Email: fiske.lee@epa.gov

EPA Region 2 NJ, NY, PR, VI
Alex Peck
Phone: 212-637-3758
Email address: peck.alex@epa.gov

EPA Region 3 DC, DE, MD, PA, VA, WV
Mindy Lemoine
Phone: 215-814-2736
Email: lemoine.mindy@epa.gov

EPA Region 4 AL, FL, GA, KY, MS, NC, SC, TN
Daphne Wilson
Phone: 404-562-9098
Email: wilson.daphne@epa.gov

EPA Region 5 IL, IN, OH, MI, MN, WI
Christine Anderson
Phone: 312-886-9749
Email: anderson.christinea@epa.gov

EPA Region 6 AR, LA, NM, OK, TX
David Bond
Phone: 214-665-6431
Email: bond.david@epa.gov

EPA Region 7 IA, KS, MO, NE
Lisa Thresher
Phone: 913-551-7964
Email: thresher.lisa@epa.gov

EPA Region 8 CO, MT, ND, SD, UT, WY
Melissa Payan
Phone: 303-312- 6511
Email:  payan.melissa@epa.gov

EPA Region 9 AZ, CA, HI, NV, AS, GU
Jessica Counts-Arnold
Phone: 415-972-3288
Email: counts-arnold.jessica@epa.gov

EPA Region 10 AK, ID, OR, WA
Robert Drake
Phone: 206-553-4803
Email: drake.robert@epa.gov