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Region 10 Tribal Environmental GAP Funding

Questions?

For questions about the application process or grant requirements, contact your GAP Project Officer.

Webinar Schedule

EPA Region 10 will host four webinars to assist you in preparing your GAP application:

  1. FY20 Funding Announcement: Overview
    Nov. 15, 2018
  2. EPA's New Indirect Cost Rate Policy
    Dec. 10, 2018
  3. Tips and Forms
    Thursday, Jan. 3, 2019
    1:30-3pm (AKST)
    2:30-4pm (PST)
  4. Tools to Help Develop the Air Quality Components in Your FY20 Work Plan
    Thursday, Jan. 10, 2019
    10-11am (AKST)
    11am-12pm (PST)
  5. Grants.gov: Submitting Your Final Application
    Thursday, Feb. 7, 2019
    10am-12pm (AKST)
    11am-1pm (PST)

You do not need to register in advance.

All the webinars will use the same URL and phone line:

If you have questions about these webinars, contact Susan Conbere (conbere.susan@epa.gov).

This page contains information about how to apply for Indian General Assistance Program (GAP) funding in EPA's Region 10 (Alaska, Idaho, Oregon, Washington).

Budgets and work plans are due January 31, 2019, for work beginning in fiscal year 2020. See due dates below for more information.

On this page:

You can also view/print the FY2020 funding announcement in PDF format below.


I. Overview

The U.S. EPA, Region 10, Tribal Trust and Assistance Unit, is announcing the funding opportunity for Indian E­nvironmental General Assistance Program (GAP) grant proposals from federally recognized tribal governments and intertribal consortia for work to be initiated in federal fiscal year (FY) 2020.

EPA provides GAP financial and technical assistance to tribal governments and intertribal consortia to assist tribes in planning, developing, and establishing the capacity to implement federal environmental programs administered by the EPA and to assist in implementation of tribal solid and hazardous waste programs in accordance with applicable provisions of law, including the Solid Waste Disposal Act (commonly known as the Resource Conservation and Recovery Act, or RCRA). See the Indian Environmental General Assistance Program Act of 1992.

EPA administers this program in accordance with the statute, applicable federal regulations, including 40 CFR Part 35, Subpart B, and national guidance, including the 2013 Indian Environmental General Assistance Program Guidance on the Award and Management of General Assistance Agreements for Tribes and Intertribal Consortia. EPA’s GAP Guidance provides a consistent national framework for building tribal environmental program capacity under GAP and is designed to improve the management of GAP resources.

As described in the GAP Guiding Principles, this support promotes tribal government efforts to develop core environmental program capacities (administrative, financial management, information management, environmental baseline needs assessment, public education/communication, legal, and technical/analytical) and baseline capacities for media-specific programs (e.g., ambient air quality, water quality, managing waste, and other EPA-administered statutory programs).

For a complete list of the legal authorities relevant to GAP, please see Legal Provisions and Policies Applicable to EPA's GAP Guidance.

A. Guiding Principles

EPA will apply the following Guiding Principles in awarding GAP grants to tribes and intertribal consortia:

  1. Ensure tribal governments have the opportunity to build the capacity to:
    1. Implement federal environmental programs through EPA delegations, authorizations, and primacy designations. See Tribal Assumption of Federal Laws - Treatment as a State (TAS).
    2. Meaningfully participate and engage in environmental protection activities that inform, support, or enhance direct implementation under federal environmental statutes administered by EPA.
  2. Promote tribal self-governance by working closely with tribes to:
    1. Accomplish tribal environmental program goals in EPA-Tribal Environmental Plans (ETEPs) that reflect federal environmental program areas of need to protect human health and the environment.
    2. Support tribes’ development of strong core environmental program capacities for media-specific programs administered by EPA.
    3. Foster tribes’ capacity to assume the authority to implement programs administered by EPA (e.g., Treatment as a State status or through Direct Implementation Tribal Cooperative Agreements).
  3. Promote intergovernmental collaboration and cooperative federalism among EPA, tribes, states, and other partners, and focus EPA financial and technical assistance to protect human health and the environment.
  4. Support implementation of established solid and hazardous waste regulatory programs in accordance with the purposes and requirements of applicable provisions of law, including the Solid Waste Disposal Act (commonly known as the Resource Conservation and Recovery Act).
  5. Maintain strong national program management practices to produce compelling results that align with EPA’s statutory authorities.

These Guiding Principles underscore GAP’s role in fostering partnerships between EPA and federally recognized Indian tribes through collaboration and shared accountability. In addition, they clarify how activities funded under GAP will support EPA’s priorities consistent with the:

EPA’s management of GAP will continue to strive to support all federally recognized tribes that are building capacity to implement the full spectrum of environmental regulatory programs administered by EPA.

See the GAP Guiding Principles Memo (Attachment A below).

B. Due Dates

Steps

Due Date

1.Review the Notice of Funding Availability.
  • EPA issues Notice of Funding Availability in November 2018.
2. Submit budget(s) and a work plan (and narrative if applicable) to your Project Officer. All applicants must submit a narrative once every four years.
  • EPA invites GAP funding requests from $75,000 to $128,000.
  • Budgets and work plans (and narratives if applicable) must be postmarked, hand-delivered, faxed or emailed to EPA or submitted in the new version of GAP Online no later than January 31, 2019. If budgeting for indirect costs (or requesting indirect costs in your budget), submit a copy of your approved indirect cost rate, proposal for a new rate, or an exception request. PPG applicants wanting a match waiver must submit match waiver requests with their proposals.
3. Obtain a DUNS Number if you do not have one.
4. Register with the System for Award Management (SAM).
  • The EBiz POC/Entity Administrator must renew your organization's SAM registration annually. EPA recommends registering by December 1, 2018. Visit Register with SAM at Grants.gov.
  • Reminder: Tribes registering in SAM need to submit a notarized letter appointing their authorized Entity Administrator.
5. Register in Grants.gov.
  • Check that the applicant’s registration in Grants.gov is current and that the person submitting the funding request is a registered user. Visit Organization Application Registration at Grants.gov.
  • EPA recommends registering by February 1, 2019. Registration can take up to a month.
6. Submit consortia eligibility documentation once every four years.
  • Intertribal consortia resolutions (or other supporting documentation) from all GAP-eligible member tribes, authorizing the consortium to apply for and receive funding on their behalf, are due to EPA by March 15, 2019.
7. Enter the final application package into Grants.gov.
  • After negotiating the work plan and budget, your Project Officer will ask you to submit the application package into Grants.gov (see Attachment F below).
  • EPA expects applications to be submitted by the date applicants negotiate with their Project Officers.
  • No GAP applications will be accepted after May 24, 2019. PPG applicants should also strive to submit applications by this date.
8. EPA issues FY20 GAP awards to tribes and intertribal consortia.
  • FY20 GAP awards will be made to tribes and intertribal consortia no later than September 30, 2019.
9. EPA hosts webinars for applicants.
  • EPA Region 10 will host a variety of webinars related to the FY20 Notice of Funding Availability (see "Webinar Schedule" sidebox).

C. Highlights

Updated!Optional Proposal Review Checklist: The proposal review checklist has been updated to make it easier for tribes to evaluate their proposals before submitting them. See Attachment B.

New!Work Plan Template Instructions: EPA Region 10 has developed instructions to help applicants complete the work plan template. See Attachment D.

New!FTE & Component Cost Calculator: EPA Region 10 has provided a new tool to help applicants calculate estimated work hours and component costs for their GAP work plans and budgets. See Region 10 Tribal Environmental GAP Tools.

Updated!Budget Template: The new template clarifies that if Tribal Council members or others not included in the Personnel section of the budget are traveling under the grant, these costs go in the “Other” section of the budget worksheet as Participant Support Costs. Please also provide a justification for the travel. See Attachment E.

New!Requests for Unmet Needs Funding: Provided that GAP funds are available in FY20, EPA will consider additional funding up to $20,000 per tribe or consortium for the GAP-eligible projects applicants choose to address. See Section II.B.

New!Indirect Costs: EPA has a new Indirect Cost Rate policy. The policy defines different approved rate types and includes opportunities for exceptions that can increase options for tribes. See Section IV.C.

New!Narrative Templates: EPA Region 10 has updated the narrative template for tribes and tribal consortia. If you need to submit a narrative, see Attachment C.

New!Application Package: Beginning in FY20, all applicants must include the following forms when submitting applications into Grants.gov: SF-424, SF-424A, SF-424B, EPA Form 4700-4, EPA Key Contacts Form, and Grants.gov Lobbying Form. See Attachment F.

New!SF-424: Examples of the SF-424 are available in Attachment G for PPG and GAP applicants. Please refer to these examples when completing your application.

New!Success Stories: EPA Region 10 encourages – but no longer requires – GAP grant recipients to produce a success story at least once during each four-year grant period. Grant recipients who have a project they would like to share with EPA staff or others can find examples, an optional template, and recommendations to develop a written or video story at Region 10 Tribal Environmental GAP Success Stories.

Tribal Leaders Summit: The Tribal Caucus of the EPA Region 10 Tribal Operations Committee (RTOC) will host a regional Tribal Environmental Leaders Summit March 6-8, 2019, in Portland, OR. Applicants whose tribal leaders and environmental staff are interested in attending in 2020 should include travel for this event in their FY20 GAP work plans and budgets. Details will be posted at 2018 Tribal Leaders Summit.Exit

Webinars: EPA Region 10 will host a series of webinars associated with this announcement (see "Webinar Schedule" sidebox on this page, and through the AK Info Box). Find previously recorded webinars on developing a GAP work plan and budget on the Region 10 RTOC webinars page.

  • FY20 Notice of Funding Availability – Overview: November 2018
  • EPA’s New Indirect Cost Rate Policy: December 2018
  • FY20 Notice of Funding Availability – Tips and Forms: January 2019
  • Tools to Help Develop the Air Quality Components in Your FY20 Work Plan: January 2019
  • Grants.gov: February 2019

D. Funding Priorities

Based on Region 10’s GAP budget allocation, EPA will prioritize applicant funding in the following order:

  1. Individual Tribes. The primary purpose of GAP grants is to build tribal capacity for developing and administering environmental protection programs. Therefore, providing GAP grants to individual tribal governments is our highest priority.
  2. Intertribal Consortia. EPA will consider funding for intertribal consortia after it has funded individual tribes’ proposals. Consortia work plans must meet the capacity-building needs of member tribes without duplicating individual tribal efforts.

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II. Available Funding

Last year, EPA Region 10 was allocated $30,051,000 of the national GAP budget for tribes and intertribal consortia in Alaska, Idaho, Oregon and Washington. The actual amount of GAP funding available in Region 10 for FY20 will be determined after EPA receives its full FY19 budget from Congress.

A. Funding Amounts

Grantees may request funding between $75,000 and $128,000 for FY20, depending on program need and ability to perform the work. Applicants are not guaranteed to be funded at their requested amount. (See Section V.) Applicants with high balances on the current grant are expected to work with their Project Officer to request no-cost extensions or lower levels of additional funding.

Region 10 will determine award amounts based on:

  • Amount of GAP funding Region 10 receives.
  • Number of tribes and intertribal consortia submitting applications.
  • Applicant’s level of unexpended GAP funds.
  • Whether proposed activities are eligible (see Section III).
  • Whether proposed activities meet the review factors, including past performance (see Section V).

Tribes with large reservations may receive a higher level of funding. For Umatilla, Spokane, and Quinault, funding may be up to $155,000. For Coeur d’Alene, Nez Perce, Shoshone Bannock, and Warm Springs, funding may be up to $165,000. For Colville and Yakama, funding may be up to $175,000.

B. Unmet Needs Requests

If funding is available, Region 10 may award up to $20,000 per tribe or consortium for GAP-eligible environmental priorities applicants choose to address.

The following criteria apply for all applicants:

  • The applicant may not be on the high risk list.
  • The applicant must submit a separate budget for the unmet needs funding.
  • The applicant must identify the activities as a separate component in their work plan and include the specific capacity indicators the project will address.
  • The activities must be included as a priority in their ETEP (if a tribe) or the ETEPs of member tribes (if a consortium).

The following criterion applies for consortia:

  • The project must benefit member tribes.

Additional Criteria for Solid Waste Implementation

The following criteria also apply if the applicant seeks funding for solid waste and recovered materials collection, transportation/backhaul, or disposal services:

  • A tribe needs to have an Integrated Waste Management Plan in place (see EPA’s Developing Tribal Integrated Waste Management Plans page).
  • A consortium’s work plan should support implementation activities related to individual member tribes’ integrated solid waste management plans.

C. Period of Performance

Tribes typically apply for new funding every year. However, current GAP recipients are eligible for multi-year funding if they are completing proposed activities as scheduled, submitting progress reports on time, fulfilling closeout requirements, regularly drawing funds down, and meeting all other grant requirements. A separate work plan and budget must be included for each year of funding requested. Applicants should discuss this option with their EPA Project Officer before submitting a multi-year proposal.

All tribes and intertribal consortia that desire funding must reapply for a new grant at the end of their 4-year grant cycle.

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III. Eligibility Information

A. Eligible Applicants

Indian tribal governments (tribes) and intertribal consortia are eligible to receive funds under this program (40 C.F.R. § 35.543). These terms are defined in 40 C.F.R. § 35.502 as follows:

An Indian tribal government (tribe), except as otherwise defined in statute or applicable program specific regulation, is any Indian tribe, band, nation, or other organized group or community, including any Alaska Native village, which is recognized as eligible by the U.S. Department of the Interior for the special services provided by the United States to Indians because of their status as Indians.

An intertribal consortium is a partnership between two or more tribes authorized by the governing bodies of those tribes to apply for and receive assistance under [GAP].

Intertribal Consortia

Funding for consortia will be considered after the needs of individual tribes are met.

Under EPA’s tribal grant regulations, an intertribal consortium is eligible to receive GAP financial assistance when the consortium can adequately document compliance with the following requirements (40 C.F.R. § 35.504):

  • A majority of its members are eligible to receive GAP grants.
  • All member tribes that meet GAP eligibility requirements authorize the consortium to apply for and receive the award.
  • Adequate accounting controls are in place to ensure that only members that meet the eligibility requirements will benefit directly from the award and the consortium agrees to an award condition to that effect.

This means that a consortium may receive a GAP grant even if the consortium includes groups that are not federally recognized tribes, as long as the consortium meets the three regulatory requirements specified above. Authorization of the consortium to apply for and receive a GAP grant is required from all GAP-eligible member tribes. For purposes of determining intertribal consortia eligibility, a “GAP-eligible tribe” is any tribe that meets the definition of Indian tribal government (tribe) in 40 CFR 35.502.

With each new GAP grant application (i.e., at the beginning of each four-year grant cycle), an intertribal consortium must provide EPA with adequate documentation of (1) the existence of the partnership between eligible tribal governments; and (2) authorization by all GAP-eligible member tribes for the consortium to apply for and receive the new or supplemental GAP funding.

This documentation ensures clear communication so that EPA can appropriately consider individual tribal needs and priorities when awarding GAP funds to intertribal consortia. For example, tribal authorization may be provided by a tribal council resolution or other written certification from a duly authorized representative of each GAP-eligible member tribe. Documentation is due to the EPA Project Officer by March 15. Applications that do not contain adequate documentation from all GAP-eligible tribes are incomplete.

As provided in Guiding Principle #2, EPA will award GAP funds to help tribes accomplish their tribal environmental program development goals as outlined in their ETEPs. To further this principle, proposals from intertribal consortia must describe in their work plans how their work plan activities will support the environmental priorities of the GAP-eligible tribes they serve.

B. Allowable Activities

GAP provides funding for activities that build the capacity of tribal governments to plan, develop, and establish environmental protection programs consistent with the federal laws that EPA implements. Tribes must first establish core environmental protection program capacities as provided under Appendix 1 of the 2013 GAP Guidance: Guidance on the Award and Management of General Assistance Agreements for Tribes and Intertribal Consortia (Appendix I) (PDF)(86 pp, 630 K).

Following is a brief synopsis of allowable capacity-building and solid and hazardous waste program implementation activities:

Capacity-Building Activities: Tribal Environmental Program

Capacity building may include developing the appropriate administrative and legal infrastructure, establishing tribal technical capability, and planning and establishing an integrated tribal environmental management program to be implemented by a tribe with technical and financial assistance from other EPA program-specific grants. For more information, see the GAP Guidance, Appendix I: Guidance on the Award and Management of General Assistance Agreements for Tribes and Intertribal Consortia (Appendix I) (PDF)(86 pp, 630 K).

Program Capacity-Building Activities: Waste Management

For recommendations on developing solid waste management capacity, see Appendix I of the GAP Guidance.

Region 10 encourages the development, periodic revision, and implementation of Integrated Waste Management Plans, which outline how a tribe will reduce, manage, and dispose of its solid waste. An effective integrated solid waste management system considers how to prevent, recycle, and manage solid waste in ways that most effectively protect human health and the environment. Visit Developing Tribal Integrated Waste Management Plans.

Implementation Activities: Waste Management

EPA strongly encourages tribes to include work plan tasks that promote the development of a self-sustaining solid waste management program and to consider developing partnerships to increase cost-effectiveness. GAP funds may be used for solid waste implementation activities, including recovered materials collection, transportation, backhaul, and disposal services. To learn about allowable solid waste activities, see Implementation Activities Related to Solid Waste and Recovered Materials that are Allowable for GAP Funding Under the 2016 Consolidated Appropriations Act.

Please note that solid waste implementation activities are allowable past FY20.

Waste Reporting

Tribes seeking financial assistance for solid waste and recovered materials collection, transportation, backhaul, and disposal activities should include a work plan commitment to identify:

  1. Where the serviced materials came from (residential, institutional, or commercial sources).
  2. How much material was serviced (weight/volume/number estimate).

C. System for Award Management (SAM)

For EPA to process grant awards or make payments to grant recipients, the tribe or consortium must provide a valid Data Universal Numbering System (DUNS) number and maintain an active SAM registration. SAM requirements apply to all federal funding.

SAM registration must be renewed at least annually and entities registering in SAM must submit a notarized letter appointing an authorized Entity Administrator. EPA recommends that tribes renew their SAM registrations by December 1 to avoid a lapse in GAP funding. To register in SAM or update an existing registration, go to SAM.gov.

When submitting a grant application, tribes must use the name of the tribe exactly as it appears on BIA’s list of federally recognized tribes. If the tribe’s SAM registration name is not exactly the same as the legal name on BIA’s list, the tribe should contact their local Procurement Technical Assistance Center (PTAC) as soon as possible. Changing a name can take several weeks. Find your local PTACExit. Alaska tribes may also call 1-800-478-7232.

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IV. Proposal Requirements

All requirements must be met prior to receiving GAP funding.

Initial proposals include the following items (by January 31, 2019):

All applicants:
  • Budget(s).
  • Single work plan.
  • A narrative if FY20 is the beginning of the applicant’s four-year grant cycle (see Section IV.A).
All applicants using an Indirect Rate:
  • A current indirect cost rate letter of approval or the proposal to the agency requesting a rate or a copy of the exception submitted to EPA (see Section IV.C).
PPGs:
  • Letter requesting a match waiver if desired (see Section VI).

Current GAP grant recipients should direct questions and submit their proposal to their EPA Project Officer.

New applicants that have not received a GAP grant before may submit their proposal to Stacy Murphy, TTAU Manager, US EPA, Region 10, 1200 Sixth Avenue, RAD-122, Seattle, WA 98101-1128, murphy.stacy@epa.gov.

General questions can be directed to Region 10’s Tribal Trust and Assistance Unit at 1-800-424-4372.

A. Narrative

New! EPA Region 10 has updated and simplified the narrative template for tribes and consortia (Attachment C). The narrative is required at the beginning of each four-year grant period.

The narrative should include:

  • A summary of the tribe or consortium’s location, history, culture, membership, and other related information (i.e., is it compacting or self-governance, audit schedule, description of other programs the tribe administers, number of employees, description of personnel and financial policies and procedures, and any history of administrative or financial issues).
  • A list of other environmental funding sources/amounts (both federal and non-federal) that the tribe or consortium has managed or plans to pursue.

B. Work Plan

1. General Work Plan Requirements

Please submit draft work plans in the standardized template, provided in Attachment D.

Work plans must not duplicate prior efforts; they should demonstrate clear progress in building capacity or specify new focus areas. Duplicates of prior work plans will be rejected by the EPA Project Officer and the grant application may be denied.

New and Updated Tools

Proposal Review Checklist: EPA encourages applicants to use the optional proposal review checklist before submitting their work plans and budgets to EPA. The checklist is intended to reduce errors in work plans and budgets and thereby reduce the time required for negotiations. See Attachment B.

FTE & Component Cost Calculator: See the new Region 10 GAP Tools page for an Excel spreadsheet designed to help applicants easily calculate estimated work years and cost per component.

Work plans must include the following elements, which are described in the new Work Plan Template Instructions (Attachment D):

  • Components
  • Capacity Indicators
  • Personnel
  • Long-Term and Intermediate Outcomes
  • Estimated Work Years
  • Estimated Cost Per Component
  • Commitments
  • Outputs and Deliverables
  • EPA Roles and Responsibilities
  • Joint Performance Evaluation Process

2. Mandatory Tasks

The following tasks are mandatory for all applicants:

Update or complete an EPA-Tribal Environmental Plan

In accordance with the GAP Guidance, EPA will work with each tribe to develop and implement an EPA-Tribal Environmental Plan, which sets the stage for stronger environmental and human health protection in tribal communities. The purpose of an ETEP is to develop a complete picture of the environmental issues facing the tribe, and establish a shared understanding of the issues the tribe will be working on and the issues EPA will address. ETEPs are instrumental for tribes and EPA to define mutual roles and responsibilities for environmental protection program implementation on tribal lands and help prioritize tribal work funded under GAP and work conducted by EPA in the tribal arena. GAP work plans should direct funds toward developing program capacities that support the long-term priorities and goals in the ETEP.

Tribes that have an ETEP must include a commitment to work with EPA to update the ETEP the year before it expires. When applying for GAP funding, tribes should describe how their proposals respond to the program development goals documented in their ETEPs.

Tribes and EPA should jointly review the ETEP at least annually and update it as needed to reflect changes in environmental program priorities over time, adjust performance expectations, or account for changing environmental and administrative conditions. Tribes may include activities to update their ETEP in their work plan proposals.

The following guidance applies to any tribe that does not have a complete ETEP (i.e., that includes the four components outlined in the GAP Guidance, Section 4, p. 13 of 22) at the time of applying for GAP funding during Federal Fiscal Year 2019 and beyond:

  • The EPA Regional Office may request approval from the director of EPA’s American Indian Environmental Office to modify its schedule and have a documented agreement for an ETEP completion date later than December 31, 2018. The tribe’s work plan should include a component to finalize the ETEP by the new agreed-upon date. Note: If an EPA regional office fails to establish an ETEP with a tribe in accordance with the approved schedule, EPA may consider the ETEP grant condition to be unmet and the GAP grant could be denied.
  • EPA reserves the right to award new, incremental or supplemental funding only for work plan activities related to finalizing the ETEP.
  • For any tribe seeking GAP funding for the first time or after several years without GAP funding that does not have an ETEP, EPA expects ETEP development to be included as a component of the tribe’s work plan.
Assess Administrative/Fiscal Policies and Procedures

Tribes that do not conduct a single audit must review and assess the tribe’s financial, procurement, and property management policies and procedures to ensure that the tribe’s systems meet the requirements of 2 CFR Part 200. This assessment must be repeated whenever there are substantial changes to the tribe’s financial systems or at least every four years. EPA Project Officers can provide grantees with a questionnaire to use as a guide for performing this administrative self-assessment. Addressing deficiencies in the tribe’s administrative systems is an eligible activity under GAP.

Submit Quality Assurance Documentation

If a tribe plans to conduct any environmental measurements, including sampling and data collection activities and/or use existing environmental data, applicants should include commitments to attend any necessary training, develop a Quality Assurance Project Plan (QAPP), and submit it to their EPA Project Officer. The QAPP must be approved by EPA before grant recipients can conduct environmental measurements. EPA requires grant recipients to demonstrate competency before conducting any activities that involve collecting, analyzing, or using environmental data. Once approved by EPA, QAPPs are valid for 5 years unless changes in the work require earlier updates.

A term and condition will be included in any grants that involve collection of environmental data to ensure competency is addressed. For laboratory analysis, documentation could include an accreditation certificate, a quality manual, or performance testing results. For field sampling, documentation could include standard operating procedures, training documents, or a training protocol specified within the QAPP. Competency may need to be reassessed as a result of staff turnover.

C. Detailed Budget

A detailed budget must be submitted for each year of funding requested. EPA has developed a recommended budget template, provided in Attachment E. The GAP grant does not require cost sharing or matching funds.

Indirect Cost Rate

If your tribe uses an indirect cost rate, please review EPA's new indirect cost policy, guidance, and restrictions, available at RAIN-2018-G02: Indirect Cost Guidance for Recipients of EPA Assistance Agreements.

In summary:

  • Before drawing down EPA funds for indirect costs and/or using unrecovered indirect costs for cost-sharing, recipients must have an approved rate and an EPA-approved budget that includes an indirect cost rate.
  • The policy defines different approved rate types and includes regulatory exception opportunities that can increase recipient options but also require EPA approval. The options include:
    • Use of the 10% de minimis rate even if a recipient has had an IDC rate in the past.
    • Continued use of fixed rates with carry-forward dates for up to four years past the expiration date.
    • Providing exceptions if a recipient has been out of compliance with the indirect cost rate requirements in 2 CFR Part 200 before the effective date of the policy.
  • Applicants may budget for indirect costs in their application if they provide proof that an indirect cost rate proposal has been submitted to their cognizant agency, or if applicants have submitted a request for a regulatory exception. However, it is unallowable to draw down EPA funds for indirect costs until the indirect cost rate or regulatory exception has been approved.

Requesting an Exception for an Indirect Cost Rate

Email your request to OGDwaivers@epa.gov and copy Paula VanHaagen (vanhaagen.paula@epa.gov) by January 31. Please also copy your EPA Project Officer.

Find instructions on what to include in your request under How to Request a Regulatory Exception to Continue to Use an Expiring/Expired Fixed Rate with Carry-Forward on page 5 of the Indirect Cost Guidance for Recipients of EPA Assistance Agreements (PDF)(9 pp, 557 K, About PDF).

Equipment Purchases

Equipment is defined as tangible, non-expendable personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit, although a lower dollar amount threshold can be established by the tribe’s policies and procedures. Purchasing equipment for construction activities is not allowable unless EPA headquarters has reviewed and approved a specific project. ALL equipment purchases require prior approval by the EPA Project Officer and the EPA Grants Unit.

D. Work Plan/Budget Negotiation

EPA Project Officers will contact applicants to negotiate revisions to work plans and budgets and arrange a timeframe for completing those revisions. Tribes are responsible for responding to revision requests within the timeframes negotiated with their EPA Project Officer. EPA will contact the GAP staff member’s Tribal Council if the staff member does not respond to revision requests or make revisions after three documented requests.

Submitting an initial proposal does not guarantee that a grant will be awarded.

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V. Proposal Review Criteria

A. Review Criteria

To qualify for funding in FY20, all applicants must have:

  • Active/updated DUNS, SAM, and Grants.gov registrations.
  • A single or program-specific audit in compliance with 2 CFR Part 200 if the applicant spends $750,000 or more in federal awards annually.
  • Completed an ETEP or included a commitment to complete an ETEP in FY20 (tribes only).
  • Included all information requested in this Notice of Funding Availability in the proposal.

To qualify for funding in FY20, current grant recipients must:

  • Be current with all reporting requirements (progress reporting for current GAP grants, closeout requirements for prior GAP grants, and annual Federal Financial Reports).
  • Be making satisfactory progress (completing workplan commitments, outputs, and deliverables) and if not, have a corrective action plan in place.
  • Be making regular drawdowns per the terms and conditions of the grant agreement and not have an excessive balance of unexpended funds.
  • Have completed an ETEP (tribes only).
  • Have new, non-duplicative activities in the proposed work plan and budget compared to earlier awards.
  • Be responsive to EPA requests, including responding to emails and phone calls in a timely manner.

Grant recipients with a history of performance issues should submit a statement describing those issues and how they have been resolved.

Grant recipients that are out of compliance with the regulatory, programmatic, or administrative terms and conditions of their existing award may be denied funding, receive a reduced award, and/or be designated as "high risk."

GAP applications will also be reviewed to determine:

  • Do the proposed work plan activities build the applicant’s administrative and environmental program capacity consistent with the GAP Act, GAP Guidance, and GAP Guiding Principles? ­
  • Do the proposed activities include well-defined, achievable commitments, outputs, and outcomes (environmental results)?
  • Is the proposed budget sufficient to accomplish the proposed project? Proposed costs must be necessary, allowable, allocable, reasonable, and sufficient to accomplish the proposed project.
  • Does the work plan identify the expected intermediate and long-term outcomes of the proposed project? Work plans must identify expected changes in human health or the environment, or in the behavior or knowledge of community members.
  • Do the proposed activities support achieving the priorities identified in the ETEP?
  • Has the applicant included all information requested in this Notice of Funding Availability in the proposal?

B. No-Cost Extensions

EPA may recommend that applicants with a high balance of unspent GAP funding from previous years request a no-cost extension or reduced award. A no-cost extension allows the grant recipient to continue working to complete approved work plan tasks for up to a year using funds from prior years. No-cost extensions are not an option if the applicant is in the last year of a four-year grant. Extensions are not automatic and must be requested by the applicant at least 10 calendar days before the end of the performance period specified in the award document. (2 CFR 200.308)

New funds require new work commitments; a no-cost extension allows time for a grant recipient to successfully complete the commitments in previously approved work plans. No-cost extensions do not limit the amount of funds that may be requested in the future, and they do not reflect poorly on a grant recipient’s future chances of receiving full funding.

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VI. Performance Partnership Grants

Performance Partnership Grants (PPGs) are formed by incorporating at least two eligible EPA grants into a single grant agreement. Since multiple grants are involved, PPG proposals and applications may take longer to develop than single grant proposals. PPG deadlines may vary depending on the type of grants involved; however, tribes should strive to complete their applications no later than May 24, 2019.

New! PPG Match Requirements

Some program funds included in a PPG have cost share requirements. In the first year of a new PPG, the tribal match will be 5% for any program grants with a match requirement.

A Tribe may request a waiver to reduce or eliminate the match requirement if the tribe can demonstrate in writing that fulfilling the requirement would impose undue hardship. The tribe must submit supporting socio-economic documentation in the letter including:

  1. Estimated median household income within the last 2-3 years, or the last census, or poverty level statistics;
  2. Unemployment rate, preferably with a comparison to the local county;
  3. Other socio-economic information that demonstrates hardship in meeting a five (or more) percent match.

After two years, the tribal match will automatically increase to 10% for any programs in the PPG with a match requirement of 10% or greater. If a tribe wants to continue with the reduced match, the tribe must submit a letter requesting the reduced match be continued. Supporting documentation is not required. The re-evaluated match will then hold for the duration of the grant.

To request a match waiver, email a letter to your project officer by January 31, along with your work plans and budget(s). Address the letter to:

Paula vanHaagen
Grants Management Officer
U.S. EPA
1200 Sixth Ave., Suite 155, OMP-173
Seattle, WA 98101

The letter must be signed by the Tribal Council or an authorized representative designated by the Council.

PPG Match Waiver Requirements

  • Year One: 5%
  • Year Two: 5%
  • Years Three and Beyond: 10%

To request a waiver, submit a letter with your initial work plan and budget demonstrating that fulfilling the match requirement would impose undue hardship. The letter must be signed by the Tribal Council or an authorized representative.

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VII. Submission Instructions

A. Project Officer Notification

After EPA Project Officers and applicants complete negotiations of GAP work plans and budgets, Project Officers will ask applicants to submit their full application package in Grants.gov. Notification will include:

  • Amount of tentatively approved funding.
  • Any final requests for revisions.
  • Due date by which the revised application package must be submitted.

B. Grants.gov

All applicants must submit their applications in Work Space in Grants.gov. Applications should be submitted by the date tribes negotiate with their Project Officers (sometime between March 2 and May 24).

No GAP applications will be accepted after May 24, 2019.Tribes and consortia applying for PPGs should also strive to submit applications by this date.

Applications submitted to EPA in Grants.gov must include the following elements. Please see Attachment F for Grants.gov submission instructions.

GAP/PPG Application Requirements

Submit in Grants.gov by date negotiated between the applicant and the EPA Project Officer.

All applicants:
  • Application for Federal Assistance (SF-424).
  • Budget Information for Non-Construction Programs (SF-424A).
  • EPA Key Contacts Form.
  • Pre-award Compliance Review (EPA Form 4700-4).
  • Grants.gov Lobbying Form.
  • Assurances for Non-Construction Programs (SF-424B).
All applicants using an Indirect Cost Rate:
  • A current indirect cost rate letter of approval or the proposal to the agency requesting a rate or a copy of the exceptions request submitted to EPA.

Please note: Once you successfully submit your application in Grants.gov, you will receive two email messages within 48 hours. The first email will confirm receipt of your application by the Grants.gov system, and the second will indicate that the application has been validated by the system. Please forward these messages to your Project Officer.

Once your application has been submitted and transmitted to EPA, do not submit any additional documents in Grants.gov, even if your application contains errors.

Duplicate copies create problems in the award system and may delay application processing. Please work with your Project Officer to correct your application if needed.

C. GAP Online

The old version of GAP Online is no longer accepting new work plans and budgets. GAP grant recipients may enter their final FY20 work plans and upload final budgets in the new version of GAP Online, GO3.

Grant recipients that participate in the GO3 pilot during FY19 will have the opportunity to provide feedback to EPA’s American Indian Environmental Office that will further improve the system.

To access GO3, visit General Assistance Program 3.0 (GO3).

D. Confidentiality

Applicants must clearly mark information in their application that they consider confidential. EPA will make confidentiality decisions consistent with Agency regulations found at 40 CFR Part 2, Subpart B.

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Microsoft Word Versions

Below are Microsoft Word versions of certain documents so you can save and edit them more easily. Free Viewers

Optional Proposal Review Checklist for GAP Applications (Microsoft Word)(2 pp, 45 K, October 2018)

GAP Narrative Template for Tribes (Microsoft Word)(2 pp, 23 K, October 2018)

GAP Narrative Template for Inter-Tribal Consortia (Microsoft Word)(2 pp, 23 K, October 2018)

GAP Standardized Work Plan Template (Microsoft Word)(4 pp, 27 K, October 2018)

Attachments

You may need a PDF reader to view some of the files on this page. See EPA’s About PDF page to learn more.