Building the Capacity of Drinking Water Systems

Request for Applications: Frequently Asked Questions


Frequently Asked Questions for Small Systems Request for Application

In accordance with EPA's Assistance Agreement Competition Policy (EPA Order 5700.5A1), EPA will respond to questions from individual applicants regarding threshold eligibility criteria, administrative issues related to the submission of the proposal, and requests for clarification about the announcement. However, consistent with the provisions in the announcement, EPA staff cannot meet with individual applicants to discuss draft proposals, provide informal comments on draft proposals, or provide advice to applicants on how to respond to ranking criteria.
Applicants are responsible for the contents of their proposals.

Categories

A. Applicant Eligibility
B. Project Eligibility
C. Threshold Issues
D. Evaluation Issues
E. Timing and Logistics
F. Budget Concerns
G. Funding Clarifications
H. Miscellaneous


A.  Applicant Eligibility:
A1: Am I eligible to apply for the RFA?

Eligible applicants under this competition are nonprofit organizations, nonprofit private universities and colleges, and public institutions of higher education.  Nonprofit organizations described in Section 501(c)(4) of the Internal Revenue Code that engage in prohibited lobbying activities as defined in Section 3 of the Lobbying Disclosure Act of 1995 are not eligible to apply. For-profit organizations are not eligible to apply.

A2: How does EPA define nonprofit organization?
In accordance with the Federal Financial Assistance Management Improvement Act at 31 USC Sec. 6101, the term “nonprofit organization” means any corporation, trust, association, cooperative, or other organization that - (A) is operated primarily for scientific, educational, service, charitable, or similar purposes in the public interest; (B) is not organized primarily for profit; and (C) uses net proceeds to maintain, improve, or expand the operations of the organization.

A3: Are states, municipalities or tribal governments eligible to apply for the RFA?
No, states, municipalities and tribal governments are not eligible to apply. Eligible applicants are described in Section III.A. of the Request for Proposals (RFA), where it is stated: “Eligible applicants under this competition are nonprofit organizations, nonprofit private universities and colleges, and public institutions of higher education. For-profit organizations are not eligible to apply.... Nonprofit organizations described in Section 501(c)(4) of the Internal Revenue Code that engage in prohibited lobbying activities as defined in Section 3 of the Lobbying Disclosure Act of 1995 are not eligible to apply.”

A4: If I have questions regarding this announcement, will EPA respond to them?
It depends.  EPA will respond to questions from individual applicants regarding threshold eligibility criteria, administrative issues related to the submission of the application, and requests for clarification about the announcement.   Questions must be submitted via e-mail (smallsystemsRFA@epa.gov) by October 19th, 2015. Written responses will be posted on EPA’s website at http://www2.epa.gov/dwcapacity/training-and-technical-assistance-small-systems-funding#faqs.  However, EPA staff will NOT discuss draft applications, provide informal comments on draft applications, or provide advice to applicants on how to respond to ranking criteria. Applicants are responsible for the contents of their applications.

A5: A consultant has offered to help my organization prepare our application if we agree to hire her firm as a technical assistance provider if our application is successful. Is that practice acceptable to EPA?
No. Successful applicants must comply with the Procurement Standards in 2 CFR Part 200.317 - 200.326 when acquiring services from consultants and other contractors. These standards require recipients to hire contractors through open competition to the maximum extent practicable. There are a number of firms in the commercial marketplace qualified to compete for the types of services a successful applicant would need to provide technical assistance with EPA funding available under this announcement. 

As stated in section IV. E, Contracts and Subawards, please note that applicants may not award sole source contracts to consulting, engineering or other firms assisting applicants with the application solely based on the firm's role in preparing the application.

A6: May successful applicants charge fees for training and technical assistance services that are funded in whole or in part under their EPA cooperative agreements?
It depends. Under the statutory authority for the cooperative agreements, section 1442(c) of the Safe Drinking Water Act, recipients may not charge fees for training and technical assistance provided to personnel of state and local government agencies. However, the statute does allow recipients to charge reasonable fees to other personnel. Please note that recipients must account for any fees they receive for training and technical assistance funded in whole or in part under their cooperative agreement with EPA as program income under 2 CFR 200.315.

A7: Is the EPA going to provide the actual training, or is this grant opportunity for the small systems to provide their own training, with the assistance of the grant money from EPA?
This funding opportunity is designed to provide funding for eligible non-profit organizations (as described in Section III.A. of the announcement, quoted below). These organizations in turn will provide training and technical assistance to eligible drinking water and wastewater systems and private well owners. Successful grant applicants will provide the training and technical assistance using their own personnel, contracting with other individuals or organizations, or through some other approved mechanism. State and municipal government entities are not eligible for receiving funding under this announcement.

Section III.A. of the Request for Proposals states: “Eligible applicants under this competition are nonprofit organizations, nonprofit private universities and colleges, and public institutions of higher education. For-profit organizations are not eligible to apply.... Nonprofit organizations described in Section 501(c)(4) of the Internal Revenue Code that engage in lobbying activities as defined in Section 3 of the Lobbying Disclosure Act of 1995 are not eligible to apply.”

A8: Can individual non-profit water systems apply for a grant to make improvements to their systems?
No, individual water systems are not eligible for funding under this announcement. It is designed to provide funding to eligible non-profit organizations (as described in section III.A. “Eligible Applicants” of the Request for Applications, quoted below), which in turn will provide training and technical assistance to eligible drinking water and wastewater systems and private well owners.

Section III.A. “Eligible Applicants” of the Request for Applications states: “Eligible applicants under this competition are nonprofit organizations, nonprofit private universities and colleges, and public institutions of higher education. For-profit organizations are not eligible to apply.... Nonprofit organizations described in Section 501(c)(4) of the Internal Revenue Code that engage in lobbying activities as defined in Section 3 of the Lobbying Disclosure Act of 1995 are not eligible to apply”.

A9: In reviewing the application package for this grant I noted that the eligible applicants include nonprofit organizations, nonprofit private universities and colleges, and public institutions of higher education. Can you tell me if a public health agency would be eligible under these grant criteria?
If your public health agency is an agency of your county government, then you are not eligible to apply. For the purpose of this Request for Applications, EPA does not consider units of government such as counties as well as their component agencies to be nonprofit organizations.

A10: This cooperative agreement opportunity would have been extremely useful to us to develop and implement this program but states are not eligible to apply.  Do you foresee any similar funding opportunities for which states will be eligible?
As you state in your e-mail message, in accordance with Section III.A of the competitive announcement, states are not eligible to apply for the funding.  Unfortunately, EPA cannot speculate regarding any future grant opportunities for assisting private well owners for which states would be eligible to apply.  This is EPA’s fourth round of competitive funding for small system training and technical assistance grants, and Congress has stipulated in each case that eligibility is limited to non-profit organizations.  You may wish to monitor the Grants.gov web site in the future to see if there are any other grant competitions that may include states as eligible applicants.

A11: Are tribal consortiums eligible to apply? Could a consortium create a non-profit entity for the purpose of assistance?

This funding opportunity is designed to provide funding for eligible non-profit organizations (as described in Section III.A. of the announcement, quoted below). These organizations in turn will provide training and technical assistance to eligible small drinking water and wastewater (including onsite/decentralized) systems and private well owners. Successful grant applicants will provide the training and technical assistance using their own personnel, contracting with other individuals or organizations, or through some other approved mechanism.

Section III.A. of the Request for Proposals states: “Eligible applicants under this competition are nonprofit organizations, nonprofit private universities and colleges, and public institutions of higher education. For-profit organizations are not eligible to apply.... Nonprofit organizations described in Section 501(c)(4) of the Internal Revenue Code that engage in lobbying activities as defined in Section 3 of the Lobbying Disclosure Act of 1995 are not eligible to apply.”

In accordance with the Federal Financial Assistance Management Improvement Act at 31 USC Sec. 6101, the term “nonprofit organization” means any corporation, trust, association, cooperative, or other organization that - (A) is operated primarily for scientific, educational, service, charitable, or similar purposes in the public interest; (B) is not organized primarily for profit; and (C) uses net proceeds to maintain, improve, or expand the operations of the organization.  In order to be considered a nonprofit organizations entities must be incorporated by the state as a nonprofit organization.  Tribal Consortiums that fall within the definition of a nonprofit organization and are incorporated by the state as a nonprofit organization may apply.  Also, tribal consortiums may create a nonprofit organization for the purpose of applying for assistance.  However, the nonprofit organization must be in existence, incorporated by the state as a nonprofit, at the time of proposal submission.

A12: I work as an environmental engineer for a state drinking water program. I am in the process of starting a nonprofit organization that would apply for the training and technical assistance grants to improve water quality and provide safe drinking water. In the event that the nonprofit organization I started earned a grant, I would quit my job with the state and begin working full time as the technical assistance provider for the nonprofit. Given my position, may I, as acting director of the nonprofit organization, apply for the grants?

Eligibility criteria is describes in Section III.A. “Eligible Applicants” of the Request for Applications states: “Eligible applicants under this competition are nonprofit organizations, nonprofit private universities and colleges, and public institutions of higher education. For-profit organizations are not eligible to apply.... Nonprofit organizations described in Section 501(c)(4) of the Internal Revenue Code that engage in lobbying activities as defined in Section 3 of the Lobbying Disclosure Act of 1995 are not eligible to apply. States, municipalities, tribal governments, and individuals are not eligible to apply.”

In accordance with the Federal Financial Assistance Management Improvement Act at 31 USC Sec. 6101, the term “nonprofit organization” means any corporation, trust, association, cooperative, or other organization that - (A) is operated primarily for scientific, educational, service, charitable, or similar purposes in the public interest; (B) is not organized primarily for profit; and (C) uses net proceeds to maintain, improve, or expand the operations of the organization.

The nonprofit organization must be incorporated by the State at the time of the proposal submission.  If, at the time of application submission, your nonprofit organization has not yet been incorporated by the state as a nonprofit organization, it will not be eligible for consideration.  If the nonprofit has been incorporated by the state at the time of application, then representatives of the nonprofit organization could apply for the grant on behalf of the nonprofit organization.

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B.  Project Eligibility:
B1: The RFA restricts training and technical assistance to small PWSs, serving 10,000 or less people. We have several water system owners including municipal owners, which have both small PWSs and large PWSs. Would these water system owners be eligible for training under the RFA contracts? If so, we have only 1 large system that would not be eligible for the training. Would the selected technical assistance provider be allowed to provide and charge for training to this large system?

The training and technical assistance described in National Priority Areas 1 and 2 is specific to addressing the short and long-term needs of small systems in meeting the requirements of the Safe Drinking Water Act. Personnel receiving training and assistance should be associated specifically with systems that meet the criteria of this funding announcement, namely those systems serving 10,000 persons or fewer. We presume that you are asking whether a technical assistance provider could provide services to a large system without using EPA funds by charging the large system a fee to finance the services. That decision would be up to the technical assistance provider rather than EPA. However, the provider would need to maintain accounting data to demonstrate that it did not charge the cost for providing technical assistance to a large system to its EPA cooperative agreement.

B2: Does an onsite/decentralized wastewater system include an individual home sewerage system?
A home septic system is an example of an onsite/decentralized system. The funding opportunity is intended for technical assistance activities that would help multiple onsite/decentralized systems (e.g., a community, a collection of houses, part of a watershed, a geographic region, etc.) to improve their performance.  In Section I.B of the Request for Applications, on-site/decentralized systems are defined as: publicly-owned or privately-owned onsite or clustered systems used to collect, treat, and disperse or reclaim wastewater from a small community, tribe or service area that are publicly or privately-owned and/or serve tribal communities (with the exception of systems that are owned by U.S. federal entities).

B3: I was wondering if the funds would enable small water systems/disadvantaged communities to update water system planning documents.
A nonprofit organization that received funding under this announcement could potentially provide technical assistance to small water systems/disadvantaged communities to update water system planning documents if such an activity were included in its EPA-approved scope of work. The Request for Applications includes the following as an example of eligible activities:
“Conduct preliminary engineering evaluations to assess treatment, storage and distribution system issues, and identify low-cost alternative technology and management techniques…” (Request for Applications, Section I.B.)

B4: Can you please direct me to information that clearly delineates the types of projects that are eligible to apply for these funds?
For example, I work with a number of small communities who need funds to conduct or update their Technical, Managerial, and Financial assessments for water systems, do planning and/or design work for needed water or wastewater system improvements, and to construct improvements to their systems.
Which of these activities would qualify? And can we request funds for specific communities, or does it have to be broader, i.e. across a number of states?

The types of activities and services that are eligible for funding are described in Section I.B. of the announcement, under “National Priority Areas.” Additionally, the funding opportunity is intended to provide training and technical assistance on a national basis. Applicants are asked to describe a process for consulting with appropriate agencies in each state or territory prior to initiating training and technical assistance activities. This process would take place before assistance is provided to individual communities or systems.
Also, please note that this funding opportunity is designed to provide funding for eligible non-profit organizations (as described in section III.A. "Eligible Applicants" of the Request for Applications), which in turn will provide training and technical assistance to eligible drinking water and wastewater systems and private well owners. States, tribal governments, municipal government entities, and for-profit organizations are not classified as nonprofit organizations and are not eligible to apply under this announcement.

B5: If a county/municipality operates several distinct "systems" that are not connected to each other, and one of these distinct systems serves less than 10,000 people, would it qualify as a "small system," or do we aggregate all the distinct systems operated by single entity to determine "smallness"?
Yes, the system you describe, a distinct system serving 10,000 persons or fewer, is eligible for receiving training or technical assistance from a grant recipient under this funding announcement. However, the Request for Applications also requires funding recipients to prioritize the use of their funds by working with the state or territory where they are providing assistance, to identify the systems in greatest need of assistance. The Request for Applications, Section I.B., "National Priority Areas" states:
" Applicants should also describe a process whereby they will consult with the appropriate regulatory authority (such as the state or territorial primacy agency or EPA regional direct implementation coordinator) in each state or territory in which the assistance is to be expended or otherwise made available prior to providing training and technical assistance in that state or territory.  In particular, applicants should indicate how they will work with the state, territory or EPA to identify the systems in greatest need of assistance; how they will keep those agencies, the EPA grant project officer and appropriate EPA regional coordinators informed regarding the assistance provided; and how they will document these results."

B6: Is this grant just for training or more than that? We are a small private (Board run) drinking water system that serves 1,281 at present. Would this grant help us with repairs/replacement to existing lines? Is there another choice that would be better?
This funding opportunity is designed to provide funding for eligible non-profit organizations (as described in Section III.A. of the announcement, quoted below). These organizations in turn will provide training and technical assistance to eligible drinking water and wastewater systems and private well owners. Successful grant applicants will provide the training and technical assistance using their own personnel, contracting with other individuals or organizations, or through some other approved mechanism. State, tribal and municipal government entities are not eligible for receiving funding under this announcement.
[Section III.A. of the Request for Proposals states: “Eligible applicants under this competition are nonprofit organizations, nonprofit private universities and colleges, and public institutions of higher education. For-profit organizations are not eligible to apply.... Nonprofit organizations described in Section 501(c)(4) of the Internal Revenue Code that engage in lobbying activities as defined in Section 3 of the Lobbying Disclosure Act of 1995 are not eligible to apply.”]
Also, repairs or replacement of existing water lines would not be eligible for funding under this announcement. The funding announcement covers training and technical assistance activities only.

B7: We have a population of 1,779 in our Municipality and are currently undergoing a mandatory upgrade to our waste water treatment facility. We were wondering if this project would meet any of the criteria of the grant monies to be awarded, or if this type of grant is for training only.
This funding opportunity is only for training and technical assistance projects. A project for adding new equipment or upgrading, retrofitting or rehabilitating existing equipment would not be eligible for funding under this announcement.

B8: The RFA states the performance period will be for eighteen (18) months.  May an applicant submit a twelve (12) month period proposal?  If so submitted, will it be viewed negatively?
Section II.A of the RFA states that cooperative agreements funded under this announcement will have a project period up to eighteen months.  Thus, an applicant can submit an application with a project period and milestone schedule that is 18 months or shorter.  The milestone schedule should provide a breakout of the project activities into phases with associated tasks and a timeframe for completion of tasks and an approach for ensuring that awarded funds will be expended in a timely and efficient manner.  In accordance with Section V, criterion number 4 “Milestone Schedule/Detailed Budget,” applicants will be evaluated on a number of factors  such as adequacy and completeness of the milestone schedule, including timeframes and major milestones to complete significant project tasks, and an approach to ensure that awarded funds will be expended in a timely and efficient manner.

B9: Am I to understand that “urban” communities are ok for us to service as long as they are below 10,000 in population?  Is that the same for decentralized WW systems?
As indicated in the announcement, the systems targeted to receive training and technical assistance under National Priority Areas 1 and 2 are "small public water systems," which are defined as "community and non-community water systems serving a population of 10,000 persons or fewer."  The systems targeted for assistance under National Priority Area 3 are "small publicly-owned wastewater systems" or "onsite/decentralized systems".  "Small publicly-owned wastewater systems" are defined as "wastewater systems or treatment facilities that have permitted and actual flows of less than 1 million gallons per day (MGD) and are: owned by a public entity (such as a municipality) or not-for-profit entity (such as regional sewer districts), and/or serve tribal communities (with the exception of systems that are owned by U.S. federal entities). "Onsite/decentralized systems" are defined as "publicly-owned or privately-owned onsite or clustered systems used to collect, treat, and disperse or reclaim wastewater from a small community, tribe or service area that are publicly or privately-owned and/or serve tribal communities (with the exception of systems that are owned by U.S. federal entities)."  There is no size designation for onsite/decentralized systems, and as long as the criteria in the above definitions are met, any of the water and wastewater systems described above may be located in either rural or urban communities.

B10: RFA, Section C, “Providing Training and Technical Assistance on a National Basis”: is this stating that the awardees must provide their training on a national basis?
Providing training on a national basis is not a threshold eligibility criterion that if not met will result in the elimination of the application from consideration of funding.  However, applicants are asked to demonstrate and will be evaluated on their ability to provide training and technical assistance on a national basis.  Section I.C. of the RFA states that applications "...should demonstrate the applicant's ability to and approach to making training and technical assistance available on a national basis."  Section I.C also states that: "Applications will be evaluated based on the criteria in Section V, including the demonstrated ability and described approach to making training and technical assistance available nationally in the maximum number of states and U.S. territories through face-to-face/on-site and/or remote training and technical assistance.  EPA will give priority consideration to applications that describe a flexible approach that tailors the training and technical assistance techniques and resources to address the specific needs of the target audience in as many states and U.S. territories as possible."

B11: In conjunction with the state environmental agency, our college has been running Wastewater programs for several years.  We will be running another class starting late fall.  We are interested in finding out if we qualify for your grant.  This grant would help offset tuition for this program.
Regarding your question as to whether a wastewater program qualifies for the grant, the scope of activities under “National Priority Area 3: Training and Technical Assistance for Small Publicly-Owned Wastewater Systems and Onsite-Decentralized Wastewater Systems to Help Improve Water Quality” includes a range of wastewater-related training and technical assistance activities (see the description starting on page 8, under Section I.B., National Priority Areas).  Applications for National Priority Area 3 must address the two elements of that priority as described in Section I.B.

Please note that applicants should describe their proposed approach to making training and technical assistance available nationally in all 50 states and the U.S. territories as described under Section I.C of the competitive announcement.  Providing training on a national basis is not a threshold eligibility criterion that if not met will result in the elimination of the application from consideration of funding. However, applicants are asked to demonstrate and will be evaluated on their ability to provide training and technical assistance on a national basis. Section I.C. of the RFA states that applications "...should demonstrate the applicant's ability to and approach to making training and technical assistance available on a national basis." Section I.C also states that: "Applications will be evaluated based on the criteria in Section V, including the demonstrated ability and described approach to making training and technical assistance available nationally in the maximum number of states and U.S. territories through face-to-face/on-site and/or remote training and technical assistance. EPA will give priority consideration to applications that describe a flexible approach that tailors the training and technical assistance techniques and resources to address the specific needs of the target audience in as many states and U.S. territories as possible."

B12: The description of NPA 1 on page 4 lists six challenges faced by small public water systems "in providing safe drinking water to their customers and consistently meeting the requirements of the SDWA …", the first of which is "lack of adequate revenue or access to financing"; based on that item being the number one listed challenge can an applicant assume that activities that address this challenge are allowable activities within the scope of NPA 1? 
No. The six challenges faced by small public water systems that are mentioned on page 4 as well as on page 6 are a “general introduction” to National Priority Areas (NPA) 1 and 2, which both relate to small public water systems (by contrast, NPA 3 relates to wastewater systems, and NPA 4 pertains to private well owners).  The rest of the text in each of the NPA descriptions more specifically describes what types of assistance are to be provided in each NPA.  NPA 1 specifically focuses on strengthening technical capacity and helping system personnel to comply with regulatory requirements and increase system resiliency.  NPA 2 specifically addresses building financial and managerial capacity, which includes revenue sufficiency, rate-setting, accessing infrastructure funding sources, and other financial activities.  So, while the need for obtaining funding is a great challenge, it is addressed by training and technical assistance activities under the scope of NPA 2, and is not included in the scope of activities under NPA 1.

B13: Will unique approaches to technical assistance to small PWS be considered?
Yes, unique approaches to technical assistance to small PWS will be considered. Section I.C. of the RFA states that “EPA encourages applications that include non-traditional or innovative approaches in addition to conventional or traditional approaches for training and technical assistance.  The applicant should demonstrate how these non-traditional or innovative approaches in conjunction with conventional or traditional approaches show the potential to more effectively reach the intended audience than only conventional or traditional means.”

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C.  Threshold Issues:
C1: If I put charts and exhibits in my proposal can they be a smaller font than the 12 point font that is required of the body of the proposal?

The RFA does not establish a required minimum 12 point font for the project narrative or any charts and/or exhibits; however, the RFA does indicate that readability is of paramount importance. Section IV.C.2, Project Narrative, states in part
"...It is recommended that applicants use a standard 12-point type with 1-inch margins. While these guidelines establish the minimum type size recommended, applicants are advised that readability is of paramount importance and should take precedence in selection of an appropriate font for use in the Project Narrative." EPA recommends that all of the project narrative, including any charts and/or exhibits is in a 12 point font.

C2: Is there a grant ceiling & floor for applications?
There is a ceiling but no floor for the amount of funds applicants may request. The Request for Applications (RFA) section III.C., “Threshold Eligibility Criteria” states that:  Applications for awards under National Priority Area 1 cannot exceed $1.8 million; applications for awards under National Priority Area 2 cannot exceed $1.178 million; applications for awards under National Priority Area 3 cannot exceed $1.178 million; and applications for awards under National Priority Area 4 cannot exceed $1.7 million.  Applications exceeding these amounts will be rejected.  EPA has not established a minimum amount of funding for applicants.

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D.  Evaluation Issues:
D1: The RFA states the performance period will be for eighteen (18) months.  May an applicant submit a twelve (12) month period proposal?  If so submitted, will it be viewed negatively?

Section II.A of the RFA states that cooperative agreements funded under this announcement will have a project period up to eighteen months. Thus, an applicant can submit an application with a project period and milestone schedule that is eighteen months or shorter.  The milestone schedule should provide a breakout of the project activities into phases with associated tasks and a timeframe for completion of tasks and an approach for ensuring that awarded funds will be expended in a timely and efficient manner.  In accordance with Section V, criteria under Item number 4, “Milestone Schedule/Detailed Budget,” applicants will be evaluated on a number of factors such as adequacy and completeness of the milestone schedule, including timeframes and major milestones to complete significant project tasks, and an approach to ensure that awarded funds will be expended in a timely and efficient manner.

D2: Section II. B., regarding anticipated substantial federal involvement mentions a review of qualifications of key personnel with a caveat that EPA "does not have the authority to select employees or contractors employed by the recipient".  Since staff expertise/qualifications are part of the scoring criteria upon which an award is based, can EPA elaborate on this review?  Is this limited to new employees or contractors selected by the recipient?  What further review of identified staff would be conducted for a successful recipient?
Regarding staff expertise and qualifications of key personnel, the EPA application review panel members will review the information provided by the applicant and conduct their scoring in accordance with the selection criteria.  The information reviewed by the panel includes the project narrative itself as well as biographical sketches and resumes submitted along with the narrative.  If an applicant proposes future changes in key personnel after an application has been selected for funding, then the EPA Project Officer must approve of these changes after reviewing biographical and qualifications information provided by the applicant, before the project can proceed or continue.

D3: Will entities that already provide technical assistance to small public water suppliers have an advantage in the proposal selection phase?  Is this RFA primarily intended for national organizations that work with small water supplies on an ongoing basis?
All eligible applicants, based on the threshold eligibility review, will be evaluated based on the evaluation criteria provided in Section V.A.  Applications will be evaluated on the applicant’s ability to successfully complete and manage the proposed project considering their programmatic capability, experience and community support.  Under the past performance evaluation factors, applicants will be evaluated on their past performance.  Applicants with no relevant or available past performance information or reporting history must indicate that in the application and they will received a neutral score for the past performance criterion. 

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E.  Timing and Logistics:
E1: When does EPA anticipate that awards will be announced?

EPA anticipates making funding awards by Winter, 2016-17, but this is only an estimate, and not a guarantee. 

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F.  Budget Concerns:
F1: Would the selected technical assistance provider be allowed to charge for training?

Under the statutory authority for the cooperative agreements, section 1442(c) of the Safe Drinking Water Act, recipients may not charge fees for training and technical assistance provided to personnel of state and local government agencies. This prohibition on charging fees for training State and local agency personnel extends beyond the 18 month grant period. However, the statute does allow recipients to charge reasonable fees to other personnel. Please note that recipients must account for any fees they receive for training and technical assistance funded in whole or in part under their cooperative agreement with EPA as program income under 2 CFR 200.80.

F2: The RFA states an eighteen-month project period. Do you anticipate that this type of funding would be available in future years?
The funding announcement is based on EPA’s current budget. The Agency is not making any commitment to future funding.

F3: We have a question regarding the application review process. If an applicant applies for a certain amount...e.g., $1,000,000...and after reviewing the applications the agency feels that the work in the proposal is eligible but that there is only $750,000 available. Would the agency go back to the applicant and invite a revised application for the lower amount? Or would the application just be rejected because the amount was higher than the funds available?
EPA would not necessarily reject an otherwise meritorious proposal if the Agency did not have adequate funding to provide the full amount the applicant requested provided the applicant did not request more funding than specified in section III C. 3 of the RFA.
The following provision of the RFA (section II A) would apply:
“In appropriate circumstances, EPA reserves the right to partially fund applications by funding discrete portions or phases of proposed projects. If EPA decides to partially fund an application, it will do so in a manner that does not prejudice any applicants or affect the basis upon which the application or portion thereof, was evaluated and selected for award, and therefore maintains the integrity of the competition and selection process.”

F4: Does EPA have a limit on indirect costs that can be charged?
While there is no “limit”, per se, indirect cost rates must be negotiated with the cognizant federal funding agency in accordance with the procedures in OMB Circular A-122, “Cost Principles for Non-Profit Organizations”.
As specified in the Request for Applications, section IV.B.1.i:
“You must submit a copy of your organization‘s Indirect Cost Rate Agreement as part of the application package if your proposed project budget includes indirect costs.”

F5: If when calculating the total cost, you propose $10 million for the cost of the program plus $1 million for cost share/matching, would the total cost be $11 million which would be over the $10 million maximum or is it looked at that the $10 million would be the award amount and $1 million would be the cost share/match?
The "not to exceed" dollar amounts listed under threshold criterion 3 (under section III.C. of the Request for Applications), include only the requested federal funding, and do not include any cost share/matching amounts. In your example, if an applicant submitted an application requesting $10 million of federal funding and agreed to provide an additional $1 million in cost share/matching, then the application would be evaluated as a $10 million project for the purposes of determining compliance with the threshold requirement in Section III C. 3. The application would comply with the requirement in your example.

F6: When determining cost share/match, can the average hourly wage of the trainees attending the courses be used as cost share?
No. Trainees would not be performing services for the applicant and, accordingly, their wages would not meet the standards at 2 CFR 200.306 for allowability as cost share. Additionally, it is likely that trainees may charge EPA or other federal grants for their salaries and recipients may not use costs charged to federal grants as cost share without statutory authority. 2 CFR 200.306. Applicants may pay trainee travel as a "participant support cost" with their own funds and include those costs as a match. However, EPA has determined that other forms of participant support cost such as trainee stipends or child care expenses are unallowable and applicants may not count these costs towards their cost share.

F7: If the applicant develops curriculum for training delivery, can that curriculum be used as voluntary cost share/match? And if so, who then owns the curriculum?
Yes, provided the applicant can meet the requirements at 2 CFR 200.306 for documenting that the amount of cost share it claims reflects the fair market value of the curriculum. The applicant will "own" the curriculum. However, if the applicant uses the costs (i.e., personnel or contractor expenses) for developing the curriculum as cost share, EPA would have a "federal purpose" license to use the curriculum under 2 CFR 200.315.

F8: If the applicant develops curriculum for training delivery, will the developer be able to use the material developed for systems not targeted by the grant? For example: municipalities larger than the target group.
Yes. The applicant will "own" the curriculum and can use it for its own purposes as long as the cost of the additional use of the curriculum is not charged to this grant.

F9: I understand that according to the RFA, when I am completing the SF424A I include the subgrant/subcontract funding requested in Section h, “Other.”

1. Should I include a separate SF424A for each of the subgrant/subcontracts as an attachment or can I incorporate the explanation of the  subgrant/subcontracts in the Budget Narrative?

2. Do I need to include a copy of each subgrant/subcontracts’ Negotiated Indirect Cost Rate Agreement as an attachment?

No, you do not need to include a separate SF424A for each subgrant and/or subcontract.  Please note that all subgrant funding should be located in the "other" cost category.  All subcontract funding should be located in the "contractual" cost category. Yes, you can include a narrative description of the budget or aspects of the budget found in the SF424A such as "other" or "contractual" in the detailed budget narrative.
Please also see Section IV.E., Contracts and Subawards, for additional information on contracts and subawards as it is unlikely that EPA will accept sole source justifications for professional services, including services provided by individual consultants,that are available in the commercial marketplace. The Agency will not agree to a sole source contract based on a determination that a firm or individual is the “best” or provides “unique capabilities.”
Categorizing an agreement with a commercial firm or individual consultant as a subgrant is not an acceptable practice. EPA does recognize subgrants between educational institutions or between an educational institution and a nonprofit organization provided the funding arrangement meets the standards for a subrecipient relationship described at 210 of OMB Circular A-133.
No, you do not need to include copies of each proposed subgrantee’s Negotiated Indirect Cost Rate Agreement as an attachment.

F10: Under this RFA, are indirect/facilities and administrative costs waived allowed as part of the cost share?
As described in the RFA under Section III.B., “The non-federal cost-share/match… is subject to the regulations government matching fund requirements described in 2 CFR 200.306.” 

2 CFR 200.306(c), which applies to Institutions of Higher Education, Hospitals and Other Nonprofit Organizations, states in part: “Unrecovered indirect costs may be included as part of cost sharing or matching only with the prior approval of the EPA Award Official.”

2 CFR 200.306(i)(3) further states: “The value of donated space shall not exceed the fair rental value of comparable space as established by an independent appraisal of comparable space and facilities in a privately-owned building in the same locality.”

Please consult 2 CFR 200.306 as well as OMB Circulars A-110 and A-21 to further determine the governing rules and cost principles that apply to the specific costs that you are proposing to apply toward the match. 

F11: To reach private well owners, there is a need to market in unconventional ways, including advertising the training and technical assistance developed under this RFA. Is it allowable to include advertising costs in the proposals for this RFA as long as the advertising is only used to market and promote training and technical assistance under this RFA?
Federal grant regulations and policies do not prohibit the use of grant funds to advertise the services offered by the grantee, as long as the advertising is specifically for making the intended audience aware of the specific training and technical assistance services available to them under this grant.  General marketing of the grantee or its services outside of the scope of the specific grant would be beyond the scope of the grant, and would not be appropriate.

Details on what costs are allowable related to advertising and public relations are contained in OMB Circular A-21, “PRINCIPLES FOR DETERMINING COSTS APPLICABLE TO GRANTS, CONTRACTS, AND OTHER AGREEMENTS WITH EDUCATIONAL INSTITUTIONS”, Section J(1), “Advertising and public relations costs.” 

F12: We are a 501c3 but work with many state agencies to assist with onsite system technical training and community outreach. As part of the budget can we allocate funds to reimburse their staff participation?

You asked whether EPA funding available under this announcement for training and technical assistance for small water systems may be used to pay “honorarium” to state employee “consultants” who would provide advice on training programs.  The answer from EPA’s perspective is Yes, provided those payments are not precluded by state law. 

There are two alternative bases for our determination (described below) in the 2 CFR Part 200 Uniform Grant Guidance.  Which one applies depends on how your organization chooses to obtain the advice. Note also that some states, like the Federal government, preclude employees from receiving additional compensation for performing official duties.

If your organizations establishes an advisory council of state employees under 2 CFR 200.422 EPA may authorize your organization to incur direct costs, including stipends and travel assistance, for the membership of such a council.  Your proposal would need to describe the advisory council, the functions it would carry out, and include a budget narrative specifying the payments (amounts, purposes etc.) that your organization would make to the state employees who are members of the council.

If your organization procures consulting services from state employees individually, under 2 CFR 200.320(a) you may enter into “micro-purchase” agreements with the state employees in amounts up to $3500 provided these purchases are equitably distributed among qualified sources to the extent practicable.   Reproduced below is additional guidance on using micro-purchase procedures to acquire consulting services from EPA’s Subaward Frequently Asked Questions which are available at /grants/grants-policy-issuance-gpi-16-01-epa-subaward-policy-epa-assistance-agreement-recipients.

Q. C. 5. Is the $3,500 micro-purchase threshold for one consultant over the life of the assistance agreement?

Not necessarily. 

* Recipients may purchase professional services non-competitively in amounts less than the $3500 micro-purchase threshold with the same consultant more than once during the life of the assistance agreement provided the recipient meets the requirement at 2 CFR 200.320(a) to distribute purchases equitably among qualified sources to the extent practicable.  However, multiple micro-purchases from only one consultant throughout the performance period of the assistance agreement would raise serious doubts regarding the recipient’s compliance with that requirement. 

* Consulting services are widely available in the commercial market-place so if the recipient needs additional consulting services it must make an effort to hire other consultants as well.  Note that it may be more efficient for the recipient to use 2 CFR 200.320(b) small purchase procedures to obtaining proposals from an adequate number (at least 3) of sources for a contract up to the $150,000 threshold rather than incur the transaction costs of multiple micro-purchases with different consultants.

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G.  Funding Clarifications:
G1: I teach Water Operator Certification Courses for both small and large systems and have questions about the RFA. In particular how the application process would work, is it a reimbursement program or up-front funding and how would this work with the College’s typical payment procedures.

EPA will provide payments to successful applicants under procedures described in 2 CFR 200.305. Essentially, the Agency will pay recipients for eligible and allowable costs in a manner that minimizes the length of time between when the recipient incurs the costs and the payment to the recipient. This is the usual method of reimbursing colleges that receive federal financial assistance. The Agency will not provide an “up front” lump sum payment to the recipient that bears no relationship to actual costs incurred.

G2: Can the funds for this grant program be used for the purchase of sewer maintenance/inspection equipment?
Equipment purchases solely for the purpose of providing training or technical assistance are eligible under this funding announcement. Equipment purchases would need to be included in the application budget and approved by EPA as part of the final project work plan.  In general, equipment purchases should represent a small portion of the total project budget.

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H.  Miscellaneous:
H1: Page two of the announcement states, "EPA has previously awarded financial assistance agreements to nonprofit organizations to provide technical assistance activities that are similar to those described in this announcement."  Can you please advise what programs are being referenced in this section and what applicants received those funds?

Training and technical assistance activities similar in scope have been funded in recent years through competitively-awarded grants to several organizations.  These grants are summarized below, and are also summarized in EPA’s Grant Awards Database (found at http://yosemite.epa.gov/oarm/igms_egf.nsf/HomePage?ReadForm)

  • (Rural Community Assistance Partnership, FY 14 Grant 83580401, $4,000,000):
    Training/Technical Assistance to Improve Water Quality
    The Rural Community Assistance Partnership, Inc. (RCAP) will provide compliance-based training and technical assistance to operators, board members and managers of small drinking water systems to build their technical capacity and enable them to achieve and maintain compliance with the Safe Drinking Water Act (SDWA). Water systems in need of assistance will be assessed to determine the nature of the technical deficiencies, and a corrective plan will be developed. Training and technical assistance will be delivered through face-to-face sessions, webinars, web-based learning modules, video demonstrations and social media dissemination of information.
  • (Rural Community Assistance Partnership, FY 14 Grant 83580601, $1,200,000):
    Training/Technical Assistance Private Well Owners

    The applicant will partner with its six regional affiliates and with the Illinois State Water Survey and Illinois Water Resources Center at the University of Illinois to provide training and technical assistance to owners and managers of private drinking water wells. The overall objective of the project is to help these owners and managers help protect water quality by minimizing contamination via drinking water wells through the activities of this project. Technical assistance will be provided on-site as well as through phone and electronic communications. Training for private well owners will be accomplished through multimedia learning, face-to-face presentations and webinars.
  • (National Rural Water Association, FY 14 Grant 83580701, $4,000,000):
    Training and Technical Assistance for Small Public Water Systems

    This project will provide classroom and/or on-site training and technical assistance to small public water systems on Safe Drinking Water Act and National Primary Drinking Water Regulations compliance and related public water system operation. Training and technical assistance will be provided to strengthen the technical capacity of public water system personnel and enable them to comply with the regulatory requirements applicable to their system. Training and technical assistance priorities and specific activities will be identified in state specific operating plans developed in consultation with state drinking water regulatory agencies and drinking water program staff at U.S. Environmental Protection Agency regional and headquarters offices.
  • (National Rural Water Association, FY 14 Grant 83580501, $1,700,000):
    Training and Technical Assistance to Improve Wastewater Quality and Public Health

    This project will provide workshops and follow-up training and technical assistance in small publicly owned wastewater systems and onsite/decentralized system management. The training and technical assistance activities are to assist these systems to improve operational performance over the long-term, thereby improving public health and water quality.
  • (University of North Carolina, Chapel Hill, FY 14 Grant 83580801, $1,800,000):
    Training and Technical Assistance to Improve Water

    The Environmental Finance Center at the University of North Carolina, in conjunction with the 9 other Environmental Finance Centers nationwide, will provide training and technical assistance for small drinking water systems in the area of financial and managerial capacity. Additionally, the American Water Works Association is a partner in the effort, to enhance attendance at training and technical assistance events and to make available free online eLearning modules. Training will be delivered by the EFC’s through face-to-face workshops, small group work sessions, “funder forums”, webinars, in-depth on-site technical assistance, basic technical assistance (through phone and e-mail consultation), and online rates benchmarking dashboards. Topics incorporated in the training include: asset management, rate-setting and fiscal planning, energy management, water loss reduction, regional collaboration/coordination/partnerships, access to funding sources, leadership, and enhancing regulatory compliance through sustainable financing and management.

H2: Will EPA seek external reviewers for the Training and Technical Assistance to Improve Water Quality and Enable Small Public Water Systems to Provide Safe Drinking Water RFA?
No. EPA will not seek external reviewers for this announcement. Section V.B of the RFA states that a panel(s) comprised of EPA staff will review the eligible applications by National Priority Area based on the evaluation criteria listed in Section V.A.

H3: What systems within the 50 states are we to work with, how are those systems chosen, who will choose them, and who has the contact information?
Identifying the small public water systems to work with will be the responsibility of the successful applicant. EPA will evaluate your approach to identifying systems to serve under the “National Priority Area” and “Providing Training and Technical Assistance on a National Basis” described in section V.A. of the Request for Applications (RFA).
As required by section I.B. of the RFA, the successful applicant must work with the appropriate regulatory authorities to identify and prioritize systems in greatest need. Your application should describe a process that you propose to follow to assure proper consultation with the appropriate regulatory authority such as the state or territorial primacy agency or EPA regional direct implementation coordinator.

H4: We operate a few small water systems and I’d like to know more about the above funding opportunity. Could you please give me your phone number so that I can ask you some questions?
A telephone conversation would not be fair to other applicants. [As stated in the funding announcement under section VII, “In accordance with EPA’s Assistance Agreement Competition Policy (EPA Order 5700.5A1), EPA staff will not meet with individual applicants to discuss draft applications, provide informal comments on draft applications, or provide advice to applicants on how to respond to ranking criteria.”]
Also, please note that this funding opportunity is designed to provide funding for eligible non-profit organizations (as described in section III.A. of the announcement, quoted below), which in turn will provide training and technical assistance to eligible drinking water and wastewater systems and private well owners. State and municipal government entities are not eligible for receiving funding under this announcement.
[Section III.A. of the Request for Applications states: “Eligible applicants under this competition are nonprofit organizations, nonprofit private universities and colleges, and public institutions of higher education. For-profit organizations are not eligible to apply.... Nonprofit organizations described in Section 501(c)(4) of the Internal Revenue Code that engage in lobbying activities as defined in Section 3 of the Lobbying Disclosure Act of 1995 are not eligible to apply.”]

H5: We are planning to apply for this grant and would like to know more about the trainees. If this a cooperative agreement, how can we get the contact information for the trainees?
Obtaining contact information for trainees will be the responsibility of the successful applicant. EPA will evaluate your approach to identifying potential trainees and conducting outreach to potential trainees under the “National Priority Area” and ”Providing Training and Technical Assistance on a National Basis” described in section V.A. of the Request for Applications. Additionally, section I.B., "National Priority Areas" states: " Applicants should also describe a process whereby they will consult with the appropriate regulatory authority (such as the state or territorial primacy agency or EPA regional direct implementation coordinator) in each state or territory in which the assistance is to be expended or otherwise made available prior to providing training and technical assistance in that state or territory.  In particular, applicants should indicate how they will work with the state, territory or EPA to identify the systems in greatest need of assistance; how they will keep those agencies, the EPA grant project officer and appropriate EPA regional coordinators informed regarding the assistance provided; and how they will document these results.”
The state or territorial agencies, in addition to assisting with prioritizing the systems in greatest need, should be able to help provide the successful applicant with contact information for those systems.

H6: Our organization has been asked by two different entities to act as a sub-awardee on the submissions. Each response covers a different National Priority Area (they do not overlap responsibilities or programs within our organization).  Would it be appropriate for our organization to be listed on two separate applications or do we need to choose one? There is no restriction in the announcement that would preclude a subawardee from being included in more than one application. 

1. Please note that any applications that include a subawardee must comply with the provisions of Section IV.E of the Request for Applications (RFA), entitled “Contracts and Subawards.”

Also, please note that Section III.C.2 of the RFA states that: “Applications must address one, and only one, of the four National Priority Areas listed in Section I.B, although eligible organizations may submit more than one application as long as each one is separately submitted and addresses only one National Priority Area.  Applications that address more than one National Priority Area in a single application will not be reviewed.  In addition, applications for National Priority Area 3 must address the two elements of that priority as described in Section I.B.” 

H7: Does this RFA require a Significant Financial Interests Disclosure (SFI) such as that required by some other funding agencies?
Under this funding announcement there is no requirement for a Significant Financial Interests Disclosure for key personnel or any equivalent requirement.

H8: Can EPA provide an explanation as to why proposed projects that range from $1.178 million to $8 million all have a 12 page limit for the applications.  Is it not reasonable to expect that a proposed project with the potential of 6 times greater funding and a commensurate higher level of activities be allocated a greater amount of pages for a response?
As explained in Section V.B. of the Request for Applications (RFA), the eligible applications are reviewed by panels comprised of EPA staff, based on the evaluation criteria.  The panel members review each application in great detail, and carefully document the results of their evaluation for each selection criterion.  The 12-page application limit attempts to strike a balance between allowing applicants to adequately describe their approach, while limiting the number of pages so that panel members can provide adequate analysis and consideration of each application within the timeframe available for the review and evaluation process.  A 10- to 12- page limit is commonly used for EPA competitions, regardless of the level of funding available.

H9: Section II. B., regarding anticipated substantial federal involvement includes the statement "collaboration during performance of the scope of work, including participation in training and technical assistance activities such as attending specific trainings and workshops"; could EPA clarify further related examples of substantial federal involvement?  Will EPA provide trainers for workshops or simply be in attendance?  Will EPA assist in developing agendas for workshops?
Depending on the topic area and the specific location and timing of training or workshops, EPA may sometimes choose to be in attendance.  It is less likely but certainly appropriate, that on some occasions EPA personnel may participate in developing workshop agendas or in conducting training activities in conjunction with the training being provided by the grantee and/or state regulatory officials.  This would be determined on a case-by-case basis, in consultation with the grantee and state regulatory officials.

H10: We are hoping to find more information or clarification on the 2 different applications offered (2 different CFDA numbers); we are not clear about which application we should complete. Can you clarify the difference between the two applications?

  • CFDA Number(s):
    • 66.424 -- Surveys, Studies, Investigations, Demonstrations, and Training Grants - Section 1442 of the Safe Drinking Water Act

    • 66.436 -- Surveys, Studies, Investigations, Demonstrations, and Training Grants and Cooperative Agreements - Section 104(b)(3)

If you are applying for:

  • National Priority Area 1 (Training and Technical Assistance for Small Public Water Systems to Achieve and Maintain Compliance with the SDWA), or National Priority Area 2 (Training and Technical Assistance to Improve Financial and Managerial Capacity and Enable Small Public Water Systems to Provide Safe Drinking Water), you should use the application for CFDA 66.424

If you are applying for:

  • National Priority Area 3 (Training and Technical Assistance for Small Publicly-Owned Wastewater Systems and Onsite/Decentralized Wastewater Systems to Help Improve Water Quality), or National Priority Area 4 (Training and Technical Assistance for Private Well Owners to Help Improve Water Quality), you should use the application for CFDA 66.436.

Applications will not be rejected solely for using an incorrect CFDA number, and the number can be corrected later in the application process.

H11: Our research program has been working with private well owners in rural communities. We are considering to submit a proposal to the EPA's call for proposal below, addressing Priority Area 4.
We have worked with the U.S. Geological Survey and other state agencies in the past.  Could they be sub-awardees of the grant? The eligibility criteria indicates "States, municipalities, tribal governments, and individuals are not eligible to apply". What role could they play? Reading of the FAQ did not clarify this for us so your help is much appreciated.

Generally, unless prohibited by statute, an entity/individual is eligible to receive a subaward even if it is not eligible to receive an assistance agreement.  So, the state agencies could be eligible to be subawardess of this grant.  However, one of the entities you inquired about, the U.S. Geological Survey (USGS), is a federal entity.  Unless authorized by statute (e.g., the National Oceanic and Atmospheric Administration self-certifying that it has the statutory authority to receive subgrants under Clean Water Act 319) federal entities are not eligible for subawards.  In order to award a subgrant to USGS, you must show that USGS has the statutory authority to receive subgrants. Additional information regarding Contracts and Subawards can be found at: http://www.epa.gov/ogd/competition/solicitation_provisions.htm#Contracts_subawards

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