Request for Applications: Frequently Asked Questions

Water: Safe Drinking Water Act

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Safe Drinking Water Act

Small Public Water Systems
Tribally-Owned & Operated Public Water Systems

Frequently Asked Questions for Small Systems Request for Application

Questions may be sent to smallsystemRFA@epa.gov no later than
March 30, 2012.

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:
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 or municipalities eligible to apply for the RFA?
States or municipalities are not classified as nonprofit organizations, and 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 (smallsystemRFA@epa.gov) by March 30, 2012. Written responses will be posted on EPA’s website at http://water.epa.gov/grants_funding/sdwa/smallsystemsrfafaq.cfm. 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 the our application is successful. Is that practice acceptable to EPA?
No. Successful applicants must comply with the Procurement Standards in 40 CFR Part 30 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 II. C, 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 tor 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 40 CFR 30.36.

A7: May a State entity be eligible to apply for some of the available training funds?
Thank you for your inquiry regarding whether a State entity is eligible to apply for funding opportunity EPA-OW-OGWDW-12-01. States are not eligible to apply.

Eligible applicants are described in Section III.A. of the Request for Proposals (RFA), where it is stated that “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: Is the EPA going to provide the actual training, or is this grant opportunity for the Small System 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.”

A9: I have a question on funding eligibility for the islands in the Federated State of Micronesia and island of Palau. I am a university researcher and interested to submit a proposal for water distribution system training for island of the Pohnpei in the Federated States of Micronesia (FSM), and also for the island of Palau. My question is: can we apply for this grant for doing water system training on these islands?
Palau, the Marshall Islands, and Micronesia are all sovereign nations independent from the United States. These countries are neither territories nor possessions of the United States; therefore, they are not eligible for receiving grants under this announcement, unless the proposed work benefits the United States. The National Environmental Policy Act (NEPA) 102(2)(F) enables us to apply our domestic statutes, such as the Clean Water Act 104(b)(3), internationally. Without NEPA 102(2)(F) we do not have authority to award grants internationally. By not including NEPA 102(2)(F) in the RFP, we are indicating that these grants are only available for work benefitting the United States. If a foreign entity is otherwise qualified to receive the grant, then as long as the work is done to benefit the US, then it would be eligible.

A10: Is this for US only applicable to India and Other Countries. We are promoting Safe Drinking Water using Clean technologies. Please give us more information on this.
This funding opportunity is NOT directed to projects in India or countries other than the United States. It is limited to eligible entities providing training and technical assistance in the United States and its territories (i.e., Guam, the Commonwealth of Puerto Rico, the Northern Mariana Islands, the Virgin Islands, and American Samoa).

A11: I am hoping you can assist me with a few questions regarding the Training and Technical Assistance for Small Systems grant program. My inquiry is on behalf of the city. City’s population is just over 10,000. Could the City apply? Could the city apply for technical assistance funds in order to complete final design? or is this funding limited to staff training?
A municipal government is not an eligible applicant under this announcement and could not use funding under it for design-related technical assistance or staff training. 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.

A12: I have a question about the grant described below: is this intended only for entities that provide training, or can individual non-profit water systems apply for it 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”.

A13: We are an inter-tribal consortium representing 26 tribes in the South and Eastern US from Maine to Florida to Texas. We noted that in the Tribally funded portion, RPA-OW-OGWDW-12-02, that only Regions 6, 8 & 9 are to receive the Tribal only portion for that RFP. Our questions is can an applicant provide Training & Technical Assistance to Tribes in the RFP RPA-OW-OGWDW-12-01?
Yes, an applicant may provide training and technical assistance to tribes with funding available under this announcement.
However, 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. For the purposes of this Request for Applications, eligible drinking water systems, wastewater systems, and private wells are defined in Section I.B., “National Priority Areas”.
Please note also that applicants for this funding will be evaluated based on their ability and approach to making training and technical assistance available nationally in a maximum number of states and U.S. territories through face-to-face/on-site and/or remote training and technical assistance (Section V.A., “Selection Criteria”, in Request for Applications).

A14: 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.

A15: Can this grant be applied to one specific well of a city? We have 8 functioning wells in Greenville (population 34,400), and I noticed that this grant only funds communities of 10,000 or less. Could we apply for a grant to improve our water treatment for just one or two wells in the city, thus serving less than 10k?
The project you describe would not be eligible for funding under this announcement. 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.”]

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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 (PDF) (37 pp, 219K, About PDF) 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: I am unclear on the specific equipment required for the 3 National Priority Areas described in the RFA. Is this proposal intended to provide only training and technical assistance, or will equipment also be required? If the latter, what specific equipment is required? Last, would University/College students be allowed to oversee the implementation for learning purposes?
The funding announcement covers training and technical assistance activities only. It is not intended for the purchase of equipment.
Successful applicants are required to demonstrate that they will provide qualified, experienced staff to carry out the activities and services proposed in their work plan. Successful applicants may potentially employ qualified college or university students to provide some of the services because of their capabilities and qualifications, but not for learning purposes.

B3: Does a onsite/decentralized wastewater system include a 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 or service area.

B4: 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.)

B5: 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 regulatory 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, municipal government entities, and for-profit organizations are not classified as nonprofit organizations and are not eligible to apply under this announcement.

B6: Does this RFA cover the upgrade, addition, retrofit, or rehabilitation of water treatment plants with micro hydro power turbine systems. In this case there is a need for some training, and obviously rehabilitative work, in some cases it is completely new work, and in other cases if utilizing "Small hydro or Micro hydro" may even involve either electrifying or electrifying some situations.
No, a project for adding new equipment or upgrading, retrofitting or rehabilitating existing equipment would not be eligible for funding under this announcement. The funding announcement covers training and technical assistance activities only.

B7: If a county/municipality operates several distinct "systems" that are not connected each other, and one these distinct systems service 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 agencies 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 or territory to identify the systems in greatest need of assistance and for reporting back to those authorities, and the EPA grant project officer on the assistance provided and documented results."

B8: 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 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 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.

B9: We are a non-profit association that trains the general public on rainwater harvesting systems. Most systems are small for residential and commercial projects. Some are for non-potable uses while others are sole water supplies for the development. We teach how to build, how to purify, how to size, and all other components required for a system. We have different levels of education from general rainwater information to master rainwater harvesters. We are looking for monies to help us spread our educational practices. Would we fit into this category for the grants, how or what would we need to do to fit into the category? Team with a water district for training? We are not and water harvesting in general is not big enough for supplying entire communities but we do have systems the supply neighborhoods etc. Please give me your ideas, thank you.
A project to educate the general public on rainwater harvesting would not be eligible for funding under any of the National Priority Areas described in section I.B. of the Request for applications. Please review Section I.B. to get a good sense of the goals of this competitive opportunity to ensure that the proposed project is appropriate for this competition. Otherwise, EPA cannot provide you with advice on how to submit a competitive proposal. As stated in Section VII of the RFA:
“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. Applicants are responsible for the contents of their applications. However, consistent with the provisions in the announcement, 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.”

B10: We have a population of 1779 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 this summer, or if this type of grant is for training only.
Yes, 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.

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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 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 $10 million; applications for awards under National Priority Area 2 cannot exceed $5 million; and applications for awards under National Priority Area 3 cannot exceed $2 million. Applications exceeding these amounts will be rejected. EPA has not established a minimum amount of funding for applicants.

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E. Timing and Logistics:
E1: When does EPA anticipate announcing awardees and subsequently spent down?
EPA anticipates making funding awards sometime during the summer of 2012, but this is only an estimate, and not a guarantee. Also, as stated in the RFA (under Section II.A.),
“EPA reserves the right to make no awards under this announcement or to make fewer awards than anticipated.”
Cooperative agreements funded under this announcement will have a one-year project period.

E2: In order to develop the Milestone Schedule I would like an estimate of the following:

1) Anticipated Award Date: Summer, 2012? June, July or August?
2) Anticipated Support Period Start Date: 12 months starting about?

We anticipate making funding awards sometime during the summer of 2012, but this is only an estimate, and not a guarantee. We cannot be more definitive about dates at this time. The performance period for the grants would be 12 months, beginning with the approved start date, which normally would be soon after the grant award date.
Also, please note that a for-profit firm is not eligible to apply for funding under this RFA either directly or “through” an eligible applicant. Further, as stated in the RFA section II. C, “Contracts and Subawards”, applicants may not award sole source contracts to firms assisting applicants with the application solely based on the firm's role in preparing the application. Successful applicants must comply with the Procurement Standards in 40 CFR Part 30 when acquiring services from consultants and other contractors. These standards require recipients to hire contractors through open competition to the maximum extent practicable.

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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. 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 40 CFR 30.36.

F2: The RFA states a one year 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...ex., $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 voluntary 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 voluntary 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: If the applicant has existing curriculum for training delivery, can that curriculum or the value of curriculum contributed to the effort be used as voluntary cost share?
Yes, provided the applicant can meet the requirements at 40 CFR 30.23(a) for documenting that the amount of cost share it claims reflects the fair market value of the curriculum.

F7: When determining voluntary 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 40 CFR 30.23(d) and (e) 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. 40 CFR 30.23(a)(5). Applicants may pay trainee travel as a "participant support cost" with their own funds and include those costs as a voluntary 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 voluntary cost share.

F8: 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. 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 40 CFR 30.36(a).

F9: 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.

F10: I understand that according to the RFA, when I am completing the SF424A I include the subgrant/subcontract funding requested in Section h. Other.

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

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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 Colleges typical payment procedures.
EPA will provide payments to successful applicants under procedures described in 40 CFR 30.22. 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: For National Priority Area 1, the document states “EPA anticipates awarding approximately one to three cooperative agreements under this National Priority Area ranging from approximately $3 million to no more than $10 million each.” Is this accurate?
It seems like the rest of the document is aimed at helping several small systems and not just a few. Please clarify the anticipated award structure.
The range in the anticipated number of awards and the amount of each award specified in Section II.A. of the Request for Applications (RFA) is accurate. As you have stated, for example, the number of awards EPA anticipates making under National Priority Area 1 (NPA 1) is one to three awards, and the amount of funding for each is $3 million to $10 million.
Section III.C. of the RFA further specifies the maximum funding amounts for any one application. For example, the maximum amount for an application under NPA 1 is $10 million. Ranges for funding amounts and anticipated numbers of awards are similarly specified for the other NPA's.

G3: 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: I would like to discuss EPA-OW-OGWDW-12-01 with U.S. EPA. I want to make sure that what we are going to propose is within the scope of the RFA.
If you can provide me with your phone number, I would like to call you at a time that is convenient for you.
Thank you for your inquiry regarding funding opportunity EPA-OW-OGWDW-12-01. However, a telephone conversation would not be fair to other applicants. Please submit questions to this e-mail address. We also invite you to visit our EPA website regularly to see answers to frequently answered questions submitted to the EPA inbox.

As stated in the funding announcement, “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. Applicants are responsible for the contents of their applications. However, consistent with the provisions in the announcement, 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.”

H2: Page two of the guidelines state, "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 advised 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 non-competitive grants to several organizations designated by Congress in EPA’s appropriations. 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).

(Water Systems Council, Grant 83478301, $700,000): Water Systems Council Wellcare Project
This project continues funding for the wellcare Hotline and Well Owners Network and updates to educational materials on drinking water and ground water protection for those served by household water wells and shared wells. In addition, the recipient intends to help plan and conduct a Children's Water Festival to promote the importance of protecting water resources and conservation.

(National Rural Water Association, Grant 83477401, $13,000,000): Training & Technical Assistance for Source and Rural Water
This project will provide classroom and/or on-site training and technical assistance to small, rural, public (including tribal) drinking water systems to help these small drinking water systems improve their compliance with EPA drinking water regulations and to consistently supply safe drinking water. This project will also provide training and technical assistance to facilitate development of source and/or wellhead protection plans to help ensure that sources of drinking water supplies are protected from contamination.

(Rural Community Assistance Partnership, Grant 83469501, $1,250,000): Drinking Water Technical Assistance and Training Program
The Rural Community Assistance Partnership and its network of drinking water personnel will provide on-site, drinking water technical assistance and training services to very small/small communities. Along with technical assistance and training, the recipient will also engage in outreach activities and disseminate drinking water information to very small/small communities.

(Rural Community Assistance Partnership, Grant 83446701, $1,250,000): RCAP Small Community Wastewater Project
The Small Community Wastewater Project (SCWP) is an outreach, training, and technical assistance program focused on addressing community-specific wastewater treatment issues in small, rural communities and systems.

H3: Will grant fund become available in the future to help local agencies such as ours keep providing operational, technical, and managerial assistance to small water systems?
EPA cannot speculate on future funding availability.

H4: 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.

H5:

What systems within the 50 states are we to work with.

How are those systems chosen and who will choose them.

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 National Training and Technical Assistance Approach” 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 state or territorial regulatory authorities.

H6: 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, “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.”]

H7: We are planning to apply for this grant and would like to know how more about the trainees. If this a cooperative agreement, how can we get the contact info of the trainee?
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 National Training and Technical Assistance Approach” 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 agencies 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 or territory to identify the systems in greatest need of assistance and for reporting back to those authorities, and the EPA grant project officer on the assistance provided and documented results."
The state or territorial regulatory 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.

H8: We are not interested in applying for this grant but we are a small system and would appreciate any training and assistance available. If you could, please let us know who will be serving the Northeast once the grants for this program have been awarded.
We anticipate making awards under this funding opportunity sometime during the summer of 2012. At that time, you may wish to contact Stephen Hogye (hogye.stephen@epa.gov) to find out what organization(s) were selected to provide the training and technical assistance.

H9: Can you please clarify exactly what is expected regarding the biographical sketches and resumes for project staff. A description of the information being requested is contained both in Section IV.C.1.j “Biographical Sketches for Key personnel” and Section IV.C.2.7.b “Staff Experience/Qualifications.
In the first case the RFA requests:

Biographical sketches for each “project manager”

Name, phone number, business address and
Name, phone number, business address and email address for “proposed principal investigators” and “key associates” as well as “qualification, experience and availability” of these personnel

Annotated resumes for each “major project manager, support staff member or other participant”

Full resumes that may be included in an appendix, yet no mention of which of the above should be reflected.

In the second case the RFA requests:

A list of “key staff” with their experience/expertise/qualifications …

Biographical sketches for each “major project manager, support staff or other major project participant”

This is rather confusing as the following different designations appear duplicative and are used without any definitions:

Project Manager

Proposed principal investigator

Key associates

Support staff

Other (major project) participant

Key staff

It’s also confusing when the RFA at different times asks for lists, biographical sketches and annotated resumes (and separately allows for full resumes).
Please clarify exactly what is being requested for each type of project participant. In addition, is the material requested in the workplan, Section IV.C.2.7.b, to be included in the appendix or as part of the narrative, or both. It appears that in this section the only required information other than biographical sketches is the estimated number of FTEs.

We agree that the wording in the Request for Applications should be clarified. Thank you for bringing this matter to our attention. We have modified the RFA to clarify and simplify the language in Sections IV.B.1.j and IV.C.1.j, regarding biographical sketches and have extended the due date for applications to 4:00 PM EDT April 13, 2012 for hard copy applications and to 11:59 PM EDT April 13, 2012 for applications submitted electronically through Grants.gov.

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Frequently Asked Questions
for Tribally-Owned & Operated Public Water Systems Request for Application

Questions may be sent to tribalsystemRFA@epa.gov no later than
March 30, 2012.

Categories

Tribally-Owned & Operated Public Water Systems
A. Applicant Eligibility:
A1: Can a nonprofit organization include a for-profit organization on its proposal team for the subject procurement?
Yes, but only if the nonprofit has selected the for profit firm in a manner that complies with the Procurement Standards in 40 Code of Federal Regulations Part 30 before listing the firm in its proposal. Please refer to Section III.A of the RFA. Given the widespread availability of consulting firms capable of providing technical assistance or other services eligible for funding under this RFA, the nonprofit organization must select the for profit firm competitively, including efforts described at 40 Code of Federal Regulations Part 33 to include disadvantaged business enterprise in the competition, and conduct a cost or price analysis for the proposed transaction. Nonprofits may not justify sole source procurements on the grounds that a for profit firm assisted in preparing the proposal as a "partner" or "team member".
Also, please note that the RFA is not an EPA procurement. It is a request for applications for financial assistance.

A2: Please let me know if EPA-OW-OGWDW-12-02 Request for Applications : EPA Funding for Training & Technical Assistance for Small Systems cover applicants from Pakistan?
No. Applications to provide technical assistance in Pakistan are not eligible for funding under this announcement. This funding is limited to providing training and technical assistance in the United States and its territories (i.e., Guam, the Commonwealth of Puerto Rico, the Northern Mariana Islands, the Virgin Islands, and American Samoa).

A3: I was wondering if tribal governments are eligible to apply for this grant? It mentions non-profits and tribal universities, but I didn’t see anything about tribal governments. Our tribe operates tribally-owned water systems for public use in several of our tribal communities. Would we be eligible for this grant?
Tribal governments are not eligible for funding under EPA-OW-OGWDW-12-02 Request for Applications. As indicated in Section III. A eligible applicants under this competition are limited to nonprofit organizations, nonprofit private universities and colleges, and public institutions of higher education including tribal colleges and Intertribal consortia that are incorporated as nonprofits. Tribal governments do not fit under any of these categories.

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Tribally-Owned & Operated Public Water Systems
B. Project Eligibility:
B1: Please clarify that services to the Navajo Nation are not included in this RFA
The Navajo Nation is not eligible to receive training or technical assistance under the request for applications. Section III.C.4. Threshold Criteria states that applications must demonstrate that the training and technical assistance to be provided will be limited to tribally-owned and operated public water systems where EPA Regions 6, 8 and 9 have primacy responsibilities under the Safe Drinking Water Act. EPA does not have primacy responsibilities for Navajo Nation since Navajo has primacy responsibility over public water systems located on their reservation.

B2: Why is this limited to Regions 6, 8 & 9 when there are 6 other EPA regions with Tribes in them that also need Training & Technical Assistance?
EPA has decided to limit the training and technical assistance to Regions 6, 8 and 9 because these Regions contain tribally owned and operated public water systems with the largest number of systems that are not in compliance with the National Primary Drinking Water Regulations. According to Safe Drinking Water Information System (SDWIS), 496 (92%) serve less than 3,300 and have a large number of violations of the National Primary Drinking Water Regulations.

B3: Can an applicant break out a state or states within a region for Training & Technical Assistance?
Yes, an applicant may propose to provide technical assistance to tribes in any state or states in EPA Regions 6, 8 and 9. Please note, however that Section V.A.2 of the RFA states, in part, that applicants will be evaluated based on their ability and approach to make training and technical assistance available to a maximum number of tribally-owned and operated public water systems where EPA Regions 6, 8 and 9 have primacy responsibilities through face to-face/on-site and/or remote training and technical assistance.

B4: Can an applicant include other Regions that have Tribes as part of their grant application?
No. Section I.B states that the training and technical assistance provided under this announcement is limited to tribally-owned and operated public water systems where EPA Regions 6, 8 and 9 have primacy responsibilities under the Safe Drinking Water Act.

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Tribally-Owned & Operated Public Water Systems
C. Threshold Issues:
C1: Please clarify whether or not the biographical sketch of each project manager is included in the 10 page limit for the project narrative. If not, are the biographical sketches different from the full resumes that may be included as an appendix?
Biographical sketches are not counted in the 10 page limit. Section IV.C .2. Project Narrative, of the request for applications states that a biographical sketch must be submitted for each major project manager, support staff member or other major project participant. Full resumes may be included as an appendix to the Project Narrative and are not counted in the page limit.

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Tribally-Owned & Operated Public Water Systems
D. Evaluation Issues:
D1: Can we include a brochure on our Tribal PWS Utility Management Program in the application as part of the biographic sketches/resumes attachment?
Yes, you may include a brochure as part of the biographical sketches/full resumes appendix to the Project Narrative. Supporting materials such as biographical sketches and full resumes are not included within the page limit.

D2: Can we include letters of support? If so, how many?
Yes, letters of support may be included in your application. Letter of support would be considered supplemental materials and there is no limit on the number of letters of support. Please note that the RFA does not request or require letters of support and they will not be evaluated against the factors in Section V of the RFA.

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Tribally-Owned & Operated Public Water Systems
E. Timing and Logistics:
E1: Have you determined an approximate award date and an approximate start date?
Yes. We anticipate making funding awards sometime during the summer of 2012, but this is only an estimate, and not a guarantee. We cannot be more definitive about dates at this time. The performance period for the grants would be 12 months, beginning with the approved start date, which normally would be soon after the grant award date.

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Tribally-Owned & Operated Public Water Systems
F. Budget Concerns:
F1: It could potentially be less expensive to pay for travel for Tribal members to attend an event or training rather than send staff to multiple locations. Can any portion of the funding be used to pay for travel (mileage, hotel, per diem) for Tribal members?
Applicants may propose technical assistance project budgets that include costs for trainee travel as participant support costs. However, EPA will carefully evaluate applicants' budgets to determine whether applicants are proposing to deliver technical assistance services efficiently.
Please refer to Section IV.C for a description of how to itemize costs related to personnel, fringe benefits, contractual costs, travel, equipment, supplies, other direct costs, indirect costs and total cost. EPA recommends that applicants include their anticipated participant support costs in the "other" category.

F2: If the applicant has existing curriculum for training delivery, can that curriculum or the value of curriculum contributed to the effort be used as voluntary cost share?
Yes, provided the applicant can meet the requirements at 40 CFR 30.23(a) for documenting that the amount of cost share it claims reflects the fair market value of the curriculum.

F3: 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. The applicant will "own" the curriculum. However, if the applicant uses the costs (ie personnel or contractor expenses) for developing the curriculum as cost share EPA would have a "federal purpose" license to use the curriculum under 40 CFR 30.36(a).

F4: When determining voluntary 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 40 CFR 30.23(d) and (e) for allowability as cost share. Additionally, it is likely that trainees may charge EPA of other federal grants for their salaries and recipients may not use costs charged to federal grants as cost share without statutory authority. 40 CFR 30.23(a)(5). Applicants may pay trainee travel as a "participant support cost" with their own funds and include those costs as a voluntary 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 use count these costs towards their voluntary cost share.

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Tribally-Owned & Operated Public Water Systems
F. Miscellaneous:
H1: After award of a grant, can the nonprofit organization awardee use the services of a for profit organization that was not on its original proposal team in performance of the work?
Yes. EPA does not encourage nonprofit organizations to name commercial vendors in their proposals. Rather, as indicated above, nonprofit recipients must comply with the 40 Code of Federal Regulations Part 30 Procurement Standards for open and free competition and the provisions at 40 Code of Federal Regulations Part 33 for providing disadvantaged businesses opportunities to compete for EPA funds.

H2: Regarding the database for current contact information (page 4 of the RFA), are there additional entities other than EPA and Indian Health Service that will need to be included?
Yes, the database may include contact information for EPA, Indian Health Services as well as other entities such as the technical assistance providers and other sources of information.
Section I.B National Priority Area of the request for applications states that applicants should describe a process for providing and maintaining current contact information in a publicly-available technical assistance database targeted to small public water systems.

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Frequently Asked Questions for Small Systems Request for Application

Frequently Asked Questions for Tribally-Owned & Operated Public Water Systems Request for Application

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Frequently Asked Questions
for Tribally-Owned & Operated Public Water Systems Request for Application