WIIN Act Section 2105: Frequently Asked Questions
Reduction in Lead Exposure Via Drinking Water
Primary tasks
The activities to be funded under this announcement support the Agency’s Strategic Plan for Fiscal Year (FY) 2018 – 2022, Goal 1: A Cleaner, Healthier Environment: Deliver a cleaner, safer, and healthier environment for all Americans and future generations by carrying out the Agency’s core mission, Objective 1.2: Provide for Clean and Safe Water. The funding opportunity is described in the Request for Applications (RFA) for Reduction in Lead Exposure Via Drinking Water.
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.
OVERVIEW
A1. How much money will be awarded?
The total estimated amount of federal funding available under this announcement is $39,900,000. It is anticipated that a total of four to fifteen assistance agreements, each with a project period of up to four years, will be awarded under this announcement. Applicants must provide a minimum non-federal cost-share/match that is at least 20 percent of the total project cost. The EPA may grant a waiver to reduce the cost share/match requirement for reasons of affordability. (See Section III.B of the RFA for information on the minimum non-federal 20 percent cost-share/match requirement and the criteria for a waiver.)
The following is the expected total of awards in each of the two National Priority Areas.
- One to three awards are anticipated under NPA 1: Reduction of Lead Exposure in the Nation's Public Water Systems through Infrastructure Improvements with a potential total of up to $17,100,000.
- Three to twelve awards are anticipated under NPA 2: Reduction of Children’s Exposure to Lead in Drinking Water in Schools and Child Care Facilities, with a potential total of up to $22,800,000.
A2. Are matching funds required?
Yes. All applicants must demonstrate in their application submission how they will contribute a minimum non-federal cost-share/match of 20 percent of the total project cost. The EPA may grant a waiver to reduce the cost share/match requirement for reasons of affordablity. See Section III.B of the RFA for additional information on the minimum non-federal 20 percent cost-share/match requirement and the criteria for a waiver.
A3. Is a waiver available for the required 20 percent non-federal cost-share/ match?
Section 1459B(b)(4)(B) of the SDWA states that EPA may reduce the cost share/match requirement for reasons of affordability, as the Administrator determines to be appropriate. If an applicant is interested in obtaining a reduced cost share/match waiver for the funds to be awarded under this solicitation, they must submit a letter requesting a reduced cost share/match waiver as part of their application submission. The reduced cost-share/match waiver request letter must demonstrate that they meet their state’s Drinking Water State Revolving Fund (DWSRF) affordability criteria.
National Priority Area 1 applicants that are community water systems, water systems located in an area governed by an Indian Tribe, non-transient non-community water systems, municipalities, or intermunicipal agencies that meet their state’s Drinking Water State Revolving Fund (DWSRF) affordability criteria, may prepare a budget and application based upon the assumption that EPA will approve a reduced cost share/match of 10 percent.
National Priority Area 2 applicants that are community water systems, water systems located in an area governed by an Indian Tribe, non-transient non-community water systems, municipalities, or intermunicipal agencies that meet their state’s Drinking Water State Revolving Fund (DWSRF) affordability criteria, may prepare a budget and application based upon the assumption that EPA will approve a full cost share/match waiver.
State, interstate, and nonprofit organizations are not eligible for a reduced cost-share/match waiver. Please refer to Cost Sharing or Matching (Section III.B of the RFA) for information.
A4. What is an eligible project under the Reduction in Lead Exposure via Drinking Water Grant program?The EPA is soliciting applications from eligible applicants, as described under Eligibility Information (Section III.A. of the RFA), to reduce lead in drinking water in disadvantaged communities through infrastructure and/or treatment improvements or facilitate remediation in schools and child care facilities. National Priority Areas identified in this announcement are for: (1) Reduction of Lead Exposure in the Nation’s Drinking Water Systems through Infrastructure and Treatment Improvements and (2) Reduction of Children’s Exposure to Lead in Drinking Water at Schools and Child Care Facilities. Refer to the RFA Summary section for more information.
A5. Should the application include complete project planning and design?
Applicants should include a description of the completed project planning and design phases. See Expeditious Project Readiness to Proceed (Section I.C in the RFA) for more information.
A6. When is the application deadline?
The closing date and time for receipt of application submissions is June 1, 2020 by 11:59 PM, Eastern Time, in order to be considered for funding.
A7. When does EPA expect to send notification of award status, as related to Reduction in Lead Exposure Via Drinking Water?
Please refer to SECTION VI. A. Award Notices which states “Following EPA’s evaluation of the applications, all applicants, including those who are not selected for funding, will be notified regarding their status. Notification will be made to the original signer of the Standard Form (SF) 424, Application for Federal Assistance and will be sent to the original signer of the application or the project contact listed in the application. This notification, which informs the applicant that its application has been selected and is being recommended for award, is not an authorization to begin work. The official notification of an award will be made by the Grants and Interagency Agreements Management Division.
Applicants are cautioned that only an Award Official is authorized to bind the Government to the expenditure of funds; selection does not guarantee an award will be made. For example, statutory authorization, funding or other issues discovered during the award process may affect the ability of EPA to make an award to an applicant. The award notice, signed by an EPA Award Official, is the authorizing document and will be provided through electronic or postal mail. The successful applicant may need to prepare and submit additional documents and forms (e.g., workplan), which must be approved by EPA, before the assistance agreement can officially be awarded. The time between notification of selection and award of a grant can take up to 90 days or longer.”
A8. Will the EPA consider award requests below the $1.9 million threshold described in the Request for Proposals?
Please refer to Section III.C. Threshold Eligibility Criteria. Criteria 6 of the threshold criteria states, “Applications for awards under National Priority Area 1, Reduction of Lead Exposure in the Nation’s Drinking Water Systems through Infrastructure and Treatment Improvements, cannot request more than $17,100,000 in federal funds, and applications for awards under National Priority Area 2 Reduction of Children’s Exposure to Lead in Drinking Water at Schools and Child Care Facilities cannot request more than $22,800,000 in federal funds. Applications exceeding the amount for the National Priority Area it addresses will be rejected.”
Please refer to Section I. Program Objectives. National Priority Area 2. All eligible applications will be evaluated based on the criteria on how well and thoroughly the National Priority Area is addressed. The EPA anticipates awarding approximately three to twelve assistance agreements under this National Priority Area, ranging from approximately $1,900,000 to no more than $7,600,000 in federal funds. It is anticipated that the total amount of all awards under this priority area will be approximately $22,800,000.
Section V.A., Selection Criteria states “All eligible applications, based on the Section III threshold eligibility review, will be evaluated based on the evaluation criteria and weights below (100 total point scale). Points will be awarded based on how well and thoroughly each criterion and/or sub-criterion is addressed in the application package.”
A9. Is there a ranking criteria established?
Please refer to Section V.A., Selection Criteria. All eligible applications, based on the Section III threshold eligibility review, will be evaluated based on the evaluation criteria and weights (100 total point scale). Points will be awarded based on how well and thoroughly each criterion and/or sub-criterion is addressed in the application package.
Please refer to Section II.B. Type of Funding, the RFA states “It is anticipated that grants and/or cooperative agreements may be funded under this announcement. When cooperative agreements are awarded, the EPA will have substantial involvement with the project work plan and budget. Although the EPA will negotiate precise terms and conditions relating to substantial involvement as part of the award process, the anticipated substantial federal involvement for the project selected and funded as a cooperative agreement may include the following.”
Applicants should also refer to additional information regarding awards found in the FAQ response A7 pertaining to the notification of award selections.
A11. Given the small amount of funds available, is it possible for the applicant to apply for funds to cover only the post construction monitoring?
Please refer to Section I.B. National Priority Areas:
National Priority Area One: Reduction of Lead Exposure in the Nation’s Drinking Water Systems through Infrastructure and Treatment Improvements
“Under this National Priority Area, the EPA is soliciting applications to reduce lead in drinking water in disadvantaged communities through infrastructure and/or treatment projects, such as lead service line replacement and corrosion control practices.”
National Priority Area Two: Reducing Children’s Exposure to Lead in Drinking Water in Schools and Child Care Facilities
“Under this National Priority Area, the EPA is soliciting applications for projects in disadvantaged communities that will reduce children’s exposure to lead in schools and child care facilities through removal and/or replacement of lead-containing drinking water fixtures, fountains, outlets, and plumbing materials.”
ELIGIBILITY
B1. What applicants are eligible to apply for the funding?Please refer to Section III.A, Eligible Applicants, of the RFA. Eligible applicants under this competition include the following. Individuals and for-profit organizations are not eligible to apply. The EPA may ask applicants to demonstrate that they are eligible for funding under this announcement.
- Community water systems, for example a town’s drinking water system.
- Water systems located in an area governed by an Indian Tribe.
- Non-transient non-community water systems, for example schools and hospitals that have their own water systems.
- Qualified nonprofit organizations servicing a public water system.
- Municipalities.
- State, interstate, or intermunicipal agencies, such as a department of environmental protection, an interstate environmental commission, or a joint municipal pollution control board.
B2. How does EPA define nonprofit organization?
Nonprofit organization, as defined by 2 CFR Part 200, means any corporation, trust, association, cooperative or other organization that: (1) is operated primarily for scientific, educational, service, charitable or similar purposes in the public interest; (2) is not organized primarily for profit; and (3) uses its net proceeds to maintain, improve and/or expand its operations. Note that 2 CFR Part 200 specifically excludes the following types of organizations from the definition of nonprofit organization because they are separately defined in the regulation: (i) institutions of higher education; and (ii) state, local and federally-recognized Indian tribal governments. Institutions of Higher Education are defined at 20 U.S.C. 1001. 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.
B3. What are the requirements to be eligible as a qualified nonprofit organization servicing a public water system?
Please refer to Section III, A. Eligible Applicants of the RFA, which states that a “Nonprofit organization, as defined by 2 CFR Part 200, means any corporation, trust, association, cooperative or other organization that: (1) is operated primarily for scientific, educational, service, charitable or similar purposes in the public interest” Applicants should demonstrate in the application that they are a qualified nonprofit organization servicing a public water system. During the application process, the applicant should define or describe how the organization is servicing a public water system. For example, describe the working relationship between the applicant (that is a non-profit) and the public water system that would be served under the application.
B4. Are territories of the United States eligible to apply to this RFA?
Yes. For purposes of this RFA, territories of the United States are considered States and are eligible entities. Any eligible entity located in a territory may apply and compete to receive funding under this competition, so long as the applicant meets the requirements described in Section III of the RFA.
B5. Does the community being served by the project need to be disadvantaged?
Yes. These projects must be in one or more disadvantaged communities as determined by the state’s Drinking Water State Revolving Fund (DWSRF) affordability criteria.
B6. What is considered a disadvantaged community?
Each state establishes affordability criteria under section 1452(d)(3) of the Safe Drinking Water Act (SDWA), and a disadvantaged community is defined as “the service area of a public water system that meets affordability criteria.” The affordability criteria must be met for the community for which the project will be performed. More information about a state’s affordability criteria can be found in a state’s most current final Intended Use Plan or by contacting the state Drinking Water State Revolving Fund program. See Threshold Criteria (Section II.C.3 in the RFA) for more information.
B7. Are schools and child care facilities that are considered public water systems (PWS) eligible applicants for this funding opportunity?
Yes. A school or child care facility that is a community water system, water system located in an area governed by an Indian Tribe, or non-transient non-community water system is an eligible entity under this RFA. See Eligible Applicants (Section III.A) for more information.
B8. Are privately-owned public community water systems eligible for funding under the WIIN Grant: Reduction in Lead Exposure Via Drinking Water under SDWA Section 1459B as one of the eligible entities addressed below?
- Community water systems, for example a town’s drinking water system.
- Water systems located in an area governed by an Indian Tribe.
- Non-transient non-community water systems, for example schools and hospitals that have their own water systems.
- Qualified nonprofit organizations servicing a public water system.
- Municipalities.
- State, interstate, or intermunicipal agencies, such as a department of environmental protection, an interstate environmental commission, or a joint municipal pollution control board
There are 151,000 public water systems in the US. The EPA breaks those down into 3 categories (public water systems, non-transient non-community water systems, and transient water systems). Community water systems (CWSs) are a subset of the public water systems. They can be publicly- or privately-owned. For example, the City of Baltimore’s water system is a publicly-owned CWS. Boise, Idaho’s water system is also an example of a privately-owned CWS.
B9. Are school districts eligible to apply for funds under the Reduction in Lead Exposure Via Drinking Water under SDWA Section 1459B RFA? Do they qualify as municipalities or intermunicipal agencies?
Please refer to SECTION III. A. Eligible Applicants, in the RFA, which defines the applicants that are eligible. Please see response to question B8. Whether a school district is considered a municipality or an intermunicipality may vary by state and may be dependent on state, municipal, or local regulations. Contact your state or proper authority administration or department of education for further information. Applicants should demonstrate in the application submission that they meet the eligibility requirements.
B10. We are a not for profit Church and a not for profit School sharing a building and water system. How do we go about applying for Grant money?
Please refer back to question B3, above, to understand how applicants describe or define how the organization is servicing a public water system. For example, describe the working relationship between the applicant (that is a non-profit) and the public water system that would be served under the application.
B11. Does the District of Columbia qualify to participate in applying for the Request for Application if there is no established definition for “disadvantaged communities” under the jurisdiction? How should it proceed?
Congress did not authorize the establishment of drinking water state revolving loan fund programs in the District of Columbia and the U.S. territories of U.S. Virgin Islands (USVI), Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands (CNMI). Therefore, those jurisdictions do not have disadvantaged community criteria under SDWA section 1452(d)(3). However, the EPA allots a portion of the national Drinking Water State Revolving Fund (DWSRF) appropriation as construction grants for drinking water infrastructure in those jurisdictions. These RFA applicants must demonstrate that the proposed project services a disadvantaged community.
B12. Does the proposal need to address both disadvantaged communities and Opportunity Zones?
No. Please refer to Section III.C., Threshold Eligibility Criteria, which states “Applications must demonstrate that the proposed project is in a disadvantaged community. Each state establishes affordability criteria under section 1452(d)(3) of the Safe Drinking Water Act (SDWA), and a disadvantaged community is defined as “the service area of a public water system that meets affordability criteria.” The affordability criteria must be met for the community for which the project will be performed. Applicants must include their state’s affordability criteria and how the proposed project meets the affordability criteria. Applicants can obtain more information about their state’s affordability criteria in their state’s most current final Intended Use Plan or contacting their state Drinking Water State Revolving Fund program for more information.”
Section I.A. Program Objectives, states, “The EPA is also prioritizing lead reduction projects at drinking water systems that have exceeded the lead action level during the last three years and/or that fall within or contain Opportunity Zones. Information regarding Opportunity Zones is available at https://www.cdfifund.gov/Pages/Opportunity-Zones.aspx.”
Section V.A., Selection Criteria, states under the evaluation criteria National Priority Area “Under this criterion the applicant will be evaluated based on their ability and approach for effectively addressing the National Priority Area that is the subject of their application. In conducting this evaluation, the following factors will be evaluated:…..vi. The degree to which the proposed project is in an Opportunity Zone and/or the proposed project will help improve health outcomes within an Opportunity Zone as described in Section I.A. (3 points)”.
B13: Are the terms of disadvantage community and affordablilty criteria interchangeable as used in the RFA or do you expect them to have two different sets of criteria for water systems to meet?
Affordability criteria are fundamental to the state’s definition of a disadvantaged community under SDWA 1452(d). If a state designates a community as disadvantaged then it has already taken into consideration the affordability of the community. Therefore, for the purposes of this grant, the two terms can be considered interchangeable.
SDWA 1452(d) Assistance for disadvantaged communities states:
(3) "Disadvantaged community" defined
In this subsection, the term "disadvantaged community" means the service area of a public water system that meets affordability criteria established after public review and comment by the State in which the public water system is located
B14. Are all homes within the disadvantaged community/opportunity zones eligible, regardless of Owner's status (i.e., Is an owner/landlord of a multi-family home eligible if their income does not meet the criteria for a "disadvantaged community")?
Please refer to Section I.A., Program Objectives, which states, “These projects must be in one or more disadvantaged communities. Each state establishes affordability criteria under section 1452(d)(3) of the Safe Drinking Water Act (SDWA), and a disadvantaged community is defined as “the service area of a public water system that meets affordability criteria.” The affordability criteria must be met for the community for which the project will be performed. More information about a state’s affordability criteria can be found in a state’s most current final Intended Use Plan or by contacting the state Drinking Water State Revolving Fund program. The EPA is also prioritizing lead reduction projects at drinking water systems that have exceeded the lead action level during the last three years and/or that fall within or contain Opportunity Zones.”
Additionally, Section I.B., National Priority Areas, states,
“The EPA encourages applications that focus on projects that assist disadvantaged communities with one or more lead action level exceedances in the past three years and/or that fall within or contain Opportunity Zones…. Applicants should describe the known lead issue in the disadvantaged community by describing for example: any lead action level exceedances the system has had, service line inventories, historical challenges in meeting the requirements of the Lead and Copper Rule, as defined in 40 CFR Part 141, Subpart I, and any other information relevant to demonstrate the need for the proposed lead reduction project.”
NATIONAL PRIORITY AREAS
C1. Who is eligible to qualify for a cost share/match waiver?
Section III.B., Cost Sharing or Matching states “Section 1459B(b)(4)(B) of the SDWA states that the EPA may reduce the cost share/match requirement for reasons of affordability, as the Administrator determines to be appropriate.
National Priority Area 1 applicants that are community water systems, water systems located in an area governed by an Indian Tribe, non-transient non-community water systems, municipalities, or intermunicipal agencies that meet their state’s Drinking Water State Revolving Fund (DWSRF) affordability criteria, may prepare a budget and application based upon the assumption that EPA will approve a reduced cost share/match of 10 percent.
National Priority Area 2 applicants that are community water systems, water systems located in an area governed by an Indian Tribe, non-transient non-community water systems, municipalities, or intermunicipal agencies that meet their state’s Drinking Water State Revolving Fund (DWSRF) affordability criteria, may prepare a budget and application based upon the assumption that EPA will approve a full cost share/match waiver.
State, interstate, and nonprofit organizations are not eligible for a reduced cost-share/match waiver.
If an applicant is interested in obtaining a reduced cost share/match waiver for the funds to be awarded under this solicitation, they must submit a letter requesting a reduced cost share/match waiver as part of their application submission. The reduced cost-share/match waiver request letter must demonstrate that they meet their state’s DWSRF affordability criteria. The reduced cost-share/match waiver request is not subject to any page limitations specified for the application in Section IV of this solicitation. If the applicant demonstrates it meets their state’s DWSRF affordability criteria, the cost share/match requirement will be reduced from a 20 percent to a 10 percent cost share/match for NPA 1 applicants, and a full cost share/match for NPA 2 applicants. If the applicant does not demonstrate it meets their state’s DWSRF affordability criteria, the applicant must then meet the 20 percent cost share/match. The applicant must also provide a new budget with the final grant application based upon the 20 percent cost share/match requirement and the federal award will be reduced accordingly. The purpose of this requirement is to ensure that all work plan activities for a project which is evaluated and competitively awarded will be implemented as described in the original application.”
The following link provides more information on State Drinking Water SRF contacts: https://19january2021snapshot.epa.gov/dwsrf/state-dwsrf-website-and-contacts
C2. Are state funds eligible as a cost share/match that can be applied towards an application under National Priority Areas?
Section III.B. Cost Sharing or Matching, of the RFA states “The non-federal cost-share/match may be provided in cash or from in-kind contributions, such as use of volunteers and/or donated time, equipment, expertise, and is subject to the regulations governing matching fund requirements described in 2 CFR 200.306, as applicable….... Cost-share/matching funds are considered grant funds and are included in the total award amount and should be used for the reasonable and necessary expenses of carrying out the workplan. All grant funds are subject to federal audit. Any restrictions on the use of grant funds also apply to the use of the cost-share/match. Other federal grants may not be used as cost-share/match without specific statutory authority.”
NATIONAL PRIORITY AREA 1: Reduction of Lead Exposure in the Nation’s Drinking Water Systems through Infrastructure and Treatment Improvements
D1. Can eligible applicants use funding to replace privately owned portions of lead service lines?
Yes. An eligible entity may use funding to replace privately-owned portions of lead service lines.
D2. Can eligible applicants use funding to perform partial lead service line replacements?
Partial lead service line replacement is not an eligible activity unless the replacement is of partial lead service lines that are remnants of previous partial replacement efforts. An eligible entity must ensure that no section of lead service line remains in place at the completion of the replacement.
D3. The RFA states that a disadvantaged community is the service area of a water system that meets the state’s affordability criteria, and that a system that meets state affordability criteria qualifies for a reduced cost share/match of 10% if they apply under National Priority Area 1. Does this mean that all eligible water systems applying under National Priority Area 1 qualify for the reduced cost share/match?
No. Section III.B., Cost Sharing or Matching states "National Priority Area 1 applicants that are community water systems, water systems located in an area governed by an Indian Tribe, non-transient non-community water systems, municipalities, or intermunicipal agencies that meet their state’s Drinking Water State Revolving Fund (DWSRF) affordability criteria, may prepare a budget and application based upon the assumption that EPA will approve a reduced cost share/match of 10 percent.” It also states “If an applicant is interested in obtaining a reduced cost share/match waiver for the funds to be awarded under this solicitation, they must submit a letter requesting a reduced cost share/match waiver as part of their application submission. The reduced cost-share/match waiver request letter must demonstrate that they meet their state’s DWSRF affordability criteria. The reduced cost-share/match waiver request is not subject to any page limitations specified for the application in Section IV of this solicitation. If the applicant demonstrates it meets their state’s DWSRF affordability criteria, the cost share/match requirement will be reduced from a 20 percent to a 10 percent cost share/match for NPA 1 applicants." See also the response to question C7.
D4. Are projects eligible that replace lead lines if the State requires a Water System to replace them regardless of lead action level values?
Please refer to Section I. Funding Opportunity Description. “The EPA is also prioritizing lead reduction projects at drinking water systems that have exceeded the lead action level during the last three years and/or that fall within or contain Opportunity Zones.”
Applicants should also refer to Section V.A. Application Review Information indicating “All eligible applications, based on the Section III threshold eligibility review, will be evaluated based on the evaluation criteria and weights below (100 total point scale). Points will be awarded based on how well and thoroughly each criterion and/or sub-criterion is addressed in the application package.”
Applicants should refer to the following sections under Section V.A. regarding the lead infrastructure projects submitted as part of the application for scoring:
Section V.A, 1.ii, National Priority Area, states, “The extent and quality to which the applicant describes a known lead issue in the disadvantaged community. (8 points)”
Section V.A.1.v. states, “The degree to which the proposed project demonstrates that the assistance will target disadvantaged communities with one or more lead action level exceedance(s) in the past three years. (3 points)”
NATIONAL PRIORITY AREA 2: Reducing Children’s Exposure to Lead in Drinking Water in Schools and Child Care Facilities
E1. Can this grant be used to support remediation following testing conducted under the Lead Testing in School and Child Care Program Drinking Water Grant Program?
Yes. The Lead Testing in School and Child Care Program Drinking Water Grant creates a voluntary program to assist states with testing for lead in drinking water at schools and child care programs using the EPA’s 3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities guidance or applicable state regulations or guidance regarding reducing lead in drinking water in schools and child care programs that are not less stringent.
Under National Priority Area 2, the EPA is soliciting applications for projects in disadvantaged communities that will reduce children’s exposure to lead in schools and child care facilities through removal and/or replacement of lead-containing drinking water fixtures, fountains, outlets, and plumbing materials.
Applicants should describe the known lead issue in the disadvantaged communities’ schools and/or childcare facilities by describing for example: drinking water fixtures, fountains, outlets and/or plumbing that need to be removed or replaced. The description may include prior use of the 3Ts, or applicable state regulations or guidance that are not less stringent, for identification and prioritization of drinking water fixtures, fountains, outlets and/or plumbing that need to be removed or replaced. See National Priority Area Two (Section I.B in the RFA) for more information.
E2. What is the remediation trigger level for lead drinking water in schools and child care facilities?
There is no recommended remediation trigger level in the EPA’s 3T’s (Training, Testing, and Taking Action) toolkit. The EPA encourages schools to prioritize remediation efforts based on the highest lead sample results and to use the steps in the 3T’s toolkit to pinpoint potential lead sources to reduce their lead levels.
All 50 states and the District of Columbia are participating in the EPA’s Lead Testing in School and Child Care Program Drinking Water grant. In establishing and conducting programs for lead in drinking water in schools, states have the discretion, but are not required, to identify remediation levels for their program. Program contacts are available at: [https://19january2021snapshot.epa.gov/dwcapacity/wiin-2107-lead-testing-school-and-child-care-program-drinking-water-state-grant-program]. Schools and child care facilities also are encouraged to check with state and local health department as they may have guidance or requirements.
E3. Can grant funding be used to support remediation in private schools or child care facilities?
For the purposes of this RFA, a child care facility is a Head Start program or an Early Head Start program, a state licensed or regulated child care program, a state pre-kindergarten program, or a program operated by a local educational agency serving children from birth through age six.
For the purposes of this RFA, a school is a nonprofit institutional day or residential school, including a public charter school, that provides elementary or secondary education, as determined under state law, up through grade twelve. Additionally, for the purposes of this RFA, the definition of a school includes a school or community college that is controlled by an Indian tribe, band, or nation, including any Alaska Native village, which is recognized as eligible for special programs and services provided by the United States to Indians because of their status as Indians. Facilities administered by the Bureau of Indian Affairs are not included in this definition for the purposes of this announcement.
E4. What types of supporting documentation to demonstrate project readiness to proceed can be provided that is not included in the Project Narrative page limitation?
Section I.C. Expeditious Project Readiness to Proceed in the RFA states, “Supporting documentation demonstrating this readiness to proceed, such as bid documents, construction schedules, easements, and any legal agreements to access private property to complete the project, may be submitted as optional attachments, as referenced in Section IV of the solicitation. These documents are not subject to the 25-page limitation under the Project Narrative.
Section IV.D.2. Project Narrative states Additional pages beyond the 25-page limit will not be considered. The following documents may be included as supporting materials and do not count towards the 25 page limitation. These include, as mentioned in Section D.1, parts f. through i (f. Biographical Sketches, g. Negotiated Indirect Rate Cost Agreement, h. Supporting documentation demonstrating readiness to proceed, and i. Supporting documentation describing the known lead issue). Additionally, reduced cost share/waiver request letter, full resumes and QA/QC documentation are not included within the page limitation.”
E5. The RFA indicates “no technical assistance projects are eligible”. Remediation work with schools and childcare facilitates often require some form of planning, training and technical assistance as part of the implementation process. Are these activities eligible to ensure successful program implementation to reduce lead in schools and childcare facilities or are these activities not allowable?
Section I.A, Program Objectives, states “The EPA expects that successful applications will demonstrate that projects are ready to proceed expeditiously upon award. All applications must be for lead reduction projects that support the goals and objectives identified below. Planning, training, and technical assistance projects are not eligible for funding under this announcement.”
Section I.C, Expeditious Project Readiness to Proceed states, “Applications for projects under both of the National Priority Areas described above must demonstrate the applicant’s ability and readiness to proceed expeditiously upon receiving an award. Applicants must describe the plan and approach to proceed expeditiously to implement the project upon award of funding. Applicants should describe past and current practices being implemented to reduce exposure of lead in drinking water (such as public education and outreach, existing corrosion control treatment, or the use of control measures to reduce exposure from fountains or fixtures where elevated lead levels have been detected in schools or child care facilities). Applicants should include a description of the completed project planning and design phases. Applications must demonstrate that all required permits and approvals from the appropriate regulatory authority (such as the primacy agency, municipality, or school board) have been obtained.
Supporting documentation demonstrating this readiness to proceed, such as bid documents, construction schedules, easements, and any legal agreements to access private property to complete the project, may be submitted as optional attachments, as referenced in Section IV of the solicitation. Please note the “Expeditious Project Readiness to Proceed” evaluation criteria in Section V.
Section V.A, Selection Criteria, states, Expeditious Project Readiness to Proceed:
Under this criterion applicants will be evaluated based on their ability, plan, and approach to proceeding expeditiously to implement the project upon award (see Section I.C of this announcement) taking into account the following factors.
Section I.B, National Priority Area 2 states, “The projects are expected to result in reduction of lead in drinking water in schools and/or childcare facilities in disadvantaged communities. Examples of eligible drinking water lead reduction activities to support this National Priority Area may include, but are not limited to, the following. The projects are expected to result in reduction of lead in drinking water in schools and/or childcare facilities in disadvantaged communities. Examples of eligible drinking water lead reduction activities to support this National Priority Area may include, but are not limited to, the following.
- Removing or replacing drinking water fixtures, fountains, or outlets demonstrated to be sources of lead in schools and/or child care facilities drinking water.
- Replacing plumbing materials determined to be sources of lead in schools and/or child care facilities drinking water.
- Conducting follow-up monitoring, public education, and outreach to ensure the long-term performance of the remediation.
The EPA also encourages applicants to propose other types of activities the objectives of this National Priority Area to meet the objective of addressing the reduction of lead exposure.”
E6. What is the expectation around the requirements for Expeditious Project Readiness to Proceed--can we describe that we have template for these things and what our process would be without having the concrete example for each school?
Please refer to Section C. Expeditious Project Readiness to Proceed, which states “Applications for projects under both of the National Priority Areas described above must demonstrate the applicant’s ability and readiness to proceed expeditiously upon receiving an award. Applicants must describe the plan and approach to proceed expeditiously to implement the project upon award of funding. Applicants should describe past and current practices being implemented to reduce exposure of lead in drinking water (such as public education and outreach, existing corrosion control treatment, or the use of control measures to reduce exposure from fountains or fixtures where elevated lead levels have been detected in schools or child care facilities). Applicants should include a description of the completed project planning and design phases. Applications must demonstrate that all required permits and approvals from the appropriate regulatory authority (such as the primacy agency, municipality, or school board) have been obtained.
Supporting documentation demonstrating this readiness to proceed, such as bid documents, construction schedules, easements, and any legal agreements to access private property to complete the project, may be submitted as optional attachments, as referenced in Section IV of the solicitation. Please note the Expeditions Project Readiness to Proceed evaluation criteria in Section V.”
In Section V, this information is included in Criteria #2. Expeditious Project Readiness to Proceed.
Selection Criteria 2) Expeditious Project Readiness to Proceed
“Under this criterion applicants will be evaluated based on their ability, plan, and approach to proceeding expeditiously to implement the project upon award (see Section I.C of this announcement) taking into account the following factors.
i. The extent and quality to which the application describes past and current practices being implemented to reduce exposure lead in drinking water. (5 points)
ii. The extent and quality to which the applicant demonstrates completion of planning and design, and securement of necessary approvals to proceed expeditiously. (10 points)”
E7. Do specific schools, school districts, and childcare facilities have to be identified at the time of proposal submittal, or is listing the state, county, and/or opportunity zones with known lead challenges and DAC status, acceptable?
Section V.A. Selection Criteria include, but are not limited to, the following,
1. “National Priority Area Under this criterion the applicant will be evaluated based on their ability and approach for effectively addressing the National Priority Area that is the subject of their application. In conducting this evaluation, the following factors will be evaluated:
i. The extent and quality of the overall approach to addressing the National Priority Area that is the subject of the application.
ii. The extent and quality to which the applicant describes a known lead issue in the disadvantaged community.
iii. The extent and quality to which the application demonstrates plans to provide public education, conduct outreach, and conduct post-implementation monitoring.
iv. The extent and quality to which the application demonstrates plans to maintain lead reduction after project completion.
v. The degree to which the proposed project demonstrates that the assistance will target disadvantaged communities with one or more lead action level exceedance(s) in the past three years.
vi. The degree to which the proposed project is in an Opportunity Zone and/or the proposed project will help improve health outcomes within an Opportunity Zone as described in Section I.A.
2. Expeditious Project Readiness to Proceed, Under this criterion applicants will be evaluated based on their ability, plan, and approach to proceeding expeditiously to implement the project upon award (see Section I.C of this announcement) taking into account the following factors.
i. The extent and quality to which the application describes past and current practices being implemented to reduce exposure lead in drinking water.
ii. The extent and quality to which the applicant demonstrates completion of planning and design, and securement of necessary approvals to proceed expeditiously.”
E8. Can a state apply for the grant to remediate disadvantaged schools that have been determined to have high lead levels, which are unknown until the testing conducted under the Voluntary Lead Testing in Schools program reveals which schools have remediation needs?
Please refer to Section I.B. National Priority Areas:
National Priority Area Two: Reducing Children’s Exposure to Lead in Drinking Water in Schools and Child Care Facilities
“Under this National Priority Area, the EPA is soliciting applications for projects in disadvantaged communities that will reduce children’s exposure to lead in schools and child care facilities through removal and/or replacement of lead-containing drinking water fixtures, fountains, outlets, and plumbing materials.”
Applicants should note criterion 2) Expeditious Project Readiness to Proceed in Section V. A. Selection Criteria: “Under this criterion applicants will be evaluated based on their ability, plan, and approach to proceeding expeditiously to implement the project upon award (see Section I.C of the RFA) taking into account the following factors.
i. The extent and quality to which the application describes past and current practices being implemented to reduce exposure lead in drinking water. (5 points)
ii. The extent and quality to which the applicant demonstrates completion of planning and design, and securement of necessary approvals to proceed expeditiously. (10 points)”
Applicants should note Section IV.D.2. Projective Narrative subsection “4. Milestone Schedule: Provide a projected milestone schedule for the proposed project period (up to four years). The milestone schedule should provide a breakout of the project 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. The project start date will follow award acceptance by the successful applicant.”
E9. Is initial sampling to discover and/or confirm a lead exceedance exists an eligible project activity/cost under NPA 2 in WIIN Act Section 2105 or if this only applies to post-implementation monitoring?
Please refer to Section I.B. National Priority Area Two: Reducing Children’s Exposure to Lead in Drinking Water in Schools and Child Care Facilities for eligible projects/activities The RFA states, “The projects are expected to result in reduction of lead in drinking water in schools and/or childcare facilities in disadvantaged communities. Examples of eligible drinking water lead reduction activities to support this National Priority Area may include, but are not limited to, the following.
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Removing or replacing drinking water fixtures, fountains, or outlets demonstrated to be sources of lead in schools and/or child care facilities drinking water.
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Replacing plumbing materials determined to be sources of lead in schools and/or child care facilities drinking water.
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Conducting follow-up monitoring, public education, and outreach to ensure the long-term performance of the remediation. “
Applicants should also refer to Section I.C Expeditious Project Readiness to Proceed states, “Applications for projects under both of the National Priority Areas described above must demonstrate the applicant’s ability and readiness to proceed expeditiously upon receiving an award. Applicants must describe the plan and approach to proceed expeditiously to implement the project upon award of funding. Applicants should describe past and current practices being implemented to reduce exposure of lead in drinking water (such as public education and outreach, existing corrosion control treatment, or the use of control measures to reduce exposure from fountains or fixtures where elevated lead levels have been detected in schools or child care facilities). Applicants should include a description of the completed project planning and design phases. Applications must demonstrate that all required permits and approvals from the appropriate regulatory authority (such as the primacy agency, municipality, or school board) have been obtained.
Supporting documentation demonstrating this readiness to proceed, such as bid documents, construction schedules, easements, and any legal agreements to access private property to complete the project, may be submitted as optional attachments, as referenced in Section IV of the solicitation. Please note the “Expeditious Project Readiness to Proceed” evaluation criteria in Section V.”
E10. The RFA references “drinking water fountains” as a point source that may be addressed under the grant. Are these fountains inclusive of those located on the exterior of the building (such as around playgrounds and ball fields)?
Please refer to Section I.B. National Priority Areas.
Under this National Priority Area, the EPA is soliciting applications for projects in disadvantaged communities that will reduce children’s exposure to lead in schools and child care facilities through removal and/or replacement of lead-containing drinking water fixtures, fountains, outlets, and plumbing materials.”
“Applicants should describe the known lead issue in the disadvantaged communities’ schools and/or childcare facilities by describing for example: drinking water fixtures, fountains, outlets and/or plumbing that need to be removed or replaced. The description may include prior use of the 3Ts, or applicable state regulations or guidance that are not less stringent, for identification and prioritization of drinking water fixtures, fountains, outlets and/or plumbing that need to be removed or replaced.”
E11. Under national priority area 2, do lead service lines qualify as plumbing materials that are determined to be sources of lead? Can applicants use funding under priority area 2 to replace lead service lines?
Applications are divided under 2 National Priority Areas under Section I.B. of the RFA. There is National Priority Area One: Reduction of Lead Exposure in the Nation’s Drinking Water Systems through Infrastructure and Treatment Improvements. The RFA states “Under this National Priority Area, the EPA is soliciting applications to reduce lead in drinking water in disadvantaged communities through infrastructure and/or treatment projects, such as lead service line replacement and corrosion control practices. For the purposes of this announcement “drinking water system” means a community water system, a nontransient noncommunity water system, and a water system located in an area governed by an Indian Tribe. National Priority Area Two: Reducing Children’s Exposure to Lead in Drinking Water in Schools and Child Care Facilities. The RFA states, “Under this National Priority Area, the EPA is soliciting applications for projects in disadvantaged communities that will reduce children’s exposure to lead in schools and child care facilities through removal and/or replacement of lead-containing drinking water fixtures, fountains, outlets, and plumbing materials.”
Applicants should note Section III.C. Threshold Eligibility Criteria, where the RFA states “These are requirements that if not met by the time of application submission will result in the elimination of the application from consideration from funding. Only applications that meet all of these criteria will be evaluated against the ranking factors in Section V of this announcement. This includes:
“2. Applications must address one, and only one, of the two National Priority Areas listed in
Section I.B. Eligible organizations may submit more than one application under this
competition 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.”
GENERAL PROJECT RELATED QUESTIONS
F1. What is the project length of time?
It is anticipated that a total of four to fifteen assistance agreements, each with a project period of up to four years, will be awarded under this announcement.
F2. We are applying for the Reduction of Lead Exposure in the Nation’s Drinking Water Systems through Infrastructure and Treatment Improvements grant. We need assistance determining whether the Quality Assurance/Quality Control is required for the proposed project. What documents do you need to determine this?
Please refer to Section II, Part A. Project Narrative, Subsection C. Workplan, #8 Reduced Cost Share/Match Waiver Request Letter and Quality Assurance/Quality Control, part B of the RFA (page 28), which explains what an application project narrative should describe as Quality Assurance/Quality Control (QA/QC) should they plan to collect or use environmental data or information. The application should explain how the applicant plans to comply with the Quality Assurance/Quality Control requirements. Additionally, information can be found on the Agency’s Enterprise Quality Management Division (EQMD) webpage that includes documents to assist in the development and implementation of a suitable Quality System for both EPA and non-EPA organizations. The documents include FAQs, and may provide guidance. They can be found on the following website: https://19january2021snapshot.epa.gov/quality.
F3. For the start date of the project, can I pick a date in the past? Or do I need to make the start date the date of when I make the application?
No. As stated on page 33 of the RFA, SECTION VI. Award Administrative Information, Part C. Administrative & National Policy Requirements, the general award and administration process for assistance agreements to be funded under this announcement are governed by regulations at 2 CFR 200.
2 CFR §200.458 Pre-award costs states “Pre-award costs are those incurred prior to the effective date of the Federal award directly pursuant to the negotiation and in anticipation of the Federal award where such costs are necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency.”
F4. Is a water system’s comprehensive project subject to grant reporting requirements if the grant was sought for and used to complete a phase of the project versus the whole project?
Grant reporting requirements apply to the federal funds and associated non-federal cost-share/match for awards made under this announcement. Please refer to Section VI.D. Reporting in the RFA, which states, “In general, recipients are responsible for managing the day-to-day operations and activities supported by the assistance funding, to assure compliance with applicable federal requirements, and for ensuring that established milestones and performance goals are being achieved…. Recipients will be required to report direct and indirect environmental results from the work accomplished through the award.”
Section III.B. Cost Sharing or Matching, states “Cost-share/match must be used for eligible and allowable project costs. Cost-share/matching funds are considered grant funds and are included in the total award amount and should be used for the reasonable and necessary expenses of carrying out the workplan. All grant funds are subject to federal audit. Any restrictions on the use of grant funds also apply to the use of the cost-share/match.”
F5. Is a QA/QC required for the proposed project? Which QA/QC requirements apply? The project is for lead service line replacement and we are designing the project with post-implementation monitoring as described in the RFA. What are the next steps for determining what QA/QC requirements apply.
Please refer to the response in the FAQ under F2. Additionally, the EPA Office of Environmental Information's Enterprise Quality Management Division (EQMD) oversees implementation of the EPA Quality Program which provides requirements for conducting quality management activities for environmental data collection and environmental technology programs performed by or for the Agency. The EQMD welcomes questions and suggestions. More information can be found at https://19january2021snapshot.epa.gov/quality/forms/contact-us-about-managing-quality-environmental-information
GENERAL APPLICATION QUESTIONS
G1. How do eligible applicants apply for grant funding?
Applicants must apply electronically through Grants.gov under this funding opportunity based on the grants.gov instructions in this announcement. See Section IV of the RFA for more information. If an applicant does not have the technical capability to apply electronically through grants.gov because of limited or no internet access which prevents them from being able to upload the required application materials to Grants.gov, the applicant must contact OGDWaivers@epa.gov or the address listed in Section IV. A, Requirement to Submit Through Grants.gov and Limited Exception Procedures, in writing (e.g., by hard copy, email) at least 15 calendar days prior to the submission deadline under this announcement to request approval to submit their application materials through an alternate method.
G2. If an applicant has questions regarding the RFA, where should they be directed, and how long do they have to ask questions?
Questions about this RFA must be submitted in writing via e-mail and must be received by the Agency Contact, at WIINDrinkingWaterGrants@epa.gov, as identified in Agency Contact (Section VII. of the RFA), by May 15, 2020. Written responses will be posted here on EPA’s FAQs webpage.
G3. Can an applicant apply for both NPAs with the same application?
No. Each application submitted under this announcement must address one, and only one, of the National Priority Areas described below. Applicants may submit more than one application package under this announcement as long as each application is separately submitted and addresses only one National Priority Area.
G4. How do I know if my application was received by the deadline?
After submitting an application in Grants.gov, you will receive a confirmation PDF through the Grants.gov user interface in addition to the confirmation email. You may use the tracking number in confirmation PDF to check the application status.
Applications submitted through Grants.gov will be time and date stamped electronically. If you have not received a confirmation of receipt from the EPA (not from grants.gov) within 60 days of the application deadline, please contact Brianna Knoppow, (202) 564-4433. Failure to do so may result in your application not being reviewed.
G5. The required elements of the Project Narrative are outlined very specifically in the RFA, but it does not include where applicants should include information on their disadvantaged community status. Where in the application package would you like applicants to include documentation showing that they meet Disadvantaged Community status? Does this belong in the Workplan or as an attachment?
Section III.C., Threshold Eligibility Criteria states that “Applications must demonstrate that the proposed project is in a disadvantaged community. Each state establishes affordability criteria under section 1452(d)(3) of the Safe Drinking Water Act (SDWA), and a disadvantaged community is defined as “the service area of a public water system that meets affordability criteria.” The affordability criteria must be met for the community for which the project will be performed. Applicants must include their state’s affordability criteria and how the proposed project meets the affordability criteria. Applicants can obtain more information about their state’s affordability criteria in their state’s most current final Intended Use Plan or contacting their state Drinking Water State Revolving Fund program for more information.” Applicants are responsible for the content of their application.
G6. What type of commitment is required by the City for this grant? Is a formal action required by the City appropriating the 20% match funds or is a letter. Are a range of points awarded in this category? If so what is the difference between a letter commitment and an appropriation commitment of funds?
A letter of commitment for the non-federal cost share/match is not required. Section III.B, Cost Sharing or Marching states “All applicants must demonstrate in their application submission how they will contribute a minimum non-federal cost-share/match of 20 percent of the total project cost. The non-federal cost-share/match may be provided in cash or from in-kind contributions, such as use of volunteers and/or donated time, equipment, expertise, and is subject to the regulations governing matching fund requirements described in 2 CFR 200.306, as applicable. In-kind contributions often include salaries or other verifiable costs and this value must be carefully documented. In the case of salaries, applicants may use either minimum wage or fair market value. Cost-share/match must be used for eligible and allowable project costs. Cost-share/matching funds are considered grant funds and are included in the total award amount and should be used for the reasonable and necessary expenses of carrying out the workplan. All grant funds are subject to federal audit. Any restrictions on the use of grant funds also apply to the use of the cost-share/match. Other federal grants may not be used as cost-share/match without specific statutory authority. Examples of cost share/match calculations are provided in Table 1.
Section IV.D.2.C.5, Detailed Budget Narrative, states “Provide a detailed budget and estimated funding amounts for each project component/task. This section provides an opportunity for narrative description of the budget or aspects of the budget found in the Sf-424A such as “other” and “contractual”. a. Applicants must itemize costs related to personnel, fringe benefits, contractual costs, travel, equipment, supplies, other direct costs, indirect costs and total cost. All subgrant funding should be located in the “other” cost category. Total costs must include both federal and cost- share/matching (non-federal) components. For each cost category, indicate what portion of the cost will be paid by the EPA and what portion of the cost will be covered by the minimum non-federal cost-share/match. Also indicate whether the applicant has requested a cost share/match request waiver (the non-federal cost share/match may be reduced to 10 percent for NPA 1 applicants. The non-federal cost share/match may be reduced in full for NPA 2 applicants). See Section III. B for additional information. Describe itemized costs in sufficient detail for the EPA to determine the allowability of costs for each project component/task, as well as the cost-effectiveness and reasonableness of all costs (both federal and non-federal components).”
Section V.A states under the Milestone Schedule/Detailed Budget factor, “The reasonableness of the budget and estimated funding amounts for each project component/task and the adequacy of the information provided in the detailed budget and whether the proposed costs are reasonable and allowable. Total costs must include both federal and cost-share/match (non-federal) components. The cost-effectiveness and reasonableness of all costs (both federal and non-federal components) will also be evaluated. (8 points).”
G7. How do I find out if the project needs to be reviewed under State Executive Order 12372 process?
Intergovernmental Review of Federal Programs, can be found at the following website: https://www.whitehouse.gov/wp-content/uploads/2017/11/Intergovernmental_-Review-_SPOC_01_2018_OFFM.pdf. More information on the process can be found on the EPA Office of Grants and Debarment website at: https://19january2021snapshot.epa.gov/grants/fact-sheet-applicants-intergovernmental-review-process
Executive Order 12372, Intergovernmental Review of Federal Programs, may be applicable to awards resulting from this announcement. EPA implemented the Executive Order in 40 CFR Part 29. EPA may require applicants selected for funding to provide a copy of their application to their State Point of Contact (SPOC) for review as provided at 40 CFR 29.7 and 40 CFR 29.8. The SPOC list can be found on the webpage below.
EPA may require successful applicants from states that do not have a SPOC to provide a copy of their application for review to directly affected state, area-wide, regional and local government entities as provided at 40 CFR 29.7 and 40 CFR 29.8. These reviews are not required before submitting an application. Only applicants that EPA selects for funding under this announcement are subject to the Intergovernmental Review requirement.
G8. Where in the application package would applicants document the project meets the Disadvantaged Community status, in the Workplan or as an attachment?
Section III.C. Threshold Eligibility Criteria, of the RFA states “3. Applications must demonstrate that the proposed project is in a disadvantaged community. Each state establishes affordability criteria under section 1452(d)(3) of the Safe Drinking Water Act (SDWA), and a disadvantaged community is defined as “the service area of a public water system that meets affordability criteria.” The affordability criteria must be met for the community for which the project will be performed. Applicants must include their state’s affordability criteria and how the proposed project meets the affordability criteria. Applicants can obtain more information about their state’s affordability criteria in their state’s most current final Intended Use Plan or contacting their state Drinking Water State Revolving Fund program for more information.”
Section IV.D.2.C. Content of Application Package Submission, The Project Narrative, Workplan states, “The workplan must address the following elements.
1. National Priority Area:
a. Describe the approach for addressing one of the two National Priority Areas. Provide a description of the extent to which the project supports lead reduction for the disadvantaged community (e.g. the number of lines that will be replaced and the population they serve, the installation of corrosion control treatment, the addressing of lead exposure in schools and/or child care facilities).
b. Describe the known lead issue in the disadvantaged community. Examples of relevant information include any lead action level exceedances the system has had, service line inventories, testing results identifying drinking water fixtures, fountains, outlets, and plumbing materials with high levels of lead, historic challenges in meeting the requirements of the Lead and Copper Rule, and any other information relevant to demonstrate the need for the proposed lead reduction project.”
Section V.A. Selection Criteria of the RFA states, “All eligible applications, based on the Section III threshold eligibility review, will be evaluated based on the evaluation criteria and weights (100 total point scale). Points will be awarded based on how well and thoroughly each criterion and/or sub-criterion is addressed in the application package.”
Under 1) National Priority Area, the following sub-criterion is factored in for evaluation:
“v. The degree to which the proposed project demonstrates that the assistance will target disadvantaged communities with one or more lead action level exceedance(s) in the past three years. (3 points)”
G9. Where is the link to Synopsis 6?
As stated in Section 4.C.Technical Issues With Submission
“1. Once the application package has been completed, the "Submit" button should be enabled. If the "Submit" button is not active, please call Grants.gov for assistance at 1-800-518-4726.”
G10. If applicants include, in the project narrative, a description of the budgetary costs, do they still have to fill out the non-construction budget form included in the RFA application materials?
Section IV.B., Grants.gov Application Submission Instructions, states;
“Application Materials
The following forms and documents are required under this announcement.
Mandatory Documents:
1. Application for Federal Assistance (SF-424).
2. Budget Information for Non-Construction Programs (SF-424A).
3. EPA Key Contacts Form 5700-54.
4. EPA Form 4700-4 – Preaward Compliance Review Report.
5. Narrative Proposal (Project Narrative Attachment Form)-prepared as described in Section IV of the announcement.
Optional Documents:
6. Other Attachments Form – Biographical Sketches
7. Other Attachments Form – Negotiated Indirect Cost Rate Agreement, if applicable
8. Other Attachments Form – Supporting documentation demonstrating readiness to proceed
9. Other Attachments Form – Supporting documentation describing the known lead issue”
G11. FORM 4700-4 Preaward Compliance Review Report: Are pipe replacements considered “new construction” ?
Please review the form’s instructions and guidelines for the Environmental Protection Agency Preaward Compliance Review Report for all Applicants and Recipients Requesting Federal Financial Assistance (form 4700-4). The instructions on how to fill out the form can be found here: https://19january2021snapshot.epa.gov/sites/static/files/2014-09/documents/epa_form_4700_4.pdf
G12. Would a 319 subaward grant from the state be considered a federally funded EPA assistance agreement for past performance?
Section IV.D.2.C.7. Past Performance states in part “Briefly describe federally funded and/or non-federally funded assistance agreements (assistance agreements include grants and cooperative agreements but not contracts) similar in size, scope, and relevance to the proposed project that your organization performed within the last three years (no more than five agreements). If you have had any EPA agreements in the last three years, those are preferred to be included.” Subgrantee past performance is not considered a federally funded EPA assistance agreement because a subgrantee is accountable and responsible to the prime grantee (in this example the state). For the past performance to qualify for consideration the applicant must be the direct recipient of federal and/or non-federal assistance agreement funding.
Section IV also states “Note: In evaluating an applicant’s past performance, the Agency will consider the information provided by the applicant and may also consider relevant information from other sources, including information from EPA files and/or from current and prior federal agency grantors (e.g. to verify and/or supplement the information provided by the applicant). If you do not have any relevant or available past performance information, please indicate this in the application, and you will receive a neutral score for these factors under Section V. Failure to provide any programmatic past performance or reporting information, or to include a statement that you do not have any relevant or available past performance or reporting information, may result in a zero score for these factors (see also Section V).”
G13. On Form SF-424, item #14, it is asking for “Areas Affected by Project”. In the Request for Application, there is no specific area; do we reference “National Priority Area One or Two”?
Regarding the forms for the application process, please refer to the EPA’s Funding Opportunities: How to Apply and Required Forms webpage and instructions for Form SF-424, which can be found at : https://19january2021snapshot.epa.gov/sites/static/files/2015-04/documents/sf424instructions.pdf
G14. Will it help our application to have letters of support from Congressional Representatives representing our distribution system?
Please refer to SECTION VII. AGENCY CONTACT
Note to Applicants: 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.
Applicants should also refer to Section IV.B Grants.Gov Application Submission Instructions.
Optional Documents:
6. Other Attachments Form – Biographical Sketches
7. Other Attachments Form – Negotiated Indirect Cost Rate Agreement, if applicable
8. Other Attachments Form – Supporting documentation demonstrating readiness to proceed
9. Other Attachments Form – Supporting documentation describing the known lead issue
Who can I contact if I have further questions?
You may send additional questions to WIINDrinkingWaterGrants@epa.gov.