FEDERAL AGENCY AND OFFICE: U.S. Environmental Protection Agency, Office of Environmental Justice and External Civil Rights
(OEJECR)
FUNDING OPPORTUNITY TITLE: Environmental and Climate Justice Community Change Grants Program
ANNOUNCEMENT TYPE: Notice of Funding Opportunity (NOFO) FUNDING OPPORTUNITY NUMBER: EPA-R-OEJECR-OCS-23-04
ASSISTANCE LISTING NUMBER: 66.616
ACTION: Modification No. 3 to the NOFO
DATE: August 6, 2024
SUMMARY: This modification revises and clarifies the February 12, 2024 NOFO , which was originally issued on November 21, 2023. This version of the NOFO supersedes previous versions of the NOFO. The revisions of this modification include:
1. The Important Dates section on the first page is revised to indicate that initial selections were made in July 2024, and the anticipated start of the period of performance for the initial selections is November 2024.
In addition, on the first page EPA added a notice about the changes to the grant regulations in 2 CFR.
2. In section I.D the language about the Track I Two -Phase Evaluation Process is revised to remove the reference to oral presentations. EPA is eliminating the oral presentation component of the Track I application process to streamline the application and review process, reduce burdens on applicants, and facilitate timely awards to benefit disadvantaged communities as required by the Inflation Reduction Act.
3. In order to account for the grant regulation change increasing the de minimus indirect cost rate from 10% to 15% effective October 1, 2024, Section II.A of the NOFO and corresponding sections are revised to remove the statement that Track I awards cannot exceed $20 million and that Track II awards cannot exceed $3 million. This modification does not impact threshold eligibility criteria #10 in Section III.D.
4. In Section II.B, “Hawaii” was removed from TIA B to clarify that the TIA applies only to Federally Recognized Tribes in the Continental United States.
5. Section II.E is revised to indicate that the first awards are expected in the fall of 2024.
6. Sections V.B, C, and D of the NOFO are revised to remove the oral presentation component for Track I applications, and corresponding changes are made in these sections for consistency purposes.
7. Section V.F of the NOFO is revised to indicate that initial selections were made in July 2024 and initial awards are expected to be made by November 2024.
8. Appendix A is revised to update the components of the EPA map used to identify disadvantaged communities specific to this NOFO and to make additional clarifying changes. 1 2
FEDERAL AGENCY AND OFFICE: U.S. Environmental Protection Agency, Office of Environmental Justice and External Civil Rights
(OEJECR)
FUNDING OPPORTUNITY TITLE: Environmental and Climate Justice Community Change Grants Program
ANNOUNCEMENT TYPE: Notice of Funding Opportunity (NOFO) FUNDING OPPORTUNITY NUMBER: EPA-R-OEJECR-OCS-23-04
ASSISTANCE LISTING NUMBER: 66.616
IMPORTANT DATES:
November 21, 2023 NOFO Opening Date
November 21, 2024 Application Closing Date
July 2024 Initial Award Selections Made
November 2024 Anticipated Start of Period of Performance for Initial Selections
DEADLINE: Application packages will be accepted on a rolling basis, as further explained in the NOFO, until November 21, 2024, at 11:59 PM (Eastern Time) through Grants.gov. Applications received after the closing date and time will not be considered for funding.
In alignment with EPA’s commitment to conducting business in an open and transparent manner, copies of applications selected for award under this NOFO may, as appropriate, be made publicly available on the OEJECR website or other public website for a period after the selected applications are announced.
Therefore, applicants should clearly indicate which portion(s) of the application, if any, they are claiming contains confidential, privileged, or sensitive information. As provided at 40 CFR § 2.203(b), if no claim of confidential treatment accompanies the information when it is received by EPA, it may be made available to the public by EPA without further notice to the applicant.
Notice To Applicants: The revisions to the grant regulations in 2 CFR described at 89 FR 30046- 30208 (April 22, 2024) will apply to awards made under this NOFO, including the change to the de minimis indirect cost rate.
NOTE: Prior to naming a contractor (including consultants) or subrecipient in your application as a “partner,” please carefully review Section IV.d, “Contracts and Subawards,” of EPA’s Solicitation Clauses that are incorporated by reference in this NOFO in Section I.J. EPA expects recipients of funding to comply with competitive procurement contracting requirements as well as EPA’s rule on Participation by Disadvantaged Business Enterprises in EPA Programs in 40 CFR Part 33. The Agency does not accept justifications for sole source contracts for services or products available in the commercial marketplace based on a contractor’s role in preparing an application or a firm or individual’s “unique” qualifications. 3 TABLE OF CONTENTS:
Section I. Funding Opportunity Description............................................................................................6 A. Backgr
ound: Inflation Reduction Act and Executive Orders............................................................... 6 B. Stat
utory and Regulatory Authority....................................................................................................... 7 C. Communi
ty Change Grants Objectives ................................................................................................ 8 D. NOFO
Competition Features................................................................................................................. 8 E. Technica
l Assistance............................................................................................................................. 9 F. Commun
ity or Tribal Relocation Resources......................................................................................... 9 G. Funding Tr
ack I: Community-Driven Investments for Change .........................................................10 H. Funding Tr
ack II: Meaningful Engagement for Equitable Governance.............................................21 I. EPA St
rategic Plan Linkage, Anticipated Outputs, Outcomes & Performance Measures...................24 J. Additiona
l Provisions for Applicants Incorporated into the NOFO ...................................................25 Section I
I. Federal Award Information ..................................................................................................26 A. Number
and Amount of Awards .........................................................................................................26 B. Targe
t Investment Areas (TIA) for Track I Applications....................................................................26 C. Rolli
ng Application Submittal and Review Process, Application Award Limits, and Application Resubmission Procedures.........................................................................................................................27 D. Conditi
onal Awards............................................................................................................................28 E. Peri
od of Performance .........................................................................................................................28 F. Part
ial Funding.....................................................................................................................................28 G. Additi
onal Awards...............................................................................................................................29 H. Funding Type ......................................................................................................................................29 Section I
II. Eligibility Information..........................................................................................................30 A. Eligible
Applicants .............................................................................................................................30 B. Stat
utory Partnership Requirements and Collaborating Entities ........................................................32 C. Cost-Shari
ng or Matching Funds........................................................................................................33 D. Thres
hold Eligibility Criteria .............................................................................................................33 Section I
V. Application and Submission Information...........................................................................36 A. Requir
ement to Submit through Grants.gov and Limited Exception Procedures................................36 B. Conten
t of Application Submission.....................................................................................................39 C. Inform
ational Webinars and Application Assistance .........................................................................48 Section
V. Application Review Information...........................................................................................48 A. Thres
hold Eligibility Review Process ................................................................................................49 4 B. Review Panel and Evaluation Process................................................................................................49 C. Track I
Application Review Process and Evaluation Criteria ............................................................49 D. Tra
ck II Application Review Process and Evaluation Criteria...........................................................54 E. Fina
l Selection Process and Other Factors..........................................................................................57 F. Anti
cipated Announcement and Federal Award Date.........................................................................58 Secti
on VI. Award Administration Information....................................................................................60 A. Awa
rd Notification and Disputes ........................................................................................................60 B. Adminis
trative and National Policy Requirements .............................................................................60 C. Audit
Requirements.............................................................................................................................63 D. Remedi
es for Non-Compliance ...........................................................................................................63 E. Progr
am Administration Activities ......................................................................................................64 F. Fraud
, Waste, and Abuse Awareness...................................................................................................64 G. Quali
ty Management Plans (QMPs) & Quality Assurance Project Plans (QAPPs)............................64 Section
VII. Contact Information............................................................................................................66 Appendix A
. Definition of Disadvantaged Communities and Mapping Requirements......................67 Appendix B
. Partnership Agreement between the Lead Applicant and Statutory Partner ..............70 Append
ix C. Climate Action Strategies and Associated Project Activities .........................................71 Appendix D
. Pollution Reduction Strategies and Associated Project Activities .................................78 Appendix E
. Job Quality & Equitable Employment Opportunities ....................................................81 Appendix F.
Track I and II Outputs and Outcomes..............................................................................82 Appendix G
. Budget Template ................................................................................................................87 Appendix H
. Alaska Tribal Lands Target Investment Area.................................................................92 5 Section I. Funding Opportunity Description
(back to the Table of Contents)
A. Background: Inflation Reduction Act and Executive Orders The Environmental and Climate Justice Community Change Grant program (Community Change Grants) – the subject of this NOFO – offers an unprecedented opportunity to transform disadvantaged communities across the United States into healthy, climate resilient, and thriving communities for their current and future residents. The Community Change Grants will fund community-driven projects that address climate challenges and reduce pollution while strengthening communities through thoughtful implementation. The historic levels of support provided by these grants will enable communities and their partners to overcome longstanding environmental challenges and implement meaningful solutions to meet community needs now and for generations to come.
The Inflation Reduction Act ( IRA) created the Environmental and Climate Justice Program ( ECJP)—the largest investment in environmental and climate justice in U.S. history —when it was signed into law by President Biden on August 16, 2022. The E CJP is now contained in Section 138 of the Clean Air Act (CAA), 42 U .S.C. § 7438. Under this program, EPA was provided $2.8 billion to award grants to help disadvantaged communities address a wide range of environmental and climate justice issues, and $200 million for technical assistance related to these grants. This historic investment advances Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, which established a whole-of-government approach to advancing equity and opportunity, and Executive Order 14008, Tackling the Climate Crisis at Home and Abroad, which created the government- wide Justice 40 Initiative that established the goal that 40 percent of the overall benefits of certain federal investments flow to disadvantaged communities. Awards under the E CJP also support core goals of Executive Order 14091, Further Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, and Executive Order 14096, Revitalizing Our Nation’s Commitment to Environmental Justice for All.
The Community Change Grants are the final and most comprehensive piece of EPA’s implementation of ECJP IRA funding. The Community Change Grants will complement grant programs that EPA launched in 2022 and 2023, including those for the Collaborative Problem-Solving, Government-to-Government, and Thriving Communities Grantmaker programs. Collectively, these programs will empower communities and their partners to design, develop, and implement multi-faceted community-driven projects. These programs will address the diverse and unique needs of disadvantaged communities by:
1. Reducing and preventing pollution;
2. Building resilience to climate change and mitigating current and future climate risks;
3. Enhancing meaningful involvement in government processes related to environmental and climate justice;
4. Expanding access to high-quality jobs and economic opportunity through workforce development; and
5. Bolstering community strength by ensuring that local residents receive the benefits of investments and have the opportunity to build on them for current and future generations.
Through the approximately $2 billion to be awarded under the Community Change Grants, and the technical assistance that will be available to eligible applicants related to the grants, EPA will advance the goals of these Executive Orders (EO) and the agency’s environmental and climate justice priorities. Environmental justice, as defined by EO 14096, means the just treatment and meaningful involvement of all people, 6 regardless of income, race, color, national origin, Tribal affiliation, or disability, in agency decision-making and other federal activities that affect human health and the environment so that people:
• Are fully protected from disproportionate and adverse human health and environmental effects (including risks) and hazards, including those related to climate change, the cumulative impacts of environmental and other burdens, and the legacy of racism or other structural or systemic barriers; and
• Have equitable access to a healthy, sustainable, and resilient environment in which to live, play, work, learn, grow, worship, and engage in cultural and subsistence practices.
B. Statutory and Regulatory Authority
The authority for the awards under this NOFO is Clean Air Act (CAA) § 138, codified at 42 U.S.C. § 7438.
Of the $2.8 billion appropriated , approximately $2 billion will be awarded for the Community Change Grants under this NOFO. As provided in 42 U.S.C. § 7438(a)(1) and (b)(1), all the funds must be awarded by September 30, 2026, the grants cannot be longer than three years in duration, and no extensions will be granted.
Eligible entities and eligible activities are defined in 42 U.S.C. §7438(b)(2) and (3) and are further described below and in Section I and Section III of this NOFO.
Section 138(b)(2) of the CAA specifies that a n eligible entity may use a grant awarded under this NOFO for:
1. community-led air and other pollution monitoring, prevention, and remediation, and investments in low and zero- emission and resilient technologies and related infrastructure and workforce development that help reduce greenhouse gas emissions1 and other air pollutants;
2. mitigating climate and health risks from urban heat islands, extreme heat, wood heater emissions, and wildfire events;
3. climate resiliency and adaptation;
4. reducing indoor toxics and indoor air pollution; or
5. facilitating engagement of disadvantaged communities in s tate and federal advisory groups, workshops, rulemakings, and other public processes.
In addition, Section 102(2)(I) of the National Environmental Policy Act, 42 U.S.C. § 4332(2)(I) is applicable to international work, if any, under this NOFO. Further, all funded activities under this NOFO must comply with federal, state, and local laws and regulations, including but not limited to:
1. 2 CFR 200.435(b), which restricts the use of grant funds to defend a recipient that is subject to a criminal, civil or administrative proceeding against it commenced by any government for fraud or similar offenses;
2. 2 CFR 200.435(g), which precludes the use of grant funds to prosecute claims against the Federal Government; and
3. 2 CFR 200.450(c), which restricts the use of federal funds by nonprofit organizations for certain lobbying or electioneering activities but does not preclude the use of federal funds to promote adoption of local ordinances, including those related to zoning. 1 “Greenhouse gas” means the air pollutants carbon dioxide, hydrofluorocarbons, methane, nitrous oxide, perfluorocarbons, and sulfur hexafluoride.
7 4. 40 CFR Parts 5 and 7, which prohibit discrimination on the basis of race, color, national origin (including limited-English proficiency), disability, sex, and age by recipients and subrecipients of federal financial assistance.
C. Community Change Grants Objectives
The Community Change Grants will support comprehensive community and place- based approaches to redressing environmental and climate injustices for communities facing legacy pollution, climate change, and persistent disinvestment. These concentrated local investments will fund community-driven, change- making projects that center collaborative efforts for healthier, safer, and more prosperous communities.
Designed with meaningful community, Tribal, and other stakeholder involvement, the investments EPA makes through the Community Change Grants are intended to achieve the following objectives:
1. Provide resources for community-driven projects to address environmental and climate challenges in communities facing disproportionate and adverse health, pollution, and environmental impacts, and suffering from generations of disinvestment.
2. Invest in strong cross -sectoral collaborations with partners who bring a robust commitment to working with and for communities with environmental and climate justice concerns.
3. Unlock access to additional and more significant resources to advance environmental and climate justice goals from across the federal government and other sources.
4. Empower communities and strengthen their capacity to drive meaningful positive change on the ground for years to come.
5. Strengthen community participation in government decision-making processes that impact them.
D. NOFO Competition Features
EPA anticipates awarding approximately $2 billion in funding through this NOFO , depending on funding availability, quality of applications received, EPA priorities, and other applicable considerations. EPA will consider applications under two separate tracks.
• Track I applications – Community-Driven Investments for Change will focus on multi-faceted applications with Climate Action and Pollution Reduction Strategies to meaningfully improve the environmental, climate, and resilience conditions affecting disadvantaged communities. Awards under Track I are expected to be $10-20 million each. EPA expects to award approximately $1.96 billion for approximately 150 Track I awards, including those under the Target Investment Areas described in Section II.B.
• Track II applications – Meaningful Engagement for Equitable Governance will facilitate the engagement of disadvantaged communities in governmental processes to advance environmental and climate justice. Awards under Track II are expected to be $1 -3 million each. EPA will award approximately $40 million for approximately 20 Track II awards.
The number of Track I and Track II awards are estimates, and EPA reserves the right to increase or decrease the total number of awards and dollar amounts for each t rack, contingent on the quality of applications received, the amount of funds awarded to selected applicants, budget availability, agency priorities, programmatic considerations, or a combination of these. 8 Target Investment Areas for Track I Applications : EPA has identified five Target Investment Areas (TIA) to help ensure that communities with unique circumstances, geography, and needs can equitably compete for funding (see Section II.B). Applicants applying under a specified TIA will compete against other applicants under the same TIA, as opposed to the broader application pool. Please note that applicants applying for the TIA for Alaska Tribal lands should review Appendix H for additional guidance pertaining to the Climate Action and Pollution Reduction Strategies to include in their application, including those related to the Alaska Native Claims Settlement Act (ANCSA).
Eligible Applicants: Eligible applicants for the Community Change Grants include a partnership between two community-based non-profit organizations (CBOs), or a partnership between a CBO and one of the following: a Federally recognized Tribe, a local government, or an institution of higher education (IHE), including Minority Serving Institutions as further described in Section III.A . Other organizations and entities may participate in the Community Change Grants as Collaborating Entities through subawards, or as contractors selected in accordance with competitive procurement requirements. Further details about applicant eligibility, partnership requirements, Collaborating Entities, subawards, and procurement contracts are in Section III.
Under this NOFO, Lead Applicants, as defined in Section III.A , may submit a maximum of two eligible applications and may receive up to two awards , if they demonstrate the capacity and capabilities to effectively perform, manage, oversee, and complete the awards within the three -year grant period of performance. The two applications may be two Track I applications, two Track II applications, or one of each. Lead Applicants who submit more than two total eligible applications will be asked to withdraw the excess one(s). EPA will not review more than two eligible applications from any one Lead Applicant.
In addition, EPA is introducing several features to enhance community involvement and ease the application process. Unless otherwise noted, the following applies to both Track I and Track II applications:
• Rolling Applications. EPA will allow applications to be submitted on a rolling basis over a 12- month period, through November 21, 2024, and will permit applicants to resubmit an unsuccessful application after a debriefing with the agency. Further details about the rolling application and resubmission process are in Sections II and V.
• Fast-Tracked Approach. EPA will review and select high-quality applications to fund on a rolling basis to deliver results and benefits to disadvantaged communities. • Indirect Costs Limitation. As further described in Appendix G, there is a 20% cap on indirect costs for certain recipients and subrecipients.
E. Technical Assistance
Under the IRA, EPA received $200 million for technical assistance to eligible entities in connection with the ECJP. Technical assistance will be available for pre-award technical assistance including but not limited to designing a project, preparing an application, or facilitating partnerships, and for post-award technical assistance to help grant recipients manage, oversee, perform, and report on the grants. Further details about technical assistance can be found here, and additional information on technical assistance that may be available through EPA’s technical assistance contractor can be found here. Receiving technical assistance does not guarantee that applicants will be selected for funding.
F. Community or Tribal Relocation Resources
9 Projects for community or Tribal relocation activities are not eligible for funding under this NOFO and will not be reviewed. For purposes of this NOFO, relocation activities generally include activities intended to plan or assist the moving of an individual from their residence or a business from its place of business. 2 EPA is working with other federal agencies on a separate and tailored effort to develop a support mechanism for communities that want to implement community-driven relocation plans. EPA intends to share relocation assistance information in future guidance posted on the Community Change Grants website. In the interim, information related to Federally-assisted relocation can be found on FEMA’s webpage and in the HUD Climate Resilience Implementation Guide for Community Driven Relocation . A ny questions about whether an activity is considered a relocation activity should be sent by email to [email protected] prior to applying.
G. Funding Track I: Community-Driven Investments for Change
1. Track I Objectives
Track I is the primary emphasis for the Community Change Grants. These projects will be implemented through strong collaborations to achieve sustained impacts related to climate resilience, pollution reduction, community health , economic prosperity, and community strength. This approach catalyzes change by focusing on the following objectives:
• Increase community resilience through climate action activities: Implement comprehensive Climate Action Strategies and infrastructure that build the resilience and adaptive capacities of communities, reduce greenhouse gas (GHG) emissions, and better prepare for and reduce the impacts of climate change.
• Reduce local pollution to improve public health: Reduce and remediate quantifiable health - harming pollutants to improve public health.
• Center meaningful community engagement: Conduct robust community engagement throughout the project – from design to implementation.
• Build community strength: Develop strategies to increase the likelihood that benefits of the investments accrue to existing residents of disadvantaged communities , both immediately and sustainably beyond the grant period.
• Reach priority populations: Support people within the Project Area as described in Appendix A who are acutely exposed to and impacted by climate, pollution, and weather -related threats, and / or who exhibit acute vulnerabilities to the impacts of environmental pollution.3 • Maximize integration across projects: Ensure that the projects and activities within the Project Area are integrated and complement each other to maximize benefits. 2 The Uniform Relocation Assistance and Real Property Acquisition Policies Act, 42 U.S.C. § 4601 et seq. (URA) would apply if a construction project funded through a Community Change Grant has an incidental effect of permanently displacing residents or businesses.
3 This may include populations of concern as identified in The Impacts of Climate Change on Human Health in the United States: A Scientific Assessment (2016) that “experience disproportionate, multiple, and complex risks to their health and well-being in response to climate change,” such as children and pregnant women, older adults, and those with low incomes, limited-English-proficiency, disabilities or chronic medical conditions, or other risks that may put them at greater vulnerability.
10 2. Track I Community Vision Description
Track I applications should be rooted in addressing specific, community-driven environmental justice challenges. Accordingly, Track I applications should begin with a Community Vision Description that, at a minimum, provides an overview of the Project Area (as described in Appendix A) to benefit from the grant, a clear description of the challenges the Project Area faces, and a vision for how the grant will respond to those challenges to advance environmental and climate justice in the Project Area. This description should provide essential context for the rest of the application, informing how the Climate Action and Pollution Reduction Strategies were selected and the positive impact the applicant envisions the grant will have in the Project Area. The Community Vision Description is further described in Section IV.B: Content of Application Submission.
3. Track I Application Requirements
Track I applications must address the following six requirements, as further described below . Additional information about the contents of the Project Narrative for Track I applications can be found in Section IV.B: Content of Application Submission and information about how applications will be evaluated can be found in Section V.C: Track I Application Review Process and Evaluation Criteria.
Requirement 1. Climate Action Strategy: Applications must include at least one project aligned with at least one of the C limate Action Strategies as described below. The Climate Action Strategies focus on strengthening the community’s climate resilience and / or reducing GHG emissions. Climate Action Strategies should be responsive to the community challenges described in the Community Vision Description.
Requirement 2. Pollution Reduction Strategy: Applications must include at least one project aligned with at least one of the Pollution Reduction Strategy as described below. The Pollution Reduction Strategy can include monitoring, prevention, reduction, and remediation activities that support community efforts to address quantifiable and health-harming pollutants . Pollution Reduction S trategies range broadly depending on the type and pathway of pollution (e.g., indoor, or outdoor air pollution, water pollution, soil pollution). Pollution Reduction Strategies should be responsive to the community challenges described in the Community Vision Description.
Requirement 3 . Community Engagement and Collaborative Governance Plan : Successful implementation of environmental and climate justice projects requires relationships among an ecosystem of community leaders and members along with partners across varied sectors. To help ensure that the community itself drives project development and implementation, applicants must submit a Community Engagement and Collaborative Governance Plan which should demonstrate how the applicant will inform, respond to, and engage community members through out project development and implementation. This plan should include a Collaborative Governance Structure, which describes the roles and responsibilities of the Lead Applicant, Collaborating Entities, and community residents in implementing the project.
Requirement 4. Community Strength Plan : Applicants must submit a Community Strength Plan that describes how their proposed projects will enhance the overall strength and economic prosperity of the community, including maximizing the benefits of the projects for existing residents and minimizing potential risks associated with investing significant resources into the Project Area. This should include strategies for how the projects will promote inclusive economic development, drive benefits of the projects to existing residents, and proactively address unintended displacement consequences. This plan should speak to how the projects will enhance the overall wellbeing of the community, ensuring existing 11 community members receive the benefits of these investments and can build on those benefits for future generations.
Requirement 5. Readiness Approach: Given the statutory requirement that all Community Change Grants must be completed within three years, applicants must describe how they will be able to initiate grant performance upon award, or generally no later than 120 days after award, so they can successfully complete the grant within the three-year period of performance.
Requirement 6. Compliance Plan: Applicants must submit a Compliance Plan that describes how they will: (1) ensure compliance with the grant’s terms and conditions, including 2 CFR § 200.302(b) (financial management), 2 CFR § 200.303 (internal controls), and 2 CFR § 200.332 (requirements for pass -through entities); and (2) manage broader legal and compliance risks.
Details of Track I Application Requirements
Requirement 1. Climate Action Strategies: Applicants must include at least one project aligned with at least one of the Climate Action Strategies identified below. When addressing the strategy in their application, applicants should describe relevant challenges faced in the Project Area and how the selected Climate Action Strategy(ies) and associated project(s) will address those challenges. Each Climate Action Strategy outlined below is focused on building short-term and long-term climate resilience, reducing GHGs, and providing additional co- benefits so that impacted communities can adapt to the changing climate.
Applicants are also encouraged, as applicable, to integrate processes that minimize burdens to human health and the environment while maximizing benefits to the Project Area through such means as integrating nature-based solutions, utilization of low -carbon building materials, or sourcing sustainable products and materials to perform the projects. When selecting a Climate Action Strategy and designing their climate action projects, applicants may refer to the National Climate Resilience Framework released in September 2023.
Examples of project activities and guidelines associated with the strategies can be found in Appendix C.
While applicants may select from among the examples in the Appendix, applicants may also submit other types of project activities as long as they are consistent with a Climate Action Strategy described in Section I.G of the NOFO and are eligible for funding under §138(b)(2) of the CAA.
Strategy 1: Green Infrastructure and Nature-Based Solutions Many disadvantaged communities face complex climate challenges, such as urban heat island effects and flooding risks. Strategy 1 supports using nature-based solutions (NBS), also referred to as green infrastructure, to address such climate risks. Nature-based solutions are generally actions to protect, sustainably manage, or restore natural systems to address the impacts of climate change, while simultaneously providing benefits for people and the environment .4 Projects under this strategy can include planting shade trees, restoring native plants and wetlands to capture stormwater, and deploying other green infrastructure solutions that often ha ve the co -benefit of reducing GHG emissions.
Communities also may incorporate vegetation or similar natural features into traditional infrastructure.
Strategy 2: Mobility and Transportation Options for Preventing Air Pollution and Improving Public Health and Climate Resilience
Many disadvantaged communities lack access to affordable low- or zero -emission transportation options, leading to disproportionate difficulties in daily life , limiting access to educational and 4 Applicants may use the White House’s Nature-Based Solutions Resource Guide as a resource for integrating nature- based solutions.
12 economic opportunities, and creating vulnerability to climate risks. Strategy 2 focuses on providing community members with access to low- and zero-emission technologies to improve their overall health and well-being, reduce emissions, and increase access to important community destinations such as schools, workplaces, health care centers, and community spaces. Projects funded under this strategy may include installing protected bike lanes or walking paths, supplying traditional or electric bikes to community members, and deploying other low- or zero-emission transportation solutions. The impact of such projects could include improved publi c health outcomes, reduced GHG emissions from the transportation sector, more equitable access to community resources, increased community connectivity and safety, and greater community resilience to extreme weather events.
Strategy 3: Energy-Efficient, Healthy, and Resilient Housing and Buildings Residential and commercial buildings are a significant source of GHG emissions due to the large amounts of electricity consumed for heating, cooling, lighting, and other similar functions. Many disadvantaged communities also face a disproportionately high energy burden, defined as the percentage of gross household income spent on energy costs. Many factors can influence high energy burden, including higher-cost fuels, such as propane or other bottled fuels, and energy-inefficient homes due to a lack of insulation in older homes or older appliances. Strategy 3 supports investments in low- and zero-emission technologies and energy efficiency upgrades that can help decarbonize residential and commercial buildings, decrease energy burden, and increase resilience for communities. Many of these activities also contribute to positive public health outcomes by improving indoor air quality and the safety and comfort of buildings . Co-benefits associated with this strategy can be maximized by combining additional Climate Action and Pollution Reduction Strategies to improve indoor air quality and / or produce additional resiliency benefits . This strategy can support a range of residential and commercial buildings, including single -family homes, multi- family housing buildings , small businesses, community health facilities, community centers, nonprofit offices, schools, and other similar community-serving buildings.
Strategy 4: Microgrid Installation for Community Energy Resilience Many disadvantaged communities suffer from unreliable access to electricity , a problem that is becoming more acute due to increased heating and cooling demands during extreme weather events driven by climate change. Strategy 4 supports the installation of microgrids powered by low- and zero- emission renewable energy to improve electric reliability, enhance overall energy efficiency, reduce emissions of GHG and other air pollutants, and build a community’s capacity to prepare for and withstand power disruptions. The U.S. Department of Energy defines microgrids as “ a group of interconnected loads and distributed energy resources within clearly defined electrical boundaries that acts as a single controllable entity with respect to the grid .” A microgrid can operate autonomously when disconnected from the grid or when there is no grid to connect to, such as in some remote communities. When connected and operated with the grid, a microgrid can provide grid ancillary services.
Strategy 5: Community Resilience Hubs
Many disadvantaged communities lack the resources to evacuate in a safe and timely manner when disaster strikes or is imminent . Strategy 5 supports the creation of , or upgrades to, community-level resilience hubs, which are public -serving spaces that provide shelter and essential services during extreme weather, natural hazards, or other events causing or contributing to an emergency or disaster, such as dangerous wildfire woodsmoke, toxic releases, industrial fires, or similar hazardous chemical incidents. These community-level resilience hubs can also serve as community-convening spaces that provide educational activities and related emergency and disaster preparedness resources to community residents year-round.
13 Strategy 6: Brownfield Redevelopment for Emissions Reduction and Climate Resilience Many disadvantaged communities contain brownfield sites that impede economic development .
Redeveloping brownfields provides an opportunity to make investments that contribute to community revitalization, resilience, and GHG emissions reduction . Redeveloping brownfield sites also supports infill development that significantly reduces residential vehicle use and the associated GHG emissions.
Strategy 6 supports the redevelopment of brownfield sites that have already been cleaned up, or where a site assessment indicates that cleanup is not necessary for reuse. These projects should seek to improve energy efficiency through investments in low - and zero -emission technologies, integrate climate resiliency, and / or mitigate climate change impacts while also promoting economic development and improving public health for residents . Examples could include construction of a public park or partnering on a LEED Certified low-income housing project on a former brownfield site.
Note: Projects funded under this Climate Action Strategy must be performed on sites where, at the time of application submission, the applicant demonstrates that cleanup is complete or that the site does not require any cleanup activities for the intended use or reuse of the site. See Section III.D.8 and Appendix C section on this Strategy.
Strategy 7: Waste Reduction and Management to Support a Circular Economy Disadvantaged communities often bear the brunt of environmental contamination from improper disposal of physical waste, or from disposal in landfills adjacent to those communities. This strategy supports circular economy 5 activities and promote s sustainable use of natural resources to keep materials and products in circulation for as long as possible, resulting in the reduction of GHG emissions and other pollution across a product’s lifecycle. Examples of these projects may include efforts to reduce food waste (e.g., composting, anaerobic digestors), or to promote the reduction, reuse, and recycling of disaster debris, construction and demolition debris, and other materials and products.
Project activities should demonstrate that they will result in materials being diverted from end-disposal facilities (e.g., landfills, incinerators) to reduce GHG emissions, toxic air pollution, and soil and water pollution.
Strategy 8: Workforce Development Programs for Occupations that Reduce Greenhouse Gas Emissions and Air Pollutants
Individuals in disadvantaged communities often lack pathways into fast-growing and well-paying job opportunities related to environmental and climate justice. This strategy allows applicants to propose workforce development programs to enable individuals in these communities to pursue career pathways in fields related to the reduction of GHG emissions and other air pollutants. Strong workforce development proposals should include all three of the following features, as detailed in Appendix C:
(1) multi-sectoral partnerships that bring together workforce expertise and enable pathways into high- quality careers that help reduce GHG emissions and other air pollutants ; (2) high- quality training models, such as pre-apprenticeships or Registered Apprenticeship Programs, that are worker-centered, demand-driven, and lead to good jobs that help reduce GHG emissions and other air pollutants ; and (3) strategies for recruiting and retaining individuals from disadvantaged communities, especially for populations that face barriers to employment. Given that workforce development opportunities can be significant to achieving environmental and climate justice in many communities , EPA anticipates making a minimum of fifteen awards for high-ranking applications that include a workforce training program as further described in Section V.E. Note that it is a statutory requirement that workforce development activities funded under this program be focused specifically on reducing greenhouse gas emissions and other air pollutants.
5 A circular economy keeps materials, products, and services in circulation for as long possible. 14 Requirement 2. Pollution Reduction Strategies: Applications must include at least one project aligned with at least one of the Pollution Reduction Strategies identified below. When addressing the strategy in their application, applicants should describe relevant challenges faced in the Project Area and how the selected Pollution Reduction Strategy(ies) will address those challenges. Each Pollution Reduction Strategy outlined below is focused on pollution monitoring, prevention, and remediation of quantifiable and health- harming pollutants.
Applications that include activities to increase monitoring capabilities or raise community awareness of pollution must also include an associated remediation, implementation, or infrastructure pollution reduction project that addresses the identified pollution issue.
Examples of project activities and guidelines associated with the strategies can be found in Appendix D .
While applicants may select from among the examples in the Appendix, applicants may also submit other types of project activities as long as they are consistent with a Pollution Reduction Strategy described in Section I.G of the NOFO and are eligible for funding under §138(b)(2) of the CAA.
Strategy 1: Indoor Air Quality and Community Health Improvements Disadvantaged communities often face high levels of indoor air pollution from several sources, including mold, lead paint, radon, asbestos, fossil fuel combustion, and pollution from outdoors that seeps inside. These pollutants can have a detrimental impact to human health, particularly for vulnerable populations including children, the elderly, and people with health conditions like asthma and heart disease.
6 Activities under Strategy 1 can include education on air toxins / toxics and how to monitor them (e.g., curriculum development, outreach strategies, public education activities) and direct assessment and remediation to reduce harmful air pollution (e.g., installation of filtration systems, building retrofits that address multiple sources of pollution, replacement of wood heaters that do not meet EPA standards, asbestos abatement in schools).
Strategy 2: Outdoor Air Quality and Community Health Improvements Outdoor air pollution from mobile and stationary sources can compromise human health and the environment in many ways, including by triggering asthma attacks and heart attacks, exacerbating respiratory disease, and causing children and adults to miss school and work on bad air days. Activities funded under Strategy 2 could include : funding the purchase, upgrade, and / or maintenance of equipment and technology to allow for the inspection, testing, monitoring, and sampling of air pollution; purchasing equipment that limits community exposure to outdoor air pollutants; and reducing exposure to near-road pollution, pollution from airports and ports, and mobile source pollution. This could include land use and zoning policies that enable households to live in affordable, dense, and vibrant communities within urban and rural areas. These activities can be bolstered by educating the public on air toxins / toxics and how to monitor them (e.g., curriculum development, outreach, public education), and communication of air pollution assessment results to reduce exposure, including during environmental emergencies or events where the risk of pollution exposure is high.
Strategy 3: Clean Water Infrastructure to Reduce Pollution Exposure and Increase Overall System Resilience
Disadvantaged communities often lack access to clean water and clean drinking water. Functional water infrastructure is essential for protecting the quality of drinking water resources as well as the safety of recreational waters communities use for subsistence fishing, swimming, and other activities everyone deserves to enjo y. Strategy 3 addresses challenges communities face in accessing clean, reliable drinking water and wastewater treatment. Projects funded under this strategy may include focused 6 Indoor Air Quality (IAQ).
15 infrastructure investments that can be completed within the three -year project period and within the funding amounts specified in this NOFO, as well as assessment and planning that will enable communities to better access tens of billions of dollars in federal water infrastructure funding from other sources such as EPA’s Clean Water and Drinking Water State Revolving Funds . Targeted infrastructure projects can include identification and replacement of lead pipes in homes and public spaces, improved resilience of water systems through deployment of backup power such as onsite renewable energy and storage, targeted efficiency upgrades, septic to sewer conversions, lining waste lagoons, and investments in redundancy such as backup wells. Assessment and planning efforts could include, for example, a leak detection and pipe replacement plan, or a PFAS monitoring program that informs a funding application to one of several sources of state and federal funding.
Strategy 4: Safe Management and Disposal of Solid and Hazardous Waste Disadvantaged communities are disproportionately exposed to solid and hazardous waste, which negatively impacts public health. This strategy supports pollution prevention, recycling, and disposal activities related to the management of solid and hazardous waste, such as discarded electronics, tires, single-use plastics, and other disposable items. Community-level responses to these challenges could include, for example, the purchase of equipment and the development of facilities to manage solid and hazardous waste to improve public health outcomes. Brownfields cleanup is not contemplated under this strategy and is not a Community Change Grants program priority.
Requirement 3. Community Engagement and Collaborative Governance Plan: Track I applications must include a Community Engagement and Collaborative Governance Plan. Successful implementation of environmental and climate justice projects requires relationships and meaningful engagement among an ecosystem of community leaders and members alongside partners across many sectors. This plan is required to help ensure that grant activities are driven and informed by the views of the Project Area community and are accomplished through collaborati on among key stakeholders , The plan should describe how the applicant will engage, educate, and be responsive to community members throughout project development and / or implementation. Additionally, the plan should incorporate a Collaborative Governance Structure that demonstrates how the Lead Applicant and Collaborating Entities (as described in Section III.A) will work together to successfully implement the grant in a timely, effective, and equitable manner.
The Community Engagement and Collaborative Governance Plan cannot exceed 10 single spaced pages – excess pages will not be reviewed. It should address the following elements and any others the applicant deems relevant to their projects:
• Past Community Outreach and Engagement Conducted: The applicant should demonstrate what outreach and engagement methods were used to engage with the Project Area community , including any with specific neighborhoods or groups, and how this impacted the selection of the strategies and associated projects as well as the applicant’s implementation approach. • Community Engagement Plan Implementation: The applicant should demonstrate the specific community engagement methods, as well as how they will mitigate barriers and involve relevant governmental stakeholders, necessary to support overall implementation including:
o Clear Methods for Engagement and Transparency: The applicant should describe the following elements:
Outreach methods that provide opportunities for broad and diverse community member involvement in project development and / or implementation and feedback during grant performance.
Transparent mechanisms that will promote meaningful accountability to the needs and preferences of residents in the Project Area.
16 Mechanism(s) that will be used to continuously inform the community before and during project implementation on project status, benefits available to them through the project, and indicators being tracked, such as air quality improvements or trees planted.
o Mitigating Barriers: The applicant should describe m easures to minimize and mitigate barriers around community engagement and participation in project development and / or implementation including but not limited to those related to linguistic differences, communication challenges, disabilities, inaccessible technology, lack of trust or awareness, transportation, childcare, and elderly / adult care.
7 o Government Involvement: As applicable, the applicant should demonstrate the support and involvement of government agencies needed to facilitate successful grant performance.
For example, projects that intersect with local-government authorities such as permitting, planning, and zoning are encouraged to demonstrate the involvement and cooperation of local government authorities.
• Collaborative Governance Structure: The applicant should provide details regarding the roles and responsibilities of the Lead Applicant, Collaborati ng Entities, and community residents and / or community -selected representatives for implementing, managing, and overseeing the application’s project activities, including how they should meet regularly to discuss project implementation. The description should include at a minimum:
o Outreach methods to solicit community representatives and processes to choose representatives to enable a broad cross-section of community representatives to participate so different voices are heard.
o An explanation of how the Lead Applicant and Collaborating Entities will coordinate with each other and community members to inform and engage the community on project development and progress.
o An outline of the planned decision-making processes between the Lead Applicant and Collaborating Entities, including procedures to ensure that decisions are transparent and can be made in an expedited manner when necessary.
o Processes for replacing a Collaborati ng Entity to ensure that the replacement entity has comparable skills, qualifications, expertise, community support, and experience to avoid any adverse impact on grant performance. EPA approval of the qualifications, expertise , and experience of the replacement Collaborating Entity will be required pursuant to 2 CFR 200.308I(2) and / I(c)(6).
Note: Awards may include terms and conditions requiring that subaward agreements between the Lead Applicant and Collaborating Entities (including the Statutory Partner described in Section III.A) contain provisions reflecting certain of the requirements above.
Requirement 4. Community Strength Plan : Track I applications must include a Community Strength Plan. Advancing environmental and climate justice requires bolstering the strength and economic prosperity of a community for the benefit of local residents, while also ensuring those residents can remain within the community and benefit from the investments over the long term. Executive Order 14096, Revitalizing Our Nation's Commitment to Environmental Justice for All , states, “ Advancing environmental justice will require investing in and supporting culturally vibrant, sustainable, and resilient communities in which every person has safe, clean, and affordable options for housing, energy, and transportation. It is also necessary to prioritize building an equitable, inclusive, and sustainable economy that offers economic opportunities. 7 Refer to the EPA Office of Grants and Debarment Guidance on Selected Items of Cost for Recipients, EPA Guidance on Participant Support Costs, and EPA Subaward Frequent Questions, including for additional information on paying for light refreshments, providing dependent care stipends or services for community meeting participants, and meeting participant transportation stipends. See Appendix G for additional information. 17 Pursuing these and other objectives integral to advancing environmental justice can successfully occur only through meaningful engagement and collaboration with underserved and overburdened communities to address the adverse conditions they experience and ensure they do not face additional disproportionate burdens or underinvestment.”
In alignment with this Executive Order and to help EPA assess whether the proposed projects will benefit disadvantaged communities, as required by §138(b)(1) of the CAA, this plan should describe how the projects in the application are intended to (1) maximize the economic benefits of the projects for existing residents in the Project Area, and (2) avoid unintended consequences for existing residents in the Project Area including the displacement of residents in the Project Area.
This plan cannot exceed 5 single-spaced pages – excess pages will not be reviewed. Consistent with the above discussion, the plan should address the following elements.
1. Maximizing Economic Benefits of Projects:
The plan should describe how the projects included in the application will maximize economic benefits for individuals in the Project Area, including priority populations defined in footnote 3.
Examples of economic benefits, as described below, could include (1) opportunities for local small businesses or contractors; (2) jobs for community members; (3) financial savings for residents; and other similar benefits, in alignment with EPA grant regulations and applicable law.8 • Business Opportunities : Applicants may need to hire contractors to carry out certain project activities. Applicants may inform local businesses of open solicitations and encourage them to compete for contracts. For example, a pplicants may consider partnering with their local government’s small business office to broadly advertise contracting opportunities. Similarly, applicants should make a “good faith effort” to provide disadvantaged business enterprises (DBEs) with an opportunity to compete for contracts in accordance with EPA’s 40 CFR Part 33 Disadvantaged Business Enterprise rule.9
• Job Opportunities: Applicants may propose measures to facilitate the employment and retention of workers from disadvantaged communities on funded projects . For example, applicants may propose developing recruitment strategies in partnership with the ir local workforce development board; funding support ive services for workers on grant-funded projects (e.g., transportation, childcare, mental health supports), coordinating such services with local social service providers; or establishing goals for hiring individual s from disadvantaged communities on the projects and transparently tracking progress toward those goals. Applicants may propose measures to increase community awareness of these job opportunities and the as sociated skill requirements, such as hiring workshops or job fairs. Applicants may also describe specific measures that will ensure Project Area residents are developing skills that are necessary to take advantage of existing or future jobs in professions contributing to the reduction of GHG emissions and other air pollutants. 8 Note that a pplicants are not bound by statutory or administrative local-preference requirements, per 2 CFR 200.319(c).
9 Note: Please carefully review Section IV.d, “Contracts and Subawards,” of EPA’s Solicitation Clauses that are incorporated by reference in this NOFO in Section I.J. EPA expects recipients of funding to comply with competitive procurement contracting requirements. The Agency does not accept justifications for sole source contracts for services or products available in the commercial marketplace based on a contractor’s role in preparing an application or a firm or individual’s “unique” qualifications. For example, applicants cannot name local contractors as part of this Community Strength Plan without adhering to these competitive procurement requirements. 18 Note: Jobs funded under this program should be high-quality jobs, in alignment with the U.S.
Department of Labor and Commerce’s Good Jobs Principles , as described in Appendix E.
Applicants may propose measures to increase the likelihood that these will be good jobs for individuals from disadvantaged communities, such as training for employers / contractors on grant- funded projects to promote best practices such as equal opportunity recruitment and hiring practices, good benefits, healthy organizational culture, and opportunities for advancement .
Additionally, jobs for construction activities funded under this grant will be required to pay prevailing wage rates, as required by CAA § 314 and the Davis-Bacon and Related Acts. • Fi
nancial Savings: Applicants may also describe how and the extent to which Project Area residents will receive direct economic benefits from the C limate Action and Pollution Reduction projects in the applications, such as through energy bill savings or affordable zero- or low-emission transportation solutions. The plan may also discuss how the applicant plans not only to deliver these benefits for residents in the short-term but also to preserve them for the long-term. As an example, applicants working on a transportation project that will deliver immediate cost savings for residents may negotiate with a vendor / contractor to lock-in long-term cost savings for community members.
Applicants may consider using tools to align stakeholders around these benefits, such as a Community Benefits Agreement (CBA), which is a legally binding contract that defines benefits. Parties to a CBA may include CBOs, neighborhood associations, local government entities, contractors and developers, and other similar project stakeholders. Applicants are reminded of the three-year period of performance for the grant and should be prepared to expeditiously begin the negotiation of community benefits to prevent project delays.
2. Displacement Avoidance:
Benefits to disadvantaged communities can be evaluated by whether residents are able to retain the benefits of EPA-funded projects over the short and long -term. While climate action and pollution reduction can have a positive impact on a community, those benefits can also lead to unintended consequences, such as increased costs of living in a Project Area . Given that the purpose of CAA §138 is to fund activities that will benefit disadvantaged communities, applicants should describe measures to increase the likelihood that existing community members of the Project Area will benefit from investments in both the immediate and long term.
Applicants should discuss potential short-term and long-term risks associated with the proposed projects to residents, small businesses, nonprofits, and other community members in the Project Area . Applicants should assess and describe the community’s vulnerability to rising costs attributable to the proposed projects and assess potential impacts to households, small businesses, and other existing groups. Based on the specific risks identified, applicants should describe measures for mitigating those risks as applicable.
Some measures can mitigate these displacement vulnerabilities in the short -term, whereas other measures can have long-term impacts. For example, for projects that increase the energy efficiency of multi-family housing facilities, and that may have the unintended effect of raising rents for those facilities, the approach may focus on outreach / education to residents, such as information packets, tenant protection workshops that feature information about tenant rights under applicable state and local laws , or other educational activities. Other approaches may focus on securing commitments from landlords benefiting from EPA - funded property improvements to extend affordable housing covenants or agree not to raise rents 19 unnecessarily.10 Applicants can also describe how they will work with relevant entities , such as local governments, to create policies, plans, or programs to mitigate unintended impacts of the EPA-funded investments.
Applicants should describe any work already underway in the Project Area that would mitigate these risks, or existing policies, ordinances, or programs that are relevant. For example, an applicant could describe any ordinances in the Project Area designed to expedite construction or availability of additional affordable housing. Applicants can also describe any Climate Action and Pollution Reduction Strategies proposed as part of this application that might help mitigate displacement risks by providing project co-benefits. For example, a strategy that promotes increased housing density as a tool to reduce emissions could have the co-benefit of reducing housing costs by increasing housing supply.
Requirement 5. Readiness Approach: Given the statutory requirement that all Community Change Grants must be completed within three years, applicants must describe their approach for initiating grant performance upon award, or generally within 120 days after award, in compliance with the requirements in 2 CFR Parts 200 and 1500, 40 CFR Part 33 that apply to all EPA grants so they can successfully complete the grant within the three-year period.
This includes addressing the readiness considerations listed below, and any others, that are applicable to the projects and how they will be met. If any of the below considerations are not applicable, the application should explain why not.
• Government Approvals : If government approval at any level (e.g., construction permits) is necessary to implement or perform a project, the applicant must demonstrate that they have obtained such approval. If such approval has not been obtained, then the applicant must demonstrate how they will obtain it immediately after award, so it does not impede grant implementation.
• Federal Requirements for Construction Projects: Applicants must demonstrate that they have systems in place, or a plan to have such systems in place immediately after the grant award, to comply with CAA § 314 and the Davis-Bacon and Related Acts prevailing wage requirement, the Build America Buy America domestic preference requirement , and other cross -cutting statutory and Executive Order requirements that apply to Federally funded construction projects. • Alignment with Existing Plans : Applicants must demonstrate that the project(s) in the Project Area as defined in Appendix A are consistent with any community development, climate resilience, or hazard mitigation plans, or other comparable government land use restrictions. • Site Control: Applicants must demonstrate that they own or control the site where a project will be performed or that they will have legally binding access or permission to the site so they can perform the project(s).
• Operations and Maintenance: Applicants must describe their operations and maintenance plan and financing approach for their project’s infrastructure investments, if relevant, which may include long-term service costs, fee structures, detailed indebtedness for all properties, and other relevant information demonstrating how operations and maintenance of the investment will be assured during and after the grant award.
10 Note that any agreements must be in alignment with local and state housing laws. For example, in some instances, state or local law may allow a landlord to raise rents to compensate for increases in property taxes attributable to the value of EPA funded improvements.
20 Requirement 6. Compliance Plan: Applicants must submit a Compliance Plan that describes how they will: (i) ensure compliance with the grant’s terms and conditions, including 2 CFR § 200.302(b) (financial management), 2 CFR § 200.303 (internal controls), and 2 CFR § 200.332 (requirements for pass -through entities); and (ii) manage broader legal and compliance risks. This plan cannot exceed 5 single-spaced pages – excess pages will not be reviewed.
H. Funding Track II: Meaningful Engagement for Equitable Governance Under this track, eligible applicants may submit projects, as described in CAA § 138(b)( 2)(E), for “facilitating engagement of disadvantaged communities in State and Federal advisory groups, workshops, rulemakings, and other public processes.” EPA has interpreted “other public processes” as encompassing local, Tribal, and other governmental processes. All funded activities under this NOFO must comply with federal, state, and local laws and regulations, including but not limited to:
1. 2 CFR 200.435(b), which restricts the use of grant funds to defend a recipient that is subject to a criminal, civil or administrative proceeding against it commenced by any government for fraud or similar offenses;
2. 2 CFR 200.435(g), which precludes the use of grant funds to prosecute claims against the federal Government; and
3. 2 CFR 200.450(c), which restricts the use of federal funds by nonprofit organizations for certain lobbying or electioneering activities but does not preclude the use of federal funds to promote adoption of local ordinances, including those related to zoning.
4. 40 CFR Parts 5 and 7, which prohibit discrimination on the basis of race, color, national origin (including limited-English proficiency), disability, sex, and age by recipients and subrecipients of federal financial assistance.
Track II Objectives
Section 138 of the CAA provides that grants may be awarded for the purpose of “facilitating engagement of disadvantaged communities in State and Federal advisory groups, workshops, rulemakings, and other public processes.” Accordingly, Track II applications intend to build the capacity of communities and governments to evaluate and redress environmental and climate injustices by giving disadvantaged communities a meaningful voice in government decision- making processes. By supporting direct participation of disadvantaged communities in the development and implementation of solutions, policies, and programs, the Community Change Grants can help close equity gaps and redress environmental and climate injustices.
Track II applications should focus on breaking down systemic barriers to community participation in government processes impacting environmental and climate justice. This can be done by creating engagement and feedback mechanisms with two-way communications between community members and government decision-makers. Applications should focus on ways to provide disadvantaged communities with information about issues that directly impact them, while simultaneously creating mechanisms for the government to gather input to ensure community needs inform decision-making and are integrated into government processes and policies. Applications in this track should strive to enable communities to play a meaningful role in making and implementing decisions.
Effective projects should also involve partnerships between community organizations, governments, philanthropic organizations, the private sector, and / or third- party facilitators and evaluators who can support collaboration across sectors to facilitate the engagement of disadvantaged communities in governmental decision-making processes.
21 Track II Project Examples
The following are examples of activities that may be proposed under Track II. Applicants may expand or refine these examples or submit projects that are not listed below if they demonstrate how they will facilitate the engagement of disadvantaged communities in governmental processes.
Example 1. Educational and Training Programs
These projects prepare, train, and educate members of disadvantaged communities on how to engage in government processes related to environmental and climate justice activities.
Examples of activities that could be performed under this type of project include but are not limited to:
• Creating a leadership development program that trains community members to identify environmental and climate justice challenges, devise strategies to address them, and recommend actions to governmental authorities. Example topics could include how to review public sector budgets, navigate specific processes such as land-use ordinances or National Environmental Policy Act (NEPA) reviews, and participate effectively in public meetings. The EPA EJ Academy is an example of a type of project applicants may consider developing for their own community. • Designing and implementing a training program to help members of disadvantaged communities effectively participate in advisory boards, commissions, land use authorities, or other bodies that involve community members in environmental and climate related policy making. • Partnering with a government to develop and / or implement Equity Action Plans that identify and address barriers to equity and opportunity and discrimination that disadvantaged communities may face. Equity Action Plans should meaningfully incorporate community input and result in city-or- statewide transformational, equitable change in environmental or climate related policies . For informational purposes only, please find here a link to Equity Action Plans developed by federal agencies that may help applicants with designing and preparing these types of projects.
Example 2. Environmental Advisory Boards (EABs)
These are projects that facilitate the engagement of disadvantaged communities in environmental decision- making by establishing advisory councils, taskforces, or similar bodies to engage with government. These boards should have regular meetings to create consistent opportunities for disadvantaged communities to provide recommendations on actions government entities should take to address environmental and climate justice challenges. These bodies should include members from disadvantaged communities, may include additional representatives from other stakeholder groups that can effectively represent important and related perspectives (including Tribal, academia, youth / elderly / disability populations, government, etc.).
Examples of activities under an EAB -type project may include but are not limited to facilitating the engagement and involvement of disadvantaged communities in governmental processes at different levels of government to provide input, recommendations, and advice on matters such as:
• Permitting decisions for factories or industrial sites. • Community infrastructure upgrades to address pollution and climate concerns. 22 • Zoning and siting guidance for fence-line / frontline communities11 such as new school placements, highway construction, and industrial and commercial uses of land. • Issues and actions of municipal and public utilities related to workforce development, drinking water shutoffs, drinking water quality and affordability , and aging wastewater treatment infrastructure in / near disadvantaged communities.
Example 3. Collaborative Governance Activities
These are projects that facilitate the process of providing recommendations and implementing decisions that will benefit disadvantaged communities . Projects can focus on creat ing collaborative bodies with members from and / or representing the interests of disadvantaged communities, governmental entities, and other stakeholders to work on environmental and climate justice issues.
Functions these bodies may focus on include co-producing solutions with disadvantaged communities to identify and address environmental issues. This could be done through obtaining feedback from a wide range of experts and stakeholders , including but not limited to those working in public health, housing, economic development, environmental justice, and other relevant fields , to identify environmental and directly related public health issues, develop solutions, and then work towards implementing the ideas with the necessary parties.
Examples of activities under a co llaborative governance project may include but are not limited to facilitating the engagement and involvement of disadvantaged communities in governmental processes on matters such as:
• Participating in the development of one or more community benefits agreements to help ensure that environmental projects funded by federal, state, and / or private entities meaningfully engage and account for community needs . For informational purposes only, the resource here from the Department of Energy provides information that may help applicants with designing and preparing these types of projects.
• Creating a governance body or “ development community” for a brownfields post -cleanup redevelopment project.
12 • Creating a source water protection plan to protect public health and reduce burdens on water systems.
• Recommending organizational changes to government entities that make them more receptive and sensitive to the environmental and climate justice concerns of disadvantaged communities.
Example 4. Participation in Governmental Funding and Budgeting Processes These are projects that use participatory budgeting to inform public spending on environmental priorities.
Participatory budgeting is an approach to making decisions about governmental spending that is focused on meaningfully and deeply engaging the community in governmental funding processes. Projects can enable community-based organizations to partner with a public entity to design and implement processes whereby members of disadvantaged communities have input into, and influence, decisions about how to allocate public budgets for environmental and climate justice priorities. An example of a project using participatory budgeting could involve designing a program where the community identifies problems, 11 A fence-line community or frontline community is generally one immediately adjacent to high polluting facilities such as industrial parks, manufacturing facilities, or commercial facilities and is directly affected by the noise, odors, traffic, and chemical and pollution emissions of the operations of these entities. 12 U.S. Department of Health & Human Services. Build a Development Community. 23 evaluates proposals, and recommends decisions for public funding of projects that implicate environmental and climate justice issues.
I. EPA Strategic Plan Linkage, Anticipated Outputs, Outcomes & Performance Measures
1. Strategic Plan Linkage
Awards made under this NOFO will support the following goals and objectives of the FY 2022-2026 EPA Strategic Plan. Applications must explain how their projects will further these goals and objectives.
Goal 2: Take Decisive Action to Advance Environmental Justice and Civil Rights • Objective 2.1: Promote Environmental Justice and Civil Rights at the Federal, Tribal, State, and Local Levels which includes the strategy of Building Community Capacity and Climate Resilience and Maximizing Benefits to Overburdened and Underserved Communities: EPA will increase support for community-led action by providing unprecedented investments and benefits directly to communities with environmental justice concerns and by integrating equity throughout Agency programs.
Depending on the projects included in them, awards will also support and advance the following EPA Strategic Plan Goals as applicable:
• Goal 1: Tackle the Climate Crisis
• Goal 4: Ensure Clean and Healthy Air for All Communities • Goal 5: Ensure Clean and Safe Water for All Communities • Goal 6: Safeguard and Revitalize Communities; and
• Goal 7: Ensure Safety of Chemicals for People and the Environment.
2. Environmental Results: Outputs and Outcomes
Pursuant to EPA Order 5700.7A1, Environmental Results under Assistance Agreements , applicants must describe the environmental outputs and outcomes to be achieved under the award. Applicants should specifically describe the environmental results of the proposed project in terms of well-defined outputs and, to the maximum extent practicable, well-defined outcomes that will demonstrate how the project will contribute to the goals and objectives of the Community Change Grants program.
The following questions may be useful to consider when developing output and outcome measures of quantitative and qualitative results:
• What measurable short- and longer-term results will the grant achieve? • How will the Lead Applicant and Collaborating Entities measure progress in achieving the expected results (including outputs and outcomes) , and how will the approach to measuring progress use resources effectively and efficiently?
• Are the projected outputs and outcomes specific and detailed? Are specific target measures included where possible? Are target measures reasonable and achievable within the project period and for the funding amount?
See Appendix F for further details on expected outputs and outcomes from Track I and II awards. 24 3. Performance Measurement Plan
The evaluation component of the Community Change Grants is essential. In their Performance Measurement Plan, applicants should describe how they plan to track and measure their project implementation and progress towards achieving the expected outputs and outcomes , including those identified in Appendix F, throughout the performance period.
Generally, higher quality performance measurement plans include specific target metrics for both outputs and outcomes. The applicant’s performance measurement plan should help gather insights, will be a mechanism to track progress toward output and outcome objectives, and may provide the basis for developing lessons learned to inform future funding recipients.
Applicants should incorporate program evaluation activities from the outset of their program design and implementation to meaningfully document and measure their progress towards meeting project goals.
Applications may include funding in the budget for personnel with expertise in planning, designing, developing, implementing, and evaluating programs.
J. Additional Provisions for Applicants Incorporated into the NOFO Additional provisions that apply to Sections III, IV, V, and VI of this NOFO and / or awards made under this NOFO can be found at EPA Solicitation Clauses. These provisions are important for applying to this NOFO, and applicants must review them when preparing applications for this NOFO. If you are unable to access these provisions electronically at the website above, please email [email protected] to obtain the provisions.
25 Section II. Federal Award Information
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A. Number and Amount of Awards
EPA anticipates awarding approximately $2 billion in funding through this NOFO depending on funding availability, quality of applications received, EPA priorities, and other applicable considerations. Awards under Track I are expected to be between $10-20 million each. Awards under Track II are expected to be between $1-3 million each. EPA expects to award approximately $1.96 billion for about 150 Track I awards, including those under the Target Investment Areas described below in B, and approximately $40 million for about 20 Track II awards. These amounts are estimates only, and EPA reserves the right to increase or decrease the total number of awards and funding amounts for each Track contingent on the quality of applications received, the amount of funds awarded to selected applicants, budget availability, and / or agency priorities and programmatic considerations. In addition, given that workforce development programs as described in Section I.G can be significant to achieving environmental and climate justice in many communities , EPA anticipates making a minimum of fifteen awards for high- ranking applications that include a workforce training program(s) as further described in Section V.E.
B. Target Investment Areas (TIA) for Track I Applications Out of the approximate $2 billion in funding, EPA has identified five Target Investment Areas (TIA) listed below to help ensure that communities with unique circumstances, geography, and needs can equitably compete for funding. The amounts are estimates only and subject to change based on the number and quality of applications received, funding considerations, and agency priorities. Applicants interested in submitting an application for projects benefitting a TIA must identify this in their application. Consistent with the Track I evaluation process described in Section V, the TIA applications will be ranked and selected per TIA. Applications for the TIAs must address the Track I application requirements identified in Section I.G. • TIA A: Tribes in Alaska: an estimated $150 million for projects benefitting Indian Tribes in Alaska.
As noted in Appendix H and Section V.E below, the EPA anticipates making a minimum of 5 awards for high-ranking applications under this TIA that include projects to assess and/or clean up lands conveyed under the Alaska Native Claims Settlement Act that were contamina ted at the time of their conveyance from the federal government to an Alaska Native Corporation .
• TIA B: Tribes in the Continental United States: an estimated $300 million for projects benefitting Tribal communities outside Alaska, which include Indian Tribes as defined by the Clean Air Act in Section III.A.3 below and Tribal Lands included in the EPA Disadvantaged Community Environmental and Climate Justice Program Map referenced in Appendix A. This also includes projects benefitting such Tribal communities that are located in the Border Area identified below in TIA E.
• TIA C: Territories: an estimated $50 million for projects benefitting disadvantaged communities in the United States’ territories of Puerto Rico, the Virgin Islands, Guam, American Samoa, and the Northern Mariana Islands.
• TIA D : Disadvantaged Unincorporated Communities : an estimated $50 million for projects benefitting disadvantaged unincorporated communities as defined in Appendix A. • TIA E : United States ( U.S). – Southern Border Communities : C onsistent with EPA’s longstanding approach to addressing transborder climate and pollution challenges, an estimated 26 $100 million for projects benefitting non-Tribal disadvantaged communities within 100 kilometers north of the U.S.-Mexico border.
Special Requirements for Cross-Border Projects to Benefit U.S. Disadvantaged Communities EPA’s strong preference is that the work for all projects to be performed under the awards made through this NOFO will be performed entirely within the United States. However, in limited circumstances, projects to benefit U.S. disadvantaged communities near an international border may require some international work to be performed within 100 kilometers of that border (e.g., within 100 km south of the U.S.-Mexico border for a TIA E application, or within 100 km north of the U.S.-Canada border for any application). In those limited cases, to be eligible for funding consideration, the applicant must demonstrate in their application that:
• The project(s) will directly and predominantly benefit disadvantaged communities in the U.S., for example by monitoring and / or preventing pollution from an international source that is impacting the disadvantaged community in the U.S.
• Any work outside of the U.S. is necessary for the project(s) to be successful in benefitting the disadvantaged communities in the U.S. — e.g., the project(s) will not be effective otherwise. • Any work outside of the U.S. will not be a substantial part of the project. • The applicant will ensure that any work outside of the U.S. will be timely and properly completed and monitored to ensure it is effectively performed.
Failure to address how the application meets these conditions will render the application ineligible for review as stated in Section III.D. Applications involving cross-border work that are selected for award must address any cross -border work issues (e.g., site access and control) during the workplan negotiations following selection and before award, The appropriate terms and conditions will be included in the grant.
Projects benefitting Project Areas along the U.S.- Mexico Border should be consistent with guidance and best practices outlined by EPA’s Border Program.13 14
C. Rolling Application Submittal and Review Process, Application Award Limits, and Application Resubmission Procedures
1. Applications may be submitted under this NOFO through November 21, 2024, to provide applicants, to the maximum extent practicable, flexibility on when to submit an application.
Applications will be reviewed and evaluated on a rolling basis as described in Section V to facilitate and expedite the review and award process. EPA cannot guarantee that funding will be available through the end of the NOFO 12-month application period as funding availability is dependent on the volume and quality of applications received, as well as other applicable programmatic and funding considerations. As such, it is possible that funding could be exhausted before the conclusion of the 12-month rolling application period.
2. Under this NOFO, Lead Applicants, as defined in Section III.A, may submit a maximum of two eligible applications and receive up to two awards if they demonstrate their capacity and capabilities to effectively perform, manage, oversee, and complete both awards within the three- year grant period of performance. The two applications may be either two Track I applications or two Track II applications, or one of each. Lead Applicants who submit more than two total eligible 13 United States – Mexico Environmental Program.
14 U.S.-Mexico Border Program – Borderwide Resources.
27 applications will be asked to withdraw the excess one (s). EPA will not review more than two eligible applications from any one Lead Applicant.
3. Lead Applicants whose initial eligible application(s) is not selected for funding may, after timely requesting and receiving a debriefing on the application (as described in the Section VI Debriefings and Disputes clauses included in the EPA Solicitation Clauses), resubmit a revised application one additional time while the NOFO remains open. For example, if a Lead Applicant submits two eligible applications and both are not initially selected for funding, they may resubmit each application one additional time within the 12- month NOFO open period as explained above and further below. There is no guarantee that resubmissions, even after a debriefing, will be selected for funding. In addition, applicants who submit applications towards the end of the 12-month rolling period may not have an opportun ity to resubmit the application because the NOFO is expected to close for applications on November 21, 2024. While EPA intends to review applications and provide debriefings as expeditiously as possible, applicants should keep this in mind when determining the timing of their application submission to ensure there is sufficient time for a resubmission.
4. The resubmitted application must be clearly identified as a resubmission of a previously submitted application by providing the date of the original submission through www.grants.gov and / or the date of the EPA debriefing in the updated application package. The resubmission should take into consideration the feedback received during a debriefing and any other relevant considerations, and it cannot be a completely different application from the one initially submitted. If EPA determines, in its sole discretion, that it is a different application bearing little resemblance to the original application, it may be rejected and not reviewed.
D. Conditional Awards
EPA may make conditional awards under this NOFO, which will be subject to applicable terms and conditions in the grant award.
E. Period of Performance
The period of performance of every grant funded under this NOFO cannot by statute exceed three years.
There can be no extensions. Projects must be designed to be successfully and effectively completed within three years. EPA anticipates that the first awards under this NOFO will be made in the fall of 2024 and will continue to be made on a rolling basis until funding is exhausted. EPA cannot predict when funding will be exhausted since it is dependent on the volume and quality of applications received, as well as other applicable programmatic and funding considerations. As such, it is possible that funding could be exhausted before the 12-month rolling application period is over.
F. Partial Funding
EPA reserves the right to partially fund applications by funding discrete portions or phases of applications.
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. To facilitate consideration of an application for partial funding, if applicable, EPA recommends that applications separate costs for the proposed grant in the program bud get by project category, to the extent practicable.
28 G. Additional Awards
EPA reserves the right to make additional awards under this NOFO, consistent with EPA policy and guidance, if additional funding becomes available after all the selections are made under this NOFO. For this NOFO, this only applies to making additional awards for those applications considered during the final monthly review, described in Section V. Any additional selections for awards will be made no later than 6 months after the final monthly review.
H. Funding Type
EPA anticipates awarding cooperative agreements under this NOFO because it is expected that there will be substantial Federal involvement through the EPA Project Office r with selected applicants in the performance of the grant and for e ffective EPA oversight of grantee performance. Although EPA will negotiate precise terms and conditions relating to substantial federal involvement as part of the award process with each grantee awarded a cooperative agreement, the anticipated substantial federal involvement may include:
• Closely monitoring the grantee’s performance to verify the results reported by the applicant; • Reviewing proposed procurement, in accordance with the Procurement Standards in 2 CFR Parts 200 and 1500;
• Reviewing evidence of completion of project phases (e.g., planning) before providing approval for the grantee to begin work on the next project phase (e.g., implementation); • Reviewing the substantive terms of contracts, subawards, or other financial transactions (EPA will not select contractors, subrecipients, or program beneficiaries); • Approving qualifications of key personnel (EPA will not select employees or contractors employed by the grantee);
• Reviewing and commenting on reports prepared under the cooperative agreement (the final decision on the content of reports will rest with the grantee); and • Addressing compliance with Build America, Buy America requirements, in accordance with 2 CFR § 184, and providing technical assistance, if necessary, on compliance with CAA § 314 and the Davis-Bacon and Related Acts.
In addition, there may be Federal involvement with selected applicants in the performance of the grant, which may include co- sponsoring community meetings and other events and collaborating during performance of the scope of work.
29 Section III. Eligibility Information
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Note: Additional provisions that apply to th is section of the NOFO can be found in the EPA Solicitation Clauses.
A. Eligible Applicants
Consistent with CAA §138(b)(3) and Assistance Listing 66.616, applicants eligible to apply and receive grants under this NOFO are (1) a partnership between two community- based nonprofit organizations (CBOs) as defined below, or (2) a partnership between a CBO and one of the following: a federally recognized Tribe, a local government, or an institution of higher education. These types of partnerships for eligibility purposes are known as Statutory Partnerships. Further eligibility requirements are described below.
1. Community-Based Non-Profit Organization (CBO)
To qualify as a CBO for eligibility purposes, an organization must demonstrate that they are a “nonprofit organization” as defined at 2 CFR 200.1, which “means any corporation, trust, association, cooperative, or other organization that is operated mainly for scientific, educational, service, charitable, or similar purpose in the public interest and is not organized primarily for profit; and uses net proceeds to maintain, improve, or expand the operation of the organization.”
Applicants must include documentation in their application demonstrating that they are a nonprofit organization by one of two ways: 1) a written determination by the Internal Revenue Service that they are exempt from taxation under Section 501 of the Internal Revenue Code , or 2) based on a written determination by the state, territory, commonwealth, Tribe, or other United States governmental entity in which they are located. This can be done, for example, by submitting a letter , certificate, or articles of incorporation from the state where the organization is located that recognizes them as a nonprofit organization. Nonprofit organizations described in Section 501I (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. Foreign non-profit organizations cannot qualify as a CBO for eligibility purposes.
In addition to being considered a nonprofit organization, an organization must demonstrate that they are a public or private nonprofit organization that supports and / or represents a community and/or certain populations within a community through engagement, education, and other related services provided to individual community residents and community stakeholders. A “community,” for these purposes, can be characterized by a particular geographic area and / or by the relationships among members with simila r interests and can be characterized as part of a local, regional, or national community where organizations are focused on the needs of urban, rural, and / or Tribal areas, farmworkers, displaced workers, children with high levels of lead, people with asthma, subsistence fishers, and other similar groups. For purposes of this NOFO, the CBO must have a geographic presence or connection in, or relationship with, the specified community that the projects are intended to benefit. For example, national or statewide CBOs must demonstrate the CBO’s connection to the community that will benefit from the grants.
For the purposes of this NOFO, applicants that demonstrate that they are Alaska Native Nonprofit Organizations or Alaska Native Nonprofit Associations are considered CBOs. In addition, Inter tribal Consortia may be able to qualify as CBOs if they meet the above requirements and 40 CFR 35.504(a) and (c). The for-profit Alaskan Native Corporations are not eligible under the CBO definition and therefore are unable to apply as CBOs.
30 2. Local Government (in partnership with a CBO)
The following units of government within a state, as defined by the regulations in 2 CFR 200.1, are eligible to enter a Statutory Partnership with a CBO:
• County
• Borough
• Municipality
• City
• Town
• Township
• Parish
• Local public authority, including any public housing agency under the United States Housing Act of 1937
• Special district
• School district
• Intrastate district
• Council of governments, whether incorporated as a nonprofit corporation under State law; and • Any other agency or instrumentality of a multi-, regional, or intra-State or local government.
3. Federally Recognized Tribe (in partnership with a CBO) For the purposes of eligibility for entering into a Statutory Partnership with a CBO, EPA uses the definition of “Indian Tribe” in §302 I of the CAA which provides that the term “...means any Indian T ribe, band, nation, or other organized group or community, including any Alaska Native village, which is Federally recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians.” Note that this definition does not include Alaskan Native Corporations or State-recognized Tribes.
4. Institutions of Higher Education (in partnership with a CBO) For the purposes of eligibility for entering into a Statutory Partnership with a CBO, the grant regulations at 2 CFR 200.1 state that Institutions of Higher Education (IHEs) are defined at 20 U.S.C. § 1001.
EPA also recognizes that it is important to engage all available minds to address the environmental and climate justice challenges the nation faces. Accordingly, EPA encourages Minority Serving Institutions (MSIs) to participate in the grants under this NOFO, including by partnering with a CBO.
For purposes of this NOFO, the following are considered MSIs:
1. Historically Black Colleges and Universities, as defined by the Higher Education Act (20 U.S.C. § 1061(2)). A list of these schools can be found at Historically Black Colleges and Universities.
2. Tribal Colleges and Universities (TCUs), as defined by the Higher Education Act (20 U.S.C. § 1059c(b)(3) and (d)(1)). A list of these schools can be found at American Indian Tribally Controlled Colleges and Universities.
3. Hispanic-Serving Institutions (HSIs), as defined by the Higher Education Act (20 U.S.C. § 1101a(a)(5)). A list of these schools can be found at Hispanic-Serving Institutions.
4. Asian American and Native American Pacific Islander -Serving Institutions; (AANAPISIs), as defined by the Higher Education Act (20 U.S.C. § 1059g(b)(2)). A list of these schools can be 31 found at Asian American and Native American Pacific Islander-Serving Institutions.
5. Predominantly Black Institutions (PBIs), as defined by the Higher Education Act of 2008, 20 U.S.C. § 1059e(b)(6). A list of these schools can be found at Predominantly Black Institutions.
B. Statutory Partnership Requirements and Collaborating Entities Please refer to Section III.A above for who is eligible to apply for the grants. The Statutory Partnership application is comprised of one Lead Applicant (an eligible CBO, Federally recognized Tribe, local government, or institution of higher education) who enters into a Partnership Agreement with one Statutory Partner (which is one of the following eligible entities – a CBO, Federally recognized Tribe, local government, or institutio n of higher education) to carry out the grant activities if the application is selected for funding. Please note that a CBO must be either the Lead Applicant or a Statutory Partner in every Statutory Partnership (e.g., there cannot be a statutory partnership of a local government and an institution of higher education or either of these entities and an Indian Tribe). In other words, as identified in Section III.A all Statutory Partnerships must include a CBO. If the application is selected for award, the Lead Applicant will enter into a subaward with the Statutory Partner that must contain the elements of the Partnership Agreement in Appendix B. The Lead Applicant must include a copy of a written and signed Partnership Agreement with their application to be eligible for funding consideration.
To ensure effective grant performance to meet the objectives of the Community Change Grants outlined in Section I, subawards from the Lead Applicant to other entities to implement and perform specific grant project activities identified in the application will be necessary. These other entities, including the Statutory Partners, are collectively referred to as Collaborating Entities in the NOFO. Given the community centered focus of the Community Change Grants, applications that do not include Collaborating Entities will likely not score well during the evaluation process. Collaborating Entities may include Statutory Partners (CBOs, Federally-recognized T ribes, local governments, and institutions of higher education) and entities that cannot legally be Statutory Partners (e.g., states, territorial governments, and international organizations).
However, for -profit firms and individual consultants or other c ommercial service providers cannot be Collaborating Entities. Subawards made by the Lead Applicant and Collaborating Entities to implement the project strategies and activities under the application must be made consistent with the grant regulations at 2 CFR 200.331 and as permitted in Appendix A of the EPA Subaward Policy.
If selected for award, the Lead Applicant will become the grantee, operating as a pass- through entity for purposes of 2 CFR Part 200 and the EPA Subaward Policy, and taking responsibility for making subawards to Collaborating Entities. The Lead Applicant will also be accountable to EPA for effectively carrying out the full scope of work and the proper financial management of the grant (including the subawards it makes under the grant, and contracts to consultants and procurement contractors selected in accordance w ith the competitive procurement requirements in 2 CFR Parts 200 and 1500 as well as EPA’s 40 CFR Part 33 Disadvantaged Business Enterprise rule). Additionally, as provided in 2 CFR § 200.332, the Collaborating Entities, and other subrecipients, will be accountable to the Lead Applicant for proper use of EPA funding.
Note that pursuant to 2 CFR § 200.332(a)(2), as implemented in Items 2 and 4 of EPA’s Establishing and Managing Subawards General Term and Condition, successful Lead Applicants in the Statutory Partnership must ensure that the terms and conditions of the grant agreement “flow down” to all subrecipients in the subawards. EPA has developed an optional template for subaward agreements, available in Appendix D of the EPA Subaward Policy.
As noted above, Collaborating Entities cannot include for -profit procurement contractors or individual consultants who may be involved in project performance but who receive procurement awards made in compliance with the competitive procurement requirements in 2 CFR Parts 200 and 1500 and 40 CFR Part
33. Further information on procurement and distinguishing between subawards and procurement 32 transactions can be found in the Best Practice Guide for Procuring Services, Supplies, and Equipment Under EPA Assistance Agreements and in EPA Subaward Policy.
C. Cost-Sharing or Matching Funds
No cost-sharing or matching is required as a condition of eligibility under this NOFO.
D. Threshold Eligibility Criteria
Applications must meet the threshold eligibility criteria below to be considered for funding. Applications that do not meet all the applicable threshold eligibility criteria will be deemed ineligible for funding consideration and will not be considered further. If necessary, EPA may contact applicants to clarify issues relating to threshold eligibility criteria compliance prior to making an eligibility determination. In addition, applicants should contact EPA with any questions about the threshold eligibility cri teria prior to submission of their applications . Applicants whose applications are deemed ineligible for funding consideration because of the threshold eligibility review will be notified within 15 calendar days of the ineligibility determination.
Applications must meet the following threshold eligibility criteria to be considered eligible for funding under this NOFO:
1. A
pplications must comply with the content and submission requirements listed below. • Applications must substantially comply with the application submission instructions and requirements set forth in Section IV of this NOFO or else they will be rejected. However, where a page limit is expressed in Section IV with respect to the application, or parts thereof, pages in excess of the page limitation will not be reviewed. Applicants are advised that readability is of paramount importance and should take precedence in application format, including selecting a legible font type and size for use in the application. • In addition, initial applications must be submitted through Grants.gov as stated in Section IV of this NOFO (except in the limited circumstances where another mode of submission is specifically allowed for as explained in Section IV ) on or before the application submission deadline published in Section IV of this NOFO. Applicants are responsible for following the submission instructions in Section IV of this NOFO to ensure that their application is timely submitted. Please note that applicants experiencing technical issues with submitting through Grants.gov should follow the instructions provided in Section IV, which include both the requirement to contact Grants.gov and email a full application to EPA prior to the deadline.
• Applications submitted outside of Grants.gov will be deemed ineligible without further consideration unless the applicant can clearly demonstrate that it was due to EPA mishandling or technical problems associated with Grants.gov or SAM.gov. An applicant’s failure to timely submit their application through Grants.gov because they did not timely or properly register in SAM.gov or Grants.gov will not be considered an acceptable reason to consider a submission outside of Grants.gov.
DO NOT WAIT! Register in SAM.gov or Grants.gov as soon as possible. Finalizing these registrations could take a month or more. You do not want a late registration to prevent you from being able to properly submit your application through Grants.gov.
2. All applicants must meet the eligibility and statutory partnership requirements in III.A and include a Partnership Agreement (See Appendix B) with the application. 33 3. All applications must demonstrate, as required by CAA § 138(b)(1), that the projects will benefit disadvantaged communities as defined in Appendix A . While projects may have an incidental benefit to census block groups or other areas that are not considered disadvantaged communities as defined in Appendix A, the applicant must demonstrate how all the projects in the application will primarily benefit disadvantaged communities as defined in Appendix A.
4. Track I applications proposing to serve a geographically defined communit y identified as disadvantaged in Appendix A must submit a Project Area Map that defines which specific census block groups are designated as disadvantaged within the Project Area . Track 1 applications proposing to serve a farmworker community or DUC as defined in Appendix A must submit a Project Area Map showing where the communities that will benefit from the project are located.
5. Given the requirement under CAA § 138(b)(1) that all grants must be completed within three years, all applications must describe how the projects in the application, including any construction projects, can be completed within three years of award.
6. All Track I applications must include projects under at least one Climate Action Strategy and at least one Pollution Reduction Strategy as described in Section I.G. Track I applications also must include a Community Engagement and Collaborative Governance Plan, Community Strength Plan , Readiness Approach, and Compliance Plan as described in Section I.G.
7. All Track I applications including a workforce development project under the Climate Action Strategy must demonstrate how it will help reduce air pollutants and GHG emissions.
8. Track I applications that include projects under Climate Action Strategy 6, Brownfields Redevelopment, must demonstrate that the project will be performed on sites where, at the time of application submission, cleanup is complete or where the site does not require any cleanup activities for the intended use or reuse of the site. Please refer to the Climate Action Strategy 6 section in Appendix C for how to show that cleanup is complete or is not necessary.
9. All Track I applications for Pollution Reduction activities to increase monitoring capabilities or raise community awareness of pollution must also include an associated remediation, implementation, or infrastructure pollution reduction project that addresses the identified pollution issue.
10. Track I applications cannot request more than $20 million in EPA funding and Track II applications cannot request more than $3 million in EPA funding. Applications requesting more than these amounts will be rejected. If necessary, EPA will clarify any questions about the funding amounts requested prior to application review.
11. A Track I application for a TIA defined in Section II.B can only address one TIA. An application cannot address more than one TIA.
12. Track I applications submitted for TIA A benefitting Alaskan Tribal lands that include a project(s) for the assessment and cleanup of sites covered by the Contaminated ANCSA Lands Assistance Program must meet the relevant requirements specified in Appendix H. 34 13. Applications submitted for TIA E for U.S.-Southern Border Communities projects, as well as any including projects that may include project activities within 100 km of a U.S. border as discussed in Section II.B, must meet the special requirements identified in Section II.B.
14. Applications must be submitted in English only. Applications written in languages other than English will not be reviewed or considered for award. If you need assistance to submit the written application in English, technical assistance may be available. Please refer to Section I.E.
15. Multiple Applications. Lead Applicants may submit no more than two eligible applications under this NOFO, and receive no more than two awards, as explained in Section II. Excess applications will not be reviewed. If a Lead Applicant submits more than two eligible applications, they will be contacted by EPA to determine which one(s) to withdraw. Notwithstanding this limitation, a Lead Applicant may be a Statutory Partner or Collaborating Entity on other applications.
16. Resubmissions. As stated in Section II.C, a resubmitted application must be clearly identified as a resubmission of a previously submitted eligible application through such means as providing the date of the original submission and / or date of the EPA debriefing. It cannot be a completely different application from the one originally submitted. If EPA determines, in its sole discretion, that it is a completely different application bearing little resemblance to the original application, it may be rejected and not reviewed.
17. EPA will not consider any application that includes projects that are exclusively designed to conduct scientific research. However, applications may include research components such as building blocks for outreach, training, and program implementation projects. In such cases, applications should clearly articulate this link, explain why the research is necessary for the project’s success, and ensure that such research does not already exist.
18. EPA will not consider any application requesting funding for assessment, removal, or remediation of Superfund sites.
Note: If an application is submitted that includes any ineligible projects, tasks, or activities, including but not limited to ones that EPA determines cannot be funded under the statutory / regulatory authorities for the grant, that portion of the application will be ineligible for funding and may, depending on the extent to which it affects the application, render the entire application ineligible for funding. This includes but is not limited to projects requesting funding for relocation activities as described in Section I.F.
Applicants who have any questions about whether their project can be funded under the statutory / regulatory authorities for the grants and this NOFO, or whether certain costs related to the project are allowable costs, should clarify the issue with EPA prior to submitting their application. Failure to do so may result in the projects and / or costs being ineligible for funding and may impact the eligibility of the entire application.
35 Section IV. Application and Submission Information
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Note: Additional provisions that apply to this section of the NOFO, including those related to Intergovernmental Review, can be found in the EPA Solicitation Clauses.
A. Requirement to Submit through Grants.gov and Limited Exception Procedures Applicants must apply electronically through Grants.gov under this NOFO based on the grants.gov instructions below. If your organization has no access to the internet or access is very limited, you may request an exception from applying through Grants.gov for the remainder of this calendar year by following the procedures outlined here.
Issues with submissions with respect to this NOFO only are addressed in section 3: Technical Issues with Submission below.
1. SAM.gov (System for Award Management) Registration Instructions Organizations applying to this funding opportunity must have an active SAM.gov registration. If you have never done business with the Federal Government, you will need to register your organization in SAM.gov.
If you do not have a SAM.gov account, then you will need to create an account using login.gov to complete your SAM.gov registration.
SAM.gov registration is FREE. The process for entity registration includes obtaining a Unique Entity ID (UEI), a 12- character alphanumeric ID assigned an entity by SAM.gov, and requires assertions, representations and certifications, and other information about your organization. Please review the Entity Registration Checklist for details on this process.
If you have done business with the Federal Government previously, you can check your entity status using your government issued UEI to determine if your registration is active. SAM.gov requires you renew your registration every 365 days to keep it active.
Please note that SAM.gov registration is different than obtaining a UEI only. Obtaining an UEI only validates your organization’s legal business name and address. Please review the Frequently Asked Question on the difference for additional details.
Organizations should ensure that their SAM.gov registration includes a current e-Business (EBiz) point of contact name and email address. The EBiz point of contact is critical for Grants.gov Registration and system functionality.
Contact the Federal Service Desk for help with your SAM.gov account, to resolve technical issues or chat with a help desk agent: (866) 606-8220. The Federal Service desk hours of operation are Monday – Friday 8am – 8pm ET.
2. Grants.Gov Registration Instructions
Once your SAM.gov account is active, you must register in Grants.gov. Grants.gov will electronically receive your organization information, such as e-Business (EBiz) point of contact email address and UEI.
Organizations applying to this funding opportunity must have an active Grants.gov registration. Grants.gov registration is FREE. If you have never applied for a federal grant before, please review the Grants.gov 36 Applicant Registration instructions. As part of the Grants.gov registration process, the EBiz point of contact is the only person that can affiliate and assign applicant roles to members of an organization. In addition, at least one person must be assigned as an Authorized Organization Representative (AOR).
Only person(s) with the AOR role can submit applications in Grants.gov. Please review the Intro to Grants.gov-Understanding User Roles and Learning Workspace – User Roles and Workspace Actions for details on this important process.
Please note that r
egistering in grants.gov for the first time can take a month or more for new registrants.
Applicants must ensure that all registration requirements are met to apply for this opportunity through Grants.gov and should ensure that all such requirements have been met well in advance of the application submission deadline.
Contact Grants.gov for assistance at 1 -800-518-4726 or [email protected] to resolve technical issues with Grants.gov. Applicants who are outside the U.S. at the time of submittal and are not able to access the toll-free number may reach a Grants.gov representative by calling 606-545-5035. The Grants.gov Support Center is available 24 hours a day 7 days a week, excluding federal holidays.
Application Submission Process
To begin the application process under this NOFO, go to Grants.gov and click the red “Apply” button at the top of the view grant opportunity page associated with this opportunity.
The electronic submission of your application to this NOFO must be made by an official representative of your organization who is registered with Grants.gov and is authorized to sign applications for Federal financial assistance. If the submit button is grayed out, it may be because you do not have the appropriate role to submit in your organization. Contact your organization’s EBiz point of contact or contact Grants.gov for assistance at 1-800-518- 4726 or [email protected].
Applicants need to ensure that the Authorized Organization Representative (AOR) who submits the application through Grants.gov and whose UEI is listed on the application is an AOR for the applicant listed on the application. Additionally, the UEI listed on the application must be registered to the applicant organization's SAM.gov account. If not, the application may be deemed ineligible.
Application Submission Deadline
Your organization's AOR must submit your complete application package (including any resubmission as explained in Section II.C) electronically to EPA through Grants.gov no later than November 21, 2024, at 11:59 PM ET. Please allow for enough time to successfully submit your application and allow for unexpected errors that may require you to resubmit. Please see Section II and Section V describing the rolling application submittal and review process for this NOFO.
Applications submitted through Grants.gov will be time and date stamped electronically. Please note that successful submission of your application through Grants.gov does not necessarily mean your application is eligible for award. Any application submitted after the application deadline time and date deadline will be deemed ineligible and not considered.
3. Technical Issues with Submission
If applicants experience technical issues during the submission of an application that they are unable to 37 resolve, follow these procedures before the application deadline date:
a. Contact the Grants.gov Support Center before the application deadline date. b. Document the Grants.gov ticket / case number.
c. Send an email with EPA-R-OEJECR-OCS-23-04 in the subject line to [email protected] before the application deadline time and include the following information:
i. Grants.gov ticket / case number(s)
ii. Description of the issue
iii. The entire application package in PDF format
Without this information, EPA may not be able to consider applications submitted outside of Grants.gov.
Any application submitted after the application deadline will be deemed ineligible and not be considered.
Please note that successful submission through Grants.gov or email does not necessarily mean your application is eligible for award.
EPA will make decisions concerning acceptance of each application submitted outside of Grants.gov on a case-by-case basis. EPA will only consider accepting applications that were unable to submit through Grants.gov due to Grants.gov or relevant SAM.gov system issues or for unforeseen exigent circumstances, such as extreme weather interfering with internet access. Failure of an applicant to submit the application prior to the application submission deadline time and date because they did not properly or timely register in SAM.gov or Grants.gov is not an acceptable reason to justify acceptance of an application outside of Grants.gov.
4. Required Forms and Documents
The following forms and documents are required under this NOFO:
Mandatory Documents for Track I and Track II Applications
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 Preaward Compliance Review Report Form 4700-4 (Please see these Useful Tips for completing this form)
5. Project Narrative Attachment Form: Use this to prepare your Project Narrative as described in Section IV.B below.
6. Attachments: Use the “Other Attachments Form ” in Grants.gov for the following additional documents. These attachments are not subject to the page limitation that applies to the Project Narrative identified below and some have their own page limitation as identified below:
• Attachments for Track I and Track II Applications:
o Attachment A: Program Budget Template (See below in Section IV.B and also optional template in Appendix G)
o Attachment B: Partnership Agreement (See Section III.A and Appendix B) o Attachment C: Indirect Cost Rate Agreement, if applicable. • Attachments for Track I Applications Only:
o Attachment D: Project Area Map as described in Appendix A. o Attachment E: Community Engagement and Collaborative Governance Plan as described in Section I.G that does not exceed 10 single spaced pages-excess pages will not be reviewed.
38 o Attachment F: Community Strength Plan as described in Section I.G that does not exceed 5 single spaced pages-excess pages will not be reviewed. o Attachment G: Readiness Approach Information as described in Section I.G. o Attachment H: Compliance Plan as described in Section I.G that does not exceed 5 single-spaced pages--excess pages will not be reviewed.
B. Content of Application Submission
Applicants should read the following sections very carefully. A complete application package includes the forms, documents, and attachments listed above in Section IV.A.4: Required Forms and Documents, which includes the materials further described below.
Applicants should ensure that their application materials, including attachments, address all the applicable evaluation criteria in Section V, and applicable threshold eligibility criteria in Section III.D, for Track I and II applications. The evaluation criteria in Section V place increased emphasis on certain evaluation criteria that are integral to ensuring that the application will advance environmental and climate justice, meet CCG objectives, and maximize benefits to disadvantaged communities.
Project Narrative for Track I and II Applications
Below are the instructions for both Track I and Track II applications. There are different instructions for each track, so applicants should carefully read the instructions and contact EPA at [email protected] with any questions. There are also certain attachments for Track I and II applications that must be submitted as identified in Section IV.A.4 above.
The Project Narrative for both application tracks are comprised of Sections A and B as described below for each track and should include the information and content below . Applicants should ensure they include information addressing the relevant evaluation criteria in Section V for Track I or II applications and any applicable threshold eligibility criteria in Section III.D . Please make sure the required attachments identified in Section IV.A.4 for Track I and II applications also include the applicable information. • The Project Narrative for Track I applications must not exceed twenty (20) single-spaced pages and be on letter size pages (8 ½ X 11 inches). Excess pages will not be reviewed. The attachments for Track I described in Section IV.A.4 are not part of the Project Narrative. • The Project Narrative for Track II applications must not exceed fifteen (15) single spaced pages and be on letter size pages (8 ½ X 11 inches). Excess pages will not be reviewed. The attachments for Track II described in Section IV.A.4 are not part of the Project Narrative.
Applicants are encouraged to be concise and do not need to use all the pages within the page limit. Links to external websites or content will not be reviewed or considered. Any pages beyond the page limitations will not be reviewed by the Review Panel. It is recommended that applicants use a standard font (e.g., Times New Roman, Calibri, and Arial) and a 12-point font size with 1- inch margins. While these guidelines establish the acceptable type size requirements, applicants are advised that readability is of paramount importance and should take precedence in selection of an appropriate font for use in the application. The grant application forms and other attachments identified in Section IV.A.4: Required Forms and Documents above are not included in the Project Narrative page limits for Track I and II applications.
To assist EPA reviewers, applicants should reference the numbers and titles of the evaluation criteria identified in Section V.C in their Project Narratives (and attachments) to help identify where the criteria are being addressed as applicable. Applicants should contact EPA with any questions about the application content requirements.
39 Track I Project Narrative
Track I application s include a Project Narrative with two sections as identified below : (A) Executive Summary and (B) Project Workplan. Together these cannot exceed 20 pages as described above.
Section A. Executive Summary
The Executive Summary should contain the elements below and should not exceed three pages. • Application Title: Provide a name for the application. • Lead Applicant: Name of the Lead Applicant.
• Statutory Partner to the Lead Applicant: Name of the Statutory Partner. • Contact Information: Include a name, title, email address, and phone number for key personnel for the Lead Applicant and, Statutory Partner.
• Eligibility: Describe how the Lead Applicant and Statutory Partner meet the eligibility requirements in Section III.A of the NOFO.
• Climate Action Strategy: Specify which Climate Action Strategy(ies) is addressed in the application.
• Pollution Reduction Strategy: Specify which Pollution Reduction Strategy(ies) is addressed in the application.
• Grant Award Period and Completion: Provide estimated beginning and ending dates for the period of performance for your proposed grant. Given the requirement under CAA § 138(b)(1) that all grants must be completed within three years, all applications must state how the projects in the application, including any construction projects, can be completed within three years of award. • Amount of EPA Funding Requested: See award sizes specified in Section II.A. • Target Investment Area: If the application is for a Target Investment Area as defined in Section II.A, please identify which one. If the application is not for a Target Investment Area, put N/A. • Disadvantaged Community to be nefit from the projects : Identify and describe the disadvantaged community, as defined in Appendix A, intended to benefit from the projects in the application.
• Other Sources of Funding: Briefly explain, to the extent you can, whether funding for the projects in your application is available under the Infrastructure Investments and Jobs Act (IIJA), other IRA programs, or other funding streams and if so your reasons for seeking funding for these projects under this NOFO. Please also note the Duplicate Funding clause included in Section IV of the EPA Solicitation Clauses incorporated by reference in this NOFO and referenced in Section V.E. • Resubmission Status: Specify if the application is for a resubmission of a previously submitted and reviewed application. If so, please identify the date of the original submission and the date of EPA debriefing of the previously submitted application (See Section II.C for further information on the resubmission process).
Section B. Project Workplan
The Project Workplan should contain the elements below.
Part 1. Community-Driven Investments for Change
1.1 Community Vision Description.
• Community Description: Provide an overview of the Project Area described in Appendix A, 40 including its resources, assets, and characteristics. Describe how the boundary of the Project Area was determined and demonstrate how the project activities in the Project Area are designed and focused to provide impactful benefits to the residents of disadvantaged communities in the Project Area as defined in Appendix A. 15 Applicants should note that while they can determine the Project Area for their projects consistent with the instructions in Appendix A, concentrated and compact Project Areas may maximize benefits to the residents of the disadvantaged communities in the Project Area .
Activities spread across a large Project Area may be more dispersed and less impactful. As described in Section V.C, EPA will evaluate applications based in part on the extent and quality to which project benefits will accrue to the residents of disadvantaged communities in the Project Area as defined in Appendix A in an impactful manner. • Community Challenges: Describe the needs and challenges the Project Area is facing, including climate impacts , climate change risks / exposures, and / or localized pollution .
Describe the impact of these challenges on the residents of the disadvantaged communities in the Project Area as defined in Appendix A and particularly on priority populations within the Project Area who are acutely exposed to and impacted by climate, pollution, and weather - related threats, and / or who exhibit acute vulnerabilities or susceptibilities to the impacts of environmental pollution. See footnote 3 for more information on priority populations. • Community Vision: Articulate an overall vision for the impact and benefits the grant would have on the Project Area in the near and long term, including the effect it will have on reducing and pre venting pollution; building resilience to climate change and mitigating current and future climate risks; creating high-quality jobs and expanding economic opportunity through workforce development; and bolstering Project Area strength by ensuring that residents of the disadvantaged communities in the Project Area receive the benefits of investments and have the opportunity to build on them for current and future generations.
1.2 Selected Strategies: As described in Section I.G, applications must address at least one Climate Action Strategy and at least one Pollution Reduction Strategy. Accordingly, applications should address the following requirements:
• Strategy Overview – for each selected Climate Action and Pollution Reduction Strategy:
o Provide an overview of the strategy and associated projects and describe how they will be implemented during the grant term.
o Describe how the strategies and associated projects in the application are integrated and / or designed to complement each other to provide impactful benefits to the residents of disadvantaged communities within the Project Area as defined in Appendix A and describe how the scale and scope of the Project Area was designed to accomplish this.
o Explain how the amount / proportion of the requested funding was determined for each strategy and associated project in the application.
• Climate Action Strategies
15 Disadvantaged communities as defined in Appendix A include census block groups designated as geographically defined disadvantaged communities, as well as farmworker communities and DUCs. 41 o Describe how the project(s) associated with the Climate Action Strategy(ies) will address the climate impacts, risks, and / or challenges facing the Project Area and especially the residents of disadvantaged communities with in the Project Area as defined in Appendix A ; will decrease GHG emissions within the Project Area and increase the overall resilience of the Project Area to current and anticipated climate impacts; and are responsive to the Project Area needs and challenges identified in the Community Vision Description.
• Pollution Reduction Strategies
o Describe how the project(s) associated with the Pollution Reduction Strategy(ies) will address the localized pollution challenges facing the Project Area and especially the residents of disadvantaged communities within the Project Area as defined in Appendix A; will make substantial and measurable (i.e., quantifiable) progress towards preventing, reducing, and / or mitigating existing and future sources of pollution to benefit the Project Area; and are responsive to the Project Area needs and challenges identified in the Community Vision Description.
Part 2. Program Management, Capability and Capacity
2.1 Performance Management Plan , Outputs / Outcomes : Applicants should describe the environmental results of the proposed project in terms of well -defined outputs and, to the maximum extent practicable, well- defined outcomes that will demonstrate how the project will contribute to the Community Change Grants goals and objectives. (See Section I.I and Appendix F for more detail on expected outputs and outcomes). In addition to identifying expected project outputs and outcomes, applicants should describe how they plan to track and measure their project performance, including through indicator tracking, to monitor progress towards achieving the expected outputs and outcomes throughout the performance period.
Applicants should also:
• Describe how they selected the expected outputs and outcomes and how they will lead to improvements to the environmental conditions and public health of the community members of the Project Area in the short and long term. • Describe how the expected project outputs and outcomes are specific and include achievable and reasonable target measures within the project period. • Describe how the recipient will use program evaluation activities (e.g., utilizing proper evaluation tools and personnel / organizations with experience in evaluating program and project progress / success) from project initiation through project completion to meaningfully document and measure their progress towards achieving project goals.
2.2 Project Linkages to the EPA Strategic Plan : Applications should describe how the proposed project activities support and advance EPA Strategic Plan Goal 2 (Take Decisive Action to Advance Environmental Justice and Civil Rights), Objective 2.1, (Promote Environmental Justice and Civil Rights at the Federal, Tribal, State, and Local Levels). See Section I.I. In addition, applications, depending on the projects included in them, should also address how they support
and advance the following EPA Strategic Plan Goals as applicable:
• Goal 1 - Tackle the Climate Crisis
42 • Goal 4 - Ensure Clean and Healthy Air for All Communities • Goal 5 - Ensure Clean and Safe Water for All Communities • Goal 6 - Safeguard and Revitalize Communities; and
• Goal 7 - Ensure Safety of Chemicals for People and the Environment Refer to the EPA Strategic Plan.
2.3 CBO Experience and Commitment : Applications should describe the following for the Lead Applicant and / or Statutory Partner for the proposed grant:
• Their history and experience as a CBO.
• The depth of their commitment, connections, and relationships with the disadvantaged communities the application is intended to benefit.
2.4 Programmatic and Managerial Capability and Resources: Applications should provide information demonstrating the Lead Applicant's and Statutory Partner’s ability to successfully complete, oversee, and manage the award including:
• Their organizational experience and capacity related to performing the proposed projects or similar activities (e.g., experience in managing projects and activities like those in the application).
• Their resources, capacity, capabilities, staff (e.g., project manager and other key personnel), expertise, and skills to perform and manage the award activities effectively during the three-year award period. For Lead Applicants submitting two applications under this NOFO, this includes how they demonstrate they have the above attributes to perform, manage, and oversee two awards effectively within the three-year award period. • Their financial stability, controls in place, and capacity to manage taxpayer dollars ethically and efficiently as well as the policies and controls to be in place for project oversight and to manage program risk. This includes controls to identify waste, fraud, and abuse, and reduce the potential for waste, fraud, and abuse, by including plans and policies for program oversight, including confidential reporting (e.g., whistleblower protections), and risk management.
• A projected milestone schedule for the proposed projects (up to three years) with a breakout of the project activities into phases with associated tasks and timeframes for completion of tasks, including the approach, procedures, and controls for ensuring that the award funds will be expended in a timely and efficient manner while ensuring that costs are eligible, reasonable, and allowable.
2.5 Past Performance : Describe federally funded and / or non- federally funded assistance agreements (assistance agreements include grants and cooperative agreements but not contracts) that the Lead Applicant performed within the last three years (no more than three agreements in total) and provide the information below for them. EPA agreements are preferred to be included. • Describe whether, and how, the Lead Applicant was able to successfully complete and manage the agreements.
• Describe the history of the Lead Applicant in meeting the reporting requirements under the agreements including submitting acceptable final technical reports. 43 • Describe how the Lead Applicant documented and / or reported on whether progress towards achieving the expected results (i.e., outputs and outcomes) under those agreements was being made . If progress was not made, please indicate whether, and how, that was documented.
Note: In evaluating the Lead Applicant’s past performance, the Agency will consider the information provided in the application 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 there is no 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 past performance 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).
Part 3. Feasibility, Sustainability, and Budget: Provide the following information:
3.1 Feasibility: Demonstrate that all the projects in the application can be successfully and effectively performed within the three-year grant period of performance, and the degree of risk that they cannot be. This includes describing how the strategies and associated projects can individually and collectively be completed within three years.
3.2 Sustainability: Demonstrate the extent to which the benefits and outcomes from the projects can be sustained after the three -year grant period of performance based on factors including but not limited to whether (i) the applicant will leverage funding and / or resources from other sources to ensure the sustainability of the projects beyond the three-year grant term and (ii) the description of an operations and maintenance approach including plans and commitments to ensure there is continued funding available for operation and maintenance activities of infrastructure activities for the projects after the grant term is over (e.g., are there demonstrated commitments for continuing operation and maintenance funding / resources from the appropriate parties after the three year grant term is over) including coordination with appropriate responsible parties.
3.3 Program Budget Description: Provide a detailed budget description and estimated funding amounts for each project component / task similar to that on the budget found in SF -424A, which includes the EPA funding requested to be expended over the three-year period of performance. This section provides an opportunity for a narrative description of the budget or aspects of the budget found in the SF-424A. In the description, explain how the budget is reasonable to accomplish the projects, and the cost-effectiveness of the budget in terms of maximizing the share of funds used for the delivery of benefits to disadvantaged communities (both the direct costs of funds passed through for financial assistance as well as associated indirect costs).
Note: A template to depict the program budget description is included as Appendix G and may be used to supplement the budget description in the Project Narrative. Applicants that do not use the template will not be penalized and applicants can convey the information in other forms. While the program budget description is part of the Proj ect Narrative page limit, the template is not part of the page limit for the Project Narrative and will not count against the 20 -page Project Narrative page limit for Track I applications.
44 C. Track I Application Attachments. These attachments must be submitted with the application as stated in Section IV.A.4 above and are not part of the Project Narrative described above. Please note any page limits that apply to these attachments.
• Project Area Map (Attachment D). Submit a Project Area Map as described in Appendix A. • Community Engagement and Collabora tive Governance Plan (Attachment E). Applications must include a Community Engagement and Collaborative Governance Plan that should address the elements of the plan as described in Section I.G. This plan cannot exceed 10 pages (excess pages will not be reviewed).
• Community Strength Plan (Attachment F). Applications must include a Community Strength Plan that should address the elements of the plan as described in Section I.G. This plan cannot exceed 5 pages (excess pages will not be reviewed).
• Readiness Approach (Attachment G ). Applicants must d emonstrate, based on the Readiness Approach Requirements described in Section I.G, their ability and readiness to proceed with grant performance for the projects in the application upon receiving an award, and generally no later than 120 days after award, in order to ensure that the projects can be completed within the statutory three- year grant period. As appropriate, this may include a description of the completed project planning and design phases related to the project(s) as well as demonstrating that the applicant has obtained and / or complied with the necessary approvals, permits, permissions, and any other applicable requirements, to commence project performance upon award, and if not their plan for doing so within 120 days of award. There is no page limit for this information, but applicants should be as concise as possible.
• Compliance Plan (Attachment H). Applications must include a Compliance Plan as described in Section I.G that does not exceed 5 pages (excess pages will not be reviewed).
Track II Application Requirements
Track II applications include a Project Narrative with two sections as identified below: (A) Executive Summary and (B) Project Workplan. Together these cannot exceed 15 pages as described above.
Section A. Executive Summary
The Executive Summary should contain the elements below and should not exceed two pages. • Application Title: Provide a name for the application. • Lead Applicant: Name of the organization applying.
• Statutory Partner to the Lead Applicant: Name of the Statutory Partner. • Contact information: Include a name, title, email address, and phone number for key personnel for Lead Applicant, Statutory Partner.
• Eligibility: Describe how the Lead Applicant and Statutory Partner meet the eligibility requirements in Section III.A of the NOFO.
• Disadvantaged Community to benefit from the projects: Identify and describe the disadvantaged communities, as defined in Appendix A, intended to benefit from the projects in the application.
• Grant Award Period and Completion: Provide estimated beginning and ending dates for the period of performance for your proposed grant. Given the requirement under CAA § 138(b)(1) that 45 all grants must be completed within three years, all applications must state how the projects in the application can be completed within three years of award. • EPA Funding Requested: See award sizes specified in Section II.A. • Other Sources of Funding Briefly explain, to the extent you can, whether funding for the projects in your application is available under the Infrastructure Investments and Jobs Act (IIJA), other IRA programs, or other funding streams and, if so, your reasons for seeking funding for these projects under this NOFO. Please also note the Duplicate Funding clause included in Section IV of the EPA Solicitation Clauses incorporated by reference in this NOFO and referenced in Section V.E. • Resubmission Status: Specify if the application is for a resubmission of a previously submitted and reviewed application. If so, please identify the date of the original submission and date of EPA debriefing of the previously submitted application (See Section II.C for further information on the resubmission process).
Section B. Project Workplan
1. Track II Program Objectives: Applications should describe the following:
• How the application addresses the Track II objectives identified in Section I.H. • What methods, tools, and trainings the applicant will use to facilitate the engagement of disadvantaged communities in state and Federal advisory groups, workshops, rulemakings, and / or other public processes, including local, Tribal, and other governmental processes, related to environmental and climate justice.
• How the application addresses the disadvantaged community’s lack of access to, or weak relationships with, governmental entities, including how the application improves those relationships, increases points of access for disadvantaged communities with government entities, and creates channels to work cooperatively to promote environmental and climate justice
• How the application will result in governmental entities better understanding the root causes of environmental and climate justice issues that impact disadvantaged communities, so government leaders and decision -makers are better prepared to proactively address concerns before issues materialize.
2. Project Collaboration and Participation: Applications should describe the following:
• How meaningful input and feedback was considered from the disadvantaged community and other stakeholders in designing and developing the project and how input will continue to be obtained and considered during grant performance. • The facilitation and accountability measures to establish and maintain trust between the disadvantaged community and government officials to ensure the community can collaborate in a n authentic and meaningful way, rather than an insincere manner, on environmental and climate justice issues with governmental bodies. • The applicant’s and any Collaborating Entities’ history of relationships and collaborations with disadvantaged communities, governmental bodies, and other stakeholders to address environmental and environmental / climate justice issues.
3. Project linkages: Applicants should describe how their application supports and advances EPA Strategic Plan Goal 2 (Take Decisive Action to Advance Environmental Justice and Civil Rights), Objective 2.1, (Promote Environmental Justice and Civil Rights at the Federal, Tribal, State, and Local Levels).
46 4. Program Budget Description: Provide a detailed budget description and estimated funding amounts for each project component / task similar to that on the budget found in SF -424A, which includes the EPA funding requested to be expended over the three-year period of performance. This section provides an opportunity for a narrative description of the budget or aspects of the budget found in the SF-424A. In the description, explain how the budget is reasonable to accomplish the projects, and the cost-effectiveness of the budget in terms of maximizing the share of funds used for the delivery of benefits to disadvantaged communities (both the direct costs of funds passed through for financial assistance as well as associated indirect costs).
Note: A template to depict the program budget description is included as Appendix G and may be used to supplement the budget description in the Project Narrative. Applicants that do not use the template will not be penalized and applicants can convey the information in other forms. While the program budget description is part of the Project Narrative page limit, the template is not part of the page limit for the Project Narrative and will not count against the 15-page Project Narrative page limit for Track II applications.
5. Environmental Results: Applicants should describe the following:
• Their plan, with associated timeframes, for tracking and measuring their progress in achieving the expected project outcomes and outputs for Track II applications. See Section I.I and Appendix F for more detail on expected outputs and outcomes. • Whether and how the projects and their outcomes are sustainab le beyond the three -year grant period, and how they will leverage resources, community support, etc. to facilitate this. The quality and specificity of the proposed outputs and outcomes, and how they will lead to the success of the grants, should also be addressed.
6. CBO Experience and Commitment: Applicants should describe the following for the Lead Applicant and / or Statutory Partner for the proposed grant:
• Their history and experience as a CBO.
• The depth of their commitment, historical connections, and relationships with the disadvantaged community the application is intended to benefit.
7. Programmatic and Managerial Capability and Resources: Provide information demonstrating the Lead Applicant's and Statutory Partner’s ability to successfully complete, oversee, and manage the award including:
• Their organizational experience and capacity related to performing the proposed projects or similar activities (e.g., experience in managing projects and activities like those in the application).
• Their r esources, capacity, capabilities, staff (e.g., project manager and other key personnel), expertise, and skills to perform and manage the award activities effectively during the three-year award period. For Lead Applicants submitting two applications under this NOFO, this includes how they demonstrate they have the above attributes to perform, manage, and oversee two awards effectively within the three-year award period. • Their milestone schedule for the proposed projects (up to three years) including the breakout of the project activities into phases and timeframes for completion of tasks, and the approach, procedures, and controls for ensuring that the award funds will be expended in a timely and efficient manner while ensuring that costs are eligible, reasonable, and allowable.
• Their legal and financial controls in place, and capacity to manage taxpayer dollars ethically and efficiently as well as the policies and controls for project oversight and program risk. This includes the extent and quality to which the application includes controls to identify waste, fraud, and abuse, and reduce the potential for waste, fraud, and 47 abuse by including plans and policies for program oversight, including confidential reporting (e.g., whistleblower protections).
8. Past Performance: Describe federally funded and / or non-federally funded assistance agreements (assistance agreements include grants and cooperative agreements but not contracts) that the Lead Applicant performed within the last three years (no more than three agreements in total) and provide the information below for them. EPA agreements are preferred to be included. • Describe whether, and how, the Lead Applicant was able to successfully complete and manage the agreements.
• Describe the Lead Applicant’s history of meeting the reporting requirements under the agreements including submitting acceptable final technical reports. • Describe how the Lead Applicant documented and / or reported on whether progress towards achieving the expected results (i.e., outputs and outcomes) under those agreements was being made. If progress was not being made, please indicate whether, and how, this was documented.
Note: In evaluating the Lead Applicant’s past performance, the Agency will consider the information provided in the application 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 there is no 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 past performance 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).
C. Informational Webinars and Application Assistance
EPA will host and/or participate in a series of webinars about this NOFO while it remains open for application submission. EPA will post information about the webinars, schedule for webinars, as well as additional information about this NOFO (e.g., frequently asked questions, technical assistance) on the Inflation Reduction Act Community Change Grants Program page. A recording of each webinar will be posted at the link above along with presented materials.
In addition, EPA’s technical assistance contractor may host webinars related to the NOFO and information on that will be posted on their website.
Please note that in accordance with EPA’s Policy for Competition of Assistance Agreements, 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 evaluation criteria.
Please note, however, that as stated in Section I, technical assistance will be available to eligible applicants for help with this NOFO.
Applicants are responsible for the contents of their applications. However, consistent with the provisions in the NOFO, 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 this NOFO.
Section V. Application Review Information
(back to the Table of Contents)
48 Note: Additional provisions that apply to this section can be found at EPA Solicitation Clauses.
A. Threshold Eligibility Review Process
All applications will be evaluated for threshold eligibility purposes based on the threshold eligibility criteria described in Section III.D.
B. Review Panel and Evaluation Process
All applications that pass the threshold eligibility review process will be evaluated and scored by review panels, on a rolling basis, using the track-specific evaluation criteria and processes described below. Review panels will be comprised of EPA staff and / or external reviewers. See below for additional detail about the evaluation criteria and processes for each track.
C. Track I Application Review Process and Evaluation Criteria All eligible Track I applications (including those for the TIAs described in Section II.B) will be evaluated, on a rolling basis, based on the155 point scale described below.
Track I Application Criteria
Section
Part 1. Community Driven Investments for Change 80 total
1.1 Community Overview 10
1.2 Selected Strategies 45
1.3 Community Engagement and Collaborative Governance Plan 15
1.4 Community Strength Plan 10
Possible
Points
Part 2. Program Management, Capability, and Capacity 35 total
2.1 Performance Management Plan, Outputs / Outcomes 6
2.2 Project Linkages to the EPA Strategic Plan 4
2.3 CBO Experience and Commitment 5
2.4 Programmatic and Managerial Capability and Resources 15
2.5 Past Performance 5
Part 3. Readiness to Perform, Feasibility, and Sustainability 40 total
3.1 Readiness Approach 8
3.2 Feasibility 9
3.3 Sustainability 5
3.4 Program Budget Description 8
3.5 Compliance Plan 10
TOTAL 155
Evaluation Criteria for Track I Applications (155 points total) Pa
rt 1. Community Driven Investments for Change (80 points total) 49 1.1 Community Vision Description (10 points)
• Community Description: Applications will be evaluated based on their description of the Project Area including its resources, assets, and local characteristics, as well as how the project activities in the Project Area are designed and focused to maximize benefits for the residents of disadvantaged communities in the Project Area. Please note that in evaluating applications under this criterion, EPA will evaluate the extent and quality to which project benefits will accrue to the residents of the disadvantaged communities in the Project Area, as defined in Appendix A, in an impactful manner. (4 points ) • Community Challenges: Applications will be evaluated based on how well they describe the challenges and needs the residents of the disadvantaged communities in the Project Area, as defined in Appendix A, are facing, including climate impacts, climate change risks / exposures, and / or localized pollution, and the impact these challenges have on priority populations within the Project Area who are acutely exposed to and impacted by climate, pollution, and weather -related threats, and / or who exhibit acute vulnerabilities or susceptibilities to the impacts of environmental pollution. See footnote 3 for more information on priority populations. (3 points)
• Community Vision: Applications will be evaluated based on the quality and extent to which they articulate a n overall and clear vision for the impacts and benefits the grant would have on the residents of the disadvantaged communities in the Project Area as defined in Appendix A in the near and long term. (3 points).
1.2 Selected Strategies (45 points)
• Strategy Overview (15 points). Applications will be evaluated based on the quality and extent to which they:
o Provide an overview of the strategies and associated projects and describe how they will be implemented during the grant term. (5 points)
o Describe how the strategies and associated projects in the application are integrated and / or designed to complement each other to benefit the residents of the disadvantaged communities in the Project Area, and how the scale and scope of the Project Area was developed to accomplish this. (7 points) o Explain how the amount / proportion of the requested funding was determined for each strategy and aligned project in the application. (3 points) • Climate Action Strategies (15 points). Applications will be evaluated based on the quality and extent to which they:
o Describe how the associated projects will address the identified climate impacts and / or climate change risk(s) / exposure(s) within the Project Area , and especially those facing residents of disadvantaged communities in the Project Area as defined in Appendix A and explain how the project(s) will decrease GHG emissions within the Project Area and / or increase overall Project Area resilience to current and anticipated climate impacts. (8 points)
o Describe how the selected Climate Action Strategies and associated projects help meet the needs and challenges of the Project Area as articulated in the Community Vision Description. (7 points)
• Pollution Reduction Strategies (15 points). Applications will be evaluated based on the 50 quality and extent to which they:
o Describe how the associated project(s) will address the identified localized pollution challenges facing the Project Area, and especially the residents of disadvantaged communities within the Project Area as defined in Appendix A , and will make substantial and measurable (i.e., quantifiable) progress towards preventing, reducing, and / or mitigating existing and future sources of pollution to benefit the Project Area. (8 points)
o Describe how the selected Pollution Reduction Strategies help meet the needs and challenges of the Project Area as articulated in the Community Vision Description. (7 points)
1.3 Community Engagement and Collaborative Governance Plan (15 points): The Community Engagement and Collaborative Governance Plan described in Section I.G will be evaluated based on the quality and extent to which it demonstrates:
• Past Community Outreach and Engagement Conducted : How the applicant’s past engagement with the Project Area community impacted the Strategy and associated project selection and implementation approach included in the application, including the outreach and engagement methods used for the Project Area and specific neighborhoods or groups within the Project Area. (4 points)
• Community Engagement Plan Implementation : The specific community engagement methods used by the applicant , as well as how they will mitigate barriers and involve relevant governmental stakeholders necessary to support overall project implementation. (6 points)
• Collaborative Governance Structure: The details regarding the roles and responsibilities of the Lead Applicant, Collaborating Entities, and community residents and / or community-selected representatives for implementing, managing, and overseeing the application’s project activities, including how regularly they will meet to discuss project implementation. (5 points)
1.4 Community Strength Plan (10 points): The Community Strength Plan as described in Section I.G will be evaluated based on the quality and extent to which it demonstrates:
• Maximizing Economic Benefits of Projects: How the projects included in the application are intended to provide economic benefits for individuals in the Project Area, including priority populations as defined in footnote 3. (5 points) • Displacement Avoidance: The measures for mitigating potential near-term and long-term risks associated with the proposed projects to residents, small businesses, nonprofits, and other community members , the vulnerability the community faces to rising costs attributable to their proposed project, and the potential project impacts to households, small businesses, and other existing groups. (5 points)
Part 2. Program Management, Capability, and Capacity (35 points total)
2.1 Performance Management Plan and Outputs / Outcomes (6 points): Applications will be evaluated based on:
51 • Whether the application describes an effective plan, with associated timeframes, for tracking and measuring progress in achieving the expected project outcomes and outputs including those identified in Appendix F, as appropriate, and any additional ones identified in the application. (2 points)
• The quality and specificity of the proposed outputs and outcomes and how they will lead to improvements to the environmental conditions and public health of the disadvantaged communities in the short and long term. (2 points)
• Whether, and how, the applicant has incorporated program evaluation activities (e.g., utilizing proper evaluation tools and personnel / organizations with experience in evaluating program and project progress / success) from project initiation through project completion to meaningfully document and measure their progress towards achieving project goals and how they will use the results of the evaluations to meet the project goals within the required timeframes. (2 points)
2.2 Project Linkages to the EPA Strategic Plan (4 points): Applications will be evaluated based on the extent and quality to which the proposed project activities support and advance EPA Strategic Plan Goal 2 (Take Decisive Action to Advance Environmental Justice and Civil Rights), Objective
2.1, (Promote Environm ental Justice and Civil Rights at the Federal, Tribal, State, and Local Levels).
In addition, applications, depending on the projects included in them, will also be evaluated based on the quality and extent to which they also support and advance the following EPA Strategic Plan Goals as applicable:
• Goal 1 - Tackle the Climate Crisis
• Goal 4 - Ensure Clean and Healthy Air for All Communities • Goal 5 - Ensure Clean and Safe Water for All Communities • Goal 6 - Safeguard and Revitalize Communities; and
• Goal 7 - Ensure Safety of Chemicals for People and the Environment
2.3 CBO Experience and Commitment (5 points): The CBO(s) that are either the Lead Applicant and / or Statutory Partner for the proposed grant will be evaluated based on their history and experience as a CBO and the depth of their commitment, connections, and relationships with the disadvantaged communities the application is intended to benefit.
2.4 Programmatic and Managerial Capability and Resources (15 points): The Lead Applicant and Statutory Partner will be evaluated based on their ability to successfully complete, oversee, and manage the award considering:
• Their organizational experience and capacity related to performing the proposed project(s) or similar activities (e.g., experience in managing projects and activities like those in the application). (4 points)
• Their r esources, capacity, capabilities, staff (e.g., project manager and other key personnel), expertise, and skills to perform and manage the award activities effectively during the three-year award period. For Lead Applicants submitting two applications under this NOFO, this includes how they demonstrate they have the above attributes to perform, manage, and oversee two awards effectively within the three-year award period (4 points) 52 • The milestone schedule for the proposed projects (up to three years) including the breakout of the project activities into phases and timeframes for completion of tasks, and the approach, procedures, and controls for ensuring that the award funds will be expended in a timely and efficient manner while ensuring that costs are eligible, reasonable, and allowable. (3 points)
• Their financial stability, controls in place, and capacity to manage taxpayer dollars ethically and efficiently as well as the policies and controls for project oversight and program risk. This includes the extent and quality to which the application includes controls to identify waste, fraud, and abuse, and reduce the potential for waste, fraud, and abuse by including plans and policies for program oversight, including confidential reporting (e.g., whistleblower protections). (4 points)
2.5 Past Performance (5 points): The Lead Applicant will be evaluated based on their ability to successfully complete and manage the proposed projects considering their:
• Past performance in successfully completing and managing the assistance agreements identified in response to Section IV.B. (3 points)
• History of meeting the reporting requirements under the assistance agreements identified in response to Section IV.B including whether the applicant submitted acceptable final technical reports under those agreements and the extent to which the applicant adequately and timely reported on their progress towards achieving the expected outputs and outcomes under those agreements and if such progress was not being made whether the applicant adequately reported why not. (2 points)
Note: The focus of this criterion is on the Lead Applicant’s past performance and not that of any other Collaborating Entities or contractors / consultants who may be assisting the applicant with performance of the award. In evaluating the Lead Applicant under these factors, EPA will consider the information provided in the application and may also consider relevant information from other sources, including information from EPA files and from current / prior grantors. If the Lead Applicant does not have any relevant or available past performance related to federal or non-federal grants, this should be stated explicitly in the application (e.g., our organizations have no relevant past grants experience). Including this statement will ensure you receive a neutral score for these factors (a neutral score is half of the total points available in a subset of possible points). Failure to include this statement may result in your receiving a score of 0 for these factors.
Part 3. Readiness to Perform, Feasibility, and Sustainability (40 points total):
3.1 Readiness Approach (8 points): Applications will be evaluated based on the applicant's ability and readiness to proceed with grant performance for the projects in the application, based on the Readiness Approach Requirements described in Section I.G, upon receiving an award, or generally no later than 120 days after award, to ensure that the projects can be completed within the statutory three-year grant period. As appropriate, this may include evaluating the description of the completed project planning and design phases related to the project(s) as well as demonstrating that the applicant has obtained and / or complied with the necessary approvals, permits, permissions, and any other applicable requirements, to commence project performance upon award, and if not generally within 120 days of award.
3.2 Feasibility (9 points): Applications will be evaluated based on whether it is demonstrated that all the projects in the application can be successfully and effectively performed within the three -year grant period of performance, and the degree of risk that they cannot be. This includes also 53 evaluating how the strategies and associated projects can individually and collectively be completed within three years.
3.3 Sustainability (5 points): Applications will be evaluated based on whether it is demonstrated that the benefits and outcomes from the projects in the application can be sustained after the three-year grant period of performance based on factors including but not limited to whether (i) the Applicant will leverage funding and / or resources from other sources to ensure the sustainability of the projects beyond the three-year grant term and (ii) the description of an operations and maintenance approach including the plans and commitments to ensure there is continued funding availa ble for operation and maintenance activities of infrastructure activities for the projects after the grant term is over (e.g., are there demonstrated commitments for continuing operation and maintenance funding / resources from the appropriate parties after the three year grant term is over) including coordination with appropriate responsible parties.
3.4 Program Budget Description (8 points): The program budget will be evaluated based on:
• The reasonableness of the budget and allowability of the costs for each component / activity of the projects in the application. This includes evaluating whether funding is well balanced and equitably distributed to project partners, including sub-awardees, commensurate with their role in the project, and whether funding is categorized into the proper budget categories providing clarity, accuracy, and granularity on the applicant’s planned use of the grant funds during the project period. (4 points)
• The cost effectiveness of the budget / project in terms of maximizing the share of funds used for the delivery of benefits to disadvantaged communities (both the direct costs of funds passed through for financial assistance as well as associated indirect costs to the greatest extent practicable). (4 points)
3.5 Compliance Plan (10 points): Applications will be evaluated based on the quality and extent to which the Compliance Plan addresses the elements for the Compliance Plan described in Section I.G.
D. Track II Application Review Process and Evaluation Criteria All eligible Track II applications will be evaluated, on a rolling basis, based on a 100-point scale using the criteria specified below.
Evaluation Criteria for Track II Applications
Track II applications will be evaluated using the criteria below on a 100-point scale.
Track II Evaluation Criteria
Section Possible Points
1. Program Objectives 35
2. Project Collaboration and Participation 20
3. Project Linkages 4
4. Budget 8
5. Environmental Results 6
54 6. CBO Experience & Commitment 5
7. Programmatic and Managerial Capability and Resources 16
8. Past Performance 6
TOTAL 100
1. T rack II Program Objectives (35 points): Applications will be evaluated based on the quality and extent to which they demonstrate:
• How the project(s) in the application address the Track II objectives identified in Section I.H. (10 points)
• The methods, tools, and trainings, the applicant will use to facilitate the engagement of disadvantaged communities in state and Federal advisory groups, workshops, rulemakings, and / or other public processes, including local, Tribal, and other governmental processes, related to environmental and climate justice. (10 points) • How the project(s) in the application address and improve the disadvantaged community’s lack of access to, or weak relationships with, governmental entities and changes those relationships to increase points of access for disadvantaged communities with government to work cooperatively to promote environmental and climate justice. (8 points) • Will result in governmental entities better understanding the root causes of environmental and climate justice issues that impact disadvantaged communities, so the communities are better prepared to proactively address them before the issues materialize. (7 points)
2. P
roject Collaboration and Participation (20 points) : Under this criterion, applications will be evaluated based on the quality and extent to which they:
• Demonstrate that meaningful input and feedback was considered from the disadvantaged community and other stakeholders in designing and developing the applications and how feedback / input will continue to be obtained and considered during grant performance. (10 points)
• Describe the facilitation and accountability measures to establish and maintain trust between the disadvantaged community and government officials to ensure the community can collaborate in a meaningful manner on environmental and climate justice issues with governmental bodies. (5 points)
• Demonstrate the applicant’s and Collaborating Entities relationships and history of collaborations with disadvantaged communities, governmental bodies, and other stakeholders to address environmental and environmental / climate justice issues. (5 points)
3. Project linkages (4 points): Applications will be evaluated based on the extent and quality to which the proposed project activities support and advance EPA Strategic Plan Goal 2 (Take Decisive Action to Advance Environmental Justice and Civil Rights), Objective 2.1, (Promote Environmental Justice and Civil Rights at the Federal, Tribal, State, and Local Levels).
4. Budget (8 points): Under this criterion, applicants will be evaluated based on:
55 • The reasonableness of the budget and allowability of the costs for each component / activity of the project and their approach, procedures, and controls for ensuring that awarded grant funds will be expended in a timely and efficient manner to comply with the statutory 3 - year project period limitation. (4 points)
• The cost effectiveness of the budget / project in terms of maximizing the share of funds used for the delivery of benefits to disadvantaged communities (both the direct costs of funds passed through for financial assistance as well as associated indirect costs to the greatest extent practicable). (4 points)
5. Environmental Results (6 points): Applications will be evaluated based on the quality and extent to which:
• They describe an effective plan, with associated timeframes, for tracking and measuring their progress in achieving the expected project outcomes and outputs for Track II applications including those identified in Appendix F. (2 points) • They demonstrate that the project can ensure sustainability of outcomes beyond the three- year grant period, and how they will leverage resources, community support, etc. to facilitate this. (2 points)
• The quality and specificity of the proposed outputs and outcomes, and how they will lead to the success of the grants, are described. (2 points)
6. CBO Experience and Commitment (5 points): The CBO(s) that are either the Lead Applicant and / or Statutory Partner for the grant will be evaluated based on their history and experience as a CBO and the depth of their commitment, connections, and relationships with the disadvantaged communities the application is intended to benefit.
7. Programmatic and Managerial Capability and Resources (16 points): The Lead Applicant and Statutory Partner will be evaluated based on their ability to successfully complete, oversee, and manage the award considering:
• Their organizational experience and capacity related to performing the proposed projects or similar activities (e.g., experience in managing projects and activities like those in the application). (4 points)
• Their r esources, capacity, capabilities, staff (e.g., project manager and other key personnel), expertise, and skills to perform and manage the award activities effectively during the three-year award period. For Lead Applicants submitting two applications under this NOFO, this includes how they demonstrate they have the above attributes to perform, manage, and oversee two awards effectively within the three-year award period. (4 points) • The milestone schedule for the proposed projects (up to three years) including the breakout of the project activities into phases and timeframes for completion of tasks, and the approach, procedures, and controls for ensuring that the award funds will be expended in a timely and efficient manner while ensuring that costs are eligible, reasonable, and allowable. (3 points)
• Their legal and financial controls in place, and capacity to manage taxpayer dollars ethically and efficiently as well as the policies and controls for project oversight and 56 program risk. This includes the extent and quality to which the application includes controls to identify waste, fraud, and abuse, and reduce the potential for waste, fraud, and abuse by including plans and policies for program oversight, including confidential reporting (e.g., whistleblower protections). (5 points)
8. Past Performance (6 points total): The Lead Applicant will be evaluated based on their ability to successfully complete and manage the proposed projects considering their:
• Past performance in successfully completing and managing the assistance agreements identified in response to Section IV. (3 points)
• History of meeting the reporting requirements under the assistance agreements identified in response to Section IV including whether the applicant submitted acceptable final technical reports under those agreements and the extent to which the applicant adequately and timely reported on their progress towards achieving the expected outputs and outcomes under those agreements and if such progress was not being made whether the applicant adequately reported why not. (3 points)
The focus of this criterion is on the Lead Applicant ’s past performance and not that of any other Collaborating Entities or contractors / consultants who may be assisting the applicant with performance of the project. In evaluating the Lead Applicant under these factors, EPA will consider the information provided in the application and may also consider relevant information from other sources, including information from EPA files and from current / prior grantors. If you do not have any relevant or available past performance related to federal or non-federal grants, you should state this explicitly in your application (e.g., our organization has no relevant past grants experience).
Including this statement will ensure you receive a neutral score for these factors (a neutral score is half of the total points available in a subset of possible points). Failure to include this statement may result in your receiving a score of 0 for these factors.
E. Final Selection Process and Other Factors
The Selection Official will make the final selection recommendations for Track I and II applications based on the evaluation criteria and process described above on a rolling basis. In addition, in making the final selection recommendations for award, the Selection Official may also consider any of the “other” factors below.
Further, as noted in Sections I.G and II.A, EPA anticipates making a minimum of fifteen awards for high-ranking applications that include a workforce training project(s) as described in Section I.G. In addition, as noted in Sections II.B and Appendix H, EPA anticipates making a minimum of five awards for high-ranking applications under the Target Investment Area A-Tribes in Alaska (projects benefitting Alaska Tribal lands) that include projects to assess and/or clean up lands conveyed under the Alaska Native Claims Settlement Act that were contaminated at the time of their conveyance from the federal government to an Alaska Native Corporation.
In making the final selection recommendations for award, the Selection Official may consider any of the following “other factors”:
1. Geographic d iversity to promote a mix of high -scoring applications benefitting disadvantaged communities located in urban, rural, or remote areas, different regions of the country, territories, as well as the geographical nature or impact of the project(s). 57 2. Program p riorities- how the application supports and advances EPA and OEJECR’s goals and priorities, including those in EPA’s Strategic Plan that focus on environmental climate and justice issues. This may also include considering how the application promotes Community Change Grant program objectives, the depth and extent of community involvement in project development and implementation, the extent and quality to which the project activities will provide impactful benefits to the residents of disadvantaged communities in the Project Area as defined in Appendix A rather than attenuated benefits spread out throughout a large Project Area, and the priority that the grants must be able to be successfully completed within three years to meet CAA § 138 statutory requirements.
3. Organizational diversity in terms of applicant type and size to ensure a broad representation of applicants receiving awards to improve program effectiveness and equity.
4. Whether the applicant is participating in a federal capacity building program as part of the Thriving Communities Network (please see complete list at Federal Interagency Thriving Communities Network or the Rural Partners Network).
5. Whether the projects support, advance, or complement funding related to Community Disaster Resilience Zones (CDRZs) as designated by FEMA.
6. The capacity and capabilities of Lead Applicants, who are selected for two awards under this NOFO, to successfully perform, manage, and oversee both grants within the three-year grant term and the risks posed by multiple awards to successful grant performance.
7. The extent to which the EPA funding may complement or be coordinated with other EPA funding or other Federal and / or non-Federal sources of funds / resources to leverage additional resources to contribute to the performance and success of the grant. This includes but is not limited to funds and other resources leveraged from businesses, labor organizations, non- profit organizations, education and training providers, and / or Federal, state, Tribal, and local governments, as appropriate.
8. Duplicate funding considerations as stated in Section IV of the EPA Solicitation Clauses incorporated by reference in this NOFO. This includes considering whether funding for the projects in the application is available under the Infrastructure Investments and Jobs Act (IIJA), other IRA programs, or other funding streams and if so the applicant’s reasons for seeking funding for these projects under this NOFO.
9. Consistent with the language in Section II.B and Appendix H for Target Investment Area A-Tribes in Alaska (projects benefitting Alaska Tribal lands), whether an application includes projects to assess and/or clean up lands conveyed under the Alaska Native Claims Settlement Act that were contaminated at the time of their conveyance from the federal government to an Alaska Native Corporation.
10. Availability of funds.
In addition, because the objectives of this NOFO are part of a government -wide effort to address environmental and climate justice concerns and challenges, information pertaining to proposed selection recommendations may be shared by EPA with other Federal, state, local, territorial, or Tribal governmental departments or agencies before final selections are made in order to determine whether potential selections under this NOFO: (1) are expected to be funded by another department or agency to minimize the possibility of duplicate funding, (2) could be affected by permitting, regulatory or other issues involving another department or agency, and / or (3) will complement or can be used to leverage funding and capacity-building by another department or agency to maximize value. Note that this process is separate from the Intergovernmental Review requirements in 40 CFR Part 29.
F. Anticipated Announcement and Federal Award Date
58 As stated in Section II.C, applications will be reviewed and selected on a rolling basis and may be submitted through November 21, 2024. EPA announced initial selection decisions for awards in July 2024 and expects initial awards being made in November 2024.
59 Section VI. Award Administration Information
(back to the Table of Contents)
Note: Additional provisions that apply to this section of the NOFO, including those related to responsibilities under civil rights laws, can be found in the EPA Solicitation Clauses.
A. Award Notification and Disputes
EPA anticipates that the first notification of selected applicants will be made via electronic mail in July 2024 and will continue to be done on a rolling basis. The notification will be sent to the original signer of the application, or the contact listed in the application. This notification, which informs the applicant that its application has been selected, is not an authorization to begin work. The official notification of an award will be made by the EPA Award Official. Applicants are cautioned that only a grants officer 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, readiness to perform projects, 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 a grants officer, is the authorizing document and will be provided through electronic mail. The successful applicant may be requested to prepare and submit additional documents and forms that must be approved by EPA before the grant can officially be awarded. The time between notification of selection and finalization of the award agreement can take up to 90 days or longer.
Assistance agreement competition -related disputes will be resolved in accordance with the dispute resolution procedures published in 70 FR (Federal Register) 3629, 3630 (January 26, 2005), which can be found at Grant Competition Dispute Resolution Procedures . Copies of these procedures may also be requested by contacting the person listed in Section VII of the announcement. Note, the FR notice references regulations at 40 CFR Parts 30 and 31 that have been superseded by regulations in 2 CFR Parts 200 and 1500. Notwithstanding the regulatory changes, the procedures for competition- related disputes remain unchanged from the procedures described at 70 FR 3629, 3630, as indicated in 2 CFR Part 1500, Subpart E.
Non-profit applicants that are recommended for funding under this announcement are subject to pre-award administrative capability reviews consistent with Section 8b, 8c, and 9d of EPA Order 5700.8: EPA's Policy on Assessing Capabilities of Non -Profit Applicants for Managing Assistance Awards . In addition, non- profit applicants selected for awards over $200,000 may be required to fill out and submit to the grants management office EPA Form 6600.09, United States Environmental Protection Agency Administrative Capability Questionnaire with supporting documents as required in EPA Order 5700.8.
Depending on the projects in the grant award, EPA will impose programmatic terms and conditions to ensure successful and timely grant performance. In addition, if applicants have any questions about whether a proposed project cost is eligible or allowable, they should contact EPA for clarification prior to application submittal.
B. Administrative and National Policy Requirements
Grantees will be subject to administrative and national policy requirements. Note that EPA plans to establish programmatic requirements in the terms and conditions of each grant agreement to implement these administrative and national policy, and other relevant, requirements, which will include but not be limited to: this award is subject to the requirements of the Uniform Administrative Requirements, Cost 60 Principles and Audit Requirements for Federal Awards; Title 2 CFR, Parts 200 and 1500. EPA also has programmatic regulations located in 40 CFR Chapter 1 Subchapter B.
A listing and description of general EPA regulations applicable to the award of assistance agreements is available on the EPA Policies and Guidance for Grants page.
Readiness to Perform Requirements: Following selection and before award, EPA may work with selected applicants to ensure that all approvals, requirements, permits, and permissions that are needed to begin performance will, if not already obtained or complied with, be resolved by the time of award, and if not generally within 120 days of award (unless extended by EPA). A term and condition may also state that EPA may terminate the award for the recipients’ failure to meet these requirements.
State / Territories Operation and Maintenance : Because of their unique roles, State and territorial governments may receive subawards to help implement specific project activities such as an infrastructure project in which they own the land or where they have governmental technical expertise and staf fing necessary to effectively implement activities of an infrastructure or other type of project. The terms of the EPA award will also require, if applicable, that state and territorial subrecipients commit to o peration and maintenance funding for any infrastructure constructed or improved on land they own with funding available under the NOFO.
Build America, Buy America Act (BABA): Certain projects under this NOFO may be subject to the Buy America domestic content sourcing requirements under the Build America, Buy America (BABA) provisions of the Infrastructure Investment and Jobs Act (IIJA) (P.L. 117- 58, §§ 70911-70917). These provisions apply when using Federal funds for the purchase of goods, products, and materials on any form of construction, alteration, maintenance, or repair of infrastructure in the United States. BABA requires that all iron, steel, manufactured products, and construction materials consumed in, incorporated into, or affixed to federally funded infrastructure projects must be produced in the United States. Please consider this information when preparing budget information and your application. The award recipient must implement these requirements in its procurements, and these requirements must flow down to all subawards and contracts at any tier. For more information, consult EPA’s Build America, Buy America website. When supported by rationale provided in the Infrastructure Investments and Jobs Act (IIJA) §70914, the recipient may submit a BABA waiver request to EPA. The recipient should request guidance on the submission instructions of an EPA waiver request from their EPA Project Officer. A list of approved EPA waivers is available on the BABA website. In addition to BABA requirements, all procurements under grants may be subject to the domestic preference provisions of 2 CFR §200.322.
Davis-Bacon and Related Acts (DBRA): The Davis-Bacon and Related Acts (42 U.S.C. §§ 3141-3144) set labor standards, including prevailing wages and fringe benefits, and apply to most federally funded contracts for construction of public works. The DBRA labor standards and reporting requirements apply to construction projects assisted with grants authorized by the CAA, including this program, as provided in CAA § 314 (42 U.S.C. § 7614).
16 A term and condition specifying DBRA compliance requirements will be included in the grant agreement.
Uniform Relocation Assistance and Real Property Acquisition Policies Act (URA): The URA applies to acquisitions of property and displacements of individuals and businesses that result from federally 16 EPA will use the definition of Construction in 40 CFR 33.103 to determine whether funding will be for a construction project. That definition defines Construction as “. . . erection, alteration, or repair (including dredging, excavating, and painting) of buildings, structures, or other improvements to real property, and activities in response to a release or a threat of a release of a hazardous substance into the environment, or activities to prevent the introduction of a hazardous substance into a water supply.” 61 assisted programs. The URA and Federal Highway Administration’s implementing regulations at 49 CFR Part 24 require grantees to follow certain procedures for acquiring property for grant purposes, such as notice, negotiation, and appraisal requirements. The statute and regulations also contain requirements for carrying out relocations of displaced persons and businesses, such as reimbursement requirements for moving expenses and standards for replacement housing. A term and condition specifying URA compliance requirements will be included in the grant agreement.
National Historic Preservation Act (NHPA) : Section 106 of the NHPA requires all federal agencies to consider the effects of their undertakings, including the act of awarding a grant agreement, on historic properties. If NHPA compliance is required, necessary Section 106 consultation activities, such as historic or architectural surveys, structural engineering analysis of buildings, p ublic meetings, and archival photographs, can be considered allowable and allocable grant costs. A term and condition specifying NHPA compliance requirements will be included in the grant agreement.
Note that Section 7(c) of the Energy Supply and Environmental Coordination Act of 1974 (15 U .S.C. § 793(c)(1)) exempts all actions under the CAA from the requirements of NEPA (National Environmental Policy Act). This Section states: “No action taken under the Clean Air Act shall be deemed a major Federal action significantly affecting the quality of the human environment within the meaning of the National Environmental Policy Act of 1969.” Therefore, as a grant program authorized under the CAA, NEPA will not apply to projects funded under the Community Change Grants.
Justice40 Reporting: The activities to be performed under the awards are expected to contribute to the President’s goal that 40% of overall benefits of certain federal investments flow to disadvantaged communities (the Justice40 Initiative. See Section I.A). Recipients, therefore, will be expected to report on certain metrics to demonstrate to what extent the activities contribute to the 40% goal. A term and condition specifying reporting of metrics demonstrating the extent to which the gran t’s activities advance this 40% goal will be included in each grant agreement.
Signage: The activities to be performed under the awards are expected to publicize that they were funded by the U.S. Environmental Protection Agency and the Inflation Reduction Act (e.g., via signs at the place(s) of performance. The award will include appropriate terms and conditions about signage requirements.
Environmental Justice Grant Applicant Database : The Community Change Grants program strives to support as many CBOs that apply regardless of their ultimate success in receiving a grant, by, as appropriate 1) familiarizing applicants with federal grant application requirements, 2) sharing expectations and responsibilities of managing federal grants, 3) providing constructive feedback and recommendations on ways to strengthen unselected applications, 4) helping organizations build sustainability into projects so they continue to grow and develop after the project period is over, and 5) facilitating connections with other potential resources that can help organizations address community needs. To facilitate the achievement of these, all applicants who apply under this NOFO will be added to our Environmental Justice Grant Applicant Database.
Reporting Requirements: Grantees will be subject to both program performance as well as financial and administrative reporting requirements, as described below. Note that EPA will only collect reporting information from the Lead Applicant (rather than from any subrecipients), but each Lead Applicant may need to collect reporting information from subrecipients (e.g., Collaborating Entities, Statutory Partners) to meet these reporting requirements.
Program Performance Reporting: In accordance with 2 CFR § 200.329, each grantee will be subject to program performance reporting requirements. Reporting requirements effective during the period of 62 performance will be established in the grant agreement’s terms and conditions, and reporting requirements effective after the period of performance will be established in a closeout agreement.
During the period of performance, EPA will require each grantee to submit quarterly performance reports within 30 days after the end of each reporting period (and with additional requirements every fourth quarterly report i.e., annually) as well as a final performance report within 90 days after the end of the period of performance. EPA will require that each grantees chief executive officer or equivalent review and submit each of these reports. EPA will use information from these reports as part of program -wide public reporting, except to the extent such information includes confidential business information (CBI) or personally identifiable information (PII) pursuant to 2 CFR § 200.338. 17 Included below is information that
EPA may require in these reports.
Financial and Administrative Reporting Requirements : Each grantee will be subject to financial and administrative reporting requirements, which will be included in the grant agreement's terms and conditions (EPA’s General Terms and Conditions). These requirements will include, but not be limited to:
• Federal Financial Report : In accordance with 2 CFR § 200.328 and 2 CFR § 200.344, each grantee must submit the Federal Financial Report (SF-425) at least annually and no more frequently than quarterly. The frequency of reporting and report submission instructions will be specified in the terms and conditions.
• Financial Records Retention: In accordance with 2 CFR § 200.334, each grantee will be required to retain financial records, supporting documents, statistical records, and all other non- Federal entity records pertinent to the grant award for a period of three years from the date of submission of the final expenditure report. Additional record retention requirements on program income used after the end of the period of performance will be specified in close-out agreements. • MBE / WBE Utilization: When required, each grantee must complete and submit a “MBE/WBE Utilization Under Federal Grants and Cooperative Agreements” report ( EPA Form 5700-52A) on an annual basis.
• Real Property Status Report: In accordance with 2 CFR § 200.329, each grantee must submit a “Real Property Status Report” (SF-429) to report real property status or request agency instructions on real property that was / will be provided as Government Furnished Property (GFP) or acquired (i.e., purchased or constructed) in whole or in part under a federal financial assistance award.
C. Audit Requirements
In accordance with 2 CFR § 200.501(a), each grantee will be required to obtain a single audit from an independent auditor, if the grantee expends $750,000 or more in total federal funds in the grantee’s fiscal year. Audits will be made public in accordance with the process described in 2 CFR § 200.512. The grantee must submit the form SF -SAC and a Single Audit Report Package within 9 months of the end of the grantee’s fiscal year or 30 days after receiving the report from an independent auditor. The SF-SAC and a Single Audit Report Package MUST be submitted using the Federal Audit Clearinghouse’s Internet Data Entry System. In addition, each grantee may be subject to additional audit requirements, including but not limited to compliance requirements as part of any compliance supplement to the single audit.
D. Remedies for Non-Compliance
17 Information claimed as CBI in accordance with this Notice will be disclosed only to the extent, and by means of the procedures, set forth in 40 CFR Part 2, Subpart B.
63 In accordance with 2 CFR § 200.208, 2 CFR § 200.339, and 2 CFR § 200.340, EPA is provided authority for multiple potential responses if a grantee violates the terms of the grant agreement.
E. Program Administration Activities
Under 2 CFR § 200.403 and other applicable provisions of 2 CFR Part 200, Subpart E, costs are allowable under federal awards so long as they are necessary and reasonable for the performance of the grant award.
Under this NOFO, consistent with these regulations, program administration activities are allowable costs, with such activities supporting administration of the grant program. Program administration activities include (but are not limited to) conducting due diligence and underwriting financial transactions; establishing and convening advisory councils; conducting program performance and other reporting activities (e.g., expenditures for personnel and equipment to procure technology infrastructure and expertise for data analysis, performance, and evaluation); and supporting, monitoring, overseeing, and auditing subrecipients, contractors, and program beneficiaries.
F. Fraud, Waste, and Abuse Awareness
Recipients of awards under this NOFO need to be alert and sensitive to indicators of fraud, waste, and abuse regarding the use of federal funds under the award. Fraud generally is a false representation about a material fact and can be any intentional deception designed to unlawfully deprive the United States or the EPA of something of value or to secure for an individual a benefit, privilege, allowance, or consideration to which he or she is not entitled. Waste generally involves the taxpayers not receiving a reasonable value for money in connection with any government-funded activities due to an inappropriate act or omission. Most waste does not involve a violation of law; rather, waste relates primarily to mismanagement, inappropriate actions, and inadequate oversight. Abuse generally involves behavior that is deficient or improper when compared with behavior that a prudent person would consider reasonable and necessary business practice given the facts and circumstances. Abuse may also include misuse of a uthority or position for personal financial interests of those of an immediate or close family member or business associate. Abuse does not necessarily involve fraud or violation of always, regulations or grant provisions. Indicators of fraud, waste, and abuse can be found on the EPA Office of Inspector General website. Recipients should report any suspected fraud, waste, and / or abuse to the EPA Project Officer for the award or the EPA Office of Inspector General. Note that EPA Project Officers will refer matters to the EPA Office of Inspector General as appropriate.
G. Quality Management Plans (QMPs) & Quality Assurance Project Plans (QAPPs) Quality assurance documentation is required for awards that involve environmental information operations.
EPA Project Officers will work with all selected recipients on quality assurance (QA) requirements. Once the award is made, if a QMP and / or QAPP is required for the project, the applicant will develop the document and submit for EPA’s approval. Selected applicants cannot begin environmental information operations until EPA approves the QMP and / or QAPP.
Environmental Information Operations: A collective term that encompasses the collection, production, evaluation, or use of environmental information and the design, construction, operation, or application of environmental technology. Environmental information includes data and information tha t describe environmental processes or conditions. Examples include but are not limited to: direct measurements of environmental parameters or processes, analytical testing results of environmental conditions (e.g., geophysical, or hydrological conditions), information on physical parameters or processes collected using environmental technologies, calculations or analyses of environmental information, information provided by models, information compiled or obtained from databases, software applications, decision support tools, 64 websites, existing literature, and other sources, and development of environmental software, tools, models, methods, and applications.
Quality Management Plan (QMP) : The recipient may need to develop a QMP. The QMP describes an organization’s Quality Program. Requirements for QMPs are found in the most recent version of EPA’s Quality Management Standard. A QMP documents the technical activities to be performed and how the program will integrate QA, quality control, QAPPs, training, etc., into all its environmental information operations.
Quality Assurance Project Plans (QAPP) : The recipient may need to develop a QAPP(s). A QAPP describes how environmental information operations are planned, implemented, documented, and assessed during the life cycle of a project. Requirements for QAPPs are found in the most recent version of EPA’s Quality Assurance Project Plan Requirements / Standard Quality Assurance Project Plans (QAPP). Quality assurance is sometimes applicable to assistance projects (see 2 CFR 1500.12). Quality assurance requirements apply to the collection of environmental data. Environmental (data are any measurements or information that describe environmental processes, location, or conditions; ecological or health effects and consequences; or the performance of environmental technology. Environmental data include information collected directly from measurements, produced from models, and compiled from other sources, such as databases or literature. Once the award is made, if a Quality Assurance Project Plan is required for the project, the applicant will have to draft a QAPP prior to beginning work on the project. You must reserve time and financial resources in the beginning of your project to prepare your QAPP and include the cost for developing your QAPP in your Detailed Budget. Selected applicants cannot begin data collection until EPA approves the QAPP.
65 Section VII. Contact Information
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For information or questions about this NOFO, please email: [email protected] 66 Appendix A. Definition of Disadvantaged Communities and Mapping Requirements
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Applicants must demonstrate that the projects in their application would benefit a disadvantaged community. EPA is defining a disadvantaged community as one that meets at least one of the following criteria:
1. A geographically defined community designated as disadvantaged by the EPA Disadvantaged Community Environmental and Climate Justice Program Map , which includes the following components:
a. EPA IRA Disadvantaged Communities 1.0 map
b. EPA IRA Disadvantaged Communities 2.0 map
c. Any area of American Samoa, Guam, the Commonwealth of the Northern Mariana Islands, or the U.S. Virgin Islands.
2. A community that falls into one of the following two categories:
a. A farmworker community comprised of individuals with no fixed work address, who travel from their permanent residence to work in agriculture on a temporary or seasonal basis and may relocate several times throughout the year. Applicants can demonstrate that a farmworker community is comprised of such individuals by submitting verification documentation from an authorizing governmental entity or through comparable means. b. A Disadvantaged Unincorporated Community (DUC). For purposes of this NOFO, DUCs are generally defined as Census Designated Places
19 that lack fixed legally determined
geographic boundaries and have certain common characteristics and conditions (e.g., the absence of adequate potable permanent water, adequate sewage systems, or acceptable housing). For example, all areas defined as Colonias by the U.S. Department of Housing and Urban Development (HUD) ,20 and Colonias that are not defined by HUD but are identifiable on the “Colonias” layer in EJScreen, are considered DUCs for purposes of this NOFO. In other cases, DUC status can be demonstrated through submitting localized data that represent similar characteristics. Applicants who seek funding for projects benefitting DUCs need to explain in their Project Narrative (e.g., in the Executive Summary) that the projects will either benefit Colonias as defined above or show how the projects otherwise meet the DUC criteria listed above, including demonstrating how the area to be benefitted is both unincorporated and shares “common characteristics and conditions” with DUCs as described above.
Project Area and Project Area Map for Track I Applications Track I Applications
For Track I applications to benefit geographically defined communities identified as disadvantaged communities on the EPA Disadvantaged Community Environmental and Climate Justice Program Map, 19 Census Designated Places (CDPs) are statistical equivalents of incorporated places and represent unincorporated communities that do not have a legally defined boundary or an active, functioning governmental structure. 20 Colonias History – HUD Exchange.
67 applicants must identify the specific census block groups designated as disadvantaged communities that the projects and supporting activities will benefit by submitting to EPA one contiguous Project Area Map with an outlined boundary as instructed below. Applicants should note that while they can determine the Project Area for their projects consistent with the instructions in Appendix A and the other relevant parts of the NOFO, concentrated and compact Project Areas may maximize benefits to the residents of the census block groups designated as disadvantaged communities in the Project Area. Activities spread across large Project Areas may be more dispersed and less impactful to the residents of the census block groups designated as disadvantaged communities in the Project Area.
The Project Area Map should also reflect where each project submitted under the application is located within the Project Area. The Project Area may include multiple census block groups that are designated as a disadvantaged community by EPA as defined above, but the disadvantaged census block groups need not be fully contiguous with each other.
For Track 1 applications addressing farmworker communities or DUCs as defined above, applicants must submit a Project Area Map specifying where the communities and projects designed to benefit them are located. Applications addressing these communities are not required to submit a map showing census block groups designated as disadvantaged.
21 All projects and activities should be located within the Project Area, except in cases where the project is located outside of the Project Area to address the localized pollution (or other) issue at the source, or where otherwise necessary to ensure and/o r facilitate that disadvantaged communities as defined above will benefit from the project. One such example is if the project addresses water quality issues upstream to benefit a downstream disadvantaged community. While projects and activities may have an incidental benefit to census block groups (or other areas) that are not considered disadvantaged communities, the applicant must demonstrate that the projects’ primary benefits will flow to disadvantaged communities in the Project Area.
Applicants may submit a map generated in EPA’s EJScreen tool. Applicants also have the option to submit a map in another geospatial format such as a shapefile (.shp), geodatabase (.gbd), or map service.
The submitted Project Area Map should include the following:
a. The Project Area with an outlined boundary.
b. The disadvantaged communities intended to benefit from the projects as identified on the EPA Disadvantaged Community Environmental and Climate Justice Program Map. c. Main streets, landmarks, community assets (e.g., parks or play areas, schools, community centers), and/or any other attributes that may provide important context about the Project Area. d. Jurisdictional boundaries, including incorporated and unincorporated areas.
Note: While Track II applications are not required to submit a Project Area Map, they must still use the EPA Disadvantaged Community Environmental and Climate Justice Program Map layer in EJScreen to describe and identify in their application (e.g., Executive Summary) the disadvantaged communities as defined above that will benefit from the projects as required by Section III.D. 21 However, applicants are encouraged to indicate in the relevant portion of the Executive Summary whether projects benefitting DUCs or farmworkers would also benefit areas identified as disadvantaged as described in #1. 68 EPA’s Disadvantaged Community Environmental and Climate Justice Program Map Availability Within EJScreen, the EPA Disadvantaged Community Environmental and Climate Justice Program Map can be found in the “Places” tab by clicking the “Designated Disadvantaged Communities” category and then “EPA IRA Disadvantaged Communities. Please note, applicants must turn on the layer in the legend on the right of the screen. See screenshot below.
Please see the video that EPA’s technical assistance contractor prepared that may be useful in helping to create a Project Area Map.
If you would like the data products and technical document associated with this map layer, please visit:
Inflation Reduction Act Disadvantaged Communities Map.
69 Appendix B. Partnership Agreement between the Lead Applicant and Statutory Partner
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To be eligible for funding, the Lead Applicant must include in the application a copy of a written and signed Partnership Agreement with the Statutory Partner that is legally binding . At a minimum, t he Partnership Agreement must specify the following:
• Who will be the Lead Applicant and the Statutory Partner. • The Lead Applicant is responsible for the overall management, performance, oversight, and reporting responsibilities under the grant, and for making subawards to Collaborating Entities. • The Lead Applicant will be responsible for the receipt of federal funds from EPA and the proper expenditure of these funds and will bear liability for unallowable costs. • The roles and responsibilities of the Lead and Statutory Partner for project activities and how disputes between them will be handled and resolved. Please note that EPA is not a party to the Partnership Agreement, and any disputes between the parties must be resolved under the law applicable to the Partnership Agreement.
• The Lead Applicant is responsible for compliance and legal issues, and managing risks associated with the project. It must also describe the procedures for replacing a Statutory Partner with another Statutory Partner , and for ensuring the replacement has the comparable expertise, experience, knowledge, and qualifications of the replaced Statutory Partner to ensure successful grant completion within 3 years. Replacement may be necessary for various reasons including performance issues. Note that replacement requires prior approval by an authorized EPA official pursuant to 2 CFR 200.308(c)6).
• The Lead Applicant and Statutory Partner’s agreement, if the proposed application is selected for award, to enter a subaward that complies with the subaward requirements in the grant regulations at 2 CFR 200.331 and in EPA’s Subaward Policy and related guidance and that contains terms and conditions including those above.
70 Appendix C. Climate Action Strategies and Associated Project Activities (back to the Table of Contents)
Eligible project activities associated with each Climate Action Strategy identified in Section I.G. of the NOFO could include but are not limited to the following examples. Applicants may propose different activities as long as they are consistent with the applicable Climate Action Strategy as described in Section I.G of the NOFO and are eligible for funding under section 138(b)(2) of the Clean Air Act.
Strategy 1: Green Infrastructure and Nature-based Solutions Examples:
• Building climate resilience and carbon sequestration through tree planting o Mitigate urban heat islands through reflective surfaces and shade trees or other vegetation, including preparing planting sites and establishing and caring for trees and other vegetation.
o Plant trees in public spaces.
o Plant trees in sites that are strategically selected to shade buildings (i.e., planted within 60 feet of a building).
• Multi-benefit stormwater projects
o Construct permeable surfaces, collection basins, rain gardens, bioswales and other green infrastructure.
o Restore and / or protect wetlands.
o Improve urban forest site(s) to create new or more functional planting locations for trees and other vegetation, such as bioswales, which contribute to:
Greening to protect and conserve community lands and water; Watershed protection that supports sensitive wildlife habitat and enhances water access.; and / or
Replacement of concrete or pavement and restoring spaces to more natural conditions to restore water to the community, reduce flooding, and improve public greenspace.
• Public parks and open spaces
o Create new parks or enhance / expand existing parks to provide climate resilience benefits like heat island reduction and flood mitigation or other demonstrable environmental benefits.
o Green existing schoolyards to protect vulnerable populations by adding nature -based solutions.
Strategy 2: Mobility and Transportation Options for Preventing Air Pollution and Improving Public Health and Climate Resilience
Examples:
• Construct new, expanded, or enhanced bikeways, walkways, or non- motorized urban trails that reduce vehicle miles traveled and related air pollution by providing safe routes for zero-emission travel between residences, workplaces, commercial and community centers, and schools. • Implement “ Complete Streets ” projects to improve walkability, bike -ability, and transit use, including improved access for people with disabilities. projects to improve walkability, bike - ability, and transit use, including improved access for people with disabilities that reduce vehicle miles traveled and related air pollution.
71 • Implement climate resilience measures on bikeways or trailways such as raising the elevation or installing permeable pavers to reduce flooding or increasing shade coverage to mitigate extreme heat.
• Conduct the measurement, analysis, design, planning and engineering work necessary to submit a competitive application for state and / or federal funding that will fund large-scale improvements (larger than this competition is able to fund) to significantly reduce a community’s Greenhouse Gas (GHG) emissions and / or improve climate resilience.
• Purchase, lease, or contract for the use of zero -emission vehicles for community car sharing, vanpooling, ride-sharing, and related mobility options. • Purchase, construct, and / or install infrastructure, equipment, or facilities to create and / or support low or zero-emission transportation options.
Guidelines:
• Transportation projects that involve public transit or improvements to public property should include a governmental agency as a Collaborating Entity that will help perform and oversee the project.
Strategy 3: Energy-Efficient, Healthy, Resilient Housing and Buildings Examples:
• Install energy efficiency measures such as insulation, double or triple glazed windows, “cool roofs” that reflect sunlight, and energy management systems in public buildings. • Install ventilation systems to help improve indoor air quality during pollution-related events such as wildfires.
• Install or retrofit homes or multi- family housing with higher -efficiency electric heating, cooling, and cooking systems (e.g., heat pumps, heat pump water heaters, electric and induction stoves, electric clothes dryers).
• Reduce heat island effects by installing cool roofs on homes, multi -family housing, or public buildings.
• Implement other similar projects qualified under HUD’s Green and Resilient Retrofit Program (GRRP). Note that applicants who have received or will receive HUD funding under this program must have internal controls in place to ensure that the same costs are not charged to more than one Federal grant.
26 Guidelines:
• In their Project Narrative, applicants should describe how low-income residents will directly benefit from the project through lower costs and how resident s will be trained on how to operate and maintain new technology and equipment, where applicable. • For projects that will fund home or multi-family housing improvements, applicants should include details of their target tenants or homeowners, such as with those incomes at or below the greater of:
o For Metropolitan Areas: (1) 80% Area Median Income (AMI) and (2) 200% of the Federal Poverty Level
26 Refer to 2 CFR 200.403(f).
72 o For Non-Metropolitan Areas: (1) 80% AMI; (2) 80% Statewide Nonmetropolitan Area AMI; and (3) 200% of the Federal Poverty Level
• Applicants may also target community housing (e.g., land bank, housing conservancy, cooperative, or other community-based nonprofit) or public housing for this strategy. • Applicants should refer to the description of the Community Strength Plan in the NOFO, particularly the need to minimize the risks associated with displacing current residents due to EPA- funded investments for this strategy.
Strategy 4: Microgrid Installation for Community Energy Resilience Examples:
• Construct microgrid infrastructure.
• Install microgrids with onsite renewable energy generation and storage. • Install ancillary energy infrastructure necessary to support microgrids. • Install other energy infrastructure for microgrid operations.
Guidelines:
• The application should include details that demonstrate the extent to which the microgrid will serve the target community, such as: that the microgrid will be used to ensure that reliable power is provided for any community- serving buildings or critical facilities during extreme weather emergencies or any weather- related outages; that the community lacks an external grid, and the microgrid will be used to meet local energy consumption needs during normal or “blue sky” conditions; or where an external grid i s available, that the microgrid will be capable of interconnecting with that grid to meet peak energy consumption demands and increase grid reliability.
Strategy 5: Community Resilience Hubs
Examples:
• Assess the most acute climate risks facing a community (e.g., extreme heat, flooding, wildfire), identify where the community has gaps in its resilience strategy, then design a plan to mitigate specific risks by creating or upgrading community facilities to serve as resilience hubs that remain operable during an emergency.
• Purchase and install backup power equipment such as generators or onsite solar and storage at one or more resilience hubs.
• Implement structural and non-structural retrofits to enhance the resilience of the hub (e.g., raise the building elevation to reduce flood risk, improve cooling systems and / or insulation to reduce extreme heat risk).
• Implement wildfire mitigation measures such as retrofitting the hub to reduce flammability, creating a defensible space between the hub and its surrounding environment, and installing air filtration equipment to reduce the risks of smoke inhalation. • Purchase and install communications devices that can operate even with loss of local power and telecommunications systems.
Guidelines:
• The resilience hubs should be operable during an emergency. Applicants are encouraged to develop plans that will help ensure the facility is operable, including an emergency communications plan, 73 plan for backup power during emergencies, and agreements and processes for activating the facility in the event of an emergency.
• The community resilience hub should be a community -convening space that provides climate resilience and related resources and services to community residents. • Applicants should demonstrate how they will work with relevant emergency response organizations to maximize the efficacy and use of the resilience hub.
Strategy 6: Brownfields Redevelopment
Examples:
• Build and / or upgrade existing structures and sites to improve community use while reducing GHG emissions and / or improving climate resilience.
• Implement greening efforts (tree-planting, park construction or renovations , community garden developments, etc.) that mitigate GHG emissions and / or improve climate resilience. • Install low or zero emission energy infrastructure such as solar and storage. • Conduct deconstruction and green demolition activities to support adaptive reuse or new construction. Applicants can r efer to EPA’s Climate Smart Brownfields Manual for information about green demolition activities.
• Acquire land to enable a brownfield redevelopment that has emissions mitigation and / or climate resilience benefits.
Guidelines:
• Redevelopment sites eligible for funding must be consistent with the federal definition of a Brownfield site in 42 U.S.C. 9601(39) as follows: a brownfield is a property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant.
• Projects for adaptive reuse should explore and can leverage national and state historic preservation tax credits to maximize funding streams.
27 • In order for a Brownfields Redevelopment project to be eligible, the applicant must demonstrate at time of application submission that all cleanup activities have been completed at the site and / or that cleanup activities are not necessary at the site for the intended use or reuse. This can be demonstrated by, for example, one of the following:
o A completed Phase I Environmental Site Assessment with no recognized environmental conditions (RECs) at actionable levels;
o A completed Phase II Environmental Site Assessment with sampling result levels below actionable levels;
o Lead or asbestos building survey or equivalent environmental or building investigation to determine no likely sources of contamination or hazardous materials will be encountered on site that pose risks to the adjacent community or occupational health and safety risks to workers; or
o No Further Action letter from the state or Tribal Brownfields response program. 27 See guidelines for Tax Incentives for Preserving Historic Properties. 74 Strategy 7: Waste Reduction and Management to Support a Circular Economy28 Examples:
• Implement a community-scale composting program to reduce emissions from food waste that includes an educational campaign to inform Project Area residents about climate benefits of reducing food waste.
• Implement a community-scale recycling program.
• Reduce emissions from food waste by implementing programs that distribute unused food to project area residents.
Guidelines:
• Where relevant, applicants should demonstrate that all inedible food scraps derived from projects are composted, and that other materials are diverted from landfills and support a circular economy. • Where relevant, project activities should demonstrate how they are using EPA best practices related to the circular economy or other sources of guidance.29 Resources include the Planning for Natural Disaster Debris guidance and Sustainable and Resilient Communities Through Solid Waste Investments and Best Practices After Disasters.
• Applicants should consider EPA's ranking of wasted food management pathways and EPA Waste Management hierarchy for sustainable materials management.
Strategy 8: Workforce Development Programs for Occupations that Reduce GHG Emissions and Air Pollutants
This strategy allows applicants to propose workforce development programs that will help reduce GHG emissions and other air pollutants to benefit disadvantaged communities.
This strategy allows applicants to propose workforce development programs for employment in fields that will help reduce GHG emissions and other air pollutants to benefit disadvantaged communities. A wide range of occupations support the reduction of GHG emissions and air pollutants. Because EPA cannot provide an exhaustive list of such occupations, applicants should describe how their workforce development program will support the reduction of GHG emissions or other air pollutants.
Examples of career pathways that may be part of a workforce development program include but are not limited to: electricians, steamfitters, pipefitters, laborers, and other skilled trades occupations that support building electrification, renewable energy projects, and other similar activities; occupations related to the manufacturing of low- and zero-emission technologies; careers in low- and zero-emissions transportation such as vehicle mechanics supporting electric vehicle technologies; community health and outreach workers that assist households in reducing their emissions and addressing sources of pollution; and other careers related to emissions reduction, such as methane mitigation or agricultural carbon mitigation.
Applicants should describe how their workforce development program will support the reduction of GHG emissions or other air pollutants.
Guidelines:
28 A circular economy is generally described as a model of production and consumption, which involves sharing, leasing, reusing, repairing, refurbishing, and recycling materials and products as long as possible and based on three main principles: eliminate waste and pollution, circulate products and materials, and regenerate nature. 29 Refer to EPA’s guidance on the Circular Economy | US EPA 75 As noted in Section I.G of the NOFO, strong workforce development programs should include the following three features at a minimum:
1. Multi -sectoral partnerships that bring together workforce expertise and enable pathways into high-quality careers.
The foundation of a strong workforce development initiative is a set of partners that represent diverse expertise, community and worker voice, and employer needs. For these programs, applicants may collaborate with organizations with workforce development expertise, such as labor unions, tradeswomen organizations, local workforce development boards (locate yours using this U.S. Department of Labor search tool), career and technical schools, community colleges, workforce development nonprofits, and other similar organizations.
Examples of the types of expertise and experience that are important for a successful workforce development program include, but are not limited to:
• Technical skills and experience to lead classroom and on -the-job training, including equipping students and individuals with the skills needed to succeed and be safe on the job, including knowledge of new and emerging greenhouse gas and other air emissions-reduction technologies; • Knowledge of the local, State, and regional labor market and relevant relationships to have a deep understanding of employer hiring, staffing, and skilling needs, emerging trends especially related to the clean energy transition, and considerations for local job quality and worker voice; • Strong awareness of the barriers individuals in the community face to training and employment, including an understanding of unique barriers specific populations face, and clear strategies for how to address those barriers; and
• Established relationships of trust within the community, including knowledge of relevant history and community dynamics, in addition to meaningful, long- lasting relationships in the community that will support trainee recruitment and participation.
2. High-quality training models that are worker-centered, demand-driven, and lead to good jobs.
Workforce development projects should be focused on training individuals for high- quality, long-term career pathways in family-sustaining jobs, rather than short-term or temporary, low-wage jobs. Applications should demonstrate that the workforce development project fulfills an industry demand in the Project Area and surrounding region, is informed and supported by employers, and has a clear pathway to long- term employment with family -sustaining wages. This will be key to delivering programs that enable tru e economic mobility for individuals in disadvantaged communities and bolster the capacity of communities to respond to environmental justice concerns in a sustained fashion.
Examples of high-quality, evidence -backed training models are: Apprenticeship readiness programs (or “pre-apprenticeships”) with a connection to one or more Registered Apprenticeship Programs; Registered Apprenticeship Programs (registered via the U.S. Department of Labor (DOL) Office of Apprenticeship or State Apprenticeship Agency); Joint Labor-Management Training Programs; paid internships; partnerships with community colleges or vocational schools that award an industry- recognized credential; and similar models that combine on -the-job learning, classroom learning, and mentorship. DOL has a resource on “high-road training programs” that applicants are invited to review here.
Workforce development programs can serve adult or youth populations. Applicants may consider high- quality youth-serving training models, including: pre-apprenticeship programs that prepare young people to enter Registered Apprenticeship Programs; career and technical education programs (as described by the 76 U.S. Department of Education); and other similar models. Please note that applicants may propose programs to be included in the American Climate Corps (ACC), which is a federal government initiative focused on training young people for high-demand skills for jobs in the clean energy economy. To qualify as an ACC program, the program must provide youth with at least 300 hours of paid skills- based training and / or service. Applicants submitting a workforce development project to be considered for the ACC should note that in their application.
3. Strategies for recruiting and retaining individuals from disadvantaged communities, especially for populations that face disproportionate barriers to employment.
It is a statutory requirement (section 138(b)(1) of the Clean Air Act) for this program to benefit disadvantaged communities . These benefits may include providing opportunities to individuals with barriers to training and / or employment, so they can find long-term employment and economic opportunity in fields associated with air pollutants and GHG reduction. Projects should be designed with comprehensive research and evidence- based strategies for addressing barriers to recruitment, training, employment, an d retention. Examples include supportive services to meet the needs of the disadvantaged community, such as childcare and transportation assistance; life skills and basic skills training, such as financial literacy and job readiness, to prepare for a career related to GHG and air pollutant reduction; career services, such as developing individualized em ployment plans; peer -to-peer mentorship programs to connect experienced workers with new workers to help them learn the job and find a sense of belonging in the workplace; reasonable accommodations consistent with federal equal employment opportunity laws ; coaching to support work-based learning; and case workers to support workers with barriers to employment.
Applicants proposing a workforce development project are encouraged to describe the following elements and any additional details identified by the applicant:
• Design of the program, including if the applicant is proposing a high-quality, evidence-backed training model as described above, and a description of the credential(s) the participants will earn. • Duration of the program and program components, such as time spent in classroom and on-the-job training. Applicants are encouraged to also describe ongoing support participants will receive once they exit the training program and connect to full-time employment to support retention. • How applicants will engage employers and how the program will connect to high -quality jobs.
Applicants can review the federal Good Jobs Principles here. • Estimated number of participants that will be trained in the program. • Plan for how the program will recruit participants and how the program will build visibility and trust among residents of the Project Area.
• Curriculum the program will use and how it is informed by industry standards and employer demand.
• Wages or stipends for the duration of the program. Applicants are strongly encouraged to provide reasonable compensation for time spent in training to increase participation and retention. • Strategies the program will use to meet the needs of populations that experience barriers to training and employment.
• Applicant’s approach to administering supportive services to mitigate barriers to training and employment.
• Indicators the program will use to evaluate success as well as the methodology the program will use to track the progress of participants during and after the program. Applicants may review the Six Primary Indicators of Performance used by the public workforce system, as described by the Department of Labor here.
77 Appendix D. Pollution Reduction Strategies and Associated Project Activities
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Eligible project activities associated with each Pollution Reduction Strategy could include but are not limited to the following examples. Applicants may propose different activities as long as the activities are consistent with the applicable Pollution Reduction Strategy described in Section I.G of the NOFO and are eligible for funding under section 138(b)(2) of the Clean Air Act.
Strategy 1: Indoor Air Quality and Community Health Improvements Examples:
• Remediate or mitigate harmful substances in buildings, including lead, mercury, pesticides, radon, mold, PCBs (caulk, flooring, etc.), lead-based paint, asbestos, and other toxic substances.30 • Install, upgrade, or replace HVAC and / or filtration systems that improve indoor quality in schools, community-serving buildings, and single-and-multifamily homes. These upgrades may be done in conjunction with climate strategies that reduce building GHG emissions. • Equip community centers and community buildings in agricultural worker communities with decontamination stations (e.g., publicly available shower and laundry stations) to eliminate take - home pesticide exposures.
• Purchase equipment that can enable “do-it-yourself” upgrades using research-based methods, to distribute within communities impacted by smoke.
• Replace wood heaters that do not meet EPA’s New Source Performance Standards with more efficient, cleaner heaters certified by EPA, and independently verified to meet (or to have emissions below) the most stringent Step 2 emission reduction standards described in Standards of Performance for New Residential Wood Heaters, New Residential Hydronic Heaters, and Forced- Air Furnaces heaters.
Strategy 2: Outdoor Air Quality and Community Health Improvements Examples:
• Reduce exposure from mobile and stationary sources by:
o developing or expanding vegetative barriers.
o creating alternate truck route programs to decrease impacts to sensitive communities. o providing grants, rebates, or subsidies for households, small businesses, public partners, and community organizations to replace portable diesel equipment such as leaf blowers and lawn mowers with zero-emission alternatives.
o retrofitting spray booths in local small businesses to reduce VOC contamination from auto body painters.
o providing grants, rebates, or subsidies for backup battery systems to replace diesel backup generators in homes, public facilities, or small businesses. • Create clean air zones or low-emission zones such as:
30 The prohibition on using Community Change Grant funding to remediate Brownfields sites does not apply to this activity.
78 o Encouraging “last-mile” delivery through electric delivery vehicles (e.g., trucks, vans, cargo bikes).
o Electrifying local government -owned fleets providing services to communities (e.g., sanitation trucks, public buses).
o Implementing urban designs that promote air flow and reduce the concentration of pollution along street corridors (e.g., remove or reduce costly parking mandates, reduce idling of diesel vehicles).
• Implement s ustainable construction practices such as minimiz ing dust and emissions during building projects (e.g., electrify equipment, cover construction sites, utilize water sprays, properly manage waste).
• Replace toxic play surfaces that emit harmful pollutants (e.g., tire crumb and certain turfs at schools, community playgrounds, and fields ) with non-toxic, permeable options to provide safe places for children to play.
• Develop other policies that promote reductions in air pollution from transportation such as land use and zoning policies that enable households to live in affordable, dense, and vibrant communities within urban and rural areas.
Guidelines:
• Communities seeking funding for zero-emission school buses should encourage their local school district apply to EPA’s $5 billion Clean School Bus program.
Strategy 3: Clean Water Infrastructure to Reduce Pollution Exposure and Increase Overall System Resilience
Examples:
• Perform targeted infrastructure upgrades such as:
o Replacing private-side lead lines in a home, childcare facility, school, or other community- serving building during full lead service line replacement 31 o Septic to sewer conversions that connect homes to nearby community water systems. o Installing working water fountains at schools and parks where there are no fountains or they are inoperable, malfunctioning, or contaminated.
o Installing water conservation and efficiency technologies that will allow utilities to better monitor and reduce energy consumption onsite.
o Installing water reuse technologies that allow for system decreases in both energy and water use efficiencies through water capture, loss prevention, and closed loop approaches. • Prepare and apply for state and / or federal water infrastructure funding to address larger community needs (e.g., a leak detection and pipe replacement plan, a PFAS action plan, or upgrades to water and wastewater treatment facilities that reduce pollution) by:
o Assessing the problem through water sampling and monitoring. o Developing a plan, which could include the necessary design and engineering work. o Preparing an application for federal funding to one of several sources such as to EPA’s State Revolving Loan funds.
• Provide emergency interventions such as:
31 EPA’s Drinking Water Regulations for Lead. Lead Service Lines . Strategies to Achieve Full Lead Service Line Replacement.
79 o providing recurring point -of-use filters while communities await lead service line replacement.
o providing alternate water supplies for communities and buildings that have contaminated water (PFAS, lead, PCBs, arsenic, nitrates, etc.) in communities with contaminated water systems.
o adopting facility procedures or system upgrades that allow for service flexibilities, mobility, and continuity in the event of an emergency due to climate-related disaster events.
Guidelines:
• The projects should also include a public outreach / education campaign on safe drinking water and / or wastewater, working with the public water system where possible.32 33 • Activities should be coordinated with the EPA funded Environmental Finance Centers to minimize duplication of effort.
Strategy 4: Safe Management and Disposal of Solid and Hazardous Waste Examples:
• Purchase equipment for hazardous waste sampling to determine classification. • Collect, process, recycle, or otherwise dispose of household hazardous waste and electronics programs and infrastructure.
• Conduct compliance oversight for the collection, processing, recycling, storage and disposition of household hazardous waste and electronics.
• Develop or expand hazardous waste collection, recycling, and safe recycling programs and infrastructure.
• Develop or expand safe disposal technologies for hazardous waste. • Reduce demand for single-use plastic products (by installing public water bottle refill stations and water fountains or implementing community and city -scale water reuse and refill systems) and phasing out single-use products that may be unnecessary. 32 EPA on Reducing Lead in Drinking Water. EPA Communication Plan 3Ts. Basic Information about Your Drinking Water.
33 Drinking Water Analytical Methods.
80 Appendix E. Job Quality & Equitable Employment Opportunities (back to the Table of Contents)
It is a priority of the EPA that this grant program supports high- quality, family-sustaining, community- strengthening jobs with the free and fair choice to join a union, consistent with Executive Order 14082, Implementation of the Energy and Infrastructure Provisions of the Inflation Reduction Act of 2022. As such, EPA is interested in funding proposals that have a commitment to creating good jobs and utilizing a diverse, highly skilled workforce, including an emphasis on creating employment opportunities for populations living in communities that are disadvantaged.
This supports the broader goals of environmental justice by making sure federal funds are spent on Climate Action and Pollution Reduction projects that have a commitment to strong labor standards, creating stronger communities where worker, employer, and community needs are collectively met. Characteristics of a good job include strong wages and family-sustaining benefits; worker empowerment and neutrality with respect to union organizing and collective bargaining; work environments that promote worker health and safety; job security; equitable workforce development pathways and opportunities for career advancement; and supportive services, such as childcare and transportation, to support individuals that face barriers to employment; among others. When considering how to support job quality, EPA encourages applicants to review the eight Good Jobs Principles developed by the U.S. Department of Labor and Department of Commerce. The Department of Labor has produced several resources that help potential applicants understand the Good Jobs Principles and implement them through federal funding programs including:
Good Jobs in Federal Investments: A Toolkit for Employers, Workers, and Government ; Good Jobs Initiative Job Quality Check List; Good Jobs in Federal Investments: Data and Reporting Appendix.
Grant funding for construction projects under this program is subject to Davis Bacon and Related Acts prevailing wage laws as provided in Section 314 of the Clean Air Act. Beyond this requirement, applicants are encouraged to articulate additional strategies they will use to deliver on the goals outlined above, including ensuring high labor standards and a diverse workforce to benefit the local community where the EPA funded work is taking place. These commitments should be concrete, specific, and measurable rather than vague statements, and may be integrated into EPA’s agreement with the recipient through programmatic terms and conditions.
81 Appendix F. Track I and II Outputs and Outcomes
(back to the Table of Contents)
The term “output” means an environmental activity, effort, and / or associated work product related to an environmental / public health goal and objective that will be produced or provided over a period or by a specified date. Outputs may be quantitative or qualitative but must be measurable during the assistance agreement funding period.
The term “outcome” means the result, effect, or consequence that will occur from carrying out an environmental / public health program or activity that is related to an environmental / public health programmatic goal or objective. Outcomes may be environmental, behavioral, health- related, or programmatic in nature, but must be quantitative. They may not necessarily be achievable within the assistance agreement funding period.
Examples of expected outputs and outcomes for the Track I and II awards under this NOFO include but are not limited to the following as applicable depending on the strategies and projects in the application.
Applicants may identify additional outputs and outcomes as relevant to their specific strategies and projects in their application.
Track I Output and Outcome Examples
Strategy Output Examples Outcome Examples
Climate Action Strategies
Strategy 1: Green
Infras
tructure and
Nature-based Solutions
Coastal green infrastructure
projects, including blue-green
trails (#)
Increased green space as measured
by square footage of added
greenspace
Green / complete streets,
sidewalks, bus stops (#)
Increased resilience to extreme
weather and climate conditions as
measured by reduction in flash
flooding events, improved
groundwater recharge, and cooler
ambient temperatures during heat
waves
Green / cool roofs (#)
Area of impermeable surfaces
replaced with vegetation (acres)
New parks and / or public green
space developed (acres)
New shade tree canopy (square
footage, # of shade trees
planted)
Increased community resilience as
measured by reduced damage and
recovery costs for infrastructure,
property, and cultural resources
Area under implementation of
low tillage / composting
practices (acres)
New community gardens and
greenhouses (#)
Strategy 2: Mobility and
Tra
nsportation Options
for Preventing Air
Pollution and Improving
Public Health and
Climate Resilience
New EVs, bikes / electric bikes,
and other low-and-zero
emissions vehicles that are
available via carsharing / bike
sharing programs (#)
Reduced air pollution from
trans portation (e.g., GHG
reductions, reduced number of
days with unsafe air quality for
vulnerable populations)
Increased use of public
transportation services and
82 Streets improved to encourage
walkability, bike-ability, and
transit use (#, miles)
EVs that can be used as backup
power in lieu of diesel
generators (#)
programs that promote electric
vehicles, car sharing, and bike
sharing
Strategy 3: Energy-
efficient, Healthy,
Resilient Housing and
Buildings
Home energy audits performed
(#)
Ai
r sealings completed (#)
Homes insulated (#)
Natural gas appliances replaced
with electric equivalents (#)
Mobile homes retrofitted with
solar panels and storage (#)
Electrification, weatherization,
and HVAC upgrades /
replacements of low-income
houses, apartments, small
businesses, and other
community buildings (#)
Energy efficient home-heating
appliances installed (#)
Homes or units converted to
electric heating (#)
L ower consumption of home
heating fuels (propane, he ating oil,
natural gas, and wood) and
reduction in associated climate
pollutants (e.g., black carbon,
methane, CO2), as well as ambient
and indoor emissions of Hazardous
Air Pollutants and PM2.5.
D ecreased incidence of asthma
Strategy 4: M icrogrid
Installation for
Community Energy
Resilience
R enewable energy capacity
installed (MW)
Battery storage installations
(MWh)
GHG emissions reductions (ton
CO2)
Enhanced resilience during
extreme weather events as
measured by fewer power
disruptions
Increased number of homes
connected to a resilient power
source
Strategy 5: Community
Resilience Hubs
Space built or converted into a
community resilient hub (square
ft)
Disaster preparedness trainings
delivered (#)
Stormwater management flood
preparedness training delivered
(#)
Enhanced physical safety during
natural disasters as measured by
the number of hospitalizations and
lives lost among vulnerable
populations
Increased community awareness o f
emergency preparedness
Strategy 6: Brownfield
Redevelopment
Impervious surface reduced
(square footage)
Community meetings to involve
impacted residents (#)
Green demolition activities to
support adaptive reuse or new
construction (#)
Shade trees planted (#) and new
vegetation (square f ootage)
Square footage of space
redeveloped for resilience
purposes, such as heat-reducing
shade
New economic opportunities
created through the redevelopment
of previously polluted land (e.g.,
number of business or low-income
housing units)
83 Strategy 7: Waste
Reduction and
Management to Support
a Circular Economy
Waste d iverted from landfills
(pounds / tons)
Waste recycled (pounds / tons)
Food waste composted (pounds /
tons)
Cleaner communities with less
tr
ash / waste on land a nd in
waterbodies as measured by litter
surveys
Reduced food waste and associated
emissions as measured by weight
of compost diverted from landfills
Strategy 8: Workforce
Development Programs
for Occupations that
Reduce Greenhouse Gas
Emissions and Air
Pollutants
Individuals i n disadvantaged
communities that participate in
workforce training in sectors
related to GHG emissions and
air pollution reduction who are
currently unemployed, under-
employed, or face employment
barriers (#)
People i n disadvantaged
communities hired and retained
into high-quality jobs to reduce
air pollution and GHG emissions
based on participation i n a
workforce training program (#)
Indi viduals who receive ages /
stipends and supportive services
delivered to enable community
members’ participation in
workforce training programs (#
individuals receiving such wages
/ stipends)
community members about
environmental sectors and skills
required to pursue these jobs
Increased number of high-quality
w
orkforce training programs, such
as pre-apprenticeship and
Registered Apprenticeship, in
disadvantaged communities
Increased wages, benefits, job
qua
lity, a nd job security for
participants in workforce training
programs
Increased literacy among
Alaskan-specific
Climate Action
Strategies
Renewable generation capacity
installed (MW)
Fuel storage facilities repaired
(#)
Greenhouses constructed (#)
Portable micro-water treatment
systems installed (#)
Improved water and soil quality so
water / land can be used for
Alaskan Native traditional uses
Increased access to energy sources
with low air pollution and carbon
emissions
Protection of cultural resources
including environmental habitats
Pollution Reduction Strategies
Strategy 1: Indoor Air
Q
uality and Community
Health Improvements
[ Type of] trainings implemented
(#)
Classrooms with air cleaners (#)
Houses / schools with upgraded /
improved HVAC systems (#)
Homes in which moisture issues
have been addressed (#)
Wood appliance upgraded or
replaced (#)
Increased public and
environmental health literacy
Decreased incidence of asthma
symptoms as measured by doctor
visits or school nurse visits for
asthma symptoms
Reduced exposure to radon and
risk of developing radon-induced
lung cancer
Strategy 2: Outdoor Air
Quality and Community
Health Improvements
Clean air zones or low-emission
zones created (#)
Increased public and
environmental health literacy
84 Abandoned oil / gas wells
plugged (#)
Toxic play surfaces replaced (#)
Community monitoring and alert
systems installed to alert
households to increasing
pollution levels (#)
Wildfire smoke preparedness
trainings delivered (#)
Reduced exposure to PM, carbon
dioxide, VOCs, ozone, nitrogen
dioxides, and toxics.
Increased skill development and
improvements in community
capacity to independently assess
air pollution reduction options
Strategy 3: Clean Water
Infrastructure to Reduce
Pollution Exposure and
Increase Overall System
Resilience
Clean water fountains installed
in schools / parks (#)
Full lead service lines replaced
for low-income homes (miles)
Private wells tested for PFAS (#)
Stormwater management / flood
preparedness trainings delivered
(#)
Water efficiency systems
installed (e.g., drought
mitigation systems, rain capture
installations) (#)
Decreased levels of water
contamination and pollution as
measured by boil water advisories,
lead poisoning, or water quality
monitoring results
Increased availability of clean, safe
drinking water
Strategy 4: Safe
Manag
ement and
Disposal of Solid and
Hazardous Waste
Lead paint remediations
c
ompleted (#)
Tires diverted from landfills /
the environment to disposal
facilities (#, weight)
Neighborhoods / cities /
residents served through
residential waste composting /
chipping program (#)
Waste transfer, material reuse,
and / or recycling stations
installed in underserved
communities (#)
Decreased exposure t o toxics and
hazardous chemicals
Reduced odors and pathogens
Increased residential waste
composting
Strategy 5: Eliminate
Ha
rmful Chemicals
through Product
Replacements
Conventional p roducts replaced
with Safer Choice-certified or
other EPA recommended
products (#, volume, customers
impacted)
Units of PFAS food contact
materials replaced (#)
Reduced exposure to hazardous
chemicals for those who live and
work in and near places with
chemical use and application
ANCSA-Specific
Pollution Reduction
Strategies
Ho mes served with micro-water
treatment systems (#)
Planning documents and
Environmental Information
Document created (#)
Site assessments and initial
cleanups completed (#)
Improved water and soil quality so
water / land can be used for
Alaskan Native traditional uses
Protection and preservation of
cultural resources including
environmental habitats
85 Reduced exposure to harmful
chemicals and pollutants on
Alaskan Native lands through
remediation of contaminated
lands and buildings (acres of
land, # buildings)
Track II O utput and Outcome Examples
Outputs
• New policies developed and implemented in response to community recommendations (e.g., through a new advisory council, participatory budgeting) (#) • Community benefits agreements or memoranda of understanding signed (#) • Number of community residents who complete a training that builds their capacity to participate in government processes (#)
• Amount of new funding allocated to benefit disadvantaged communities (dollars) • Number of residents who participate in a community -based participatory research initiative that informs a government process and / or priority (#)
• Research products published with data reflecting community opinions and preferences (#) • Number of educational forums and / or meetings held between governmental officials and community members (#)
Outcomes
• Increased involvement of individuals from disadvantaged communities in local, state, federal and other governmental environmental public processes
• Expanded knowledge of local, state, federal and other governmental environmental public processes among disadvantaged communities
• Stronger relationships and trust between disadvantaged communities and government entities on matters relating to environmental protection
• More transparent processes for governmental decision -making on environmental protection policies and greater governmental focus on inclusivity
• Increased accountability and community input into governmental decision- making on environmental protection policies
• More informed decisions made, and environmental actions taken, by government bodies to benefit disadvantaged communities
• Enhanced capacity in disadvantaged communities to be involved in local, state, federal, and other governmental environmental public processes
• Increased funding to enable disadvantaged communities to address environmental and climate justice issues
• New environmental or climate policies developed to be responsive to community needs 86 Appendix G. Budget Template
(back to the Table of Contents)
(This template is optional, and applicants may use a different format for the template).
Category Description Total
Personnel
Fringe Benefits
Travel
Equipment
Supplies
Contractual
Construction
Other (separate by
participant support costs,
subawards, and other costs)
Total Direct Costs (sum of
the above categories)
Indirect Costs
Total Project Costs (sum of
direct and indirect costs)
87 Guidance for Budget Template
The budget template is an attachment to the application and does not count toward the Project Narrative’s page limit as described in Section IV of the NOFO. Applicants should include applicable rows of costs for each budget category in their budget template to accurately reflect the proposed application budget for each year of the grant. EPA provides detailed guidance on budget development in the Interim General Budget Development Guidance for Applicants and Recipients of EPA Financial Assistance, but applicants may use other forms instead of this template as long as total costs per category (and specific descriptions of costs) are included.
Applicants must itemize costs related to personnel, fringe benefits, travel, equipment, supplies, contractual costs (including acquisitions of intangible property), construction, and other costs (including subawards and participant support costs) as direct costs. Direct costs plus the indirect costs equal the total project costs.
Descriptions of these cost categories are below. Applicants should be aware that if their projects include using federal funds to purchase goods, products, and materials on any form of construction, alteration, maintenance, or repair of infrastructure in the United States, they must comply with the Build America, Buy America Term and Condition if they are selected for an award.
To facilitate consideration of an application for partial funding, EPA recommends that applicants separate costs for financial assistance in the program budget by project category, to the extent practicable.
• Personnel - List all staff positions by title. Give annual salary, percentage of time assigned to the project, and total cost for the budget period. This category includes only direct costs for the salaries of those individuals who will perform work directly for the program (paid employees of the applicant organization as reflected in payroll tax records). Personnel costs do not include: (1) costs fo r services of contractors (including individual consultants), which are included in the “Contractual” category; (2) costs for employees of subrecipients under subawards or non-employee program participants (e.g., interns or volunteers), which are included in the “Other” category; or (3) effort that is not directly in support of the proposed program, which may be covered by the organization’s negotiated indirect cost rate. The budget table must identify the personnel category type by Full Time Equivalent (FTE), including percentage of FTE for part-time employees, number of personnel proposed for each category, and the estimated funding amounts. • Fringe Benefits - Identify the percentage used, the basis for its computation, and the types of benefits included. Fringe benefits are allowances and services provided by employers to their employees as compensation in addition to regular salaries and wages. Fringe benefits may include, but are not limited to, the cost of leave, employee insurance, pensions, and unemployment benefit plans. If the applicant’s fringe rate does not include the cost of leave, and the applicant intends to charge leave to the agr eement, it must provide supplemental information describing its proposed method(s) for determining and equitably distributing these costs. • Travel - Specify the mileage, per diem, estimated number of trips in -state and out-of-state, number of travelers, and other costs for each type of travel . Travel may be integral to the purpose of the proposed program (e.g., site visits); related to proposed program activities (e.g., attendance at community engagement meetings); or for a technical training or workshop that supports effective implementation of the program activities (e.g., consumer awareness activities).
Only include travel costs for employees in the travel category. Travel costs do not include: (1) costs for travel of contractors (including consultants), which are included in the “Contractual” category; or (2) travel costs for employees of subrecipients under subawards and non- employee program participants (e.g., trainees), which are included in the “Other” category. Further, travel does not 88 include bus rentals for group trips, which would be covered under the “Contractual” category.
Finally, if the applicant intends to use any funds for travel outside the United States, it must be specifically identified. All proposed foreign travel must be approved by EPA’s Office of International and Tribal Affairs prior to being taken.
• Equipment - Identify each item to be purchased that has an estimated acquisition cost of $5,000 or more per unit and a useful life of more than one year . Equipment also includes accessories necessary to make the equipment operational. Equipment does not include: (1) equipment planned to be leased / rented, including lease / purchase agreement; or (2) equipment service or maintenance contracts that are not included in the purchase price for the equipment.
These types of proposed costs must be included in the “Other” category. Items with a unit cost of less than $5,000 must be categorized as supplies, pursuant to 2 CFR § 200.1. The budget table must include an itemized listing of all equipment proposed under the program. If installation costs are included in the equipment costs, labor expenses shall be itemized with the detailed number of hours charged and the hourly wage. If the applicant has written procurement procedures that define a threshold for equipment costs that is lower than $5,000, then that threshold takes precedence. • Supplies - “Supplies” means all tangible personal property other than “equipment.” The budget detail should identify categories of supplies to be procured (e.g., laboratory supplies or office supplies) . Non-tangible goods and services associated with supplies, such as printing services, photocopy services, and rental costs must be included in the “Other” category. • Contractual - Identify proposed contracts, specifying the purpose and estimated cost for typical contractual services and disaggregating any costs for acquisitions of intangible property. Contractual services (including consultant services) are those services to be carried out by an individual or organization, other than the applicant, in the form of a procurement relationship.
The EPA Subaward Policy and supplemental frequently asked questions have detailed guidance available for differentiating between contractors and subrecipients. Leased or rented goods (equipment or supplies) must be included in the “Other” category. EPA does not require applicants to identify specific contractors, but if an applicant does so they must demonstrate that the contractor was selected in compliance with competitive procurement requirements in 2 CFR Parts 200 and 1500. Subcontracts are not subawards and belong in the “Contractual” category.
In the budget description, the applicant should list the proposed contract activities along with a brief description of the anticipated scope of work or services to be provided, proposed duration, and proposed procurement method (competitive or non-competitive), if known. Any proposed non- competed / sole -source contracts more than the applicant’s 2 CFR § 200.320(a) micro -purchase threshold (generally $10,000) must include a justification. Note that EPA rarely accepts proposed sole source contracts for goods and services (e.g., consulting) that are widely available in the commercial market absent a copyright, patent, or equipment warranty requirement or similar restriction that establishes that only one source can provide the necessary good or service; unique qualifications or long-standing relationships with a grantee do not provide an adequate basis for a sole source contract. Applicants must provide the aggregate amount they propose to issue as acquisitions of intangible property as a separate line item in the “Contractual” category. Refer to the EPA Best Practice Guide for Procuring Services, Supplies, and Equipment Under EPA Assistance Agreements for EPA’s policies on competitive procurements and encouraging the use of small and disadvantaged business enterprises.
•
Construction.
89 Include costs for activities that fall under the definition of construction in EPA’s Small and Disadvantaged Business (DBE) rule at 40 CFR 33.103 which defines construction as “ . . . erection, alteration, or repair (including dredging, excavating, and painting) of buildings, structures, or other improvements to real property, and activities in response to a release or a threat of a release of a hazardous substance into the environment, or activities to prevent the introduction of a hazardous substance into a water supply.” (Emphasis added). As stated on p. 32 of the Interim General Budget Development Guidance for Applicants and Recipients of EPA Financial Assistance mentioned above:
Construction costs may include site preparation, demolishing and building facilities, making permanent improvements to facilities or other real property, major renovations of existing facilities, remediation of contamination and related architectural or engineering services. With very few exceptions, recipients carry out construction projects by hiring contractors which typically include a general contractor and an architectural or engineering firm for design work and in some cases purchasing equipment for installation at the site.
Construction costs are to be categorized on the SF 424A budget table as follows:
1. Anticipated costs for hiring general contractors and other contractors performing activities described in the DBE Rule’s definition of Construction will be categorized as “Construction”.
2. Anticipated costs for pre-construction architectural and engineering Services as defined in the DBE rule for design and specifications documents will be categorized as “Contractual”.
3. Anticipated costs for separately purchased Equipment as defined in the DBE Rule that will be installed in a facility or used to remediate contamination will be categorized as “Equipment”.
4. Anticipated costs for land acquisition or relocation assistance paid to individuals or businesses will be categorized as “Other”.
• Other - List each item in sufficient detail for EPA to determine the reasonableness and allowability of the cost. This category should include only those types of direct costs that do not fit in any of the other budget categories including subawards, participant support costs, and additional costs (e.g., insurance, costs fo r acquiring real property, rental / lease of equipment or supplies, equipment service or maintenance contracts, and printing or photocopying). Subawards - 2 CFR § 200.1 defines a subaward as “an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity.” 2 CFR § 200.1 defines a Pass -through entity as “a non- federal entity that provides a subaward to a subrecipient to carry out part of a federal program” and a Subrecipient as “an entity…that receives a subaward from a pass- through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award.” Identify each major subaward including those with the Collaborating Entities. Applicants must show the individual and aggregate amounts they propose to issue as subawards. Additional guidance is available in the EPA Subaward Policy and below.
Participant Support Costs - 2 CFR § 200.1 defines participant support costs as “direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training 90 projects.” EPA regulations at 2 CFR § 1500.1(a)(1) expands the definition of participant support costs to include “[S]ubsidies, rebates, and other payments to program beneficiaries to encourage participation in statutorily authorized environmental stewardship programs.” Additional guidance is available in the EPA Guidance on Participant Support Costs.
Indirect Costs
If indirect costs are budgeted, indicate the approved rate and distribution base. Indirect costs are those incurred by the grantee for a common or joint purpose that benefit more than one cost objective or project and are not readily assignable to specific cost objectives or projects as a direct cost. Indirect costs must be based on a rate approved by the applicant’s cognizant federal agency, or the 10% de -minimus rate authorized by 2 CFR § 200.414(f). Additional indirect cost guidance is available in Indirect Cost Guidance for Recipients of EPA Assistance Agreements and in Section VI.u, “IDC Competition Clause,” of the EPA Solicitation Clauses.
Notwithstanding this, indirect costs have been capped as described below based on a deviation approved per 2 CFR 200.414:
Limitation on indirect costs for grants and cooperative agreements a. In general: Except as otherwise provided by statute, indirect costs charged against any grant and / or cooperative agreement awarded under this NOFO shall not exceed 20 percent of the total amount of the federal award.
b. Exception: Subsections (a) and (c) shall not apply to Indian Tribes as defined in section 302(r) of the Clean Air Act who serve in the role of direct recipient and / or subrecipient under the program or to Intertribal consortia that meet the requirements of 40 CFR 35.504(a) and (c) even if the Intertribal consortia is eligible for funding as a Community Based Nonprofit Organization. c. Treatment of subawards: In the case of a grant and / or cooperative agreement described in subsection (a), the limitation on indirect costs specified in such subsection shall be applied to both the initial direct assistance award amount and any subaward of the federal funds provided under the initial assistance award so that the total of all indirect costs charged to each of the federal awards (i.e., both the initial direct assistance award amount and any subawards) funded under the initial assistance award does not exceed such limitation. As provided in 2 CFR 200.332(a)(2) pass-through entities are responsible for ensuring compliance with the indirect cost limitation by their subrecipients.
Note: This limit does not extend to indirect costs on procurement contracts. 91 Appendix H. Alaska Tribal Lands Target Investment Area (back to the Table of Contents)
As noted in Section II.B, this NOFO includes a Target Investment Area for projects benefitting Alaska Tribal lands that are defined as disadvantaged communities in Appendix A. Under this Target Investment Area, EPA is accepting applications that include projects focusing on the clean -up of contaminated lands conveyed through the Alaska Native Claims Settlement Act (ANCSA).
Applications submitted by eligible applicants including Alaska Native Villages (ANVs), Alaska Native Nonprofit Organizations, and Alaska Native Nonprofit Associations for the Alaskan Target Investment Area must include, like all other Track I applications, at least one Climate Action Strategy and at least one Pollution Reduction Strategy and meet the other Track I application requirements in Section I.G of the NOFO, to be eligible for funding. Applicants are not limited to a single project activity under a strategy and may select several project activities associated with a strategy. Note that the for -profit Alaska Native Corporations are not eligible to be Lead Applicants or Statutory Partners for this NOFO. The Climate Action and Pollution Reduction Strate gies addressed in applications for the Alaskan Target Investment Area can address either the Climate Action and Pollution Reduction Strategies (and project activities referenced in Appendices C and D) in Section I.G, or any specific Alaskan ones described below under paragraphs 1 and 3. EPA strongly encourages applications that include Pollution Reduction strategy projects to clean up contaminated lands conveyed through ANCSA as addressed in Section 1 below.
Consistent with this priority, EPA anticipates making a minimum of 5 awards for high-ranking applications that include projects to assess and/or clean up contaminated lands conveyed under ANCSA in furtherance of the federal government’s interest in addressing this historic injustice as noted in Sections II.B and V.E.
1. ANCSA-Specific Pollution Reduction Strategy and Associated Project Activities This section describes project activities specific to the assessment and cleanup of sites covered by the Contaminated ANCSA Lands Assistance Program . T he specific requirements that apply to ANCSA cleanup projects are below.
ANCSA was enacted in 1971 to settle aboriginal claims to public lands through the conveyance of 46 million acres of land to Alaska Native regional and village corporations and the transfer of one billion dollars from the state and federal governments as co mpensation for lands which could not be returned to Alaska Native ownership. Many of the lands promised and conveyed to corporations pursuant to the settlement in ANCSA were contaminated. The contaminants on some of these lands—which include arsenic, asbes tos, lead, mercury, pesticides, polychlorinated biphenyls, and petroleum products—pose health and other concerns to Indigenous Alaskans and communities and are present in quantities above state and federal clean-up levels, negatively impacting subsistence resources and hampering cultural, social, and economic activities.
In 2023, EPA initiated a new Contaminated ANCSA Lands Assistance Program (ANCSA Program) to assist with addressing contamination on lands conveyed pursuant to ANCSA and provide funding to (1) characterize, assess, and conduct planning and community involvement activities related to these lands and (2) to carry out cleanup activities at ANCSA sites contaminated at the time of conveyance. The statutory authority for the ANCSA Program (Public Law 117-328) states that recipients of grants awarded under the ANCSA Program may use the funding to “. . . supplement other funds provided by the Environmental Protection Agency through individual media or multi-media grants or cooperative agreements.” Eligible ANSCA project activities:
92 • Conducting Planning and Developing Site Plans:
o Planning and site plan development for individual contaminated sites. o Where multiple sites are connected through location, infrastructure, or economic, social, and environmental conditions, planning and site plan development can take an area- wide approach for multiple sites. Applicants must demonstrate how work conducted at several sites will benefit the primary site selected for investment. Pro ject Area requirements are outlined in I.D of the NOFO but may be waived for purposes of coordinated cleanup. • Conducting Site Assessments and Related Activities:
o Conducting site assessment and sampling activities
o Developing a Health and Safety Plan, Quality Assurance Project Plan and / or Sampling Plan prior to conducting any environmental sampling and analysis (a requirement for any projects conducting sampling).
o Submitting samples for analysis to an EPA accredited laboratory. Analytical costs from evaluating site samples.
o Developing a report of the sample results and conclusions based on analysis (i.e., Conceptual Site Model, Assessment report, Site Inspection or Sampling Summary Report).
o Supporting planning for future cleanup activities such as analysis of cleanup alternatives. • Conducting Initial Cleanup Activities:
o Developing a site cleanup approach and documenting the approach in a Site Cleanup Plan to include agreed upon cleanup endpoints, aligned with Alaska Department of Environmental Conservation (ADEC) cleanup process.
o If necessary, procuring contract services to conduct cleanup activities such as contaminated material removal, sampling, or health and safety monitoring. o Conducting environmental confirmation sampling post-cleanup activities to determine if further action is required. If necessary, planning for next phase of site cleanup. o Developing a report documenting removal and / or cleanup activities. • Conducting Community Engagement Activities:
o As noted in Section I of the NOFO, all applicants are required to develop a Community Engagement Plan. Effective community engagement is vital to working effectively with Alaska Native communities. Therefore, for ANCSA-related cleanup projects, Community Engagement Plans should include community engagement activities and / or development of culturally sensitive protocols for project implementation of cleanup activities. o Costs of conducting community engagement activities, including training for workforce development, youth engagement, elder engagement in documentation of Traditional Knowledge, and other costs associated with meaningfully engaging the community in the project can be included in the proposal budget.
• Compiling Information to Use to Comply with NEPA
o T
he projects funded under this NOFO do not require Environmental Information Documents (EID) because EPA awards under this NOFO are not subject to the National Environmental Policy Act (NEPA), under Section 7(c) of the Energy Supply and Environmental Coordination Act of 1974 (15 U.S.C. 793(c)(1)). However, applicants may seek funding to prepare EIDs as needed to comply with NEPA in connection with other federal grant -funded projects in Alaska. EPA awards under the ANCSA program, for example, are subject to NEPA, as are programs funded by other federal agencies. 93 Additional Eligibility Requirements for ANCSA-related projects and activities:
Applicants proposing ANCSA -related cleanup projects must provide the following documentation of eligibility in their application. Failure to do so may render the application ineligible for funding.
Specifically, applicants must provide the following site-specific information for where the cleanup activities will be performed, demonstrating that the site:
• was conveyed pursuant to ANCSA;
• was contaminated by hazardous substances, pollutants, contaminants, or petroleum at the time of conveyance; and
• is listed on the interim EPA inventory of Contaminated ANCSA Lands (for more information on EPA’s interim inventory and program related to cleaning up contaminated lands conveyed pursuant to ANCSA, visit EPA Region 10’s website).
• If the applicant is not the owner of the contaminated site(s) to be addressed, EPA will require proof that the landowner will provide access to the site and supports taking action to address contamination.
2. General Alaskan Pollution Reduction Strategies
In addition to the ANCSA land contamination projects identified above, applicants for the Alaskan Tribal Lands Target Investment Area may include Pollution Reduction Strategies as identified in Section I.G of the NOFO.
3. Alaska-Specific Climate Action Strategies
Below are examples of additional Alaska-specific Climate Action Strategies and project activities that may be included in applications for the Alaskan Tribal Lands Target Investment Area, which are in addition to the Climate Action Strategies described in Section I.G of the NOFO. • Community energy resilience, which may include activities such as:
o Multi-energy systems including renewable (solar, wind, etc.) and traditional (bulk fuel) sources to increase resilience during extreme events and support a clean energy transition. o Power system projects, including renewable energy projects, and the construction, repair, and maintenance of fuel storage facilities in rural areas. • Improving human health and climate resilience, which may include activities such as:
o Construction of greenhouses that enable sustainable food growth that can promote healthy foods, food accessibility, and food availability.
o Food storage facilities to enable sustainable access to traditional foods to support places where permafrost degradation is destroying traditional ice cellars. New food storage facilities may be constructed to support the access and availability of traditional f oods.
Selection of this project component must include a permafrost mitigation strategy. o Projects to support new and improved access points to traditional food resources , such as construction of new fishing docks or river / lake boat ramps to allow for improved fishing opportunities in places that have a high reliance on traditional foods, where climate change has degraded access and availability of food sources.
• Permafrost degradation management strategies that may include strategies such as:
o Source water protection (impacts from landfills, thawing of permafrost, and potential impacts to traditional drinking water sources as well as established drinking water systems).
94 o Portable micro -water treatment systems applicable to those impacted by emergencies which impact drinking water systems, with the ability to treat water until system repairs are complete or new systems built.
o Manage and monitor contamination impacting land, food, and water backhaul / removal of waste materials not suitable for disposition in permitted landfills in Alaska. • Climate emergency management and response strategies that may include activities such as:
o Purchase of emergency response cargo containers with materials ready to deploy, including four-wheeler, snowmachine, communications, temporary office location, boat, oil spill response materials, smoke management equipment, etc.
o Development of emergency alert and warning systems for wildfires, flooding and other emergencies stemming from climate change.
• Nature-based resilience strategies that may include activities such as:
o Restoration of natural systems to help protect coastal communities from the impacts of storms, floods, and other natural hazards.
o Storm damage prevention and reduction, coastal erosion, and ice and glacial damage stemming from climate change.
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