Exhibit A
Final Revised Grant Application (August 18, 2021)
16 OMB Number: 4040-0004
Expiration Date: 12/31/2023
* 1. Type of Submission: * 2. Type of Application:
* 3. Date Received: 4. Applicant Identifier:
5a. Federal Entity Identifier: 5b. Federal Award Identifier:
6. Date Received by State: 7. State Application Identifier:
* a. Legal Name:
* b. Employer/Taxpayer Identification Number (EIN/TIN): * c. Organizational DUNS:
* Street1:
Street2:
* City:
County/Parish:
*
State:
Province:
* Country:
* Zip / Postal Code:
Department Name: Division Name:
Prefix: * First Name:
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* Last Name:
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Title:
Organizational Affiliation:
* Telephone Number: Fax Number:
* Email:
* If Revision, select appropriate letter(s):
* Other (Specify):
State Use Only:
8. APPLICANT INFORMATION:
d. Address:
e. Organizational Unit:
f. Name and contact information of person to be contacted on matters involving this application:
Application for Federal Assistance SF-424
Preapplication
Application
Changed/Corrected Application
New
Continuation
Revision
08/18/2021 City of San Pablo
City of San Pablo
946000423 1097383560000
1000 Gateway Avenue
San Pablo
Contra Costa
CA: California
USA: UNITED STATES
94806-3703
Public Works Environmental Services
Ms. Sarah
Kolarik
Environmental Program Analyst
City of San Pablo
5102153068 5102153013
[email protected]
X
17 * 9. Type of Applicant 1: Select Applicant Type:
Type of Applicant 2: Select Applicant Type:
Type of Applicant 3: Select Applicant Type:
* Other (specify):
* 10. Name of Federal Agency:
11. Catalog of Federal Domestic Assistance Number:
CFDA Title:
* 12. Funding Opportunity Number:
* Title:
13. Competition Identification Number:
Title:
14. Areas Affected by Project (Cities, Counties, States, etc.):
* 15. Descriptive Title of Applicant's Project:
Attach supporting documents as specified in agency instructions.
Application for Federal Assistance SF-424
C: City or Township Government
Environmental Protection Agency
66.312
State Environmental Justice Cooperative Agreement Program EPA-OP-OEJ-20-02
STATE ENVIRONMENTAL JUSTICE COOPERATIVE AGREEMENT PROGRAM (SEJCA) / COVID-19 PROJECTS COVID-19 Action Teams (CO-ACT): Healthier People, Healthier Homes Engaging and Training New Youth Leadership to Understand, Communicate and Navigate the Impacts of COVID-19
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18 * a. Federal
* b. Applicant
* c. State
* d. Local
* e. Other
* f. Program Income
* g. TOTAL
.
Prefix: * First Name:
Middle Name:
* Last Name:
Suffix:
* Title:
* Telephone Number:
* Email:
Fax Number:
* Signature of Authorized Representative: * Date Signed:
18. Estimated Funding ($):
21. *By signing this application, I certify (1) to the statements contained in the list of certifications** and (2) that the statements herein are true, complete and accurate to the best of my knowledge. I also provide the required assurances** and agree to comply with any resulting terms if I accept an award. I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties. (U.S. Code, Title 218, Section 1001) ** The list of certifications and assurances, or an internet site where you may obtain this list, is contained in the announcement or agency specific instructions.
Authorized Representative:
Application for Federal Assistance SF-424
* a. Applicant
Attach an additional list of Program/Project Congressional Districts if needed. * b. Program/Project
* a. Start Date: * b. End Date:
16. Congressional Districts Of:
17. Proposed Project:
CA-011 CA-011
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10/01/2021 09/30/2023
197,500.00
0.00 0.00
0.00 0.00
0.00 197,500.00
a. This application was made available to the State under the Executive Order 12372 Process for review on b. Program is subject to E.O. 12372 but has not been selected by the State for review. c. Program is not covered by E.O. 12372.
Yes No
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** I AGREE
Mr. Matt
Rodriguez
City Manager
5102153016 5102153011
[email protected]
Sarah Kolarik
* 20. Is the Applicant Delinquent On Any Federal Debt? (If "Yes," provide explanation in attachment.) * 19. Is Application Subject to Review By State Under Executive Order 12372 Process? 08/18/2021
If "Yes", provide explanation and attach
19 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 1 1 PROGRAM OBJECTIVES
a) Project Summary Page
Organization Name City of San Pablo, CA.
Program Title
COVID-19 Action Teams (CO-ACT): Healthier People, Healthier Homes Learning Together in a New World: Engaging and Training New Youth Leadership to Understand, Communicate and Navigate the Impacts of COVID-19.
Program Priorities /
Goals
1. Public Education, Training, Emergency Planning, and/or Investigations on Impacts of CO
VID-19 on Underserved Communities and Vulnerable Populations Work with 3 public Title 1 high schools to deploy an afterschool internship program for disadvantaged students, reaching out to peers and the public to raise awareness and mitigate the impacts of COVID-19 on environmental justice communities The internship program will directly train 45 students each year in d ata collection and content creation to launch outreach campaigns to 3,000 peers in 3 campuses and households.
2. Documenting the safety and efficacy of vaccines and various preventative safety measures against COVID-19 infection, including masks/ PPE, hyg iene best practices, social distancing, and frequent testing. In the midst of social-distancing and local st
ay-at-home orde
rs, as well as widespread disinformation campaigns on social media especially i
n places where accurate information may not be readily av ailable to all residents, the program will a) share information related to CDC recommendations for COVID-19 safety procedures; b) address under-served residents’ lack of trust in and access to free vaccines in an effort to increase vaccination and testing rates in vulnerable communities; c) train teams of high school youth
leadership
as community educators for e nvironmental justice communities.
Qualified
Environmental Statutes Clean Air Act 103(b)(3)
Project Core Team Sarah Kolarik, Project Manager. Chiara Hanna, Management Analyst. Manuel Alonso, Earth Team’s Executive Director, Joelle Alley, Earth Team’s Program Director, Key Partnerships
Richmond High School, Richmond, CA. Deploying one leadership team of 15- student- interns each year
JF Kennedy High School, Richmond, CA. Deploying one leadership team of 15 student- interns each year
Pinole Valley High School, Pinole CA. – Deploying one leadership team of 15 student- interns each year
Project Activities Assessment and Data Collection, Tool Development, Training, Outreach Campaigns Planned Sub-Grantees 1 Sub-Grantee: Earth Team
Implementation /
Delivery Method
Afterschool Paid Internships: 45 interns per year, in 3 teams of 15 students each, meet weekly receiving 120 hours of education and skills training prior to implementing direct service learning projects to conduct COVID-19 impact assessments, data collection and development of key messaging using new technologies for public outreach events to engage 3,000 high-school peers, families and community members.
Target Population
90 High school students recruited as paid interns from 3 public high schools to engage in public education and outreach campaigns to 3,000 students and their households (65% low-income) with limited or no access to environmental education programs. 38% Latino, 18% African American, 17% White, 15% Asian-American, 7% Filipino.
Participant ages between 14 and 18; 69% female, 31% male.
Project Period 24 months, from October 1, 2021 through September 30, 2023 Federal Funds $197,500 Matching funds: N/A
Sub-Awards Sub Grants: $152,278 (Earth Team, a nonprofit 501c3 organization uniquely qualified to deliver
youth-driven education and outreach to the San Pablo larger community Total Project Cost $197,500
20 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 2 Project Abstract
Earth T
eam has
developed and successfully tested the remote meeting infrastructure to respond to shelter-in- place
orders, working with teams of trained high school youth to produce and distribute easy to understand and reliable information t
o disadvantaged communities in the midst of a storm of "fake news" and disinformation campai
gns that are
creating confusion in our communities aboud vaccine safety and more. This infrastructure will mobilize eac
h year 45 high school students working as paid project interns to acquire COVID-19 data and use
it in research
-action projects and campaigns in their local community. High school students are true "digital natives”, and we can mobilize their potential to ent er the conversation about COVID basics and best practices by:
§ Creating pop-up bilingual (Spanish/English) interactive exhibits and or virtual displays that show to the public COVID basic and reliable information and best practices in an easy to absorb, fun way. § Three local public
high-school based leadership teams, armed with laptops and internet access, will c
reate onli
ne content and develop a powerful network with peers t o distribute actionable information on "virus smart" best practices via distribution of energet ic and enticing "pop-culture" key messaging (in-person and virtual) that is easily understood by peers and familie s, contributing to combat misinformation as t
he teams of “COVID Myth Busters”.
CO-ACT is a youth-leadership and community-dr iven program that will be implemented by sub-grantee Earth Team, a leading
environmental organization with 25 years of e xperience with local communities in the East Bay.
Earth Team will facilitate the other project partnerships: 3 local public high schools t hat have long term working relationships with Earth Team. In the two-year project period, COA-ACT will hire and train a total of 90 disadvantaged youth as afterschool paid interns to learn and help build awareness among 6,000 peers and their households and ge
neral community members, improving their understanding and engagement in COVID- smart practic
es in personal hygiene, testing and vaccination. By hiring, training and educating local youth to design their own
community-based service-learning projects, we will be engaging local leaders, amplifying their voices to increas
e public participation and awareness, addressing directly EPA’s Strategi c Plan GOAL 2 (Increasing Transparency and Public Participation).
The short-term outcomes and related activities will engage, educate and empower yout h to understand and communicate
COVID-19 reliable information, specifically with issues such as clean air and virus transmission/ susceptibility, accurate information about vaccines, acces s to vaccines and access to testing. 90 paid project
interns in two
years recruited from local high schools will become trained COVID-19 communicators and will be integrally in
volved in the thinking behind and execution of all activities. Our project partner, Earth Team, which has been
working for 25 years in the East Bay and has direct connections to the underserved community impacted by the
se environmental harms and risks, will be in charge of deploying all aspects of the two-year internship program
that will gather valuable information and conduct innovative, interactive, outreach campaigns to a total of
6,000 high-school students and their households in two years.
The City of San Pablo and Earth Team will partner to educate and train teams of high-school age youth to launch an outreach and information campaign to help underserved communities that face environmental justice concerns in understanding and acquiring reliable information on the impacts of COVID-19 in their lives and in homes. Earth Team will use its successful public high-school internship program to train and mobilize 3 teams of student-inter ns as "digital natives" to act as science ambassadors in their families and neighborhoods, creating accessible pop-culture content and key messaging related to (1) CDC dictated best practices to protect against COVID-19, including social distancing, hygiene, use of PPE, testing and vaccinations (2) addressing underserved residents’ lack of access to accurate information about vaccine safety and efficacy , availability of vaccine, and availability of testing (3) Developing an understanding of COVID-19 as it relates to personal practices, air quality and healthier homes.
21 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 3 Project Objectives
• Develop New Youth Leadership and Promote Public-Private Partnerships: The City of San Pablo will partner w
ith Earth Team to implement a youth-led afterschool internship pr ogram to train 3 leadership teams each year to 3,000 peers and their households on the basi c facts and the impac ts of COVID19 in underserved
communities.
• Off-Campus
Public O
utreach to Increase COVID-19 Awareness Amongst Residents and Local Businesses: presenting the results of data c ollected to street residents and in public forums to engage other community stakeholders and local leaders, using forums such as PTA, Home Owner Associations, City Councils, Advisory
Boards and others when possible, or via innovative electronic means. b) Disproportionate Environmental and Public Health Issues Impacting Underserved Communities
While the effects of the COVID-19 pandemic are still emerging, current data suggests certain populations are more vulnerable to the novel coronavirus than others. According to a recent study from APM Research Lab, African Americans are dying from the virus at nearly three times the rate of white Americans. In 42 states and Washington D.C., Hispanics/Latinos make up a greater share of confirmed COVID-19 cases than their share of the population. Early data also indicates dramatically disproportionate rates of infection and death among Native Americans. Centene recently announced new partnerships addressing these inequities as part of our commitment to ensuring underserved populations can access high-quality healthcare.
The pandemic has propelled the conversation in America about racial inequities in health and what can be done in the future. According to the CDC, African Americans account for nearly 20% of coronavirus cases and Latinos account for 16.7% of all cases. The City of San Pablo has a largely Latino population. Dr. Shelley Cooper, CEO Diversity Telehealth, said that hundreds of years of racism has impacted where individuals live and their access to certain services. For example, many people live in food desserts, or areas where there is no access to fruits and vegetables, resulting in a higher prevalence of diabetes. Diabetes and other chronic conditions are associated with a higher risk of mortality among coronavirus patients. “All of these factors leading to chronic diseases that weaken out immune systems – we are calves to slaughter almost,” Cooper said. “When you add all of these factors in, we started out behind the eight ball.” The City of San Pablo and Richmond in the East Bay and surrounding unincorporated areas have populations with high environmental vulnerability indexes, high incidence of asthma and impounded streams or water bodies. Early information shows that some people are at higher risk of getting very sick from this illness. This includes: Older adults and people with chronic medical conditions such as, heart disease, diabetes, lung disease.
As part of the effort to build robust partnership with the community, it is critical to invite the youth to the table. They are the truly “Digital Natives” and able to use STEM skills to collect and create easy to understand, po-culture related contents that makes the problem closer and more digestible to their own communities. They need to feel valuable and to provide their own perspective on what works and what does not work in terms of communicating information to their age group. Once the information is communicated and youth is engaged, this will help in building trust regarding the City of San Pablo Operations Plans and Urgency Ordinances. • On-Campus Outreach to Increase COVID-19 Literacy Amongst High School Students: Using new awareness, skills and data collected, leadership teams create compelling communication packages and in- person/virtual interactive exhibits to educate 3,000 students in 3 campuses and 3,000 households about COVID-19, with an emphasis on vaccine education/safety and access and supplemental testing. 22 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 4 c) Organization’s Recent Efforts to Directly Support Underserved Communities AB 617: Community Air Protection Program (CAPP)
Due to the significant air quality issues, the Richmond-San Pablo area has been identified as AB 617:
Community Air Protection Program (CAPP) jurisdictions. The communities of San Pablo and Richmond are involved in an extensive Community Air Monitoring Plan that will be transitioning to a Community Action Plan in the coming year. Due to the work of the CAPP, San Pablo has had extensive air quality monitoring performed over the 2019-2020 year. Some preliminary results of this air quality monitoring can be found at https://insights.aclima.io/richmond-san-pablo.
Childhood Obesity Prevention Task Force (Task Force)
Improving public health through active living is a significant policy priority for City Council—under the major policy goal of “Build a Healthy Community” in the 2019-2021 Priority Workplan—as the City of San Pablo has severe issues with obesity. In 2010, the University of California, Los Angeles (UCLA) Center for Health Policy Research released the Overweight and Obesity among Children by California Cities report that showed that the City of San Pablo had a childhood obesity rate of 52.4%, the third highest obesity rate among children in the State. After this report was released, the City developed a Childhood Obesity Prevention Task Force (Task Force) to develop and implement a feasible, evidence-based plan to improve the health of all San Pablo residents. In 2014, the Task Force released a Community Action Plan that emphasized active living as a priority strategy to improve community health.
San Pablo Local Economic Opportunity Policy.
The City has a Local Economic Opportunity Policy, which sets forth local employment and contracting requirements for certain City projects and contracts. This policy requires that contractors make good-faith efforts to hire local residents as part of project requirements.
Outreach Approach
The predominant language spoken in San Pablo is Spanish; therefore, the City prepares informational materials (e.g. meeting invitations/notifications, flyers, presentations, handouts, etc.) and conducts outreach efforts in both English and Spanish. Additionally, outreach efforts for major projects include a variety of tactics— including targeted mailers, targeted neighborhood meetings, “pop-ups,” temporary demonstration and online surveys—in order to make engagement opportunities accessible for folks of all ages and preferred communication styles. Meetings and “pop-ups” adapt to the primary language to those in attendance, providing simultaneous Spanish translation (or simultaneous English translation) depending on the needs of the attendees.
Importantly, as much as possible the City makes an effort to go to the community, rather than asking the community to come to us.
Community Demographics
The program targets directly 9-12th grade students in public, Title 1 high schools, of all ethnic backgrounds. As an average the participant school demographics are 85% youth of color including 45% Latino, 17% African American and 7% Filipino. 90% of the students enrolled have never participated in outdoor projects or had meaningful experiences in understanding and caring for the environment. Participants largely are members of low-income families, with 65% qualifying for free or reduced lunch programs. Student ages range from 14 to 17, 71% are female and 29% are male.
Community Involvement
Subawardee Earth Team is a nonprofit environmental education service provider founded in 1994. It was founded to support overcrowded schools and teachers with no time or competences to teach environmental education. Their Sustainable Youth Internships Program is now a leader in innovating the environmental education field serving students in Title 1 public schools in the San Francisco East Bay. The project-based learning approach targets each year a group of 8 core schools with a total student population of 15,000. In the past 24 years we have worked with 80+ partners to implement award winning projects reaching a combined total population of 50,000 students, 100 schools and 400 teachers. 23 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 5 Earth Team’ s Afterschool Internships Pr ogram Results: In the past 6 years, Earth Team has enrolled and trained 1,000 under
served youth with excellent results: the partner public schools highly value t heir internship program and many alumni are choosing environment al car eers. The internship program was developed over the years w
orking with dozens of community partners, hundreds of participating students, teachers and community membe
rs feedback.
d) Project Linkages
Increasing You
th Participation and COVID-19 Leadership via High School Paid Internships
e) Partnerships
Earth
Team – Sub Awardee with Unique Qualifications
to Deliver the Programmatic Outcomes
Earth Te
am is a nonprofit environmental education service provider founded in 1994. Its Sustainable Youth Program (SYP) leads
in innovating the environmental education field serving students in Title 1 public schools in Alameda and Contra Costa counties in the San Francisco Bay Area. Their project-based learning approach t
argets a group of 8 core schools with a total student population of 15,000. In the past 25 years they have worked with
80+ partners to implement award winning projects reaching a combined total population of 50,000 students, 1
00 schools and 400 teachers. With a team of 6-full time experienc ed environmental educators and 2-part time positions, Earth Team is run by a 6-person board of directors who oversees mission, program vision and financial perfor
mance. Campus-based projects e mphasize carefully structured hands-on learning ex
periences created in partnership with other organizat ions and community representatives. Students receive comprehensive hands-on training and orientation appropriate to the project tasks, giving them a structured and safe context on which to explore and develop motivation, engagement, exercise choices, and develop leadership. Always working in teams, students, school staff and community members learn how to apply cur
riculum content to solve local environmental challenges, focusing on urba n sustainability and how communities can learn to minimize required inputs of energy, water and food, and better manage waste and outputs of heat, air pollution and water pollution.
Earth Team
’s program is the result of many years of close relationships with many experienced community partners. This makes Earth Team a uniquely qualified organization to implement all programmatic aspect s of the program. Their network of local organizations provides students with the opportunity to work with professional organizations,
scientists and experts, which act as mentors for the interns. Earth Team has a long- term relationship and signed letters of agreement to implement each year the Sustainable Youth Internships program with public hi
gh schools.
Other Partners - Title
1 Public High Schools: J.F. Kennedy High School, Richmond High School, Pinole High School
all serve City of San Pablo residents and will be the core schools that have partnership agreements signed with Earth Team to implement hands on environmental education internship programs now and in the future. They will provide a te
acher liaison and access to classroom space, cooperating also with the recruitment of the project interns. Earth Team has a long-term relationship and signed letters of agreement to implement each year the
Sustainable Youth Internships program with all proposed public high schools.
The proposed program supports EPA ’s Strategic Plan Goal 2, Objective 2.2 because is a student-led community project with a primary focus on youth learning and training on how to build awareness on the impacts of COVID-19 in their homes. All project tasks are designed to increase COVID-19 literacy amongst underserved youth, and thus increasing community participation in the strategies to improve measures to understand and prevent contagion and illness, developing necessary skills to (1) understand virus es, (2) analyze air pollution and virus incidence on and off campus, (3) use data collected to create and disseminate key content, (4) implement on and off campus-wide education and outreach campaigns to combat COVID-19 misinformation, increase testing and vaccination rates. The project activities support the federal Clean Air Act.
24 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 6 2 PROJECT ACTIVITIES / MILESTONE SCHEDULE / DETAILED BUDGET NARRATIVE f) Project Activities and Outputs (includes performance measures as Indicators) TASK 1. CO-ACT Teams Recruitment, Education and Training
1. Project Planning with Partners
• Fall planning: the City of San Pablo and Earth Team staff meets with school’s academy staff and project partners to develop the plan for the year and create a final project calendar.
2. CO-ACT Internship Participant Recruitment
• Initial project presentation: Earth Team staff in coordination with school partners’ designated lead teachers prepares a project PowerPoint presentation of the internship and schedules 15-30 min presentations to at least
15 classrooms on-campus, reaching out to 1,000 students in 3 campuses. • Applications: interested students fill an online application and initial survey (sample available).
Normally we receive over 300 applications each year).
• Interviews: Applic
ants are scheduled for a 10-minute phone interview with Earth Team staff, further assessing eligibility and interest.
• Final selection and enrollment: Earth team staff discusses all applicant interviews and finally selects 15 interns per school to be enrolled as paid interns for 1 year. Total 3 teams, or 45 students.
Intern stipends of $500 per student/yr. will be provided as an incentive as well as for career training and job skills-- students learn to document and manage their time, behave professionally, work as a team to accomplish a common goal, etc. Interns receive a completion certificate at the end of the project, listing all learning and training activities, totaling over 120 contact hours per student.
TASK 2. CO-ACT LEADERSHIP TEAMS Education and training activities (CURICULUM)
Leadership Team Activities
§ Monthly curriculum updating leadership team about the most recent developments and scientific updates related to COVID-19
§ Environmental and health justice workshop: how and why does COVID-19 disproportionately impact communities of color?
Outreach Activities
§ Distribution at schools and online of multi -lingual basic resource guide with links to state and local health w
ebsite
s and useful infographics
§ Creation and distr
ibution of animated short about how the virus spreads
Task 1 Indicators / Outputs
• 120 hours per year of contact time per intern
• 5,040 impressions per year for the internship component (contact hours, or total students x hours) • 56 hours of hands-on COVID-19 impacts specific STEM skills development, GLOBE framework data collection and analysis protocols
• 8 hours of human and environmental health careers exploration as a motivational factor, including interest profiling and interaction with professionals in both classroom and field settings !"#$% &'& ()*+,-./0 1
! What is a virus
! How is COVID-19 spreading: transmission mechanisms
! The case of Patient Zero
! Human health/ virology guest speaker
25 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 7 Outreach Activities
§ Flyers posted around schools and online about mask fitting and sanitation and handwashing technique § Students develop local maps showing vaccine and test sites § Interns use Scratch to cr
eate online games that teach hygiene and sanitation pr actices § Interns create videos and T
ikToks based om research that show to identify fake news about vaccines • Intern teams will collect data from local sources including Contra Costa Health Services about COVID19 cases, vaccination rates and more.
• 2-minute educational video to be shown at 3 high school career academies and online High School Capacity Building Campaigns
• CO-ACT leadership teams maintain contact via peer to peer education, lunch rallies, in-class presentations and assemblies, helping environmental academies and clubs to build capaci ty for long- term COVID-19 resilience and impacts. Curriculum, data sets, research posters, and videos will be made available t
o academy
Indicators
• 1 Curriculum package and media kit shared with academies to build capacity for relevant, sustained education in the long-term and as a basis for
continued experiential learning in academies
!"#$ %& !"#$% !"##$%&' "%( &'()(*+,-* ".+'(/01
Once leadership teams have documented the issues at hand, the next step will be to disseminate this information on-campus, engaging and educating the entire population at 3 campuses:
!"#$%&
! How viruses spread
! Use of PPE: masks/ gloves
! Proper hygiene and hand washing
Air door quality and ventilations
!! Food/Produce handling
! Packaging handling and disposal
! Va ccine science, safety , and how to identify fake news ! Te sting sites and availability
!"#$"%&'() *"#+ ,-.(/(.("&
! Fundamental hygiene lessons: mask etiquette and the science of PPE ! Interns research science about how viruses spread and what other conditions increase susceptibility ! Interns research how to safely navigate public places including grocery stores and school ! Interns research different vaccines, why and how they work, why they are not risky or "untested/ unapproved"
!"#$%&'()*
• Analysis and creation of contents of publicly available CCHS health data !"#$%&'()*+
• , ("-%&./0 * 1#0%&'$(" % &./&$2"* /1) 31&) '&) 21'$"2 ,4555 *'0#1"'*63) 7 to increase vaccination rates and use of proper PPE.
COVID-19 Knowledge Data Collection
• Use data from CC Health Services to disseminate information to community members. 26 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 8 Leadership Team Activities
§ Students research and log all local COVID-19 testing sites § St
udents research vaccine e
fficacy, recommendations, and where they are administered § EBRPD guest lecture on best practices when spending time outdoors and what local outdoor spaces are ope
n
§ Guest lecture on
the economic impacts of COVID-19
§ Workshop on mental health and mindfulness during SIP
§ Guest lecture on diet and immunity
§ COVID-land (like candy land) online board game about navigating the world during COVID-19 § Virt
ual art walk: interns and community create art at home and compile § At-home VR headsets using carboard and a smartphone (ie . https://arvr.google.com/cardboard/)
§ Outdoor, mobile cleaning supply workshops: wast
e reduction, self-sufficiency, sanitation etc.
Indicators
• 3 public presentations per year at Home Owner associations, PTA m eetings, local residential groups, or city events and1 local government presentation per year including City Council Meetings • 1 educational video: “COVID-19 Myth Busters
(2 minute)
• 20 posters for communication of project data, research and recommended actions TASK 5: Internet and COVID-19 Information Sources - – Activities and Indicators (Outputs) Topics
§ Elevating social media skills for CO-ACT project interns as community science ambassadors § Fake News Busters
§ Hot Spots accessibility and information access and distribution Leadership Team Activities
§ Workshop on understanding media bias and identifying trustworthy news sources § Guest speaker on media effectiveness, creating good content, and spotting fake news § Intern research project on the best ways to reach people and what makes media go viral (ie. Which platforms, video length, word to image rations etc.)
!"#$ %& '()*+,+- ./ ',0( 1,.2 3456789:! "#$%& '() *+,-. /'.0'(+1 !
!
!
!
!/A,<=
Virus Smart practices
W orking from home best practices
Understanding your emotions and improving mental health during SIP events Diet and its impacts on immunological strength
!"#$%&'( )'#*+*#*%,
! Student map of all COVID-19 test sites based on research ! “Just Covid Things”, a comedy series of short snippets about navigating new habits ! Students create and distribute a consolidated guide of open outdoor spaces in their community and a “How to Enjoy Nature” song/ infographic
! Distribute a screen-recorded video and multi-lingual guide about how to apply for unemployment and other benefits/ small flyers to be distributed informing people about the benefits they are eligible for ! Instagram “zines” about work/ study from home best practices for productivity ! Creation and distribution of affordable, COVID friendly meal plans and shopping lists 27 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 9 Outreach Activities
§ YouTube and Instagram videos on Fake News Busting
§ Distribute guides to families about identify
ing science-backed information vs disinformation
§ Create and distribute a game that has you identify fake news stories, like bingo § Compile
d list of multi-lingual, culturally relevant and trustworthy news sources
Leadership Team Activities
§ Lesson on how habitat destruction (defor estation, increased agriculture etc.) increase spread of
impacts in
door air
quality
!"#$ %& '()*+,(-.(/01 2-31*40/*,(5 ,6 7892:;<= ; "4/*)*/*.5 0(> 2(>*40/,+5 ?8@/3@/5A !,3*45
! Air pollution and exacerbation of respiratory conditions ! Indoor air quality during SIP
zoonotic viruses
! Workshop on how poor air quality exacerbates health conditions and respiratory infections Guest speakers from BAAQMD
! Students track indoor air quality using Pocket Lab and research how staying home in confined spaces !"#$%&'( )'#*+*#*%,
! Distribution of educational materials addressing intersection of climate change, human health, air quality, and viral illnesses
28 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 10 h) Itemized Budget Sheet / Budget Narrative (attached as “Other Attachment”) 3 ENVIRONMENTAL RESULTS
i) Environmental Results -Outputs/Outcomes (Logic Model attached as “Other Attachment”)
j) Performance Measurement Plan
Project Goals
(What are you
measuring?)
Measurement Tools and Methods
(How are you measuring it?)
Targets
Tools: What will you use as a ruler to measure
the target?
Public understanding of the benefits
reliable COVID-19 information.
Method: How will the Measurement Tools be
used to measure the target?
Public outreach campaigns
The City will leverage a comprehensive
public outreach strategy to engage the
public.
The City will use Earth Team’s
internship program to create and
distribute bi-lingual mailers, e-news,
Electronic Targets:
500 visitors to the project
pages/blogs
3 blog posts per month in
project webpage
In-person targets:
3 public-high school-based
leadership teams
g) Milestone Schedule and Workplan: Tasks and Activities To deliver the outcomes listed in the previous section, the project schedule for the CO-ACT internship component includes up to 40 work sessions per year per team (32 sessions on a weekday and 8 extended sessions on 1 Saturdays per month) , totaling at least 120 contact hours per intern, distributed as follow per the school-year calendar: (AS= afterschool meetings). Following schedule repeats each year starting in August
Increase in
public interest
and awareness
of COVID-19
information,
and learning
to identify and
stop dis
information
and mis
information
• 32 Project Blog Posts per year including CO VID information events, statistics, best practices, challenges and successes using photos, data and video to communicate progress and invite peers, teachers, families, local businesses and the general public. 29 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 11 Project Goals
(What are you
measuring?)
Measurement Tools and Methods
(How are you measuring it?)
Targets
handouts and “pop-up” informational
tables and interacti
ve exhibits at local
businesses/events to inform people
about the Project. Use existing
relat
ionships built by Earth Team with
local groups and door-to-door outreach
by Earth Team int
erns to inform
residents about the opportunity to be
involved in the design process.
45 youth participants in
service l
earning-activities
5,400 hours of paid contact
hours with project student-
interns
200 hours of door-to-door
outreach performed
20 posters with COVID-19
information
60 hours of COVID-19
information content design
and dissemination to the
public
School /
Project
Team
Number
of
Student
Interns
After
School
Meetings
Campus
Outreach
Events
Public
Outreach
Events
Educational
Materials/
Exhibits
Peer Students
Reached by
Interns
Community
Households
Reached by
Interns
Richmond
HS 15 32 3 2 2 1,000 1,000
JF Kennedy
HS 15 32 3 2 2 1,000 1,000
Pinole
Valley HS 15 32 3 2 2 1,000 1,000
Totals 45 96 9 6 12 3,000 3,000
CO-ACT Engagement Metrics for the Internship Component (per year) All meeting presentations and materials,
will be heavily advertised online so that
residents have the option to engage in
the way that works for them.
Increase best
practices for
prevention
and increase
vaccinations
and testing
rates in San
Pablo
Tools: What will you use as a
ruler to measure the target?
Data from the Contra Costa Health
Services on increased vaccination
rates.
Data from Contra Costa Health
Services on decreased cases of
COVID.
Increas e of 5% in
vaccination rates in
the Ci ty
of San
Pablo, each year.
Decrease
of 10% in
total reported
cases of
COVID
30 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 12 k) Cumulative Impacts
This project will increase local understanding of the diverse and cumulative impacts of COVID-19 on the public health of underserved and vulnerable communities. This project will specifically serve these communities in San Pablo and Richmond through targeted multi-lingual outreach. Educational efforts will include mapping COVID-19 test sites which will increase testing rates in vulnerable communities of color, providing continued insight into direct impacts of COVID- 19 on public health. Increased testing will allow us, at a local level, to better understand the spread of COVID- 19 and the rates at which it impacts undeserved community members. Mapping of test sites and provision of this data in a concise and accessible format will be critical in increasing capacity for testing and generally understanding direct impacts of COVID- 19 . information will help us better understand the secondary impact s of COVID- 19 on publ ic health, which we anticipate as decreased income, lack of access to fresh healthy foods, and interactions with existing health conditions that may exacerbate respiratory illness. This project will also include localized audits of availability and use of household cleaners throughout underserved neighborhoods in San Pablo. l) Sustainability Plan and Environmental Justice Integration Climate Action Plan- In 2012, the City developed a Climat e Action Plan that provides a policy framework to reduce our City's greenhouse gas emissions, while also promoting city improvements to increase livability, health and safety of our community.
Green Infrastructure Plan- Completed in 2019, the City’s Green Infrastructure Plan (GI Plan) guides a shift from convent
ional, existing “collect and convey ” storm drain infrastructure to a more resilient, sustainable storm
water management system that reduces runoff volumes, disperses runoff to vegetated areas, harvests and uses runoff
where feasible, promotes infiltration and evapotranspiration, and uses natural processes to detain and treat runoff. The GI Plan includes: a defined prioritization pr ocess for identifying projects, t argets for the amount of im
pervious surface to be retrofit, guidelines for project design, standard de signs and specifi cations, and sizing requirements.
San Pablo Bicycle and Pedestrian Master Plan- Completed in 2017, t he purpose of t he Bicycle and Pedestrian Master Plan is to (1) identify exist ing routes and gaps in routes or sidewalks that are used by bicyclist
s and pedestrians for travel or rec reational activity and (2) compete for funds to invest in or enhance additional infrastructure. This Plan identifies ways to improve bike and pedestrian infrastructure to e ncourage active living
.
AB 617: Community Air Protection Program (CAPP): San Pablo and Richmond Community Air Monitoring Plan. In response to Assembly Bill (AB) 617, the California Air Resources Board established the Community Air Protection Program (CAPP). The CAPP’s focus is to reduce exposure in communities most impacte
d by air pollu tion. The City has b een involved in the development of the community air monitoring plan. Data collected from these monitoring plans will inform future community-based emissions reduction plans.
Sub awardee EJ integration efforts : Earth Team has been working for 25 years with a wide network of nearly 100
high schools to help build capacity at the California Partnership Academies to design and sustain project-based learning opportunities in the field of environmental education to underserved youth. They have signed letters
of agreement with a dozen career academies and pathways to continue wor k towards thi s goal in the future. Aligning positive youth development with community development is at the core of Earth Team’s 31 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 13 strategy to expand stewardship. Underserved Title 1 high schools need better afterschool programs to sustain this vision of the schools
being agents of change in the communit y. We need to build more capacity in public high sc
hools for engagem
ent of diverse student populations in the environmental sciences and buil d a better framework for environmental education that goes beyond empowerment and generates c ommunity support and true coll
abora
tive conservation and participation.
4 PROGRAMMATIC CAPABILITY
m) Staff Experience / Qualifications of Project Manager Project Manager, Sar
ah Kolarik, Environmental Program Analyst. Ms. Kolarik has 4 years of experience in developing and
delivering various environmental and outreach programs for the City of San Pablo. Ms. Kolarik has managed
various environmental and community outreach projects, including leading community outreach for the City's ongoing Bicycle and Pedestrian Corridor Study, Safe Routes to School Master Plan, Cleaner Contra Costa and more. As part of this project, Ms. Kolarik will coordinat e with Earth Team for project reporting, outreach, invoicing and ensure all City policies and procedures are met.
Management Analyst,
Chiara Hanna, has over 20 years public sector experience, including 17 years working as a Utility Analyst for Alameda M
unicipal Power at the City of Alameda in their Engineering & Operations Division. Ms. Hanna i
s the Management Analyst and procurement/grant administrator for t he Public Works Department
with responsibilities including ensuring compliance with all grant agreement policies and procedures, maintaining a record system for grant expenditures and required documentation, and ensuring timely status-reporting and preparation of final close-out documentation.
Manuel
Alonso, Earth
Team’s Executive Director, has a Ph.D. in Cultural Anthropology and has worked inter
nationally for 20 years in executive positio ns with many environmental nonprofits, successfully managing award winning projects and numerous governmental and foundation grant programs in the US, Europe, Central and South Americ
a.
Joelle Alley, Earth Team’s Program Director, graduated from the University of California Santa Barbara with a degree
in Environmental Studies. She focused her studies on environmental policy, primarily in relation to agriculture and water resource management. Whil e living in Santa Barbara, Joelle worked as an outdoor educator at a
local
sustainable agriculture nonprofit called Fairview Gardens. She also worked as the re gional intern at the
Ventura, CA office of Califor nia Trout. During her last year as a student, Joelle s pent the majority of he
r time r
esearching for and writing her thesis about the implementat ion of t he Sustainable Groundwater Management Act
in California.
Itzel Gomez, Earth Team
Campus Coordinator, she graduated from the University of California, San Diego with a degree in Environmental Engineering. In college, she developed an interest in topics in hydrology and water resources as well as environment al justice issues related to water quality and conser vation. During her time as a student she served as Outreach Chair for the UCSD Society of Hispanic Professional Engineers (SHPE) where she was able to foster her passion for encouraging youth of color to pursue careers in STEM fields. Itzel was born and
raised in San Pablo, CA and knows the East B ay to be her home. n) Expenditure of Awarded Grant Funds
The City of San Pablo has an experienced team of project management, finance and administrative staff to help administer the grant funds. The Public Works Department has w eekly staff meet ings to get updates on projects and discuss any issues or
upcoming reporting requirements. The City of San Pablo has deve loped policies and procedures for the complete efficient and effective delivery of grant projects. These policies and procedures include the development
of extensive checklists, delivery milestones, project schedules, contracting r
equir
ements and more. The Environmental Program Analyst will be dedicated to ensure all reporting requirements are me
t within the desired timeframe. This Environmental Program Analyst will work with the 32 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 14 Public Works' Management Analyst, project partners and the consultants to ensure reports are complete and accurate.
Sub awardee Earth Team has been operating successfully for 25 years and has developed excellent information systems
and detailed financial control policies and procedures. As a recipient of other Federal awards, we have a fund-accounting
system, clear policie s to control allowable expenses, allocate cost ledgers on a monthly basis, separate general and participant costs, separate dire ct and indir ect costs. We employ an accountant/CPA and have an active Finance Committee with expe rtise in non-profit financial matters and FAR compliance. During the proj
ect we will produce monthly job-costing r eports detailing all expenses against the approved EPA budget and w
ill make sure that no draw downs are executed that exc eed the total allowable expenses for the period. 5 PAST PERFORMANCE
The City of San Pablo has experienced outreach, environmental, administration and finance staff that will administer the
Project and manage the grant funds. The Public Works De partment has weekly staff meetings— in addition to frequent staff coordination—to disseminate Project updates, discuss upcoming reporting requireme
nts and address any potential issues. A Management Analyst will be dedicated to the Projec t in order to ensure
that all reporting requirements are met within the required timeframe. This Management Analyst will work with the Environmental Services and Engineering Divisions, Finance Department, contractors and others to
ensure reports are complete and accurate. As with all capital improvement projects, a checklist of require
ments and delivery milestones will be cr eated at the star t o f the Project to ensure that no requirements are m
issed. Below are examples of similar grant-funded projects that have bee n delivered by the City.
Past Grant-Funded Projects:
Rumrill Sports Complex- In 2013/2014, the C ity received over $4 million in funding from the US EPA (Brownfie
lds Cleanup Cooperative Agreeme nt), Proposition 84 and Measure WW to fund a contaminated site cleanup and development of a public sports park. This project provided funding to clean up the Burlington Northern Santa Fe (BNSF) railroad track brownfield site and conduct community outreach related to the cleanup activities. In total, 4.5 acres were cleaned and redevelope d as the Rumrill Sports Complex. This was a complex pr
oject with multiple funding sources; however, the City completed the project and met all of the reporting requirements from the different funding and regulatory agencies. Agreement requirements included:
quarterly
reports, final reports, affiliation signage, community education and involvement, additional written reports
when requested, financial records for auditing purposes and inclusion of green featur e designs where possible.
23rd Street-Wildcat
Creek Trail- In 2015, the City comple ted construction on the 23rd Street-Wildcat Cr eek Trail. The Cit
y received $460,000 from the California Natural Resources Agency (CNRA) to construct an eight- foot wide asphalt t
rail along an 840-foot segment betw een 23rd Street and Davis Park. The project included a t
rail, pe
destrian bridge, lighting, safety improvements and riparian habitat restoration. The City completed the project
on time and met all of the reporting a nd regulatory requirements. Agreement require ments included: site visits, inspec
tion reports, ongoing monitoring, affiliation and educational signage, additional written reports when requested and financial records for auditing purposes.
El Portal Greening Project-
In 2017, the City received $562,000 in funding from CNRA to build green infrastructur
e and a bike lane on El Portal Drive. This project has completed all grant requirements and was completed in 202
0. Wildcat Creek Restoration & Greenway Trail- In 2017, the City received $689,000 in funding from CNRA to restore a
2,000 linear-foot section of Wildcat Creek and build a creekside trail for bicycles and pedestrian s.
This project has comple
ted all grant requirements to date and was completed within budget in summer 2021.
Current Grant-Funded Projects:
Rumrill Complete Green Streets- In 2016 the City received $864,000 from EPA to construction green infrastructure on Rumrill Boulevard and deliver trash reduction and education to the public. The City has partnered with Earth Team’s Sustainable Youth Internships (SYI) program to deliver hands-on environmental education, training and community outreach. Several teams of high school students have been recruited and trained to help restore local watersheds through yearlong service-learning projects in support of the Complete 33 EPA-OP-OEJ-20-02 CFDA.66.312 SEJCA / COVID-19 PROJECTS 15 Green Streets project. Students are trained in specific project-based skills and will conduct a range of scientific and environmental monitoring techniques including litter surveys and trash assessments, restoration techniques, and more. Agreement requirements included: site visits, inspection reports, ongoing monitoring, affiliation and educational signage, additional written reports when requested and financial records for auditing purposes.
Sub Awardee Earth Team
Past Performance
Earth Team projects focus on environmental sustainability and how communities can learn to minimize required inputs of energy, water and food, and better manage wast e and outputs of heat, air pollution and water
pollution. The organization has 25 years of experience and has received federal, state, county and local grants
w
ith successful management and reporting completion in 100% of the awards. Earth Team has over 50 communi
ty partners and we provide environmental education services to Contra Costa and Alameda Counties, as well
as several municipalities.
Table: Sub Awardee Earth Team Latest Projects / Completed Reports 6 QUALITY ASSURANCE PROJECT PLAN (QAPP) Information
The project will not involve the use of existing of environmental data or the collection of new scientific data.
All data collected by students is for training and learning purposes only and will not follow any valid established standard sampling or analysis protocols, nor will be used for any formal recommendations on environmental decisions.
34 COLA
3.0%
FTE
Years 1-2
Annual
Salary Year 1 Year 2 Project Cost
7% 103,000$ $ 7,210.00 $ 7,426.30 $ 14,636.30 4% 101,000$ $ 4,040.00 $ 4,161.20 $ 8,201.20 11,250.00$ 11,587.50$ 22,837.50$
Rate
23.0% 2,587.50$ 2,665.13$ 5,252.63$
13,837.50$ 14,252.63$ 28,090.13$
$ - $ - $ - $ - $ - $ - No. Amount
4 $500 2,000$ 2,000$ 4,000$
2 $500 1,000$ 1,000$ 2,000$
10 $150.00 1,500$ 1,500$ 3,000$
4,500$ 4,500$ 9,000$
$ - $ - $ - $ - $ - $ - No. Amount Year 1 Year 2 Total
4 $125 500$ 500$ 1,000$
1,500$ 1,521$ 3,021$
75,517.37$ 76,761.02$ 152,278.39$
77,517.37$ 78,782.02$ 156,299.39$
95,854.87$ 97,534.65$ 193,389.52$
10% MTDC 2,055.24$ 2,055.24$ 4,110.48$
Total Year 1 Total Year 2 Total Project
97,910.11$ 99,589.89$ 197,500.00$
Total Other
Total Direct Costs
i. Indirect Charges
Budget Total
Total Supplies
f. Contractual
g. Construction
h. Other
Computer Use Fees
Subaward - Earth Team
Transportation of COVID materials
d. Equipment
e. Supplies
Materials for COVID-19 outreach
Rentals of existing COVID-19 outreach materials
Maintenance/upgrades of existing outreach materials
b. Fringe Benefits
Total Fringe
Total Personnel & Fringe
c. Travel
Chiara Hanna, Grants Manager
Total Personnel
Subaward Budget Detail
City of San Pablo - CO-ACT - October 1, 2021 to September 30, 2023 a. Personnel
Sarah Kolarik, Project Manager
35 COLA
3.0%
FTE
Years 1-2
Annual
Salary
Year 1 Year 2 Project Cost
2% 75,000$ $ 1,500 $ 1,545 $ 3,045
10% 60,000$ $ 6,000 $ 6,180 $ 12,180 20% 50,000$ $ 10,000 $ 10,300 $ 20,300 20% 40,000$ $ 8,000 $ 8,240 $ 16,240 20% 26,250$ $ 5,250 $ 5,408 $ 10,658 10% 34,200$ $ 3,420 $ 3,523 $ 6,943 34,170.00$ 35,195.10$ 69,365.10$
Rate
17.0% 5,808.90$ 5,983.17$ 11,792.07$
39,979$ 41,178$ 81,157$
3,200 miles 0.58 1,840$ 1,840$ 3,680$
8 trips $250 per trip 2,000$ 2,000$ 4,000$
3,840$ 3,840$ 7,680$
$ - $ - $ -
No. Amount
56 $8 448$ 448$ 896$
56 $5 280$ 280$ 560$
600 $0.50 300$ 300$ 600$
1,028$ 1,028$ 2,056$
50 hrs/yr. $40/hr. 2,000$ 2,000$ 4,000$
$ - $
-
$ -
Year 1 Year 2 Total
12 months $203/month 1,476$ 1,520$ 2,996.28$
45 interns/yr.
@ $500 / yr. 22,500$ 22,500$ 45,000$
-$ -$
23,976$ 24,020$ 47,996$
70,823$ 72,067$ 142,889$
10% MTDC 4,694$ 4,694$ 9,389$
Total Year Total Year Total
75,517$ 76,761$ 152,278$
Total Other
Total Direct Costs
i. Indirect Charges
Budget Total
Total Supplies
f. Contractual (accountant,
bookkeeper)g. Construction
h. Other
Computer Use Fees / Field Tablets
Student-Intern Yearly Stipends
Total Travel
d. Equipment
e. Supplies
Educational Supplies (per student)
Field supplies (per student)
Flyers and posters
b. Fringe Benefits
Total Fringe
Total Personnel & Fringe
c. Travel
Staff Mileage
Student Transportation /
Jolle Alley, PI, Program Director
Itzel Gomez, Lead Educator, Campus
Ben Mc Laughlin, Lead Educator,
Assistant Educator 1, Campus Coord.
M. Smythe, Logistics/IT Manager
Total Personnel
Subaward Budget Detail
Subaward: Earth Team – CO-ACT - October 1, 2021 to September 30, 2023 a. Personnel
Manuel Alonso, CoPI, Executive
36 Description Total
Personnel Project Manager @ $103,000 annual salary X 7% of time on project = $14,636 for two years, Grants Manager, @ $101,000 annual salary x 4% of project time = $8,201 for two years.
$22,837
Fringe Benefits Project Manager @ 23% of salary (includes medical, dental, life insurance) = $2,588 for two years; Grants Manager 23% of salary (includes medical, dental, life insurance) = $2,665
$5,253
Travel Updated to zero travel for City of San Pablo as a result of increased use of virtual meetings and outreach strategies.
$0
Equipment (for
purchases greater
than $5,000 per unit)
N/A $0
Supplies Materials for developing COVID-19 interactive and/or virtual outreach, 4 exhibits/displays/other @ $500 = $2,000 per year; Rental of existing outreach materials, 2 exhibits/displays/other @ 500 = $1,000 per year; Maintenance and upgrade of materials per community feedback, 10 upgrades @ $150 = $1,500 per year.
$9,000
Contractual N/A $0
Indirect Costs 10% of the MTDC base of $41,111 $41,111
Other Subaward = $75,517 year 1 and $76,761 year 2 = $152,278 (details of deliverables for subawardee provided in grant narrative and in separate budget) $152,278
Total $197,500
37 38
2022
39 30th
Estimated Budget of Annual Costs for the Internship
40 41
F. Project Funding
MEMORANDUM OF UNDERSTANDING (MOU) FOR SERVICES
EarthTeam and John F. Kennedy High School
Sustainable Youth
Work-Based Learning Internship Program
2017-2018
Purpose and Intent
Scope of Work
Earth Team staff will facilitate 36 weekly meetings with a team of ten to fourteen (10-14) student interns to implement a work-based learning after-school program for students at John F. Kennedy High School. Each student will be required to attend all on- campus after school meetings and all off-campus and weekend field outings throughout the year. Each intern will receive a minimum of 100 hours/yr. of education, training and work-based learning opportunities participating in one or more of our three main project areas: Climate Change (CAP), Watershed Restoration (RAP) and Waste Reduction (WAP).
Earth Team will provide the following programming/services:
A dedicated staff person (acting as onsite Campus Coordinator) to lead and implement the internship program, including one or two recruitment visits (with the help of school staff) and up to 34 weekly (2 hours) after-school meetings, including a minimum of 8 off-campus field trips, a minimum of 4 weekend activities (4-6 hrs. on Saturdays), one overnight camping trip and any other activities described in attached Program Schedule (Exhibit A).
Education materials, research instrumentation, field materials and outreach materials.
Transportation for student off-campus events and all field trips during the year.
A stipend of $400/yr. payable to all participating student-interns that meet program requirements.
Earth Team will work with school staff on the following activities:
Secure approval for any physical installations and events for all on-campus project activities in accordance with school policy.
Coordinate with school staff, students and parents all off-campus trips.
Align work-based learning activities with existing school curriculum in coordination with teachers when possible to enhance informal STEM learning opportunities and the development of valuable career, 21st Century and social-emotional skills.
John F. Kennedy High School will provide the following assistance for programming/services:
Classroom space for meetings on campus, access to media carts when needed A lead teacher/school staff person acting as main liaison between Earth Team staff and school staff and faculty to assist with initial recruitment Timely communications to facilitate program implementation via agreed upon channels.
Participation in at least 2 planning meetings per year with Earth team Staff (usually recruitment in early fall and evaluation/follow up in late spring) Assist with recruiting one team of 10-14 paid student-interns, facilitating access to several short class presentations (5 to 10 mins.). Earth Team reserves the right to make final decisions regarding enrollment.
Board of Directors
Mark Westwind, President
Westwind Associates
Paul Wicks, Secretary
Ridecell
Vladimir Foronda,
Treasurer
UC Davis
Tracy Ostrom
UC Berkeley CCASN
John Steere
Contra Costa County
Manuel Alonso-Martinez
Executive Director
Advisory Board
Joe McBride
UC Berkeley
Katharine Barrett,
Emeritus
UC Botanical Gardens
(retired)
Michele Perrault,
Emeritus
Sierra Club
Whitney Dotson
East Bay Regional Park
District
Doug Karpa
Karpa Land Use
Michelle Korpos
PG&E
Office
1301 South 46th Street,
Building 155
Richmond, CA 94804
Tel. 844-704-4030
[email protected]
Connect
Instagram @EarthTeam
Facebook @EarthTeam
Twitter @ETnetwork
This Agreement is e ntered into by Earth T eam and John F . Kennedy High School. The purpose and intent of this MOU is to establish the terms of reference to implement a work-based learning afterschool internship program with John F . Kennedy High School during the period between July 1st, 2017 and June 30, 2022 following the overall goals of Earth T eam’s Sustainable Y outh Program as described in the Letter of Agreement (LOA)
43 2
www.earthteam.net
[email protected]
All program expenses will be compensated by Earth Team’s according to its general budget appropriations per mutually agreed budget (Paragraph D).
We encourage the school to provide matching funds for these categories: student transportation (field trips), intern-stipends and program supplies. School matching funds are optional but recommended.
School cash or in-kind contributions will be reflected in the School Match column below and Earth Team will invoice the school for these contributed funds in December and May of each year.
G. Project Budget
Personnel Hours/Unit
s Rate Earth Team School
Match Total Match
Type
Earth Team
Executive
Director
20 $65 $622 $- $622
Earth Team
Program
Manager
75 $35 $2,070 $- $2,070
Earth Team
Campus
Coordinator
400 $30 $12,000 $- $12,000
School Staff $-
SubTotal $14,692 $0.00 $14,692
Other Direct
Costs Units Rate Earth Team School
Match Total
Student
Stipends 12-14 400 $4,800 4,800
Program
Supplies
2 $500 $1,000 $1.000
Food, snacks 50 $10.00 $500 $500
Student
Transportation
(bus/van)
12 $250 $3,50
0 $3,500
Staff Mileage 750 $0.56 $420 $420
Media (photo,
video editing) 10 $50 $500 $500
Printing and
Copying 300 $0.50 $150 $150
Sub Total $10,870 $10,870
44 45
46 47
OMB Number: 2030-0020
Expiration Date: 04/30/2021
EPA KEY CONTACTS FORM
Authorized Representative: Original awards and amendments will be sent to this individual for review and acceptance, unless otherwise indicated.
Name: Prefix: Mr. First Name: Matt Middle Name:
Last Name: Rodriguez Suffix:
Title: City Manager
Complete Address:
Street1: 1000 Gateway Avenue
Street2:
City: San Pablo State: CA: California
Zip / Postal Code:94806 Country: USA: UNITED STATES
Phone Number: 5102153016 Fax Number: 5102153011
E-mail Address: [email protected]
Payee: Individual authorized to accept payments.
Name: Prefix: Mr. First Name:Erick Middle Name:
Last Name:Cheung Suffix:
Title: FINANCE DIRECTOR
Complete Address:
Street1: 1000 Gateway Avenue
Street2:
City: San Pablo State: CA: California
Country: USA: UNITED STATES
Fax Number: 510-215-3013
Zip / Postal Code: 94806
Phone Number: 510-215-3020
E-mail Address: [email protected]
Administrative Contact: Individual from Sponsored Programs Office to contact concerning administrative matters (i.e., indirect cost rate computation, rebudgeting requests etc).
Name: Prefix: Ms. First Name: Chiara Middle Name:
Last Name:Hanna Suffix:
Title: Management Analyst
Complete Address:
Street1:1000 Gateway Avenue
Street2:
City: San Pablo State: CA: California
Zip / Postal Code: 94806 Country: USA: UNITED STATES
Fax Number: 510-215-3013Phone Number: 5102153063
E-mail Address: [email protected]
EPA Form 5700-54 (Rev 4-02)
48 EPA KEY CONTACTS FORM
Project Manager: Individual responsible for the technical completion of the proposed work.
Name: Prefix: Ms. First Name: Sarah Middle Name:
Last Name:Kolarik Suffix:
Title:Environmental Program Analyst
Complete Address:
Street1:1000 Gateway Avenue
Street2:
City: San Pablo State: CA: California
Zip / Postal Code:94806 Country: USA: UNITED STATES
Phone Number:5102153068 Fax Number: 5102153013
E-mail Address:[email protected]
EPA Form 5700-54 (Rev 4-02)
49 1000 Gateway Avenue
San Pablo CA, 94806
510-215-3068
[email protected]
www.sanpabloca.gov/882/
Environmental-Programs
Sarah Kolarik
Environmental Analyst
City of San Pablo
Experience
Sarah Kolarik has 4 years of experience in developing and delivering environmental programs in the public sector. Sarah works in the Environmental Services Division of the Public Works Department for the City of San Pablo. As an experienced project manager, she has supervised many project teams comprised of staff, consultants and non-profits. As part of this work, Sarah has coordinated, facilitated and presented at meetings with large groups, technical advisors, and stakeholders.
Education
• B.S. Earth Systems, Stanford University, Stanford, CA Recent Major Projects
San Pablo Safe Routes to School (SR2S) Master Plan. The City’s SR2S Master Plan, in progress as of 2021, recommends engineering, education and engagement recommendations to make it safer and more enjoyable for youth to walk, bike and roll to school. The SR2S Master Plan includes 10 public and private schools, in and adjacent to San Pablo. Recommendations were developed through an extensive, bilingual community outreach process, including in-person walk audits, an online “do-it-yourself” walk audit, a temporary demonstration and collaboration with Contra Costa Health Services.
Sarah is the Project Manager for the SR2S Master Plan.
www.sanpabloca.gov/2693/Safe-Routes-to-School
San Pablo Bicycle and Pedestrian Corridor Study (Corridor Study).
The City’s Corridor Study, in progress as of 2021, builds upon the City’s Bicycle and Pedestrian Master Plan that was adopted in 2017.
The Corridor Study developed concept designs for 10 corridor segments that were identified as needing further study in the Bicycle and Pedestrian Master Plan. Through a comprehensive, bilingual outreach process— which included informative sidewalk stickers, an interactive online survey, community meeting presentations, paid partnerships with community based-organizations (CBO), a technical advisory committee (TAC), an online community meeting and a temporary demonstration— and a feasibility analysis, the Corridor Study developed preferred alternatives for future project construction. Sarah is the Project Manager for the Corridor Study. www.sanpabloca.gov/2665/Bicycle-and-Pedestrian-Corridor-Study 50 San Pablo Green Infrastructure Plan. Completed in 2019, the City’s Green Infrastructure Plan (GI Plan) guides a shift from conventional, existing “collect and convey” storm drain infrastructure to a more resilient, sustainable stormwater management system that reduces runoff volumes, disperses runoff to vegetated areas, harvests and uses runoff where feasible, promotes infiltration and evapotranspiration, and uses natural processes to detain and treat runoff. The GI Plan includes: a defined prioritization process for identifying projects, targets for the amount of impervious surface to be retrofit, guidelines for project design, standard designs and specifications, and sizing requirements. Sarah co-wrote the GI Plan.
www.sanpabloca.gov/2637/Green-Infrastructure-Plan
Cleaner Co
ntra Costa Challenge. The Cleaner Contra Costa Challenge is an online sustainable action platform that makes it easy and fun to take sustainable actions by giving residents helpful tips and free or low-cost resources for those actions. The Challenge tracks savings (in dollars and emissions) and provides residents with opportunities to engage with their neighbors and learn more about their community.
Sarah was San Pablo’s Project Manager for the Cleaner Contra Costa Challenge website launch and community outreach efforts. www.sanpabloca.gov/2600/Cleaner-Contra-Costa-Challenge
51 SECTION A - BUDGET SUMMARY
$
BUDGET INFORMATION - Non-Construction Programs OMB Number: 4040-0006 Expiration Date: 02/28/2022
Grant Program
Function or
Activity
(a)
Catalog of Federal
Domestic Assistance
Number
(b)
Estimated Unobligated Funds New or Revised Budget
Federal
(c)
Non-Federal
(d)
Federal
(e)
Non-Federal
(f)
Total
(g)
5. Totals
4. 3.
2. 1. $ $ $ $
$$$$
COVID-19 Action
Teams (CO-ACT) 197,500.00 0.00 197,500.00
197,500.00 0.00 197,500.00$
Standard Form 424A (Rev. 7- 97)
Prescribed by OMB (Circular A -102) Page 1
52 SECTION B - BUDGET CATEGORIES
7. Program Income
d. Equipment
e. Supplies
f. Contractual
g. Construction
h. Other
j. Indirect Charges
k. TOTALS (sum of 6i and 6j)
i. Total Direct Charges (sum of 6a-6h)
(1)
Authorized for Local Reproduction
Prescribed by OMB (Circular A -102) Page 1A
Standard Form 424A (Rev. 7- 97)
GRANT PROGRAM, FUNCTION OR ACTIVITY
(2) (3) (4) (5)
Total6. Object Class Categories
a. Personnel
b. Fringe Benefits
c. Travel
COVID-19 Action
Teams (CO-ACT)
22,837.50
5,252.63
0.00 9,000.00
0.00 156,299.39
193,389.52
4,110.48
197,500.00
22,837.50
5,252.63
0.00 9,000.00
0.00 156,299.39
193,389.52
4,110.48
197,500.00
$$$$$
$$$$$
$$$$$
$
$
53 SECTION D - FORECASTED CASH NEEDS
14. Non-Federal
SECTION C - NON-FEDERAL RESOURCES
(a) Grant Program (b) Applicant (d) Other Sources(c) State (e)TOTALS $
$
$ $ $
$
$
$
$
$8.
9. 10.
11. 12. TOTAL (sum of lines 8-11)
15. TOTAL (sum of lines 13 and 14)
13. Federal
Total for 1st Year 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter COVID-19 Action Teams (CO-ACT)
97,910.11
97,910.11
24,477.53
24,477.53
24,477.53
24,477.53
24,477.53
24,477.53
24,477.52
24,477.52
$ $
$ $ $
$ $ $ $
FUTURE FUNDING PERIODS (YEARS)
SECTION F - OTHER BUDGET INFORMATION
SECTION E - BUDGET ESTIMATES OF FEDERAL FUNDS NEEDED FOR BALANCE OF THE PROJECT Authorized for Local Reproduction
$
$
$ $
$
$16.
17. 18.
19. 20. TOTAL (sum of lines 16 - 19)
21. Direct Charges: 22. Indirect Charges:
23. Remarks:
(a) Grant Program
(b)First (c) Second (d) Third (e) Fourth
COVID-19 Action Teams (CO-ACT) 97,910.11 99,589.89
97,910.11 99,589.89
4,110.48193,389.52
$ $
Standard Form 424A (Rev. 7- 97)
Prescribed by OMB (Circular A -102) Page 2
54 Preaward Compliance Review Report for
All Applicants and Recipients Requesting EPA Financial Assistance Note: Read Instructions before completing form.
OMB Number: 2030-0020
Expiration Date: 04/30/2021
I. A. Applicant/Recipient (Name, Address, City, State, Zip Code) Name: City of San Pablo
Address:1000 Gateway Avenue
City: San Pablo
State: CA: California Zip Code: 94806
B. DUNS No. 1097383560000
II. Is the applicant currently receiving EPA Assistance? Yes No III. List all civil rights lawsuits and administrative complaints pending against the applicant/recipient that allege discrimination based on race, color, national origin, sex, age, or disability. (Do not include employment complaints not covered by 40 C.F.R. Parts 5 and 7.) None.
IV. List all civil rights lawsuits and administrative complaints decided against the applicant/recipient within the last year that allege discrimination based on race, color, national origin, sex, age, or disability and enclose a copy of all decisions. Please describe all corrective actions taken. (Do not include employment complaints not covered by 40 C.F.R. Parts 5 and 7.) None.
V. List all civil rights compliance reviews of the applicant/recipient conducted by any agency within the last two years and enclose a copy of the review and any decisions, orders, or agreements based on the review. Please describe any corrective action taken. (40 C.F.R. § 7.80(c)(3))
None.
VI. Is the applicant requesting EPA assistance for new construction? If no, proceed to VII; if yes, answer (a) and/or (b) below.
Yes No
a. If the grant is for new construction, will all new facilities or alterations to existing facilities be designed and constructed to be readily accessible to and usable by persons with disabilities? If yes, proceed to VII; if no, proceed to VI(b).
Yes No
b. If the grant is for new construction and the new facilities or alterations to existing facilities will not be readily accessible to and usable by persons with disabilities, explain how a regulatory exception (40 C.F.R. 7.70) applies.
VII. Does the applicant/recipient provide initial and continuing notice that it does not discriminate on the basis of race, color, national origin, sex, age, or disability in its program or activities? (40 C.F.R 5.140 and 7.95) Yes No
a. Do the methods of notice accommodate those with impaired vision or hearing? Yes No b. Is the notice posted in a prominent place in the applicant's offices or facilities or, for education programs and activities, in appropriate periodicals and other written communications? Yes No
c. Does the notice identify a designated civil rights coordinator? Yes No VIII. Does the applicant/recipient maintain demographic data on the race, color, national origin, sex, age, or handicap of the population it serves? (40 C.F.R. 7.85(a)) Yes No
IX. Does the applicant/recipient have a policy/procedure for providing access to services for persons with limited English proficiency? (40 C.F.R. Part 7, E.O. 13166) Yes No
55 X. If the applicant is an education program or activity, or has 15 or more employees, has it designated an employee to coordinate its compliance with 40 C.F.R. Parts 5 and 7? Provide the name, title, position, mailing address, e-mail address, fax number, and telephone number of the designated coordinator.
Yes.
Alicia Southern
HR Manager
1000 Gateway Avenue
San Pablo, CA 94806
510-215-3002\510-215-3011
[email protected]
XI. If the applicant is an education program or activity, or has 15 or more employees, has it adopted grievance procedures that assure the prompt and fair resolution of complaints that allege a violation of 40 C.F.R. Parts 5 and 7? Provide a legal citation or Internet Address for, or a copy of, the procedures.
A copy of the procedure is attached to this application.
For the Applicant/Recipient
I certify that the statements I have made on this form and all attachments thereto are true, accurate and complete. I acknowledge that any knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law. I assure that I will fully comply with all applicable civil rights statutes and EPA regulations.
A. Signature of Authorized Official
Sarah Kolarik
B. Title of Authorized Official
City Manager
C. Date
08/18/2021
For the U.S. Environmental Protection Agency
I have reviewed the information provided by the applicant/recipient and hereby certify that the applicant/recipient has submitted all preaward compliance information required by 40 C.F.R. Parts 5 and 7; that based on the information submitted, this application satisfies the preaward provisions of 40 C.F.R. Parts 5 and 7; and that the applicant has given assurance that it will fully comply with all applicable civil rights statures and EPA regulations.
A. *Signature of Authorized EPA Official
B. Title of Authorized Official C. Date
56 * See Instructions
Instructions for EPA FORM 4700-4 (Rev. 06/2014)
General. Recipients of Federal financial assistance from the U.S. Environmental Protection Agency must comply with the following statutes and regulations.
Title VI of the Civil Rights Acts of 1964 provides that no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance. The Act goes on to explain that the statute shall not be construed to authorize action with respect to any employment practice of any employer, employment agency, or labor organization (except where the primary objective of the Federal financial assistance is to provide employment). Section 13 of the 1972 Amendments to the Federal Water Pollution Control Act provides that no person in the United States shall on the ground of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under the Federal Water Pollution Control Act, as amended. Employment discrimination on the basis of sex is prohibited in all such programs or activities. Section 504 of the Rehabilitation Act of 1973 provides that no otherwise qualified individual with a disability in the United States shall solely by reason of disability be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance. Employment discrimination on the basis of disability is prohibited in all such programs or activities. The Age Discrimination Act of 1975 provides that no person on the basis of age shall be excluded from participation under any program or activity receiving Federal financial assistance.
Employment discrimination is not covered. Age discrimination in employment is prohibited by the Age Discrimination in Employment Act administered by the Equal Employment Opportunity Commission. Title IX of the Education Amendments of 1972 provides that no person in the United States on the basis of sex shall be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving Federal financial assistance. Employment discrimination on the basis of sex is prohibited in all such education programs or activities. Note: an education program or activity is not limited to only those conducted by a formal institution. 40 C.F.R. Part 5 implements Title IX of the Education Amendments of 1972. 40 C.F.R. Part 7 implements Title VI of the Civil Rights Act of 1964, Section 13 of the 1972 Amendments to the Federal Water Pollution Control Act, and Section 504 of The Rehabilitation Act of 1973. The Executive Order 13166 (E.O. 13166) entitled; "Improving Access to Services for Persons with Limited English Proficiency" requires Federal agencies work to ensure that recipients of Federal financial assistance provide meaningful access to their LEP applicants and beneficiaries.
Items “Applicant” means any entity that files an application or unsolicited proposal or otherwise requests EPA assistance. 40 C.F.R. §§ 5.105, 7.25. “Recipient” means any entity, other than applicant, which will actually receive EPA assistance. 40 C.F.R. §§ 5.105, 7.25. “Civil rights lawsuits and administrative complaints” means any lawsuit or administrative complaint alleging discrimination on the basis of race, color, national origin, sex, age, or disability pending or decided against the applicant and/or entity which actually benefits from the grant, but excluding employment complaints not covered by 40 C.F.R. Parts 5 and 7. For example, if a city is the named applicant but the grant will actually benefit the Department of Sewage, civil rights lawsuits involving both the city and the Department of Sewage should be listed. “Civil rights compliance review” means any review assessing the applicant’s and/or recipient’s compliance with laws prohibiting discrimination on the basis of race, color, national origin, sex, age, or disability.
Submit this form with the original and required copies of applications, requests for extensions, requests for increase of funds, etc. Updates of information are all that are required after the initial application submission. If any item is not relevant to the project for which assistance is requested, write “NA” for “Not Applicable.” In the event applicant is uncertain about how to answer any questions, EPA program officials should be contacted for clarification. * Note: Signature appears in the Approval Section of the EPA Comprehensive Administrative Review For Grants/Cooperative Agreements & Continuation/Supplemental Awards form.
57 Other Attachment File(s)
* Mandatory Other Attachment Filename:
To add more "Other Attachment" attachments, please use the attachment buttons below. 1235-CO-ACT Budget EPA COVID-19.pdf
Add Mandatory Other Attachment Delete Mandatory Other Attachment View Mandatory Other Attachment Add Optional Other Attachment Delete Optional Other Attachment View Optional Other Attachment 58 Project Narrative File(s)
* Mandatory Project Narrative File Filename:
To add more Project Narrative File attachments, please use the attachment buttons below. 1234-EPA CO-ACT v4.pdf
View Mandatory Project Narrative FileDelete Mandatory Project Narrative FileAdd Mandatory Project Narrative File Add Optional Project Narrative File Delete Optional Project Narrative File View Optional Project Narrative File 59 Exhibit B
Award Letter 84034001 (September 23, 2021)
60 AJ - 84034001 - 0 Page 1
RECIPIENT TYPE: Send Payment Request to:
Municipal Contact EPA RTPFC at: [email protected]
RECIPIENT: PAYEE:
84034001GRANT NUMBER (FAIN):
AJ
PAYMENT METHOD:
ASAP
DATE OF AWARD
MAILING DATE
ACH#
09/30/2021
90655
U.S. ENVIRONMENTAL
PROTECTION AGENCY
Cooperative Agreement
MODIFICATION NUMBER:
PROGRAM CODE: 09/23/2021
TYPE OF ACTION
New
0 EIN:
City of San Pablo
1000 Gateway Ave
San Pablo, CA 94806
94-6000423
City of San Pablo
San Pablo, CA 94806-3703
Finance Director
1000 Gateway Avenue
PROJECT MANAGER EPA PROJECT OFFICER EPA GRANT SPECIALIST Sarah Kolarik Sorcha Vaughan Jennifer Brooks
1000 Gateway Avenue 75 Hawthorne Street 1200 Pennsylvania Ave, NW, 3903R San Pablo, CA 94806-3703 San Francisco, CA 94105 Washington DC, DC 20460-0001 [email protected]: E-Mail: E-Mail:[email protected] [email protected] 510-215-3068Phone: Phone: Phone:415-947-4217 202-564-6374 The purpose of this American Rescue Plan funded cooperative agreement is to provide funding to the City of San Pablo to work with 3 public Title 1 high schools to deploy an afterschool internship program for disadvantaged students, reaching out to peers and the public to raise awareness and mitigate the impacts of COVID-19 (an airborne contaminant) on environmental justice communities. Project activities include developing the internship program that will directly train 45 students each year in data collection and content creation to launch outreach campaigns to 3,000 peers in 3 campuses and households along with educating the community of San Pablo in related health impacts and facilitating access to reliable and actionable COVID-19 mitigation information. Direct beneficiaries of this program are residents of the city of San Pablo and the city of Richmond, particularly high school students. In the midst of social distancing and local stay-at-home orders, especially in places where internet access may not be readily available to all residents, the program will address underserved residents’ increased exposure to in-home air pollutants and healthy housing issues as an unintended consequence of local stay-at-home orders, and train teams of high school youth leadership as community educators on prevention of air pollution for environmental justice communities. The expected environmental outcomes are an increase in public interest and awareness of COVID-19 information, learning to identify and stop disinformation and misinformation, an increase in best practices for prevention, and an increase in vaccinations and testing rates. The recipient intends to issue subaward agreements to its partners in compliance with Appendix A of EPA’s Subaward Policy. Earth Team will use its successful public high-school internship program to train and mobilize 3 teams of student-interns as "digital natives" to act as science ambassadors in their families and neighborhoods.
SEJCA / ARP COVID-19 Action Teams (CO-ACT): Healthier People, Healthier Homes Engaging and Training New Youth Leadership to Understand,
PROJECT TITLE AND DESCRIPTION
$197,500.00
TOTAL PROJECT PERIOD COSTBUDGET PERIOD
10/01/2021 - 09/30/2023 $197,500.0010/01/2021 - 09/30/2023
TOTAL BUDGET PERIOD COSTPROJECT PERIOD
NOTICE OF AWARD
Based on your Application dated 06/30/2020 including all modifications and amendments, the United States acting by and through the US Environmental Protection Agency (EPA) hereby awards $197,500.00. EPA agrees to cost-share 100.00% of all approved budget period costs incurred, up to and not exceeding total federal funding of $197,500.00. Recipient's signature is not required on this agreement. The recipient demonstrates its commitment to carry out this award by either: 1) drawing down funds within 21 days after the EPA award or amendment mailing date; or 2) not filing a notice of disagreement with the award terms and conditions within 21 days after the EPA award or amendment mailing date. If the recipient disagrees with the terms and conditions specified in this award, the authorized representative of the recipient must furnish a notice of disagreement to the EPA Award Official within 21 days after the EPA award or amendment mailing date. In case of disagreement, and until the disagreement is resolved, the recipient should not draw down on the funds provided by this award/amendment, and any costs incurred by the recipient are at its own risk. This agreement is subject to applicable EPA regulatory and statutory provisions, all terms and conditions of this agreement and any attachments.
Grants and Interagency Agreement Management Division
San Francisco, CA 94105
1200 Pennsylvania Ave, NW Mail code 3903R
Washington, DC 20460
Digital signature applied by EPA Award Official for
THE UNITED STATES OF AMERICA BY THE U.S. ENVIRONMENTAL PROTECTION AGENCY
ISSUING OFFICE (GRANTS MANAGEMENT OFFICE)
ORGANIZATION / ADDRESS
75 Hawthorne Street
AWARD APPROVAL OFFICE
ORGANIZATION / ADDRESS
09/23/2021
DATE
LaShaun Phillips - Associate Award Official
Jill Young - Chief - Grants Management Branch
U.S. EPA, Region 9
OA - Office of the Administrator
61 AJ - 84034001 - 0 Page 2
EPA Funding Information
FUNDS FORMER AWARD THIS ACTION AMENDED TOTAL
$0 $197,500EPA Amount This Action $197,500
$0 $0EPA In-Kind Amount $0
$0 $0Unexpended Prior Year Balance $0
$0 $0Other Federal Funds $0
$0 $0Recipient Contribution $0
$0 $0State Contribution $0
$0 $0Local Contribution $0
$0 $0Other Contribution $0
$0 $0Allowable Project Cost $0
Clean Air Act: Sec. 103(b)(3)66.312 - State Environmental Justice Cooperative Agreement Program
Statutory Authority Regulatory AuthorityAssistance Program (CFDA) 2 CFR 200, 2 CFR 1500 and 40 CFR 33
Fiscal
Site Name Req No FY Approp.
Code
Budget
Oganization
PRC Object
Class
Site/Project Cost
Organization
Obligation /
Deobligation
- $197,500-4183000M57QBBS7212111B11031-
$197,500
62 AJ - 84034001 - 0 Page 3
Total Approved Allowable
Budget Period Cost
Budget Summary Page
$0
$197,500
$193,390
$197,500
$5,253
$0
$0
$9,000
$156,299
Table A - Object Class Category
(Non-Construction)
$0
$22,838
$0
$197,500
$197,500
$4,110
1. Personnel
2. Fringe Benefits
3. Travel
4. Equipment
5. Supplies
6. Contractual
7. Construction
11. Total (Share: Recipient ______ % Federal ______ %)
8. Other
9. Total Direct Charges
12. Total Approved Assistance Amount
13. Program Income
14. Total EPA Amount Awarded This Action
15. Total EPA Amount Awarded To Date
10. Indirect Costs: 10.00 % Base MTDC
100.000.00
63 AJ - 84034001 - 0 Page 4
Administrative Conditions
A. General Terms and Conditions
The recipient agrees to comply with the current EPA general terms and conditions available at: https://www.epa.gov/grants/epa-general-terms-and-conditions-effective-november-12- 2020-or-later.
These terms and conditions are in addition to the assurances and certifications made as a part of the award and the terms, conditions, or restrictions cited throughout the award.
The EPA repository for the general terms and conditions by year can be found at:
https://www.epa.gov/grants/grant-terms-and-conditions#general.
B. Correspondence Condition
The terms and conditions of this agreement require the submittal of reports, specific requests for approval, or notifications to EPA. Unless otherwise noted, all such correspondence should be sent to the following email addresses:
· Federal Financial Reports (SF-425): [email protected] and [email protected]
· MBE/WBE reports (EPA Form 5700-52A): Suzanne Hersh; DBE Coordinator, [email protected]
· All other forms/certifications/assurances, Indirect Cost Rate Agreements, Requests for Extensions of the Budget and Project Period, Amendment Requests, Requests for other Prior Approvals, updates to recipient information (including email addresses, changes in contact information or changes in authorized representatives) and other notifications:
[email protected] and [email protected]
· Payment requests (if applicable): [email protected] · Quality Assurance documents, workplan revisions, equipment lists, programmatic reports and deliverables: [email protected]
64 AJ - 84034001 - 0 Page 5
Programmatic Conditions
A. Reporting Terms and Conditions
1. Semi-Annual Reports – In accordance with federal regulations (Title 2 CFR, Part 200.329), the recipient agrees to submit semi-annual progress reports (i.e. every six (6) months) to the EPA Project Officer within thirty (30) days after each six-month reporting period. Specifically, reports are due each April 30 and October 31 for the duration of the agreement These reports shall cover work status, work progress, difficulties encountered, preliminary data results and a statement of activity anticipated during the subsequent reporting period, including a description of equipment, techniques, and materials to be used or evaluated. A discussion of expenditures along with a comparison of the percentage of the project completed to the project schedule and an explanation of significant discrepancies shall be included in the report. The report shall also include any changes of key personnel concerned with the project.
In addition, the report shall include brief information on each of the following areas: 1) a comparison of actual accomplishments with the anticipated outputs/outcomes specified in the assistance agreement work plan; 2) reasons why anticipated outputs/outcomes were not met; and 3) other pertinent information, including, when appropriate, analysis and explanation of cost overruns or high unit costs. It may be helpful to include best practices and/or lessons learned (e.g., tip sheets, “how-to” sheets) to date, and attachments and links for materials that may be helpful to other Environmental Justice Grants recipients or similar organizations (e.g., communication materials, outreach materials, web tools, etc). The recipient agrees that it will notify EPA of problems, delays, or adverse conditions which materially impair the ability to meet the outputs/outcomes specified in the assistance agreement work plan.
2. Final Reports – In accordance with federal regulations (Title 2 CFR, Part 200.329), the recipient agrees to submit to the EPA Project Officer within one hundred twenty (120) days after the expiration or termination of the approved project period, a final report and at least one reproducible copy suitable for printing. The final report shall document project activities over the entire project period and shall include brief information on each of the following areas: 1) a comparison of actual accomplishments with the anticipated outputs/outcomes specified in the assistance agreement work plan; 2) reasons why anticipated outputs/outcomes were not met; and 3) other pertinent information, including, when appropriate, analysis and explanation of cost overruns or high unit costs. This description may include overall best practices and/or lessons learned over the project performance period, and attachments and links for materials that may be helpful to other Environmental Grants recipients or similar organizations (e.g., tip sheets, “how-to” sheets, communication materials, outreach materials, web tools, etc). The recipient agrees that it will notify EPA of problems, delays, or adverse conditions which materially impair the ability to meet the outputs/outcomes specified in the assistance agreement work plan.
Subaward Performance Reporting
The recipient must report on its subaward monitoring activities under 2 CFR 200.332(d). 65 AJ - 84034001 - 0 Page 6
Examples of items that must be reported if the pass-through entity has the information available are:
1. Summaries of results of reviews of financial and programmatic reports.
2. Summaries of findings from site visits and/or desk reviews to ensure effective subrecipient performance.
3. Environmental results the subrecipient achieved.
4. Summaries of audit findings and related pass-through entity management decisions.
5. Actions the pass-through entity has taken to correct deficiencies such as those specified at 2 CFR 200.332(e), 2 CFR 200.206 and the 2 CFR Part 200.339 Remedies for Noncompliance.
B. EJ Grantee Workshops (Virtual and/or In-Person)
All SEJCA recipients will be required to attend at least one EJ Grantee virtual training workshop hosted by your EPA Region. These trainings will assist all current EPA EJ grant recipients with strategic planning and project management of their grants and/or cooperative agreements, as well as afford recipients opportunities to learn from their peers and other experts. Recipients will need to identify at least one authorized official to participate. The virtual workshops will utilize webinar technology that can be accessed via personal computer. A conference call line will be available for any recipient who doesn’t have the technical capability (i.e. slow internet connection) to access the webinar. Your EPA Project Officer will keep you informed of the dates of the workshops. Each EPA Regional Office will tailor their workshop agenda to the environmental needs and priorities of workshop participants and local communities in the region. Workshops may include a mix of current and former EJ grant recipients, local community stakeholders, other EPA and federal program personnel, and other attendees. Workshop attendees will come together to provide perspective, insight, and lessons learned regarding environmental justice issues plaguing their communities and ways to address them. If COVID-19 related travel and gathering concerns are sufficiently mitigated during the project period, your EPA Regional Office may work to coordinate an in-person workshop where active EJ grant recipients may travel to the EPA Regional office, if they choose to, for a workshop. Recipients would need to identify at least one authorized official to participate. Recipients are permitted to use awarded funds to pay for travel to the workshops. Conference lines and virtual call-in options will be made available for all recipients who cannot or choose not to physically attend any potential in- person workshops. Your EPA Project Officer will keep you informed of any and all developments.
C. Review and Oversight
1. Products - The recipient agrees that any product (e.g., publication, outreach materials, training manuals) produced through this assistance agreement and made available for public view must be first reviewed by the EPA Project Officer for comment before release. The recipient shall make all final decisions on the product content. 66 AJ - 84034001 - 0 Page 7
2. Monthly Calls - The recipient shall consult with the EPA Project Officer on a monthly basis in order to obtain input on program activities and products produced. However, the recipient should make all final decisions on project implementation and product content.
Conference call minutes/notes will be prepared after each call. It is at the EPA Project Officer’s discretion to determine any change to the frequency with which calls are held.
3. Prior Approval - Any proposed changes to the project must be submitted in writing to EPA Region 9 for approval prior to implementation. The recipient incurs costs at its own risk if it fails to obtain written approval before implementing any changes.
D. Post-Project Period Follow-up and Engagement
For no less than one year after completion of the project, recipient agrees to periodically update its designated EPA Project Officer on current community-based and environmental justice work the recipient is performing and how/if that work relates to its now completed SEJCA project. These periodic updates may include (but are not limited to) recent local media reports, additional grant funding received, new initiatives, and developing partnerships. The EPA EJ Grants program is invested in the long-term success of each EJ Grant recipient and its long-term impact on addressing the disproportionate environmental and public health impacts plaguing their communities. These post-project period updates allow the EJ Grants program to provide past recipients with additional guidance about applicable funding opportunities, potential collaborations, and technical assistance that may assist recipients in their future work*. The periodic updates also allow the program to track best practices that lead to greater project sustainability and long-term community revitalization for impacted community residents. The frequency of these periodic updates will be at the discretion of the designated EPA Project Officer and will be discussed with the recipient before the end of the project period. Recipients are also encouraged to continue providing updates and engaging with their EPA Project Officers beyond the additional year after the end of the project.
*NOTE – Compliance with this term & condition will not give the recipient priority during future EPA EJ grant competitions and is not a guarantee for future EPA grant funding.
E. Cybersecurity Condition
Cybersecurity Grant Condition for Other Recipients, Including Intertribal Consortia (a) The recipient agrees that when collecting and managing environmental data under this assistance agreement, it will protect the data by following all applicable State or Tribal law cybersecurity requirements.
(b) (1) EPA must ensure that any connections between the recipient’s network or information system and EPA networks used by the recipient to transfer data under this agreement, are secure. For purposes of this Section, a connection is defined as a dedicated persistent interface between an Agency IT system and an external IT system for the purpose of transferring information. Transitory, user-controlled connections such as website browsing are excluded from this definition.
67 AJ - 84034001 - 0 Page 8
If the recipient’s connections as defined above do not go through the Environmental Information Exchange Network or EPA’s Central Data Exchange, the recipient agrees to contact the EPA Project Officer (PO) no later than 90 days after the date of this award and work with the designated Regional/Headquarters Information Security Officer to ensure that the connections meet EPA security requirements, including entering into Interconnection Service Agreements as appropriate. This condition does not apply to manual entry of data by the recipient into systems operated and used by EPA’s regulatory programs for the submission of reporting and/or compliance data.
(2) The recipient agrees that any subawards it makes under this agreement will require the subrecipient to comply with the requirements in (b)(1) if the subrecipient’s network or information system is connected to EPA networks to transfer data to the Agency using systems other than the Environmental Information Exchange Network or EPA’s Central Data Exchange. The recipient will be in compliance with this condition: by including this requirement in subaward agreements; and during subrecipient monitoring deemed necessary by the recipient under 2 CFR 200.331(d), by inquiring whether the subrecipient has contacted the EPA Project Officer. Nothing in this condition requires the recipient to contact the EPA Project Officer on behalf of a subrecipient or to be involved in the negotiation of an Interconnection Service Agreement between the subrecipient and EPA.
F. Procurement Terms and Conditions
The recipient agrees to conduct all procurement actions under this assistance agreement in accordance with the procurement standards set forth in Title 2 CFR, Parts 200.317 through 200.326. No assistance agreement funds shall be used to reimburse the Federal share of any procurement action found to be in noncompliance with the procurement standards. Any costs incurred by the recipient under contracts and/or small purchases that EPA determines to be in noncompliance with EPA procurement standards shall be unallowable for Federal reimbursement.
G. Use of Logos
If the EPA logo is appearing along with logos from other participating entities on websites, outreach materials, or reports, it must not be prominently displayed to imply that any of the recipient or subrecipient’s activities are being conducted by the EPA. Instead, the EPA logo should be accompanied with a statement indicating that the City of San Pablo received financial support from the EPA under an Assistance Agreement. More information is available at: https://www.epa.gov/stylebook/using-epa-seal-and-logo#policy H. Paperwork Reduction Act
Notwithstanding any references to collection of information in the recipient’s application or proposal for EPA funding, the scope of work for this cooperative agreement does not include a survey or other information collection of identical information from 10 or more parties. No EPA funds (directly paid by EPA or from the recipient’s cost share) may be used for the design or administration of such an information collection, and EPA personnel may not participate in such activities. Reasonable costs for analyzing independently collected 68 AJ - 84034001 - 0 Page 9
information and publishing the results of such information collections are allowable to the extent authorized in the EPA approved budget for this agreement.
I. Substantial Involvement
EPA will be substantially involved in this agreement. Substantial involvement by the EPA Project Officer may include:
1.) monthly telephone calls and other monitoring,
2.) reviewing project phases and providing approval to continue to the next phase,
3.) reviewing and commenting on any documents, web content, or other materials developed under this agreement (the recipient will make final decisions on these matters),
4.) approving substantive terms included in contracts or subawards (EPA’s Project Officer will not suggest, recommend or direct the recipient to select any particular contractor or subrecipient except to the extent permitted in Section 10 of EPA’s Subaward Policy).
5.) reviewing and commenting on the programmatic progress reports 6) Consultation with EPA regarding the selection of key personnel (EPA’s involvement is limited to reviewing the technical qualifications of key personnel and the recipient will make the final decisions on selection. EPA’s Project Officer will not suggest, recommend or direct the recipient to select any individual).
7.) Joint operational involvement, participation, and/or collaboration between EPA and the recipient.
69 Exhibit C
Federal Contract Provisions
Federally Funded Projects. This Project is funded in whole or in part by federal funds and subject to the following federal requirements under the terms of the funding agreement(s) between City and the federal agency or agencies providing federal funds, which are fully incorporated by this reference and made part of the Agreement. Copies of any funding agreement between City and a funding agency will be made available upon request. In the event of any conflict or inconsistency between Exhibit C, Exhibit D, if applicable, and this Agreement, Exhibit C will control.
1. Equal Opportunity. If this Agreement is for public works, during the performance of this Agreement, the Subrecipient agrees as follows:
(A) The Subrecipient will not discriminate against any employee or applicant for employment because of race, color, religion, sex, sexual orientation, gender identity, or national origin. The Subrecipient will take affirmative action to ensure that applicants are employed, and that employees are treated during employment without regard to their race, color, religion, sex, sexual orientation, gender identity, or national origin. Such action shall include, but not be limited to the following: Employment, upgrading, demotion, or transfer; recruitment or recruitment advertising; layoff or termination; rates of pay or other forms of compensation; and selection for training, including apprenticeship. The Subrecipient agrees to post in conspicuous places, available to employees and applicants for employment, notices to be provided setting forth the provisions of this nondiscrimination clause.
(B) The Subrecipient will, in all solicitations or advertisements for employees placed by or on behalf of the Subrecipient, state that all qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, or national origin.
(C) The Subrecipient will not discharge or in any other manner discriminate against any employee or applicant for employment because such employee or applicant has inquired about, discussed, or disclosed the compensation of the employee or applicant or another employee or applicant. This provision will not apply to instances in which an employee who has access to the compensation information of other employees or applicants as a part of such employee’s essential job functions discloses the compensation of such other employees or applicants to individuals who do not otherwise have access to such information, unless such disclosure is in response to a formal complaint or charge, in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer, or is consistent with the Subrecipient's legal duty to furnish information.
(D) The Subrecipient will send to each labor union or representative of workers with which it has a collective bargaining agreement or other contract or understanding, a notice to be provided advising the labor union or workers' representatives of the Subrecipient’s commitments under this section, and will post copies of the notice in conspicuous places available to employees and applicants for employment.
70 (E) The Subrecipient will comply with all provisions of Executive Order 11246 of September 24, 1965, and of the rules, regulations, and relevant orders of the United States Secretary of Labor.
(F) The Subrecipient will furnish all information and reports required by Executive Order 11246 of September 24, 1965, and by rules, regulations, and orders of the United States Secretary of Labor, or pursuant thereto, and will permit access to his books, records, and accounts by the administering agency and the United States Secretary of Labor for purposes of investigation to ascertain compliance with such rules, regulations, and orders.
(G) In the event of the Subrecipient’s noncompliance with the nondiscrimination clauses of this Agreement or with any of the rules, regulations, or orders, this Agreement may be canceled, terminated, or suspended in whole or in part and the Subrecipient may be declared ineligible for further federal government contracts or federally assisted construction contracts in accordance with procedures authorized in Executive Order 11246 of September 24, 1965, and such other sanctions may be imposed and remedies invoked as provided in Executive Order 11246 of September 24, 1965, or by rule, regulation, or order of the United States Secretary of Labor, or as otherwise provided by law.
(H) The Subrecipient will include the portion of the sentence immediately preceding paragraph (A) and the provisions of paragraphs (A) through (H) in every subcontract or purchase order unless exempted by rules, regulations, or orders of the United States Secretary of Labor issued pursuant to section 204 of Executive Order 11246 of September 24, 1965, so that such provisions will be binding upon each subcontractor or vendor. The Subrecipient will take such action with respect to any subcontract or purchase order as the City or funding agency may direct as a means of enforcing such provisions, including sanctions for noncompliance: Provided, however, that in the event a Subrecipient becomes involved in, or is threatened with, litigation with a subcontractor or vendor as a result of such direction by the City or funding agency, the Subrecipient may request the United States to enter into such litigation to protect the interests of the United States.
2. Davis-Bacon Act. If this Agreement is for public works, Subrecipient will pay wages to laborers and mechanics, not less than once a week, and at a rate not less than the current federal prevailing wages specified in the Davis-Bacon Act Wage Determination. By entering into this Agreement, Subrecipient accepts the Wage Determination found at https://www.wdol.gov/dba.aspx.
3. Copeland “Anti-Kickback” Act. If this Agreement is for public works, Subrecipient will comply with 18 U.S.C. § 874, 40 U.S.C. § 3145, and the requirements of 29 CFR Part 3 as may be applicable, which are incorporated by reference into this Agreement. Subrecipient and subcontractors must insert this requirement into subcontracts of any tier. Subrecipient is responsible for compliance with these requirements by each subcontractor of any tier.
4. Contract Work Hours and Safety Standards Act. In addition to the California state law requirements, Subrecipient and each subcontractor must comply with the requirements of the federal Contract Work Hours and Safety Standards Act, as set forth in 40 U.S.C. 3701-3708, as supplemented by the regulations set forth in 29 CFR Part 5, as may be amended from time to time, which are fully incorporated herein, including:
71 (A) No Subrecipient or subcontractor will require or permit any laborer or mechanic performing Work for the Project to work in excess of 40 hours in a work week unless such laborer or mechanic receives compensation at a rate not less than one and one-half times the basic rate of pay for all hours worked in excess of 40 hours during that work week.
(B) If Subrecipient or a subcontractor violates this requirement, the Subrecipient and any responsible subcontractor will be liable for the unpaid wages. In addition, the Subrecipient and subcontractor will be liable to the United States for liquidated damages.
The liquidated damages will be computed with respect to each individual worker as specified under federal law.
(C) Subrecipient and subcontractors must insert this requirement into subcontracts of any tier. Subrecipient is responsible for compliance with these requirements by each subcontractor of any tier.
5. Rights to Inventions. If the federal funding for this Agreement meets the definition of “funding agreement” under 37 CFR section 401.2(a) and constitutes an agreement between the City and a small business firm or nonprofit organization regarding the substitution of parties, assignment or performance of experimental, developmental, or research work under that “funding agreement,” the requirements of 37 CFR Part 401, “Rights to Inventions Made by Nonprofit Organizations and Small Business Firms Under Government Grants, Contracts and Cooperative Agreements,” and any implementing regulations issued by the awarding agency, will apply to this Agreement and are fully incorporated into the Agreement by this reference.
6. Clean Air Act. If the Agreement is for an amount in excess of $150,000, Subrecipient and each subcontractor must comply with the requirements of the Clean Air Act, as amended, (42 U.S.C. §§ 7401-7671q), which are fully incorporated into the Agreement by this reference, including requirements for reporting violations to the awarding agency and the applicable Regional Office for the Environmental Protection Agency. Subrecipient and subcontractors must insert this requirement into subcontracts of any tier in excess of $150,000.
7. Federal Water Pollution Control Act. If the Agreement is for an amount in excess of $150,000, the requirements of the Federal Water Pollution Control Act (33 U.S.C. §§ 1251-1387) apply to this Agreement and are fully incorporated into the Agreement by this reference, including requirements for reporting violations to the awarding agency and the applicable Regional Office for the Environmental Protection Agency requirements for reporting violations. Subrecipient and subcontractors must insert this requirement into subcontracts of any tier in excess of $150,000.
8. Suspension and Debarment. Subrecipient is required to verify that neither it, nor its principals, as defined at 2 CFR section 180.995, or its affiliates, as defined at 2 CFR section 180.905, are excluded or disqualified, as defined at 2 CFR sections 180.935 and 180.940.
Subrecipient must comply with 2 CFR Part 180, subpart C and 2 CFR Part 3000, subpart C, and must include a provision requiring compliance with these regulations in any subcontract of any tier.
If it is later determined that the Subrecipient did not comply with the applicable subparts, the Federal Government may pursue available remedies, including, but not limited to, suspension and/or debarment. By submitting a bid and entering into this Agreement, Subrecipient agrees to comply with these requirements.
9. Byrd Anti-Lobbying Amendment. If the Agreement is for an amount in excess of $100,000, Subrecipient must comply with the Byrd Anti-Lobbying Amendment (31 U.S.C. § 1352) 72 and file the certification provided at 44 CFR Part 18, Appendix A, and any disclosures, with the applicable federal agency. Each tier certifies to the tier above that it will not and has not used federal-appropriated funds to pay any person or organization for influencing or attempting to influence an officer or employee of any agency, a member of Congress, officer or employee of Congress, or an employee of a member of Congress in connection with obtaining any federal contract, grant, or any other award covered by 31 U.S.C. § 1352. Each tier will also disclose any lobbying with non-federal funds that takes place in connection with obtaining any federal award.
Such disclosures will be forwarded from tier to tier up to the recipient.
10. Procurement of Recovered Materials. The requirements of section 6002 of the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act at 42 U.S.C. § 6962, apply to this Agreement and are fully incorporated into the Agreement by this reference. For individual purchases of $10,000 or more, Subrecipient will make maximum use of products containing recovered materials that are EPA-designated items unless the product cannot be acquired (A) competitively within the Agreement schedule, (B) in conformance with Agreement performance requirements, or (C) at a reasonable price. Information on this requirement, including a list of EPA-designated items, is available at the EPA’s Comprehensive Procurement Guidelines website:
https://www.epa.gov/smm/comprehensive-procurement-guideline-cpg-program.
11. Small and Minority Businesses. When procuring subcontractors, Subrecipient must take all necessary affirmative steps pursuant to 2 CFR § 200.321(b), subject to the limitations of law, to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Affirmative steps must include:
(A) Placing qualified small and minority businesses and women’s business enterprises on solicitation lists.
(B) Assuring that small and minority businesses and women’s business enterprises are solicited whenever they are potential sources.
(C) Dividing total requirements, when economically feasible, into smaller tasks or quantities to permit maximum participation by small and minority businesses and women’s business enterprises.
(D) Establishing delivery schedules, where the requirement permits, which encourage participation by small and minority
businesses, and women’s business enterprises.
(E) Using the services and assistance, as appropriate, of such organizations as the Small Business Administration and the Minority Business Development Agency of the Department of Commerce.
12. Prohibition on Covered Telecommunications. Federal loan or grant funds must not be obligated or expended to procure or obtain, extend or renew a contract to procure or obtain, or enter into a contract (or extend or renew a contract) to procure or obtain equipment, services, or systems that use covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system, as further specified in 2 CFR § 200.216, which is fully incorporated into the Agreement by this reference. Covered telecommunications equipment or services includes equipment produced by, services provided by, or services using equipment produced by: Huawei Technologies Company or ZTE Corporation (or any subsidiary or affiliate of such entities); Hytera Communications Corporation, Hangzhou 73 Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities); or an entity that the Secretary of Defense, in consultation with the Director of the National Intelligence or the Director of the Federal Bureau of Investigation, reasonably believes to be an entity owned or controlled by, or otherwise connected to, the government of a covered foreign country.
13. Domestic Preferences for Procurements. As appropriate and to the extent consistent with laws, the City should, to the greatest extent practicable under a federal award, provide a preference for the purchase, acquisition, or use of goods, products, or materials produced in the United States, as further specified in 2 CFR § 200.322, which is fully incorporated into the Agreement by this reference, including, but not limited to, iron, aluminum, steel, cement, and other manufactured products, as specified therein. The requirements of 2 CFR § 200.322 must be included in all subcontracts and purchase orders for work or products under the federal award.
74 Exhibit D
USEPA Subaward Policy
75 Please see RAIN-2018-G04-R1 for details regarding changes to this GPI effective September 28, 2021.
Please see RAIN-2018-G03-R for details regarding changes to this GPI effective November 12, 2020.
Amended Grants Policy Issuance (GPI) 16-01
EPA Subaward Policy
1.0 Purpose
(a) This policy establishes the requirements and procedures for Grants Management Offices and Program Offices in making determinations regarding subrecipient eligibility, overseeing pass-through entity monitoring and management of subawards, and authorizing fixed amount subawards under 2 CFR 200.331, 200.332, and 200.333 (“the applicable regulations”). This policy supersedes EPA’s previous Subaward Policy contained in Part 2, Section 01 of EPA’s Assistance Administration Manual.
(b) In order to effectively implement the EPA Subaward Policy, it is important at the outset for EPA personnel as well as pass-through entities to understand the difference between subawards and procurement contracts since the rules for these two types of transactions are different.
(1) Pass-through entities make subawards to other organizations to carry out a portion of the Federal award under terms that establish a financial assistance relationship to accomplish a public purpose that is authorized under a Federal program. Subrecipients only receive reimbursement for their actual direct or approved indirect costs such that they do not “profit” from the transaction and subrecipients are subject to the same Federal requirements as the pass-through entity. There is no requirement in the applicable regulations for pass-through entities to compete subawards.
(2) In contrast, procurement contractors (including individual consultants) typically provide goods and services on commercial terms, operate in a competitive environment and a reasonable profit is allowable. Additional guidance is available in Section 7.0 and Appendix A: Distinctions Between Subrecipients and Contractors of this policy. The Procurement Standards of 2 CFR Part 200 include competition requirements.
(c) A pass-through entity may use the term ‘contract’ to characterize a subaward arrangement.
Therefore, it is important to examine the substance of the agreement using the characteristics discussed in 2 CFR 200.331 and Appendix A: Distinctions Between Subrecipients and Contractors of this policy to determine if the transaction is a subaward or a procurement contract.
2.0 Applicability and Effective Date
EPA’s Subaward Policy applies to financial assistance agreements and incremental or supplemental funding amendments awarded to pass-through entities on or after March 29, 2016. The revision effective November 12, 2020, supersedes all prior versions of the Subaward Policy.
The Subaward Policy does not apply to collaborative relationships, including those documented in a written agreement, between recipients and third parties that do not involve the transfer of assistance funds or property purchased with assistance funds.
76 The Subaward Policy does not apply to financial assistance agreements for the capitalization of revolving loan funds (RLF). Requirements for RLF recipients and borrowers are addressed in more detail in 2 CFR Part 1500, national program guidance for EPA RLF programs or the terms and conditions of RLF assistance agreements. The Agency may apply the Subaward Policy, or selected provisions of it, to other financial assistance agreements with the consent of the pass-through entity.
3.0 Definitions
For purposes of this Subaward Policy, the following terms are defined at 2 CFR 200.1:
Contractor
Federal Award
Federal Financial Assistance
Fixed Amount Awards
Indian Tribe
Institutions of Higher Education
Local Government
Modified Total Direct Costs
Non-Federal Entity
Nonprofit Organization
Obligations
State
Contract. Defined at 2 CFR 200.1. A contract does not include a Federal award or subaward.
Individual: A natural person.
Pass-through entity: This term is defined at 2 CFR 200.1 and refers to a non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program.
Recipient: This term is defined at 2 CFR 200.1 and does not include subrecipients. For the purposes of this Subaward Policy the term “Recipient” also includes individuals who receive awards under EPA statutes authorizing direct Federal financial assistance to individuals other than fellowship recipients under 40 CFR Part 46.
Simplified Acquisition Threshold: This term is defined at 2 CFR 200.1.
As of the date of the issuance of the Subaward Policy the Simplified Acquisition Threshold is $250,000.
This amount is periodically adjusted for inflation and the revised threshold is published in the Federal Acquisition Regulation at 48 CFR 2.1 (Definitions).
Subaward: This term is defined at 2 CFR 200.1.
Subawards do not include payments to contractors (including consultants) or to program beneficiaries such as trainees, interns, fellows and subsidy or rebate program participants. Subawards may include loans, loan guarantees, interest subsidies and principal forgiveness, purchases of insurance or similar transactions entered into with borrowers by recipients of RLF capitalization agreements. Requirements for RLF pass-through entities and borrowers for complying with the Uniform Grant Guidance (UGG) 77 provisions relating to subawards are described in 2 CFR Part 1500, national program guidance for EPA RLF programs or the terms and conditions of the RLF agreements rather than this Subaward Policy.
Subrecipient: This term is defined at 2 CFR 200.1.
For the purpose of this Subaward Policy “subrecipient” includes both Federal and non-Federal entities and individuals (who are not program beneficiaries) who are eligible for subawards to the extent consistent with the authorizing statutes and regulations, 2 CFR Part 180, Office of Management and Budget (OMB) Guidance to Agencies on Governmentwide Debarment and Suspension (Nonprocurement) and 2 CFR Part 1532, EPA’s Nonprocurement Suspension and Debarment regulation.
4.0 Background
EPA’s Subaward Policy implements regulatory requirements and addresses recommendations from Office of Inspector General (OIG) audits of assistance agreements containing subawards.
(a) The Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Grant Guidance or UGG) codifies standards for distinguishing between subawards and contracts at 2 CFR 200.331 and this Subaward Policy provides additional guidance consistent with that regulation.
(b) Under 2 CFR 200.332, pass-through entities must include a number of provisions in subaward agreements and implement effective systems to monitor and guide subrecipient performance; this Subaward Policy provides guidance on how EPA will oversee compliance with those requirements.
(c) The OIG has recommended that EPA enhance its oversight of pass-through entities to ensure that subawards are used in appropriate circumstances, costs are reasonable and that pass-through entities effectively monitor subrecipient performance. This Subaward Policy includes provisions that respond to the OIG’s recommendations.
5.0 General Principles
It is EPA policy that subawards under Agency assistance agreements be properly awarded, managed and monitored in compliance with the applicable regulations and in a manner that promotes accountability while minimizing burdens on pass-through entities and EPA staff. The Agency will appropriately oversee pass-through entities on a pre-award and post-award basis. This includes ensuring that:
(a) Agency personnel identify pass-through entities during pre-award cost reviews or post-award requests to make subawards under 2 CFR 200.308(c)(1)(vi) and advise pass-through entities to have adequate systems in place to comply with 2 CFR 200.331, 2 CFR 200.332 and section 9.0 of this Subaward Policy during post-award monitoring.
(b) Pass-through entities effectively monitor the performance of subrecipients.
(c) Pass-through entities do not use subawards to transfer or delegate their responsibility for successful completion of their EPA assistance agreement.
(d) Financial assistance awards to pass-through entities do not circumvent the requirements of EPA 78 Order 5700.5A1, Policy for Competition of Assistance Agreements (02/06/2014) (“EPA’s Competition Policy”).
(e) EPA personnel do not direct, recommend or suggest that pass-through entities make subawards to particular organization(s) except to the extent allowed under section 10.0(b) of this Subaward Policy.
6.0. National Term and Condition.
EPA has established a National Term and Condition for Subawards for all assistance agreements, which is located in Appendix B of this policy.
7.0 Eligibility for Subawards.
(a) Generally, unless prohibited or limited by statute, a non-Federal entity or individual is eligible to receive a subaward even if it is not eligible to receive an assistance agreement from EPA directly as long as the subaward is consistent with applicable regulations, policies, and EPA guidance. Federally Funded Research and Development Centers are eligible subrecipients provided the substance of the transaction is consistent with the guidance at 2 CFR 200.331 and Appendix A: Distinctions Between Subrecipients and Contractors.
(b) As provided in 2 CFR Part 25, Appendix A , Federal agencies are subrecipients for the purposes of the System for Award Management and Universal Identifier Requirements when they receive “subawards” from pass-through entities. Federal agencies may also be subrecipients for the purposes of 2 CFR Part 200 as indicated in the definition of Subrecipient in 2 CFR 200.1. Nonetheless, Federal agencies must have statutory authority to provide services to non-Federal entities on a reimbursable basis or otherwise receive and use funds from non-Federal entities under subawards. Examples of statutes available to all Federal agencies for receipt and use of EPA financial assistance funds are the Intergovernmental Cooperation Act for services to state and local governments, the Federal Technology Transfer Act for Cooperative Research and Development and Agreements, and the Omnibus Territories Act for reimbursable services agreements with U.S. Territories.
(c) For-profit organizations and individual consultants, with very few exceptions, are contractors rather than subrecipients under the standards in 2 CFR 200.331 and EPA’s guidance; they are typically ineligible for subawards from pass-through entities. As provided in the National Term and Condition for Subawards, EPA’s Award Official must approve subawards to these entities on the basis of either precise descriptions of the subawards in the EPA approved budget and work plan or on a transaction by transaction basis. See Appendix A: Distinctions Between Subrecipients and Contractors for additional guidance.
(d) Nonprofit organizations exempt from taxation under section 501(c)(4) of the Internal Revenue Code that engage in lobbying activities are ineligible for EPA subawards based on the Agency’s policy for interpreting the Lobbying Disclosure Act, 2 U.S.C. 1611.
(e) EPA program office staff should ensure that pass-through entities are aware of limitations on subrecipient eligibility contained in statutes or regulations. EPA program offices may communicate 79 applicable limitations to potential pass-through entities in announcements for competitive awards, program guidance for continuing environmental program grants or other noncompetitive awards, and programmatic terms and conditions.
(f) In consultation with OGD’s National Policy, Training and Compliance Division and the Office of General Counsel or Office of Regional Counsel, as appropriate, Program offices may establish policies limiting eligibility for subawards to the extent permitted by statute or regulation. EPA program offices must communicate applicable policies to potential pass-through entities in announcements for competitive awards, program guidance for continuing environmental program grants or other noncompetitive awards, and programmatic terms and conditions.
8.0 Internal Controls for EPA Oversight of Pass-Through Entity Compliance with the Applicable Regulations and EPA Subaward Policy.
This section identifies policies and procedures designed to provide internal controls that promote pass- through entity compliance with applicable regulations and this Subaward Policy.
(a) EPA policy is to require that pass-through entities include the aggregate amount for subawards in the “Other” budget category of their Standard Form (SF) 424A, “Budget Information for Non- Construction Programs” or equivalent forms for construction agreements unless OMB revises the budget categories in the SF-424A to include one for subawards.
1. Pass-through entities may erroneously place costs for subawards under the “Contractual” budget category based on practices at other agencies. As part of their pre-award cost reviews, Project Officers (PO) and Grant Specialists (GS) must review budget justifications and amounts recipients budget for “Contractual” to ensure that subaward costs are classified as “Other”.
2. The amount of funding a pass-through entity estimates that it will use for subawards costs must be documented in a separate line item in the budget justification for the “Other” budget category or another provision of the work plan.
(b) If necessary, POs should work with the pass-through entity to obtain approval for international subawards as provided in section 11.0 (a) of this Subaward Policy.
(c) During pre-award review, GS must check for compliance with the $25,000 limitation at in Modified Total Direct Costs as defined in 2 CFR 200.1on including subaward costs in Modified Total Direct Cost for the purposes of distributing indirect costs.
(d) Award Officials are responsible for ensuring that all awards (including those in which the recipient has not identified subawards) contain the National Term and Condition for Subawards.
Additionally, the Award Officials may highlight this term and condition in the cover letter in the Notice of Award using either the following template or similar language:
If your work plan and budget includes subawards of financial assistance (as defined in Subawards at 2 CFR 200.1 and 2 CFR 200.331), please pay particular attention to EPA’s National Term and Condition for Subawards which is found in the programmatic terms and conditions for this award. By accepting this assistance agreement, your organization is certifying that it either has 80 systems in place to comply with the regulatory or EPA policy requirements specified in the National Term and Condition for Subawards or that it will refrain from making subawards with funding EPA provides under this agreement until the systems are designed and implemented.
Also note that should your organization decide to make a subaward(s) that was not described in the work plan and budgeted for under this agreement you must obtain prior written approval from EPA’s Award Official for the subaward as provided at 2 CFR 200.308(c)(1)(vi).
(e) POs must include the Model Programmatic Subaward Reporting Requirement contained in Appendix C, or a customized version of the model in the performance reporting terms and conditions for assistance agreements with pass-through entities. The reporting frequency must be the same as that for other performance reports.
1. Project Officers may customize the Model Programmatic Subaward Reporting Requirement based on programmatic information needs provided they do not create a form for the collection of identical data from 10 or more pass-through entities. Doing so may trigger the Office of Management and Budget’s Information Collection Request regulations. Project Officers should consult with OGC or ORC as appropriate if there are questions regarding whether an ICR is required.
2. In situations in which a recipient advises EPA after award that it intends to make subawards, the PO must request that the Award Official amend the assistance agreement to add the Model Programmatic Subaward Reporting Requirement or a customized subaward reporting term and condition when granting approval under 2 CFR 200.308(c)(1)(vi) for the subawards.
(e) POs must review pass-through entity performance reports describing subrecipient progress towards achieving program objectives. If the pass-through entity’s performance reports raise questions regarding whether a subrecipient is making adequate progress, POs should ensure that the pass-through entity considers measures such as those set forth at 2 CFR 200.332 (d)(2), (e)(1) and (2) or (h) to address the situation.
(f) POs are responsible for ensuring that, as appropriate, awards to pass-through entities include program-specific terms and conditions relating to subawards. Additionally, under cooperative agreements with pass-through entities, Program Offices may be substantially involved in subaward related activities under the terms and conditions of the agreement and POs may exercise EPA’s approval rights under these T&Cs. Consistent with EPA Order 5700.1, examples of EPA substantial involvement include, but are not limited to:
1. EPA approval of or consultation on proposed subrecipients’ eligibility provided the Agency does not direct, recommend, or suggest that the pass-through entity provide a subaward to a particular organization.
2. If not described in the approved work plan, EPA approval of competitive or noncompetitive procedures the pass-through entity will use to select subrecipients prior to the award of any subawards.
3. EPA participation in panels for subaward competitions to the extent permitted in section 10.0 (b) of the Subaward Policy.
81 4. EPA approval of the substantive terms of subawards.
(g) In situations in which EPA determines that a pass-through entity has not adequately monitored subrecipient performance, POs may participate in the pass-through entities’ subaward monitoring activities if a specific award condition is added to the award pursuant to 2 CFR 200.208.
(h) As a component of post-award oversight, POs and GSs are responsible for inquiring whether pass-through entities have adequate systems in place for complying with:
1. 2 CFR 200.331, the subrecipient eligibility provisions of EPA’s National Term and Condition for Subawards, and any program specific restrictions on subrecipient eligibility.
2. 2 CFR 200.332, Requirements for pass-through entities, as described in EPA’s National Term and Condition for Subawards. A template for a subaward agreement that meets the requirements of 2 CFR 200.332(a) (a) is available at Appendix D of this Subaward Policy and may be provided to the pass-through entity subject to the limitations in Section 12 of this Subaward Policy.
The level of inquiry should be based on the PO’s or GS’s assessment of the pass-through entities’ history of managing subaward programs as reflected in programmatic baseline and advanced monitoring reports, audit reports, and other information that has come to the POs attention. Inquiries may be made as part of programmatic or administrative base line monitoring, advance monitoring, desk reviews, discussions of progress reports with pass-through entities, or otherwise, as appropriate. Program offices may, in consultation with EPA’s Office of Grants and Debarment, the Office of General Counsel and, if appropriate, Office of Regional Counsel develop program specific guidance for pass-through entities and their subrecipients on compliance with this Subaward Policy. OGD may also issue Agency-wide supplemental guidance as necessary.
9.0 Fixed Amount Subawards
(a) Under 2 CFR 200.333, EPA may allow pass-through entities to award subawards up to the simplified acquisition threshold on a fixed amount or “lump sum” basis such that the subrecipient does not account for actual costs. OGD will consider approving the use of fixed amount subawards on a pilot basis at the request of a Program Office. After completion of the pilot, OGD and the Program Office will consider whether fixed amount subawards will be a permanent feature of the grant program. Fixed amount subawards must meet the standards of 2 CFR 200.201(b).
Examples of potential fixed amount subaward pilot projects include:
1. Conference support for units of government, Institutions of Higher Education (IHE) and nonprofit organizations including general “sponsorships” in amounts up to $25,000 provided the recipient obtains in accordance with 2 CFR 200.201(b)(1) written assurance that the conference organizer will refund the entire amount of the subaward if the conference does not take place.
2. Studies or research projects that produce written reports funded on a milestone achievement or project completion basis provided the subrecipient is a unit of government, an IHE, a 82 nonprofit organization, or a student or post-doctoral fellow at an IHE.
3. Training classes funded on a milestone completion (e.g., preparation of curricula, rental of facility, course delivery, and submission of evaluation report) or a unit price basis upon project completion provided the subrecipient is a unit of government, an IHE or a nonprofit organization.
4. Community meetings funded on a milestone completion (e.g., outreach, preparation of agenda, rental of facility, meeting, and submission of attendee roster/meeting summary) or on a unit price basis upon project completion provided the subrecipient is a unit of government, an IHE or a nonprofit organization.
10.0 Subaward Competitions.
Unlike contracts subject to the Procurement Standards of 2 CFR Part 200, the applicable regulations do not require that pass-through entities select subrecipients competitively. Program Offices, however, may require that pass-through entities conduct competitions for subawards unless otherwise prohibited by statute, regulation or official EPA policy. Similarly, pass-through entities may choose to select subrecipients competitively provided this practice is consistent with applicable statutes, regulations and the terms of their EPA financial assistance agreement.
(a) EPA Required Subaward Competitions
1. Under some EPA assistance programs, pass-through entities may be legally required to conduct subaward competitions. Program Offices and Regions must ensure pass-through entities conduct these competitions consistent with any applicable legal requirements and provisions of this Subaward Policy.
2. Under both competitive and non-competitive EPA assistance agreement awards, if Program Offices require the pass-through entity to conduct a competition for subawards, they must determine that the subaward competition is necessary for the effective and efficient implementation of the assistance program. This determination must be in writing and placed in the official program office assistance agreement file.
a. Non-Competitive EPA Assistance Agreements - When a Program Office requires the pass- through entity to conduct a subaward competition under a non-competitive EPA assistance agreement, the award must include a programmatic term and condition requiring the recipient to conduct the subaward competition consistent with the negotiated work plan and the provisions of this Subaward Policy.
b. Competitive EPA Assistance Agreements - When a Program Office requires the pass- through entity to conduct a subaward competition under a competitive EPA assistance agreement, the Agency’s competitive funding announcement must include ranking factors for evaluating the applicants’ proposed procedure for conducting the subaward competition. In addition, the award must include a programmatic term and condition requiring the pass-through entity to conduct the subaward competition consistent with the subaward competitive process described in the approved work plan and the provisions of this Subaward Policy. 83 (b) EPA Participation in Subaward Competitions.
1. General. Pass-through entities are responsible for selecting their subrecipients and conducting their subaward competitions. In addition, EPA personnel may not direct pass- through entities to make subawards to particular organizations, suggest the use of specific subrecipients, interfere with the recipient’s subaward selection decisions, or use subawards to circumvent EPA policies for competition of assistance agreements. For example, a Program Office may want to award a non-competitive grant to Organization A but is not authorized to do so because of restrictions under EPA’s Assistance Agreement Competition Policy. EPA may not circumvent these restrictions by awarding a non-competitive grant to Organization B with the understanding that Organization B will then subaward all of the work to Organization A.
2. Participation as Technical Advisors. EPA personnel may serve as technical advisors to a pass- through entity’s subaward evaluation panel as part of EPA’s substantial involvement in a cooperative agreement provided that they do not unduly influence the panel or selection decisions and are free of any conflicts of interest, and actual or apparent violations ethical standards (e.g., Office of Government Ethics (OGE) Standards of Ethical Conduct for Employees of the Executive Branch), with respect to any competing subrecipients.
3. Participation on Evaluation Panels. For subaward competitions conducted by pass- through entities under cooperative agreements, EPA personnel may serve as members of the recipient’s subaward evaluation panel provided:
a. The pass-through entity uses objective, transparent criteria to rank and select subrecipients.
b. EPA and other federal agency personnel do not unduly influence the panel or selection decisions (e.g., federal employees must comprise substantially less than a majority of the panel).
c. EPA employees are free of conflicts of interest, or actual or apparent violations of ethical standards (e.g., OGE Standards of Ethical Conduct for Employees of the Executive Branch), with respect to any competing subrecipients.
11.0 Special Considerations for Specific Types of Subawards.
(a) In accordance with EPA Order 4540.1, EPA’s Office of International and Tribal Affairs (OITA), must consent to proposed EPA financial assistance agreements, prior to award, where work will be performed by any recipient or subrecipient in whole or in part in a foreign country, or where work will be performed in the United States by a foreign government recipient and its subrecipient or an international organization recipient and its subrecipient. OITA must consent to any work by a subrecipient that meets these criteria either prior to award of the EPA assistance agreement to the pass- through entity or prior the pass-through entity’s award of the subaward.
(b) EPA’s National Subaward Term and Condition requires Agency approval for subawards to individuals. Although individuals are eligible for subawards under this Subaward Policy on the basis of several EPA statutes (e.g., section 103 of the Clean Air Act, section 104 of the Clean Water Act, 84 section 8001 of the Solid Waste Disposal Act) EPA Program Offices and GMOs must ensure that subawards are not made to individuals who are considered program beneficiaries (e.g., interns, fellows, trainees, community members attending conferences). The definition of Subrecipient at 2 CFR 200.1 program beneficiaries are excluded from the definition of Subrecipient. Stipends and other payments to program beneficiaries are properly characterized as Participant Support Costs under 2 CFR 200.1 and 2 CFR 200.456 and included as line items in the “Other” budget category.
(c) Program Offices and GMOs must carefully review situations in which a pass-through entity intends to make a subaward(s) for 100% of funds EPA will award under a financial assistance agreement. Competitive proposals with 100% pass through should be discussed with the Grant Competition Advocate’s staff. If not adequately addressed in the work plan, the PO should request that the pass- through entity explain, in writing:
1. The reasons for subawards for 100% of the funds out to another organization(s) and;
2. How the pass-through entity will provide adequate resources to manage the award, including providing required financial and programmatic reports to EPA, and for monitoring subrecipients as required by 2 CFR 200.332.
This information must be reviewed by the Award Official or designee prior to awarding funds to the pass-through entity.
12.0 Template for Subaward Agreements.
Program Offices may provide the subaward template contained in Appendix D of the Subaward Policy to recipients of EPA financial assistance that are “Pass-through entities” as defined by 2 CFR 200.1 to assist them in complying with the “subaward content” requirements in 2 CFR 332(a). EPA does not mandate the use of this template. With OGD, OGC, and if appropriate ORC approval, Program Offices may use program specific subaward templates that are consistent 2 CFR 200.332(a). Pass- through entities may also use their own form of subaward agreements provided the requirements of 2 CFR 200.332(a) are met.
13.0 Evaluation
OGD, in coordination with the EPA grants management community, will periodically review this policy to assess its effectiveness.
14.0 Waivers
In response to a written request from the appropriate Senior Resource Official, or designee, the Director of OGD, or designee, may approve waivers to this Subaward Policy on a case-by-case or class basis in circumstances of compelling urgency or unique programmatic consideration or where a waiver would be in the public interest provided the waiver is consistent with statutes, the applicable regulations and Executive Orders. The Director of OGD, or designee, may also make exceptions to any regulatory requirements of mentioned in this policy on case-by-case basis as authorized by 2 CFR 200.102 and 2 CFR 1500.4(a). Exceptions will be granted only in extraordinary circumstances and when consistent with statutes and Executive Orders.
85 15.0 Roles and Responsibilities
A. Office of Grants and Debarment (OGD)
OGD is responsible for:
1. Posting the National Subaward Term and Condition described in Section 6.0 of this policy.
2. Developing cost review guidance to facilitate implementation of Section 8.0 of this policy.
3. Overseeing Agency compliance with this policy and providing necessary implementing guidance including approval of Program specific subaward guidance and subaward templates.
4. Consulting with Program Offices on their proposed policies to limit subaward eligibility under Section 7.0(e) of this policy.
5. Approving or disapproving pilots for fixed amount subawards under Section 9.0.
6. Evaluating the effectiveness of this policy under Section 13.0 of this policy including conducting periodic reviews of pass-through entity compliance with the requirements.
7. Approving or disapproving waiver requests under Section 14.0 of this policy and posting waiver decisions on the OGD Intranet page.
8. Developing training, responses to frequently asked questions, and, as necessary, Agency wide supplemental guidance on implementing this Subaward Policy.
B. Headquarters and Regional Program Offices
Program Offices are responsible for:
1. Adhering to the subaward eligibility provisions and consulting with OGD and OGC/ORC on program- specific eligibility restrictions as described in Section 7.0 of this policy.
2. Complying with applicable pre-award and post-award oversight requirements described in Sections
8.0, 10.0 and 11.0 of this policy including providing EPA approvals specified in substantial involvement terms and conditions for cooperative agreements.
3. Including (and modifying, if applicable) the Model Programmatic Subaward Reporting Requirement contained in Appendix C, in the performance reporting terms and conditions for assistance agreements with pass-through entities as described in Section 8.0.
4. Complying with subaward competition requirements as described in Section 10.0 of this policy.
5. Obtaining OITA consent for subaward work in a foreign country or subaward work performed in the U.S. by a foreign government or a foreign government subrecipient as described in Section 11.0(a) of this policy.
86 6. Working with GMOs to ensure that subawards are not approved to individuals who are considered program beneficiaries as described in Section 11.0(b) of this policy.
7. Reviewing proposals for 100% pass-through sub-awards as described in Sections 11.0(c) of this policy.
8. Requesting OGD approval for pilots of fixed amount subawards.
9. Providing pass-through entities with the template for subaward agreement in Appendix D or an OGD approved program specific template when requested to do so by the pass-through entities.
10. Subject to OGD approval, developing as appropriate program specific guidance and subaward templates for pass-through entities and their subrecipients to promote compliance with this Subaward Policy.
C. Office of General Counsel (OGC)/Office of Regional Counsel (ORC)
OGC/ORC is responsible for providing legal advice to ensure compliance with applicable statutes, executive orders, ethical standards, and OMB/EPA regulations.
D. Grants Management Offices (GMOs)
GMOs are responsible for:
1. Including the National Term and Condition for Subawards described in Section 6.0 and Appendix B of this policy in all assistance agreements, providing EPA approvals as specified in the T&C, and providing the notification described at 8.0(d).
2. Complying with applicable pre-award and post-award requirements described in Sections 8.0 and
11.0 of this policy.
3. Working with Program Offices to ensure that subawards are not approved to individuals who are considered program beneficiaries as described in Section 11.0 of this policy.
4. Working with Program Offices to prevent improper 100% pass-through sub-awards as described in Sections 11.0 of this policy.
E. Office of International and Tribal Affairs (OITA)
OITA is responsible for acting on requests for EPA consent for subawards involving any work to be performed in a foreign country or any work to be performed in the U.S. by a foreign recipient or international organization as provided in section 11.0 of this policy. 87 EPA Subaward Policy Appendix A: Distinctions Between Subrecipients and Contractors
This Appendix uses 2 CFR 200.331 as the basis for distinguishing between subrecipients and contractors.
Pass-through entities make subawards to other organizations to carry out a portion of the Federal award under terms that establish a financial assistance relationship to accomplish a public purpose that is authorized under a Federal program. Subrecipients only receive reimbursement for their actual direct or approved indirect costs such that they do not “profit” from the transaction and subrecipients are subject to the same Federal requirements as the pass-through entity. In contrast, consistent with 2 CFR 200.331 ,
procurement contractors (including individual consultants) typically provide goods and services on commercial terms, operate in a competitive environment and a reasonable profit is allowable.
The regulations require that non-Federal entities award contracts following full and open competition with the exception of transactions in amounts below the micro-purchase level or when a sole source contract is properly justified; 2 CFR 200.319; 2 CFR 200.320 . Pass-through entities may enter into
subawards without competition unless a statute, regulation, or the terms of the EPA award provide otherwise. This distinction makes accurate determinations regarding whether a transaction is with a subrecipient or a contractor particularly important.
A subaward may be provided by any form of legal agreement that complies with 2 CFR 200.332(a)(1). A pass-through entity may use the term ‘contract’ to characterize a subaward arrangement. It is, therefore, important to examine the substance of the agreement using this appendix to determine if the transaction is a subaward or a procurement contract.
The legal status of an organization as a governmental unit, non-profit organization, institute of higher education, or for-profit organization while not necessarily determinative of whether the transaction at issue is a subaward or procurement contract is an important factor to consider. As provided in 2 CFR 200.331 recipients must exercise sound judgment in deciding whether a transaction is a procurement contract or subaward subject to this EPA guidance. Based on the standards at 2 CFR 200.331(a) and (b) EPA has determined that transactions:
1. Between legally distinct units of government (e.g. a state providing funds to a local government) will in almost all cases be either subawards or intergovernmental agreements under 2 CFR 200.318(e) rather than procurement contracts since governmental units do not provide services on commercial terms.
2. Between institutions of higher education (IHE), or between IHEs and units of government or nonprofit organizations, are typically subawards particularly when the transactions relate to joint research, training (including technical assistance and public education) or demonstration projects.
3. Between nonprofit organizations for collaborative projects that further the missions of both organizations are typically subawards although situations in which one nonprofit provides ancillary services that are widely available in the competitive market such as accounting or information technology for operations (e.g., payroll) to another nonprofit are characteristic of a procurement contract. 88 4. Between any recipient and a for-profit firm or individual consultant, in almost all cases, would be a procurement contract subject to the competitive requirements of 2 CFR 200.319 and 2 CFR 200.320.
For-profit firms and individual consultants operate in a competitive environment and provide goods and services on commercial terms to many different purchasers rather than carrying out a program for public purposes under the statute authorizing EPA to award financial assistance.
EPA’s National Term and Condition for Subawards requires EPA Award Official approval for subawards to for-profits and individual consultants. Examples of situations in which a for-profit firm may be an eligible subrecipient would be an EPA financial assistance program that provides funding for pollution control projects at a company’s production facilities and the firm will receive reimbursement for personnel and contractor costs. The for-profit firm in that case would not be providing goods and services to the pass- through entity.
As provided in 2 CFR 1500.1
, EPA considers rebates and similar subsidies for the purchase of commercially available “off the shelf” pollution control equipment or to encourage participation in environmental stewardship programs by companies and individuals to be participant support costs. These payments to program beneficiaries are not subawards. EPA’s
Guidance on Participant Support Costs provides
additional information on the distinction between participant support costs and subawards. 89 EPA Subaward Policy Appendix B: National Term and Condition for Subawards
If the recipient chooses to pass funds from this assistance agreement to other entities, the recipient must comply with applicable provisions of 2 CFR Part 200 and the EPA Subaward Policy, which may be found at https://www.epa.gov/sites/production/files/2016- 02/documents/grants_policy_issuance_gpi_16_01.pdf.
As a pass-through entity, the recipient agrees to:
1. Be responsible for selecting subrecipients and as appropriate conducting subaward competitions using a system for properly differentiating between subrecipients and procurement contractors under the standards at 2 CFR 200.331 and EPA’s supplemental guidance in Appendix A of the EPA Subaward Policy.
(a) For-profit organizations and individual consultants, in almost all cases, are not eligible subrecipients under EPA financial assistance programs and the pass-through entity must obtain prior written approval from EPA’s Award Official for subawards to these entities unless the EPA-approved budget and work plan for this agreement contain a precise description of such subawards.
(b) Stipends and travel assistance for trainees (including interns) and similar individuals who are not are not employees of the pass-through entity must be classified as participant support costs rather than subawards as provided in 2 CFR 200.1 Participant support costs , 2 CFR
200.1 Subaward, and EPA’s Guidance on Participant Support Costs.
(c) Subsidies, rebates and similar payments to participants in EPA funded programs to encourage environmental stewardship are also classified as Participant support costs as provided in 2 CFR 1500.1 and EPA’s Guidance on Participant Support Costs.
2. Establish and follow a system that ensures all subaward agreements are in writing and contain all of the elements required by 2 CFR 200.332(a). EPA has developed a template for subaward agreements that is available in Appendix D of the EPA Subaward Policy.
3. Prior to making subawards, ensure that each subrecipient has a “unique entity identifier.” This identifier is required for registering in the System for Award Management (SAM) and by 2 CFR Part 25 and 2 CFR 200.332(a)(1). Information on registering in SAM is available at the SAM Internet site:
https://www.sam.gov/SAM/
and in EPA’s General T&C “System for Award Management and Universal Identifier Requirements” of the pass-through entity’s agreement with EPA.
4. Ensure that subrecipients are aware that they are subject to the same requirements as those that apply to the pass-through entity’s EPA award as required by 2 CFR 200.332(a)(2). These requirements include, among others:
(a) Title VI of the Civil Rights Act and other Federal statutes and regulations prohibiting discrimination in Federal financial assistance programs, as applicable.
(b) Reporting Subawards and Executive Compensation under Federal Funding Accountability and Transparency Act (FFATA) set forth in the General Condition pass- 90 through entity’s agreement with EPA entitled “Reporting Subawards and Executive Compensation.”
(c) Limitations on individual consultant fees as set forth in 2 CFR 1500.10 and the General Condition of the pass-through entity’s agreement with EPA entitled “Consultant Fee Cap.”
(d) EPA’s prohibition on paying management fees as set forth in General Condition of the pass-through entity’s agreement with EPA entitled “Management Fees.”
(e) The Procurement Standards in 2 CFR Part 200 including those requiring competition when the subrecipient acquires goods and services from contractors (including consultants) and Domestic preferences for procurements at 2 CFR 200.322.
Other statutes, regulations and Executive Orders that may apply to subawards are described at Information on Requirements that Pass-Through Entities must “Flow Down” to Subrecipients.
Many Federal requirements are agreement or program specific and EPA encourages pass-through entities to review the terms of their assistance agreement carefully and consult with their EPA Project Officer for advice if necessary.
5. Ensure, for states and other public recipients, that subawards are not conditioned in a manner that would disadvantage applicants for subawards based on their religious character.
6. Establish and follow a system for evaluating subrecipient risks of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward as required by 2 CFR 200.332(b) and document the evaluation. Risk factors may include:
Prior experience with same or similar subawards;
(a) Results of previous audits;
(b) Whether new or substantially changed personnel or systems, and;
(c) Extent and results of Federal awarding agency or the pass-through entity’s monitoring.
7. Establish and follow a process for deciding whether to impose additional requirements on subrecipients based on risk factors as required by 2 CFR 200.332(c). Examples of additional requirements authorized by 2 CFR 200.208 include:
(a) Requiring payments as reimbursements rather than advance payments;
(b) Withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance;
(c) Requiring additional, more detailed financial reports;
(d) Requiring additional project monitoring;
(e) Requiring the non-Federal entity to obtain technical or management assistance, and
(f) Establishing additional prior approvals.
91 8. Establish and follow a system for monitoring subrecipient performance that includes the elements required by 2 CFR 200.331(d) and report the results of the monitoring in performance reports as provided in the reporting terms and conditions of this agreement.
9. Establish and maintain an accounting system which ensures compliance with the $25,000 limitation at 2 CFR 200.1, Modified Total Direct Costs, if applicable, on including subaward costs in Modified Total Direct Costs for the purposes of distributing indirect costs.
Recipients with Federally approved indirect cost rates that use a different basis for distributing indirect costs to subawards must comply with their Indirect Cost Rate Agreement.
10. Work with EPA’s Project Officer to obtain the written consent of EPA’s Office of International and Tribal Affairs (OITA), prior to awarding a subaward to a foreign or international organization, or a subaward to be performed in a foreign country even if that subaward is described in a proposed scope of work.
11. Obtain written approval from EPA’s Award Official for any subawards that are not described in the approved work plan in accordance with 2 CFR 200.308.
12. Obtain the written approval of EPA’s Award Official prior to awarding a subaward to an individual if the EPA-approved scope of work does not include a description of subawards to individuals.
13. Establish and follow written procedures under 2 CFR 200.302(b)(7) for determining that subaward costs are allowable in accordance with 2 CFR Part 200, Subpart E and the terms and conditions of this award. These procedures may provide for allowability determinations on a pre-award basis, through ongoing monitoring of costs that subrecipients incur, or a combination of both approaches provided the pass-through entity documents its determinations.
14. Establish and maintain a system under 2 CFR 200.332(d)(3) and 2 CFR 200.521 for issuing management decisions for audits of subrecipients that relate to Federal awards. However, the recipient remains accountable to EPA for ensuring that unallowable subaward costs initially paid by EPA are reimbursed or mitigated through offset with allowable costs whether the recipient recovers those costs from the subrecipient or not.
15. As provided in 2 CFR 200.333, pass-through entities must obtain EPA approval to make fixed amount subawards. EPA is restricting the use of fixed amount subawards to a limited number of situations that are authorized in official EPA pilot projects. Recipients should consult with their EPA Project Officer regarding the status of these pilot projects.
By accepting this award, the recipient is certifying that it either has systems in place to comply with the requirements described in Items 1 through 14 above or will refrain from making subawards until the systems are designed and implemented.
92 EPA Subaward Policy Appendix C: Model Programmatic Subaward Reporting Requirement
The recipient must report on its subaward monitoring activities under 2 CFR 200.332(d). Examples of items that must be reported if the pass-through entity has the information available are:
1. Summaries of results of reviews of financial and programmatic reports.
2. Summaries of findings from site visits and/or desk reviews to ensure effective subrecipient performance.
3. Environmental results the subrecipient achieved.
4. Summaries of audit findings and related pass-through entity management decisions.
5. Actions the pass-through entity has taken to correct deficiencies such as those specified at 2 CFR 200.331(e), 2 CFR 200.208 and the 2 CFR Part 200.339 Remedies for Noncompliance.
Note: EPA Project Officers may customize this reporting requirement based on programmatic information needs.
93 EPA Subaward Policy Appendix D: Subaward Agreement Template
OVERVIEW: Program Offices may provide this subaward template to recipients of EPA financial assistance that are Pass-through entity as defined by 2 CFR 200.1 to assist them in complying with the “subaward content” requirements in 2 CFR 200.332(a). EPA does not mandate the use of this template.
Pass-through entities may use their own form of subaward agreements provided the requirements of 2 CFR 200.332(a) are met. Any changes to the data elements that are required under 2 CFR 200.332(a) must be reflected in subsequent modifications to subawards. If any of the information required by 2 CFR 200.332(a) is not available, pass-through entities must provide the best information that is available to describe the Federal award and subaward.
Section I. [Title and Description of Subaward including whether the Subaward is for Research and Development]
Section II. Federal Requirements.
A. Federal Award Identification.
1. Subrecipient name--which must match registered name in the System for Award Management (SAM).
If the subrecipient is not yet registered in SAM, then information about registration procedures may be found at the SAM Internet site (currently at http://www.sam.gov).
2. The subrecipient’s “unique entity identifier” in SAM. This identifier is required for registering in SAM and by 2 CFR Part 25 and 2 CFR 200.332(a)(1).
Note: Additional information on registering in SAM is available at the SAM Internet site:
https://www.sam.gov/SAM/ and in the “General Term and Conditions” (T&Cs), under the “System for Award Management and Universal Identifier Requirements” T&C, of the pass-through entity’s agreement with EPA.
3. Federal Award Identification Number (FAIN) The FAIN corresponds with the “Assistance ID No.” on the EPA Notice of Award.
4. EPA Award Date. This is the date the EPA Award Official signs the assistance agreement with the pass-through entity and may be found on page 1 of the EPA Notice of Award.
5. Subaward Period of Performance Start and End Date;
6. Amount of EPA Funds Obligated under the initial subaward. Subsequent funding actions may be documented by amendments to the subaward.
7. Total or cumulative amount of EPA Funds Obligated to the subrecipient under the initial subaward plus any subsequent funded amendments. These amounts may be documented in sequential amendments to the subaward.
8. Total Amount of the EPA funds committed to the subrecipient by the pass-through entity. This is typically the “ceiling” amount for the subaward that may not be exceeded in funded amendments. 94 9. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA). This information may be found in the “Project Title and Description” box on page 1 of the EPA Notice of Award.
10. Information identifying EPA as the Federal awarding agency, your organization as the pass-through entity, and contact information for your awarding official for the subaward.
11. Assistance Listing Number and Name for each EPA award used to support the subaward.
Assistance Listing information for the pass-through entities’ EPA award may be found on page 2 of EPA’s Notice of Award form in the second chart under “EPA Award Information”. (Note the Uniform Grant Guidance requires at 2 CFR 200.332(a)(1)(xii) that the Pass-through entities identify the dollar amount under each Federal award and the CFDA number at the time of disbursement of Federal funds to the subrecipient so it is important for pass-through entities to maintain accounting records to meet this requirement.
12. Indirect cost rate for the pass-through entity’s Federal award. This rate may be found on page 3 of the pass-through entity’s EPA Award in Table A, Object Class Category and may be the 10% de-minimis indirect cost rate described at 2 CFR 200.414(f).
B. All “flow down” requirements imposed on the subrecipient by the pass-through entity to ensure that the EPA award is used in accordance with Federal statutes, regulations and the terms of the EPA award.
The subrecipient is accountable to the pass-through entity for compliance with Federal requirements. In turn, the pass-through entity is responsible to EPA for ensuring that subrecipients comply with Federal requirements.
These requirements include, among others:
1. Title VI of the Civil Rights Act and other Federal statutes and regulations prohibiting discrimination in Federal financial assistance programs, as applicable.
2. Reporting Subawards and Executive Compensation under Federal Funding Accountability and Transparency Act (FFATA) set forth in General Condition of the pass-through entity’s agreement with EPA entitled “Reporting Subawards and Executive Compensation.”
3. Limitations on individual consultant fees as set forth in General Condition 2 CFR 1500.10 and the General Condition of the pass-through entity’s agreement with EPA entitled “Consultant Fee Cap.”
4. EPA’s prohibition on paying management fees as set forth in General Condition of the pass-through entity’s agreement with EPA entitled “Management Fees.”
5. The Procurement Standards in 2 CFR Part 200 including those requiring competition when the subrecipient acquires goods and services from contractors (including consultants) and Domestic preferences for procurements at 2 CFR 200.322.
6. For states and other public recipients, a provision ensuring that subawards are not conditioned in a manner that would disadvantage applicants for subawards based on their religious character.
Other statutes, regulations and Executive Orders that may apply to subawards are described at Information on Requirements that Pass-Through Entities must “Flow Down” to Subrecipients. Many Federal requirements are agreement or program specific and EPA encourages pass-through entities to review the terms of their assistance agreement carefully and consult with their EPA Project Officer for advice, if necessary.
95 C. Any additional requirements such as financial and performance reports the pass-through entity imposes on the subrecipient to ensure that the pass-through entity meets its own responsibilities to the Federal awarding agency.
D. Subrecipient’s Indirect Cost Rate. The indirect cost rate may be a rate negotiated and approved by the subrecipient’s cognizant Federal agency. If the subrecipient does not have a Federal indirect cost rate, the pass-through entity may negotiate an indirect cost rate with the subrecipient that complies with 2
CFR Part 200, Subpart E or use the 10% de-minimis indirect cost rate described at 2 CFR 200.414(f).
E. Requirements for the subrecipient to provide access to subaward records so that the pass-through entity and Federal auditors may verify compliance with 2 CFR 200.332 as well as 2 CFR Part 200, Subpart D, Post Federal Award Requirements for Financial and Program Management, and 2 CFR Part 200, Subpart F, Audit Requirements. Examples of records include:
1. Subrecipient financial statements and reports;
2. Programmatic reports including information on environmental results
3. Audit findings
F. Additional Requirements imposed by the pass-through entity under 2 CFR 200.208 that reflect the pass- through entity’s assessment of the subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward based on the factors described at 2 CFR 200.332(b).
1. Risk factors may include:
(a) Prior experience with same or similar subawards;
(b) Results of previous audits;
(c) Whether new or substantially changed personnel or systems, and;
(d) Extent and results of Federal awarding agency or the pass-through entity’s monitoring.
2. Examples of additional requirements authorized by 2 CFR 200.208 include:
(a) Requiring payments as reimbursements rather than advance payments;
(b) Withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance;
(c) Requiring additional, more detailed financial reports;
(d) Requiring additional project monitoring;
(e) Requiring the non-Federal entity to obtain technical or management assistance, and;
(f) Establishing additional prior approvals.
96 G. Terms and conditions concerning the close out of the subaward.
III. Other requirements based on the pass-through entity’s own laws, regulations, and policies to the extent that they do not conflict with applicable Federal laws, statutes, regulations and policies. 97