EPA Region 4 Brownfields Grant Writing Workshop CLU-IN Sessions of August 22 and September 13, 2007 Attendees Questions and EPA Region 4 Answers Preface: The National Brownfields Program Frequently Asked Questions (FAQs) for Assessment, Revolving Loan Fund and Cleanup Grants are currently posted at our CLU- IN Resource web-site at http://www.epa.gov/brownfields/fy08_grantfaq_final.pdf. We suggest that you also review these FAQs posted at the location listed above. 8/22/2007 CLU-IN Session 1. I know that you have targeted brownfields "assessment" money that is noncompetitive, but do you have targeted brownfields "cleanup" funds that are not competitive? No. Currently, EPA s Targeted Brownfields Assessment dollars are used to perform environmental site assessments only. Your state environmental agency receives Brownfields Law Section 128(a) funding and may allocate a small percentage of those funds for targeted brownfields cleanups. However, only certain states perform cleanups at this time. So please check with the Brownfields contact at your state environmental agency for more information. You may access a list of the Region 4 State contacts at the following address: http://www.cluin.org/conf/tio/r4bfgrantwriting/bf.statecontacts.aug2007.pdf 2. Please discuss what eligible attachments are. Is there a limit to attachments? Page 17 of the Proposal Guidelines for Brownfields Assessment, Revolving Loan Fund, and Cleanup Grants FY 08 (Guidelines) lists the following as eligible attachments: a. Documentation of non-profit status, if applicable; b. Documentation of applicant eligibility if other than city, county, state, or tribe; c. [A] Letter from the state or tribal environmental authority; d. For site-specific assessment waivers only Justification for [a] waiver; e. For cleanup and RLF applicants only Legal opinion to access and secure sites in the event of an emergency or default of a loan agreement or nonperformance under a sub-grant; f. For RLF applicants only Legal opinion that demonstrates your legal authority to perform the actions necessary to manage a revolving loan fund. 1
Applicants are advised to avoid submission of non-essential materials unrelated to the requirements identified in the Guidelines. Your proposal will be copied and distributed to evaluators. So we encourage you to limit your attachments only to those items essential to your proposal. 3. What specifics should the states include in their letters? The State letter simply acknowledges that the state environmental agency is aware that the applicant is submitting the brownfields proposal(s), and the state supports the possible award of the grant to the applicant. States have provided these support letters for several years and are aware of the information that should be included in the letter. If you are applying for multiple grants or grant types, only one letter reflecting all proposed activities is required; however, this letter should be included with each proposal. One important thing to remember is that the letter must be current for the year in which you are submitting the proposal(s). Letters regarding proposals from prior years are not acceptable. Site Specific Assessment or Cleanup Proposals for Petroleum Only: If you plan to submit a site-specific assessment or cleanup proposal for petroleum contamination, you must also ask your state representative to determine if the site you choose is eligible to receive Brownfields funding based on the criteria listed below or the state s own eligibility criteria (reference the site in your request to the state). You must provide information in your proposal indicating the date you submitted your request above to the state and whether the site meets each of the following criteria: a. The site is of relatively low risk compared with other petroleum-only sites in the state; and b. There is no viable responsible party; and c. The site will not be assessed, investigated or cleaned up by a person that is potentially liable for cleaning up the site. For more information on petroleum site eligibility requests, please see pages 25 and 67 of the Guidelines for assessment proposals and pages 48 and 67 for cleanup proposals. You may access a list of the Region 4 State contacts at the following address: http://www.cluin.org/conf/tio/r4bfgrantwriting/bf.statecontacts.aug2007.pdf For participants from other EPA regions, we suggest you contact the EPA Regional Brownfields contact listed on page 61 of the Guidelines. The list Contact List is located at: http://www.epa.gov/swerrims/docs/grants/epa-oswer-obcr-07-09.pdf. Your regional office should be able to share with you the State/Tribal Brownfields contact to help write an acknowledgement letter. 2
4. Can costs for acquiring properties be considered as the 20% matching requirement? How about infrastructure improvements to the neighborhood? No. Costs for acquiring property cannot be considered as the applicant s 20% cost share. The cost share must be used for an eligible and allowable expenditure under the Brownfields Law. It may be in the form of money, labor, material, or eligible services. Neither land acquisition nor infrastructure improvements are eligible activities under the Brownfields grant authority and therefore cannot be used as the local match. 5. Would a four-block area be considered a site-specific assessment application? If you plan to assess multiple properties within a four-block area, then EPA recommends that you submit a community-wide proposal. Site-specific assessment proposals include one property/parcel. If you submit a proposal with adjacent properties owned by the same entity, then you would be able to submit a site-specific assessment proposal. Otherwise, you must submit a community-wide proposal. 6. Please repeat the conference information. The National Brownfields 2008 Conference will be held on May 5-7, 2008 in Detroit, Michigan at the Cobb Center. The address is: One Washington Boulevard Detroit, MI 48226 For more information about the National Conference, please access: http://www.brownfields2008.org/en/index.aspx 7. Are fees to the State Voluntary Cleanup (VCP) program for review and participation an eligible budget item? Fees associated with participation in a State Voluntary Cleanup Program (VCP) are eligible expenses for the competitive brownfields grants. 9/13/2007 CLU-IN Session 8. Is this grant program open to non-profits such as watershed associations? A non-profit is only eligible to apply for brownfields clean-up grants. If a Revolving Loan Fund grantee is in your regional area, non-profits are eligible to apply for subgrants offered under that program. Please refer to pages 14-15 of the Guidelines for a complete list of which eligible entities can apply for which grant. 3
9. Regarding the Fee Simple Title: If a watershed association does not own the land, can they enter into an agreement with the owner to be the agent for the owner to make the application for funding? Fee simple titles are only necessary for Brownfields cleanup grants. Each cleanup grant applicant must first compete successfully in the national proposal process, and then legally own the property by June 30, 2008 to receive Brownfields cleanup grant funding. A non-profit watershed association can apply for the cleanup funding. Having such a sales agreement in advance with the owner to complete the sale of the land to the watershed association prior to the time requirement of June 30, 2008 is a good idea. Our Cleanup grants require successful applicants to own the property (per the Guidelines, the term own means fee simple title). The grantee must maintain such sole ownership until all the cleanup work funded by the grant is complete. For a Brownfields assessment grant, you do not have to own the property, but you do have to describe how you are planning to gain access to it. 10. How can we obtain a list of the participants in this session? The participants for both the August 22 nd and the September 13 th CLU-IN Grant-Writing Workshops are listed at: http://clu-in.org/conf/tio/r4bfgrantwriting/resource.cfm. Take advantage of other resources, such as our presentation on grant-writing tips and our great new Ranking Criteria Section Length Tools that are located there as well. 11. In the grant proposal is it a good idea to confer with the local historical society to include the site background into the proposal? Yes. The Community Need section in the Guidelines (Ranking Criteria, B.1., worth 5 points) asks for a detailed description of the targeted community. So it might be helpful to include information from your local historical society here. Be judicious with your section lengths. Using our Section Length tools, for a typical Community-Wide assessment grant, B1 is suggested to be at an approximate 0.6 page length, so be concise. Relevant, supplemental information can be placed at any time in the Attachment section of your proposal. In our on-line comments, it was shared that winning grantees will have to be in compliance with the National Historic Preservation Act (NHPA), and to make sure those statutes are being followed during the course of your grant. 12. Comment: Please note that registration on Grants.gov may take more than 2-3 days. You must have a DUNS number to start. If not, you must add additional time to obtain one. Please begin registration now to avoid problems. Good suggestion. Page 19 of the Guidelines describes the EPA submission requirements for your proposal (either hard-copy or electronic.) If you choose to submit your proposal electronically via www.grants.gov, give yourself enough time to register on that website and to request a DUNS number. For more information on acquiring a DUNS number, please refer to: http://www.whitehouse.gov/omb/grants/duns_num_guide.pdf. 4
13. Regarding maps and photos of the site, can we reference web sites that have the mapping of the site to save proposal space? It is important to clearly provide a written description of your targeted community in sub criterion B1. The applicant may choose to enhance a written description with references to websites within the required first 18-main pages. Keep in mind that EPA reviewers evaluate the grant proposal based on what is contained within the first 18 pages and are not required to research web-sites for maps and other items. As previously stated, you may enclose a readable, black and white map in the Attachment section. 14. What does the Letter from the State cover and what state agency issues it? Please refer to the answer for #3. 15. How much weight is given to Environmental Justice concerns in the proposal? Environmental Justice (EJ) is referenced in the sub criterion, B.1, Community Need. If applicable, EJ should be incorporated into B.1 of the Ranking Criteria (worth 5 points). The applicant must provide a description of their community (e.g., poverty, racial statistics, unemployment rate, sensitive populations, etc.) and demographics in that section. 16. Question regarding 1" margin, as mentioned on slide 27? Can someone locate (page number, section) in the Proposal Guidelines where it indicates that proposals are limited to 1" margins? The Region suggests you use 1 margins. This is not a requirement. However, we encourage you to do so to ensure your proposal is readable. 17. Slides 50, 51, 52 Helpful Hints are somewhat different but clearer than the print out from the web site. How can we get these revised slides? The Helpful Hints slides have been incorporated into the September 13 th presentation. Please download these from the CLU-IN website at: http://clu-in.org/conf/tio/r4bfgrantwriting/resource.cfm 18. If I include an attachment to demonstrate pre-award communication, or community involvement, does that count against the 18 pages? No. As long as you refer to it and include it within the attachments, this will not count against the first 18 pages. 19. Can you tell me the implications of having a hazardous only assessment grant and discovering petroleum contamination during the assessment process? In other words, if you have funding for hazardous materials grants and during the Phase I or Phase II 5
process you discover that there is petroleum contamination on the site or in the area. How can you proceed with addressing the petroleum contamination? First of all, should you suspect you have separate petroleum contamination that is not comingled, we suggest you also submit a petroleum assessment proposal. Recall that during our on-line workshop, an example was given of a rails-to-trails applicant, who unsuccessfully submitted a hazardous substance proposal last year and may now consider a petroleum proposal. The rationale was that petroleum contamination likely exists as a result of a maintenance and/or switchyard within the 14 miles of a former railroad. If you do discover petroleum during the performance of your hazardous substance assessment grant, as long as it is co-mingled, you can indeed conduct a Phase II assessment. But if it is a distinct concentrated cell of petroleum contamination (e.g., underground storage tank), we suggest you use a separate petroleum assessment grant to conduct the Phase II work. 20. I am doing a site-specific assessment proposal for an old textile mill. My targeted community includes the owners of the 23 remaining original mill houses. Most of the demographic information from the Census Bureau is on a census tract basis only. Is it acceptable to personally gather demographic information on these residents through personal visits and public meetings prior to application submission? Yes. For smaller targeted communities, within larger census tracts, you may obtain anecdotal information from visits and public meetings. Ensure that you cite the source for your demographic information (as the Guidelines require). Oftentimes, U.S. Census tract data pertains only to large tracts; for Region 4 participants, a good resource person is Genora F. Barber, US Census Bureau, Information Services Specialist, 404-730-3833, 404-730-3964 (fax), genora.f.barber@census.gov. 21. Our organization and environmental engineer consultant downloaded the guidelines in early August so that we could begin planning for a cleanup grant application. These guidelines state applicant must be sole owner by June 30, 2007. Please verify that it is, in fact, June 30, 2008, as this will change applicant, site, etc. The Proposal Guidelines for Brownfields Assessment, Revolving Loan Fund, and Cleanup Grants FY 08 was posted on August 15, 2007. This year s Guidelines are only slightly changed from last year s. The ownership date was one of the modifications made. Cleanup applicants must now have sole ownership of the property by June 30, 2008. 22. What language is required in the state acknowledgement letter? Is there a sample letter available online? Please refer to answer for #3. There is no sample letter online to our knowledge. 23. Could you expound on the difference between targeted assessment and assessment grants? 6
Under the Targeted Brownfields Assessment (TBA) program, EPA provides technical assistance for environmental assessments at Brownfields sites throughout the country. EPA s TBA assistance is available through two sources: directly from the EPA regional Brownfields program and from State or Tribal Brownfields programs. EPA s regional TBA program (as mentioned on slide 23 of the online CLU-IN presentation) provides limited funding for conducting high priority Phase I or Phase II assessments for successful applicants. The EPA Regions have discretion in selecting applications for properties that are abandoned or publicly owned; have low to moderate contamination; include issues of environmental justice; suffer from the stigma of liability; or have a prospective purchaser willing to buy and pay for cleanup of the property, if needed. In conducting a TBA, EPA Regional Brownfields offices provide contractual services to perform assessments of sites recommended by local governments. In these TBAs, EPA oversees the technical and financial processes for conducting this work. A TBA fact sheet can be found at www.epa.gov/brownfields/facts/tba_0403.htm. Since the availability of TBA funding is rather limited compared to the overall $72M in grant opportunities afforded by the National EPA Brownfields grant program, we encourage you to apply for the competitive assessment grant first. 24. The SBIR (Small Business Innovative Research) program supplies examples of sucessful grant applications. Can you do the same for BF grants? You may receive a copy of specific successful Brownfields grant proposals by contacting the Region 4 Freedom of Information Act (FOIA) office at: U.S. Environmental Protection Agency Region 4 Freedom of Information SNAFC Bldg, 61 Forsyth Street, S.W., 9th Floor Atlanta, GA 30303-8960 (404) 562-9891 FAX (404) 562-8054 Email: r4foia@epa.gov If you choose to submit your request electronically, please view the site listed below: http://www.epa.gov/region4/foiapgs/submit.htm We suggest that you visit the website to view a list of EPA s current grantees at http://epa.gov/brownfields/plocat.htm. Then contact those award-winning grantees from FY07 (marked new and in yellow). The respective Fact Sheets list contact information. Most applicants are usually flattered that you are requesting successful proposals to use as a model. However, they are not required to give you this information. Please note that those applicants who used environmental consultant firms as grant-writers may be reluctant to share their proposals, as these firms limit the sharing based upon propriety information. However, the cities and towns without a 7
third-party grant-writer are often happy to share their winning proposals. We also suggest you conduct an internal and external peer review before submitting final proposals to EPA. 25. Can you please clarify the types of contaminants that you would be eligible "other environmental contaminants"? EPA does not actually make an eligibility determination based on the types of contaminants present. Eligibility is based on whether or not the site meets the definition of a brownfields site and whether or not an entity is eligible to apply for a grant. The Small Business Liability Relief and Brownfields Revitalization Act defines a brownfields site as real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant. The Law further defines the term brownfields site to include mine-scarred lands and sites that are contaminated by a controlled substance or by petroleum products. These broad definitions allow for a wide variety of contaminants to be addressed with Brownfields funding. It is important to be aware that the ranking criterion Reduction of Threats to Human Health and the Environment carries the highest amount of available points for each grant type. Sites perceived by reviewers to have lower threats due to less harmful substances will likely be scored lower than those with greater threats posed by more dangerous substances. 26. Can we apply if we like to open a community center for our children? Our area [is] growing so fast with housing and schools; however, there are no community centers for our children. Yes. Re-using a parcel of land for a community center may be feasible. You may be eligible to apply for an assessment grant (refer to pages 14-15 of the Guidelines) for a given site or for several properties where redevelopment is occurring. In the case of an assessment grant, if a Phase I environmental site assessment (ESA) reveals contamination, then a Phase II ESA would be required to fully assess the contamination on a given property. After a Phase II environmental assessment is completed and if high levels of contamination are present, then the owner of that property may choose to apply for a brownfields cleanup grant (see page 14 of the Guidelines for eligible applicants). With a cleanup grant, one would expend funds to conduct remedial actions and/or implement and maintain institutional or engineering controls in order to protect public health and the environment on that property (especially since the re-use is centered around children). 27. Is there a spacing requirement? Double or single space for the proposal? No. There is no specific reference to line spacing. We suggest single spacing in order for the applicant to have more space to thoroughly address each ranking criteria. 8
28. Can you describe the co-mingled plume condition that contains hazardous substances with petroleum? A co-mingled plume occurs when substances from two or more contaminant sources mix in the groundwater. In the event that an entity applies for and receives a hazardous substance cleanup grant and later discovers previously unknown petroleum contamination in the groundwater, the grant funds may be used to address petroleum contaminants in the groundwater, subject to the $200,000 funding limit and three-year time limit for the grant. 29. Please elaborate on the specifics of what sort of property owner information is required at the time of submission of the application for a community-wide/regional Assessment Grant. It was a little confusing to me as to exactly what EPA requires on this as part of the application. For Community-Wide Assessment grants, no property owner information is required at the time of submission. For these kinds of proposals, the threshold section is rather simple to complete. After grant award, you will be required to work with your EPA project officer to determine if specific properties are eligible for funding Phase II assessment work. 30. I would very much like to know more about the Targeted Assessment Grant program as I have a Manager of a small town who met with your counterparts in the DC office of EPA, and it was suggested that the three UST sites in the town could very possibly be eligible as special circumstances. After hearing Olga Perry speak briefly about the program today and then going to the EPA website for more information, I m thinking it s this program the person in DC was talking about. Please refer to the response to # 23. 31. Could large abandoned hog farms with lagoons holding tons of waste qualify as a Brownfield? Yes. However, the amount of Brownfields funding available may not be adequate to properly assess or clean up such a large site. For cases such as this, it may be prudent to find partners to work with you to ensure the success of the project. 9