Notable Changes in the FY14 EPA Brownfield Grant Proposal Guidelines

by JEFF HAWKINS
Nov 27, 2013
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Last week, the Environmental Protection Agency (EPA)'s Office of Brownfields and Land Revitalization (OBLR) formally released the Fiscal Year (FY) 2014 Guidelines for Brownfield Assessment, Cleanup and Revolving Loan Fund (ARC) Grants. Our team has reviewed the release document and has provided a summary of the anticipated program for FY14.

In this year's guidance release, the EPA estimates total funding for the program to be $63.2 million, an increase of approximately $3 million from FY13. The majority of the increase in funding will be directed toward Assessment Grants. In addition, the number of anticipated Cleanup and RLF Grant awards is slated to decrease from FY13. EPA anticipates awarding 198 Assessment Grants ($40 million), 61 Cleanup Grants ($14 million) and 10 RLFs ($10 million).

It should be noted that if you received an assessment grant from EPA in Fiscal Year 2013 you are not eligible to apply this year; this includes applicants that were part of a coalition.

Due to the later than normal release date of the EPA guidance document, the deadline for the FY14 ARC Request For Proposal (RFP) is set for 11:59 EST on January 22, 2014. Given the release coincides with the start of the holiday season, there are sure to be added time constraints on applicants and further challenges coordinating with community partners. Applicants must demonstrate a commitment to involve and inform their community and any associated stakeholders. The application will need to demonstrate high levels of community engagement, which will occur along each stage of the proposed grant implementation process: initial planning, implementation and other brownfield assessment activities. Additionally, it will be important to request your letter early from the State of Michigan (MDEQ) that acknowledges your community's plans to apply for federal grant funds.

Community involvement has remained an integral component of successful EPA grant applications. In fact, for the FY14 grants, community involvement is now both a threshold criteria and ranking criteria requirement. Until this year, community involvement had only been included in the point-based ranking criteria.

According to the EPA, as one of the new threshold eligibility qualifiers, "failure to demonstrate community involvement in the threshold criteria will result in the proposal not being further evaluated." Simply put, this addition clearly demonstrates that community involvement has been elevated in weight and is more important than ever. Not only will the EPA require community involvement to attain high enough criteria points but to even qualify as an applicant.

These partnerships help to drive successful grants by linking community goals and priorities and creating valuable synergy between organizations. The EPA requires each organization to provide a letter of support demonstrating their role in the grant planning and implementation process.

Applicants will also notice that several of the evaluation factors appear in a new order and the EPA has added several new sub-criteria to the RFP's overall structure. Each ARC RFP also contains a new fifth ranking criterion and therefore the point allocation to each has been altered some to reflect this addition. With the expansion of more extensive sub-criterions, the page requirements remain the same for the transmittal letter and the narrative proposal. Applicants will need to balance the expansion of sub-criterion requirements with the same page limitations as the previous grant cycle.

The RFP's Ranking Criteria now features new evaluation factors for applicants to consider. Most notably, the EPA now requires a Targeted Community section, which aims to collect more information on the current economic conditions of your community and the anticipated criteria/process used to select specific sites.
Additionally, in FY14, the EPA no longer requires applicants to outline their plan to track or measure progress towards short and long term goals. Lastly, although the EPA still encourages applicants to share other current or anticipated sources of funding to demonstrate an increased likelihood of success, applicants are "no longer required to demonstrate firm leveraged commitments." If an applicant is unable to provide any potential sources, the EPA will allow an example from a project partner where they have effectively leveraged other funding to tackle an environmental or revitalization goal.

As noted above, the EPA continues to adjust the process for applications, requesting additional information that aligns with the goals and objectives of the Small Business Liability Relief and Brownfield Revitalization Act ("Brownfields Law"). Due to the number of applicants each year (typically over 800), these grants are extremely competitive. A successful application requires close attention not only to the information requested, but also the format, various criteria, and attachments that are required.

If you have any further questions, please feel free to reach out for further assistance. My team is available to help navigate the complexities of the FY14 guidelines and each step of the application process.

Meet the Author

Jeff HawkinsJeffrey C. Hawkins is President, founder and a co-owner of Envirologic Technologies, Inc., a full-service environmental services firm celebrating nearly 25 years of business. Mr. Hawkins has over 27 years of environmental consulting experience in the field. Mr. Hawkins is frequently utilized as an expert on Brownfield redevelopment issues.

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