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Proposal Guidelines for
Brownfields Job Training
Grants
Recycled/Recyclable
Printed with Soy/Canola Ink on paper that
contains at least 50% recycled fiber
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Solid Waste and EPA-500-F-02-143
Emergency Response November 2002
(5105T) www.epa.gov/brownfields
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Table of Contents
1. EPA's Brownfields Job Training Grants 3
1.1. Background 3
1.2. EPA's Brownfields Demonstration Grants 3
2.
3.
4.
Summary of Brownfields Job Training Grants Program 5
2.1. Deadlines 5
2.2. Applicant Eligibility 5
2.3. Authority for Job Training Grant Program 6
2.4. Eligible Uses of EPA Funds 6
3.5. Prohibited Uses of EPA Brownfields Job Training Grant Funds 6
Proposal Submission and Selection Process Overview 9
3.1. Evaluation of the Proposals 9
3.2. Proposal Submission Schedule 10
Job Training Proposal Guidelines 11
4.1. Cover Page 11
4.2. Threshold Criteria 11
4.3. Ranking Criteria 12
Appendix 1. EPA Regional and Headquarters Contacts 17
Appendix 2. Prohibitions on Use of Funds 19
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EPA's Brownfields Job Training
Grants
These guidelines are provided pursuant to Catalog of Federal Domestic
Assistance Number 66.811 (a revised CFDA entry has been submitted for
approval).
The new Small Business Liability Relief and Brownfields Revitalization Act ("Brownfields Law" or "the
Law", P.L. 107-118) allows the U.S. Environmental Protection Agency (EPA) to provide training to
facilitate assessment, remediation, or preparation of brownfields sites. A brownfield site is "real property,
the expansion, redevelopment, or reuse of which may be complicated by the presence or potential pres-
ence of a hazardous substance, pollutant, or contaminant," as defined in §101(39) of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980, as amended (CERCLA). Applicants
for this program must be located in or near a community mat currently receives, or has received, financial
assistance from EPA for brownfields-related activities.
1.1. Background
In the early 1990s, stakeholders expressed concerns to EPA that more than 600,000 properties that were
once used for industrial, manufacturing, or other commercial uses were lying abandoned or underused due
to the actual or perceived presence of hazardous substance contamination. Brownfield areas, particularly
those in city centers, were contributing to blight and joblessness in surrounding communities. Unknown
environmental liabilities were preventing communities, developers, and investors from restoring these
properties to productive use and revitalizing impacted neighborhoods.
In 1994, EPA responded to the brownfield problem with an approach that is locally based, encourages
strong public-private partnerships, and promotes innovative and creative ways to assess, clean up, and
redevelop brownfields sites. This approach empowers state, tribal, and local environmental and economic
development officials to oversee brownfield activities. It encourages implementing local solutions to local
problems. EPA also has provided funding to create local environmental job training programs to ensure
that the economic benefits derived from brownfield revitalization efforts remain in local neighborhoods.
A critical part of EPA's efforts to encourage assessment and cleanup of brownfields is participation by
affected residents. In addition, EPA works to ensure that disadvantaged residents do not bear a dispro-
portionate burden of the effects of environmental contamination. To help residents take advantage of jobs
created by the assessment and clean up of brownfields, EPA initiated the Brownfields Job Training Grants.
1.2. EPA's Brownfields Financial Assistance Program
EPA's Brownfields Program is an organized commitment to help communities revitalize brownfield proper-
ties both environmentally and economically, mitigate potential health risks, and restore economic vitality to
areas where brownfields exist. Successful cleanup and redevelopment of brownfields are proof that
economic development and environmental protection can indeed coexist. As a part of the Brownfields
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Economic Redevelopment Initiative, EPA has funded over 500 brownfields grants. The grants are de-
signed to empower states, communities, tribes, and other economic redevelopment stakeholders to work
together in a timely manner to prevent, assess, safely cleanup, and sustainably reuse brownfields.
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Summary of Brownfields
Grant Programs
Under this announcement, EPA is requesting applications for Brownfields Job
Training Grants. This is a competitive grant program, conducted under a ranking
system established under the new Brownfields Law.
EPA will award up to $200,000 per job training grant. However, EPA reserves the right to fund successful
proposals at lower amounts depending on the availability of EPA funds, applicant access to other sources of
funds, quality of applicant proposals, and needs of the community.
Successful applicants will be able to use brownfields job training grant funds to bring together community
groups, job training organizations, educators, investors, lenders, developers, and other affected parties to
provide training to residents in communities impacted by brownfields and to empower local community
residents. The Job Training Program's goals are to prepare the trainees for future employment in the
environmental field and facilitate cleanup of brownfield sites contaminated with hazardous substances,
pollutants, or contaminants. Although EPA has decided not to require recipients to provide program funding
through a specific matching formula, EPA will take into account the extent to which recipients demonstrate
the ability to "leverage" limited funds when evaluating and ranking proposals.
2.1. Deadlines
Proposals must be postmarked by January 24,2003. Depending on the availability of funds, EPA
expects to select approximately 10 Brownfields Job Training Grants by the end of April 2003.
2.2. Applicant Eligibility
Applicants must be "eligible entities" as defined in CERCLA § 104(k)( 1) or nonprofit organizations as
defined in Public Law 106-107, the Federal Financial Assistance Management Improvement Act. Eligible
entities under CERCLA § 104(k)(l) include a general purpose local unit of government; a land clearance
authority or other quasi-governmental entity that operates under the supervision and control of, or as an
agent of, a general purpose unit of government; a governmental entity created by a state legislature; a
regional council or group of general purpose unit of local government; a redevelopment agency mat is
chartered or otherwise sanctioned by a state; a state; "an Indian Tribe (other than in Alaska), or an Alaskan
Native Regional Corporation and an Alaska Native Village Corporation as those terms are defined in the
Alaska Native Claims Settlement Act (43 U.S.C. 1601 and following), and the Metlakatla Indian
Community. EPA welcomes and encourages applications from coalitions of such entities, but a single
eligible entity must be identified as the legal recipient. Intertribal consortia, except consortia comprised on
ineligible Alaska tribes, are eligible to apply as well.
Eligible applicants must be located in or near a community that currently receives, or has received, financial
assistance from EPA for brownfields-related activities. For a complete listing of existing EPA-funded
brownfield grant areas, please visit: http://www.epa.gov/swerosps/bf/pilot.htmttassess.
EPA encourages eligible applicants with experience in providing environmental job training and placement
programs to apply.
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2.3. Authority for Brownfields Job Training Grants
Funding for the brownfields environmental job training grants is authorized under § 104(k)(6) of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended,
(CERCLA or Superfund), 42 U.S.C. 9660(b)(9)(A). This statute authorizes EPA to provide, or fund
eligible entities or nonprofit organizations to provide, training, research, and technical assistance to
individuals and organizations, as appropriate, to facilitate site assessment, remediation of brownfields sites,
or site preparation. EPA awards grants authorized by § 104(k) under a ranking system that includes factors
relating to community need, stimulation or leveraging other funds, community involvement, eligibility for
funding from other sources, effective use of existing infrastructure.
2.4. Eligible Uses of EPA Funds
Project proposals must conform to the following guidelines:
• Grant funds may be used to train residents for the handling and removal of hazardous substances, which
includes training for jobs in sampling, analysis, and site remediation.
Funds also may be used for the following: 1) training in the management of facilities at which hazardous
substances are located; 2) training for response activities often associated with cleanups—for example,
landscaping, demolition, and groundwater extraction; and 3) development of curriculum for the training
described in this paragraph.
Grant funds may be used for training participants in the use of techniques and methods for cleanup of
leaking underground storage tanks and other sites contaminated by petroleum products, asbestos
abatement, or lead abatement where this training is a component of a more comprehensive hazardous
waste management training course or environmental technology training course.
Grant funds may be used for outreach activities directed toward improving participation in hazardous
waste management training for communities impacted by brownfields. Proposed training programs must
establish procedures to ensure that participants are recruited from the neighborhoods where the
brownfields site(s) are located and graduates from their training programs are employed in assessing and
cleaning up hazardous waste facilities.
2.4. Prohibited Uses of EPA Brownfields Job Training Grant
Funds
Grant funds may not be used for conducting site assessments or actual cleanups. Grant funds may not be
used for conducting response activities often associated with cleanups—for example, landscaping,
demolition, and groundwater extraction. Assessment, cleanup, and associated activity costs should
be funded through other means.
Grant funds may not be used for general or life skills education activities, job readiness training, job
placement costs, GED costs, transportation costs or stipends for students, web site development, vehicle
or medical insurance, or child care costs.
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Grant funds may not be used for costs that are unallowable (e.g. lobbying, fund-raising) under OMB
Circulars A-21 (universities), A-87 (state, tribal, and local governments), or A-122 (nonprofit
organizations), as applicable.
Grant funds may not be used to match any other federal funds unless there is specific statutory authority
for the match. CERCLA does not provide this authority. However, grant funds may be used to match
state or local funds if authorized by the relevant state statute or local ordinance.
Under the new Brownfields law, grant funds may not be used for administrative costs. See
Appendix 2 for details on this important prohibition.
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Proposal Submission and
Selection Process Overview
3.1. Evaluation of the Proposals
The National Brownfields Job Training Grants are awarded to the highest ranking
applicants, as determined by EPA under a competitive ranking system. Evaluation panels consisting of EPA
Regional and Headquarters staff and other federal agency representatives will evaluate the proposals and
make recommendations to EPA senior management. Disputes will be resolved under 40 CFR 30.63 and
40 CFR Part 31, Appendix F.
The evaluation panels will assess how well the proposals meet the evaluation criteria outlined below. There
are two different types of criteria-threshold criteria and ranking criteria. Threshold and ranking criteria
will be clearly indicated in each section below. If a response to a threshold criterion fails, the proposal
will be disqualified from further consideration under these guidelines. However, EPA Regions may seek
clarification from an applicant regarding its response to certain threshold criteria.
Scores on each ranking criterion will be totaled to determine proposal rankings. EPA will not seek
clarification of responses to ranking criteria. The panels determine which proposals have the potential to
effectively use the limited funds EPA has available for awards. The highest ranking proposals will be
selected by EPA senior management taking into consideration the recommendations of the review panel
and geographic distribution of funding between urban and non-urban areas and among EPA regions.
Proposals must be clear and concise and strictly follow each of the criteria. Sufficient detail must be pro-
vided for the panel to evaluate the merits of each proposal and decide which proposals best support the
intent of the grant program. Vague descriptions, redundancy, and failure to address budgetary responsibility
for training, recruitment, and placement costs may result in a lower rating. Incomplete proposal packages
will not be accepted. Proposals providing the best evidence of need, quality proven record of job placement
and student tracking, leveraging of partnerships with public and private sources, measures of success, a
comprehensive budget analysis and detailed budget narrative, and effective use of funds will have the best
chance of being recommended for funding by the panels.
EPA's goal is to select brownfields environmental job training projects that will serve as training models for
other communities across the nation. EPA will only fund projects that are integrated with their community's
existing brownfields cleanup and redevelopment efforts. In addition, EPA will evaluate how the proposed
training project fits in with other federal, state, tribal, and local sustainable development and job training
programs; community revitalization programs; and pollution prevention programs.
Pre-application assistance is available to all potential applicants upon request. EPA encourages interested
parties to contact the EPA office in their Region (contacts are provided at the back of the guidelines) to
answer questions regarding their proposal. Please note that taking advantage of pre-application assistance
from EPA Regional staff does not guarantee selection by the national panel.
Following the panel review and senior management selection, successful applicants will receive a
confirmation letter, and the appropriate EPA Regional Brownfields Coordinator and Regional Grants
Specialist will be informed. EPA anticipates that other applicants will be informed of EPA's decision within
approximately 60 days of final decisions on grants by senior management.
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EPA will ask the successful applicants to submit a formal cooperative agreement application package. This
package will include a formal work plan that describes the work to be performed, including a final budget,
and the required certification forms. The EPA Regional Brownfields Coordinators and Regional Grants
Specialists will work closely with the applicants to process and finalize the Cooperative Agreement pack-
age.
Proposal funding is not guaranteed at any stage of the proposal process until the Cooperative
Agreement is finalized and the final award is made. EPA reserves the right to reject all proposals
and make no awards.
Prior to application, interested parties should contact the EPA office in their Region (contacts are listed in
Appendix 7).
3.2. Proposal Submission Schedule
November 2002
January 24,2003
April 2003
Federal Register Notice published
Proposals due to EPA
Announcement of Grants
Submit two copies of your proposal, including attachments, to EPA headquarters. In addition, submit one
copy of your proposal, including attachments, to your EPA Regional Brownfield Contact (listed in Appen-
dix 7). Proposals must be sent to EPA by January 2003.
Mail your proposal to:
U.S. Environmental Protection Agency
OSWER Office of Brownfields Cleanup and Redevelopment (5105T)
Attn: LaKisha Odom
1200 Pennsylvania Avenue, NW
Washington, DC 20460
OR
Overnight your proposal to:
U.S. Environmental Protection Agency
OSWER Office of Brownfields Cleanup and Redevelopment
Attn: LaKisha Odom (5105T)
1301 Constitution Ave, NW (Rm 2402)
Washington, DC 20004
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Job Training Proposal
Guidelines
4.1. Cover Page
NOTE: APPLICANTS MUST CLEARLY MARK ANY INFORMATION
THEY CONSIDER TO BE PROPRIETARY, CONFIDENTIAL BUSINESS INFORMATION.
IF MARKED INFORMATION IS REQUESTED FROM EPA UNDER THE FREEDOM OF
INFORMATION ACT, THE AGENCY WILL FOLLOW THE PROVISIONS OF 40 CFR PART
2, SUBPART B.
This is intended to identify the brownfields job training and development pilot applicant and a contact for
communication with EPA. This should be one page and in the format of your choice.
A. Project Title: This should be as descriptive as possible.
B. Applicant Identification: The name of the main implementor of your proposed training pilot project.
C. Location: City, county, and state or reservation, tribally owned lands, tribal fee lands, etc. of your
assessment grant or revolving loan fund grant partner. Include the names, addresses, and phone num-
bers of: 1) your assessment grant or revolving loan fund grant partner's mayor, county executive,
governor, tribal chair, etc.; and 2) federal Congressional representatives.
D. Project Director: Name, phone number, fax/e-mail, and address of the person responsible for the
project proposal. This person will be contacted if other information is needed.
E. Date Submitted: Date when the proposal is postmarked or sent to EPA via registered or tracked mail.
F. Project Period: Project period must not exceed two years.
G. Cooperative Partners: Provide names and phone numbers of individuals and organizations that have
agreed to participate in the implementation of the project. Please note that financial transactions with
cooperative partners that involve EPA funding will be subject to compliance with applicable EPA
assistance regulations.
4.2. Threshold Criteria
A. Location of the Proposed Project
Identify the EPA-funded Brownfields grant (assessment, RLE) in your project area.
B. Applicant Eligibility
Describe how you are an eligible applicant for the job training grant. See description of eligible applicant
below.
Eligible governmental applicants include a general pmpose local unit of government, a land clearance
authority or other quasi-governmental entity that operates under the supervision and control of or as an
agent of a general purpose unit of government; a governmental entity created by a state legislature; a
regional council or group of general purpose unit of local government; a redevelopment agency that is
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chartered or otherwise sanctioned by a state; a state; "an Indian Tribe (other than in Alaska), or an
Alaskan Native Regional Corporation and an Alaska Native Village Corporation as those terms are
defined in the Alaska Native Claims Settlement Act(43 U.S.C. 1601 and following) and the Metlakatla
Indian Community. EPA welcomes and encourages applications from coalitions of such entities, but a
single eligible entity must be identified as the legal recipient. Intertribal consortia, except consortia
comprised on ineligible Alaska tribes, are eligible to apply as well.
Eligible nonprofit organizations include any corporation, trust, association, cooperative, or other organi-
zation that is operated mainly for scientific, educational, service, charitable, or similar purpose in the
public interest; is not organized primarily for profit; and uses net proceeds to maintain, improve, or
expand the operation of the organization. For profit or proprietaiy training organizations or trade
schools are not eligible to apply.
C. Duplication
Applicants must demonstrate that the proposed training project does not duplicate other federally
funded hazardous waste management training programs in their target community. The National Institute
of Environmental Health Sciences maintains a list of their worker training grantees on their web site,
http://www.niehs.nili.gov/wetp.
Eligible use of Funds
Proposals must not include costs that are ineligible for EPA Brownfields Job Training funding. (See Appen-
dix 2 for details).
4.3. Ranking Criteria
A. Community Need (a maximum of 10 points may be received for this criterion)
The purpose of this section is to provide evidence of need. Demonstrate the impact on the tar-
geted community.
1. Describe the community you propose to serve under this project. Provide a detailed description of
the target community. Include demographic information and indicators, such as the poverty rate and
the unemployment rate.
2. Describe, in detail, the current brownfields challenges of your targeted community, including
environmental, economic, and social issues.
3. Describe, in detail, the demand from future employers to hire local residents to fill environmental
jobs. Also describe the skills potential employers will need.
4. Indicate whether your community is located in or near an Empowerment Zone/Enterprise
Community (EZ/EC), Renewal Community, or is classified as a small community (population under
100,000).
B. Institutional Capacity (a maximum of 15 points may be received for this criterion).
1. Describe your experience and the experience of your partners in providing environmental j ob
training and other job training services. Include in your description, your success in recruitment,
training, and job placement as well as your instructors' experience with training your target
population.
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2. Describe prior experience in managing federal grants. You must include information on all adverse
audit findings made within the last five years and special or "high risk" terms and conditions imposed
as a result of grant compliance issues within the last five years
C. Training Program Objectives and Plans (a maximum of 25 points may be received for this criterion).
1. Describe the objectives of your proposed project. Specify: 1) how many participants you expect to
train through this grant; 2) number of training cycles; how many hours per cycle; names of courses;
when and where you plan to conduct training classes; 3) your targeted placement rate at jobs that
bear a direct correlation to the training received; and 4) how graduates will be tracked and the
target time frame for tracking (at least one year).
2. Describe how prospective trainees will be screened, including academic and other criteria.
3. Provide a course outline as an attachment and include a list of training tools and materials that will be
provided to trainees. List and describe certifications (e.g., OSHA health and safety training for
hazardous waste workers, lead abatement, asbestos abatement) graduates will earn. Indicate
whether your organization or collaborative partners are approved to provide such certification, and
explain how any exam fees will be covered.
4. Describe any local incentives or other mechanisms for encouraging employment of local residents
(e.g., first source or local hire ordinance for contractors of public agencies, tax incentives for local
hire, wage subsidies, or other mechanisms).
D. Budget. Schedule, and Leveraging (a maximum of 20 points may be received for this criterion).
1. Provide a comprehensive proposed budget for your training project. This should include cost
estimates for each of the proposed project activities to be conducted using EPA funds. EPA does
not require that applicants include a matching or cost share.
Although EPA grant funds may be used on personnel, equipment, and supplies, emphasis should be placed
on delivery of training. The following is a suggested budget format:
Project Funding
EPA Project Funding
Personnel
Progress or performance reporting
Travel
Other (contractual, supplies, etc.)
Total EPA Funds
Non-EPA Project Funding
Administrative Costs
Other
Total Non-EPA Funds
Instruction
Outreach
Other Tasks
Total
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2. Budget Narrative. A budget narrative should accompany the budget and explain each activity,
including how it is relevant to the EPA funding authority and to the objective of providing
environmental training. Describe how each activity and cost is relevant to the EPA funding authority.
All costs incurred under this program must be allowable under the applicable OMB Cost Circulars
(A-21 for educational institutions, A-87 for governments, and A-122 for nonprofit organizations)
and eligible for funding under the Brownfields Job Training and Development Grant. See Appendix
2 for a description of prohibited administrative costs and eligible programmatic costs.
• Applicants must comply with the procurement requirements of the EPA financial assistance
regulations, 40 CFR Part 30 for universities and nonprofit organizations, and 40 CFR Part 31 for
states, tribes, and local governments.
• If your organization intends to provide noncompetitive subgrants to other nonprofit or governmental
organizations, discuss the process you will follow to ensure that these agreements meet the
standards for financial assistance contained in OMB Circular A-133, Section 210.
• EPA's Brownfields program does not allow recipients of Job Training grant funds to make subgrants
to for-profit organizations. Recipients are accountable for the selection of contractors and
subgrantees. However, EPA will review and approve the substantiative terms of all contracts and
subgrants for activities that are central to the performance of this agreement under 40 CFR 30.25
and 40 CFR 31.30.
3. Leveraged Funds. Demonstrate how you will leverage funding to develop an integrated training
program. Provide a narrative and detailed description that clearly explains how funds and other
resources provided by collaborative partners will complement EPA grant funds and support recruit-
ment, job readiness and placement. Each partner's role should be clearly defined. Distinguish
between how EPA funds will be used and how funds or other resources from the partners will be
used (e.g., DOL-fmanced life-skills training). Letters of support should reference these commit-
ments.
Describe how you plan to leverage funds and other resources to support the pilot. For example,
provide details on how you intend to fund life-skills training, pre-employment training, counseling,
child care, academic enhancement, placement assistance, transportation assistance, and other
activities not funded by this grant.
E. Community Involvement and Partnerships (a maximum of 20 points may be received for this criterion).
1. Describe your partnership with the EPA brownfields grant recipient in your grant area.
2. EPA believes that early community involvement in the development of the proposal and
throughout the project is necessary and critical to the success of a pilot. Describe your efforts
to involve the community in the development of this proposal. Provide a list of neighborhood-based
and community-based organizations and other stakeholders.
3. Letters of support should be included as attachments. The letters of support should reference the
organizations' role in, or commitments to, the Job Training project if the applicant is selected.
These organizations may be contacted by EPA during the evaluation process.
4. Describe how the proposed project addresses environmental justice considerations and addresses
issues of disadvantaged populations within your target community.
5. Describe how residents of the identified community have easy access to training facilities.
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6. Describe how the employer community (for example, local businesses, environmental contractors,
brownfields site owners) has been involved in the development of the proposed training. This
involvement could include curriculum development, advisory councils, apprenticeships, and
mentoring.
7. Describe partnerships with local community groups, labor unions with apprenticeship programs,
academic and other institutions, historically black colleges and universities, and public schools
located in or near the identified community that can provide the prerequisite skills or knowledge.
The letters of support, from partnering institutions, employer communities, community-based
organizations, and EPA assessment project grant recipient should substantiate this description by
stating their specific commitments and/or participation to the job training project if the applicant is
selected. These entities may be contacted by EPA during the evaluation process.
F. Measures of Success (a maximum of 10 points may be received for this criterion).
1. Define success in terms of your project goals. Goals should be specific, measurable, realistic, and
within a specific time frame.
2. State your objectives and milestones for the end of each term listed: 6 months, 1 year, 18 months,
and 2 years (final closeout report due). This description should include a narrative as well as a table
or graphic timeline.
3. Describe how your organization will ensure sustainable employment, including initial job placement
and long-term employment. Describe job placement and tracking strategies and identify the
responsible entity and the source of funding (non-EPA) for this.
4. Describe any evaluation tools that will be used to gauge the compatibility of your objectives to
potential employers' future needs.
5. List the reports or other deliverables you plan to provide to EPA as documentation of your project's
progress and success. Please note that EPA requires quarterly reports including key measures
(needed for statistical data collection) or other indicators of a successful job training program.
6. Provide a timetable showing start and completion dates for significant tasks.
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EPA Regional and
Headquarters Contacts
Regions and States
Address and Phone Number
EPA Region 1
Lynne Jennings
CT,ME,MA,
NH,RI,VT
One Congress Street, Suite 1100 (Mailcode HIO)
Boston, MA 02114-2023
Phone (617) 918-1210 Fax (617) 918-1291
jennings.lynne @ epa.gov
EPA Region 2
Larry D'Andrea
NJ, NY, PR, VI
290 Broadway, 18th Floor, New York, NY 10007
Phone (212) 6374314 Fax (212) 6374360
dandrea .larry @ epa.gov
EPA Region 3
Tom Stolle
DE,DC,MD,
PA,VA,WV
1650 Arch Street (3HS34), Philadelphia, PA 19103-2029
Phone (215) 814-3129 Fax (215) 814-5518
stolle.tom@epa.gov
EPA Region 4
Mickey Hartnett
AL,FL,GA,KY,
MS,NC,SC,TN
Atlanta Federal Center, 61 Forsyth Street (SNFC, EPA Mail Rrn.)
Atlanta, GA 30303
Phone (404) 562-8661 Fax (404) 562-8628
hartnettrnickey @ epa.gov
EPA Region 5
Deborah Orr
MN,OH,WI
77 West Jackson Boulevard (SE-4J), Chicago, IL 60604-3507
Phone (312) 886-7576 Fax (312) 886- 6741
orr.deborah @ epa .gov
EPA Region 6
Stanffitt
AR,LA,NM,
OK,TX
1445 Ross Avenue, Suite 1200 (6SF-PB), Dallas, TX 75202-2733
Phone (214) 665-6736 Fax (214) 665-6660
hitt.stan@epa.gov
EPA Region 7
Nancy Schelle
IA,KS,MO,NE
901N. 5th Street (SUPR/STAR), Kansas City, KS 66101
Phone (913) 551-7940 Fax (913) 551-8688
schelle.nancy@epa.gov
EPA Region 8
Mary Ahlstrom
CO,MT,ND,
SD,UT,WY
999 18th Street, Suite 300 (EPR-SA), Denver, CO 80202- 2466
Phone (303) 312-6626 Fax (303) 312-6067
ahlstrom.mary @ epa.gov
EPA Region 9
Jim Hanson
AZ,CA,ffl,
NV,AS,GU
75 Hawthorne Street, SFD 1-1, San Francisco, CA 94105
Phone (415) 972-3188 Fax (415) 947-3528
hanson.jim@epa.gov
EPA Region 10
Susan Morales,
RoopaKaria
AK,D),OR,WA
1200 Sixth Avenue (ECL-112), Seattle, WA 98101
Phone (206) 553-2100, (206) 553-0124 Fax (206) 553-0124
morales .susan @ epa.gov, karia.roopa @ epa.gov
EPA Headquarters
Myra Blakely
U.S. Postal Service mailing address:
1200 Pennsylvania Avenue, NW (MC 5105T)
Washington, DC 20460
Overnight Delivery mailing address:
EPA West Building, 1301 Constitution Avenue, Room 2402
Washington, DC 20004
Phone (202) 566-2777 Fax (202) 566-2757
blakely.myra @ epa.gov
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Prohibitions on Use of Funds
The Brownfields law prohibits the use of any "part of a grant or loan" awarded
under § 104(k) of CERCLA for:
1. A penalty or fine.
2. A federal cost-share requirement (for example, a cost share required by
other federal funds).
3. A response cost at a brownfield site for which the recipient of the grant or
loan is potentially liable under CERCLA § 107.
4. A cost of compliance with any federal law, excluding the cost of compliance with laws applicable to the
cleanup.
5. The payment of an administrative cost.
Administrative Costs
In implementing the administrative cost prohibition, EPA has made a distinction between prohibited adminis-
trative costs and eligible programmatic costs.
A. Administrative Costs. Prohibited administrative costs are direct costs including those in the form of
salaries, benefits, contractual costs, supplies, and data processing charges incurred to comply with most
provisions of the "Uniform Administrative Requirements for Grants" contained in 40 C.F.R. Part 30 or 40
C.F.R. Part 31. Direct costs for grant administration are ineligible even if the grantee or subgrantee is
required to carry out the activity under the grant agreement. Prohibited administrative costs are also all
indirect costs under OMB Circulars A-21 (Educational Institutions), A-87 (Governments), and A-122
(Nonprofit Organizations), and Subpart 31.2 (Commercial Organizations) of the Federal Acquisition
Regulation.
B. Programmatic Costs. EPA has determined that the administrative cost prohibition does not apply to
"programmatic" costs, i.e., costs for activities that are integral to achieving the purpose of the grant, even
if the Agency considered the costs to be "administrative" under the prior brownfields program.
1. The prohibition does not apply to direct costs of training. For example, costs for instructors salaries,
program management salaries (to the extent that such costs are included in the scope of work for the
brownfields job training grant), training materials (e.g. textbooks, equipment, and classroom supplies)
necessary travel and transportation expenses and, medical tests required to qualify for hazardous sub-
stances related work are programmatic, not administrative. Direct costs, as defined in the applicable
OMB Cost Principle Circular, for the following programmatic activities are not subject to the administra-
tive cost prohibition. These costs, however, must be allowable under the scope of work for the grant.
2. Costs incurred for complying with procurement provisions of 40 CFR Part 30 and 31 are considered
eligible programmatic costs only if the procurement contract is for services or products that are direct
costs for training as described above.
3. Costs for performance and financial reporting required under 40 CFR 30.51 and 30.52, and 40 CFR
31.40 and 31.41 are eligible programmatic costs. Performance and financial reporting are essential
programmatic tools for both the recipient and EPA to ensure that grants are carried out in accordance
with statutory and regulatory requirements.
For further information on these prohibitions, call your Regional Brownfields Contact listed in Appendix 1.
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