FY 2022 Training and Technical Assistance to Improve Water Quality and
Enable Small Public Water Systems to Provide Safe Drinking Water

Frequently Asked Questions

Last updated 12/7/22

In accordance with EPA's Assistance Agreement Competition Policy (EPA Order 5700.5A1),
EPA will respond to questions from individual applicants regarding threshold eligibility criteria,
administrative issues related to the submission of the application, and requests for clarification
about the announcement. However, consistent with the provisions in the announcement, EPA
staff cannot meet with individual applicants to discuss draft applications, provide informal
comments on draft applications, or provide advice to applicants on how to respond to ranking
criteria.

Applicants are responsible for the contents of their applications.

Categories

A.	Applicant Eligibility

B.	Project Eligibility

C.	Threshold Issues

D.	Evaluation Issues

E.	Timing and Logistics

F.	Budget Concerns

G.	Funding Clarifications

H.	Miscellaneous

A. Applicant Eligibility:

Al: Am I eligible to apply for the RFA?

Eligible applicants under this competition are nonprofit organizations, nonprofit private
universities and colleges, and public institutions of higher education. For-profit organizations are
not eligible to apply. States, municipalities, or tribal governments are not eligible to apply.

A2: How does EPA define nonprofit organization?

Consistent with the definition of Nonprofit organization at 2 CFR § 200.1, the term nonprofit
organization means any corporation, trust, association, cooperative, or other organization that is
operated mainly for scientific, educational, service, charitable, or similar purpose in the public
interest and is not organized primarily for profit; and uses net proceeds to maintain, improve, or
expand the operation of the organization. The term includes tax-exempt nonprofit neighborhood
and labor organizations. Note that 2 CFR 200.1 specifically excludes Institutions of Higher
Education from the definition of non- Nonprofit organizations that are not exempt from taxation
under Section 501 of the Internal Revenue Code must submit other forms of documentation of
nonprofit status; such as certificates of incorporation as nonprofit under state or tribal law.

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Nonprofit organizations exempt from taxation under Section 501(c)(4) of the Internal Revenue

Code that lobby are not eligible for EPA funding as provided in the Lobbying Disclosure Act, 2
U.S.C. 1611.

A3: Are states, municipalities, or tribal governments eligible to apply for the RFA?

No. States, municipalities and tribal governments are not eligible to apply. Eligible applicants are
described in Section III. A., where it is stated: "Eligible applicants under this competition are
nonprofit organizations, nonprofit private universities and colleges, and public institutions of
higher education. For-profit organizations are not eligible to apply. States, municipalities, tribal
governments, and individuals are not eligible to apply. Nonprofit organizations described in
Section 501(c)(4) of the Internal Revenue Code that engage in lobbying activities as defined in
Section 3 of the Lobbying Disclosure Act of 1995 are not eligible to apply. EPA may ask
applicants to demonstrate that they are eligible for funding under this announcement."

A4: If I have questions regarding this announcement, will EPA respond to them?

It depends. EPA will respond to questions from individual applicants regarding threshold
eligibility criteria, administrative issues related to the submission of the application, and requests
for clarification about the announcement. Questions must be submitted via e-mail to
(smallsystemsrfa@epa. gov) by January 11, 2022. However, EPA staff will NOT discuss draft
applications, provide informal comments on draft applications, or provide advice to applicants on
how to respond to ranking criteria. Applicants are responsible for the contents of their
applications.

A5: Can individual non-profit water systems apply for a grant to make improvements to
their systems?

No, individual water systems are not eligible for funding under this announcement. It is designed
to provide funding to eligible non-profit organizations (as described in Section III. A. "Eligible
Applicants" of the Request for Applications, quoted below), which in turn will provide training
and technical assistance to eligible drinking water and wastewater systems and private well
owners.

Section III. A. "Eligible Applicants" of the Request for Applications states: "Eligible applicants
under this competition are nonprofit organizations, nonprofit private universities and colleges,
and public institutions of higher education. For-profit organizations are not eligible to apply.
States, municipalities, tribal governments, and individuals are not eligible to apply. Nonprofit
organizations described in Section 501(c)(4) of the Internal Revenue Code that engage in
lobbying activities as defined in Section 3 of the Lobbying Disclosure Act of 1995 are not
eligible to apply. EPA may ask applicants to demonstrate that they are eligible for funding under
this announcement.

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A6: Are public health agencies eligible to apply?

If your public health agency is an agency of your county government, then you are not eligible to
apply. For this Request for Applications, EPA does not consider units of government such as
counties as well as their component agencies to be nonprofit organizations.

A7: Do you foresee any similar funding opportunities for which states will be eligible to
apply?

In accordance with Section III. A of the competitive announcement, states are not eligible to
apply for the funding. EPA cannot speculate regarding future grant opportunities in which states
would be eligible to apply. This is EPA's nineth round of competitive funding for small system
training and technical assistance grants, and Congress has stipulated in each case that eligibility
is limited to non-profit organizations. You may wish to monitor the Grants.gov web site in the
future to see if there are any other grant competitions that may include states as eligible
applicants.

A8:1 work as an environmental engineer for a state drinking water program. I am in the
process of starting a nonprofit organization that would apply for the training and technical
assistance grants to improve water quality and provide safe drinking water. In the event
that the nonprofit organization I started earned a grant, I would quit my job with the state
and begin working full time as the technical assistance provider for the nonprofit. Given
my position, may I, as acting director of the nonprofit organization, apply for the grants?

Eligibility criteria describes in Section III. A. "Eligible Applicants" of the Request for
Applications states:

Eligible applicants under this competition are nonprofit organizations, nonprofit private
universities and colleges, and public institutions of higher education. For-profit organizations are
not eligible to apply. States, municipalities, tribal governments, and individuals are not eligible to
apply. Nonprofit organizations described in Section 501(c)(4) of the Internal Revenue Code that
engage in lobbying activities as defined in Section 3 of the Lobbying Disclosure Act of 1995 are
not eligible to apply. EPA may ask applicants to demonstrate that they are eligible for funding
under this announcement.

Section III. C. Threshold Eligibility Criteria, states, "All applications will be reviewed for
eligibility and must meet the eligibility requirements described in Sections III. A., B., and C. to
be considered eligible. Applicants deemed ineligible for funding consideration as a result of the
threshold eligibility review will be notified within 15 calendar days of the ineligibility
determination." EPA may ask applicants to demonstrate that they are eligible for funding under
this announcement.

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A9:1 represent a nonprofit organization interested in applying for the following
opportunity. As long as we are the lead organization, can we include institutions of higher
education (universities) as subcontractors for this grant opportunity?

Eligible grant applicants under this competition include nonprofit private universities and
colleges, and public institutions of higher education.

Funding may be used to provide subawards of financial assistance, which includes using
subawards to fund partnerships, provided the recipient complies with applicable requirements for
subawards including those contained in 2 CFR Part 200 and EPA's Subaward Policy. EPA has
also posted Additional Resources on Subawards for applicants to consult.

If you name sub awardees/subgrantees and/or contractor(s) including individual consultants in
your application as partners to assist you with the proposed project, pay careful attention to the
information in the CONTRACTS AND SUBAWARDS provision found at
http://www.epa.gov/grants/epa-solicitation-clauses.

A10: May successful applicants charge fees for training and technical assistance services
that are funded in whole or in part under their EPA cooperative agreements?

As discussed in Section I.E, the statutory authorities for the awards expected to be made under
this announcement are Section 1442(e) of the SDWA and Section 104(b)(3) of the CWA.

Under the statutory authority for the cooperative agreements, Section 1442(e) of the Safe
Drinking Water Act and Section 104(b)(3) of the Clean Water Act, a prohibition on charging
fees does not apply.

B. Project Eligibility:

Bl: The RFA restricts training and technical assistance to small PWSs, serving 10,000 or
less people. We have several water system owners including municipal owners, which have
both small PWSs and large PWSs. Would these water system owners be eligible for
training under the RFA contracts? If so, we have only one large system that would not be
eligible for the training. Would the selected technical assistance provider be allowed to
provide and charge for training to this large system?

The training and technical assistance described in National Priority Area 1 is specific to
addressing the short and long-term needs of small systems in meeting the requirements of the
Safe Drinking Water Act. Personnel receiving training and assistance should be associated
specifically with systems that meet the criteria of this funding announcement, namely those
systems serving less than 10,000.. We presume that you are asking whether a technical
assistance provider could provide services to a large system without using EPA funds by
charging the large system a fee to finance the services. That decision would be up to the
technical assistance provider rather than EPA. However, the provider would need to maintain
accounting data to demonstrate that it did not charge the cost for providing technical assistance to
a large system to its EPA cooperative agreement.

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B2: Does an onsite/decentralized wastewater system include an individual home sewerage
system?

A home septic system is an example of an onsite/decentralized system. The funding opportunity
is intended for technical assistance activities that would help multiple onsite/decentralized
systems (e.g., a community, a collection of houses, part of a watershed, a geographic region, etc.)
to improve their performance. In Section I.B of the Request for Applications, on-
site/decentralized systems are defined as: publicly-owned or privately-owned onsite or clustered
systems used to collect, treat, and disperse or reclaim wastewater from a small community, tribe
or service area that are publicly or privately-owned and/or serve tribal communities (with the
exception of systems that are owned by U.S. federal entities).

B3: What types of projects are eligible to apply for these funds? For example, I work with a
number of small communities who need funds to conduct or update their technical,
managerial, and financial assessments for water systems, do planning and/or design work
for needed water or wastewater system improvements, and to construct improvements to
their systems. Which of these activities would qualify? And can we request funds for
specific communities, or does it have to be broader, i.e. across a number of states?

The types of activities and services that are eligible for funding are described in Section I.B. of
the announcement, under "National Priority Areas." Additionally, the funding opportunity is
intended to provide training and technical assistance on a national basis. In accordance with
Section V, criterion number 2, "Providing Training and Technical Assistance on a National
Basis," applicants will be evaluated on a number of factors, such as providing training and
technical assistance in a maximum number of states and U.S territories, demonstrating an
effective process for reaching out to tribally-owned and operated systems, addressing the specific
needs of the target audience in as many states and U.S. territories as possible, and transferring
results, effective compliance strategies, and resources developed, to interested stakeholders
nationally.

Applicants are asked to describe a process for consulting with appropriate agencies in each state
or territory prior to initiating training and technical assistance activities. This process would take
place before assistance is provided to individual communities or systems.

Also, note that this funding opportunity is designed to provide funding for eligible nonprofit
organizations, nonprofit private universities and colleges, and public institutions of higher
education (as described in Section III. A. "Eligible Applicants" of the Request for Applications),
which in turn will provide training and technical assistance to eligible drinking water and
wastewater systems and private well owners.

For-profit organizations, states, municipalities, or tribal governments, and individuals are not
eligible to apply. Nonprofit organizations described in Section 501(c)(4) of the Internal Revenue
Code that engage in lobbying activities as defined in Section 3 of the Lobbying Disclosure Act of
1995 are not eligible to apply. The EPA may ask applicants to demonstrate that they are eligible
for funding under this announcement.

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B4: Is this grant just for training or more than that? We are a small private (Board run)
drinking water system that serves 1,281 at present. Would this grant help us with
repairs/replacement to existing lines? Is there another choice that would be better?

This funding opportunity is designed to provide funding for eligible non-profit organizations,
nonprofit private universities and colleges, and public institutions of higher education (as
described in Section III. A. of the announcement, quoted below). These organizations in turn will
provide training and technical assistance to eligible drinking water and wastewater systems and
private well owners. Successful grant applicants will provide the training and technical
assistance using their own personnel, contracting with other individuals or organizations, through
subawards, or through some other approved mechanism. State, tribal, and municipal government
entities, and individuals are not eligible for receiving funding under this announcement.

Section III. A. of the Request for Applications states: "Eligible applicants under this competition
are nonprofit organizations, nonprofit private universities and colleges, and public institutions of
higher education. For-profit organizations are not eligible to apply. States, municipalities, tribal
governments, and individuals are not eligible to apply. Nonprofit organizations described in
Section 501(c)(4) of the Internal Revenue Code that engage in lobbying activities as defined in
Section 3 of the Lobbying Disclosure Act of 1995 are not eligible to apply. EPA may ask
applicants to demonstrate that they are eligible for funding under this announcement."

Repairs or replacement of existing water lines would not be eligible for funding under this
announcement. The funding announcement covers training and technical assistance activities
only.

B5: We have a population of 1,779 in our municipality and are currently undergoing a
mandatory upgrade to our wastewater treatment facility. Will this project meet the criteria
of the grant monies to be awarded, or is this type of grant for training only?

This funding opportunity is only for training and technical assistance projects. A project for
adding new equipment or upgrading, retrofitting, or rehabilitating existing equipment would not
be eligible for funding under this announcement.

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B6: Are "urban" communities ok for us to service as long as they are below 10,000 in
population? Is that the same for decentralized wastewater systems?

As indicated in the announcement, the systems targeted to receive training and technical
assistance under National Priority Area 1 include "small public water systems," which are
defined as "community and non-community water systems serving a population of less than
10,000 persons." The systems targeted for assistance under National Priority Area 2 are "small
publicly-owned wastewater systems" or "onsite/decentralized wastewater systems." "Small
publicly-owned wastewater systems" are defined as "wastewater systems or treatment facilities
that have permitted and actual flows of less than 1 million gallons per day (MGD) and are:
owned by a public entity (such as a municipality) or not-for-profit entity (such as regional sewer
districts), and/or serve tribal communities (with the exception of systems that are owned by U.S.
federal entities)." "Onsite/decentralized systems" are defined as "publicly-owned or privately-
owned onsite or clustered systems used to collect, treat, and disperse or reclaim wastewater from
a small community, tribe or service area that are publicly or privately-owned and/or serve tribal
communities (with the exception of systems that are owned by U.S. federal entities)" There is no
size designation for onsite/decentralized systems, and as long as the criteria in the above
definitions are met, any of the water and wastewater systems described above may be located in
either rural or urban communities.

B7: Will unique approaches to technical assistance to small PWS be considered?

Yes, unique approaches to technical assistance to small PWS will be considered. Section I.B. of
the RFA states that "EPA encourages applications that include non-traditional or innovative
approaches in addition to conventional or traditional approaches for training and technical
assistance. The applicant should demonstrate how these non-traditional or innovative
approaches in conjunction with conventional or traditional approaches show the potential to
more effectively reach the intended audience than only conventional or traditional means."

B8: If a county/municipality operates several distinct "systems" that are not connected to
each other, and one of these distinct systems serves less than 10,000 people, would it qualify
as a "small system," or do we aggregate all the distinct systems operated by single entity to
determine "smallness"?

Yes, the system you describe, a distinct system serving less than 10,000, is eligible for
receiving training or technical assistance from a grant recipient under this funding
announcement. However, the Request for Applications also requires funding recipients to
prioritize the use of their funds by working with the state or territory where they are providing
assistance, to identify the systems in greatest need of assistance. The Request for Applications,
Section I.B., "National Priority Areas" states:

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"Applicants should also describe a process whereby they will consult with the appropriate
regulatory authority (such as the state or territorial primacy agency or EPA regional direct
implementation coordinators) in each state, tribe or territory in which the assistance is to be
expended or otherwise made available prior to providing training and technical assistance in that
state, tribe or territory. In particular, applicants should indicate how they will work with the state,
territory or EPA to identify the systems in greatest need of assistance; how they will keep those
agencies, the EPA grant project officer and appropriate EPA regional coordinators informed
regarding the assistance provided; and how they will document these results."

C. Threshold Issues:

CI: If I put charts and exhibits in my proposal can they be a smaller font than the 12 point
font that is required of the body of the proposal?

The RFA does not establish a required minimum 12 point font for the project narrative or any
charts and/or exhibits; however, the RFA does indicate that readability is of paramount
importance. Section IV.E.2, Project Narrative, states in part:

"...It is recommended that applicants use a standard 12-point type with 1-inch margins. While
these guidelines establish the minimum type size recommended, applicants are advised that
readability is of paramount importance and should take precedence in selection of an appropriate
font for use in the Project Narrative." EPA recommends that all of the project narrative,
including any charts and/or exhibits, is in a 12-point font.

C2: Is there a grant ceiling & floor for applications?

There is a ceiling but no floor for the amount of funds applicants may request. The Request for
Applications (RFA) Section III.C., "Threshold Eligibility Criteria," states that: "Applications for
awards under National Priority Area 1 cannot exceed $22,000,000 in federal funds; applications
for awards under National Priority Area 2 cannot exceed $1,000,000 in federal funds; and
applications for awards under National Priority Area 3 cannot exceed $2,700,000 in federal
funds. Applications exceeding the amount for the National Priority Area it addresses will be
rejected." EPA has not established a minimum amount of funding for applicants.

D. Evaluation Issues:

Dl: Section II. B., regarding anticipated substantial federal involvement mentions a review
of qualifications of key personnel with a caveat that EPA "does not have the authority to
select employees or contractors employed by the recipient." Since staff
expertise/qualifications are part of the scoring criteria upon which an award is based, can
EPA elaborate on this review? Is this limited to new employees or contractors selected by
the recipient? What further review of identified staff would be conducted for a successful
recipient?

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Regarding staff expertise and qualifications of key personnel, the EPA application review panel
members will review the information provided by the applicant and conduct their scoring in
accordance with the selection criteria. The information reviewed by the panel includes the
project narrative itself as well as biographical sketches and resumes submitted along with the
narrative. If an applicant proposes future changes in key personnel after an application has been
selected for funding, then the EPA Project Officer must approve of these changes after reviewing
biographical and qualifications information provided by the applicant before the project can
proceed or continue.

D2: Will entities that already provide technical assistance to small public water suppliers
have an advantage in the proposal selection? Is this RFA primarily intended for national
organizations that work with small water suppliers on an ongoing basis?

All eligible applicants, based on the threshold eligibility review, will be evaluated based on the
evaluation criteria provided in Section V.A. Applications will be evaluated on the applicant's
ability to successfully complete and manage the proposed project considering their programmatic
capability, experience and community support. Under the past performance evaluation factors,
applicants will be evaluated on their past performance. Applicants with no relevant or available
past performance information or reporting history must indicate that in the application and they
will receive a neutral score for the past performance criterion.

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E. Timing and Logistics:

El: When does EPA anticipate that awards will be announced?

EPA anticipates making funding awards by fall 2023, but this is only an estimate, and not a
guarantee.

F. Budget Concerns:

Fl: The RFA states a project period of up to two years. Do you anticipate that this type of
funding would be available in future years?

The funding announcement is based on EPA's current budget and funding availability under FY
2022. The Agency is not making any commitment to future funding.

F2: If an applicant applies for a certain amount...e.g., $l,200,000...and after reviewing the
applications the agency feels that the work in the proposal is eligible but that there is only
$750,000 available, would the agency go back to the applicant and invite a revised
application for the lower amount? Or would the application be rejected because the
amount was higher than the funds available?

EPA would not necessarily reject an otherwise meritorious application if the Agency did not
have adequate funding to provide the full amount the applicant requested, provided the applicant
did not request more funding than specified in Section III.C.3 of the RFA.

The following provision of the RFA (Section II. A) would apply:

"In appropriate circumstances, EPA reserves the right to partially fund applications by funding
discrete portions or phases of proposed projects. If EPA decides to partially fund an application,
it will do so in a manner that does not prejudice any applicants or affect the basis upon which the
application or portion thereof, was evaluated and selected for award, and therefore maintains the
integrity of the competition and selection process."

F3: When determining cost share/match, can the average hourly wage of the trainees
attending the courses be used as cost share?

No. Trainees would not be performing services for the applicant and, accordingly, their wages
would not meet the standards at 2 CFR 200.306 for allowability as cost share. Applicants may
pay trainee travel as a "participant support cost" with their own funds and include those costs as a
match. However, EPA has determined that other forms of participant support costs such as
trainee stipends or child care expenses are unallowable and applicants may not count these costs
towards their cost share.

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F4: If the applicant develops curriculum for training delivery, can that curriculum be used
as voluntary cost share/match? And if so, who then owns the curriculum?

Yes, provided the applicant can meet the requirements at 2 CFR 200.306 for documenting that
the amount of cost share it claims reflects the fair market value of the curriculum. The applicant
will "own" the curriculum. However, if the applicant uses the costs (i.e., personnel or contractor
expenses) for developing the curriculum as cost share, EPA would have a "federal purpose"
license to use the curriculum under 2 CFR 200.315.

F5: If the applicant develops curriculum for training delivery, will the developer be able to
use the material developed for systems not targeted by the grant? For example:
municipalities larger than the target group.

Yes. The applicant will "own" the curriculum and can use it for its own purposes as long as the
cost of the additional use of the curriculum is not charged to this grant.

F6: To reach private well owners, there is a need to market in unconventional ways,
including advertising the training and technical assistance developed under this RFA. Is it
allowable to include advertising costs in the proposals for this RFA, as long as the
advertising is only used to market and promote training and technical assistance under this
RFA?

Federal grant regulations and policies do not prohibit the use of grant funds to advertise the
services offered by the grantee, as long as the advertising is specifically for making the intended
audience aware of the specific training and technical assistance services available to them under
this grant. General marketing of the grantee or its services outside of the scope of this grant
would be beyond the scope of the grant and would not be appropriate. Details on what costs are
allowable related to advertising and public relations are contained in
https://www.epa.gov/sites/default/files/2018-
05/documents/recipient guidance selected items of cost final.pdf.

F7: Does EPA have a limit on indirect costs that can be charged?

While there is no "limit", per se, indirect cost rates must be negotiated with the cognizant federal
funding agency in accordance with the procedures in 2 CFR 200 Subpart E "Cost Principles."

As specified in the Request for Applications, Section IV.E

"If indirect costs are requested, a copy of the Negotiated Indirect Cost Rate Agreement must be
submitted as part of the application package. "

For more information, please read the EPA's Indirect Cost Guidance for Recipients of EPA
Assistance Agreements at https://www.epa.gov/grants/rain-2018-g02.

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F8: Under this RFA, are indirect/facilities and administrative costs eligible for a waiver of
the cost share?

As described in the RFA under Section III.B., "The non-federal cost-share/match may be
provided in cash or can come from in-kind contributions, such as use of volunteers and/or
donated time, equipment, expertise, etc., and is subject to the regulations governing matching
fund requirements described in 2 CFR 200.306, as applicable."

For more information, please read policy (Section 6.5) at

https://www.epa.gOv/sites/production/files/2018-08/documents/indirect-cost-policv-for-
recipients-of-epa-assistance-agreements.pdf) and EPA's Indirect Cost Guidance for Recipients of
EPA Assistance Agreements (Section 6.7) at https://www.epa.gov/sites/production/files/2018-
08/documents/indirect-cost-policv-guidance-for-recipients-of-epa-assistance-agreements.pdf.

G. Funding Clarifications:

Gl: Can the funds for this grant program be used for the purchase of sewer
maintenance/inspection equipment?

Equipment purchases solely for the purpose of providing training or technical assistance are
eligible under this funding announcement. Equipment purchases would need to be included in
the application budget and approved by EPA as part of the final project work plan. In general,
equipment purchases should represent a small portion of the total project budget.

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H. Miscellaneous:

HI: The announcement states, "EPA has previously awarded financial assistance
agreements to nonprofit organizations to provide technical assistance activities that are
similar to those described in this announcement." What programs are being referenced in
this Section and what applicants received those funds?

Training and technical assistance activities similar in scope have been funded in recent years
through competitively-awarded grants to several organizations. Examples of the FY19
competition are summarized below.

Example projects include classroom training on operation and maintenance, board training, on-
site rule education and public health training, training on private wells and contaminants, on-site
technical assistance, and creation of educational videos, among others.

For EPA-OW-OGWDW-20-02, National Priority Area 1, EPA selected the University of New
Mexico, the Rural Community Assistance Partnership (RCAP) and the National Rural Water
Association (NRWA) to help small public water systems to achieve and maintain compliance
with the SDWA, including improving financial and managerial capacity. For EPA-OW-
OGWDW-20-02, National Priority Area 2, EPA selected the University of New Mexico to work
with small publicly-owned wastewater and onsite/decentralized wastewater systems to help
improve water quality.

For EPA-OW-OGWDW-20-02, National Priority Area 3, EPA selected the Rural Community
Assistance Partnership (RCAP) to work with private well owners to help improve water quality.

H2: Will EPA seek external reviewers for the Training and Technical Assistance to
Improve Water Quality and Enable Small Public Water Systems to Provide Safe Drinking
Water RFA?

No. EPA will not seek external reviewers for this announcement. Section V.B. of the RFA
states that a panel(s) comprised of EPA staff will review the eligible applications by National
Priority Area based on the evaluation criteria listed in Section V. A.

H3: What systems will we work with, how are those systems chosen, who will choose them,
and who has the contact information?

Identifying the small public water systems to work with will be the responsibility of the
successful applicant. EPA will evaluate your approach to identifying systems to serve under the
"National Priority Area" and "Providing Training and Technical Assistance on a National Basis"
described in Section V.A. of the Request for Applications (RFA).

As required by Section I.B. of the RFA, the successful applicant must work with the appropriate
regulatory authorities ".. .to identify the systems in greatest need of assistance..Your
application should describe a process that you propose to follow to assure proper consultation

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with the appropriate regulatory authority such as the state or territorial primacy agency or EPA
regional direct implementation coordinator.

H4: Does this RFA require a Significant Financial Interests Disclosure (SFI) such as that
required by some other funding agencies?

Under this funding announcement there is no requirement for a Significant Financial Interests
Disclosure for key personnel or any equivalent requirement.

H5: Section II. B., regarding anticipated substantial federal involvement, includes the
statement "collaboration during performance of the scope of work."; Could EPA provide
examples of substantial federal involvement? Will EPA provide trainers for workshops or
simply be in attendance? Will EPA assist in developing agendas for workshops?

Depending on the topic area and the specific location and timing of training or workshops, EPA
may sometimes choose to be in attendance. It is less likely but certainly appropriate, that on
some occasions EPA personnel may participate in developing workshop agendas or in
conducting training activities in conjunction with the training being provided by the grantee
and/or state regulatory officials. This would be determined on a case-by-case basis, in
consultation with the grantee and state regulatory officials.

H6: We are hoping to find more information or clarification on the two different
applications offered (two different assistance listing numbers); we are not clear which
application we should complete. Can you clarify the difference between the two
applications?

Assistance listing Number(s):

66.424 — Surveys, Studies, Investigations, Demonstrations, and Training Grants - Section
1442 of the Safe Drinking Water Act

66.436 — Surveys, Studies, Investigations, Demonstrations, and Training Grants and
Cooperative Agreements - Section 104(b)(3) of the Clean Water Act

If you are applying for:

National Priority Area 1 (Training and Technical Assistance for Small Public Water Systems
to Achieve and Maintain Compliance with the SDWA, Including Improving Financial and
Managerial Capacity) you should use the application for assistance listing number 66.424.

If you are applying for:

National Priority Area 2 (Training and Technical Assistance for Small Publicly-Owned
Wastewater Systems and Onsite/Decentralized Wastewater Systems to Help Improve Water
Quality) you should use the application for assistance listing 66.436.

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If you are applying for:

National Priority Area 3 (Training and Technical Assistance for Private Drinking Water Well
Owners to Help Improve Water Quality), you should use the application for assistance listing
66.436

Applications will not be rejected solely for using an incorrect assistance listing number, and the
number can be corrected later in the application process.

H7: Our research program has been working with private well owners in rural
communities. We are considering submitting a proposal addressing Priority Area 3.

We have worked with the U.S. Geological Survey and state agencies in the past. Could they
be sub-awardees of the grant? The eligibility criteria indicate, "States, municipalities,
tribal governments, and individuals are not eligible to apply." What role could they play?

Generally, unless prohibited by statute, an entity/individual is eligible to receive a subaward even
if it is not eligible to receive an assistance agreement. So, the state agencies could be eligible to
be subawardess of this grant. However, one of the entities you inquired about, the U.S.

Geological Survey (USGS), is a federal entity. OMB's revisions to the definition of Subrecipient
in 2 CFR 200.1 and the regulatory coverage in 2 CFR 200.101, Applicability, provides that
Federal agencies may receive subawards from pass-through entities when authorized by Federal
statutes. In order to award a subaward to USGS, you must demonstrate that USGS has the
statutory authority to receive subawards from pass-through entities. Additional information
regarding Contracts and Subawards can be found at: https://www.epa.gov/grants/epa-solicitation-
clauses.

H8: Is EPA available to discuss the program and answer questions from an applicant on
achieving the program objectives prior to submitting an application?

As described in Section VII of the Request for Applications, EPA staff cannot meet with
individual applicants to discuss draft applications.

Section VII states: "Note to Applicants: In accordance with EPA's Assistance Agreement
Competition Policy (EPA Order 5700.5A1), EPA staff will not meet with individual applicants to
discuss draft applications, provide informal comments on draft applications, or provide advice to
applicants on how to respond to ranking criteria. Applicants are responsible for the contents of
their applications. However, consistent with the provisions in the announcement, EPA will
respond to questions from individual applicants regarding threshold eligibility criteria,
administrative issues related to the submission of the application, and requests for clarification
about any of the language or provisions in the announcement. Please note that applicants should
raise any questions they may have about the solicitation language to the contact identified in

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Section VII of this announcement as soon as possible so that any questions about the solicitation
language may be resolved prior to submitting a proposal. In addition, if necessary, EPA may
clarify threshold eligibility issues with applicants prior to making a final eligibility
determination."

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