On October 4, 2022, EPA's Office of Brownfields & Land Revitalization held a webinar to assist
applicants with preparing applications for Fiscal Year 2023 Cleanup Grants. Below is a transcript
of questions submitted by participants and EPA's response. Responses below may include
additional information than what was provided during the webinar.

If you have general questions about EPA's Brownfields Program or questions about a specific
site for which you're seeking funding, please contact your Regional Brownfields Contact listed in
Section VII. of the Guidelines. If you have questions on how to submit an application through
www.grants.gov. please visit the "APPLICANTS" tab on the grants.gov website for information.

GENERAL QUESTIONS & ANSWERS

Q: Can applicants use an organizational chart to show staff that will be using the grant and
if so, does the organizational chart count against the page limitation for the Narrative?

A: Any information provided as a response to the narrative/ranking criteria must be included
in 10-page limit and attachments that are not specified will not be reviewed. If the
organizational chart is part of the response to the narrative/ranking criteria response it will
count toward the page limits.

Q: Will there be a second round of grant funding this year?

A: No, there will not be a second round of Brownfields Grant funding this year. EPA's
competition policy requires that grant guidelines are available for 45 days. EPA issues
Brownfields Grant guidelines 60 days prior to the submission deadline to give applicants
additional time to meet all requirements and prepare their applications. EPA's Brownfields
Program has also issued Tips on How to Get Started Early on Preparing Your Brownfields
MARC Grant Application to help facilitate applicants' efforts to prepare a thorough,
thoughtful, timely, and most importantly, successful application.

Q: I am a bit confused about the criteria outlined in Section III.B of the guidelines and how
they relate to the narrative of the criteria at IV.D. It looks like the III.B criteria needs to be a
separate attachment. How does EPA address the overlap between the two discussions on
similar criteria?

A: The criteria in Section III.B. are the threshold criteria. The responses are pass/fail. The
information requested in Section IV.D. is separate - this is information that is requested as
part of the Narrative Information Sheets. These data are just for EPA records and are not
pass/fail.

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A: Only an Authorized representative of the applicant may submit an application through
Grants.gov.

Q: Clarifying: The Lobbying form is NOT optional if we are selected & requesting more than
$100k correct?

A: That is correct.

Q: Do any of the required forms need to have signatures? Or are they automatically signed
when submitted through grants.gov?

A: Yes, the forms require signatures. We believe that Grants.gov will automatically apply the
digital signature of the Authorized Organization Rep. EPA does not manage the Grants.gov
system. Please review the information and resources available on www.grants.gov.

Cleanup Grants

Q: Does it hurt you to apply for more cleanup funding? Are the applicants who apply for
$500k more competitive than applicants who apply for $1-2M?

A: EPA staff cannot advise you on whether a particular application strategy will be more
competitive than another. You must make that decision based on the information in the
guidelines.

As stated in the FY23 Cleanup Grant guidelines: "EPA anticipates awarding an estimated 40
Cleanup Grants for up to $500,000, an estimated 25 Cleanup Grants for projects that are
between $500,001 and $1,000,000, and an estimated 8 Cleanup Grants for projects that are
between $1,000,001 and $2,000,000. These amounts are subject to the availability of funds,
quality of applications, and other applicable considerations."

Q: If an applicant applies for a $2M cleanup grant but does not get selected, will they
automatically be considered for a lower dollar amount cleanup grant?

A: No, applicants that are not selected for a higher grant amount will not be automatically
considered for a lower dollar amount. For selection purposes, EPA will prepare three ranked
lists of applications with one list for each funding category.

Q: Can a fiscal agent apply for the grant in partnership for a separate 501(c)(3), local
government or private owner?

A: No, only the owner of the site can apply for a Cleanup Grant. EPA does not recognize the
"fiscal agent" concept for Brownfields Cleanup Grants. Applicants must apply for funding as
the potential recipient and meet all eligibility requirements specified in the guidelines.

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Q: If a firm was paid by the city to update a Phase I and to provide an estimated cost of
remediation, is that firm exempt (i.e., not allowed to bid) from bidding on the remediation
if bids are taken through the public bidding process?

A: If the city is only using the estimated cost for remediation to develop the RFP, then the
contractor may be able to bid on the remediation work provided the city also made an
independent cost estimate to verify that the contractor's estimate is realistic. The city must
make a concerted effort to ensure that there is robust price competition from other bidders
under these circumstances. The regulations require that contracts be awarded through full
and open competition so prior contracting relationships with a firm must not be a
determinative factor.

Cleanup Grants

Q: Are public school districts (County level) eligible for cleanup grants for land remediation
costs prior to school construction?

A: Probably. Local governments as defined in 2 CFR 200.1 are eligible to apply for Cleanup
Grants. That definition includes certain types of public school systems. We suggest that you
review the definition and consult with your district's legal department.

Q: We have a property in mind for the cleanup grant. It's not owned yet however we are in
negotiations now. I know it was stated that property must be owned by Nov 22, 2022. Are
there any exceptions to that date?

A: No, there are no exceptions. You must own the site by the time specified in the guidelines.

Q: How many sites can you submit on? For more than one site, do you need a separate
ABCA for each site? Also, do the sites have to be contiguous?

A: The sites do not have to be contiguous. Yes, you will need include a separate ABCA if the
sites are not contiguous. If the sites are adjacent, then it may be acceptable to provide one
ABCA if the ABCA discusses all the subject sites. Note, you will need to provide a response to
all threshold criteria for each site.

Q: How extensive does the ABCA need to be? We've already ran Phase I & II reports. Do we
need actual site plans for future use in the ABCA portion?

A: A draft ABCA is sufficient to meet the requirement. If you have site plans, even in draft,
that will be sufficient to meet the threshold criterion.

Q: How can we prepare an ABCA if we have not completed site characterization sufficient
to begin cleanup?

A: The requirement is a draft ABCA, which can be modified before finalized if needed.

Q: Regarding the Community Notification and the public meeting, having the final draft of
the application available is difficult given the tight timeline. Does the full draft application
need to be available or can just portions be publicly available?

A: Yes - Applicants must provide the community with notice of its intent to apply for an EPA
Brownfields Cleanup Grant and allow the community an opportunity to comment on the
draft application.

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Q: In reference to the Threshold criterion in Section III.B. 9.b. Site Characterization, does
the State or Tribal Environmental Authority need to affirm if the site is required to be
enrolled in the voluntary response program or eligible to be enrolled?

A: EPA recognizes that not all State or Tribal Environmental Authorities require sites to be
enrolled in their voluntary response program. As stated in the FY23 Cleanup Grant guidelines,
this requirement is asking for affirmation that the site is eligible to be enrolled. This
clarification was made during the Cleanup Grant guideline webinar and the presentation
slides have been corrected to reflect this.

PROJECT AREA DESCRIPTION AND PLANS FOR REVITALIZATION QUESTIONS & ANSWERS

No questions were submitted for this criterion.

COMMUNITY NEED AND COMMUNITY ENGAGEMENT QUESTIONS & ANSWERS

Q: How can community partners be part of the cleanup of the site if there are
contaminants there?

A: The community plays an important role, even for Cleanup Grants. They may provide
meeting space, translation services, be the community champion to ensure the project and
reuse is carried out with community's voice and vision in mind.

TASK DESCRIPTIONS, COST ESTIMATES, AND MEASURING PROGRESS

QUESTIONS & ANSWERS

Q: Cleanup grant guidelines mention that demolition must be necessary to the remediation
of the site, and the FAQs further elaborate that an engineering analysis that supports a
decision to demolish a structure to address contamination is required. We have a site with
asbestos where the second floor has been deemed unsafe (i.e., we do not want to put an
abatement worker in harm's way and therefore demolition with appropriate controls is the
most appropriate). Would an engineering analysis with the primary concern being the
safety of workers and concluding demolition and handling all materials as contaminated by
asbestos be sufficient?

A: Yes. An engineering analysis concluding that demolition is necessary to protect workers
conducting abatement would be satisfactory support for using cleanup funds for demolition.

Q: Can you apply for funding to cover cleanup costs that you've already incurred?

A: EPA only allows pre-award cleanup costs in very limited situations. Refer to 2 CFR Parts
200 and 1500 for regulatory requirements for pre-award costs. Pre-award costs incurred
prior to being notified of selection will not meet regulatory requirements. Also, all

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construction contracts must comply with Davis-Bacon prevailing wage requirements,
including pre-award costs.

Q: Is there any criteria where cleanup funds can be utilized at a site not owned by the
grantee?

A: No. The recipient must own the site to be cleaned up with EPA Cleanup Grant funds. This is
a statutory requirement that EPA cannot waive.

Q: Does asbestos removal count as construction?

A: Yes. Asbestos removal is a repair to a building.

Q: The information provided in the presentation sounded like all activities subject to Davis
Bacon Act need to be listed on the construction budget line. However, not all activities that
are subject to Davis Bacon Act are construction. For instance, soil dig and haul activities and
asbestos material remediation. Please clarify whether or not all activities subject to Davis
Bacon Act need to be listed on the construction budget line.

A: If an activity is subject to Davis Bacon, it is considered a construction activity and must be
included on the construction budget line. Asbestos removal is an activity that involves repair
to a building which also triggers Davis Bacon to the best of our knowledge. We follow DOL's
Bunker Hill Superfund decision with regard to soil remediation.

PROGRAMMATIC CAPABILITY AND PAST PERFORMANCE QUESTIONS & ANSWERS

Q: If a non-lead member of an Assessment Coalition Grant previously received an EPA
Brownfields Grant, can the applicant (lead member) respond to criterion 4.b.i. Currently
Has or Previously Received an EPA Brownfields Grant?

A: No, under 4.b. Past Performance and Accomplishments, EPA is asking for past performance
information for the lead recipient of a grant, not for non-lead coalition members. Depending
on your situation, you should respond to 4.b.ii. Has Not Received an EPA Brownfields Grant
but has Received Other Federal or Non-Federal Assistance Agreements or 4.b.iii. Never
Received Any Type of Federal or Non-Federal Assistance Agreements.

Q: Can you describe subawardee experience with past Brownfields Grants in the
Programmatic Capability section or does it need to be only the applicant?

A: EPA will only consider the information for the entity that is applying for the grant.

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