TSCA Section 404(g) Lead-Based Paint Programs State, Territory, District of Columbia, Tribal and Federal Grant Guidance for FY21 March 2021 ------- TSCA Section 404(g) Grants - Purpose and Scope The U.S. Environmental Protection Agency (EPA) is making available non-matching financial assistance agreements (grants) to States, Territories, the District of Columbia, and eligible Indian Tribes and Intertribal Consortia under the authority of section 404(g) of the Toxic Substances Control Act (TSCA) (15 U.S.C. 2684(g)). Lead-based paint program grants are awarded 1) to develop and/or carry out an authorized lead-based paint activities program; 2) to develop and/or carry out an authorized lead pre-renovation education program; and 3) to develop and/or carry out an authorized renovation, repair and painting program. Collectively these programs are referred to as lead-based paint programs. Since 1994, EPA has been offering financial assistance agreements under TSCA section 404(g) to States, Territories, and the District of Columbia (hereafter referred to as "States") and to Indian Tribes and Intertribal Consortia (hereafter referred to as "Tribes"). EPA encourages States and Tribes to seek authorization of their own lead-based paint programs. EPA's goal is to have authorized programs in all States and on those Indian Tribal lands where such a program is warranted. The grants must be used to develop and implement authorized programs. To receive this funding, a State or Tribe must be making substantial progress toward an authorized program. Therefore, the EPA Regional Offices, as part of its grant oversight responsibilities, will work with the grantees to determine the appropriate amount of funding based upon the amount of developmental work to be completed as the grantee makes progress toward authorization. This guidance describes the purposes of this grant program and EPA's authority for issuing them; explains what entities are eligible to apply for grants; outlines what activities can be funded; explains how the funds will be awarded and distributed, including the criteria EPA will consider when evaluating grant proposals; discusses grant application submission requirements; and summarizes grant reporting requirements. Proposals that qualify for funding will be funded according to the procedures outlined in the "Award of Funds" and "Distribution of Funds" sections of this guidance document. Background and Authority On October 28, 1992, the U.S. Congress passed the Residential Lead-Based Paint Hazard Reduction Act of 1992 (Title X of Public Law 102-550). Title X amended TSCA by adding Title IVLead Exposure Reduction (15 U.S.C. 2681 et seq.). The purpose of Title X was to develop a national strategy and to build an infrastructure to eliminate lead-based paint hazards in all housing. Congress passed Title X based on findings that: 1) low-level lead poisoning is widespread among American children, affecting as many as three million children under the age of six, with minority and low-income communities being disproportionately affected; 2) low levels of lead poisoning in children cause intelligence quotient deficiencies, reading and learning disabilities, impaired hearing, reduced attention span, hyperactivity, and behavior problems; 3) pre-1980 American housing stock contains more than three million tons of lead in the form of lead-based - 1 - ------- paint; and 4) the ingestion of household dust containing lead from deteriorating or abraded lead- based paint is the most common cause of lead poisoning in children. Section 402(a) of TSCA authorizes EPA to promulgate regulations governing lead-based paint activities to ensure that individuals engaged in such activities are properly trained, that the training programs are accredited, and that contractors engaged in such activities are certified. EPA promulgated these regulations at 40 CFR part 745, subpart L. Section 402(c) of TSCA authorizes EPA to promulgate regulations governing renovation activities conducted in homes built before 1978 that produce a lead-based paint hazard. EPA promulgated these regulations at 40 CFR part 745, subpart E. This regulation also amended provisions under 40 CFR Subpart Q to allow for the authorization of State, Tribal or Territorial Renovation, Repair and Painting (RRP) programs. Section 406(b) of TSCA authorizes EPA to promulgate regulations to require each person who performs for compensation renovation and remodeling of target housing to provide a lead hazard information pamphlet to the owner and occupant of such housing prior to commencing the renovation. EPA promulgated the regulations called for by section 406(b) (Lead Pre- Renovation Education Rule) at 40 CFR Part 745, subpart E. Under TSCA section 404, EPA may authorize any State to administer and enforce the standards, regulations, or other requirements established under TSCA sections 402 and/or 406(b) if the State has a program that is at least as protective of human health and the environment as the program specified in TSCA sections 402 and/or 406(b), and that provides adequate enforcement. EPA's implementing regulations at 40 CFR part 745, subpart Q, extends EPA's ability to authorize lead-based paint programs to Indian Tribes. This extension to Indian Tribes is consistent with the general principles of Federal Indian law and the Agency's Indian policy, which states that Tribal governments will implement environmental programs in Indian country to the maximum extent possible. EPA administers the TSCA lead-based paint grant program under the authority of section 404(g) of TSCA. Regulations governing these grants are found at 2 CFR 200 and 2 CFR 1500 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Assistance). Regulations which supplement the EPA general assistance regulations found in 2 CFR 200 and 2 CFR 1500 are found at 40 CFR part 35, subpart A, and subpart B. Contained within 40 CFR part 35 are specific subsections which govern grants for the lead-based paint program under section 404(g); 40 CFR 35.270 through 35.272 (applicable to States, Territories, and the District of Columbia), and 40 CFR 35.690 through 35.693 (applicable to Indian Tribes and Intertribal Consortia). This grant program is listed in the Catalog of Federal Domestic Assistance (CFDA) under program number 66.707 TSCA Title IV State Lead Grants Certification of Lead-Based Paint Professionals. The EPA Regional Offices administer these grants pursuant to a delegation of authority that permits the 10 EPA Regional Administrators to enter into grants and cooperative agreements with eligible States and Tribes1. This national guidance document is directed primarily to EPA's 1 http://intranet.epa.gov/ohr/rmpolicy/ads/dm/12-29.htm -2- ------- Regional Offices to facilitate and support Regional administration of this program. Regional Offices will work closely with the States and Tribes to develop programs that reflect both EPA and State and Tribal program priorities. Section 404(h) of TSCA requires EPA to implement and enforce a federal lead-based paint program in all States and Tribal areas that do not have a program authorized by EPA under 40 CFR part 745, subpart Q. Although EPA's goal is to authorize as many State and Tribal programs as possible, the Agency and Congress anticipated that there would be a number of States and Tribes that would not seek program authorization. EPA is authorized to use section 404(g) funds to implement a federal lead-based paint program for non-authorized States and Tribes. See 40 CFR 35.116, and 40 CFR 35.516. Eligibility States and Tribes are eligible to apply for financial assistance under this program. To be eligible for funding under this grant a Tribe must meet the criteria in 40 CFR 35.693(a). A State or Tribal applicant may receive assistance if it is either implementing an EPA authorized lead-based paint program pursuant to 40 CFR Part 745, subpart Q, or if it is developing a lead- based paint program that will be authorized in the future. The EPA Regional Offices, as part of their grant oversight responsibilities, will have discretion with respect to determining whether a given State or Tribe is making sufficient progress toward the development and implementation of a program under TSCA Title IV. Failure to make satisfactory progress toward program authorization will result in a State or Tribe receiving no funding. Where the Agency has direct implementation responsibilities, EPA cannot provide financial assistance under this grant program to non-authorized States or Tribes to assist the Agency in implementing and enforcing a Federal program under TSCA section 404(h). Eligible parties may use this grant support in a way that complements and does not duplicate activities for which they already receive or could receive financial assistance from other federal sources (e.g., Centers for Disease Control and Prevention (CDC) and U.S. Department of Housing and Urban Development (HUD)). Where funding is provided to States and Tribes for both TSCA 404(g) Lead STAG grants and Toxic Substances Compliance Monitoring Cooperative agreements, those awards may not be consolidated as a single grant because TSCA 404(g) Lead STAG grant funds cannot be used for enforcement activities. The cooperative agreements must either be awarded as separate grants or be combined in a Performance Partnership Grant (PPG). A PPG provides additional flexibility to grantees allowing States and Tribes to combine funds from this grant program with other environmental program grants, such as the Toxic Substances Compliance Monitoring grants, States must adhere to the requirements for PPGs in 40 CFR 35.130 through 35.138. Tribes must adhere to the requirements for PPGs in 40 CFR 35.530 through 35.538. Activities to Be Funded -3 - ------- This section describes in detail eligible activities that may be funded under this program. Required elements of authorized lead-based paint programs are specified in 40 CFR 745.323 through 745.327. Although the list below is not exhaustive, funding under this grant can be used for the following purposes Develop required elements of authorized lead-based paint programs: Develop and/or enact enabling legislation. Adopt implementing regulations. Develop and/or revise, as needed, work practice standards for the conduct of lead-based paint activities and for the conduct of renovation, repair, and painting. Develop and/or adopt lead hazard standards and clearance standards for lead in soil, dust, and paint. Develop and/or revise, as needed, lead-based paint programs, including regulations or procedures for decertification, suspension, revocation or modification of approvals and certificates. Develop and/or revise, as needed, requirements for the administration of a third-party certification exam. Implement the program: Maintain, improve and/or develop the appropriate infrastructure to successfully administer and enforce a program to ensure that individuals engaged in lead-based paint activities and/or renovation, repair and painting activities regulated by a grantee's lead- based paint renovation, repair, and painting program are properly trained, that training programs are accredited, and that contractors and firms engaged in such activities are certified. Foster activities that would increase the efficiency of a grantees program to ensure that individuals engaged in lead-based paint activities and/or renovation, repair and painting activities regulated by a grantee's program are properly trained; that training programs are accredited; and that contractors engaged in such activities are certified. These activities could include initiatives to develop local capacity in low-income and rural areas, to promote increased competition in the regulated community through agreements which permit entities recognized by an outside jurisdiction to operate in the grantee's jurisdiction (referred to as "reciprocity"), and similar efforts. Foster activities that increase public demand for certified firms and individuals and accredited training providers. These activities could include the provision of outreach and education to the regulated community or the public, as long as the outreach/education activities are designed to increase the number of certified firms, trained individuals and accredited training providers. -4- ------- Adjust or enhance the appropriate infrastructure to accommodate additional program responsibilities. Maintain, improve and/or develop a system to document certification of inspectors, risk assessors, supervisors, workers, project designers, renovators, and dust sampling technicians. Maintain, improve and/or develop the appropriate infrastructure to successfully administer and enforce a program to ensure that renovation contractors provide lead- hazard information to building owners and residents. Oversee the conduct of certified individuals engaged in lead-based paint activities to ensure that they are conducting their activities in accordance with all applicable regulations, including monitoring inspection, risk assessment, and abatement activities per the authorized program. Oversee the conduct of certified renovators engaged in regulated renovation, repair and painting activities to ensure that they are conducting their activities according to all applicable regulations per the authorized program. Oversee accredited training programs per the authorized program. Report on grant performance: Prepare a report per 40 CFR 745.327(d) and/or 2 CFR 200 and 2 CFR 1500 grant reporting requirements on the grantees program progress and performance. Grant Activities that are not authorized2 Section 404(g) of TSCA does not authorize grant funds awarded under this program to be used for the following activities: Activities or programs that provide general lead awareness outreach and education to the public, including o The development of materials, o The printing and distribution of materials, o Purchasing radio, TV or other mass media advertising. GIS mapping and other technology to identify neighborhoods with high incidences of children with elevated blood lead levels. The performance of risk assessments, inspections or lead-based paint abatements. 2 Based on Guidance from OGC on the Use of State and Tribal Assistance Grant Funds under TSCA Sections 10, 28 and 404(g). ------- The training of renovators, dust sampling technicians, risk assessors, inspectors, project designers, abatement supervisors or abatement workers. Enforcement activities including field inspections and case development. (EPA's Office of Enforcement and Compliance Assurance provides grants to fund compliance assurance and enforcement activities in authorized lead-based paint programs.) Funding staff to perform functions other than those allowed, as listed in the section of this guidance entitled "Activities to be Funded." Program Income Under TSCA, authorized lead-based paint training and certification programs are required to collect fees to cover certain costs incurred by the program. These fees are considered "program income," which is defined as "gross income received by a grantee or subgrantee directly generated by a grant supported activity or earned only as a result of the grant agreement during the grant period." See 2 CFR 200 and 2 CFR 1500. It includes income from fees for services performed by the recipient. Program income generated by activities supported under TSCA section 404(g) grants may include fees that a State or Tribe charges for training, accreditation, certification, licensing or other services performed by the lead-based paint program, as well as fees that are collected which provide for enforcement of standards and regulations. Consequently, States and Tribes must comply with the rules governing "program income," found at 2 CFR 200.307 and 2 CFR 1500.7. Specifically, recipients are authorized to add program income to the funds committed to the grant agreement. According to 2 CFR 200.307(e)(2), this program income must be used for the purposes and under the conditions of the grant agreement. Note that according to 2 CFR 200.307(e), a designation must be made in the grant agreement that the addition method is being applied to program income. Funds Available EPA has $14,275,000 in FY2021 appropriated STAG funds available to support EPA's Lead Program. EPA expects that up to $10,990,000 in FY2021 appropriated funds will be available for financial assistance agreements under TSCA section 404(g) for awards to States for the development and implementation of EPA-authorized lead-based paint activities (402(a)) programs, Renovation Repair and Painting Programs (402(c)), and Pre-Renovation Education Programs (406((b)). Of that amount, the Agency is reserving up to $200,000 for States, Tribes or Territories that receive authorization for an RRP program and $100,000 for Tribes to develop and implement an EPA-authorized lead-based paint program. Any funds not used for this purpose will be allocated for other purposes within the lead program. The FY2021 deadline for commitment of funds is June 30, 2021, and for obligation of funds is September 1, 2021. Carryover of FY2021 funds into FY2022 will not be allowed. Funds not committed or obligated by a Region by these deadlines will be reprogrammed to EPA HQ and allocated for other purposes within the lead program. In addition, all STAG funds returned from grantees during FY2021, including returned STAG designated as E1D would be reprogrammed back to EPA HQ at that time and allocated for other purposes within the lead program. -6- ------- Funding for EPA Authorized Lead Programs Financial assistance to Tribes Each Tribe that submits a qualifying proposal and is making sufficient progress toward the development and/or implementation of an acceptable lead-based paint program, as determined by the EPA Regional Offices, may receive base funding of up to $50,000. Though Tribes without an authorized program may submit qualifying proposals, the award of funds will be based upon the applicant's progress in developing an acceptable program, including implementing regulations and seeking program authorization from EPA. Failure to make satisfactory progress toward program authorization will result in the Tribe receiving no funding. Tribes can only be eligible for program development funding for 3 years after their first grant. If a Tribe is unable to receive program authorization within that period, it will be considered ineligible for further grant funding until it receives program authorization. Further distribution of the Tribal set-aside funds will be dependent upon the number of applicants, the progress that the grantee is making in developing a program, the status of expenditures of previously awarded funds, population, and the relative strength of the proposal. After the closing date for submittal of Tribal applications specified in this guidance, EPA Headquarters and Regional Offices will consider each of the proposals and make decisions about the level of funding to be awarded to each of the applicants. Following those decisions, EPA Headquarters will transfer the funds to the Regional Offices for award to the Tribes. Tribal set- aside funds are not included in the formula funds pool for States as discussed below. Requests for Tribal grant funds under TSCA section 404(g) must be submitted to HQ by March 31, 2021. If these funds remain unrequested by that date, HQ will redirect the funds to other lead program priorities. Financial Assistance to States The process used by EPA for determining award-funding levels for States involves two steps. In Step 1, EPA Headquarters determines, based on the factors discussed below, the funding level that will be made available to each of the EPA Regional Offices for grants. Following distribution of the funds to the EPA Regional Offices, in Step 2, the Regional Offices make decisions on the actual funding level for each of the grantees. A two-tiered system to determine the amount of grant funds that will be distributed to the EPA Regional Offices will be used in FY2021. This system provides a base funding level for each authorized program while providing funds targeted to States with the largest program workload and with the greatest potential lead burden. The base funding set-aside provides a base level of funds for every State. Each State that has an authorized lead-based paint abatement program receives a base funding allotment of $50,000. Each State that has an authorized Renovation, Repair and Painting program receives a base funding allotment of $75,000. Each State that has an authorized Pre-Renovation Education program, but not an RRP program, receives a base funding allotment of $50,000. Any State that submits a qualifying proposal and is making sufficient progress toward implementation of an acceptable program may receive a $50,000 base. In order to remain eligible for grant funding, the -7- ------- State must have a final application package for program authorization to the Agency three years after the State's enabling legislation is signed into law. In calculating the lead burden for the formula rankings, EPA uses readily available data derived from the 2019 Census and the 2001 National Survey of Lead and Allergens in Housing prepared by the U.S. Department of Housing and Urban Development (HUD). The formula uses four factors to generate an estimate of the potential lead problem, or "lead burden," in each state. Two of these factors, the number of housing units built before 1980 and the number of children under age five, express the potential magnitude of the lead problem. The remaining two factors, the percentage of children under five in poverty and the number of low-income housing units with lead-based paint, express the potential severity of the problem. In calculating the estimated workload of each grantee, the Agency collects data from each grantees' lead-based paint abatement program. This data includes the number of active certifications (individual and firm), and active accreditations issued by the grantee. In determining formula rankings, each State is scored independently for each factor. The four lead burden factors and the two workload-estimated factors for each State are then summed to obtain two score totals lead burden and workload. These are then weighted 30% for lead burden and 70% for workload and summed for that applicant to produce a combined factor score. The combined factor scores of all applicants for formula funds are summed, and the percentage of the total sum represented by that score is then identified. The grantees formula allotment is determined by multiplying the total formula funding by the percentage score. In addition to the funds described above, the Agency is expecting to make available grants to any State, Tribe or Territory that receives authorization for an RRP program by March 31, 2021. The Agency has set aside $200,000 for FY2021 for that purpose. The final award amount will be dependent on the number of new authorized programs, the financial needs of the applicant and the availability of funds. Requests for funds made after the March 31st cutoff will be considered on a case by case basis, but generally HQ will redirect any funds not requested by that date to other lead program priorities. Agency Direct Implementation In FY2021, the program plans to use approximately $3,285,000 for direct implementation of the abatement and RRP programs in all non-authorized States, Tribes and Territories. $1,638,000 will be distributed to the Regions based on a formula with sixty percent of the funds being distributed evenly across all Regions as base funding. In FY2021, the formula uses the percentage of certified renovation firms, the number of training providers that are eligible for reaccreditation in FY2021 and the lead burden number for each Region. The Regions will primarily use these funds to hire support staff to assist in the accreditation of RRP and abatement training providers and in Regions 2 and 9 for the certification of abatement professionals. Regions 2 and 9 process certifications of abatement professionals for all Regions and will receive additional funding to support these activities. $1,647,000 will be used to support the certification of RRP and abatement professionals as well as the accreditation of training providers, this equals the funding allocated for this purpose in the ------- previous fiscal year. The bulk of these funds will provide contract support for the entire lead program. These funds will cover: Working Capital Fund costs for the Regions, HQ and contractors; CDX maintenance and enhancement (electronic submission of abatement applications and training provider notifications and RRP firm applications); The National Lead Information Center only for the purpose of answering questions regarding Lead-based activities and RRP certification and accreditation; FLPP database operations, maintenance and redesign; Processing and data entry for all RRP and abatement applications; Processing and data entry of all training provider accreditation applications; and Processing and data entry of all pre and post training notifications for both abatement and RRP training. Section 404(g) of TSCA does not authorize Direct Implementation funds be used for the following activities. Activities or programs providing general lead awareness outreach and education to the public, including o The development of materials, o The printing and distribution of materials, o Purchasing radio, TV or other mass media advertising. GIS mapping and other technology to identify neighborhoods with high incidences of children with elevated blood lead levels. The performance of risk assessments, inspections or lead-based paint abatements. The training of renovators, risk assessors, inspectors, abatement supervisors, abatement workers or dust testing technicians. Funding staff to perform functions other than those listed above as allowable activities. Submission Requirements 40 CFR part 35, subpart A and subpart B describes in detail the submission requirements for grant applications. For section 404(g) funding for Tribes, EPA is soliciting pre-application grant proposals prior to the submittal of the forms and certifications listed in this unit. This pre- application procedure entails the applicants initially submitting only a work plan and a budget. -9- ------- The Agency will use the applicants' work plans and budgets to select programs to be funded under this grant program. EPA will conduct a review of all submitted applications and required documents, including but not limited to the "Application for Federal Assistance" form (Standard Form 424), and the "Budget Information: Non-Construction Programs" form (Standard Form 424A). The required forms can be found at https://www.epa.gov/grants/epa-grantee-forms. All applications must be submitted by an official representative of your institution who is registered with grants.gov and is authorized to sign applications for federal assistance. The grantee should go to Grants.Gov and click on "APPLICANTS" on the top of the page and then click on "Apply for Grants" from the dropdown menu and then, click on 'APPLY" and follow the instructions accordingly. Please note to apply through Grants.gov you must use Adobe Reader software and download the compatible Adobe Reader version. For more information about Adobe Reader, to verify compatibly, or to download the free software please visit Adobe Reader Compatibility Information on Grants.gov. The grantee may also access the application package for this announcement by searching for the opportunity on Grants.gov. Go to grants.gov and then click on "Search for Grants" at the top of the page, under Basic Search Criteria in the CFDA box, enter the CFDA number and click on the search button. The Catalog of Federal Domestic Assistance (CFDA) number is 66.707 "TSCA Title IV State Lead Grants Certification of Lead-Based Paint Professionals Grant. The grantee should select the "PACKAGE TAB" and click on "select package" for 66.707. In addition, as part of the pre-application, Tribes must include all appropriate information to demonstrate that they meet the criteria at 40 CFR 35.693 for treatment as a State. In order for Intertribal Consortia to be eligible for financial assistance under section 404(g), they must include all appropriate information to demonstrate that they meet the requirements at 40 CFR 35.504 concerning eligibility. Where a single State agency has been designated as responsible for coordinating lead activities, EPA encourages that agency to apply for funding under TSCA section 404(g). Coordination of federally funded lead activities by a single agency is viewed as conducive to achieving integration of lead activities. Early consultations are recommended between prospective applicants and their EPA Regional Offices. Because TSCA grants will be administered at the Regional level, these consultations can be critical to the success of a project or program and can also contribute substantially to efficient program operations. As part of the work plan, EPA Regional Offices may ask for additional information that will be useful in evaluating the program such as the status of enabling legislation, a detailed line-item budget with sufficient information to clearly justify costs, a list of work products or deliverables, a schedule for their completion and application for program authorization under TSCA, and a description of any financial assistance received from other federal sources concerning the lead program. Applicants must - 10- ------- also include all appropriate information on program income in accordance with 2 CFR 1500.7 and 2 CFR 200.307. Work plans are to be negotiated between applicants and their Regional Offices to ensure that both EPA and State or Tribal priorities are addressed. Any application from a State or Tribe that is not making sufficient progress toward implementation of an acceptable program will not be funded. Reporting Pursuant to 2 CFR 200.307, grantees shall submit quarterly performance reports to the appropriate EPA Regional Office. The Office of Management and Budget (OMB) under OMB Control Number 2030-0020 (General Administrative Requirement for Assistance Programs) approved these requirements. The specific information contained within the report should include: a comparison of actual accomplishments to the objectives established for the period; the number of lead-based paint activities individual and firm certifications issued in the reporting period; the number of valid certified lead-based paint activities individuals and firms, by discipline; the number of RRP firm certifications issued in the reporting period; the number of valid RRP firm certifications; the number of accredited of lead-based paint activities training courses by discipline; the number of RRP training provider accreditations issued in the reporting period. Cost Principles for State, Local, and Indian Tribal Governments Grantees should note that 2 CFR 225 - Cost Principles for State, Local, And Indian Tribal Governments (OMB Circular A-87) is applicable to these grants and they should pay particular attention to Appendix B, Section 8.h.- Selected Items of Cost3 regarding compensation for personal services. Support of salaries and wages. These standards regarding time distribution are in addition to the standards for payroll documentation. 3 https://www.gpo.gov/fdsys/pkg/CFR-2012-title2-voll/pdf/CFR-2012-title2-voll-part225-appB.pdf - 11 - ------- (1) Charges to Federal awards for salaries and wages, whether treated as direct or indirect costs, will be based on payrolls documented in accordance with generally accepted practice of the governmental unit and approved by a responsible official(s) of the governmental unit. (2) No further documentation is required for the salaries and wages of employees who work in a single indirect cost activity. (3) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semiannually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. (4) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports or equivalent documentation which meets the standards in subsection 8.h.(5) of this appendix unless a statistical sampling system (see subsection 8.h.(6) of this appendix) or other substitute system has been approved by the cognizant Federal agency. Such documentary support will be required where employees work on: (a) More than one Federal award, (b) A Federal award and a non-Federal award, (c) An indirect cost activity and a direct cost activity, (d) Two or more indirect activities which are allocated using different allocation bases, or (e) An unallowable activity and a direct or indirect cost activity. (5) Personnel activity reports or equivalent documentation must meet the following standards: (a) They must reflect an after the fact distribution of the actual activity of each employee, (b) They must account for the total activity for which each employee is compensated, (c) They must be prepared at least monthly and must coincide with one or more pay periods, and (d) They must be signed by the employee. (e) Budget estimates or other distribution percentages determined before the services are performed do not qualify as support for charges to Federal awards but may be used for interim accounting purposes, provided that: (i) The governmental unit's system for establishing the estimates produces reasonable approximations of the activity actually performed; (ii) At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports are made. Costs charged to Federal awards to reflect - 12- ------- adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent; and (iii) The budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances. - 13 - ------- STAG Distribution FY21 FY20 Target* $14,275,000 $14,049,000 Program Regional DI $1,413,000 $1,390,000 Regional Centers of Excellence $225,000 $225,000 $1,638,000 $1,615,000 HQ DI $1,647,000 $1,620,000 Agency Direct Implementation $3,285,000 $3,235,000 Grants for Authorized Tribes $100,000 $100,000 State Grants - Abate, RRP & 406(b) $10,690,000 $10,514,000 State Grants - FY21 RRP Apps. $200,000 $200,000 Sec 404(g) State/Tribal Support $10,990,000 $10,814,000 Total $14,275,000 $14,049,000 * FY21 funding is based on the enacted budget of $1^ t,275K. - 14- ------- FY21 STAG Funds - Regional Distribution Reg. Formula DI Tribes Total Auth. 1 $1,257,327 $127,905 $1,385,232 2 $547,136 $308,122 $855,258 3 $1,445,812 $145,850 $1,591,662 4 $1,766,571 $174,121 $1,940,691 5 $1,838,382 $186,344 $2,024,726 6 $1,009,178 $144,703 $1,153,880 7 $1,080,843 $111,477 $1,192,320 8 $596,021 $115,847 $711,868 9 $562,363 $213,100 $775,463 10 $586,368 $110,531 $696,899 Totals $10,690,000 $1,638,000 $12,328,000 - 15 - ------- Regional Direct Implementation 1 2 3 4 5 6 7 8 9 10 RRP Trainers - Reaccredit. Trainers due for Re Accredit, in FY21 14 22 11 14 24 16 3 9 12 7 132 Percentage 10.6% 16.7% 8.3% 10.6% 18.2% 12.1% 2.3% 6.8% 9.1% 5.3% RRP Certified Firms Includes EPA Cert, firms in Authorized States 4,619 12,132 9,466 6,451 14,806 3,749 2,199 1,928 9,228 1,452 66,030 Percentage 7.0% 18.4% 14.3% 9.8% 22.4% 5.7% 3.3% 2.9% 14.0% 2.2% Combined Percentages 8.8% 17.5% 11.3% 10.2% 20.3% 8.9% 2.8% 4.9% 11.5% 3.8% 100% Percent of Lead Burden 6.5% 8.4% 10.3% 21.4% 15.6% 12.3% 6.6% 6.1% 7.3% 5.4% 100% Combined Percentages 7.6% 13.0% 10.8% 15.8% 18.0% 10.6% 4.7% 5.5% 9.4% 4.6% 100% 40% Formula Funding $43,125 $73,342 $61,070 $89,341 $101,564 $59,923 $26,697 $31,067 $53,320 $25,751 r $565,200 60% Base Funding $84,780 $84,780 $84,780 $84,780 $84,780 $84,780 $84,780 $84,780 $84,780 $84,780 $847,800 Total DI Funds $127,905 $158,122 $145,850 $174,121 $186,344 $144,703 $111,477 $115,847 $138,100 $110,531 Centers ofExeellence $150,000 $75,000 $225,000 M2".')ll5 S3HN.I22 M45.S5II M "4.121 MX(.J44 M44.-H3 Ml 1.4" MI5.S4" S213.HHI SI 111.531 M.(i3K.IIIIII ------- ii! 1 1_ 1_ 1_ 1_ 1_ 2. 2 2 3 3 3_ 3_ 3 3_ _4 _4 4_ 4_ _4 4_ 4_ 4_ _6 6 _6 _6 _6 ]_ 1_ 1_ 1_ a_ _8 _8 _8 _8 9_ 9 State Connecticut Maine Massachusetts New Hampshire Rhode Island Vermont New Jersey New York Puerto Rico Delaware DC Formula Allocation $225,050 $165,855 $337,837 $157,145 $250,533 $120,908 $276,628 $0 $270,508 $164,310 $211,766 1 $1,257,327 2 $547,136 3 $1,445,812 4 $1,766,571 5 $1,838,382 6 $1,009,178 7 $1,080,843 8 $596,021 9 $562,363 10 $586,368 Maryland $293,411 Pennsylvania $323,087 Virginia $295,495 West Virginia Alabama $157,743 $320,015 Florida Georgia Kentucky Mississippi North Carolina South Carolina Tennessee Illinois Indiana Michigan Minnesota Ohio Wisconsin Arkansas Louisiana New Mexico Oklahoma Texas Iowa Kansas Missouri Nebraska Colorado Montana North Dakota South Dakota Utah Wyoming Arizona California Hawaii Nevada Alaska Idaho Oregon Washington $0 $344,012 $214,920 $261,332 $337,397 $0 $288,896 $340,937 $257,245 $372,571 $231,186 $312,387 $324,057 $161,845 $255,226 $0 $255,728 $336,378 $303,618 $294,947 $299,080 $183,198 $234,253 $0 $108,673 $0 $253,095 $0 $0 $341,965 $220,398 $0 $0 $0 $267,914 $318,454 $10,690,000 - 17 ------- Region State Number of Pre-1978 Housing Units (2019 Cens us) Number of children under 5 years (2019 Census) °/o of children under 5 in powrty(2019 Census) Number of Low- Income Housing Units with LBP (2001 NSLAH) Decile Rank ounirii Lead Burden « # of Cert Acer. Training Course Rank Workload Workload Score Percent of Total $ Formula Award 402 Auth RRP/406b Auth. 406b Only Base Award Total Award °/0 total 1 Connecticut 1,063,176 180,598 15 73,023 31 19 16 17 83 469 24 36 29 65 2.3% $175,050 Y N N $50,000 $225,050 211% 1 Maine 423,717 62,813 17 44,311 14 10 22 13 59 226 8 24 18 42 1.5% $115,855 Y N N $50,000 $165,855 1 55% 1 Massachus etts 2,054,901 355,066 12 164,435 42 33 9 33 117 390 44 33 42 75 2.8% $212,837 Y Y N $125,000 $337,837 3 16° o 1 New Hampshire 345,758 64,200 8 24,904 12 11 1 6 30 204 14 23 22 45 1.4% $107,145 Y N N $50,000 $157,145 147° o 1 Rhode Island 347,039 54,802 16 34,066 13 7 20 10 50 116 33 14 35 49 1.7% $125,533 Y Y N $125,000 $250,533 2 34% 1 Vermont 195,386 29,021 11 17,637 3 1 4 3 11 166 2 18 14 32 0.9% $70,908 Y N N $50,000 $120,908 1.13% 2 New Jeis ey 2,369,457 511,925 13 174,580 43 41 13 35 132 812 34 42 36 78 3.0% $226,628 Y N N $50,000 $276,628 2 50% 2 New York 6,442,524 1,119,825 19 629,147 50 48 33 49 180 0 0 1 1 2 0.0% $0 N N N $0 $0 0.00% 2 Puerto Rico 847,100 115,403 64 314,016 23 14 51 44 132 385 46 31 44 75 2.9% $220,508 Y N N $50,000 $270,508 2 53% 3 DC 201,480 54,261 18 25,029 5 6 30 7 48 146 22 17 27 44 1.5% $114,310 Y N N $50,000 $164,310 1 54° o 3 Delaware 233,127 45,263 19 18,100 7 3 32 4 46 172 1 19 12 31 1.2% $86,766 Y y N $125,000 $211,766 1.98% 3 Maryland 1,312,100 358,346 12 111,181 32 34 7 24 97 1,389 76 47 48 95 3.2% $243,411 Y N N $50,000 $293,411 2 74° o 3 Pennsylvania 3,964,002 695,661 17 367,748 48 46 26 47 167 1216 70 46 46 92 3.6% $273,087 Y N N $50,000 $323,087 3 02° o 3 Virginia 1,633,999 499,906 14 181,204 39 40 14 36 129 795 71 41 47 88 3.3% $245,495 Y N N $50,000 $295,405 2 76° o 3 West Virginia 530,529 91,548 23 86,555 18 13 44 20 95 116 4 14 15 29 1.4% $107,743 Y N N $50,000 $157,743 148° o 4 Alabama 1,008,512 286,597 24 186,526 28 27 45 38 138 188 38 22 39 61 2.6% $195,015 Y Y N $125,000 $320,015 2 0Q% 4 Florida 3,549,752 1,131,148 20 520,901 47 49 35 48 179 0 0 1 1 2 0.0% $0 N N N $0 $0 0.00% 4 Georgia 1,516,938 639,713 20 252,267 36 44 36 41 157 331 40 28 40 68 2.9% $219,012 Y Y N $125,000 $344,012 3 22° o 4 Kentucky 1,013,385 273,130 26 169,114 29 26 46 34 135 375 7 30 17 47 2.2% $164,920 Y N N $50,000 $214,920 2.01% 4 Mississippi 597,260 179,497 31 131,142 20 18 50 27 115 173 8 20 18 38 1.8% $136,332 Y Y N $125,000 $261,332 244% 4 North Carolina 1,773,330 596,583 22 265,694 41 43 41 43 168 339 30 29 33 62 2.8% $212,397 Y Y N $125,000 $337,397 3 16° o 4 South Carolina 843,448 289,537 21 144,783 22 28 39 29 118 0 0 1 1 2 0.0% $0 N N N $0 $0 0.00% 4 Tennessee 1,318,378 407,026 23 210,108 33 36 43 40 152 524 45 36 43 79 3.2% $238,896 Y N N $50,000 $288,896 2.70% 5 Illinois 3,536,485 742,404 18 315,543 46 47 28 45 166 1,829 115 50 51 101 3.9% $290,937 Y N N $50,000 $340,937 3 loo o 5 Indiana 1,688,016 414,553 17 162,133 40 37 21 32 130 548 28 37 32 69 2.8% $207,245 Y N N $50,000 $257,245 241% 5 Michigan 2,958,788 567,914 19 262,580 44 42 34 42 162 1,425 58 48 45 93 3.6% $272,571 Y N Y $100,000 $372,571 3 4°% 5 Minnesota 1,346,224 349,621 11 110,688 34 32 6 23 95 600 19 39 26 65 2.4% $181,186 Y N N $50,000 $231,186 2 16° 0 5 Ohio 3,431,409 686,672 21 329,971 45 45 38 46 174 1,177 42 44 41 85 3.5% $262,387 Y N N $50,000 $312,387 2 02% 5 Wisconsin 1,608,023 327,258 15 131,067 38 30 16 26 110 1,197 17 45 25 70 2.7% $199,057 Y Y N $125,000 $324,057 3 03° 0 6 Arkansas 595,824 183,327 26 113,475 19 20 47 25 111 42 4 12 15 27 1.5% $111,845 Y N N $50,000 $161,845 1.51% 6 Louisiana 1,036,807 292,977 28 198,945 30 29 48 39 146 385 30 31 33 64 2.7% $205,226 y N N $50,000 $255,226 2 30% 6 New Mexico 432,754 116,978 28 75,838 15 16 49 17 97 0 0 1 1 2 0.0% $0 N N N $0 $0 0.00% 6 Oklahoma 914,381 251,083 22 138,266 25 25 42 28 120 127 8 16 18 34 1.7% $130,728 Y Y N $125,000 $255,728 2 30% 6 Te>as 4,256,847 1,981,755 21 699,940 49 50 40 50 189 975 110 43 50 93 3.8% $286,378 Y N N $50,000 $336,378 3 15° 0 7 Iowa 905,005 190,606 15 80,995 24 22 17 19 82 773 22 40 27 67 2.4% $178,618 Y Y N $125,000 $303,618 2 84% 7 Kansas 759,726 183,236 17 76,717 21 19 23 18 81 405 24 34 29 63 2.3% $169,947 Y Y N $125,000 $294,047 2 76° 0 7 Missouri 1,557,239 365,451 18 182,503 37 35 31 37 140 1,638 37 49 38 87 3.3% $249,080 Y N N $50,000 $299,080 2.80% 7 Nebraska 519,321 129,551 13 49,097 17 17 12 15 61 173 25 20 30 50 1.8% $133,198 Y N N $50,000 $183,198 1.71% 8 Colorado 1,068,818 327,302 11 104,793 31 31 3 22 87 248 8 26 18 44 1.8% $134,253 Y N Y $100,000 $234,253 2 10% 8 Montana 271,276 58,850 15 36,137 8 8 18 11 45 0 0 1 1 2 0.0% $0 N N N $0 $0 0.00% 8 North Dakota 195,594 50,567 10 23,377 4 4 2 5 15 103 1 13 12 25 0.8% $58,673 Y N N $50,000 $108,673 1.02% 8 South Dakota 214,443 58,859 17 26,142 6 9 25 8 48 0 0 1 1 2 0.0% $0 N N N $0 $0 0.00% 8 Utah 436,491 245,883 11 46,679 16 24 5 14 59 236 16 25 23 48 1.7% $128,095 Y Y N $125,000 $253,095 2 37% 8 Wyoming 141,748 33,098 14 16,318 2 2 15 2 21 0 0 1 1 2 0.0% $0 N N N $0 $0 0.00% 9 Arizona 981,175 427,707 21 156,549 27 38 37 31 133 0 0 1 1 2 0.0% $0 N N N $0 $0 0.00% 9 California 8,454,319 2,377,839 16 959,875 51 51 19 51 172 7,000 106 51 49 100 3.9% $291,965 Y N N $50,000 $341,965 3 20° 0 9 Hawaii 298,724 85,335 12 28,429 9 12 8 9 38 596 34 38 36 74 2.3% $170,398 Y N N $50,000 $220,398 2.06% 9 Nevada 307,021 184,168 18 51,651 10 21 29 16 76 0 0 1 1 2 0.0% $0 N N N $0 $0 0.00% 10 Alaska 127,853 50,891 17 13,924 1 5 24 1 31 0 0 1 1 2 0.0% $0 N N N $0 $0 0.00% 10 Idaho 309,844 115,837 18 40,159 11 15 27 12 65 0 0 1 1 2 0.0% $0 N N N $0 $0 0.00% 10 Oregon 931,204 223,364 13 104,399 26 23 10 21 80 321 16 27 23 50 1.9% $142,914 Y Y N $125,000 $267,914 2.51% 10 Washington 1,494,387 455,283 13 155,037 35 39 11 30 115 406 26 35 31 66 2.6% $193,454 Y Y N $125,000 $318,454 2.98% Totals 74,365,044 19,520,238 8,837,698 5387 28,736 1363 100% $7,490,000 S3,200,000 $10,690,000 100.00% Source: I .s. < ensiis Bureau, American Community Survey, 2019, Table B01001, B17001 and DP04; HUD National Survey of Lead and Allergens in Housing, 2001 ------- |