Water Infrastructure Improvements for the Nation (WIIN) Act Reducing Lead in Drinking Water Grant Program Frequently Asked Questions Updated 2/15/2022

Water Infrastructure Improvements for the Nation (WIIN) Act: Reducing Lead in
Drinking Water grant program

Frequently Asked Questions
Updated 2/15/2022

Al. How much money will be awarded?

The total estimated amount of federal funding available under the CY2022 announcement is
$20 million. It is anticipated that a total of three to seven assistance agreements, each with a
project period of up to four years, will be awarded under the announcement.

The following is the expected total of awards in each of the two National Priority Areas.

• One to two awards are anticipated under NPA 1: Reduction of Lead Exposure in the
Nation's Public Water Systems through Lead Service Line Replacements and Corrosion
Treatment Improvements with a potential total of up to $10,000,000.

• Two to five awards are anticipated under NPA 2: Reduction of Children's Exposure to
Lead in Drinking Water in Schools and Child Care Facilities, with a potential total of up to
$10,000,000.

A2. Are matching funds required? Is a waiver available for the required 20 percent non-
federal cost-share/ match?

No, for the current funding, EPA is applying a waiver to all grant applicants of the statutory 20
percent cost-share due to the financial constraints caused by the COVID-19 pandemic across
the country.

A3. What is an eligible project under the Reduction in Lead Exposure via Drinking Water
Grant program?

The EPA is soliciting applications from eligible applicants, as described under Eligibility
Information (Section III.A. of the RFA), to reduce lead in drinking water in disadvantaged
communities through infrastructure and/or treatment improvements or facilitate remediation
in schools and child care facilities. National Priority Areas identified in this announcement are
for: (1) Reduction of Lead Exposure in the Nation's Drinking Water Systems through
Infrastructure and Treatment Improvements and (2) Reduction of Children's Exposure to Lead
in Drinking Water at Schools and Child Care Facilities. Refer to the RFA Summary section for
more information.

A4. Should the application include complete project planning and design?

Applicants should include a description of the completed project planning and design phases.
See Expeditious Project Readiness to Proceed (Section I.C in the RFA) for more information.

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A5. When is the application deadline?

The closing date and time for receipt of application submissions is April 18th, 2022 by 11:59 PM,
Eastern Time, in order to be considered for funding.

A6. When does EPA expect to send notification of award status, as related to Reduction in
Lead Exposure Via Drinking Water?

Please refer to SECTION VI. A. Award Notices which states "Following EPA's evaluation of the
applications, all applicants, including those who are not selected for funding, will be notified
regarding their status. Notification will be made to the original signer of the Standard Form (SF)
424, Application for Federal Assistance and will be sent to the original signer of the application
or the project contact listed in the application. This notification, which informs the applicant
that its application has been selected and is being recommended for award, is not an
authorization to begin work. The official notification of an award will be made by the Grants
and Interagency Agreements Management Division.

Applicants are cautioned that only an Award Official is authorized to bind the Government to
the expenditure of funds; selection does not guarantee an award will be made. For example,
statutory authorization, funding or other issues discovered during the award process may affect
the ability of EPA to make an award to an applicant. The award notice, signed by an EPA Award
Official, is the authorizing document and will be provided through electronic or postal mail. The
successful applicant may need to prepare and submit additional documents and forms (e.g.,
workplan), which must be approved by EPA, before the assistance agreement can officially be
awarded. The time between notification of selection and award of a grant can take up to 90
days or longer."

A7. Is there a ranking criteria established?

Please refer to Section V.A., Selection Criteria. All eligible applications, based on the Section III
threshold eligibility review, will be evaluated based on the evaluation criteria and weights (100
total point scale). Points will be awarded based on how well and thoroughly each criterion
and/or sub-criterion is addressed in the application package.

A8. How will the projects be awarded funding?

Please refer to Section II.B. Type of Funding, the RFA states "It is anticipated that grants and/or
cooperative agreements may be funded under this announcement. When cooperative
agreements are awarded, the EPA will have substantial involvement with the project work plan
and budget. Although the EPA will negotiate precise terms and conditions relating to substantial
involvement as part of the award process, the anticipated substantial federal involvement for
the project selected and funded as a cooperative agreement may include the following."

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A9. What is Justice40?

Justice40 is a whole-of-government effort to ensure that Federal agencies work with states and
local communities to make good on President Biden's promise to deliver at least 40 percent of
the overall benefits from Federal investments in climate and clean energy to disadvantaged
communities. More information on the justice40 initiative is available at
https://www.whitehouse.gov/omb/briefing-room/2021/07/20/the-path-to-achieving-
justice40/.

A10. Given the small amount of funds available, is it possible for the applicant to apply for
funds to cover only the post construction monitoring?

Please refer to Section LB. National Priority Areas:

National Priority Area One: Reduction of Lead Exposure in the Nation's Drinking Water
Systems through Infrastructure and Treatment Improvements

"Under this National Priority Area, the EPA is soliciting applications to reduce lead in drinking
water in disadvantaged communities through infrastructure and/or treatment projects, such as
lead service line replacement and corrosion control practices."

National Priority Area Two: Reducing Children's Exposure to Lead in Drinking Water in
Schools and Child Care Facilities

"Under this National Priority Area, the EPA is soliciting applications for projects in
disadvantaged communities that will reduce children's exposure to lead in schools and child care
facilities through removal and/or replacement of lead-containing drinking water fixtures,
fountains, outlets, and plumbing materials."

ELIGIBILITY

Bl. What applicants are eligible to apply for the funding?

Please refer to Section III.A, Eligible Applicants, of the RFA. Eligible applicants under this
competition include the following. Individuals and for-profit organizations are not eligible to
apply. The EPA may ask applicants to demonstrate that they are eligible for funding under this
announcement.

• Community water systems, for example a town's drinking water system.

• Water systems located in an area governed by an Indian Tribe.

• Non-transient non-community water systems, for example schools and hospitals that
have their own water systems.

• Qualified nonprofit organizations servicing a public water system.

• Municipalities.

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• State, interstate, or intermunicipal agencies, such as a department of environmental
protection, an interstate environmental commission, or a joint municipal pollution
control board.

B2. How does EPA define nonprofit organization?

Nonprofit organization, as defined by 2 CFR Part 200, means any corporation, trust, association,
cooperative or other organization that: (1) is operated primarily for scientific, educational,
service, charitable or similar purposes in the public interest; (2) is not organized primarily for
profit; and (3) uses its net proceeds to maintain, improve and/or expand its operations. Note
that 2 CFR Part 200 specifically excludes the following types of organizations from the definition
of nonprofit organization because they are separately defined in the regulation: (i) institutions
of higher education; and (ii) state, local and federally recognized Indian tribal governments.
Institutions of Higher Education are defined at 20 U.S.C. 1001. Nonprofit organizations
described in Section 501(c)(4) of the Internal Revenue Code that engage in prohibited lobbying
activities as defined in Section 3 of the Lobbying Disclosure Act of 1995 are not eligible to apply.

B3. What are the requirements to be eligible as a qualified nonprofit organization servicing a
public water system?

Please refer to Section III, A. Eligible Applicants of the RFA, which states that a "Nonprofit
organization, as defined by 2 CFR Part 200, means any corporation, trust, association,
cooperative or other organization that: (1) is operated primarily for scientific, educational,
service, charitable or similar purposes in the public interest" Applicants should demonstrate in
the application that they are a qualified nonprofit organization servicing a public water
system. During the application process, the applicant should define or describe how the
organization is servicing a public water system. For example, describe the working relationship
between the applicant (that is a non-profit) and the public water system that would be served
under the application.

B4. Are territories of the United States eligible to apply to this RFA?

Yes. For purposes of this RFA, territories of the United States are considered States and are
eligible entities. Any eligible entity located in a territory may apply and compete to receive
funding under this competition, so long as the applicant meets the requirements described in
Section III of the RFA.

B5. Does the community being served by the project need to be disadvantaged?

Yes. These projects must be in one or more disadvantaged communities as determined by the
state's Drinking Water State Revolving Fund (DWSRF) affordability criteria.

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B6. What is considered a disadvantaged community?

Each state establishes affordability criteria under section 1452(d)(3) of the Safe Drinking Water
Act (SDWA), and a disadvantaged community is defined as "the service area of a public water
system that meets affordability criteria." The affordability criteria must be met for the
community for which the project will be performed. More information about a state's
affordability criteria can be found in a state's most current final Intended Use Plan or by
contacting the state Drinking Water State Revolving Fund program. See Threshold Criteria
(Section II.C.3 in the RFA) for more information.

B7. Are schools and child care facilities that are considered public water systems (PWS)
eligible applicants for this funding opportunity?

Yes. A school or child care facility that is a community water system, water system located in an
area governed by an Indian Tribe, or non-transient non-community water system is an eligible
entity under this RFA. See Eligible Applicants (Section III.A) for more information.

B8. Are privately-owned public community water systems eligible for funding under the WIIN
Grant: Reduction in Lead Exposure Via Drinking Water under SDWA Section 1459B as one of
the eligible entities addressed below?

•	Community water systems, for example a town's drinking water system.

•	Water systems located in an area governed by an Indian Tribe.

•	Non-transient non-community water systems, for example schools and hospitals that
have their own water systems.

•	Qualified nonprofit organizations servicing a public water system.

•	Municipalities.

•	State, interstate, or intermunicipal agencies, such as a department of environmental
protection, an interstate environmental commission, or a joint municipal pollution
control board

There are 151,000 public water systems in the US. The EPA breaks those down into 3 categories
(public water systems, non-transient non-community water systems, and transient water
systems). Community water systems (CWSs) are a subset of the public water systems. They can
be publicly- or privately-owned. For example, the City of Baltimore's water system is a publicly-
owned CWS. Boise, Idaho's water system is also an example of a privately-owned CWS.

B9. Are school districts eligible to apply for funds under the Reduction in Lead Exposure Via
Drinking Water under SDWA Section 1459B RFA? Do they qualify as municipalities or
intermunicipal agencies?

Please refer to SECTION III. A. Eligible Applicants, in the RFA, which defines the applicants that
are eligible. Please see response to question B8. Whether a school district is considered a
municipality or an inter-municipality may vary by state and may be dependent on state,
municipal, or local regulations. Contact your state or proper authority administration or
department of education for further information. Applicants should demonstrate in the
application submission that they meet the eligibility requirements.

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BIO. We are a not-for-profit Church and a not-for-profit School sharing a building and water
system. How do we go about applying for Grant money?

Please refer back to question B3, above, to understand how applicants describe or define how
the organization is servicing a public water system. For example, describe the working
relationship between the applicant (that is a non-profit) and the public water system that
would be served under the application.

Bll. Does the District of Columbia qualify to participate in applying for the Request for
Application if there is no established definition for "disadvantaged communities" under the
jurisdiction? How should it proceed?

Congress did not authorize the establishment of drinking water state revolving loan fund
programs in the District of Columbia and the U.S. territories of U.S. Virgin Islands (USVI), Guam,
American Samoa, and the Commonwealth of the Northern Mariana Islands (CNMI). Therefore,
those jurisdictions do not have disadvantaged community criteria under SDWA section
1452(d)(3). However, the EPA allots a portion of the national Drinking Water State Revolving
Fund (DWSRF) appropriation as construction grants for drinking water infrastructure in those
jurisdictions. These RFA applicants must demonstrate that the proposed project services a
disadvantaged community.

B12: Are the terms of disadvantage community and affordability criteria interchangeable as
used in the RFA or do you expect them to have two different sets of criteria for water systems
to meet?

Affordability criteria are fundamental to the state's definition of a disadvantaged community
under SDWA 1452(d). If a state designates a community as disadvantaged then it has already
taken into consideration the affordability of the community. Therefore, for the purposes of this
grant, the two terms can be considered interchangeable.

SDWA 1452(d) Assistance for disadvantaged communities states:

(3) "Disadvantaged community" defined

In this subsection, the term "disadvantaged community" means the service area of a
public water system that meets affordability criteria established after public review and
comment by the State in which the public water system is located.

NATIONAL PRIORITY AREA 1: Reduction of Lead Exposure in the Nation's Drinking Water
Systems through Infrastructure and Treatment Improvements

CI. Can eligible applicants use funding to replace privately owned portions of lead service
lines?

Yes. An eligible entity may use funding to replace privately-owned portions of lead service lines.

C2. Can eligible applicants use funding to perform partial lead service line replacements?

Partial lead service line replacement is not an eligible activity unless the replacement is a

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remnant of previous replacement efforts. An eligible entity must ensure that no section of lead
service line remains in place at the completion of the replacement.

C3. Are projects eligible that replace lead lines if the State requires a Water System to replace
them regardless of lead action level values?

Applicants should also refer to Section V.A. Application Review Information indicating "All
eligible applications, based on the Section III threshold eligibility review, will be evaluated based
on the evaluation criteria and weights below (100 total point scale). Points will be awarded
based on how well and thoroughly each criterion and/or sub-criterion is addressed in the
application package."

Applicants should refer to the following sections under Section V.A. regarding the lead
infrastructure projects submitted as part of the application for scoring:

Section V.A.l.ii, states, "The extent and quality to which the applicant describes a known lead
issue in the disadvantaged community. (6 points)"

Section V.A.l.v. states, "The degree to which the proposed project support environmental
justice by prioritizing lead reduction projects at drinking water systems with at least one lead
action level exceedance(s) within the last three years, in schools with at least 50% of the
children receiving free and reduced lunch, in Head Start facilities, and/or in areas with
additional environmental health burdens (e.g., areas with older buildings likely to have lead-
based paint). (4 points)"

NATIONAL PRIORITY AREA 2: Reducing Children's Exposure to Lead in Drinking Water in
Schools and Child Care Facilities

Dl. Can this grant be used to support remediation following testing conducted under

the Lead Testing in School and Child Care Program Drinking Water Grant Program?

Yes. The Lead Testing in School and Child Care Program Drinking Water Grant creates a
voluntary program to assist states with testing for lead in drinking water at schools and child
care programs using the EPA's 3Ts for Reducing Lead in Drinking Water in Schools and Child
Care Facilities guidance or applicable state regulations or guidance regarding reducing lead in
drinking water in schools and child care programs that are not less stringent.

Under National Priority Area 2, the EPA is soliciting applications for projects in disadvantaged
communities that will reduce children's exposure to lead in schools and child care facilities
through removal and/or replacement of lead-containing drinking water fixtures, fountains,
outlets, and plumbing materials.

Applicants should describe the known lead issue in the disadvantaged communities' schools
and/or childcare facilities by describing for example: drinking water fixtures, fountains, outlets
and/or plumbing that need to be removed or replaced. The description may include prior use of
the 3Ts, or applicable state regulations or guidance that are not less stringent, for identification

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and prioritization of drinking water fixtures, fountains, outlets and/or plumbing that need to be
removed or replaced. See National Priority Area Two (Section I.B in the RFA) for more
information.

D2. What is the remediation trigger level for lead drinking water in schools and child care
facilities?

There is no recommended remediation trigger level in the EPA's 3T's (Training, Testing, and
Taking Action) toolkit. The EPA encourages schools to prioritize remediation efforts based on
the highest lead sample results and to use the steps in the 3T's toolkit to pinpoint potential lead
sources to reduce their lead levels.

All 50 states and the District of Columbia are participating in the EPA's Lead Testing in School
and Child Care Program Drinking Water grant. In establishing and conducting programs for lead
in drinking water in schools, states have the discretion, but are not required, to identify
remediation levels for their program. Program contacts are available at:
[https://www.epa.gov/dwcapacitv/wiin-2107-lead-testing-school-and-child-care-program-
drinking-water-state-grant-programl. Schools and child care facilities also are encouraged to
check with state and local health department as they may have guidance or requirements.

D3. Can grant funding be used to support remediation in private schools or child care
facilities?

For the purposes of this RFA, a child care facility is a Head Start program or an Early Head Start
program, a state licensed or regulated child care program, a state pre-kindergarten program, or
a program operated by a local educational agency serving children from birth through age six.

For the purposes of this RFA, a school is a nonprofit institutional day or residential school,
including a public charter school, that provides elementary or secondary education, as
determined under state law, up through grade twelve. Additionally, for the purposes of this
RFA, the definition of a school includes a school or community college that is controlled by an
Indian tribe, band, or nation, including any Alaska Native village, which is recognized as eligible
for special programs and services provided by the United States to Indians because of their
status as Indians. Facilities administered by the Bureau of Indian Affairs are not included in this
definition for the purposes of this announcement.

D4. What types of supporting documentation to demonstrate project readiness to proceed
can be provided that is not included in the Project Narrative page limitation?

Section I.C. Expeditious Project Readiness to Proceed in the RFA states, "Supporting
documentation demonstrating this readiness to proceed, such as bid documents, construction
schedules, easements, and any legal agreements to access private property to complete the
project, may be submitted as optional attachments, as referenced in Section IV of the
solicitation. These documents are not subject to the 25-page limitation under the Project
Narrative.

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Section IV.D.2. Project Narrative states Additional pages beyond the 25-page limit will not be
considered. The following documents may be included as supporting materials and do not
count towards the 25 page limitation. These include, as mentioned in Section D.l, parts f.
through i (f. Biographical Sketches, g. Negotiated Indirect Rate Cost Agreement, h. Supporting
documentation demonstrating readiness to proceed, and i. Supporting documentation
describing the known lead issue). Additionally, reduced cost share/waiver request letter, full
resumes and QA/QC documentation are not included within the page limitation."

D5. The RFA indicates "no technical assistance projects are eligible". Remediation work with
schools and childcare facilitates often require some form of planning, training and technical
assistance as part of the implementation process. Are these activities eligible to ensure
successful program implementation to reduce lead in schools and childcare facilities or are
these activities not allowable?

Section I .A, Program Objectives, states "The EPA expects that successful applications will
demonstrate that projects are ready to proceed expeditiously upon award. All applications
must be for lead reduction projects that support the goals and objectives identified below.
Planning, training, and technical assistance projects are not eligible for funding under this
announcement."

Section I.C, Expeditious Project Readiness to Proceed states, "Applications for projects under
both of the National Priority Areas described above must demonstrate the applicant's ability
and readiness to proceed expeditiously upon receiving an award. Applicants must describe the
plan and approach to proceed expeditiously to implement the project upon award of funding.
Applicants should describe past and current practices being implemented to reduce exposure of
lead in drinking water (such as public education and outreach, existing corrosion control
treatment, or the use of control measures to reduce exposure from fountains or fixtures where
elevated lead levels have been detected in schools or child care facilities). Applicants should
include a description of the completed project planning and design phases. Applications must
demonstrate that all required permits and approvals from the appropriate regulatory authority
(such as the primacy agency, municipality, or school board) have been obtained.

Supporting documentation demonstrating this readiness to proceed, such as bid documents,
construction schedules, easements, and any legal agreements to access private property to
complete the project, may be submitted as optional attachments, as referenced in Section IV of
the solicitation. Please note the "Expeditious Project Readiness to Proceed" evaluation criteria
in Section V.

Section V.A, Selection Criteria, states, Expeditious Project Readiness to Proceed:

Under this criterion applicants will be evaluated based on their ability, plan, and approach to
proceeding expeditiously to implement the project upon award (see Section I.C of this
announcement) taking into account the following factors.

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i. The extent and quality to which the application describes past and current practices being
implemented to reduce exposure lead in drinking water. (5 points)

ii. The extent and quality to which the applicant demonstrates completion of planning and
design, and securement of necessary approvals to proceed expeditiously. (10 points)

Section I.B, National Priority Area 2 states, "The projects are expected to result in reduction of
lead in drinking water in schools and/or childcare facilities in disadvantaged communities.
Examples of eligible drinking water lead reduction activities to support this National Priority
Area may include, but are not limited to, the following. The projects are expected to result in
reduction of lead in drinking water in schools and/or childcare facilities in disadvantaged
communities. Examples of eligible drinking water lead reduction activities to support this
National Priority Area may include, but are not limited to, the following.

1. Removing or replacing drinking water fixtures, fountains, or outlets demonstrated to be
sources of lead in schools and/or child care facilities drinking water.

2. Replacing plumbing materials determined to be sources of lead in schools and/or child
care facilities drinking water.

3. Conducting follow-up monitoring, public education, and outreach to ensure the long-
term performance of the remediation.

The EPA also encourages applicants to propose other types of activities the objectives of this
National Priority Area to meet the objective of addressing the reduction of lead exposure."

D6. What is the expectation around the requirements for Expeditious Project Readiness to
Proceed--can we describe that we have template for these things and what our process
would be without having the concrete example for each school?

Please refer to Section C. Expeditious Project Readiness to Proceed, which states "Applications
for projects under both of the National Priority Areas described above must demonstrate the
applicant's ability and readiness to proceed expeditiously upon receiving an award. Applicants
must describe the plan and approach to proceed expeditiously to implement the project upon
award of funding. Applicants should describe past and current practices being implemented to
reduce exposure of lead in drinking water (such as public education and outreach, existing
corrosion control treatment, or the use of control measures to reduce exposure from fountains
or fixtures where elevated lead levels have been detected in schools or child care facilities).
Applicants should include a description of the completed project planning and design phases.
Applications must demonstrate that all required permits and approvals from the appropriate
regulatory authority (such as the primacy agency, municipality, or school board) have been
obtained.

Supporting documentation demonstrating this readiness to proceed, such as bid documents,
construction schedules, easements, and any legal agreements to access private property to
complete the project, may be submitted as optional attachments, as referenced in Section IV of
the solicitation. Please note the Expeditions Project Readiness to Proceed evaluation criteria in
Section V."

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In Section V, this information is included in Criteria #2. Expeditious Project Readiness to
Proceed.

Selection Criteria 2) Expeditious Project Readiness to Proceed

"Under this criterion applicants will be evaluated based on their ability, plan, and approach to
proceeding expeditiously to implement the project upon award (see Section I.C of this
announcement) taking into account the following factors.

i. The extent and quality to which the application describes past and current practices being
implemented to reduce exposure lead in drinking water.

ii. The extent and quality to which the applicant demonstrates completion of planning and
design, and securement of necessary approvals to proceed expeditiously."

D7. Do specific schools, school districts, and childcare facilities have to be identified at the
time of proposal submittal, or is listing the state, county, and/or disadvantaged communities
with known lead challenges and DAC status, acceptable?

Section V.A. Selection Criteria include, but are not limited to, the following,

1. "National Priority Area Under this criterion the applicant will be evaluated based on their
ability and approach for effectively addressing the National Priority Area that is the subject of
their application. In conducting this evaluation, the following factors will be evaluated:

/'. The extent and quality of the overall approach to addressing the National Priority Area that is
the subject of the application.

ii. The extent and quality to which the applicant describes a known lead issue in the
disadvantaged community.

Hi. The extent and quality to which the application demonstrates plans to provide public
education, conduct outreach, and conduct post-implementation monitoring.

iv. The extent and quality to which the application demonstrates plans to maintain lead
reduction after project completion.

v. The degree to which the proposed project benefits drinking water systems who had at least
one lead action level exceedance within the last three years, or in schools/childcare programs
with at least 50% of the children receiving free and reduced lunch, in Head Start facilities,
and/or in areas with additional environmental health burdens (e.g., areas with older buildings
likely to have lead-based paint), and/or for purposes of the Justice40 Initiative delivers at least
40 percent of the benefits from the project to disadvantaged communities.

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2. Expeditious Project Readiness to Proceed, Under this criterion applicants will be evaluated
based on their ability, plan, and approach to proceeding expeditiously to implement the project
upon award (see Section I. C of this announcement) taking into account the following factors.

/'. The extent and quality to which the application describes past and current practices being
implemented to reduce lead exposure in drinking water.

The extent and quality to which the applicant demonstrates completion of planning and
design, and securement of necessary approvals to proceed expeditiously.

D8. Can a state apply for the grant to remediate disadvantaged schools that have been
determined to have high lead levels, which are unknown until the testing conducted under
the Voluntary Lead Testing in Schools program reveals which schools have remediation
needs?

Please refer to Section LB. National Priority Areas:

National Priority Area Two: Reducing Children's Exposure to Lead in Drinking Water in
Schools and Child Care Facilities

Applicants should note criterion 2) Expeditious Project Readiness to Proceed in Section V. A.
Selection Criteria: "Under this criterion applicants will be evaluated based on their ability, plan,
and approach to proceeding expeditiously to implement the project upon award (see Section I.C
of the RFA) taking into account the following factors.

i. The extent and quality to which the application describes past and current practices being
implemented to reduce exposure lead in drinking water.

The extent and quality to which the applicant demonstrates completion of planning and
design, and securement of necessary approvals to proceed expeditiously."

Applicants should note Section IV.D.2. Projective Narrative subsection "4. Milestone
Schedule: Provide a projected milestone schedule for the proposed project period (up to four
years). The milestone schedule should provide a breakout of the project into phases with
associated tasks and a timeframe for completion of tasks, and an approach for ensuring that
awarded funds will be expended in a timely and efficient manner. The project start date will
follow award acceptance by the successful applicant."

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D9. Is initial sampling to discover and/or confirm a lead exceedance exists an eligible project
activity/cost under NPA 2 in WIIN Act Section 2105 or if this only applies to post-
implementation monitoring?

Please refer to Section LB. National Priority Area Two: Reducing Children's Exposure to Lead
in Drinking Water in Schools and Child Care Facilities for eligible projects/activities The RFA
states, "The projects are expected to result in reduction of lead in drinking water in schools
and/or child care facilities in disadvantaged communities. Examples of eligible drinking water
lead reduction activities to support this National Priority Area may include, but are not limited
to, the following.

• Removing or replacing drinking water fixtures, fountains, or outlets demonstrated to be
sources of lead in schools and/or child care facilities drinking water.

• Replacing plumbing materials determined to be sources of lead in schools and/or child
care facilities drinking water.

• Conducting follow-up monitoring, public education, and outreach to ensure the long-
term performance of the remediation. "

Applicants should also refer to Section I.C Expeditious Project Readiness to Proceed states,
"Applications for projects under both of the National Priority Areas described above must
demonstrate the applicant's ability and readiness to proceed expeditiously upon receiving an
award. Applicants must describe the plan and approach to proceed expeditiously to implement
the project upon award of funding. Applicants should describe past and current practices being
implemented to reduce exposure of lead in drinking water (such as public education and
outreach, existing corrosion control treatment, or the use of control measures to reduce
exposure from fountains or fixtures where elevated lead levels have been detected in schools or
child care facilities). Applicants should include a description of the completed project planning
and design phases. Applications must demonstrate that all required permits and approvals from
the appropriate regulatory authority (such as the primacy agency, municipality, or school board)
have been obtained.

D10. The RFA references "drinking water fountains" as a point source that may be addressed
under the grant. Are these fountains inclusive of those located on the exterior of the building
(such as around playgrounds and ball fields)?

Please refer to Section LB. National Priority Areas.

Under this National Priority Area, the EPA is soliciting applications for projects in disadvantaged
communities that will reduce children's exposure to lead in schools and child care facilities

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through removal and/or replacement of lead-containing drinking water fixtures, fountains,
outlets, and plumbing materials."

"Applicants should describe the known lead issue in the disadvantaged communities' schools
and/or childcare facilities by describing for example: drinking water fixtures, fountains, outlets
and/or plumbing that need to be removed or replaced. The description may include prior use of
the 3Ts, or applicable state regulations or guidance that are not less stringent, for identification
and prioritization of drinking water fixtures, fountains, outlets and/or plumbing that need to be
removed or replaced."

Dll. Under national priority area 2, do lead service lines qualify as plumbing materials that
are determined to be sources of lead? Can applicants use funding under priority area 2 to
replace lead service lines?

Applications are divided under 2 National Priority Areas under Section I.B. of the RFA. There
is National Priority Area One: Reduction of Lead Exposure in the Nation's Drinking Water
Systems through Infrastructure and Treatment Improvements. The RFA states "Under this
National Priority Area, the EPA is soliciting applications to reduce lead in drinking water in
disadvantaged communities through infrastructure and/or treatment projects, such as lead
service line replacement and corrosion control practices. For the purposes of this
announcement "drinking water system" means a community water system, a nontransient
noncommunity water system, and a water system located in an area governed by an Indian
Tribe. National Priority Area Two: Reducing Children's Exposure to Lead in Drinking Water in
Schools and Child Care Facilities. The RFA states, "Under this National Priority Area, the EPA is
soliciting applications for projects in disadvantaged communities that will reduce children's
exposure to lead in schools and child care facilities through removal and/or replacement of
lead-containing drinking water fixtures, fountains, outlets, and plumbing materials."

Applicants should note Section III.C. Threshold Eligibility Criteria, where the RFA states "These
are requirements that if not met by the time of application submission will result in the
elimination of the application from consideration from funding. Only applications that meet all
of these criteria will be evaluated against the ranking factors in Section V of this announcement.
This includes:

"2. Applications must address one, and only one, of the two National Priority Areas listed in
Section I.B. Eligible organizations may submit more than one application under this
competition as long as each one is separately submitted and addresses only one National
Priority Area. Applications that address more than one National Priority Area in a single
application will not be reviewed."

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GENERAL PROJECT RELATED QUESTIONS

Fl. What is the project length of time?

It is anticipated that a total of three to seven assistance agreements, each with a project period
of up to four years, will be awarded under this announcement.

F2. We are applying for the Reduction of Lead Exposure in the Nation's Drinking Water
Systems through Infrastructure and Treatment Improvements grant. We need assistance
determining whether the Quality Assurance/Quality Control is required for the proposed
project. What documents do you need to determine this?

Please refer to Section II, Part A. Project Narrative, Subsection C. Workplan, #8 Reduced Cost
Share/Match Waiver Request Letter and Quality Assurance/Quality Control, part B of the RFA
(page 28), which explains what an application project narrative should describe as Quality
Assurance/Quality Control (QA/QC) should they plan to collect or use environmental data or
information. The application should explain how the applicant plans to comply with the Quality
Assurance/Quality Control requirements. Additionally, information can be found on the
Agency's Enterprise Quality Management Division (EQMD) webpage that includes documents to
assist in the development and implementation of a suitable Quality System for both EPA and
non-EPA organizations. The documents include FAQs, and may provide guidance. They can be
found on the following website: https://www.epa.gov/quality.

F3. For the start date of the project, can I pick a date in the past? Or do I need to make the
start date the date of when I make the application?

No. As stated on page 33 of the RFA, SECTION VI. Award Administrative Information, Part C.
Administrative & National Policy Requirements, the general award and administration process
for assistance agreements to be funded under this announcement are governed by regulations
at 2 CFR 200.

2 CFR §200.458 Pre-award costs states "Pre-award costs are those incurred prior to the
effective date of the Federal award directly pursuant to the negotiation and in anticipation of
the Federal award where such costs are necessary for efficient and timely performance of the
scope of work. Such costs are allowable only to the extent that they would have been allowable
if incurred after the date of the Federal award and only with the written approval of the Federal
awarding agency."

F4. Is a water system's comprehensive project subject to grant reporting requirements if the
grant was sought for and used to complete a phase of the project versus the whole project?

Grant reporting requirements apply to the federal funds and associated non-federal cost-
share/match for awards made under this announcement. Please refer to Section VI.D.
Reporting in the RFA, which states, "In general, recipients are responsible for managing the
day-to-day operations and activities supported by the assistance funding, to assure compliance
with applicable federal requirements, and for ensuring that established milestones and
performance goals are being achieved.... Recipients will be required to report direct and indirect
environmental results from the work accomplished through the award."

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Section III.B. Cost Sharing or Matching, states "Cost-share/match must be used for eligible and
allowable project costs. Cost-share/matching funds are considered grant funds and are
included in the total award amount and should be used for the reasonable and necessary
expenses of carrying out the workplan. All grant funds are subject to federal audit. Any
restrictions on the use of grant funds also apply to the use of the cost-share/match."

F5. Is a QA/QC required for the proposed project? Which QA/QC requirements apply? The
project is for lead service line replacement and we are designing the project with post-
implementation monitoring as described in the RFA. What are the next steps for determining
what QA/QC requirements apply.

Please refer to the response in the FAQ under F2. Additionally, the EPA Office of Environmental
Information's Enterprise Quality Management Division (EQMD) oversees implementation of the
EPA Quality Program which provides requirements for conducting quality management
activities for environmental data collection and environmental technology programs performed
by or for the Agency. The EQMD welcomes questions and suggestions. More information can
be found at https://www.epa.gov/aualitv/forms/contact-us-about-managing-qualitv-
environmental-information

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