Publication No. 190P24002 RESPONSE TO COMMENTS FY 2025-2026 NATIONAL PROGRAM GUIDANCE OFFICE OF CONGRESSIONAL AND INTERGOVERNMENTAL RELATIONS Comment Commenter(s) Location in Draft Guidance National Program Offices Response Action Taken in Final Guidance States recommend that language be added in the NPG to the "Performance Partnership Agreements Section" that details the bene fits/advantages related to the development and utilization of aPPA. ECOS Section II. A. p.5 EPA concurs on the importance of messaging the benefits of PPAs. Continuing the joint governance and coordination of mutually defined priorities is the cornerstone of the National Environmental Performance Partnership System. Language added in Section II. A. p.5, including link to The Best Practices Guide for Performance Partnership Grants with States. A clearly defined workplan negotiation schedule or timetable would be beneficial and efficient for both state partners and EPA and the process would be improved if negotiations culminated at the application deadline date. ECOS General Comment EPA concurs. Regions adhere to workplan schedules with individual PPG recipients and continually adjust throughout the year to accommodate application deadlines for workplan approval. External factors such as administration changes, delays in appropriated funding and other ancillary management changes contribute to maintaining flexibility in workplan timetables. EPA will continue seeking innovative ways to improve and streamline the workplan development process, including No Action taken 1 | P a g e ------- Publication No. 190P24002 Comment Commenter(s) Location in Draft Guidance National Program Offices Response Action Taken in Final Guidance encouraging use of electronic collaborative forums to develop and negotiate grant workplans. Allow advance process for the workplan development between the technical leaders. This allows both teams to explore topics prior to the submission of the workplan which makes the formal review and approval process more efficient. ECOS Section IV. B. p. 12 EPA concurs with the importance of building in sufficient time for technical consultation during workplan development Language included on p. 12 to underscore this suggestion. Supply chain issues and resource constraints in the private sector can hinder or delay timelines for projects using this funding. Providing expedited waivers from federal requirements such as BABA can help states deploy and target federal funding quicker and achieve the goals of these programs ECOS General Comment EPA is committed to implementing Build America, Buy America (BABA) requirements effectively and efficiently across all programs that fund infrastructure. Although EPA recognizes that there are concerns regarding some current supply chains, implementing BABA successfully will build more resilient supply chains over time and provide long-term investments to broaden the manufacturing base for critical products here in the United States. In limited circumstances, EPA recognizes that it may be appropriate to approve a recipient's request to waive certain BABA requirements, such when a No Action taken 2 | P a g e ------- Publication No. 190P24002 Comment Commenter(s) Location in Draft Guidance National Program Offices Response Action Taken in Final Guidance domestic product is not available or if the requirements substantially increase project costs. EPA reviews these requests expeditiously with our partners in the Made-in-America Office (MIAO). EPA has also approved some general waivers, such as the De Minimis Waiver, that are intended to ease administrative burden associated with implementing BABA requirements. Because federal requirements such as BABA has the potential to affect infrastructure project delivery timelines and budgets, EPA encourages funding recipients to take these requirements into consideration as early as possible, including during the application and workplan development stages. State agencies need maximum flexibility and efficiency from U.S. EPA in the workplanning process to ensure that state priorities are addressed in a timely manner. As emerging contaminants and cross-media initiatives continue to evolve, states need flexibility to deploy funding and resources toward the ECOS General Comment EPA concurs with the importance of maximum flexibility and efficiency. The Agency continually promotes and supports creative approaches to applying innovative and flexible approaches throughout the duration of a Performance Partnership Grant. Please reference the following documents on p.7 of the OCIR NPG, No Action taken 3 | P a g e ------- Publication No. 190P24002 Comment Commenter(s) Location in Draft Guidance National Program Offices Response Action Taken in Final Guidance next thing while ensuring federal dollars are allocated and expended in a timely manner. which underscore this support: • The Best Practices Guide for PPGs and the States • The Best Practices Guide for PPGs with Tribes • E COS's Field Guide to Flexibility and Results The importance of providing accommodation for the EMF disabled for medical programs and services is two-fold. First, exposure to RF / EMR / EMF / MW radiation in medical facilities can be life-threatening. Second, a "patient's vital signs or test results may vary dependent on EMF/EMR exposures at a specific location and at a specific moment (electrosmog can affect the autonomic nervous system, the blood, the heart and even blood sugar levels in some sensitive diabetics)... this can lead to misdiagnosis, over-treatment, under-treatment, inappropriate medications or dosages ..." Further reasons and a detailed list of recommendations for accommodation are provided by the ElectroSensitive Society - see Electrosensitive Society The National Call for Safe Technology Sec IIA. The National Environmental Performance Partnership System p. 4 The EPA has embedded many of the suggested competencies into the draft "Achieving Health and Environmental Protection Through EPA's Meaningful Involvement Policy", which guides the EPA staff to provide meaningful public involvement in all its programs and regions. Public comments on the draft policy closed on January 16, 2024. The EPA is considering the comments provided by the public in developing the final policy. Once the policy is finalized, there are plans to develop and provide training to support policy implementation across the EPA. The public review draft of the policy is located on OEJECR's website: https://www.epa.gov/system/files /documents/202 3- 12/final_meaningful-involvement- policy_eams_l 1.7.2023_508.pdf. No Action taken 4 | P a g e ------- Publication No. 190P24002 Comment Commenter(s) Location in Draft Guidance National Program Offices Response Action Taken in Final Guidance Other recommendations within your comment will be reviewed and considered across the EPA. Wired connections, such as fiber and cable, to the premises provide the best capacity for remote learning for children and students, particularly those who are already EMF disabled, and more reliable access to medical and other services for the elderly and disabled during emergencies or severe weather when wireless service is more likely to be interrupted. Wired connections will also prevent the exclusion of the EMF disabled who cannot be near RF radiation emitted from mobile devices and equipment The National Call for Safe Technology Sec IIA. The National Environmental Performance Partnership System p. 4 The EPA has embedded many of the suggested competencies into the draft "Achieving Health and Environmental Protection Through EPA's Meaningful Involvement Policy", which guides the EPA staff to provide meaningful public involvement in all its programs and regions. Public comments on the draft policy closed on January 16, 2024. The EPA is considering the comments provided by the public in developing the final policy. Once the policy is finalized, there are plans to develop and provide training to support policy implementation across the EPA. The public review draft of the policy is located on OEJECR's website: https://www.epa.gov/system/files /documents/202 3- 12 /final_me aningful- involve me nt- policy_eams_l 1.7.2023_508.pdf. Other recommendations within your comment will be reviewed and considered across the EPA. No Action taken 5 | P a g e ------- |