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Special Appropriation Projects

Special Appropriation Projects (SAPs), also referred to as Earmarks, STAG, or Line Items, are rather unique sources of funding.Congress earmarks discrete amounts of funding to specific organizations for a defined purpose.

If you are with an organization that has been provided with a SAP grant or is responsible for the oversight of a SAP project, the following information should be helpful for you. You will need to obtain the necessary forms to apply for the grant, manage the grant after it is awarded, and close the grant when it is completed. The following information includes common questions, pitfalls, how to access the funds, etc.

The information provided is general in nature. Please refer to the annual guidelines for detailed requirements or contact the appropriate project officer for additional assistance.

STAG Questions & Answers

  1. How much of the earmark is available for award?
  2. What kind of projects may be included?
  3. What is the non-federal match requirement?
  4. What must I send to EPA in order to gain access to the funds?
  5. May I be reimbursed for pre-award costs?
  6. How do I get a reduction or waiver of the local match?
  7. What are the Project Guidelines and Regulatory Requirements and Restrictions?
  8. Who should I submit the grant application package to?
  9. How do I access the funds after the grant has been awarded?
  10. What should I do after I get the grant award document in the mail?
  11. What if I need to make changes during the project?
  12. Helpful Links
  13. Who should I call with questions?

1. How much of the earmark is available for award?

Since FY 2001, EPA has been taking 3% off the top of the earmark grants for project management. The funds may be used to fund the State, Corps of Engineer or for contractor support for the management and oversight of the special projects. This means that the set-aside monies cannot be used to pay for EPA staff or travel expenses. EPA Region 5 utilizes a portion of the 3% set-aside for contractor support in order to conduct on-site project inspections for those projects under EPA Region 5 oversight. Projects under State oversight will be inspected by the appropriate State agency. (see Post Award Management).

Additionally, the government’s budget sometimes gets cut across the board and a small rescission is often taken from all our funding, including earmarks. It varies from year to year and will be specified in the guidelines.

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2. What kind of projects may be included?

Each earmark has corresponding language in the appropriations bill. The scope of work must fall within that language. For instance, if the language in the bill specifies wastewater infrastructure improvements the grant couldn’t fund the upgrading of drinking water mains.

It is possible to get a language/recipient change. You must work with your Congressional sponsor on any language/recipient changes needed.

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3. What is the non-federal cost share requirement?

There is a requirement for a 45% non-federal cost share. This means that you must pay at least 45% of the total project cost, not 45% of the federal amount being provided. So if your total project cost is $500,000, your minimum share would be at least $225,000.

The recipient share of the grant may not come from another federal funding source, unless that source is specifically allowed to match other Federal funds. There are a number of Federal sources which can be used as local match:

State Revolving Loan Funds (SRF) may also be used. You must check with your state’s State Revolving Fund contact to determine whether this is an option for your particular project.

Also, you are not required to include your entire matching grant or loan on the EPA grant application. For instance, if you have a rural development grant for $2 million and you only need $300,000 in local cost share for the earmark grant, you don’t have to include the entire $2 million. You can include only what is necessary.

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4. What must I send to EPA Region 5 in order to gain access to the funds?

Although these funds have been earmarked for your organization, youstill have to go through the grant application process in order to gain access to the funds.

  1. Application Forms and Certifications
    1. Common Pitfalls on the Standard Form 424
    2. Completing the Standard Form 424c
    3. Certifications
  2. Project Workplan
  3. Documentation of Procurement
  4. Environmental Information Document (PDF) (19pp, 118K) (if the project includes construction)
  5. Quality Assurance Project Plan (QAPP) (if applicable)
  6. Indirect cost rate agreement (if applicable)

The descriptions and instructions for these elements, as well as additional information, are provided below.

4.a. Application Forms and Certifications

Although the final application must be signed, we strongly encourage your initial submittal of the grant forms be unsigned. Quite often changes to the application are necessary and providing a draft application prevents the need for repeated signing by your organization’s signature authority. However, please sign the Environmental Information Document (if used) for the initial submittal.

  1. Common Pitfalls on the Standard Form 424
  2. Completing the Standard Form 424c
  3. Certifications
i. Common Pitfalls on the Standard Form 424

Organizational DUNS Number

We often receive applications with block 5 blank. We cannot make a grant award without an organizational DUNS number (PDF, 23KB, 2 pages).

Also, in order for us to be able to communicate with you when necessary, provide all the contact information requested in this block (phone, fax, email, etc.)

CFDA Number

The appropriate CFDA number is 66.202 and the title is “Congressionally Mandated Projects."


Estimated Funding

When filling out this block, bear in mind that you have to draw down the funding at the same proportion (Federal to Total Project Cost) that the funds are awarded. For example, if the funds are awarded at the maximum Federal share level of 55%, then for every $100 of invoices you have, you may draw down only $55 of EPA funds.

Therefore, if you are doing a multi-million dollar project and we are only contributing a small portion of it, consider funding just a part of that project with this grant. Otherwise you will end up with a grant with a Federal share of only 5%, for example, and it will take quite some time for you to get all the money.

For example, if you are upgrading your wastewater treatment plant at a cost of $4 million; however the Federal amount for your STAG grant is only $500,000 (minimum project cost of $909,091). If you were to include the entire project on the grant document, the Federal/cost share ratio would be only 13% Federal to 87% match. That is only $13 out of every $100. Another option would be choosing a portion of the project that is close to the minimum project cost. Let’s say the cost for replacing the pumps is $1.1 million. That would make the ratio 45% Federal and 55% cost share, which is reasonable.

Clearinghouse

We often receive applications with block 16 left blank. This block is referring to the clearinghouse process. Each state has a State Point of Contact (SPOC) you must submit the grant application to when you submit it to EPA. Indicate the date you submitted it to the SPOC on the 424. The SPOCs in Region 5 are:

Federal Debt

Don’t forget to answer this question, too! We often receive applications with block 17 left blank.

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4.a. Application Forms and Certifications (cont.)

ii. Completing the Standard Form 424c

The SF 424c is the budget page we use for the special appropriation projects. It breaks the costs out by a number of categories. We ask that you provide the total.

The budget totals on this sheet should include all the relevant funding, federal and cost share, not just federal.

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4.a. Application Forms and Certifications (cont.)

iii. Certifications

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4.b. Project Workplan

The project workplan is where you tell us exactly what you are going to do with the funding.

Your Workplan Should Include the Following
  • Project Title: Please be consistent with the grant application.
  • Applicant Name: Please be consistent with the grant application.
  • Project Description and Activities:
    • Describe the overall project. Is it multi-phased? What are those phases and which is being funded with this grant? The project must be consistent with the earmark language in the appropriations bill.
    • Specify which activities (planning, design, and/or construction) are to be completed with EPA & local match funds.
    • Are permits required for this project? Which ones? Have they been applied for?
    • If this is a combined sewer overflow project, is it in conformance with EPA’s Combined Sewer Overflow Control Policy?
    • Has the project started? If so, when and how much has been completed? If the project has already began, what are the costs you wish to have reimbursed? Include that information and documentation [i.e. invoices] with your workplan.
    • Include a map of construction activities.
    • Include a copy of the facilities plan.
  • Environmental Benefit: Describe the intended environmental and/or public health benefits to be achieved. Explain if the project is being implemented to comply with a compliance order.
  • Project Schedule: Provide target dates for the start and completion of planning, design and construction as well as any other key milestones during the project (such as bid dates, contract award, etc).
  • Project Budget: If multi-phased, what are the costs associated with each phase? Provide the costs both from EPA Region 5 and from match sources. What is/are the source(s) of the local match? Most importantly, has the project started? If so, what has been completed and what are the costs associated with those activities? Provide documentation [invoices, etc.] to justify those costs. If the pre-award costs are not approved prior to the award of the grant, those costs will not be eligible for reimbursement.

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4.c. Documentation of Procurement

Our regulations governing the procurement of services may impact what costs may be included on the EPA grant. All contract costs to be charged to the grant must have been procured according to EPA's procurement regulations. For state, local and tribal governments, those regulations can be found in 40 CFR Part 31 subpart 36. For universities, hospitals and non-profit entities, those regulations can be found in 40 CFR Part 30 subpart 40 Exit EPA.

We tend to run into problems with this when the planning and design of a project has already been completed and the contract was not procured according the regulations, (which would be with a request for qualifications for architectural and engineering work). It is important to review these costs carefully before including them in the budget.
If the contract(s) have advertised/procured prior to grant award, you will need to provide the announcement [Request for Qualifications, Request for Proposals, Bid Package], proof of advertising [copies of ads, etc] and a copy of the final contract. If the contract(s) have not yet been advertised/procured, the grant award document will contain and term and condition requiring this documentation within a certain amount of time after the procurement has been conducted.

If the contract(s) have advertised/procured prior to grant award, you will need to provide the announcement [Request for Qualifications, Request for Proposals, Bid Package], proof of advertising [copies of ads, etc] and a copy of the final contract. If the contract(s) have not yet been advertised/procured, the grant award document will contain and term and condition requiring this documentation within a certain amount of time after the procurement has been conducted.

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4.d. Environmental Information Document (PDF) (19pp, 118K)

The NationalEnvironmental Policy Act (NEPA) Exit EPA requires Federal agencies to assess the potential impact on the environment of the projects they fund.This includes assessing requirements relating to various Federal laws,including the Endangered Species Act, the National Historic PreservationAct etc. Federal laws that apply across Federal agencies are referredto as cross-cutters (see guidelines).

EPA Region 5 uses the completed Environmental Information Document as the basis for its NEPA review. The NEPA review generally concludes with either a Finding of No Significant Impact (FONSI) or a Categorical Exclusion determination.

We cannot award funds for work beyond the preliminary design stage until our environmental review is completed. If you need funds in order to get your project started before the environmental review is completed, you can break your project into phases as follows:

Should you choose this approach, you will still need to submit the application forms, certifications and the project workplan for the initial grant award. . If you would like additional guidance on the environmental review, we suggest you review the Environmental Review Guide for Special Appropriation Grants (PDF) (171 pp, 3.5MB).

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4.e. Quality Assurance Project Plan (QAPP) (if applicable)

Any project funded under an EPA grant which calls for the collection of data requires a QAPP. The purpose of the QAPP is to develop the data quality objectives and describe how the data will be used in order to ensure that the data collected is useful and is collected according to approved methods.

4.f. Indirect cost rate agreement (if applicable)

If you will be including indirect cost in the budget, you will need to include a copy of your organization’s indirect cost rate agreement with your application.

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5. May I be reimbursed for pre-award costs?

According the guidelines, if necessary, you can incur costs prior to the award of the grant. There are time limits on that. The costs cannot have been incurred prior to the beginning of the federal fiscal year in which those funds were appropriated. For example, if your funds were earmarked in the FY 2010 appropriations bill, then only the construction costs incurred after October 1, 2009 are eligible for funding [The Federal Fiscal Year (FY) runs from October 1 to September 30]. In certain other situations, Congressional language could require the grant to include pre-award costs in excess of those that could be approved in the circumstances described above.

If you have incurred pre-award costs and wish to include them in the grant, your workplan must specifically identify how much work has already been completed and distinguish between prior costs and estimated future costs. You will also need to submit supporting documentation of what those costs were, how much they were, when they were incurred and the latest inspection report available, as well as relevant contract materials.

Remember that pre-award costs are only eligible for reimbursement if the contracts were procured according to EPA regulations.

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6. How do I get a reduction or waiver of the local cost share?

Occasionally, there will be situations when organizations will be in fiscal emergency. When this occurs, there is potential for a reduction or waiver of the local cost share. The process for this is outlined in the guidelines. We utilize the March 1997 document entitled Combined Sewer Overflows: Guidance for Financial Capability Assessment and Schedule Development (PDF) (62pp, 2.3Mb). This document includes a process for measuring the financial impact of current and proposed wastewater treatment facilities and drinking water facilities on the users of those facilities, and establishes a procedure for assessing financial capability. The assessment process requires the calculation of a financial capability indicator. The Agency approves waivers in those cases where the financial capability indicator shows that the project would result in a high financial burden on the users of the facility.

Exceptions to the 45 percent cost sharerequirement must be approved by EPA Headquarters via a recommendation from the EPA Regional Office.

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7. What are the Project Guidelines and Regulatory Requirements and Restrictions?

The EPA Office of Water publishes annual guidelines for the special appropriation projects. Although EPA cannot award funds for a specific fiscal year until that year’s guidelines are final, an organization is encouraged to submit their application to EPA Region 5 to get the review process started prior to the guidelines being released.

  1. Special Appropriation Guidelines
  2. Cross-Cutter Authorities
  3. 40 CFR 30 (Regulations for Non-Profits)
  4. 40 CFR 31 (Regulations for state, local, and tribal governments)
  5. 40 CFR Part 6 Subparts A, B, C, and D (Regulations relating to NEPA)
  6. 40 CFR Part 25 (Regulations relating to public notification)
  7. OMB Circulars
  8. Purchasing Supplies, Equipment and Services Under the Grant
  9. MBE/WBE Utilization
  10. National Term on Suspension and Debarment

7.a. Special Appropriation Guidelines

  1. FY 03 Guidelines (PDF) (62pp, 9.7Mb)
  2. FY 04 Guidelines (PDF) (63pp, 6.6Mb)
  3. FY 05 Guidelines (PDF) (66pp, 2.1Mb)
  4. FY 06 Guidelines (PDF) (56pp, 4.0Mb)
  5. FY 08 Guidelines (PDF) (83pp, 4.0Mb)
  6. FY 09 Guidelines (PDF) (82pp, 4.21Mb)
  7. FY10 Guidelines (PDF) (52pp, 4.1Mb)

7.b. Cross-Cutter Authorities

Federal laws that apply across Federal agencies are referred to as cross-cutters. They are listed in the guidelines.


7.c. 40 CFR 30 : Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations

7.d. 40 CFR 31 : Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments

7.e. 40 CFR Part 6 Subparts A, B, C, and D : Procedures for Implementing the Requirements of the Council on Environmental Quality on the National Environmental Policy Act

7.f. 40 CFR Part 25 : Public Participation in Programs under the Resource Conservation and Recovery Act, the Safe Drinking Water Act, and the Clean Water Act

7.g. OMB Circulars

7.h. Purchasing Supplies, Equipment and Services Under the Grant

7.i. MBE/WBE Utilization

7.j. National Term on Suspension and Debarment

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8. Who should I submit the grant application package to?

You will need to provide your information to your project officer. At Region 5, the project officers are assigned by State:

The mailing address is:

State and Tribal Programs Branch
U.S. EPA Region 5 (WS-15J)
77 West Jackson Boulevard
Chicago, IL 60604-3590

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9. How do I access my funds after the grant has been awarded?

Access to grant funds are typically through either the Automated Standard Application for Payment (ASAP) system or the Automated Clearinghouse (ACH) system. Generally speaking, we will only use ASAP if you already have an active ASAP account. Most of the time, these grants use the ACH system.

Either way, in order to receive reimbursement, you will have to provide documentation of eligible costs incurred to the project officer for approval. Once approved, the funds will be transferred to your account. Payment requests must be timed to minimize the time between receipt and disbursement of EPA funds. It could take up to a week to receive the funds, so plan accordingly. You will not be sent a check upon award of your grant.

DO NOT DEPOSIT THESE FUNDS INTO AN INTEREST BEARING ACCOUNT.

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10. What should I do after I get the grant award document in the mail?

  1. Receiving the Award Document
  2. Post Award Management
    1. Semi-annual progress reports
    2. Administrative Reporting
    3. On-Site Inspections
  3. Grant Close-Out
    1. Final Project Report
    2. Project Completion Certification
    3. Final Inspection report (if applicable)
    4. Final Financial Status Report
    5. Final MBE/WBE
    6. Lobbying and Litigation Certificate
    7. Inventions Report

10.a. Receiving the Award Document

Our goal is to make grant awards within 60 days of receiving a complete application. Complete means the application is complete and signed; our technical contacts have reviewed and approved the workplan and a final NEPA determination has been made.

When the grant is awarded, you will receive a cover letter and two signed copies of the grant award. Review the award document carefully, including the terms and conditions. When your organization signs the award document, they are agreeing to everything in it. Note, there are two EPA contacts listed on the first page of the award. One is the project officer, whom you have been working with and is located in the Water Division. The other is the grant specialist who is located in the Resource Management Division. As you will notice under Post Award Management and Grant Close-Out, there are a few reporting forms you will be sending directly to this individual.

If everything is acceptable, sign both copies, keep one for your files and mail the other one to the address specified in the cover letter. Do not mail it to your project officer. Once the executed copy of the award document reaches the grant specialist at EPA, the grant specialist will note it in our grant system. Please note that you cannot get access to the grant funds until you have signed and returned the grant document.

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10.b. Post Award Management


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10.c. Grant Close-Out

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11. What if I need to make changes during the project?

11.a. No-cost time extensions

Sometimes the original project is delayed due to weather difficulties, etc. In these situations, we will do what is called a no-cost time extension. You need to provide a written request (email is fine) to your project officer indicating 1) you need an extension; 2) how long an extension you require; and 3) why the extension is necessary.

11.b. Budget amendments

Sometimes budgets change during the course of the project. Projects come in under or over cost. This can change the % federal share on the grant. As long as we aren’t paying more than 55%, this isn’t a problem; however, the % federal share needs to match what is on the award document. Therefore, when you become aware of a budget change significant enough change the percent ratio, you need to do a budget amendment. Provide your project officer with a revised budget page (SF 424c) and the justification for the amendment (again, email is fine).

Additionally, occasionally funds may need to be shifted between budget categories (from Architecture & Engineering to Construction, etc.). We can do this without a formal budget amendment until the shifts reach a cumulative total of 10% of the total project cost. For instance, if you move 5% of the funds one month a formal budget amendment will not be necessary. Ensure the change is well documented in the file. If however 2 months later you need to move another 7%, that totals 12% and at that time you will need to contact your project officer for a formal budget amendment.

11.c. Changes in the scope-of-work

Periodically, a project may change significantly enough that it requires a change in scope. At that point, contact your project officer to begin a renegotiation of the workplan.

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12. Helpful Links

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13. Who should I call with questions?

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