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USTfields Qs & As: Evaluation Criteria
Q1: Can a state use the evaluation criteria in the EPA proposal guidelines to rate the proposals the state receives?
A: It is up to the state's discretion how it evaluates any proposals it might receive.
Q2: Evaluation Criteria #1, Resource Use and Leveraging, accounts for 1/3 of the total potential points. What if you do not have a Brownfields site in your city? According to your evaluation criteria, would that city score lower?
A: EPA does have a preference for pilots in EPA Brownfields communities. This is because of the infrastructure that is already in place to assist in the implementation of the USTfields Pilot. However, everything depends on the proposals submitted in this competition. A state and partnering city not located in a Brownfields community that prepares a proposal demonstrating the existence of an excellent infrastructure and reuse plan in place and ready to support an USTfields Pilot might possibly rate high enough on this and other criteria to score well.
Q3: Can the USTfields Pilot funds be transferred to the partnering community if the State and EPA Regional office agree to do so?
A: Subagreements and contracts are permitted consistent with 40 CFR 31.35, 31.36 and 31.37. A recipient must have prior written approval to change its subawards from the original proposal (see 40 CFR 31.30(d)(4)).
Q4: What is the time frame for spending the USTfields Pilot funds?
A: Funds awarded in an USTfield Pilot are awarded from the LUST appropriation, which are "no year" funds. The recipient, however, must comply with EPA's regulations governing the period of availability of funds (40 CFR 31.23). A recipient should try and spend USTfield funds during the funding period (also known as "budget period") specified in the cooperative agreement. If a recipient needs to extend the funding period, it may do so with prior written approval from EPA, in accordance with 40 CFR 31.30(d)(2).
Q5: Does receipt of an USTfields Pilot award require a new Cooperative Agreement, or can we amend the old Cooperative Agreement?
A: That is up to your EPA Regional office.
Q6: Will EPA allow amendment to the USTfields Pilot Cooperative Agreement if, for instance, the state cannot follow through on the original pilot site?
A: A state and partnering local area would do well to include in their pilot proposal a list of eligible sites in the pilot where USTfields work could be done so that if the original site doesn't work out for some reason, the state and local area can move on to the next eligible site in the pilot.
Q7: Will the USTfields pilot program become a permanent activity for EPA's LUST program?
A: EPA certainly hopes the program will show positive results and continue, and it is currently proceeding on the assumption that it will do so.
Q8: Will sites with MTBE be given a higher preference? What if a state does not have an MTBE standard-will that be held against that state?
A: The evaluation criteria indicate that sites with "expected MTBE contamination will be addressed" in the proposal and that a preference will be given to "proposals that will assess the properties for MTBE contamination." Proposals fulfilling this criteria will be given higher points. However, USTfields Pilots are not restricted to MTBE contamination only. Therefore, lack of a state standard for MTBE is not determinative in and of itself as to whether a site is selected as a pilot.
Q9: Under Criteria #1, second bullet, it says "Preference will be given to pilots that target USTfields funds for the assessment and characterization of properties and that use other public/private funding and resources for site cleanup." We are encouraging our pilot communities to leverage the potential $100,000 USTfields grant with one of our $120,000 state brownfields grants. Our state's brownfields grant program only pays for the assessment and preparation of cleanup plans, not actual corrective action. We need the USTfields money to pay for cleanup (including tank removal) since no other funding mechanism exists for corrective action activities. We don't want to be penalized in the scoring process. Will the use of USTfields dollars for corrective action only jeopardize our pilot applications?
A: No. We would not characterize the use of USTfields dollars for corrective action as necessarily "jeopardizing" a pilot application. Everything depends upon the relative strength of the pilot proposals we receive. If we receive proposals that demonstrate the applicant will use the funds to assess several sites to, for instance, trigger state cleanup funds, then, as stated in the reproduced criteria in the proposal guidelines, we will show a preference for those proposals. (Please see Q10 under Eligibility Requirements concerning tank removal.)
Q10: Under Criteria #1, third bullet: "Preference will be given to proposals that demonstrate sufficient funds to complete the project." Does "project completion" mean that the site is fully cleaned up and ready for redevelopment?
A: Not necessarily. We will be looking at the entire pilot proposal. If the pilot proposal will consist primarily of cleaning up a site and getting it ready for reuse, then the pilot will be "complete" when that goal is accomplished. If, however, the pilot proposal includes carrying out the full details of a reuse plan, then the pilot will be "complete" when full reuse is accomplished. The point is not that the pilot is actually completed but that the pilot proposal demonstrates that whatever the goals of the pilot may be, the pilot proposal includes provision for all the resources necessary to reach those goals.
Q11: Under Criteria #4, third bullet, "Preference will be given to pilots assessing/cleaning up multiple properties and tanks." How do you define multiple properties? Is any consideration given to multiple tanks? One of our pilot candidates has 11 USTs buried at one orphaned gas station site.
A: EPA defines multiple properties as more than one parcel of land within the pilot area. EPA will give consideration to multiple tanks on the same site. As indicated in the guidelines, a preference will be given to pilots assessing/cleaning up multiple tanks at the same site as well as tanks on multiple properties. The aim is to clean up as many LUST sites as possible with the USTfields LUST Trust funds.