Performance Partnership Grants for Tribes in R9

1. Performance Partnership Grants for Tribes in R9 Presented by: Julie Milazzo, Angela Mendiola, Larry Maurin, Tim Wilhite, Destinee Cooper, and Heidi Brow (Pala Band)

2. What is a Performance Partnership Grant (PPG)? • A PPG is a grant that combines two or more eligible programs into one overall grant. PPGs provide flexibility to combine funding resources into one grant, with one pot of money, in order to increase overall grant performance and decrease administrative burden. • For example, a PPG may have funding and activities from the Clean Water Act (CWA) and the Clean Air Act (CAA) combined into one grant. • Ideally, a PPG could have as many eligible programs included in it as a tribe chooses! 

3. How Do PPGs Work? PPGs are designed to be administered as one grant with: • One application package with: • One budget; • One workplan; and • One award; • One progress report and joint evaluation per reporting period; and • One closeout. Funding comes from more than one grant program, and the workplan contains activities that are allowed under any PPG-eligible program. Once a PPG workplan has been approved and an award has been made, the PPG is the program, and EPA does not require funding, including match/cost-share, to be tracked by the individual programs in the PPG.

4. What Are the Benefits of PPGs? In accordance with 40 CFR Part 35.530, PPGs are intended to: • Strengthen partnerships between EPA and Tribes and Intertribal Consortia through joint planning and priority setting and better deployment of resources; • Provide Tribes and Intertribal Consortia with flexibility to direct resources where they are most needed to address environmental and public health priorities; • Link program activities more effectively with environmental and public health goals and program outcomes; • Foster development and implementation of innovative approaches, such as pollution prevention, ecosystem management, and community-based environmental protection strategies; and • Provide savings by streamlining administrative requirements.

5. Reduced Cost-Share When a tribe includes programs in PPGs, the overall required cost-share is may be reduced. Each program has specific cost-share requirements, but when included in PPGs: • Programs with cost-share of 5% or less will remain the same. • Programs with cost-share over 5% will only be required to provide 5% for each applicable program for the first two years a tribe has a PPG.

6. PPG Challenges • Lack of PPG Flexibility in Practice • Timing and Time Frames • PPG Schedule • Unliquidated Obligations (ULOs) and Tracking of Funds • No Time Savings • Competitive Programs • Communication and Coordination • Regulatory Interpretations

7. EPA National Efforts to Increase PPG Use and Flexibility In accordance with the FY 18 – 22 EPA Strategic Plan(Goal 2 – Cooperative Federalism, Objective 2.1 – Enhance Shared Accountability), increase PPG utilization and flexibility by lead state environmental entities, other state agencies, and tribes receiving multiple grants from EPA. EPA is currently conducting outreach to tribes, to obtain feedback on challenges and barriers to PPGs. Goal is toincrease the percentage of eligible categorical grant funds in tribal PPGs to 65.4% (10% increase from FY17)

8. How Flexible is Funding Once it is Awarded in a PPG? 40 CFR part 35.535(b) states “A Tribe or Intertribal Consortium may use PPG funds for any activity that is eligible under the environmental programs listed in 35.501(a) of this subpart, as determined by the Regional Administrator. If an applicant proposes a PPG work plan that differs significantly from any of the proposed work plans approved for funding that the applicant now proposes to move into a PPG, the Regional Administrator must consult with the appropriate National Program Managers before agreeing to the PPG workplan.” Region 9’s Project Officer Best Practices Guide states that “Prior to the end of the project period, if all work plan activities are completed and funds are remaining, the Tribe can propose to do a new significant environmental priority activity. The PPG Project Officer should check with the appropriate Project Officer to determine allowability under PPG-eligible grants and is not already funded.”

9. Old PPG Awarding Process Old GAP Funding Process Dec Dec-Mar Apr-Jun Oct-Dec May-July Coaching call Proposal Submission Negotiation & tentative funding decisions Application submitted via grants.gov Guidance letters sent Additional negotiations as needed Non-GAP proposal submissions; negotiate & tentative funding decisions

10. New PPG Funding & Awarding Process Jan Jan-Apr Apr-July Oct-Jan Negotiation & tentative funding decisions; notify Tribe ETEP & GAP FY20 workplan & budget reviewed between Tribe & EPA GAP-only portion of PPG application submitted via grants.gov Updated 424 & 424a submitted via email Non-GAP proposal submissions; negotiate & tentative funding decisions; notify Tribe

11. Do Tribes and Project Officers need to track expenses by program? • No. Tribes may see a comparison, though, of funds spent versus work accomplished in End-of-Year reports. Comparisons would be based on estimated costs provided in the approved workplan. • Once funds enter the PPG, they are no longer tied to a specific program. • One drawdown for all included programs.

12. How can competitive funding be incorporated in a PPG? • Applications for competitive funding must be submitted separately from your PPG to the appropriate Funding Opportunity Number in grants.gov. • Please notify your project officers if you have applied for competitive funding. • If your competitive application is selected, EPA can join the competitive application package with your PPG application package. • If you are selected for competitive funding, you must ensure that you account for FTE accordingly in your other programs.

13. What is the role of the “lead” Project Officer in a PPG? • The “lead” Project Officer is a proactive communication facilitator; • Keeps lines of communication between grantee, grant specialist, and program lead(s) open; • Copies program lead(s) on relevant correspondence; and • Forwards grantee to appropriate program lead for program-specific matters. • The Project Officer is listed in the Award Notice.

14. Sample Consolidated Workplan

15. Sample Consolidated Work Plan

16. Sample Consolidated Budget

17. Questions? • Heidi Brow (Pala Band): hbrow@palatribe.com; 760-891-3514 • Angela Mendiola (EPA): Mendiola.angela@epa.gov; 415-972-3284 • Larry Maurin (EPA): maurin.lawrence@epa.gov; 415-972-3943 • Tim Wilhite (EPA): wilhite.timothy@epa.gov; 530-841-4577 • Destinee Cooper (EPA): cooper.destinee@epa.gov; 415-972-3790