DEVELOPING AN EFFECTIVE WORK PLAN FOR A 128(A) GRANT

Transcription

1 A PRIMER FOR NEW AND EXISTING GRANTEES DEVELOPING AN EFFECTIVE WORK PLAN FOR A 128(A) GRANT Jane Neumann EPA Region 5 Tribal Lands Forum August 20-22, 2013

2 WORK PLAN AS ROAD MAP Conforms to regulations and policy Well-organized and specific Shows progress Is feasible and well paced Has only approvable work Budget makes sense and adds up 2

3 GOALS OF TRAINING Understand federal grant requirements Understand how to create a work plan that guides you to success Have ideas to tackle the toughest parts Understand what you can do with the 128(a) grant Identify some peer mentors 3

4 Tohono O odham Nation Example Timely Survey and Inventory of Brownfields To facilitate the timely survey and inventory of brownfields sites there is a continued need to investigate potential Brownfields sites that are not listed on the National Priority List (NPL). To accomplish this task requires visits to these various sites, as well as searches for documents, data reviews, site investigation reporting, and collaboratively working with numerous government agencies, tribal departments and various Inspectors. 4

5 TON Example (cont.) There are numerous sites with potential reuse, which may be contaminated with environmental concerns such as lead, asbestos or other potential hazardous chemicals, including historical mine-scarred lands, abandoned buildings, and/or homes. There has not yet been a comprehensive evaluation of environmental impacts conducted for most of these sites and research continues on associated risks. Inventoried sites are selected and prioritized for investigation based on reuse options and available funding. 5

6 TON Example (cont.) Task List for the Inventory 1. Survey and inventory potential sites which meet the definition of a brownfields site. 2. Maintain Site Inventory and update survey list. 3. Work collaboratively with departments, districts and communities to obtain and review site documents. 4. Completion of investigation site screen reports at sites with potential hazardous risks. 5. Lists will be provided to Executive Branch, Districts, TON programs, and others as requested. 6

7 TON Example (cont.) Survey and inventory potential sites which meet the definition of a brownfields site. Create a list of prioritized sites for investigation based on risks and community input. Update list at least twice a year. 7

8 TON Example (cont.) Maintain Site Inventory and update survey list. This will be accomplished by preparing an updated inventory list. The inventory will include the name, basic location, site characteristics, past activity, site safety, and potential hazardous contamination issues. 8

9 TON Example (cont.) Work collaboratively with departments, districts and communities to obtain and review site documents. Schedule site visits/tours of identified sites to conduct preliminary assessments. Meet with the Tohono O odham Nation Departments and Districts to discuss potential sites. Work with Inspectors to create a list of abandoned buildings and/or homes. Assess potential chemicals of concern, contamination risks and response options. Documents will be electronically scanned instead of making paper copies whenever possible. 9

10 TON Example (cont.) Environmental Outcome for this Objective Inventory listing will enhance the Tribe s Response Program by promoting and encouraging evaluation, revitalization and reuse of potential brownfields sites for cleaner, healthier communities. 10

11 TON Example (cont.) Talk to Laurie Suter at 11

12 Federal Grant Requirements A few words from our sponsor 12

13 40 CFR Part 35 Work plan must specify activity commitments and time frame for their accomplishment Work plan must be feasible Level of funding approved must be supported by appropriate amount of work 13

14 EPA Policy for Environmental Results Work must be linked to EPA Strategic Plan Priorities Work plan must contain well-defined outputs and outcomes Outputs vs. outcomes Intermediate vs. end outcomes Measuring your performance 14

15 What are environmental results? Reuse/redevelopment of a site to provide for improved human health and environmental conditions. More effective tribal government response to contaminated sites. Improved public awareness of contaminated sites. Community working with government for sustainable protection of health of all. 15

16 What are measureable results? Number of site assessments Number of sites inventoried Number of staff trained/eligible for field work Number of homes cleaned of asbestos, lead paint or mold contamination Number of government entities participating in a tribal response exercise 16

17 Deliverables and outputs Deliverable is something tangible (brochure, magnet, report) that is given to EPA. Output is either something produced or an action that takes place (meetings attended, training delivered, sites inventoried). Not all outputs have a deliverable but all are reportable and should be quantifiable. 17

18 BUDGETS Not just about the numbers 18

19 Budget and Work Plan as Unit Budget needs to be in proportion to the work proposed Work plan needs enough detail about who is doing tasks to evaluate the budget Budget is an estimate The two help PO meet obligation of responsible stewardship of federal money 19

20 Budget submittals 424A in the application package Budget detail in the work plan Includes a narrative within or below the budget Supporting documents for certain costs Equipment Cost vs. lease comparison Disposition plan 20

21 Indirect Cost Rate Attach the most recent rate letter Use the most recent rate in your calculation or the default rate Explain the base in the budget narrative Just salaries? Salary and fringe only? Everything but contractual? 21

22 Show your work Personnel - Pay rate times hours Contracts should match work planned Contractual - Hourly charge times estimated hours for each contract (other than lab analysis) Supplies - Don t show same stuff every year if it isn t disposable Other - Training costs other than travel 22

23 Show your work Travel - Each trip, how many staff, how many days of lodging & per diem, airfare Remember it s just an estimate! Tribal vehicle use Gas cost under Other or Travel - estimate total miles, divide by mpg, multiply by gas price Regular service and repairs, insurance can be covered by the grant 23

24 Check your work -- NO MATH ERRORS!! 24

25 Structure of a 128(a) work plan No single model is for everyone 25

26 Many ways to organize the work plan Multi-program integrated work plan - PPG Four Elements Project-specific 26

27 PPG work plans are different Work plan can look the same as for a stand-alone grant or Work plan can be completely integrated across contributing programs Be guided by your regional PO and grants office 27

28 Four Elements as structure Developing a site inventory Developing oversight and enforcement authorities Developing a mechanism for community involvement Developing system to approve cleanup plans and certify cleanups are complete 28

29 Beyond the Four Elements Additional work objectives Program management tasks Site-specific work, including contracting and QAPP development Emergency preparedness work General capacity-building like training or procuring equipment 29

30 Program management tasks Quarterly progress reports Annual PALs report Annual Four Elements reporting Funding request and work plan prep Can show all staff training here 30

31 Project and site-focused work plan Example task categories: Developing implementing procedures for new tribal spill law Developing cleanup standards Solid waste and/or UST collaboration Sites with active work followed by description of anticipated work by site Emergency preparedness Training anticipated Grant administration 31

32 Breaking Down Broad Activities Specific tasks to help you make progress 32

33 Examples of broad activities Create tribal site response ordinance Create tribal cleanup standards Conduct tabletop oil spill exercise Community outreach Develop program technical capacity 33

34 Create Tribal ordinance Hire contractor Review existing ordinances Review other tribal response ordinances Draft response ordinance Brief elected officials about need for law Follow legislative process to enact Outreach to tribal law enforcement and community members about new law 34

35 Create Tribal cleanup standards Hire contractor Review other governments standards Outreach to tribal community about their preferred overall approach to cleanup requirements Select individual standards and draw up rule or ordinance Follow legislative process to enact 35

36 Yurok Tribe Example Working on Developing Laws and Cleanup Standards Establish Hazardous Substance Control Ordinance as Yurok Tribal law Take meaningful steps towards establishing tribal cleanup standards 36

37 Yurok Tribe Example (cont.) Meet with Tribal Council to present law Begin public hearing process Have legal consultant prepare draft administrative framework YTEP comments on draft administrative framework YTEP presents revised framework to Tribal Council for approval 37

38 Yurok Tribe Example (cont.) Prepare and publish RFP for toxicologist or biologist; complete procurement process Meet with consultant to initiate development of standards Contractor prepares recommendations on state or federal standards suited to Yurok Reservation community needs 38

39 Yurok Tribe Example (cont.) Present recommended standards to Tribal Council for approval YTEP work with Yurok Office of Tribal Attorney to incorporate standards into HSCO 39

40 Yurok Tribe Example (cont.) Talk to Kathleen Sloan 40

41 Community outreach Create informational brochure Create tabletop display board Attend community elder gatherings to explain why the response program exists Present at Earth Day events or other community environmental celebrations Write articles for tribal newsletter 41

42 Progression of work from year-to-year One-time activities Incremental work Continuing work If task or project is scheduled to be completed in current grant period, do not include it in next year s work plan. 42

43 One-time activities Developing a QAPP Review and update of QAPP Developing Public Participation Plan Create program web page Create public record Create inventory database or structure 43

44 Incremental work Developing ordinances, standards and procedures Investigating specific sites Developing site ranking or priority scheme Developing mechanism for approval of cleanups Updating and enhancing preparedness planning 44

45 Continuing work Site discovery Maintain inventory database Response to site reports from public Staff development Participation in recurring meetings Maintain and update public record Community outreach & education 45

46 White Earth Band of Ojibwa Example Break it down to many steps Logical progression year-to-year Give yourself a stretch goal 46

47 White Earth Example (cont.) Objective 8 - Emergency Preparedness and Planning White Earth Natural Resources Staff will attend various emergency preparedness and planning meetings. Staff will develop and design a table top exercise involving a Hazardous Materials Spill. Staff will develop and design a functional exercise in year two of the grant. 47

48 White Earth Example (cont.) Task 8.1 White Earth Natural Resources Staff will attend various emergency preparedness and planning meetings. Task 8.2 Design a Table Top Exercise regarding a Hazardous Materials Spill Task 8.3 Design a Functional Exercise regarding a Hazardous Materials Spill 48

49 White Earth Example (cont.) Task 8.1 White Earth Natural Resources Staff will attend various emergency preparedness and planning meetings. Quarterly TERC meetings County emergency preparedness meetings Northwest Regional Quarterly meetings Participate in Tribal Quarterly conference calls sponsored by the EPA-USCG-FEMA 49

50 White Earth Example (cont.) Task 8.2 Design a Table Top Exercise regarding a Hazardous Materials Spill Contact EPA Superfund Division Staff regarding the exercise (FY14 Q1) Present the introductory information to the TERC (FY14 Q2) Establishing a Date to host the table top exercise (FY14 Q2) Reserve Meeting Rooms (FY14 Q2) Meet with Exercise Design Team (FY14 Q2) Establish an exercise evaluation group (FY14 Q3) 50

51 White Earth Example (cont.) Talk to Ed Snetsinger 51

52 Conduct tabletop spill exercise Contact EPA for facilitation assistance (or contract for this) Select target date and type of exercise Recruit other governments to participate Make logistical arrangements Invite participants & observers Conduct exercise Share lessons learned report from EPA with other participants 52

53 How much work? Break down larger tasks to interim milestones Develop a time chart to show all work across the year, including the detailed tasks Look at overlapping tasks in time Look at length of time given for each task How many people (FTE) are doing it? 53

54 Pacing the work Tasks Jan Feb March 2013 Apil 2013 May 2013 June 2013 July 2013 Aug Community interviews to discover sites X X X X X X X X X Windshield survey of all reservation areas X X X Sept Update inventory database X X X Phase I assessment of Boingo Lake Site X X X Enter data in ACRES for Boingo Lake Site X X Bid out contract for cleanup standards X X Direct contractor on cleanup standards work X X X Pursue DRM-MPCA MOU to improve X X X communication Monitor RPs progress on Squeaky Leaker Site X X X cleanup Attend Tribal Lands Forum X Expected completion Date Ongoing Recurring quarterly Recurring quarterly Report completed Q2 When standards approved by council Depends on state cooperation Continues quarterly until RP completes remedial action 54

55 Intent of Site Response Program Grant Flexible but doesn t cover everything 55

56 Approvable work Proposed activities need to be eligible under the guidelines and policy First Priority Work needs to support progress toward establishing a program with the Four Elements Second Priority Site-specific work, solid waste and UST, emergency preparedness 56

57 Site-specific work Tying it into an Element How much detail What assessment is planned? Using a consultant - need contracting step Site eligibility task Submitting SAP and HASP to EPA Don t forget the ACRES reporting Listing specific sites Don t forget your public record 57

58 Including non-brownfields sites Yes, you can for oversight but not direct action Name each such site in work plan NPL or emergency response sites RCRA corrective action sites LUST cleanups 58

59 Work not eligible NRDA activities including participation in trustee meetings and review of documents HHW collections limited role Actual emergency response work Environmental outreach not related to response program, contaminated sites and spills Some solid waste work Brownfields prevention work 59

60 Work not eligible Developing debris management plan Developing IWMP in entirety 60

61 Are PPGs different? Perception and reality 61

62 What is the same? Work plan commitments for each funding source Budget for each funding source Requirements for work plan detail and budget No difference in eligible work Reports and deliverables 62

63 What is different? Someone else does the application forms Can do integrated work plan (all the same format) 63

64 This work plan is for YOU! (and your Project Officer too) Questions as you are developing yours: First call your PO or PM/TC Contact your peers for ideas & samples 64

65 Contact Jane Neumann Region 5 Tribal Coordinator Superfund and Brownfields neumann.jane@epa.gov 65