|
Point/Counterpoint
Counterpoint: You Call This Level?
Anonymous
The EPA may have “leveled the playing field” for brownfield grant
applicants; however, after a grant has been awarded, grantees find that the
playing field is four inches wide, 27 miles long and has a high hurdle every
two feet. A grantee may not deviate from the rules of the game established by
EPA, regardless of experience, expertise or established state programs.
The funds that EPA has provided for brownfield redevelopment are needed. Many
projects would not go forward without the funding, which is critical to the
success of many states’ programs. The issue is one of efficiency and cost/benefit.
Many states have operated brownfield programs successfully for many years —
long before EPA recognized that brownfield sites could be safely redeveloped.
States apply for federal funding to supplement their brownfield programs and
to increase the grants and loans awarded to communities (sub-recipients) for
projects that meet the state’s criteria and standards.
In their applications, states provide detailed information on their programs
and the projects to be funded with federal dollars. The EPA, through the competitive
process, selects which states receive the grant funds. Why does EPA then turn
around and stipulate the exact process to be used in sub-recipient projects
without regard for established state programs?
States enter into the competitive application process with the expectation that,
if their proposal is selected and a grant awarded, EPA has app-roved their program
and supports the use of federal funds in that program. Unfortunately, soon after
the grant is awarded, the hurdles start popping up, and the games begin.
For example, states could use their existing documents for sub-recipient loans,
but review by EPA attorneys in Washington will be lengthy, so it’s best
to use forms already approved by EPA. But the problem is that the forms have
to be modified to be consistent with the individual state’s legal authority.
They have to be approved by the state’s attorneys.
The communities have never seen these documents and have to employ their attorneys
to review them. Sub-recipients have already been through this once with the
state’s forms.
Consider the review process. Under a sub-recipient grant, a workplan is developed
and negotiated between the state and the community. Then EPA comments on the
plan. Concerns are relayed to the state. The state starts over again with the
community. The revised plan goes to the state, then to EPA. And so it goes.
A significant amount of staff time and consultant time is expended in this process.
If EPA is going to approve each plan for each phase for each sub-recipient grant
or loan, why is the state involved? Wasn’t the point of the competitive
process to ensure that federal grant money was going to be spent appropriately?
A little flexibility by EPA would go a long way toward more efficient use of
the grant funds.
This counterpoint was written by a past grant recipient who wishes to remain anonymous.
Counterpoints
Grants Not for Everyone by Betsy Bowe
Grants One Piece of the Puzzle by Leah Yasenchak and Michele Christina