Overview
Title
Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Environmental Justice Thriving Communities Grantmaking (TCGM) Program: Applications for Subawards, Public Outreach Information Collections, and Post-Award Reporting (New)
Agencies
ELI5 AI
The EPA wants to make sure everyone has a fair and safe environment, so they are asking big organizations to help share $600 million with communities for good projects. They are also asking people to tell them what they think about this plan to make sure it's done right.
Summary AI
The Environmental Protection Agency (EPA) is seeking approval from the Office of Management and Budget (OMB) for a new information collection related to its Environmental Justice Thriving Communities Grantmaking Program. This initiative, part of an effort to achieve environmental justice, allocates about $600 million to "Grantmakers," who will distribute subawards to community-led projects. The information collection will involve soliciting applications and gathering reports to ensure proper fund management and transparency. Public comments on the proposal are welcomed until January 27, 2025.
Abstract
The Environmental Protection Agency (EPA) has submitted an information collection request (ICR), Environmental Justice Thriving Communities Grantmaking (TCGM) Program: Applications for Subawards, Public Outreach Information Collections, and Post-Award Reporting (EPA ICR Number 2795.01, OMB Control Number 2035-NEW) to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act. This is a request for approval of a new collection. Public comments were previously requested via the Federal Register on January 8, 2024 during a 60-day comment period. This notice allows for an additional 30 days for public comments.
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Sources
AnalysisAI
The document published by the Environmental Protection Agency (EPA) announces a request for public comments on a new initiative aimed at promoting environmental justice through the distribution of grant funds. Known as the Environmental Justice Thriving Communities Grantmaking Program, this initiative intends to allocate approximately $600 million across 11 cooperative agreements to entities referred to as "Grantmakers." These Grantmakers will be responsible for awarding subgrants to community-led projects focused on environmental justice.
General Summary
The EPA's proposal is centered around collecting pertinent information as part of their grantmaking process. This includes the solicitation of applications for subawards, conducting public outreach, and requiring post-award reporting to ensure transparency, accountability, and effective use of funds. The public is encouraged to submit comments on this proposal until January 27, 2025.
Significant Issues and Concerns
The document raises several critical concerns. One of the main issues is the lack of detailed criteria for selecting Grantmakers. This omission could lead to perceptions of favoritism or unfairness in how organizations are chosen. Furthermore, the document does not provide a breakdown of the fund allocation, raising potential concerns about the equitable distribution of the $600 million budget among the various cooperative agreements.
Another noteworthy issue is the ambiguity surrounding how various activities, such as application solicitation and reporting, will be measured and executed. While the document provides estimated numbers for respondents and burden hours, it lacks an explanation of how these figures were derived, potentially undermining confidence in the initiative’s planning and impact.
Impact on the Public
The proposal has broad implications for the public, particularly for communities striving for environmental justice. By earmarking substantial funds to support grassroots projects, the initiative could empower communities to address local environmental challenges. However, without clear accountability measures and transparent processes, there is a risk of inefficient or mismanaged fund use, which would ultimately detract from the program’s objectives.
Impact on Specific Stakeholders
Stakeholders such as community groups, environmental organizations, and Grantmakers stand to benefit significantly from this proposal. For these groups, successful navigation through the application and reporting processes could mean securing much-needed financial support for their projects. However, stakeholders may also express concerns about the lack of clarity in selection and monitoring processes, potentially hindering their enthusiasm or participation.
In conclusion, while the EPA's environmental justice initiative presents an opportunity to make meaningful progress in addressing environmental disparities, the absence of explicit criteria and detailed implementation plans poses challenges that could limit its effectiveness. Enhanced clarity and transparency in the program’s execution could build trust and maximize positive outcomes for communities targeted by this effort.
Financial Assessment
The Environmental Protection Agency (EPA) has outlined a financial plan under the Environmental Justice Thriving Communities Grantmaking Program, which involves significant monetary commitments. The program is set to provide approximately $600 million in funding through 11 cooperative agreements to entities referred to as "Grantmakers." These Grantmakers will serve as intermediaries, facilitating the distribution of subgrants aimed at supporting community-led environmental justice projects.
Financial Allocations
The $600 million funding is a substantial allocation designed to support numerous projects under the umbrella of environmental justice. However, the document does not offer a breakdown of how this sum will be distributed among the 11 cooperative agreements. This lack of detail in financial distribution raises potential concerns about the equitable allocation of resources among Grantmakers. Without transparency in how funds are apportioned, stakeholders might question the fairness and effectiveness of the program's financial strategy.
Moreover, while the document mentions a total estimated program cost of $10,845,779 per year, including $338,342 for annualized capital or operation and maintenance costs, there is no explanation of how these figures were derived. The absence of a detailed cost analysis can lead to uncertainty about the program's cost-effectiveness and efficiency. Stakeholders might be interested in understanding whether such high annual costs are justified and how they align with the program's goals and activities.
Relationship to Identified Issues
The financial references in the document relate to several identified issues. The lack of specific criteria for selecting Grantmakers and the absence of a clear financial distribution plan heighten concerns about potential favoritism or inequitable fund distribution. Financial transparency is crucial to ensuring that the program's intentions of advancing environmental justice are met without bias.
Furthermore, the document highlights an estimated number of respondents at 295,638 per year with a total estimated burden of 237,049 hours annually. However, there is no accompanying rationale for these large numbers, nor is there an explanation of how these estimates impact the overall program costs. Without such details, it becomes challenging to assess whether the funding levels and associated burdens are appropriately balanced.
Lastly, while mandatory and voluntary information collection obligations are mentioned, the criteria determining these obligations remain unclear, potentially impacting the financial planning behind these activities. For the program to be effectively monitored and assessed, stakeholders would benefit from a more detailed explanation of these financial commitments and their expected outcomes.
In summary, while the document outlines significant financial commitments, greater transparency and specificity regarding the allocation and justification of these resources would strengthen confidence in the program's financial stewardship and its capacity to achieve environmental justice objectives.
Issues
• The document does not specify the criteria for selecting 'Grantmakers,' which could lead to perceptions of favoritism or lack of transparency in how organizations are chosen to manage subgrants.
• There is no detailed breakdown of how the $600 million fund will be allocated among the 11 cooperative agreements, nor is it specified how much each 'Grantmaker' will receive, which might raise concerns about potential inequitable distribution of funds.
• The abstract mentions a wide range of activities (application for subawards, public outreach, and post-award reporting), but it lacks detailed explanation of how each activity will be executed and measured for success, leading to potential ambiguity about actual implementation.
• The estimated number of respondents (295,638 per year) and the total estimated burden (237,049 hours per year) seem quite large, yet the document does not explain how these estimates were calculated or justified.
• The obligations for respondents to provide information are described as mandatory and voluntary, but there is no clarification on what specific criteria determine these obligations.
• There may be potential wastefulness in funding, given the high total estimated cost ($10,845,779 per year) without specific accountability measures outlined in the document.
• The language regarding the 'survey and focus groups' activities is broad, and lacks specificity on how feedback will directly influence or improve the Environmental Justice Thriving Communities Grantmaking Program.
• The document refers to regulations (2 CFR parts 200 and 1500) and burden definition (5 CFR 1320.03(b)) but does not explain what these regulations entail, which could be confusing for lay readers.