Tribal Exchange Network FAQs FY24

Exchange Network Grants

How does the EN support tribal environmental management?

The EN can help tribal partners to:

Increase capacity to collect, analyze, manage, and share data.
Increase access to environmental and health related information to assist the tribe with planning, decision-making, and addressing environmental issues more broadly.
Improve ability to characterize environmental conditions on tribal land and identify resources needed to address issues.
Facilitate information sharing within a tribe's agencies, with other tribes, states and the federal government.
Expedite sharing of environmental data with emergency managers and community members
Identify and take advantage of tools and resources already created by other EN partners to meet their Information Technology/Information Management needs.
Support compliance with federal regulations.

How can a tribe get involved in the EN?

There are many ways for tribes to get involved in the Exchange Network. Tribes in any stage of information management program maturity may apply for Exchange Network grants to build the tribe's capacity to share environmental information with EPA, other EN partners, and the public. Tribes can apply for individual projects or can partner with a more experienced tribe. Tribes can also visit http://www.tribalexchangenetwork.org/ for more information, subscribe to the Tribal EN alerts or subscribe to EN alerts. Tribal representatives can seek assistance from or volunteer to join the Tribal Exchange Network Group (TXG). Tribes may also contact Lydia Scheer (lydia.scheer@nau.edu) with the Institute for Tribal Environmental Professionals (ITEP) or TXG@tribalexchangenetwork.org with EN questions. Interested tribes can also participate in open calls or EN-related meetings and conferences on topics of interest hosted by the TXG or announced via Tribal EN alerts.

How have tribes used EN Grants in the past?

Tribes use EN grants to develop the Information Technology (IT), Information Management (IM), and sharing capabilities needed by their tribe to support and improve environmental decision-making. Find out more about the types of activities in which states, tribes and territories are involved by reviewing Previous Exchange Network Grant Projects that were awarded from 2002 to 2023. Below are also some examples of how tribes have used EN grants:

Provide training and support to participating tribes to submit new data for Quality Assurance/Quality Control, data analysis and upload, geospatial features, and share open dump data via the exchange network.
Provide understandable summaries of water quality data to citizens and partner with a local school to empower and create future environmental leaders.
Collect data using Unmanned Aerial System flight imagery and process, interpret, and store those data.
Provide the foundation to collaborate with other tribal nations to help build tools that allow for better environmental management within each tribe's jurisdiction.
Develop tools to manage and monitor water quality as well as facilitate data exchange and analysis to help examine how environmental stressors are affecting wild rice resources across the region.
Develop geospatial data layers and an application to allow for faster and more effective data sharing for quicker emergency response and recovery.
Focus on air data gathering and transmissions through the Air Quality System to improve data submissions and reduce submission costs and burden.
Build the capacity of 23 tribal programs to consolidate, validate, analyze and share their water quality data to the EPA's Water Quality Exchange (WQX), in order to reduce program workload through more efficient processes and mechanisms.

Are there any EN funding areas that are only available to tribes?

Section I-B of the Solicitation Notice summarizes funding areas and general categories of projects that are eligible for funding in the current grant cycle. Specific funding opportunities are listed in Appendix A, Appendix B, and Appendix C.

Appendix C has opportunities available only to tribes and territories to build IT and data management capacity necessary to manage their environmental programs and enable increased participation in the EN.

Examples of capacity-building projects include developing a back-end database or implementing an intra-tribal data exchange.

Which tribal entities are eligible to apply for EN grant funds?

Eligible applicants for the Exchange Network Grant Program include federally recognized Indian tribes, Alaska Native Villages, and inter-tribal consortia of federally recognized tribes (e.g., the Northwest Indian Fisheries Commission). Other entities, such as regional air pollution control districts and some public universities may apply for assistance if they are agencies or instrumentalities of a tribe under applicable laws. Entities asserting they are instrumentalities of a tribe must provide a certification and supporting documentation from the tribal council or other appropriate tribal government official certifying they are an instrumentality of the tribe. EPA will not accept or review an application which does not include the required documentation.

What is an 'instrumentality of a tribe'?

An instrumentality is an organization created by or pursuant to state statute or tribal laws and operated for public purposes.

What Are Intertribal Consortia?

An intertribal consortium is a coalition of two or more separate federally recognized Indian tribes that join for the purpose of applying for a grant. An intertribal consortium is eligible to receive a grant or Cooperative Agreement from EPA only if the intertribal consortium demonstrates that all members of the consortium meet the eligibility requirements for the Cooperative Agreement, and all members authorize the consortium to apply for and receive assistance.

How can my tribe apply for an EN grant?

Tribes can apply for resources as an individual applicant or as a partnership. The funding limit on individual grants for FY 2024 cycle is $300,000. Tribes can also apply for Individual Capacity Building with Mentorship which is available to individual applicants who have never been awarded an EN grant. Under this opportunity the tribe identifies a mentor to help them with their capacity building project and may receive up to $15,000 for mentorship support costs on top of the $300,000 threshold for individual capacity building grants (for a possible total of up to $315,000).

Tribes and inter-tribal consortia can also apply for EN partnership grants, which include one or more eligible partners. The funding limit for partnership grants for the FY 2024 cycle is $500,000. Eligibility requirements for partnership grants can be found in Section III-D of the Solicitation Notice.

Can tribes request basic grants training from EPA? If so, what is the process for requesting training?

YES. EPA's Office of Grants and Debarment offers training opportunities for tribal grantees and potential applicants online throughout the year. Sessions include topics related to grants management, new regulations, EPA policies, and more. Training opportunities for grant applicants and recipients can be found here.

First time grant recipients or grantees who have not received an EPA assistance agreement since October 1, 2014 are required to complete two courses, the EPA Grants Management Training for Applicants and Recipients and the How to Develop a Budget.

EN Grants Specific Training: After posting the Exchange Network Grant Program Solicitation Notice, EPA holds webinars on writing an Exchange Network (EN) grant application. EPA's Regional Exchange Network Coordinators hold conference calls and meetings with grantees throughout the year. Information about upcoming trainings and webinars will be posted to this web page. EPA also has a cooperative agreement with the Institute for Tribal Environmental Professionals (ITEP) to support tribal participation in the EN and conduct webinars and trainings on data management. Tribes may also contact Lydia Scheer, ITEP, by email at: lydia.scheer@nau.edu or TXG@tribalexchangenetwork.org with any EN questions.

Are tribes limited to a percentage of EN grants funding annually?

No. However, for Fiscal Year 2024, EPA remains committed to awarding at least 20% of the appropriated funds being used to award EN grants to tribes. The amount awarded to tribes may be greater than this, depending on the final appropriated amount for grant programs, the number of applicants, proposed project budgets, the merit of tribal applications, and on the competitive review of all applications. In addition, EPA reserves the right to increase or decrease (including decreasing to zero) the total number and amount of awards under this set-aside, or change the ratio of assistance agreements awarded.

How many EN grants have tribes received?

Since 2002 EPA has awarded 239 Exchange Network grants to tribes for a total of approximately $50.4 million.

If I am a Federally recognized tribe, can I charge indirect costs?

Tribes must have an approved indirect cost rate agreement from the Department of the Interior's National Business Center to apply an indirect cost rate.

If you do not have a previously established indirect cost rate (IDC) agreement, you must prepare an indirect cost rate proposal in accordance with 2 CFR 200 Subpart E, "Special Considerations for States, Local Governments and Indian Tribes." Submit your indirect cost rate proposal to:

National Business Center
Indirect Cost Services
U.S. Department of the Interior
2180 Harvard Street, Suite 430
Sacramento, CA 95815-3317

Applicant Questions Asked in FY24:

Is there a site where we can access all QAPPS approved by EPA to use as an example or template?

EPA does not currently publish approved QAPPs online. QAPPs are approved at the EPA regional level and there are not currently any repositories for these documents. To find out what resources are available in your region, we recommend reaching out to your Regional Exchange Network Coordinator (RENC) to be connected with your Regional QA Manager (RQAM).

For contract procurement, it can be challenging for tribes to solicit and get the right proposals. Is documenting those difficulties enough to justify sole-source contractual procurement?

EPA approves noncompetitive or sole-source procurement only under very specific circumstances according to 2 CFR 200.320(c). One example of a potential valid use of non-competitive procurement may be: “After solicitation of a number of sources, competition is determined inadequate.” Details should be provided, in this case, that describe the efforts made to identify and source from multiple sources and why these sources, if found, were deemed inadequate for the purposes of your project. Another example of a potentially valid use of non-competitive procurement is that software required for the proposed project is proprietary and developed by the contractor; therefore, the item is available only from a single source.

Please note that an existing relationship or a history of prior work completed by a contractor or vendor does not justify the use of non-competitive procurement. Similarly, proximity of a contracting firm to an applicant’s organization is not sufficient reasoning.

Can you tell us how we might budget for IT costs provided by another office within our own agency that is a separate branch of the same government? Would this be considered a subaward or a contract, even though we are not soliciting services?

The costs should be categorized under the cost category of ‘other’, but not as a subaward. This would truly be an ‘other’ cost, with a unique category: ‘central IT service’ or something similar to that. Then, if it is a lump sum cost, it should be included as one line item, using the standard ‘other’ cost category table template. Please note that a rationale explaining what this cost is and why the use of this IT office is applicable to the project should likewise be provided. Please see an example of the table below:

In a case where the costs for this central IT cost are structured per staff position, and not as a lump sum, the table would look like this instead. Please note that, as this differs from the typical ‘other’ cost category table format, this can be added as a second table within that section of the budget narrative attachment form:

In the case like this, where an organization is working with an off-site technical office or department, the applicant should name this IT office as the 'programmatic contact' within Section 3: Identifying Key Personnel and Associated Roles, Responsibilities, and Qualifications. The relationship between the applicant and this office/department, as well as a key contact from the IT office and anticipated roles and responsibilities, should then be detailed in this section. See pages E4 - E6 of the FY24 Exchange Network Solicitation Notice for more information on what details should be included in the project narrative, as relates to this role.

For the Project Manager requirement -- we usually have someone in the Environmental Dept as the project manager and someone else in the Finance Dept deal with the financial end. Can we put two people down for this "Project Manager" requirement?

One person should be listed as the project manager within the project narrative and should match the one program manager contacted in the mandatory ‘key contact form’ attachment. When asked about project manager experience in section 3 of the project narrative, the applicant should include any relevant experience to budget and project management, keeping in mind that this requirement is designed to ensure that the selected project manager will be able to effectively manage both the programmatic and financial management aspects of the grant. However, this experience does not have to be exhaustive – just reflective of the named individual’s capacity to handle planning and budgeting aspects of the project. In this specific case, the applicant should also mention that the project manager plans to work closely with the finance department when addressing financial aspects of the project.

Can you provide additional guidance on how to include the mentorship money in the grant? Do we include it as its own line item? Do we split it up as mentorship in the various line items (e.g., contractual, travel, etc)? Other?

Within the budget narrative attachment form, funds to the mentor should be included as a single line item, under the category of ‘subaward’. You can see how this should be included in the example below; although this is technically for a EN partner subaward, it would be the same thing.

Details on this mentorship cost (so a line-item breakdown of the $15,000) should then be included in the Additional Attachment D, which is mandatory for applicants applying with a formal mentor. Please see the four sub-bullets under the first bullet, below.

Is there a way to have a mentor without a subaward?

The subaward is the mechanism to provide the available $15k to the mentoring organization, under the EN Project Opportunity ‘Individual Capacity Building with Mentorship’. Under this Opportunity, the applicant can budget up to $300K in project costs and up to $15K in mentorship support costs. If the subaward is unnecessary (aka, there is no need for funds for the mentor), the applicant should just apply for the Individual Capacity Building opportunity. An organization could then still ‘mentor’ but it would no longer be a formal mentor under our program (with associated funding). It would just be one organization providing guidance to another (at their own expense).

Could EPA direct the subaward directly to a Tribal nation to manage, so that our Tribe is not involved in tracking requirements that seem to be part of the post-award requirements with subawards?

The only option to pass funds to a mentoring organization is through a subaward, which does require the lead recipient (grantee) to both follow EPA’s subaward requirements and policies as outlined in the SN (see Section II-A), and to provide the vehicle/mechanism for distributing the subaward to their mentoring organization. The additional attachment ‘Additional Attachment D: Formal Project Mentors – Roles and Responsibilities, Distribution of Funds, and Overview of Subaward Budget’ is also required for all applicants applying with a Formal Mentor (see SN page E12).

If we provide a subaward, could be provide it to the Tribal nation where the mentor is employed, rather than directly to a mentor? This would alleviate concerns around insurance.

The mentor should be an organization, not an individual (see the language in the SN, under this Project Opportunity write-up (page C-3): “The identified mentor should be a tribe, state, or territory (organization) that has successfully completed an EN assistance agreement and that currently reports or publishes data for one or more environmental programs using an EN node, Virtual Exchange Services (VES), or APIs.”

Exchange Network Technical Topics for Tribes

Does the EN grants program fund Operations & Maintenance costs for tribal governments?

EN grants do not fund operations and maintenance costs because these costs would overwhelm the program's grant resources. Instead, EPA encourages EN partners to investigate the possibility of using media program grant funds to support operations and maintenance. EPA understands that operations and maintenance expenditures are of concern to tribes and EPA has tried to address those concerns by leveraging existing Virtual Exchange Services (i.e., virtual node) to minimize the need. The following costs are also not allowable: construction costs, workshops and conferences, pre - award costs, management fees, or the development and deployment of physical partner nodes. EPA includes definitions of operations and maintenance in the solicitation notice.

What has EPA done to address Operations & Maintenance concerns regarding EN grants? Where can I find additional information on this topic?

EPA realizes that Operations and Maintenance is a main concern of our tribal stakeholders. While we cannot fund activities that are considered operations and maintenance, we provide existing Virtual Exchange Services or VES (i.e., virtual node) for select dataflows. VES are free to use and grantees would not have to develop their own node to exchange data. Also see answer to FAQ directly above.

As the EN Grants Program does not fund Operations & Maintenance related costs, is there any information to assist tribes with planning for software investments and long-term costs to sustain the work developed under EN grant projects?

Yes. The resources listed below were developed to help tribal professionals navigate and plan for recurring software costs.

Software Licensing Frequently Asked Questions (FAQ): A Resource for Tribal Environmental Professionals

- Addresses common issues or questions that Tribes experience when they are purchasing software.
- Provides definitions on common terminologies, suggestions on how to fund short- and long-term software needs through the grant process.
- Gives suggestions and informational links on technical assistance available to tribal partners.

A Software Procurement Roadmap for Tribes

- Examines the entire life cycle of the software licensing process as part of the grants work planning process creates efficiencies, less waste, and less burden.

Outlines the steps to consider when purchasing a software license to support grant workplan activities.

What is the Cybersecurity term and condition for EPA assistance agreements?

Cybersecurity includes policies, procedures and technologies that ensure data confidentiality, integrity and availability. As part of EPA's cybersecurity efforts, the Agency wants to ensure that its partners are protecting their data and ensuring that network connections between partners and EPA are also secure. Consequently, EPA has added a Cybersecurity Term and Condition to all assistance agreements, including agreements with tribes. The tribal term and conditions require that the recipient follow all applicable tribal law and policy cybersecurity requirements to protect environmental data it collects and/or manages. (It does not, however, require tribes to establish cybersecurity requirements, only to adhere to requirements that already exist.) Second, recipients that connect with EPA information systems must ensure that machine to machine connections meet EPA security requirements and enter into Interconnection Service Agreements as appropriate. The second requirement does not apply if the tribe is connecting to EPA through EPA's Central Data Exchange, as they already have their own security in place.

How does this cybersecurity term and condition affect tribal EN grant recipients?

This Term and Condition requires tribes to follow applicable cybersecurity requirements. It does not, however, require tribes to establish cybersecurity requirements, only to adhere to requirements that already exist. EPA, however, encourages tribes that do not currently have such requirements to develop them. The second requirement, which concerns connections with EPA, does not apply to EN grants because tribes will be connecting to EPA through the Exchange Network. The Exchange Network already has its own security in place.

Eligibility, Partnerships, and Mentors

A requirement of the new ‘Individual Capacity Building with Mentorship’ opportunity is that the applicant cannot be a former EN grantee. What if your tribe has received previous EN grants, but not you or your current group of employees. Are we still not allowed to apply for this opportunity?

If your tribe has received a previous EN grant award, your organization is not eligible to apply under the Individual Capacity Building with Mentorship opportunity. However, prior grantees should visit the Tribal Exchange Network Group (TXG) website supported by the Institute for Tribal Environmental Professionals (ITEP) to request free technical assistance and training.

Is a current Indirect Cost Rate (IDC) required to apply?

An Indirect Cost Rate is not required to apply for a grant. However, if you wish to include indirect costs in your proposed budget, you must provide a copy of your current approved indirect cost rate agreement in your application package. Please review the Budget Guidance in Appendix D, particularly the section titled “How to Capture Indirect Costs” for more information on this topic and for additional options that are available specifically to tribal applicants.

Please note that all applicants may also elect to use the De Minimis Rate of 10% of modified total direct cost to charge indirect costs in a proposed project.

For Tribal Partnership Grants, should the lead Tribal Nation's Indirect Cost Rate be used and how it is applied for both Tribes?

Both organizations can charge indirect costs, but each organization must adhere to its own rate agreement (and allowable costs under the base) and you would capture each organization’s indirect costs in separate cost categories.

In the proposed project’s budget:

The lead organization’s indirect costs would be captured in the cost category of ‘indirect costs’ by applying the current IDC rate (from that (lead) organization’s IDC rate agreement) to the costs allowable under that agreement’s base. This cost is included in the project narrative, budget narrative attachment form, and under ‘Indirect Charges’ in the Standard Form 424a (see SN Appendix E for additional information on these application attachments).
Indirect costs for a partnering organization should be calculated using their own IDC rate agreement and the allowable base according to that agreement. Please include the IDC agreement of partnering organizations charging indirect costs as an additional application attachment. These IDC costs should be included within the ‘subawardee’ cost under the cost category ‘Other’ and in Section H in the Standard Form 424a.
- To clarify, all funds that would be going to the partnering organization (including indirect costs) should be captured under a single cost as a subaward under the cost category of ‘other’. So, in the example below, this might include 17,500 towards the two project goals that will be completed by the partner and 2500 in indirect costs for the partnering organization, per their own IDC rate agreement and base.
The details on how the subawards funds will be distributed to the partnering organization (and how amounts like the partner’s indirect cost were calculated) should be included in the application attachment titled “Formal Project Partners – Roles and Responsibilities and Distribution of Funds’. See the Exchange Network Grants Solicitation Notice Appendix E for more information on this.

If an employee under a Tribal Partnership Grant works full-time for one tribe under the partnership grant and part-time for another tribe under the same partnership grant, would it be acceptable to cover that employee's salary for each tribe? Or should the employee's hours be covered under the costs for the lead tribal nation?

You have the option to split your costs across the two organizations, if you choose, but like the response above on indirect costs – you need to ensure that you have costs in the right cost category.

Therefore, in the proposed project’s budget:

Your costs as associated with the lead organization would be captured in the cost categories of ‘personnel’ and ‘fringe’ (if applicable).
- This would be Sections A: Personnel and B: Fringe Benefits in the 424a Form.
Your costs as associated with the partnering organization would be captured as part of your overall subaward under the cost category of ‘other’.
- This would be Section H: Other in the Standard Form 424a.
- This subaward should include ALL funds that would be going to the partnering organization, captured as a single ‘subaward’ cost under the cost category of ‘other’.
- In the example below, this might include $15,000 towards a project goal, $3,000 towards personnel and fringe costs not included in the goal cost, and $2,000 in indirect costs.

Important:

- Indirect costs should be calculated per that (partnering) organization’s IDC rate and base.
- Any fringe costs (if applicable) should likewise be calculated using the fringe rate for this organization/position.
- The details on how the subawards funds will be distributed to the partnering organization (and how amounts like the partner’s personnel/fringe/indirect costs were calculated) should be included in the application attachment titled “Formal Project Partners – Roles and Responsibilities and Distribution of Funds’ (see the Exchange Network Grants Solicitation Notice Appendix E).

Is there a list or resources available for tribes to find suitable mentors?

For assistance in finding an appropriate mentor, applicants should consider contacting the:

Institute for Tribal Environmental Professionals (ITEP) Lydia Scheer, Manager, at lydia.scheer@nau.edu
The Tribal Exchange Network Group (TXG), txg@tribalexchangenetwork.org or at PO Box 15004, Flagstaff, AZ 86011-5004
Environmental Council of the States (ECOS)
- For suggestions on potential state or territorial mentors:
- Contact Kurt Rakouskas, Program Manager, at krakouskas@ecos.org
Applicants may also find the following websites helpful for identifying potential mentors:
- E-Enterprise Community Inventory Platform (EECIP)
- Previous Projects Page of the EN Website

Would two federally recognized tribes in the same geographic region comprise an eligible partnership?

Yes, two different federally recognized tribes in the same geographic region may apply for funding as an EN partnership, as these are two distinct governments.

Additionally, a noneligible tribe (e.g., one that is not federally recognized) may partner with an eligible one in the same geographic region, if the eligible entity is the lead applicant.

What types of entities qualify as Mentors? What types of support can a mentor provide?

Mentors should be a tribe, state, or territory that has successfully completed an EN grant and that currently reports or publishes data for one or more environmental programs using an EN node, Virtual Exchange Services (VES), or APIs. Mentoring activities may take place by phone, over web conferencing, or in person, as needed.

Support activities of a mentor may include:

Demonstrating the mentor's implemented system;
Providing technical assistance to set up the data exchange;
Training on data entry, data analysis, and report generation;
Giving ongoing support after installation:
- Addressing data and exchange questions;
- Providing guidance on submitting reports and completing close-out activities;
Offering guidance on how to actively participate in the Exchange Network, as well as Tribal Governance Group trainings and assistance.