American Rescue Plan Build Back Better Regional Challenge – Frequently Asked Questions

January 21, 2022

Contents

I. Overview: EDA Build Back Better Regional Challenge

1. What is the Build Back Better Regional Challenge?
2. How is the Build Back Better Regional Challenge different from EDA’s other programs funded under the American Rescue Plan? How many awards will EDA make under this Challenge?
3. What does Equity mean in the context of the Build Back Better Regional Challenge?

Eligibility

4. Who is eligible to apply for this funding?
5. What are examples of potential Build Back Better proposals
6. Are previous or active EDA grantees, including grantees with active CARES Act projects, eligible for this program?
7. Are all areas of the country eligible for this funding?
8. What project costs are eligible for funding under this competition?
9. Can my coalition use Phase 1 technical assistance funds past the Phase 2 deadline? Even if my coalition’s projects are not selected for Phase 2 awards?
10. Is a 501c6 organization an eligible entity for this competition?

Evaluation Criteria

11. How will EDA evaluate Concept Proposals and Full Applications?
12. What other information should I consider in preparing a competitive application for this competition?
13. How were Phase 1 awardees selected?

Distress Criteria

14. Must the projects included in a Build Back Better Regional Challenge Application be located in a distressed area?
15. What criteria will be used to determine the degree of economic distress in the project region?

Comprehensive Economic Development Strategy (CEDS) Requirements

16. Do the activities proposed under the Build Back Better Regional Challenge have to be aligned with a Comprehensive Economic Development Strategy (CEDS)?
17. How do I locate the applicable CEDS for my region? What if my project covers multiple planning districts or states?
18. Can my region still apply if it does not have a CEDS?
19. How can we address the requirement if our project is not addressed in a regional CEDS, or the CEDS was prepared before the pandemic and does not yet address current conditions and opportunities?

Coal Communities

20. How much funding will support coal communities through the Build Back Better Regional Challenge program?
21. How does EDA define a coal community?

Project Funding

22. What is the maximum amount that applicants can request under a Build Back Better Regional Challenge Application?
23. What is the deadline for expending grant funds awarded for projects assisted under this competition?
24. Can we use Department of the Treasury State and Local Fiscal Recovery Funds (SLFR Funds) for the local share of EDA ARPA projects?

Procurement and Preaward Costs

25. Are there any restrictions on using consultants engaged in Phase 1 technical assistance grant activities, such as to conduct preliminary engineering or environmental reports, in the implementation projects that EDA may fund in Phase 2?
26. Can an applicant go out to bid for proposed implementation projects, before being selected for Phase 2?
27. Can we use the Phase 1 technical assistance award to solicit consulting services for multiple projects under a single solicitation?

II. Application Materials and Submission Process

Project Applicants

28. What is a lead institution? Do we need one to apply?
29. Can the Regional Competitiveness Officer be an existing staff person within the lead institution for the coalition, or must this be a new position?
30. What is a Coalition, for purposes of this Application?
31. What constitutes a Region for purposes of this Challenge? Can an application include noncontiguous project areas?
32. Are co-applicants allowed in this competition?
33. If co-applicants are allowed in Phase 2 of the Build Back Better Regional Challenge, what are the additional requirements?
34. Can I include sub-awardees in my application?

Phase 1 Concept Proposal Preparation

35. When is the Phase 1 Concept Proposal submission deadline?
36. What is a Concept Proposal? How does it differ from a Full Application?
37. What are the required contents of the Phase 1 Concept Proposal?
38. Are applicants limited to submitting one Phase 1 Concept Proposal in this competition?
39. Will EDA accept multiple applications from the same state or region? Will EDA accept multiple applications for the same industry cluster?

Governor’s Office and State Support for Applications

40. How can a Governor’s Office support a regional coalition in this competition?
41. Can a state use other federal recovery funds to assist applicants to meet match requirements for their projects?
42. Can a Governor’s Office or other partner organization provide letters of support to more than one Build Back Better Regional Challenge applicant from our state?

Phase 1 Technical Assistance Award

43. Why must I submit an EDA application for financial assistance with my Concept Proposal in Phase 1 of this competition?
44. What are the deliverables for the technical assistance grant awarded in Phase 1?
45. Must the ~$500,000 technical assistance award be fully expended by the March 15, 2022, deadline for the Phase 2 application?

Phase 2 Full Application

46. Who can submit a Full Application in Phase 2 of this competition?
47. If selected for Phase 2, can I include a component project in my Phase 2 Full Application that wasn’t listed in my Phase 1 Concept Proposal?

Budget and Match Requirements

48. Is a Budget Narrative required for the Phase 1 Concept Proposal? For Full Applications in Phase 2?
49. Is there a match requirement for the Build Back Better Regional Challenge?
50. Can other federal Covid19 Relief funds, such as those authorized under CARES Act or the American Rescue Plan Act, be used as match in Phase 2 of this competition?
51. Are grant amounts allotted by year or for the entire project period?

Application Submission Guidance

52. What are the deadlines and important dates for this Competition?

Contact Us

53. How do I get in touch with EDA?

I. Overview: EDA Build Back Better Regional Challenge

1. What is the Build Back Better Regional Challenge?

Through the American Rescue Plan, the Economic Development Administration (EDA) created a $1 billion Build Back Better Regional Challenge that seeks to transform regional economies through groups of complementary, aligned projects that will help regions recover from the coronavirus pandemic and increase resilience. These regions will have the opportunity to supercharge their local economies by growing new regional industry clusters or scaling existing ones.

Grant activities to support these regional growth clusters can include planning, infrastructure development, innovation and entrepreneurship, workforce training, access to capital, and more. Activities are expected to begin quickly, leverage existing plans and resources, and engage broadly with regional industry, community, and civic partners.

The Build Back Better (BBB) Regional Challenge is a two-phased competition. Phase 1 is now open and accepting Concept Proposals from interested applicants. EDA strongly encourages potential applicants to review the Build Back Better Regional Challenge Notice of Funding Opportunity (NOFO) for all detailed information regarding this opportunity.

2. How is the Build Back Better Regional Challenge different from EDA’s other programs funded under the American Rescue Plan? How many awards will EDA make under this Challenge?

The Build Back Better Regional Challenge will allow EDA to provide larger, more transformational investments to regions across the nation while utilizing EDA’s greatest strengths, including flexible funding to support community-led economic development. Coordination among partners and projects is essential, and EDA will require regions to select a key member of the regional coalition to lead coordination among the component projects, ensure connectivity with industry and community, and accelerate collaboration and support for the cluster.

This program is designed as a two-phase competition. In Phase 1, interested regions form coalitions of eligible entities and collaborate to develop a Concept Proposal that outlines a vision for the development or expansion of a new or existing regional industry or industries, as well a collection of 3-8 potential projects that support that vision. EDA will select 50-60 Phase 1 coalition finalists and award technical assistance grants of up to $500,000 each, through a lead institution, to further develop the coalition’s concept and collection of projects for their regional growth cluster.

In Phase 2, coalition finalists will compete for significant implementation assistance. EDA will award 20-30 coalitions each a total of $25-75 million, and up to $100 million. These awards will assist communities in executing ambitious plans to supercharge their regional economies across a variety of strategic growth sectors.

3. What does Equity mean in the context of the Build Back Better Regional Challenge?

Equity is defined in EDA’s Investment Priorities as Economic development planning or implementation projects that advance equity across America through investments that directly benefit:

1. one or more traditionally underserved populations (PDF), including but not limited to women, Black, Latino, Indigenous and Native American persons, Asian Americans, and Pacific Islanders; or
2. underserved communities within geographies that have been systemically and/or systematically denied a full opportunity to participate in aspects of economic prosperity, such as Tribal Lands, Persistent Poverty Counties (XLSX), and rural areas with demonstrated historical underservice.

For more information on these populations and geographies, please see: https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/20/executive-order-advancing-racial-equity-and-support-for-underserved-communities-through-the-federal-government/.

Eligibility

4. Who is eligible to apply for this funding?

Eligible lead institutions or coalition members who may submit applications in this competition include a(n):

• District Organization of an EDA-designated Economic Development District (EDD);
• Indian Tribe or a consortium of Indian Tribes;
• State, county, city, or other political subdivision of a State, including a special purpose unit of a State or local government engaged in economic or infrastructure development activities, or a consortium of political subdivisions;
• Institution of higher education or a consortium of institutions of higher education; or
• Public or private non-profit organization or association acting in cooperation with officials of a political subdivision of a State (i.e., a county or municipality).

EDA is not authorized to provide financial assistance to individuals, small businesses, or for-profit entities under the BBB Regional Challenge.

5. What are examples of potential Build Back Better proposals?

Both the region covered and the industry targeted by the Build Back Better proposal should be defined by the applicant in their application materials. Examples of what a Build Back Better cluster of projects may look like and what makes a strong coalition can be found in section A.1.a of the NOFO.

6. Are previous or active EDA grantees, including grantees with active CARES Act projects, eligible for this program?

Yes. Applicants that are current recipients of EDA awards including CARES Act funding are generally eligible to apply for funding under the BBB Regional Challenge. Proposed project activities and outcomes from prior EDA awards must be distinct and separate from the project submitted for the BBB Regional Challenge. Put differently, awards made under this program cannot fund project costs that are charged to other federal funding.

7. Are all areas of the country eligible for this funding?

Yes. EDA has determined that economic injury from the coronavirus pandemic constitutes a “Special Need,” and eligibility may be established on that basis without reference to the other economic distress criteria, provided that the proposed project will assist in recovery from the economic effects of the pandemic. This determination of nationwide eligibility for these funds is consistent with the March 13, 2020 emergency declaration for the coronavirus disease 2019 (COVID-19) pandemic pursuant to the Stafford Act for all states, tribes, territories, local governments, and the District of Columbia. See questions 9 and 10 for details about evaluation and success criteria.

8. What project costs are eligible for funding under this competition?

Phase 1 grants will fund technical assistance activities, while Phase 2 grants will be larger and fund project implementation.

Technical assistance grants to Phase 1 awardees may include costs associated with personnel to coordinate new or existing resources to benefit regional competitiveness, convening regional partners, and outreach activities to engage historically underserved populations, racial minorities, and women in the proposed cluster. Eligible uses of the technical assistance award funds also include development of environmental and engineering information, if applicable.¹

Funding awarded for implementation projects in Phase 2 of the BBB Regional Challenge may be used for the implementation of a variety of construction and non-construction projects. Projects proposed to support regional growth clusters may encompass everything from infrastructure that supports industrial sites, developing or supporting transportation hubs, entrepreneurship and commercialization programs, or demand-driven workforce training that builds or expands an industry sector.

Some other eligible Phase 2 implementation grant costs include construction activities, such as water and sewer system improvements, industrial parks, shipping and logistics facilities, business incubators and accelerators, brownfield redevelopment, technology-based facilities, wet labs, multi-tenant manufacturing facilities, science and research parks, transportation enhancements, and telecommunications infrastructure (e.g., broadband). Eligible non-construction activities can include design and engineering, technical assistance, economic recovery strategy development, market feasibility studies, and the capitalization of revolving loan funds (RLFs).

Please note that, in general, EDA will not reimburse pre-award project costs, and under no circumstances will EDA or DOC be held responsible for application preparation expenditures, which are distinguished from pre-award project costs.

9. Can my coalition use Phase 1 technical assistance funds past the Phase 2 deadline? Even if my coalition’s projects are not selected for Phase 2 awards?

These Phase 1 grants may be used to continue the strategic development and planning of the coalition’s collection of projects in preparation for submission in Phase 2 of this competition as well as continued assistance beyond the Phase 2 application deadline to support the regional growth cluster in other ways, such as funding to staff a Regional Economic Competitiveness Officer and other activities that will increase collaboration across the cluster.

• If the region is not selected in Phase 2, this funding could be used to mature the projects for future funding opportunities at EDA or other agencies and support other activities that could lead to increased regional economic competitiveness.
• If the region is selected in Phase 2, the Phase 1 technical assistance grant funds may go towards additional planning activities that support the approved Phase 2 implementation projects.

10. Is a 501c6 organization an eligible entity for this competition?

For eligibility purposes, nonprofit organizations are not required to have any form of status with the IRS. An eligible non-profit organization must be an entity organized and in good standing in accordance with applicable state law. Therefore, a non-profit organization that has 501(c)(6) status is generally eligible so long as the organization is in good standing with the state and is authorized to undertake eligible activities under the BBB Regional Challenge NOFO. Please note that if the organization undertakes activities that are unauthorized or are ineligible uses of EDA funds (such as lobbying or promoting specific businesses), EDA will implement requirements to ensure that EDA funds are used only for eligible purposes.

Evaluation Criteria

11. How will EDA evaluate Concept Proposals and Full Applications?

Phase 1 Concept Proposals and Phase 2 Full Applications will be reviewed for eligibility and completeness, and complete submissions will be evaluated according to the review criteria, scoring and process for each Phase of the competition, which are set forth in Section E of the NOFO.

EDA will evaluate the collection of projects within each regional growth cluster holistically, and if selected in Phase 2, may at its discretion, fund all or only some of the proposed component projects.

12. What other information should I consider in preparing a competitive application for this competition?

Section A.1.b provides a summary of four key elements of a successful regional growth cluster, and these should be addressed in your Concept Proposal and subsequent Full Application, if selected to go through to Phase 2. EDA strongly encourages potential applicants to review the entire Build Back Better Regional Challenge NOFO for detailed information regarding this opportunity.

13. How were Phase 1 awardees selected?

All complete Concept Proposals were reviewed by at least 3 individuals and scored against the evaluation criteria outlined in Section E.1 of the NOFO. This group of individuals consisted of federal employees and external evaluators who collectively have expertise and experience in evaluating national and regional grant programs, economic development, equity, regional industry clusters, and program management and evaluation.

Applications recommended by the Phase 1 Concept Proposal Review, and also deemed fully compliant with applicable rules and regulations, were forwarded for final selection review and approval by the Grants Officer. For the final selection review, EDA convened a Selection Review Committee composed of 12 federal employees that were chosen based on their experience in their field and previous experience reviewing and evaluating federal grant programs.

The Selection Review Committee, chaired by the Grants Officer, selected this portfolio of projects to fund based on the scores resulting from the evaluation criteria described above and the selection factors listed in Section E.2 of the NOFO.

Distress Criteria

14. Must the projects included in a Build Back Better Regional Challenge Application be located in a distressed area?

No, however Applicants should indicate how the proposed projects will address economic distress in the proposed region, both long standing and as caused by the pandemic, as well as how the benefits of the cluster will be shared equitably across all affected communities within the project area. See NOFO Sections A.1.a (specifying that it must be clear how proposed projects will address economic distress in the region) and D.2, as well as Section E.1 for further guidance.

In determining whether to fund a project at a federal share in excess of 80%, EDA will consider the circumstances, including whether the region meets other thresholds for elevated need based on the relative economic distress of the region. See NOFO Section C.3.a.

15. What criteria will be used to determine the degree of economic distress in the project region?

The degree of economic distress in a proposed project area can be measured in terms of local employment and regional GDP, as well as additional economic indicators, labor market analyses, demographic and industry data, including official announcements made by local and regional industries and firms regarding significant closures (e.g., closure of a coal mine, coal fired power plant, or various coal economy supply chain businesses) that negatively impact the local/regional economy.

Comprehensive Economic Development Strategy (CEDS) Requirements

16. Do the activities proposed under the Build Back Better Regional Challenge have to be aligned with a Comprehensive Economic Development Strategy (CEDS)?

Yes, each project funded under the BBB Regional Challenge must be consistent with the current Comprehensive Economic Development Strategy (CEDS) or equivalent EDA-accepted regional economic development strategy for the region or regions served by the proposed project.

A CEDS is a strategy-driven plan for regional economic development, typically prepared by an EDA-designated Economic Development District (EDD) organization, to guide capacity building efforts that best serve economic development in the region. Documents for consideration as a CEDS equivalent can include various regional economic development plans (or a combination of plans), including but not limited to: regional comprehensive plans, regional resilience or recovery plans.

In the Phase 2 Full Application, the Overarching Narrative (see NOFO Section D.2.c) should include a discussion of how the collection of proposed component projects will support the economic development needs and objectives outlined in the applicable CEDS or equivalent strategy or strategies. Applicants may also include letters of support from organizations that prepare CEDS or equivalent plans for areas that will be served by the proposed collection of projects.

17. How do I locate the applicable CEDS for my region? What if my project covers multiple planning districts or states?

EDA supports the CEDS Resource Library where applicants can determine whether their region is served by an EDD organization and locate its most recent CEDS. Because of the regional footprint of the projects anticipated by this NOFO, applicants may need to show alignment with multiple CEDS or regional or statewide equivalents.

Applicants may contact the EDA Representative for their area listed at https://eda.gov/contacts/ (and in NOFO Section G) for assistance to locate the applicable CEDS or equivalent plan(s).

18. Can my region still apply if it does not have a CEDS?

Yes. Applicants from geographies that are not covered by an EDD are encouraged to reach out to the EDA Regional Office that serves the state in which the proposed regional cluster is based (view the full list). The EDA Regional Office Point of Contact (POC) listed in Section G of the NOFO will help the applicant identify an equivalent EDA-accepted regional economic development strategy.

19. How can we address the requirement if our project is not addressed in a regional CEDS, or the CEDS was prepared before the pandemic and does not yet address current conditions and opportunities?

Your coalition’s vision and group of projects for the cluster should be consistent with the region’s Comprehensive Economic Development Strategy (CEDS) or equivalent EDA-accepted regional economic development plan. EDA-designated Economic Development Districts are required to update or replace the CEDS at least every five years, with action plans that address near-term activities and implementation goals, as well as medium and longer-term goals, strategies and objectives developed through an ongoing and collaborative process. The proposed regional growth cluster and component projects in your application need not be specifically identified in a CEDS or equivalent regional plan but should be in tune with the economic development needs, opportunities, and outcomes that regional stakeholders have collectively agreed to pursue, and should and advance the comprehensive vision for regional economic prosperity and resilience expressed in their plan (or plans) that cover the proposed project area.

Coal Communities

20. How much funding will support coal communities through the Build Back Better Regional Challenge program?

As a part of EDA’s $3 billion American Rescue Plan funding, EDA is making an unprecedented Coal Communities Commitment, allocating $300 million to ensure support for these communities as they recover from the pandemic and create new jobs and opportunities, including through the creation or expansion of a new industry sector. EDA will award a minimum of $100 million to one or multiple regional growth clusters that support coal communities through this program (see Section A.1.e of the NOFO).

Please visit https://eda.gov/arpa/coal-communities/ for additional details.

21. How does EDA define a coal community?

Coal communities are communities and regions that can reasonably demonstrate how changes in the coal economy have resulted or are anticipated to result in job losses and layoffs in any coal-reliant commercial sector. This includes, but is not limited to:

• Coal mining
• Coal-fired power plants
• Related transportation, logistics, and/or supply chain manufacturing industries

In general, EDA will consider applications for projects in communities and regions where the primary coal economy contraction “event” (e.g., closure of a coal mine or a coal-fired power plant, closure of various coal economy supply chain businesses, etc.) took place within 15 years of the application submission date. Note, this timeframe is a range during which projects will generally be eligible; applicants may propose projects outside this timeframe, but should take special care to demonstrate that the primary coal economy contraction “event” continues to tangibly impact the community.

EDA has no pre-defined list of impacted coal communities. To demonstrate eligibility, complete applications must provide appropriate third party economic and demographic statistics that document the extent to which contractions in the coal economy have negatively impacted the community or region.

Project Funding

22. What is the maximum amount that applicants can request under a Build Back Better Regional Challenge Application?

For Phase 1 awards, EDA anticipates awarding technical assistance grants of up to $500,000 each to finalists whose Concept Proposals are selected to apply for Phase 2 of this competition.

For Phase 2 awards, EDA anticipates funding 3-8 aligned component projects in the selected regional growth clusters. EDA anticipates that the funding of individual component projects within regional growth clusters will range from approximately $750K to $25M or more per project, if the cluster or project warrants it. The cost for each region’s 3-8 projects could sum to $25M to $75M, and up to $100M.

23. What is the deadline for expending grant funds awarded for projects assisted under this competition?

The period of performance for projects funded under the Build Back Better Regional Challenge will end no later than May 31, 2027 to allow for orderly closeout.²

EDA expects that all projects will proceed efficiently and expeditiously, and EDA encourages applicants to clearly document how quickly they will be able to start and complete the proposed project scope of work. Given ongoing economic conditions, EDA expects some projects may require longer periods of performance, but typically will range in duration from:

EDA will work closely with award recipients to accommodate their projected timelines within reason and allowances of regulations and grant policies.

24. Can we use Department of the Treasury State and Local Fiscal Recovery Funds (SLFR Funds) for the local share of EDA ARPA projects?

Yes, subject to the following limitations: Only the portion of an applicant’s SLFR Funds that is available for “the provision of government services” may be used as match on an EDA award. That amount is determined in accordance with Treasury’s recently published regulations and is based on a state or locality’s reduction in revenue due to the COVID-19 public health emergency. The portion of SLFR Funds that is not available for the provision of government services may not be used as match. Applicants should direct questions regarding calculating the government services portion of their SLFR Funds to the Treasury; EDA cannot assist with that calculation.

All applicants seeking to apply SLFR Funds to the local share must certify in their match letter to EDA that (1) there are sufficient government services funds available and (2) the pledged funds are committed to the EDA project. Applicants must also agree that if SLFR Funds subsequently become unavailable for any reason that they will replace those funds with other allowable sources of local match. Please note that under Treasury’s regulations, all SLFR Funds must be obligated by December 31, 2024 and expended by December 31, 2026.

25. Are there any restrictions on using consultants engaged in Phase 1 technical assistance grant activities, such as to conduct preliminary engineering or environmental reports, in the implementation projects that EDA may fund in Phase 2?

Yes. The Procurement Standards of the Uniform Guidance at 2 C.F.R. 200.317 – 200.327 govern all procurements under the Build Back Better (BBB) Regional Challenge. The “Competition” regulation at 2 C.F.R. 200.319 sets out the general rule for federal financial assistance that contractors that develop or draft specifications, requirements, statements of work, or invitations for bids or requests for proposals must be excluded from competing for such procurements. In the context of the BBB Regional Challenge, this means that a professional engineer or architect that undertakes preliminary design activities for the project, including a Preliminary Engineering Report (PER) for an EDA application, must be excluded from bidding on the same work under an EDA award. Please see section H.3 of the Build Back Better Regional Challenge NOFO (pg. 43) “Notice of Government-wide Procurement Restriction.”

In accordance with 2 C.F.R 200.317, only state recipients are expressly exempt from this procurement restriction. Local governments and Indian Tribes may also take advantage of the procurement exemption in certain narrow circumstances. As noted above, see section H.3 of the BBBRC NOFO (pg. 44) for additional details.

Practically speaking this means that if a recipient has a selection process that will involve two separate competitions - one solicitation and contract for undertaking preliminary design for a project and then a separate solicitation and contract to select a contractor for final design activities, the successful contractor that undertakes preliminary design (including developing the PER) would be excluded from competing for final design under a Phase 2 award.

There are options to help avoid unintentionally excluding contractors by helping to make sure all competing contractors are on equal footing from the beginning:

• In designing the solicitation for design and engineering services, make sure to include a broad array of such services that will be required under the BBBRC, including preliminary and final design. The coalition may also wish to specify that if the preliminary design is successful and the coalition is selected for an award, final design work is anticipated. The solicitation should also cover the expected funding level and performance period that will be required under the BBBRC.
• If a coalition already has a contractor on an existing general or broad services contract that would cover all anticipated tasks required to develop an application and to implement an award under Phase 2 of the BBBRC and that was competed consistent with the Procurement Standards of the Uniform Guidance (2 C.F.R. 200.317 – 200.327), the contractor exclusion requirement may not be an issue. Please note that in this situation the contract must be competed regularly – in general the performance period should extend no longer than five years. In addition, the services must be within the scope of the existing contract, as interpreted by EDA. Please reach out to your regional POC if you have questions about an existing contract.

Please Contact your EDA Economic Development Representative (EDR) with further questions. You can find your local EDR at https://eda.gov/contact/.

26. Can an applicant go out to bid for proposed implementation projects, before being selected for Phase 2?

In general, an applicant can start necessary solicitation processes before a Phase 2 implementation award, but the applicant must understand it is proceeding at its own risk and there is no guarantee of a federal award. The applicant should take this risk into account in the contracting process as appropriate (e.g., the contract is contingent upon successfully obtaining a federal award, options, etc.). If an applicant does receive a federal award, please note that a procurement must be compliant with the procurement standards set out at 2 CFR 200.317 – 200.327 to be eligible for reimbursement.

27. Can we use the Phase 1 technical assistance award to solicit consulting services for multiple projects under a single solicitation?

Yes. The applicant may advertise for services needed for multiple projects, so long as the procurement is compliant with the procurement standards of 2 CFR 200.317 - 200.327, including 2 CFR 200.319 (e.g., the solicitation incorporates a clear and accurate description of the technical requirements and does not contain features that unduly restrict competition).

Please see the previous question in this section for important information about the competitive procurement restrictions for contractors that develop a PER for a project and then compete for design, and for important considerations to avoid intentionally excluding contractors. Also, see the related question in this section for important considerations about advertising before receiving a federal award.

II. Application Materials and Submission Process

Project Applicants

28. What is a lead institution? Do we need one to apply?

Each coalition that comes together to apply for the Build Back Better Regional Challenge must identify a key member of the coalition, who is an eligible applicant, to serve as the lead institution for the entire collection of projects to support the regional growth cluster. The lead institution will facilitate communication, cooperation, and collaboration between the various partners.

If a Phase 1 Concept Proposal is selected as a finalist, EDA will award its lead institution the technical assistance grant to further develop individual component projects to support the regional growth cluster. Lead institutions selected under Phase 1 will then be eligible to submit a Full Application in Phase 2 for implementation funding to support the proposed regional growth cluster and may serve as the lead applicant for one or more of the component project applications for the cluster. Other members of the coalition may also submit applications for one or more component project.

The lead institution and members of the region’s established coalition are encouraged to consult with the EDA Regional POC listed in the NOFO to determine the best lead applicant for each component project application.

29. Can the Regional Competitiveness Officer be an existing staff person within the lead institution for the coalition, or must this be a new position?

Yes, an existing staff person who is well suited to this position can be selected to serve as the coalition’s Regional Competitiveness Officer. See Section D.2, p.18 of the NOFO for useful information about this important role.

30. What is a Coalition, for purposes of this Application?

A Coalition is a group of eligible entities (see NOFO section C.1) that commit to working together to apply to the BBB Regional Challenge for a collection of related projects that will build or expand a competitive regional growth cluster. Coalition members provide documentation that they have read the application, including the overarching narrative that represents the joint vision of the coalition, and that each member is committed to executing any components of the regional growth cluster for which it is responsible.

31. What constitutes a Region for purposes of this Challenge? Can an application include noncontiguous project areas?

The region covered by the proposed regional growth cluster should be defined by the applicant and can include a geographic footprint that spans multiple jurisdictions, and even crosses two or more states. Projects do not have to be located in contiguous areas, but the proposed group of projects should be strongly connected through an established coalition of government, industry, labor, and academic leaders who are aligned around a shared vision for building, strengthening or scaling a strategic industry or industries.

Section A.1 of the BBB Regional Challenge NOFO includes examples of ways in which a targeted area may be bounded in connection with relevant labor markets, in order to strengthen urban-rural linkages, and other considerations that can maximize collaboration and impact.

32. Are co-applicants allowed in this competition?

Only the lead institution may receive a Phase 1 technical assistance grant, although the lead institution may subaward portions of that grant to other eligible coalition members. Co-applicants are permissible for Phase 2 implementation proposals, but should be limited to the coalition members who will perform the implementation project and any other eligible entities that are required for project performance, such as the owner of necessary real property.

33. If co-applicants are allowed in Phase 2 of the Build Back Better Regional Challenge, what are the additional requirements?

Co-applicants jointly perform the scope of work outlined in the award. Co-applicant organizations must therefore each be eligible entities, as described in Question 4 of this document and Section C.1 of the NOFO. Each co-applicant must submit a signed form SF-424, SF-424D (construction projects only), ED-900A, CD-511, and SF-LLL (if required). Co-applicants do not need to duplicate any other application submissions.

For further assistance on determining co-applicant eligibility, please reach out to EDA at [email protected].

34. Can I include sub-awardees in my application?

Yes. Sub-awardees may be included in the scope of work and budget for applications submitted under the Build Back Better Regional Challenge NOFO. For more information on the requirements for sub-awarding, see 2 CFR § 200.332 (Requirements for pass-through entities).

Phase 1 Concept Proposal Preparation

35. When is the Phase 1 Concept Proposal submission deadline?

Concept Proposals must be submitted to EDA via Grants.gov by October 19, 2021.

36. What is a Concept Proposal? How does it differ from a Full Application?

Phase 1 of this competition involves the preparation and submission of a Concept Proposal, as described in Section A.1 and D.2 of the NOFO. The Concept Proposal should outline the vision for the region’s growth strategy, partners, resources, and transformational projects designed to support that vision, as well as possible outcomes of the proposed strategy and projects. The Concept Proposal also provides general timelines and letters of support from key participants. EDA will select the most compelling Concept Proposals and award these finalists a technical assistance grant to further refine and detail coalition’s strategy and proposed projects toward a Full Application in Phase 2.

The Full Application for Phase 2 will require more specific information about the overarching regional growth cluster, partnering organizations, commitments for matching funds or other investments, and specific metrics expected from implementation, which may evolve from the original Phase 1 Concept Proposal. EDA will also require a complete set of financial assistance forms for the Full Application, including complete forms and documents for each component project within the Full Application. For example, if the proposed regional growth cluster is proposing three component projects: 1) A strategic plan, 2) a wastewater and road project, and 3) a new building to house advanced workforce training, EDA would in general expect three sets of application forms – each appropriate to a complete application for the given component project.

More information on requirements for submitting a Concept Proposal in Phase 1 of this competition, and a Full Application, with component applications for each proposed project in Phase 2 are listed in Section D.2 of the NOFO.

37. What are the required contents of the Phase 1 Concept Proposal?

The Concept Proposal must include the items listed in Section D.2.a of the NOFO.

EDA is preparing application checklists and budget templates which will be available shortly at: https://eda.gov/arpa/build-back-better/

38. Are applicants limited to submitting one Phase 1 Concept Proposal in this competition?

EDA strongly encourages eligible entities to submit only a single application for their region. The Build Back Better Regional Challenge is designed to support regional coalitions with a group of complementary and aligned projects working together to benefit their respective geography around a holistic approach to building and scaling a strategic industry, making multiple applications from the same regional growth cluster unlikely to be competitive.

39. Will EDA accept multiple applications from the same state or region? Will EDA accept multiple applications for the same industry cluster?

The Build Back Better Regional Challenge is a national competition through which EDA will provide transformational investments of $25M to $75M, and up to $100M, per region in grant funding to 20-30 regions across the country to grow new regional industry clusters or scale existing ones. EDA anticipates strong competition for these funds.

Applicants whose regional growth clusters target the same region and related industries should consider opportunities to consolidate projects and align partnerships on related strategies for regional growth and competitiveness.

Phase 1 Concept Proposals and Phase 2 Full Applications will be scored using the criteria set out in sections E.1.a and b of the NOFO, respectively (pgs. 31 – 34 of the NOFO). In addition, EDA’s Selection Review Committee will consider funding recommendations based on selection factors, which include factors such as geographic and regional balance, project and industry types and the overall portfolio into account for final selections. (NOFO Section E.2, p. 35).

Governor’s Office and State Support for Applications

40. How can a Governor’s Office support a regional coalition in this competition?

EDA encourages regional applicants to demonstrate strong collaboration with state government partners, as well as with local government, private sector, labor, and community-based organizations. Cluster activities that are coordinated and strategically aligned with state economic development priorities and resources are well-positioned to foster long-term growth and sustainability. States may also participate as members of the applicant coalition to implement component projects or can work with lead institutions for each coalition to provide letters of support, access to eligible matching funds, and other available resources as part of a competitive application for assistance during the Phase 1 Concept Proposal, and subsequent Phase 2 Full Application.

41. Can a state use other federal recovery funds to assist applicants to meet match requirements for their projects?

Guidance regarding use of other federal funds to match EDA projects, including Treasury State and Local Fiscal Recovery Funds and HUD Community Development Block Grant (CDBG) funds, is addressed in Section C.3 of the NOFO. Applicants may also consult with their EDA Economic Development Representative (EDR) for guidance regarding a proposed project. You can find your local EDR at https://eda.gov/contact/.

42. Can a Governor’s Office or other partner organization provide letters of support to more than one Build Back Better Regional Challenge applicant from our state?

Yes, this is allowable. Note that EDA expects the competition for the Build Back Better Regional Challenge to be strong. Where there may be multiple coalitions forming to submit applications under the Build Back Better Regional Challenge, EDA encourages governors and state agencies to consider applicants’ projects in the context of their statewide plans for regional recovery, and to facilitate partnerships to combine efforts where feasible.

Phase 1 Technical Assistance Award

43. Why must I submit an EDA application for financial assistance with my Concept Proposal in Phase 1 of this competition?

EDA will provide a technical assistance award to the lead institution for coalitions whose Concept Proposal is selected as a finalist in Phase 1. The lead institution must submit the OMB and EDA application forms with their Concept Proposal documents so that they can receive the technical assistance grant. Please see Section D.2 of the NOFO for the required forms and instructions.

44. What are the deliverables for the technical assistance grant awarded in Phase 1?

Lead institutions who receive a technical assistance award in Phase 1 will be expected to submit a complete and timely Full Application for Phase 2 of this competition as their primary deliverable.³ Additional deliverables and eligible activities for the technical assistance award are described in Section A.1.f of the NOFO.

45. Must the ~$500,000 technical assistance award be fully expended by the March 15, 2022, deadline for the Phase 2 application?

No. Coalition finalists that receive a technical assistance award in Phase 1 may propose a period of performance that best meets the needs of their coalition and vision for the regional growth cluster. While submission of a complete Phase 2 Full Application is a key deliverable for this award, EDA expects the period of performance for the technical assistance awards to range from 12 to 24 months.

Phase 2 Full Application

46. Who can submit a Full Application in Phase 2 of this competition?

Lead institutions for coalitions whose Concept Proposals are selected as finalists in Phase 1 may submit Full Applications in Phase 2, but other members of the selected Phase 1 coalitions should submit applications if they are going to run a component project. See section D.2 of the NOFO for more detailed information on the requirements for a Full Application.

47. If selected for Phase 2, can I include a component project in my Phase 2 Full Application that wasn’t listed in my Phase 1 Concept Proposal?

Yes. EDA expects that regional coalitions may identify new or modified implementation projects in the course of preparing their Phase 2 Applications. When that is the case, coalitions may include those projects in their Phase 2 application and must explain how the newly identified project will support the regional growth cluster.

Budget and Match Requirements

48. Is a Budget Narrative required for the Phase 1 Concept Proposal? For Full Applications in Phase 2?

Yes. For Concept Proposals submitted in Phase 1, all applicants must submit a Budget Narrative describing how the lead institution would use the $500,000 technical assistance award, if selected, to further develop the Full Application and component projects under Phase 2. See NOFO Section D.2.a for complete instructions.

Yes, Full Applications submitted in Phase 2 for component projects will also require a budget narrative. Please review the instructions for what to include in each component project application, including budget and supplemental materials. These are found in the NOFO, Section D.2.d.

49. Is there a match requirement for the Build Back Better Regional Challenge?

Phase 1 technical assistance grants awarded to Concept Proposal finalists will not have a cost share or local match requirement.

For component projects awarded under Phase 2 (Full Application), EDA expects to fund at least 80% of eligible costs due to the severe economic dislocation caused by the coronavirus pandemic. For Indian tribes, and in very limited other circumstances, EDA may establish a maximum investment rate of up to 100% of the eligible costs of an individual component project within the regional growth cluster.

Applicants must demonstrate that any required match (cash, in-kind, or a combination of cash and in-kind contributions) is available, unencumbered, and committed to the project at the time of award. Other Federal funds generally cannot be considered as matching funds.

For additional guidance on the cost-sharing and match requirement for this program, please review Section C.3 of the NOFO.

50. Can other federal Covid19 Relief funds, such as those authorized under CARES Act or the American Rescue Plan Act, be used as match in Phase 2 of this competition?

In general, matching funds must be from a non-federal source. Other federal funds may be used to meet match requirements only if the statute for the federal program expressly allows the funds to be used as match AND the purposes for which the other federal funds can be used are eligible under this funding opportunity (in other words, there must be a purpose match between the other federal program and the proposed Phase 2 project). Typically, HUD Community Development Block Grant (CDBG) funding may be used as matching funds for EDA projects, but applicants are advised to consult with their EDA Economic Development Representative (EDR) for guidance regarding their proposed project. You can find your local EDR at https://eda.gov/contact/.

51. Are grant amounts allotted by year or for the entire project period?

The amount of federal funds requested (if approved by EDA) will be allotted for the entire period of performance specified.

Application Submission Guidance

52. What are the deadlines and important dates for this Competition?

Contact Us

53. How do I get in touch with EDA?

EDA staff members are available to provide applicants with technical assistance regarding application requirements. Applicants may contact the EDA representative for their area listed in Section G of the NOFO and on EDA’s webpage at https://eda.gov/contact/.

For clarification or questions about EDA’s Build Back Better Regional Challenge, please email EDA at [email protected].

Please visit http://eda.gov/arpa/ for the latest news and announcements about EDA’s American Rescue Plan programs.

^1. Please note that EDA must approve an award before any costs to be reimbursed with federal funds. The full text of 2 C.F.R. § 200.458 can be found at https://www.ecfr.gov/cgi-bin/text-idx?SID=428b9d90f2a68bef431bf570de2e204b&mc=true&node=pt2.1.200&rgn=div5.

EDA still will not approve pre-award or award costs associated with application preparation costs (e.g., completion of Forms SF-424, ED-900, etc.) or the costs of application expediters.

^2. All American Rescue Plan Act Funds must be expended by September 30, 2027, and therefore no grant periods of performance may be extended beyond that date.

^3. Please note that EDA must approve an award before any costs to be reimbursed with federal funds. The full text of 2 C.F.R. § 200.458 can be found at https://www.ecfr.gov/cgi-bin/text-idx?SID=428b9d90f2a68bef431bf570de2e204b&mc=true&node=pt2.1.200&rgn=div5.

EDA still will not approve pre-award or award costs associated with application preparation costs (e.g., completion of Forms SF-424, ED-900, etc.) or the costs of application expediters.