FY24 NGDISM Grant Program NOFO FAQs
How do we get access to previously submitted successful applications?
PHMSA has made available FY 2022 applications at the following URL under the "FY 22 Bipartisan Infrastructure Law (BIL) Grant Awards" heading: https://www.phmsa.dot.gov/foia/phmsa-electronic-reading-room
Regarding Common Errors and "Using only one contact name on the SF-424". I only see one location available in the PDF for a single contact. Where should additional contacts be listed?
There are two contact information sections on the Standard Form (SF) 424:
- The programmatic/application contact in Section 8f.
- The authorized representative’s contact in Section 21.
We are working on a grant application and wanted to know if there was a link to the document that allows users to input in the type of pipeline material and length to generate the amount of Greenhouse gas produced?
Applicants are encouraged to use the table included in the NOFO to approximate the methane leak rate based on pipeline material that will be replaced. The table is based on Average Methane Emissions Factors (kg/mile activity) for natural gas pipelines and will streamline methane emissions reduction reporting.
What level of documentation/justification is required to ask for new/additional Leak Detection Equipment?
Applicants should describe the need for the equipment such as current leaks or unlocatable pipe. The project narrative should include sufficient detail about the equipment and how it will support the purpose of the grant program. Quotes or market research should be provided to justify the cost of the equipment.
Will applicants who did receive provisional funding receive any grant application feedback to help improve future applications?
PHMSA conducted debriefs for FY 2022 applicants. Nearly 60 debriefs were held, several were with applicants who were provisionally selected for funding.
Can we still apply at grants.gov?
Applications will be accepted via Grants.gov.
I am working on the Budget and Project narrative forms. Our company is submitting 1 application with 2 projects. For the Budget and Project narrative form do I need to submit 1 project for the mandatory form and the other under optional form?
No. The grant application requires a project narrative and budget narrative. These documents should be submitted via Grants.gov as mandatory forms.
What does labor costs include? Is outside contract labor for the listed project allowable? Should we hire another employee, is their labor costs (hourly rate with benefits) while working on the project allowable? Can this employee be hired as temporary for this specific project and once the project is concluded the employment is terminated?
Under both scenarios, these are allowable costs. Recipients have the flexibility of utilizing in house staff, or they can contract out the labor.
How do tribes include the Gas Distribution Annual Report if we are not a PHMSA regulated utility?
For federally recognized tribes, please submit documentation about your natural gas distribution system so that PHMSA may verify that the eligibility requirements are met.
Should we submit an application for each project or all projects under one application?
If feasible, PHMSA encourages applicants to submit one application with the different projects appropriately segmented. If the projects lack a reasonable tie-in, or if segmenting the projects prove to be more burdensome, applicants should consider submitting separate applications. Applicants who submit multiple applications or propose multiple projects in a single application are not guaranteed to receive the same award recommendation for each project.
The NOFO states that the period of performance is 5 years, but others have stated 3 years. Can that be clarified, please?
The FY 2024 NOFO's Period of Performance is up to 60 months.
Are there match waivers available for under 5,000 population?
The NGDISM Grant Program does not have a cost-share (match) requirement.
If we submit an application for construction work, do the projects need to be broken out as segments with the Project Narrative, Budget Narrative, and all associated documents having individual costs broken down by segments as well?
Applicants have the flexibility in determining how to breakout their costs as long as the methodology is consistent, and readily understandable to the reviewer.
What "percentage" of leak prone pipe or deficient material that must be part of a bundled project scope?
There is no set leak-percentage of any pipe material per project.
PHMSA will evaluate each project for its conformance to the grant program's requirements and all the criteria set forth in the NOFO.
Is it possible to submit an application and call out one project as equipment for year one in addition to a construction project with a start date in subsequent years? As a provisional recipient of the 2022 NGDISM grant, delaying the proposed start date out a year or more will eliminate doubling up construction efforts. Or is it advised to defer applying until the next round?
PHMSA will prioritize projects that can start after the NEPA review process has concluded. PHMSA is expected to provide ongoing data on projects once the award has been executed.
What level of Risk Modeling Process Summary needs to accompany Risk Model Results in Project Scopes?
Applicants are required to submit the current Distribution Integrity Management Plan (DIMP).
How should individual service renewals be applied for?
It is not necessary to separate individual service renewals from a larger project.
Can an engineering firm submit an application on behalf of a municipality if they are a registered user under the municipality's UEI number on Grants.gov?
The NGDISM grant applicant must be a municipality- or community- owned facility, therefore the eligible municipality- or community-owned entity must be named as the applicant on all required grant forms, etc.
A non-eligible entity may assist an eligible municipality- or community-owned entity with their NGDISM grant application package. One example, utilizing Grants.gov workspace feature, an applicant may assign roles so that multiple individuals may work on their grants.gov application(s). For more information about the workspace feature, please review this short video.
An entity is requesting templates for submitting project scopes, equipment acquisitions, and individual service line renewals.
NGDISM proposed projects vary in size and scope for construction only, construction with equipment, and/or equipment only. PHMSA has made available FY 2022 applications at the following URL under the "FY 22 Bipartisan Infrastructure Law (BIL) Grant Awards" heading: https://www.phmsa.dot.gov/foia/phmsa-electronic-reading-room
Do you mean an actual documented quote from a vendor?
When preparing a budget narrative, if a vendor quote or bid is available for the entity's future/unawarded project, that quote/bid would be an attachment to the budget narrative. If at the time of application, a vendor quote/bid is not available, the entity may use past, completed pipeline work costs or conduct market research on the current cost of items.
I am speaking with a MN Electric Cooperative (non-profit, owned by members) who has a fully-owned gas distribution subsidiary. The wholly-owned subsidiary is for-profit.
Would the electric cooperative be able to apply under the NGISM for their gas subsidiary?
NGDISM Grant program entity-eligibility:
- City or township governments owning and operating a natural gas distribution system
- Community-owned utilities owning and operating a natural gas distribution system (owned by the customers it serves)
- County governments owning and operating a natural gas distribution system
- Municipality-owned utilities owning and operating a natural gas distribution system (owned by a local government)
- Native American tribal governments (federally recognized) owning and operating a natural gas distribution system
For-profit entities, and/or any pipeline assets owned by a for-profit entity, are not eligible for NGDISM grant funding.
There is a discrepancy in the mapping tools. The USDOT tool clearly identifies the proposed project area as a disadvantaged community. However, the CEJST does not identify the proposed project area as a disadvantaged area. Please advise on how to interpret.
Please submit the required CEJST map with your application. A map from another source/tool may be submitted with your application, such as the USDOT tool. In your application, please feel free to reference both maps, if there is a discrepancy.
I am unsure of how to list out the activities under Section 3 of the Project Summary. The table provided in the NOFO seems logical when only replacing a small amount of pipeline. Our proposed project, which we are submitting as one project, is in 4 census tracts at various locations. We are replacing over 36 miles with varying ages.
Each project should be described in detail and should be ranked by priority or most at-risk component. Please ensure all pipe lengths are described in miles. The proposed project should include reasonable boundaries that can be replaced within the period of performance. A project prioritization table has been provided should the applicant wish to utilize it. If so, please ensure project prioritization numbering is consistent throughout the application documents.
The PHMSA NGDISM Grant Application Checklist discusses a "project funding table." Please clarify what a project funding table means and what components should be included in the table.
Indicate in a table format the total amount of federal funding requested and the total project cost. If more than one project, provide the information above per project.
We are trying to understand and interpret what the below means in relationship to the grant application and project. This is the first time I have encountered this requirement. What we're having trouble understanding is Civil Rights relative to our employees or with our resident rate payers? There was a reference to a Community Participation Plan, we are not sure what the means. We have encountered a community benefits plan, but is the participation plan our communication / outreach plan for the construction crews encountering local residents during the pipeline construction work?
PHMSA NOFO requirement: Confirmation that a plan is in place or will be in place for compliance with civil rights obligations and nondiscrimination laws, including Title VI of the Civil Rights Act of 1964 and implementing regulations (49 CFR Part 21), the Americans with Disabilities Act of 1990 (ADA), and Section 504 of the Rehabilitation Act, all other civil rights requirements, and accompanying regulations. If there are any questions concerning the responsibilities under the External Civil Rights Program, please contact Rosanne Goodwill, PHMSA Civil Rights Director, at 202-366-6580 or e-mail PHMSACivilRights@dot.gov.
The Civil Rights laws will in all cases apply to your employees, and in some cases will apply to your rate payers depending on the context. For example, 49 CFR § 21.5 states in part that a grant recipient may not, directly or through contractual or other arrangements, on the grounds of race, color, or national origin:
- Deny a person any service, financial aid, or other benefit provided under the program;
- Provide any service, financial aid, or other benefit to a person which is different, or is provided in a different manner, from that provided to others under the program;
- Subject a person to segregation or separate treatment in any matter related to his receipt of any service, financial aid, or other benefit under the program, etc.
Your rate payers would count as persons receiving a service or benefit provided under the program. Section 21.5 also states that grant recipients may not make selections about the site or location of a facility or infrastructure improvement if the purpose is to exclude individuals from the benefits of the program (i.e.¸the safety and other benefits of having the distribution pipelines replaced) on the basis of race, color, or national origin. 49 CFR. Part 27 contains similar requirements with regard to persons with disabilities.
PHMSA has published a Civil Rights guide specifically for grant recipients, which outlines basic requirements and how to comply. The guide is available here: https://www.phmsa.dot.gov/about-phmsa/civil-rights/external-civil-rights-program-guidelines-grant-recipients
A community participation plan refers to a plan to seek public input on decision-making related to the project, particularly from underserved communities that may be affected. Community participation plans can vary in the level of influence they allow the public to have in the decision-making process. For example, some projects might simply inform the public of a decision, while others could seek comments on a proposed decision or allow the public to make the decision. We encourage you to think about what level of public involvement would be most useful to your community and your project. Note also that non-discrimination on the basis of national origin means that grant recipients must take steps to allow persons with limited English proficiency ("LEP") to meaningfully participate in the public involvement process. This should be included as an element of your community participation plan.
For additional information on community participation plans, you may find it helpful to review the DOT guide to public involvement in grant projects, which is available here: https://www.transportation.gov/priorities/equity/promising-practices-meaningful-public-involvement-transportation-decision-making. Section 5.2 of that guide, starting on page 12, specifically covers community participation plans.
The City we are working with, has a transmission line that is also a distribution line. Customer (residential) services off this high-pressure segment require individual pressure regulators. Would this line qualify for eligible costs for replacement through this grant program?
Entities operating both transmission and distribution systems may apply for projects involving their distribution systems. Construction costs including labor costs related to repairing, rehabilitating, or replacing leak prone natural gas pipeline distribution infrastructure, which includes main lines, service lines, and related components. Projects involving transmission lines are ineligible.
The program's priority is on aging high-risk, leak-prone or leaking natural gas distribution infrastructure. PHMSA cannot make full eligibility determinations until applications have been submitted and the NOFO is closed. PHMSA will use annual reports to assist in the verification of whether pipelines are transmission or distribution lines.
Could you please verify if yard line replacement is an eligible expense?
Entities operating both transmission and distribution systems may apply for projects involving their distribution systems. Construction costs including labor costs related to repairing, rehabilitating, or replacing leak prone natural gas pipeline distribution infrastructure, which includes main lines, service lines, and related components. Projects involving transmission lines are ineligible.
Will replacing leaking valves be eligible for funding this year?
Yes, that would be an eligible project if you have the safety case supported for that project proposal.
If there were errors in the 424C & A, were project excluded from considerations in 2023?
No, they weren't excluded, but they likely received a lower score. If a project was submitted from an eligible entity and it was within scope, it received a full review.
One of your slides mentioned administrative staff that would manage the grant - can salaries of existing employees, for time spent on grant, be included or does it have to be new employees?
Yes, we highly encourage you if you have existing employees that will be responsible for helping to manage this grant. Yes, their salaries can be charged. You just must make sure you have an adequate system in place to calculate how much time they're spending on the grant.
If a project was not selected for funding, how can an applicant receive a debrief or feedback on what didn't score well?
So, we did send out status letters for those that were not selected for funding. If you feel like you didn't get enough information, send us an email. We unfortunately don't have the capacity to do debriefs this year, but if you feel like your letter did not adequately explain why you didn't get funding, you can send us an email now if your project proposal scored recommended or higher and you didn't get funding, it's very likely that it was nothing wrong with your project proposal. It was simply that we didn't have enough funding to fully fund all all-recommended projects, which is the case for a lot of you all. But if your project proposal received a score of like not acceptable or acceptable, that means that there was something wrong with the project proposal or something lacking with the project proposal. It's important to look at the rating that was provided in your status letter.
Is the 15% de minimis rate specific to PHMSA or is that a new federal rate?
That's a new federal rate and I believe that takes place this fall for any agreements executed. After September, I believe maybe it's October 1, the start of the fiscal year.
Did I understand correctly that pre-contract costs are eligible for reimbursement?
Yes, it depends. We call those pre-award costs. From the date that the awards are announced if you are working with an environmental consultant or a grants consultant, specifically on the project, you will then submit a letter to PHMSA asking for those pre-award costs to be approved. Many of the FY 2022 recipients did that; probably over 80% requested pre-award costs. The key thing is submitting your pre-award costs for approval first if you are a FY 2023 recipient. We will discuss this in detail at another webinar separate for grantees.
Pre-award costs would not be included in the application?
Any cost necessary to complete the project should go into the application. The distinction between pre-award costs means that before the grant agreement is executed you know you've already incurred some costs. You can then submit a letter to us asking for those costs to be approved. So that way, once your grant agreement is executed, you can immediately come in and recoup those costs or recover those costs.
We have been eliminating all our cast-iron to the point of completion over the last 3 years. My next project is going to be meter replacement - we have many 20–30-year-old leaking meters still in place. Would this be eligible since we have already eliminated our cast iron and steel?
That's still an eligible project. It's still an eligible project and if you can identify the safety need for that replacement, then you'll have a strong application, but it is eligible.
The administrative costs, are we to use a negotiated cost rate agreement and if we don't have that, what can we do? (To clarify: Are you speaking about administrative costs or indirect costs? Yes, in administrative costs).
Yes, administrative costs will go under line item one of the 424C. For example, if you know that you're going to need an administrative assistant to support the program, and let's say that person makes $50,000 a year and half of their time will be spent helping with the program, you can charge up to $25,000. Whatever the current salary may be for the staff that will be supporting the grant, you just have to make sure you only charge the equivalent of how much they're spending on the grant.
Thank you for the presentation. If Tribes are considered DACs, do Tribes have to use the CEJST and other such tools?
While the CEJST tool map is required in the application, tribes do not have to satisfy this requirement. All Tribes are considered disadvantaged for the purposes of this grant program. If you have anything else to supplement the CEJST map, you may submit that as well.
Can cost estimates include an inflation factor?
Yes. Cost estimates would be best possible estimates/projections.
Applicants are encouraged to account for all anticipated costs, including fluctuations/any anticipated increases, when preparing their project budgets. Once a Notice of Grant Agreement (NGA) is executed, PHMSA is unable to add additional grant funding to cover additional costs. However, if the award is for more than the actual costs.
Are there plans to cap project awards at $10M like FY 2022?
PHMSA does not have any current plans to cap awards at $10M.
What is the typical value of an award?
FY 2022 awards ranged from $100K – $10M. FY 2023 awards ranged from $15K – $75M.
Are there restrictions to public bidding of proposed project(s)?
Applicants should follow their own procurement policies and ensure that those policies align with 2 CFR § 200.317 through 200.327. You must ensure open and free competition in your Purchasing, 2 CFR 200.319, and follow the procurement methods listed in 2 CFR 200.220.
If an engineering consultant assists with development of the grant application, are they still eligible to be selected as the design engineer (through a competitive RFQ process)?
Applicants should follow their own procurement policies and ensure that those policies align with 2 CFR § 200.317 through 200.327. You must ensure open and free competition in your Purchasing, 2 CFR 200.319, and follow the procurement methods listed in 2 CFR 200.220.
Once selected provisionally, can fees for updates to the project and budget narratives by a consultant grant writer be part of the grant funding?
Consultants that work on an approved NGDISM funded project(s) and/or the associated environmental requirement(s) are an allowable/reimbursable Federal grant cost. The entity will need to follow the procurement standards in 2 CFR 200.317-327.
Note that 2 CFR 200.320(a) allows for informal procurement methods for micro-purchases (total spent on the consultant is less than $10,000) and small purchases (total spent on the consultant is less than $250,000). These informal procurement methods do not require a formal bidding/proposal process. The entity should follow its procurement policy.
In regard to providing "job opportunities" can we include a position for 3 years (project scope) thus creating a job opportunity within the city gas utility company?
Yes. Any job created, regardless of the duration of that job, can be counted toward the number of jobs created by a project. Costs related to current and/or hiring employees who will work on the grant project may be charged to the grant as long as the costs are allowable, allocable, reasonable, and necessary for the proposed NGDISM project.
If an employee works on the grant project for 100% of their time, 100% of their cost may be charged to the grant. If an employee works on the grant project for 50% of their time, 50% of their cost may be charged to the grant.
Employees, including contracted employees/contractors, performing work on a natural gas distribution system must meet all Federal and state regulatory qualifications for pipeline infrastructure repair, rehabilitation, or replacement activities.
Can engineering fees be included as part of the PHMSA Grant funding?
On the required Standard Form (SF) 424C, Budget Information for Construction Programs, applicants must identify all costs associated with proposed projects by line item. SF-424C, lines 4 and 5, are for architectural and engineering fees. Applicants should refer to the SF-424C instructions when completing the SF-424C to understand what is allowable under these line items.
Engineering fees reimbursable only after award?
There is no pre-award authority to incur costs for any projects before the award announcement. However, the applicant should provide a thorough and concise explanation of the project elements (e.g., design services) and include the projected pre-award costs as part of their application. Once provisional project selections are made, PHMSA may extend pre-award cost approval, consistent with 2 CFR 200.458, for these provisionally selected projects.
A provisionally selected applicant may not bill for accrued costs until it receives an executed Notice of Grant Agreement (NGA). NGAs will not be executed until the project has fully complied with the required NEPA process and/or any provisional requirement(s).
A provisionally selected applicant that does not meet the provisional requirements may have their provisional agreement rescinded by PHMSA, making any accrued costs the responsibility of the entity and not reimbursable by PHMSA NGDISM funds.
Are engineering costs incurred after an applicant has been selected for an award reimbursable?
Applicants selected for award should provide a thorough and concise explanation of the project elements (e.g., design services) and include the projected pre-award costs as part of their application. Once provisional project selections are made, PHMSA may extend pre-award cost approval, consistent with 2 CFR 200.458 for these provisionally selected projects. However, PHMSA cannot reimburse any costs until a Notice of Grant Agreement (NGA) is executed.
How many applications received a rating of Highly Recommended and did not receive funding in the FY 2022 funding cycle?
24 highly recommended applications were unfunded in FY 2022. The total funding requested by FY 2022 applicants well exceeded our available FY 2022 grant funding and PHMSA was unable to fund all applications/projects rated highly recommended.
Can the grant award reimburse for grant administrator and a grant writer? The grant writer will complete the application for my organization.
Costs associated with the drafting of a grant application are not an allowable/reimbursable Federal grant cost.
Is there a designated inflation rate that we should use if including inflation in our budget?
Yes. Cost estimates would be best possible estimates/projections.
Applicants are encouraged to account for all anticipated costs, including fluctuations/any anticipated increases, when preparing their project budgets. Once a Notice of Grant Agreement (NGA) is executed, PHMSA is unable to add additional grant funding to cover additional costs. However, if the award is for more than the actual costs, PHMSA will reimburse for the actual costs that are less than the initial approved higher award amount.
What is the required match what percent?
There is no match requirement with this grant program.
Will the projects not funded move over to future rounds of funding?
No. Unawarded projects may be submitted for future NGDISM grant NOFO funding
Can this funding be used as a match in conjunction with funding from other agencies such as FEMA or HUD?
PHMSA recommends that applicants contact the agencies to understand any match restrictions. Generally, federal programs with a match requirement requires entities to use non-federal funds.
Will the partially funded projects in one round of funding be fully funded in a subsequent round of funding or will those entities have to resubmit?
Unawarded NGDISM projects, partially or in whole, and/or new projects may be submitted for NGDISM NOFOs. PHMSA cannot guarantee that partially funded projects will receive additional funding.
My town has a lot of work to do, but we can't possible do it all in a couple of years (we don't have the bandwidth to oversee the work, etc.) Can we apply one time for a grant for the entire project and receive grants split up over 4 years?
Yes, applicants are encouraged to apply for projects that can be completed in five years. If an entity is selected for an award, the performance period will depend on the timeline submitted in the grant application. Applicants selected for an award do not have to come back in to apply each year if the award amount fully funds the project.
Can you tell me more about micro purchases?
Recipients must comply with the requirements of 2 CFR 200.320(a) when using informal or the micro-purchase and small purchase methods of procurement. Micro-purchases may be awarded without soliciting competitive quotes if the non-federal entity considers the price reasonable based on research, experience, purchase history, or other documented information. If small purchase procedures are used, price or rate quotes must be obtained from an adequate number of qualified sources.
Can recipients reapply? My town received a grant, but we have more work to do... can we reapply? If so, will the performance period overlap with the previous grant's 60 months, or do we get an additional 12 months?
Unawarded projects and/or new projects may be submitted for future NGDISM NOFO funding. If an entity has multiple approved NGDISM projects under different fiscal year NGDISM NOFOs, the period of performances of all approved projects may overlap. Please contact your grant specialist for additional details.
When our letter stating we were not selected arrived it mentioned a rating of "recommend". What does this mean?
As described in our NOFO, there are four rating categories. Recommended is defined as: "The application demonstrates that the NOFO requirements are understood, and the approach will likely result in satisfactory performance. The application addresses and meets requirements with some minor but correctable weaknesses. The application demonstrates requisite experience, qualifications, and performance capabilities. The application scope aligns with DOT objectives and priorities. The risk of poor performance is low."
Can PHMSA Grant funding be used to repay a USDA loan for eligible projects that have not begun?
PHMSA recommends that applicants contact the USDA loan office to understand any loan repayment restrictions.
I'm completing the modified total direct cost calculation and would like verification on whether the contracted construction costs should be included under "Contractual" or "Construction".
Please follow the regulations available at 2 CFR § 200.68 and § 200.92.
Can any of the funds be applied to retroactive projects that we are currently working on?
Unfortunately, no. And that's for several reasons. But one of the key reasons is because we did not conduct a NEPA analysis on that project and so federal funds cannot be applied to a project that PHMSA has not conducted a NEPA analysis on and issued a finding of no significant impact.
When can we submit bids for 2024?
Applications can be submitted when the NOFO is posted to Grants.gov.
I missed the first few minutes - could you repeat the date the NOFO will be released and what is the application deadline.
No, you didn't miss the date. It's pending final approval. It can be released any day now. We just don't have a firm date, unfortunately. PHMSA is anticipating announcing the next round of awards in October of this year, so it will be a highly expedited review cycle, and for that reason the NOFO is only going to be open for six weeks.
What is the FY2024 NOFO application deadline?
June 20, 2024.
What if we won a partial award. What is the timeline to complete the project?
It is 5 years as a period of performance to complete the project. And 5 years to financially close out the project.
Can a contractor write and administer the grant for an eligible entity and, if so, what are the eligible/relevant fees the contractor could charge?
Costs associated with the drafting of a grant application are not an allowable/reimbursable Federal grant cost.
Consultants that work on an approved NGDISM funded project(s) and/or the associated environmental requirement(s) are an allowable/reimbursable Federal grant cost. The entity will need to follow the procurement standards in 2 CFR 200.317-327. Note that 2 CFR 200.320(a) allows for informal procurement methods for micro-purchases (total spent on the consultant is less than $10,000) and small purchases (total spent on the consultant is less than $250,000). These informal procurement methods do not require a formal bidding/proposal process. The entity should follow its procurement policy.
Administrative costs will go under line item one of the 424C. For example, if you know that you're going to need an administrative assistant to support the program, and let's say that person makes $50,000 a year and half of their time will be spent helping with the program, you can charge up to $25,000. Whatever the current salary may be for the staff that will be supporting the grant, you just have to make sure you only charge the equivalent of how much time they're spending on the grant.
We are working with a firm that completed the preliminary design and budget for the application. Would they be eligible to bid on the work? I am assuming we have to abide by federal procurement procedures.
There is no explicit provision barring entities from selecting or retaining contract staff. All organizations must comply with their internal procurement policies and ensure that it aligns with the federal grant regulations.
If the utility has a master meter facility that could benefit from the utility taking it over and replacing the piping would that qualify?
If a master meter system is acquired by, and is a part of, a municipal- or community-owned (not for profit) operator at the time of NGDISM grant application, the entity could apply for a grant to cover the acquired assets for an approved project. However, the entity must be the owner of the master meter system at the time of application.
The town I previously worked for has asked if I would do some grant writing and fundraising for a variety of projects, one of which is to find funding for the purchase of a Kohler gas electronic fuel injected vacuum SpinDoctor boom/valve exerciser and trailer.
Because this product would help the city's utility workers prevent damage to its gas pipeline, we are hopeful that this equipment would be eligible for funding through your grant program.
Can you please let me know if this is a proper source of funding for a purchase like this and, if so, provide me with some guidance on what is needed with our grant application?
Leak detection equipment is an eligible cost for this grant program if the application demonstrates that it will lead to the reduction of incidents and fatalities, reduce environmental impacts, and avoid economic loss, for example, via repairs or rehabilitation.
Is there a list of approved/recommended eligible equipment?
No. There is no list of approved/recommended eligible equipment.
Examples of eligible grant project expenses may include the following:
- Construction costs including labor costs related to repairing, rehabilitating, or replacing leak prone natural gas pipeline distribution infrastructure, which includes main lines, service lines, and related components.
- Equipment costs related to repairing, rehabilitating, or replacing natural gas pipeline distribution infrastructure and/or related to reducing incidents and fatalities, and avoiding economic losses.
- Equipment purchases to improve an operator's leak detection system, to address a risk that could lead to the unsafe operation of a system, and/or to improve an operator’s ability to locate difficult to find legacy pipelines.
What all opportunities fall under the grant? I ask because I'd like to GPS our gas system and upgrade some bare steel yard line to poly.
Projects that involve the repair, rehabilitation, or replacement of natural gas distribution pipeline systems or portions thereof, or to acquire equipment to (1) reduce incidents and fatalities and (2) to avoid economic losses are eligible for the NGDISM grant.
A replacement project currently involves multiple line sizes, but it is necessary for the replacement pipe to be of one size and larger in diameter. The project alone qualifies for grant funding but installing in-kind pipe size is not practical. Does PHMSA have a method to account for the betterment cost to be funded by the utility and still be able to receive grants funds for in-kind replacement cost? A mechanism like highway relocation cost reimbursement that includes betterment costs.
If we have an eligible replacement project with multiple diameters and while we have the highway opened it makes sense to put back one larger diameter. Is there a way to receive grants funds for in kind replacement costs with the utility providing aid to construction for the actual costs?
Projects that will require upsizing for safety are allowable. Applicants should include a safety case for upsizing in their applications. Applicants have the discretion of using in house staff or contracting out the construction work.
Is a project to relocate inaccessible pipeline considered eligible?
NGDISM grant applications must demonstrate that the proposed project will lead to infrastructure updates that reduce safety risks and/or leaks. Relocation of inaccessible pipelines is a low-priority project in comparison to other projects having higher risk/safety projects.
Are projects related to access issues eligible?
These projects are a low priority for the program unless a compelling safety case can be made. NGDISM grant applications must demonstrate that the proposed project will lead to infrastructure updates that reduce safety risks and/or leaks. Relocation of pipelines or distribution mains due to access issues is a low-priority project in comparison to other projects having a higher safety risk.
Are projects that replace legacy plastic pipe still considered Eligible Projects?
Yes.
Is meter replacement eligible?
The purchase of equipment to improve an operator's leak detection system or address a vulnerability that could lead to the unsafe operation of a natural gas distribution system falls within the scope of this grant program if it helps identify necessary infrastructure upgrades. PHMSA will evaluate each project for its conformance to the grant program's requirements and all the criteria set forth in the NOFO.
Is Advanced Metering Infrastructure? (AMI) eligible?
The purchase of equipment to improve an operator's leak detection system or address a vulnerability that could lead to the unsafe operation of a system falls within the scope of the program. However, applicants should consider whether equipment costs are reasonable and cost effective compared to other equipment that serve the same purpose.
Are advanced metering solution's eligible?
The purchase of equipment to improve an operator's leak detection system or address a vulnerability that could lead to the unsafe operation of a natural gas distribution system falls within the scope of this grant program if it helps identify necessary infrastructure upgrades. PHMSA will evaluate each project for its conformance to the grant program's requirements and all the criteria set forth in the NOFO.
Would replacement gas meters be considered equipment?
Replacement of gas meters would need to be tied to a project related to infrastructure repair/replacement.
For technical questions we submitted prior to the webinar will they be answered in the FAQs?
PHMSA accepts NGDISM grant questions via our email, PHMSAPipelineBILGrant@dot.gov. Dependent on the question's topic/complexity, a NGDISM question might be answered via email response, or it might be included in our FAQ document. Please be aware, to be able to publicly post our FAQ-responses takes time and we appreciate, in advance, your patience during this process. PHMSA will post updates to its FAQs as frequently as possible. The deadline for submitting questions is stated on the first page of the NOFO.
We are looking to replace mains, located throughout residential backyards, and construct the new pipeline in the front yard right of way. Is that an eligible project?
NGDISM grant applications must demonstrate that the proposed project will lead to updating aging infrastructure that reduces safety risks and/or leaks. Applicants must describe how the replacement of steel mains will advance safety.
Are risk assessment activities an eligible project expense?
No. Activities that are already required by regulation such as updating DIMP plans is considered to be out of scope.
Would costs for services that do not involve construction or the purchase of equipment be eligible if the services are essential to identifying methane leaks and informing the plan to repair, rehabilitate and replace pipeline distribution infrastructure?
For example, providing access to data and analysis which tracks the location and life cycle of methane leaks across the entire pipeline distribution infrastructure. This provides a highly cost effective approach to prioritizing which areas of the pipeline need to be addressed.
A project that provides access to data and analysis does not meet the intent of this grant program. Applications must demonstrate that the proposed project will lead to infrastructure updates that reduce safety risks and/or leaks. Risk assessment activities are already required by regulation as part of the operator's DIMP program.
Is installing new valves to reduce the number of miles of pipes and customers of being shut off for repairs grant eligible?
Upgrades for normal operator maintenance required by regulations do not meet the intent of this grant.
Are mainline valves that are leaking internally i.e., not able to shut off gas flow to the system (but not leaking externally to atmosphere) eligible?
Projects that involve the repair, rehabilitation, or replacement of natural gas distribution pipeline systems or portions thereof, or to acquire equipment to (1) reduce incidents and fatalities and (2) to avoid economic losses are eligible for the NGDISM grant. PHMSA will evaluate each project for its conformance to the grant program's requirements and all the criteria set forth in the NOFO.
The NOFO has a specific requirement to estimate the number of jobs the project will create within the community and suggests using BLS data to make these estimates. I've been reviewing the BLS website and am having trouble finding this specific information. I did, however, come across a table published in the Economic Policy Institute from 2019 that estimates employment multipliers based on project dollars. The table references BLS data and statistics as the source of information used to create the table. I would argue this is more of a construction project than a utility project but there is no clear definition of each that I could find. Would PHMSA find this acceptable to use for jobs created estimates in our application? If not, can you please point me in the right direction on how to better navigate the BLS website?
Yes, this is acceptable to use in the grant application for calculating an estimate of the number of jobs created.
I intend to use Tier 2 Appendix 6 data/values (Methane Leak Rate pre/post Construction chart) to estimate methane reduction attributable to the project.
Applicants are encouraged to use the table included in the NOFO to approximate the methane leak rate based on pipeline material that will be replaced. The table is based on Average Methane Emissions Factors (kg/mile activity) for natural gas pipelines and will streamline methane emissions reduction reporting.
Our system has a 6" steel pipe from the bulk meter and has several points where gas is supplied to the distribution system. Is the 6" pipe considered a transmission line?
If you have identified the line as a distribution line in your GDAR then PHMSA will consider it a distribution line in general.
Does PHMSA consider Dupont Aldyl-A PE2306 Poly Pipe installed in 1972-1974 as a risk in the State of Iowa? I am aware that it has been an issue in southern states.
Yes, Aldyl-A is considered high-risk. It has problems (e.g., it tends to get brittle). It is being replaced all over the nation.
Has a funded grant application been posted online for review?
PHMSA has made available FY 2022 applications at the following URL under the "FY 22 Bipartisan Infrastructure Law (BIL) Grant Awards" heading: https://www.phmsa.dot.gov/foia/phmsa-electronic-reading-room
Are there plans to share a list of all the projects applied for in 2022? (generic or specific) which ones received highly recommended, recommended, acceptable, etc.
PHMSA has made available FY 2022 applications at the following URL under the "FY 22 Bipartisan Infrastructure Law (BIL) Grant Awards" heading: https://www.phmsa.dot.gov/foia/phmsa-electronic-reading-room
My "APPLY" button is greyed out on grants.gov.
If an applicant goes to use the grants.gov "Apply" button and it is greyed out, they should take the following steps.
- Go to the top left corner of the screen and click on "My Account".
- Click "Manage Profiles".
- Click "Add Profile".
- Add your UEI number.
- Applicants will also be asked to enter their name and job title, but that does not have to be specific or match an existing profile.
- Once that is done, applicants may select Enter and go back to the grant application page.
- After those steps are completed, if the "Apply" button is still greyed out, reload the screen.
- If that doesn't work, applicant may log out of Grants.gov and log back in again.
- If that still doesn't work, applicant likely has an administrative issue where a role is not assigned to them. Applicant may need to have their grants.gov administrator assigned them a role in grants.gov. Grants.gov recommends the "Enhanced" or "EOR" designation.
Will you post this webinar for us to reference in the future?
Yes. NGDISM grant program webinar slides and recordings are available at https://www.phmsa.dot.gov/about-phmsa/working-phmsa/grants/pipeline/natural-gas-distribution-infrastructure-safety-and-modernization-grants.
Are there specific companies that are recommended to help write/submit for this Grant?
Because we're a federal agency, we cannot promote a private vendor over another.
Have any of the FY 2022 awardees started construction?
We do have at least one recipient that had to start emergency work. Many of our other FY 2022 recipients will be starting this summer.
Will the slides be available for us to review?
Yes, they will be made available on the PHMSA website. This presentation will also be posted on YouTube.
If awarded a grant, is there a timeline for when work is to begin?
I mentioned a little bit earlier that we are on an expedited timeline for this round of awards. This year for your applications will be we're bringing in a whole new team just for this to review applications this summer. We will turn this around and record time so that the next round of awards will go out in October for the NEPA process that usually takes anywhere from 2 to 8 months. I would anticipate that that round for FY 2024 funds, construction can probably start as early as next spring.
Could you let us know when you'll send registration information for next week's webinar?
Participants can register at the following link: https://events.gcc.teams.microsoft.com/event/9c50d975-8e8d-4c33-b438-d5c35b4ef6f1@c4cd245b-44f0-4395-a1aa-3848d258f78b
What is the schedule for next week's webinar?
Next Tuesday, May 14th at 2:00 PM.
When will this presentation be available on the website?
We will have the slides up on the website no later than tomorrow and then the YouTube link that might take a few days for public affairs to put that up.
What is the timeline of the NEPA process for construction projects?
It takes anywhere from 8 to 9 months. We highly encourage you to plan for the environmental consultants. If you don't have the resources necessary to get through the Tier 2 NEPA process on your own, now's a good time to make sure that you have it. The sooner that you submit your Tier 2 site specific environmental assessment, the sooner will start your environmental review process. For example, with FY 2022, those awards were announced April 5th, 2023, and we started executing construction projects in December of 2023. We're 75% finished with all the FY 2022 projects.
What is the scope of next week's webinar? Is it the same scope?
Yes, the scope is the same.