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Activities to be performed under these cooperative agreements include, but are not limited to, (1) environmental assessment to identify the contaminants at brownfields sites and initiate cleanup planning; (2) direct cleanup of brownfield sites; (3) community involvement activities for site selection, cleanup and reuse planning; (4) training participants in the handling and removal of hazardous substances, including training for jobs in sampling, analysis, and site cleanup.

• Environmental Assessment - EPA will award cooperative agreements and, in some instances, provide funding directly through the Targeted Brownfields Assessment program, for Phase I and Phase II environmental assessments, community involvement activities and cleanup planning.
  
• Environmental Cleanup - EPA will award cooperative agreements for the cleanup of brownfields sites.
  
• Revolving Loan Funds for Environmental Cleanup ¡V EPA will award cooperative agreements to capitalize existing, high-performing RLFs to make no-interest or low-interest loans and provide subgrants to carry out cleanup activities at brownfield sites.
  
• Job Training - EPA will award cooperative agreements to provide training in the environmental field to unemployed and underemployed residents in communities impacted by brownfields.

Each cooperative agreement is assigned an EPA regional Project Officer (PO) who has the responsibility to oversee every aspect of the recipient's work. All EPA POs must meet Agency requirements to serve as a PO and must undergo significant training, with refresher courses every three years. The PO will continually monitor progress and identify any schedule slippage via general interaction with the recipient and the Quarterly Report each recipient is required to submit. The Quarterly Report, a Term and Condition for each grant, will provide detailed information to EPA on the reporting requirements identified in Sec.1512 of the Recovery Act. In addition to these quarterly updates, EPA will administer a Recovery Act cooperative agreement review to ensure the recipient is making "sufficient progress" beginning in June of 2010, one year after date of award.

EPA has defined sufficient progress for assessment, cleanup, RLF and Job Training grants to be reasonable expectations of the progress a typical recipient would make in one year. These reasonable expectations are documented directly in the Terms and Conditions of each cooperative agreement.

• Assessment cooperative agreements- the recipient demonstrates ¡§sufficient progress¡¨ when 35% of funds have been drawn down and obligated to eligible activities; for assessment coalitions "sufficient progress" is demonstrated when a solicitation for services has been released, sites are prioritized or an inventory has been initiated if necessary, community involvement activities have been initiated and a Memorandum of Agreement is in place within one year.
  
• Cleanup cooperative agreements - the recipient demonstrates ¡§sufficient progress¡¨ when an appropriate remediation plan is in place, or institutional control development, if necessary, has commenced, initial community involvement activities have taken place, relevant state or tribal pre-cleanup requirements are being addressed and a solicitation for remediation services has been issued within one year.
  
• RLF cooperative agreements- the recipient demonstrates ¡§sufficient progress¡¨ when a loan(s) and/or subgrant(s) has been made within two years.
  
• Job Training cooperative agreements- the recipient demonstrates ¡§sufficient progress¡¨ when one training class has graduated from the program within one year.

Assessment cooperative agreement recipients; TBA (EPA-lead assessment) recipients $33 M Sites assessed; jobs leveraged; funding leveraged;

Cleanup & RLF cooperative agreement recipients $57.4 M Sites cleaned up; jobs leveraged; funding leveraged; acres made ready for reuse;

Job Training cooperative agreement recipients $5 M Number of participants trained; percentage of participants placed in green jobs

Eligible recipients include local governments, states, tribes and non-profits (cleanup and job training only). The Brownfields Program is positioned to provide transparent information on the performance, progress and accomplishments of brownfields projects funded with Recovery Act funds. The Program tracks specific outputs and outcomes at the recipient level and can provide that information on a quarterly basis once the recipients begin reporting accomplishment data to EPA.

The Brownfields program will ensure that the expenditure and monitoring of Recovery Act funds are transparent and that appropriate, qualified staff oversee Recovery Act resources. Managers will meet regularly to assess implementation progress and expeditiously resolve any issues related to Recovery Act-funded projects.

In compliance with the Federal Managers' Financial Integrity Act (FMFIA) EPA's ongoing management integrity program requires us to develop a multiyear program review strategy, conduct systematic and rigorous assessments of internal controls over our programmatic and financial operations, and report on the effectiveness of those controls in our annual letter of assurance to the Administrator. For FY 2009, we will be addressing the integrity of Recovery Act programs and including an additional assurance statement regarding ARRA funds and activities as part of our annual assurance letter to the Administrator.

In addition to our internal reviews, we will rely on audit findings and program evaluation results to inform our assessment and strengthen program accountability. The Brownfields program has one open audit finding from a 2008 Office of Inspector General (OIG) report. The recommendation from the OIG states: "the Assistant Administrator for Solid Waste and Emergency Response should revise model terms and conditions for assessment grants to include a definition for the term 'insufficient progress.'" The Brownfields Program currently has completed draft sufficient progress definitions for the Assessment, RLF and Cleanup cooperative agreements and will incorporate these into final Terms and Conditions (T&Cs) for agreements funded under the Recovery Act. The Brownfields Program plans to finalize the T&Cs by early May, in preparation for the Recovery Act awards in the summer of 2009.

The oversight process in place for ARRA funding ensures that managers and staff will be held accountable for performance. Senior managers'; performance standards include specific performance measures related to the Brownfields program, and staff's performance standards contain measures reflecting their role and responsibilities in achieving progress. (During midyear performance reviews, these performance standards and measures are being modified to address Recovery Act-specific goals.)

The Recovery Act provides funding for site assessment, job training, and cleanup activities that do not generally meet the definition of infrastructure. However, a limited amount of funding awarded to state and local governments may fall into the category of infrastructure where the principal purpose of the activity is to construct a cap to be directly incorporated into a public building or public work as defined in 2 CFR 176.140(a). It may also apply where funds are used to install piping to connect households or businesses to public water systems or replace public water system supply well(s) and associated piping due to groundwater contamination.

EPA does not consider remediation activities conducted with Brownfields supplemental funds by tribes, private sector developers, non-profit organizations (except non-profit organizations that are councils of governments or regional or interstate governmental entities per 40 CFR 31.3 Local government) or other non-governmental borrowers or sub-grantees to be infrastructure investments for the purposes of the certification and reporting requirements.

Though the majority of our projects are not considered infrastructure investments, the Brownfields Program will continue to promote green and sustainable redevelopment on brownfield sites. Each Recovery Act cooperative agreement applicant is evaluated against criteria that weigh the green contribution of the proposed project. Applicants that demonstrate their commitment to sustainable practices are ranked more favorably. Each recipient is encouraged to implement sustainable practices such as green cleanup techniques, energy efficiency and reusing construction and demolition materials.

Further, the Brownfields Program will provide opportunities for additional funding and technical support to Recovery Act projects to promote sustainable redevelopment including green design and locating renewable energy facilities, such as wind farms and solar panel installations, on brownfields.