DFOP0019505 - Tunisia PhosCo Q&A_FINAL.pdf

DFOP0019505

Safeguarding U.S. Critical Minerals Supply Chains-Tunisia

Questions and Answers

Question 1:

Could you please provide the full Notice of Funding Opportunity (NOFO) package, and outline the step-by-step process for applying, including how to register on MyGrants, and/or any supplementary guidance documents if available?

Answer 1:

All documents, including the Safeguarding U.S. Critical Minerals Supply Chains-

Tunisia Notice of Funding Opportunity are available via Grants.gov and

MyGrants. Job aids on how to register in MyGrants and submit an application are included in the Document section of the Grants.gov announcement.

Question 2:

Who is eligible to apply to this NOFO?

Answer 2:

Please refer to Section B. Eligibility of the NOFO for information on Eligible

Applicants and Selection Preference.

Question 3:

Can you review and provide feedback on aspects of our proposal prior to our submission?

Answer 3:

We do not review any documents and cannot provide feedback prior to the closing of the NOFO.

Question 4:

If our organization — a specialized local commercial enterprise, including a local

Tunisian company, that has some of the technical requirements to respond to this

NOFO — cannot apply directly for this grant, are we eligible to participate as a partner, sub-recipient, or subcontractor alongside a primary or international lead applicant, and/or can we submit a joint proposal?

Answer 4:

Applicants may form a consortia or submit joint proposals to collectively meet the technical and financial requirements described in the NOFO. Please refer to 2

CFR 200.332 Requirements for pass-through entities for information on subrecipients and reference Section B.4 of the NOFO for eligibility requirements and selection preferences.

https://simpler.grants.gov/opportunity/4b467319-d103-4f0b-a7e7-a31e30565d85

Question 5:

Is it acceptable or encouraged for an applicant to form a consortium combining a private-sector implementation partner, Tunisian phosphate/mining subject-matter experts, and investment/project-finance specialists?

Answer 5:

Applicants may form a consortia or submit joint proposals to collectively meet the technical and financial requirements described in the NOFO. Please reference

Section B.4 of the NOFO for eligibility requirements and selection preferences.

Question 6:

If a U.S.-based organization serves as the prime recipient, can a company operating in Tunisia serve as a subrecipient or implementation partner for significant portions of the program?

Answer 6:

Please refer to 2 CFR 200.332 Requirements for pass-through entities for information on subrecipients and Section B. Eligibility of the NOFO for information on Eligible Applicants and Selection Preference for eligibility requirements and selection preferences.

Question 7:

Can grant funds be used for reasonable salaries and benefits of personnel who dedicate time directly to implementation of the project, including project management, stakeholder engagement, technical coordination, and investment facilitation?

Answer 7:

Please refer to section I. Other Information and H. Post-Award Requirements and

Administration for guidelines and information about budgetary requirements and allowability of expenditures.

Question 8:

Are fees for specialized phosphate, mining, processing, environmental, or other technical experts allowable when their work directly supports the program's objectives?

Answer 8:

Applicants have discretion to identify Key Personnel based on the materiality of their role, provided this determination is substantiated in the proposal narrative and budget justification. All such costs must be allowable, allocable, and reasonable under 2 CFR 200, Subpart E — Cost Principles.

Question 9:

Would activities such as mining-sector skills-gap assessments, development of specialized technical talent pools, training, knowledge transfer, and local workforce-capacity development be considered responsive activities when linked directly to strengthening the phosphate investment and supply chain?

Answer 9:

The means and methods of achieving the program's goals and objectives are left to the applicant to propose. Any proposed activity must clearly tie back to and advance the goals and objectives outlined in Section C of the NOFO.

Question 10:

Can the proposed program include investor identification and qualification, investment forums, investor roadshows, site visits, due-diligence support, and engagement with potential strategic investors, financiers, and offtakers?

Answer 10:

The means and methods of achieving the program's goals and objectives are left to the applicant to propose. Any proposed activity must clearly tie back to and advance the goals and objectives outlined in Section C of the NOFO.

Question 11:

Given the references to PhosCo Ltd (and Himilco Resources) and PhosCo's

Tunisian phosphate development project in the funding opportunity, does the

Department require applicants to establish a formal relationship or consortium agreement with PhosCo Ltd or Himilco Resources, or obtain a letter of support/commitment from PhosCo (and/or Himilco) prior to submission — or would a letter of support and evidence of operational coordination be sufficient, with formal coordination occurring following award?

Answer 11:

Applicants are not responsible for establishing a relationship or obtaining a letter of support/commitment from PhosCo or Himilco Resources prior to submission.

Question 12:

What specific registrations (such as SAM.gov, Unique Entity ID / UEI, or NCAGE code) are required for a Tunisian company to participate either as a direct applicant or as a sub-recipient/subcontractor?

Answer 12:

Please refer to Section B. Eligibility of the NOFO for information on Eligible

Applicants and Selection Preference and Section E. Submission Requirements and

Deadlines of the NOFO for information on application requirements.

Question 13:

Will PhosCo provide applicants with access to the Gasaat technical, legal, environmental, and financial information required to develop a credible proposal, or should applicants secure this access independently before submitting their applications?

Answer 13:

After the period of performance has begun, PhosCo will work with the selected implementing partner on collaboration mechanisms for information sharing.

Question 14:

The NOFO refers to PhosCo as holding development rights to the basin, while the publicly available Tunisian instrument appears to establish a mineral research permit. Should proposals include an independent mining-title review and a regulatory roadmap from exploration to commercial exploitation?

Answer 14:

Applicants are encouraged to include comprehensive legal, regulatory, and technical analysis in their proposed scope of work. Proposals should incorporate a clear methodology for navigating local regulatory processes including independent verification of project titles, permit status, and the regulatory pathway required to transition from current resource exploration/validation stages to commercial exploitation. Implementing partners will be expected to establish viable commercial frameworks that account for host-nation legal requirements, land and mineral rights, and investment governance to ensure long-term project bankability.

Question 15:

May the five-year mining-transaction requirement, U.S. government program-management experience, and track record with State, DFC, Commerce, or other

U.S. government institutions be satisfied collectively across a consortium, or must the prime applicant independently meet each requirement?

Answer 15:

Applicants may form a consortia or submit joint proposals to collectively meet the technical and financial requirements described in the NOFO. Please reference

Section B.4 of the NOFO for eligibility requirements.

Question 16:

Are the targets of more than $100 million in U.S. private capital, a 30–40 percent

American equity stake, $15–25 million in U.S. equipment exports, and 75–125 U.S.

manufacturing jobs mandatory results to be completed during the 18–24-month period of performance? Alternatively, may documented investment commitments, signed agreements, purchase orders, and transactions in an advanced pipeline qualify as successful results?

Answer 16:

The program goal figures are aspirational, not mandatory contractual deliverables during the period of performance. Per the exit strategy, USG support concludes once capital is anchored, technical standards are embedded, and initial off-take agreements are executed outcomes that documented commitments, signed agreements, purchase orders, or an advanced pipeline can demonstrate.

Applicants must propose realistic targets and a reasonable pathway to achieving the end goal in the Results Monitoring Plan and Logic Model.

Question 17:

Does the Department envision PhosCo Ltd or Himilco Resources as a program partner, commercial counterparty, beneficiary, data provider, or potential subrecipient under the cooperative agreement?

Answer 17:

PhosCo Ltd. holds development rights to the Northwest Mineral Basin in Tunisia and is actively seeking trusted private equity investment, commercial partnerships, and engineering expertise to develop this asset. The program is designed to facilitate U.S. private-sector engagement with PhosCo's phosphate development.

Question 18:

Does the Department expect the recipient to conduct an independent technical, legal, environmental, regulatory, and commercial assessment of Gasaat, including independent verification of information supplied by PhosCo or other project stakeholders?

Answer 18:

Implementing partners are expected to conduct objective, independent due diligence and technical evaluations to substantiate data provided by project stakeholders. These assessments support risk mitigation, inform potential investors, and help embed U.S. technical, environmental, and commercial standards into project development plans.

Question 19:

May a Tunisian company participate as a consortium partner, subcontractor, consultant, or subrecipient when the prime applicant holds the required active

SAM.gov registration, UEI, and MyGrants organizational account? Please also clarify when a Tunisian subrecipient would be required to obtain its own UEI.

Answer 19:

Please refer to Section B. Eligibility of the NOFO for information on Eligible

Applicants and Selection Preference and Section E. Submission Requirements and

Deadlines of the NOFO for information on application requirements.

Question 20:

Under Objective 3, may the technical assessment cover naturally occurring uranium, rare-earth elements, cadmium, and other potentially recoverable or commercially relevant elements associated with the phosphate deposit, provided that the assessment is supported by scientific evidence and complies with applicable Tunisian and international requirements?

Answer 20:

Under Objective 3, the comprehensive technical analysis to explore byproduct use and economic viability is to include supply chains for cadmium and other elements discovered, as applicable.

Question 21:

Please confirm whether our SOI, submitted on July 11, 2026, remains active and under consideration following the update to the opportunity listing, or whether it needs to be resubmitted?

Answer 21:

Applications must be submitted to this NOFO in order to be considered for this opportunity.

Question 22:

What is the expected timeline for notification regarding whether we will be invited to submit a full application?

Answer 22:

Applications are due in MyGrants by 11:59 PM ET. Unsuccessful Applicants will be notified by October 1st, 2026 through MyGrants.

Question 23:

Could you provide any available information regarding the anticipated ROM mine production and processing capacity (Mtpa) of the PhosCo phosphate development, including whether the project is expected to be developed in a single phase or through staged expansions?

Answer 23:

At this early stage of project development, not all of the technical details are available. Implementing organizations may be working with PhosCo to determine the answers to some of these questions during the evolution of this project.

Question 24:

Are technical data currently available regarding the expected ROM phosphate characteristics, including maximum lump/feed size, particle-size distribution, moisture and clay content, abrasiveness and compressive strength?

Answer 24:

At this early stage of project development, not all of the technical details are

Question 25:

Has the project's primary crushing/sizing philosophy already been established? If so, could you indicate the anticipated design throughput, maximum feed size, target product size and reduction requirements?

Answer 25:

At this early stage of project development, not all of the technical details are

Question 26:

Has the engineering work identified any particular requirements associated with wet, sticky or clay-bearing ROM material, fines generation, or controlled product sizing ahead of downstream beneficiation?

Answer 26:

At this early stage of project development, not all of the technical details are

Question 27:

Has a preliminary concept been established for ROM receiving, heavy-duty feeding and conveying? If so, are indicative capacities, maximum lump sizes and operating conditions available?

Answer 27:

At this early stage of project development, not all of the technical details are

Question 28:

Has the project determined whether primary size reduction will be based on a fixed installation, or are semi-mobile/mobile crushing or sizing and in-pit/near-pit conveying concepts also open for technical consideration?

Answer 28:

At this early stage of project development, not all of the technical details are

Question 29:

At what stage are the process flowsheet, crushing/sizing philosophy, material handling concept and major equipment specifications? In particular, have the relevant equipment technologies already been selected, or is there still an opportunity for qualified OEMs to propose alternative technical solutions before specifications are finalized?

Answer 29:

At this early stage of project development, not all of the technical details are

Question 30:

Has an engineering consultant, EPCM contractor or technical advisor been appointed for the development of the process and equipment specifications? If so, will qualified technology providers have an opportunity to engage with the relevant engineering team, PhosCo and/or the selected NOFO recipient through technology assessments, RFIs or vendor prequalification?

Answer 30:

At this early stage of project development, not all of the technical details are

Question 31:

Could you provide an indicative timeline for the specification and procurement of the principal mining and processing equipment packages, particularly ROM feeding, primary/secondary crushing or sizing, conveying and associated material-handling systems?

Answer 31:

At this early stage of project development, not all of the technical details are

Question 32:

Could the Department clarify how "U.S.-aligned" is defined for purposes of this

NOFO, and whether applicants should prioritize exclusively U.S.-headquartered companies? Specifically, can a non-U.S.-headquartered mining technology and equipment manufacturer participate as a technical, equipment, or consortium partner (with internationally recognized technologies considered where specifications are performance-based), and may DFC debt, direct equity, guarantees, or political-risk insurance be counted toward the target of more than

US$100 million in U.S. private capital mobilized?

Answer 32:

For purposes of this program, "U.S.-aligned entities" refers to companies or organizations from countries that share strategic economic and security interests with the United States, including but not limited to allied nations, partners in multilateral frameworks, and entities from countries with which the United States maintains formal trade and investment agreements. U.S.-aligned entities for critical minerals investment, for example, must demonstrate that their participation will result in tangible benefits to U.S. supply chain security, including through offtake agreements, processing arrangements, or other mechanisms that direct resources or products to U.S. markets.

The primary metric is mobilizing private commercial capital. Concessional or federal financing instruments (such as DFC loans, equity, guarantees, or political risk insurance) serve as de-risking mechanisms and do not directly count as private capital. However, private commercial equity or debt leveraged or unlocked as a direct result of DFC instruments counts fully toward the $100+ million target.

Question 33:

Can NEA/AC please confirm that organizations can submit one proposal as a prime and also be part of another consortium as a sub-awardee?

Answer 33:

Applicants may form a consortia or submit joint proposals that collectively meet the technical and financial requirements.

Question 34:

If an applicant’s consortium includes a financial institution to facilitate deal-making, is that consortium member precluded from structuring their own investment as part of securing the $100 million in U.S. private capital?

Answer 34:

Applicants should propose financial arrangement and mechanisms and clearly explain how the arrangements account for commercial alignment with U.S. supply chain protocols and technology standards.

Question 35:

Section C.1: Exit Strategy states “U.S. government support concludes at 18-24 months, once American capital is anchored in PhosCo Ltd, U.S. technical standards are embedded in project procurement specifications, and initial off-take agreements are executed.”

a. Can NEA/AC confirm how many off-take agreements are expected to be negotiated in the period of performance?

b. Can NEA/AC confirm if the $100 million in U.S. capital is expected to comprise solely of off-take agreements?

Answer 35:

a) NEA/AC does not prescribe an explicit number of offtake agreements.

Applicants should propose realistic milestones based on commercial viability.

b) The $100-million target refers to total private capital mobilized which includes direct equity investments, project-level venture capital, debt financing, or joint-venture capital. Off-take agreements represent commercial purchase commitments for raw or processed materials and are distinct from primary equity/debt capital mobilization.

Question 36:

Is the selected implementer expected to be accountable for full completion of the investment and equity transaction within the 18–24-month performance period, or principally for generating a qualified investor pipeline, completing due diligence and transaction preparation, and advancing negotiations toward financial close?

Answer 36:

Applications will be judged on the feasibility of their exit strategy during the 18-24 month performance period. NOFO benchmarks at the end of the performance period include anchoring American capital in the project, embedding U.S.

technical standards, and executing initial offtake agreements.

Question 37:

What commitments or access arrangements have already been secured with

PhosCo Ltd, the Government of Tunisia, relevant mining and railway entities, and the development banks reportedly financing associated infrastructure? Will the selected contractor receive access to existing feasibility studies, geological and byproduct data, procurement plans, ownership and licensing information, and environmental assessments?

Answer 37:

At this early stage of project development, technical details for collaboration mechanisms are evolving with supportive partners in PhosCo and the Government of Tunisia.

Question 38:

What is the current status of engagement between the U.S. government and

PhosCo Ltd?

Answer 38:

The U.S. government will work with successful applicants to provide a current state-of-play for evolving engagement with PhosCo.

Question 39:

Section A.1. states that “Funding Instrument Type: Grant, fixed amount award

(FAA), or cooperative agreement. Awards issued under this funding opportunity may include substantial involvement of the U.S. government.” However, Section

C.2 states, “This award will be issued as a Cooperative Agreement”. Could you please confirm that the funding instrument type can be either a grant, fixed amount award or cooperative agreement?

Answer 39:

Through the selection process it will be determined if the funding instrument will be a grant, fixed amount award or cooperative agreement.

Question 40:

Could you please clarify whether the targeted 30-40% American equity stake refers to an acquisition of existing shares in PhosCo Ltd, a subscription to newly issued PhosCo Ltd shares, an investment in a Tunisian project entity, or a combination?

Answer 40:

NEA/AC does not mandate a specific corporate transaction structure. The evaluating factor is whether the proposed structure successfully grants U.S.

entities a 30-40% ownership share along with proportional governance, voting rights, or off-take access aligned with U.S. commercial interests.

Question 41:

Are there other programs or funding opportunities, that could be relevant to

Tunisian companies operating in other sectors, particularly aerospace, advanced manufacturing?

Answer 41:

Please refer to Grants.gov for current funding opportunities relevant to Tunisia.