FAST FAQ Clarification.docx

Fueling Aviation’s Sustainable Transition (FAST) Grant Program Frequently Asked Questions / Clarification #2 Question: Does the requirement that projects must be “located in the United States (U.S.)” and that sustainable aviation fuel and low-emission aviation technologies must be “produced in the United States” preclude secondary support from global team members of U.S.-based applicants? How do the Build America, Buy America Act requirements apply?

Answer/Clarification: Per Section C.1 of the Notice of Funding Opportunity (NOFO), foreign entities are eligible for the FAST Grant Program, if the project otherwise meets eligibility requirements. This includes global team members of U.S.-based applicants.

Build America, Buy America Act requirements apply directly to all projects constructing infrastructure, such as may occur in FAST-SAF Tier 2 fuel infrastructure projects, or building a test facility as may occur under FAST-Tech Category 2 projects.

Additionally, the FAST Program applies BABA definitions to clarify the meaning of “produced in the United States,” as explained in NOFO Section C.3. This section explains that:

For the purposes of the FAST program this means that the aviation technology and aviation fuel will be manufactured in the United States and that the cost of the components of the manufactured product that are mined, produced, or manufactured in the United States is greater than 55 percent of the total cost of all components of the manufactured product.

This means that production of fuel and aviation technologies, construction of infrastructure, and fabrication of any hardware (including technology prototypes, test hardware, etc.) under a FAST grant must occur in the U.S. and, in the case of manufactured products, that at least 55 percent of the cost of the components of this manufacturing must consist of components manufactured in the United States and, in the case of construction materials, all manufacturing processes for the construction material must occur in the United States.

Note that the hardware developed under a grant for research and development purposes is considered a “manufactured product” under the NOFO if it meets the following definition, as stated in 2 CFR 184.3, “Manufactured products means: (1) Articles, materials, or supplies that have been: (i) Processed into a specific form and shape; or (ii) Combined with other articles, materials, or supplies to create a product with different properties than the individual articles, materials, or supplies.” Therefore, the 55 percent requirement applies to any hardware (including technology prototypes, test hardware, etc.) developed under the grant.

Additionally, this requirement applies only within the applicant’s project scope proposed for FAST. For example, in the case of a project constructing a fuel production facility, this requirement would apply to the construction of the facility itself but not to feedstock if used in eventual fuel production operations beyond the conclusion of the grant’s awarded work scope. However, any feedstock included in the grant’s awarded work scope must satisfy the greater than 55 percent requirement.

Finally, to clarify the meaning of “located in the United States” as it applies to the FAST program:

Per Section C.3 of the Notice of Funding Opportunity (NOFO), FAST projects must be located in the U.S. For FAST-SAF projects, the physical site of Tier 2 projects or the study area of Tier 1 projects must be located in the U.S.

Additionally, the FAST Program applies the BABA “greater than 55 percent” standard to clarify that in order to be “located in the United States” greater than 55 percent of the total project cost for a FAST grant (both Federal funds and applicant cost share) must occur in the U.S. This includes, but is not limited to, tasks such as analysis, studies, design, and testing activities conducted under the grant scope. This applies to all projects in the FAST program regardless of category or tier.