Questions and Answers Doc BESS Project HCMC Rev Final.docx

Questions and Answers Document Opportunity Number: ESF-HOCHIMINH-FY2020-0102 Funding Opportunity Title: Battery Energy Storage System Pilot (BESSP)

Q1: Can the grant funding be used to secure the project site, including administrative costs, permitting costs and land costs (lease or purchase)?

A1: In accordance with 2 CFR §200.1, real property means land, including land improvements, structures and appurtenances thereto, but excludes moveable machinery and equipment.

Federal funds for this award can be used for real property (including lease or purchase of land). See real property requirements are in 2 CFR §200.310, §200.311, §200.316, §200.330, and §200.465.

Project site costs, such as administrative costs and permitting costs, should be in accordance with the applicable sections of OMB 2 CFR 200 and 600 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Q2: Please confirm that the award recipient will own and operate the BESS system/hardware and be able to generate income after the 4-years program duration has ended.

A2: Program income generated after the period of performance and license fees and royalties is in 2 CFR §200.307 sections (f) and (g).

As outlined in 2 CFR §200.307 sections (f) and (g), there are no Federal requirements governing the disposition of income earned after the end of the period of performance for the Federal award and the non-Federal entity is not accountable to the Federal awarding agency with respect to program income earned from license fees and royalties for copyrighted material, patents, patent applications, trademarks, and inventions made under a Federal award to which 37 CFR part 401 is applicable.

However, the Grants Officer may negotiate agreements with award recipients regarding appropriate uses of income earned after the period of performance as part of the grant closeout process. See also §200.344.

During the closeout phase, the Grants Officer will give the recipient disposition instructions for property, equipment (including hardware), and unused supplies purchased with award funds.

The Grants Officer’s disposition instructions for equipment will be in accordance with 2 CFR §200.313, (e) Disposition, as follows:

equipment with a current per unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further responsibility to the Federal awarding agency by the award recipient, and;

equipment with a current per-unit fair market value in excess of $5,000 may be retained by the non-Federal entity or sold. The Federal awarding agency is entitled to an amount calculated by multiplying the amount calculated by multiplying the current market value or proceeds from sale by the Federal awarding agency's percentage of participation in the cost of the original purchase. If the equipment is sold, the Federal awarding agency may permit the non-Federal entity to deduct and retain from the Federal share $500 or ten percent of the proceeds, whichever is less, for its selling and handling expenses.

See also intangible property requirements in 2 CFR §200.315, §200.316, and §600.315.

Q3: Will federal funding be reduced by the amount of income generated during the period of performance?

Will repayment of the grant funding be required, if income is generated after the period of performance?

A3: Use of program income is specified in 2 CFR §200.307 (e). The federal awarding agency will determine, prior to award issuance, which approach: (e)(1) deduction, (e)(2) addition, or (e)(3) cost sharing or matching will apply to the use of program income.

Program income after the period of performance is specified in 2 CFR §200.307 (f).

Q4: If cost share or matching funds is provided by the award recipient, will federal funding be used prior to cost share or matching funds?

A4: Per 2 CFR §200.1, voluntary committed cost sharing means cost sharing specifically pledged on a voluntary basis in the proposal's budget on the part of the non-Federal entity and that becomes a binding requirement of Federal award. See also §200.306.

Cost share or matching funds included in the final award budget will need to be provided during the period of performance of the award.

Q5: Do first time applicants, that do not receive any other revenue or income via any other federal contracts, need to provide a PDF copy of the most recent single audit, under 2 CFR 200 Subpart F, or any other audit report?

A5: Consistent with 2 CFR §200.501- Audit requirements (d): Exemption when Federal awards expended are less than $750,000. A non-Federal entity that expends less than $750,000 during the non-Federal entity's fiscal year in Federal awards is exempt from Federal audit requirements for that year, except as noted in §200.503, but records must be available for review or audit by appropriate officials of the Federal agency, pass-through entity, and Government Accountability Office (GAO).

See also 2 CFR §200.503 - Relation to other audit requirements.

Q6: The NOFO requires at least one past performance reference which describes any contracts, grants, cooperative agreements which the applicant organization has implemented involving similar or related programs over the past three years. If an organization is a first-time applicant, are they excluded from qualifying for this Notice of Funding Opportunity?

A6: The Notice of Funding Opportunity, Narrative Components, encourages applicants to include at least one past performance reference in their proposal.

Q7: As per the NOFO, construction is not an allowable activity under this award. Will site preparation costs be allowable under this award?

A7: All applicants should submit their best proposals in accordance with the applicable sections of OMB 2 CFR 200 and 600 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

In accordance with 2 CFR §200.1, real property means land, including land improvements, structures, and appurtenances thereto, but excludes moveable machinery and equipment.

Real property requirements are in 2 CFR §200.310, §200.311, §200.316, §200.330, and §200.465 Q8: Please clarify that the traveling costs of the employees of local offices/subsidiaries of an applicant incorporated in the USA (US commercial firm) should be included under “In-Country” line item.

A8: In-Country travel would relate to travel within Vietnam, which is the priority region included in the Executive Summary section of the Notice of Funding Opportunity (NOFO).

Travel from the United States to Vietnam should be categorized as international travel. Travel within the United States should be categorized as U.S. based travel.

Q9: Please clarify that the costs of all BESS equipment such as battery module, battery management system (BMS), protection and monitoring equipment, transformers and switchgears, energy meters, SCADA, etc., will be included in the line item, “Equipment”.

A9: The Budget Guidance and Template for New Awards, included in the Related Documents section of the Grant Opportunity in Grants.gov, ESF-HOCHIMINH-FY2020-0102 provides the following explanation for equipment and supplies:

Under Budget Guidelines, tab 1 Equipment – provide justification for any equipment purchase/rental, defined as tangible personal property having a useful life of more than one year and an acquisition cost of $5000 or more. If equipment is replacing previous equipment, provide more information on equity among other projects or certification that the equipment is used solely for the intended project.

Supplies - Describe and/or list supplies that may be specific to the project from those supplies for general office use. Where general office supplies are being requested, provide types (photocopying, postage, telephone/fax, printing, etc.) of supplies, amount being charged and the percentage to the award. Generally, laptops, cell phones and printers less than 5K USD would be considered supplies.

Q10: Please clarify that no separate “Sub-Recipient Budget” will be required for local contractors and consultants hired for conducting an Environmental Impact Assessment (EIA), grid impact study (GIS), facility study (FS), design review, or similar activities for the BESS pilot project.

A10: All applicants should submit their best proposals in accordance with the applicable sections of OMB 2 CFR 200 and 600 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

The Budget Guidance and Template for New Awards, included in the Related Documents section of the Grant Opportunity in Grants.gov, ESF-HOCHIMINH-FY2020-0102 provides the following explanation for contractual costs:

Under Budget Guidelines, tab 1 Contractual – Inclusive of sub-recipients, contractors, and consultants. Both sub-recipients and contractors must be legally registered organizations and acquire a DUNS numbers (certain exceptions apply). Contractors/consultants purely for procurement of goods and/or services do not require a separate detailed excel breakdown. Sub-recipient line-item budgets should be submitted in a separate tab with the same level of detail for all line items (personnel, travel, supplies, etc.) required of the prime recipient. Sub-recipient budget narratives may be incorporated into the prime recipient budget narrative or in a separate document. Similar to the prime recipient budget narrative, detail should be provided on how costs were calculated, staff responsibilities, and specific activities being supported. Assistance in the form of in-kind materials or direct payments for services may be considered for informal/unregistered groups and should be itemized under Line H.

· Subrecipients: A subaward is for the purpose of carrying out a portion of a Federal award and creates a Federal assistance relationship with the subrecipient. See §200.92 Subaward. Subrecipients agreements are subject to §200.331 Requirements for pass-through entities.

· Contractors: A contract is for the purpose of obtaining goods and services for the non-Federal entity's own use and creates a procurement relationship with the contractor. See §200.22 Contract.

Q11: Please clarify that the costs of all site activities such as civil works, BESS equipment installation, grid interconnection, testing, and commissioning should be included in this line item.

A11: All applicants should submit their best proposals in accordance with the applicable sections of OMB 2 CFR 200 and 600 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

The Budget Guidance and Template for New Awards, included in the Related Documents section of the Grant Opportunity in Grants.gov, ESF-HOCHIMINH-FY2020-0102 provides guidance on contractual costs, supply costs, and equipment costs in the Budget Guidelines, tab 1.

Q12: The SF-424 form requires Applicant Identifier and Federal Entity Identifier (separate from the DUNS number). Although it doesn’t seem to be mandatory fields, what number can use?

A12: Applicant Identifier is an optional field in the SF-424 Form, it is a unique identification number created by the applicant for their own purposes.

Federal Entity Identifier is an optional field in the SF-424 Form, it is a number assigned to organizations by a Federal Agency.

Q13: In the SF-424 form, question 19, Is Application subject to review by State under Executive Order 12372 Process?

A13: No, the application is not subject to review by State under Executive Order 12372 Process.

Q14: Form SF-424A BUDGET INFORMATION - Non-Construction Programs: as per the instructions, this form should reflect the appropriate amounts of funds needed to support the project for the first funding period (usually a year). Can you please confirm if we should include the funding needs for the entire period of the program (4 years) or for only first year? It seems Sections A-D cover the first year only, while Sections E-F cover subsequent years?

A14: The SF-424A form should include the estimated federal funds for the entire period of performance (4 years).

Sections A-D should include the estimated federal funds for the entire period of performance.

Section E - BUDGET ESTIMATES OF FEDERAL FUNDS NEEDED FOR BALANCE OF THE PROJECT (optional) is the section where the estimated federal funds for each year can be entered.

Q15: Form SF-424A: What is meant by “Grant Program Function or Activity” in Section-A of this form?

A15: The Grant Program Function or Activity is Battery Energy Storage System Pilot (BESSP).

Q16: Form SF-424A: Should cost sharing be entered in the “Non-Federal” column in Section-A, and “Applicant” column in Section-C?

SECTION A – BUDGET SUMMARY: leave Column (c) and (d) blank it is not applicable to this project. Enter the cost share or matching funds in Column (f).

SECTION C – ON-FEDERAL RESOURCES, 8-b.,Applicant Contribution for Non-Federal Resources: Enter cost share or matching funds provided by the applicant for the project. If not applicable, leave blank.

Q17: Form SF-424A: Is Section-B meant to cover the aggregate of Federal and Non-Federal budget, or only the Federal Budget?

A17: Section B -Budget Categories, in the column headings (1) through (4): fill in the estimated total amount for each budget category for both federal and non-federal funds.

Q18: Form SF-424A: Section-B, question 7, Program Income: Are we supposed to estimate such revenues and disclose it here?

A.18: The Program Income field is optional. The applicant may enter the estimated amount of total income, if any, expected to be generated from this project. If not applicable, leave blank.

Q19: Form SF-424A: Please confirm if Section-F requires budget for first year only or for the entire 4-year program period?

A19: Section F requires budget information for the entire period of performance (4 years).

Q20: Form SF-424A: what is the nature of the Indirect Costs? Can for-profit/commercial entities use 10% of MTDC for indirect costs? What actual costs items could be reported (during the program period) under this category?

A20: For-profit entities may have a formally established overhead or General and Administrative (G&A) rate, which should be included with their application and considered when determining indirect costs.

For-profit recipients who do not have a formally established overhead or G&A rate should allocate indirect costs into the appropriate direct cost categories, as described in OMB 2 CFR 200 and 600 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

Q21: As part of our application submission on Grants.gov, we will be uploading a few documents. Do we have to follow any specific rules how to name such files?

A21: There are no rules for naming files in Grants.gov.

Q22: Is incorporation cost of a Special Purpose Entity, under which the BESS project will be developed and held, an allowable cost under this grant funding?

A22: Per 2 CFR §200.455 Organization costs.

Costs such as incorporation fees, brokers' fees, fees to promoters, organizers or management consultants, attorneys, accountants, or investment counselor, whether or not employees of the non-Federal entity in connection with establishment or reorganization of an organization, are unallowable except with prior approval of the Federal awarding agency.

Q23: Can we submit a PDF copy (instead of the word document) of the proposal narrative and budget narrative?

A23: Yes, you can submit a PDF copy of the Proposal.

No, the Budget Narrative should not be submitted in a PDF copy, the Budget Narrative should be in a Word Document.

Q24: Can we lock the budget template (excel worksheet) before uploading it on the Grants.gov portal? The excel template will then become a “read-only” document.

A24: The budget document should be in a format that allows for revisions.

Q25: Will payment allocations be used for this award? Is money typically given to a recipient every few months based on progress?

A25: Payments are issued based on the progress of the project and allowable expenses of the project.

Q26: Is 2 CFR 200 Subpart F—Audit Requirements, applicable to foreign entities?

A26: Foreign non-profit and for-profit organizations that expend $750,000 or more in Department of State funds in the organization’s fiscal year, whether as a prime or a subrecipient, are required to undergo a recipient-contracted single or program-specific audit annually.

Foreign non-profit and for-profit organizations or subrecipient organization that expend less than $750,000 in its fiscal year, will be assessed by the Grants Officer and Federal Assistance Team at the Department to determine if a financial and/or a program audit should be performed to verify financial accountability.

Q27: Is there a funding cap or minimum amount for the hardware equipment that should be used?

A27: There is no funding cap or minimum amount for the hardware equipment that should be used but the total project budget should not exceed the total funding available, $2,962,000 U.S. Dollars.

Q28: Do subrecipient need to have a DUNS number by the application deadline?

A28: Subrecipients are required to obtain a UEI (currently a DUNS number), unless the criteria for an exemption are met and approved by the Grants Officer. The prime recipient is required to check SAM.gov and document that no active exclusions prevent the subrecipient organization from receiving Federal funding. Please see other vetting requirements described in the U.S. Department of State Standard Terms and Conditions located at: https://www.state.gov/about-us-office-of-the-procurement-executive/ Q29: Budget: Please clarify if the cost of Equipment which includes BESS and BESS installation costs, can be included in the Modified Total Direct Cost (MTDC) when claiming up to 10% as Indirect Charges.

A29: Equipment is excluded from the Modified Total Direct Cost (MTDC) calculation per 2 CFR §200.1 – Definitions:

“Modified Total Direct Cost (MTDC) means all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000. Other items may only be excluded when necessary to avoid a serious inequity in the distribution of indirect costs, and with the approval of the cognizant agency for indirect costs.”