Tag Archives: ARRA

The Investing in Innovation Fund (i3) Notice Inviting Applications Finally Appears

NOTE: The Notices Inviting Applications (NIA) for Fiscal Year 2011 are now available. It took the Department of Education a year and three months to issue the second round, but I suppose that’s better than never.

Subscribers to our e-mail grant newsletter saw that the Investing in Innovation Fund (i3) RFP was (finally) released on Friday by the Department of Education, with a deadline of May 11. We’ve already written about i3 twice, including a post about its similarity to other Department of Education programs, like Goals 2000. We’ve also found one nasty trick in the RFP in our first reading.

Virtually every Department of Education RFP has a section at the start that clearly states what types of organizations are eligible applicants. This one doesn’t. Instead, the i3 RFP says on page 8 of 29 that:

Applicant means the entity that applies for a grant under this program on behalf of an eligible applicant (i.e., an LEA or a partnership in accordance with section 14007(a)(1)(B) of the ARRA).

What’s a partnership? Are nonprofits on their own eligible? If you find section 14007 in the American Recovery and Relief Act full text, you’ll see that the legislation is completely clear that an eligible entity is:

(A) a local educational agency; or
(B) a partnership between a nonprofit organization and—
(i) one or more local educational agencies; or
(ii) a consortium of schools.

(Emphasis added.)

So an LEA has to be involved for a nonprofit to apply, but presumably several schools could apply even if their respective districts were not involved in the project. Interesting, but curious. The text at the very beginning of the RFP lists the entities blockquoted above but doesn’t specifically say they are the eligible organizations. There are probably other gotchas too, despite the fact that ARRA was passed in February 2009. We first wrote about i3 in November 2009. The proposals won’t be reviewed until July 2010—almost 18 months after ARRA, which was designed to provide immediate stimulus fund to the economy, passed in Congress.

Another notable aspect to the i3 application process is that the grant writer has to understand the relevant sections of 407-page ARRA, the 29-page RFP, the 76-page application with lots of complex forms, and (get ready for it) the 212-page Final Priorities Notice. While i3 is a great opportunity with tons of money up for grabs, preparing a technically correct proposal will be fantastically complicated and not for the faint-of-heart or inexperienced grant writer. If you’ve never written a Dept. of Education proposal before, this is not a good starter. Isaac uses three monitors as a matter of course; I use two; but you probably need five to have all these documents open at once. Writer beware.

Late August Links: Unintended Consequences, Multitasking, Government, Stimulus Madness, and More

* Isaac predicted that YouthBuild will run a new competition rather than use earlier grants; it looks like other parts of the federal government have done the same in response to the Stimulus Bill, with the Teacher Quality Partnership Grants Program Recovery Act (ARRA) coming for another round of action.

* Speaking of schools, Steven Brill’s The Rubber Room: The battle over New York City’s worst teachers should be required for anyone interested in schools, teachers, charter schools, or grants related to education; it also describes one of many reasons I’m not a teacher.

* Telecom companies were rushing to meet the Aug. 14 BIP and BTOP deadlines, according to Business Week. This means they didn’t plan ahead: Seliger + Associates was not rushing to meet those deadlines for our clients.

* Speaking of fiber, Ars Technica says rural telcos are rolling out fiber to the home (ftth) while their urban counterparts languish with cable and DSL.

* I sent an e-mail to GAO report author Stanley Czerwinski on the subject of Grants.gov and our many writings about it over the past three years, figuring that he might be interested in people who actually use Grants.gov regularly and therefore probably know more about its flaws than anyone else. A guy named David Fox, who is a “Senior Analyst, Strategic Issues,” wrote back to say:

Thank you for contacting us about our recent report on Grants.gov. My director, Stanley Czerwinski, asked that I respond to your inquiry. We appreciate that you took the time to comment on our report and make us aware of your blog. As you may already know, we have issued several reports on Grants.gov and e-Government over the last few years. We will add your name and contact information to our distribution system so that you receive notice of any future work on Grants.gov.

Thank you again for your interest in our work.

This is an improvement over the e-mail I got from Tom Harrington of FEMA regarding the Assistance to Firefighters Grant Program, but in terms of form it still reminds me of Roger Shuy’s book, Bureaucratic Language in Government and Business.

* More from the busy department of unintended consequences: “The New Book Banning: Children’s books burn, courtesy of the federal government.” This is because the Consumer Product Safety Improvement Act of 2008 (CPSIA) stops the selling of used children’s good produced before 1985, when lead was banned, unless those products conform to the post-1985 standards. Although lead in children’s books hasn’t been shown to be harmful, the books don’t pass muster anyway.

I am generally not an organized political person who writes angry letters to Congresspersons and such, but this might be worth an exception. Furthermore, see this post regulatory processes at their worst regarding the legislation in question. It’s hard not to admire Mattel’s Machiavellian expertise even as one abhors their ethics or lack thereof.

(Hat tip to Megan McArdle.)

* William Easterly on How it helps to teach NGOs as selfish. One might replace “NGOs” with “nonprofits” and make the same argument.

* No one actually multitasks. I agree.

* The Wall Street Journal warns of unintentional consequences from the Treasury Department’s efforts to regulate financial institutions:

Here’s a stumper: In the Treasury financial reform proposal, who comes in for more regulatory retooling: Fannie Mae, or your average 14-man venture capital shop? If you said venture capital, you understand why one of America’s greatest competitive advantages is now at risk in Washington.

(Compare this to Paul Graham’s comment in The Venture Capital Squeeze, when he says that venture capitalists should “lobby to get Sarbanes-Oxley loosened. This law was created to prevent future Enrons, not to destroy the IPO market. Since the IPO market was practically dead when it passed, few saw what bad effects it would have. But now that technology has recovered from the last bust, we can see clearly what a bottleneck Sarbanes-Oxley has become.”)

* The criminalization of poverty.

* Read Lev Grossman’s novel The Magicians, which is excellent, as further described at the link.

* On criminals and signaling.

* Needle exchanges are effective—and the politics of “ick.”

* It was once a rule of demography that people have fewer children as their countries get richer. That rule no longer holds true.

* Cash for Clunkers is a clunker, says CNN commentator and painfully bad headline.

* Can Jazz Be Saved? The audience for America’s great art form is withering away.

* Stimulus Slow to Flow to Infrastructure, says the Wall Street Journal. The subhead could also say, “Duh.”

Fake Requests for Proposals (RFP) Notices Gain Popularity

When I was a kid, Isaac liked to quote the famous line from Ian Fleming’s James Bond book, Goldfinger: “The first time is happenstance. The second time is coincidence. The third time is enemy action” (that’s how I remember it, anyway, and I don’t have a copy of Goldfinger handy to check the quote). Actually, Isaac still says that not infrequently, and I’m going to appropriate it for this post, since I’m noticing a pernicious trend in the form of fake grant announcements, or announcements of announcements, in the Federal Register.

We discussed this particular irritating brand of federal idiocy in “A Primer on False Notes, Close Reading, and The Economic Development Administration’s (EDA) American Recovery and Reinvestment Act (ARRA) Program, or, How to Seize the Money in 42 Easy Steps:”

There’s also another other curious thing about th[e] March 5 announcement: it was an announcement of an announcement: “Under a forthcoming federal funding opportunity (FFO) announcement, EDA will solicit applications for the EDA American Recovery Program under the auspices of PWEDA.” This is like sending an announcement of a forthcoming invitation to a party—why not simply make the announcement, especially since the two followed each other within days? The situation could be fundamentally irrational, or there could be some unknown statutory requirement hidden in the legislative language, or someone at the EDA could have simply been tipsy while entering Grants.gov information.

Non-RFP RFPs, or non-announcement announcements, seem to be becoming more popular, like the outbreak of swine flu. Reading Grant Writing Confidential will help immunize you from this malady, but not from the itching, sweating, and swearing it might cause. For another example of it, check out the Solicitation for Proposals for the Provision of Civil Legal Services, which says: “The Request for Proposals (RFP) will be available April 10, 2009.” But April 10 has come and gone, and as far as I can tell a genuine RFP still hasn’t arrived. Now we’ve passed happenstance and entered the land of circumstance.

But the latest iteration of my favorite program to pick on, the Assistance to Firefighters Grants Program (AFG), includes this in its first full paragraph on page two:

The American Recovery and Reinvestment Act of 2009 provided $210 million in funding to DHS to construct new fire stations or modify existing fire stations. That funding opportunity will be announced in the near future and will NOT be part of this offering. Under the funding opportunity presented in this guidance, the AFG will only fund projects that do not alter the footprint or the profile of an existing structure. Projects for modifications that involve altering the footprint or the profile of an existing structure or projects that involve construction of new facilities will fall under a different funding opportunity.

(See some earlier posts on the AFG here and here.)

As Goldfinger would say, this is now enemy action. I wouldn’t be surprised if phantom announcements become more common as the kinds of deadlines buried somewhere in the Stimulus Bill American Recovery and Relief Act approach federal agencies like a swarm of swine flu virus particles from a gigantic congressional sneeze.

No More Ball of Confusion: The Reality of the Grant Making Process is Really Simple and I’m the Guy to Explain It to You

  • In the April 20, 2009 Wall Street Journal, Elizabeth Williamson wrote “Stimulus Confusion Frustrates Business,” in which she states “Confusion over how to go after money allocated to various stimulus programs appears to be clouding corporate efforts to plan ahead . . .”
  • In the April 12, 2009 New York Times, Kirk Johnson wrote “Waving a Hand, Trying to Be Noticed in the Stimulus Rush,” which concerns a nonprofit group stumbling around looking behind the refrigerator looking for stimulus funds like our faithful Golden Retriever, Odette, sniffing after the scent of the salami she was tossed yesterday, and thinking, “it’s just got be here somewhere.” Kirk states, “Whether the stimulus even has a place for the ideas [the nonprofit] is pursuing is not clear.” Both the reporter and the nonprofit smell the grant salami, but can’t quite find it, while Odette eventually gives up and rolls on her back.

Sense a trend? I could cite a dozen other similar stories in which talented reporters interview presumably bright individuals, none of whom find the Stimulus Bill salami, but you get the idea: no one in the media is writing “how” stories about the ways federal funds are distributed. Instead, endless “who,” “what,” “where” and “when” articles are published, leaving readers to assume the whole process, is, as the Temptations sang when I was in high school in 1968, just a Ball of Confusion. To quote:

Evolution, revolution, gun control, sound of soul.
Shooting rockets to the moon, kids growing up too soon.
Politicians say more taxes will solve everything.
And the band played on.
So, round and around and around we go.
Where the world’s headed, nobody knows.
Oh, great googalooga, can’t you hear me talking to you.
Just a ball of confusion.

Every time I see a “ball of confusion” story about the Stimulus Bill, I write the same note to the reporter . . . “call me and in 15 minutes, I will explain how federal funding actually is distributed.” Few call, perpetuating the “ball of confusion” story line. Like Tiny Mills, my favorite professional wrestler when I was a kid growing up in the late ’50s in Minneapolis, used to say when being interviewed by announcer Marty O’Neil, “I’m all burned up, Marty, I’m all burned up.” Since I’m all burned up about the slipshod Stimulus Bill reporting, here is the shorthand version of the federal funding process (and even this is a slightly simplified version):

  • Imagine Barney Frank (if you are a Democrat) or John Boehner (if you are a Republican) waking up one morning with a bright idea to solve some real or imagined problem in American by taking money from Peter to help Paul.*
  • The bright idea is turned into a bill, which both houses of Congress pass and the President signs.
  • Funding authorization for the newly minted program is included in a budget authorization bill. In some cases, the legislation creating the program and funding are in the same bill. The recently passed ARRA (“Stimulus Bill”) both creates new programs with funds authorized for the new programs and authorizes additional funding for existing programs. An example of the first case is the Department of Energy’s Smart Grid Investment Grant (SGIG) Program, which was originally created in 2007 but substantially modified with additional funding in the ARRA. An example of the second case is the Department of the Treasury’s Community Development Financial Institutions (CDFI) Program, which received an extra $100 million under the ARRA. A new NOFA was just issued with a deadline of May 27.
  • The new program is assigned to a Federal agency, which in turns assigns existing or new staff as Program Officers for the program.
  • Along with the requisite donut eating and mindless meetings, draft regulations are written and passed among Beltway types (e.g., legislation staff, “evil” lobbyists, interest groups, etc.) for informal review and comment. After the draft regulations are made as obtuse as possible, they are published in the Federal Register for public comment, usually for 30 days.
  • Final regulations are then published, usually featuring detailed explanations of why all the public comments are stupid and pointless, meaning the final regs are generally about the same as the draft regs. This is because interested parties have already taken their shots during the informal review process and Program Officers don’t care about what folks in Dubuque think anyway. It may take a federal agency anywhere from 30 days to 180 days to publish draft regs, and the review comment period is usually 30 days. The final regs will usually appear about 30 – 60 days later. The SGIG Program mentioned above is still in the informal regulatory review stage. A client sent us the draft regs, and they are a mess (the reasons why would be a post in itself). The FOA is being drafted simultaneously with the regs to speed up the process and the FOA is supposed to be published in June.
  • After the program regs are finalized, there are two possibilities, as follows:
    • (1) If the program is a federal pass-through to the states, the money is made available for the states to distribute, using an existing or new system, and based on some formula. Most of the so-called “infrastructure” funding in the Stimulus Bill was allocated this way, allowing the feds to more or less wash their hands of the process and say, “we’ve allocated the money with lightening speed and it’s not our fault if the states are too dumb to spend it quickly.” These pass-through Stimulus Bill funds go the relevant agencies in each state, with highway construction funds to the State Transportation Department, water/sewer funds to the State Water Department, UFO landing strip construction funds to the State Department of Extraterrestrial Affairs, and so on. I will eventually write a detailed post on how states distribute funds, but I digress.
    • (2) If the program involves direct submission to the federal agency, the Program Officers draft a RFP/NOFA/SGA/FOA or what have you, which is the document that applicants will actually use as the guidelines for spinning their tales of woe and need. RFPs are sometimes published in the Federal Register, made available through Grants.gov, FedBizOpps.gov, and/or in even more obscure ways. As Jake has previously noted, Grants.gov is the central repository for all Federal grant information, except when it isn’t.**
  • Applicants prepare and submit proposals in response to the RFPs. This is what Seliger + Associates does endlessly. Depending on the funding agency, the amount of hysteria surrounding the grant program and the underlying problem it is supposed to solve, the length of time allowed for submission varies from about two weeks to three months, with 45 days being typical. In the case of new programs, where new regs and RFPs have been drafted, one can usually expect several modifications to the RFP to be published, as mistakes and inconsistencies are identified. Since we spend much of our time deciphering arcane RFPs, we often have the thankless task of letting the Program Officer know that they have screwed up their RFP. In making these calls, we usually receive snarls and growls, not attaboys in return. We don’t do this out of civic duty, but to protect our client’s interest by not having the Program Officer declare a do over and start the RFP process again.
  • Once the RFP deadline arrives, the process submerges into the murky waters of Washington, but the review process goes more or less as follows:
    • 1. Applications are “checklist reviewed” to make sure the applicant is eligible, the forms are signed, etc. In most cases, if the application is technically incorrect, it is summarily rejected. You do not pass Go and you do not get $200, but you will eventually get a charming “thanks for the lousy application” form letter. Certain funding agencies, such as HUD, may send a deficiency letter, giving the applicant one more chance to sign the forms or what have you.
    • 2. Applications that pass the technical checklist are reviewed on “merit.” These reviews can be done by the Program Officers, by “peer reviewers” (nonprofit and public agency managers lured to Washington by per diem and a $100/day honorarium) or by other Federal employees dragooned into the task. The last is the worst alternative, because the shanghaied bureaucrats will know nothing about the program and will be annoyed at having been roused from their slumber. Think of Smaug the Dragon in The Hobbit, who always slept with one eye half-open.
    • 3. The applications will be scored on some scale and, in most cases, allegedly against criteria in the RFP. The applications will be ranked by their score, at which point our old friend, politics, rears its ugly head again. Most RFPs contain language along the lines of “The Secretary reserves the right to make funding recommendations based on geography and other factors.” While the Secretary of Whatever can basically fund any agency she bloody well feels like, as a practical matter this means that the funds are spread to many states for applicants in big cities, towns and rural areas and for projects that are perceived to help certain populations of interest. One could have a highly ranked application but still not be funded due to the vagaries of the approval process. If it is good news, the applicant might get a congratulations call from their House Rep or Senator’s office before the notice of grant award letter shows up. Some our of clients have reported reading press releases in local papers from their elected representatives before they were officially notified of being funded. While most Federal agencies aim for about a 90 day review process, about three – nine months is more typical. Using six months is a good standard.
  • The grant award letter will include instructions to contact the Budget Officer who has been assigned to the application. This being the Federal government, the award being offered may be the exact amount requested, or less than requested, or even more than requested.
  • You’re not done yet because the applicant must “negotiate” a contract with the Budget Officer. If the Budget Officer thinks the budget originally submitted was not prepared in accordance with Federal budgeting rules, or is just having a bad day, he will demand that you modify your budget or prove that it is reasonable. I have lots of funny stories about this process, but will save them for future posts. After the budget is agreed, the rest of the contract is negotiated. Allow two months for the contracting process.
  • Congratulations, you’ve fallen across the finish line. Since Federal funds cannot usually be expended before contract is signed, most recipients will not begin project implementation until the money is actually available, so another three months can be added to hire staff, teach them where the restrooms are, arrange for donuts to be delivered for weekly staff meetings and the like. Keep in mind that, if the money is for construction of something, add additional time for environmental reviews, permits, bidding and yet more contracts!

How much time is likely to go by before funds for new programs in the Stimulus Bill actually start stimulating something other than reporter’s imaginations? Adding it all up, I’ve got:

  • 3 months to develop regulations
  • 2 months to develop the RFP
  • 1.5 months for submission of applications
  • 6 months for application review
  • 5 months for contracting/start-up activities

If all goes right—and it almost never does—it takes at least one year for a Federal grant program to move from congressional approval/budget authorization to walkin’ around money for nonprofits. Keep in mind that this is for a program involving direct Federal competition. In the case of state pass-through programs, an additional one to three years can be added, depending on state budgeting and other processes. We’ll be writing “Stimulus Bill” proposals in the twilight of President Obama’s first term!


* As George Bernard Shaw famously quipped, “The government who robs Peter to pay Paul can always depend on the support of Paul.”

** The CDFI Program is a good example of how Federal agencies sometimes “forget” to publish their grant opportunities in grants.gov or the Federal Register. As noted above, the Department of the Treasury received $100 million in extra Stimulus Bill funds for this program and decided to use $45 million to fund additional applications for the last funding round, which closed in October. The funding announcements for the October round have not yet been made, so for those of you counting, six months has gone by since the application deadline. Even though there is much gnashing of teeth in the media about banks not lending, the Treasury Department itself is taking forever to get its funds on the street.

The other $55 million in CDFI Stimulus Bill funds have been set aside for new applicants in a supplemental funding round, which has been rumored for two months. The NOFA was finally issued on April 21, with a deadline of May 27, but was only placed on an obscure part of the CDFI web site, if one drills down to “News and Events.” It is not listed on the “How to Apply Page,” which includes timely info on the deadline for last October. Nor was it published on Grants.gov or in the Federal Register. If there are any aspiring Woodward or Bernstein type investigative reporters out there, you might want to find out why the Department of Treasury did as little as possible to let potential applicants know about this very sweet pot of gold. With all the fuss and bother over the Stimulus Bill, one would have thought the Department of the Treasury would have been trumpeting the availability of these funds.

A Primer on False Notes, Close Reading, and The Economic Development Administration’s (EDA) American Recovery and Reinvestment Act (ARRA) Program, or, How to Seize the Money in 42 Easy Steps

All three of you masochistic enough to read the Federal Register on a regular basis might have noticed that the Economic Development Administration (EDA) posted a couple of notices about the American Recovery and Reinvestment Act of 2009 Recovery Act Funding, which exemplifies many of the trends we’ve been discussing while also showing that it’s business as usual at EDA. To explain why this announcement is particularly sneaky, we’ll have to explain it and how EDA works.

The Grants.gov notifications says:

EDA is soliciting applications for the EDA American Recovery Program under the auspices of [the Public Works and Economic Development Act of 1965] PWEDA. Specifically, the [RFP] pertains to applications for funding under EDA’s Public Works and Economic Adjustment Assistance programs only.

Ah ha! Money for economic development and job training. This sounds like a new program—but it’s not, or at least not as new as it sounds. To the uninitiated, this seems like a standard announcement for a federal program except for the rolling deadline. The sneaky part comes from the way EDA funds projects: rather than accepting a batch of proposals in response to a set deadline/RFP process, grading them, and then issuing funding notices, EDA requires that you apply to the “Economic Development Representative” (EDR) for your region (you can find a list of them at the bottom of the “Announcement of Federal Funding Opportunity” (FFO) (warning: .pdf link), which is yet another way of saying RFP). EDA has used more or less the same byzantine funding system since the late 1960s, which the application explains on pages 12 – 13 with all the traditional clarity of federal lingo. We’ll break it down in steps:

Each application package is circulated by a project officer within the applicable EDA regional office for review and comments. After all necessary information has been obtained, the application is considered by the regional office’s investment review committee (IRC), which is comprised of regional office staff. The IRC discusses the application and evaluates it…

So you submit the application, the EDR reviews it, and “checks it for eligibility,” according to Arizona and Western Washington EDR Jacob Macias, who I spoke to via phone on Wednesday, March 11 (he’ll appear later in this story).

Assuming your EDR accepts the initial proposal:

The IRC recommends to the Regional Director whether an application merits further consideration, documenting its recommendation. For quality control assurance, EDA Headquarters reviews the IRC’s analysis of the project’s fulfillment of the investment policy guidelines set forth below … After receiving quality control clearance, the Selecting Official, who is the Regional Director, considers the evaluations provided by the IRC and the degree to which one or more of the funding priorities provided below are included, in making a decision as to which applications merit further consideration.

To summarize: you submit the application to the EDR. The EDR obtains the necessary information. The IRC reviews the application. If the IRC thinks your app is kosher, it goes to the Regional Director, and, apparently, to the EDA’s headquarters. Oh, yeah, and:

To limit the burden on the applicant, EDA requests additional documentation only if EDA determines that the applicant’s project merits further consideration. The Form ED-900 provides detailed guidance on documentation, information, and other materials that will be requested if, and only if, EDA selects the project for further consideration. EDA will inform the applicant if its application has been selected for further consideration or if the application has not been selected for funding.

That bolded section is critical. In words other than those used by the RFP, the initial submission is really a pre-application: you’ll be submitting what amounts to a letter of interest or a letter of intent to the EDR, along with a few forms, to see if he or she (I’ll go for “he,” since I spoke with Macias) wants you to submit a full proposal. If he doesn’t, you’re screwed. He’s the first gatekeeper. When potential clients call to discuss applying to EDA, Isaac tells them that they effectively have to be “invited” by their EDR, since if they’re not invited in some way there’s no point in chasing EDA money; only if the EDR likes your project, you have juice in Washington, or you have juice with the Regional Director should you pursue it. Once you’re invited to submit a full proposal, in most cases, the project will eventually be funded, although it may languish in the pipeline waiting for EDA to get additional appropriations.

But if you don’t read the passage above carefully and know how EDA tends to work, you might end up submitting a full proposal that’ll never be funded. And one reason you need your EDR behind the project is that EDA already has a bunch of proposals that could be sped or slowed or funded or not at the pace of EDRs. When I called Macias earlier this week, he said that he had “a number of proposals in here” in various stages of completion that need to be “cleaned up” or are missing documentation or whatever.

Unlike other federal proposals, with EDA you don’t just send everything you’ve got and that’s that: there’s a bunch of back and forth. Suddenly, the standard deadline system of most federal grant programs begins to look pretty good, since they’re built on the gladiator model in which the Emperor (or, in this case, program officer) simply gives your project a thumbs up or thumbs down. You enter the grant arena, say “Morituri te salutant” (“Those who are about to die salute you”) and find out what happens.

Anyway, Macias thinks that “maybe five” EDA applications have been sent to DC and still not wholly funded. There are seven EDRs for the Western region. If he’s representative of the whole, that means there are 35 or more applications sent to Washington D.C. but still unfunded. And that’s only a single region, which includes the megatropolis of California, where there are no doubt more projects than Arizona and Western Washington. Macias couldn’t even tell me how many projects had been submitted in the Western Region. He’s probably right that no one really knows the answer; it could be as high or as low as the EDRs want it to be, or as high and as low as the funding allows. The important thing from the perspective of an applicant is that some of those projects being “cleaned up” could probably be cleaned up really, really quickly if necessary.

Another question: why does no one know the answer to this question? Wouldn’t it be in EDA’s best interest to know so they can plan accordingly? Wal-Mart tends knows how many pairs of socks it has at every location and Dell magically gets almost every computer order right. But the EDA doesn’t seem to know, or at least Macias isn’t telling if they do, but I’d tend to take his assertion at face value. In the new found federal interest in transparency, one wonders why EDA doesn’t just post a list of pending projects by region on their website, so that applicants could better determine their chances of being funded before cozying up to the EDR with flowers and chocolates. I may submit a FOIA request to EDA to see just how many projects are already waiting to be funded and how that compares to the amount of money just announced. When I get an answer, I’ll post it.

Whatever the number of unfunded EDA projects, it’s probably high enough that, with a stimulus-related cash infusion, EDA could probably simply fund more projects in the pipeline rather than encourage new proposals if the organization felt so inclined. So your EDR better believe in your project if you want to be funded. That’s just how it goes, and the RFP is something of a slight-of-hand trick, since you still have this Texas two-step to get the money. The EDA programs are continuing opportunities for which there always some amount of funds available. Thus the announcement in question is misleading, if not outright disingenuous.

But if you haven’t been dealing with EDA for years, you wouldn’t know the deal and might take the announcement at face value. Isaac confirmed the actual nature of the EDA beast in a conversation he had this week with highly placed manager in a state economic development office, which is considering hiring us to write some of their ARRA proposals. The topic turned from the Department of Labor to EDA, at which point this fellow, who also has years of experience with EDA, described EDA as a “heiney-kissing” exercise requiring lots of trips to the regional office to sweet talk the EDR and Regional Director.


 

These EDA issues are also indicative of what Isaac wrote earlier in “Stimulus Bill Passes: Time for Fast and Furious Grant Writing“:

… [I]t’s going to take quite a while to get the money to the streets. Most Federal agencies usually take anywhere from three to six months to select grantees and probably another three months to sign contracts. My experience with Federal employees is that they work slower, not faster, under pressure… there are no bonuses in the Federal system for work above and beyond the call of duty.

This program shows how long it will take the funds to hit the street for a new applicant, since the EDA pipeline is frequently a long one, running as it does from the local EDR to the Regional Director to Washington back to the Regional Director and back to Washington, with each one taking a piece along the way;* it’s like writing a dissertation, in which every committee member must be satisfied before you can graduate.

In addition, notice some key words in the EDA’s initial, March 5 announcement of the Recovery Act Funding: “[I]t takes a minimum of 90 days from EDA’s receipt of a complete application until award, when funds are obligated.”

There’s also another other curious thing about this March 5 announcement: it was an announcement of an announcement: “Under a forthcoming federal funding opportunity (FFO) announcement, EDA will solicit applications for the EDA American Recovery Program under the auspices of PWEDA.” This is like sending an announcement of a forthcoming invitation to a party—why not simply make the announcement, especially since the two followed each other within days? The situation could be fundamentally irrational, or there could be some unknown statutory requirement hidden in the legislative language, or someone at the EDA could have simply been tipsy while entering Grants.gov information.

The answer came from an EDA representative. Isaac traded some emails with Jamie Lipsey, the EDA contact person, about the pre-announcement announcement. She sent back the following to his initial query:

Under a forthcoming federal funding opportunity (FFO) announcement, EDA will solicit applications for the EDA American Recovery Program under the auspices of PWEDA. Specifically, the forthcoming FFO will pertain to applications for funding under EDA’s Public Works and Economic Adjustment Assistance programs only. EDA will not accept applications until the FFO is published. The FFO will be posted on www.grants.gov as soon as it is available.

When Isaac replied by essentially saying, “huh?”, Lipsey simplified it to this:

Perhaps I should have summed up: under the Recovery Act and guidance provided by the Office of Management and Budget (OMB), EDA was required to post the status of our recovery announcement on www.grants.gov by March 5, 2009. I believed the posting did that clearly in stating that the FFO announcement was forthcoming and that applications would not be accepted until it was published, which should happen next week.

Ah: so EDA got around the deadline through the pre-announcement. As so often happens, the agency protects its turf and itself, effectively executing the pre-announcement as a cover-your-ass (CYA) maneuver with the beauty of a dancer’s pirouette. I gave this post a long and convoluted title in honor of the length necessary to explain what the EDA is actually like.

Despite all the issues discussed above, EDA grants are still very much worth applying for, and if you’re interested in doing so you should call us. Isaac has been writing funded EDA applications for 30 years and knows how to warm the stone-like hearts of the elusive EDRs.


 

* Actually, the EDA application process can be even more complicated than summarized above and described in the FFO. In many cases, before the EDR will accept a pre-application, the project has to be ranked in the regional Community Economic Development Strategies (CEDS). The CEDS process replaced the former process, which was called the Overall Economic Development Planning (OEDP) process, in 1999. The FFO is silent on the subject of CEDS. Perhaps CEDS has gone the way of the OEDP, or maybe EDA is saving this nugget for the EDRs to drop on applicants. EDA is like the lyrics of the theme song of the 1968 movie classic (and the dopey 1999 remake), The Thomas Crown Affair, Windmills of Your Mind: “Round, like a circle in a spiral, Like a wheel within a wheel / Never ending or beginning / On an ever spinning reel …”.