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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

March 14th, 2009 · by Jake Seliger · 1 Comment

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 …”.

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