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Questions and Answers

Transit Security Grant Program Tier I FY 2009

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Conferences and Workshops Questions and Answers

Emailed Questions and Answers - Revised 1/27/09

Conference Call Questions and Answers

Washington, DC Workshop 11/21/08

In the FY2009 TSGP Guidance and Application Kit, it is recommended that Freight rail operators should be added as members of the Regional Transit Security Working Groups (RTSWG). Has that already occurred in some regions? How do we include them? Do the freight operators apply separately?

Freight rail operators apply for grant funding under a separate grant program, the Freight Rail Security Grant Program (FRSGP), which is specific to Class I, II and III railroads that travel through at least one high population density area and freight rail car owners and offerors that transport Toxic by Inhalation Materials (TIH). Even though freight rail entities are not eligible to receive awards from the Transit Security Grant Program (TSGP), we recommend the participation of freight rail owners and operators in the RTSWG for the additional security value that they may add to the group, especially since transit agencies and freight rail operators often share the same infrastructure. We suggest that you invite them to become a member of the RTSWG and notify them of the next scheduled meeting. We should note however, that freight rail operators are under no obligation to participate as they are not recipients of TSGP funds and therefore, they are not bound by the same grant requirements. Along those same lines, you will not be held accountable if freight rail operators do not participate in the RTSWG.

Why does the guidance list additional transit agencies as eligible entities in some regions?

The list of eligible agencies has expanded in some regions and the names of the new agencies are included in the guidance. This expanded eligibility resulted from our blending of the Department of Transportation (DOT), Federal Transportation Administration (FTA) list of the top 100 transit agencies in terms of ridership and the Urban Areas Security Initiative (UASI) list. These agencies were included for the potential security value that they may add to your region. We recommend that RTSWGs extend an invitation to these agencies as well and unlike the freight rail operators, these agencies will be required to participate if they become Tier I TSGP award recipients in FY2009.

How do these new agencies weigh in or factor into a region's future funding decisions?

That is a question that we would like your feedback on. We requested your comments on a draft Information Bulletin (IB) we distributed that concerns the scoring and decision making process for RTSWGs. We are trying to design regional groups that are of the right composition for the region. RTSWG membership is optional for some members and it is up to them to determine how much or how little they participate. Typically, full membership comes with full voting rights. If you have any comments on the regional scoring and decision making process as proposed in the IB, please provide them to us by email at tsagrants@tsa.dhs.gov.

Has TSA conducted any outreach to the new Tier I agencies?

Yes. We used our transit agency contacts lists to reach out to the new Tier I agencies to send them copies of the grant guidance and other relevant application information.

If an agency chooses to include a cost match, is the match eligible for audit?

Yes, if you include a match in the investment justification (IJ) and project budget, the cost match is subject to a federal audit and you are bound by all grant regulations concerning cost matches. For the Tier II scoring process, agencies that choose to include a match are eligible for a half-point increase in their project score. For many Tier II agencies, the half of a point bump in score from the cost match means more to them than the auditing requirement. It is optional this year, but if you choose a match in project IJ and budget, it will be audited.

Can agencies begin to upload standard forms and other qualifying forms to grants.gov?

You could if the forms were currently available on grants.gov. Right now, grants.gov is not operational for the transit grants, so you cannot begin to upload any forms on grants.gov. FEMA is trying to resolve this issue with grants.gov and they will issue an Information Bulletin (IB) to notify you when they will be available.

You can however download the IJ template and budget template on the TSA website at www.tsa.gov/grants and begin the programmatic portions of your application.

Do you know when the forms may be available on grants.gov?

No, we do not know when grants.gov will be operational for the transit grants, but we will notify you as soon as we learn that the forms are available.

Are we required to use the OMB budget form with our Investment Justification (IJ)? Where can we find the form?

Yes. It is in your best interest to use the OMB detailed budget form from the very beginning. The form is required by FEMA and it must be completed before FEMA will review and approve your project budgets and issue the clearance memo (formerly known as the GAN—Grant Adjustment Notice). The form is available in the guidance, and a fillable word template is available on our website at www.tsa.gov/grants. Use the budget categories provided on the form as you complete your budget. If a budget category does not apply to your project, mark that category as not applicable (i.e. N/A). Do not add or delete budget categories as the form cannot be altered.

Do you have a checklist to assist us with navigating the FEMA budget review? Will FEMA request more information from us later on in the process?

To expedite the budget review process, you must use the OMB-approved Sample Detailed Budget Worksheet when completing your project budgets. A copy of the Sample Detailed Budget Worksheet is included in the FY2009 guidance and a fillable template of the worksheet is available on our website at: www.tsa.gov/grants. FEMA reviews the budgets for the allowability of the costs and does not audit individual budget categories. FEMA will contact you if they have questions or need further clarification on your budget.

Is there any flexibility in the January 13, 2009 application date?

All agencies are required to submit the necessary documentation on grants.gov by January 13, 2009, as this is a Congressionally-mandated date. All Tier I agencies must submit all standard forms (i.e. SF424s) and qualifying information, including certifications and assurances along with at least a draft IJ and detailed budget via grants.gov by 11:59 PM EST on January 13, 2009 to be considered eligible for TSGP funding. However, since Tier I agencies are awarded through cooperative agreements and not competitive grants, there is some flexibility in the date everything needs to be finalized. Tier I agencies have until February 13, 2009 to work with TSA to finalize their IJs and detailed budgets. All Tier I agencies however, must have their final projects submitted via the Secure Portal no later than February 13, 2009. There is no flexibility for Tier I agencies beyond that date. However, we strongly recommend that Tier I agencies try to finalize their projects as near to the January 13th deadline as possible instead of waiting until the February 13th deadline.

Tier II agencies do not have any flexibility beyond the January 13, 2009 deadline. Thus, Tier II agencies must submit all standard forms (i.e. SF424s) and qualifying information, including certifications and assurances along with a final IJ and detailed budget via grants.gov by 11:59 PM EST on January 13, 2009 to be eligible for TSGP funding. Also, due to the competitive nature of the Tier II program, TSA is not able to work collaboratively with Tier II agencies before the actual application due date.

What is the difference between the Secure Portal and Grants.gov?

Grants.gov is the centralized website that is owned by the federal government and serves as the application portal for all government grant programs. The Secure Portal is owned and maintained by FEMA and functions as a portal for certain documents, such as those related to Department of Homeland Security (DHS) grants.

Where can we find the OMB guidance? Is it the same as the OMB circulars?

Yes, the OMB circulars contain the OMB guidelines that govern federal grants. You can find the OMB guidelines in the financial administration section of the TSGP guidance.

In which budget category in the OMB Budget Form does Management and Administration (M&A) fall?

If you intend to take M&A, you must include it in your budget under the category "Other" and all M&A costs must be broken down in detail. M&A does not qualify as a separate project; it must be listed as a line item in the budget of each project. You will not be eligible for M&A if it is not listed in your project budget.

Is the 3-percent that is allowable for M&A 3-percent of each project?

Yes. Previously when the grants were awarded to the State Administrative Agencies (SAA), the 3-percent for M&A was taken off the top for Tier I regions. Now that the transit agencies are the direct grantees, the 3-percent for M&A must be written into the budget of each project in order for the agencies to recover the costs associated with the administration and management of the grants.

Is there an additional 3-percent for project management?

No. Three percent is the maximum that can be used for management and administration (M&A).

Should we revise our project concepts to include M&A?

M&A is itemized in the project budget only and does not need to be included in the project description.

Should an agency always request M&A?

It is in the agency's best interest to request M&A but any agency must include it in their detailed budget to receive it.

Is there any reference that an agency can use to help us with the Environmental and Historical Preservation (EHP) review?

We recommend using Information Bulletin #271 (IB #271) as a reference. This IB provides general guidance to grantees on environmental planning and historic preservation (EHP) requirements for grant funded projects involving communication towers, physical security enhancements, new construction, renovation, and modifications to buildings and structures that are 50 years old or older. A Statement of Work (SOW), as outlined in IB #271 is required by FEMA prior to the initiation of these projects. IB #271 is available for you to download at http://www.fema.gov/plan/ehp/ehp-applicant-help.shtm.

Furthermore, we suggest that you consider the potential environmental impact of your projects as you develop your project concepts. If your project is scalable, break it down into separate phases such as planning, procurement and installation to help expedite the EHP review. Otherwise, your project may be delayed at all stages.

Should agencies include the SOW for EHP in their project IJs?

Your project IJ should be your SOW. If you include the specifics of the installation and environmental information as outlined in IB #271 in your IJ, it could eliminate the need for you to submit additional information during the EHP review process and potentially shorten the EHP review process by weeks or months.

If our project involves the installation of equipment on a historical building, do we need the project to be approved by the State Historic Preservation Officer (SHIPO) before FEMA will review it? Is there a way to have the environmental reviews occur simultaneously?

You can submit the information to FEMA and the SHIPO at the same time so that it can be reviewed simultaneously.

If we include the environmental details of our projects in the IJ, do we still need to submit additional information to FEMA for the EHP review?

If you include the environmental information in the IJ as detailed in IB #271, FEMA will not ask for the same information unless some information is missing. If you provide these details upfront, FEMA can sign off on many projects that are Type A or Type B projects as long as the information is correct. Type C projects require a thorough EHP review. Examples of Type C projects include the construction of radio communication towers and the installation of camera on buildings or other infrastructure over 50 years old. For more information on the categorical types of projects that trigger an EHP review see IB #271, which is available for you to download at http://www.fema.gov/plan/ehp/ehp-applicant-help.shtm.

Are FEMA's requirements regarding the EHP review included in the grant guidance?

No. It is in your agency's best interest to follow IB #271 in relation to your SOW for the EHP review. FEMA is creating an EHP check list to assist applicants with understanding the EHP requirements. Before this checklist can be released however it must be approved by the Office of Management and Budget (OMB).

Can we send our environmental SOW to our FEMA program analyst before our projects are approved?

Yes. Your FEMA program analyst will accept your SOW.

Will the letter we receive authorizing us to draw down funds specify the date that the period of performance begins?

In prior years the state received an award letter that detailed the total award amount to the state for that fiscal year. The date on that letter indicates the beginning of the period of performance for that fiscal year. However, you will also receive a second letter for each of your projects, now known as a clearance memo (formerly known as a GAN), that will notify you as to which projects you can begin drawing down funds on. To be clear, the beginning of the period of performance is on the award letter, not the clearance memo.

How does the clearance memo relate to the cost of M&A and the development of the SOW? Can we retroactively deduct costs for M&A?

No costs incurred prior to the beginning of the period of performance are allowable. Pre-application and pre-award costs are not allowed.

Has the minimum for non-training projects changed?

No. The project minimum for non-training projects is $250,000. This has been the minimum for non-training projects for the last three years.

What amount do we put in the investment amount question on our IJ?

The investment amount is the amount of federal grant funds requested from TSGP for that project only. Do not include any cost share or other dollar amounts in this figure. Lastly, the investment amount must match the total project budget.

Who is the appropriate agency point of contact (POC) that should be listed in the Investment Justification?

The agency POC is the single authorizing official for the agency. This is the person who has signatory authority and the authority to bind the agency to grants or contracts. The process to change a POC can take a few weeks, so it is recommended that the POC be someone likely to be involved in the grant process throughout the course of the grant.

Is the FY2009 IJ Writing Guide available on line?

Yes. The IJ Writing Guide has been updated for FY2009 and is available on the TSA website at www.tsa.gov/grants.

Our system is very large and completing all of this background information is time consuming. Do we really need to complete all of this background information that is requested in the IJ?

Yes. The background information is a necessary part of the IJ and once completed, it may be copied from one IJ to another. We need to know what your agency currently has in place, what your needs are and where the gaps are in your current system. We also need to know what projects are ongoing and how they are impacting your system and infrastructure. For example, if your agency has under water tunnels, we want to know how many tunnels you have and any ongoing projects related to that infrastructure. We understand the sensitivity of the information. We are not looking for Sensitive Security Information (SSI); we do not need that level of detail. Instead, we are asking for a brief overview of your entire system to outline what has been done and what needs to be done to provide us with a sense of where you are and where you are going.

What level of detail is appropriate for disclosure in the IJ?

We are looking for information that is useful for putting your projects into context, which is not necessarily sensitive security information (SSI). The level of detail that is provided is at the agency's discretion however, it is important to note that the IJ is the main source of information for the review and evaluation of your project. For Tier II agencies, due to the competitive nature of the program, the IJ is the only source of information for the review panel. Tier I agencies may want to discuss the level of disclosure that is appropriate for the region in the Regional Transit Security Working Group (RTSWG).

If the agency has sensitive information they don't want to include in their IJ, will TSA assume the requested project is critical for the agency? Must we provide this information in the IJ?

The review panel that looks at the applications (Tier II) cannot make any assumptions. The IJ is the main source of information for the review and evaluation of your project. It is in your agency's best interest to provide a "complete picture" of your project. You do not want TSA or the National Review Panel (NRP) to make assumptions on incomplete or inadequate information. However, for Tier I agencies, we have the flexibility to obtain/disclose the information in a different manner than the IJ, as we have the ability to talk with the Tier I agencies outside of the process as it is a cooperative agreement rather than a competitive grant.

Is in-house labor or force support labor permissible under the grant?

No. In-house labor or force support labor is not allowable. However, we still need to know if in-house labor or force support labor is critical to a project's completion. Contracted labor is permissible.

What level of detail needs to be provided in the project abstract in the IJ?

The project abstract should provide a very detailed description of your project upfront. For a multi-phased project, for example, we need to know the total number of phases, in which phase this project occurs, and where you are on this project. If you are requesting equipment, there needs to be enough information in the abstract for us to evaluate the security value and reasonableness of the request. Please refer to the IJ Writing Guide for FY2009 that is available on the TSA website at www.tsa.gov/grants.

What type of information do we need to provide if we are requesting cameras?

For camera projects, you need to provide the number of cameras, placement (where they are pointing), and capabilities of cameras along with details on how the cameras will be monitored, how often they will be monitored and who will be doing the monitoring. For the EHP review, describe how they will be mounted (on new poles, existing poles, or building exterior) and, if on a building, the age of the structure.

Does video analytic technology count as monitoring?

No. Live monitoring is still required. At least one human must monitor the video analytic technology to monitor for failures in the event that something goes wrong or the technology fails. Video analytics can reduce the number of people needed to monitor but is not a complete substitute for live monitoring. We want to know that a human is monitoring so that he/she can react immediately when the system is breached or an intrusion occurs.

Are equipment maintenance plans an allowable expense for equipment purchased with FY 2009 TSGP funding?

Equipment maintenance plans are an allowable expense within the 36 month period of performance for equipment procured under the grant. The agency is responsible for any costs associated with the equipment, including the maintenance plan beyond the 36 month period of performance.

You had mentioned that the period of performance for training is 24 months. Is 24 months the period of performance for any training projects or fast-track training?

The period of performance for fast-track training is 24 months. The period of performance for training projects that are not fast-track training projects is 36 months. Training projects with costs that exceed the costs allowed in the fast-track training matrix and those with lower costs estimates than that allowed in the training matrix are examples of training projects that do not qualify as fast-track training requests.

If we include ten project milestones, is that acceptable to TSA and FEMA?

Yes. Investment Justification (IJ), Section IV C, directs applicants to provide up to ten project milestones. However, applicants should only list as many milestones as necessary and include only those major milestones that are critical to the success of the project.

Where do we find the Information Bulletins (IB) discussed here?

The FY2009 IBs and some FY2008 IBs that are relevant to the TSGP are available on the TSA website at: www.tsa.gov/grants under the FY2009 and FY 2008 WebPages, respectively. Additional IBs can also be found on the FEMA website at: www.fema.gov/grants. A direct link to all IBs released for all programs is: http://www.ojp.usdoj.gov/odp/docs/bulletins.htm.

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Portland Workshop 11/19/08

If my transit agency chooses to eliminate the FY08 match and scale-back the project per Information Bulletin #298 (IB #298) and the retroactive elimination of the match for FY08, is the "review" of my updated Investment Justification (IJ) a competitive review? Are the resubmissions going to be re-competed for Tier II?

No. A competitive review or re-compete of resubmissions is not required. Any resubmissions will be reviewed by TSA however, to ensure that the scaled-back project maintains security value. Project resubmissions must be of the same project type as originally funded by TSA. The resubmission is not an opportunity for the reprogramming of grant funds.

What are TSA's requirements for the evacuation plans as listed in priority group 5 in the guidance?

As with any request for TSGP funds, evacuation plan projects must be transit-related and have a counterterrorism focus. Evacuation plans that provide transit support for natural disasters such as earthquakes or other non-terrorism-related disasters will not be funded.

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San Diego Workshop 11/17/08

Q: If you do not have a security assessment plan in place can you apply for funding to use for this assessment?

A: Yes. If you do not have a current vulnerability assessment and security plan, this is the only funds you may apply for this grant year.

Q: Does the Baseline Assessment for Security Enhancement (BASE) review performed by TSA count as an assessment?

A: Yes, the BASE review meets the requirement for the vulnerability assessment and security plan.

Q: Does the security plan have to be approved by the transit security provider?

A: The plan does not have to be approved by your security provider, only reviewed. We are issuing an information bulletin detailing the difference between approved and reviewed.

Q: Do we need to submit our security plan with the application?

A: You do not need to submit your plan with the application, but you do need to submit the certification statement that states you have a current security plan.

Q: Do we need to give you the date the security plan was completed?

A: As long as it has been in the past three years, we will take your word for it. We do reserve the right to ask to see it.

Q: Can you register on grants.gov more than once for multiple users?

A: You can have several users but you can only have one registration for your transit agency.

Q: We have contacted the technical help line for grants.gov because we have found that if you have acrobat professional it conflicts with the grants program. We are working on correcting this problem but will we need to get another system?

A: We do not have control over grants.gov, so you are absolutely right to work with the technical help line to find a solution.

Q: For each Investment justification (IJ) we submit, do we need to submit an application for each one?

A: You need only one application but you will need to submit an investment justification for each individual project.

Q: After the application submission on January 13, 2009 if we find something is not feasible can we make changes or substitutions?

A: For Tier II, it is a competitive process and we cannot consider any modifications after January 13, 2009. For Tier I, you can make minor adjustments until February 13, 2009, but you cannot change projects, scope, or overall budgets.

Q: Does the template have the capability to use the copy and paste function?

A: Yes, the templates are in Microsoft Word so you can cut and paste to the templates. The budget and the IJ templates are already on our web site at www.tsa.gov/grants.

Q: In FY2009 we are no longer going through the States, who do we go through for questions that may arise?

A: We have weekly conference calls and we have two email addresses that allow us to give a coordinated response between TSA and FEMA. Those email addresses are AskCSID@dhs.gov (FEMA) and TSAGrants@tsa.dhs.gov. All questions will be posted on our website, this is a good place to find answers to questions and great information.

Q: When working in collaboration with regional partners on an evacuation plan, how do we submit this multiregional plan?

A: There must be one responsible/lead agency that submits the IJ. In your explanation tell us which agencies you are teaming with and state that it is a regional collaboration project. Your evacuation plan cannot be for all-hazards; it must be related to terrorism on transit.Transit must be the specific target of the attack, and not a means of escape for other types of emergencies.

Q: Do you receive the extra consideration for regional collaboration if you deal with local responders and Police Department, if we are in the same city or county?

A:We are looking to see if you are going above and beyond what is required. In general, collaboration cannot hurt you.

Q: If another entity is directly involved with transit can we invite them to our training?

A: You can invite them, but if they are not listed as an eligible entity in the Grant Guidance, then they cannot be reimbursed for any expenses they would incur, such as backfill or overtime.

Q: Can we pay for the course instructor out of grant funding?

A: Yes, this is listed as an allowable use of funds in the guidance.

Q: We are installing cameras in a multiple phases. We have not received approval to drawdown our funds for this purpose from FY2007, so how do we ask for the next phase?

A: If the phases are not dependent on one another, then you can ask for the next phase. If they are dependant, then you must ensure that the previous phase will be completed in enough time so that the phase you are requesting with FY 2009 TSGP funding can be completed within the period of performance.

Q: What happens if you come in under budget for your project?

A: This does happen, if there is additional money you can ask to reprogram the remaining funds. You do not want to severely over estimate your projects and run into time crunches when asking for reprogramming.

Q: If a project falls into two project effectiveness groups, can you submit in both groups or must you choose only one?

A: Each IJ will only be scored in one project effectiveness group. Explain specifically for the group you think it falls in, and why that group is the best fit for the overall project. There are no extra points for multiple categories.

Q: Who determines what is reasonable for the investment proposed?

A: The National Review Panel and TSA will determine what are reasonable. We understand that different areas have different costs, but if you do not explain or justify your costs, we will not know. We are not unreasonable, and have experience with a wide range of agencies, geographical areas, and projects. Explain yourself fully and there will not be an issue.

Q: When doing an in-kind match, how much documentation is needed?

A: Document what was contributed in detail, for example, salaries of staff used for installation of equipment, the number of hours, etc.

Q: If we have a project that is part DHS and one part from another source, will you audit the other source?

A: If it is not part of what the TSGP grant is funding, then it will not be audited. However, if you put that other source as a match, then that is auditable. As a reminder, you cannot match federal funds (this grant) with other federal funds.

Q: We have been dealing with the FTA where they provide a printed chart for life sustainment, will you be providing one?

A: Not at this time. We are looking to you to explain how you will sustain the capability after the grant funds have been expended.. Justify your project, we do not want something that will be turned off after the grant period because you do not have the resources to keep it operational.

Q: When using dog teams you must have a handler, and you must have a handler for the life of the dog, is this cost justified?

A: Yes, the personnel costs associated with the handler and the dog go together.

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Houston Workshop 11/14/08

Are any entities other than those specifically listed in the guidance, eligible to apply for TSGP?

The FY09 DHS appropriation explicitly states that transit agencies will be the direct recipients of TSGP grant funds and only those transit agencies listed in the guidance are eligible to apply for TSGP funding. The FY09 TSGP Guidance and Application Kit can be found on our website at: www.tsa.gov/grants.

Are local law enforcement agencies eligible for TSGP funding?

Certain law enforcement agencies have been designated as dedicated security providers of transit agencies and as such, they are eligible sub-grantees of transit agencies. The list of eligible law enforcement agencies is included in the FY09 TSGP Guidance and Application Kit, which is available on our website at: www.tsa.gov/grants.

How does TSA determine the "certain law enforcement agencies" that are eligible?

Some transit agencies have separate transit-specific bureaus/departments that provide dedicated security operations for those transit agencies. We have identified these in the guidance. As a dedicated security provider, these law enforcement agencies are eligible sub-grantees of the transit agencies they secure.

If our agency was a direct recipient of a federal grant in a previous year and we registered with grants.gov at that time, will we need to register again?

You only need to register on grants.gov once, so if you registered with grants.gov in the past, your information should be stored in the system and you should not be required to register again. You should however, update any agency information (i.e. agency point of contact, agency address, etc.) that has changed since your last submission through grants.gov.

What is the Environmental Historical Preservation (EHP) review?

The Environmental Historical Preservation (EHP) review is a federal requirement that directs the Federal Emergency Management Agency (FEMA) to assess the potential environmental impact of any project that will be funded with federal grant dollars. While all projects are subject to the EHP review, it affects you most if your project involves construction or installation on infrastructure (buildings, rail cars) that are 50 years old or older.

Were there FY08 Freight Rail Security Grant Program (FRSGP) funds that were uncommitted?

In FY08, some of the money originally allocated to FRSGP was transferred back into TSGP. This was possible since the funding for freight rail is carved out of the amount appropriated for TSGP each fiscal year. For FY08, the policy decision was to allocate $15 million for the FRSGP but when we received eligible requests for only $7.5 million, the excess money was reverted into TSGP.

Was the quantity of FRSGP applications too low in FY08? Was this the reason for the FY08 FRSGP funds to be transferred back to TSGP?

Yes, due to the FY08 cost match requirement of 50 percent, there were a limited amount of applications received.

Did TSGP have a cost match requirement in FY07?

A cost match was not required in FY07 with the exception of requests for Operational Packages (OPacks) from Tier I security partners.

Will TSGP grants fund the monitoring of cameras by agency staff or local law enforcement?

TSGP funds cannot be used to supplant other sources of funding and thus, TSGP funds cannot be used to pay the salaries or benefits of employees or staff. TSA has had limited success in advocating for TSGP funds to be used for this purpose.

Are cost associated with the installation of new Supervisory Control and Data Acquisition (SCADA) systems covered under the program?

Only the costs associated with the hardening of already existing SCADA systems will be covered under TSGP.

If our current SCADA system is basic or of a lower technology and we want to remove it and install an enhanced SCADA system, would that be considered hardening of an already existing system?

In order for TSA to consider this request, you must clarify in your project description that you have an existing SCADA system and that it is an existing system that you want to enhance or harden otherwise TSA will not be able to consider the request. You must also have existing SCADA security protocols and you must provide TSA with specific information as to what these are so that it is clear that your agency has the appropriate operating procedures and standard response protocols in already place before TSA will consider this request.

What would interoperable communications involve?

Interoperable communication projects could involve the integration of multiple communications systems with the capabilities for multi-users, of which one must be a transit agency, to be able to communicate over the same frequency. It could also cover the cost for purchasing radios, depending on the rest of the project and what the agency has/does not have. For projects of this type, we require that you first consult with the appropriate local agencies (i.e. local law enforcement, first responders) to obtain consensus and coordinate project specifics with them before you submit your investment request. The SAFECOM website available at: http://www.safecomprogram.gov/SAFECOM/ is a good resource for more information on interoperable communications and best practices.

Is Closed-Circuit Television (CCTV) considered interoperable communications?

We do not consider CCTV interoperable communications, as we consider "communications" to be the ability to communicate real-time. The sharing of live video feeds from CCTV with other entities such as first responders or local law enforcement would still fall under the realm of a CCTV project.

What is TSA looking for in the Investment Justification (IJ)?

Your IJ should provide enough information and detail about your project as to give TSA the complete picture. Some essential components of your IJ are a project abstract that describes your project in sufficient detail (i.e. what does the project entail, is it a phased or scalable project); a sufficient justification as to why your project should be funded; and a detailed budget. An IJ Writing Guide with instructions on how to complete an IJ is available on our website at: www.tsa.gov/grants.

Are there standards that you place on video communications?

We do not place standards on video communications. One standard frequency is not available nationwide and therefore, it is not possible for TSA to impose standards on video communications.

What should an agency do if they do not use all of the grant money they were awarded?

First, the agency should attempt to use the funds for its intended purpose. That is, if a grant was awarded to an agency to fund training, that agency should try to use any excess grant funds to provide more training (e.g. follow-on training, training to more employees) before the agency requests a reprogramming of grant funds. Second, if the agency's reprogramming request is consistent with program funding priorities and the continuation or expansion of training, for example, is not justified, the agency may seek approval to use the funds for another purpose by submitting a reprogramming request. This request would be evaluated by FEMA and TSA to ensure that it is an allowable project, and would have successfully competed against other project types funded in that grant cycle. Third, if the agency can demonstrate that they made a good faith effort to expend the funds for the intended purpose or that circumstance beyond its control prevented the expenditure of the funds for the intended purpose, the agency may request an extension.

Are phased projects more likely to be funded?

It is advisable for an agency to submit a scalable or phased project only if the project meets the follow criteria: 1) it is reasonable and makes sense to rollout or implement the project in phases 2) each phase of the project is self-contained and 3) each phase of the project has security value. Projects that meet these criteria and that are submitted as scalable or phased projects may be considered for partial funding of a phase if they score competitively if the amount of funds remaining in the program is not enough to fully fund the entire project.

Does the Baseline Assessment for Security Enhancement (BASE) assessment qualify as a security plan? Does the BASE increase an agency's chances of receiving funding?

To be eligible to apply for TSGP, transit agencies are required to have a security plan that has either been develop or updated within the last three years or to have had a security assessment that has been conducted by DHS. The BASE is one example of an acceptable security assessment. TSA Transportation Security Inspectors – Surface (TSIs), perform the BASE, and its purpose is to assess a transit system's security, to more effectively target transit resources and security programs and to elevate transit security. When we assess security value, we weight the security plan, BASE and other security components equally as each have security impact and all are used to evaluate project feasibility. If an agency ties their investment request to the results of their BASE assessment, it will likely be viewed favorably by the National Review Panel, but it does not have a specific point-association in the scoring methodology.

If we do not have actual project costs when completing the detailed budget, should we provide cost projections?

You should research project costs and provide an average as an estimate. We suggest that you obtain at least three cost estimates before you provide us with an average.

What form do we use to submit requests for the reprogramming of grant funds?

There is no specific form that must be submitted to request the reprogramming of funds. To request the reprogramming of funds, send a request to your FEMA Program Analyst and include a detailed explanation of where you are reprogramming from (why are there excess funds from another project), what you intend to do with the funds that you want reprogrammed (your new project request) and why you are making the request along with the amount of money you want reprogrammed.

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Chicago Workshop 11/12/08

What is the deadline for agencies to notify FEMA if they will be revising their FY08 projects?

The deadline for agencies to notify FEMA is December 1, 2008. However, since FY08 grants were awarded through the State Administrative Agencies (SAA), agencies must first notify their SAA of their intention to either keep the cost match or remove the cost match and revise their project Investment Justifications (IJs) and detailed budgets. Then, it is the responsibility of the SAA to notify FEMA of the agencies decisions for each agency in the state. For our information, see Information Bulletin #298 (IB #298) that is available on our website at: www.tsa.gov/grants.

Does an agency need to submit a revised project description and IJ if the scope of its FY08 project will not change if the cost match is removed?

Yes. The removal of the cost match changes the information contained in the agency's original FY08 application that was approved for funding. Therefore, the agency must submit a revised project description, IJ and detailed budget (if applicable) to document the removal of the cost match and to provide TSA and FEMA with a clear indication of what has changed and how the changes impact or do not impact the project. If the project scope is not impacted by the removal of the match, agencies may indicate such in the form of a sentence in the most appropriate section of the IJ.

When will the funds for the FY08 awards be released?

The sooner the SAA's notify FEMA of the agency's intention to either keep the match or remove the match, the sooner FEMA can review the projects and release the funds. In accordance with Information Bulletin #298 (IB #298), each TSGP sub-grantee must inform the SAA of which option they will choose for each of their approved FY08 projects. The SAA must submit a list of all projects submitted and approved with the option selected for each project to ASKCSID@dhs.gov by December 1, 2008. The revised IJ and detailed budget, if applicable, are not due by this date, but DHS must know the intention of the SAA and agencies by this date. That is the first step. The second step is to resubmit the revised IJ and detailed budget for those projects that they agency wishes to no longer include a match. Any revised or re-scaled projects will then be reviewed by TSA for their security value. Once TSA has completed its review, the IJs and budgets will be submitted to FEMA for EHP and budget review. Upon approval by FEMA, a clearance memo will be issued, which signifies the release of the funds.

What is a clearance memo?

A clearance memo is issued by FEMA to indicate that an agency's project has successfully passed EHP and FEMA budget review. The clearance memo authorizes the release of grant funds for approved projects and formally signifies the point at which an agency may begin to draw down or expend grant funds. The Grant Adjustment Notice (GAN) previously served this purpose.

What does the acronym EHP mean?

The Environmental Historical Preservation or EHP is a federal mandate that requires FEMA to conduct an environmental impact review of federally funded projects prior to the release of any federal funds. The EHP review is primarily concerned with assessing the environmental impact of capital projects, construction projects or projects involving historical property, landmarks or buildings.

Is there an advantage to submitting multiple Investment Justifications (IJs) for projects, if all projects may not require an EHP review?

All projects require EHP review but depending upon the type of project and its potential environmental impact, the EHP review process may be relatively quick, or long and extensive. If projects of various types are submitted on one IJ, clearance memos cannot be issued for those projects until all projects listed on that IJ have successfully passed EHP and budget review. However, if those projects were submitted on individual IJs, each project could undergo a separate EHP review and clearance memos could be issued project by project as they clear the EHP and budget review process.

When does the period of performance begin for the FY09 projects?

The period of performance begins with the award letter; the date on the award letter is the start date of the performance period.

Who is on the National Review Panel (NRP)?

The NRP consists of five to six security and transit subject matter experts (SMEs) from multiple federal agencies including TSA, FEMA and FTA.

If ridership is the determinant of high and low density stations, what determines whether a bridge is high or low density?

Bridge density may be determined by the number of trains, vehicles or passengers transported over the infrastructure. Infrastructure that is shared by multiple users or multiple transit agencies, the number of routes and shared routes and trackage rights are additional factors that may be used to justify the high or low density of a bridge.

What project effectiveness grouping would evacuation drills fall into? Could signage be a part of the evacuation plan?

You should choose the project effectiveness group that is most appropriate for your project based on the information that is available in the guidance and then justify your choice. Evacuation drills must be transit-related and focused on transit-specific events; city-wide evacuation drills will not be funded under the grant. Any planning associated with the evacuation drills would be considered operational costs and are capped at a maximum of 30 percent for the entire program nationwide. Signage associated with the evacuation plan or drill would not be covered under the grant.

What would interoperable communications involve?

Interoperable communication projects would involve the integration of multiple communications systems with the capabilities for multi-users, of which one must be a transit agency, to share and view live data feeds. For projects of this type, we require that you first consult with the appropriate local agencies (i.e. local law enforcement, first responders) to obtain consensus and coordinate project specifics with them before you submit your investment request. We also require that you have an agreement in place among all applicable agencies that indicates mutual agreement and delineates responsibility along with assurances that the system will include the monitoring of live data feeds. The SAFECOM website available at: http://www.safecomprogram.gov/SAFECOM is a good resource for more information on interoperable communications and best practices.

If an agency's interoperable communications project is related to another grant program, would that affect the project scoring?

The interoperable communication project must be transit-related and transit security-related and it must align with the program's priorities of terrorism prevention and detection to be considered for funding under TSGP. If the project meets those criteria and the agency is leveraging another grant program, include that information in your IJ as it may make the project seem more sustainable.

Are operational costs capped in Fiscal Year (FY) 2009 like they were in FY 2008?

Per the limitations imposed by the 9/11 Act on operating projects associated with security and counter-terrorism, the FY 2009 TSGP is restricted to using no more than 30 percent of the funds for "operating uses" as outlined in section 1406(b)(2) of the 9/11 Act which includes security training, exercises, public awareness campaigns, canine patrols, development of security plans, overtime reimbursement, and operational costs associated with security or counter-terrorism duties. In FY 2008, operational costs were restricted to 50 percent.

Is it accurate to describe priority group one projects as operational?

Priority group one project types are at a minimum operational; operational costs may be associated with certain projects that fall within priority groups two through five. Evacuation drills are one example of a priority group five project type that is, in part, operational.

If an agency does not spend all operational funds on projects from priority group one, can the agency use those funds on other projects from other priority groupings as long as they stay under the cap?

The 30% cap on operational costs is TSGP-wide, and not restrictive on an agency-by-agency basis. Therefore, there is no limit on the percentage an individual agency may request or receive for operational expenses so long as the funding nation-wide does not exceed 30% for operational costs.

Does the program fund construction?

The program does not fund construction; TSGP does however fund the installation of equipment for transit security-related projects.

What scale is used for risk scores?

Risk scores are a function of the agency's risk and regional risk and are scored on a scale from one through six. We score them in this manner to de-classify the scores so that we may share them with you.

Where can an agency find more information on the project scoring methodology?

The five components of a project score are: agency risk group score; project effectiveness group score; risk mitigation score; regional collaboration; and match. The FY 2009 TSGP Guidance and Application Kit is the best source of information on how the projects are scored.

To receive credit for the match component of the project score does an agency need to offer a cash match?

The match may be either cash or in-kind.

Does the cash match need to be non-federal?

Yes, the cash match must be non-federal funds.

Will agencies receive feedback on how their application scored?

Tier I projects will be prioritized for the region and funded by priority within the region's funding allocation. Tier I agencies will part of this decision process. Due to the competitive nature of the program for Tier II regions, those agencies will receive feedback only on those projects that were either partially funded or not funded after the awards have been announced.

Will you give out detailed examples of how to write an Investment Justification (IJ)?

While we cannot give out detailed examples of how to write an IJ, we have developed an IJ Writing Guide, which is posted on the website www.tsa.gov/grants and provides detailed instructions on how to write an IJ along with helpful hints for what we are looking for when the review panel evaluates your IJ.

If two or more agencies will be collaborating on a project, should they submit anything to corroborative this relationship?

The agencies should submit anything that implies that the collaboration or discussions are on-going or completed. Some examples of documents that an agency may want to submit are Letters of Intent (LOIs) or Memorandums of Understanding (MOUs). Such documentation is important, especially during audits to substantiate consensus and agreement among agencies.

Are project Investment Justifications (IJs) subject to Freedom of Information Act (FOIA) requests?

While certain basic information from the IJs may be subject to FOIA, most of the information provided in the IJs are considered Security Sensitive Information (SSI) and are therefore exempt from FOIA.

Should cost estimates be submitted along with the Investment Justifications (IJs)?

Cost estimates should be submitted for any activities or equipment procurements of significant cost. These should be best-guess cost estimates based on market research. They should not be used to endorse specific vendors or be linked to any vendors.

Are agencies automatically eligible for the reimbursement of Management and Administrative (M&A) costs associated with the grant?

For FY 2009, transit agencies may use up to 3 percent of TSGP grant funds for M&A costs. M&A costs however are not automatically reimbursable. Agencies must request M&A funds in the form of an M&A line item in the project budgets and the costs must be allowable under the program guidelines before agencies are eligible for M&A reimbursement.

Will an agency be penalized if they do not use the entire grant funds awarded for fast track training?

While an agency will not be penalized, we do expect that an agency will use the funds for the intended purpose. Any agency that has or expects to have excess funds following the completion of the approved project should contact us to discuss options for the excess funds. It is expected that every effort will be made to use the funds for additional or continuing training before reprogramming requests will be considered. Furthermore, any agency that finds the training matrix not cost-effective should submit a regular IJ for training to avoid having excess funds.

Have training funds been successfully reprogrammed to capital projects or equipment acquisitions in previous years?

Before the reprogramming requests would be considered, agencies must document that they have completed all of the training in the matrix and supply us with the following: the total amount of grant funds spent on training; training and courses given or received; and, the number of employees trained.

What venues are available for agencies to share project ideas and lessons learned?

The TSA Blog, which is accessible through the TSA Grants website at: www.tsa.gov/grants, is the best venue for the sharing and exchange of project information and ideas as well as lessons learned. The Blog offers an access-controlled environment that is monitored by TSA and restricted to those who have been successfully vetted and approved for access. While the Blog is currently only suitable for the discussion of non-sensitive information, work is underway to make it SSI suitable. Please see the Blog Access Protocols, which are available on our website for access instructions and restrictions.

Will TSA establish equipment guidelines and testing standards for the program?

TSA Mass Transit has several things that are in process to assist with the development and establishment of testing standards. The American Public Transit Association (APTA) has several work groups that are looking into equipment and testing standards and the American National Standards Institute (ANSI) is developing testing standards as well. Those are great resources to consult when planning and designing your projects.

Does the project timeline start with the release of the funds?

No. The project timeline starts when the award letter is issued, as that is when the period of performance for the grant begins. Milestones must be included in the timeline, and milestones can be referred to in terms of months or spans of time rather than specific dates.

Will FEMA tell agencies what they need to submit to pass EHP review?

To assist with the EHP review process, agencies should provide as much detail as possible about their projects in the IJ to enable FEMA to judge the extent of the project and its potential environmental impact. The inclusion of photos, maps, and other visuals are also recommended. For example, for a camera project, an agency should include photos and markings to indicate the planned camera placement so that FEMA can judge the impact of the camera installations from the visuals. Agencies should consult Information Bulletin #271 (IB #271) for more information on the FEMA environmental review process and its requirements.

Does FEMA need pictures of the interior and exterior to conduct an EHP review?

Environmental impacts do not really apply to interiors. It is the exterior, most notably changes to the exterior such as changes to building facades, that most comes into play.

Will FEMA accept the environmental rulings of the State Historical Information Preservation Officer (SHIPO) or Federal Transportation Administration (FTA)?

Generally, FEMA does accept the ruling of the SHIPO however; there have been several incidents when EHP required further verification. FEMA does not accept FTA rulings without justification.

Are agencies responsible for submitting project and fiscal reports for FY09 projects?

Yes. As the direct grantee, agencies are responsible for submitting their own quarterly project and fiscal reports to FEMA. See Part VI, Section C, Reporting Requirements in the FY 2009 TSGP Guidance and Application Kit available on the TSA website at: www.tsa.gov/grants for more information on grantee reporting requirements.

Are agencies required to submit quarterly reports for the period between the award announcement and award letter and the issuance of the clearance memo and release of the funds?

Yes. For any quarterly fiscal reports due during the time between the award and release of funds, agencies must submit a zero report. If agencies do not, they will be considered delinquent on reports.

When is the first quarterly fiscal report due?

The first fiscal report or Standard Form 269 (SF269) is due in June 2009.

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Tampa Workshop 11/07/08

Do we still need the local Law Enforcement to give us an approval rating after review of our security plan as we have in previous years?

This is a change from last year, this year the security plan is to be reviewed by local law enforcement but no approval is required.

With the removal of the SAA as the grantee, are the reporting guidelines clear and easy to understand for the transit agencies that will now be responsible?

They are in the guidance and have not changed from that from last year; the difference is now the agencies are responsible for submitting the grants themselves. All funding of approved grants will now go directly to the agencies.

If our agency chooses to use the SAA can they submit the grants for us?

All projects must be submitted by the individual eligible agency/person within that agency.

Will the change from using the SAA allow the funding to reach us in a timelier manner?

In the past the SAA could take up to forty-five days after award to transfer funds to the agency, now the funding will go directly to the agency and should make a faster timeframe.

If a project is a regional project and it involves multiple agencies, how do they receive their share of the funding?

If everyone involved is an eligible entity, one agency can act as the primary recipient and sub-grant to the other agencies. However, if you are involving ineligible entities, you may not transfer funding to them, all agencies that are part of your grant application and funding must be on the list of eligible entities. You cannot reimburse non-eligible entities for expenses. They can come and fill in seats if you hold a training class, but you cannot fund their backfill or overtime.

Under the current guidelines are contractors eligible to attend training?

All contractors should be hired with the needed training already completed.

At our agency we interface with high rail and intercity lines and stations, is this considered multi- users or regional collaboration?

This could be either, if each agency is given a specific responsibility for their part and depending on how you explain the details in your Investment Justification. Give us details on how you are working together, as this sounds like a smart idea and that could get additional scoring points. This could show us you are going above and beyond what is needed for regional collaboration.

We have a project that our staff is qualified to do, but based on the DPM procurement rules the project must go out to bid. Is it ok for our staff to bid on the work needed?

No, if your staff does the work on their regular schedule, that would be paying double and we cannot fund that as it would be considered supplanting.

Please explain the policy for submitting projects that are continuing investments versus doing totally new projects.

Our first priority is to get projects done. Explain to us exactly what you are doing, and if the project is being completed in phases, explain what each phase is, where you are now, and where this investment request will get you. Explain your justification.

If we have done a phased project in previous years, how do we submit to complete the last five units?

In your Investment Justification description, state that this will complete all stations.

If a project was previously declined in FY2008 can we submit this project again this year?

Yes, use the comments from the National Review Panel you received to address concerns with your Investment Justification.

When our agency does exercises in collaboration with outside agencies, such as the fire department, are these costs associated with including outside agencies allowable?

No, only costs associated with eligible transit agencies are allowable.

Are there guidelines that limit how many exercises can be done and how often exercises can be done?

There are not guidelines written, but we expect a reasonable number. Something such as one full scale exercise per year is normal, with other drills and table tops as appropriate.

Is the investment amount we enter on the first page of the Investment Justification the total for all of our projects we're requesting, or should it be unique for each individual project?

The project heading is unique for each individual project, so the amount listed should be for the Federal request for that project only.

If we use private security companies for certain projects should we put that information in our applications?

Yes and put details of exactly what they are to do.

At some of our rail stations we would like to install alarms going out. We currently have only a security guard. If we wanted to install an alarm system is this an allowable cost?

Yes, but there are pieces we will need to know are in place to ensure that there will be a proper response if an alarm is triggered. Describe a real time response plan: if the alarm goes off what are the procedures to be followed? Explain any updates as a result of the new investment, such as using new technology, response protocols, and changes as to how people are trained to use the new equipment. You may be doing all of these things, but you need to tell us otherwise we will not assume you are.

If my agency wanted to do security enhancements for existing vehicles what category would this fit into?

This is an allowable expense, make the case for the category you feel it fits into best and explain the risk. For example, if the vehicles service multi-user high-density stations, then you would need to explain that and justify it in your Investment Justification in order for it to be given the score for that project effectiveness group.

We have many questions on services and equipment. Does DHS/TSA have a listing of subject matter experts or other agencies that are doing similar projects who we could contact for information?

Across the country many projects have been done by many agencies, and most agencies are very open to sharing what they have done. We can put you in contact with an agency that is similar in size and is doing similar projects. We cannot recommend specific vendors, but we can give you contacts in other transit agencies to talk to. Another great place to get answers is on the TSA Grants Blog.

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Question and Answers received via Email

When will the application packages and application instructions be posted on grants.gov?

FEMA will be releasing an Information Bulletin (IB) that will note when the grants.gov system and applications are available. For more information, please see Information Bulletin #295 (IB #295) which is available on our website at: www.tsa.gov/grants. In the meantime, we suggest that you complete the following steps:

Will applicants need to fill out the standard forms (i.e., SF 424, standard assurances and certifications, etc) for each separate Investment Justification (IJ), or just once per application?

You only need one set of completed standard forms regardless of how many investments you are submitting. The standard forms including the SF 424s, standard assurances and certifications are required and must be submitted along with your IJs and budgets. You may download the standard forms and store your information on grants.gov at any time however do not hit the submit button until you are ready to submit a complete application with IJ(s) and detailed budget(s).

What template should be used for the FY08 Budget resubmissions?

Please use the OMB-approved Sample Detailed Budget Form (OMB Approval No. 1121-0188) as a template. The form is available in the guidance and on our website at www.tsa.gov/grants under the Grant Guidance and Application Kit section for FY08 and FY09. The form is the same for both FY08 and FY09 and is a new requirement for both fiscal years. Using any other form will only slow down the budget review process.

What Information Bulletin (IB) provides details on the removal of the FY08 cost match and the options available to transit agencies that included matches in their FY08 applications?

This information can be found in IB #298, which is available on our website at: www.tsa.gov/grants.

When does the FY09 Period of Performance exactly begin and end? Page 8 of the Guidance states that, "The period of performance of this grant is 36 months...", but it doesn't specifically mention when the period begins and ends.

The period of performance is 36 months from the award date. In the past, the award was made to the state in bulk and all the sub-awards had the same beginning date. The announcement of the grant amounts to each agency (not the actual award) will be on or about April 10, 2009, with the awards being made before the end of the federal fiscal year of September 30, 2009. The performance period will be listed on the award documents.

Would you please clarify when the FY08 Period of Performance began and when it will end?

During the Question and Answer session of a Conference Call on August 27, 2008, FEMA stated that the FY08 Period of Performance began August 1, 2008.

Finally, for FY05, FY06 and FY07, the state Office of Homeland Security (OHS) released a memo dated November 17, 2007 specifying grant expiration dates for the "Subgrantee Period of Performance" and the "Federal Period of Performance". For each grant cycle, the "Subgrantee Period of Performance" expired three months before the "Federal Period of Performance", ostensibly, to allow OHS sufficient time to comply with federal requirements to close out the grant. Since transit agencies are "Grantees" for FY09, is the Period of Performance really 36 months or 33 months?

The period of performance for FY09 is 36 months, except for fast track training (24 months) and Opacks (30 months). But the transit agency will now be responsible for the activities the state would have performed before.

Would the budget format we submitted last year be acceptable in FY09?

The template provided with the FY2009 TSGP Guidance and Application Kit is the template that should be used. All categories shown in the template must be addressed with either an entry or a "not applicable". No additional categories should be added (i.e. M&A). M&A expenses should be categorized as other and should be broken down as to detail so that we can easily determine what the funds are being used for.

The result of grants being directed to each agency requires a full budget review by FEMA and in order to make this process as efficient as possible we need to have a uniform format or template.

Is the overall use of Contractors/Consultants to perform tasks under the grant limited by the 3-percent M&A Cost limitations, OR is the use of contractors/consultants for just MANAGEMENT-TYPE FUNCTIONS subject to the 3-percent limitation?

The restriction in Section E.6 refers to is the management and administrative function of the grant and does not limit a grantee from using contractors to perform tasks associated with approved TSGP projects as long as the costs are accurately and appropriately captured within the proposed budgets for those projects.

It has been mentioned that analytics is an acceptable alternative to live monitoring, as long as it is tied to an alarm/alert that would then immediately notify a live person. Would it be acceptable if the "live" person was part of a 3-party monitoring company?

Analytics tied to an alarm/alert are considered a security enhancement olive monitoring, allowing the agency to use fewer people to monitor more cameras, but analytics themselves are not an acceptable alternative to live monitoring. Analytics give the ability for fewer people to monitor more cameras, but does not replace the need for live monitoring. For your last question, if you are asking if 3 people are enough to monitor your cameras, that would depend on the number of cameras and the types of algorithms programmed into your analytics. You cannot use a 3rd-party company to monitor instead of the agency. A 3rd-party company may monitor in addition to the agency, but in the end, the agency must be responsible for the monitoring.

Can FY 2009 TSGP award money be used for installing security/surveillance cameras on transit vehicles (buses) and security upgrades for administrative facilities/offices?

Installing security/surveillance cameras on buses is an allowable expense under the TSGP provided that those cameras have the ability to be live-monitored in the case of an event. Cameras on buses that do not have the ability to be monitored in real-time in the event an incident occurs will not be considered for funding.

Security upgrades for administrative facilities/offices may also be allowable, depending on what is meant by "upgrades". New security measures such as cameras, lighting, fencing, and access control are allowable expenses. However, the grant will not pay for the replacement of equipment unless the security capability is enhanced.

A facility hardening project has budgeted $11,000 for "Permitting/City Requirements." Are permit fees an allowable cost?

Obtaining permits and compliance with other local building codes are reasonable and necessary expenses of any construction project. They are an allowable cost under the grant if they are required to complete the approved security project.

Are we allowing reimbursement of overtime for "flaggers "to meet federal safety requirements when doing approved projects in a railroad right of way?

"Flaggers" are required by federal safety regulations for construction/installation projects on railways. Any additional costs related to use of flaggers should be permitted on a case-by-case basis. We can only reimburse for their time when the construction/installation project is directly related to a project funded through TSGP. Any personnel costs attributed to flaggers should count towards the costs of the construction/installation project and should not be considered an "operational" personnel cost subject to the 50/30% limitation. These costs are attributable to Section 1406(b)(1), not 1406(b)(2) which is subject to the limitation.

Are there any restrictions on hiring of a "planner" as described in the Guidance and application Kit, Pg. 31 Section 1 bullet point 6? "Hiring of full or part-time staff and contractors and consultants to assist with planning activities (not for the purpose of hiring public safety personnel)"?

Costs for developing a security plan are allowable under TSGP, so personnel costs for hiring planners to create such plans should be allowable. 9/11 Act section 1406(b)(2)(E). Per our discussion yesterday, this could be for the full cost of a security planner, or part of the time of a security planner. However, paying for only a portion of the planner's time will be difficult to enforce. We want to ensure that planner's time we pay for is only used for security planning and not general transit planning. It is within the program's discretion on implementing this. As costs related to planners full under section 1406(b)(2), they are subject to the 50/30% limitation.

To gain access to the TSGP Blog, the "President/CEO/General Manager" needs to grant or designate the person. Would our business group president be the appropriate person to grant access?

If your business group president is the Grants Administrator than he would be considered the authorizing official. If he is not, then we would need your Grants Administrator, President or CEO to send the email. If your business group president is the Grants Administrator, please specify that in the email as that will speed up the process for getting you access into the Blog.

How does one get on the email distribution list for the Informational Bulletins [IB]?

If you have not been receiving our email or other distributions, please send us your contact information in an email to TSA grants at TSAgrants@tsa.dhs.gov and carbon copy FEMA at AskCSID@dhs.gov and request to be added to our contact lists.

Is there telephone number of someone I could speak with about TSA grants, specifically, Transit Security Grant Program Tier I or Tier II and also about FEMA grants, specifically, Urban Area Security Initiative Non Profit Security Grant Program (UASI-NSGP)?

The Transit Security Grant Program (TSGP) is targeted towards transit agencies in high-risk areas with high ridership as reported to FTA. You can find more information about the program, including the Grant Guidance and Application Kit which contains the list of eligible transit agencies, on our website at http://www.tsa.gov/what_we_do/grants/programs/tsgp_tieri/2009/index.shtm and http://www.tsa.gov/what_we_do/grants/programs/tsgp_tierii/2009/index.shtm. If you have further questions, you can contact TSA at TSAgrants@tsa.dhs.gov. For the FEMA grants, you may contact FEMA at AskCSID@dhs.gov and they can assist you on a point of contact for the UASI-NSGP.

We will be completing three investment justifications: one each for training, equipment and planning. For the training and equipment requests, we would like to include funding to have a consultant assist in the planning of construction implementation (equipment) and in the planning of training implementation. Should we include these requests for the planning consultant's assistance within the individual training and equipment justifications or should they be included in our separate planning projects investment justification?

Those costs should be included in the individual training and equipment justifications as consultant costs for planning.

The very first block on form SF 424 asks for "Application Filing Name" but doesn't define this. Is this the name of my company, the name of the project we are requesting funding for or...?

This should be the company name or name that you registered at grants.gov.

When I save data from the form it goes to my local drive. How will the form be re-populated if I exit the web site and come back in at a later time as there does not appear to be any import type button?

This is a technical question having to do with the operations within grants.gov. Please call the grants.gov helpdesk at 1-800-518-4726. Hours of Operation: Monday-Friday, 7:00 a.m. to 9:00 p.m., EST.

We are installing an ITS system and cameras would be a great element to this system, however we are at least a year away from having our private WWAN up and running. Would the TSGP support the use of cellular service to connect the camera to the authority in the case of emergency for the short term (not more then two years) until the our WWAN is up and running? Would these expenses qualify under the allowable costs?

The TSGP would support a permanent solution that would have the ability to do real-time monitoring. If cellular service would be this long-term solution, with the ability to continuously monitor, then that would be an allowable use of TSGP funds. If the cellular solution would be short-term only and not provide the ability to continuously monitor it would not be an eligible use of TSGP funds. The technical functionality to support real-time continuous monitoring must be clearly and fully explained in the IJ submission. Additionally, the TSGP could also pay for WWANs if it is meant for security and not for other operational purposes.

My transit agency has no dedicated security force and depends upon the local police department when needed. Who then would sign the investment justification and the security plan certification?

The primary transit security providers for certain Tier I agencies are listed in the grant guidance in Table 3. Only those agencies where a transit security provider is listed are subject to the requirements listed in the grant guidance regarding the review and/or approval of the security plan and Investment Justification. As such, the review/signature of a security provider is not required for your agency if the primary security provider is not specifically listed in the grant guidance in Table 3.

While reading the questions and answers it was clear that on-vehicle cameras don't really meet the definition of a good use of TSA funds for this grant program. I was wondering if a project that incorporates on-vehicle cameras that the local police department could access via their already existing police network to view emergency situations real-time would be a valid use of TSGP grant funds.

On-vehicle cameras are allowable, provided that they provide incident-based monitoring capability (e.g., in the event of a security issue, the driver/conductor can hit a panic button that is relayed to a control center where someone can then pull up the video feed live to monitor the events and set in place the proper response protocols). The transit agency itself must be the primary entity responsible for the monitoring of the cameras – while a feed to local police departments is a good regional approach, the agency itself must also monitor the live incident-based feed in order for the project to be considered.

The very last page of the IJ contains a worksheet with the header – Responsible Transit Security Provider Investment Justification Approval Form. There seems to be no clear language in the FY 2009 TSGP Guidance and Application Kit to indicate whether the approval form is required for both Tier I and Tier II agencies. Please provide clarification.

The primary transit security providers for certain Tier I agencies are listed in the grant guidance in Table 3. Only those agencies where a transit security provider is listed are subject to the requirements listed in the grant guidance regarding the review and/or approval of the security plan and Investment Justification. As such, the review/signature of a security provider is not required for your agency if the primary security provider is not specifically listed in the grant guidance in Table 3.

For an online application, how do we submit the signature of the authorized certifying official? In the box it just states "completed on submission to Grants.gov," can you please clarify this?

These documents are considered electronically signed by the signatory authority you list in the application when the application is submitted to and accepted by grants.gov.

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1/07/09 Conference Call

TSGP Conference Call
January 7, 2009
Time: 1:00 p.m.

If the application deadline is extended, do you how long it may be extended?

We do not know that information at this time. When we receive any information or updates on this, we will let you know as quickly as we can to give you the maximum amount of time to apply.

How will an extension of the deadline affect the grant performance period or date of the award?

If the submission date gets pushed back, the dates of the National Review Panels, the award date and all associated dates would subsequently be pushed back as well. As the period of performance begins on the award date, if the award date is subsequently pushed back, the period of performance would also be pushed back.

For a project that involves the procurement and installation of cameras, how much detail should we provide in the detailed budget? Could we provide generic information about the number of cameras, the capability, some hardware types and specific locations? If we give you a total aggregate number and cost for cameras is that sufficient?

The level of detail that you include should be at a level of detail that is sufficient enough for us to judge if the request is reasonable and allowable. We do not need for the detail to be "in the weeds". However, if the project involves different types of cameras, such as PTZ cameras, infrared cameras or forward-facing cameras, we would like to know the type of cameras you are requesting and the number of cameras of each type you are requesting.

Can we include the detailed information on the cameras in an attachment?

Yes. This information can be included as an attachment to your application. Please reference the attachment in the appropriate section of the Investment Justification (IJ) so that we know to look for the attachment. Also, be sure to include any attachment that you reference in your IJ as part of your final application submission.

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12/31/08 Conference Call

TSGP Conference Call
December 31st, 2008
Time: 1:00 p.m.

I haven't seen any guidance posted to grants.gov and wondered when that might be posted.

There is still nothing up on grants.gov. FEMA is still working this through with OMB.The issue is getting the forms through the Paperwork Reduction Act.There has been some preliminary talk about extending the deadline if the forms are not up in the next few days but there is nothing official yet.

Does that mean the 424 forms are not up yet?

Nothing is up on grants.gov site including the standard forms (SF) 424s.If you have filled out the standard forms before for other grants programs, those forms should remain the same.You can find the forms outlined in the guidance on grants.gov through their general forms page.The Investment Justification (IJ) and budget template forms are available on the TSA website. However, you will not be able to upload and submit those documents through grants.gov at this time.

There is a question under the impact section on the IJ regarding metrics.What kind of metrics are you looking for?We are not clear what is being sought?

We are looking for how the project will have an impact on the security of your system.We recognize it is very hard to talk about metrics when it comes to security outcomes.When people talk about this they generally say something like:If we implement a CCTV project that is monitored 24/7 we will be able to increase security because we will be able to see things as they happen and we will be able to respond in real time and mitigate consequences.You could put in outcome measures if you were doing training like: this will increase our trained staff to 80%.A more trained workforce will lead to increased security because staff is the eyes and ears of our system.

In terms of metrics, are people offering specific numbers like response times before and after?

That is not a level of detail that we have seen.If you want to put a metric that you think could happen like reducing response times from 5 minutes to one minute, that would be a good metric to put in, but we will not hold you to that standard.

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12/17/08 Conference Call

TSGP Conference Call
December 17th, 2008
Time: 1:00 p.m.

We understand there are some challenges with gaining access to the grants.gov site relating to the Paper Work Reduction Act. Will this affect our ability to submit our application by the due date of January 13, 2009?

The Paperwork Reduction Act (PRA) governs all documents and forms that the federal government gives to non-government entities to fill out. This year FEMA had to go through the PRA process again for the templates before grants.gov will post the application information. The PRA process is at OMB and is taking longer than expected. FEMA does not know how long this process will take or when the documents will be approved

The grants.gov site is working. You can log on to the site, register with CCR and get your DUNS number and get your log in username and password. The problem relating to the PRA is the pieces of paper that you have to fill out in order to qualify such as your SF424s and other documents at the administrative end that the state used to do for you. FEMA wants to assure everyone that they will give organizations adequate time to get the forms done. If the forms are not up in the next week, extending the deadline is under consideration. FEMA wants to be sure that everyone has adequate time to complete the forms.

My organization was just notified of this grant opportunity so this is my first conference call. We are designated as a Tier 2. Is there any way to access information from previous calls?

Go to the grants website at www.tsa.gov/grants. The site is divided into three sections: an awards section, a program section and an engage section. The program section is self explanatory and will detail all the information you need for any of the grant years for all of the grant programs. Go to the Transit Security Program for Tier II where you will find a tab for Conference Calls and a tab for Questions and Answers. The Conference Calls tab will allow you access to summaries for each of the previous Conference Calls. With the Questions and Answers tab, you will be able to access a list of all the questions along with our responses from Conference Calls, workshops we did across the country and emails sent to us.

Will the process of registering with grants.gov take long?

It is time consuming and can take up to three weeks to get all the numbers you need before you can register at grants.gov. You need a Central Contractor Registry (CCR) number and a DUNS number which will take some time. Even if you have not started on your budget or Investment Justification, try to get started with this process. You need to be sure you can log in by the time the documents are due and access the documents in enough time to get documents signed by appropriate people at your agency before they are due.

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11/19/08 Conference Call

TSGP Conference Call
November 19th, 2008
Time: 1:00 p.m.

When should the State expect to receive the letter that approves FY08 projects?
As you may be aware, the match requirement for FY08 was retroactively eliminated for FY2008 by the FY08 Appropriations Bill. FEMA issued IB 298 to specify what this means for FY08 TSGP grant recipients. Three options are detailed in the IB that transit agencies can consider when deciding how to deal with the elimination of the match requirement. Transit agencies must notify the state of which of the options they chose by December 1, 2008 and in turn the state will notify FEMA/TSA if we should expect to receive modified IJs by any transit agencies. TSA cannot issue an approval letter to FEMA until we have received, and approved, the final IJ from the transit agencies. Therefore, make sure that your state's transit agencies (1) have decided which option for the match they will chose and (2) are working on revising their IJs (if that is the option they chose). Approving FY08 IJs, given the match requirement change, is a priority of TSA and we hope to issue those approval letters to FEMA soon—however we cannot review your IJs until we know how you plan to address the match. For more information about the match elimination and your options, please see IB 298 at http://www.tsa.gov/assets/pdf/ib298.pdf. Please note that this approval letter DOES NOT authorize you to draw down funds—that letter is the GAN (renamed "clearance memo" by FEMA). The clearance memo cannot be issued for a project until the project has undergone a budget review and EHP (environmental and historical preservation) review, as appropriate. The budget review and EHP review occur at FEMA. Please contact your FEMA POC for questions about the status of the clearance memo once the approval letter from TSA has been written.

Is there any room for flexibility in the budget numbers submitted to TSA for the November 21, 2008 project concept due date? In other words, can these budget numbers change slightly as we refine our budgets before final IJ submission?

TSA requires the project concepts to be submitted on November 21st in order to guide the process of rating and ranking projects in each region based on the scoring framework. As in FY2008, the ranking generates the prioritized list of projects that serves as the basis for funding decisions. There will be some room to refine budgets after the initial submission on the 21st, but due to the short timelines this year final budget numbers must be determined by the draft IJ submission deadline on January 13, 2008.

A draft information bulletin (IB) was circulated to Tier I security partners a couple weeks ago soliciting feedback about the composition of the RTSWG and the process for making funding decisions. The deadline for comments was Friday, November 14. When should we expect to see the final IB issued that incorporates that feedback?

In order to educate all transit partners about the FY09 TSGP process, the grants team has been on the road for the past two weeks conducting workshops. As soon as we get back to DC on Friday November 21st, one of our priorities is reading all of the feedback we received, internalizing that feedback, and issuing the final IB in a timely manner. We hope to have to final IB issued before the second round of RTSWG meetings where we will go through the process of making funding decisions based on the prioritized list of projects for each region.

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11/12/08 Conference Call

TSGP Conference Call
November 12th, 2008
Time: 1:00 p.m.

Has any outreach been made by TSA to pass information to the new Tier II agencies?
Yes, we did send out an email to our contacts at the newly eligible agencies with the Grant Guidance, a frequently asked questions sheet, and a fact sheet last week after the Guidance was formally released.

Is there any way to get a copy of the email and who it was sent to in New York?
Yes.

I have a question in regards to the 30 percent cap on page 30 of the Guidance. The 'operating uses' says the limit that the grant funding can be used for costs for personnel assigned to full-time or part-time security or counterterrorism duties cannot total more than 10 percent of the total grant funds received by a public transportation agency in any one year. Is that 10 percent for TSGP funding received, or on all federal grants received by the agency?
The 10 percent cap is against all federal grants that your agency receives in a year, not just TSGP.

Can you explain on operational packs, page 18, the new requirement of a 5 year Operational Sustainment Plan?
The requirement for the Operational Sustainment Plan was added to make sure that the agency has a plan to sustain the operational packs after the grant funding has been expended and/or complement it with new technology. We will work with you on when it's due after the awards are made, and after you know how much funding you received for operational packages.

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11/06/08 Conference Call

What are the key application dates for Tier I and Tier II?

The first important date for everyone is January 13, 2009. That is the application due date on grants.gov. By this date, Tier II applicants must submit their final applications with all necessary attachments through grants.gov and Tier I applicants must all required standard forms, as well as draft Investment Justifications and detailed budgets through grants.gov. The second important date that only applies to Tier I is February 13, 2009, which is the deadline for Tier I applicants to submit their final applications through the Secure Portal. For both Tiers, final applications will consist of Standard Form (SF) 424, Investment Justifications (IJ), Detailed Budgets and any other required certifications and authorizations.

Will the transit agencies apply directly for funding this year instead of going through their State Administrative Agency (SAA)?

Yes. The transit agencies will be the direct recipients of the grants in fiscal year (FY) 2009 and therefore, the agencies are responsible for applying for the funding themselves. As direct recipients, transit agencies are also responsible for the administration and reporting requirements that accompany the grant. In previous years, these duties were the responsibility of the SAA.

To apply, transit agencies must first register with grants.gov. (www.grants.gov). Agencies should begin the registration process as soon as possible, as it requires several steps and may take several weeks to complete.

Has any responsibility been designated to the SAA now that the SAA is no longer the grantee?

No, we cannot mandate any responsibilities for the SAA. We do however encourage their participation in the Regional Transit Security Working Groups (RTSWG) and hope that they will act as facilitators and coordinators for their region.

Is the System Security and Emergency Preparedness Plan (SSEPP) the same as the security plan?

Yes. When we refer to the security plan, we are referring to the SSEPP.

Is it acceptable if we call our security plan something other than the SSEPP?

Yes, that is fine.

Are transit agencies still required to have their Investment Justifications (IJ) approved by their designated transit security provider?

The transit security provider should review the project IJ but they are not an approval authority. We realize that the current language in the guidance refers to the security provider's approval of the project by his/her signature on the Responsible Transit Security Provider Investment Justification Approval Form and we will work to get that corrected as soon as possible.

Who should sign the Responsible Transit Security Provider Investment Justification Approval Form?

We will leave that up to you to determine who the appropriate person is to review the project IJ and thus, sign the form. It does not necessarily need to the Chief of Police.

Who is the transit security provider signoff form applicable to?

It is applicable only to those agencies that are listed in the guidance as having and/or being designated security providers.

What is the definition of high-density vs. low-density?

There is no national standard or definition of either high-density or low-density. It is relative to your transit agency.

How do you define a high-density bridge?

Again, this is relative to your agency, and the volume of riders that are taken over the bridge by your agency.

If an agency needs to update a security plan, where does that fall in the priority groupings?

It would be in the highest group, Priority Group #1.

If my agency does not have an updated plan, does that preclude my agency from applying?

Yes. You must have a security plan that has been developed or updated within the last three years to be eligible to apply for other projects under the FY 2009 TGSP. However, you may apply for funding to develop/update a security plan.

Do agencies submit the security plan with the IJ and other required forms?

No. There is a certification statement that is required as part of the submission to state that you have a current security plan, but you are not required to submit the plan itself.

What is the maximum score that an application can receive?

We are developing an Informational Bulletin (IB) that will address all of the scoring components, which will include scoring ranges for those components that currently do not have them listed in the guidance. We anticipate that it will be issued very shortly.

Can agencies modify the detailed budget worksheet?

No. The detailed budget worksheet is a standard form that has been approved by the Office of Management and Budget (OMB) and therefore, cannot be modified without prior approval. The worksheet should serve as a template for your detailed project budgets and your detailed budgets must be submitted in the exact format as the Sample Detailed Budget Worksheet provided within the guidance. Furthermore, your detailed budgets must contain all of the categories that the worksheet currently contains. If a budget category is not applicable to your agency or project, mark that category as not applicable or N/A but do not remove it from the worksheet.

Has a checklist been developed to assist applicants with completing the Environmental Historical Preservation (EHP) form?

FEMA has developed a checklist and that checklist is currently under review by OMB. We cannot release it until it is approved. Until then, we are still operating under Information Bulletin (IB) 271.

The guidance grants full RTSWG membership rights to Amtrak and freight rail. What if a region invites them to be members of the RTSWG but they do not participate?

The guidance states that Amtrak and freight rail must be invited to participate in the RTSWG meetings and discussions, but they can choose not to participate. Amtrak and freight rail have their own grant program and therefore would not be pulling grant funding from the region. Their participation in the RTSWG could be meaningful in that, they often share much of the infrastructure that the region hosts.

Could DHS clarify the limitation on operational costs?

There is a 30% limit on the entire grant for operational costs, as outlined in the 9/11 Act. This means that no more than 30% of the entire TSGP funding can be spent on operational activities, which include:

Can an agency sub-award money to its regional agencies that are listed on the Urban Area Security Initiative (UASI) list?

The only eligible entities are listed in the grant guidance. If an agency is not listed as eligible, then they cannot receive sub-award funding.

Does an agency's updated security plan have to be approved by TSA before that agency can apply for funding?

If your agency's security plan meets the Federal Transit Administration's (FTA) Security Emergency Preparedness Format, it will suffice as a security plan and prior approval by TSA will not be required.

The TSGP guidance says that the Intercity Passenger Rail (IPR) and Freight Rail Security Grant Program (FRSGP) are included. Are these two new programs?

No, these programs are ongoing from previous years. All three programs (TSGP, IPR, and FRSGP) are authorized under a single line item in the FY 2009 Department of Homeland Security (DHS) appropriation. A total of $388.6 million is appropriated for these three programs, to include the $25 million allocation for IPR and the $15 million allocation for FRSGP. Similar amounts were appropriated to IPR and FRSGP in FY 2008.

Are subways included as an eligible mode?

Yes, subways are an eligible rail mode.

Will agencies be given pre-award spending authority?

No. Pre-award spending authority will not be authorized under the grants.

If an agency's security plan expires next year, can they still apply for a grant next year?

We hope that you would update and revise your security plan before applying.

When a Tier I agency submits its draft on January 13, 2009, will that agency receive a confirmation notice?

Yes, once you submit your initial applications or draft IJ and detailed budget, you will receive a confirmation notice from grants.gov to confirm that your application was received.

If a Tier I agency submits its draft IJ and budget on grants.gov can that agency resubmit a revised application on February 13, 2009?

Tier I agencies will submit their draft IJ and detailed budget through grants.gov by January 13, 2009 to meet the application deadline. Tier I agencies will then be required to upload their final IJ and detailed budget through the Secure Portal by February 13, 2009, to meet the deadline for final submissions.

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