would likely participate in actual shipment planning,” thereby being able to“leave their state or Tribe with an action plan that could be used to implement a Section 180(c) program in the future” (ibid.). The states’ goals in “volunteering” to take part in the exercise were developed by the Interregional Team: 1. To better understand how the recommendations of the 180(c) Interregional Team (IRT) will apply to the Grant Program. 2. To gain experience and obtain feedback from the Mock Merit Review Panel on the budget justification process (e.g., the level of detail required in application justifications). 3. To evaluate the efficiency and effectiveness of the communication process between DOE and the applicants and to provide feedback to DOE. 4. To evaluate the proposed funding allocation method put forward by the IRT (ibid., p. 1). In 2015, the IRT worked with the exercise participants to evaluate how well the exercise helped them to achieve these goals. Regarding how the IRT recommendations would apply, the states rated their satisfaction as 3.6 out of 5 (5 being“completely satisfied”). On the positive side, the process clarified what qualified as "allowable activities," helped the states to understanding their potential needs, and improved their understanding of the DOE grant-making process. Work remained to be done, however, in testing the IRT’s funding allocation formula, defining terms, and identifying a resource for funding operational activities such as inspections (IRT 2014, p. 2). The experience working with the Mock Merit Review Panel was also mixed, earning a rating of 3.4 out of 5. Some states were not able to complete their applications and, as a result, did not benefit from a review. Some states that did receive feedback “perceived it as reflecting a limited understanding of the way governmental structures and politics can differ from state to state in ways that could affect planning and preparedness activities” (ibid., p. 3). Kevin Leuer, the MRMTC member from Minnesota at the time, served as a member of the Mock Merit Review Panel. According to Mr. Leuer, “the grant process and level of detail required were administratively burdensome on states, especially given the grants were non-competitive” (MRMTC 2016b, p. 4). Mr. Leuer added that not having a “concept of shipment operations (i.e., what security/ escorts/emergency response would be provided by DOE versus what would the state need to provide)” had made the exercise more difficult for the states (ibid.). Overall, though, he “thought the exercise was extremely beneficial and felt DOE would use the input received” (ibid.). Scoring the highest, at 4.3 out of 5, was the third goal of evaluating the efficiency and effectiveness of the communication process between DOE and the applicants. The survey respondents reported that the exercise was resulting in “a good working relationship with DOE” and highlighted DOE’s “flexibility” in accommodating the need for additional time. The states also appreciated the responsiveness of DOE and its contractors in addressing the states’ questions and concerns (ibid.).
The IRT’s input was incorporated into DOE-NE’s lessons-learned report on the exercise, published in March 2017. The report provides an excellent description of the exercise and the challenges and benefits of conducting it. Several of the findings stand out as particularly important from the states’ perspective: 1. Instead of asking states to apply for two grants, as envisioned in the 2008 Federal Register notice, DOE acknowledged that “one grant application, enacted in two phases, is expected to be sufficient” (Helvey 2017, p. vi). 2. DOE does not perceive a significant difference between cooperative agreements and grants; the states, however, do and have expressed a preference for grants. 3. In the process of planning and training for shipments, “significant effort is needed up front to discuss expectations and outcomes and to define more clearly the steps required” (ibid., p. v). This observation points to the need for longer lead times for states, Tribes, and DOE to work together prior to any shipments taking place. Conducting the exercise was a major milestone for the Section 180(c) AHWG. Among the tasks identified in connection with the exercise or in follow-up to it, the AHWG worked on developing a grant guidance document and a factsheet to help state/tribal participants justify to their management the investment of staff time
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