When reporting MBE/WBE utilization under the EPA State Revolving Fund Program, is it acceptable to claim MBE and WBE participation generated from sources beyond the EPA capitalization amount(s) of the EPA grant?
A. SRF recipient may elect to claim MBE/WBE participation generated above and beyond the EPA Cap Grants. “Above and beyond the EPA Cap Grants” means all procurement monies expended for construction, equipment, supplies, and services for EPA SRF projects which EPA funds capitalizes DIRECTLY. It does NOT include expenditures for SRF projects funded by reimbursement funds (i.e., MBE/WBE expenditures paid for by principal plus interest paid back by SRF loan recipients to ALL SRF projects in a particular state for a given SRF reporting period, including but not limited to EPA loan projects). When a EPA SRF grant recipient elects to claim MBE/WBE participation “above and beyond the EPA CAP Grant”, it must also submit a “Total Procurement Amount” that includes not only the “MBE/WBE participation above and beyond the EPA CAP grants” but also a corresponding NON-MBE/WBE participation amount.