ASDWA Provides Comments on OMB’s Proposed Revisions to the Agency’s Guidance for Grants and Agreements

Today (March 13), ASDWA submitted comments to the Office of Management and Budget’s (OMB) proposal to revise the Agency’s Guidance for Grants and Agreements. The proposed revisions are limited to the implementation of the Build America, Buy America Act (BABA) provisions of the Infrastructure Investments and Jobs Act (IIJA), which requires federal agencies to ensure that “none of the funds made available for a Federal financial assistance program for infrastructure, including each deficient program, may be obligated for a project unless all of the iron, steel, manufactured products, and construction materials used in the project are produced in the United States.”

ASDWA’s comments note that the association has had concerns with the workload that EPA staff will face as the Agency works to provide product-specific waivers under BABA. ASDWA is appreciative of OMB’s proposed guidance and hopes it will help EPA staff process these waivers in a timely fashion. ASDWA’s letter encourages OMB to continue to engage with EPA as the Agency begins to process these product-specific waivers to determine if more guidance is needed. Additionally, ASDWA’s letter asks for clarifications and additional information for many of the definitions included in the guidance, the primary area OMB asked for public comment.