EPA OTAQ updates BABA Implementation Procedures (memo/FAQs) for OTAQ programs

EPA OTAQ updated its BABA implementation procedures (FAQ-style memorandum) for OTAQ-administered federal financial assistance programs (e.g., DERA, Clean School Bus-related infrastructure, Clean Ports). The updated procedures clarify applicability (including that BABA applies to infrastructure components) and outline documentation and waiver-related expectations for recipients and contractors. Compliance teams supporting EPA-funded infrastructure projects should align procurement documentation, domestic-content substantiation, and waiver request workflows with the revised OTAQ procedures.