**FFP Response Matrix:**

**FY 2008 Guidelines Questions and Comments from Private Voluntary
Organizations (PVOs)**

+------------------------------------+---------------------------------+
| **Questions and Comments from      | **FFP Responses**               |
| PVOs**                             |                                 |
+====================================+=================================+
| 1\. The PVOs request guidance as   | Monetization requests in        |
| to whether or not monetization can | Single-Year Assistance Programs |
| be used in a Single-Year           | (SYAPs) will be considered on a |
| Assistance Program.                | case by case basis. However,    |
|                                    | given that SYAPs respond to     |
|                                    | emergency food aid needs, we do |
|                                    | not envision approving          |
|                                    | monetization in most cases.     |
+------------------------------------+---------------------------------+
| 2\. The PVOs request clarification | While it is recognized that     |
| as how PVOs should categorize      | emerging market access programs |
| commodity that might be used in an | have a fundamentally different  |
| emerging market access approach to | reason for the monetization     |
| smooth commercial commodity        | than traditional monetization   |
| markets. This approach is selling  | programs, they should still be  |
| commodity through local channels   | classified as a monetization    |
| to respond to potential price      | because FFP is expected to      |
| spikes and to ensure availability  | report on the extent to which   |
| of commodity. It can be used to    | monetization is used for any    |
| prevent vulnerable populations     | reason, not the extent to which |
| from further falling into food     | it is used primarily for        |
| insecurity. It is not for the      | generating funding for program  |
| generation of proceeds.            | implementation.                 |
+------------------------------------+---------------------------------+
| 3\. The PVOs request that FFP      | Given the complex legal and     |
| revisit the issue of NICRA         | financial issues associated     |
| allowability on ITSH costs, given  | with this subject, FFP intends  |
| the emphasis on using ITSH instead | to review all issues related to |
| of monetization proceeds. Many of  | allowability and categorization |
| these costs are direct costs that  | of costs in the future. At this |
| require a certain management       | time, however, indirect costs   |
| burden and should be treated as    | continue to be ineligible on    |
| such.                              | Internal Transport, Storage and |
|                                    | Handling (ITSH) costs in        |
|                                    | accordance with USAID's Food    |
|                                    | for Peace Information Bulleting |
|                                    | No. 04-01.                      |
+------------------------------------+---------------------------------+
| 4\. The guidelines indicate that   | This information will be        |
| priority countries are based on    | included in the revised 2008    |
| established criteria. We would     | Frequently Asked Questions      |
| like to request a revised copy of  | (FAQs) document and will be     |
| the priority countries with the    | posted on the FFP website.      |
| selection criteria as well as      |                                 |
| other countries that were          |                                 |
| considered be posted to the FFP    |                                 |
| website along with the guidance.   |                                 |
+------------------------------------+---------------------------------+
| 5\. The PVOS requests that a       | FFP has revised the FY 2008     |
| review calendar be provided for    | guidelines to include language  |
| the FY 2008 MYAP proposals as part | pertaining to the review        |
| of the guidance.                   | calendar. Exact steps in the    |
|                                    | review process depend on many   |
|                                    | factors and firm dates cannot   |
|                                    | be established for all          |
|                                    | submissions, such as review     |
|                                    | dates in the field, which may   |
|                                    | vary depending on the review    |
|                                    | committee members' travel       |
|                                    | schedules.                      |
+------------------------------------+---------------------------------+
| 6\. Lines 130-156: Definition of   | FFP has revised the definition  |
| Beneficiary:                       | of beneficiary in the FY 2008   |
|                                    | guidelines.                     |
| "In the case of food rations,      |                                 |
| direct beneficiaries include the   |                                 |
| individual recipient in the case   |                                 |
| of individual rations, and the     |                                 |
| recipient plus his/her family      |                                 |
| members in the case of family      |                                 |
| rations." (lines 142-146)          |                                 |
|                                    |                                 |
| "Direct beneficiaries do not       |                                 |
| include those who benefit          |                                 |
| indirectly from the goods and      |                                 |
| services provided to the direct    |                                 |
| beneficiaries, e.g., members of    |                                 |
| the household of a beneficiary     |                                 |
| farmer..." (lines 149-151)         |                                 |
|                                    |                                 |
| This definition is inconsistent.   |                                 |
| It is possible for a member of a   |                                 |
| household to receive a family      |                                 |
| ration for the entire household,   |                                 |
| and for all members of the         |                                 |
| household to be counted as direct  |                                 |
| beneficiaries. However, it is not  |                                 |
| possible for an entire household   |                                 |
| to be counted as direct            |                                 |
| beneficiaries when a household     |                                 |
| member receives another type of    |                                 |
| ration (i.e. food for work), or    |                                 |
| other good or service from a PVO.  |                                 |
| Either direct beneficiaries should |                                 |
| in all cases be direct recipients  |                                 |
| of goods and services (including   |                                 |
| all rations), or direct            |                                 |
| beneficiaries should include the   |                                 |
| household of the direct recipient  |                                 |
| of all goods and services. It is   |                                 |
| not clear why other household      |                                 |
| members of the recipient of a      |                                 |
| family ration would be considered  |                                 |
| direct beneficiaries while the     |                                 |
| household members of direct        |                                 |
| recipients of other types of       |                                 |
| rations, goods and services would  |                                 |
| not be so considered.              |                                 |
+------------------------------------+---------------------------------+
| 7\. Line 594: Please confirm the   | FFP has confirmed the website   |
| website address in the guidelines  | in the final FY 2008 guidelines |
| for FAQs.                          | for FAQs. Note that the link    |
|                                    | takes the reader to the section |
|                                    | where the guidelines are found  |
|                                    | as a PDF file; they are not     |
|                                    | directly linked.                |
+------------------------------------+---------------------------------+
| 8\. Line 655-657: The guidelines   | FFP has revised the language in |
| indicate that credit will be given | the FY 2008 guidelines to take  |
| to those that bring private sector | into account this comment,      |
| resources to the program. The PVOs | removing the term credit.       |
| request further clarification of   |                                 |
| the term "credit" and the weight   |                                 |
| of this credit. The evaluation     |                                 |
| criteria do not necessarily        |                                 |
| reflect "private sector"           |                                 |
| involvement but instead            |                                 |
| leveraging.                        |                                 |
+------------------------------------+---------------------------------+
| 9\. Line 748-752: The emphasis     | FFP has revised the language in |
| appears to be on changing risky    | the HIV section of "New Issues  |
| behaviors. However, for PLWHA,     | and Sectoral Guidance Updates"  |
| emphasis should also be placed on  | in the FY 2008 guidelines. The  |
| other livelihood programming for   | revised language takes into     |
| those already impacted. As those   | account questions and comments  |
| receiving ART interventions become | numbers 9, 10, 11 and 12 from   |
| physically capable of productive   | the PVOs.                       |
| activities, support, training, and |                                 |
| provision of credit and/or         |                                 |
| productive assets could in many    |                                 |
| circumstances facilitate the       |                                 |
| transition from food assistance to |                                 |
| independent self-support. Such     |                                 |
| opportunities should also be       |                                 |
| highlighted.                       |                                 |
+------------------------------------+---------------------------------+
| 10\. Line 758-763: To what extent  | Please see the response to      |
| does FFP expect PVOs to cover      | Comment #9 above.               |
| costs related to HIV prevention    |                                 |
| with PEPFAR funds rather than      |                                 |
| monetization? There is reference   |                                 |
| here to coordination with "already |                                 |
| existing programs funded through   |                                 |
| PEPFAR, Global Fund and other      |                                 |
| donors." If a PVO plans to submit  |                                 |
| a MYAP for a program that          |                                 |
| addresses HIV prevention, and they |                                 |
| do not have a PEPFAR program in    |                                 |
| the country that addresses these   |                                 |
| issues, should they submit a       |                                 |
| concurrent proposal to the USAID   |                                 |
| Mission for PEPFAR funds for this  |                                 |
| purpose? If so, where and to what  |                                 |
| extent should this PEPFAR proposal |                                 |
| be referenced within the MYAP      |                                 |
| proposal (i.e. in description of   |                                 |
| complementary resources,           |                                 |
| discussion of activities, within   |                                 |
| budgets, etc.)? Please clarify.    |                                 |
+------------------------------------+---------------------------------+
| 11\. Line 768-786: It appeared     | Please see the response to      |
| that this bullet list places       | Comment #9 above.               |
| little emphasis on livelihood      |                                 |
| activities (only mentioning once   |                                 |
| within the list) and more on       |                                 |
| addressing health. The PVOS        |                                 |
| request a more balanced approach.  |                                 |
+------------------------------------+---------------------------------+
| 12\. Line 780-781: The following   | Please see the response to      |
| line is unclear: "Safeguarding FFP | Comment #9 above.               |
| support for HIV-affected target    |                                 |
| groups that are uniquely covered   |                                 |
| by Title II programs, e.g.,        |                                 |
| HIV-affected households and high   |                                 |
| risk populations". Please clarify  |                                 |
| what is meant by safeguarding FFP  |                                 |
| support.                           |                                 |
+------------------------------------+---------------------------------+
| 13\. Lines 912-915, 950-974, and   | As a general rule, the types of |
| Figures 1 and 2: Given the NER     | programming and activities, as  |
| funding levels defined by the F    | well as their duration, should  |
| process for priority MYAP          | govern the decision as to which |
| countries, it is not clear how     | type of resources the PVO       |
| emergency resources (ER) would be  | requests. Given the envisioned  |
| integrated into transitional MYAPs | MYAPs and foreign aid reforms,  |
| (previously referred to as TAPs or | however, it is much more likely |
| DRPs) except in cases where MYAPs  | that emergency resources would  |
| have been funded regularly with ER | be added to MYAPs to address    |
| in the past (i.e. in Ethiopia).    | unanticipated emergency needs   |
| Would countries transitioning from | than new MYAPs would be started |
| emergency situations (such as DRC, | with emergency resources. We do |
| Burundi, and Afghanistan) be       | not envision starting new MYAPs |
| eligible to receive initial ER     | in DRC, Burundi and Afghanistan |
| funding to support new programs    | with emergency resources. We    |
| during FY08 above and beyond the F | will continue to consult on how |
| process levels that have been made | Ethiopia will be handled.       |
| public? If ER is anticipated to be |                                 |
| included in the year one budgets   | If new MYAPs may be started     |
| for these programs, how would a    | with emergency resources, this  |
| PVO obtain information with        | will be made known to PVOs. The |
| respect to availability or         | guidance has been revised to    |
| appropriateness of these funds?    | state that separate budgets and |
| The guidance states that a         | AERs are required at the time   |
| separate AER will be required for  | of submission of the MYAP for   |
| ER commodities, but how should the | year 1 use of ER and NER. Note  |
| cost of implementing emergency     | that in years 2 through 5, FFP  |
| safety-net activities be expressed | anticipates funding activities  |
| in the budget? Please clarify.     | tied to shocks with ER and      |
|                                    | thus, the ER budget and ER AER  |
|                                    | would be submitted after the    |
|                                    | shock occurs for accuracy and   |
|                                    | appropriateness.                |
+------------------------------------+---------------------------------+
| 14\. Lines 920-915: While the      | Please see the response to      |
| guidance states that ER may be     | Comment #13 above.              |
| requested for strengthening        |                                 |
| disaster management or emergency   |                                 |
| preparedness, as well as for       |                                 |
| mitigation activities during the   |                                 |
| course of the MYAP. Would this be  |                                 |
| in addition to the amount          |                                 |
| designated by the F process for    |                                 |
| the country in question, or would  |                                 |
| it be included within that amount? |                                 |
| As ER resources tend not to be     |                                 |
| used for these purposes,           |                                 |
| indicating that it might be        |                                 |
| possible to request them for such  |                                 |
| purchases is misleading.           |                                 |
+------------------------------------+---------------------------------+
| 15\. Lines 926-932: It is noted    | If a MYAP does not include      |
| that it is possible to request     | triggers, then a request for    |
| additional resources in the event  | additional resources in the     |
| of an emergency, and if this       | event of an emergency (greater  |
| request would be greater than 10   | than 10 percent in country      |
| percent of the program budget,     | resources) requires approval    |
| that it would be necessary to      | from both the Mission or        |
| request the resources from Food    | Regional Office and FFP/W. FFP  |
| for Peace Washington. No           | has revised the FY2008          |
| procedures are provided indicating | guidelines to clarify the       |
| how and to whom this request       | language. In some cases, a SYAP |
| should be made.                    | would be more appropriate.      |
+------------------------------------+---------------------------------+
| 16\. Lines 940-944, Lines 982-989, | FFP is not expecting PVOs to    |
| Figure 4: No procedures or         | submit proposals with           |
| guidance are provided for the      | hypothetical scenarios that may |
| manner in which a PVO would        | require funding in any year of  |
| propose hypothetical budget or     | the MYAP. FFP expects PVOs to   |
| commodity amounts for ER as part   | have spelled out activities     |
| of the MYAP proposal in the event  | that require either ER or NER   |
| of an anticipated emergency during | in year 1 or provide triggers   |
| the course of the MYAP to enable   | to result in requests for ER    |
| surge capacity, i.e. how to make   | resources in years 2 through 5. |
| use of a hypothetical budget line  | At the time the trigger is      |
| and/or a hypothetical AER.         | activated, the PVOs then assess |
| Instructions should be provided on | the severity of the emergency   |
| the methods of developing these    | and submit the ER AER and ER    |
| hypothetical requests for          | budget accordingly.             |
| inclusion in MYAPs. In addition,   |                                 |
| clarification should be provided   |                                 |
| on how such a response should be   |                                 |
| modeled (based on past experience, |                                 |
| based on the impact of potential   |                                 |
| risk factors)? What should be done |                                 |
| given that the size and severity   |                                 |
| of the shock can not be known?     |                                 |
| What would be the FFP threshold    |                                 |
| for response to a shock? What if   |                                 |
| the shock is more severe than      |                                 |
| anticipated and the hypothetical   |                                 |
| request for ER is inadequate? What |                                 |
| if the shock is not as severe as   |                                 |
| anticipated? More specific         |                                 |
| guidance is required to clarify    |                                 |
| these points.                      |                                 |
+------------------------------------+---------------------------------+
| 17\. Lines 946-1002: The PVOs      | FFP edited the descriptions     |
| request that these graphics be     | accompanying the graphics to    |
| expanded to more adequately        | represent the budgeting         |
| represent budgeting categories     | categories.                     |
| that the PVO will have to utilize. |                                 |
+------------------------------------+---------------------------------+
| 18\. Line 922-923: We request that | FFP edited the descriptions     |
| FFP make a note that the inclusion | accompanying the graphics to    |
| of additional ER funding in the    | ensure the same categories are  |
| graph was not included in the      | used.                           |
| original design but additional     |                                 |
| resources requested when needed.   |                                 |
| The graphics focus on livelihood   |                                 |
| and safety nets. Please ensure     |                                 |
| that the same categories are used  |                                 |
| throughout the guidance, executive |                                 |
| summary tables, and other annexes. |                                 |
+------------------------------------+---------------------------------+
| 19\. Line 1210-1211: Please        | Both the hard copy and          |
| clarify if both the hard copy and  | electronic copy must be         |
| the electronic copy must be        | submitted by 5:00 p.m. local    |
| submitted by 5:00 on the due date  | time on January 22, 2008.       |
| or whether an electronic copy      |                                 |
| would suffice with hard to follow  |                                 |
| (e.g., to the Missions).           |                                 |
+------------------------------------+---------------------------------+
| 20\. Lines 1251-1252: Annex A      | FFP has revised the language in |
| provides maximum page lengths for  | the FY 2008 guidelines and has  |
| the various sections. However, if  | corrected the page limit.       |
| all of these maximum page-lengths  |                                 |
| were conformed to, proposals with  |                                 |
| one objective would total 36½      |                                 |
| pages and those with two or more   |                                 |
| objectives would total 46 ½ pages. |                                 |
| The proposal maximum page limit    |                                 |
| should either be increased, or     |                                 |
| sections of the proposal should be |                                 |
| moved to annexes. Reducing a       |                                 |
| multi-objective proposal to        |                                 |
| conform to a 30 page limit would   |                                 |
| necessarily limit the PVO capacity |                                 |
| to address in a complete and       |                                 |
| comprehensive manner the proposal  |                                 |
| requirements. While the PVOS       |                                 |
| recognizes the FFP need to reduce  |                                 |
| paperwork for its CBOs and         |                                 |
| technical reviewers, it is likely  |                                 |
| that the items not addressed       |                                 |
| within the proposal completely and |                                 |
| comprehensively will require the   |                                 |
| submission of revised proposals in |                                 |
| response to questions. This then   |                                 |
| increases the amount of paperwork  |                                 |
| required by CBOs and technical     |                                 |
| reviewers. The PVOS recommends     |                                 |
| that either the page limit be      |                                 |
| raised to 35 for single-objective  |                                 |
| proposals and 45 for               |                                 |
| multi-objective proposals, or      |                                 |
| parts of the proposal format be    |                                 |
| moved to annexes.                  |                                 |
+------------------------------------+---------------------------------+
| 21\. Line 1256: FFP requests that  | FFP has revised the language in |
| files be in Microsoft Word and     | the FY 2008 guidelines to       |
| Excel. This line should also allow | include PDF files.              |
| for PDF files for signed documents |                                 |
| or other files as necessary (e.g., |                                 |
| NICRA document, certifications,    |                                 |
| etc.). For example, the IEE        |                                 |
| specifically requests digital      |                                 |
| files of pictures.                 |                                 |
+------------------------------------+---------------------------------+
| 22\. Lines 1261-1297: The          | FFP has revised the language in |
| distinction made between "core"    | the FY 2008 guidelines and      |
| versus "non-core" documents is not | eliminated the distinction      |
| particularly helpful to            | between "core" and "non-core"   |
| applicants. Most PVOs are          | documents.                      |
| accustomed to submitting proposals |                                 |
| within defined formats by specific |                                 |
| deadlines. They know that this is  |                                 |
| a competitive process and that if  |                                 |
| they want to win they need to      |                                 |
| fulfill the requirements. If a     |                                 |
| number of documents are not        |                                 |
| required for evaluation of the     |                                 |
| proposal perhaps they should not   |                                 |
| be submitted with the proposals    |                                 |
| and only requested if and when a   |                                 |
| TA is forthcoming. Alternatively,  |                                 |
| it might be better to go back to   |                                 |
| stating that a submission is       |                                 |
| considered incomplete if certain   |                                 |
| items are missing.                 |                                 |
+------------------------------------+---------------------------------+
| 23\. Lines 1286-1287: It is not    | Please see the response to      |
| clear why the Indicator            | Comment #22 above.              |
| Performance and Tracking Table and |                                 |
| corresponding narrative on the     |                                 |
| program's monitoring and           |                                 |
| evaluation plan are not considered |                                 |
| to be required for review of the   |                                 |
| proposal. In the Evaluation        |                                 |
| Criteria (Annex A1) a weight of    |                                 |
| 10% is assigned to monitoring and  |                                 |
| evaluation, and the applicant will |                                 |
| be graded on the IPTT in #19.      |                                 |
| Either the evaluation criteria     |                                 |
| should be changed, or the IPTT     |                                 |
| should be considered a document    |                                 |
| required for review of the         |                                 |
| proposal.                          |                                 |
+------------------------------------+---------------------------------+
| 24\. Lines 1292-1295: It is not    | Please see the response to      |
| clear why a final evaluation on    | Comment #22 above.              |
| file with FFP (or attached) for    |                                 |
| any follow-on Multi-Year           |                                 |
| Assistance Program proposals would |                                 |
| not be considered necessary for    |                                 |
| the review of the proposal. PVO    |                                 |
| Qualifications and Experience has  |                                 |
| a 15% weighting, and one of the    |                                 |
| two criteria (#22) in this section |                                 |
| refers to concerns raised in       |                                 |
| previous evaluations and audits.   |                                 |
| Also, as part of the M&E plan, the |                                 |
| PVO is required to conduct an      |                                 |
| evaluation in the penultimate year |                                 |
| of the program so that findings    |                                 |
| can be utilized in the design of   |                                 |
| the next program and for           |                                 |
| evaluation of future MYAP          |                                 |
| submissions by the PVO in the      |                                 |
| country. Either the evaluation     |                                 |
| findings should be eliminated as   |                                 |
| review criteria, or the final      |                                 |
| evaluation should be included as a |                                 |
| document required for the review   |                                 |
| of the proposal.                   |                                 |
+------------------------------------+---------------------------------+
| 25\. Line 1351-1356: "If a         | FFP has revised the language in |
| proposal is denied, USAID/W will   | the FY 2008 guidelines          |
| identify the reasons for the       | pertaining to denials.          |
| denial and the conditions that     |                                 |
| must be met for the approval of    |                                 |
| such proposal. In this case, and   |                                 |
| based on information provided,     |                                 |
| applicants will have one           |                                 |
| opportunity to revise and resubmit |                                 |
| the proposal according to the      |                                 |
| timeframe indicated by USAID/W     |                                 |
| (equal to the time allocated for   |                                 |
| responses to issues letters, in    |                                 |
| general). If USAID/W determines    |                                 |
| that funds are still available in  |                                 |
| the funding cycle, USAID/W will    |                                 |
| evaluate the revised proposal to   |                                 |
| determine whether funding is       |                                 |
| appropriate/warranted." The line   |                                 |
| regarding denial/approval appears  |                                 |
| contradictory. When would this     |                                 |
| denial be issued, at the time when |                                 |
| issues letters are generally       |                                 |
| issued or at a later time? Why     |                                 |
| would the PVO not simply get an    |                                 |
| issues letter (since it does not   |                                 |
| guarantee funding)? Also, does     |                                 |
| this mean that PVOs will have to   |                                 |
| respond to issues letters without  |                                 |
| knowing resource levels? This sets |                                 |
| PVOs up for multiple revisions as  |                                 |
| they await determination on the    |                                 |
| rejected proposal, and thus will   |                                 |
| be incurring additional expenses.  |                                 |
| Please clarify.                    |                                 |
+------------------------------------+---------------------------------+
| 26\. Line 1370-1373: It appears    | In order to comply with annual  |
| that FFP is considering the        | reporting requirements, FFP     |
| percentage of monetization for     | calculates the percentage of    |
| each program by calculating the    | monetization based on the       |
| monetization MT as a percentage of | metric tonnage. If FFP          |
| the total requested. Given that    | anticipated changes to          |
| monetization commodity is often    | monetization policy in          |
| bulk grains, which have a lower    | situations where the metrics    |
| value, and that transportation     | would have an impact, then we   |
| costs are often lower, the PVOs    | would consult on the metrics    |
| request that the percentage of     | used.                           |
| monetization be based on the C&F   |                                 |
| value of the monetization          |                                 |
| commodity as a percent of the      |                                 |
| total commodity value requested,   |                                 |
| not by the metric tonnage. This    |                                 |
| will more adequately reflect the   |                                 |
| breakout of FFP resources.         |                                 |
+------------------------------------+---------------------------------+
| 27\. Line 1370-1373: One issue the | Typically, PVOs and FFP         |
| PVOs deal with is the disconnect   | calculate the anticipated cost  |
| between the actual cost recovery   | recovery for monetization       |
| anticipated and the value          | programs differently because    |
| requested from the Executive       | the reasons for the             |
| Summary Tables. For example, for   | calculations are different. A   |
| many countries, the PVOs know that | PVO is looking at an activity   |
| the actual transportation costs    | (i.e. monetization), while FFP  |
| will be much lower than that       | is focusing on multi-year       |
| mandated by the Executive Summary  | budget planning.                |
| Tables. However, the Executive     |                                 |
| Summary Tables are based on set    | Specifically, for planning a    |
| rates. Therefore, FFP is           | monetization program, PVOs      |
| interpreting this at a higher      | provide anticipated cost        |
| value than what the PVO might.     | recovery calculations that are  |
|                                    | usually based upon estimated    |
|                                    | \"commodity and freight (C&F)\" |
|                                    | values that are formulated on   |
|                                    | an \"as requested basis\" using |
|                                    | commodity price estimates       |
|                                    | furnished by the U.S.           |
|                                    | Department of Agriculture       |
|                                    | (USDA) at or near the time of   |
|                                    | calling forward commodities or  |
|                                    | during annual program proposal  |
|                                    | submissions to FFP, These USDA  |
|                                    | price estimates usually factor  |
|                                    | in commercial commodity futures |
|                                    | prices.  PVOs also use          |
|                                    | estimated foreign flag ocean    |
|                                    | freight rates provided by       |
|                                    | USAID\'s Office of              |
|                                    | Transportation (OAA/T) on a     |
|                                    | periodic basis.  OAA/T\'s ocean |
|                                    | freight foreign flag rates are  |
|                                    | influenced by interim rate      |
|                                    | adjustments to comply with U.S. |
|                                    | Cargo Preference requirements   |
|                                    | and legislative mandates such   |
|                                    | as Small Business or Great      |
|                                    | Lakes set-asides, and may       |
|                                    | include price spikes due to     |
|                                    | increased freight rates         |
|                                    | considering rising fuel costs   |
|                                    | and other factors. By contrast, |
|                                    | for planning the FFP budget     |
|                                    | expenditures for current and    |
|                                    | soon to be approved programs    |
|                                    | over time, Title II MYAP        |
|                                    | Executive Summary Tables only   |
|                                    | capture C&F values that are     |
|                                    | based upon standardized,        |
|                                    | estimated price averages that   |
|                                    | are stored in FFP\'s automated  |
|                                    | Food for Peace Information      |
|                                    | System. These price averages    |
|                                    | are updated either twice a year |
|                                    | for commodity estimates, and in |
|                                    | two-to-three-year intervals for |
|                                    | standardized ocean freight      |
|                                    | estimates. FFP will continue    |
|                                    | with its current practice       |
|                                    | because the Executive Summary   |
|                                    | Tables are used to for          |
|                                    | multi-year budget planning, and |
|                                    | this information must be        |
|                                    | consistent and uniform. In the  |
|                                    | future, should FFP data needs   |
|                                    | change, then we would consult   |
|                                    | on the metrics used.            |
+------------------------------------+---------------------------------+
| 28\. Line 1371-1373: The guidance  | FFP has revised the language in |
| states that "At a minimum, for     | the FY 2008 guidelines,         |
| each program's total non-emergency | deleting the reference to each  |
| tonnage (includes both direct      | program's total non-emergency   |
| distribution and monetization      | tonnage.                        |
| commodities), 75 percent must be   |                                 |
| processed, fortified or bagged."   |                                 |
| It is the PVO's understanding that |                                 |
| the total NER tonnage for FFP must |                                 |
| be 75% processed, fortified or     |                                 |
| bagged, not each program. The PVOs |                                 |
| request that the language be       |                                 |
| modified to reflect this.          |                                 |
+------------------------------------+---------------------------------+
| 29\. Line 1375-1376: The language  | While PVOs should include       |
| contained herein, "Proposals with  | commodities that are            |
| a higher proportion of processed,  | appropriate to the country      |
| fortified or bagged commodities    | situation, context and Bellmon  |
| may be given priority." appears to | Analysis, it is also necessary  |
| deemphasize the issue of           | for FFP to meet legislative     |
| appropriateness within the country | mandates. Due to the mandates,  |
| context for any particular         | FFP must encourage the          |
| proposal as determined by the      | programming of value-added      |
| Bellmon Analysis.                  | commodities when there are      |
|                                    | options with regard to          |
|                                    | commodities chosen.             |
+------------------------------------+---------------------------------+
| 30\. Line 1378: The guidance       | FFP is prohibited from making a |
| language states that no 202(e)     | change on this issue because    |
| funds may be expended until the    | pre-approval of Section 202(e)  |
| obligation is made. Given past     | grant funds is prohibited by    |
| history of delayed obligations,    | statute in accordance with 22   |
| the PVOs request that this         | CFR 226 standard provisions and |
| language be reconsidered or        | OMB Circular A-122 cost         |
| additional language be added that  | principles.                     |
| details what the PVO should do for |                                 |
| pre-approval of spending authority |                                 |
| in the event of delays in          |                                 |
| obligation in order to keep        |                                 |
| programs running.                  |                                 |
+------------------------------------+---------------------------------+
| 31\. Line 1474-1476: The           | FFP has revised the language on |
| justification for switching        | justifying commodities changes  |
| commodities is unclear. The        | in the FY 2008 guidelines.      |
| example doesn't tie into the       |                                 |
| explanation.                       |                                 |
+------------------------------------+---------------------------------+
| 32\. Lines 1459-1462 state: "FFP   | FFP has revised the             |
| will closely scrutinize all        | monetization language in the FY |
| proposed monetization activities   | 2008 guidelines.                |
| and approve only those levels of   |                                 |
| monetization that are appropriate  |                                 |
| and directly tied to integrated    |                                 |
| activities that address the        |                                 |
| underlying causes of food          |                                 |
| insecurity, without in any way     |                                 |
| causing harm to local production   |                                 |
| or markets." Lines 1427- 1429      |                                 |
| state: "The key issue is not       |                                 |
| whether the monetization will have |                                 |
| an effect on the market, but       |                                 |
| rather the tolerability or         |                                 |
| desirability of the effect." The   |                                 |
| PVOs request that the former       |                                 |
| language be modified to reflect    |                                 |
| tolerable levels and ensure        |                                 |
| consistency in the guidance.       |                                 |
+------------------------------------+---------------------------------+
| 33\. Lines 1459-1462: The          | FFP has revised the language to |
| significant amount of              | include both monetization and   |
| justification required for         | distribution considerations, to |
| monetization requests is not       | the extent practicable, in the  |
| balanced with a similar            | FY 2008 guidelines.             |
| requirement for justification of   |                                 |
| distribution requests. There are   |                                 |
| many potential negative impacts    |                                 |
| that can result from commodity     |                                 |
| distribution. A more balanced and  |                                 |
| comprehensive approach would be to |                                 |
| request that the PVO provide       |                                 |
| evidence that they will minimize   |                                 |
| the potential negative impacts of  |                                 |
| commodity use within the program.  |                                 |
+------------------------------------+---------------------------------+
| 34\. Line 1591: Mission DA funding | FFP has revised the language to |
| is listed as an example of         | correct this error in the FY    |
| cost-share. Please explain or      | 2008 guidelines.                |
| modify.                            |                                 |
+------------------------------------+---------------------------------+
| 35\. Line 1627: Please change      | FFP has not revised the         |
| language from "or feasible" to     | language in the FY 2008         |
| "FFP prefers"                      | guidelines.                     |
+------------------------------------+---------------------------------+
| 36\. Line 1667-1668: Guidance      | PVOs should become familiar     |
| requests signed waivers with the   | with the Mission vehicle        |
| proposal. Please see note under    | procurement policy, but revised |
| Annex A, Format for procurement    | language has been included so   |
| policies below.                    | that signed waivers are not     |
|                                    | required at the time of the     |
|                                    | MYAP submission. Signed waivers |
|                                    | are required before the signing |
|                                    | of the Transfer Authorization.  |
+------------------------------------+---------------------------------+
| 37\. Line 1724-1730: FFP is        | FFP has revised the language to |
| indicating that it may publish     | eliminate the option that it    |
| accepted proposals and states that | may publish accepted proposals  |
| PVOs should make every effort to   | at this time in the FY 2008     |
| separate out confidential          | guidelines.                     |
| information. However, there are    |                                 |
| aspects of proposals that PVOs may |                                 |
| consider proprietary, such as      |                                 |
| internally standardized            |                                 |
| methodologies developed with       |                                 |
| non-Federal resources utilized     |                                 |
| within various types of programs   |                                 |
| funded by various donors, the      |                                 |
| publication of which could         |                                 |
| potentially compromise an          |                                 |
| organization's competitiveness.    |                                 |
| FFP should be aware that           |                                 |
| proprietary information may extend |                                 |
| beyond staff salaries, employment  |                                 |
| history and NICRA rates, and       |                                 |
| should consult PVOs accordingly    |                                 |
| before publicizing this            |                                 |
| information.                       |                                 |
+------------------------------------+---------------------------------+
| Annex A: Format                    | Please see the response to      |
|                                    | Comment #26 above.              |
| 38\. Title Page: FFP requests that |                                 |
| the total amount of metric tons be |                                 |
| broken out into monetization and   |                                 |
| direct distribution. The PVOs      |                                 |
| request that this be changed to    |                                 |
| the C&F value for monetization and |                                 |
| direct distribution. Given that    |                                 |
| both the cost of monetization      |                                 |
| commodity and transportation is    |                                 |
| typically lower than that for the  |                                 |
| direct distribution component,     |                                 |
| assessing the levels of            |                                 |
| monetization vs. direct            |                                 |
| distribution based on a            |                                 |
| calculation of MT does not provide |                                 |
| a true picture of the level of FFP |                                 |
| resources within a Title II        |                                 |
| program.                           |                                 |
+------------------------------------+---------------------------------+
| 39\. C.4. Sustainability Strategy: | FFP has revised the language    |
| The PVOs appreciate the offer of   | and eliminated the reference to |
| assistance for the CBO to help in  | CBO assistance in the FY 2008   |
| pursuing one of more of the        | guidelines.                     |
| linkages. However, the PVOs would  |                                 |
| also like clarification as to how  |                                 |
| equitable treatment of competing   |                                 |
| programs will be ensured. Given    |                                 |
| the risk of having an individual   |                                 |
| who is also rating the proposal be |                                 |
| involved in the design process,    |                                 |
| will all information be provided   |                                 |
| to all PVOs at the same time?      |                                 |
| Perhaps a better approach would be |                                 |
| for FFP to provide the names and   |                                 |
| email addresses of contacts and    |                                 |
| website addresses for potential    |                                 |
| linkage agencies                   |                                 |
+------------------------------------+---------------------------------+
| 40\. E. Detailed Implementation    | FFP has revised the language in |
| Plan: The guidance now requests    | the FY 2008 guidelines. The     |
| that the first year activities be  | first two years require         |
| described on a monthly basis and   | information on a quarterly      |
| that the out-years be described on | basis and the final years       |
| a quarterly basis. This level of   | require information on an       |
| detail for a new program,          | annual basis.                   |
| especially for the 4 or 5 years    |                                 |
| out, is significant. The PVOs      |                                 |
| request to provide only the        |                                 |
| detailed plan on a quarterly basis |                                 |
| for the first year and annual      |                                 |
| levels for the outyears. PVOs will |                                 |
| be providing more detailed plans   |                                 |
| in their PREPs for the outyears    |                                 |
| which will hopefully meet FFP's    |                                 |
| need for detail. Also reference    |                                 |
| comment above regarding page       |                                 |
| lengths.                           |                                 |
+------------------------------------+---------------------------------+
| 41\. Section F.2: Confidence       | FFP has revised the language    |
| intervals are not always available | and removed the reference to    |
| with a formally published number.  | confidence intervals in the FY  |
| Does this really need to be in the | 2008 guidelines.                |
| guidelines?                        |                                 |
+------------------------------------+---------------------------------+
| 42\. Section F.2.: Results,        | FFP expects to have additional  |
| Performance Indicators and         | guidance on triggers available  |
| Targets: Reference questions       | in October 2007. The document   |
| above. The text says that more     | and its location on the FFP     |
| guidance will be provided on       | website will be shared with the |
| trigger indicators. The PVOs       | Food Aid Consultative Group     |
| request clarification as to the    | (FACG).                         |
| anticipated timeframe. Will        |                                 |
| written guidance be provided in    |                                 |
| enough time to integrate this      |                                 |
| guidance effectively into MYAP     |                                 |
| submissions?                       |                                 |
+------------------------------------+---------------------------------+
| 43\. I.1.a.: AER -- The text       | FFP expects only minor changes  |
| requests that the AER in design be | in the AER, but it will be      |
| used in the interim. However these | posted soon, PVOs may submit    |
| were not provided with the draft   | comments within 30 days of      |
| guidance.                          | posting and FFP will consider   |
|                                    | the comments in finalizing the  |
|                                    | document for circulation to the |
|                                    | PVOs well before the MYAP due   |
|                                    | date of January 22, 2008.       |
+------------------------------------+---------------------------------+
| 44\. I.1.b: This has been deleted. | FFP has revised the language    |
| Section headings need to be        | and corrected this numbering in |
| adjusted to take into account its  | the FY 2008 guidelines.         |
| removal (i.e., jumps fro I.1.a to  |                                 |
| I.1.c).                            |                                 |
+------------------------------------+---------------------------------+
| 45\. I.1.d: Monetization Cost      | FFP has revised the             |
| Recovery Table: The PVOs note that | monetization cost recovery      |
| the far right column, Total/Avg.,  | table of the FY 2008 guidelines |
| is a simple average. The PVOs      | and confirmed that the average  |
| request that the formulas be       | used is a weighted average.     |
| adjusted to reflect weighted       |                                 |
| averages to better reflect the     |                                 |
| results when more than one         |                                 |
| commodity is programmed.           |                                 |
+------------------------------------+---------------------------------+
| 46\. I.3.: Management: New         | FFP has revised the language    |
| language has been added to reflect | and shifted some additional     |
| the justification of why partners  | management language to Section  |
| were selected. The PVOs believe    | B in the FY 2008 guidelines.    |
| this has already been addressed in |                                 |
| Section B. If something has not be |                                 |
| appropriately addressed in Section |                                 |
| B and is included in the new       |                                 |
| language, this language should be  |                                 |
| added to Section B.                |                                 |
+------------------------------------+---------------------------------+
| 47\. J. Procurement: FFP is now    | Please see the response to      |
| requesting that the procurement of | Comment #36 above.              |
| non-US equipment and Mission       |                                 |
| concurrence for the vehicles       |                                 |
| requested be provided as part of   |                                 |
| the proposal. The PVOs believe     |                                 |
| that having, and understanding the |                                 |
| Mission procurement and vehicle    |                                 |
| policies, and ensuring that the    |                                 |
| planned program is in line with    |                                 |
| these policies is sufficient.      |                                 |
| Given that PVOs often have to      |                                 |
| adjust their budgets, and          |                                 |
| subsequently their budget plans,   |                                 |
| after acceptance by FFP,           |                                 |
| requesting concurrence only once   |                                 |
| alleviates a burden on both the    |                                 |
| PVO and the Mission.               |                                 |
+------------------------------------+---------------------------------+
| Annex A1: Checklist                | FFP has verified all ratings    |
|                                    | and revised the language in the |
| 48\. General: The PVOs request     | FY 2008 guidelines.             |
| that FFP verify all ratings. Some  |                                 |
| questions did not have rating      |                                 |
| numbers attached (i.e., #12) while |                                 |
| others were only 0 to 3 (i.e.,     |                                 |
| #16). In the latter case, was this |                                 |
| intentional?                       |                                 |
+------------------------------------+---------------------------------+
| 49\. Question #11: The criteria    | FFP has revised the language to |
| are a mix of gender and HIV/AIDS.  | address this specific issue in  |
| As HIV/AIDS can be considered a    | the FY 2008 guidelines.         |
| vulnerability, much as others can  |                                 |
| (environment, political climate),  |                                 |
| the PVOs question mixing gender    |                                 |
| with a specific vulnerability and  |                                 |
| not others. This also applies to   |                                 |
| the criteria under sector specific |                                 |
| reviews.                           |                                 |
+------------------------------------+---------------------------------+
| 50\. Question #27: This is the     | FFP has revised the language to |
| same as last year's but still      | address these specific issues   |
| raises a couple of issues. The     | to the degree feasible and      |
| category of these criteria         | practicable in the FY 2008      |
| indicates that it is a review of   | guidelines. FFP's intention     |
| the Management Plan and Logistics  | based on discussions arising    |
| as it relates to direct            | from the Title II Streamling    |
| distribution and monetization.     | Report was to not change the    |
| However, all of the sub-bullets    | guidelines substantially during |
| relate only to monetization. Will  | its current strategic plan (FY  |
| FFP be looking at anything         | 2006-2010). FFP recognizes the  |
| specific with regard to how well   | importance of this issue and    |
| the direct distribution program is | intends to revisit this with    |
| spelled out and mitigation of      | guidelines to accompany its     |
| potential issues such as theft,    | next strategic plan.            |
| hijackings, diversion, spoilage,   |                                 |
| pipeline breaks, etc.? Also, it    |                                 |
| requests a separate monetization   |                                 |
| sales budget. However, no category |                                 |
| was listed in the example          |                                 |
| templates for the comprehensive    |                                 |
| and detailed budgets. Are PVOs     |                                 |
| expected to separate out these     |                                 |
| costs into a separate category     |                                 |
| (meaning there could many more     |                                 |
| budgets given some costs could     |                                 |
| come out of ITSH, some out of      |                                 |
| 202(e), some out of monetization   |                                 |
| proceeds, etc.)                    |                                 |
|                                    |                                 |
| Another related comment            |                                 |
| underscores the importance of      |                                 |
| distribution as well as            |                                 |
| monetization and states that (1)   |                                 |
| the program checklist for          |                                 |
| reviewers should include something |                                 |
| on the quality of the Bellmon      |                                 |
| Analyses done for distribution     |                                 |
| programs and (2) distribution      |                                 |
| programs are not scrutinized to    |                                 |
| the same degree as monetization    |                                 |
| programs as required legally. The  |                                 |
| comment continues to recommend     |                                 |
| that the policy section of the     |                                 |
| guidelines take this into account  |                                 |
| and that the Bellmon Analysis,     |                                 |
| local production, market           |                                 |
| disincentive and more be           |                                 |
| highlighted in detail and not      |                                 |
| simply be included as a sentence   |                                 |
| in the middle of the text with     |                                 |
| other various issues.              |                                 |
+------------------------------------+---------------------------------+
| 51\. Part 2, Page 4: Categories of | FFP has revised the language to |
| Intervention: There are            | be consistent with these new    |
| differences from the categories    | categories in the FY 2008       |
| used in the FY 2007 AER. For       | guidelines.                     |
| example, in the FY 2008 checklist, |                                 |
| there is no category for civil     |                                 |
| society strengthening, community   |                                 |
| capacity building, or emergency    |                                 |
| preparedness. Will the new FY 2008 |                                 |
| AER and executive summary tables   |                                 |
| be changed to be consistent with   |                                 |
| these new categories?              |                                 |
+------------------------------------+---------------------------------+
| 52\. Relevant Sectors: The PVOs    | FFP has revised the language    |
| request clarification to question  | and included instructions to    |
| #4 and how FFP will apply it if    | leave the score blank if it is  |
| rations are not part of the        | not applicable in the FY 2008   |
| intervention. There does not       | guidelines.                     |
| appear to be a N/A category.       |                                 |
+------------------------------------+---------------------------------+
| Annex A2: AER/Commodity Pipeline   | Please see the response to      |
|                                    | Comment #43 above.              |
| 53\. Not yet available for review. |                                 |
| How will PVOs be given the         |                                 |
| opportunity to review these prior  |                                 |
| to submission to the Federal       |                                 |
| Register?                          |                                 |
+------------------------------------+---------------------------------+
| Annex A3: Summary Request,         | FFP expects only minor changes, |
| Beneficiary Tables, and Executive  | and as in the case with the     |
| Summary Tables                     | AER, PVOs may submit comments   |
|                                    | on the summary request,         |
| 54\. Not yet available for review. | beneficiary tables and          |
| How will PVOs be given the         | executive summary tables within |
| opportunity to review these prior  | 30 days of posting and FFP will |
| to submission to the Federal       | consider the comments in        |
| Register?                          | finalizing the documents for    |
|                                    | circulation to the PVOs well    |
|                                    | before the MYAP due date of     |
|                                    | January 22, 2008.               |
+------------------------------------+---------------------------------+
| Annex B: Budget Guidance           | FFP has revised the language in |
|                                    | Annex B in the FY 2008          |
| 55\. In the first paragraph, the   | guidelines.                     |
| guidance requests a budget for     |                                 |
| emergency activities. This is      |                                 |
| contradictory to the Title II      |                                 |
| guidance overall.                  |                                 |
+------------------------------------+---------------------------------+
| 56\. Verbiage needs to be updated  | FFP has updated the language in |
| (e.g., DAP, resource request).     | the FY 2008 guidelines.         |
+------------------------------------+---------------------------------+
| Annex B1, B2, C, no comments       | \- -                            |
+------------------------------------+---------------------------------+
| Annex D: Environmental Guidance    | FFP has revised the language in |
|                                    | the FY 2008 guidelines.         |
| 61\. Section G. The text lists     |                                 |
| areas of intervention that may     |                                 |
| have negative determination with   |                                 |
| conditions, including ag/NRM, WS,  |                                 |
| etc., however it does not list     |                                 |
| health and nutrition or food       |                                 |
| distribution as a potential area   |                                 |
| of intervention which can have     |                                 |
| negative impacts.                  |                                 |
+------------------------------------+---------------------------------+
| 62\. Environmental Compliance and  | Monetization funding requests   |
| ESR Face sheets: The PVOs request  | from PVOs should be based upon  |
| clarification as to whether the    | the value of the estimated      |
| monetization funding requested is  | commodity and freight costs for |
| the value of the monetization      | the commodity to be sold, which |
| request or the actual monetization | takes into account USDA\'s      |
| budget.                            | commodity price estimates, and  |
|                                    | OAA/T\'s estimated ocean        |
|                                    | freight foreign flag rates that |
|                                    | are included in the             |
|                                    | Monetization Cost Recovery      |
|                                    | Table.  In contrast, PVOs\'     |
|                                    | monetization budgets will       |
|                                    | generally include other types   |
|                                    | of support costs such as        |
|                                    | associated staff support costs, |
|                                    | internal handling or transport  |
|                                    | costs, fees, or other direct    |
|                                    | and indirect costs in support   |
|                                    | of the monetization program.    |
+------------------------------------+---------------------------------+
| Annex E, F, G, no comments         | \- -                            |
+------------------------------------+---------------------------------+