It appears that your NOFO is ONLY for pass-through to sub-recipients. Can a City apply to provide service in an EJ community through its own programs and not subcontract?

An applicant to the NOFO would be either a Principal Recipient or a coalition member, and not eligible for funding for on-the-ground GLRI-funded projects. Principal Recipients or coalition members would use RFA funding to develop the Project RFA, manage Project subawards, and provide technical and administrative support to Project Subrecipients. Project subrecipients, selected through the Project RFA, will complete the on-the-ground GLRI-funded projects.