Is it possible to distribute the majority of project funding in Year 2 and 3?

Yes. Applicants should commit to being able to issue its first Project RFA within one year of being selected as Principal Recipient (page 9 of the RFA), however this is not a threshold eligibility requirement. There are no specific requirements as to the timing of issuing Project RFAs and funding to subrecipients. However, applicants should be aware that EPA will provide funding to Principal Recipients as incrementally funded cooperative agreements. As such, your application should include an annualized budget and budget detail narrative for the program corresponding to the workplan project narrative covering each year of the program as described on page 33 of the RFA.