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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF THE INSPECTOR GENERAL FOR AUDITS
WESTERN DIVISION
75 HAWTHORNE STREET
1»TH FLOOR. MAIL CODE M
SAN FRANCISCO. CA 94105-3901
March 31, 1997
SUBJECT:
FROM:
TO:
Audit of Idaho's State Revolving Fund
Audit Report No. E1HTF5-10-0038-7100147
Truman R. Beele
Divisional Inspector General for Audit
Western Audit Division
Chuck Clarke
Regional Administrator
EPA Region 10
PURPOSE
The Office of Inspector General, Western Audit Division, has
completed an audit of Idaho's State Revolving Fund {SRF). The
purposes of the audit were to determine whether: (i) there was
sufficient demand from local communities to use all of the SRF
funds available; and {ii> the State's reporting systems were
adsquate.
SCOPE AND METHODOLOGY
We conducted a performance audit of selected elements of Idaho's
SRF program. We also did a limited test to determine whether the
amount of cash reported in Idaho's SRF financial statements
agreed with its general ledger. We did not perform a financial
audit of SRF cash or other accounts. Our audit was conducted in
accordance with Government Auditing Standards issued by the
Comptroller General. Our field work was conducted from March
1996 through June 1996. The audit covered Idaho's SRF program
from its inception in fiscal 1989 through the year ended
June 30, 1995.
We discussed Idaho's SRF Program with officials of EPA Region
10's Office of Ecosystems and Communities and Idaho's Department
of Health and Welfare, Division of Environmental Quality (DEQ).
Primal on Rtcycltd Paptr
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Idaho's State Revolving Fund
The audit included reviews of SRF Intended Use Plans (lUPs), SRF
Annual Reports, loan files, and the Wastewater Facility Loan
Account of the State's general ledger system. The audit was
performed giving consideration to SRF statutes and regulations,
Idaho's program information, and discussions with EPA Office of
Water officials. No previous performance audits of Idaho's SRF
Program had been performed.
BACKGROUND
The SRF Program was established in 1987 by Title VI of the
Federal Water Pollution Control Act {commonly referred to as the
Clean Water Act-CWA). The intent of the SRF program was to
replace the Wastewater Treatment Facilities Construction Grants
Program with self-sustaining revolving funds in each State. The
SRFs provide loans for construction of.wastewater treatment
facilities and other activities authorized under the Act.
Capitalization Grants were authorized to initially fund SRFs.
Annual appropriations were allotted to the States using a fixed
formula of percentages from the CWA. As of January 1995, EPA had
awarded $11.3 billion in grants to the States.
Title VI of the CWA requires that States annually prepare JUPs
that identify the intended uses of amounts available in their
SRFs. The lUPs include a description of the State's program
goals, a list of projects that are expected to receive funds, and
a description of the activities to be supported.
Title VI also requires that all funds be expended in an
expeditious and timely manner. SEC. 602. (B) requires States to
enter into binding commitments to provide assistance within 1
year after the receipt of a grant payment.
Grant funds are to be obligated, made available, and loans
awarded within established time limits.
Idaho received seven SRF Capitalization grants totaling $50.4
million during the period August 1989 through April 1995. When
combined with State matching funds, $60.5 million in SRF funds
was available for loans to local communities and for
administrative expenses. As of June 30, 1995, the State made
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Idaho's State Revolving Fund
binding commitments1 of $40.9 million (68 percent) for loans and
administrative expenses, and had disbursed $25 million (41
percent).
RESULTS IN BRIEF
Local demand for loans was not sufficient to use SRF funds
available during the first 6 years of the program. A gap between
demand and available funds reached a high point of more than $25
million at October 1, 1994. This gap of $25 million represented
more than double the largest annual grant ever awarded to Idaho.
The gap was reduced to $17 million at June 30, 1995 by two large
loans totaling $14 million. However, the $17 million still
exceeded more than double the fiscal 1995 grant.
Region 10 recognized Idaho's problem with loan demand in its
annual SRF reviews. While the Region has made reasonable efforts
with Idaho to overcome the problem, we believe that more needs to
be done. As noted by the Region, timely use of funds to high
priority water quality projects is fundamental to the purpose for
which SRF was established.
The low level of demand was primarily due to instances where
local communities decided to delay or discontinue plans for SRF
loans. The causes for this condition in local community demand
included: (i) the inability to get authorization or support from
their citizens to take on the debt and repayment burdens of SRF
loans; (ii) delays in getting permits: (iii) obtaining funds for
facilities from other sources; and (iv) changing priorities. We
recommend that DEQ increase efforts to ensure that there are a
sufficient number of qualified loan applicants.
Regarding the State's SRF related reporting systems, we concluded
they were inadequate in two respects. First, Idaho's annual lUPs
did not include enoxigh projects to account for all of the
expected SRF funds. To illustrate, the fiscal 1995 IUP listed
projects in support of the $6 million Federal grant, but did not
identify projects for an additional $14 million that was
i
In Idaho, a binding commitment is the equivalent of a loan to a local
community.
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Idaho'* state Revolving Fund
available. Second, amounts reported in the SRF financial
statements were not adequately controlled by DEQ's general ledger
and the cash balance reported in the fiscal 1995 financial
statements was under-reported by $91,295. To improve DEQ's
accountability for the SRF, we recommend that the lUPs account
for all funds and that DEQ obtain annual audits of the SRF
financial statements.
AGENCY COMMENTS and OIQ EVALUATION
We provided a draft report to Region 10 and DEQ on
January 31, 1997 with a request that the Region incorporate DEQ's
comments into its response. Region 10 responded on
March 24, 1997 and its response is included as APPENDIX A to this
report. The Region concurred with all of the recommendations and
described corrective actions that have been taken or will be
taken by the Region and DEQ. We agree that those actions will
implement the recommendations in our report.
ACTION REQUIRED
In its response to the draft report, Region 10 concurred with the
recommendations and described an action plan and milestone dates
or activities which respond to all aspects of the
recommendations. As a result, and as outlined in EPA Order 2750,
we find the Region's response to the report acceptable.
Therefore, we are closing this report in our tracking system as
of this date. The Region should, however, track implementation
of the action plan and milestone dates in the Management Audit
Tracking System.
This report identifies corrective actions the Office of Inspector
General {OIG) recommends involving EPA's SRF program. As such,
it represents the opinion of the OIG. Final determinations on
matters in the report will be made by EPA managers in accordance
with established EPA audit resolution procedures. Accordingly,
the findings described in this report do not necessarily
represent the final EPA position.
We have no objections to the further release of this report to
the public. Should you or your staff have any questions about
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Idaho's State Revolving Fund
this report, please contact me at (415) 744-2445 or Charles
Reisig, Team Leader at (206) 553-4032.
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Idaho1* State Revolving Fund
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Idaho's State Revolving Fund
FINDINGS AMP RECOMMENDATIONS
Lo
and has Imroved - But More
Necessar
Ir. the first 6 years of the SRF program demand for loans has not
been sufficient to obligate all of the funds that were available.
A chart for the period
July 1989 through June
1995 shows that the demand
for loans (cumulative loan
awards and expenses) had
not kept up with the
amount of available funds .
A gap between demand and
available funds increased
to more than $17 million
by October 1992, and
exceeded $25 million
during the period October
1994 to mid-June 1995.
The $25 million
represented more than
double the largest annual
gr£.nt that had ever been
mace to Idaho. While the
gap was reduced to $17 million at June 30, 1995 by two large
loans totaling $14 million, it was still sufficiently large to
warrant attention. At the $17 million dollar level, the gap
still was more than double the fiscal 1995 annual SRF grant of
about $7 million.
EPA,. Region 10, has appropriately recognized a growing problem
with demand in Idaho's SRF program during its annual program
evaluation reports over the last several years. Its 1992 report
stazed:
We are concerned that the SRF barely met the minimum
Federal requirement for loan commitments in 1992 . The
slowdown in loan commitments is particularly
troublesome in the current funding environment .... I
urge you to take action to ensure that the SRF will be
Cumulative Demand for SRF Funds
«fr
tn Afl —4
g40
•S30-
5 20-
/
/ — ' ,
/
/ ' /*"
/ /
, /• ""
" 1 i i i . 1 I [ i i 1 i i i ! i 1 i i : I I
7/B9 7/90 7/91 7/92 7/93 7/94 7/95
Date
Available Funds (Grant + State Match)
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"Idaho1* State Revolving Fund
able to meet the minimum Federal requirements for
commitments as well as meet the challenges that new
Federal appropriations will mean.... This weakening of
demand coupled with the anticipation of higher than
expected levels of Federal funding created concerns
that the State should look at new strategies and
markets for using SRF funds.... Management of the
program to commit available funds in a timely manner to
high priority water quality projects is fundamental to
the purpose for which the SRF was established.
Region 10's 1993 report stated:
Our review has shown that the Idaho State Program had
serious periods of noncotnpliance regarding commitment
levels during SFY1993. This unsatisfactory performance
in the area of loan commitments and several related
areas as detailed in our findings.... The State and
EPA identified several measures during the onsite visit
that could better ensure future compliance with the
commitment requirement...
Region 10's 1994 report stated:
The Idaho SRF program showed significant improvement
from last year by meeting the Federal Binding
Commitment requirement during all of 1994. However, we
remain concerned about the pace at which the program is
able to make new commitments.... Please note that the
need for timely commitments extends beyond the
discussion of the Federal binding commitment
requirement. At the end of 1994 the Idaho SRF had
accumulated about $1.2 million in interest revenues.
These revenues will accumulate at an increasing rate in
the years to come as more and more loans begin
repayment...
While the Region's efforts are recognized, we believe that the
$17 million of unused funds at June 30, 1995 shows that more
needs to be done. In addition, as noted in the Region's 1993
report, Idaho failed to meet its binding commitment requirement
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Idaho1* State Revolving Fund
in fiscal 1993. This is a statutory requirement that can lead to
sanctions against a State.
The CWA establishes minimum requirements for the timely award of
loans to local communities. Title VI, SEC. 602. (B) states that
"the State will enter into binding commitments to provide
assistance in accordance with the requirements of this title in
an amount equal to 120 percent of the amount of each such grant
payment within 1 year after the receipt of such grant payment."
As shown below for 3 quarters in fiscal 1993, the total amount of
loan awards fell below the required minimum level for binding
conmitments:
Quarter-
State Fiscal
Year
1-1993
2-1993
3-1993
Cumulative
Loans
$17,837,912
$17,862,912
$18,381,428
Binding
Commitment
Requirements
$17,868,383
$23,590,098
$23,590,098
Requirements
Not Met
($30,471)
($5,727,186)
($5,208,670)
While the Region and the State identified some measures and took
som>5 actions to improve future compliance, we attempted to focus
our effort on causes for the gap between loans awarded and SRF
funds available. We found a common cause was that several local
communities failed to follow through with their original plans to
obtain SRF loans. During the 6-year period covered by our audit,
there were 43 potential projects for which loans were planned.
However, of these potential project's, 16 projects (37 percent)
totaling $15 million did not result in loans. We interviewed
Idaho's regional project engineers to find out why these 16
planned loans had not been made. They provided the following as
reasons:
• Local communities could not get authorization or support
from their citizens to take on the debt and repayment
burdens of SRF loans (two projects totaling $2.4 million).
* Local communities could not obtain National Pollutant
Discharge Elimination System permits from EPA to set
allowable waste levels (three projects totaling $4.1
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Idaho'* State Revolving fund
million).
Local communities obtained other sources of funds from block
grants from other governmental agencies or self funding
(seven projects totaling $4.8 million).
Local communities decided to pursue other priorities (four
projects totaling $3.7 million).
Conclusions
While Idaho has made improvements in meeting the minimum Federal
requirement for loan commitments, a significant amount of funds
was still available to fund additional projects. Further
improvements can be made to ensure that available funds are
committed to high priority water quality projects in a timely
manner.
We encourage Region 10 to continue to focus on demand in its
annual plan reviews of Idaho's SRF program. In addition, while
the causes as to why local communities do not ultimately obtain
SRF loans may not be directly within the control of DEQ, we
believe that DEQ should place a greater emphasis on: (i) early
screening of potential applicants for their readiness to proceed
for a loan; and (ii) expanding the list of potential loan
applicants so that if a potential applicant is unable to proceed,
another can take its place.
Recommendat ions
We recommend that the Regional Administrator:
1. Continue to focus on demand during the Region's annual
reviews of Idaho's SRF Program.
2. Request DEQ to identify the steps that it is taking to
ensure a sufficient number of applicants that are ready to accept
loans, and other steps it is taking to accelerate the
timely use of funds to high priority projects.
10
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Idaho'* State Revolving Fund
Agency Comments and QIG Evaluation
Reigion 10 concurred with the recommendations and stated that
subsequent to the audit, actions have been taken to improve
demand and accelerate the timely use of funds to high priority
projects. DEQ has made several binding commitments which
substantially reduced the gap between funds available and funds
committed to projects. DEQ has also identified specific steps
that it is taking to accelerate the program pace. The Region
stated that it will continue to follow these improvements in its
program reviews. We are pleased at the positive steps that have
been taken and believe that they will result in more timely and
effective use of SRF funds.
11
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Idaho's State Revolving Fund
Idaho* a Reporting on Intended
e PX Was
Idaho's lUPs did not identify intended uses for all available SRF
funds as required. In fiscal 1995, Idaho's IUP only accounted
for $6 million of the $20 million in available SRP funds.
Idaho's lUPs listed projects for only the amount of Federal funds
requested for the current year. The state did not identify
projects for: (i) the amount of the State's matching funds; (ii)
funds available from interest earned on SRF funds; and (iii) SRF
funds that became available as a result of canceled projects that
were on prior lUPs.
We believe that the failure to identify intended uses for all
available SRF funds could be a contributing factor to Idaho's
limited success in using all SRF funds timely. When we inquired
as to causes for the above condition, a State SRF program
official said that they had been doing it the same way for years,
and EPA had never questioned their approach of only reporting
intended uses of the Federal funds portion of the SRF.
To illustrate our concern with Idaho's approach to identifying
the intended use of the SRF, the following discussion of its IUP
for Federal fiscal 1995 funds is provided. The IUP reported
projects and a reserve for administrative expenses that totaled
about $6 million, the amount of the Federal allotment. However,
Idaho's SRF (Idaho's Wastewater Facilities Loan Account) had
about $20 million in funds available. Thus, about $14 million in
SRF funds were not identified to any projects. It is noted that
Idaho's IUP stated that its primary purpose "is to identify the
proposed annual intended use of the funds available in Idaho's
Wastewater Facilities Loan Account." The $20 million available
in Idaho's SRF was determined as follows:
12
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Idaho'a State Revolving Fund
Sources of Funds:
Federal grants (1983 through 1995)
State match (1989 through 1995)
Interest from loan repayments
Interest on unused funds
Total Funds Provided
Uses of Funds (prior to the 1995 IUP):
Reserve for administrative expenses
Principal on outstanding loans
Total Funds Reserved and Used
Funds Available
As of
Jung 30. 1995
$50,445,915
10,089,183
1,230,525
83.946
S61.849.569
$ 2,007,109
40.030.918
S42.038.Q27
519,811.5422
Federal regulation 40 CFR H35.3150 specifies requirements for
annual lUPs. Under subparagraph(a), Purpose, it states that "The
State must prepare a plan identifying the intended uses of the
funds in the SRF and describing how those uses support the goals
of the SRF."... The IUP "must be prepared annually and must be
subjected to public comment and review before being submitted to
EPA. EPA must receive the IUP prior to the award of the
capitalization grant." Under subparagraph(c), Amending the IUP,
the regulation states that "The IUP project list may be changed
during the year ... as long as the projects have been previously
identified through the public participation process." An EPA
Headquarters program official stated that the intent of the
regulation was that lUPs should account for all funds in the SRF,
not just anticipated. Federal grant awards.
We asked an Idaho program official why the State's lUPs included
projects for only the amount of the Federal allotment. We were
told that they had been doing it the same way for years, and that
EPA had never questioned their approach of only reporting the
2 Of this total, $5.7 million was identified for projects in
the 1995 IUP, leaving a balance of $14 million not identified
with specific projects.
13
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Idaho'* State Revolving Fund
anticipated Federal allotment amount.
Conclusions
By excluding significant amounts of SRF funds from the IXIPs,
Idaho is not complying with the SRF regulations. In our view,
one purpose for the requirement is to assist EPA, at the time of
a new capitalization grant award, in assessing the effectiveness
of a State's planned use of SRF funds. We also believe that the
failure to identify intended uses for all available SRF funds
could be a contributing factor to Idaho's limited success in
using all SRF funds timely.
Reeommendat ion
We recommend that the Regional Administrator inform DEQ of the
requirement that lUPs should account for all available SRF funds
and that the Region include this requirement in its annual
reviews of Idaho's SRF Program.
Agency Comments and OIG Evaluation
Region 10 concurred with the recommendation and stated that DEQ
has implemented this recommendation and that no further action is
required. We consider this corrective action to be satisfactory.
14
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Idaho's State Revolving Fund
SRF Cash Was Not Properly Recorded or Reported
DiSQ's accounting system did not have sufficient controls to
ensure that SRF funds were recorded and reported accurately.
Cash balances reported in SRF financial statements were from
amounts on computer worksheets that did not agree with SRF
general ledger cash balance maintained by the State. The cash
bcilance reported in the fiscal 1995 financial statements was
under-reported by $91,295. Additionally, SRF funds were included
with State funds in some general ledger accounts.
The cash balance reported in the SRF financial statements for the
year ended June 30, 1995 did not agree with general ledger cash
subaccounts for the SRF under the Wastewater Facility Loan
Account. With the assistance of a Senior Accountant at DEQ, we
obtained the following information on the SRF cash balance that
should have been reported in the financial statements. We did
not perform a financial audit of SRF cash or other accounts.
As of
June 30. 1995 Notes
$2,080,258
72,842 1
1,239,235
(1.113.14R) 2
$2,279,187 3
83.946 4
52.363.133
£2.271.838 5
S 91.2QR
1. This account included SRF and State only funds.
The amount shown is the amount the accountant identified as the
SRF portion.
Cas;h Balance That Should Have Been Reported;
SRF accounts - Cash in Treasury
Clearing Account - Cash in Treasury
£FR (STA REV LOAN FUND WW) - Cash in
Treasury
SFR (STA REV LOAN FUND WW) - State Only
Loans - Cash in Treasury
Subtotal - Cash recorded in SRF accounts
Interest earned on SRF fund balance
Total
Cash Balance Reported
Under-reported Cash
15
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Idaho's State Revolving Fund
2. Even though the title contains "State Only Loans", the
accountant stated that this account was actually SRF.
3. This subtotal agrees with a Summary of State Revolving Fund
Loans as of June 30, 1995 prepared by DEQ which shows total loan
repayments of $2,279,187 (interest $1,230,525 and principal
$1,048,662).
4. This amount is the total interest earned on SRF funds that was
reported in the SRF financial statements. The accountant said
that interest earned on SRF funds was recorded together with
interest on State loan funds in the State loan accounts.
5. This total came from a computer worksheet.
The problems with the recording and reporting of SRF funds
occurred because Idaho had two loan programs whose transactions
were recorded in a series of subaccounts under the State's
Wastewater Facility Loan Account. One program was a prior State
Wastewater Facility Loan program for which payments were
currently being received. Transactions for this State only
program and the SRF program were recorded in subaccounts under
the Wastewater Facility Loan Account. The subaccounts were not
clearly titled, recording errors were made and not corrected, and
some of the accounts contained commingled funds. SRF financial
statement balances were kept on a separate computer worksheet
because the general ledger did not accurately reflect SRF
transactions.
Federal regulations under 40 CFR l35.3110(b) specify accounting
requirements for a SRF. It states that "The SRF can be
established within a multiple-purpose State financing program.
However, the SRF must be a separate account or series of accounts
that is dedicated solely to providing loans and other forms of
financial assistance, but not grants." A capitalization grant
agreement requirement is described in 40 CFR 1(35.3135(h)(1) which
states that "The State must agree to establish fiscal controls
and accounting procedures that are sufficient to assure proper
accounting for payments received by the SRF, disbursements made
by the SRF, and SRF balances at the beginning and end of the
accounting period."
16
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Idaho'* State Revolving Fund
Concilia ions
The size of the SRF, in excess of $60 million, requires that
adequate fiscal controls and accounting procedures be established
to ensure accountability for the fund assets. We believe that it
is; a serious internal control weakness when the general ledger
does not accurately reflect cash transactions and account
balances in the SRF. Memorandum records and computer worksheets
can be useful to expand upon or explain amounts in the general
ledger, but they should be reconcilable to and be controlled by
the general ledger.
The Statements on Auditing Standards state that establishing and
maintaining an internal control structure is an important
management responsibility (ref. AUH319A.69}. We believe that
DEQ's management could improve internal controls by: (i) using a
separate series of accounts for the SRF/ (ii) making a thorough
reconciliation of the SRF to ensure that all assets are accounted
for,- and (iii) engaging an independent public accountant to
render an opinion on the SRF financial statements after the above
activities have been accomplished.
Recommendat ion
We recommend that the Regional Administrator request DEQ to
obtain annual audited financial statements of the SRF in the
future.
Agency Comments and OIG ^valuation
Region 10 concurred with the recommendation and stated that it
will include an audit requirement as a grant condition when it
awards the next capitalization grant. We consider this
corrective action to be satisfactory.
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Idaho's State Revolving Fund
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18
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APPENDIX A
SUBJECT:
FROM:
TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 Sixth Avenue
Seattle, Washington 98101
MAR 2 4 t997
Comments on Draft Audit
of Idaho's State Revolving Fund Audit
Report No. E1HTF5-10-0038-
Janet Kesler
Grants and Acquisitions Unit
Truman R. Beeler
Divisional IG for Audit
Western Division
Thank-you for the opportunity to comment on your Draft
Audit of the Idaho State Revolving Fund(Report No. E1HTF5-10-
0033} that was transmitted to us by your letter of January 31,
1997. We have reviewed the Draft Audit internally and we have
reviewed the comments that were prepared by the Idaho Division of
Environmental Quality and provided to me by letter dated February
24, 1997. Our comments on the recommendations to Region 10
contained in the Draft Audit are based on these reviews. They
are as follows:
{1} Recommendation: Continue to focus on demand during the
Region's annual reviews of Idaho's SRF Program.
Response : Concur with comment.^
Demand was a problem during the audit period, but subsequent
to the audit, the S-ate made several binding commitments which
reduced substantially the gap between funds available and funds
committed to projects. EPA has made program pace a priority in
their ongoing communication with Idaho and other states in the
region. We will continue to follow these practices. No further
special action is required.
(2) Recommendation: Request DEQ identify the steps that it
is teiking to ensure a sufficient number of applicants are ready
to accept loans, and other steps it is taking to accelerate the
timely use of funds to high priority projects.
Response: Concur with comment.
19
r Prtni»a an ftocyctod P»p*r
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DEQ has identified the steps that they are taking to
accelerate program pace in their February 24 letter. EPA will
follow up on these in its routine reviews of the Idaho program.
No further special action is required.
(3) Recommendation: Regional Administrator inform DEQ of the
requirement that lUPs should account for all available SRF funds
and that the Region include this requirement in its annual
reviews of Idaho's SRF Program.
Response: Concur with Comment.
DEQ has implemented this recommendation. The 1996 IUP along
with the capitalization grant application to the EPA Region 10
contained lUPs which account for available SRF funds. No further
special action is required.
(4) Recommendation: We recommend that the Regional
Administrator request DEQ obtain annual audited financial
statements of the SRF in the future.
Response: Concur with recommendation.
EPA will include this requirement as a grant condition when
it awards the Idaho FY 1998 capitalization grant.
Thank you again for the opportunity to comment on the Draft
Audit. The directions that Idaho and EPA are taking with respect
to the SRF program are consistent with the concerns expressed in
the draft audit report. We will continue to make these a
priority in our implementation of this program in Region 10.
If you have specific questions on our comments on the draft
audit report for the Idaho SRF, please contact me at(206)-553-
1192 or Lee Daneker at(206)-553-1380.
cc: Lee Daneker, SRF Coordinator, Region 10
Charles Reisig, Team Leader, Seattle Branch
20
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Idaho's State Revolving Fund
APPENDIX B
REPORT DISTRIBUTION
Office of Inspector General
Inspector General (2410)
Headquarters Offipe
Audit Liaison, Office of Water (4102)
Director, Office of Wastewater Management (4201)
Director, Municipal Support Division (4204)
Chief, State Revolving Fund Branch (4204)
Agency Followup Official, (3101), Attn: Assistant
Administrator for Administration and Resource
Management
Agency Followup Coordinator (3304), Attn: Director,
Resource Management Division
Audit Foliowup Coordinator, Office of Wastewater
Management (4201)
Associate Administrator for Regional Operations and
State/Local Relations (1501)"
Audit Liaison, Grants Administration Division (3903F)
Region 10
Regional Administrator
Director, Office of Ecosystems and Communities
Supervisor, Geographic Unit
SRF Coordinator
21
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Idaho's State Revolving Fund
Audit Coordinator, Grants Administration Unit
External
General Accounting Office
22
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