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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
CENTRAL DIVISION
725 MINNESOTA AVENUE
KANSAS CiTY, KANSAS 66101
(912) £=1-7373
FAX; IS12) 551-7237
September 29, 1995
MEMORANDUM
SUBJECT;
FROM:
TO:
The Southwest Center for Environmental Research and
Policy (SCERP) Should Focus on Border Problem Solutions
Report No. E1FUFS-08-0019-5100528
Bennie Salem Ad*-*-*--*— *&—*-*-»—,
Acting Divisional Inspector General
for Audit
Gary M. Katz, Director
Grants Administration Division (3903F)
Jerry A. Kurtsweg, Director
Office of Program Management Operations (W947)
Attached is our report entitled "The Southwest Center for
Environmental Research and Policy Should Focus on Border Problem
Solutions." The report contains recommendations on jointly
developing a prioritized list of border problems, improving the
SCERP - Environmental Protection Agency (EPA) relationship,
developing clearer project evaluation criteria, stabilizing the
SCERP management structure, and distributing research
information. We summarized comments to the draft report and
included the complete SCERP and Office of Air and Radiation
responses as Appendices I and II respectively.
SCERP and EPA appear to have made progress in working more
closely in fiscal 1995. We hope that the results of our report
will provide direction for continued improvements in solving U.S.
- Mexican border environmental problems.
^•fr
The Director of the Grants Administration Division is the
primary action official. In accordance with EPA Order 2750, the
primary action official is required to provide this office a
written response to the audit report within 90 days of the final
audit report date. For corrective actions planned but not
completed by your response date, reference to specific milestone
dates will assist this office in deciding whether to close this
report.
RECYCLED
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This audit report contains findings that describe problems
the Office of Inspector General (OIG) has identified and
corrective actions OIG recommends. This audit report represents
the opinion of OIG. Final determinations on matters in this
audit report will be made by EPA managers in accordance with
established EPA audit resolution procedures. Accordingly, the
findings described in this audit report do not necessarily
represent the final EPA position.
We have no objections to the release of this report to the
public.
If you or your staff have any questions, please contact me
at (913) 551-7878 or Jeff Hart, Audit Manager in our Denver
office, at (303) 294-7520. Please refer to audit control number
E1FUF5-Q8-0019-5100528 on any correspondence.
Attachment
cc: Dr. William Raub, Director
National Center for Environmental Research and Quality
Assurance (8701)
Office of Research and Development
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EXECUTIVE SUMMARY
PURPOSE
In July 1994, 'the Environmental Protection Agency's (EPA)
Office of Research and Development (ORD) requested that the
Office of Inspector General audit three university research
centers funded by congressional legislative mandate. ORD
questioned the quality of research and the centers' use of
EPA funds.
The research center covered in this audit is the Southwest
Center for Environmental Research and Policy (SCERP), a
consortium of five U.S. and four Mexican universities. SCERP
received $9.9 million in EPA funds earmarked by Congress,
about $2 million each year between 1991 and 1995, to help
solve the severe environmental and health problems along the
U.S. - Mexican border.
We audited SCERP to determine if it effectively performed the
research contemplated in the legislation. In addition, we
determined if costs SCERP claimed through October 31, 1994,
were eligible, reasonable, and allocable to the respective
cooperative agreements (CA).
BACKGROUND
EPA involvement with SCERP began in 1991 in response to a
congressional mandate. Congress funded SCERP to "...initiate
a comprehensive analysis of possible solutions to the acute
air, water quality, and hazardous waste problems that plague
the U.S. - Mexico border region...."
U.S. members of the SCERP consortium are the University of
Texas at El Paso, University of Utah, Arizona State
University, New Mexico State University, and San Diego State
University. A SCERP Management Committee, comprised of one
member from each university, administered SCERP activities.
Chairmanship of the Committee rotated between universities on
an annual basis.
ORD was responsible for administration and oversight of the
CAs awarded for 1991, 1992, and 1993 research. The Office of
i
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Air and Radiation (OAR) assumed responsibility for SCERP
oversight in 1994. ORD and OAR used CAs to fund SCERP
research to encourage an active EPA role in setting the
direction and development of the research program.
Each year the SCERP Management Committee, in consultation
with EPA and others, selects a list of research proposals for
funding. Upon approval of the list of projects, the lead
university enters into subagreements with the other
consortium universities to fund their approved research
projects.
RESULTS IN BRIEF
SCERP and EPA could have better focused limited research
funding toward developing solutions to acute border
environmental problems by prioritizing research topics.
Although SCERP sought more EPA involvement recently, the
working relationship between SCERP and EPA hindered consensus
on the most important border environmental problems and
related research. Although not essential to SCERP's success,
a closer working relationship would help SCERP and EPA obtain
maximum benefit from limited EPA research funds.
PRINCIPAL FINDINGS
SCERP and EPA needed to better focus limited research funding
on developing solutions to the most acute environmental
problems along the U.S. - Mexican border. Although Congress
explicitly intended that research be focused on acute
problems and be solution-focused, SCERP did not prioritize
research topics in its proposal requests, did not clearly
define its selection criteria, and did not always select the
highest ranked research proposals. As a result, while some
SCERF-funded research projects focused on the solution of
acute border environmental problems, others did not..
Although SCERP recently sought more EPA involvement, the two
parties need to address conditions which continue to
frustrate relations and obstruct progress in finding
solutions to border environmental problems. SCERP and EPA
did not fully implement CA special conditions designed to
foster a strong working relationship. EPA limited its
participation because some staff had a negative perception of
the value of SCERP's research. SCERP and EPA needed to
ii
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provide stable SCERP and EPA management structures and
adequate resources to facilitate developing an effective
relationship. A closer working relationship would help
SCERP and EPA reach consensus on the highest priority
environmental problems and obtain maximum benefit from
limited EPA research funds.
We questioned costs of $51,880 claimed under the CAs as
ineligible for Federal participation. Most of these costs
were incurred for SCERP administrative functions.
RECOMMENDATIONS
To focus research on the most important border problems, we
recommend that the Director, Office of Program Management
Operations, OAR obtain input and develop a .prioritized list
or lists of border problems and related research, reach a
consensus with SCERP on border priorities for inclusion in
proposal requests, and work with SCERP to develop and apply
clear project evaluation criteria.
To improve the EPA - SCERP relationship, we also recommend
that the Director work with SCERP to develop a technical
monitoring program, and ensure that the system to distribute
research information to EPA staff is fully implemented.
We recommend that the Director, Grants Administration
Division recover the $51,880 of ineligible costs claimed by
SCERP under the CAs.
AUDITEE COMMENTS
SCERP and OAR generally agreed with our findings and
recommendations and in some cases had taken steps to
implement changes. EPA's Grants Administration Division
chose not to comment. Both SCERP and OAR offered comments to
clarify some issues and recommendations and we modified the
report as appropriate. We summarized auditee comments and
our evaluation at the end of each finding chapter and
included the full text of the SCERP and OAR comments as
Appendices I and II, respectively.
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY i
CHAPTERS
1 INTRODUCTION . 1
PURPOSE 1
BACKGROUND 1
SCOPE AND METHODOLOGY ...... 2
PRIOR AUDIT COVERAGE 5
2 PRIORITIZING BORDER PROBLEMS IS NECESSARY TO FOCUS
LIMITED RESEARCH RESOURCES 7
BORDER ENVIRONMENTAL PROBLEMS ARE SEVERE AND FUNDS
ARE LIMITED 7
SCERP'S PROPOSAL REQUESTS DID NOT PRIORITIZE
PROBLEMS TO FOCUS ON ACUTE BORDER ENVIRONMENTAL
PROBLEMS 8
SCERP DID NOT CLEARLY DEFINE SELECTION CRITERIA
OR CONSISTENTLY SELECT THE HIGHEST RANKED PROJECTS . 10
EPA DID NOT AGREE ON HIGHEST PRIORITY PROBLEMS .... 11
RESEARCH DID NOT CONSISTENTLY ADDRESS ACUTE
BORDER PROBLEMS . 12
CONCLUSION ..... ..... 13
RECOMMENDATIONS 14
AUDITEE COMMENTS AND OIG EVALUATION 14
3 A CLOSER WORKING RELATIONSHIP WOULD HELP BUILD
A CONSENSUS ON THE WORST BORDER PROBLEMS 17
EPA SOUGHT A CLOSE WORKING RELATIONSHIP THROUGH A
COOPERATIVE AGREEMENT 17
Report NO. E1FTTFS-08-0019-5100528
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SCERP AND EPA DID NOT FULLY IMPLEMENT CA SPECIAL
CONDITIONS .......... • ._ . . . ....... 18
NEGATIVE EPA STAFF PERCEPTIONS LIMITED
EPA PARTICIPATION ............... . . 20
EPA PARTICIPATION WAS LIMITED BY INADEQUATE
RESOURCES ......
22
FREQUENTLY CHANGING SCERP AND EPA MANAGEMENT
HINDERED DEVELOPING AN EFFECTIVE RELATIONSHIP
.. 22
CONCLUSION . . ..... ........ ....... 23
RECOMMENDATIONS ........... ......... 24
AUDITEE COMMENTS AND OIG EVALUATION ......... 24
4 SCERP UNIVERSITIES CLAIMED INELIGIBLE COSTS ...... 27
TRAVEL COSTS ................... .. 27
EQUIPMENT COSTS ............ ....... 28
CONTRACTUAL COSTS ......... ......... 30
MISCELLANEOUS COSTS . . . . ...... ....... 32
RECOMMENDATION . . ................. . 33
AUDITEE COMMENTS AND OIG EVALUATION ......... 33
APPENDICES
APPENDIX I: SCERP RESPONSE ..... . .......... 35
APPENDIX II: OAR RESPONSE .............. . . 50
APPENDIX III: ABBREVIATIONS ........ ....... 54
APPENDIX IV: DISTRIBUTION ... ............ . 55
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CHAPTER 1
INTRODUCTION
PURPOSE
In July 1994, the Environmental Protection Agency's (EPA)
Office of Research and Development (ORD) requested that the
Office of Inspector General (OIG) audit three university
research centers funded by congressional mandate. ORD
questioned the quality of research and the centers' use of
EPA funds.
The research center covered by this audit is the Southwest
Center for Environmental Research and Policy (SCERP). He
audited SCERP to determine if it was effectively meeting its
purpose as established by Congress. Specifically, our audit
objectives included determining if:
SCERP research benefitted EPA in meeting the
highest priority environmental problems in the
border region;
project accomplishments were within cooperative
agreement (CA) scope and EPA accepted final
research project reports; and
costs claimed by SCERP were eligible, reasonable,
and allocable to the CAs and complied with Federal
laws and regulations as well as CA terms and
conditions.
BACKGROUND
SCERP is a consortium of five U.S. and four Mexican
universities. U.S. universities include the University of
Texas at El Paso (UTEP), University of Utah (UTAH), Arizona
State University (ASU), New Mexico State University (NMSU),
and San Diego State University (SDSU). A Management
Committee comprised of one member from each university
primarily administered SCERP. The Management Committee was
responsible for establishing SCERP policy. Chairmanship of
the Management Committee rotated between the universities on
ah annual basis. SCERP administrative responsibilities
Report No. E1FUF5-08-0019-5100528
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shifted from UTEP in 1991 and 1992, to UTAH in 1993 and 1994,
and to ASU in 1995.
Congress earmarked $1.9 million in EPA's 1991 appropriation
for U.S. - Mexican border environmental research. The 1991
Senate Committee on Appropriations Report stated that funding
was provided.to initiate a comprehensive analysis of possible
solutions to the acute air, water quality, and hazardous
waste problems along the U.S. - Mexican border region of
Arizona, Utah, New Mexico, and Texas. The report recommended
a U.S. - Mexican public-private sector consortium
representing these four states to conduct such research and
organize a management conference to focus U.S. - Mexican
public-private sector expertise on the border environmental
issues. Four universities, in close coordination with
Congress, submitted a formal proposal to EPA for creation of
SCERP to carry out the programs and activities envisioned in
the Senate report. SCERP added SDSU as the fifth university
in the second year of funding.
Since 1991, EPA has awarded about $2 million annually through
a CA to the lead SCERP university. On July 31, 1991, ORD
awarded CA CR818296 for $1.9 million to UTEP as the lead
university. EPA awarded CR821542 for $2 million to UTAH on
June 7, 1993.
In 1994, the congressional appropriations conference report
provided a congressional add-on of $2 million "for air
quality monitoring and improvement along the U.S./Mexico
border region." The report was unclear as to the recipient
of the $2 million. Congress informed EPA that SCERP was the
intended recipient of the $2 million* As a result, the
Office of Air and Radiation (OAR) awarded CA CX823711 to UTAH
as the lead university.
The ORD decision memorandum for the initial CA stated that
special conditions were included to document the substantial
involvement of EPA in planning the work, allocating the
resources, and providing overall direction to SCERP.
SCOPE AND METHODOLOGY
We conducted our audit in accordance with Government Auditing
standards (1988 Revision) issued by the Comptroller General
of the U.S. and included tests of the accounting records and
other auditing procedures as we considered necessary. Other
Report NO. E1FUF5-08-0019-5100528
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than the issues discussed in this report, no other
significant issues cane to our attention that warranted
expanding the scope of our audit. We performed our fieldwork
from October 1994 to July 1995. We conducted both a
performance and a financial/compliance audit.
Performance Audit
We conducted a performance audit of CAs CR818296 and CR821542
to determine if SCERP research addressed the most urgent
border environmental problems. We also reviewed the research
project solicitation and selection process documentation for
CAs CX823711 and CX824099. We conducted the fieldwork at
each of the member universities except SDSU. We reviewed
records and held discussions with selected principal
investigators who currently or previously conducted research
under the CAs. We reviewed documentation and held
discussions with SCERP management regarding the
organizational structure, operation, and practices. We
reviewed SCERP's project identification and selection process
documentation. Additionally, we reviewed documents and held
discussions with SCERP and EPA officials regarding their
relationship and interaction.
We performed an extensive review of the project officers1
(PO) files and conducted interviews with the current and past
EPA POs in Headquarters. The results of our performance
audit of ORD's administration and management of CAs CR818296
and CR821542 will be included in an audit report to be issued
by the OIG Southern Audit Division. We met and held
discussions with EPA Regions 6 and 9 staff regarding their
relationship and interaction with SCERP and obtained
supporting documentation, as appropriate. We interviewed
members of the SCERP Management Committee and reviewed
committee correspondence. We reviewed reports and
interviewed a former member of the SCERP advisory board.
Financial/Compliance Audit
We conducted a financial/compliance audit to determine if the
costs incurred and claimed under CAs CR818296 and CR821542
were eligible, reasonable, and allocable under the CA terms
and conditions and in accord with laws and regulations. We
conducted an extensive financial/compliance audit at UTEP and
UTAH. We limited our review of ASU, NMSU, and SDSU to
selected financial information and documentation provided by
the universities. This audit represented a final audit of
Report NO. E1FUF5-08-0019-5100528
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costs claimed under CA CR818296 and an interim audit of costs
claimed under CA CR821542. Our financial/compliance audit
covered the period March 1, 1991, through October 31, 1994.
We requested the latest UTEP and UTAH Financial Status Report
(FSR) or certified statement of claimed costs on which to
base our audit. Performance under the UTEP CA CR818296 was
complete, and UTEP prepared a final FSR during our site
visit. As a result, this report may be used to close out the
CA. At the time of our site visit to UTAH, performance under
CA CR821542 was not complete. UTAH provided a certified
statement of costs incurred under its CA CR821542 which we
used as the basis for our interim audit.
We judgmentally selected a sample of costs claimed by each
university. Our sample consisted primarily of costs incurred
by UTEP and UTAH because they were the CA recipients. At
UTEP, we selected transactions from each research project and
administrative account. Our sample included salaries and
wages, fringe benefits, travel, supplies, equipment,
scholarships, and miscellaneous transactions. At UTAH, the
payroll expenses were certified on a quarterly basis. .As a
result, we judgmentally selected 10 of the 14 project
accounts and reviewed total payroll costs for 3 fiscal
quarters. Additionally, we judgmentally selected a sample of
UTAH'S non-payroll transactions including travel, supplies,
equipment, and miscellaneous costs. At ASU, SDSU, and NMSU
we selected three invoices from each university and requested
supporting documents. We reviewed the purchase orders,
invoices, travel authorizations, travel vouchers, timesheets,
and personnel records provided by the universities.
Our audit did not include a complete review of the
universities1 internal control systems. We relied on the
1991 and 1992 single audits of the five U.S. universities to
the extent possible in performance of our audit* We analyzed
a sample of incurred costs and related internal controls to
assure compliance with Federal statutory and regulatory
criteria and with the SCERP universities' policies and
procedures. Because of the inherent limitations in any
system of internal accounting control, errors or
irregularities may occur and not be detected. Except for the
questioned costs noted in Chapter 4, nothing came to our
attention which would cause us to believe that the
universities,1 procedures were not adequate for our purposes.
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PRIOR AUDIT COVERAGE
We did not identify any previous audits related to SCERP.
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• CHAPTER 2
PRIORITIZING BORDER PROBLEMS IS
NECESSARY TO FOCUS LIMITED RESEARCH RESOURCES
SCERP and EPA needed to better focus limited research funding
on developing solutions to the acute environmental problems
that plague the U.S. - Mexican border. Although Congress
explicitly intended that research be focused on acute
environmental problems and solutions, SCERP did not
prioritize research topics in its proposal requests.
Prioritizing topics in the proposal requests would have
assisted prospective researchers in focusing their proposals
on the most important border problems. SCERP did not always
select the highest ranked research proposals based on peer
reviewers' scores and did not adequately clarify project
selection criteria. Also, SCERP received mixed messages from
EPA regarding research priorities. As a result, while some
SCERP-funded research projects addressed important border
environmental problems, others did not adequately focus on
solutions to the most serious problems.
BORDER ENVIRONMENTAL PROBLEMS ARE
SEVERE AND FUNDS ARE LIMITED
Given the severe environmental and health problems along the
border and the extremely limited funding, SCERP needed to
prioritize border research to focus on the most critical and
acute problems. SCERP did identify some of the most critical-
environmental and health problems along the border, such as
contaminated drinking water and respiratory ailments.
Specifically, a 1993 SCERP review of border environmental
infrastructure needs stated that border air and water quality
in many border communities ranked among the most hazardous in
the U.S. and rivaled those seen in third world countries.
Earmarked funds provided to SCERP represented approximately
50 percent of EPA's entire 1994 and 1995 border research
budget totalling $3.4 and $4.4 million, respectively. SCERP
needed to evaluate the severity of border environmental
problems and direct its limited funding toward the most
severe problems directly impacting human health.
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SCERP'S PROPOSAL REQUESTS DID NOT PRIORITIZE
PROBLEMS TO FOCUS ON ACUTE BORDER
ENVIRONMENTAL PROBLEMS
Although Congress directed SCERP to focus research on solving
acute border environmental problems, SCERP did not prioritize
research topics in its proposal requests to ensure that it
directed research proposals to the most acute border
environmental problems. SCERP's proposal requests included
research topics from a variety of sources, including EPA, the
U.S. - Mexican border plan, border communities, non-
governmental organizations, State and local governments, and
other U.S. and Mexican Federal agencies. The 1993 and 1995
proposal requests included 73 and 59 unprioritized multi-
media research topics respectively.1
Developing border environmental priorities and related
research was a very difficult task* SCERP considered
priorities established by a variety of stakeholders including
environmental activist groups, trade groups, border
communities, and State and Federal agencies on both sides of
the border. Priorities vary and change over time depending
on geographic region, rotating personnel, changing
perceptions, and improved knowledge and understanding of
environmental issues.
SCERP and EPA relied on the border plan developed jointly by
the U.S. and Mexican Governments as one source to identify
border environmental problems, but border plan designers did
not prioritize environmental problems. The border plan
included an extensive list of several hundred environmental
problems identified by specific location and media (i.e.,
air, water, hazardous waste). However, it did not assess
risk associated with the border environmental problems or
classify needs in order of severity or importance. While
staff in Regions 6 and 9 stated that they relied on the
general priorities set out in the border plan, SCERP and EPA
had not attempted to develop a prioritized list of
environmental problems to specifically target research
opportunities. Additionally, the Udall Center, specializing
in environmental and related issues, claimed that the border
plan was not integrated and did not effectively guide the
1 Congress directed 1994 funds toward air quality research.
Consequently, the 1994 proposal requests included research topics
focused specifically on air quality.
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application of congressional border research appropriations.
The Udall Center stated that the border plan was a
compilation of "wish lists" developed through input from
Federal agencies on both sides of the border.
Also, SCERP did not prioritize research topics included in
the proposal requests in order of importance or severity.
For example, the 1995 proposal request assigned equal
priority to the following:
- Assessment of drinking water quality and innovative
water treatment methods; and
- Evaluation of the structure, practice, and funding
of environmental administration in Mexico,
including an analysis of emerging municipal, State,
and private components along with the evolving
Federal agencies.
By assigning equal priority to these topics, SCERP implied
that Mexico's environmental administration ranked alongside
drinking water assessment. In its response to our draft
report, SCERP stated that these proposals are of equal
importance. While both of these proposals address important
problems, we do not agree that they are equally important.
SCERP stated, and we agree, that the resolution of border
environmental issues requires trahsborder cooperation and
SCERP and EPA should understand how environmental
administration functions in Mexico.
SCERP also stated that water quality is a high priority in
the Texas colonias (informal subdevelopments without basic
infrastructure) and all along the Mexican side of the border.
However, water quality is only a minor issue for the more
developed regions on the U.S side of the border. SCERP
emphasized the importance of water quality in an August 1993
SCERP report, Review of U.S. - Mexico Border Environmental
Infrastructure Needs, stating that water pollution problems
present a threat to public health throughout the border
region. Each day more than 10 million gallons of raw sewage
are carried by the Tijuana River from Mexico into San Diego.
The river carries sewage, bacteria and viruses that cause
typhoid, salmonella, polio and 25 other deadly diseases.
Despite the importance of Mexico's environmental
administration, water quality issues present a more immediate
threat to human health and the environment.
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SCERP DID NOT CLEARLY DEFINE SELECTION
CRITERIA OR CONSISTENTLY SELECT
THE HIGHEST RANKED PROJECTS
Although SCERP used a peer review process for ranking
proposed research projects, it did not clearly define project
selection criteria or consistently select the highest ranked
proposals for funding. In 1995, of seven thrust areas, SCERP
selected projects from six. However, SCERP only selected the
highest ranked projects in four of the thrust areas.
Also, in 1995, SCERP used factors other than peer review
scoring to select projects for funding. The 1995 proposal
request stated that upon receipt of the peer review
evaluations, the SCERP Management Committee would meet to
consider the peer review panel recommendations and select
"...a balanced, coordinated group...n of proposals for
funding, but SCERP and EPA would make the final selection.
The projects selected were not those projects receiving the
highest average score by the peer review panel. For example,
SCERP evaluated eight proposals in the water quality thrust
area which resulted in a range of scores averaging from 65 to
90. SCERP selected two water quality projects, but neither
was the highest ranked proposal. Instead, SCERP selected the
third and fifth ranked proposals with average scores of 82
and 78, respectively.
SCERP and EPA conducted a project selection meeting to
determine which 1995 research projects should be funded.
Meeting participants included SCERP representatives and EPA
staff from Headquarters, Regions 6 and 9, and the border
liaison offices. The merits of each proposal were discussed
and participants were given the opportunity to provide input.
According to SCERP and EPA, the peer review scores were
considered; however, the final research projects were
selected based on a variety of other factors.
In 1994, SCERP did not submit all research proposals for peer
review and scoring. It set aside $229,227 for inclusion in
an "opportunity fund.11 According to the PO, the funds were
set aside to address projects submitted later in the year.
These projects were reviewed by SCERP technical experts and
approved by EPA; however, they were not evaluated or scored
by external peer reviewers.
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EPA DID NOT AGREE ON HIGHEST
PRIORITY PROBLEMS (
EPA minimized its impact and influence on the research
selection process by not reaching agreement among the various
EPA offices on the highest border environmental priorities.
EPA Headquarters, regional offices, and border offices
appeared to have different priorities for border research.
SCERP stated that:
...frequently the different regional offices and
divisions within EPA often had quite different
opinions on what SCERP should be doing... It has
not always been easy for us to sort out this
diversity of opinion....Within EPA, each region,
office, and individual ranks priorities for the
border in different ways....
Based on our discussions with representatives of various EPA
offices, they considered the border plan as a reasonable
source of border problems. However, they had not coordinated
their efforts and agreed on a prioritized list of the most
serious border environmental problems.
Review of the 1995 scores awarded by various EPA offices
showed a significant difference in research priorities. For
example, one 1995 project had the following scores:
Office Points
EPA Headquarters . 87
EPA Region 6 -38
EPA Region 6 Border Office 6
Similar discrepancies existed in scoring projects between the
regions. For example, a second 1995 project received the
following scores:
Office Points
EPA Headquarters 82
EPA Region 6 40
EPA Region 6 Border Office 54
EPA Region 9 72
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The differing research priorities between EPA offices diluted
EPA influence on research project selection and sent nixed
messages to SCERP regarding EPA priorities.
RESEARCH DIDHOT CONSISTENTLY ADDRESS
ACUTE BORDER PROBLEMS
SCERP research did not consistently address solutions to
acute border environmental problems. The severity of border
environmental problems and the limited resources required a
narrowly focused research program. Although some SCERP
research had a direct impact on the health and environment of
border communities, other research did not comply with
SCERP's congressional mandate to develop possible solutions
to acute border environmental problems.
SCERP stated that it had responded to pressing border
environmental needs, we found that some SCERP research
addressed possible solutions to acute border environmental
problems and had a direct beneficial impact on border
communities. In particular, SCERP researchers developed
methods to improve drinking water distribution and storage in
substandard housing along the border. SCERP researchers also
facilitated a binational network on improving water
availability in the El Paso - Juarez region. SCERP funded
research for developing low technology, low cost wastewater
treatment methods. The initial results of this research
indicated that these methods could be effective at removing
certain wastes. SCERP also conducted research to mitigate
the serious air pollution problem in the El Paso - Juarez air
basin caused by brick manufacturing and residential heating.
However, SCERP did not properly prioritize border problems
and consistently select research that matched those
priorities. Some projects did not address acute border human
health and environmental problems and had minimal direct
impact on border communities. For example, SCERP funded a
research project on selenium dynamics of the Upper Colorado
River Basin. The objective of this project was to create a
data base for selenium in the Upper Colorado River Basin with
a particular emphasis in the area above Lake Powell in Utah
and Colorado. The project report clearly indicated that this
research was not transferrable to other geographical areas.
Also, in 1994, SCERP provided funding to develop a proposal
for the establishment of a binational biosphere wetlands
reserve in the San Diego - Tijuana region. This project
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included ecosystem preservation and policy research.
Although preservation of a major wetland may be important, it
did not directly address the acute health and environmental
problems along the border.
SCERP spent almost half of its 1995 research budget on
computer modeling and other data management projects that
would not directly result in the solution of an immediate,
acute border environmental problem. The projects totaled
$809,000, or 48 percent, of the total projects funded, some
of these 1995 projects may be an important part of
environmental research in the long term and consume a
significant amount of SCERP funding over the next several
years. However, until the border population centers have
potable water, and safe, clean air to breathe, computer
modeling would not appear to be among the highest priority
border research topics.
We agree with SCERP that defining priorities is a complex
task. However, we believe it is an essential first step.
SCERP stated that its researchers "...view priorities through
the lenses of their particular disciplines and interests."
We believe priorities should be viewed through the common
lens of acute border environmental problems. SCERP also
stated that it:
...carefully considers the strength of its
researchers, which projects will provide added
synergy as part of an integrated program, and which
projects will constitute a focused
program....(italics added for emphasis)
We believe SCERP's research should be focused on a
prioritized list of the most severe border environmental
problems.
CONCLUSION
SCERP and EPA did not consistently focus limited research
funding on developing solutions to acute border environmental
problems. The severity of border environmental problems and
the limited resources required a narrowly focused research
program. SCERP's proposal requests included numerous
unprioritized research topics compiled from a variety of
sources. Prioritizing research would ensure that research.
proposals are focused first on critical border environmental
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problems. In addition, SCERP did not consistently select the
highest scoring research proposals based on peer reviewers'
scores. As a result, some SCERP research had a direct impact
on the health and environment of border communities, but
other research did not comply with SCERP's congressional
mandate.
RECOMMENDATIONS
He recommend that the Director, Office of Program Management
Operations, OAR: . ""
1. Obtain input from EPA Headquarters; regional
offices, selected research labs, the border
offices, and other knowledgeable EPA staff and
develop a prioritized list or lists, in descending
order of importance, of border environmental
problems that require research;
2. Reach a consensus with SCERP on a prioritized list
or lists of acute border problems requiring
research;
3. Establish procedures to confirm that SCERP's
proposal requests accurately reflect EPA'a and
SCERP .'s jointly developed prioritized list or
lists; and
4. Develop clear criteria with SCERP to evaluate and
select research projects based on the agreed
priority list or lists, and develop procedures with
SCERP to confirm consistent application of the
criteria.
AUDITEE COMMENTS AND OIG EVALUATION
SCERP and OAR generally agreed with our findings and
recommendations and in some cases had taken steps to
implement changes. Both SCERP and OAR offered comments to
clarify some issues and recommendations and we modified the
report as appropriate.
SCERP emphasized the difficulty of developing a single ranked
priority list that all stakeholders in the border region
could agree upon. SCERP stated that the border region is
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complex and dynamic. Needs and concerns vary from community
to community along the border. SCERP also emphasized the
importance of flexibility in establishing priorities to
ensure that as concerns change and become critical to the
environmental health of the border, priorities can be
modified. SCERP agreed that a more systematic approach to
defining border environmental priorities would be helpful.
SCERP stated that a consensus with EPA on a stratified list
of priorities to guide the annual proposal request and
project selection process would be possible and desirable.
SCERP recognized that developing a stratified list of
priorities, would more fully involve different EPA offices in
identifying priorities prior to the proposal request
development and would encourage SCERP researchers to develop
higher quality, more focused proposals. SCERP agreed to work
with OAR to include the analysis of priorities in the 1996
proposal request.
SCERP and OAR provided clarification regarding the criteria
used to select research projects. SCERP stated that final
project selection is made by the SCERP Management Committee
in concert with OAR and the regions. In addition to the peer
review scores, SCERP selects projects based on input from EPA
at decision meetings, synergy with other.SCERP projects,
potential for capacity building in the border region,
potential for binational participation in the project,
equitable distribution of projects in the different regions
along the border, and projects with near term and longer term
impacts. SCERP stated that it will work toward developing
clearer priorities in the 1996 proposal request and will
include more detail regarding the evaluation criteria applied
by the peer reviewers, the Management Committee, and EPA in
selecting projects for funding. Providing a more detailed
explanation of the selection criteria will make the selection
process more obvious and assist researchers in developing
proposals.
Initially, OAR stated that all activities included in the
proposal request were considered high priority and further
delineation of the priorities would provide no value.
However, during our exit conference, OAR agreed that there
would be benefit to narrowing the list of priorities included
in the proposal request. OAR stated that it would be willing
to work with SCERP to reach consensus on some kind of ranking
system to better focus research efforts on high priority
border problems. Specifically, OAR stated that it is
considering establishing a subcommittee of the Clean Air Act
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Advisory Committee to focus on border environmental
priorities.
Region 6 commented that SCERP had good information from which
to build a relevant priority list based on information SCERP
gathered in workshops beginning in 1991, and on specific
priority lists Region 6 staff provided SCERP. Region 6 also
stated it has always been confused about SCERP's project
ranking process and agreed SCERP needed to establish a more
objective methodology.
While we agree that developing consensus on a single
prioritized list of border environmental problems may be
difficult, we believe a more systematic approach is essential
to solve the most acute problems as required by the
congressional mandate. We agree that developing a rank-order
list or lists of problems—stratified by geography, media, or
other strata—is both possible and necessary. We also agree
that priorities must be flexible and modified as frequently
as necessary to remain effective.
We also believe that a more open, systematic project
evaluation and selection process with clear criteria would
help focus attention on the most important problems and
improve relationships between SCERP and EPA staff. Clearer
criteria will help prospective researchers better focus their
proposals. Clearer criteria will also assist unsuccessful
applicants and EPA staff to better understand the reasons
certain projects were funded over others.
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CHAPTER 3
A CLOSER WORKING RELATIONSHIP WOULD HELP
BUILD A CONSENSUS ON THE WORST BORDER PROBLEMS
Although SCERP sought more recent EPA involvement, the
working relationship between SCERP and EPA hindered reaching
consensus on the most important border environmental problems
and related research. SCERP and EPA did not fully implement
CA special conditions designed to foster a strong working
relationship. Negative perceptions regarding the 'value of
SCERP research deterred EPA regional staff from becoming more
actively involved with SCERP. Inadequate EPA staff and
travel resources also limited EPA participation. Frequent
changes in the SCERP and EPA management structures impeded
development of an effective relationship. Establishing an
earlier close working relationship would have helped SCERP
and EPA reach consensus on the highest priority environmental
problems and obtain maximum benefit from limited EPA research
funds.
EPA SOUGHTACLOSE WORKING RELATIONSHIP
THROUGH A COOPERATIVE AGREEMENT
EPA used a CA to allow EPA substantial influence in the
content and direction of the SCERP research program. Code of
Federal Regulations (CFR), Title 40, subpart 30.200, defines
a CA as an assistance agreement in which EPA anticipated
substantial involvement during project performance.
Additionally, the CFR defines a PO as "The EPA official
designated in the assistance agreement as EPA's program
contact with the recipient...responsible for monitoring the
project."
To allow and encourage meaningful EPA participation, CAs
CR818296 and CR821542 (covering 1991, 1992, and 1993)
included special conditions which required that:
r
— the PO appoint EPA technical advisors to major
thrust areas and specific project tasks;
— EPA technical advisors provide quarterly progress
reports to the PO and SCERP Chairperson;
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the PO establish an EPA Steering committee to
assist on matters of agency policy, strategy, and
programs pertinent to SCERP activities;
the SCERP Chairperson involve the PO directly in
SCERP activities and development including
definition of thrust areas and specific project
task initiatives;
SCERP submit quarterly and final reports to the PO;
the PO conduct an annual program review; and
the PO and SCERP Chairperson work together to
promote and disseminate research results.
SCERP AND EPA DID NOT J'TFtT-Y IMPLEMENT
CA SPECIAL CONDITIONS
Although EPA included and SCERP agreed to the CA special
conditions meant to foster a strong working relationship,
SCERP and EPA did not fully implement the conditions. The
special conditions were important because they provided for
frequent, meaningful communication between a broad spectrum
of EPA staff and SCERP researchers. This communication was
critical due to the number of universities involved and the
multi-media nature of SCERP's research program. The
assistance and participation of EPA regional and other staff
was also important .to help maximize the value of SCERP
research.
The technical monitoring program required by the CA special
conditions was critical to establishing a close working
relationship at the staff level, but was not implemented.
EPA never assigned the technical advisors specified by the
CAs. In fact, SCERP did not inform SCERP researchers that
EPA technical staff were available for consultation. Any
interaction between SCERP and EPA researchers was voluntary
and coincidental. Some individual SCERP researchers and
regional staff consulted on individual research projects, but
interaction was infrequent and at each individual* s.
initiative.
A technical monitoring program with interaction at the
working level would have helped maximize the value of SCERP's
research. EPA regional staff would have become more
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knowledgeable of the actual research being performed and
would have been able to integrate research results into their
own work and apply the results toward solutions of specific
problems. Also, SCERP researchers would have had a better
idea of EPA's research needs and could have better focused
their research to address EPA's specific needs. The
technical monitors were essential to keep the PO adequately
informed on the direction and progress of the many individual
research projects which spanned EPA media programs. Without
the technical -monitoring program, contact between SCERP and
EPA was largely limited to the management level.
Also, the PO never fully implemented the special condition to
establish an EPA Steering Committee. This committee, like
the technical monitoring program, would have facilitated
regular communication among SCERP and EPA staff, promoted
consensus-building, and helped to maximize SCERP research
benefits. The committee•s purpose was to assist the PO on
EPA strategy and programs and thereby help guide the
direction of SCERP's research. The PO appointed two regional
and two Headquarters representatives to an interim steering
committee and obtained some input from these individuals.
However, only one media program office was included. We
found no evidence that the individuals ever met as a group,
that SCERP was consulted on committee appointments as the CA
required, or that a permanent committee was ever established.
The PO acknowledged that the committee was never formally
established. As a result, the committee never served its
intended purpose.
Direct involvement of the EPA PO in SCERP activities and
project development was sporadic at best in the early years.
However, more recently, SCERP and the current PO indicated
that EPA is more fully involved in SCERP activities. SCERP
acknowledged it did not work closely with EPA in research
proposal selection during its early years. However, as of
July 1995, SCERP and EPA representatives had met three times
to plan, review, and select fiscal 1995 research proposals.
The PO did not effectively implement the special conditions
concerning quarterly reports and annual program reviews. The
PO generally did not use SCERP's quarterly reports or other
published research results to become knowledgeable of the
many individual SCERP research projects and did not
distribute research results to the EPA regional offices
responsible for the border areas. . As a result, regional
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staff were generally unaware and unsupportive of SCERP
research activities.
SCERP did not implement an information dissemination plan to
assist in keeping the EPA regions informed of on-going
research and could have stimulated greater interest and
interaction between SCERP researchers and regional technical
staff. On October 30, 1992, SCERP provided EPA with a SCERP
protocol entitled, "Research, Education and Training
Publication Policy." This protocol contained guidelines and
procedures for disseminating SCERP research findings.
Procedure number 7 of the guidelines states, "The SCERP
Executive Director....submits the research project reports,
and copies of articles written as a result of the research to
EPA ORD, 6IA [Office of International Activities], and
Regions 6 and 9...." However, SCERP did not follow this
protocol.
ORD recently disclosed that it abolished several of the
special conditions meant to foster a close working
relationship with SCERP. ORD replaced the technical
monitoring program and the EPA Steering Committee with an EPA
Science Advisory Committee because the PO "...never had
success relying on EPA personnel who are working basically as
volunteers and who may have conflicting priorities...." ORD
also abolished quarterly reporting in favor of annual
reporting.
In 1994, OAR eliminated all the above special conditions from
its CA CX8237H, except those requiring quarterly and final
project reports and the PC's annual reviews.
NEGATIVE EPA STAFF PERCEPTIONS LIMITED
EPA PARTICIPATION
While we recognize that SCERP recently obtained greater EPA
participation, our discussions with EPA regional staff
confirmed they are not convinced that changes to the research
project selection process have significantly improved
research project selection. EPA's skepticism and limited
participation stemmed from some staff perceptions regarding
the value of SCERP*s research. EPA regional staff perceived
that their participation had no real impact or was not
considered important by SCERP. One of the ORD POs explained
that EPA staff were frustrated because they perceived SCERP
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was generally unwilling to negotiate whenever SCERP and EPA
were unable to agree on an issue.
SCERP generally agreed it had not worked closely with EPA
during the first 2 years but claimed a consensus was reached
on the 1995 SCERP research program. SCERP stated that its
Management Committee "...as a matter of continuing policy
refuses to support research that does not have relevance to
resolution of a critical border environmental issue.*1 SCERP
also claimed that EPA had been much more active in project
selection since 1992.
Discussions with EPA regional staff indicated that they
thought their opinions and advice were largely ignored by
SCERP. EPA Regions 6 and 9 staff stated that the majority of
SCERP research did not address high priority problems along
the border and had little practical value. Because EPA is
mandated by Congress to provide funds to SCERP, EPA regional
staff believed they had no recourse even if they considered
SCERP's performance unacceptable. Regional staff generally
stated that the funding provided to SCERP would be better
used if regions were allowed to award the funds to local
communities or to a competitive research facility with
specific research goals.
Our review of the 1995 research proposal scoring provided
some insight .into the basis for EPA staff's perception.
Comparison of the scoring of the 1995 research proposals
highlighted the differences between those evaluators actively
engaged in research (SCERP and EPA Headquarters personnel)
and the EPA regional staff and border offices. In the water
thrust area, of the regional staff's two highest ranked
proposals, neither were selected. Instead, SCERP selected
and EPA approved the third and fifth ranked proposals in the
thrust area.
Hore significantly, peer reviewer scores showed limited
interest or enthusiasm by the regions and border offices on a
group of 1995 data management project proposals. Of the
$1.67 million in total research projects selected for 1995
funding, $809,000 (or 48 percent) was for data management
projects. The regions and EPA's El Paso Border Office gave
these proposals a combined average score of 70 on a scale of
100. SCERP representatives and EPA Headquarters gave these
same proposals an average score of 97. On 4 of the selected
data management proposals, a SCERP representative assigned a
combined average score of 99.75, just short of a perfect
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score. This apparent disparity in research priorities
between SCERP and EPA regions may account for the regional
perception that the SCERP research has limited utility in
addressing immediate and acute environmental problems on the
border.
SCERP stated that, "...as the level of interaction between
SCERP project leaders and EPA subject specialists increases,
we feel that perceptions of derived benefits on the part of
EPA staff will change," and we agree.
EPA PARTICIPATION WAS LIMITED
BY INADEQUATE RESOURCES
Lack of adequate EPA staff and travel resources hampered
development of an effective relationship. The first EPA PO
had responsibility for as many as 17 research centers, and
the second PO had responsibility for as many as 21 research
centers. The first PO's supervisor estimated that a PO can
effectively manage four or five centers. For example, the
lack of adequate EPA resources contributed to ORD's inability
to implement the special CA conditions designed to foster a
close relationship, according to the ORD PO.
To effectively implement the special conditions, the PO
needed the active participation of the EPA regional offices.
However, Regions 6 and 9 staff stated they were provided no
additional staff or travel funds to assist with SCERP. The
regional staff's choices were to perform the work officially
assigned to them and upon which their job performance was
rated or to participate with SCERP, which was not part of
their official responsibilities. Had regional staff used
their limited travel funds to visit SCERP researchers or
attend SCERP conferences, they would not have had travel
funds to fulfill their official responsibilities. Because
regional staff did not perceive SCERP research to be of high
utility or benefit, they were especially unwilling to use
their limited resources for SCERP.
FREQUENTLY CHANGING SCERP AND EPA MANAGEMENT
HINDERED DEVELOPING AN EFFECTIVE RELATIONSHIP
Frequent changes in POs made it difficult to establish an
effective working relationship. EPA responsibility for SCERP
shifted among three different POs and from one EPA
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Headquarters office to another in 4 years. Two POs were
responsible for monitoring SCERP. An ORD PO was responsible
for the first two CAs, and an OAR PO was responsible for
projects funded in 1994 and 1995.
SCERP's rotation of the Chairmanship of the Management
Committee to a different university each year also
complicated interactions with EPA. SCERP's organizational
structure was complicated by its multi-institutional
membership and wide geographical dispersion. SCERP was
administered primarily by the Management Committee comprised
of one member from each of the five member universities. The
constant rotation of the chairmanship created confusion
within EPA regarding who at SCERP was "in charge." EPA
regional staff repeatedly raised this issue.
An effective relationship requires time to build the
necessary familiarity and trust. Each new PO must become
familiar with the SCERP organization, personnel, and the
many, varied research projects. The PO must also become
comfortable with and gain the trust of EPA staff, from EPA
Headquarters program offices, regional offices, and border
offices. Likewise, the SCERP Management Committee Chairman
must become familiar with three different POs, all the
financial and administrative requirements of the CAs, a
variety of individual projects, and researchers spread among
five universities in five States.
CONCLUSION
Various barriers remain which hinder SCERP and EPA from
establishing an effective relationship and finding solutions
to the highest priority border environmental problems.
Although EPA included special conditions in the CAs meant to
foster a strong working relationship, SCERP and EPA did not
fully implement the conditions and EPA recently abolished
several of them.
EPA limited its participation because some staff still had
negative perceptions of the value of SCERP's research. SCERP
and EPA had not effectively dealt with these negative EPA
staff perceptions. These perceptions will probably not
change until SCERP and EPA participants reach consensus on a
rank order list or lists of border environmental problems to
better guide the specific research needed to find solutions
to the most pressing problems.
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EPA also limited its participation because of inadequate EPA
staff and travel resources and the lack of stable SCERP and
EPA management structures. Although a closer working
relationship is not essential to SCERP's success, it would
help SCERP and EPA focus limited resources on the most acute
issues.
RECOMMENDATIONS
He recommend that the Director, Office of Program Management
Operations, OAR:
1. Include a CA special condition requiring a formal
technical monitoring program that provides for
regular and meaningful participation of EPA
technical advisors;
2. Work with appropriate EPA Regional Administrators
or other senior managers to make the technical
advisor role part of staff's official
responsibilities and provide sufficient travel
funds and other resources necessary for advisors to
successfully fulfill this role;
3. Fully implement OAR's agreement with SCERP to
distribute quarterly project progress reports,
research articles, and final project reports to
appropriate EPA staff in Regions 6 and 9, EPA
border offices, ORD, and other EPA offices who can
use and build upon SCERP's research; and
4. If SCERP's recent policy change to lengthen the
term of the SCERP Management Committee Chairman
from 1 to 2 years does not meet the intended goal
of improving relationships, consider having SCERP
establish a permanent position to manage the day-
to-day operations of SCERP and to serve as the
principal contact between SCERP and EPA.
AUDITEE COMMENTS AND OIG EVALUATION
SCERP and OAR generally agreed with our findings and
recommendations and in some cases had taken steps to
implement changes. . Both SCERP and OAR offered comments to
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clarify some issues and recommendations and we modified the
report as appropriate.
OAR agreed a technical monitoring program is desirable and
SCERP responded that it is committed to improving interaction
between SCERP researchers and EPA technical staff. OAR
stated it could not spend additional resources on such a
program and could not require other .offices to assume
responsibility for the program. OAR preferred to maintain a
"voluntary" technical monitoring program. However, at our
exit conference OAR officials agreed they could work through
the advisors' Regional Administrators or other managers to
formalize and properly fund the program. SCERP committed to
work with OAR to develop an improved interaction method. We
believe a formal, funded program is absolutely essential to
ensure the program's successful implementation.
Region 6 commented that ORD never formally requested Regions
6 or 9 to provide technical advisors. Region 6 stated that
technical advisor duties could have been added to the
advisors' position descriptions had ORD made formal requests
to the Regional Administrators.
SCERP and OAR responded that they had recently reached
agreement with OAR and Regions 6 and 9 border coordinators to
distribute information from SCERP to EPA. SCERP and EPA's
OIA also agreed to have SCERP projects listed in the
Compendium of EPA Binational and Domestic U.S./Mexico
Activities. which is widely distributed to other government
agencies. SCERP agreed a sustained effort is necessary to
maintain and improve information dissemination. SCERP and
ORD had a similar plan that was never fully implemented. We
modified our recommendation to emphasize that implementation
is key to the success of the recent agreement.
SCERP and OAR agreed that it was important to stabilize
SCERP's management structure. SCERP changed its policy to
rotate the Chairmanship every 2 years rather than every year.
SCERP also committed to working with OAR to identify other
means of tightening its structure to facilitate a closer
working relationship with EPA. SCERP also stated it had
recently established relationships with the new EPA border
offices in San Diego and El Paso. We believe SCERP and OAR
should monitor the effectiveness of SCERP*s recent policy
change and modified pxjr recommendation accordingly.
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CHAPTER 4
SCERP UNIVERSITIES CLAIMED INELIGIBLE COSTS
Office of Management and Budget (OMB) Circular A-21
establishes principles for determining costs applicable to
grants, contracts, and other agreements with educational
institutions. SCERP used grant funds for equipment and
activities outside the limitations of A-21. University
officials defended the charges as directly related to SCERP
activities or as standard university procedure for project
costs.
SCERP universities claimed $51,880 in questioned research
costs under CAs CR818296 and CR821542. The table below
relates the questioned costs to the appropriate CA. The
information following the table identify the university to
which the questioned costs apply.
Travel
Equipment Costs
Contractual costs
Miscellaneous Costs
TRAVEL COSTS
Total CR818296 CR821542
$ 4,869 $ 1,538 $ 3,331
13,272 13,272
18,388 9,983 8,405
15.351 15.351
S51.880 S40.144 S11.736
UTAH claimed $4,869 in unallowable travel costs. The
questioned costs consisted of $1,538 claimed under CR818296
and $3,331 ($1,544 + $1,787) under CR 821542. The questioned
travel costs consisted of:
— $3,082 for consultant travel for unallowable public
relations work. Of the $3,082 questioned, $1,538
was claimed under CR818296 and $1,544 under
CR821542. Review of the consultant agreement and
descriptions of the services clearly identified the
consultant's activities as unallowable for EPA
participation. (See contractual Costs for a
detailed discussion).
— $1,787 claimed under CR821542 for a UTAH employee
to travel to Washington, D.C., for the "SCERP
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Fiscal '94 Appropriation/Meeting with Congressmen."
OMB Circular A-21, Section J24, b.(1) describes
allowable interactions with Congress as technical
and factual presentations:
... in response to a documented request
(including a Congressional Record notice
requesting testimony or statements for the
record at a regularly, scheduled
hearing)....and further provided that costs
under this section for travel, lodging, or
meals are unallowable unless incurred to offer
testimony at a regularly scheduled
Congressional hearing pursuant to a written
request for such presentation made by the
Chairman or Ranking Minority Member of the
Committee or Subcommittee conducting such
hearing.
The criteria is very specific regarding the form of
written request and the specific members of
Congress who can issue the request.
SCERP responded, "With regard to travel costs of $1,787
for a Utah employee to travel to Washington, D.C.,
members of the Utah SCERP consortium were regularly
invited by members of -Congress to present SCERP progress
reports....** SCERP was unable to provide documentation
supporting any invitation to meet with an individual
member of Congress or to appear at a regularly scheduled
congressional hearing. Furthermore, being "invited by
members of Congress*1 did not meet the OMB criteria.
EQUIPMENT COSTS :
Utah claimed $13,272 for unallowable general purpose
equipment. The equipment was purchased without documented
prior EPA approval required by OMB Circular A-21. According
to OMB Circular A-21, Section J16, a.(4):
General purpose equipment means equipment, the use
of which is not limited only to research, medical,
scientific or other technical activities. Examples
of general purpose equipment include office
equipment and furnishings, air conditioning
equipment, reproduction and printing equipment.
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motor vehicles, and automatic data processing
equipment.
Subparagraph b.(1) states that:
Capital expenditures for general purpose equipment,.
buildings, and the land are unallowable as direct
charges, except where approved in advance by the
sponsoring agency.
We were unable to locate advance approval for the specific
items of general purpose equipment discussed below. The
questioned equipment costs included:
$4,689 for oak office furniture purchased by UTAH
for the Associate Dean of the College of
Engineering and his secretary.
— $4,086 for two personal computers purchased by UTAH
for the Associate Dean of the College of
Engineering and his secretary. The Associate Dean
was also the Chairman of the SCERP Management
Committee. UTAH purchased the computers in January
1992, and charged them to a project account
(#22176) established for sponsoring an air quality
conference. However, UTAH officials told us that
most of the planning for this conference was
performed by the UTAH conference planning center
which recovered its costs from income generated by
the conference. In addition, UTEP, not UTAH, had
administrative responsibility for the CA at the
time UTAH purchased this equipment. Although the
SCERP Chairman was from UTAH, that fact did not
justify the need for two computers for
administrative purposes. UTAH allocated 75 percent
of the computer systems cost to the CA.
— $2,712 for a laser printer, color monitor, and
other computer equipment for the administrative
staff.
— $1,785 for an August 1992 purchase of a facsimile
machine. These costs were charged to the "Program
Operations and Management" account.
SCERP claimed that the EPA PO approved the acquisition of the
general purpose equipment to be used for administrative
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purposes. However, SCERP submitted no documentation to
substantiate its claim. SCERP claimed that the equipment
acquired was dedicated for use only on SCERP activities and
should be allowed as a direct charge to SCERP.
We disagree that the furniture and equipment is eligible.
The furniture and other equipment clearly met OMB's
definition of general purpose equipment and therefore
requires documented, prior EPA approval. We also question
how and where the Associate Dean of the College of
Engineering and his secretary performed the work associated
with their primary jobs for the College of Engineering
without the use of the furniture and equipment claimed
against the CA. Furthermore, at the time UTAH purchased the
questioned furniture and equipment, UTEP, not UTAH, had
administrative responsibility for the CA.
CQKTRACTUAIi COSTS
Utah claimed $18,388 in unallowable consultant fees. The
consultant agreement provided for ineligible public relations
services. Utah claimed $9,983 under CR818296 and $8,405
under CR821542. Public Law 101-121, Section 1352 (a)(1),
passed October 23, 1989, states:
None of the funds appropriated by any Act may be
expended by the recipient of a Federal contract,
grant, loan, or cooperative agreement to pay any
person for influencing or attempting to influence
an officer or employee of any agency, a Member of
Congress, ...in connection with any Federal action
described in paragraph (2) of this subsection.
Subsection (2)(E) of the law includes, "The extension,
continuation, renewal, amendment, or modification of any
Federal contract, grant, or cooperative agreement.11
In addition, OMB Circular A-21, Section J24, a., states:
Notwithstanding any other provisions of this
Circular, costs associated with the following
activities are unallowable: ...(5) Legislative
liaison activities, including attendance at
legislative sessions or committee hearings,
gathering information regarding legislation, and
analyzing the effect of legislation, when such
30
Report NO. E1FUF5-08-0019-S100528
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activities are carried on in support of or in
knowing preparation for an effort to engage in
unallowable lobbying.
The consultant agreement required the consultant to:
Provide advice to SCERP and the College on
.government, foundations, and industry; public
relations; fund-raising; and Federal research
contract acquisition. Maintain financial support
for SCERP and University research programs and
assist in maintaining competitive advantage which
has helped increase this base from $14 million to
$25 million a year from 1992 to 1993.
A description of services actually provided by the consultant
indicated most costs were associated with unallowable public
relations activities. Much of the description appears to
involve contacting congressional representatives and keeping
them informed about SCERP. For example, the consultant's
October 1993 invoice includes the following activities that
were billed to the. CAs:
— attended meeting in Washington, D.C., with Utah
congressional delegation to discuss SCERP functions
and budget needs;
planned publicity for SCERP infrastructure report;
— continued to draft general-purpose SCERP booklet;
and
drafted a letter to Senator Hatch to send to other
Senators for co-signature to be sent to EPA
Administrator for $2 million in funding.
SCERP contended that the consultant costs were eligible
because the consultant was hired specifically for his writing
and communication skills. . Some of the consultant's charges
were for preparation of SCERP's Interim Report to EPA, and
SCERP contended that the services of the consultant should be
allowable under OMB Circular A-21, Section Jl, d, 2, which
provided -that allowable public relations costs include
communications with the public and press on accomplishments
resulting from the work conducted under sponsored agreements.
.31
Report No. E1FUF5-08-0019-5100528
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We agree that the costs to prepare the SCERP Interim Report
to EPA may be an eligible public relations cost, but the
consultant's invoices did not identify how much time the
consultant spent preparing the interim report. Because the
consultant's invoices did not specify the time charged for
each activity, we were unable to distinguish eligible from
ineligible costs.
MISCELLANEOUS COSTS
SCERP universities claimed $15,351 of unallowable
miscellaneous costs under CA CR818296. The claimed cost of
$15,351 consists of two items ($12,372 + $2,979) that are
explained below.
$12,372 for an NMSU research project that was
outside the approved scope of the CA. Federal
regulations define allowable costs under 40 CFR
30.200 as, "Those project costs that are:
...approved by EPA in the assistance agreement."
In addition, 40 CFR 30.308(a) states that, "...the
award official and the university must sign the EPA
assistance agreement before you incur costs."
SCERP submitted a research proposal to EPA as part
of its fiscal 1992 application. NMSU allowed the
researcher to initiate work on the project in the
summer of 1992 even though EPA had not accepted the
proposal for funding. When EPA signed and approved
the CA in August 1992, this proposal was
specifically excluded. Subsequently, NMSU
transferred the $9,302 of labor and fringe charges
incurred under the unfunded project to another
approved SCERP research project. We found no
evidence that EPA waived the regulatory
requirements for these costs. We questioned direct
costs of $9,302, and allocable indirect costs of
$3,070 calculated at 33 percent of direct costs as
. ineligible. The 33 percent indirect expense rate
was the effective rate applied to the direct costs
claimed on the NMSU invoice ($9,302 x .33 =
$3,070).
$2,979 of costs UTAH claimed for an August 1991
Snowbird Conference. UTAH claimed $1,015 for .
alcoholic beverages. OMB Circular A-21, J2, states
that, "Costs of alcoholic beverages are
32
Report NO. E1PUP5-08-0019-5100528
-------
unallowable." UTAH claimed $1,000 for rental of a
private tram car at 9:00 p.m. We consider the cost
to be unnecessary to accomplish the purpose of the
conference. UTAH claimed $964 for barometers. OKB
Circular A-21, Jl, f.(3), defines promotional items
and memorabilia, including models, gifts, and
souvenirs, as ineligible advertising and public
relations costs.
Regarding the unapproved NMSU research project, SCERP
contended that the work performed under the unfunded project
actually fit within the scope of the funded project. SCERP
provided a written statement, dated July 3, 1995, and other
documentation from the principal investigator to substantiate
its position.
We were unable, from the documentation provided, to determine
whether the work performed under the unapproved project
substantively contributed to accomplishing the intended
research goals of the approved project to which the costs
were transferred. If the work conducted under the unapproved
project was essential to conducting the approved project, we
would have expected that work to have already been
incorporated into "the research design of the approved
project.
SCERP agreed the Snowbird Conference costs were ineligible.
RECOMMENDATION
We recommend that the Director, Grants Administration
Division, recover the $51,880 of ineligible costs claimed by
SCERP under the CAs.
AUDITEE COMMENTS AND OIG EVALUATION
SCERP disagreed with $26,820 of questioned costs related to
an SDSU project titled, "Proposal for a Man and the Biosphere
Reserve system for the San Diego Border Region." We
questioned the costs because the costs to develop a funding
proposal or to develop the data necessary to prepare a
funding proposal are ineligible according to OMB Circular A-
21, J-34. SCERP provided additional information
demonstrating that the project's purpose was not for the
33
Report HO. E1FUP5-08-0019-5100528
-------
purpose of developing a funding proposal. As a result, we
eliminated these questioned costs from our report.
We incorporated a summary of SCERP's comments on each of the
remaining findings and our evaluation of SCERP's comments in
the text above.
34
Report MO. E1FD75-08-0019-5100528
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APPENDIX I
Page 1 of 15
\SOUTHWESTCENTER FOR ENVIRONMENTAL RESEARCH & POLICY
September 12,1995
Ms. Bennie Salem
Acting Divisional Inspector General for Audit
U.S. Environmental Protection Agency
Office of Inspector General
Central Division
726 Minnesota Avenue .
Kansas City, Kansas 66101
RE: The Southwest Center for Environmental Research and
Policy Should Focus on Border Problems
Draft Audit Report E1FUF5-09-0019-XXXXXX, August
14, 1995
Dear Ms. Salem:
I am pleased to enclose the response of the Southwest Center for Environmental Reseach and
Policy to the above indicated Draft Audit Report prepared by your office. We feel that the audit
process has been quite rigorous and has produced important suggestions that will be of great help
to SCERP in carrying out its mission and meeting its goals in the. most cost effective manner and
in maximizing the benefits of its interaction with EPA.
Thank you for the significant effort on the part of your staff in carrying out this audit.
Sincerely yours, .
Paul Ganster
Chairman, SCERP Management Committee
35
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APPENDIX I
Page 2 of 15
SOUTHWEST CENTER FOR ENVIRONMENTAL RESEARCH & POLICY
Response by the
Southwest Center for Environmental Research and Policy
(SCERP)
to
Office of Inspector General
U.S. Environmental Protection Agency
Draft Audit
"The Southwest Center for Environmental Research and
Policy Should Focus on Border Problem Solutions"
E1FUF5-08-0019-XXXXXX
September 12,1995
36
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APPENDIX I
Page 3 of 15
Contents
f-
I. Executive Summary / 3
n. General Response / 4
Priorities/4
Project Selection / 5
Recommendations / 7
m. Specific Responses to Items in the Draft Audit Report / 8
IV. Responses to Chapter 4 "SCERP Universities Incurred Ineligible Costs" /12
Responses relating to projects at the University of Utah / 12
Responses relating to projects at New Mexico State University / 13
V. Summary /13
37
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APPENDIX I
Page 4 of 15
SCERP Response to EPA DIG, 9/12/95, page 3
I. Executive Summary
SCERP is appreciative of the efforts of OIG to analyze the consortium operations and to provide
constructive suggestions that will help SCERP to carry out its mission in a more focused and cost
effective manner QIC's draft report is extremely helpful and it is a useful blueprint for positive
change, but there are a number of areas for which SCERP comments and clarification are needed.
i>
The OIG draft report's discussion of priorities for SCERP and EPA projects is quite detailed and
will assist SCERP to more clearly define priorities. We feel that it is not possible to define a
single set of priorities that all stakeholders in the border region will agree upon. The border is a
region that is complex and dynamic and needs and concerns vary considerably from community to
community along the border and evolve rapidly over time. However, we do agree with the OIG
that it is possible to develop each year a consensus on a stratified list of priorities that can serve as
the basis of, or guide to, project selection and program determination. The OIG draft will help us
better refine our methodology for defining priorities and it has stimulated SCERP to embark on an
effort to analyze the problems of defining priorities for border environmental projects.
The OIG draft report also raised concerns about the selection of specific projects funded in the
annual SCERP research program, particularly with the selection process and the appropriateness
of the projects to resolving border environmental problems. In our response, we explain that
scores by outside technical reviewers are used in concert with other criteria to determine final
selection. EPA priorities and needs, synergy with other SCERP projects, binational participation,
potential for long-term capacity building in the border region and border communities, equitable
distribution of projects along the border, a mix of projects with immediate and longer term
impacts, and other factors all enter into the selection. SCERP is committed to the long-term
resolution of border environmental problems and that entails not only projects that focus on
immediate concerns but projects that will bring significant results in the medium and long run.
With that said, the OIG draft report does provide key suggestions that will help SCERP work with
the Office of Air and Radiation and the other EPA offices to improve the project selection
process, beginning with the FY 1996 RFP which is now being developed.
SCERP acknowledges the utility of the various recommendations made in the OIG draft report.
SCERP has already moved to stabilize its management structure with implementation of a policy
to rotate the chairmanship of die management committee every two years and will discuss
additional measures in our continuing meetings with OAR. The OIG suggestions on enhanced
interaction between SCERP project principal investigators and EPA technical staff will be
incorporated into the next RFP issued by the consortium. With respect to better distribution of
SCERP research results to appropriate EPA staff, SCERP has been working on this with OAR
and the regions and will monitor the effort in the future.
Finally, the draft report of OIG identifies a number of costs incurred by the various SCERP
projects that it feels are ineligible. We have included responses to those specific items and
respectfully request that OIG carefully consider the new information that we provide on the
questioned items.
38
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APPENDIX I
Page 5 of 15
SCERP Response to EPA DIG, 9/12/95, page 4
II. General Response
SCERP acknowledges the very significant effort by the Office of Inspector General (OIG) in
preparation of the draft report and the consortium expresses its appreciation for the many
suggestions and recommendations that will help us to better carry out our mission in coordination
with EPA. The draft report will help us improve the focus and efficiency of SCERP projects by
better defining projects that have an impact on critical border environmental problems and that
serve to build the sustainable capacity of border institutions and communities to address those
problems. However, we feel that there are several central points in the EPA draft report that need
comment and/or further explanation.
Priorities
The OIG draft report frequently refers to development of a prioritized list of border problems and
related research and implicit in the report is the assumption that it is possible to develop such a
list. An examination of the yearly action plans developed by the EPA regions for border activities;
the working documents of the EPA-Mexican counterpart working groups under the framework of
the 1983 La Paz agreement; the ongoing discussions in the Border Environment Cooperation
Commission (BECC); the positions of border environment activist groups, border trade groups,
and border communities concerns; priorities of state-level agencies on both sides of the border;
and so forth, clearly reveals mat stakeholders involved in addressing border environmental
problems have quite different perceptions of priorities. Moreover, these priorities differ according
to geographical region and tend to change over time, reflecting rotating personnel, changing
perceptions, improved knowledge and understanding of environmental issues, the state of the
economy in Mexico and the United States, and other factors. SCERP thus feels that it is extremely
difficult to develop a single ranked priority list that reflects the multicultural, transnational,
dynamic nature of the border region and associated environmental issues and that can be used
mechanistically to determine which applied research projects SCERP funds.
As its approach to the conundrum of border environmental priorities, SCERP, working with EPA,
has evolved a process to develop an annual request for proposals and then determine a final
annual applied research program for the consortium. First, SCERP develops a list of applied
research project topics based on input from Congress, border communities, state and local
agencies, SCERP researchers on both sides of the border, U.S. and Mexican federal agencies,
IBEP, IBWC/CILA, the U.S. Embassy in Mexico City, the Mexican Embassy in Washington,
D.C., BECC, environmental organizations, arid other sources. SCERP then discusses the list of
topics with EPA to better focus the list and to include items that might have been overlooked. The
revised listing, which has been agreed to by SCERP and EPA, is then incorporated into the RFP
for distribution to all SCERP institutions. It should also be noted that EPA reviews the RFP prior
to its distribution.
We feel that the above methodology provides SCERP with a good mechanism to establish a
listing of priority projects for border environmental applied research activities. It is a flexible
39
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APPENDIX I
Page. 6 of 15
SCERP Response to EPA OIG, 9/12/95, page 5
process that permits incorporation of new topics as different concerns become critical to the
environmental health of the border region.
We do understand the shortcomings of this approach and understand the concerns raised by the
Office of Inspector General. We feel that it is impractical to develop a list of priorities that will
meet with the approval of all stakeholders and that will stand the test of time. For instance, one of
the goals that the Border XXI (formerly known as Border 2000) effort that EPA is now leading is
to determine community priorities to be folded into the next version of IBEP. This is a year-long
process, and will constitute only one set of the U.S. inputs that will be combined with similar
suggestions for priorities from the Mexican government. The point is that the border is a very
dynamic region with new problems and opportunities appearing almost daily. Thus, a flexible
approach is the most efficient and cost effective way to address the problems.
Noting the above caveat, however, it is clear that it would be helpful to undertake a more
systematic approach to the analysis of the issue of defining border priorities in the area of
environmental issues. We agree with OIG that it is possible and desirable to develop consensus
with EPA on a stratified list of priorities to guide the annual RFP and project selection process.
This will not only involve different offices of EPA more fully in the development of a set of
priorities at the front end of the RFP development process, but it will stimulate SCERP
researchers to develop higher quality, more focused proposals. SCERP proposes to work with
OAR to include this analysis in the RFP for FY 1996. The types of variables that likely need to be
examined when determining SCERP priorities include, for example, the following:
0 Cost-benefit analysis. Does the cost of the project area bring significant benefits in
relationship to costs incurred? This is an extremely complex area and must be treated
carefully because of the dangers of misuse. For example, using the sole criterion of most
good for the greatest number of people, all border environmental investment would be
concentrated in the large population centers of San Diego-Tijuana or El Paso-Ciudad
Juarez while areas such as the two Nacos would be ignored because of the low population
base.
c
D Sustainability. Does the project support the concept of sustainable development?
D Capacity building. Does the project help build capacity in the region for sustained
attention to resolution of environmental problems, including training of students, members
of the community, and local government; does the project help build capacity on both
sides of the border?
D Balance. Do the priorities address the needs of both large and small communities along the
border? Are the concerns of the central governments being met?
Project Selection
Related to the above topic of priorities are concerns raised by the Office of Inspector General
40
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APPENDIX I
Page 7 of IS
SCERP Response to EPA DIG, 9/12/95, page 6
regarding the selection of the specific projects to be funded within the annual applied research
program of SCERP. Specifically, OIG emphasized inconsistencies between the projects selected
for funding for FY 1995 and the scores of outside reviewers. Some explanation is in order.
SCERP never intended that the scores from the outside evaluators be the primary factor in
determining projects to be funded for a number of reasons. SCERP lacks the financial resources to
compensate the reviewers and to bring reviewers together to discuss variances in scores. Instead
we must rely on professionals who contribute their time and this reduces the number of reviewers
who are able to help us. Typically, each reviewer analyzes a half dozen projects and scores vary
significantly from reviewer to reviewer due to differing scales employed, different perspectives,
diverse professions and specializations, and so forth. With this variance, score totals or composite
scores cannot be seen as definitive. Instead, the reviews are one important consideration that the
SCERP Management Committee employs when making its initial selection of projects. The
reviews bring to the attention of the Management Committee strengths and weaknesses of
particular projects. Also, the written comments of reviewers are useful in helping researchers
improve their projects.
SCERP recognizes that a project may be technically excellent, and thus receives very high scores
from technical reviewers. However, the project may have minimal relevance to resolving border
problems or may not be a good fit in the applied research program. Consequently, other criteria
may temper a high score or a low score.
It is common for the proposal review processes of many agencies to take into account many
criteria, not just the highest score. To rely only on the highest score would be like giving a
contract to the lowest bidder although another bidder could do the job with higher quality
deliverables.
Other factors influencing the final determination of the research program include the assembled
expertise from SCERP and EPA for the meeting when the final decisions are made. For example,
in 1995 EPA representatives at the meeting (most in person, some by conference call) to discuss
proposals included representatives from OAR, Washington, D.C., Regions 6 and 9, and the
Border Liaison Offices. Each proposal was discussed in detail and all present had ample
opportunity to provide input. Some projects highly rated by SCERP were not funded due to EPA
exceptions and some projects not ranked highly by SCERP were funded because of strong EPA
interest and support.
SCERP also considered the synergy generated by the package of proposals selected as an
important element in the final determinatipn of the package of proposals. By synergy we mean
enhanced value added by collaboration of partners and projects within the Consortium that assures
a greater short term, medium term, and long term impact on important border environmental
problems. Technology transfer, sharing of data and methods, and building the regional and
Mexican capacity in key areas are examples of this synergy. On another level, the concentration
of a number of projects by SCERP on air pollution problems of the El Paso-Ciudad Juarez airshed
enabled the consortium to have a tangible impact on this important issue. Likewise, concentration
of resources in data management and CIS development as planning, monitoring, and enforcement
41
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APPENDIX I
Page 8 of 15
SCERP Response to EPA DIG, 9/12/95, page 7
tools through a number of articulated projects provides an effective means to achieve results that
will have a major role to play in resolution of border environmental problems. SCERP firmly
believes that development of a yearly integrated applied research program is much more cost
effective in the long run than simply selecting an assortment of high priority projects that do not
interact in meaningful ways.
In summary, final project selection is made by the SCERP Management Committee in concert
with OAR and the regions. In addition to the scores provided by the written evaluations, the
following considerations enter into the process:
0 Input from EPA at decision meetings.
D Synergy with other SCERP projects.
D Potential for capacity building in the border region; potential for binational participation in
the project.
0 Roughly equitable distribution of projects in the different regions along the border.
D Projects that have impacts in the near term as well as in the longer term.
SCERP is aware of the anomalies in the scoring that the draft audit report pointed out, but it must
be understood that many other factors enter into the final project selection decisions.
Each year SCERP has been able to refine its RFP and the project selection process. The comments
from die Office of Inspector General provide excellent suggestions on ways that we can work
with OAR and other EPA offices to improve the process. We will incorporate these suggestions in
the RFP that is now being developed for FY 1996 and OAR and other EPA offices will be fully
involved in that process from the start.
Specifically, at the suggestion of OIG, we will present a clearer indication of priorities in the FY
1996 RFP in the form of a priority rank list that can be used in a flexible fashion. In addition, the
RFP will have substantially more detail on the criteria considered for the scoring by outside peer
reviewers and by the Management Committee and EPA when selecting projects for funding. This
will serve to make the selection process more transparent and focused on priority areas. At the
same time, it will become clearer to SCERP researchers, EPA, and other stakeholders why project
decisions were made.
Recommendations
With respect to the recommendations from the Office of Inspector General that OAR work with
SCERP to stabilize the latter's management structure, we concur that this is an important goal.
SCERP has recently implemented a policy to rotate the chairmanship of the management
committee every two years rather than every year. In addition, in our future meetings with OAR,
42
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APPENDIX I
Page 9 of 15
SCERP Response to EPA OIG, 9/12/95, page 8
we will discuss other suggestions for tightening up the management structure in order to work
more closely with EPA. Finally, it should be noted that establishment by EPA of the Border
Liaison Offices in San Diego and El Paso has provided a new and important point of contact with
the agency for SCERP and already we have established close contact with those offices.
SCERP is also committed to improving the level of interaction between project principal
investigators and EPA technical staff We will work with OAR to incorporate an. improved, but
feasible, system into the next RFP and into subsequent subcontracts and award letters for new
projects.
Finally, with respect to distribution of research information to appropriate EPA staff, SCERP
reached an agreement with OAR and the border coordinators from Regions 6 and 9 at a meeting
in Dallas mat these offices would serve to distribute relevant information from SCERP to
headquarters and to the regions. So far, this has been an effective mechanism for SCERP to
communicate relevant information to key offices and individuals in EPA, although a sustained
effort needs to be devoted to maintaining and improving this communication. As well, SCERP
worked with OIA to have consortium projects listed individually in the recently released
Compendium of EPA Binational and Domestic U.SJMexico Activities. This document has been
widely distributed in U.S. federal agencies.
HI. Specific Responses to Items in the Draft Audit Report
The following section contains responses by SCERP to a select number of items raised in the draft
audit report that we feel need comment and/or clarification.
Page 6, last paragraph: "Earmarked funds provided to SCERP represented approximately 50
percent of EPA's entire 1994 and 1995 border research budget totaling $3.4 and $4.4 million,
respectively."
Over the years, we have heard this statement made by OIA and other EPA offices, but have never
received a clear explanation and the figures never matched available data. For example, in the
Integrated Border Environmental Plan for the Mexico-U.S. Border Area (First Stage, 1992-1994)
(IBEP), EPA commits to spending some $384 million in FY 1992 and 1993 on border
environmental problems, including infrastructure, research, and other activities. Moreover, a
recent publication by EPA, Compendium of EPA Binational and Domestic U.SJMexico Activities,
which is the first time EPA has compiled a listing of ongoing border-related projects, some $20
million in border environmental projects are listed and a substantial portion are for applied
research and related activities.
SCERP feels that if the consortium has a better understanding of ongoing EPA border
.environmental research and related projects, this will facilitate our efforts to coordinate activities
with EPA. In turn, this will more efficiently use scarce border resources.
43
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APPENDIX I
Page 10 of 15
SCERP Response to EPA OIG, 9/12/95, page 9
Page 7, paragraph 1: "The 1993 and 1995 proposal requests included 73 and 59 unprioritized
multimedia research topics respectively."
As explained above in the section on general responses, the research topics in the RFP are a list of
priority projects identified by SCERP and EPA.
Page 7, paragraph 2: "SCERP and EPA primarily relied on the border plan developed jointly by
the U.S. and Mexican governments to identify environmental border problems,...."
SCERP also relied on its community environmental forums, contacts with the Border Trade
Alliance, suggestions from government officials at all levels, and extensive interaction with
researchers and agency personnel in Mexico along with workshops that included high level
officials from both governments, environmental activists, researchers, and private sector
representatives to identify environmental problems of the border region. SCERP made sure that
projects identified supported the efforts of IBEP and the 1983 La Paz Agreement. SCERP also
worked in areas that did not receive much attention in IBEP; specifically, on human health issues
and ecosystems.
Page 7, paragraph 2: "...the Udall Center, specializing in environmental and related issues,
claimed that the border plan was not integrated and did not effectively guide the application of
congressional border research appropriations.'*
t
Everyone acknowledges that IBEP is not a perfect document, but the Udall Center has failed to
recognize the positive achievements of IBEP. Perhaps this center did not fully appreciate the
difficulties involved in getting Mexico and the United States to agree on such a comprehensive
document.
Page 7, last paragraph: "For example, the 1995 proposal request assigned equal priority to the
following:
- Assessment of drinking water quality and innovative water treatment methods; and
- Evaluation of the structure, practice, and funding of environmental administration
in Mexico...."
This again raises the issue of priorities and illustrates the difficulty of establishing a ranked listing
of border environmental priorities. For example, water quality is a high priority in the Texas
colonias (informal subdevelopments without basic infrastructure) and all along the Mexican side
of the border. It is only a minor issue for the more developed regions on the U.S. side of the
border, such as San Diego and Tucson, where a high percentage of U.S. border residents live.
Since resolution of border environmental issues requires transborder cooperation in many cases, it
is absolutely necessary that EPA, state governments, local governments, researchers, NGOs, and
communities understand how border environmental administration functions in Mexico. During
the past five years, Mexican environmental administration has undergone a veritable revolution
44
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APPENDIX I
Page 11 of 15
SCERP Response to EPA OIG, 9/12/95, page 10
that has included a new federal environmental law and implementation regulations, two
reorganizations of the federal environmental bureaucracy, emergence of border state level
environmental laws and agencies, and emergence of environmental laws and agencies at the
municipal level. This extremely dynamic situation is very confusing to U.S. counterparts, trade
groups, communities, researchers, and NGOs. Thus, the project on Mexican environmental
administration was considered a high priority by many actors in EPA and elsewhere who deal
with the border on a daily basis. Cleaning up the Rio Grande, the source of drinking water for
many border residents, is dependent on full collaboration by Mexican environmental authorities at
the federal, state, and local level. Thus, it is very difficult to argue that one project should have
absolute priority over the other or that one ranking should have absolute priority over the other.
As part of the 1995 SCERP applied research program, a project on assessment of drinking water
quality was funded and one on Mexican environmental administration was not funded. However,
one SCERP institution was able to obtain funding from another source for the environmental
administration project and it will begin in the near future.
Page 8, last paragraph: "In 1994, SCERP did not submit all research proposals for external peer
review and scoring. In 1994, SCERP set aside $222,177 for inclusion in an 'opportunity
fund.'...SCERP subsequently funded nine additional projects using the opportunity fund, none of
which were evaluated or scored by peer reviewers."
The purpose of die opportunity fund was to permit SCERP to respond to pressing border
environmental issues through a process that was more flexible and responsive than that of the
regular project funding. The opportunity funds were set aside, beginning in FY 1993, at the
suggestion of the EPA Project Officer. In some cases, the opportunity funds supported projects
suggested by border communities, in other cases, they provide seed money for a key project start
up. In all cases, the projects were reviewed by the SCERP technical experts for technical merit,
and then submitted to and approved by the EPA prior to funding and implementation.
Page 10, last paragraph: "In 1994, SCERP provided funding to develop a proposal for the
establishment of a binational biosphere wetlands reserve in the San Diego-Tijuana region. This
project included ecosystem preservation and policy research. Although preservation of a major
wetland may be important, it did not directly address the acute health and environmental problems
along the border."
This project was to complete research necessary for the development of an application to the Man
and the Biosphere Program to designate the Tijuana River Basin as a Biosphere Reserve. The
community activities, scientists, and policy specialists who proposed this project felt that this was
the best way to develop an effective basin-wide approach to resolving critical environmental
issues that affect the health of the wetlands and of the more than two million residents of the basin
that covers more than one million acres straddling the border between Mexico and the United
States. It is felt that this basin-wide, transnational approach to dealing with environmental issues
is the only valid long term approach to protecting human and ecosystems health in the basin.
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APPENDIX I
Page 12 of 15
SCERP Response to EPA OIG, 9/12/95, page 11
In addition, border problems such as sewage, air pollution, and hazardous waste that will be
exacerbated by NAFTA-induced growth, make more urgent the need for an internationally
acceptable, large scale planning system for the border region. The Biosphere Reserve project is
an important step in development of an interdisciplinary/transboundary network mat proposes
sustainable human development while protecting natural processes and biological resources.
Finally, it should be mentioned that this project is quite similar in approach and impact to a
project being undertaken by the Texas Natural Resources Conservation Commission (TNRCC)
for "A Watershed Alliance for the Rio Grande/Bravo Basin." This project is being funded by
EPA ($134,000 for first year) and will develop an ecosystem framework to address the
environmental issues of the transboundary Rio Grande/Rio Bravo watershed.
Page 11, paragraph 2: "SCERP spent almost half of its 1995 research budget on computer
modeling and other data management projects that would not directly result in the solution of an
immediate, acute border environmental problem."
The computer modeling and other data management projects that SCERP funded for 1995 include
projects that will accumulate and generate data for inclusion in decision support systems for
regulators and policymakers. Without accurate binational, regional data, it is often impossible for
policymakers to develop cost effective approaches that prioritize properly the allocation of
enforcement and remediation resources. The multiagency federal government taskforce on border
environmental issues has identified binational environmental data as a top priority.
On a more specific level, the project "Upper Atmospheric Wind and Temperature Profile
Data for the El Paso-Juarez Airshed" will generate data that will be incorporated in computer
models to determine diffusion and transport of pollutants in the airshed. Without these data, it will
not be possible for the regional, binational authorities to devise specific strategies to reduce
pollution in the airshed. El Paso currently has the poorest quality air of any major city in Texas
and ranks among the ten worst nationally, so this work is of great importance.
Data in and of itself, however, is only one part of what is needed for development of cost effective
mitigation strategies. Sophisticated computer modeling, in which both U.S. and Mexican
researchers participate, provides policy options for decision makers. The collection and
organization of binational environmental data serves as input to specific models that optimize the
complex relationships between costs and environmental impact.
Another project "Database Coordination Initiative: Sources of Air Pollution along the Border...,"
will provide data on sources of air pollution along the border to be used as the basis for
developing realistic, cost effective, mitigation strategies to reduce air pollution. This innovative
approach is necessary because monitoring data are not adequate for the region. It will provide a
borderwide view that will provide a solid basis of comparison to determine priorities through
cost/benefit analysis.
Border communities cannot have "clean air to breathe" until these basic data are available to
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APPENDIX I
Page 13 of 15
SCERP Response to EPA OIG, 9/12/95, page 12
regulators and policymakers.
IV. Responses to Chapter 4 "SCERP Universities Incurred Ineligible Costs"
This section contains responses by SCERP for the projects with costs questioned by OIG and are
listed by the appropriate consortium member.
Responses relating to projects at the University of Utah.
Travel
With regard to travel costs of $1,787 for a Utah employee to travel to Washington, D.C., members
of the Utah SCERP consortium were regularly invited by members of Congress to present SCERP
progress reports, not to lobby. However, we have been unable, after a change in PI and an office
move, to locate the supporting documentation for these trips.
SCERP wishes to have the Director of Grants Administration reevaluate the recommendation on
the travel costs within the scope of the entire award.
Equipment $13.272
In the Year 2 budget approved by our Project Officer, administrative equipment was included.
Equipment to support the administrative functions of SCERP by definition falls into the category
of "general purpose equipment" SCERP consortium communicates extensively by fax and
printed media; the need for a fax machine, laser printer, and computers should not be questioned.
When items of this nature are used to support one project rather man as shared resources among
several sponsored activities, their costs should be allowable. These items of equipment would not
have been purchased had it not been for SCERP, and are still being used daily for SCERP
activities. No college funds are available for equipment dedicated to particular research activities.
Utah believes that these costs are reasonable and should be allowed. As with all general purpose
equipment, EPA is welcome to request return of the equipment in question at the end of SCERP's
funding relationship with EPA.
Consultant fees $18.388
With respect to the Utah's consultant costs that were questioned, the consultant's fees and
expenses should be allowable; the consultant was hired for this project for his skills in writing and
communications. The individual in question has been compensated far below market-level for his
skills and experience as a retired high level executive (Manager, Worldwide Information Services)
of an international oil corporation. As a result, the most important contributions to SCERP have
been the writing and editing of significant documents. For example, successive editions of
SCERP's Interim Report to EPA and the congress were all written in layman's language by the
consultant and provided useful overall summaries of SCERP's activities to the Agency, Congress,
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APPENDIX I
Page 14 of 15
SCERP Response to EPA OIG, 9/12/95, page 13 '
and others. As is pointed out in other pans of this report, information transfer has been a
consortium weakness, one that the Utah consultant has helped the consortium address. He also
serves the Engineering College in other capacities (funded from non-SCERP sources), mostly in
the capacity of writer and editor, but also including lobbying the state legislature for the annual
"Engineering Initiative" that provides infrastructure support to the college as a whole (no benefit
to SCERP), but has not and does not lobby the federal government for any purpose, including
SCERP. Further, we have reviewed the OMB Circular A-21 provisions on allowable public
relations costs (SecUld2), which states that allowable public relations costs include: "(2) Costs of
communicating with the public and press pertaining to specific activities or accomplishments
which result from performance of sponsored agreements;" and believe that the consultant costs
fall within this category. Therefore, SCERP wishes to have the Director of Grants Administration
reevaluate the recommendation on the consultant costs.
Miscellaneous Costs
Utah concurs with the questioned miscellaneous costs related to the Snowbird Conference.
Responses relating to projects at New Mexico State University.
With respect to the contention by OIG that NMSU claimed $12,372 in unallowable expenses:
The work done was within the approved scope of the CA. Specifically, the work performed was
part of the system designed to include a training component that could be used for training
inspectors and maquila employees and provide training and information to client groups.
NMSU submitted two proposals for which the work was related. It did not submit two proposed
research projects for identical work.
V. Summary
In sum, SCERP is appreciative of the efforts of OIG to analyze the consortium operations and to
I provide constructive suggestions that will help SCERP to carry out its mission in a more focused
} and cost effective manner. We find OIG's draft report to be extremely useful and it is a helpful
blueprint for positive change. However, there are a number of areas where SCERP comments and
I clarification are needed.
[The OIG draft report's discussion of priorities for SCERP and EPA projects is quite detailed and
I is very helpful in terms of assisting SCERP to more clearly define priorities. However, we do feel
that it is not possible to define a set of priorities that all actors in the border region will agree
upon. The border is a region that is complex and dynamic and needs and concerns vary
considerably from community to community along the border and evolve rapidly over time. The
OIG draft will help us better refine our methodology for defining priorities and it has pointed out
to us the need for SCERP to undertake a concerted effort to better analyze the issue of defining
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APPENDIX I
Page 15 of- 15
SCEBP Response to EPA OIG, 9/12/95, page 14
priorities for border environmental projects.
The OIG draft report also raised concerns about the selection of specific projects funded in the
annual SCERP research program, particularly as concerns the selection process and the
appropriateness of the projects to resolving border environmental problems. In our response we
explain that scores by technical reviewers are used in concert with other criteria to determine final
selection. For example, EPA priorities and needs, synergy with other SCERP projects, binauonal
participation, potential for long-term capacity building in the border region, equitable distribution
of projects along die border, a mix projects with immediate and longer term impacts, and other
factors ail enter into the selection. We also need to underline that SCERP is committed to the
long-term resolution of border environmental problems and that entails not only projects that
focus on immediate concerns but projects that will bring significant results in the medium and
long run. With that said, the OIG draft report does provide very helpful suggestions that will help
SCERP work with OAR and the other EPA offices to improve the project selection process,
beginning with the FY 1996 RFP which is now in the works.
SCERP acknowledges the utility of the various recommendations made in the OIG draft report.
SCERP has already moved to stabilize its management structure with implementation of a policy
to rotate the chairmanship of the management committee every two years and will discuss
additional measures in our continuing meetings with OAR. The OIG suggestions on enhanced
interaction between SCERP project principal investigators and EPA technical staff will be
incorporated into the next RFP issued by the consortium. With respect to better distribution of
SCERP research results to appropriate EPA staff, SCERP has been working on this with OAR
and the regions and will monitor the effort in the future.
Finally, the draft report of OIG identifies a number of costs incurred by the various SCERP
projects that it feels are ineligible. We have included responses to those specific items and
respectfully request that OIG carefully consider the new information that we provide on the
questioned items.
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?,PPSNDIX II
Pace 1 of 4
UNITED STATES ENVIRONMENTAL PROJECTION AGENCY
WASHINGTON. D.C. 20460
SEP I 2 1995
OFF1CEOF
AIR AND RADIATION
MEMORANDUM
SUBJECT:
FROM:
TO:
Draft Report on Audit of Cooperative Agreements with the
Southwest Center for Environmental Research and Policy
K
Office
czveg, Directoi
Program
ent Operations.
Bennie Salem, Acting Divisional Inspector
General for Audit
In response to your request, we have reviewed the draft audit
report, "The Southwest Center for Environmental Research and Policy
Should Focus on Border Problems."
Overall, we believe that in many instances this report
provides either incomplete information or ignores information that
we provided to "the investigators. This report is, in many
respects, less complete and accurate than the previous draft. We
urge the investigators to review the following comments carefully
and make important and necessary revisions to the report.
The report is not clear about the extent of the audit and the
findings for different elements. We understood that the
investigation.involved both financial and performance audits for
the three cooperative agreements (CAs) (FY 1991-FY 1993) managed by
the Office of Research and Development and only a performance audit
for rhe first CA (FY 1994) managed by the Office of Air and
Radiation (OAR). The report confirms this on page 3 but then in
Chapter 2 the report addresses the technical review and selection
processes for the FY 1995 CA. In addition, throughout the report
recommendations and criticisms are provided that are not time-
specific. We believe that it is important that specific-comments
be tied to specific CAs or management phases (i.e., under ORO
management or under OAR management).
s
Our most serious concerns with the report are with Chapter 2,
"Prioritizing Border Problems is Necessary to Focus Limited
Research Resources," which primarily focuses on the FY 95 CA. The
central theme presented in the chapter, that EPA has not
prioritized border problems in selecting among research proposals,
may have been accurate for the early CAs. We do not believe this
finding is accurate for the FY 1994 or FY 1995 CAs. It is clear
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APPENDIX II
Page 2 of 4
fron the report that the Investigators did not understand or were
unaware of the complete processes that were used to set priorities
and decide among research proposals for the FY 1S54 and FY 1995
CAs-
Our general approach for both the FY 1994 and FY 1995 CAs was
to identify EPA priorities as explicitly as possible and work with
SCERP in selecting among research projects proposed by individual
researchers to address these priorities. In identifying the
priorities to be addressed by the TY 1994 and FY 1995 CAs/ OAR
worked closely with other headquarters offices, Region 6 and 5
Mexico border coordinators and the border offices. The activities
that were included in the request for proposals (RFP) were a subset
of -toe activities included in the U.S./Mexico border plan (i.e.,
priority projects). All of tie activities that were Included in
the RFP vere considered hig-h priority by SPA staff. Border plan
activities that were not included in the RFP were either considered
inherently governmental or of lesser priority by EPA staff.
In developing the RFP OAR and the Regions decided that further
delineation of priorities within the set of activities would
provide no added value. Under a CA involving a solicitation to
researchers EPA has only limited ability to ensure that a specific
project is selected. Whether or not a specific project is
conducted is dependent upon all three of the following criteria
being met: 1) having a researcher who is qualified to do the work;
2} having a researcher who is interested in doing the work; and 3)
having a researcher who is available to do the work. Thus, OAR and
the Regions decided that providing a set of high priority problems
from which the investigators could choose was the appropriate
approach.
While all activities included in the RFP were considered high
priority, EPA did not assign the same priority to each. The
relative importance of an activity was considered during the
technical evaluation of the proposal. The criteria "relevance to
border environmental issues" and "statement of the problem and
need" combined to account for 35 of the possible 100 points a
proposal could receive. These criteria basically served as
"yes/no" screen—i.e., "yes" meant it was a high priority and it
was evaluated using the other criteria and "no" meant it was not a
high priority and it was off the table for consideration. For
example, if a proposed project could not demonstrate its relevance
or need it could only hope to receive at most 65 points under the
technical review.
The report is also inaccurate in describing the process for
selecting projects once the technical evaluations were complete.
The process was significantly more complex than a mere ranking of
projects based on technical evaluations. While the report
correctly points out that "the scoring of the technical evaluations
resulted in a significant variation in scores," this was not, as
the report indicates, because "EPA [offices] did not agree on the
highest priority problems." Rather, it was because of the
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APPENDIX II
Page 3 of 4
assumptions -of the individual reviewers. The first example of
variation in scores _ on page 9 cf the report can be used to
illustrate this point. In an effort to involve the greatest
expertise from the Agency as possible, OAR involved all
Headquarters offices in- the technical review as well as both
Regions 6 and 9 and their border offices. Most of the individuals
who participated from Headquarters were involved because of their
technical (scientific) expertise and not because of their knowledge
of border needs. If a project was scientifically sound they would
give it a high score (e.g., 86). On the other hand, individuals
from the Regions and Border offices were involved primarily for
their knowledge of border needs and to a lesser extent for their
scientific knowledge. If a project did not aeet a recognized need
of the border they would give it a low score (e.g., 38 and 6) even
if they thought the proposal was sound technically.
What the report fails .to point out is that the project
selection meeting was designed to work through these conflicting
pieces of information. The meeting participants, EPA staff and
SCERP management, discussed over a six hour period the merits of
each proposal using the results of the technical evaluations. The
discussions focused on understanding why evaluators scored
proposals as they did. In almost every instance after discussing
a proposal the group was unanimous in its decision on whether to
fund it. For instance, regarding the proposal used in the report's
first example, the selection committee decided not to fund the
project based on the lack of "need." The variation in scores noted
in the report's second example can be explained in similar fashion
to the first example's.
If Congress directs funding to SCERP again in FY 1996, OAR
will revise its proposal review process to separate the "needs"
review from the technical review, making the "needs" review the
first, and possibly the last review for some projects. In this way
fewer proposals will have to undergo the more time consuming
technical review. The selection committee meeting, and the need
for it, will remain however.
Regarding the report's four recommendations that apply to OAR,
we agree with one, have previously implemented another, and
disagree with two.
+ OAR agrees that stabilization of the SCERP management
structure is desirable for the purposes of continuity and will
take steps to ensure, that it happens.
•• OAR has. already implemented with SC-21? a systen for
disseminating research information to the EPA Headquarters,
Regional and Border Office staffs.
As mentioned previously, OAR has in place an appropriate
prioritization process for proposed research and based on the
report findings sees no need to make changes.
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Page
*• Finally, OAR agrees that a technical nonitoring program to
review ongoing research is desirable. In fact, OAR has made
solicitations to EPA staff that they voluntarily serve as
technical monitors for SCERP projects. However, OAR is in no
position to expend additional resources to ensure that this
done or to require that Regional or other headquarters offices
take on this function.
If you have any questions regarding these comments please
contact me at (202) 260-7415,
cc: Paul Ganster, SCERP
Oscar Ramirez, Region 6
Jim Yarbrough., Region 6
Nellie Rocha, Region 6 Border office
John Hamill, Region 9
Bill Jones, Region 9
Dave Fagey, Region 9 Border Office
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APPENDIX III
ABBREVIATIONS
ASU Arizona State University
CA Cooperative Agreement
CFR Code of Federal Regulations
EPA Environmental Protection Agency
FSR Financial Status Report
NMSU New Mexico State University
OAR Office of Air and Radiation
OIA Office of International Activities
OIG Office of Inspector General
OMB Office of Management and Budget
ORD Office of Research and Development
PO Project Officer
SCERP Southwest Center for Environmental Research and
Policy
SDSU San Diego State University
UTAH University of Utah
UTEP University of Texas at El Paso
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Report NO. E1FUF5-08-0019-5100528
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APPENDIX IV
DISTRIBUTION
Office of Inspector General
Inspector General (2410)
Deputy Assistant Inspector General for Acquisition
and Assistance Audits (2421)
Deputy Assistant Inspector General for Internal
and Performance Audits (2421)
EPA Headquarters Office
Director, Research centers Program (1101)
Headquarters Library (.£-304)
3lo\
EPA Region 6
Regional Administrator (6RA)
Border Office
EPA Region 8
Regional Administrator (8A)
EPA Region 9
Regional Administrator
Border Office .
Southwest Center for Environmental Research and Policy
Management Committee Chairperson
University of Utah
Dean, College of Engineering
University of Texas at El Paso
President
55
Report NO. E1FUF5-08-0019-5100528
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