AN EVALUATION OF THE
DELEGATED CONSTRUCTION
GRANTS PROGRAM
IN THE STATE OF IDAHO
Prepared for
THE ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER PROGRAM OPERATIONS
Larry Walker Associates
October 1980

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TAELE OF CONTENTS
Pa^e
INTRODUCTION 		1
STATUS OF DELEGATION 		2
DESCRIPTION OF THE STATE'S PROGRAM 		5
Organization 		5
Resources 		9
Management . . . 			9
Grants Processing Procedures 		12
Processing Times 		17
ASSESSMENT OF THE STATE'S PERFORMANCE ....	17
Organizational Structure and Resources .	20
Management			21
Grants Processing Procedures 		26
Quality of State Reviews 		28
Timeliness of State Reviews 		28
Overall State Performance 		30

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AN EVALUATION OF THE
DELEGATED CONSTRUCT I ON GRANTS PROGRAM
III THE STATE OF IDAHO
INTRODUCTION
This evaluation was conducted for EPA's Office of Water Program Opera-
tions as part of a nationwide assessment of the delegated construction
grants program. Evaluations, in conjunction with on-site reviews, were
made of each of the ten EPA regional offices and of one delegated state
within each region. The purposes of the evaluations were:
1)	To determine the status of delegation in each state and region
2)	To evaluate the performance of the delegated states
3)	To evaluate the performance of the EPA regional offices under
delegation, and
4)	To identify any problems or needs that are developing under delegation.
After the on-site evaluations were completed, a national report was
prepared summarizing the findings of the individual evaluations, discussing
the problems and needs that were identified, and making recommendations
as to how these problems and needs should be dealt with.
This particular report represents the results of an on-site evaluation
of the State of Idaho's administration of the delegated construction
grants program. An accompanying report discusses the findings of the on-site
evaluation of EPA Region X's operation under delegation.
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The contractor spent two days in the Idaho State offices (July 23 and 24)
interviewing the management staff involved in the grants program. The
following individuals were interviewed:
A1 Murrey	Chief, Bureau of Water Quality
Robert Olson	Chief, Bureau of Regional Environmental
Services
Orlando Dalke	Manager, Municipal Facilities Construction,
Bureau of Water Quality
Bob Braun	Senior Environmental Engineer, Municipal
Facilities Construction, Bureau of
Water Quality
Mike McMasters	Principal Environmental Specialist,
Municipal Facilities Construction,
Bureau of Water Quality
Bill Jerrel	Senior Accountant, Municipal Facilities
Construction, Bureau of Water Quality
Tom Korpalski	Senior Environmental Engineer, Region II,
Bureau of Regional Environmental Services
STATUS OF DELEGATION
The State of Idaho entered into a delegation agreement with EPA Region
X on March 5, 1979. The agreement called for the immediate assumption of
authority by the State of five delegated tasks and subsequent assumption of
eight additional tasks (a schedule for the assumption of these latter tasks
was not specified). TTiree of the five tasks originally delegated to Idaho
were already being performed by the State under a previous delegation
agreement under Section 106 of the Clean Water Act. These three functions
involved the review and approval of plans and specifications, change orders,
and operation and maintenance manuals.
Idaho, as of the date of this evaluation, has not assumed authority for
any function beyond the five originally delegated in March of 1979, as indiciated
in Table 1." However, three additional delegation subagreements have been
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Table 1
STATUS OF DELEGATION IN IDAHO
Function	Status
Step 1, 2 and 3 Applications
Delegated
Plans of Study
Delegated
Plans and Specifications
Delegated
Change Orders
Delegated
O&M Manuals
Delegated
Plans of Operation
August 1980
A/E Subagreenents
August 1980
Pre-application Meetings
August 1980
Facility Plans
March 1981
Infiltration/Infl ow
March 1981
Pretreatment Program
Unscheduled
Start-up Services
Unscheduled
Small Community Assistance
Unscheduled

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drafted and are in various stages of completion. These include plans of
operation, A/E subagreements, and pre-application meetings. In addition
the State has expressed the intent to develop delegation subagreements
relating to facility plan review and infiltration/inflow later this Fall,
with the expectation of assuming full authority to administer these activities
in the Spring of 1981. The remaining three delegable tasks identified in
the original delegation agreement have not been scheduled, though the State
hopes to assume all thirteen delegable tasks identified by mid 1981.
At this time, the State will have assumed most of the delegable acti-
vities associated with Step 1 and Step 2 of the construction grants process.
The State will not have assumed any of the construction related activities
being performed by the Corps of Engineers; bid analysis and award, precon-
struction conferences, interim and final inspections, and payment requests
review. In addition, the State will not have assumed a number of delegable
functions commonly identified in delegation agreements. These includes the
review of user charge/ICR systems and sewer use ordinances, the preparation
of environmental documents, the preparation of federal grant offers, and
maintenance of the official project files.
As of the date of this evaluation, the State only had immediate plans
to take over the remaining thirteen delegable functions identified in the
original delegation agreement. No plans exist to take over those functions
being administered by the Corps of Engineers or the additional functions
commonly delegated to States. The State has indicated that if sufficient
manpower can be secured with available Section 205(g) funding, they would
like to assume all delegable functions associated with program administration.
The State of Idaho currently gets the minimum Section 205(g) funding
available to delegated States, i.e. $400,000 per year. The State's current
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year budget, however, exceeds $500,000 per year. The State is making up
for the deficit by using funds carried over from previous years, prior to
when the State assumed delegation.
The State of Idaho provides 15% matching grants to the 75% federal
grant, bringing the total municipal grant available to local municipalities
to the 90% level. In addition, using funds acumulated in this matching
fund pot, the State has initiated a separate State grant program for pro-
jects not typically fundable under the Clean Water Act. The State anti-
cipates that the current build up of funds in the matching fund pot will
allow them to fund projects for about a three year period, before the
excess funds run out. The separate State grant program will be administered
in a manner similar to the EPA construction grant program, though identical
program requirements will not be utilized.
DESCRIPTION OF THE STATE'S PROGRAM
Organization
Within the State of Idaho, the construction grants program is administered
by the Idaho Division of Environment, under the State Department of Health
and Welfare. The organizational structure of the Division of Environment
is shown in Figure 1. The division includes three bureaus: the Bureau of
Water Quality, the Bureau of Air Quality and Hazardous Materials, and the
Bureau of Regional Environmental Services. Within the division, two of the
three bureaus are actively involved in administration of the construction
grants program. These are the Bureau of Water Quality and the Bureau of
Regional Environmental Services. The Bureau of Water Quality has overall
responsibility for the construction grants program on a statewide basis,
but the Bureau of Regional Environmental Services has responsibility for
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ORGANIZATIONAL
Figure 1
STRUCTURE - IDAHO DIVISION OF
ENVIRONMENT
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the day to day administration of the program and the processing of indi-
vidual construction grant projects.
The Municipal Facilities Construction Section within the Bureau of
Water Quality has responsibility for management of the construction grants
program within the State of Idaho. This section establishes program goals
and objectives, develops statewide staffing plans, develops regulations,
guidelines and procedures for the program, provides quality control of the
work performed on individual grant projects by the regional offices, provides
assistance to regional staff, prepares the priority evaluation system and the
annual construction grants priority list, and biannually conducts a needs survey.
In addition the staff of the Municipal Facilities Construction Section reviews
grant applications approved by the regional offices for consistency and quality
and prepares the certifications for submission to the EPA regional office.
Figure 2 presents the organizational structure of the Municipal Facilities
Construction Section.
The three regional, offices within the Bureau of Regional Environmental
Services have prime responsibility for processing individual construction
grants projects. This function is performed under general guidance and
direction provided by the Municipal Facilities Construction Section. While
from a supervisory standpoint the construction grants staffs within the regional
offices answer to the directors of the regional offices, prograrnnatically
they answer to the manager of Municipal Facilties Construction Section.
No other organizational unit within the Idaho State government plays a
significant role in construction grants administration, though some units may
provide input relative to individual grant projects on request, either from
the Municipal Facilities Construction Section or from one of the regional
offices.
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Figure 2
ORGANIZATIONAL STRUCTURE/RESOURCES
MUNICIPAL FACILITIES CONSTRUCTION SECTION
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Resources
The State of Idaho currently has a staff of 17.5 positions involved in
administering the delegated construction grants program. As indicated in
Figure 2, 5 of these positions are located in the Municipal Facilities
Construction Section within the Bureau of Water Quality and 10.5 of the posi-
tions are located within the three regional offices. In addition, 2 clerks,
located in the regional offices, are involved in program administration.
Prior to delegation the State had 5.5 positions involved in administration
of program activities, with 12 additional positions heing added as a result
of delegation. At the present time the State believes that the existing 17.5
positions will be sufficient to allow it to assume all of the delegable
functions identified in the original delegation agreement, except for those
activities being administered by the Corps of Engineers.
Managment
The manager of the Municipal Facilities Construction Section has overall
responsibility for management of the delegated construction grants program.
The manager and his staff have several tools to assist them in carrying out
this responsibility. First, a number of monthly reports are produced
which indicate the current status of the construction grants program. One
report indicates the number of grant awards made during the current and
previous months as well the amount of grant funds obligated in association
with those awards. Another report identifies significant activities and
outputs during the current month, including the specific grant awards made
and the amount of the grant, as well as the major activities performed by
staff involved in program administration. A third report, prepared by the
three regional offices, reports on the status of active construction grants
projects. Finally a monthly report is produced which identifies various
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outputs in relation to planned outputs identified in the State EPA agree-
ment. This report indicates the actual performance in the current month
versus the planned performance identified in the State EPA agreement. The
specific perameters identified include the number of grant awards, the
number of preapplication conferences attended, the number of facilities
plans reviewed and approved, the number of plans and specifications reviewed
and approved, the number of change orders reviewed and approved, etc.
Another tool utilized by program managers is the publication
of program guidance memos. These memos are produced by the Municipal
Facilities Construction Section staff, based on input from the
regional program managers, and provide guidance to those in the
regional offices involved in processing individual grant projects.
One such program guidance memo outlines the review procedures
associated with the processing of grant applications. Another
provides guidelines for land application systems. A third memo
addresses the elegibility of land application facilities for the
alternative technology bonus.
The staff of the Municipal Facilities Construction Section
meets with the senior environmental engineers in the regional
offices every several months to discuss construction grants related
issues. At these meetings the municipal facilities construction staff up-
dates the regional senior engineers on new program developments and new
program direction and discusses any general problems or issues. At these
meetings the senior staff in the regional offices have an opportunity
to raise problems identified from their perspective.
Another tool utilized by the Municipal Facilities Construction Staff
to oversee the program is a quality control program, still in the early
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stages of development. To date this quality control effort has involved
the periodic review of documents processed by the regional staff together
with a comprehensive review of regional performance activities conducted in
conjunction with the EPA Operations Office located in Boise. The staff of
the Municipal Facilities Construction Section is in the process of developing
a comprehensive quality control program to oversee the performance of the
individual grant processors located in the regional offices.
One additional tool recently developed jointly by the EPA Operations
Office and the State staff is the Idaho Targeting and Tracking System (ITTS).
This is basically a project tracking system developed for the purpose of
assisting individual project engineers as well as program managers in follow-
ing the progress of grant projects through the long grants process. This
computerized reporting system will contain projected dates for various inter-
mediate steps through each of the three steps of the construction grants
process. The program will also identify actual dates in relation to those
projected and will maintain a running accumulated slippage for each grant
project. These reports will be available on a monthly basis to the indi-
vidual project engineers and the program managers within the regional and
central offices. Another report to be produced from the ITTS system will
provide each project engineer with a schedule of anticipated activities
for the coming months. Basically this program will identify for each pro-
ject engineer, and for each project that he is responsible for, the documents
that are anticipated to be received during the coming month. Through use
of this particular report, the project engineer can plan and schedule his
activities for the month.
A third report developed from the ITTS system is designed to assist
the senior engineers in the regional office and the central office program
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managers with carrying out their responsibilities. This report will provide
for each region the current status of each active grant project. For each
step associated with each project, this report will identify an original
target date for receipt of a document, the actual date the document is
received, the date the State staff performs the initial review, and the
date on which the final review is completed.
The ITTS system has been developed and at this point is just beginning
to be implemented by the State staff. The system basically uses the GICS
management information system developed by EPA. Available storage space
within GICS will be used to store the additional tracking information
required for this particular program. At the present time the GICS system is
maintained out of the Seattle regional office. The State hopes to get a
computer terminal for their use^located either in their State offices or in
the EPA Operations Office located in Boise.
Grants Processing Procedures
As previously stated, the responsibility for processing individual grant
projects lies with the projects engineers located in the three regional offices.
The project engineers handle all review aspects associated with a
construction grants project, from the initial step 1 preapplication conference
through to final project close-out. A project engineer's first involvement
with an individual grant project begins with the conduct of a preapplication
conference. This conference is usually scheduled two months prior to the
date contained on the adopted priority list for award of a step 1 grant.
The project engineer tries to schedule the preappl ication conference prior
to the grantees selection of a consulting engineer. The reason for this
is that the project engineers like to advise the grantee on the proper pro-
cedures for hiring a consulting engineer. More particularly they like to
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suggest that the grantee interview a number of engineers and check on their
background and experience in the program and in the sanitary engineering
field prior to selection.
At the preapplication conference, the project engineer provides the
grantee with a general overview of the program and specific guidance on
what the grantee must do next. After the grantee has selected a consultant,
the project engineer will meet with the consultant to review general program
requirements and specific requirements relative to preparation and submittal
of a step 1 application and plan of study. In almost all cases the consultant
will submit a draft plan of study and A/E contract to the project engineer for
review and comment prior to preparation of the final application package.
Upon receipt of an acceptable step 1 application package the project
engineer will approve the plan of study and send an approval letter to the
grantee. The project engineer will also review and recommend approval of
the step 1 application. The application package and the recommend approval
will be forwarded to the State's central office for a quality and consistency
review and for preparation of a certification package. The certified package
will then be sent to the EPA Operations Office.
During the step 1 facilities planning process, the project engineer
will have numerous contacts with the grantee and/or its consulting engineer.
In almost all cases the project engineer will review population projections
prepared by the consultant early in the facilities planning process. In
addition the project engineer will provide an intermediate review of facilities
plans at the time of the public meeting required by the public participation
regulations. In all cases the project engineer will receive a draft facili-
ties plan for review and comment. Because facilities planning has not yet
been delegated to the State, the State attempts to combine its comments with
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those prepared by EPA. Recently, however, because of excesive work load
imposed on EPA operations office staff, EPA comments have lagged State
comments. Generally the State is able to get its comments out within 30
days of receipt of the draft facilities plan, the time table identified
within the delegation agreement.
Subsequent to receipt of State comments on the draft facility plan,
the grantee will schedule a public meeting. This meeting will generally be
attended by the project engineer. Subsequent to the receipt of comments from
the public, the grantee will prepare a final facilities plan and submit it
to the State project engineer.
After receipt of a final facilities plan, the project engineer will
review and recommend approval of the document. The approval is transmitted
through the State's central office to the EPA Operations Office for review
and final approval. Generally the EPA Operations Office staff has already
prepared the environmental assessment for the project and is in a position
to grant approval to the facilities plan.
About the time the State is reviewing the final facilities plan, the
project engineer requests submittal of a step 2 application package from
the grantee. While EPA is finalizing its approval of the facilities plan
and preparing the environmental assessment, the State is reviewing the
step 2 application package. When the State reviewer is satisfied that
everything is in order, the step 2 application is recommended for approval
and is transmitted to the central office for a quality/consistency review.
Subsequently the central office transmits the certified step 2 application
to the EPA Operations Office for processing. Upon approval by the Operations
Office, the package is transmitted to the EPA regional office in Seattle for
grant award.
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Step 2 grants generally contain dates requiring submittal of plans and
specifications at various stages of completion. The grantee is required to
submit a set of plans and specifications at the 10% completion point, the 50%
completion point and the 90 to 100% completion point. Each of these submittals
is reviewed by the project engineer. The 10% submittal generally contains the
detailed design criteria and the initial unit sizing and dimensions. For each
of the submittals the project engineer performs a detailed review and transmits
comments back to the consulting engineer.
Upon receipt of the completed set of plans and specifications (90% to
100% complete), the project engineer transmits tv/o copies directly to the Corps
of Engineers for a biddability/constructability review. The project engineer's
review of the plans and specifications is conducted simultaneously with the
Corp's review. The Corps of Engineers' comments are transmitted back to the
project engineer who attaches the comments to his own comments and transmits
them to the consulting engineer. Generally, subsequent to submission of
these comments, a meeting is held between the State project engineer, a
Corps of Engineers representative, and the grantee and its consultant. The
comments are discussed and agreement is reached as to modifications that are
to be made in the design. At this meeting, a time schedule for resubmittal
of a final set of plans and specifications and for an advertisement and bid
date are negotiated.
Upon receipt of a final set of plans and specifications, the project
engineer reviews them to insure that all comments which he and the Corps of
Engineers made have been taken care of. During this review, the project
engineer will request that the grantee submit a step 3 application. The
application is processed similar to the processing of step 1 and 2 applications.
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The State project engineer is also involved during the construction
phase of individual projects, though the Corps of Engineers has prime re-
sponsibility for administration of most step 3 activities. For example, the
State project engineer is notified prior to individual construction inspec-
tions conducted by the Corps. Generally the project engineer attends the
construction inspections. The Corps of Engineers inspection report is trans-
mitted through the State to the individual grantees. In terms of processing
change orders, the State has the prime responsibility for this activity,
though the Corps of Engineers-provides assistance. Change orders submitted
to the State are transmitted to the Corps of Engineers for a parallel review.
The understanding between the State and the Corps is that the Corps has three
weeks to get its comments on change orders to the State, whereas the State has
four weeks to approve or comment on the change order. Generally the Corps
reviews in detail about one of every five change orders that it receives.
The Corps utilizes its basic construction knowledge, as well as detailed
knowledge of individual projects gained through its inspections, as a basis
for its comment on change orders.
Also during construction the project engineer will review draft and
final operation and maintenance manuals. User charge and ICR systems, as well
as sewer use ordinances, are not yet delegated to the State and these documents,
when received by the project engineers, are transmitted through the central
office to the EPA Operations Office for review and approval. The State project
engineers also are not involved in processing payments during any part of the
construction grants process. During steps 1 and 2 payments requests are sub-
mitted by the grantee directly to EPA. During step 3, the Corps of Engineers
receives and processes progress payments.
In conjunction with final inspections, the project engineer will conduct
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an operation and maintenance inspection of the completed facility. The project
engineer will not approve the facility for final payment unless the facility
is operating as it was intended to operate.
Processing Times
The average State processing times for step 1, step 2, and
step 3 applications are presented in Table 2. Facilities planning
reviews times were not shown in this table because the State has
not yet been delegated the responsibility for the approval of
facilities plans. In addition, processing times for plans and specifications
were unavailable.
Of interest each functional delegation agreement contains target reveiw
times for State reviews. For example the State has 30 days after receipt of
a completed grant application from the grantee to prepare and transmit a
certification to EPA. Likewise, the State has 30 days after receipt of plans
and specifications, operation and maintenance manuals, and change orders,
to transmit its comments back to the grantee.
In conducting their quality control programs, the State's
central office and the EPA Operations Office review actual performance
of the project engineers in relation to the processing time goals
established in the functional delegation agreements.
ASSESSMENT OF THE STATE'S PERFORMANCE
The State's performance in terms of administering the delegated construction
grants program, was evaluated in the following areas:
1)	Organizational structure and resources
2)	State management of the program
3)	Grants processing procedures
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Table 2
STATE REVIEW TIMES
Peview/Approval
Processing Times, Days3
Step 1 Applications
17(11)
Step 2 Applications
18(3)
Step 3 Applications
9(1)
Total
34
a Review times are for approvals made between April 1, 1980
and July 16, 1980

Numbers in parentheses are number of projects approved
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4)	Quality of State reviews
5)	Timeliness of State reviews
The contractor's analysis of the State of Idaho's performance in each of
these areas is discussed in the following paragraphs.
Before assessing the State's performance in each of these activities,
however, the contractor would like to make one general comment
relative to the State's future plans for assuming additional delegated
functions. Contrary to other States visited in conjunction with
this evaluation of delegation, the State of Idaho is not planning
to assume responsibility for all delegable functions. A number of
functions that are legally delegable to individual States are not
addressed in the delegation agreement. Nor do discussions with
State staff indicate a desire to pursue remaining undelegated but
delegable functions. Delegable functions that are typically delegated to
States but which are not specifically addressed in the Idaho delegation
agreement include the processing of payments, the preparation of environmental
documents, the processing of user charge/ICR systems and sewer use ordinances,
the preparation of federal grant offers, and the maintenance of the official
project files.
It is the contractor's recommendation that the State pursue assumption of
these additional delegable functions and that the State plan to take over
these activities over the next year. The reason for this recommendation
is that until all delegable functions are in fact delegated to Idaho, or
to any State for that matter, EPA will have to continue to be involved in
individual grant projects. Thus the benefits of delegation (the
elimination of duplication, the reduction of paper work and the
administration of program by a single agency) will not be achieved.
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Organizational Structure and Resources
The State of Idaho has a rather unique organizational structure relative
to the administration of the construction grants program. Within the State,
the responsibility for the processing of grant projects lies with the three
regional offices. In most States the responsibility for administering this
program lies with a central headquarters type of operation. The decentrali-
zation of administrative responsibilities for this program to three regional
offices obviously makes program administration somewhat more difficult. It
also places considerable responsibility on the central office staff to coor-
dinate and oversee program administration as well as to provide quality
and consistency control.
In any organizational structure responsible for the administration of
the construction grants program, the contractor feels that it is important
to have a single manager responsible for administration of the construction
grants program. Further the contractor believes it is important to have all
significant grant related activities directly under the control of that
program manager. It is important that responsibility for such an important
and complicated program not be divided between individual managers. Initially
because of this strong feeling held by the contractor and because of the
decentralized approach to program administration utilized by the State of
Idaho, the contractor had some reservations about the States organizational
structure. However, in talking to program staff both in the central and the
regional offices, in learning more about the details of the operating pro-
cedures employed by state staff, and in reviewing the job descriptions of
the individual managers involved in program administration, the contractor
now feels comfortable with the present organizational structure. The
responsibilities appear to be clear as do the lines of authority. It is
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also clear that the responsibility for overall program management lies
with the manager of the Municipal Facilities Construction Section. Further
it is clear that the senior engineers having supervisory responsibility for
construction grants project processing within the regional offices answer,
from a programmatic standpoint, to the manager of the Municipal Facilities
Construction Section. Not only are these responsibilities and lines of
authority clear, but it appears that the present organizational
structure, while somewhat uncommon, is working effectively.
Part of the reason for this is the effort exerted by the central
office staff towards coordination of regional processing activities
and towards quality and consistency control.
In terms of the resources available within the State of Idaho to
administer the construction grants program, it appears to the contractor
that existing resources are adequate to administer those existing delegated
functions and the additional delegable functions identified in the' delegation
agreement. If and when the state takes over delegable functions beyond those
identified in the delegation agreement, i.e. processing of payments, pre-
paration of environmental documents, preparation of the federal grant offer,
etc., additional resources may be needed. In addition, it is likely that
at the time the state takes over Step 3 activities currently being admini-
stered by the Corps of Engineers, that additional resources also
will be needed for this purpose.
Management
The contractor was impressed with the numerous management systems and
tools employed by the management staff of the Idaho program. The
contractor was particularly impressed with the Idaho Targeting and
Tracking System (ITTS). This is by far the best project tracking
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system that the contractor has seen in the eight states visited to
date. The contractor anticipates that when this system is fully
operational, it will prove very valuable both to project engineers
responsible for reviewing individual grant projects and to program
managers. The system provides a mechanized approach towards scheduling
and tracking the progress of individual projects. It also pro-
vides a valuable tool for forecasting and planning workload. Finally the
contractor believes that on-going operation of this system will encourage
individual project engineers to more closely track the progress of indivi-
dual grants projects and to put more effort towards keeping their projects
on schedule. This in turn will provide considerable benefit to the State's
municipal facilities program: it will undoubtedly lead to more rapid com-
pletion of construction grants projects, and in turn to more rapid compliance
with water quality standards and discharge requirements, and finally it will
result in considerable cost savings due to reduced inflationary losses.
The contractor was also impressed with the various monthly reports
available to program managers to track the status and progress of the pro-
gram. Again the contractor finds these reports to be among the most com-
prehensive prepared by any state visited to date. These reports provide the
program managers with valuable information as to the status of various
program activities.
Another tool which the contractor found impressive was the water quality
guidance memos which are produced by the Municipal Facilities Construction
staff for the individual project engineers located in the regional
offices. Written guidance documents, relating important policy
decisions as well as providing procedural guidance, are necessary
and invaluable in the administration of the program.
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The contractor was also impressed with the quality control efforts
exerted by the central office to ensure consistency and high quality
performance from the regional offices. The contractor was particularly
impressed with the joint State/EPA annual evaluation of the performance
of the regional offices. The contractor believes this joint effort, which
serves both federal needs under delegation and State needs in terms of
ensuring consistency, expresses a certain spirit of cooperation that will
have positive impacts upon the conduct of the delegated program.
Another aspect of the State's management that the contractor found
impressive was the use made of the State EPA agreement. While all States
are required to have such agreements, Idaho appears to be using the State
EPA agreement process in the manner that it was intended to be used: as
a program planning document. The contractor believes that the use
of the State EPA agreement for this purpose is a valuable adjunct
to the State's management of the program.
In terms of management, while the state has one of the most sophisticated
array of management tools observed to date by the contractor, the contractor
has several suggestions that could further enhance the management capabilities
of the state. In general these suggestions involve elaborations or extentions
of management tools currently in place, rather than the development of any
new management systems or tools.
First in terms of the ITTS system, the contractor suggests that the State
produce another report from this system. Specifically the contractor re-
commends that the state prepare a report which summarizes the projected grant
awards and obligation levels for each month over the next several year period.
The ITTS system contains the projections necessary to produce this report,
but currently plans do not exist to do this. The contractor believes such
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information would be very valuable to state program managers in terms of
looking ahead and foreseeing problems, either in terms of dips in antici-
pated obligation rates or, on the other hand, peaks which the State cannot
possibly satisfy through the normal flow of construction grant funds. By having
such projections available to them, state program managers can do a better
job in terms of planning ahead to meet future program needs.
A second recommendation is that the state take the four basic monthly
reports and produce a single monthly management report containing all of the
information currently produced by the individual reports. These reports
could be included individually in the single monthly report or, preferably,
this information could be integrated in to a more comprehensive format.
Third, the contractor recommends that the central office schedule regular
meetings with the senior engineers responsible for program administration in
the three regional offices. Current practice is to hold such meetings every
several months, as the need arises. The contractor has two observations in
this regard. First the contractor does not feel in a program that is as
complicated and as changeable as the grants program that meeting every
several months is sufficient. A monthly meeting would be preferable.
Further, leaving the scheduling of such meetings to the time v/hen it appears
appropriate, tends to lead towards holding meetings on a less
frequently basis. The contractor recommends therefore that these meetings
be regularly scheduled on a monthly basis.
The contractor also recommends that upon receipt of delegation of all
activities associated with steps 1 and 2, and more particularly upon receipt
of delegation for facilities planning, that the state establish a regular
formalized meeting with the EPA Operations Office. At the present time, it
appears that there is almost continual communication between the EPA Opera-
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tions Office staff and the various individuals employed in state grant pro-
gram activities. The primary reason for this in the eyes of the contractor
is that facilities planning, as well as other significant program admini-
strative responsibilities, still lie with the EPA Operations Office. In
this situation there must of necessity be continual communications and con-
tact between the state and EPA. Upon delegation of the remaining functions,
however, this normal contact on a project by project basis will cease. That
is the time when regularly scheduled and formalized meetings become
desirable if not necessary.
The contractor believes that a regularly scheduled meeting will tend to
force communications, whereas meetings scheduled as the need appears to exist,
tend to put off communications and result in insufficient communications.
The contractor also recommends that these meetings follow a formalized or
routine agenda. Specifically these meetings.should be used as an opportunity
for EPA to update state staff on current developments at the federal level,
to express concern about any aspects of the state program administration
that EPA may be concerned about and to inquire into projects and issues of
interest to EPA. Likewise these meetings should be used by the State as an
opportunity to update EPA on state program activities, direction and output,
to update EPA on projects or issues that may be controversial or otherwise
of interest to EPA, and to discuss any problems in the relationship
between the state and EPA.
Fourth the contractor recommends the state establish a formal advisory
committee to provide input relative to state management of the construction
grants program. While considerable flexibility exists in the makeup of this
advisory committee, it is recommended that the committee be made up of
those outside interest groups that are active in the program. At a minimum
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consulting engineers and grantees should be represented on this committee and,
in addition, other interest groups such as contractors, environmental groups,
public interest groups, etc. may be included. The contractor believes that
the state should meet with this advisory group on a regular basis, somewhere
between monthly and quarterly, and follow a formalized agenda. The state
should use these advisory committee meetings as a means of updating
outside interest groups on current activities, developments and concerns,
as a means of reviewing proposed state policies and direction, and as a
forum to listen to program problems as seen from the eyes of those out-
side of state government. It is also recommended that the minutes from these
meetings be published and widely distributed throughout the state. Whereas
limited representation from various interest groups will be able to partici-
patate in the meetings, by distributing detailed minutes to all consulting
engineers active in the field, to all grantees with active construction
grants projects and to other interest groups, the state can communicate
much important information to those who have an interest in following
program activities, developments and issues.
The contractor also believes it would be of benefit to the state to have
a formal system of transmitting written information on new program requirements,
policy statements, etc. to grantees and consultants. The grants program is so
complicated and there is so much information being transmitted to consultants
and grantees, that they are often confused as to which of the many require-
ments are currently applicable. Through the use of a formalized system of
transmitting information to grantees and consultants, the state can con-
tinually update grantees and consultants on the current program requirements.
Grants Processing Procedures
The grants processing procedures employed by the State of Idaho appear
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to be quite adequate. The contractor particularly liked the approach uti-
lized by the state staff in the conduct of preapplication conferences. The
project engineers have numerous contacts with grantees and consultants
in advance of submittal of a final Step 1 application package. The
initial contact is oriented towards providing the grantee with general infor-
mation as well as advising him on how to select a consulting engineer. Like-
wise the project engineer provides specific guidance to the consultant rela-
tive to the identification of alternatives to be evaluated and assists the
grantee and the consultant by reviewing draft documents prior to preparation
of a final Step 1 package.
In addition the contractor was impressed with the fact that the project
engineers are actively involved with grantees and consultants during the
preparation of facilities plans and during the design phase of the project.
Further it appears that the state is moving towards even greater involvement
in the facilities planning process. They now plan to make a detailed review
of program progress subsequent to the initial screening of alternatives by
the consulting engineer. This is meant to supplement the intermediate
reviews already provided and, in the contractor's opinion, will greatly
assist grantees and consultants with preparing documents that are acceptable
to the state. The contractor supports this increased contact and communi-
cation between the state, grantees and consultants during the facilities
planning stage.
Relative to grants processing procedures, the contractor did not find
any problem in terms of coordination, unclear responsibilities, or over-
lapping reviews. The primary reason for this probably is the fact that all
review activities on a given project are handled by a single project
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engineer. Thus there is little opportunity for lack of coordination, poor
comnunications or overlapping responsibilities.
Quality of State Reviews
The contractor evaluated state reviews of three facilities plans and
four plans and specifications. Based on these reviews, the contractor
feels that the technical reviews performed by Idaho state staff are of
very high quality. Both in the case of facility plan reviews and plans
and specifications reviews, the contractor found the reviews to be very
detailed and thorough and to be substantative in nature. The contractor
felt the review comments were substantative in that they positively in-
fluence projects, in terms of project performance, project cost and pro-
ject operability. It is the contractor's opinion that these projects
will be better and more cost effective projects as a result of the
state reviews than if these reviews were not performed.
Timeliness of State Reviews
It appears that state reviews of grant applications are conducted in
a timely manner. Whereas the delegation agreement calls for State processing
of grant applications in a thirty-day period, review of the records indicate
that applications are routinely processed by the state in less than twenty
days. The contractor feels that this is a very good processing time. The
State indicates that the prime reason for such a rapid turnaround time on
the approval of applications is the fact that they request the applicant to
submit a draft application package for review and comment by the State prior
to submission of the final package. While some may argue that this is not
a fair assessment of total review time, the contractor is of the opinion
that the total processing time through such a technique will be less than
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were the applicant to submit what he feels is an acceptable package in
final form to the state for a one time only review.
Information was not available to the contractor relative to state pro-
cessing time for review of plans and specifications. However routine moni-
toring by the EPA Operations Office of delegated functions indicates that
State review comments generally are submitted to the grantee in a period
slightly beyond the thirty days called for in the delegation agreement.
One of the prime reasons why the review time of plans and specifications
goes beyond thirty days is that the Corps of Engineers has thirty-five
days to get its comments on plans and specifications relative to biddability/
constuctability review back to the state.
Based on this information it appears that the state is doing a very
good job in terms of timeliness of reviews and approvals of key documents.
The only recommendation that the contractor has relative to the processing
times taken by the state for significant reviews and approvals, is that the
State routinely report actual performance against processing time goals. The
contractor suggests that a good mechanism for reporting of processing times
would be in the monthly reports produced relative to the program.
The only other comment the contractor has relative to the State's pro-
cessing times is that state management should continue to encourage its
projects engineers to view one of their responsibilities as maintaining the
schedule of individual grant projects. Quite often the contractor finds that
project engineers view their responsibilities solely as being the review of
the quality of an individual grant document. The contractor feels that an
additional responsibility of significant importance is to keep a project
moving through the complex grants project in accordance with a reasonable
schedule. By keeping a project moving and completing it as soon as possible,
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water quality improvements are achieved sooner and at lesser costs. While
the contractor observed that the project engineers in Idaho appeared to feel
a responsibility for complete management of a project, including the main-
tenance of schedules, the contractor believes that additional emphasis along
these lines would help.
Overall State Performance
It is the contractor's opinion that the State of Idaho is doing a
very good job in terms of administering the delegated construction grants
program. The strengths of the Idaho program lie in the numerous management
tools that the state has developed, in the high quality of the
state's technical reviews and in the timeliness of the state's
reviews.
The only two recommendations that the contractor would offer to Idaho
are that the State pursue delegation of all delegable activities associated
with administration of the program and that they expand on the current set
of management tools already in existence.
Relative to expanding its existing set of management tools,
the contractor recommends that the state produce additional program
projections from the ITTS system, that the state combine its four
regularly produced monthly management reports into a single management
report, that the central office staff meet with the senior environmental
engineers in the regional offices on a monthly basis, that the
state and the EPA Operations Office staff meet on a regular basis
once facilities planning and other significant program functions
are delegated to the state, that the State establish a formal
advisory committee to provide input to the State relative to program
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management, and that the state develop a formal system of transmitting
written information on new program requirements to grantees and
consultants.
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