February 2, 2015
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*	• U.S. Environmental Protection Agency	15-4-0072
w "z Office of Inspector General
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At a Glance
Why We Did This Review
The U.S. Environmental
Protection Agency (EPA),
Office of Inspector General
(OIG), conducted this
examination to determine
whether the costs claimed
under a Brownfields Revolving
Loan Fund Cooperative
Agreement BF97119201
(the agreement), awarded to
the Pioneer Valley Planning
Commission (PVPC), are
reasonable, allowable and
allocable in accordance with
the applicable laws, regulations
and agreement conditions. The
OIG also sought to determine
whether the objectives of the
award were met.
PVPC is the regional planning
body for the Pioneer Valley
Region, which encompasses
43 cities and towns in the
Hampden and Hampshire
county areas of Massachusetts.
This report addresses the
following EPA goal or
cross-agency strategy:
• Cleaning up communities
and advancing sustainable
development.
Send all inquiries to our public
affairs office at (202) 566 2391
or visit www.epa.gov/oia.
The full report is at:
www.epa.gov/oig/reports/2015/
20150202-15-4-0072.pdf
Costs of $1.2 Million for Brownfields Cooperative
Agreement to Pioneer Valley Planning
Commission in Massachusetts Questioned
We found all of the
$1,261,665 drawn by PVPC to
be questionable, and PVPC
has already agreed to repay
$94,891 of that amount.
What We Found
PVPC did not follow federal requirements when
administering the agreement. Also, PVPC's
accounting system cannot provide an accurate,
current and complete disclosure of the financial
results. Of the $1,261,665 in funds drawn,
PVPC acknowledged that $94,891 involved
duplicate invoices, unverified costs, costs associated with another federal
assistance agreement, and ineligible indirect costs, and agreed to repay $94,891.
We consider the remaining $1,166,774 to also be questionable due to the other
accounting deficiencies. PVPC's accounting reports for the agreement do not
reconcile, PVPC did not implement a corrective action from a previous Single
Audit report, and PVPC is applying the wrong administrative requirements in its
internal policies and procedures because those procedures apply to non-profit
organizations and not governmental units such as PVPC.
PVPC achieved the intent of the agreement in that four brownfields were
remediated. Two of the four sites were also reused, while the other two sites
remained vacant due to market conditions and other factors.
Recommendations and Planned Corrective Actions
We recommend that the Regional Administrator, EPA Region 1:
•	Place PVPC on a reimbursement basis for all EPA grants and agreements.
•	Issue a stop work order for this agreement until PVPC is able to provide
accurate information on costs incurred for the agreement.
•	Require PVPC to transfer $19,277 program income back to the Revolving
Loan Fund.
•	Verify that PVPC has a financial management system that meets federal
standards prior to any future awards.
•	Question and recover $1,261,665 of federal funds drawn at the time we
began our review.
EPA Region 1 agreed to all recommendations and provided corrective actions
and completion dates that meet the intent of the recommendations. Further,
PVPC has already agreed to repay $94,891 in questioned costs and transfer
$19,277 back to the Revolving Loan Fund.

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