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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Protecting America's Waters
EPA Region 6 Mismanaged
Coastal Wetlands Planning,
Protection and Restoration
Act Funds
October 9, 2014
Report No. 15-P-0003
Scan this mobile
code to learn more
about the EPA OIG.
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Report Contributors: Patrick Gilbride
Randy Holthaus
Alexandra Zapata-Torres
Lisa Bergman
Mona Mafi
Abbreviations
ADA
Antideficiency Act
ARA
Assistant Regional Administrator
CWPPRA
Coastal Wetlands Planning, Protection and Restoration Act
DOE
Department of Energy
EPA
U.S. Environmental Protection Agency
EPM
Environmental Programs and Management
FY
Fiscal Year
GAO
Government Accountability Office
LDNR
Louisiana Department of Natural Resources
MIPR
Military Interdepartmental Purchase Request
MOA
Memorandum of agreement
OCFO
Office of the Chief Financial Officer
OIG
Office of Inspector General
ORISE
Oak Ridge Institute for Science and Education
PPL
Priority Project List
RESTORE Act
Resources and Ecosystems Sustainability, Tourist Opportunities, and
Revived Economies of the Gulf Coast States Act of 2012
Task Force
Louisiana Coastal Wetlands Conservation and Restoration Task Force
EPA Directive
EPA Resource Management Directive System
USACE
U.S. Army Corps of Engineers
U.S.C.
U.S. Code
WQPD
Water Quality Protection Division
Cover photos: At the left is a Louisiana barrier island (source: http://www.habitat.noaa.gov).
On the right is a dune restoration of Whiskey Island Back Barrier (EPA photo).
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• *• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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THE INSPECTOR GENERAL
October 9, 2014
MEMORANDUM
SUBJECT:
FROM:
TO:
EPA Region 6 Mismanaged Coastal Wetlands Planning, Protection
and Restoration Act Funds
Report No. 15-P-0003
Arthur A. Elkins Jr.
Ron Curry, Regional Administrator
Region 6
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report contains findings that describe the problems
the OIG has identified and corrective actions the OIG recommends. This report represents the opinion of
the OIG and does not necessarily represent the final EPA position. Final determinations on matters in
this report will be made by EPA managers in accordance with established audit-resolution procedures.
Action Required
In accordance with EPA Manual 2750, you are required to provide a written response to this report
within 60 calendar days. You should include planned corrective actions and completion dates for the
unresolved Recommendations 1, 3, 5 and 6. Your response will be posted on the OIG's public website,
along with our memorandum commenting on your response. Your response should be provided as an
Adobe PDF file that complies with the accessibility requirements of Section 508 of the Rehabilitation
Act of 1973, as amended. The final response should not contain data that you do not want to be released
to the public; if your response contains such data, you should identify the data for redaction or removal
along with corresponding justification.
The Region 6 Assistant Regional Administrator and the Office of the Chief Financial Officer should
provide the OIG with sufficient and appropriate support for the questioned costs. The agency and the
OIG should work together to reach resolution on corrective actions related to the questioned costs.
We will post this report to our website at http://www.epa.gov/oig.
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EPA Region 6 Mismanaged Coastal Wetlands
Planning, Protection and Restoration Act Funds
15-P-0003
Table of C
Chapters
1 Introduction 1
Purpose 1
Background 1
Scope and Methodology 6
2 Region 6 Did Not Manage CWPPRA Funds in Accordance With
CWPPRA Legislation and Other Agreements 7
CWPPRA Legislation Authorized Funds to Restore and
Prevent the Loss of Coastal Wetlands in Louisiana 7
Federal Appropriations Law, Appropriations Principles and
EPA Policy Address the Purpose and Use of Funds 8
EPA Policy Governs the Appropriate Use and Effective
Administration of Interagency Agreements 10
Region 6 Used CWPPRA Funds for Other EPA Water Programs
and General Management Expenses 11
Region 6 Lacks Controls to Ensure Accountability and Proper
Stewardship of CWPPRA Resources 23
Region 6 Overstated CWPPRA Costs and Augmented EPA's
Appropriations 25
EPA Planned Corrective Actions 25
Conclusion 25
Recommendations 26
Agency Comments and OIG Evaluation 27
Status of Recommendations and Potential Monetary Benefits 29
Appendices
A Details on Scope and Methodology 30
B CWPPRA Excerpts 31
C EPA's Portion of Task Force-Approved CWPPRA Planning
Budgets and Funds by Task for FYs 2010 Through 2013 34
D Agency Response 36
E Distribution 45
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Chapter 1
Introduction
Purpose
In January 2013, the U.S. Environmental Protection Agency (EPA), Office of
Inspector General (OIG), received a hotline complaint about the EPA's Region 6
Water Quality Protection Division (WQPD). The complainant alleged that the
WQPD mismanaged Coastal Wetlands Planning, Protection and Restoration Act
(CWPPRA) funds and EPA travel funds. After preliminary fact-finding on the
merits of the complaint, we found that there were indications that the WQPD
mismanaged CWPPRA and agency funds, and we decided to conduct additional
detailed audit work.
The purpose of this audit was to determine whether the WQPD used:
• CWPPRA funds in accordance with applicable federal laws, regulations
and other agreements.
• Agency funds efficiently.
Background
Loss of Louisiana Wetlands
Louisiana wetlands are unique and vital ecological assets worth saving.
According to the CWPPRA website, billions of dollars in seafood production, oil
and gas revenue, and commercial shipping will be lost without Louisiana's coastal
wetlands, which provide the basis and support for these industries. Louisiana has
lost up to 40 square miles of marsh per year for several decades. The loss of this
marsh accounts for 80 percent of the nation's annual coastal wetlands loss. This
loss is at an average rate of one acre every 38 minutes. If the current rate of loss is
not slowed by the year 2040, an additional 800,000 acres of wetlands will
disappear, and the Louisiana shoreline will advance inland as much as 33 miles in
some areas. See the map in Figure 1 for a depiction of actual land lost since 1932,
as well as land predicted to be lost through 2050.1
1 Data obtained from the Louisiana Coast CWPPRA website at http://lacoast.gov/new/About/Default.aspx.
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Figure 1: U.S. Geological Survey Map of Coastal Louisiana
New Orleans?
loumajj
Land Loss 1932 - 2000
iGrand Isle,
20 40 60 Kilomelers
1USGS 100+ Years of Land Change for Coastal Louisiana
science tor a changing world w
Land Gain 1932 - 2000
H Predicted Land Gain 2000 - 2050
/V Louisiana Land Change Study Boundary
Prepared by:
US. Geological Survey
National Wetlands Research Center Background is 2000 Thematic Map]
Lafayette, LA
Coastal Louisiana has lost an average of 34 square miles of land, primarily marsh, per year for
the last 50 years. From 1932 to 2000, coastal Louisiana has lost 1,900 square miles of land, roughly
an area the size of the state of Delaware. If nothing is done to stop this land loss, Louisiana could
potentially lose approximately 700 square miles of land, or about equal to the size of the greater
Washington D.C.-Baltimorc area, in the next SO years. Further, Louisiana accounted for an estimated
90 percent of the coastal marsh loss in the lower 48 states during the 1990s.
Source: U.S. Geological Survey National Wetlands Research Center.
According to the U.S. Army Corps of Engineers (USACE), as of May 2013,
196 coastal restoration or protection projects have been authorized, benefiting
over 113,000 acres in Louisiana. As a participating agency, the EPA has planned
and managed 23 coastal wetlands projects (completed or active), which have
benefited 13,323 net acres in Louisiana.2
Legislation
Congress enacted CWPPRA to identify, prepare and fund construction of coastal
wetlands restoration projects in Louisiana. Congress passed the CWPPRA in
1990, and the law is authorized until 2019 (see Appendix B for excerpts of the
act). Congress provided dedicated funding for the CWPPRA via the transfer of
small engine fuel taxes from the Highway Trust Fund to the Sport Fish
Restoration Account. The CWPPRA program provides targeted funds for
planning and implementing projects that create, protect, restore and enhance
wetlands along the Louisiana coast. Projects are for the long-term conservation of
wetlands and to support fish and wildlife populations. Projects funded by
CWPPRA are small-scale, cost-effective ways of creating, restoring, protecting
and enhancing coastal wetlands. The program uses a wide variety of coastal
restoration and protection methods. These methods include marsh creation and
2 Data obtained from the CWPPRA website at www.lacoast.gov (as of September 2013).
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nourishment, freshwater reintroduction, sediment diversion, foreshore protection,
barrier island restoration, terracing, containment dikes, water flow management
and invasive species removal.
The CWPPRA Task Force
The CWPPRA established the Louisiana Coastal Wetlands Conservation and
Restoration Task Force (Task Force) to manage the CWPPRA program. The
USACE chairs the Task Force and allocates funding to participating agencies for
planning activities and projects. The USACE also tracks the status of funds for all
CWPPRA projects. The Task Force is comprised of five federal agencies and one
state agency:
• USACE (represents the U.S. Army)
• U.S. EPA
• U.S. Fish and Wildlife Service (U.S. Department of the Interior)
• National Oceanic and Atmospheric Administration
(U.S. Department of Commerce)
• Natural Resources Conservation Service
(U.S. Department of Agriculture)
• Governor's Office of Coastal Activities (state of Louisiana)
The EPA Administrator delegated responsibilities for Task Force membership to
the Region 6 WQPD Director. Each year the Task Force—with the help of its
supporting committees and workgroups—prepares, selects
and approves a list of projects for funding. The Task
Force provides this Priority Project List (PPL) to
Congress as required by the CWPPRA. At right is the
CWPPRA logo (source: http://dnr.louisiana.gov).
CWPPRA Funds
Annual CWPPRA funding for all participating agencies
combined has ranged from $30 to $80 million. The act
makes funds available for two main categories of activity:
(1) developing the annual PPL (referred to as planning), and (2) implementing
restoration projects from the approved PPL. The Task Force approves an annual
planning budget and allocates funds based on the approved budget to participating
agencies.3 The annual planning budget must not exceed $5 million and is
categorized by planning tasks. Region 6 has received in excess of $500,000
annually from 2010 through 2013 to fund its Task Force planning participation.
Additionally, from 2010 through 2013, Region 6 managed Task Force-approved
projects that ranged from about $48,000 to $23 million in total funding. During
fiscal years (FYs) 2010 through 2013, Region 6 WQPD managed 14 active
3 The Task Force allocates CWPPRA funds that are equal to the amounts shown in the approved budgets.
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CWPPRA projects with a cumulative value of about $82 million, and also
managed 4 years of allocated planning funds averaging about $521,400 per year
and totaling $2,085,556.
The act is specific about the purpose of the CWPPRA funds. Funds are to be used
to plan and implement projects approved by the Task Force. The Task Force
allocates funds, based on the approved annual planning budgets, for activities
directly related to developing the PPL.4 The planning budgets do not include
funds for activities indirectly related to the CWPPRA, related to other water
programs, or for general operations of member agencies.
General EPA operations are paid with Environmental Programs and Management
(EPM) funds that come from annual congressional appropriations. The EPA
operations include personnel labor, training, travel, communication systems,
records management systems, and other general infrastructure or support. EPA
managers have the discretion to reprogram or move EPM funds among other
water programs. However, CWPPRA funds are specifically for purposes
identified in the law and activities approved by the Task Force, regardless of
whether there may be indirect ties to other Gulf of Mexico efforts.
Responsible Offices
The Region 6 WQPD has responsibility for water quality programs that protect
and preserve the aquatic ecosystems and water resources of Arkansas, Louisiana,
New Mexico, Oklahoma and Texas, as well as tribal lands located within the
region. In addition to the CWPPRA program, WQPD also manages these water
programs:
• Drinking water.
• Underground injection control.
• National Pollutant Discharge Elimination System permits and the Total
Maximum Daily Load program.
• Surface water quality and water quality standards.
• Monitoring and assessment.
• Nonpoint source.
• Wetlands.
• Coastal and oceans.
• Effective grants management.
• U.S. Mexico Border.
• Climate change.
• Water and energy efficiency.
• Environmental justice.
• Public outreach.
4 See Appendix C.
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The Ecosystems Protection Branch within WQPD manages regional water quality
and the wetlands protection programs to meet national goals of preserving and
protecting surface waters and their uses in inland, coastal and estuarine areas.
There are four sections within this branch: the Marine and Coastal Section, the
Wetlands Section, the Watershed Management Section, and the Water Quality
Monitoring and Assessment Section.
The Marine and Coastal Section manages and conducts regional activities under
the CWPPRA, as well as the National Estuary Program, the Gulf of Mexico
Program, the Coastal Zone Management Act, and the Marine Protection and
Research and Sanctuaries Act. This section provides regional expertise on a
variety of coastal and marine issues and initiatives, including international,
national, regional and local estuarine management programs. These issues and
initiatives include, but are not limited to: evaluating marine impacts from
liquefied natural gas facilities, and assessing hypoxia in the Gulf of Mexico;
designating, managing and monitoring ocean disposal sites for dredged sediment;
and coordinating beneficial use of sediments in coastal restoration efforts.
The Marine and Coastal section manages the technical aspects of the CWPPRA
program, including support of Region 6 membership on the CWPPRA Task
Force. The section also provides oversight of federal funds provided by the Task
Force, and designs and implements Task Force-authorized restoration projects.
Federal Programs for the Gulf of Mexico
Although current CWPPRA funding levels do not support all of the necessary
restoration required for a sustainable ecosystem, the CWPPRA continues to
address immediate restoration needs while establishing a foundation of strong
science, public participation, and agency cooperation that will continue to serve as
the cornerstone of future programs. To address the projected land loss of coastal
Louisiana, large-scale coastal restoration projects that focus on the restoration of
ecosystems must be constructed. Such projects exceed the funding capacity and
authorization of the CWPPRA program.
The Louisiana Coastal Area initiative, which began in 2001, received
authorization in the 2007 Water Resources Development Act to begin to address
the need to develop and fund large-scale coastal restoration projects. The EPA
receives funds in the EPM annual appropriations, and from other laws, for work
related to water programs other than the CWPPRA. Funding is received from
other coastal restoration initiatives such as the National Estuary Program, the Gulf
of Mexico Program, the Wetlands Protection Program, and other Gulf-related
activities. Other laws that are a source of funds include the Clean Water Act and
the Resources and Ecosystems Sustainability, Tourist Opportunities, and Revived
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Economies of the Gulf Coast States Act of 2012 (RESTORE Act).5 Many of these
programs and activities have similar goals and include the same participating
federal, state or local agencies and personnel; and address the same geographic
locations and impacted populations.
Scope and Methodology
We conducted our audit from March 2013 through July 2014 in accordance with
generally accepted government auditing standards. Those standards require that
we obtain sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions based on
our objectives.
The time period covered by our audit was October 1, 2009, through June 30,
2013. We reviewed spending during this time period, including expenditures paid
with CWPPRA planning funds, CWPPRA project funds and EPM funds. Our
primary focus was on the use of CWPPRA planning funds, since that was the
focus of the hotline complaint. We also focused on questionable transactions that
our audit work revealed.
During our audit, we reviewed the CWPPRA legislation, federal appropriations
laws, Task Force documents, EPA interagency agreements with the USACE and
the Department of Energy (DOE), related EPA financial policies and procedures,
and financial data in the EPA's financial system called Compass Financials. We
interviewed WQPD managers and staff, as well as USACE officials from the New
Orleans District office. We assessed WQPD controls over travel and CWPPRA
spending and funds monitoring. We performed spending analyses on the WQPD's
financial expenditures and data. We reviewed and compared budget data from the
Task Force, WQPD's interagency agreements for CWPPRA and WQPD's EPM
budgets.
Appendix A provides further details on our scope and methodology.
5 The RESTORE Act became law on July 6, 2012. The law creates an essential framework for managing and
financing the Gulf Coast's recovery, and establishes a trust account for Gulf Coast restoration that will receive
80 percent of the funds from Clean Water Act penalties associated with the Deepwater Horizon Oil Spill. According
to Region 6, to date neither the region nor the EPA has received any funds from the RESTORE Act.
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Chapter 2
Region 6 Did Not Manage CWPPRA Funds
in Accordance With CWPPRA
Legislation and Other Agreements
Region 6 WQPD used CWPPRA funds for purposes that were not consistent with
CWPPRA authority, appropriations law and principles, and interagency
agreements. Further, WQPD management did not accurately record labor and
contractor costs to the CWPPRA program. This occurred because Region 6
WQPD did not have controls in place to ensure accountability and proper
stewardship of CWPPRA resources. Federal laws and EPA policies require
federal employees to ensure resources are used efficiently and effectively and that
public funds are used for the purpose for which they were appropriated and
authorized. The WQPD spent CWPPRA funds totaling $780,793 on questioned
costs, augmented the EPA's annual appropriations, and overstated CWPPRA
program costs. This mismanagement of CWPPRA funds resulted in "purpose
violations" of appropriations law, pursuant to 31 U.S.C. §1301(a), and put
Region 6 at risk of committing Antideficiency Act (ADA) violations.
CWPPRA Legislation Authorized Funds to Restore and Prevent the
Loss of Coastal Wetlands in Louisiana
The CWPPRA established the Task Force to develop a comprehensive approach
to create, restore, enhance or prevent the loss of coastal Louisiana wetlands.
The EPA receives funds in accordance with CWPPRA Section 303(a), which
requires the Task Force to identify and prepare a priority list of coastal wetlands
restoration projects in Louisiana. According to CWPPRA Section 303(a), those
projects must:
provide for the long-term conservation of such wetlands and
dependent fish and wildlife populations in order of priority, based
on the cost-effectiveness of such projects in creating, restoring,
protecting, or enhancing coastal wetlands, taking into account the
quality of such coastal wetlands....
The CWPPRA also requires the USACE to allocate funds among Task Force
members based on the need for such funds and other factors that the Task Force
deems appropriate to carry out the purpose of the act.
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Section 302 of the CWPPRA states that a coastal wetlands restoration project is:
any technically feasible activity to create, restore, protect, or
enhance coastal wetlands through sediment and freshwater
diversion, water management, or other measures that the Task
Force finds will significantly contribute to the long-term
restoration or protection of the physical, chemical and biological
integrity of coastal wetlands in the State of Louisiana....
The act specifically states that the primary purpose of a CWPPRA coastal wetlands
restoration project shall not be to provide navigation, irrigation or flood-control
benefits.
In 2000, the EPA signed a memorandum of agreement (MO A) with the US ACE
and the Louisiana Department of Natural Resources (LDNR). The MO A, which is
still in effect, says the EPA is responsible for implementing a number of coastal
wetlands restoration projects approved for funding by the Task Force. The MO A
also states that within all projects sponsored by the EPA, it is the EPA's and
LDNR's joint responsibility to administer short-term activities, such as
engineering, design and construction; and long-term activities, such as
monitoring, operation, maintenance, and the repair and rehabilitation of
authorized project features.
To carry out long-term responsibilities, the MO A states that the EPA will request
funding from the US ACE and will certify invoices, as approved, for payment. The
CWPPRA Task Force Project Standard Operating Procedures Manual, dated
November 9, 2012, states that the EPA is responsible for ensuring that funds are
spent in accordance with the CWPPRA. During the audit, we learned that the
Task Force is currently updating the CWPPRA Task Force Project Standard
Operating Procedures Manual to reinforce and clarify that the CWPPRA funds
allocated to agencies should be used for the purposes included in CWPPRA
Task Force-approved budgets.
Federal Appropriations Law, Appropriations Principles and EPA
Policy Address the Purpose and Use of Funds
According to 31 U.S.C. § 1301(a), appropriations "shall be applied only to the
objects for which the appropriations were made except as otherwise provided by
law." The use of funds for purposes other than those for which the funds are
appropriated constitutes a purpose violation in accordance with 31 U.S.C. §
1301(a), unless the expenditure for a different purpose is otherwise authorized by
law. The specificity of the CWPPRA's purpose means that using CWPPRA funds
for EPA activities that are provided for with annual appropriations constitutes a
purpose violation. A purpose violation does not necessarily constitute an ADA
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violation, and each purpose violation must be scrutinized on a case-by-case basis.6
Costs that are not identified in a specific law such as the CWPPRA, but are
necessary to implement agency programs, are to be incurred based on the
"Necessary Expense Rule." For expenditures to be justified as necessary, three
tests must be met:
1. The expenditure must bear a logical relationship to the appropriation
sought to be charged. In other words, the expenditure must make a
direct contribution to carrying out either a specific appropriation or an
authorized agency function for which more general appropriations are
available.
2. The expenditure must not be prohibited by law.
3. The expenditure must not be otherwise provided for, that is, it must not
be an item that falls within the scope of some other appropriation or
statutory funding scheme.7
Additionally, in instances where more than one appropriation may be construed as
available, the EPA is bound by what is referred to as the "pick and stick" rule. An
agency may make an initial election as to which appropriation to use (the "pick"),
but once the decision has been made the agency must "stick" to its choice. The
agency cannot, because of insufficient funds or other reasons, change its election
in a subsequent fiscal year and use another appropriation unless Congress is first
informed of the agency's planned change.8
According to 31 U.S.C. §1341(a)(1)(A), an ADA violation occurs when an officer
or employee of the U.S. government makes or authorizes an expenditure or
obligation exceeding an amount available in an appropriation or fund for the
expenditure or obligation.
The EPA's Resource Management Directive System (EPA Directive) 2520,
U.S. Administrative Control of Appropriated Funds, dated February 4, 2008,
states that violations of appropriations laws are serious matters that can
undermine the EPA's working relationship with Congress. Employees that
violate 31 U.S.C. § 1301 may be subject to administrative discipline in
accordance with EPA Directive 2520. A purpose violation has the potential to
also constitute an ADA violation per 31 U.S.C. § 1341(a). In addition, according
to EPA Directive 2520, an ADA violation also occurs if the funds that should
6 See 63 Comptroller General 422, 424 (1984), Office of Legal Counsel Memorandum Opinion for the General
Counsel of the Environmental Protection Agency, dated April 2007. See generally Principles of Federal
Appropriations Law, at 4-9.
7 1 GAO, Principles of Federal Appropriations Law, 4-21 through 4-22 (3ded. 2010).
8 The EPA's Administrative Control of Appropriated Funds, Release 3.2, dated February 4, 2008. Also see 1 GAO,
Principles ofFederal Appropriations Law, 2-23 through2-24 (3ded. 2010).
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have been charged when the event took place are not sufficient or are not
available to enable the accounting error correction.
EPA Directive 2520 requires federal employees to ensure that federal programs
operate, and that federal resources are used efficiently and effectively, to achieve
desired objectives. The policy states that management has a fundamental
responsibility to develop and maintain effective internal controls for the proper
stewardship of federal resources. The policy also requires managers to operate
programs and use resources consistent with agency missions; in compliance with
laws and regulations; and with minimal potential for waste, fraud and
mismanagement.
EPA Policy Governs the Appropriate Use and Effective Administration
of Interagency Agreements
According to the EPA's Interagency Agreement Policies, Procedures, and
Guidance Manual, issued in 2008, an interagency agreement is a written
agreement between the EPA and another federal agency, state or local
government, foreign government, foreign entity, or international organization that
is authorized by statute and has a distinct scope of work with all activities serving
defined objectives. An interagency agreement is a mechanism that the EPA uses
to accomplish its mission more effectively and efficiently, or the agreement
allows another agency or entity to benefit from the EPA's specialized resources or
expertise. Interagency agreements between federal agencies are to help both
agencies accomplish a shared objective and achieve efficiencies and economies
while doing business together. Interagency agreements are governed by applicable
statutory authorities, appropriations law principles, and guidance from the
U.S. Office of Management and Budget and the U.S. Department of the Treasury.
The EPA's agreement with the USACE, in relation to the CWPPRA, is a
"funds-in" or reimbursement agreement. The EPA's Interagency Agreement
Policies, Procedures, and Guidance Manual states that if the EPA is reimbursed
for its expenses in providing goods or services to another federal agency, then the
EPA is the "performing" agency. The EPA may provide the other agency
(ordering agency) the goods or services:
• Through EPA employees, using EPA equipment and supplies.
• Under an EPA-awarded procurement contract.
• Through award of a funds-out interagency agreement with a third party.
• Under a federal interagency agreement using a cooperation authority, by
funding a grant or cooperative agreement.
The ordering agency remains accountable for these activities to Congress, state
legislatures, or other governing bodies. Therefore, the EPA must be able to
provide information to the other agency regarding the use of funds.
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The EPA's total costs for performing a project under an interagency agreement
include direct and indirect costs. The EPA's direct costs are directly attributable
to the interagency agreement's scope of work. The EPA's indirect costs are not
directly attributable to the EPA's effort on funds-in interagency agreements and
must be charged to the other agency as provided in the EPA Directive 2540-
13.PI, Chapter 13, Agency Indirect Cost Allocation System. Indirect costs include
management and administrative support costs, headquarters allocation of
facilities and personnel compensation support costs to regions and program
offices, regional management and support costs, and program office support
costs. The EPA's Office of the Chief Financial Officer (OCFO) calculates and
disseminates indirect cost rates to charge to the work performed under
interagency agreements, and these indirect cost rates must be included in the
interagency agreements documentation to be able to recover such indirect costs.
Grants specialists and EPA project officers are responsible for the proper award
and administration of interagency agreements, and must ensure that interagency
agreements are not used to:
• Circumvent federal travel or personnel ceilings.
• Circumvent federal appropriations laws and principles.
• Support activities that are inconsistent with the purpose for which the
funds were appropriated, unless such alternate use is specifically provided
by statute.
Region 6 Used CWPPRA Funds for Other EPA Water Programs and
General Management Expenses
Region 6 WQPD spent CWPPRA funds totaling $780,793 for purposes that were
not in accordance with CWPPRA authority, appropriations law and principles,
and interagency agreements for CWPPRA work. The WQPD used CWPPRA
funds for other water programs that have goals and objectives related to the Gulf
of Mexico.
The WQPD management authorized the use of CWPPRA funds for contractors,
travel, payroll and training; and for expenses related to other EPA water
programs, such as the National Estuary Program, the Gulf of Mexico Program, the
Wetlands Protection Program and other regulatory activities. In addition, the
WQPD management used CWPPRA funds for EPA management needs and for
indirect costs such as administrative and support expenses, equipment, staffing
and supervisory training.
Region 6 was not authorized to charge indirect costs to the CWPPRA because
indirect cost rates were not included in interagency agreement documents.
Region 6 decision memorandums for FYs 2010 through 2013, which were used to
justify the use of CWPPRA planning funds, did not include language indicating
indirect costs were allowable. In fact, for FY 2012, Region 6 stated in its decision
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memo: "Indirect costs do not apply for CWPPRA agreements." Further, the
Office of General Counsel advised Region 6 that it may be appropriate to charge
indirect costs but only to project-related activities.
The Task Force allocated CWPPRA funds to Region 6 to plan coastal wetlands
restoration projects that the Task Force had approved for funding. Region 6
received CWPPRA funds to perform authorized planning tasks, such as attending
CWPPRA task force meetings, conducting wetland value assessments, conducting
CWPPRA program outreach activities, and planning tasks for authorized
CWPPRA priority project lists.9 However, the CWPPRA planning funds that the
Task Force approved and allocated to Region 6 did not provide funds for
equipment purchases or training expenses. A summary of the questioned costs
associated with CWPPRA funds from FY 2010 through June 30, 2013, appear in
Table 1.
Table 1: Overall summary of CWPPRA questioned costs
Spending purpose
Amount
Intern and an administrative support contractor
$440,762
Equipment and infrastructure
145,398
Travel
87,109
Training
40,039
Labor costs and monetary awards
36,778
Outreach overspending (2010 through 2012)
30,707
$780,793
Source: OIG analysis.
Region 6 Used CWPPRA Planning Funds to Pay an intern and an
Administrative Support Contractor
Region 6 spent CWPPRA funds totaling $440,762 to pay for the costs of an intern
and an administrative support contractor. The costs for the intern were $390,762
and the costs for the administrative support contractor were $50,000.
Region 6 entered into an interagency agreement in February 2008 with the DOE's
Oak Ridge Institute for Science and Education (ORISE) to obtain specialized
skills for research, project planning and management; and specialized skills for
EPA programs. The WQPD obligated and spent a total of $390,76210 of
CWPPRA planning funds to fund the interagency agreement with ORISE. The
WQPD's management paid the intern's stipend and related costs fully with
CWPPRA funds. However, the intern also said he worked on other water
programs besides the CWPPRA.
9 See Appendix C.
111 This amount represents the total amount of CWPPRA funds for the interagency agreement with the ORISE since
February 2008. Although the scope of our audit was from FY 2010 through June 30, 2013, during the audit we
identified improper spending related to the ORISE intern back to February 2008.
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The WQPD should have distributed the intern's costs consistently with the work
performed among the programs and projects. As of March 2014, the WQPD has
acknowledged that a portion of these costs should have been charged to other
water programs (e.g., ocean dumping). The WQPD's management and the
Region 6 Comptroller, under the Assistant Regional Administrator (ARA), are
coordinating with the EPA's OCFO to identify EPM funds that can be used to pay
back the US ACE for the charges.
During FYs 2012 and 2013, the WQPD used CWPPRA funds totaling $50,000 to
fund a cooperative agreement with the National Older Worker Career Center to
hire a Senior Environmental Employee. This person's duties were to provide
administrative support to the WQPD Marine and Coastal Section. The Task
Force-approved annual funds allocated to the EPA for planning did not provide
funds for indirect costs such as administrative staff expenses. Therefore, to fund
this position with CWPPRA funds was not appropriate.
Equipment and General EPA Infrastructure Purchases
The Region 6 WQPD used CWPPRA planning funds totaling $145,398 to
purchase computer equipment, fund information technology services, and buy
computer systems. According to the WQPD Marine and Coastal Section chief,
Region 6 recorded and labeled the property as EPA property in its records. The
Task Force did not authorize funds to purchase equipment and information
technology infrastructure.
The EPA's interagency agreements for CWPPRA work did not include an
allocation of funds to purchase equipment as required by EPA's Interagency
Agreement Policies, Procedures, and Guidance Manual. The USACE officials said
none of the other participating agencies of the Task Force have made a request to
use CWPPRA planning funds to purchase equipment such as computers or
computer systems. In addition, as previously stated, indirect costs do not apply to
CWPPRA work. The costs the WQPD incurred for equipment and infrastructure
did not make a direct contribution to carrying out the CWPPRA's purpose.
In FYs 2010 and 2011, the WQPD spent CWPPRA planning funds totaling
$120,000 for an interagency agreement with the U.S. Department of the Army to
develop, test and implement Region 6's Enterprise Content Management System.
The system is an electronic platform for managing the EPA's information
resources, including records. Region 6's implementation of the system was
impacted in FY 2009 because of periodic funding shortfalls, priority shifts in the
EPA's Office of Environmental Information, and evolving system requirements.
According to WQPD management, they justified the use of CWPPRA funds as an
indirect cost because they used CWPPRA documents for a pilot project to develop
and implement the regional electronic information management system. The
system is currently being used across the entire region and the EPA. The Task
Force did not approve the EPA to use CWPPRA funds for this EPA system.
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In FY 2011, the WQPD used $20,000 from the CWPPRA planning funds to fund
Region 6 information technology services, including data processing, email,
mobile devices, telephone services, and other computer systems. According to
WQPD managers, the total cost was to fund the information technology service
fee for five full-time-equivalent positions.
During 2010 and 2011, the WQPD used $5,398 from CWPPRA planning funds to
purchase computer equipment and related software. According to WQPD
management, CWPPRA program managers authorized the purchase of computer
equipment and infrastructure to facilitate online meetings and webinars with the
Louisiana Coastal Protection and Restoration Authority. A summary of
questioned costs associated with CWPPRA planning funds spent to purchase
equipment and information technology infrastructure appears in Table 2.
Table 2: Questioned costs on equipment and infrastructure
Description
Amount
Region 6 Enterprise Content Management System—
filing system for electronic records.
$120,000
Region 6 information technology agreement
for data processing services.
20,000
Computer equipment and related software.
5,398
Totals
$145,398
Source: OIG analysis.
Travel
The Region 6 WQPD spent CWPPRA funds totaling $87,109 for travel purposes
that were not in accordance with CWPPRA authority, appropriations law and
principles, and interagency agreements for CWPPRA work. The WQPD funded
travel with CWPPRA funds to perform work related to other EPA water
programs. Also, the WQPD spent CWPPRA funds to pay for travel to attend
training and perform work related to general EPA administration. Further, the
WQPD spent CWPPRA project funds and EPA funds to pay for travel to attend
the Task Force meetings, which are to be funded with CWPPRA planning funds.
Travel to Perform Work Related to Other EPA Water Programs
The Region 6 WQPD spent CWPPRA funds totaling $52,942 for travel to
perform work related to other EPA water programs, or to perform other
coastal restoration initiatives in the Gulf of Mexico that are authorized under
other laws. Some of the other EPA water programs or coastal restoration
initiatives have similar objectives as the CWPPRA program or may indirectly
contribute to CWPPRA's purpose, goals and objectives. However, the
CWPPRA does not authorize the use of funds for such purposes. As stated in
the CWPPRA legislation, the USACE shall allocate funds among task force
members in accordance with the priorities set forth in the CWPPRA's priority
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projects list of Louisiana coastal wetlands projects. Likewise, it is the EPA's
responsibility to use the funds for the act's intended purpose.11
For example, the WQPD Director traveled to Austin, Texas, to give a
presentation at a Deep Water Horizon Oil Spill workshop. The Director
acknowledged during our audit that he should not have used CWPPRA funds
to pay for that trip. In some instances, WQPD managers said that some trips
served multiple purposes and explained that because a trip was planned for
CWPPRA purposes the travel was conducted at no extra expense to the
CWPPRA program. However, the cost of the travel should have been
distributed among the program's funds instead of paying the full cost of the
travel with CWPPRA funds.
The EPA's appropriations provide funds to perform work related to other EPA
water programs and to other coastal restoration initiatives such as the National
Estuary Program, the Gulf of Mexico Program, the Wetlands Protection
Program and other regulatory activities. Further, other laws—such as the
Clean Water Act, the RESTORE Act or the Water Resources Development
Act—grant authority and provide funds for other programs and restoration
initiatives along the gulf coast.12 In contrast, during our discussions with
USACE officials, they said the USACE would not authorize the use of
CWPPRA funds to pay for other programs' activities. For example, according
to USACE officials, a USACE staff person attended the Barataria-Terrebonne
National Estuary Program meetings in the past but, unlike WQPD, did not use
CWPPRA funds to attend the meetings. A summary of questioned costs of
CWPPRA funds that the WQPD spent on travel to accomplish work on other
EPA water programs appears in Table 3.
Table 3: Questioned costs for travel for other EPA water programs
Travel purpose
Number of
trips
Amount
Gulf of Mexico Alliance meetings
11
$ 11,675
Gulf Coast Ecosystem Restoration Task Force meetings
13
10,161
Barataria-Terrebonne National Estuary Program meetings
11
9,374
Ocean Disposal Material Sites and beneficial uses
12
8,807
Other (Louisiana Comprehensive Plan and Urban Waters
Coordination)
11
5,845
Regulatory Activities (e.g., the National Environmental Policy Act
and the Clean Water Act, Section 402)
4
3,265
Hypoxia Task Force meetings
3
2,702
Deepwater Horizon Oil Spill (e.g., briefings and National Oceanic
and Atmospheric Administration scoping meeting)
2
1,113
Totals
67
$ 52,942
Source: OIG analysis.
11 EPA Directive 2520, Administrative Control of Appropriated Funds, dated February 4, 2008.
12 According to Region 6, to date neither the region nor EPA has received any funds from the RESTORE Act or the
Water Resources Development Act.
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Travel to Attend Training
The WQPD spent CWPPRA funds totaling $21,551 to pay for travel to attend
training in FYs 2011 and 2012. These training expenses were to maintain,
upgrade or update employees' technical skills to operate EPA programs and to
obtain or improve employees' skills to perform general management or staff
duties required for their positions within EPA. The EPA's annual
appropriations provide funds to train staff; however, neither the EPA's
CWPPRA interagency agreements nor the Task Force provided funds for
training.
For example, one WQPD staff member traveled to the Netherlands to attend a
Dutch water management training conference. The staff member told us that
the purpose for attending the Dutch water management training was to help
him find more efficient and effective ways to implement coastal restoration
projects and flood protection. While the employee obtained knowledge and
skills useful to multiple EPA water programs regarding coastal restoration and
flood protection, the training did not relate directly to CWPPRA planning or
project implementation. In addition, the staff member was not an EPA
representative on any of the Task Force committees, and he was not a
CWPPRA project manager for the EPA.
Region 6 management provided the OIG with a copy of the employee's
performance standards, which included metrics related to work in the
CWPPRA program. However, the employee reported only 23 labor hours
charged to the CWPPRA program during the period we audited (FY 2010
through June 30, 2013). Also, the employee did not report labor hours to the
CWPPRA program while attending the Dutch water management conference.
A summary of the questioned costs of CWPPRA funds that the WQPD spent
on travel to attend training appears in Table 4.
Table 4: Questioned costs for travel to attend training
Training type
Number of trips
Amount
Clean Water Act, Section 404
5
$6,508
National Environmental Policy Act
5
4,382
Engineering dredging courses
5
4,571
Supervisory training
3
3,873
Dutch water management training
1
2,057
Diversion workshop
1
160
Totals
20
$21,551
Source: OIG analysis.
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Travel for General EPA Management Activities
Region 6 WQPD used CWPPRA planning funds to travel and perform general
EPA managerial activities. Specifically, the WQPD spent CWPPRA funds
totaling $7,524 on activities to manage EPA programs and staff, including
staff recruiting, briefings to headquarters officials, and other general staff
management and administrative activities.
In FY 2010, two WQPD managers used CWPPRA funds to travel to
Louisiana to recruit an intern from the DOE's ORISE program. Also in
FY 2010, the WQPD's Director used CWPPRA funds to travel to
Washington, D.C., to meet with OCFO and the Office of Water. WQPD's
Director briefed OCFO and OW about Region 6 water programs, including
the CWPPRA program, and the allocation of resources to WQPD. In
FY 2011, two WQPD managers traveled to Louisiana to brief the EPA
Administrator and other officials on EPA water programs as well as the EPA's
role in coastal restoration in the Gulf of Mexico.
While WQPD managers presented information about the CWPPRA program,
the purpose of the trip was not specifically related to the CWPPRA program,
but instead about the EPA's overall work in the Gulf of Mexico and coastal
restoration. Hence, the costs should have been distributed among the
applicable programs. If WQPD management was unable to trace the costs to
specific programs or projects, then, by definition, the costs should have been
considered to be general WQPD administrative costs or indirect costs and
EPM funds should have been used. See Table 5 for a summary.
Table 5: Questioned costs for travel for EPA's general administration
Travel purpose
Number of
trips
Amount
General administrative purposes, including staff
management and supervisory activities.
5
$3,125
Briefings to the EPA Administrator about Louisiana coastal
restoration efforts, including the EPA's water programs and
projects in Louisiana.
2
2,316
Recruiting trip to Louisiana.
2
1,596
Meeting with OCFO and OW in Washington, D.C., to
discuss resource and staffing issues.
1
487
Totals
10
$7,524
Source: OIG analysis.
Travel to Attend CWPPRA Task Force Meetings Using CWPPRA
Project Funds and EPA Funds
Region 6 WQPD spent CWPPRA project funds and EPA's EPM funds
totaling $5,470 for travel to attend Task Force meetings and other planning
meetings. The CWPPRA planning budget allocated funds for Region 6 to
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attend general Task Force meetings, such as financial status meetings,
planning meetings and other related meetings concerned with the management
of the CWPPRA program.13 The WQPD should have used CWPPRA planning
funds to attend Task Force and CWPPRA planning meetings. The funds
allocated for CWPPRA projects provide travel funds for specific project
purposes, such as on-site inspections to monitor the status of a project being
constructed. A summary of project-specific and EPM funds spent on travel to
attend CWPPRA planning and Task Force meetings appears in Table 6.
Table 6: Questioned costs for travel for Task Force meetings paid with project
funds and EPA funds
Meeting
CWPPRA project fund
or EPA fund charged
Number
of trips
Amount
General CWPPRA planning
meetings
Bertrandville Siphon Project, Phase I
3
$1,705
Other CWPPRA meetings
with the USACE and the
Task Force
Bohemia Mississippi River
Reintroduction ($964) and
EPM funds ($378)
142
1,342
Financial Status of
CWPPRA funds
Enhancement of Barrier Island
Vegetative Demo
2
1,291
Task Force quarterly
meeting
Venice Ponds Marsh Creation and
Crevasses
1
788
General CWPPRA planning
meetings
Phase II, Construction of the Whiskey
Island Back Barrier Project
1
344
Totals
9
$5,470
Source: OIG analysis.
Region 6 Used CWPPRA Funds to Pay for Unauthorized Training
WQPD spent CWPPRA funds totaling $40,039 ($33,289 from planning and
$6,750 from project funds) for supervisory training and training related to work
for other EPA water programs. The training expenses paid with CWPPRA funds
were to maintain, upgrade or update technical skills to operate EPA's programs or
for general management. During FYs 2010 through 2013, the Task Force did not
authorize a training allowance to Region 6.15 Therefore, WQPD did not have
CWPPRA funds available for training purposes and should have paid for training
with EPM funds. For example, WQPD used $18,375 of CWPPRA funds in
FY 2010 to send its new Marine and Coastal Section chief to a general
supervisory training class presented by the Office of Personnel Management to
learn how to be a supervisor. USACE officials told us that they would not be
allowed to spend CWPPRA funds to pay for training and related expenses.
Table 7 below summarizes the questioned costs of CWPPRA funds that WQPD
spent on training.
13 See Appendix C.
14 One trip cost $756 and was split-funded between the Bohemia Mississippi River Reintroduction Project and EPM
funds ($378 to each fund source). For the second trip, the cost was $586 fully charged to the CWPPRA project.
15 See Appendix C.
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Table 7: Questioned costs on training courses
Training Type
Number of
courses
Amount
Supervisory
4
$24,255
Dredging engineering courses
5
6,750
National Environmental Policy Act
4
4,700
Dutch water management training
1
2,750
Other
3
1,584
Totals
17
$40,039
Source: OIG analysis.
Region 6 Did Not Record Labor Costs Consistently and Used
CWPPRA Funds for Monetary Awards
The Region 6 WQPD staff and managers did not charge labor time and costs to
the EPA's programs and projects consistently in accordance with the work
performed. We found inconsistencies between when travel costs were charged to
the CWPPRA program and the staffs time charges. In several instances, WQPD
managers and staff traveled using CWPPRA funds to pay for travel expenses;
however, they did not charge labor time to the CWPPRA program. Based on
reports we reviewed for personnel and compensation expenses, Marine and
Coastal section staff and management charged labor time and costs to the
CWPPRA program without regard to the actual work conducted.
During FYs 2010 through 2013, a staff person from the WQPD Planning and
Analysis Branch attended the State of the Coast Conference, the Restore America's
Estuaries Conference, the American Shore and Beach Preservation Conference, and
the Youth Summit Restoration Tree Planting in Louisiana. The WQPD paid the
travel expenses using CWPPRA planning funds, but time was never charged to the
CWPPRA program for the activities conducted during these trips.
The Associate Director of the WQPD's Ecosystems Protection Branch traveled to
attend meetings and funded at least 17 of these trips with CWPPRA planning
funds. However, the Associate Director did not charge time for these trips
consistently to the fund accounts she charged for her travel expenses. In
June 2012, for instance, the Associate Director traveled to attend the State of the
Coast Conference and used CWPPRA planning funds to pay for travel expenses.
However, the Associate Director charged time while attending the conference to a
specific CWPPRA project. Likewise, in June 2012 the Associate Director
attended a Deepwater Horizon Oil Spill meeting and used EPM funds to pay for
travel expenses. However, the Associate Director charged her time while
attending the meeting to a CWPPRA project. As a result, in FY 2012 the
Associate Director charged about $17,469 in questioned labor costs to Phase II of
the Construction of the Whiskey Island Back Barrier Project and $18,610 in
questioned labor costs to Phase I of the Bertrandville Siphon Project.
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Monetary Awards
The WQPD's management also authorized the use of CWPPRA planning funds to
give monetary awards to two employees. These two employees, whose
responsibilities were not within the CWPPRA program, were the only employees
who received monetary awards from CWPPRA funds during the period we
audited. The EPA personnel with responsibilities in the CWPPRA program, such
as CWPPRA project managers, did not receive any monetary awards from
CWPPRA funds during the period. Further, when we discussed these events with
USACE officials, they stated that the Task Force never approved an allowance for
monetary awards.
According to WQPD management, in FY 2010 a WQPD staff person assisted the
Marine and Coastal section with graphic design support for posters to be used for
a CWPPRA dedication ceremony. The WQPD program manager for the
CWPPRA granted the employee an On-the-Spot Award of $340 for her
assistance. Further, this employee did not charge her time to the CWPPRA
program while performing her graphic design support, which is not consistent
with labor charging for accountability purposes.
In FY 2011, the WQPD managers for the CWPPRA granted a $359 On-the-Spot
Award to a headquarters program analyst in Washington, D.C., who helped
Region 6 obtain National Environmental Policy Act contractor assistance. The
National Environmental Policy Act requires federal agencies to integrate
environmental values into their decision-making processes by considering the
environmental impacts of proposed actions and reasonable alternatives to those
actions. The WQPD's Marine and Coastal Section coordinates with other regional
organizations to grant funds to and comply with National Environmental Policy
Act requirements, which is a regulatory activity that is not authorized by the
CWPPRA. The program analyst did not charge time to the CWPPRA program
while providing support to Region 6.
Outreach Activities and Related Costs
The Task Force allocated outreach funds totaling $6,60016 to Region 6 to conduct
educational events about the CWPPRA program. These events included presenting
information at conferences about the CWPPRA program, attending Task Force
extracurricular activities, attending quarterly outreach committee meetings, and
attending any other meetings that attract media attention to the CWPPRA program.
During FYs 2010 through 2012, the WQPD exceeded each year's allocation for
CWPPRA outreach. In addition, in 2011 and 2012, the WQPD used CWPPRA
project funds to travel for outreach work. As previously mentioned, CWPPRA
project funds are to be used to design and construct specific, approved projects.
Therefore, CWPPRA project budgets do not provide an allowance for outreach work.
16 See Appendix C.
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Based on interviews with managers of the EPA's CWPPRA program, the travel
trips we identified served a CWPPRA outreach purpose to some extent. However,
the information provided during conferences, symposiums, meetings or briefings
was not specifically related to the CWPPRA program. Instead, the information
provided was about ocean and coastal programs, which include the CWPPRA
program. Therefore, the WQPD should have distributed the expenses evenly
among the applicable funds instead of charging the full cost of outreach activities
to the CWPPRA program.
In FY 2010, the WQPD exceeded its annual CWPPRA outreach funding by
$9,345. As summarized in Table 8 below, the WQPD spent $9,859 for travel
related to outreach work. Additionally, the WQPD spent another $6,086 in
conference fees and supplies to prepare posters for presentations. A summary of
the WQPD's 2010 outreach expenditures, including the calculation showing how
much Region 6 overspent, is shown in Table 8.
Table 8: Fiscal year 2010 CWPPRA outreach overspending
Description
Number
of trips
Amount
Travel
Workshops, conferences, briefings and
symposiums
10
$6,056
State of the Coast Conference
5
3,803
Total outreach travel spending
15
$9,859
Conference fees and supplies
State of the Coast Conference fees
5,200
Supplies for poster preparation
886
Total CWPPRA outreach spending
$15,945
EPA's CWPPRA outreach funding
(6,600)
CWPPRA outreach overspending
$9,345
Source: OIG analysis.
In FY 2011, the WQPD exceeded its annual CWPPRA outreach funding by
$13,808. The spending excess includes $702 that WQPD management funded
with CWPPRA project funds that were supposed to be spent on Phase II of the
East Marsh Island project. The WQPD management authorized the travel for one
staff member to attend the Restore America's Estuaries Conference, which was
funded with a combination of CWPPRA planning funds and CWPPRA project
funds. The Task Force's allocation for CWPPRA projects do not provide an
allowance for outreach. In addition, USACE officials stated that some of its staff
attended the Restore America's Estuaries Conference, the State of the Coast
Conference, and the Barataria-Terrebonne National Estuary Meetings but did not
use CWPPRA funds because the purposes of these types of conferences and
meetings fall under other legislation. A summary of the WQPD's outreach
expenditures for FY 2011, including the overspending calculation of the
CWPPRA outreach budget, appears in Table 9.
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Table 9: Fiscal year 2011 CWPPRA outreach overspending
Description
Number of
trips
Amount
Restore America's Estuaries Conference
9
$7,733
Wetlands Youth Summit
4
2,900
American Beach and Shore Preservation Association
2
1,714
Wastewater workshops
3
1,707
Other presentations or briefings
3
1,311
Total outreach travel spending
21
$15,365
Conference fees and supplies
Restore America's Estuaries Conference fees
4,475
Supplies for poster preparation
568
Total CWPPRA outreach spending
$20,408
EPA's CWPPRA outreach allocation
(6,600)
CWPPRA outreach overspending
$13,808
Source: OIG analysis.
In FY 2012, the WQPD exceeded its annual CWPPRA outreach funding by
$7,554. Similar to FY 2011, the spending excess includes $4,524 that WQPD
management funded with CWPPRA project funds. The WQPD's management
authorized travel funded with CWPPRA project funds to attend the State of the
Coast Conference, the Restore America's Conference and other trips related to
outreach purposes. As we stated before, the budgets allocated to CWPPRA
projects do not provide an allowance for outreach. A summary of the WQPD's
outreach expenditures for FY 2012, including the overspending calculation of
Region 6's CWPPRA outreach funds, appears in Table 10.
Table 10: Fiscal year 2012 CWPPRA outreach overspending
Description
Number of
trips
Amount
State of the Coast Conference
5
$5,303
Restore America's Estuaries Conference
2
2,630
Wetlands Youth Summit and Super Bowl Event
4
4,248
Other briefings, presentation and outreach meetings
1
973
Total outreach travel spending
12
$ 13,154
Conference fees and supplies
State of the Coast Conference fees
1,000
Total CWPPRA outreach spending
$ 14,154
EPA's CWPPRA outreach allocation
(6,600)
CWPPRA outreach overspending
$ 7,554
Source: OIG analysis.
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Region 6 Lacks Controls to Ensure Accountability and Proper
Stewardship of CWPPRA Resources
Federal employees are required to ensure that funds are used effectively and
efficiently, and that funds are used for the purposes for which the funds were
authorized. Therefore, the WQPD management should institute controls to ensure
the proper stewardship of resources. While specific line-item budgets are not
provided in the CWPPRA, the act is specific on its authority that the purpose of
CWPPRA funds is to:
• Plan and implement coastal wetlands restoration projects approved for
funding by the Task Force.
• Provide for the long-term conservation of wetlands and dependent fish and
wildlife populations in order of priority, based on the cost-effectiveness of
such projects in creating, restoring, protecting or enhancing coastal
wetlands.
Despite the requirements above, the Region 6 WQPD did not have adequate
controls in place to provide for proper accounting and management of CWPPRA
funds. According to the EPA's CWPPRA project officer, the WQPD's CWPPRA
program managers and project officer did not perform comparisons of actual
spending of CWPPRA planning funds with the authorized planning budget.
Further, they did not perform reconciliations to verify that WQPD used CWPPRA
planning funds in accordance with agreements with Task Force-approved budgets.
Likewise, the managers and the project officer did not perform verifications to
identify financial errors or misstatements, such as expenses inaccurately charged
to CWPPRA accounts.
For example, the WQPD CWPPRA project officer provided us with copies of the
documents she used to monitor and track CWPPRA funds. However, these
documents lacked sufficient details to identify misstatements, errors or inaccurate
charges to CWPPRA fund accounts. The project officer explained that she does
not monitor and track CWPPRA spending in detail because the US ACE does not
require the WQPD to provide such details during the billing process.
For instance, WQPD managers stated that the CWPPRA statute does not require
agencies that are members of the Task Force to implement a line-item budget for
individual partner agency expenditures, such as specific travel and training.
Therefore, WQPD managers and the CWPPRA project officer tracked and billed
CWPPRA spending at the summary level amount by CWPPRA expense accounts,
without regard to individual expenditures that make up the total amount. In
addition, the WQPD Director stated that in some instances, at the end of a fiscal
year, he made travel-funding decisions based on the availability of funds in
CWPPRA and EPM accounts.
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According to USACE officials, the Task Force votes on and approves annual
CWPPRA planning budgets, and the Task Force expects agencies to use the funds
to perform authorized planning tasks.17 During discussions with USACE officials,
the officials said they were concerned about how the WQPD was spending
CWPPRA funds and that the USACE would not be permitted to spend CWPPRA
funds as the EPA did.
Ineffective Management Communication With the Project Officer
Management at the WQPD did not communicate effectively with the WQPD's
CWPPRA project officer. The project officer said WQPD management did not
always consult with her concerning the CWPPRA decision-making process for
spending. In some instances, after the CWPPRA funds were spent, she learned
that management approved spending that she believed was not consistent with the
CWPPRA's purpose. Although EPA policy and procedures require the project
officer to ensure funds are spent only for authorized purposes and to request
appropriate accounting corrections, the project officer stated that she felt the
decision to correct such transactions was not hers to make.
Management Misconceptions
The WQPD's management has several misconceptions about CWPPRA authority
and funding. Management believes that they have the discretion to decide how to
use CWPPRA funds. For example, the WQPD managers believed that it was
allowable to use CWPPRA funds to support other coastal restoration initiatives in
the Gulf of Mexico, or to support other EPA water programs that had objectives
related to coastal restoration in the Gulf of Mexico. The WQPD managers also
told us that they had broad authority to spend CWPPRA funds under the Military
Interdepartmental Purchase Request (MIPR) provided by the USACE.
The MIPR is a financial instrument used to distribute CWPPRA funds to the
agency members of the Task Force and to process CWPPRA billings. However,
the MIPR does not provide a legal authority to spend CWPPRA funds. The
USACE did not require agencies to submit supporting documentation with
CWPPRA billings. Consequently, we believe the WQPD management
misunderstood the MIPR process as a broad authority to spend CWPPRA funds at
their discretion.
The WQPD management misconstrued that Region 6 was not required to comply
with the EPA's interagency agreement with USACE. The WQPD's CWPPRA
project officer said the interagency agreement for CWPPRA planning purposes is
a mere formality and a placeholder, because Region 6 does not perform any work
for the USACE but rather performs work for the Task Force. Further, the project
officer stated that CWPPRA planning funds are unique and different from other
funds and that CWPPRA program operations change constantly. Therefore, the
17 See Appendix C.
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project officer said the WQPD is unable to follow the CWPPRA planning budgets
included in the EPA's interagency agreements with the USACE and that the Task
Force approves.
Region 6 Overstated CWPPRA Costs and Augmented EPA's
Appropriations
During the period audited, the Region 6 WQPD mismanaged CWPPRA funds and
spent CWPPRA funds totaling $780,793 for purposes that were not consistent
with CWPPRA authority, appropriations law and principles, and CWPPRA
interagency agreements. As a result, the WQPD committed purpose violations in
accordance with 31 U.S.C. §1301 (a) and augmented the EPA's EPM
appropriation with CWPPRA funds. Because the WQPD spent CWPPRA funds
on other EPA water programs and other coastal restoration efforts, actual
CWPPRA program costs were significantly overstated (i.e., costs were actually
lower than the amounts spent by the WQPD from CWPPRA funds).
By not accounting for program costs accurately, Region 6 WQPD management
will not be able to identify the actual cost of managing the CWPPRA program and
some of its other water programs, which could result in making inaccurate future
budgeting decisions, wasting resources, and an increased risk of committing ADA
violations. In addition, the effectiveness of the CWPPRA program in achieving its
purposes could be impaired if WQPD management does not properly spend and
account for CWPPRA resources. The CWPPRA funds that are not used should be
returned to the Task Force to be used by other agencies, as needed, to accomplish
CWPPRA purposes. The Task Force has procedures in place for agencies to
return any unused funds. According to the USACE officials, there have been
instances when agencies have returned unused CWPPRA funds during a fiscal
year.
EPA Planned Corrective Actions
During the course of our audit, we informed Region 6 WQPD's management
about the mismanagement and improper spending of CWPPRA funds. Region 6
WQPD's management stated that they plan to return to the Task Force some of
the CWPPRA funds spent for other EPA programs. Also, according to the
WQPD's Deputy Director, the division has changed its internal processes to avoid
using CWPPRA funds for other EPA programs such as ocean dredging and
material disposal sites, and for hypoxia in the Gulf of Mexico. However, we have
not verified these changes to WQPD's internal processes.
Conclusion
There are many coastal restoration initiatives taking place in Louisiana, including
national estuary programs for ecosystems protection and restoration. These other
initiatives are authorized by several statutes that address different coastal issues, such
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as oil spills, waterways and levees, ecosystems restoration, and hypoxia, among
others. The EPA receives appropriated funds from Congress to perform work for the
National Estuary Program, the Gulf of Mexico, the National Environmental Policy
Act, Superfund, Oil Spill, and the Clean Water Act. According to appropriations law
and principles, the EPA's appropriated funds should be used to fund work for other
water programs, including other coastal restoration programs, because these
activities are provided for with EPA appropriations.
The Region 6 WQPD should take immediate corrective actions to ensure the
proper stewardship of CWPPRA funds in accordance with laws, policies and
regulations. The use of funds for purposes other than those for which the funds
were appropriated constitutes a purpose violation in accordance with 31 U.S.C.
§ 1301(a). Implementing adequate internal controls for the management of the
CWPPRA program will reduce the opportunities to misspend CWPPRA
resources. Likewise, the WQPD management should better support the role of the
project officer, and the project officer should take a more active role in reviewing
and questioning costs. By using CWPPRA funds only for the purpose for which
the funds were authorized, Region 6 would accomplish CWPPRA program
objectives more effectively, and the region would be able to identify how much
the program costs them to implement.
To assess the appropriateness of Region 6's actual spending of CWPPRA funds,
Task Force procedures and CWPPRA interagency agreements must be
considered, and the extent to which the EPA followed or deviated from those
procedures and agreements. Based on information in this report, it is clear the
WQPD's management did not reasonably manage CWPPRA funds consistent
with the specific approval of the Task Force and its procedures or CWPPRA
interagency agreements.
Recommendations
We recommend that the Region 6 Regional Administrator:
1. Reimburse the Task Force (through the USACE) questioned costs of
$780,793, unless Region 6 WQPD management provides sufficient and
appropriate documentation to demonstrate that questioned costs paid with
CWPPRA funds were incurred in accordance with CWPPRA,
appropriations law and principles, and interagency agreements.
2. Direct the Region 6 ARA to work with the OCFO to perform an internal
review of the WQPD's CWPPRA spending at the end of FY 2014 to
identify improper expenditures that occurred in 2008 and 2009, as well as
from July 1, 2013, through September 30, 2014. Reimburse the Task
Force (through the USACE) any questioned costs identified during this
review.
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3. Identify and address any ADA violations resulting from questioned costs
identified in this report or found by the Region 6 ARA's review, and
report any violations in accordance with the ADA and EPA
Directive 2520.
4. Direct the WQPD to establish control activities for the CWPPRA program
(e.g., verifications, comparisons and reconciliations of CWPPRA spending
with Task Force-approved CWPPRA budgets) to ensure proper
stewardship and accounting of CWPPRA resources.
5. Take administrative disciplinary actions, in accordance with EPA
Directive 2520, against EPA employees responsible for purpose violations
or ADA violations related to improper CWPPRA spending.
6. Provide training to WQPD managers and staff who work on CWPPRA
activities about what constitutes a purpose violation, including the
potential for ADA violations.
Agency Comments and OIG Evaluation
Region 6 did not concur with Recommendation 1 and proposed an alternative
approach. Region 6 proposed that the Region 6 ARA and the OCFO perform a
review of the $780,793 in questioned costs to determine what amount they deem
appropriate to reimburse the US ACE. Region 6's proposed corrective action is not
responsive to our recommendation. The Region 6 ARA and the OCFO should
provide the OIG with sufficient and appropriate support for the questioned costs.
The agency and the OIG should work together to reach resolution on corrective
actions related to the questioned costs.
Region 6 concurred with Recommendation 2. Region 6 and the OCFO will
perform an internal review of the WQPD's CWPPRA spending at the end of
FY 2014 to identify improper expenditures that occurred in 2008 and 2009, as
well as July 1, 2013, through September 30, 2014. Region 6 plans to complete this
recommendation no later than March 2016. For clarity, in this final report, we
added to this recommendation that Region 6 should also reimburse the Task Force
(through the USACE) any questioned costs identified during this future review.
Region 6 did not concur with Recommendation 3. Region 6 said they consulted
with the OCFO and they feel confident the EPA would have enough funds to
make the accounting corrections and reimburse the USACE for CWPPRA
questioned costs. However, we do not have reasonable assurance that EPA would
have funds to reimburse the Task Force without committing ADA violations. In
addition, EPA has not completed the internal review for FY 2008, 2009 and the
last quarter of FY 2014 to identify improper spending of CWPPRA funds. The
amount of questioned costs that may result from the internal review is also
uncertain.
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Region 6 concurred with Recommendation 4. WQPD management said they
began the implementation of control activities for the management of CWPPRA
funds and that they plan to complete this recommendation no later than
March 2015.
Region 6 did not concur with Recommendation 5. Region 6 said they are
confident that no ADA violations occurred and that the OIG should delete this
recommendation. As we stated above, the OIG does not have any reasonable
assurance that ADA violations would not result from accounting corrections to fix
appropriations law purpose violations and to return the funds to the Task Force.
Further, employees responsible for committing appropriations law purpose
violations are also subject to disciplinary actions as stated in EPA Directive 2520.
While it is still uncertain whether ADA violations occurred, WQPD management
committed appropriations law purpose violations.
Region 6 concurred with Recommendation 6. Region 6 stated that the OCFO
provided federal budget and appropriations law training in August 2014, and that
the training included ADA violations and related implications. Region 6 planned
to complete this recommendation no later than August 2014; however, not all
management and staff working in the CWPPRA program have taken the training.
We consider Recommendations 1, 3 and 5 unresolved pending receipt of
responsive corrective actions and the dates corrective actions will be completed.
We agree with the EPA's corrective action for Recommendations 2 and 4 and
consider the recommendations open with corrective action pending. We consider
Recommendation 6 unresolved pending receipt of intended corrective action and a
completion date for training all staff.
Region 6 also provided corrections they suggested be made to the draft audit
report. We included those suggested corrections, and how we addressed them, in
Appendix D. Region 6 also provided an attachment with extensive technical
comments, which was a copy of information given to us in March 2014 after the
region reviewed our discussion document. We reviewed and evaluated those
technical comments and made appropriate revisions in the draft report.
Overall, Region 6's explanations for the use of CWPPRA funds were not
responsive; not supported with sufficient and appropriate evidence; not consistent
with laws, policies, and agreements; and contradictory to official documentation
and prior statements they made to the OIG. Since we considered those comments
before issuing the draft report, we did not make any additional changes in the
final report. Because of the number of pages in the attachment, we have not
included them in this report. Instead, we included those comments as a separate
attachment posted alongside the final report on the OIG's website.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
No.
Subject
Status1
Action Official
Planned
Completion
Date
Claimed
Amount
Ag reed-To
Amount
26 Reimburse the Task Force (through the USACE)
questioned costs of $780,793, unless Region 6
WQPD management provides sufficient and
appropriate documentation to demonstrate that
questioned costs paid with CWPPRA funds were
incurred in accordance with CWPPRA,
appropriations laws and principles, and interagency
agreements.
26 Direct the Region 6 ARA to work with the OCFO to
perform an internal review of the WQPD's
CWPPRA spending at the end of FY 2014 to
identify improper expenditures that occurred in
2008 and 2009, as well as from July 1, 2013,
through September 30, 2014. Reimburse the Task
Force (through the USACE) any questioned costs
identified during this review.
27 Identify and address any ADA violations resulting
from questioned costs identified in this report or
found by the Region 6 ARA's review, and report
any violations in accordance with the ADA and
EPA Directive 2520.
Region 6
Regional Administrator
3/31/2016
$780.8
Region 6
Regional Administrator
3/31/2016
Region 6
Regional Administrator
27 Direct the WQPD to establish control activities for
the CWPPRA program (e.g., verifications,
comparisons and reconciliations of CWPPRA
spending with Task Force-approved CWPPRA
budgets) to ensure proper stewardship and
accounting of CWPPRA resources.
27 Take administrative disciplinary actions, in
accordance with EPA Directive 2520, against EPA
employees responsible for purpose violations or
ADA violations related to improper CWPPRA
spending.
27 Provide training to WQPD managers and staff who
work on CWPPRA activities about what constitutes
a purpose violation, including the potential for ADA
violations.
Region 6
Regional Administrator
Region 6
Regional Administrator
Region 6
Regional Administrator
3/31/2015
O = Recommendation is open with agreed-to corrective actions pending.
C = Recommendation is closed with all agreed-to actions completed.
U = Recommendation is unresolved with resolution efforts in progress.
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Appendix A
Details on Scope and Methodology
During our audit, we reviewed:
• Coastal Wetlands Planning, Protection and Restoration Act, Public Law 101-646,
Title III, November 29, 1990.
• CWPPRA Project Standard Operating Procedures Manual, Revision 22, dated
November 9, 2012.
• EPA, OCFO, EPA Directive 2520, U.S. EPA 's Administrative Control of Appropriated
Funds, Release 3.2, February 4, 2008.
• EPA, OCFO, EPA Directive 2550 B, Travel Manual, November 14, 1995.
• EPA, OCFO, EPA Directive 2550C-04-P1, Procedure 1, Financial Management of
Selected Administrative Areas Interagency Agreements, July 11, 2012.
• Memorandums of Agreement between the US ACE, EPA and the LDNR.
• Interagency agreements between the US ACE and EPA for active CWPPRA projects and
for CWPPRA annual planning budgets.
• Interagency agreements between the EPA and the DOE for the ORISE interns.
• CWPPRA meeting minutes and planning meeting dates.
• Compass Data Warehouse, financial data and supporting documentation, including travel
vouchers and budget spending details.
• The hotline complaint and supporting documentation we received from the complainant.
During our audit, we interviewed the WQPD Director, three other managers, 12 staff, and the
Deputy Regional Counsel. We also interviewed three USACE officials from the New Orleans
District office in Louisiana, who manage the CWPPRA program for their agency. We performed
spending analyses on the WQPD's financial expenditures and data. We reviewed and compared
budget data from the Task Force, WQPD's interagency agreements for CWPPRA, and WQPD's
EPM budgets. We assessed the controls in place for travel and the monitoring of CWPPRA
funds. In addition, we compared purpose and destination data from travel vouchers to CWPPRA
purpose and planning meeting dates to determine validity of the travel. We also consulted with
our OIG Office of Counsel regarding legal issues related to the misuse of CWPPRA funds.
The time period covered by our audit was October 1, 2009, through June 30, 2013, and our
primary focus was on the use of CWPPRA planning funds. We performed work at the Region 6
office where our OIG office is co-located.
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Appendix B
CWPPRA Excerpts
I. CWPPRA Legislation
Excerpt from Public Law 101-646, November 29, 1990, Coastal Wetlands Planning, Protection
and Restoration Act, Title III, Sections 302, 303(a), 303(e), and 306.
Sec. 302. DEFINITIONS.
As used in this title, the term—
(1) "Secretary" means the Secretary of the Army;
(2) "Administrator" means the Administrator of the Environmental Protection Agency;
(3) "development activities" means any activity, including the discharge of dredged or fill
material, which results directly in a more than de minimus change in the hydrologic regime,
bottom contour, or the type, distribution or diversity of hydrophytic vegetation, or which impairs
the flow, reach, or circulation of surface water within wetlands or other waters;
(4) "State" means the State of Louisiana;
(5) "coastal State" means a State of the United States in, or bordering on, the Atlantic,
Pacific, or Arctic Ocean, the Gulf of Mexico, Long Island Sound, or one or more of the Great
Lakes; for the purposes of this title, the term also includes Puerto Rico, the Virgin Islands,
Guam, the Commonwealth of the Northern Mariana Islands, and the Trust Territories of the
Pacific Islands, and American Samoa;
(6) "coastal wetlands restoration project" means any technically feasible activity to
create, restore, protect, or enhance coastal wetlands through sediment and freshwater diversion,
water management, or other measures that the Task Force finds will significantly contribute to
the long-term restoration or protection of the physical, chemical and biological integrity of
coastal wetlands in the State of Louisiana, and includes any such activity authorized under this
title or under any other provision of law, including, but not limited to, new projects, completion
or expansion of existing or on-going projects, individual phases, portions, or components of
projects and operation, maintenance and rehabilitation of completed projects; the primary
purpose of a "coastal wetlands restoration project" shall not be to provide navigation, irrigation
or flood control benefits;
(7) "coastal wetlands conservation project" means—
(A) the obtaining of a real property interest in coastal lands or waters, if the obtaining of
such interest is subject to terms and conditions that will ensure that the real property will be
administered for the long-term conservation of such lands and waters and the hydrology, water
quality and fish and wildlife dependent thereon; and
(B) the restoration, management, or enhancement of coastal wetlands ecosystems if such
restoration, management, or enhancement is conducted on coastal lands and waters that are
administered for the long-term conservation of such lands and waters and the hydrology, water
quality and fish and wildlife dependent thereon;
(8) "Governor" means the Governor of Louisiana;
(9) "Task Force" means the Louisiana Coastal Wetlands Conservation and Restoration
Task Force which shall consist of the Secretary, who shall serve as chairman, the Administrator,
the Governor, the Secretary of the Interior, the Secretary of Agriculture and the Secretary of
Commerce; and
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(10) "Director" means the Director of the United States Fish and Wildlife Service.
SEC. 303. PRIORITY LOUISIANA COASTAL WETLANDS RESTORATION PROJECTS,
(a) PRIORITY PROJECT LIST—
(1) PREPARATION OF LIST.—Within forty-five days after the date of enactment of this
title, the Secretary shall convene the Task Force to initiate a process to identify and prepare a list
of coastal wetlands restoration projects in Louisiana to provide for the long-term conservation of
such wetlands and dependent fish and wildlife populations in order of priority, based on the cost-
effectiveness of such projects in creating, restoring, protecting, or enhancing coastal wetlands,
taking into account the quality of such coastal wetlands, with due allowance for small-scale
projects necessary to demonstrate the use of new techniques or materials for coastal wetlands
restoration.
(2) TASK FORCE PROCEDURES.—The Secretary shall convene meetings of the Task
Force as appropriate to ensure that the list is produced and transmitted annually to the Congress
as required by this subsection. If necessary to ensure transmittal of the list on a timely basis, the
Task Force shall produce the list by a majority vote of those Task Force members who are
present and voting; except that no coastal wetlands restoration project shall be placed on the list
without the concurrence of the lead Task Force member that the project is cost effective and
sound from an engineering perspective. Those projects which potentially impact navigation or
flood control on the lower Mississippi River System shall be constructed consistent with section
304 of this Act.
(3) TRANSMITTAL OF LIST.—No later than one year after the date of enactment of this
title, the Secretary shall transmit to the Congress the list of priority coastal wetlands restoration
projects required by paragraph (1) of this subsection. Thereafter, the list shall be updated
annually by the Task Force members and transmitted by the Secretary to the Congress as part of
the President's annual budget submission. Annual transmittals of the list to the Congress shall
include a status report on each project and a statement from the Secretary of the Treasury
indicating the amounts available for expenditure to carry out this title.
(4) LIST OF CONTENTS.-
(A) AREA IDENTIFICATION; PROJECT DESCRIPTION—The list of priority
coastal wetlands restoration projects shall include, but not be limited to—
(i) identification, by map or other means, of the coastal area to be covered by the
coastal wetlands restoration project; and
(ii) a detailed description of each proposed coastal wetlands restoration project
including a justification for including such project on the list, the proposed activities to be
carried out pursuant to each coastal wetlands restoration project, the benefits to be
realized by such project, the identification of the lead Task Force member to undertake
each proposed coastal wetlands restoration project and the responsibilities of each other
participating Task Force member, an estimated timetable for the completion of each
coastal wetlands restoration project, and the estimated cost of each project.
(B) PRE-PLAN.—Prior to the date on which the plan required by subsection (b) of
this section becomes effective, such list shall include only those coastal wetlands
restoration projects that can be substantially completed during a five-year period
commencing on the date the project is placed on the list.
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(C) Subsequent to the date on which the plan required by subsection (b) of this
section becomes effective, such list shall include only those coastal wetlands restoration
projects that have been identified in such plan.
(5) FUNDING—The Secretary shall, with the funds made available in accordance with
section 306 of this title, allocate funds among the members of the Task Force based on the need
for such funds and such other factors as the Task Force deems appropriate to carry out the
purposes of this subsection.
(e) FUNDING OF WETLANDS RESTORATION PROJECTS.--The Secretary shall, with the
funds made available in accordance with this title, allocate such funds among the members of the
Task Force to carry out coastal wetlands restoration projects in accordance with the priorities set
forth in the list transmitted in accordance with this section. The Secretary shall not fund a coastal
wetlands restoration project unless that project is subject to such terms and conditions as
necessary to ensure that wetlands restored, enhanced or managed through that project will be
administered for the long-term conservation of such lands and waters and dependent fish and
wildlife populations.
SEC. 306. DISTRIBUTION OF APPROPRIATIONS.
(a) PRIORITY PROJECT AND CONSERVATION PLANNING EXPENDITURES.-Of the
total amount appropriated during a given fiscal year to carry out this title, 70 percent, not to
exceed $70,000,000, shall be available, and shall remain available until expended, for the
purposes of making expenditures—
(1) not to exceed the aggregate amount of $5,000,000 annually to assist the Task Force in
the preparation of the list required under this title and the plan required under this title, including
preparation of—
(A) preliminary assessments;
(B) general or site-specific inventories;
(C) reconnaissance, engineering or other studies;
(D) preliminary design work; and
(E) such other studies as may be necessary to identify and evaluate the feasibility
of coastal wetlands restoration projects;
(2) to carry out coastal wetlands restoration projects in accordance with the priorities set
forth on the list prepared under this title;
(3) to carry out wetlands restoration projects in accordance with the priorities set forth in
the restoration plan prepared under this title;
(4) to make grants not to exceed $2,500,000 annually or $10,000,000 in total, to assist the
agency designated by the State in development of the Coastal Wetlands Conservation Plan
pursuant to this title.
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Appendix C
EPA's Portion of Task Force-Approved
CWPPRA Planning Budgets and Funds by Task
for FYs 2010 Through 201318
TASK
Duration (FY10 dates)
EPA
Task Category
Task
No.
Description
Start Date
End Date
FY10
FY11
FY12
FY13
Prior Year PPL TASKS
PL
19485
P&E holds 2 Public Meetings
11/17/09
11/18/09
$ 2.227
$ 2.227
$ 2.227
$ 1.548
PL
19490
TC Recommendation for Project
Selection and Funding
12/02/09
12/02/09
2.284
2.284
2.284
2.952
PL
19600
TF Selection and Funding of the 19th
PPL (1 meeting)
01/21/10
01/21/10
3.051
3.051
3.051
4.632
FY Subtotal Prior Year PPL Tasks
S 7,562
S 7,562
S 7,562
S 9,132
Current Year PPL TASKS
PL
20200
Development and Nomination of Projects
PL
20220
Sponsoring agencies prepare fact sheets
(for projects and demos) and maps
prior to and following RPT nomination
meetings.
10/13/09
02/15/10
34.297
34.297
34.297
36.520
PL
20230
RPT's meet to formulate and combine
projects.
01/26/10
01/28/10
6.679
6.679
6.679
8.928
PL
20240
Face-to-Face RPT Voting meeting (20
nominees and up to 6 demos) or
Alternate for 2010
02/17/10
02/17/10
478
478
478
PL
20300
Ranking of Nominated Projects
PL
20320
Engr Work Group prepares preliminary
fiilly firnded cost ranges for nominees.
03/05/10
03/20/10
4.079
4.079
4.079
4.928
PL
20330
Environ/Engr Work Groups review
Nominees
04/02/10
04/03/10
3.153
3.153
3.153
3.952
PL
20340
WGs develop and P&E distributes
project Matrix
04/01/10
04/01/10
2.834
2.834
2.834
3.520
PL
20350
TC selection of PPL 20 candidates (10)
and demo candidates (up to 3)
04/15/10
04/15/10
3.268
3.268
3.268
3.916
PL
20400
Analysis of Candidates
PL
20410
Sponsoring agencies coordinate site
visits for all projects
05/01/10
07/15/10
31.899
31.899
31.899
35.244
PL
20420
Engr/Environ Work Group refine project
features and determine boundaries
05/01/10
09/30/10
5.179
5.179
5.179
5.904
PL
20430
Sponsoring agencies develop project
information for WVA; develop designs
and cost estimates (projects and
05/01/10
09/30/10
39.598
39.598
39.598
40.684
PL
20440
Environ/Engr Work Groups project
wetland benefits (with WVA)
05/01/10
09/30/10
16.947
16.947
16.947
18.464
PL
20450
Engr Work Group reviews/approves
Ph 1 and Ph 2 cost estimates from
sponsoring agencies, incl cost
estimates for demos
05/01/10
09/30/10
9.961
9.961
9.961
11.408
PL
20480
Prepare project information packages for
P&E.
05/01/10
11/10/10
1.968
1.968
1.968
1.968
FY Subtotal Current Year PPL Tasks
S 160,340
S 160,340
S 160,340
S 175,436
18 Information provided by the USACE's CWPPRA Senior Program Manager and the CWPPRA project administrator and accountant.
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Project and Program Management Tasks
PM
20100
Program Management—Coordination
10/01/09
09/30/10
$ 102,386
$ 102,386
$ 102,386
$ 105,422
PM
20110
Program Management—Correspondence
10/01/09
09/30/10
34,153
34,153
34,153
34,154
PM
20120
Prog Mgmt—Budget Development and
Oversight
10/01/09
09/30/10
111,134
111,134
111,134
111,134
PM
20200
P&E Meetings (3 meetings preparation
and attendance)
10/01/09
09/30/10
9,458
9,458
9,458
11,616
PM
20210
Tech Com Mtngs (4 mtngs including
three public and one off-site; prep and
attend)
10/01/09
09/30/10
10,445
10,445
10,445
12,352
PM
20220
Task Force Mtngs (4 mtngs, including
three public and one executive session;
prep and attend)
10/01/09
09/30/10
18,124
18,124
18,124
20,528
PM
20400
Agency Participation, Review 30%
and 95% Design for Phase 1 Projects
10/01/09
09/30/10
12,758
12,758
12,758
14,784
PM
20410
Engineering & Environmental Work
Groups review Phase II funding of
approved Phase I projects (Needed
for adequate review of Phase I.)
[Assume 8 projects requesting Ph II
funding in FY09. Assume 3 will
require Eng or Env WG review, 2
labor days for each.]
10/01/09
09/30/10
3,937
3,937
3,937
3,937
PM
20600
Miscellaneous Technical Support
10/01/09
09/30/10
35,000
35,000
35,000
35,000
FY Subtotal Project Management Tasks
337,395
337,395
337,395
348,927
FY Total for PPL Tasks
S 505,297
S 505,297
S 505,297
S 533,495
SUPPLEMENTAL PLANNING AND EVALUATION TASKS
SPE
20700
Workshop to review selected projects to
aid in transferring lessons learned from
design to implementation stage - FY10.
Prepare 2012 Evaluation Report (Report
to Congress) - FY12
10/01/09
09/30/10
6,500
3,270
FY10 Total Supplemental Planning & Evaluation Tasks
6,500
_
3,270
_
FY Agency Tasks Grand Total
S 511,797
S 505,297
S 508,567
S 533,495
Otrch
20200
Outreach - Agency
10/01/09
09/30/10
6,600
6,600
6,600
6,600
FY Total Outreach
6,600
6,600
6,600
6,600
FY Grand Total
$ 518,397
$ 511,897
$ 515,167
$ 540,095
Appendix C - Abbreviations
Engr
Engineering
Env
Environmental
P&E
Planning and evaluation
PL
Project list
PM
Project management
RPT
Regional planning team
SPE
Supplemental planning and evaluation
TC
Technical committee
TF
Task Force
WG
Work group
WVA
Wetland value assessment
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Agency Response
Appendix D
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft "EPA Region 6 Mismanaged Coastal
Wetlands Planning, Protection and Restoration Act Funds," dated July 2, 2014
FROM : Ron Curry /s/
Regional Administrator
TO: Arthur A. Elkins, Jr.
Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the Coastal Wetlands
Planning, Protection and Restoration Act draft audit report. I appreciate you bringing these issues to our
attention and the extensive work of your staff. This will help us correct mischarged expenditures and
design more efficient and effective future processes for Region 6 administration of the CWPPRA
program.
My staff has reached out to the Office of the Chief Financial Officer and the Office of Administration
and Resources Management - Office of Grants and Debarment to design CWPPRA processes that will
meet two goals you described in the "At a Glance" portion of the draft report:
• ensure resources are used efficiently and effectively and that public funds are used for the
purpose for which they were appropriated and authorized
• establish contract activities to ensure proper stewardship and accounting of CWPPRA
resources
With the national financial offices and Interagency Agreement Service Center staff, we are developing
high-level corrective actions that will ensure appropriate future use of funds. I also wanted to note that
OCFO Office of Budget already provided the financial training that you recommended.
GENERAL COMMENTS
Region 6 appreciates the mission of the Office of Inspector General to promote economy, efficiency,
effectiveness, and to prevent and detect fraud, waste, and abuse. Region 6 agrees with the OIG that
controls should be put in place to ensure proper stewardship and accounting of CWPPRA resources.
Region 6 has already implemented additional controls to include procedures for more accurate
CWPPRA payroll and travel charging, conducting periodic CWPPRA budget review meetings with the
Water Quality Protection Division's management and the Comptroller's office, and ensuring that the
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project officer for the CWPPRA IA receives the necessary paperwork for cost comparison against bills to
confirm accuracy. The region has established control activities such as verification, comparison, and
reconciliation of CWPPRA funds to ensure proper stewardship and correct spending of CWPPRA
resources.
The OIG position is that the Water Quality Protection Division used CWPPRA funds to cover costs which
were not directly related to the CWPPRA program. Region 6 is confident that the vast majority of the
OIG questioned costs of $780,793 of CWPPRA funds were allowable direct costs needed to carry out our
approved task force activities, and were consistent with the CWPPRA statute, appropriations law and
principles, and the EPA's interagency agreement guidance.
The Federal Accounting Standard Advisory Board Statement of Federal Financial Accounting Standard
No. 4, Managerial Cost Accounting Standards and Concepts (attached), identifies direct costs as costs that
directly support an activity and are specifically identified with an output. All direct costs should be
included in the full cost of outputs. Typical direct costs in the production of an output include:
1) salaries and other benefits for employees who work directly on the output; 2) materials and supplies
used in the work; 3) various costs associated with office space, equipment, facilities, and utilities that are
used exclusively to produce the output; and 4) costs of goods or services received from other segments or
entities that are used to produce the output. We provided extensive documentation in support of direct
costs in our March 3, 2014, response to the preliminary discussion document on the use of CWPPRA
funds (attached.)
In coordination with the OCFO, Region 6 will review the questioned costs in your draft report and
determine which costs were improperly charged to CWPPRA. If reimbursement is required for some
portion of the questioned costs, the OCFO has confirmed that sufficient Environmental Program
Management funds are available to cover any expenditures where CWPPRA was incorrectly charged.
Region 6's preliminary review of the OIG's questioned costs while preparing a response to the
preliminary discussion document identified less than $50,000 (rather than $780,793) that may have been
incorrectly charged to CWPPRA. Consistent with discussions we have had with OIG staff since the draft
report was issued, we have provided alternative wording for Recommendation #1 in the attached table.
CWPPRA is a unique program in that the monies received from the US Army Corps of Engineers are for
the purpose of performing work required of the EPA by the CWPPRA statute. The EPA does not perform
work or provide a service to the US ACE, but rather works with other task force members on
implementing activities approved by the task force. In addition, as noted by the OIG on page 8, the
CWPPRA Task Force Project Standard Operating Procedures Manual, dated November 9, 2012, states
that the EPA is responsible for ensuring funds are spent in accordance with CWPPRA. Following this
logic, the USACE has never disputed any CWPPRA expenditures submitted by the EPA nor directed the
EPA in any way to change its spending practices.
We will work with the USACE and other task force members to clarify the procedures, processes, and
rationale for CWPPRA expenditures. This will include reviewing specific budget language in the Military
Interdepartmental Purchase Request, possibly amending current and prior I As, or coming to an agreement
with the task force on the appropriate use of indirect costs (which the USACE charges to the EPA in other
cases). Region 6 will work with the OCFO, Office of General Counsel and OARM-OGD to re-evaluate
whether an indirect cost rate for the CWPPRA IA is appropriate.
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Region 6 is confident that that no CWPPRA Anti-deficiency Act violations have occurred to date, and we
will take action to ensure that none occur in the future. In each year of the audit scope, the agency had
sufficient EPM funds to cover the questioned costs, and presently has sufficient EPM funds available to
correct the questioned expenditures, if needed. Therefore, we request that the OIG delete
Recommendations #3 and #5 in the final report.
The Region 6 Office of the Comptroller will work with the OCFO to review CWPPRA spending for fiscal
years 2008, 2009, and July 1, 2013, through September 30, 2014, to identify any further questionable
expenditures. As needed, Region 6 will correct all questionable costs.
CONTACT INFORMATION
If you have any questions regarding this response, please contact Mr. William Honker, Director of the
Region 6 Water Quality Protection Division, at (214) 665-3187, Mr. David Garcia, Deputy Director of the
Water Quality Protection Division, at (214) 665-7593, Mr. James McDonald, Senior Resource Officer, at
(214) 665-3150, or Ms. Regina Milbeck, Comptroller, at (214) 665-6540.
Attachments
1. Agency's Response to Report Recommendations
2. Corrections to the Draft Audit Report
3. Excerpts from The Federal Accounting Standard Advisory Board (FASAB) Statement of Federal
Financial Accounting Standard No. 4, Managerial Cost Accounting Standards and Concepts (SFFAS
4)
4. Response to Document titled EPA Region 6 Mismanaged and Misspent Coastal Wetlands Planning,
Protection and Restoration Act Funds w/appendices
cc: Mr. Patrick Gilbride
Office of Inspector General, U.S. Environmental Protection Agency
Mr. Randy Holthaus
Region 6 Inspector General, U.S. Environmental Protection Agency
Mr. James McDonald
Region 6 Assistant Regional Administrator, U.S. Environmental Protection Agency
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ATTACHMENT
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Intended
Corrective Action(s)
Estimated
Completion by
Quarter and FY
2
Direct the Region 6 Office of Regional
Comptroller to perform an internal
review of the WQPD's CWPPRA
spending to identify questionable
expenditures that occurred in 2008 and
2009, as well as July 1, 2013, through
September 30, 2014.
Region 6 WQPD and Office
of the Comptroller will
work with OCFO staff to
review CWPPRA spending
for fiscal years 2008, 2009,
and July 1, 2013, through
September 30, 2014 to
identify questionable
expenditures. Based on this
review, questionable
charges will be corrected.
March 2016
4
Direct the WQPD to establish control
activities for the CWPPRA program
(e.g., verifications, comparisons and
reconciliations of CWPPRA spending
with Task Force-approved authorized
CWPPRA budgets) to ensure proper
stewardship and accounting of
CWPPRA resources.
EPA will establish a more
comprehensive system of
internal controls to ensure
proper stewardship and
accounting of CWPPRA
resources.
March 2015
6
Provide training to WQPD managers
and staff on what constitutes a purpose
violation, including the potential for
ADA violations.
OCFO provided training on
federal budget,
appropriations law and
ADA violations and the
implications.
August 2014
Disagreements
No.
Recommendation
Agency
Explanation/Response
Proposed
Alternative
1
Reimburse the USACE questioned
costs of $780,793, unless Region 6
WQPD management provides
sufficient and appropriate
documentation to demonstrate that
questioned costs paid with CWPPRA
funds were incurred in accordance with
CWPPRA, appropriations laws and
This Recommendation
should be revised to read as
follows: "Region 6 WQPD
and Comptroller should
work with OCFO to review
the questioned costs
identified in this report and
determine what costs were
inappropriately charged to
March 2016
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principles, and interagency
agreements.
CWPPRA. Region 6 should
then reimburse the
CWPPRA program for any
costs deemed inappropriate
as a result of this review."
3
Identify and address any ADA
violations resulting from questioned
costs identified in this report or found
by the Region 6 Comptroller's review,
and report any violations in accordance
with the ADA and EPA Directive
2520.
Region 6 confirmed with
OCFO that there are
sufficient EPM funds
available for each FY to
correct the questioned
expenditures in the draft
report, if needed. Therefore,
this recommendation should
be deleted from the final
report.
5
Take administrative disciplinary
actions, in accordance with EPA
Directive 2520, against EPA
employees responsible for purpose
violations or ADA violations related to
improper CWPPRA spending.
This recommendation
should be deleted from the
final report, as no ADA
violations have been
documented.
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ATTACHMENT
Corrections to the Draft Audit Report
Page 6, paragraph 1: The language implies that EPA Region 6 is receiving funding under the RESTORE
Act. The report should be clarified to state that to date neither EPA as an agency, nor Region 6
specifically, has received any funding under the RESTORE Act.
OIG Comment: Language was added to footnote number 4 to include this
clarification.
Page 14, paragraph 4: The language implies that EPA Region 6 receives funding under both the
RESTORE Act and the Water Resources Development Act (WRDA). The language should be clarified to
state that Region 6 has not received funding under either of these statutes.
OIG Comment: Language was added to footnote number 11 to include this
clarification.
Page 15, paragraph 2, Travel to Attend Training: The response seems to suggest that the EPA
participant was not involved in CWPPRA at the time, and that the Netherlands trip was not relevant to
EPA's CWPPRA work. This would be inaccurate. The traveler participated in Region 6 CWPPRA team
meetings regarding project selection and prioritization, and continues to review levees for consistency
with coastal restoration and protection (CWPPRA explicitly calls on EPA to fulfill this role). The auditor
was informed of the CWPPRA provision which calls for EPA to ensure such consistency. This
information appears to have been ignored. Below is a synopsis of the information provided to the auditor.
In addition to the information provided below, it should be noted that CWPPRA responsibilities are
detailed in the PARS measures and metrics for the subject EPA employee. Specifically, he is to "[sjupport
the Agency representative on the CWPPRA Task Force by advising on identification and selection of
restoration projects" and in developing Agency positions on "CWPPRA projects" and "levee protection
projects". The description of this travel should include reference to the statutory provision listed below, as
well as a discussion of its direct relevance to the participant's work in support of the Agency's CWPPRA
activities — specifically project selection and review of proposed levee projects.
"The purpose of this trip was to learn about Dutch water management practices, particularly coastal
restoration and flood protection. The knowledge gained from this trip is directly relevant to EPA's
CWPPRA mission. The Dutch are actively engaged in coastal restoration efforts which offer potentially
valuable lessons applicable to our CWPPRA coastal restoration work. For example, the Dutch are
exploring innovative, cost-effective ways to restore barrier islands and beaches. EPA Region 6 has
sponsored a number of CWPPRA barrier island projects and continues to strongly support this practice.
Knowledge gained from the Netherlands trip can help Region 6 and our CWPPRA partners develop more
efficient and effective barrier island projects. Pursuant to CWPPRA Section 303(d)(1), EPA has an
important role in helping ensure that flood control projects such as levees do not conflict with coastal
restoration. "CWPPRA Section 303(d)(1) CONSISTENCY.—(1) In implementing, maintaining,
modifying, or rehabilitating navigation, flood control or irrigation projects, other than emergency actions,
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under other authorities, the Secretary, in consultation with the Director and the Administrator, shall ensure
that such actions are consistent with the purposes of the restoration plan submitted pursuant to this
section." Participants in this trip also studied lessons learned from Dutch levees and other flood control
structures - particularly with respect to ecological impacts. Knowledge gained from this trip is directly
applicable to EPA's CWPPRA responsibility to advise the Corps of Engineers on how to build levees in a
way that does not undermine or conflict with coastal restoration. EPA continues to be engaged in the
review of numerous levee projects in coastal Louisiana and the knowledge gained from the Netherlands
tour has been of great use in that regard. Indeed, EPA has used lessons learned from this trip to inform its
advice to the Corps on minimizing ecological impacts and ensuring consistency with coastal restoration
on numerous flood risk reduction projects."
OIG Comment: We revised Chapter 2 to provide more details that support why we
questioned this cost. Region 6 explanations about the purpose of this training were not
sufficient and appropriate to support the expenses as authorized, approved and allowable
CWPPRA expenses.
The employee obtained competencies, knowledge and/or skills useful to the EPA's water
programs regarding coastal restoration and flood protection as reflected in the Region 6
explanation above. The training did not relate directly to CWPPRA planning or project
implementation and may indirectly benefit multiple EPA water programs. Further, the
CWPPRA Task Force-approved budgets and allocated funds to EPA did not provide for
training or international travel. However, Region 6 funded this trip and conference fees fully
with CWPPRA planning funds.
Section 302(6) of the CWPPRA states that the primary purpose of a CWPPRA coastal
wetlands restoration project shall not be to provide navigation, irrigation or flood control
benefits. Sections 307(a) and (b) provide additional authority and directs the USACE, not
the EPA, to study the feasibility of modifying the operation of existing navigation and flood
control projects to allow for an increase in the share of the Mississippi River flows and
sediment sent down the Atchafalaya River for purposes of land building and wetlands
nourishment. Section 303(d)(1) states that in implementing, maintaining, modifying, or
rehabilitating navigation, flood control or irrigation projects, other than emergency actions,
under other authorities, the USACE, in consultation with the U.S. Fish and Wildlife Service
and the EPA, shall ensure that such actions are consistent with the purposes of the
CWPPRA restoration plan or PPLs. This means that the USACE shall consult with the EPA
and the U.S. Fish and Wildlife Service to make sure these projects are consistent with the
CWPPRA's PPL. The CWPPRA did not direct the EPA to plan navigation, irrigation or
flood-protection projects.
Page 16, paragraph 2: The draft report erroneously states "In FY 2010, two managers used CWPPRA
funds to recruit an intern from DOE's ORISE program." In fact, the managers were invited and attended,
as EPA's representatives to the USACE led CWPPRA Task Force, the change of command ceremony for
the New Orleans Corps of Engineers District Engineer, the CWPPRA chair. The managers also arranged a
meeting immediately prior to the ceremony with other attendees from Louisiana academic institutions to
discuss availability and interest of recent graduates in an ORISE fellowship, sponsored by EPA, to work
on CWPPRA activities.
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OIG Comment: We obtained the stated purpose of this trip from the official travel
documentation provided by WQPD. Further, we discussed the purpose of this trip with
a WQPD Associate Director who was one of the travelers. The Associate Director
confirmed that this was a recruiting trip and that she funded this trip with CWPPRA
funds because the intern would be assigned to the CWPPRA program. During the
interview, the WQPD Associate Director did not provide additional information about
the attendance at the US ACE change-of-command ceremony.
The explanation Region 6 provided above for this trip did not support how the trip was
necessary to accomplish CWPPRA's purpose. The Task Force did not approve or
allocate CWPPRA funds to EPA for recruiting purposes. The EPA's ORISE intern
worked on other EPA water programs and was not dedicated full time to performing
CWPPRA work. Further, EPA staff work with the US ACE, both in New Orleans and in
other locations, on multiple water-related programs. The region's attendance at the
US ACE change-of-command ceremony was optional and did not relate directly or only
to CWPPRA.
Page 16, paragraph 2: The draft report erroneously states "Also in FY 2010, the WQPD's director
traveled to Washington, DC, using CWPPRA funds to attend a Senior Executive Service graduation
ceremony." In fact, funding for the trip was split between EPM funding to attend the ceremony and
CWPPRA funding to brief OW and OCFO officials on CWPPRA funding and program issues. The
statement should either be deleted from the final report, or should be revised as follows - "Also in FY
2010, the WQPD's Deputy Director traveled to Washington, DC, using CWPPRA funds to brief OW and
OCFO officials on CWPPRA funding and program issues and using EPM funds to attend a Senior
Executive Service Candidate Development Program graduation ceremony."
OIG Comment: We revised this statement in Chapter 2 to include information about
the activity that was funded with CWPPRA funds. We also revised the fifth row of
Table 5 in Chapter 2 to better describe the activity funded with CWPPRA money.
Page 22, paragraph 2: The last sentence erroneously states "In addition, the WQPD director stated that
for purposes of administrative expediency, they made spending decision based on the funds available,
without regard to the intended purpose of the funds." The statement should be deleted from the final
report.
OIG Comment: We revised the statement in the report to include this clarification.
During a meeting with the WQPD Director in June 2014, he explained that he was
referring to travel spending decisions only.
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Pages 22 and 23: We believe that the interpretation of the conversation with the auditors and the PO is
not completely accurate as indicated in the attached email to her supervisor dated August 14, 2014. The
body of the email is listed below.
"I don't feel that the subject paragraphs are totally accurate. Below is what I was trying to relay to
the auditors:
There have been times where communication between 6WQPD management and myself, as the
Project Officer was lacking, however, this has improved. 6WQPD management and I have worked
together to develop controls on travel and other spending activities which has greatly improved the
communication. But decisions have been made where I as the Project Officer, did not necessarily
agree and where I had not been consulted before these decisions were made. However, I did not
mean to imply that these transactions "had occurred and could not be corrected," but that the
decision was not mine to make. And at no time did I ever feel "pressured" to certify the billings to
the USACE. In fact, I do not actually "certify" the billings. The main function of my review is to
assign the appropriate MIPR for Cincinnati Finance Center to bill against."
OIG Comment: We revised the statement in Chapter 2 to include the project officer's
clarifications, and deleted language about her feeling pressured to certify billings.
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Appendix E
Distribution
Office of the Administrator
Regional Administrator, Region 6
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
Assistant Administrator for Administration and Resources Management
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Deputy Chief Financial Officer
Principal Deputy Assistant Administrator, Office of Administration and Resources Management
Director, Office of Grants and Debarment, Office of Administration and Resources Management
Director, Grants and Interagency Agreements Management Division, Office of Grants and
Debarment, Office of Administration and Resources Management
Director, Office of Policy and Resource Management, Office of Administration and
Resources Management
Deputy Director, Office of Policy and Resource Management, Office of Administration and
Resources Management
Deputy Regional Administrator, Region 6
Audit Follow-Up Coordinator, Office of Administration and Resources Management
Audit Follow-Up Coordinator, Office of Grants and Debarment, Office of Administration and
Resources Management
Audit Follow-Up Coordinator, Region 6
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