I VMfS ? U.S. ENVIRONMENTAL PROTECTION AGENCY
\OFFICE OF INSPECTOR GENERAL
Environmental Benefits
Being Considered in Award
of Great Lakes Grants
Report No. 14-P-0004
November 5, 2013

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Report Contributors:
Janet Kasper
Doug Latessa
Mary Anne Strasser
Abbreviations
EPA	U.S. Environmental Protection Agency
GLNPO Great Lakes National Program Office
LAMP	Lakewide management plan
OIG	Office of Inspector General
RAP	Remedial action plan
Cover photo: View of Chicago, a Great Lakes shoreline city. (EPA photo)
Hotline
To report fraud, waste or abuse, contact
us through one of the following methods:
email:	OIG Hotline@epa.gov
phone:	1-888-546-8740
fax:	1-202-566-2599
online:	http://www.epa.gov/oig/hotline.htm
write: EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW
Mailcode 2431T
Washington, DC 20460
Suggestions for Audits or Evaluations
To make suggestions for audits or evaluations,
contact us through one of the following methods:
email:
OIG WEBCOMMENTS@epa.oov.
phone:
1-202-566-2391
fax:
1-202-566-2599
online:
http://www.epa.g0v/0i0/c0ntact.html#Full Info
write:
EPA Inspector General

1200 Pennsylvania Avenue, NW

Mailcode 241OT

Washington, DC 20460

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| jD, % Office of Inspector General	November 5,2013
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At a Glance
Why We Did This Review
The U.S. Environmental
Protection Agency (EPA) Office
of Inspector General (OIG)
received a hotline complaint
that Great Lakes Shoreline
Cities Green Infrastructure
grants were being awarded
with the only criterion being
population; the potential
environmental benefit was not
the primary factor for
determining awards. Our
objective was to determine
whether the EPA followed its
policies when announcing
these grants. The grants were
designed to help Great Lakes
shoreline cities reduce urban
runoff and sewer overflows that
impair Great Lakes water
quality.
This report addresses the
following EPA theme:
Environmental Benefits Being Considered in
Award of Great Lakes Grants
Region 5 plans to
assure the $8.5 million
of infrastructure
grants will result in
reducing discharges
to the Great Lakes.
What We Found
EPA Region 5 took prompt action to ensure that
Great Lakes Shoreline Cities Green Infrastructure
grants will support lakewide management plan
activities and will result in reduction of discharges to
the Great Lakes. While the grant announcement did
not specifically require proposed projects to support
lakewide management plan activities as identified in
the competition exemption, Region 5 management agreed that it should have.
To address the issue, Region 5 developed criteria for staff to use when reviewing
grant applications. Going forward, staff members will consider how each
proposed project will support lakewide management plan goals and result in
reducing discharges to the Great Lakes.
Since Region 5 has already taken action to address the issue noted, the report
contains no recommendations.
 Protecting water: A precious,
limited resource.
For further information,
contact our public affairs office
at (202) 566-2391.
The full report is at:
www.epa.gov/oig/reports/2014/
20131105-14-P-0004.pdf

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
November 5, 2013
MEMORANDUM
SUBJECT: Environmental Benefits Being Considered in Award of Great Lakes Grants
Report No. 14-P-0004
FROM: Arthur A. Elkins Jr.
TO:
Susan Hedman, Regional Administrator
Region 5
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 EPA has implemented. This report represents
the opinion of the OIG and does not necessarily represent the final EPA position. Since the agency has
taken sufficient corrective action and this report makes no recommendations, no response is required.
This report will be available at http://www.epa.gov/oig.
If you or your staff have any questions regarding this report, please contact Richard Eyermann,
Acting Assistant Inspector General for Audit, at (202) 566-0565 or evermann.richard@epa.gov;
or Janet Kasper, Product Line Director, at (312) 886-3059 or kasper.ianet@epa.gov.

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Purpose
The U.S. Environmental Protection Agency (EPA) Office of Inspector General
(OIG) received a hotline complaint that Great Lakes Shoreline Cities Green
Infrastructure grants were being awarded with the only criterion being
population; the potential environmental benefit was not the primary factor for
determining awards. Our objective was to determine whether the EPA followed
its policies when announcing these grants.
Background
The EPA invited 22 cities to submit applications for projects to reduce urban
runoff and sewer overflows that impair Great Lakes water quality. The total
amount of funds eligible for award to all potential recipients is $8.5 million. The
amount to be awarded would be based on population and would be awarded on a
first-come, first-serve basis. The funding for these grants came from the Great
Lakes Restoration Initiative. Eligible cities can use the grants to cover up to 50
percent of the cost of:
	Rain gardens.
	Bioswales.
	Green roofs.
	Porous pavement.
	Greenways.
	Constructed wetlands.
	Stormwater tree trenches.
	Other green infrastructure measures installed on public property.
It is EPA policy1 to promote competition to the maximum extent practicable in
the award of assistance agreements, and that the competitive process be fair and
impartial, that all applicants be evaluated only on the criteria stated in the
announcement, and that no applicant receive an unfair competitive advantage.
When the estimated total amount of funds expected to be awarded under an
announcement exceeds $100,000 (regardless of the amount of any individual
awards), open competition among all potentially eligible applicants is required.
The policy allows for exemptions to competition when there are urgent and
compelling circumstances, national security consideration or public interest.
Scope and Methodology
We conducted this audit in August and September 2013 in accordance with
generally accepted government auditing standards. Those standards require that
we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based on our audit
1 EPA Order 5700.5A1, "Policy for Competition of Assistance Agreements," revised July 19, 2012.
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objectives. We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objective.
To answer the objective, we interviewed staff and managers in Region 5 and the
Great Lakes National Program Office (GLNPO) and reviewed the following
documentation:
	Solicitation for Great Lakes Shoreline Cities Green Infrastructure grants.
	EPA guidance regarding competition of grants.
	Exemption from competition for lakewide management plan (LAMP) and
remedial action plan (RAP) activities.
	EPA actions to address issues identified during the audit.
Our review was limited to the process for announcing the shoreline city green
infrastructure grants. As of September 10, 2013, none of the grants had been
awarded.
Results of Review
Region 5 took prompt action to ensure that Great Lakes Shoreline Cities Green
Infrastructure grants will support LAMP activities and will result in reduction of
discharges to the Great Lakes. While the grant announcement did not specifically
require proposed projects to support LAMP activities as identified in the
competition exemption, Region 5 management agreed that it should have. During
our review, Region 5 developed criteria for staff to use when reviewing grant
applications that will look for how the proposed project will support LAMP goals
and result in reducing discharges to the Great Lakes.
On July 26, 2013, the EPA invited the 22 largest Great Lakes shoreline cities to
apply for shoreline city green infrastructure grants. To be eligible for the grants, a
city must directly touch the Great Lakes and have a population greater than
50,000 people. The amount of funding available to a specific recipient is based on
the city's total population; larger cities will receive more money. For example,
cities with a population of more than 500,000 are eligible for up to $1 million.
The total amount of funds eligible for award under the Great Lakes shoreline
cities program is $8.5 million, making it subject to the EPA competition policy.
In June 2013, the Assistant Administrator for Administration and Resources
Management approved an exemption from competition for grants to states, tribes
and local governments in furtherance of LAMP and RAP activities. The
exemption was to cover activities including the hiring of employees by the
governmental entity to oversee and implement LAMP and RAP activities; the
joint development and implementation of RAP and LAMP projects, and RAP and
LAMP activities that will be conducted on property owned by states, tribes and
local governments. However, the grant announcement made no reference to RAPs
or LAMPs, or that the activities being conducted under the grants would support
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RAPs or LAMPs. According to the GLNPO Director, the program office assumed
that activities under the shoreline cities grants would support LAMPs and RAPs,
and agreed that this should have been included in the grant solicitation.
On September 4, 2013, OIG staff met with Region 5 management to discuss the
hotline complaint and compliance with the competition policy. To comply with
the competition policy, Region 5 management agreed with the OIG that it would
develop criteria for reviewing the grant applications to ensure that the applications
addressed environmental results and funded activities were linked to the goals and
objectives of the LAMPs. Consequently, GLNPO developed criteria for reviewing
applications for shoreline cities grants. Regional staff, when reviewing the grant
work plans, would confirm and document whether the proposed project would
further the goals, or address an issue of concern, of a LAMP by:
	Reducing the discharge of untreated stormwater runoff to a Great Lake or
a waterway that discharges to a Great Lake.
	Reducing the discharge of sewer system overflows to a Great Lake or a
waterway that discharges to a Great Lake.
	Reducing the discharge of sediment, nutrients, chemicals, bacteria and/or
other contaminants to a Great Lake or a waterway that discharges to a
Great Lake.
	Reducing threats to public health at beaches or in near-shore areas caused
by contaminants including, but not limited to, bacteria, nutrients and
chemicals.
The criteria should ensure the proposed project is linked to the LAMP as provided
for in the competition exemption. It will also ensure that the proposed project will
result in an environmental benefit of reducing discharges to the Great Lakes.
Since Region 5 has already taken action to address the issue noted,
no recommendation is being made.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
No recommendations
Claimed
Amount
Ag reed-To
Amount
1 0 = 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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Distribution
Office of the Administrator
Regional Administrator, Region 5
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Director, Grants and Interagency Agreements Management Division,
Office of Administration and Resources Management
Deputy Regional Administrator, Region 5
Director, Great Lakes National Program Office, Region 5
Audit Follow-Up Coordinator, Region 5
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