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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
EPA's International Program
Office Needs Improved
Strategic Planning Guidance
Report No. 13-P-0386
September 9, 2013

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Report Contributors:	Ganesa Curley
Jerri Dorsey
Natasha Henry
Lauretta Joseph
Olga Stein
Abbreviations
EPA	U.S. Environmental Protection Agency
FY	Fiscal Year
IGMS	Integrated Grants Management System
NEPA	National Environmental Protection Act
OIG	Office of Inspector General
OITA	Office of International and Tribal Affairs
Cover photo: Examples of environmental problems addressed using EPA grant funding to
(from left) combat air pollution and reduce e-waste. (EPA photos)
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
email: OIG Hotline@epa.gov	write: EPA Inspector General Hotline
phone: 1-888-546-8740	1200 Pennsylvania Avenue, NW
fax:	202-566-2599	Mailcode 2431T
online:
http://www.epa.gov/oiq/hotline.htm
Washington, DC 20460

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*. U.S. Environmental Protection Agency	13-p-0386
ro	Offino r»f Incnortnr	September 9, 2013
At a Glance
!JSB~	Office of Inspector General
Why We Did This Review
The objective of this evaluation
was to determine how the
U.S. Environmental Protection
Agency (EPA) ensures that
environmental and human
health goals are achieved
through partnerships with
international entities. We
focused on (1) the statutory
authority by which the EPA
awards international grants,
(2)	anticipated environmental
outcomes of foreign grants, and
(3)	tools in place to manage
outcomes and measures for
grants. We focused on
activities of the EPA's Office of
International and Tribal Affairs
(OITA), which awards grants to
support international activities.
This report addresses the
following EPA Themes:
•	Addressing climate change
and improving air quality.
•	Taking action on toxics and
chemical safety.
•	Working toward a
sustainable future.
EPA's International Program Office
Needs Improved Strategic Planning Guidance
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
What We Found
The EPA has the statutory authority to conduct international activities and has
several tools in place to help ensure that its partnerships with international
entities achieve environmental and human health goals. However, the EPA's
OITA needs additional strategic planning guidance to better manage anticipated
environmental outcomes of foreign grants.
The EPA has the legal authority to award international and foreign grants under:
(1) specific international grant authorities, and (2) research and demonstration
authorities that are supplemented by the National Environmental Policy Act.
Further, the EPA uses a combination of grants management tools, such as the
Integrated Grants Management System and project officers, to help manage
outcomes and measures.
Although OITA collects environmental outcome/output information, OITA has not
incorporated the information into a comprehensive strategic planning document.
Also, the allocation of resources for planned activities is not described within
OITA's current strategic planning documents. OITA's strategic planning guidance
needs to be updated to provide greater accountability and justification for the
international activities and grants that OITA manages. This would help assure
that OITA's grants align with the EPA's goals of advancing public health and
environmental improvement and that EPA resources are properly allocated.
Recommendations and Planned Corrective Actions
We recommend that the assistant administrator for OITA develop strategic
planning guidance to document how OITA links its achieved outcomes for
international and foreign grant activities to its strategic plan goals, the process
used by OITA to allocate resources for its international and foreign grant
activities, and how OITA's international and foreign grant activities align with the
EPA's overall goals.
The agency concurred with our findings and recommendation. The agency
provided corrective actions and an estimated completion date that meet the intent
of the recommendation. The recommendation is resolved and open with
corrective actions ongoing. No further response to this report is required.
The full report is at:
www.epa.qov/oiq/reports/2013/
20130909-13-P-0386.pdf

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
September 9, 2013
MEMORANDUM
SUBJECT: EPA's International Program Office Needs Improved Strategic Planning Guidance
Report No. 13-P-0386
This is our report on the subject evaluation 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
Because you agreed to the report's recommendation and provided corrective actions and an estimated
completion date that meet the intent of the recommendation, you are not required to provide a written
response to this final report. The recommendation is resolved and open with corrective actions
ongoing. Should you choose to provide a response to this final report, we will post your response on
the OIG's public website, along with our memorandum commenting on your response. You should
provide your response as an Adobe PDF file that complies with the accessibility requirements of
Section 508 of the Rehabilitation Act of 1973, as amended.
We will post this report to our website at http://www.epa.gov/oig.
If you or your staff have any questions regarding this report, please contact Assistant Inspector General
for Program Evaluation Carolyn Copper at (202) 566-0829 or copper.carolyn@epa.gov; or Acting
Director for Toxics, Chemical Management, and Pollution Prevention Evaluations Jerri Dorsey at
(919) 541-3601 or dorsev.ierri@epa.gov.
FROM: Arthur A. Elkins Jr.
TO:
Michelle DePass, Assistant Administrator
Office of International and Tribal Affairs

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EPA's International Program Office	13-P-0386
Needs Improved Strategic Planning Guidance
		Table of C	
Purpose		1
Background		1
Scope and Methodology		2
Results of Review		3
Statutory A uthority		3
Grant Management Tools		4
Environmental Outcomes and Strategic Planning		4
Recommendation		5
Agency Comments and OIG Evaluation		6
Status of Recommendations and Potential Monetary Benefits		7
Appendices
A Files Reviewed		8
B Agency Comments		10
C Distribution		12

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Purpose
Our objective was to determine how the U.S. Environmental Protection Agency
(EPA) ensures that environmental and human health goals are achieved through
partnerships with international entities. Specifically, we focused on:
•	The statutory authority by which the EPA awards international grants.
•	The anticipated environmental outcomes of foreign grants.
•	Tools in place to manage outcomes and measures for grants.
Background
The EPA's work to improve the environment extends to nearly 180 nations
worldwide. This work is conducted through collaborative efforts with partners
from around the world to facilitate commerce, promote sustainable development,
protect vulnerable populations and engage diplomatically around the world.
Some of these activities are funded with federal financial assistance, such as
cooperative agreements and grants.
The EPA awards cooperative agreements and grants to both countries and
organizations to support international activities that protect human health and the
environment while advancing the United States' national interests through
international collaboration. Program offices such as the Office of Air and
Radiation, Office of Enforcement and Compliance Assurance, and Office of
International and Tribal Affairs (OITA) conduct and manage international work.
This report focuses on OITA.
Congress has recently shown interest in the EPA's international activities. In 2011,
Congress asked the EPA about the costs and benefits of its international grants.
In 2012, Congress proposed legislation that would restrict the agency from awarding
grants for international activities to improve air pollution.1 The EPA testified that
these international activities achieve mutual benefits including environmental
regulations similar to EPA and improved pollution control technologies.
Office of International and Tribal Affairs
OITA manages various types of activities, such as partnerships, bilateral
agreements, and international and foreign grants. According to OITA,
partnerships are generally multilateral, voluntary activities that are centrally
organized around shared goals. Bi/multilateral agreements involve the United
States and other governments agreeing to pursue specific goals and activities that
1 The bill would revoke authority specifically under the Clean Air Act. See H.R. 4255, "Accountability in Grants
Act of 2012." As of June 5, 2013, the act has not been voted on.
http://energvcommerce.house.gov/hearing/legislative-hearing-hr-4255-accountabilitv-in-grants-act-of-2012.
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are both important to the U.S. government and consistent with agency's
international priorities.
Six international priorities serve as the strategic focus of OITA's international
program activities:
1.	Building Strong Environmental Institutions and Legal Structures.
2.	Combating Climate Change by Limiting Pollutants.
3.	Improving Air Quality.
4.	Expanding Access to Clean Water.
5.	Reducing Exposure to Toxic Chemicals.
6.	Cleaning Up Electronic Waste (E-Waste).
International grants or cooperative agreements are awarded to a domestic entity to
perform work abroad. Foreign grants differ in that they are awarded to a foreign
government, international organization, or non-governmental international
organization or institution. For fiscal year (FY) 2012, OITA received more than
$3.5 million in appropriated funds for international grants.
Scope and Methodology
We conducted this performance evaluation in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform
the evaluation to 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 results based upon our
objectives. We conducted this evaluation from November 2012 to July 2013.
To determine how the EPA ensures that environmental and human health goals
are achieved through partnerships with international entities, we focused our
review on international and foreign grants managed by OITA. Specifically, we
reviewed six grantee files provided by OITA. To determine what tangible
environmental outcomes OITA expects to receive from international and foreign
grants, we reviewed grant planning and performance documents. We also
reviewed associated OITA performance measures used to capture outcomes.
To determine the tools in place to manage outcomes and measure results, we
interviewed EPA staff from OITA (including six project officers), the Office of
Enforcement and Compliance Assurance, the Office of Air and Radiation, and the
Office of Grants and Debarment. We also interviewed staff from the
U.S. Department of State and the U.S. Agency for International Development.
We reviewed relevant EPA policies and procedures, strategic planning documents,
and data from the Integrated Grants Management System (IGMS). We also
reviewed relevant U.S. Government Accountability Office and Office of Inspector
General (OIG) reports. To determine the statutory basis for the EPA awarding
international grants, we reviewed relevant statutes and met with agency staff.
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Results of Review
The EPA has the statutory authority to conduct international activities and has
several tools in place to help ensure environmental and human health goals are
achieved. Although EPA's Foreign Grants Policy and National Program Guidance
direct the development of certain strategic planning elements, the EPA's OITA
needs additional strategic planning guidance to better manage anticipated
environmental outcomes of foreign grants.
Statutory Authority
The EPA has the legal authority to award international and foreign grants under:
•	Specific international grant authorities.
•	Research and demonstration authorities that are supplemented by the
National Environmental Policy Act (NEPA).2
The majority of the agency's international grants are awarded under the EPA's
research and demonstration grant authorities as supplemented by Section
102(2)(F) of NEPA. The research and demonstration grant authorities are
contained in such federal environmental statutes as the following:
•	Clean Water Act (Section 104(b)(3)).
•	Clean Air Act (Section 103(b)(3)).
•	Solid Waste Disposal Act (Section 8001(a)).
•	Toxic Substances Control Act (Section 10).
•	Federal Insecticide, Fungicide, and Rodenticide Act (Section 20).
•	Safe Drinking Water Act (Section 1442).
•	Marine Protection, Research, and Sanctuaries Act (Section 203(a)(2)).
Although each of these statutes is unique, they generally authorize the EPA to
award grants to a variety of eligible entities for activities such as research,
demonstrations, experiments, investigations, training and education in the areas of
air pollution, water pollution, solid waste, pesticides and toxic substances.
According to the agency, these research and demonstration authorities can also
provide independent grant authority for international grants only if the activities are
anticipated to result in benefits that are transferable to any domestic environmental
program. If there is no transferrable benefit and no other explicit international grant
authority exists, the EPA's research and demonstration grant authorities may be
supplemented by Section 102(2)(F) of NEPA, which authorizes and directs the
agency to lend support to international activities designed to maximize
2 There are a number of specific international grant authorities, for example Section 617(b) of the Clean Air Act,
42 U.S.C. §7671p(b), relating to the Montreal Protocol on Stratospheric Ozone Protection; and the Federal
Insecticide, Fungicide, and Rodenticide Act, 7 U.S.C. §136o, relating to the development of improved pesticide
research and regulations.
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international cooperation in anticipating and preventing a decline in the quality of
the world's environment. The research and demonstration authorities described
above and in Section 102(2)(F) of NEPA authorize grants for activities performed
abroad or whose primary purpose is international in scope.
Grant Management Tools
OITA uses a variety of tools to manage international and foreign grants. These
international and foreign grants are managed under many of the same regulatory
requirements and systems as other agency grants. A combination of IGMS, EPA
policies and procedures on environmental results3 and grants management, project
officer oversight, and OITA's Performance Measures Tracking System create a
system of internal controls to help manage grant outcomes and measure results.
As of May 2013, OITA's Performance Measures Tracking System was still in a
pilot phase and being tested. This new database system will use a series of
measures to track OITA activities; this includes international grant activities and
their associated outputs and outcomes. According to OITA, this system will be
used as one of many tools to inform resource decisions and prioritize what work
will be conducted.
Environmental Outcomes and Strategic Planning
As noted, OITA international and foreign grants are designed to address OITA's
six international priorities. According to the EPA's Foreign Grants Policy, OITA
must determine how its proposed activities align with the EPA's goals in
advancing public health and environmental improvement and the extent to which
the proposed activity complements rather than duplicates other EPA or
U.S. government international environmental programs or initiatives. Although
OITA has environmental outcome/output information as detailed by the
Government Performance and Results Act, OITA has not incorporated the
information into a subsequent comprehensive strategic planning document.
OITA receives a range of environmental outcomes and outputs4 for its
international and foreign grants. Examples of anticipated environmental
outcomes/outputs are "Increased level of harmonization and reduced redundancies
among all key stakeholder activities" and "Improve drinking water quality
provided by partner utilities in East Africa." Examples of grantee-reported
3	EPA Policies 5700.7 and 5700.8 address, respectively, environmental results achieved and assessing capabilities of
non-profit applicants for managing assistance awards.
4	Outcome means the result, effect or consequence that will occur from carrying out an environmental program or
activity that is related to an environmental or programmatic goal or objective. Outcomes may be environmental,
behavioral, health-related or programmatic in nature; must be quantitative; and may not necessarily be achievable
within an assistance agreement funding period. Output means an environmental activity, effort and/or associated
work product related to an environmental goal or objective, that will be produced or provided over a period of time
or by a specified date. Outputs may be quantitative or qualitative but must be measurable during an assistance
agreement funding period.
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outcomes/outputs include "Training workshops organized (number of personnel
trained)" and "Number of countries phasing out lead in gasoline and going to
50 ppm fuel." Additional examples of expected outcomes and reported outputs are
provided in appendix A. Outputs and outcomes from grants will be collected and
aggregated into OITA's new Performance Measures Tracking System. Prior to the
new system, OITA did not have a systematic way to count outputs for activities
being carried out. OITA expects that the new system will assist in identifying
what work will be conducted and informing resource decisions.
Outcomes from international and foreign grants are generally project driven and
are not defined as part of the planning process. Additionally, OITA cannot
determine whether resources are being allocated to achieve results. OITA uses
various documents to guide its work that contain information about project goals
and anticipated accomplishments. These include the FY 2012 Operating Plan
Narrative Proposal and Draft FY 2014 National Program Manager Guidance.
The OITA FY 2012 Operating Plan Narrative Proposal identified project goals
and anticipated accomplishments for planned projects. However, it does not
provide information on how or why OITA allocated resources to these projects.
Prior to FY 2013, OITA did not have National Program Manager Guidance or a
strategic plan that showed the organization's process for prioritizing and
allocating resources to meet strategic goals. The Draft FY 2014 National Program
Manager Guidance includes a narrative of OITA's plans for addressing each of
the six international priorities. However, the draft National Program Manager
Guidance did not include how OITA uses its work to meet its strategic goals, nor
does the draft guidance contain any performance measures or outcome
information.
Although environmental outcome/output information is collected by OITA, this
information has not been incorporated into a comprehensive strategic planning
document. Strategic planning guidance needs to be updated to show how OITA's
grants align with the EPA's goals for advancing public health and protection of
the environment. This would provide greater accountability and justification for
the international and foreign activities/grants that are managed by OITA.
Recommendation
We recommend that the assistant administrator for the Office of International and
Tribal Affairs:
1. Develop strategic planning guidance to document:
•	How OITA links its achieved outcomes for international and foreign
grant activities to the goals of its strategic plan.
•	The process used by OITA to allocate resources for its international
and foreign grant activities.
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• How OITA's international and foreign grant activities align with the
EPA's goals in advancing public health and environmental
improvement.
Agency Comments and OIG Evaluation
The agency concurred with our findings and recommendation. The agency
provided corrective actions and an estimated completion date that meet the intent
of the recommendation. The recommendation is resolved and open with corrective
actions ongoing. No further response to this report is required.
The agency's detailed response is provided in appendix B. The agency also
provided technical comments on the draft report, which we have incorporated into
our report as appropriate.
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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
Claimed
Amount
Ag reed-To
Amount
5 Develop strategic planning guidance to document: 0
•	How OITA links its achieved outcomes for
international and foreign grant activities to
the goals of its strategic plan.
•	The process used by OITA to allocate
resources for its international and foreign
grant activities.
•	How OITA's international and foreign grant
activities align with the EPA's goals in
advancing public health and environmental
improvement.
Assistant Administrator,
Office of International and
Tribal Affairs
6/30/14
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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Appendix A
Files Reviewed
The length of time for grant implementation varied, but four of the grants were awarded for a
5-year period. Reported outputs/outcomes are generally listed in the project file and provided by
the grantee. Anticipated outputs/outcomes are generally listed in the EPA Funding Action
Memo, Scope of Work, or other documentation provided in the grant file.
Table 1: Examples of outputs/outcomes reported by the EPA and grantees
Grantee and
Cooperative
agreement/
grant type
EPA
OITA

Outputs/outcomes
Outputs/outcomes
funded amount
goal5
priority6

reported by grantee
anticipated by the EPA
Organization for
Foreign
1
2
1.
Report on monitoring and
1. Assessments
Economic




evaluation of progress in
performed or facilitated
Development



2.
3.
the development and use
of measures of effective
adaptation.
Report on private sector
engagement in adaptation.
Tools to inform
international policy,
planning and decision-
making in climate
sensitivity sectors.
by EPA.
United Nations
Foreign
3,4
6
1.
Increased harmonization
1. Increased level of
University



2.
3.
of approaches to
preventing exports of
e-waste from developed
to developing countries.
Use of tracking data to
develop appropriate
national and international
policies toward e-waste.
Replication and
refinement of
demonstrations of
sustainable recycling that
lead to improved
management of e-waste
globally.
harmonization and
reduced redundancies
among all key
stakeholder activities.
2.	Stakeholder-applied,
science-based pilot
projects.
3.	Solid recommendations
for national and
international policy
making based on the
results of pilot projects.
5	EPA FY 2011-2015 Strategic Plan Goals:
1: Taking Action on Climate Change and Improving Air Quality.
2: Protecting America's Waters.
3: Cleaning Up Communities and Advancing Sustainable Development.
4: Ensuring the Safety of Chemicals and Preventing Pollution.
5: Enforcing Enviromnental Laws.
6	OITA International Priorities:
1: Building Strong Enviromnental Institutions and Legal Structures.
2: Combating Climate Change by Limiting Pollutants.
3: Improving Air Quality.
4: Expanding Access to Clean Water.
5: Reducing Exposure to Toxic Chemicals.
6: Cleaning Up Electronic Waste (E-Waste).
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^ . . Cooperative
Grantee and r .,
, . . . agreement/
funded amount a ..
grant type
EPA
OITA
Outputs/outcomes
Outputs/outcomes
goal5
priority6
reported by grantee
anticipated by the EPA
United Nations
Environmental
Programme
Foreign
4
5
1. Number of countries
phasing out lead in
gasoline and going to
50 ppm fuel.
1.	Pilot projects on low
sulfur fuel road map
development - draft low
sulfur fuel target
developed for two
countries for
consideration of
high-level officials.
2.	Re-Launch of
Partnerships for Clean
Fuels and Vehicles
(PCFV) at Rio +20-
Successful re-launch of
the PCFV.
Breathe Easy
Jakarta
Stakeholders
Group
Foreign
4
1,3,5
1. To achieve greater
protection of human health
through improved urban
air quality in Jakarta.
Support environmental
outcomes of Breathe Easy
Jakarta, such as reduction
of key air pollutants.
1.	Improved management
and reduction
strategies of key air
pollutants in Jakarta.
2.	Improved protection of
human health in
Jakarta, through
increased awareness
and involvement by the
public.
3.	Improved capacity of air
quality management
officials to create
targeted strategies for
air quality improvement
through consistent
stakeholder input.
Desert Research
Institute
Int'l.
1,4
1,3,5
1. Strengthen the capacity to
prepare a science-based
clean air action plan to
achieve better public
health and air quality.
1. To support the
environmental
outcomes of the other
components of Breathe
Easy Jakarta, such as
reduction of key air
pollutants.
International
Water
Association
Foreign
2,4
4
1.	Training workshops
organized (number of
personnel trained).
2.	Report on long-term,
full-scale training
programme for African
region.
3.	Five-year (2011-2016)
strategic plan for Water
Safety Plan training in
Africa with committed
funding for budget.
1.	Improve drinking water
quality provided by
partner utilities in
East Africa.
2.	Accrue operational
efficiencies and
framework to better
target more sustainable
capital investments.
3.	Framework for
increasing resiliency
and preparedness of a
water utility to the
impacts of climate
change.
Source: OIG analysis.
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Appendix B
Agency Comments
August 06, 2013
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report No. OPE-FY13-0004, "The
EPA's International Program Office Needs Improved Strategic Planning
Guidance," July 1, 2013
FROM: Michelle DePass /s/
Assistant Administrator
/6/2013
TO:	Arthur A. Elkins, Jr.
Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the
draft report. The following is a summary of The Office of International and Tribal Affairs'
(OITA) overall position, along with its position on the draft report's recommendation.
OVERALL POSITION
OITA accepts the recommendation in the draft report, however we have included a
Technical Comments Attachment to supplement and clarify this response.
Over the last several years OITA has undertaken a number of efforts to strengthen its
internal control structure, resulting in the development and implementation of a variety of
important management and planning tools. As such, the Office sees the value of updating our
planning guidance, emphasizing our strategic planning approach and further detailing how our
grants support the Agency's goals and international priorities.
OITA will examine our existing guidance (e.g., NPM and Operating Plan guidance) and
identify the most appropriate options for integrating the report's recommendations.
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RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Intended
Estimated


Corrective Action(s)
Completion by



Quarter and FY
1
Develop strategic planning
OITA will update and
3rd Quarter 2014

guidance to document:
supplement planning guidance



to document:


How OITA links its achieved



outcomes for international
How OITA links its achieved


and foreign grant activities to
outcomes for international


the goals of its strategic plan.
and foreign grant activities to


The process used by OITA to
the goals of its strategic plan.


allocate resources for its
The process used by OITA to


international and foreign
allocate resources for its


grant activities.
international and foreign


How OITA's international
grant activities.


and foreign grant activities
How OITA's international


align with the EPA's goals
and foreign grant activities


in advancing public health
align with the EPA's goals


and environmental
in advancing public health


improvement
and environmental



improvement

CONTACT INFORMATION
If you have any questions regarding this response, please contact Teresa Ruppe, Audit
Follow-Up Coordinator, Office of International and Tribal Affairs at 202-564-6619.
Attachment
cc:
Jane Nishida, Acting DAA
Katrina Cherry, Director OMIS
Neilima Senjalia, Acting Director ORB A
Walker Smith, Director OGAP
13-P-0386
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Distribution
Office of the Administrator
Assistant Administrator for International and Tribal Affairs
Agency Follow-Up Official (the CFO)
Audit Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Information
Deputy Assistant Administrator for International and Tribal Affairs
Audit Follow-Up Coordinator, Office of International and Tribal Affairs
13-P-0386

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