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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
EPA Can Improve Its
Reporting of Dollars
Leveraged From the
American Recovery and
Reinvestment Act
Brownfields Program
Report No. 12-R-0898
September 27, 2012
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Report Contributors:	Janet Kasper
Shannon Schofield
Andres Calderon
Kimberly Crilly
Heriberto Ibarra
LaTanya Scott
Khadija Walker
Abbreviations
ACRES Assessment, Cleanup and Redevelopment Exchange System
EPA	U.S. Environmental Protection Agency
OBLR	Office of Brownfields and Land Revitalization
OIG	Office of Inspector General
RLF	Revolving Loan Fund
Cover photo: A remediated brownfields site in Howland, Maine, that led to dollars leveraged.
(EPA photo)
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail:	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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At a Glance
Why We Did This Review
We conducted this audit to
determine whether the results
reported for the U.S.
Environmental Protection
Agency (EPA) American
Recovery and Reinvestment
Act (Recovery Act) brownfields
assessment, cleanup, and
revolving loan fund grants were
timely and accurately reported,
and the grants achieved their
intended goals in terms of
outputs and outcomes. The
Recovery Act provided
$100 million for brownfields
activities. EPA awarded
$87.3 million in brownfields
assessment, cleanup, and
revolving loan fund grants to
state agencies, tribes,
non-profits, local communities
and commissions, and other
entities. EPA anticipated
assessing 500-750 properties,
making 500-750 acres ready
for reuse, cleaning up 30-50
properties, and leveraging
$450-$600 million by 2012.
This report addresses the
following EPA Goal or
Cross-Cutting Strategy:
• Cleaning up communities
and advancing sustainable
development
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
www.epa.qov/oiq/reports/2012/
20120927-12-R-0898.pdf
EPA Can Improve Its Reporting of Dollars
Leveraged From the American Recovery and
Reinvestment Act Brownfields Program
What We Found
EPA project officers verified grant recipient reported outputs and outcomes for
Recovery Act brownfields assessments completed, acres ready for reuse, and
cleanups completed, but did not always verify dollars leveraged. Dollars
leveraged are additional non-EPA resources invested in the project as a result of
the use of grant funds. EPA guidance includes requirements for grant recipients
to report, and for EPA project officers to review, grant output and outcome
information in its on-line data management system—the Assessment, Cleanup
and Redevelopment Exchange System (ACRES). However, the guidance does
not specify the documentation needed to support dollars leveraged. Recipients
were unclear as to what could be counted as dollars leveraged, and some project
officers were not aware of the requirement to verify reported dollars leveraged.
As a result, EPA's Office of Brownfields and Land Revitalization (OBLR) and
others may not be able to rely on the dollars leveraged data in ACRES, which is
reported to Congress and the public.
OBLR may not meet its Recovery Act dollars leveraged goal. Dollars leveraged
may not be realized until after grants are completed, and EPA has to rely on
recipients to report this information after their grants are completed, which may
be as late as the end of 2014. As a result, the dollars leveraged that EPA reports
to Congress and the public may continue to change for several more years.
Recommendations and Planned Agency Corrective Actions
We recommend that the Assistant Administrator for Solid Waste and Emergency
Response instruct the OBLR Director to create a checklist for grant recipients
and project officers that defines dollars leveraged, and identifies specific types of
supporting documents needed. We also recommend that the Assistant
Administrator instruct the OBLR Director to include a letter in closeout packages
reminding recipients of their responsibility to continue to report dollars leveraged
as they are realized. EPA agreed with our recommendations and provided
intended corrective actions to develop and distribute a checklist and develop a
letter for closeout packages. EPA estimated that these corrective actions would
be completed by December 31, 2012. The Agency's actions, when implemented,
will address the recommendations.
Noteworthy Achievements
The Brownfields program exceeded its Recovery Act goals for properties
assessed, cleaned up, and acres made ready for reuse.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
September 27, 2012
MEMORANDUM
SUBJECT: EPA Can Improve Its Reporting of Dollars Leveraged From the
American Recovery and Reinvestment Act Brownfields Program
Report No. 12-R-0898
FROM: Arthur A. Elkins, Jr.

/
TO:
Mathy Stanislaus
Assistant Administrator for Office of Solid Waste and Emergency Response
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.
The Office of Brownfields and Land Revitalization staff are to be commended for the prompt
action that was taken to develop corrective actions to address the findings and recommendations.
Action Required
In responding to the draft report, the Agency provided a corrective action plan for addressing the
recommendations with milestone dates. Therefore, a response to the final report is not required.
The Agency should track corrective actions not implemented in the Management Audit Tracking
System. We have no objections to the further release of this report to the public. This report will
be available at http://www.epa.gov/oig.
If you or your staff have any questions regarding this report, please contact Melissa Heist,
Assistant Inspector General for Audit, at (202) 566-0899 or heist.melissa@epa.gov; or
Janet Kasper, Director, Contracts and Assistance Agreements Audits, at (312) 886-3059 or
kasper.ianet@epa.gov.

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EPA Can Improve Its Reporting of Dollars Leveraged
From the American Recovery and Reinvestment Act
Brownfields Program
12-R-0898
Table of C
Chapters
1	Introduction 		1
Purpose		1
Background		1
Noteworthy Achievements		3
Scope/Methodology		3
2	Dollars Leveraged Data Reported in ACRES Were Not Always Accurate....	5
Project Officers Are to Review Recipient Reported Data in ACRES		5
Project Officers Did Not Always Review Supporting
Documentation for Dollars Leveraged		5
Dollars Leveraged Guidance Was Not Clear		6
ACRES Dollars Leveraged Data May Not Be Accurate		7
Recommendation		7
Agency Comments and OIG Evaluation		8
3	EPA's Ability to Meet Dollars Leveraged Goal Is Uncertain		9
Data on Dollars Leveraged Are Not Complete		9
Recommendation		10
Agency Comments and OIG Evaluation		10
Status of Recommendations and Potential Monetary Benefits		11
Appendices
A Agency Comments to Draft Report	 12
B Distribution	 15

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Chapter 1
Introduction
Purpose
Congress appropriated $100 million under the American Recovery and
Reinvestment Act of 2009 (Recovery Act) to assist in identification and cleanup
of brownfields sites. The U.S. Environmental Protection Agency (EPA) Office of
Inspector General (OIG) conducted this audit to determine whether results from
EPA Recovery Act brownfields assessment, cleanup, and revolving loan fund
grants were timely and accurately reported, and that grants achieved their
intended goals in terms of outputs and outcomes.
Background
Brownfields are real property, the expansion, redevelopment, or reuse of which
may be complicated by the presence or potential presence of a hazardous
substance, pollutant, or contaminant. The Brownfields Revitalization and
Environmental Restoration Act of 2001 promotes the cleanup and reuse of
brownfields and provides assistance for brownfields revitalization. EPA's Office
of Brownfields and Land Revitalization (OBLR) provides grant funding to states,
communities, and other stakeholders to prevent, inventory, assess, safely clean up,
and sustainably reuse brownfields. OBLR provides funding for four types of
grants:
•	Environmental Assessment
•	Cleanup
•	Revolving Loan Fund (RLF)
•	Job Training1
Environmental assessment grants provide funding to inventory, characterize,
assess, and conduct planning and community involvement related to brownfields
sites. Cleanup grants provide the funding needed to carry out cleanup activities at
the sites. These types of grants have 3-year performance periods.
RLF grants provide funding for a grant recipient to capitalize a revolving fund
and make loans, and provide subgrants to carry out cleanup activities at
brownfields sites. The performance period for revolving loan fund grants is
5 years.
1 Job training grants have different outcomes from the other types of grants and were not evaluated as part of this
review.
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The Recovery Act provided $100 million for EPA's Brownfields Program. EPA
competitively awarded communities $87.3 million in brownfields grants. EPA
awarded 89 Recovery Act environmental assessment grants, 37 cleanup grants,
and 45 RLF grants.
The Assessment, Cleanup and Redevelopment Exchange System (ACRES) is an
online data management system that OBLR uses to track selected outputs and
outcomes from grants. Grant recipients electronically submit a Property Profile
Form to report outputs and outcomes. Outputs are environmental activities,
efforts, and/or associated work products related to an environmental goal or
objective that will be produced or provided over a period of time or by a specified
date. Outputs reported in ACRES include number of properties assessed, cleanups
completed, and additional cleanup funding leveraged. Outcomes are the result,
effect, or consequence that will occur from carrying out activities under the grant.
Outcomes reported include minimization of the public's exposure to
contaminants, the number of acres made ready for reuse, and funds leveraged
through the economic redevelopment and reuse of properties.
The Government Performance and Results Act of 1993 requires strategic planning
and performance measurement in the federal government. EPA identified five
goals in its strategic plan. The Brownfields Program is included under EPA's
healthy communities' goal. In its efforts to achieve sustainable and livable
communities, EPA established strategic measures for its Brownfields Program
(see table 1). The results for these measures are consolidated and included in
EPA's Annual Performance and Accountability Report and congressional
justification.
Table 1: Brownfields performance measures
Measure
Definition
Properties Assessed
Number of properties that have been environmentally
assessed using EPA brownfields funding.
Properties Cleaned Up
Number of properties that have been cleaned up to a
regulatory-based standard using EPA brownfields funding.
Dollars Leveraged
Number of additional dollars leveraged at brownfields
properties as a result of EPA brownfields grant activities.
Acres Made Ready for
Reuse
Acres associated with properties benefiting from EPA
brownfields that have been assessed and determined not to
require cleanup, or where cleanup has been completed and
institutional controls are in place, if required.
Source: Brownfields Program Measure Definitions, May 2009.
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Noteworthy Achievements
For the performance measures of properties assessed, cleanups completed, and
acres ready for reuse, the results EPA reported were generally accurate.2 Project
officers or recipients were able to provide the specific required supporting
documentation for the accomplishments reported in ACRES. The project officers
verified the accuracy of the information in ACRES. As indicated in table 2 below,
as of March 31, 2012, the Brownfields Program had either met or exceeded three
of its four Recovery Act goals:
Table 2: Performance results
Expected Output/Outcome
Goal
Actual
Properties Assessed
500 -750 properties
1080 properties
Cleanups Completed
30 - 50 properties
55 properties
Acres Made Ready for Reuse
500 - 750 acres
785 acres
Dollars Leveraged
$450 to $600 million
$275 million
Sources: EPA Recovery Act Program Plan, Brownfields and Land Revitalization, May 15, 2009,
and U.S. EPA American Recovery and Reinvestment Act Quarterly Performance Report FY 2012
Second Quarter.
The OBLR was able to achieve these results even before some of the grants'
project periods start to expire on September 30, 2012.
Scope and Methodology
We conducted this performance audit from October 2011 to August 2012 in
accordance with generally accepted government auditing standards issued by the
Comptroller General of the United States. 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 objective.
We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective.
We reviewed relevant federal regulations and guidance, the Office of Solid Waste
and Emergency Response's Federal Manager's Financial Integrity Act Assurance
Letter, the EPA Recovery Act Stewardship Plan, and the EPA strategic plan. We
interviewed OBLR staff and regional brownfields project officers. We also
contacted several grant recipients to collect supporting documentation for project
results.
To determine whether the results EPA reported from brownfields grants were
timely and accurate, we selected a stratified random sample of 20 grants from
171 Recovery Act assessment, cleanup, and RLF grants. We included at least one
2 We identified some minor discrepancies during our review but these were not significant enough to impact the
overall results EPA reports for the program.
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grant from each region. For each of the sampled grants, the team reviewed project
officer files and ACRES data. The reviews included:
•	Analyses of supporting documentation for assessments completed,
cleanups completed, dollars leveraged, and acres made ready for reuse
accomplishments.
•	Comparisons of accomplishments reported in ACRES with brownfields
cooperative agreement quarterly progress reports that recipients submitted
to regional project officers.
We reviewed EPA's Recovery Act quarterly reports to determine whether the
assessment, cleanup, and RLF grants achieved their intended goals. We verified
the information in EPA's quarterly reports to ACRES.
We reviewed EPA OIG reports for related prior audit coverage. EPA OIG issued
Report No. 1 l-P-0107, EPA Must Implement Controls to Ensure Proper
Investigations Are Conducted at Brownfields Sites, on February 14, 2011.
However, the recommendations cited in the report were not relevant to the
objectives of this audit.
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Chapter 2
Dollars Leveraged Data Reported in ACRES
Were Not Always Accurate
EPA project officers verified recipient reported outputs and outcomes for
Recovery Act brownfields assessments completed, acres ready for reuse, and
cleanups completed, but did not always verify dollars leveraged. EPA guidance
includes requirements for grant recipients to report, and for EPA project officers
to review, grant output and outcome information in ACRES. However, the
guidance does not specify the documentation needed to support dollars leveraged.
Recipients were unclear as to what could be counted as dollars leveraged, and
some project officers were not aware of the requirement to verify reported dollars
leveraged. As a result, OBLR and others may not be able to rely on the dollars
leveraged data in ACRES, which is reported to Congress and the public in EPA's
Annual Performance and Accountability Report.
Project Officers Are to Review Recipient Reported Data in ACRES
The Proposal Guidelines for Assessment, Cleanup, and RLF Grants (guidelines)
state that EPA must report on the success of its Brownfields Program through
measurable outputs and outcomes. Some of these include acres ready for reuse,
assessments completed, and dollars leveraged. The guidelines require recipients to
report site-specific accomplishments on Property Profile Forms and submit them
electronically to the EPA's ACRES reporting system. The Instructions for
Completing Brownfields Property Profile Form requires project officers to review
the submissions in ACRES. Grant recipients provided the information used in
EPA's annual performance plan and congressional justification. The annual report
stated that regional EPA project officers reviewed the data to verify activities and
accomplishments.
Project Officers Did Not Always Review Supporting
Documentation for Dollars Leveraged
Generally, we found that EPA project officers received and verified appropriate
supporting documentation for cleanups completed, acres ready for reuse, and
assessments completed. However, project officers did not always verify dollars
leveraged data that recipients reported in ACRES. In our sample of 20 grants,
6 grant recipients reported dollars leveraged. For four of those six grants, EPA
project officers did not review support for the dollars leveraged reported in
ACRES. For two of the four grants, EPA project officers approved ACRES
submissions, although neither the project officer nor the grant recipient had
appropriate documentation for the $7.6 million in leveraged funds.
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•	For one grant in Region 8, the recipient claimed $75.5 million dollars
leveraged. The grant recipient stated that the costs to the city were
approximately $68 million, which left $7.5 million in unsupported
leveraged funds reported in ACRES. The project officer explained that
ACRES submissions are reviewed and approved based upon the project
officers' knowledge of the sites, but project officers do not verify
leveraging results.
•	For one grant in Region 9, neither the EPA project officer nor the recipient
had documents supporting $141,000 in leveraged funds. According to the
grant recipient, the reported $141,000 was a mistake—it actually
represented the expenses incurred under the grant.
EPA project officers also approved the ACRES submissions of approximately
$464,600 in leveraged funds without first reviewing supporting documents.
•	For one grant in Region 1, the grant recipient originally reported $42,600
dollars leveraged. After the OIG requested support for the dollars
leveraged, the EPA project officer contacted the recipient for the
supporting documentation. Upon review, the EPA project officer
discovered that this amount was not accurate. The recipient changed the
dollars leveraged amount to $2,600, but the EPA project officer did not
provide documentation to support or verify the revised amount. The grant
recipient subsequently provided to the OIG the supporting documentation
for the $2,600 in dollars leveraged.
•	For one grant in Region 5, the EPA project officer did not verify $462,000
in leveraged funds that the recipient reported in ACRES. The recipient
provided the OIG the documentation to support the amount. When asked
how the project officer verified dollars leveraged, he replied that there was
no mechanism in place to verify this information.
Dollars Leveraged Guidance Was Not Clear
The guidance provided to recipients was not always clear on what could be
counted as dollars leveraged. The Property Profile Form General Instructions
(general instructions) provide recipients with instructions for completing the
Property Profile Forms, and list specific documents needed to support properties
assessed and cleanups completed. For example, a Phase I assessment report is
final when an environmental professional or state official has signed and dated the
report as required by Title 40 Code of Federal Regulations Section 312.21(c).
However, the general instructions were not clear on what documents EPA project
officers should review before approving dollars leveraged information entered
into ACRES. The general instructions defined dollars leveraged as:
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[T]hose non-EPA brownfields cooperative agreement funds and
activities that have some link or nexus to the efforts of an EPA
cooperative agreement-funded activity, or where the EPA
cooperative agreement-funded activity was a catalyst for the
leveraged accomplishments.
Though the general instructions did not provide specific examples of the types of
documents that would support claimed dollars leveraged, it provided the
following examples of sources of leveraged funds:
•	Other Federal (e.g., U.S. Department of Housing and Urban
Development Community Development Block Grants, U.S.
Department of Housing and Urban Development Brownfields
Economic Development Initiative Grants)
•	State/Tribal Funding (e.g., state brownfields cleanup grants,
state economic development grants)
•	Local Government (e.g., local bond/tax increment financing)
•	Private/Other (e.g., company X, developer Y, non-profit Z)
Some project officers did not review supporting documents for the dollars
leveraged because they did not believe there was a requirement to perform that
review. OBLR officials agreed with the OIG that it could develop specific
guidelines for more consistent reporting and review of dollars leveraged.
ACRES Dollars Leveraged Data May Not Be Accurate
OBLR cannot rely on the dollars leveraged data in ACRES if project officers do
not always review supporting documentation and validate the information
reported in ACRES. This information is used to measure progress against the
goals identified in EPA's strategic plan. The results of these goals are reported to
Congress and the public in EPA's Annual Performance and Accountability
Report. EPA's ability to achieve its goal of $450 to $600 million in dollars
leveraged by 2012 is jeopardized when the information that recipients report is
inaccurate.
Recommendation
We recommend that the Assistant Administrator for Solid Waste and Emergency
Response require the OBLR Director to:
1. Create and distribute a checklist to grant recipients and project officers that
defines dollars leveraged, and identifies specific types of supporting
documents needed to support claimed dollars leveraged.
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Agency Comments and OIG Evaluation
EPA's OBLR generally agreed with the accuracy of the findings and
recommendations in the report. OBLR is confident that the data reported by their
grantees are generally accurate and reflect the tremendous leveraging that follows
the brownfields funding. The office plans to develop a checklist for distribution to
grant recipients and project officers for Recovery Act awards. The checklist,
scheduled for completion by December 31, 2012, will define dollars leveraged
and identify specific types of supporting documents needed to support claimed
dollars leveraged. The Agency's actions, when implemented, will address the
recommendation.
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Chapter 3
EPA's Ability to Meet Dollars Leveraged Goal
Is Uncertain
OBLR may not meet its Recovery Act dollars leveraged goal. EPA uses the
information reported in ACRES to measure its success against its goals, but we
found that ACRES information was not always accurate. Because dollars
leveraged data may not be realized until after grants are completed, EPA must
rely on recipients to report this information after their grants are completed, which
may be as late as 2014. As a result, it may not be until 2014 or later that EPA will
know whether its Recovery Act dollars leveraged goal is met. Meeting the goal
will also be contingent upon grant recipients accurately reporting, and EPA staff
verifying, the accuracy of the reported information.
Data on Dollars Leveraged Are Not Complete
The fiscal year 2009 Brownfields Cleanup Grant Guidelines states that EPA must
report on the success of its Brownfields Program through measurable outputs and
outcomes, such as the amount of funding leveraged. The Proposal Guidelines for
Assessment, Cleanup, andRLF Grants state that many activities occur beyond the
grant period, and EPA may contact the recipient well after the grant period of
performance to collect this information. EPA reports on Brownfields Program
progress in the Annual Performance and Accountability Report.
According to information in ACRES as of March 31, 2012, 61 percent of the
dollars leveraged goal for Recovery Act brownfields grants was met.
Table 3: Dollars leveraged goal

Goal
Actual as of
March 31, 2012
Percent of goal as of
March 31, 2012
Dollars Leveraged
$450 to $600 million
$275 million
61
Sources: EPA Recovery Act Program Plan, Brownfields and Land Revitalization, May 15, 2009,
and U.S. EPA American Recovery and Reinvestment Act Quarterly Performance Report FY 2012
Second Quarter, ending March 31, 2012.
EPA developed its Recovery Act brownfields dollars leveraged strategic goal
based on OBLR's $900 million non-Recovery Act performance goal. OBLR staff
wanted Recovery Act measures and goals to be similar to those for their non-
Recovery Act grants. Based on the type and number of Recovery Act grants
awarded, OBLR staff selected a goal of 50-67 percent of the non-Recovery Act
goal.
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There are several reasons why EPA may not meet its goal for dollars leveraged.
As detailed in chapter 2, the guidance provided to recipients was not always clear
on what could be counted as dollars leveraged, which resulted in ACRES data
inaccuracies. In addition, EPA staff stated that the dollars leveraged from
redevelopment of brownfields sites will not be realized until after the grant is
completed, which for some of our Recovery Act sampled brownfields grants will
not be until September 30, 2014. OBLR relies on recipients to continue to report
results after grants have closed, even though there is currently no requirement for
recipients to do so. OBLR staff indicated that there was no legal mechanism in
place to enforce reporting after the grant is closed, even though the proposal
guidelines stated that EPA may contact the recipient for the information after the
grant is completed. Therefore, it may not be until 2014 or later that EPA will
know whether the dollars leveraged goal is met, and only if the recipients
accurately report and EPA staff verify the accuracy of the information. If EPA
reports that it did not meet its dollars leveraged goal, taxpayers may believe that
the Recovery Act did not fully meet all of its objectives.
Recommendation
We recommend that the Assistant Administrator for Solid Waste and Emergency
Response require the OBLR Director to:
2. Include a letter in closeout packages sent to grant recipients reminding
them of their responsibility to continue to report dollars leveraged as they
are realized.
Agency Comments and OIG Evaluation
OBLR generally agreed with the recommendation, but emphasized that EPA's
legal relationship with cooperative agreement recipients generally ends when the
cooperative agreement period of performance expires. The nature of how
brownfields projects attract leveraged funding often results in leveraged resources
coming to projects years after the initial assessment and cleanup activity have
ended. By December 31, 2012, OBLR said it intends to develop a letter, to
include in closeout packages for Recovery Act awards, reminding recipients of
their responsibility to continue to report dollars leveraged as they are realized.
The Agency's actions, when implemented, will address the recommendation.
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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
10
Require the OBLR Director to create and distribute
a checklist to grant recipients and project officers
that defines dollars leveraged, and identifies
specific types of supporting documents needed to
support claimed dollars leveraged.
Require the OBLR Director to include a letter in
closeout packages sent to grant recipients
reminding them of their responsibility to continue to
report dollars leveraged as they are realized.
Claimed
Amount
Ag reed-To
Amount
Assistant Administrator for 12/31/12
Solid Waste and Emergency
Response
Assistant Administrator for 12/31/12
Solid Waste and Emergency
Response
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
Agency Comments to Draft Report
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report, "EPA Can Improve Its
Reporting of Dollars Leveraged From the American Recovery and Reinvestment
Act Brownfields Program" Project No. OA-FY11-0696
FROM: Mathy Stanislaus
Assistant Administrator
TO:	Melissa Heist
Assistant Inspector General for Audit
Thank you for the opportunity to respond to the issues and recommendations outlined in the
subject audit report. Following is a summary of the Agency's overall position, along with its
position on each of the report recommendations. For those report recommendations with which
the Agency agrees, we have provided high-level intended corrective actions and estimated
completion dates to the extent that we can. For those report recommendations with which the
Agency does not agree, we have explained our position and proposed alternatives to
recommendations.
AGENCY'S OVERALL POSITION
In response to the OIG's Draft Report: "EPA Can Improve Its Reporting of Dollars Leveraged
From the American Recovery and Reinvestment Act Brownfields Program," EPA's Office of
Brownfields and Land Revitalization (OBLR) basically agrees with the findings and
recommendations in this report. OBLR is confident that the data reported by our grantees is
generally accurate and reflects the tremendous leveraging that follows the Brownfields funding.
Brownfields funds leverage additional assessment monies, which leverage cleanup monies which
leverage redevelopment monies, all from both public and private sources. Brownfields
assessment and cleanup funding is often the first money in a project. These funds, along with the
protections afforded by the Brownfields statute, help provide the risk assessment knowledge, and
necessary assurances needed to attract other sources of funds.
It is also important to note that EPA's legal relationship with a cooperative agreement recipient
generally ends when the cooperative agreement period of performance expires, and so reporting
of leveraged resources may lag well beyond the end of the cooperative agreement. Also, the
nature of how brownfields projects attract leveraged funding often results in leveraged resources
coming to projects years after the initial assessment and cleanup activity has ended. These facts
are mentioned in the report, but are understated. While we have confidence in the Program's
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overall leveraged dollar outcomes, given the extensive information collected throughout the
history of the Program, the OIG's research has highlighted ways OBLR can strengthen our data
collection efforts in this area. In response to the recommendations, we will work to improve the
information that we provide to cooperative agreement recipients and project officers regarding
consistent reporting of dollars leveraged.
OBLR agrees with the first recommendation that the Assistant Administrator for Solid Waste
and Emergency Response instruct the OBLR Director to include a letter in closeout packages
reminding recipients of their responsibility to continue to report dollars leveraged as they are
realized.
OBLR also generally agrees with the second recommendation that the Assistant Administrator
for Solid Waste and Emergency Response require the OBLR Director to create and distribute a
checklist to grant recipients and project officers that defines dollars leveraged, and identifies
specific types of supporting documents needed to support claimed dollars leveraged. We will
implement the recommended letter. As a condition of retaining and utilizing program income
beyond the grant period of performance, EPA does require that Revolving Loan Fund (RLF)
recipients continue to provide periodic updates to EPA post grant closeout. As stated above,
while EPA can strongly encourage our non-RLF recipients to continue reporting outcomes
through the ACRES database after the period of performance has expired, there is no way to
enforce compliance.
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
Intended Corrective
Action(s)
Estimated
Completion by
Quarter and FY
1.
Director of OBLR to create and
distribute a checklist to grant
recipients and project officers that
defines dollars leveraged and
identifies specific types of
supporting documents need to
support claimed dollars leveraged
The Brownfields
program will develop
a checklist for
distribution to
recipients and project
officers for ARRA
awards.
FY 2013-End ofQl
2.
Require the Director of OBLR to
include a letter in
closeout packages sent to grant
recipients
reminding them of their
responsibility to continue to
report dollars leveraged as they are
realized.
The Brownfields
program will develop
a letter to include in
closeout packages for
ARRA awards.
FY 2013-End ofQl
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Disagreements
No.
Recommendation
Agency
Explanation/Response
Proposed
Alternative




CONTACT INFORMATION
If you or your staff have any questions regarding this response, please contact David Lloyd at
202-566-2731 or Llovd.DavidR@epa.gov or Gail Cooper, Deputy Director at 202-566-0168
Cooper.GailAnn@epa.gov.
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Appendix B
Distribution
Office of the Administrator
Assistant Administrator for Solid Waste and Emergency Response
Deputy Assistant Administrator for Solid Waste and Emergency Response
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
Director, Office of Brownfields and Land Revitalization, Office of Solid Waste and
Emergency Response
Audit Follow-Up Coordinator, Office of Solid Waste and Emergency Response
Regional Administrator, Regions 1 — 10
Regional Audit Follow-Up Coordinators, Regions 1 — 10
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