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OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
Special Report
Congressionally Requested
Review of Selected Grants
Report No. 2005-S-00007
September 7, 2005

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Report Contributors:
Randy Holthaus
Kevin Lawrence
Abbreviations
EPA	Environmental Protection Agency
OIG	Office of Inspector General

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At a Glance
Catalyst for Improving the Environment
Why We Did This Review
In April 2005, the House
Committee on Transportation
and Infrastructure provided
the Office of Inspector
General with a sample of
15 grants EPA awarded to
nonprofit organizations. The
Committee asked us to
determine the purpose,
justification, and progress for
each of the grants.
The Committee requested a
report containing information
on each of the 15 grants.
Background
EPA awarded over $4.3
billion (about 51 percent of its
annual budget) in 2004 to
entities via assistance
agreements. Grants are a type
of assistance agreement, and
we use the terms
interchangeably in this report.
EPA awarded about 20
percent of its grants to
nonprofit entities accounting
for about 8 percent ($337
million) of the total grant
funds awarded.
Congressionally Requested Review of Selected
Grants
What We Found
This report contains factual information on 15 grants. The report does not contain
any audit findings.
EPA awarded these 15 grants to nonprofit organizations. These grants were
awarded by 10 different EPA offices and regions, and ranged from $6,622 to $5.3
million. EPA awarded all of the grants since 2004, except for one that was
awarded in 1998. EPA awarded 13 of the 15 grants competitively.
EPA and grantees provided a wide range of purposes for these grants, including
improving protection of regional watersheds and wetlands, educating and training
local youth to clean up polluted sites in their community, and improving human
health and the environment in a region of China.
EPA cited various statutory authorities for the grants, including the Clean Air Act,
National Environment Policy Act, Clean Water Act, and the Solid Waste Disposal
Act.
Some projects are still in the early phases of work while others are nearly
complete. Project periods for these grants range from 1 to 7 years.
What We Recommend
This report does not contain any recommendations.
For further information,
contact our Office of
Congressional and Public
Liaison at (202) 566-2391.
To view the full report,
click on the following link:
www.epa.qov/oiq/reports/2005/
20050907-2005-S-00007.pdf

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Selected Assistance Agreements Reviewed


EPA



No.
Grant #
Approved
Amount
Award Date
EPA Office
Grantee
1
83174401
$ 250,000
06/18/04
Office of Air and
Radiation
Iowa Foundation for
Educational Administration,
Inc.
2
83198401
150,000
09/08/04
Office of Air and
Radiation
The Nature Conservancy
3
83199301
3,500,000
08/12/04
Office of
International
Affairs
Environmental Defense
4
83231901
86,700
03/11/05
Office of
International
Affairs
Environmental Law Institute
5
82681701
259,994
09/11/98
Office of
Research and
Development
The Smithsonian Institution
6
83215401
275,072
01/14/05
Office of
Research and
Development
Resources for the Future
7
83177901
5,301,750
09/15/04
Office of Solid
Waste and
Emergency
Response
Association of State and
Territorial Solid Waste
Management Officials
8
83193101
140,000
08/04/04
Office of Water
Environmental Law Institute
9
83124701
25,000
08/17/04
Office of Water
National Black Environmental
Justice Network
10
83192601
240,000
09/22/04
Office of Water
Association of State Wetland
Managers, Inc.
11
97115301
20,000
09/10/04
Region 1
Lowell Parks and Conservation
Trust
12
96554501
150,000
09/22/04
Region 5
Milwaukee Community Service
Corps, Inc.
13
97825401
6,622
08/16/04
Region 8
Wyoming Association for
Environmental Education
14
96912701
29,400
12/10/04
Region 9
The Chartwell School
15
97086601
97,000
09/30/04
Region 10
Oregon Environmental Council
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Individual Assistance Agreement Summaries
Grant #: 83174401-0 to the Iowa Foundation for Educational Administration, Inc.
EPA competed and awarded a $250,000 grant to The Iowa Foundation for Educational
Administration, Inc. (the Foundation) to help Iowa continue reducing school bus emissions. The
purpose of this grant is to demonstrate the use of emission control technology and alternative
fuels, and to replace engines in three pre-1989 school buses. The Foundation was to assist
several school districts in retrofitting 126 school buses with diesel oxidation catalysts, and offer
school districts the option of using biodiesel fuel on moderate-emitting engines. EPA stated that
this project will reduce pollution from school buses and children's exposure to diesel exhaust,
and serve as a case study for other school districts nationwide.
EPA cited Clean Air Act Section 103(b)(3) as the statutory authority for this grant. Section 103
is entitled "Research, Investigation, Training, and Other Activities." Section 103 states that EPA
shall establish a research and development program for the prevention and control of air
pollution. Section 103(b)(3) states that EPA can make grants to States or other public or private
entities for that purpose.
The Foundation plans to spend the full amount that EPA provided, although differently than it
had initially planned. The March 2005 quarterly report from the grantee stated that bid costs
were lower than anticipated. As a result, the grantee planned to retrofit more buses with the
diesel oxidation catalysts than it first planned. Also, the engine replacement efforts failed; it
would have been too costly to switch old mechanical engines to new electronic controlled ones.
The grantee plans to use the $12,000 originally planned for three new engines (at $4,000 each) to
retrofit more buses with the diesel oxidation catalysts or to buy more biodiesel fuel. A final
report from the Foundation is due to EPA in July 2006.
According to the EPA project officer, this is a change to the scope of work and, therefore, is
significant. She stated that the grantee informed her in writing, as required, why it planned to
change its approach. Because the grantee proposed a new way to use the money that still met the
intent of the project, the project officer approved the change.
EPA issued a solicitation for this activity in 2003 and received 120 proposals, of which 113 were
eligible. EPA funded 17 of them. The original solicitation said that applications not selected
could be retained for 1 year and considered in 2004 should more funding arise. The Clean
School Bus Program was funded an additional $4,970,350 in fiscal year 2004 and EPA
recommended 20 more projects be funded, including this project.
The Foundation is located in Clive, Iowa. According to its grant application, Iowa is the only
State that tests emissions from school buses on a statewide basis. The Foundation stated that
while bus emissions have declined significantly, retrofit technology is needed to continue
progress toward the goal of having the cleanest bus fleet in the nation within 5 years.
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Grant #: 83198401-0 to The Nature Conservancy China Program
EPA competed and awarded a $150,000 grant to The Nature Conservancy to develop and deliver
alternative energy units to 5,000 households and 20 schools in the Yunnan community of China.
The goal of the grant is to reduce the exposure for 25,000 people of indoor smoke from home
cooking and heating. The Chinese public is the beneficiary of this grant. Indoor smoke from
solid fuels is a major risk factor contributing to the global and regional burden of disease. This
grant supports the Partnership for Clean Indoor Air, an initiative launched at the World Summit
for Sustainable Development in August 2002.
On its Web site, the Nature Conservancy stated the goals of this project differently than EPA.
The goals were: (1) reduce fuel wood use by 75 percent—the majority of which will be
accomplished by promoting alternative energy sources, but also in part by promoting fuel-
efficient stoves and fireplaces; (2) augment the supply and availability of fuel wood; and (3)
achieve net growth of forests in seriously deteriorated and natural forestland.
EPA cited two statutory authorities for this grant. First, Clean Air Act, Section 103, allows EPA
to "conduct, and promote the coordination and acceleration of, research, investigations,
experiments, demonstrations, surveys, and studies relating to the causes, effects (including health
and welfare effects), extent, prevention, and control of air pollution; [and] encourage, cooperate
with, and render technical services and provide financial assistance to air pollution control
agencies and other appropriate public or private agencies, institutions, and organizations, and
individuals in the conduct of such activities."
Second, the National Environmental Policy Act, Section 102(F) states that all Federal agencies
shall "recognize the worldwide and long-range character of environmental problems and, where
consistent with the foreign policy of the United States, lend appropriate support to initiatives,
resolutions, and programs designed to maximize international cooperation in anticipating and
preventing a decline in the quality of mankind's world environment."
According to the April 2005 status report (which covered the first six months of this 2-year
grant), the grantee reported that it installed alternative energy units at 1,212 households (of a
goal of 5,000) and 3 schools (of a goal of 20). Also, 1,412 households (of a goal of 20,000
households) had been educated about the health impacts of indoor air pollution, and 7,060 people
(of a goal of 100,000) have demonstrated knowledge of indoor air issues. The grantee estimated
that about 6,800 people are actually experiencing reduced exposure to indoor smoke. The
grantee stated it planned to begin monitoring indoor air quality by July 2005. However, the
grantee stated that "the impact on IAP [indoor air pollution] on health may not be easy to
monitor over the 2-year timeframe of the project... The traditional fireplace has deep-rooted
cultural traditions and therefore bold changes may result in problems on acceptance." Of the
$150,000 grant, $66,000 is for contractual services to conduct health impact assessments, air
monitoring, and household energy use audits.
The Nature Conservancy has been working in China's northwest Yunnan Province since 1998 to
protect the natural and cultural diversity unique to China. In recent years, China's ecosystems
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have been under increasing threat from expanding development and increased collection of
wood, according to the Conservancy's Web site.
Grant #: 83199301-0 to Environmental Defense
EPA competed and awarded a $240,000 grant to Environmental Defense to enhance the capacity
for economic and environmental policy-making in Ukraine and Russia, specifically for
evaluating the costs and benefits of environmental protection. Overall, EPA approved up to $3.5
million for this project, to be funded through incremental amendments over 5 years.
EPA provided seven statutory authorities to justify this grant. Because this is an international
grant, particularly relevant was Section 102(F) of the National Environmental Policy Act. That
section requires Federal agencies to provide worldwide support, when consistent with United
States policy, to prevent a decline in the environment. EPA's Decision Memorandum for this
grant stated, "EPA funding comes from the Department of State, under the authority of the
Freedom Support Act of 1992. This funding was provided to EPA for the purpose of supporting
environmental assistance in Ukraine and Russia."
Environmental Defense proposed achieving the grant's purpose by (1) developing analytical
approaches for valuing public health and environmental damages, (2) providing tools to help
decision-makers incorporate damage considerations into management practices, and (3) building
the ability of specialists to illuminate the economic benefits of near-term environmental
protection policies that avoid much greater damage in the future. Environmental Defense
emphasized health and environmental risk assessments and cost-benefit analyses as important
components to these activities. During the final stages of the project period, Environmental
Defense plans to evaluate the overall success of the project. The grantee will identify lessons
learned and create a long-term strategy to implement an economically sound environmental
protection process.
For the first quarter (October 1 through December 31, 2004) of this project period,
Environmental Defense reported it made progress on its health risk analysis in Ukraine. Also,
Environmental Defense completed an assessment of the effect environmental damage had on
human health and the economies within Ukraine and Russia. Finally, Environmental Defense
conducted a seminar in November 2004 where risk management methodologies were discussed
with representatives from Kiev and other selected cities. The grantee reported that a problem it
encountered was "the unstable political situation in Ukraine." It indicated the recent political
changes in Ukraine could affect the project in the near future.
Environmental Defense is a nonprofit organization headquartered in New York. It was founded
in 1967 and, as of 2004, represents over 400,000 members. In 2004, Environmental Defense's
total revenue was $50.5 million, only 1 percent of which came from Government and other
grants.
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Grant #: 83231901-0 to the Environmental Law Institute
EPA competed and awarded an $86,700 grant to The Environmental Law Institute (the Institute)
to build the environmental capacity of Moroccan nongovernmental organizations and
government agencies. The Institute has planned two work components to enhance the ability of
Moroccan nongovernmental organizations to manage activities and educate decision makers and
the public. First, the Institute will conduct a 3-day training workshop, in Morocco, for Moroccan
nongovernmental organizations active in environmental and health issues. Second, the Institute
will conduct a 10-day United States study tour for Moroccan environmental agency officials.
This tour will demonstrate the United States' approach to managing environmental issues.
EPA cited seven statutory authorities to justify this grant. Because this is an international grant,
particularly relevant was the National Environmental Policy Act, Section 102(F). This section
states, "all agencies of the Federal Government shall recognize the worldwide and long-range
character of environmental problems and, where consistent with the foreign policy of the United
States, lend appropriate support to initiatives, resolutions, and programs designed to maximize
international cooperation in anticipating and preventing a decline in the quality of mankind's
world environment." EPA related this project to sound foreign policy by stressing its support for
the June 2004 United States - Morocco Free Trade Agreement. Further, the grantee told us that
"Morocco is an Islamic state and this grant is good for diplomatic reasons as well as
environmental reasons. This grant shows goodwill between our countries." EPA stated that this
justification was not in the Institute's proposal, nor did EPA use that as a reason to award the
grant.
The Institute is still establishing the dates for the training workshop and study tour. Tentatively,
four Moroccan government officials will participate in the United States study tour. Since the
grant award, the Moroccan government requested the tour include an arid State, such as Arizona,
since the project would address water conservation issues in Morocco similar to those found in
Arizona. The recipient told us that going to Arizona is unlikely due to budget constraints, and
instead the participants will likely go to Maryland since it is close to the Washington, DC area.
Also, the Institute wanted to bring an interpreter for the 10-day tour but underestimated those
costs. EPA is working with the Institute to restructure the budget so interpreter costs are
covered.
EPA did not award this grant until about 6 months after it issued the solicitation for the grant.
According to the Institute, this delay jeopardized its ability to accomplish the work under the
proposed budget due to changes in costs over time. Specifically, Institute officials said that a
large portion of the budget is based on travel expenses (airfare and lodging), which fluctuate over
time, sometimes substantially. EPA stated that the Institute accepted the award in the amount of
$86,700 without notifying EPA of a change to the budget.
The Institute is a nonprofit organization headquartered in Washington, DC. Its total annual
budget is approximately $5.5 million. Funding is primarily derived from an internal publication
house, a membership association of environmental lawyers, private foundation grants, Federal
and local grants, and contracts and donations. The Institute was created in 1969 and has received
EPA grants since the 1970s. EPA provides about 16 percent of the Institute's total revenue.
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The Institute's project manager for this grant was previously employed as an Honors Law Clerk
for EPA's Office of International Environmental Law. She is now the Co-director of the
Institute's Africa program.
Grant #: 82681701-0 to The Smithsonian Institution
The Smithsonian Environmental Research Center (the Center) received EPA grant funding of
$259,994. According to EPA's 1998 Decision Memo, "the purpose of the solicited research is
the development of methods for assessing and reporting on the ecological condition of wetlands
in the Nanticoke River watershed of Delaware and Maryland." Further, this project "will
evaluate the efficacy of surveying and reporting on the condition of wetland resources at the
watershed-scale using protocols conducive to citizen-based volunteer monitoring.. .The proposed
work will provide new information on how changing the wetland condition might affect nutrient
loading into the Chesapeake Bay." EPA used a competitive process to award this grant.
EPA cited Clean Water Act, Section 104, as the statutory authority for this grant. Section 104,
entitled "Research, Investigations, Training and Information", allows EPA to make grants to
State water pollution control agencies, interstate agencies, other public or nonprofit private
agencies, institutions, organizations, and individuals, to focus on innovative demonstration and
special projects. According to EPA, projects can fall under one of the following 104(b)(3)
funding categories: Institutional Coordination; National Pollutant Discharge Elimination System
Permits; Environmental Management Systems; Monitoring and Assessment; Program Measures
and Environmental Indicators; and Public Participation/Outreach.
According to the project officer, the products should be completed in early Fall 2005. Two
journal articles should be ready for the EPA clearance process in August 2005. She stated that
the reason the work took longer than expected was because this type of assessment had not been
done before.
EPA awarded this grant in September 1998 initially for $100,946, although it planned to fully
fund the project at $224,997 over a 3-year period (October 1998 through September 2001). In
June 1999, EPA amended the grant and added $124,048. In July 2000, EPA added the remaining
$35,000 to the grant. In November 2003, EPA amended the grant to extend the project period to
September 2004. EPA extended the grant so the Center could complete the publishing of
documents resulting from the project and prepare a map showing the status of two types of
wetlands in the Nanticoke River watershed. In September 2004, EPA granted another no-cost
extension to lengthen the budget and project periods through September 2005.
The Center, located 25 miles from Washington, DC, lies along the western shores of the
Chesapeake Bay. According to the Center's Web site, 16 senior scientists and a team of more
than 180 researchers, technicians, and students conduct long-term descriptive and experimental
research addressing such issues as global change, maintaining productive fisheries, and
protecting fragile wetlands and woodlands.
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Grant #: 83215401-0 to Resources for the Future
EPA competed and awarded a grant of $275,072 to Resources for the Future to improve general
understanding of environmental behavior and how interventions and incentives can improve
environmental quality. This project will "investigate the role of regulatory, market, and social
pressures influencing voluntary cleanup of contaminated sites and participation in state cleanup
programs." In other words, this project will help determine what factors influence private firms
to redevelop and cleanup contaminated properties under State voluntary cleanup programs. This
research will identify gaps in policy and practice as well as site and community considerations
that will help State and local officials design and target their programs more effectively.
Resources for the Future also will create a database on voluntarily remediated sites that will be
useful for future research.
EPA cited Solid Waste Disposal Act, Section 8001, as the statutory authority for this grant.
Section 8001(a) lists 13 possible areas in which "research, investigations, experiments, training,
demonstrations, surveys, public education programs, and studies" can be conducted. Section
8001(a)(10) allows for studies related to improvements in land disposal practices for solid waste,
including "means for restoring areas damaged by such earlier or existing landfills" and "means
for rendering landfills safe for purposes of construction and other uses."
EPA competed this grant for research on Corporate Environmental Behavior by issuing a
solicitation in November 2003. Before award, the proposal was subject to an external peer
review. This study will have three phases. Phase 1 will result in three detailed case studies.
Phase 2 will use a national telephone survey to generalize from the case studies. Phase 3 will use
a Web-based survey to further elaborate on underlying motivations to voluntarily clean up sites.
RFF's proposal stated that the project will result in three distinct types of benefits: (1) policy
relevant information about the types of sites and organizations most readily attracted to voluntary
remediation programs, (2) literature on voluntary behavior, and (3) database on voluntary
remediation sites that will be useful for future studies.
According to the EPA project officer, there are no grant deliverables yet. He stated that
Resources for the Future hopes to have some preliminary results ready to present at the 2005
National Brownfields Conference in November 2005, about 5 months prior to the due date of the
first progress report to EPA.
Of the $275,072 grant, the approved budget listed $34,200 in contractual costs. According to the
project officer, the $34,200 is for a consultant to design a survey ($25,200), and for an intern
working with the consultant ($9,000).
Resources for the Future's mission statement is to improve environmental and natural resource
policymaking worldwide through objective social science research of the highest caliber. Since
1952, this grantee's scholars have addressed issues in environmental and natural resource public
policy. The grantee publishes its research in peer-reviewed journals and other publications. It
also presents its findings through seminars and conferences, as well as by testifying before
Congress.
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Grant #: 83177901-0 to the Association of State and Territorial Solid Waste Management
Officials
EPA awarded a 5-year, $5,301,750 grant to the Association of State and Territorial Solid Waste
Management Officials (the Association) to promote the exchange of information between State
and EPA hazardous and solid waste officials so they can jointly resolve implementation issues
and identify emerging issues both entities face. According to EPA, it is imperative that States
are kept fully informed of, and participate in developing, EPA regulations, policies, and
guidance. This grant primarily funds the travel and per diem of State officials, and secures
meeting facilities and materials. EPA has funded $2,261,000 to date. EPA did not compete this
award; rather, it justified awarding it non-competitively based on the organization representing
the interests of co-regulators.
EPA cited the Solid Waste Disposal Act, Section 8001, as the statutory authority for this grant.
Section 8001(a) lists 13 possible areas in which "research, investigations, experiments, training,
demonstrations, surveys, public education programs, and studies" can be conducted. The
Association provides training conferences on 13 areas, such as: the planning, implementation,
and operation of hazardous waste management systems; and the development and application of
new methods of collecting and disposing of solid waste.
According to the grantee's most recent quarterly report—covering activity from February through
April 2005—the Association, among other things: held a mid-year meeting on April 20 and 21,
2005 in Keystone, Colorado, which was attended by over 130 State and EPA waste officials; and
the Hazardous Waste Subcommittee continued to solicit additional State volunteers to collect
workload and funding information in the areas of corrective action/closures, permitting,
inspections, enforcement and program development for the Association's Resource Conservation
and Recovery Act Core Program Project.
EPA is incrementally funding this 5-year grant. According to the Association, the EPA project
officer at times sends an e-mail out to EPA's program offices asking if they have any money
they want the Association to use to fund State travelers for EPA meetings. If so, EPA will
amend this grant and add funds and have the Association pay for the travel of State officials to
such meetings. For example, the Association reimbursed 34 State officials after they attended
EPA's National Corrective Action Conference in Denver in May 2005. The total EPA funding
amounted to $26,114.
The Association must match 5 percent of the EPA funded amount. The Association uses in-kind
services to do this, counting any hours State employees do not get reimbursed to travel and
attend meetings under this grant. The Association asks State employees to fill out a form
showing this time and uses $50 per hour as the rate for each in-kind hour. The grantee told us
they researched this rate and said it is the average hourly rate for an engineer.
The Association, headquartered in Washington, DC, has received EPA grants since the early
1980s. EPA currently provides 85 percent of the Association's funding.
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Grant #: 83193101-0 to the Environmental Law Institute
EPA competed and awarded a $140,000 grant to The Environmental Law Institute (the Institute)
to improve the ability of State and local governments to strengthen compensatory mitigation and
conduct research on the elements of a comprehensive State wetland program. This grant
continues work the Institute conducted under previous Wetland Program Development grants,
including the first phase of an evaluation of State wetland programs. The Institute holds the
Stakeholder Forum on Wetland Mitigation and the National Symposium on Compensatory
Wetland Mitigation annually through the grants. The extent of future grant work to continue
building on these components will be influenced by EPA's availability of funds for the Wetland
Development Program.
EPA cited the Clean Water Act, Section 104(b)(3) as the statutory authority for this grant. That
Section provides authority to award grants to nonprofit organizations for activities including
research, training and demonstrations relating to causes, effects, prevention, reduction, and
elimination of pollution. According to EPA, "This funding to the Environmental Law Institute
would provide continued technical assistance to benefit states, tribes and local governments in
their efforts to prevent wetland degradation and loss by improving their ability to protect and
restore wetlands."
The Institute proposed three primary components to achieve its objectives. Those components
were the second phase of an evaluation of State wetland programs (including regulatory, water
quality, monitoring/assessment, and other relevant State programs); continued research on
approaches for making compensatory wetland mitigation decisions, compiled for presentation at
a National symposium; and, organizing and administering the Fourth Stakeholder Forum on
Wetland Mitigation.
The Institute is progressing with its research on wetland programs in 12 States. When it
completes the research, it will compile and publish the Phase II report. The Institute is compiling
wetland research data to be presented at the National Symposium on Compensatory Wetland
Mitigation. Finally, the Institute held the Fourth Stakeholder Forum on Federal Wetlands
Mitigation in September 2004. By April 2005, the Institute finalized and distributed the report
detailing efforts from the Forum.
The overall budget for this project totaled $186,663. EPA funded $140,000, while the Institute
contributed $46,663 towards the total cost of this project. In April 2005, EPA issued a no-cost
extension to the project period, changing the project end date from April 30 to October 31, 2005.
However, no changes have been made to the project's objectives.
Grant #: 83124701-0 to the National Black Environmental Justice Network
EPA awarded $25,000 to the National Black Environmental Justice Network (the Justice
Network) to facilitate the development of a constituency that will ensure source water protection
issues are a priority among disadvantaged communities. EPA did not compete this award.
Instead, EPA justified awarding it noncompetitively because it was under the competition dollar
threshold and was an unsolicited proposal.
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EPA cited Section 104(b)(3) of the Clean Water Act as the statutory authority for this grant.
That Section authorizes EPA to make grants to nonprofit organizations for training and
demonstrations related to the causes, effects, extent, prevention, reduction, and elimination of
pollution. EPA also cited Section 1442 of the Safe Drinking Water Act which authorizes grants
for training State or State-delegated water enforcement officials.
The Justice Network proposed two types of work to achieve its goal. First, it planned to prepare
educational materials regarding source and drinking water protection issues. The materials will
include general background information as well as strategies designed to improve source water
protection in disadvantaged communities. Second, the Justice Network planned to organize an
educational/training workshop on source and drinking water protection issues. Of the $25,000
awarded to this grantee, $5,000 was allocated to the production of educational materials and
$20,000 was allocated for the workshop. The Justice Network will emphasize the need for key
stakeholders to understand the urgency of source and drinking water protection problems in
disadvantaged communities.
According to the Justice Network's mid-year progress report dated March 28, 2005, it proceeded
with planning and preparing materials to distribute at the educational/training workshop. The
workshop was held on July 1, 2005 in New Orleans, Louisiana, coinciding with the Justice
Network's annual meeting.
The Justice Network is a coalition of environmental justice organizations, made up of members
of African descent. It is a nonprofit membership organization, headquartered in Washington,
DC, and was created in 1999. The Justice Network is composed of national and local leaders,
policy advocates, youth and students, clergy, labor, civil rights activists, academics, legal
experts, environmental and public health professionals, and representatives from other
constituencies in disadvantaged communities.
Grant #: 83192601-0 to the Association of State Wetland Managers, Inc.
EPA competed and awarded a $240,000 grant to the Association of State Wetland Managers,
Inc. (the Association) to assist in developing State and local programs to enhance the overall
capacity to protect wetlands. EPA has funded $199,100 of the total.
EPA cited the Clean Water Act, Section 104(b)(3) as the statutory authority for this grant. That
section provides authority to award grants for activities including training and demonstrations
relating to causes, effects, prevention, reduction, and elimination of pollution. EPA added, "This
funding to the Association of State Wetland Managers would provide continued technical
assistance to benefit states, tribes and local governments in their efforts to prevent wetland
degradation and loss by improving their ability to protect and restore wetlands."
To accomplish its goal, the Association proposed facilitating communication between States,
Federal agencies, wetland professionals and other stakeholders. The Association's planned
strategies included conducting meetings, workshops and conferences; writing materials on
wetland issues; and, using technology such as its Web site.
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On December 27, 2004, the Association submitted to EPA a brief narrative regarding its first
quarter progress on this grant. The Association reported it reimbursed travel for five participants
at the Land Trust Alliances Annual Land Trust Rally, provided support for the Wetland 2004
conference, conducted planning for a legal conference, and coordinated work on a wetlands and
development brochure.
The initial award provided $164,100 of the $240,000 amount. On April 13, 2005, EPA amended
this grant to provide an additional $35,000, bringing the total amount funded to $199,100.
The Association, established in 1983, is a nonprofit membership organization located in
Windham, Maine. The Association works to protect and manage wetlands by promoting sound
wetland management efforts and training and educating its members and the public.
The Association's project manager for this grant worked at EPA from 1988 to 1995. When she
left EPA in 1995, she was the Acting Branch Chief of the Wetland Strategies and State Programs
Branch, Wetlands Division. In addition to this relatively new grant, the project manager is also
the contact for at least three other EPA grants, which are in their final stages.
Grant #: 97115301-0 to the Lowell Parks & Conservation Trust
EPA competed and awarded a $20,000 grant to the Lowell Parks & Conservation Trust (the
Lowell Trust) to restore, maintain, and enhance the ecological integrity of the Concord River in
Lowell, Massachusetts. EPA awarded the grant to contribute to the design of a bike path to
reduce vehicle miles traveled, consequently reducing vehicle emissions; protect open space and
water quality; and redevelop Brownfields. The grantee also proposed conducting a "river clean-
up" along the path, to include removing debris from the river bank and taking steps to prevent
future dumping.
EPA cited Clean Air Act Section 103 and Clean Water Act Section 104 as the statutory
authorities for this grant. Section 103(a)(2) of the Clean Air Act authorizes financial assistance
to public or private agencies for conducting activities to prevent and control air pollution.
EPA, in its Funding Recommendation, linked this project to EPA Strategic Plan Goal 4,
"Healthy Communities." Goal 4 strives to protect, sustain, or restore the health of people,
communities, and ecosystems using integrated and comprehensive approaches and partnerships.
The status report covering activity from January through March 2005 indicated that most of the
progress was in planning and public outreach. The Lowell Trust conducted these activities to
gain support for the project.
The total budget for this project is $26,142. EPA awarded $20,000 and the recipient contributed
an additional $6,142. The Lowell Trust's second quarterly report indicated funding for the
overall greenway project was also received from other sources, such as the National Park
Service.
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The Lowell Trust, located in Lowell, Massachusetts, is a nonprofit membership organization
whose mission is to "improve the quality of life for the people of Lowell through the
conservation, creation, and preservation of parks, open space, and special places." Further, the
Lowell Trust "supports projects that provide people opportunities to remain connected to the
land on which the city was built."
Grant #: 96554501-1 to the Milwaukee Community Service Corps
EPA competed and awarded a $150,000 grant to the Milwaukee Community Service Corps (the
Service Corps) to educate and train at-risk young adults in the Milwaukee, Wisconsin, area to
work in Brownfields remediation. This ongoing project runs from October 1, 2004, through
September 30, 2006, and has been funded through previous EPA grants.
The original Award Document incorrectly cited the City of Milwaukee as the recipient. EPA
issued a no-cost grant amendment to correctly show that the Service Corps was the recipient.
EPA stated that this was simply an administrative error and all funds actually went to the Service
Corps.
EPA cited Section 104(k)(6) of the Comprehensive Environmental Response Compensation and
Liability Act as the statutory authority for this award. That Section provides authority to fund
nonprofit organizations for training individuals and organizations to remediate Brownfields.
The Service Corps plans to train eight groups of young adults during this project. Through
relationships with the City of Milwaukee and various environmental contractors, the Service
Corps guarantees that program participants will be employed after they complete its training
program.
Since this project is still relatively new, progress is still in its early stages. The first quarter
status report indicated that a group of eight trainees began the training program. Two of those
dropped out bringing the total to six. Another eleven trainees, making up a second group, have
been enrolled in the program.
The Service Corps is a private, nonprofit organization headquartered in Milwaukee. The Service
Corps provides young people with opportunities to learn new skills and earn wages through
various community services.
Grant #: 97825401-0 to the Wyoming Association for Environmental Education
EPA competed and awarded a $6,622 grant to The Wyoming Association for Environmental
Education (the Association). According to EPA, this project is the first step necessary in
building the capacity of the State of Wyoming's environmental education profession to identify
model programs, identify duplication, and find gaps in educational programs. The goals of this
project are to (1) identify new environmental education leaders and assess their needs for
professional development, (2) create a communication network among environmental education
professionals, (3) evaluate the status of environmental education programs within the State, and
(4) create a statewide strategic plan for environmental education for the next 3-5 years. One
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additional goal stated in the grantee's application is "to expand the membership of [the
Association]." The grantee's application also stated the "intent of this project is to build capacity
by strengthening the organizational structure of [the Association] and better enable it to meet its
mission..." According to the EPA project officer, the idea for this grant originated with
educators on the Association's Board of Directors.
EPA cited Section 6 of the National Environmental Education Act as the statutory authority for
this grant. Section 6(b) of the Act lists five different areas that support eligible activities.
According to the project officer, this project would fall under #1—design, demonstration or
dissemination of environmental curricula, including development of educational tools and
materials; and #4—provision of training or related education for teachers, faculty, or related
personnel in a specific geographic area or region.
The grantee's final report is due to EPA by November 30, 2005. As of mid-June 2005, the
Association held 10 town-hall meetings for educators throughout Wyoming. The Association
stated in its application that it will measure the success of the project in terms of the number of
people who attend the town hall meetings, the return rate of the surveys describing
environmental education available in the communities, and the number of people who become
members of the Association. The goal of the grant was to reach 175-200 people around the
State.
The project officer said that the Association's recent midterm report was unacceptable because it
did not contain required information. The project officer stated that she will ask for additional
information, such as sign-in sheets, photographs, names of assistants, and receipts, when
necessary.
EPA funds are being spent on a stipend plus travel costs for the facilitator to conduct meetings in
communities, and to develop materials for the meetings. According to the project officer,
environmental education grants above $5,000 were considered large based on the Environmental
Education Act of 1990.
The Association, located in Jackson, Wyoming, was founded in 1995 to promote environmental
education statewide. The grantee provides a communication network among environmental
educators; creates partnerships among agencies and schools to increase the effectiveness of
programs; and generates support for environmental education at local, State, and regional levels.
Grant #: 96912701-0 to The Chartwell School
On December 10, 2004, EPA competed and awarded a grant of $29,400 to the Chartwell School.
EPA stated that the purpose of this grant was to develop a Design for Disassembly Resource
Handbook and a detailed case study of the process of deconstructing the current campus
buildings and designing a new campus. This project will "investigate how to increase diversion
of construction materials from landfills and recycle material." The handbook will compile tips
for building professionals on how best to construct and deconstruct the buildings so that
materials are not wasted and can be reused.
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EPA cited Solid Waste Disposal Act, Section 8001, as the statutory authority for this grant.
Section 8001(a) lists 13 possible areas for which "research, investigations, experiments, training,
demonstrations, surveys, public education programs, and studies" can be conducted. Section
8001(a)(5) allows for studies related to reducing solid waste and unsalvageable waste materials.
Section 8001(a)(7) allows for the identification of solid waste components and of the potential
materials and energy that can be recovered from such waste.
The Chartwell School's proposal listed 11 tasks to complete. According to its most recent
progress report, dated June 25, 2005, 57 percent of the work had been completed, based on
dollars spent by task. Types of tasks completed include creation of a matrix listing types and
quantities of building materials; architectural drawings of windows, skylights, roofing, structural
insulated panels, wood framing, and trusses; physical mock-ups of exterior siding and interior
wood paneling; and outreach on the project including project information being published in
Architectural Record. The project end date is March 1, 2006. However, the project officer
stated that the project team is hoping to close out the project before the end of 2005.
The original award approved costs incurred back to October 1, 2004. On March 22, 2005, EPA
amended the grant to approve costs back to May 1, 2004. The total assistance amount, however,
remained the same.
The Chartwell School, founded in 1983, is located in Seaside, CA. The School's mission is to
educate children with dyslexia in a way that enables them to return successfully to mainstream
education. The Chartwell School was one of 3 applicants that EPA selected in the competition
of 42 initial proposals.
Grant #: 97086601-0 to the Oregon Environmental Council
EPA competed and awarded $97,000 to the Oregon Environmental Council (the Council) to
significantly reduce diesel pollution from stationary sources to improve the health of Portland
metropolitan residents within high-risk communities. The Council described high-risk
communities as ".. .the lower-income Albina community, children, and the elderly."
EPA cited Section 103 of the Clean Air Act to justify this grant. Section 103 allows EPA to
provide grants to nonprofit organizations for demonstrations and studies relating to causes,
effects, extent, prevention, and control of air pollution.
EPA, in its Funding Recommendation, linked this project to EPA Strategic Plan Goal 1, "Clean
Air and Climate Change." Goal 1 strives to protect and improve the air so it is healthy to breathe
and risks to human health and the environment are reduced. Further, it strives to reduce
greenhouse gas intensity by enhancing partnerships with businesses and other sectors.
To achieve its objective, the Council planned to assess stationary diesel sources by collaborating
with stakeholders. For the remainder of the project, the Council planned to work with
stakeholders to develop and implement strategies to reduce pollution from stationary diesel
sources. This project is similar to and a continuation of prior work the Council has conducted
through EPA grants.
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EPA requires the Council to provide progress reports once per year. In April 2005, the Council
provided EPA with a report describing its assessment of stationary diesel sources in Portland.
Consistent with the work planned for this project, the report detailed the extent stationary diesel
sources are used in the Portland area and described the network/relationships the Council
developed with stakeholders.
The Council contributed an additional $53,500, bringing the total budget to $150,500. The
Council identified the following sources for its contribution to this project.
•	Donated in-kind staff time from partner organizations and stakeholders ($10,000)
•	Donated in-kind publicity, design, printing, and postage ($25,000)
•	Existing Council grants ($15,000)
•	Grants, corporate donations, and other funding to be secured by the Council ($3,500)
The Council is a nonprofit membership organization founded in 1968. Members are located
throughout Oregon. The Council collaborates with Federal agencies, businesses, professional
organizations, legislators and experts to achieve a cleaner, healthier environment within Oregon.
Scope and Methodology
The objective of our work was to identify the purpose of each assistance agreement, the statutory
authority that EPA cited to justify each agreement, and the progress each grantee made under the
agreements. This work was not an audit in accordance with generally accepted Government
auditing standards. We did not conduct this work with the intent of providing an independent
assessment of the performance of a Government organization or activity, as required by
generally accepted Government auditing standards. We performed our work from May through
July 2005.
To complete our work, we obtained the Award Document for each grant from EPA's Integrated
Grants Management System. We did not independently verify the accuracy of the data in the
Integrated Grants Management System. We obtained the Agency's Decision Memorandum, or
its Funding Recommendation, as well as the grantee's application/proposal and most recent
progress report from the EPA project officer for each grant. We also visited two grant recipients
in Washington, DC, and interviewed them about how they executed the grants. We gave EPA
the opportunity to review and comment on our draft report. We considered EPA's comments
and revised the draft report, as appropriate.
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