j A *
1
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Congressional Request and Hotline Report:
Operating Efficiently and Effectively
Follow-Up Audit:
EPA Took Steps to Improve
Records Management
Report No. 19-P-0283	August 27, 2019
Status of OIG Audit Recommendations

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Report Contributors:
Rudolph M. Brevard
Jeremy Sigel
Sabrena Stewart
Abbreviations
AFC
Audit Follow-Up Coordinator
CIO
Chief Information Officer
EPA
U.S. Environmental Protection Agency
FOIA
Freedom of Information Act
NRMP
National Records Management Program
OGC
Office of General Counsel
OIG
Office of Inspector General
OMB
Office of Management and Budget
Cover Image: The graphic shows completed corrective actions for 13 of 13 audit
recommendations related to the EPA's records management and FOIA
practices; 11 were completed before the audit and two were completed during
the audit. (EPA OIG graphic)
Are you aware of fraud, waste or abuse in an
EPA program?
EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW (2431T)
Washington, DC 20460
(888) 546-8740
(202) 566-2599 (fax)
OIG Hotline@epa.gov
Learn more about our OIG Hotline.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (2410T)
Washington, DC 20460
(202) 566-2391
www.epa.gov/oiq
Subscribe to our Email Updates
Follow us on Twitter @EPAoig
Send us your Project Suggestions

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^DS7X
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
19-P-0283
August 27, 2019
Why We Did This Project
The Office of Inspector
General (OIG) performed
this audit to determine whether
the U.S. Environmental
Protection Agency (EPA)
took action to complete OIG
recommendations regarding the
preservation of email and text
messages, and the improvement
of the agency's Freedom of
Information Act (FOIA) process.
We followed up on actions the
agency took to address the
13 recommendations from the
following prior reports:
1)	No. 13-P-0433.
Congressionally Requested
Inquiry Into the EPA's Use
of Private and Alias Email
Accounts.
2)	No. 14-P-0262. Briefing
Report: Review of EPA's
Process to Release
Information Under the
Freedom of Information Act.
3)	No. 17-P-0062.
Congressionally Requested
Audit: EPA Needs to
Improve Processes for
Preserving Text Messages
as Federal Records.
This report addresses the
following:
 Operating efficiently and
effectively.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.oiq.
Follow-Up Audit: EPA Took Steps to Improve
Records Management
What We Found
The EPA completed all corrective actions for	The EPA's FOIA guidance
13 past audit recommendations related to its	needs updating to comply
records management and FOIA practices. Two with federal requirements,
recommendations from Report No. 17-P-0062,
Congressionally Requested Audit: EPA Needs to Improve Processes for
Preserving Text Messages as Federal Records, with corrective action
completion dates of September 30, 2018, were completed by the established
milestone dates during our audit.
In Report No. 14-P-0262, we recommended that the EPA create an agencywide
FOIA policy and procedure. On September 30, 2014, the EPA's Chief
Information Officer (CIO) issued agencywide directives in the form of a FOIA
policy (CIO 2157.1) and a FOIA procedure (CIO 2157-P-01.1), which satisfied
the intent of the original recommendation.
While the EPA completed corrective actions on all of the past recommendations,
the FOIA statute changed in 2016 and the EPA updated its FOIA regulations in
June 2019. Consequently, the EPA's FOIA policy and procedure again require
management review to determine whether updates are needed.
Recommendation and Planned Agency Corrective Actions
We recommend in this report that the General Counsel issue an updated
agency Freedom of Information Act policy and procedure. The agency agreed
with the OIG's findings and recommendation. Management stated it updated the
agency's FOIA regulations on June 26, 2019, and plans to issue a new FOIA
policy and procedure. The agency provided us with December 5, 2019, as the
planned completion date for issuing the FOIA policy and procedure updates. We
consider the recommendation resolved with corrective actions pending.
List of OIG reports.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
August 27, 2019
MEMORANDUM
SUBJECT: Follow-Up Audit: EPA Took Steps to Improve Records Management
Report No. 19-P-0283
FROM: Charles J. Sheehan, Deputy Inspector General
TO:
Matthew Z. Leopold, General Counsel
Office of General Counsel
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). The project number for this audit was
OA&E-FY18-0217. This report contains findings that describe the problems the OIG has identified and
improvements 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.
The EPA's Office of General Counsel is responsible for the issues discussed in this report.
In accordance with EPA Manual 2750, your office provided acceptable corrective actions and milestone
dates in response to the OIG recommendation. The recommendation is resolved and no final response to
this report is required. However, if you submit a response, it will be posted on the OIG's website, along
with our memorandum commenting on your response. Your response should be provided as an Adobe
PDF file that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of
1973, as amended. The final response should not contain data that you do not want to be released to the
public; if your response contains such data, you should identify the data for redaction or removal along
with corresponding justification.
We will post this report to our website at www.epa.gov/oig.

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Follow-Up Audit: EPA Took Steps to
Improve Records Management
19-P-0283
Table of C
Purpose		1
Background 		1
Responsible Offices		2
Scope and Methodology		3
Results		4
Recommendation		5
EPA Response and OIG Evaluation		5
Status of Recommendations and Potential Monetary Benefits 		6
Appendices
A Evaluation of EPA Corrective Actions for Selected OIG Reports 		7
B Agency Response to Draft Report		14
C Distribution		16

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Purpose
The Office of Inspector General (OIG) performed this audit to determine whether
the U.S. Environmental Protection Agency (EPA) took action to complete OIG
recommendations regarding the preservation of email and text messages, and the
improvement of the agency's Freedom of Information Act (FOIA) process.
Background
We conducted this follow-up audit, in part, to address a congressional inquiry.
The inquiry requested that the OIG review EPA practices for complying with
legal standards for preserving certain electronic records as federal records and
responding to FOIA requests for information. After the congressional inquiry, the
OIG also received a hotline complaint involving the EPA's compliance with
federal records requirements and FOIA.
The inquiry and complaint made allegations against the EPA Administrator's
office in general and former EPA Administrator Scott Pruitt in particular. Since
Mr. Pruitt left the agency during the preliminary stages of this audit, we did not
review specific allegations made against him. Prior audits disclosed that
weaknesses existed in EPA practices involving records management and
electronic records preservation.
Our prior audits also noted that the EPA needed to take steps to strengthen its
FOIA process. During fiscal years 2013 through 2017, the OIG issued three
relevant audit reports with 13 recommendations (Table 1). These reports
recommended that the EPA strengthen its preservation of electronic records and
improve its records management and FOIA policy and procedure.
Table 1: EPA OIG reports and recommendations
EPA OIG report
Number of
recommendations
No. 13-P-0433, Conaressionallv Reauested Inauirv into the
EPA's Use of Private and Alias Email Accounts
(September 26, 2013)
5
No. 14-P-0262, Briefina Report: Review of EPA's Process to
Release Information Under the Freedom of Information Act
(May 16, 2014)
2
No. 17-P-0062, Conaressionallv Reauested Audit: EPA Needs
to Improve Processes for Preserving Text Messages as
Federal Records (December 21, 2016)
6
Total recommendations
13
Source: OIG analysis.
In response to our recommendations, EPA management provided corrective action
plans with milestone dates for completing the associated actions.
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After considering the congressional request and hotline complaint, we followed
up with the EPA, which is responsible for completing corrective actions, as
outlined in the following federal circulars and EPA manual:
	Office of Management and Budget (OMB) Circular A-123, Management's
Responsibility for Enterprise Risk Management and Internal Control,
dated July 15, 2016, states:
Correcting control deficiencies is an integral part of
management accountability and must be considered a
priority by the Agency. An Agency's ability to correct
control deficiencies is an indicator of the strength of its
internal control environment.
	OMB Circular A-50 Revised, Audit Followup, dated September 29, 1982,
states:
Audit followup is an integral part of good management...
Corrective action taken by management on resolved
findings and recommendations is essential to improving the
effectiveness and efficiency of Government operations.
	EPA Manual 2750, Audit Management Procedures, dated March 28, 2017,
states:
The Agency Audit Follow-Up Official is responsible for:
a)	Ensuring that agencywide audit management, resolution
and follow-up policies and procedures are in place... [and]
b)	Ensuring that audit reports are resolved promptly and
implemented in a manner that satisfies requirements of
statutes and agency regulations; ... [and] improves the
efficiency and effectiveness of the programs.
Responsible Offices
The Office of General Counsel (OGC) manages the agency's responses to FOIA
requests, develops and issues the agency's FOIA regulations and FOIA policy and
procedure, and compiles the EPA's annual report of FOIA activity to the U.S.
Department of Justice. The OGC is also responsible for the recommendations in
this report because the office assumed responsibility for the agency's FOIA
program on April 15, 2018.
In addition, the Office of Congressional and Intergovernmental Relations and the
Office of Mission Support were responsible for the 13 past audit recommendations
we followed up on during our audit.
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The EPA Principal Deputy Associate Administrator for the Office of
Congressional and Intergovernmental Relations is the action official designated to
complete corrective actions related to EPA processes for responding to
congressional requests for information.
The Office of Mission Support supports the National Records Management
Program (NRMP), which provides leadership and direction for managing records
that support the EPA's mission. The agency's Records Officer leads the NRMP in
accordance with EPA policy and federal statutes and regulations.
Scope and Methodology
We conducted our audit from June 2018 through June 2019. We conducted this
performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on our audit
objectives.
We coordinated with the following EPA offices and action officials responsible
for completing the corrective action plans for the 13 audit recommendations from
the three EPA OIG reports followed up on during this audit (Table 2).
Table 2: Listing of EPA offices reviewed
EPA OIG report
Office/action official
Number of
recommendations
No. 13-P-0433
Office of Mission Support
5
No. 14-P-0262
Office of General Counsel *
2
No. 17-P-0062
Deputy Administrator
1
Office of Mission Support
5
Total number of recommendations
13
Source: OIG analysis.
* After the OIG issued Report No. 14-P-0262, the OGC assumed responsibility for the EPA's
FOIA program.
We met with EPA officials to discuss what steps the agency had taken to
complete the corrective actions. We obtained documentation from EPA officials
to confirm management had completed corrective actions. We also reviewed EPA
policies and procedures for addressing records management, email records, text
messages and FOIA. For recommendations that the EPA indicated it completed
before we started the audit, we did not review whether management completed
the planned actions by the established milestone dates.
We obtained corrective action plans from the agency for all three prior audits. For
Report No. 17-P-0062, we researched the status of corrective actions for two
19-P-0283
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recommendations that were not completed before the start of this follow-up audit,
within the agency's Management Audit Tracking System.
We considered a corrective action completed if EPA officials provided
documentation to substantiate completion of all steps for the planned corrective
actions. We did not consider a corrective action completed if management could
not provide all relevant documentation to support that the corrective action was
completed.
For corrective actions that we considered as either "not complete" or "pending
further action," we summarized our understanding of management's progress in
completing the corrective actions and provided the summary to EPA officials for
comment.
Results
The EPA completed all the corrective actions for the 13 audit recommendations
related to its records management and FOIA practices. See Appendix A for the
detailed status of each audit recommendation.
In Report No. 14-P-0262, we recommended that the EPA create an agencywide
FOIA policy and procedure. The original planned completion date was
September 30, 2014. On September 30, 2014, the EPA's Chief Information
Officer (CIO) issued agencywide directives in the form of a FOIA policy
(CIO 2157.1) and a FOIA procedure (CIO 2157-P-01.1). This satisfied the intent
of the original recommendation.
However, the agency's FOIA policy and procedure had a review date of
September 30, 2017, to determine whether updates are needed. According to
agency personnel, the review was not completed due to a change in the FOIA
program's responsible office. Neither the Office of Mission Support (the
originally responsible office) nor the OGC (the newly appointed responsible
office) completed the required review to the policy and procedure.
We presented our findings to the EPA regarding the need for the policy and
procedure to be updated. The OGC provided us with a February 15, 2019,
memorandum that reaffirmed the 2014 FOIA policy and procedure were required
to be updated. The February 15, 2019, memorandum, also issued guidance from
the OGC on the FOIA Improvement Act of 2016 and stated that the OGC was
developing changes to the agency's FOIA regulations. The OGC indicated that
once the updated FOIA regulations take effect, the EPA's National FOIA Office
would fully review and revise the agency's current FOIA policy and procedure.
Subsequent to issuance of our draft report, the EPA published its finalized FOIA
regulations.1
1 84 Fed. Reg. 30028 (Jun. 26, 2019).
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It is still incumbent upon management to follow through with its plans to issue an
updated agency FOIA policy and procedure so EPA employees know the correct
process to follow. Keeping policies and procedures current is a major component
of an effective internal control program. As such, the EPA's ability to respond
correctly to FOIA requests could be hampered by not updating the associated
policy and procedure for compliance with the FOIA statute amended in 2016.
Recommendation
We recommend that the General Counsel:
1. Issue an updated agency Freedom of Information Act policy and
procedure.
EPA Response and OIG Evaluation
We originally recommended in this report that the OGC complete its review and
update of the agency's FOIA regulations and then issue an updated EPA FOIA
policy and procedure. The agency agreed with the OIG's findings and
recommendation. Management stated it updated the agency's FOIA regulations as
of June 26, 2019, and posted the new regulations on the agency's FOIA website.
As a result, we modified our recommendation to reflect the OGC's remaining
corrective action to issue an updated agency FOIA policy and procedure. Following
distribution of its response memo, the agency provided us with December 5, 2019,
as the planned completion date for issuing the FOIA policy and procedure updates.
We consider the recommendation resolved with corrective actions pending. The
agency's complete response is at Appendix B.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS




Potential



Planned
Monetary
Rec.
Page

Completion
Benefits
No.
No. Subject Status1
Action Official
Date
(in $000s)
1
5 Issue an updated agency Freedom of Information Act policy and R
General Counsel
12/5/19


procedure.



1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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Appendix A
Evaluation of EPA Corrective Actions for Selected 01G Reports
Recommendation
Corrective action
OIG evaluation
Report - Congressionally Requested Audit: EPA Needs to Improve Processes for Preserving Text Messages as Federal Records (Report No. 17-P-0062),
issued 12/21/2016.
1
Require the Office of
Congressional and
Intergovernmental Relations
to document formal
procedures for responding to
congressional requests for
records, including text
records. (Office of
Intergovermnental Relations
(OCIR)
Agency's CA Response
Developed procedures for responding to congressional requests for records.
Planned completion date September 20, 2017.
Completed.
2
Remind agency employees
that, as appropriate, all text
messages that are potentially
responsive to a Freedom of
Information Act or a
congressional request must be
available for inclusion in
searches conducted by the
agency to prepare responses to
these requests. (OEI)
Agency's CA Response
Completion date was the day the training was due for the Agency.
Completed.
19-P-0283
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Kocoiiniieiithil ion
( oiTcc(i\c iiclion
()l(> c\ iiliiiilion
3
Determine whether potential
text message records were lost
during the replacement of the
noted mobile device during
the instance where the senior
official could not provide the
requested text messages (Page
12, Bullet 1), or during the
instance when the senior
official's mobile device
automatically deleted
messages after 30 days
(Page 12, Bullet 2), and notify
the National Archives and
Records Administration if
warranted. (OEI)2
Agency's CA Response
CA 1-1: The Agency's Records Officer reviewed the reports and determined that
there was no evidence of a potential loss of text messages that were records in
either case and that a report of unauthorized destruction to NARA3 was not
required. The Office of General Counsel agreed with this conclusion.
Completed.
4
Develop and implement a
strategy instructing employees
not to change the text message
retention settings. (OEI)
Agency's CA Response
EPA will modify the Mobile Device Employee Notice to state that employees shall
not modify the text message retention settings.
Completed.
2	The OEI abbreviation refers to the EPA's former Office of Environmental Information; that office is now part of the Office of Mission Support.
3	NARA means the National Archives and Records Administration.
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Kocoiiniieiithil ion
( oiTcc(i\c iiclion
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5
Develop a plan to replace any
phones not technically
compatible with the new
mobile device management
solution identified during
market research in response to
Recommendation 6. Also,
develop a process to approve
waivers for any office that
identifies a significant
business need to keep the
existing device and identifies
an alternative solution for
records management for that
existing device. (OEI)
Agency's CA Response
Proposed Alternative Recommendation: If the Agency identifies a records-
management solution for mobile devices after the review scheduled to be
conducted between 6/30/18, and no later than 9/30/18, develop a plan to replace
any phones not technically compatible with any identified solution within 6 months
of implementation of the identified solution.
Completed.
6
Formalize a plan with
milestone dates to conduct
market research to determine
whether an enterprise mobile
device management solution
can manage text message
communications to help the
agency meet its record-
keeping responsibilities.
Document a management
decision if a new solution is
appropriate for the
implementation and, if
needed, create a project plan
with milestone dates for
implementing the new
solution. (OEI)
Agency's CA Response
OEI is in the process of researching text message tools and will complete this new
research no sooner than 6/30/18, and no later than 9/30/2018.
Completed.
19-P-0283
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Kecommciuliilion
( oiTcc(i\e iiclion willi completion ri;ilc
OK. c\iiliiiilion

1
Issue llie final agency FOIA
procedures by September 30,
2014. (OEI)
Agency's CA Response
Former Acting Assistant Administrator and Chief Information Officer, Renee P.
Wynn, issued the final Agency FOIA procedures on September 30, 2014. The
Agency's final FOIA procedures are posted on the Agency's intranet.
Completed.
2
Require that Senior
Information Officials at each
region and program office
certify that their local FOIA
procedures are consistent with
the agency's final procedures
by March 31,2015. (OEI)
Agency's CA Response
The audit corrective action completion date was extended by OEI from March 31,
2015 to September 30, 2015. On June 25, 2015, OEI provided copies of the
attached certifications from each SIO4 to the OIG.
Completed.
4 The SIO abbreviation means Senior Information Official.
19-P-0283
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Kccom moiKhil iui
( oiTcc(i\e iiclion with completion d;i(c
()l(> c\ iiliiiilion

1
Develop and implement records
management policies and
procedures regarding the use of
private email accounts when
conducting official government
business. (OEI)
Agency's CA Response
OEI issued Interim Records Management Policy CIO 2155.2, June 28, 2013, which
address the use of private email accounts when conducting official business.
OEI issued Records Management Policy CIO-2155-3, February 10, 2015, which
addresses the use of private email accounts when conducting official government
business.
Completed.
2
Develop internal controls to
ensure that all EPA employees
and contractors complete
training on their records
management responsibilities.
(OEI)
Agency's CA Response
OEI Conducted mandatory records management training for all EPA staff, contractors
and grantees.
A Mass mailer announcement was sent out on July 31, 2013.
Completed.
3
Develop and implement
internal controls to monitor and
track completion of training for
personnel with specific
delegated duties and
responsibilities outlined in the
NRMP guidance. (OEI)
Agency's CA Response
Records Liaison Officer (RLOs) have been required to obtain the National Archives
and Records Administration (NARA) Certification in Federal Records Management
since 2008. RLOs are regularly reminded of this requirement. Completion of this
training by RLOs is tracked by the Agency Records Officer through NARA and
information received from the RLOs. On November 17, 2014, the Acting Principal
Deputy Assistant Administrator and Deputy Chief Information Officer notified the
SIOs, IMOs5 and RLOs on the status of each RLOs' NARA training. An annual
reminder and status will be sent out.
Completed.
5 The IMO abbreviation means Information Management Officer.
19-P-0283
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Kecom moiKhil iui
( oiTcc(i\e aclion willi completion dale
()l(> c\ alualion
4
Conduct outreach with all IP \
offices to ensure that local I >
developed separation policies
and procedures, as well as I lie
associated employee separaiimi
checklist, include records
management retention pradices
consistent with agency
guidance. (OEI) This should
include ensuring that:


4a
Locations' out-processing
procedures contain practices
where notifications are sent to
individuals with records
management responsibilities in
a timely manner to aid in
capturing electronic records
from separating employees.
(OEI)
Agency's CA Response
The National Records Management Program (NRMP) and OARM's Office of Human
Resources (OHR) collaborated to issue the Employee Separation Checklist (EPA
Form 3110-1), which requires that all employees identify and transfer Agency
records. The Procedures for Preservation of Separating/Transferring and Separated
Personnel's Records In accordance with the Federal Records Act (CIO 2155-P-04.0)
and the accompanying EPA Records Management Checklist for
Separating/Transferring or Separated Personnel, EPA Form 3110-49 were issued on
December 23, 2014.
Completed.
4b
Locations include steps to have
employees search for potential
records residing within alias
email accounts that the
employee manages or on other
electronic media devices within
the employee's control. (OEI)
Agency's CA Response
In the new records checklist (3110-49), all separating employees must provide
information on records in multiple locations including private/personal or secondary
email accounts, PDAs, local network drives, etc. was complete on December 23,
2014.
Completed.
4c
Locations have special out-
processing procedures that
contain a method for collecting
records from departing
employees during the holiday
season or times of limited
staffing. (OEI)
Agency's CA Response
The procedures for Preservation of Separating/Transferring and Separated
Personnel's Records in accordance with the Federal Records Act and the
accompanying EPA Form 3110-49, EPA Records Management Checklist for
Separating/Transferring or Separated Personnel, ensures that separating employee's
records can be captured during the holiday season and other times when there is
limited staffing, by allowing an alternate or designee to review and sign the form.
Completed on December 23, 2014.
Agency's Planned Completion Date
12/31/13
Completed.
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Kccom moiKhil iui
( oiTcc(i\e aclion with completion dale
()l(> c\ alualion
4d
Locations update their locally
developed out-processing
checklist to ensure an area
exists for where records
managers can note their records
management certifications as
required by agency policy.
(OEI)
Agency's CA Response
EPA Form 3110-49 includes an area that must be certified by the employee,
supervisor, IMO and RLO, indicating that the records of the employee have been
reviewed and transferred, as required. Completed December 23, 2014.
Agency's Planned Completion Date
12/31/13
Completed.
5
Establish a revised date for
when the EPA will implement
an electronic content
management tool to capture
email records within the
agency's new email system.
(OEI)
Agency's CA Response
EZ Email Records for Lotus Notes deployed September 2013, EZ Email records for
MS Office deployed November 2013. A Mass mailer was sent out 11/25/13
announcing launch of tools and related mandatory training.
Agency's Planned Completion Date
12/31/13
Completed.
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Appendix B
Agency Response to Draft Report
*>	c*
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JUL 1 2 2019
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report, OA&E-FY 18-0217, EPA s
Processes for Preserving Emails and Text Messages, and Responding to Freedom of
Information Act Requests "
Thank you for the opportunity to comment on the Draft Report OA&E-FY18-0217, "EPA's
Processes for Preserving Emails and Text Messages, and Responding to Freedom of Information
Act Requests
The Office of General Counsel concurs with OIG's conclusion that EPA completed all corrective
action for the 13 audit recommendations related to records management and Freedom of
Information Act (FOIA) practices. Due to events subsequent to EPA's completion of all
corrective actions relative to OIG Briefing Report No. 14-P-0262, it has now become time for
EPA to review and update EPA's FOIA Policy and FOIA Procedures.
FROM: Elise Packard
Deputy General Counsel for Operations
Office of General Counsel
TO:
Rudolph M. Brevard, Director
Information Resources Management Directorate
Office of Audit and Evaluation
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As the Agency's Chief FOIA Officer described in a February 15, 2019 letter to you, EPA signed
a FOIA Policy and Procedure Update in February 2019. That update confirmed the continued
applicability of EPA's FOIA Policy and EPA's FOIA Procedures. The letter also advised you
that EPA was planning to update EPA's FOIA regulations. We agree with you that "it is
incumbent upon management to complete its update of the FOIA regulation" and, in fact, EPA
published its updated FOIA regulations on June 26, 2019, conforming the regulations to the
2007, 2009, and 2016 statutory amendments. As a result, it has now become timely for EPA to
review EPA's FOIA Policy and FOIA Procedures, which it is now undertaking. I want to thank
you for meeting with my team and staff from the Office of Mission Support during this process
and for the opportunity to respond.
If you have any questions, please contact Timothy Epp at 202-564-2830 or
epp.timothy@epa.gov.
cc: Vaughn Noga
Donna J. Vizian
Rebecca Moser
Charleen Townsend
Brenda Young
Brian Epley
Liza Hearns
Rena Key
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Appendix C
Distribution
The Administrator
Deputy Administrator
Chief of Staff
Deputy Chief of Staff
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Director, Office of Continuous Improvement, Office of the Administrator
Audit Follow-Up Coordinator, Office of the Administrator
Principal Deputy General Counsel
Deputy General Counsel
Principal Deputy Associate Administrator for Congressional and Intergovernmental Relations
Principal Deputy Assistant Administrator for Mission Support
Deputy Assistant Administrator for Environmental Information and Chief Information Officer,
Office of Mission Support
Audit Follow-Up Coordinator, Office of General Counsel
Audit Follow-Up Coordinator, Office of Mission Support
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