U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Special Report 

Response to Congressional 

Request on Signage 

Requirements for Projects 

Funded by the Recovery Act 

 Report No. 10-X-0175 

 August 2, 2010 
 

 

Report Contributors: Andrés Calderón 

 Denise Darasaw

 Heriberto Ibarra

 Doug LaTessa 

Abbreviations 

ARRA American Recovery and Reinvestment Act of 2009 

DERA Diesel Emissions Reduction Act 

EPA U.S. Environmental Protection Agency 

LUST Leaking Underground Storage Tank 

OIG Office of Inspector General 

RAT Board Recovery Accountability and Transparency Board 

SRF State Revolving Fund 

Cover photo: Sign identifying water projects in New Hampshire funded by the 

American Recovery and Reinvestment Act of 2009. (EPA OIG photo) 
 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

August 2, 2010 

The Honorable Darrell E. Issa 

Ranking Member 

Committee on Oversight and Government Reform 

U.S. House of Representatives 

Washington, DC 20515 

Dear Congressman Issa: 

Enclosed is our response to your request dated June 24, 2010, to the Honorable Earl 

Devaney, Chairman of the Recovery Accountability and Transparency (RAT) Board, asking for 

information on signage requirements for recipients of American Recovery and Reinvestment Act 

of 2009 funds. The RAT Board requested we respond directly to you concerning Recovery Act 

funds awarded by the U.S. Environmental Protection Agency (EPA). 

We will continue to monitor EPA’s activities to ensure that Recovery Act funds are 

properly spent. If you should have any questions about our work, please contact 

Eileen McMahon, Assistant Inspector General for Congressional, Public Affairs and 

Management, at (202) 566-2391. 

Sincerely, 

Arthur A. Elkins, Jr. 

Enclosure 
10-X-0175 

Purpose 

On June 24, 2010, Congressman Darrell Issa, Ranking Member of the House Oversight and 

Government Reform Committee, sent a request to the Recovery Accountability and 

Transparency (RAT) Board requesting an investigation regarding signage requirements for 

recipients of American Recovery and Reinvestment Act of 2009 funds. The RAT Board 

requested that the U.S. Environmental Protection Agency (EPA) Office of Inspector General 

(OIG) respond directly concerning Recovery Act funds awarded by EPA. The Congressman 

requested the following information: 

•	 A complete accounting of all guidance issued by any federal agency to recipients of 

stimulus funds, including federal, State, and local agencies, on the posting of signs, logos, 

or emblems intended to publicly identify the source or expenditure of stimulus funds. 

•	 Whether any federal agency requires, or has required, stimulus recipients to post signs, 

logos, or emblems identifying the source or expenditure of stimulus funds and whether 

such agency had statutory authority to do so. 

•	 If any federal agency has relaxed a requirement that recipients post signs, logos, or 

emblems identifying the source or expenditure of stimulus funds, and an explanation of 

the decision to do so. 

•	 An assessment of the total cost to the taxpayers from the posting of signs, logos, or 

emblems identifying the source or expenditure of stimulus funds. 

Background 

EPA received $7.2 billion from the Recovery Act. The Recovery Act awarded funds for the 

Clean Water State Revolving Fund (SRF), Drinking Water SRF, Brownfields, Leaking 

Underground Storage Tanks, Diesel Emission Reductions, and Superfund Remedial programs. 

The RAT Board was established under Section 1521 of the Recovery Act to coordinate and 

conduct oversight of covered funds to prevent fraud, waste, and abuse. 

Scope and Methodology 

To answer the questions posed, we interviewed EPA staff from five program offices, reviewed 

guidance EPA prepared for Recovery Act recipients, and obtained a limited number of invoices 

for the cost of signs posted at EPA-funded projects paid for by the Recovery Act as well as 

information on the number of Recovery Act projects for certain EPA programs. We also 

interviewed staff at EPA policy offices, including the Office of Grants and Debarment and the 

Office of Acquisition Management. The OIG’s Office of Counsel also conducted a legislative 

search to identify any authority allowing, or restricting, the posting of signs indicating the source 

of federal funds. 

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10-X-0175 

Results 

Request Item 1: A complete accounting of all guidance issued by any federal agency to 

recipients of stimulus funds, including federal, State, and local agencies, on the posting 

of signs, logos, or emblems intended to publicly identify the source or expenditure of 

stimulus funds. 

EPA developed two forms of guidance that discuss the need for recipients to display a Recovery 

Act logo to communicate to the public that the project is a Recovery Act investment. First, EPA 

included a standard term and condition in all grant agreements that stated that a sign must be 

displayed. The term and condition read as follows: 

This project receives funding under the American Recovery and Reinvestment 

Act of 2009 (ARRA) and the grantee, subgrantee or loan recipient must display 

the ARRA Logo in a manner that informs the public that the project is an ARRA 

investment. The ARRA logo may be obtained from the EPA grants office listed 

in this award document. If the EPA logo is displayed along with the ARRA logo 

and logos of other participating entities, the EPA logo must not be displayed in a 

manner that implies that EPA itself is conducting the project. Instead, the EPA 

logo must be accompanied with a statement indicating that the grantee, subgrantee 

or loan recipient received financial assistance from EPA for the project. 

The specific directions with respect to the logo that are referenced in the term and condition are 

contained in General Guidelines for Emblem and Logo Applications. A copy of these guidelines 

can be found at http://www.epa.gov/ogd/forms/Recovery_emblem_guide_v1[1].pdf. The 

guidelines do not indicate which federal agency developed them, but questions about the 

guidelines are to be directed to the General Services Administration. 

The other guidance EPA developed is a four-page question-and-answer document for Leaking 

Underground Storage Tank (LUST) program grant recipients. The guidance is titled LUST 

Program FAQs – Recovery Act Logo, dated December 29, 2009. The guidance was prepared in 

response to inquiries from recipients asking questions about signage requirements. The LUST 

program did not post this guidance on the EPA public Website, but it was provided to EPA’s 

regional Underground Storage Tank program managers, who in turn shared the guidance with 

recipients. 

Request Item 2: Whether any federal agency requires, or has required, stimulus 

recipients to post signs, logos, or emblems identifying the source or expenditure of 

stimulus funds and whether such agency had statutory authority to do so. 

Generally speaking, the terms and conditions sections of EPA’s assistance agreements require 

recipients of Recovery Act funds to post identifying signs, logos, or emblems. We were not able 

to identify statutory authority that explicitly allowed or disallowed the posting of signs, logos, or 

emblems intended to publicly identify the source or expenditure of Recovery Act funds. 

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10-X-0175 

Request Item 3: If any federal agency has relaxed a requirement that recipients post 

signs, logos, or emblems identifying the source or expenditure of stimulus funds, an 

explanation of the decision to do so. 

The Diesel Emissions Reduction Act (DERA) and LUST program offices relaxed the 

requirement that recipients post signs, logos, or emblems identifying the expenditure of 

Recovery Act funds. Specifically, the DERA program does not require recipients to post signs 

on “rolling” projects, such as school buses; the LUST program does not require recipients to post 

signs on short-term projects, such as projects that last 1 day. 

Request Item 4: An assessment of the total cost to the taxpayers from the posting of 

signs, logos, or emblems identifying the source or expenditure of stimulus funds. 

As of July 2010, EPA did not have information on the total cost of posting signs, logos, or 

emblems related to the Recovery Act. Recipients are not required to report this information. 

Therefore, we cannot provide an assessment of the total cost of posting signs, logos, or emblems. 

On July 15, 2010, the RAT Board sent a request to EPA’s Senior Accountable Official for 

Recovery to provide the assessment of total cost to the RAT Board by September 3, 2010. 

In response to the request, the OIG contacted a limited number of recipients and asked them 

about the signs that they purchased. The cost and type of signs varied greatly (Table 1). We did 

not verify the cost information provided to us. 

Table 1: Signage data for selected EPA programs – OIG limited sample 

Program 

Number 

of signs 

Cost 

per sign Total cost 

Clean Water SRF project 1 $331.12 $331.12 

Clean Water SRF project 4 500.00 2,000.00 

Clean Water SRF project 1 519.73 519.73 

Clean Water SRF project 1 945.00 945.00 

Drinking Water SRF project 1 275.00 275.00 

State LUST program 25 40.00 1,000.00 

State LUST program 250 3.20 800.00 

Superfund project 1 82.15 82.15 

Brownfields project 1 290.00 290.00 

Source: Interviews with EPA staff and grant recipients. Cost data provided was based on 

best available information or readily available invoices. 

Further, determining the number of signs that were purchased was difficult for a number of 

reasons. First, many of the grants funded multiple projects. Second, as was the case with the 

LUST program, one sign was used for multiple projects. Finally, not all projects were required 

to have signs. We obtained information on the number of projects funded by some of EPA 

programs as of July 2010 (Table 2), but the number of projects does not correlate to the actual 

number of signs that were purchased. 

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Table 2: Recovery Act projects for selected EPA programs 

Program or funding vehicle 

Number of 

Recovery Act projects 

Clean Water SRF 1,871 

Drinking Water SRF 1,347 

LUST 1,275 

Contracts 194 

Source: SRF information obtained from EPA information systems; 

LUST and Contracts information obtained from EPA staff. 

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10-X-0175 

Appendix A 

Distribution 

Office of the Administrator 

Assistant Administrator, Office of Administration and Resources Management 

Assistant Administrator, Office of Air and Radiation 

Assistant Administrator, Office of Water 

Assistant Administrator, Office of Solid Waste and Emergency Response 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for External Affairs and Environmental Education 

Director, Office of Acquisition Management 

Director, Office of Grants and Debarment 

Chairman, Recovery Accountability and Transparency Board 

Inspector General 

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