U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Environmental Benefits 

Being Considered in Award 

of Great Lakes Grants 

Report No. 14-P-0004 November 5, 2013 

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Report Contributors: Janet Kasper 

 Doug Latessa 

 Mary Anne Strasser 

Abbreviations 

EPA U.S. Environmental Protection Agency 

GLNPO Great Lakes National Program Office 

LAMP Lakewide management plan 

OIG Office of Inspector General 

RAP Remedial action plan 

Cover photo: View of Chicago, a Great Lakes shoreline city. (EPA photo) 

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U.S. Environmental Protection Agency 14-P-0004 

November 5, 2013 Office of Inspector General 

At a Glance 

Why We Did This Review Environmental Benefits Being Considered in 

The U.S. Environmental Award of Great Lakes Grants

Protection Agency (EPA) Office 

of Inspector General (OIG) What We Found 

For further information, 

contact our public affairs office 

at (202) 566-2391. 

The full report is at: 

www.epa.gov/oig/reports/2014/ 

20131105-14-P-0004.pdf 

received a hotline complaint 

that Great Lakes Shoreline 

Cities Green Infrastructure 

grants were being awarded 

with the only criterion being 

population; the potential 

environmental benefit was not 

the primary factor for 

determining awards. Our 

objective was to determine 

whether the EPA followed its 

policies when announcing 

these grants. The grants were 

designed to help Great Lakes 

shoreline cities reduce urban 

runoff and sewer overflows that 

impair Great Lakes water 

quality. 

This report addresses the 

following EPA theme: 

	 Protecting water: A precious, 

limited resource. 

EPA Region 5 took prompt action to ensure that Region 5 plans to 

Great Lakes Shoreline Cities Green Infrastructure assure the $8.5 million 

grants will support lakewide management plan of infrastructure 

grants will result in activities and will result in reduction of discharges to reducing discharges the Great Lakes. While the grant announcement did to the Great Lakes. not specifically require proposed projects to support 

lakewide management plan activities as identified in 

the competition exemption, Region 5 management agreed that it should have. 

To address the issue, Region 5 developed criteria for staff to use when reviewing 

grant applications. Going forward, staff members will consider how each 

proposed project will support lakewide management plan goals and result in 

reducing discharges to the Great Lakes. 

Since Region 5 has already taken action to address the issue noted, the report 

contains no recommendations. 
 Susan Hedman, Regional Administrator 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

November 5, 2013 

MEMORANDUM 

SUBJECT: Environmental Benefits Being Considered in Award of Great Lakes Grants 

Report No. 14-P-0004 

FROM: Arthur A. Elkins Jr. 

TO: 

 Region 5 

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 EPA has implemented. This report represents 

the opinion of the OIG and does not necessarily represent the final EPA position. Since the agency has 

taken sufficient corrective action and this report makes no recommendations, no response is required. 

This report will be available at http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact Richard Eyermann, 

Acting Assistant Inspector General for Audit, at (202) 566-0565 or eyermann.richard@epa.gov; 

or Janet Kasper, Product Line Director, at (312) 886-3059 or kasper.janet@epa.gov. 
 

 

 

Purpose 

The U.S. Environmental Protection Agency (EPA) Office of Inspector General 

(OIG) received a hotline complaint that Great Lakes Shoreline Cities Green 

Infrastructure grants were being awarded with the only criterion being 

population; the potential environmental benefit was not the primary factor for 

determining awards. Our objective was to determine whether the EPA followed 

its policies when announcing these grants. 

Background 

The EPA invited 22 cities to submit applications for projects to reduce urban 

runoff and sewer overflows that impair Great Lakes water quality. The total 

amount of funds eligible for award to all potential recipients is $8.5 million. The 

amount to be awarded would be based on population and would be awarded on a 

first-come, first-serve basis. The funding for these grants came from the Great 

Lakes Restoration Initiative. Eligible cities can use the grants to cover up to 50 

percent of the cost of: 

 Rain gardens. 

 Bioswales. 

 Green roofs. 

 Porous pavement. 

 Greenways. 

 Constructed wetlands. 

 Stormwater tree trenches. 

 Other green infrastructure measures installed on public property. 

It is EPA policy1

 to promote competition to the maximum extent practicable in 

the award of assistance agreements, and that the competitive process be fair and 

impartial, that all applicants be evaluated only on the criteria stated in the 

announcement, and that no applicant receive an unfair competitive advantage. 

When the estimated total amount of funds expected to be awarded under an 

announcement exceeds $100,000 (regardless of the amount of any individual 

awards), open competition among all potentially eligible applicants is required. 

The policy allows for exemptions to competition when there are urgent and 

compelling circumstances, national security consideration or public interest. 

Scope and Methodology 

We conducted this audit in August and September 2013 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 

1

 EPA Order 5700.5A1, “Policy for Competition of Assistance Agreements,” revised July 19, 2012. 

14-P-0004 1 
 

 

 

objectives. We believe that the evidence obtained provides a reasonable basis for 

our findings and conclusions based on our audit objective. 

To answer the objective, we interviewed staff and managers in Region 5 and the 

Great Lakes National Program Office (GLNPO) and reviewed the following 

documentation: 

 Solicitation for Great Lakes Shoreline Cities Green Infrastructure grants.
 

 EPA guidance regarding competition of grants.
 

 Exemption from competition for lakewide management plan (LAMP) and 

remedial action plan (RAP) activities. 

 EPA actions to address issues identified during the audit. 

Our review was limited to the process for announcing the shoreline city green 

infrastructure grants. As of September 10, 2013, none of the grants had been 

awarded. 

Results of Review 

Region 5 took prompt action to ensure that Great Lakes Shoreline Cities Green 

Infrastructure grants will support LAMP activities and will result in reduction of 

discharges to the Great Lakes. While the grant announcement did not specifically 

require proposed projects to support LAMP activities as identified in the 

competition exemption, Region 5 management agreed that it should have. During 

our review, Region 5 developed criteria for staff to use when reviewing grant 

applications that will look for how the proposed project will support LAMP goals 

and result in reducing discharges to the Great Lakes. 

On July 26, 2013, the EPA invited the 22 largest Great Lakes shoreline cities to 

apply for shoreline city green infrastructure grants. To be eligible for the grants, a 

city must directly touch the Great Lakes and have a population greater than 

50,000 people. The amount of funding available to a specific recipient is based on 

the city’s total population; larger cities will receive more money. For example, 

cities with a population of more than 500,000 are eligible for up to $1 million. 

The total amount of funds eligible for award under the Great Lakes shoreline 

cities program is $8.5 million, making it subject to the EPA competition policy. 

In June 2013, the Assistant Administrator for Administration and Resources 

Management approved an exemption from competition for grants to states, tribes 

and local governments in furtherance of LAMP and RAP activities. The 

exemption was to cover activities including the hiring of employees by the 

governmental entity to oversee and implement LAMP and RAP activities; the 

joint development and implementation of RAP and LAMP projects, and RAP and 

LAMP activities that will be conducted on property owned by states, tribes and 

local governments. However, the grant announcement made no reference to RAPs 

or LAMPs, or that the activities being conducted under the grants would support 

14-P-0004 2 
 

 

RAPs or LAMPs. According to the GLNPO Director, the program office assumed 

that activities under the shoreline cities grants would support LAMPs and RAPs, 

and agreed that this should have been included in the grant solicitation. 

On September 4, 2013, OIG staff met with Region 5 management to discuss the 

hotline complaint and compliance with the competition policy. To comply with 

the competition policy, Region 5 management agreed with the OIG that it would 

develop criteria for reviewing the grant applications to ensure that the applications 

addressed environmental results and funded activities were linked to the goals and 

objectives of the LAMPs. Consequently, GLNPO developed criteria for reviewing 

applications for shoreline cities grants. Regional staff, when reviewing the grant 

work plans, would confirm and document whether the proposed project would 

further the goals, or address an issue of concern, of a LAMP by: 

 Reducing the discharge of untreated stormwater runoff to a Great Lake or 

a waterway that discharges to a Great Lake. 

 Reducing the discharge of sewer system overflows to a Great Lake or a 

waterway that discharges to a Great Lake. 

	 Reducing the discharge of sediment, nutrients, chemicals, bacteria and/or 

other contaminants to a Great Lake or a waterway that discharges to a 

Great Lake. 

	 Reducing threats to public health at beaches or in near-shore areas caused 

by contaminants including, but not limited to, bacteria, nutrients and 

chemicals. 

The criteria should ensure the proposed project is linked to the LAMP as provided 

for in the competition exemption. It will also ensure that the proposed project will 

result in an environmental benefit of reducing discharges to the Great Lakes. 

Since Region 5 has already taken action to address the issue noted, 

no recommendation is being made. 

14-P-0004 3 
 

 

 

 

 

 

Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Planned 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Completion 

Date 

Claimed 

Amount 

Agreed-To 

Amount 

No recommendations 

O = 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.
 

14-P-0004 4 

1 
 

 

Appendix A 

Distribution 

Office of the Administrator 

Regional Administrator, Region 5 

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 

Deputy Regional Administrator, Region 5 

Director, Great Lakes National Program Office, Region 5 

Audit Follow-Up Coordinator, Region 5 

14-P-0004 5