Detailed Information on the
Brownfields Revitalization Assessment

Improve grantee use of electronic reporting systems to reduce data lags in performance information.

Conduct regional program reviews to share and implement best practices among regional offices that will improve the program's overall performance and efficiency.

Complete performance measures that are under development including a new cross-agency measure that tracks brownfields redevelopment.

Measure: Assessed or cleaned brownfield properties redeveloped (provisional).

Explanation:EPA will work with other agencies involved in brownfields revitalization to develop a shared performance standard that focuses on redevelopment as the desired outcome. (See follow-up action #1 for more information).

Measure: Acres of brownfields made ready for reuse.

Explanation:Brownfields are ready for reuse when (1) cleanups are certified complete by an environmental professional or State authority or (2) assessments show no further action is required as certified by an environmental professional. This measure is an aggregate of the annual measure.

Measure: Billions of dollars of cleanup and redevelopment funds leveraged at brownfield sites.

Explanation:This measure tracks the amount of cleanup/redevelopment funding leveraged by program grant recipients at brownfields properties. Grantees report on this measure in quarterly reports.

Measure: Acres of brownfields made ready for reuse.

Explanation:Brownfields are ready for reuse when (1) cleanups are certified complete by an environmental professional or State authority or (2) assessments show no further action is required as certified by an environmental professional. The results of this measure are aggregated to assess the long-term result reported under long-term measures.

Measure: Brownfield properties assessed.

Explanation:This measure tracks the number of brownfields properties assessed by program grant recipients. Grantees report on this measure in quarterly reports, but there are data lags due to delays in report submission and compilation.

Measure: Acres of brownfields made ready for reuse per million dollars.

Explanation:

Is the program purpose clear?

Explanation: The statute describes the purpose of the program is to 'promote cleanup and reuse of brownfields, to provide financial assistance for brownfields revitalization, and to enhance state response programs.' Subtitle A authorizes EPA to provide grants to eligible entities to assess, cleanup, establish revolving loan funds, conduct job training programs, and perform targeted site assessments at brownfileds sites, as well as for research and technical assistance. Subtitle C authorizes EPA to award grants to States and Indian tribes to establish or enhance programs.

Evidence: Small Business Liability Relief and Brownfields Revitalization Act (PL 107-118)

Does the program address a specific and existing problem, interest, or need?

Explanation: Office of Technology Assessment estimated that there are over 450,00 brownfields properties. Program provides financial and technical assistance to assess, cleanup, and leverage the redevelopment of these brownfield properties.

Evidence: The Office of Technology Assessment report State of the States on Brownfields: Program for Cleanup and Reuse of Contaminated Sites (OTA-BP-ETI-153, June 1995) indicated the range of brownfields sites in the U.S.

Is the program designed so that it is not redundant or duplicative of any Federal, state, local or private effort?

Explanation: EPA's Brownfields program does not replicate other federal programs and targets contaminated properties not addressed by other federal programs. Program partners with other federal agencies to coordinate efforts and achieve goals. In addition to federal agencies, the program works in partnership with and provides funding to states, tribes, and local governments as outlined by the authorizing statute.

Evidence: FY 03 Grant Funding Guidance for State and Tribal Response Programs; FY 03 Proposal Guidelines for Brownfields Assessment, Revolving Loan Fund and Cleanup Grants; FY 03 Proposal Guidelines for Brownfields Job Training Grants; Brownfields Federal Partnership Action Agenda

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: No major flaws in the program design have been identified. Program strongly supported by stakeholders, and the interest and support for the program continues to grow. No known studies on the cost effectiveness of the program, though independent research found that "$2.48 in private sector funds are leveraged for every dollar that is invested by the public sector" for brownfields cleanup.

Evidence: The program continues to receive increased interest from all stakeholder groups. In 2003, the program received over 1300 applications for funding, but the program anticipates that it will only be able to fund approximately 200 applicants. Council for Urban Economic Development (CUED) study, "Brownfields Redevelopment: Performance Evaluation;"

Is the program effectively targeted, so program resources reach intended beneficiaries and/or otherwise address the program's purpose directly?

Explanation: Program competes all Subtitle A grants nationally, using the selection criteria outlined in the authorizing statute. Authorizing statute also outlines entities eligible to receive grants and activities allowable for grant funding. Subtitle A grants are predominately awarded to local, state, and tribal governments with some minor distributions to non-profits.

Evidence: Small Business Liability Relief and Brownfields Revitalization Act (PL 107-118); Proposal Guidelines for Brownfields Assessment, Revolving Loan Fund and Cleanup Grants; Proposal Guidelines for Brownfields Job Training Grants; Proposal Guidelines for Brownfields Training, Research, and Technical Assistance Grants and Cooperative Agreements; Grant Funding Guidance for State and Tribal Response Programs

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The program funds assessments and cleanup of properties. OMB views the output of assessments as an appropriate goal since it is the first step to be taken in redevelopment and the program is by its nature a 'process'.

Evidence: 2003 EPA Strategic Plan, EPA's Annual Reports, Small Business Liability Relief and Brownfields Redevelopment Act

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: Guidance states, "Targets and timeframes must be ambitious ... must be set at a level that promotes continued improvement and achievable efficiencies." FY 2003 appropriations for brownfields assessments are nearly twice the FY 2001 appropriation, yet performance is expected to be about the same as FY 2001 for the foreseeable future. Targets and timeframes do not appear ambitions or set at a level that promotes continued improvement or efficiency. The program argues that the program's recent authorization and subsequent large funding increase has outpaced EPA's ability to reset its goals.

Evidence: 2003 EPA Strategic Plan, Annual Performance Report and Congressional Justifications

Does the program have a limited number of specific annual performance measures that demonstrate progress toward achieving the program's long-term measures?

Explanation: EPA tracks the number of assessments that it conducts each year. EPA is developing efficiency measures.

Evidence: EPA Annual Performance Report and Congressional Justification

Does the program have baselines and ambitious targets and timeframes for its annual measures?

Explanation: The program has established the baseline and developed performance targets based on prior year program performance. It is unclear that the program's goals are ambitious considering that the program has received a substantial increase in funding for FY 03. The program argues that the program's recent authorization and subsequent large funding increase has outpaced EPA's ability to reset its goals. See measures tab for more details.

Evidence: EPA Annual Performance Report and Congressional Justifications

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, etc.) commit to and work toward the annual and/or long-term goals of the program?

Explanation: Grant recipients report on performance measures, including completed assessments and cleanups and the cleanup/redevelopment jobs and dollars leveraged. Grantee performance measure information is used to set and track progress towards long term program goals.

Evidence: EPA grantee terms and conditions require grantees to include information on performance measures in quarterly reports.

Are independent and quality evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: No evaluations of significant scope have been conducted to date. Within the next couple years EPA's IG is required by the Brownfields authorizing legislation to "submit to Congress a report that provides a description of the management of the program."

Evidence: EPA OIG 2002 Memo 'Observations on EPA's Plans for Implementing Brownfields Performance Measures'

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: While EPA estimates full annual costs of operating its programs, the Brownfields program does not tie resources to its outputs/outcomes. For instance, neither the new $50 M state categorical grants nor the two-year 64% increase to the assessment program have an output impact. It is unclear how additional resources would affect outcomes. Part of the challenge for EPA will be to adopt new performance metrics for the newly authorized catagorical grants, or link them to valid existing measures.

Evidence: Annual Congressional Justification, Budget Automation System (BAS) reports;Agency's Integrated Financial Management System (IFMS) Reports

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: Strategic planning deficiencies stem from a lack of performance measures and links between performance and budgets. Program collects performance information from grantees in quarterly reports, as outlined in grantee terms and conditions. Performance information is stored in the Brownfields Management System (BMS) and reviewed for quality assurance. Management utilizes performance information to adjust out-year projections for both annual and long term goals. In addition to its utility in setting and monitoring progress towards program goals, BMS also provides anecdotal information on partner successes and challenges that inform program management. Monthly reports are generated to inform headquarters and regional managers of program progress.

Evidence: Grantee Terms and Conditions, Brownfields Data Primer, Brownfields Management System (BMS)

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: Program collects performance information from grantees in quarterly reports, as outlined in grantee terms and conditions. Performance information is stored in the Brownfields Management System (BMS) and reviewed for quality assurance. Management utilizes performance information to adjust out-year projections for both annual and long term goals. In addition to its utility in setting and monitoring progress towards program goals, BMS also provides anecdotal information on partner successes and challenges that inform program management. Monthly reports are generated to inform headquarters and regional managers of program progress.

Evidence: Grantee Terms and Conditions, Brownfields Data Primer, Brownfields Management System (BMS)

Are Federal managers and program partners (grantees, subgrantees, contractors, cost-sharing partners, etc.) held accountable for cost, schedule and performance results?

Explanation: No evidence provided to demonstrate the linkage to performance.

Evidence: None.

Are all funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: Each fiscal year, the program executes an operating plan that displays appropriated resources allocated by goal, objective, subobjective, program and object class. Program budget is aligned with the Agency's Strategic Plan. Obligations and expenditures are tracked in the Agency's Integrated Financial Management System (IFMS) against the Operating Plan. In FY 2002, the program obligated 100% of its resources in IFMS. EPA works with grantees to ensure that their work plans reflect the Agency's Strategic Plan and Operating Plan and that recipient spending is consistent with the approved workplan. Each program office and grants management office conducts post-award monitoring of assistance agreements, including monitoring the draw-down of funds against grantee progress on workplan tasks and deliverables. This monitoring ensures that recipients are spending the funds designated to each program area for the intended purpose. All grantees are required to submit annual or more frequent financial status reports.

Evidence: EPA's annual Operating Plan and Congressional Justification, EPA's Strategic Plan, Budget Automation System (BAS) data, EPA's Annual Report and Financial Statements. EPA's Policy on Compliance, Review, and Monitoring (EPA 5700.6, Advanced post-award monitoring (i.e. on and off-site grantee review) reports, documentation of post-award monitoring in assistance agreement files, grantee financial status reports.

Does the program have procedures (e.g., competitive sourcing/cost comparisons, IT improvements, approporaite incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: Program selects grant recipiets on a competitive basis. It contracts competitively and subsequently monitors contract cost, schedule, and performance. Program nationally competes all grants. This is the first year grants will be awarded under authorizing statute. Previous pilot awards considered applicant past performance. Future awards will also consider grantee performance in selection criteria. Program developing business case for the Brownfields Management System (BMS) through the OMB Capital Planning and Investment Control (CPIC) process.

Evidence: Requests for Proposals for major contracts; Monthly Progress Reports and Invoices from all contractors; FY 03 Grant Funding Guidance for State and Tribal Response Programs; FY 03 Proposal Guidelines for Brownfields Assessment, Revolving Loan Fund and Cleanup Grants; FY 03 Proposal Guidelines for Brownfields Job Training Grants; Brownfields Federal Partnership Action Agenda

Does the program collaborate and coordinate effectively with related programs?

Explanation: The program is collaborating on the One Cleanup Program which works to present a unified picture of Agency land cleanup programs. The program has had an active dialogue with and participation from the states in implementing Subtitle C of the Brownfields law. The program continues to work with the Office of Underground Storage Tanks to accommodate the inclusion of petroleum sites within the definition of brownfields.

Evidence: EPA One Cleanup Program website: www.epa.gov/oswer/onecleanupprogram/ ; FY 03 Grant Funding Guidance for State and Tribal Response Programs

Does the program use strong financial management practices?

Explanation: The program follows EPA's financial management guidelines for use of funds. EPA's controls on improper payments are based on GAO and other principles. At each step in the process, the propriety of the payment is reviewed. Training ensures staff understand their invoice review and financial responsibilites. EPA received an unqualified audit opinion on its FY03 financial statements with no audit material weaknesses. EPA met the new accelerated due dates for financial statements. The program has no material weaknesses and has procedures in place to minimize erroneous payments. The OIG's January 03 report on improper contract payments at EPA concluded that the number of improper contract payments found is minimal and EPA appears focused on providing high quality and accurate contract payments.

Evidence: Annual Congressional Justification, Budget Automation System (BAS) reports, unqualified audit opinion on EPA FY02 financial statements, Fiscal Year 2002 Advice of Allowance Letter, 2002 Integrity Act Report, resource policies at: http://intrasearch.epa.gov/ocfo/policies.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: The program uses various mechanisms including monthly calls and periodic HQ/Regional coordination meetings to discuss program performance and budgeting/strategic planning for outyears (e.g., discuss changes to allocation of budget dollars among various grant types). The program participates in Agency grant management reviews. As the Brownfields Law was signed last year, the program is developing its own protocol for regular regional grant management reviews. The program also conducts data quality reviews, both at the national and regional level, of the information reported in grantee quarterly reports prior to entry into the Brownfields Management System (BMS), the program performance measure database.

Evidence: Program does not have any identified material deficiencies in management as identified in the FMFIA annual review process; Brownfields Data Primer.

Are grants awarded based on a clear competitive process that includes a qualified assessment of merit?

Explanation: The program competes all Subtitle A grants nationally using evaluation criteria stipulated in the grant guidelines. The evaluation criteria originate from the authorizing statute. Applicant review panels include participation of various EPA offices as well as other federal agencies. The program broadly publicizes grant opportunities through federal register notices, press releases, web postings, list serve notices, and inclusion in the Catalog of Federal Domestic Assistance. Program continues to receive and award grants to new program participants.

Evidence: 2003 Proposal Guidelines for Brownfields Assessment, Revolving Loan Fund and Cleanup Grants; 2003 Proposal Guidelines for Brownfields Job Training Grants; Proposal Guidelines for Brownfields Training, Research, and Technical Assistance Grants and Cooperative Agreements; Grant Funding Guidance for State and Tribal Response Programs

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: Program negotiates work plans prior to grant award. Grantees submit quarterly reports including information on performance measures and budget. Program monitors grantee budget expenditures to ensure that funded activities are eligible and allowable. The program also conducts data quality reviews, both at the national and regional level, of the information reported in grantee quarterly reports prior to entry into the Brownfields Management System (BMS), the program performance measure database.

Evidence: Brownfields Data Primer

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: EPA collects grantee performance information on a quarterly basis. Grantee performance information aggregated and provided in EPA Annual Performance Reports and Congressional Justifications. Individual grantee performance information is scheduled to be available to the public by the end of the fiscal year.

Evidence: EPA Annual Reports; Brownfields Management System (BMS) database

Has the program demonstrated adequate progress in achieving its long-term outcome performance goals?

Explanation: While the program has already achieved its longterm goals in the current strategic plan. New goals are now being established in EPA's new strategic plan. As stated above those goals do not appear ambitious.

Evidence: 2003 EPA Strategic Plan

Does the program (including program partners) achieve its annual performance goals?

Explanation: The program has achieved its goals along with its program partners over the last several years.

Evidence: EPA Annual Reports

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program performance goals each year?

Explanation: EPA is developing its efficiency/cost effectiveness measures.

Evidence: FY 03 Proposal Guidelines for Brownfields Assessment, Revolving Loan Fund and Cleanup Grants; Brownfields Grantee Property profile

Does the performance of this program compare favorably to other programs, including government, private, etc., that have similar purpose and goals?

Explanation: Program unique from other federal and private efforts. Could be compared to EPA OUST program as it is land cleanup program that addresses smaller sites (including petroleum properties); however, program design is quite different as it performs assessments.

Evidence:  

Do independent and quality evaluations of this program indicate that the program is effective and achieving results?

Explanation: No evaluations of significant scope have been conducted to date. Within the next couple years EPA's IG is required by the Brownfields authorizing legislation to "submit to Congress a report that provides a description of the management of the program."

Evidence: EPA OIG 2002 Memo 'Observations on EPA's Plans for Implementing Brownfields Performance Measures'