Report PDF - US Environmental Protection Agency

Agreement Act of 1977 and highlighted in EPA’s “Policy for distinguishing Between
Assistance and Acquisition” (GPI-94-04), TDOT’s purpose would need to be one of
transferring something of value (e.g., money) to an eligible entity to accomplish a public
purpose of support or stimulation authorized by statute. TDOT’s role in this case is
clearly one of “assistance” and not acquisition (procurement), and therefore does not
meet the obvious intent associated with being “a public building of, and a public work of,
a government entity”.
OIG Response 5: See OIG Response 4.
7. Regarding Finding 2, we do not agree with the finding based on our discussions with
TDOT and the information that they had at the time of reporting. However, we have had
discussions with TDOT regarding the recommendations included in Finding 2, and offer
the following comments:
a. We believe the overall objectives of the cooperative agreement have been met
including the installation and operation of a network of 117 electrified parking
spaces across Tennessee with some level of demonstrated emission reductions and
fuel savings based on limited usage data provided to TDOT from the truck stops
in Tennessee. It is expected that over time the usage of the TSE equipment will
increase as people become more familiar with the benefits of using the equipment
and the availability of the TSE equipment.
b. The assumptions used by TDOT to calculate and report out on emissions
reductions and estimated reductions in fuel usage using the diesel emissions
quantifier were based on 2000 hours of usage instead of the default setting of
2400 hours. This lower usage estimation was in an effort to utilize a more
conservative approach to reporting given that they did not have any reliable
information to predict actual usage (very little to no usage data was available to
them at the time of the report).
c. Whereas it is understandable that it will likely take some time to maximize usage
of the electrified parking spaces across Tennessee, TDOT indicated they are
willing to develop an addendum to their report which provides project results
based on actual usage data that they now have for the most recent quarter. The
quarterly data will be used to extrapolate a project usage estimate for an entire
year which will be plugged into the diesel emission quantifier to generate
estimated emissions reduction information. This addendum report will be added
to the EPA grant file and provided to your office.
OIG Response 6: The OIG acknowledges comments from Region 4 and commends
the efforts already taken to address the issue. The OIG looks forward to the receipt
and evaluation of updated emission information.
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