MANATEE COUNTY CLERK OF THE CIRCUIT COURT

INTERNAL AUDIT DIVISION

ENVIRONMENTAL ACTION COMMISSION

AUDIT REPORT

TABLE OF CONTENTS

I. INTERNAL AUDIT REPORT

A. Background …….3-4

B. Purpose/Objectives; Scope ……….4

C. Methodology; Irregularities, Abuse, or Illegal Acts; Test of

Compliance and Statement on Internal Control Structure ………5

D. Audit Report Authorization ……..6

E. Overall Administration …7-13

F. Groundwater Programs

G. Surface Water Programs

Benthic Monitoring for Tampa Bay National Estuary Program…………….34

-Detailed Audit Findings…………………………………………………35-36

Tampa Bay National Estuary Program………………………………………37

Detailed Audit Findings………………………………………………………38

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MANATEE COUNTY CLERK OF THE CIRCUIT COURT

INTERNAL AUDIT DIVISION

ENVIRONMENTAL ACTION COMMISSION

AUDIT REPORT

TABLE OF CONTENTS (Continued)

1. G. Surface Water Programs (Continued)

1. EXHIBIT A: (Program Summary) 62

111. MANAGEMENT'S RESPONSE 63 - 84

MANATEE COUNTY CLERK OF THE CIRCUIT COURT

INTERNAL AUDIT DIVISION

ENVIRONMENTAL ACTION COMMISSION

AS OF JULY 31, 1994

AUDIT REPORT

A financial, compliance, and operational audit of the Manatee County Environmental Action Commission, hereafter referred to as the EAC, was conducted by the Internal Audit Division for the audit period March 1, 1993 through July 31, 1994. The audit was performed In conformance with Generally Accepted Governmental Auditing Standards, issued by the Comptroller General of the United States; and the Standards for the Professional Practice of Internal Auditing, issued by the Institute of Internal Auditors.

The EAC is comprised of the same members as the Board of County Commissioners and is responsible for overseeing the operations of the local independent environmental agency. The EAC consists of an Administration Office and the three divisions of Air Quality, Natural Resources Management and Water Quality.

The EAC Administration is charged with developing annual budgets, preparing deposits, reporting activities to the Commission, assisting other divisions by researching environmental issues and performing educational and community outreach on environmental issues.

The Natural Resources Management Division implements the environmental policies of the Manatee County Comprehensive Plan and the environmental regulations of the Manatee County Land Development Code in unincorporated Manatee County. This Division has primary responsibility for coordination of the County's beach restoration program, habitat restoration projects, and planning for environmental lands acquisition and management.

The Air Quality Management Division preserves and protects the air quality in both the unincorporated and incorporated portions of Manatee County through the administration of a state contract and enforcement of the Manatee County's Code of Environmental Regulation.

The Water Quality Management Division protects, maintains and enhances the surface and groundwater quality in Manatee County. This mission is carried out through a variety of programs, water quality monitoring, conducting special studies, and monitoring compliance with mandates of the Manatee County Comprehensive Plan. The Water Quality Division administers various state contracts and programs. This Division also performs special studies on a one-time or continuous basis, such as monitoring for the Sarasota Bay and Tampa Bay National Estuary Programs, water quality and quantity tracking, and trend analysis in the county's two watersheds.

The main audit objectives include, but are not limited to, the following:

To verify accuracy and input timeliness of financial data, and reports processed and received by the EAC.

The financial audit scope consisted of a review of accounts, financial transactions, and reports of the EAC for the period March 1, 1993 through February 28, 1994.

The compliance audit scope consisted of a review of the policies and procedures, Florida Statutes, federal regulations, the EAC's ordinances, resolutions, contracts, and agreements through July 3 1, 1994.

The operational audit scope consisted of a review of the EAC's internal controls and the effectiveness and efficiency of the operation during the audit period March 1, 1993 through July 31, 1994.

Internal control evaluations were accomplished by flow charting key operations, discussions with management and staff, observations, and analytical and substantive testing of individual internal controls.

Risk analysis was used to establish priorities of audit objectives. Statistical sampling was used whenever appropriate to accomplish audit objectives.

No indications of irregularities, abuse, or Illegal acts were discovered during the audit that could affect the EAC for the audit period ended July 31, 1994.

Environmental Action Commission Audit Report

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September 30, 1994

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Except as noted in our audit report, tested items were In compliance with significant Florida Statutes, ordinances, resolutions, personnel policies, other policies established by the EAC and other applicable laws and regulations.

Nothing came to our attention as a result of specified procedures that caused us to believe that the untested items of the EAC failed to comply with applicable laws and regulations. However, it should be noted that our audit was not directed toward obtaining knowledge of noncompliance for areas not specifically tested.

In planning and performing our audit of the EAC for the period March 1, 1993 through July 31, 1994, we considered its internal control structure in order to determine our auditing procedures for the purpose of our report on the EAC. As a result, except as noted in this report, we did not note any significant matters involving the internal control structure and its operations that we consider to be reportable conditions under standards established by the U.S. General Accounting Office, Government Auditing Standards. Reportable conditions involve matters relating to significant deficiencies in the design or operation of the internal control structure, that in our judgment, could adversely affect the organization's ability to record, process, summarize and report on data consistent with the intent of management.

Our consideration of the internal control structure would not necessarily disclose all matters in the internal control structure that might be reportable conditions, as defined above. In addition because of the inherent limitations in any internal control structure, significant deficiencies in the design or operation of the internal control structure may exist and not be detected. However, we believe the conditions identified in our audit report constitute reportable conditions as previously defined.

Environmental Action Commission Audit Report

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The first section of this report examines the overall administration and general operations. We have divided the audit report into the following sections related to each major program group performed by the EAC. Detailed Audit Findings have been included in each section.

- Overall Administration Pages 7 - 13

- Groundwater Quality Pages 14-32

- Surface Water Quality Pages 33 -43

- Air Quality Pages 44-50

- Beach Restoration Pages 51 -52

- Restoration Projects Pages 53 -54

- Residential & Commercial Developments Pages 55 -59

- Complaints Pages 60-61

Management's response to detailed audit findings can be found on pages 63 through 84. Other minor findings, not included in this report have been discussed with management or corrected during the audit. We would like to thank the Environmental Action Commission's personnel and management for the cooperation and courtesy afforded to our auditors throughout the audit.

This audit report has been reviewed and authorized by

Environmental Action Commission Audit Report

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This section of audit findings relates to the overall administration of the EAC and not exclusively to individual environmental programs.

The EAC has only been in existence for approximately three years with an overall annual budget of approximately two million dollars. Internal Audit found the personnel of the EAC to be highly competent and dedicated to serving Manatee County to the best of their abilities. We did find a lack of inter-local agreements, an overall lack of prioritization of programs, a lack of a cost accounting system to quantify the costs of individual EAC programs, a lack of local enforcement and enforcement capability, and other areas requiring management's review.

01. No inter-local agreement with Manatee County. Page 8

02. No overall evaluation and prioritization of environmental programs. Page 9

03. Lack of cost accounting system for individual programs. Page 10

04. Lack of local enforcement or local laws to allow enforcement. Page 11

05. Survey of other Florida west coast environmental programs. Page 12

06. Qualifications of three employees do not meet job description

requirements and two positions are underencumbered. Page 13

Environmental Action Commission Audit Report

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DETAILED AUDIT FINDINGS

The EAC was established in June of 1991 by enabling legislation which established the EAC as an independent agency with the Board of County Commissioners serving as the Environmental Action Commission. Organizational independence issues arise by having the same Commissioners serve as both the Board of County Commissioners and the Environmental Action Commission. Further confusion as to the degree of independence is added by the lack of an inter-local agreement between the EAC and Manatee County. The EAC receives services from Manatee County departments including administration of purchasing documentation, administration of personnel records, automobile fleet and fuel services, as well as other County services. In addition, the EAC provides development review services to the Planning, Permitting and Inspections Department and has been delegated responsibilities under Manatee County's Comprehensive Plan and the Land Development Code, without a formal agreement. The EAC has not established policies and procedures to ensure compliance with the specific sections of the Comprehensive Plan and the Land Development Code. Furthermore, the EAC is administrating several Manatee County grants regarding beach restoration and artificial reef construction. Without an inter-local agreement between these two independent governmental agencies, clear and specific delegation of responsibilities has not been accomplished.

Environmental Action Commission Audit Report

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DETAILED AUDIT FINDINGS

The EAC, when originally established, incorporated some of the programs and personnel from Pollution Control, a state division of the Health and Rehabilitative Services (HRS). According to management, Pollution Control lacked the staffing and resources necessary to carry out the programs' objectives. The EAC staffing and available resources only recently has grown to a level sufficient to begin achieving these programs' objectives. In examining the overall combination of programs performed by the EAC, we found that Manatee County's Comprehensive Plan and Land Development Code define responsibilities that have been informally delegated to the EAC. We also found that increasing demands for services and resources dedicated to existing programs have been made by outside agencies and by the EAC's divisional managers. Internal Audit believes that the EAC lacks an overall evaluation process to determine which programs would be most beneficial to the local area with the limited resources available.

Environmental Action Commission Audit Report

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DETAILED AUDIT FINDINGS

Internal Audit reviewed the various programs maintained by the EAC and found that a time accounting system has not been established to determine the cost of maintaining the various programs by the divisions. Personnel time is primarily charged to the assigned division's cost centers with no breakdown between separate programs or functions performed. In addition to the individual programs of each division, staff time is used for administrative time, responding to citizens' complaints, and commenting on development review plans. The Water Quality Division has eight distinct programs they maintain for which personnel are cross-trained and assist in performing sampling activities. Without accounting for time spent on each program, program costs and accountability for use of resources can not be determined. Internal Audit believes that a program's cost is a crucial factor in determining a program's efficiency and effectiveness. Accurate program costs must be known to determine sufficient user fee rates to recover program costs. Without knowledge of operational costs, privatization comparisons for in-house services that can be provided by outside vendors cannot be made.

The majority of the EAC's program costs is related to personnel. We believe capturing the personnel costs for each program can serve as an adequate basis for allocation of other direct and indirect costs without incurring substantial additional expense to estimate total program costs. Manatee County's is currently searching for a new finance system that includes enhanced cost accounting abilities and such a system could assist in the automation of EAC's cost accounting needs once the system has been implemented.

Environmental Action Commission Audit Report

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4. THE EAC HAS NOT DEVELOPED LOCAL LAWS AND REGULATIONS WHICH WOULD ALLOW LOCAL ENFORCEMENT ACTION FOR VIOLATIONS.

Our audit found that the EAC does not use local enforcement to assure compliance with environmental laws and regulations. Instead, the EAC attempts to secure compliance with education, through the complaint process, and through development plans review. Major violations of state environmental laws are referred to the Florida Department of Environmental Protection for their investigation and enforcement. We noted from discussions with other environmental programs in the state that enforcement revenues rarely cover the costs of enforcement; however, the lack of the ability to enforce laws can have a negative influence on compliance. As a new entity, the EAC is faced with many political and developmental pressures. According to management, the EAC has decided not to actively pursue local enforcement due to budgetary and staffing constraints. We found that, in most cases, the EAC has not developed the local laws and regulations that are required prior to taking local enforcement actions.

Environmental Action Commission Audit Report

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We surveyed five other Florida west coast counties that had environmental programs and found that two of the five operate under county health departments. The remaining three were used for comparison to Manatee County. Direct comparisons become difficult because no two counties' environmental priorities are the same. Comparisons can be used to explore possible changes or potential cost savings. Internal Audit noted Manatee County is currently attempting to obtain state funding for air monitoring that could improve Manatee County's revenue from non ad valorem taxes. We found the following:

County Ad Valorem Taxes Other Revenue Sources

Manatee $1,157,000* (74.31%) $ 400,000 (25.69%)

Pinellas $3,375,000 (67.50%) $1,625,000 (32.50%)

Hillsborough $4,000,000 (45.39%) $4,812,000 (54.61%)

Sarasota $ 120,000 (9.59%) $1,131,000(90.41%)

* Does not include reserves of approximately $400,000 which are funded by Ad Valorem Taxes

Manatee County 8 out of 32 employees - 25.00%

Pinellas County 5 out of 78 employees - 6.41%

Hillsborough County 20.5 out of 158.5 employees - 12.93%

Sarasota County 5 out of 27 employees - 18.52%

Environmental Action Commission Audit Report

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DETAILED AUDIT FINDINGS

The EAC has adopted the Manatee County's Personnel Policies and Procedures and also utilizes the services of the Office of Human Resources. Internal Audit reviewed job descriptions and found 3 out of 32 employees or 9.4% of the EAC's personnel did not meet the minimum training and/or experience requirements of their respective positions. In addition, we noted that 2 out of 32 employees or 6.25% hold positions which are underencumbered, a practice that distorts true staffing needs by hiring personnel at lower than authorized rates to fill positions for which they are not qualified, Manatee County government is attempting to eliminate underencumbering as an employment practice.

Environmental Action Commission Audit Report

As of 7/31/94

September 30, 1994

Page 14

The EAC is performing the responsibilities under the Well Construction Permitting Agreement. The objective of this program is to review, evaluate and issue permits for the construction, repair, modification and abandonment of water wells within Manatee County. The agreement allows for fees to be set to recover the costs of the program. The agreement also specifics an enforcement program is to be developed in cooperation with Southwest Florida Water Management District (SWFWMD).

7. Permit fees charged do not cover the cost of administering the program. (Page 15)
8. Well completion reports are not received from the contractors on a timely basis. (Page 16)

09. An enforcement program has not been developed. (Page 17)

10. Permits were transferred for situations not allowed by the program. (Page 18)

11. Permit fees were waived, in violation of agreement terms. (Page 19)

12. Monthly reports were not submitted timely to SWFWMD. (Page 20)

13. Permit fees were not deposited timely and applications were not date stamped when received. (Page 21)

14. Staffing requirements do not meet the requirements of the agreement. (Page 22)

Environmental Action Commission Audit Report

As of 7/31/94

September 30, 1994

Page 15

Florida Statute 373.309 allows fees paid for well construction permits to be based on actual costs incurred by the agency. Internal Audit conservatively estimates that the revenues generated by the program cover only 37% of personnel salaries used in the administration of the program for the one-year audit period examined. Personnel salaries do not include fringe benefits and all other direct and indirect costs associated with the program.

Environmental Action Commission Audit Report

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Page 16

The Well Construction Permitting Agreement requires well contractors to submit completion reports to the EAC within 30 days of completing any well activity. The well permits arc effective for a period of six months from the date issued. If the well activity is cancelled, the contractor is still required to submit a completion report to EAC explaining the cancellation.

Internal Audit found that 41.74% or 48 out of 115 of the reports examined were not submitted within the required 30 days. These consisted of the following:

25 out of 115 22% Completion reports were received in excess of 30 days.

18 out of 115 16% Completion reports were not received.

4 out of 115 3% Completion reports did not contain the well's completion date.

1 out of 115 1% Completion report was not date stamped when received by EAC.

In addition, Internal Audit found permits expired prior to the date of completion of the well activity in 20.87% or 24 out of 115 of the reports examined. These consisted of the following:

19 out of 115 17% Completion reports were not received.

2 out of 115 2% Construction was completed prior to the permit issued date.

2 out of 115 2% Permit has expired with no evidence of permit extension.

1 out of 115 1% Completion report did not contain the well's completion date.

Environmental Action Commission Audit Report

As of 7/31/94

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Page 17

The Well Construction Permitting Agreement requires that an enforcement program be implemented in cooperation with the Southwest Florida Water Management District to ensure compliance with standards. Internal Audit found the EAC has not developed an enforcement program. Through discussions with management, the EAC is currently in the process of developing such a program.

Environmental Action Commission Audit Report

As of 7/31/94

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Page 18

The Southwest Florida Water Management District's rules for the regulation of wells requires two conditions to exist for permits to be transferred. These include permit transfers from one contractor to another and permit transfers from one well to another. Both of these conditions allow transfers of permits when the well location has not significantly changed. In addition, the rule states the fee paid by contractors is a non-refundable permit processing fee that is required for permit applications to be processed and filed. Internal Audit found 11 instances where permit fees were transferred from various well locations by the same contractors that do not qualify under SWFWMD's rules. One of these instances included the holding of a check in the amount of $80 for a period of three months then subsequently returning the check to the payee.

Environmental Action Commission Audit Report

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Page 19

SWFWMD's rules state the fee paid by contractors is a non-refundable permit processing fee that is required for permit applications to be processed and filed. There are no exceptions listed for the waiving of fees. Internal Audit found two instances where fees were waived to other governmental agencies. We also found that fees were waived for permits for individuals drilling wells without a certified contractor.

Environmental Action Commission Audit Report

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Page 20

The SWFWMD Well Construction Permitting Agreement requires the following reports to be submitted to the district on or before the fifth day of each month describing the well activities of the previous month:

- Copies of Well Completion Reports

- Copies of Well Abandonment Inspection Reports

- Copies of Well Grouting Inspection reports for public supply wells

- A list by permit number of public supply site inspections

Internal Audit found no evidence that the required monthly reports were submitted to SWFWMD. While management states that the above required information has been submitted to the various SWFWMD offices sporadically, no evidence was available to support this assertion.

Environmental Action Commission Audit Report

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Page 21

The EAC uses informal internal procedures to comply with the Manatee County Well Construction Permitting Agreement. Internal Audit found the following exceptions when reviewing permit applications:

16.09% 14 out of 87 Payments received were not deposited on a timely basis.

("timely" was defined as deposited within ten working days)

28.70% 33 out of 115 Permit applications were not date stamped when received by

the EAC. This date is important in order to determine the

time it takes to process applications.

Environmental Action Commission Audit Report

As of 7/31/94

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Page 22

DETAILED AUDIT FINDINGS

The Well Construction Permitting Agreement requires minimum staffing levels and specific requirements that include one supervisor, two field technicians and one clerical position. In addition, SWFWMD requires notification of vacancies within fourteen days and these vacancies are to be filled no later than 90 days. Internal Audit found that one field technician vacancy exists, and the clerical position is not performing the duties as required by the terms of the contract. No evidence in writing exists that supports SWFWMD was notified of these staffing deficiencies and it appears that the technician position has been vacant in excess of 90 days. In addition, we noted that two of these positions are filled part-time. The contract, however, does not specify whether the positions require full or part-time positions.

Environmental Action Commission Audit Report

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Page 23

The EAC enters into annual contracts with the Florida Department of Environmental Protection (FDEP) to perform compliance and enforcement inspections of regulated pollutant storage tanks within Manatee County. The contract period for which we tested was for 12/1/92 through 11/30/93. The contract requires a specified number of inspections for the contract period. The FDEP pays the EAC for performing the services and the 1993 contract fees amounted to $161,500.

15. Reporting of inspections to FDEP is not always accurate. (Page 24)

Environmental Action Commission Audit Report

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The FDEP contract with the EAC requires Program Output Reporting System Reports on a monthly and annual basis. Internal Audit found the monthly/annual Program Output Reporting System Reports, Inspection Logs and Annual Inspections Summary for the FDEP are not reconciled. As a result, the EAC overstated the total number of inspections by 18. The errors included the following:

+5 inspections not reported due to a math error

-11 inspections double counted in the report

- 8 inspections completed by the phone, not allowed by contract requirements

- 4 inspections were closure inspections of unregulated facilities, not allowed by contract requirements

18 Overstated Number of Inspections

By not reconciling, monthly/annual Program Output Reporting System Reports, Inspection Logs and Annual Inspections Summary for the FDEP, are more susceptible to errors.

Environmental Action Commission Audit Report

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The Storage Tank System Compliance Verification Program requires non-compliance letters to be issued to facility owners that do not comply with the Florida Administrative Code during inspections of their facility. Non-compliance letters require follow-up by the EAC that may include a reinspection or a request of additional information that is subsequently placed in the facility case files. Internal Audit found 9.5% or 8 out of 84 of the non-compliance letters sampled had no evidence of facility reinspection and/or requested compliance documentation in the facility case files.

Environmental Action Commission Audit Report

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Installation requirements according to contract terms require the EAC to obtain and review from the certified contractor an Underground Storage Tank Installation and Removal Form. Internal Audit found that in all cases examined, this form was not in the facility case file (19 out of 19). In addition, the contract requires a site visit for inspections. We found that 4 out of 20 cases or 20% of these inspections were completed by phone without a physical site visit.

Environmental Action Commission Audit Report

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Page 27

Closure rules require the EAC obtain and review from the certified contractor an Underground Storage Tank Installation and Removal Form. We found that in 78.8%, or 26 out of 33 cases examined, this form was not in the facility case file. Other contract exceptions included:

Environmental Action Commission Audit Report

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The contract requires the EAC to inspect the facilities that file Discharge Reporting Forms within 10 days of their receipt. The EAC inspections require the completion of a Compliance Inspection Report. We found that the EAC does not have a system in place to verify that Discharge Reporting Forms were properly followed-up. In addition, the contract requires that Florida Petroleum Liability Insurance and Restoration Program (FPLIRP) checklists be completed by the EAC on confirmed discharges that provides the state with ranking and clean up information. We were not able to test the follow-up on Discharge Reporting Forms due to the lack of a centralized system. We were able to examine a portion of them through the FPLIRP checklist and found that 6 out of 14 or 42.9% had inspections that were not completed within ten days of receipt of the Discharge Reporting Form and 9 out of 14 or 64.3% did not have a compliance inspection report.

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The contract requires that originals or required copies of inspection reports, inspection notification letters, notification letters, non-compliance letters, requested compliance documentation, correspondence to facility owners or other agencies, and Underground Storage Tank Installation and Removal Forms for Certified Contractors be maintained in the regulated storage facility case files. We found numerous inconsistencies and deficiencies in reviewing the facility case files.

Environmental Action Commission Audit Report

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The Small Quantity Generators Notification Program is a statutory program under Florida Statute 403.7234. The program objective is to inform businesses that generate small amounts of hazardous wastes of their legal responsibilities regarding management of hazardous waste, and to obtain information from the generator concerning the quantity and types of hazardous wastes generated annually and the practices used to manage hazardous waste. This program requires notification to small quantity generator businesses once every five years. Fees to pay for the program may come from the occupational licensing process. Internal Audit learned the current five-year reporting period began in 1990. The program was passed down from HRS Pollution Control; however, Pollution Control did not perform in compliance with statutory requirements. When the EAC was formed in June 1991, this program along with many others were transferred to the EAC. At that time the EAC began notifying small quantity generator businesses but did not have the staff to physically inspect the facilities. In the last year, the EAC has obtained proper staffing levels in order to carry out the requirements under the statutes.

Detailed Audit Findings relating to the Small Quantity Generators Notification Program

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The Small Quantity Generators (SQG) Notification Program is a statutory program under Florida Statute 403.7234. Per interview with the FDEP, this program is in the process of being revised. Therefore, adherence to the specifics of the current statute is not being enforced by the FDEP. The FDEP is currently working to get all county programs on a schedule and allowing a grace period until the next five-year period, beginning in June 1995. Internal Audit learned through interview with the management of the EAC that they were not complying with the specifics of the statute. However, the FDEP was informed of the difference in procedures and they confirmed with Internal Audit that procedures followed by the EAC were acceptable. As a result of this statute being in a transitional period, Internal Audit did not test the specific procedures required and relied on the interviews of the FDEP and the EAC.

In addition, Internal Audit found that no inter-local agreement exists between Manatee County and the EAC for the SQG notification/verification program detailing each party's responsibility. The Florida Statute states the program is the responsibility of the counties.

Manatee County currently does not have an occupational license ordinance. Therefore, a surcharge is not imposed for all new businesses that may have SQG's. Occupational licenses can benefit EAC in identifying SQG business and provide revenues for the program.

Environmental Action Commission Audit Report

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The EAC entered into a cooperative funding agreement with the U.S. Geological Survey for continuation of the Braden River Stream Gaging Project for the period August 1, 1993 through July 31, 1994. Since May 1988, the U.S. Geological Survey, in cooperation with Manatee County, has been conducting a stream gaging project on the Braden River in order to establish a "water budget" for that river. The water budget will indicate seasonal volume of flows, as well as the relative contribution from surface and groundwater sources. The project involves the maintenance of one periodic discharge and six daily discharge stations in the Braden River.

Manatee County's contribution to this year's project is $43,000. This amount is provided for in the EAC's annual budget. It is intended that this agreement will continue through 1997.

The proposed split of the financial burden of the study is as follows:

U.S. Geological Survey 50%

City of Bradenton 20%

Manatee County 20%

Southwest Florida Water Management District 10%

None

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The EAC entered into an agreement with the Tampa Bay Regional Planning Council for Benthic Monitoring Implementation for the Tampa Bay National Estuary Program. The agreement period is from September 13, 1993 and continuing through December 31, 1994. The purpose of this program is for the EAC to collect and process samples of bottom dwelling organisms at stations located throughout Tampa Bay. Sample design, collection, processing and analysis protocols will follow those designated by the U.S. Environmental Protection Agency's Environmental Monitoring and Assessment Program for Estuaries. The final product will be a Final Report produced in conjunction with the Environmental Protection Commission of Hillsborough County and a statistical consultant, and will include results of analyses and interpretation from the first year's data collection and an examination of costs and benefits of the year's data collection and an examination of costs and benefits of continuation of the benthic monitoring program.

The EAC is responsibilities include the collection of samples from a minimum of 20 stations. The collection of these samples, the forms to report the results of the sample and other procedures are all determined by a work plan approved by the Tampa Bay National Estuary program. In addition, the EAC will analyze 120 stations for grain/clay content as described in the work plan. The EAC will be compensated for services up to $15,000 under the 1993 contract.

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DETAILED AUDIT FINDING

The EAC entered into an inter-local agreement with Tampa Bay Regional Planning Council for benthic monitoring implementation for the Tampa Bay National Estuary Program. The agreement called for a minimum of 20 stations to be sampled and associated environmental measurements be obtained. The sample collection, the forms to report the results of the sample and other procedures were all dictated by a work plan approved by the Tampa Bay National Estuary Program. Internal Audit found that the EAC was not complying with some of the specific details required by the work plan. Management informed us that Tampa Bay National Estuary Program had time constraints in approving the work plan and therefore adopted a state plan. Changes to the work plan to better suit the Tampa Bay's program are not anticipated to be incorporated until the subsequent year's work plan. Such discrepancies to the work plan included:

Environmental Action Commission Audit Report

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DETAILED AUDIT FINDING

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The Tampa Bay National Estuary Program is an independent agency with a goal of establishing a Comprehensive Conservation and Management Plan for Tampa Bay and producing documents for review and endorsement by local, state, and federal agencies, and the community at large. The EAC, along with other environmental programs in various counties, has provided the estuary program with information from their Ambient Water Quality Programs. In addition, the EAC also contributes in-kind services by participating in Technical Advisory Committees, Proposal Review Committee and other work groups. It is anticipated that the Comprehensive Conservation and Management Plan will be completed by December 1995.

Detailed Audit Findings Relating to the Tampa Bay National Estuary Program:

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The EAC does not have an inter-local agreement with the Tampa Bay National Estuary Program for in-kind services provided. The Tampa Bay National Estuary Program is an independent agency with a goal of establishing a Comprehensive Conservation and Management Plan for Tampa Bay. The EAC has provided the estuary program with information from their Ambient Water Quality Programs. In addition, the EAC also contributes in-kind services by participating in Technical Advisory Committees, Proposal Review Committee and other work groups.

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The Sarasota Bay National Estuary Program is an independent agency with a goal of establishing a Comprehensive Conservation and Management Plan for Sarasota Bay and producing documents for review and endorsement by local, state, federal agencies, and the community at large. It is anticipated the Comprehensive Conservation and Management Plan will be completed no later than January 1995. The Manatee County Board of County Commissioners has a five-year agreement with Southwest Florida Water Management District to contribute funds annually to support the Sarasota Bay National Estuary Program. In addition, the Manatee County Board of County Commissioners has included sections in the Manatee County Comprehensive Plan to support the program. The EAC has also contributed services to support the program. The EAC has been responsible for sample collection and laboratory services in a designated number of stations. In addition, when Sarasota County decided to discontinue their in-house laboratory, the EAC performed laboratory analyses on the samples collected by Sarasota County.

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The EAC does not have an inter-local agreement with the Sarasota Bay National Estuary Program for in-kind services provided. The Sarasota Bay National Estuary Program is an independent agency with a goal of establishing a Comprehensive Conservation and Management Plan for Sarasota Bay. The EAC has been responsible for sample collection and laboratory services in a designated number of stations.

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September 30, 1994

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The Sarasota Bay National Estuary Program has informally delegated to the EAC the responsibility for sample collection and laboratory services in a designated number of stations. When Sarasota County discontinued their in-house laborator