REVISED ATTACHMENT O SIMPLIFIES THE PREVIOUS ATTACHMENT HELPING GRANTEES TO USE AND FIND THE PROCUREMENT GUIDANCE THEY NEED BY PROVIDING SUFFICIENTLY DETAILED STANDARDS FOR A MULTIPLICITY OF PROCUREMENT CIRCUMSTATNCES. PERHAPS THE MOST SIGNIFICANT ASPECT OF THE ATTACHMENT IS PROVISION FOR GRANTOR AGENCIES TO PERFORM REVIEWS OF GRANTEES' PROCUREMENT SYSTEMS. THESE REVIEWS ARE INTENDED TO DETERMINE WHETHER A GRANTEE'S SYSTEM SHOULD BE CERTIFIED OR WHETHER GRANTOR AGENCIES NEED TO REVIEW INDIVIDUAL CONTRACT ACTIONS. THE BASIC WEAKNESS OF THE REVISED ATTACHMENT IS ITS FAILURE TO PROVIDE THE FLEXIBILITY FOR GRANTOR AGENCIES WITH UNIQUE PROGRAMS OR PROBLEMS TO ESTABLISH APPROPRIATE PROCUREMENT REQUIREMENTS FOR THEIR GRANTEES WITHOUT APPROVAL FROM THE OFFICE OF MANAGEMENT AND BUDGET. FEDERAL AGENCIES DIFFER IN MANDATES, LEVELS OF FUNDING, KINDS OF PROGRAMS, PROGRAM SIZE, GRANTEE CHARACTERISTICS, AND THE LEVEL OF SCRUTINY PROVIDED BY THE GENERAL ACCOUNTING OFFICE. EPA, PARTICULARLY, BECAUSE OF THE RELATIVE NEWNESS OF THE PROGRAMS UNDERTAKEN AND THE INEXPERIENCE OF GRANTEES, 75 PERCENT OF WHICH ARE LOCALITIES OF 25,000 POPULATION OR LESS, SHOULD PROVIDE MORE SPECIALIZED AND INTENSIVE SUPERVISION THAN IS ALLOWED GRANTOR AGENCIES UNDER THE REVISED ATTACHMENT. THIS LEAVES EPA WITH NO CHOICE BUT TO REQUEST SPECIAL DEVIATION FROM THE ATTACHMENT. (RCB)