Regulatory Reinvention

The Environmental Protection Agency (EPA) established the Common Sense Initiative in 1994 with the goal of finding ways to reduce or prevent pollution and recommend changes to the existing approach to environmental management. GAO found that in the three years that the Initiative has been under way, it has produced three formal recommendations to EPA, none of which has suggested the types of changes in the existing approach to environmental management that EPA expected. Progress toward the Initiative's goals has been limited by several factors, including the length of time needed to collect and analyze data; difficulties in reaching consensus on the approaches needed to address large, complex issues or policies; and variations in commitments of time and understanding of the technical aspects of environmental issues. EPA gauges the progress of the Initiative on the basis of accomplishments associated with processes or activities, and not on the basis of results. As a result, EPA cannot determine the extent to which the Initiative may cost-effectively reduce or prevent pollution or determine whether such improvements are due to changes in the agency's approach to environmental management.

GAO noted that: (1) in the almost 3 years the Initiative has been under way, it has produced three formal recommendations to EPA, none of which has suggested the types of changes in the existing approach to environmental management that EPA expected; (2) although stakeholders have begun to work collaboratively on environmental solutions, progress toward the Initiative's goal has been limited by several factors, such as the length of time needed to collect and analyze data, the difficulties stakeholders have had in reaching consensus on the approaches needed to address large, complex issues or policies, and variations in stakeholders' commitments of time and understanding of the technical aspects of environmental issues; (3) in addition, the Common Sense Initiative Council and its subcommittees and workgroups have spent considerable time discussing how they would carry out their work and developing their own operating standards; (4) an improved operating framework that better defined the Initiative's goal and expected results and included the specific guidance on how the Initiative would accomplish its work would enable the Council and its industrial sector subcommittees and workgroups to concentrate more of their effort on substantive issues; (5) EPA gauges the progress of the Initiative primarily on the basis of accomplishments associated with its various processes or activities, such as stakeholder meetings, and not on the basis of its results; (6) although such process-oriented information is important, it does not measure the agency's progress in meeting the Initiative's goal, consistent with the Government Performance and Results Act's intent; (7) as a result, EPA cannot determine the extent to which the Initiative may cost-effectively reduce or prevent pollution or ascertain whether such improvements are due to changes in the agency's approach to environmental management; (8) in addition, the Initiative's projects typically do not establish or provide for performance measures to gauge the extent to which they are decreasing pollution and/or reducing costs; (9) GAO found that 11 of the 15 ongoing projects it reviewed did not provide for measuring results; and (10) without such measures, it is difficult to assess progress or demonstrate whether a project's expected outcome has occurred.

Recommendations

Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.

Director: Team: Phone: