Major Management Challenges and Program Risks
Environmental Protection Agency Gao ID: GAO-03-112 January 1, 2003In its 2001 performance and accountability report on the Environmental Protection Agency (EPA), GAO identified important challenges facing the agency in improving environmental information, developing a comprehensive human capital approach, and strengthening working relationships with the states. The information GAO presents in this report is intended to help to sustain congressional attention and an agency focus on continuing to make progress in addressing these challenges--and others that have arisen since 2001--and ultimately overcoming them. This report is part of a special series of reports on governmentwide and agency-specific issues.
The Environmental Protection Agency has made progress toward resolving the specific performance and management challenges that GAO previously identified. However, each of these challenges requires more work and vigilance to be overcome. In addition, the agency must face emerging challenges in managing grant resources to better achieve environmental results and in correcting weaknesses in controls over its financial reporting. Improving environmental information: EPA has taken important steps to improve the environmental information it uses to set priorities and measure progress. For example, EPA has embarked on a major effort to determine the overall status of the nation's environment. EPA has also taken steps to improve the compatibility and security of its data systems. However, EPA must work to further improve its environmental information, fill significant data gaps, and incorporate better scientific understanding into its performance measures. Strengthening human capital management: EPA has conducted a study of its workforce and issued a human capital strategy. However, the agency still must determine the number of employees it needs to accomplish its mission, the technical skills required, and how best to allocate employees among EPA's strategic goals and geographic locations. Similarly, EPA needs to fully prepare for the loss of leadership, institutional knowledge, and scientific expertise that will likely result from upcoming retirements. Making regulatory innovation successful: EPA has invested considerable time and resources in a variety of initiatives to encourage more effective and cost-efficient environmental protection. However, these initiatives have yielded limited results. Our work shows that current environmental statutes significantly impede regulatory innovation. If the statutory obstacles to innovation are not addressed, EPA's future regulatory initiatives may not fare better than past ones. Improving grants planning and management: EPA annually spends over half its budget on grants. However, the agency has often not focused its planning and performance measurement for grants on achieving environmental results. In addition, EPA must address persistent problems in its management and oversight of grants. Strengthening controls over financial reporting: EPA's Inspector General issued an unqualified opinion on EPA's consolidated financial statements for fiscal year 2001. However, the Inspector General identified several internal control weaknesses that EPA needs to address to improve its ability to process, summarize, and report financial data.
GAO-03-112, Major Management Challenges and Program Risks: Environmental Protection Agency
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Performance and Accountability Series:
January 2003:
Major Management Challenges and Program Risks:
Environmental Protection Agency:
GAO-03-112:
A Glance at the Agency Covered in This Report:
The Environmental Protection Agency has the critical and complex
mission of protecting human health and safeguarding the environment. It
works collaboratively with the states, local governments, tribes, and
others on a variety of efforts, including ensuring that
* the air in every American community will be safe and healthy to
breathe;
* all Americans will have drinking water that is clean and safe to
drink;
* America‘s rivers, lakes, wetlands, aquifers, and coastal and ocean
waters will be protected;
* the foods Americans eat will be free from unsafe pesticide residues;
* America‘s wastes will be stored, treated, and disposed of in ways
that prevent harm to people and the natural environment; and
* the United States will lead other nations in reducing significant
risks from climate change, stratospheric ozone depletion, and other
hazards of international concern.
[See PDF for image]
[End of figure]
This Series:
This report is part of a special GAO series, first issued in 1999
and updated in 2001, entitled the Performance and Accountability
Series: Major Management Challenges and Program Risks. The 2003
Performance and Accountability Series contains separate reports
covering each cabinet department, most major independent agencies,
and the U.S. Postal Service. The series also includes a
governmentwide perspective on transforming the way the government
does business in order to meet 21st century challenges and address
long-term fiscal needs. The companion 2003 High-Risk Series: An
Update identifies areas at high risk due to either their greater
vulnerabilities to waste, fraud, abuse, and mismanagement or major
challenges associated with their economy, efficiency, or
effectiveness. A list of all of the reports in this series is
included at the end of this report.
GAO Highlights:
Highlights of GAO-03-112, a report to Congress included as part of
GAO‘s Performance and Accountability Series.
Why GAO Did This Report:
In its 2001 performance and accountability report on the
Environmental Protection Agency (EPA), GAO identified important
challenges facing the agency in improving environmental information,
developing a comprehensive human capital approach, and strengthening
working relationships with the states. The information GAO presents in
this report is intended to help to sustain congressional attention and
an agency focus on continuing to make progress in addressing these
challenges”and others that have arisen since 2001”and ultimately
overcoming them. This report is part of a special series of 25 reports
on governmentwide and agency-specific issues.
What GAO Found:
The Environmental Protection Agency has made progress toward resolving
the specific performance and management challenges that GAO previously
identified. However, each of these challenges requires more work and
vigilance to be overcome. In addition, the agency must face emerging
challenges in managing grant resources to better achieve environmental
results and in correcting weaknesses in controls over its financial
reporting.
* Improving environmental information. EPA has taken important steps to
improve the environmental information it uses to set priorities and
measure progress. For example, EPA has embarked on a major effort to
determine the overall status of the nation‘s environment. EPA has also
taken steps to improve the compatibility and security of its data
systems. However, EPA must work to further improve its environmental
information, fill significant data gaps, and incorporate better
scientific understanding into its performance measures.
* Strengthening human capital management. EPA has conducted a study of
its workforce and issued a human capital strategy. However, the agency
still must determine the number of employees it needs to accomplish its
mission, the technical skills required, and how best to allocate
employees among EPA‘s strategic goals and geographic locations.
Similarly, EPA needs to fully prepare for the loss of leadership,
institutional knowledge, and scientific expertise that will likely
result from upcoming retirements.
* Making regulatory innovation successful. EPA has invested
considerable
time and resources in a variety of initiatives to encourage more
effective and cost-efficient environmental protection. However, these
initiatives have yielded limited results. Our work shows that current
environmental statutes significantly impede regulatory innovation. If
the statutory obstacles to innovation are not addressed, EPA‘s future
regulatory initiatives may not fare better than past ones.
* Improving grants planning and management. EPA annually spends over
half its budget on grants. However, the agency has often not focused
its planning and performance measurement for grants on achieving
environmental results. In addition, EPA must address persistent
problems in its management and oversight of grants.
* Strengthening controls over financial reporting. EPA‘s Inspector
General issued an unqualified opinion on EPA‘s consolidated financial
statements for fiscal year 2001. However, the Inspector General
identified several internal control weaknesses that EPA needs to
address to improve its ability to process, summarize, and report
financial data.
What Remains to Be Done:
GAO believes that EPA should:
* Ensure that recent steps to improve environmental information receive
sustained top management support.
* Implement a systematic and comprehensive human capital approach.
* Articulate a clear and specific endorsement of legislation that would
address statutory obstacles to the agency‘s regulatory reinvention
efforts.
* Strengthen its grants planning and management to better achieve
environmental results.
* Improve its internal controls over financial reporting.
Contents:
Transmittal Letter:
Major Performance and Accountability Challenges:
GAO Contacts:
Related GAO Products:
Performance and Accountability and High-Risk Series:
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January 2003:
The President of the Senate and the
Speaker of the House of Representatives:
This report addresses the major management challenges and program risks
facing the Environmental Protection Agency (EPA) as it works to carry
out its complex mission of protecting human health and safeguarding the
environment. The report discusses the actions that EPA has taken and
that are under way to address the challenges GAO identified in its
Performance and Accountability Series 2 years ago. The report also
summarizes the challenges that remain, new ones that have emerged, and
further actions that GAO believes are needed.
This analysis should help the new Congress and the administration carry
out their responsibilities and improve government for the benefit of
the American people. For additional information about this report,
please contact Robert A. Robinson, Managing Director, Natural Resources
and Environment, at (202) 512-3841 or at robinsonr@gao.gov.
Signed by David M. Walker:
David M. Walker
Comptroller General
of the United States:
[End of section]
Major Performance and Accountability Challenges:
In January 2001 we reported that EPA faced three performance and
accountability challenges in fulfilling its mission of protecting
human health and the environment. First, EPA needed to improve its
environmental and performance information management to set priorities
and measure results. Without a comprehensive picture of environmental
conditions, EPA faces difficulty in setting risk-based priorities for
its programs, evaluating performance progress and environmental
results, and reporting on its accomplishments. Second, EPA needed to
place greater emphasis on developing a comprehensive human capital
program. Without such a program, EPA faces difficulty in aligning human
capital investments with strategic goals and objectives, and
determining the number of employees, the skills, and the deployment of
its workforce needed to accomplish its mission. Finally, we reported
that the nation‘s complex future environmental challenges require EPA
and its stakeholders to adopt fundamentally different regulatory
approaches that are more flexible and less administratively burdensome.
During the past 2 years, EPA has continued its traditional efforts to
protect the nation‘s air, land, water, and human health, while
undertaking new roles and responsibilities, such as mitigating the
environmental effects of the tragic events of 2001. EPA played a major
role in responding to the attacks at the World Trade Center, assisting
in debris removal, air and water quality monitoring, worker protection,
dust cleanup, and criminal investigation. Similarly, EPA worked with
the Federal Bureau of Investigation and the Department of Defense at
the Pentagon crash site to monitor air and drinking water quality and
to collect forensic evidence for criminal investigation. EPA also
provided personnel, equipment, and contractors to help assess or clean
up anthrax contamination at the U.S. Postal Service, the Capitol Hill
complex, and other government sites. Despite its
increased responsibilities, EPA has, to its credit, also undertaken
some major initiatives to improve the overall management of the agency
and its resources.
These management initiatives have helped EPA make progress in
addressing the management challenges we identified in our 2001 report.
For example, in an effort to improve the quality of the information
used to set priorities and measure results, EPA plans to issue the
first-ever State of the Environment Report in early 2003, which will
summarize available information on the condition of the nation‘s
environment and identify the remaining information needed to complete
the picture. In addressing its human capital challenges, EPA has begun
to develop a workforce assessment system that will identify the
technical skills and number and type of positions required, inventory
the skills of the current workforce, examine attrition rates, and
forecast the number of new hires required. Finally, in an effort to
adopt regulatory approaches that are more flexible and less
administratively burdensome, EPA has invested considerable time and
resources in a variety of initiatives to encourage more effective and
cost-efficient ways of protecting the environment. However, for each of
the management challenges we identified in 2001, more work remains to
be done. In addition, we have identified two other challenges that EPA
needs to address. Specifically, EPA needs to strengthen its grants
management and improve internal controls over its financial management
reporting. In sum, the major management challenges that EPA faces are
as follows:
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EPA Needs to Ensure That Recent Steps to Improve Environmental
Information Receive Sustained Top Management Support:
Information is critical to EPA‘s mission of protecting the environment
and public health. Information from scientific research, from the
monitoring of air and water quality and other environmental parameters,
and from epidemiological and other studies of the links between
environmental pollutants and human health effects is needed to inform
EPA‘s policies and to assess the effectiveness of the agency‘s policies
and programs in achieving desired results. While the quality of
environmental information and the scientific understanding of how
environmental factors can affect ecological conditions and human health
have improved since EPA‘s inception, the pace of progress has sometimes
been slow. Furthermore, significant gaps in environmental information
and scientific knowledge remain. EPA has taken a number of recent
actions to implement recommendations that we and others have made to
enhance the quality and usefulness of the environmental information
that it and its partners generate. These actions include adopting an
information strategic plan that envisions managing information as a
strategic resource, developing data standards to facilitate efficient
reporting, aggregating and integrating environmental data, measures to
improve information security, and initiatives to develop a
comprehensive set of environmental indicators and use them to provide
the public with a baseline report on the current state of
the environment.
To ensure that these and related actions continue and achieve the
desired results, EPA management needs to develop annual or multiyear
action plans to translate the ’vision“ embodied in the strategic
information plan into specific actions that will advance the
achievement of the plan‘s goals. Action plans would, among other
things, establish target dates for completing specific actions and
identifying the resources required to meet these milestones. Action
plans could help ensure that the strategic plan becomes and remains a
living document that informs agency decision making; guides investments
in information infrastructure, technology, and human capital; and
evolves over time to reflect progress, changing circumstances, and new
imperatives. Sustained progress in enhancing the agency‘s information
management will require a long-term commitment of management attention,
including appropriate follow-through and resource support.
Significant Gaps Remain in Environmental Data and Science:
The results of scientific research, and the information and knowledge
gained from monitoring the environment and public health, are essential
foundations for developing; assessing; and refining environmental
policy, including developing measures to gauge the effectiveness of
that policy in producing the desired outcomes. While EPA, the states,
and other environmental partners carry out a considerable amount of
research and collect extensive information on environmental parameters,
significant gaps and weaknesses remain in the knowledge and
understanding of environmental stressors and pollutants and their
effects on ecological condition and human health. Information obtained
from environmental monitoring is often fragmentary and of varying
quality, information on human exposures to toxic pollutants is limited,
and the ecological and public health effects of many environmental
contaminants are still not well understood. As we have reported in the
past, such gaps in the data and in scientific understanding hamper
EPA‘s efforts to (1) perform critical human exposure and risk
assessments, (2) use risk as a basis for setting program priorities,
(3) obtain a comprehensive understanding of environmental conditions
and changes over time, and (4) assess the agency‘s effectiveness in
carrying out its mission of protecting the environment and
human health.
Information on the health risk posed by exposures to toxic chemicals is
critical to EPA‘s policy decision making. However, the information
needed to credibly assess these risks often does not exist. In a May
2000 report on the lack of data regarding human exposures to toxic
chemicals in the environment, we reported that exposure data were
limited because the data were being collected nationwide for only a
small percentage of the nearly 1,500 potentially harmful chemicals we
reviewed.[Footnote 1] For the nearly 500 chemicals that EPA identified
as most in need of testing under the Toxic Substances Control Act, only
2 percent were being tested for human exposure. We recommended that the
Secretary of Health and Human Services and the EPA Administrator
develop a coordinated federal strategy for the monitoring and reporting
of human exposures to potentially toxic chemicals.
Progress in this area has been slow, however, and the benefits of
initiatives currently in the discussion or planning stages are likely
to be years away from realization. For example, EPA‘s Office of
Research and Development is moving to establish a program addressing
environmental public health outcomes as part of its Human Health
Research Strategy. This Office recently held a workshop involving
several public health agencies to help in developing a research
framework that would be complementary to other agencies‘ efforts and
define opportunities for collaboration. Also, according to officials of
EPA‘s Office of Environmental Information, that Office worked with the
Centers for Disease Control and Prevention in 2002 on a potential
cross-agency initiative to develop and link environmental and human
health information resources, specifically the Centers‘ National
Environmental Public Health Tracking Program network and EPA‘s National
Environmental Information Exchange Network. The proposed linkage holds
the potential to enhance information technology tools to foster the
analysis and dissemination of information obtained to a variety
of audiences.
Important data gaps also remain in EPA‘s Integrated Risk Information
System, a database containing information on human health effects that
may result from exposure to chemicals in the environment. Specifically,
the database contains no basic data on the toxicity of about two-thirds
of the known hazardous air pollutants and only limited information on
the ecological effects of environmental pollutants. Likewise, there are
significant data gaps and weaknesses in EPA‘s National Water Quality
Inventory, the primary report on the condition of the nation‘s waters.
The gaps result from the fact that only a small percentage of U.S.
waters is assessed for quality and only a limited number of assessments
are based on current, site-specific monitoring information.[Footnote
2] Incomplete water quality data make it difficult for EPA to
accurately describe the condition of the nation‘s waters and report on
the progress being made toward achieving established water quality
goals. The data gaps and weaknesses are also problematic because agency
officials rely on state-reported data in the inventory when making
program management decisions, including determining how certain Clean
Water Act funds will be allocated among the states.
EPA‘s research on the use of biological indicators for environmental
assessments demonstrates the importance and value of research.
Because site-specific water quality monitoring is complex, difficult,
and expensive, for many contaminants (including sediment, toxic
chemicals, pathogens, and invasive species) that are potentially of
concern, it is doubtful that many states, territories, and tribes will
ever be able or willing to devote sufficient resources to monitor their
streams and other water bodies adequately and on a regular basis.
Recognizing this, EPA has conducted research on alternative
methodologies for estimating the environmental conditions of streams,
estuaries, and other water bodies. EPA‘s Environmental Monitoring and
Assessment Program (EMAP) has conducted studies that have established
that the use of biological indicators that integrate chemistry,
habitat, pathogens, and other stressors over time lead to less
expensive approaches to monitoring the environmental conditions in
streams and other water bodies. According to EPA, as of May 2002,
20 states had adopted a methodology based on EMAP to determine the
environmental condition of steams and estuaries on a regional scale. In
addition, the agency reports that it has several initiatives under way
for the greater application of this approach to coastal areas and
streams in arid areas of the West and for assessing the nation‘s great
rivers.
In November 2001, at the direction of its Administrator, EPA embarked
on a major effort that holds the promise of providing, for the first
time ever, an overall picture--albeit less than perfect and complete--
of the nation‘s current environmental conditions and trends and,
equally important, of highlighting data gaps and indicating the
research and information collection efforts needed to fill those gaps.
The Administrator directed EPA‘s Office of Environmental Information
and Office of Research and Development to lead an agencywide initiative
to develop a set of indicators of environmental quality and use these
indicators as a basis for drafting the State of the Environment Report
to be issued in early 2003. The report is intended to serve as the
basis for initiating a broad public discussion about the environment
and environmental protection. As currently envisioned, it will
(1) describe current environmental conditions and trends using existing
data and indicators developed by EPA and others, (2) identify data gaps
and research needs, (3) discuss challenges that government and
other environmental partners face in filling those gaps and needs, and
(4) be accompanied by extensive technical information and support. The
report is to encompass five environmental theme areas: human health,
ecological condition, clean air, pure water, and better protected land.
Under human health, for example, the report will explore trends in
diseases, human exposure to environmental pollutants, and diseases
thought to be related to environmental pollution.
EPA views the draft State of the Environment Report as the starting
point of a public dialogue on environmental protection issues and an
important step toward a more comprehensive approach to identifying
priorities, focusing resources on areas of greatest concern, and
managing its work to achieve measurable results. If successful in its
aims, this multiyear undertaking could make a substantial contribution
not only to identifying and filling research and data gaps but also to
measuring progress within an overall framework of ecological and human
health, assisting EPA‘s strategic-planning efforts, and facilitating a
transition to performance-based management driven by environmental
goals. To be successful, however, particularly in identifying and
filling research and data gaps, this effort will require sustained
cooperation and coordination on the part of EPA, other federal and
state partners, academic institutions, and others. It will also require
adequate and dependable financing, something that many people--
including advocates of strong environmental science in the Congress--
may argue has been absent until now.
EPA Has Made Progress in Overcoming Data System Weaknesses That Limit
the Usefulness of Environmental Data, but More Needs to Be Done:
We reported in January 2001 that EPA‘s data management system is
outmoded in numerous respects, including having separately designed,
media-specific databases that are generally not technically
compatible.[Footnote 3] This incompatibility is a legacy of the
historical ’stove-pipe,“ or single media, orientation of EPA‘s programs
and has served as a barrier to the efficient reporting, aggregation,
and integration of data to present comprehensive information on
pollutants, industrial sectors, localities, and environmental
conditions and trends. Despite this historical legacy, however, EPA has
recognized the importance of integrated environmental information and
the need to make its databases compatible with one another and with
those of its state and tribal partners. For example, since our January
2001 report, the agency has made notable progress in implementing an
initiative to standardize basic data element definitions and formats to
permit the information contained in EPA and state and tribal databases
to be combined to present a more comprehensive picture of environmental
conditions and results. Agency officials also view data standardization
as a way to reduce the reporting burden for states and industry by
allowing more integrated data reporting and facilitating electronic
reporting via the Internet.
Implementing a recommendation that we made in a September 1999 report,
that the agency coordinate its data standardization efforts with the
states, federal agencies, and other organizations, EPA and its state
and tribal partners created the Environmental Data Standards Council to
work cooperatively to develop consensus-based data standards.[Footnote
4] To date, EPA and its partners on the Council have adopted and begun
to implement seven final data standards that will foster consistently
defined and formatted data elements and sets of data values and
facilitate public access to more meaningful data. The data standards
that have been finalized are:
* the date,
* the latitude/longitude,
* biological taxonomy,[Footnote 5]
* chemical identification,
* facility identification,
* permitting, and:
* the Standard Industrial Classification/North American Industrial
Classification System.
As an example of the function and value of such data standards, the
’chemical identification“ standard provides a consistent way to
identify and represent chemical substances across the agency. It
provides EPA with a unique, unambiguous, common name for each chemical
substance and chemical grouping in which the agency has an interest,
and provides a way to reference data about chemical substances across
EPA systems and to search for chemical entries in these systems. By the
same token, the ’facility identification“ data standard provides, for
the first time, a unique facility identification number for any
facility subject to EPA‘s regulatory authority, regardless of the media
program(s) involved. Achieving consensus even on such a seemingly
simple and straightforward matter was by no means an easy task. EPA
officials told us that it was necessary to overcome broad resistance
stemming from concerns about ’big brotherism.“:
In addition to these final standards, a number of new standards are
currently under development or envisioned by the Council and EPA action
teams. These standards include:
* contact,
* enforcement/compliance,
* tribal identifiers,
* reporting water quality results for chemical and microbiological
analytes,
* geospatial referencing,
* the electronic reporting of environmental laboratory results,
* federal facilities identifiers, and:
* the National Pollutant Discharge Elimination System (NPDES).
The NPDES will pick up where the final permitting standard leaves off,
by standardizing data elements related to water pollutant discharge
permits.
Other EPA initiatives related to the effort to integrate data within
and across agency programs and with partners and stakeholders include
the cross-agency Information Integration Program, which is intended to
foster the development of an information integration strategy to
identify tools and approaches that can be used across the agency and by
states and tribes to support improved decision making and increase
efficiency. This program culminated in (1) the creation of the Model
for Information Integration, which provides a framework for EPA‘s
integration efforts and establishes a vision for its target information
architecture; (2) the development of a system of registries that serve
as repositories for commonly used data element definitions and
information about data (metadata); [Footnote 6] and (3) an
Environmental Information Management System, developed by EPA‘s Office
of Research and Development, which provides descriptive information
about various data sets; databases; documents; models; and multimedia
projects, enabling users to identify and use the data that best meet
their needs.
While the measures taken to date represent noteworthy progress
toward the goal of environmental data compatibility and integration,
EPA still has some distance to travel and important challenges to
overcome. For the most part, the agency has focused on the
compatibility of its data with those of state and tribal agencies
rather than with the data of other federal agencies and nongovernmental
organizations that share an interest in environmental protection.
Improved collaboration between federal agencies is essential because
(1) individual agencies have different capacities and skills that are
complementary and lend themselves to fruitful collaboration and
(2) separate attempts have fallen short of supporting the large efforts
that are needed to produce high-quality, comprehensive data on
environmental conditions and trends. In this regard, EPA‘s Science
Advisory Board, created to provide the agency with expert and impartial
external scientific advice, recommended that EPA do more to link its
databases with external sources. For example, the Board noted that
’answering many health-related questions frequently requires linking
environmental data with census, cancer, birth registry, or other data
systems (such as water distribution maps) to determine whether there is
a relationship between the environmental measures and health.“:
Although EPA officials do not dispute the value of linking the agency‘s
databases with those of other federal agencies and nongovernmental
organizations, they note that efforts have been limited by resource
constraints and a lack of statutory authority to require other agencies
to collect and report data using formats compatible with those used by
EPA. Acknowledging that EPA may have unduly focused on state and tribal
partners, to the exclusion of federal agencies and others when
composing the Environmental Data Standards Council, officials of the
Office of Environmental Information pointed out that one of the reasons
for publishing proposed data standards in the Federal Register for
public comment, before making them final, is to solicit the
participation and input of other interested and knowledgeable parties,
including other federal agencies. They noted that another federal
agency, the Department of the Interior‘s U.S. Geological Survey (USGS),
in conjunction with the National Water Quality Monitoring Council, was
instrumental in proposing and initiating the development of the
standard for Reporting Water Quality Results for Chemical and
Microbiological Analytes. In addition, USGS has taken the lead in
developing a geospatial data standard, an e-government initiative that
is highly relevant to EPA and on which EPA is collaborating.
Data Limitations Still Hinder Development of Results Measures, but
Groundwork Is Being Laid for More Effective Performance Measurement:
Well before passage of the Government Performance and Results Act of
1993 (Results Act), a number of internal and external studies,
including our August 1988 general management review of EPA,[Footnote 7]
called on the agency to manage for measurable environmental results as
a way to improve its performance and accountability. As we and others
noted, developing effective measures of the environmental results of
EPA‘s policies and program activities would help the agency‘s managers
in assessing the extent to which the agency contributes to
environmental improvements and in setting priorities, planning, and
budgeting. The effective measurement of environmental results would
also serve to make the agency more accountable to the Congress and the
public for its performance.
The Results Act, for the first time, formally required EPA and other
federal agencies to prepare performance plans containing annual
performance goals and measures to help them move toward managing for
results. Performance goals and measures were to be used to assess an
agency‘s progress toward achieving the results expected from its major
functions. Performance goals established under the act‘s requirements
constitute target levels of performance expressed as tangible,
measurable objectives against which actual achievement can be compared.
Performance measures constitute the ’yardsticks“ to assess success in
meeting performance goals.
Notwithstanding EPA‘s timely actions to implement the Results Act‘s
procedural requirements, the agency‘s progress in moving toward
measuring the actual results of its activities has been slow. To a
large extent, EPA‘s performance goals and their associated performance
measures continue to be expressed as outputs--environmental
standards established, permits issued, enforcement actions taken--
rather than as end outcomes, measures that directly show how EPA‘s work
led to improvements in environmental conditions or public health. For
example, as shown in table 1, for fiscal year 1999, 86 percent of EPA‘s
278 performance measures consisted of output measures, while only
14 percent consisted of outcome measures. Three years later, in fiscal
year 2002, 71 percent of the agency‘s 365 performance measures
consisted of output measures, while the percentage of outcome measures
had moderately increased to 29 percent. For fiscal year 2003, under way
since October 1, 2002, EPA has a total of 284 performance measures of
which 60 percent are output measures and the remaining 40 percent,
outcome measures.
Close examination, however, shows that only a portion of EPA‘s fiscal
year 1999, fiscal year 2002, and fiscal year 2003 outcome measures
actually measured end outcomes, the environmental results of its
programs and activities (7 percent of fiscal year 1999 performance
measures, 22 percent of fiscal year 2002 performance measures, and
27 percent of fiscal year 2003 performance measures).[Footnote 8] The
remaining EPA outcome measures for these 3 fiscal years are more
properly classified as measures of intermediate outcomes rather than
end outcomes. Intermediate outcomes indicate progress or presumed
contributions toward achieving end outcomes. They are used when end
outcomes are not immediately clear, easily delivered, or quickly
achieved. For example, inducing local jurisdictions to adopt higher
water quality standards is an intermediate outcome contributing,
presumably, to the end outcome of safe drinking water.
Table 1: Classification of EPA‘s Performance Measures:
Fiscal year: 1999; Outputs: 86% (240 of 278); Intermediate outcomes: 7%
(18 of 278); End outcomes: 7% (20 of 278); Total outcomes: 14% (38 of
278).
Fiscal year: 2002; Outputs: 71% (260 of 365); Intermediate outcomes: 7%
(26 of 365); End outcomes: 22% (79 of 365); Total outcomes: 29% (105 of
365).
Fiscal year: 2003; Outputs: 60% (170 of 284); Intermediate outcomes:
13% (38 of 284); End outcomes: 27% (76 of 284); Total outcomes: 40%
(114 of 284).
[End of table]
Source: EPA.
Note: GAO‘s analysis of EPA‘s data.
The relatively low percentage of end outcome measures in EPA‘s
collection of performance metrics is largely a reflection of the fact
that data and scientific knowledge essential to permit end outcome
measurement are often lacking, as well as the fact that there is often
a significant time lag between actions taken to protect and improve the
environment and demonstrable effects. In addition, other factors, such
as the level of economic activity, can have confounding effects,
obscuring the role played by EPA programs in environmental change. The
data/knowledge problem is one that EPA is attempting to address through
its ongoing indicators initiative and anticipated State of the
Environment Report. While these efforts are expected to identify
important data gaps and point to the research needed to improve the
scientific understanding of the environment, it may be years before
such gaps are filled and research yields dividends of knowledge and
scientific understanding sufficient to allow for a more reliable
measurement of the environmental results of EPA‘s program activities.
Hence, the measurement of the environmental results of EPA‘s programs
and managing for improved performance are likely to continue to pose a
significant challenge for the agency for some time to come.
In addition to the environmental indicators and State of the
Environment Report initiatives, the agency has undertaken another
related initiative that has a similar potential over the longer term to
enhance its ability to measure and manage for environmental outcomes.
Known as ’Managing for Improved Results,“ this project was launched in
the summer of 2001 by EPA‘s Deputy Administrator, who charged the
Office of the Chief Financial Officer with the task of examining a mix
of near-and long-term reforms to improve the agency‘s ability to manage
for results. In response to this charge, a steering group of senior
headquarters and regional staff, reporting to the Deputy Administrator,
was assembled to (1) examine EPA‘s management practices, including
priority setting, planning, budgeting, and performance tracking/
reporting, and (2) explore options both for significant and far-
reaching reforms as well as smaller-scale improvements. Among the more
far-reaching recommendations that the steering group has made is the
recommendation that the agency develop a new strategic-planning
architecture with a new goal structure focused on a reduced number of
environmentally focused goals, as few as 5 in number (compared with the
current 10 strategic goals). With respect to performance measurement,
the steering group recommended that EPA‘s program offices develop
better performance measures as part of the strategic plan‘s goal
revision process. Actions envisioned as part of this recommendation
include (1) program offices responsible for each strategic objective
developing multiyear plans to improve the quality and
outcome-orientation of associated annual performance goals and annual
performance measures, (2) national program managers and lead regions
collaborating to improve measures, (3) goal teams ensuring that data of
adequate quality will be available, (4) the Office of the Chief
Financial Officer‘s expansion of its consultation and technical support
to the rest of the agency, and (5) using State of the Environment
Report indicators to guide the development of the next improved
generation of outcome-based performance goals and measures.
All of these initiatives aimed at improving EPA‘s ability to manage for
environmental results are, essentially, long-term in nature. They will
require a long-term commitment of management attention, follow-through,
and support--including the dedication of appropriate and sufficient
resources--for their potential to be fully realized. A number of
similar initiatives in the past have been short-lived and disappointing
in terms of lasting contributions to improved performance management.
Just as the forthcoming State of the Environment Report is intended to
foster an ongoing dialogue between the agency and its partners,
including the broader public, both the Environmental Indicators
Initiative and the Managing for Results Initiative represent just the
beginnings of long-term undertakings. These initiatives‘ ultimate
payoff will depend on how fully EPA‘s organization and management
support them and the extent to which needs identified--for more and
better data; for scientific research; for a restatement of strategic
goals; and for a refinement of performance goals, objectives, and
measures--are addressed in a determined, systematic, and sustained
fashion over a period of years. Even the task of revising the agency‘s
strategic goal structure and reducing the number of goals to a few
specifically focused on environmental dimensions will not be an easy
matter on which to achieve consensus and, once agreed upon, to
implement. As one senior EPA official pointed out, this is particularly
true when, as in EPA‘s case, budgeting is tied to the agency‘s
goal structure.
Significant Progress Made in Enhancing EPA‘s Information Security:
The security of EPA‘s information is critical to its mission of
protecting human health and the environment, a fact underscored by the
events of September 11, 2001, and their aftermath. Much of the
sensitive information contained in EPA‘s databases regarding
environmental infrastructure, such as municipal drinking water systems
and the location of stores of toxic chemicals, could be expected to
hold great interest for would-be terrorists and others with criminal
intent. In a review of EPA‘s information security program issued in
July 2000, we found serious and pervasive problems that ’essentially
rendered [the program] ineffective.“[Footnote 9] Our report
characterized the agency‘s security practices at the time as weak and
largely a paper exercise that did little to mitigate risks to the
agency‘s data and systems. We recommended that EPA take a number of
steps to improve security program management and planning, enhance
computer incident management, and strengthen access controls associated
with its major computer operating systems and agencywide network.
Since the issuance of our report, EPA and the agency‘s Office of
Inspector General reported that the agency has made substantial
improvements to its information security program. The agency has
improved its risk assessment and planning processes, implemented major
new technical and procedural controls, issued new policies, initiated a
regular process of testing and evaluation, and devoted significant
attention and resources to improving the technical information
infrastructure and building the management framework for an effective
security program, as documented by EPA‘s Office of Inspector General in
September 2002 and by an August 2002 GAO follow-up on the status of
agency efforts to implement the recommendations in our July 2000
report. Under the leadership of the Office of Environmental Information
(OEI), the agency has been taking steps to ensure appropriate public
access to the information in EPA‘s computer systems, while protecting
the confidentiality and integrity of its information. According to EPA
and the agency‘s Office of Inspector General, specific actions taken to
improve information security and to address problems that we, the
Inspector General, and others have cited, include the following:
* Developing the Information Security Action Plan to guide EPA‘s
revised security program and respond to the findings and
recommendations of our July 2000 report.
* Establishing the Technical Information Security Staff, within OEI, to
review EPA‘s security accomplishments, manage the agency‘s security
efforts, and evaluate needs for future security governance.
* Designating program and regional Information Security Officers,
who are responsible for coordinating security activities, providing
guidance, reviewing security practices, and informing colleagues of
their information security responsibilities.
* Defining, in consultation with EPA‘s state and tribal partners,
levels of security that must be met for the exchange of information
across the National Environmental Information Exchange Network. These
levels range from Level 1 (public information, available to all users
without authentication) to Level 4 (information requiring the highest
levels of proof of the integrity and origin of data, along with
confidentiality and third-party verification).
In an August 2002 follow-up on the status of EPA‘s efforts to address
our July 2000 report‘s recommendations, we concluded that although
some work remained to be completed to address the problems cited in
the report, EPA had made sufficient progress to justify closing out the
recommendations. However, notwithstanding the progress EPA has made in
this area, EPA‘s Inspector General continues to identify EPA‘s security
program management as a management challenge (albeit of a lower order
than in years past). As the Inspector General has noted, the dynamic
nature of security threats will require continued attention and
vigilance on the part of EPA management. The agency, moreover, will
need to strive to build and maintain a strong centralized security
program with an oversight process that identifies and adequately
addresses vulnerabilities and to ensure that information resources and
environmental data are secure. Given the agency‘s decentralized
organizational structure, it is essential for the success of EPA‘s
information security program that OEI exercise a strong leadership and
monitoring role. A major continuing challenge will be to provide the
public with access to a wide range of environmental information, while
also protecting against the use of this information in ways that could
harm the environment or public health and safety.
EPA‘s Recently Completed Information Strategy Needs to Be Implemented
Systematically and Revised Periodically in Light of Progress and
Changing Circumstances:
In a September 1999 report, we recommended that EPA develop a
comprehensive information management strategy that would (1) establish
milestones and identify the resources needed to fill key data gaps;
(2) identify and develop necessary data standards; and (3) coordinate
its data standardization efforts with other federal agencies, the
states, and other entities.[Footnote 10] In our January 2001 report on
EPA‘s major management challenges and program risks, we reported that,
beyond agreeing with our 1999 recommendation, EPA had made limited
progress in developing a comprehensive information management strategy
to ensure the completeness, compatibility, and accuracy
of data.[Footnote 11]
In July 2002, EPA issued its ’Strategic Information Plan: A Framework
for the Future,“ which largely responds to our 1999 recommendation. The
plan, developed by EPA‘s Office of Environmental Information, under the
direction of the Chief Information Officer, sets a new vision for EPA‘s
information management, which is to provide government and citizens
with fast, relevant, and integrated information about environmental and
public health conditions, trends, and potential threats. The plan
envisions establishing a system that advances the creation, management,
and use of information as a strategic resource at EPA and stresses the
need to streamline and strengthen the agency‘s information management
infrastructure to improve the effectiveness and efficiency of its
operations and programs. The plan sets six specific information
management goals for the agency: (1) improve the use of environmental
information, (2) collect appropriate data, (3) strengthen EPA‘s
information infrastructure, (4) enhance access to information,
(5) adopt an agencywide approach to using information to make
management decisions, and (6) invest in human capital for
information management.
EPA‘s Information Plan provides a much needed long-term strategic
vision for the information management function. It charts the course
the agency will need to pursue in coming years, in consultation and
collaboration with its state and tribal partners and other key
stakeholders, to design and implement systems and services that are
aimed at streamlining data collection, making the Internet the method
of choice for reporting and exchanging information, and making more
effective use of the information it collects.
As previously noted, a number of initiatives are already under way
within the agency to implement aspects of the goals laid out in the
strategic plan, including data quality improvement, the development and
implementation of data standards, and building networks for data
exchange. Missing in EPA‘s strategic information plan, however, are
indications of priorities, milestones, and estimated resource
requirements that could drive forward movement and provide a more
detailed road map for goal implementation. We recommended such an
’action plan“ in our September 1999 report and continue to believe that
an annual or multiyear action plan is needed to translate the ’vision“
embodied in the strategic plan into specific actions that will advance
goal achievement. An action plan would lay out in some detail and
specificity the discrete goal-related measures that will be taken
during the planning period. It would also establish target dates for
the completion of action and identify resources required to meet these
milestones. Action plans, we believe, could ensure that EPA‘s strategic
plan becomes and remains a living document that informs agency
decision making; guides investments in information infrastructure,
technology, and human capital; and evolves over time to reflect
achievements, changed circumstances, and new imperatives.
EPA Needs to Implement a Systematic and Comprehensive Human Capital
Approach:
High-performing organizations in the private and public sectors have
long understood the relationship between effective ’people management“
and organizational success. An organization‘s people--its human
capital--are its most critical asset in managing for results. EPA, like
many other federal agencies, has historically given insufficient
attention to strategically managing its human capital. As a result, EPA
faces critical agencywide human capital challenges that, if not
addressed, will limit its ability to achieve its mission. Specifically,
the agency has yet to determine the number of employees it needs to
accomplish its mission objectives, the technical skills required, and
how to best allocate employees among EPA‘s strategic goals and
geographic locations. Furthermore, with a substantial portion of its
workforce nearing retirement age, it is imperative that EPA fully
prepare for the resulting loss of leadership, institutional knowledge,
and scientific expertise.
To its credit, EPA has taken some steps in recent years to improve its
human capital management. The agency has conducted a workforce study
that identifies some of the general skills and abilities that EPA
employees need. Furthermore, the agency has developed a human capital
strategy that identifies EPA‘s vision for its people, its core values,
and its major human capital goals. However, EPA is far from being able
to implement a systematic and comprehensive human capital approach that
will enable the efficient and effective achievement of its mission
objectives. Specifically, EPA needs to (1) develop a system for
determining the number of employees and skills required to meet its
mission objectives and allocating staff according to identified mission
needs and (2) recruit, train, and develop employees to ensure that EPA
will have the leadership, institutional knowledge, and scientific
expertise needed to accomplish its mission, both now and in the future.
EPA Needs to Assess Workforce Requirements and Allocate Staff to
Accomplish Mission Objectives:
High-performing organizations identify their current and future human
capital needs, including the appropriate number of employees, the key
skills required for mission accomplishment, and the appropriate
deployment of staff across the organization. They then identify and
address any human capital gaps or surpluses. However, EPA, like many
other federal agencies, has yet to determine its current or future
human capital needs for accomplishing its mission or to fully inventory
the skills in the current EPA workforce. EPA‘s 1999 workforce study
identified general skills needed by EPA employees (such as effective
communication and collaboration) but did not identify the scientific or
technical skills critical to EPA‘s mission. Nor did the study address
the number of staff or the skills EPA needs agencywide and by
geographic location. In response to a 2001 Office of Management and
Budget (OMB) request, EPA, along with other federal agencies, prepared
a workforce analysis that included information on the number of its
supervisors and managers, their grade level, their location, and the
number of people they oversee, and an evaluation of the skills of the
workforce. However, because EPA has not yet comprehensively assessed
its workforce, EPA‘s human resource managers told us that the analysis
that it submitted to OMB is only a starting point for a systematic
workforce analysis.
Without reliable and valid workforce information, EPA cannot ensure
that it is hiring the right number and type of people or allocating
existing staff resources to effectively meet current or future mission
needs. During the past 12 years, when the size of the civilian federal
workforce was reduced significantly, EPA increased its workforce from
15,277 in fiscal year 1990 to 17,802 in fiscal year 2002. In doing so,
EPA hired thousands of employees without systematically considering the
workforce impact of the changes in environmental laws and regulations,
the technological advances, or the expansion in state environmental
staff that occurred during the 1990s. Similarly, EPA has yet to factor
these workforce changes into its allocation of existing staff resources
to its headquarters and regional offices to meet its strategic goals.
Furthermore, if EPA should need to downsize, as other federal agencies
have done, it would not have the information needed to ensure that
staff reductions could be absorbed with minimal impacts on mission
objectives. For example, the Congress denied EPA‘s proposal to downsize
its enforcement staff in order to shift resources to state enforcement
grants because EPA had no workforce information to demonstrate that
staff reductions would not jeopardize environmental enforcement.
In July 2001, we recommended that EPA develop a system for workforce
allocation and deployment that is explicitly linked to the agency‘s
strategic-planning efforts and is based on the systematic efforts of
each major program office to accurately identify the size of the
workforce, the deployment of staff geographically and organizationally,
and the skills needed to support EPA‘s strategic goals.[Footnote 12]
EPA has begun to develop a system, known as the ’national strategic
workforce planning system,“ that may substantially implement this
recommendation. The system is to be used by EPA regions and in
headquarters offices to assess workforce needs. According to EPA, the
system will, among other things, identify the technical skills and the
number and type of positions required, inventory the skills of the
current workforce, examine attrition rates, and forecast the number of
new hires required. EPA issued a methodology for the workforce-planning
system in September 2002 and has begun implementing the system in
several headquarters offices and in the Chicago, Kansas City, and
Seattle regional offices. EPA expects agencywide implementation of the
workforce-planning system to be under way by late 2003.
Although EPA‘s proposed workforce-planning system appears promising, it
is too early to determine how it will affect EPA‘s ability to
systematically allocate staff. As EPA‘s Deputy Assistant Administrator,
Office of Administration and Resources Management, acknowledged, EPA
has made progress in workforce planning, but the most difficult
challenges remain--such as using workforce data to make difficult
staffing decisions. For example, EPA‘s workforce planning will need to
take into account the agency‘s extensive use of grants to states and
awards to contractors to perform EPA‘s work. The agency estimates that
its contracted work alone would require an additional 11,000 to 15,000
employees if contractors were not used. Thus, EPA must plan for a
workforce that is adept at both delivering services directly and
managing the cost and quality of services delivered by third parties on
the government‘s behalf. In addition, EPA must work diligently and
effectively to gain support for its workforce-planning efforts within
both the executive and legislative branches.
Moreover, EPA‘s workforce-planning system, along with the agency‘s
other human capital efforts, will need to incorporate the implications
of major management initiatives. Specifically, EPA has undertaken a
comprehensive effort to assess the state of the environment, identify
priorities for environmental and human health improvements, and focus
its resources on achieving results in the areas of greatest concern.
EPA is currently working to integrate its ’state of the environment“
effort into its agencywide strategic plan. According to EPA officials,
the revised strategic plan will largely determine EPA‘s workforce
needs, and workforce allocation will be tied to the relative priority
assigned to strategic goals. Once the strategic plan is finalized
(expected in late 2003), EPA will then need to determine its impact on
the agency‘s human capital resources and systems.
EPA Needs to Ensure Continuity of Leadership and Mission-Critical
Skills:
To ensure a continuing ability to accomplish their mission objectives,
federal agencies need to aggressively pursue comprehensive succession
planning and executive development to address the loss of leadership
and institutional knowledge that will result from Senior Executive
Service (SES) retirements. At EPA, 162 senior executives, or
60 percent, will become eligible for retirement in the next 5 years. As
shown in figure 1, potential retirements may create particularly severe
leadership shortages in some EPA units and regions, such as region 7
(Kansas City) and region 10 (Seattle), where about 86 percent of the
executives will become eligible to retire over the next 5 years.
Figure 1: Percentage of Total SES Staff Eligible to Retire by 2008, by
EPA Unit/Region:
[See PDF for image]
[End of figure]
Note: GAO‘s analysis of EPA‘s data.
We reported in July 2001 that EPA did not have succession planning in
place to ensure continuity in the agency‘s leadership and to prepare
for the management losses that would likely occur, as many executives
become eligible for retirement.[Footnote 13] We recommended that EPA
work toward designing succession plans to maintain leadership
continuity that are based on (1) a review of current and emerging
leadership needs and (2) identifying sources of executive talent within
and outside EPA. In response, EPA reinstated a development program for
SES candidates, which is expected to prepare 51 candidates for
leadership positions. According to EPA, a number of these candidates
may be ready in the summer of 2003 for Office of Personnel Management
certification as senior executives. In addition, EPA has implemented a
management training program for new and current mid-level supervisors.
However, it remains to be seen how successful these programs will be in
developing the executive resources that the agency needs. EPA
implemented the management development programs before assessing how
revising its strategic objectives would affect its current and emergent
leadership needs. Therefore, EPA may need to modify these programs once
its strategic plan is finalized.
EPA also faces challenges in sustaining adequate scientific expertise
to carry out its mission. EPA acknowledges that its efforts to protect
human health and the environment must be based on the best available
science. However, EPA‘s scientific performance has been criticized many
times in reports by the National Research Council, EPA‘s Science
Advisory Board, and GAO, among other organizations, and in countless
complaints and lawsuits from stakeholders. In the National Research
Council‘s opinion, the concerns about EPA‘s scientific performance are
related to the agency‘s ability to attract and retain first-rate
scientific talent, given intense job market competition from the
private sector and academic institutions. EPA‘s challenge to maintain
adequate scientific expertise could intensify in the coming years, as
many agency scientists become eligible for retirement. As shown in
figure 2, a significant portion of EPA‘s key scientific and technical
staff--environmental protection specialists, biological scientists,
ecologists, toxicologists, environmental engineers, physical
scientists, and health physicists--will become eligible for retirement
by the end of 2008.
Figure 2: Percentage of EPA Staff in Key Scientific/Technical
Occupations Eligible for Retirement by 2008:
[See PDF for image]
[End of figure]
Note: GAO‘s analysis of EPA‘s data.
EPA can fill the gaps in scientific expertise that may arise from these
retirements through targeted recruitment efforts to hire ’outside“
expertise and by training current staff to develop the needed
expertise. To improve its ability to recruit highly qualified
scientists, EPA is considering the use of special hiring authority
modeled on a National Institutes of Health program to select and retain
senior scientists. Under this special authority, EPA would establish
competitive, limited-term (although renewable) appointments for
research scientists and engineers. The agency believes that the special
authority would increase EPA‘s flexibility to respond to emerging
environmental problems, establish a performance-based career path for
scientists, and reward scientific staff working on high-priority
environmental research. While such special authority might hold
promise, EPA officials acknowledge that the initiative is still in the
developmental stage. Therefore, it is too early to say how well the
proposed personnel authority would help EPA select and retain highly
qualified scientists. In addition to recruiting outside scientific
talent, EPA also needs to help current employees upgrade their
scientific expertise through internal or external training
opportunities. Thus far, however, EPA‘s strategy for developing its
workforce has aimed to enhance general competencies, such as
communication and collaboration, rather than specific mission-critical
scientific or technical skills.
EPA and State Efforts to Implement Innovative Regulatory Approaches May
Need Legislative Support:
For some time now, EPA has been counting on its efforts to ’reinvent“
environmental regulation to improve the efficiency and effectiveness
with which the agency and the states carry out their environmental
responsibilities. A key agency assumption has been that considerable
innovation can take place within the existing statutory environmental
framework. However, our work shows that limited progress in regulatory
innovation has been made to date, and that statutory constraints have
served as a major barrier. Although EPA has recently made vague
references to the impetus that statutory revisions could provide to
regulatory innovation, the agency needs to more clearly state the
legislative changes it would endorse to overcome constraints
to innovation.
EPA Has Tried a Variety of Initiatives to ’Reinvent“ Environmental
Regulation:
Under the existing federal approach to environmental protection, EPA,
pursuant to statutes such as the Clean Air Act and Clean Water Act,
prescribes regulations with which states, localities, and private
companies must comply. But this approach has often been criticized in
recent years for being costly, inflexible, and ineffective in
addressing some of the nation‘s most pressing environmental problems.
For example, the National Academy of Public Administration recently
reported that although traditional regulatory approaches manage to keep
most forms of industrial pollution in check, they are too narrow in
scope to affect many other more difficult problems and sources of
pollution or environmental degradation, such as diffuse sources of
water pollution caused by urban and agricultural runoff. Moreover, even
where existing approaches have succeeded in curtailing pollution from
major industrial sources, they have often been costly and have provided
regulated entities with little incentive to reduce pollution below
mandatory compliance levels.
EPA responded to such concerns during the 1990s with a variety of
initiatives intended to encourage innovative regulatory strategies that
could streamline environmental requirements while encouraging more
effective means of protecting the environment. Among the agency‘s
’flagship“ programs was Project XL, which encouraged individual
regulated facilities to propose projects that EPA would test to
determine whether alternative approaches could achieve compliance at
lower cost and produce greater environmental benefits. In addition to
pursuing a number of other ’high-priority actions“ and a number of
’other significant actions“ to encourage innovation, EPA stressed that
the agency‘s overall support for the reinvention effort was part of an
effort to transform the agency‘s culture to encourage staff to think
about and embrace innovative approaches to environmental regulation.
EPA‘s ’reinvention“ efforts of the 1990s encountered a number of
problems both within and outside the agency. These problems illustrated
issues that needed to be resolved in order for environmental regulation
to truly be ’reinvented.“ Specific examples follow:
* Key stakeholders in the reinvention process expressed concern over
the large number of complex and demanding initiatives under way--as
well as confusion over the underlying purpose of some of the agency‘s
major initiatives.
* EPA had difficulty in achieving ’buy-in“ among the agency‘s rank and
file, who were accustomed to the long-standing regulatory structure.
* EPA had difficulty in achieving agreement among external stakeholders
(including federal and state regulators and representatives of industry
and environmental organizations) in a number of its reinvention
efforts, particularly when stakeholders perceived that unanimous
agreement was required before progress could be made.
* EPA had a mixed record in evaluating the success of many of its
initiatives and was therefore unable to provide convincing evidence
to external stakeholders of the merits of pursuing an alternative
regulatory strategy.
Of perhaps greatest significance, much of the regulated community--
whose participation is crucial for reinvention to succeed--expressed
strong reservations about the prospects for reinvention within the
current statutory framework. In fact, a study by Resources for the
Future concluded that ’industry participants in reinvention programs
generally steer the programs to peripheral matters because their
counsels general caution them against taking any action that might
result in litigation.“[Footnote 14] Similarly, several of our studies
found that states‘ experimentation with pollutant trading and other
innovative environmental strategies was often constrained by the
statutory framework.[Footnote 15]
Recent GAO Findings Confirm Limitations on Ability to Innovate under
Current Statutory Framework:
In January 2002, we issued a report that cast doubt on EPA‘s ability to
achieve significant innovation in the absence of legislative
changes.[Footnote 16] The report contained detailed analyses of 20
initiatives that 15 states cited as being among the key initiatives
they had pursued. Specifically, we asked state environmental officials
to rank, in order, the most serious obstacles that had impeded progress
in pursuing these initiatives successfully. Among the most serious
impediments identified were federal regulations governing the
implementation of specific programs (ranked first or second in 12 of
the 20 cases).[Footnote 17] EPA has long maintained that it could
address these kinds of impediments through informal mechanisms and
administrative actions. However, our report countered this claim,
noting that EPA‘s ability to inject flexibility into its regulatory
programs was limited without clear statutory authorization.
Specifically, we concluded that current legislation does not contain
explicit language authorizing the use of innovative environmental
approaches in lieu of specific regulatory requirements, and the absence
of this ’safe legal harbor“ for EPA has been a significant obstacle to
states and others in their efforts to test innovative proposals. The
absence of this ’safe harbor“ has also tended to reinforce the cultural
resistance to innovation that EPA is seeking to change.
EPA‘s key initiatives have achieved varied success, further
underscoring questions about how well EPA‘s reinvention efforts will
fare without some kind of legislative support. For example, through the
end of 2000, the agency had invested considerable time and resources in
pursuing innovations under Project XL. The Administrator had set and
achieved the goal of signing agreements for at least 50 XL projects by
the end of that year. However, no new projects have been initiated, and
EPA reinvention officials indicated recently that the program is now
changing focus dramatically. Ongoing projects will continue, but any
new projects will need to meet a more selective test of being ’bigger,
bolder, and more strategic.“ EPA officials cited Massachusetts‘
Environmental Results Program as an example of a project meeting this
test because the underlying concepts apply broadly to a number of
facilities, as opposed to the single-facility focus of many past
XL projects.
EPA has recently taken steps to make its innovation efforts more
systematic and organized. In April 2002, the Administrator released a
new innovation strategy to help the agency strengthen innovation
partnerships with states, focus innovation on priority issues,
diversify environmental approaches, and foster a more innovative EPA
culture.[Footnote 18] To support the implementation of the strategy,
EPA has launched a pilot grant program to fund state innovations that
address the environmental priorities identified in the strategy. EPA
also plans to form the National Center for Environmental Innovation to
support implementation of its strategy, provide leadership on
environmental innovation, and manage key innovation programs. To help
assess the results of its efforts, EPA staff are tracking innovations
and reporting on them quarterly to agency management.
EPA‘s latest approach to bolstering environmental innovation is
understandable, given the fundamental barriers to broader regulatory
experimentation posed by the current statutory framework. However,
unless these statutory barriers are addressed more directly, it remains
to be seen whether EPA‘s recent efforts to promote innovation will fare
much better than its past efforts. EPA‘s innovation strategy hints at
some kind of statutory encouragement of regulatory innovation, noting
that the agency plans to ’engage in dialogue with parties that are
interested in applying the flexibility and multimedia dimensions of
these and other innovation programs more broadly through new
legislative authority.“ Such cryptic endorsement of legislative change
appears to be a small step in the right direction, but alone, it will
do little to encourage states and the regulated community to
participate actively in innovative projects. Nor will it provide
tangible assurances for the environmental community and other interest
groups that such projects can proceed without damaging the environment.
EPA needs to exert leadership in this area by articulating a clearer
and more specific endorsement of legislation that would more directly
address the root cause of the problems that have, for so many years,
impeded its regulatory reinvention efforts.
EPA Needs to Improve Its Grants Management to Better Achieve Its
Mission Objectives:
Effective grants management is essential for any federal agency that
uses grants as a vehicle to commit taxpayer money toward achieving
public purposes. Effective grants management is of particular
importance for EPA because it typically spends about half of its annual
budget on grants. In fiscal year 2002, EPA expended about $4 billion of
its $7.8 billion budget[Footnote 19] on grants, which it distributed to
over 3,300 recipients, including state and local governments, tribes,
universities, and nonprofit organizations. EPA awards grants to support
its ongoing programs--such as hazardous waste cleanup and wastewater
treatment--as well as to fund discretionary short-term projects--such
as training and outreach. The wide diversity of grant recipients and
wide range of activities that EPA grants support present the agency
with a formidable challenge to ensure that all awarded grants are used
to achieve the agency‘s overall mission of protecting human health and
the environment.
For many years, our reports and numerous other internal and external
agency management studies have called for EPA to manage its resources
to achieve environmental results. With such a high percentage of its
resources devoted to grants, the agency‘s ability to manage for results
largely depends on how well it manages its grants. However, in many
cases, EPA has not managed its grants so that they are effectively used
to achieve environmental results. EPA‘s project grants have often been
awarded without a clear plan for how the project will help achieve
EPA‘s mission or produce tangible environmental benefits. Furthermore,
after years of improvement initiatives, EPA still struggles to
efficiently and effectively administer its grant process to ensure that
available resources deliver the maximum effect.
EPA Needs to Better Plan and Measure Grant Results:
To help federal agencies more effectively use their resources to
achieve results, the Government Performance and Results Act of 1993
requires federal agencies to prepare strategic plans and goals and to
devise measures to gauge progress toward these stated objectives. Since
submitting its first strategic plan to the Congress in 1997, EPA has
continued to refine its plans, goals, and performance measures to help
it focus agency resources on environmental results. However, EPA‘s
planning and performance measurement for project grants has often been
disconnected from EPA‘s efforts to manage for an improved environment,
as shown below:
* EPA selects project grants before considering how the projects would
contribute to achieving the agency‘s strategic goals. In 2001, we
reported that EPA program officials treated EPA‘s strategic goals and
objectives not as a tool to guide the selection of project grants, but
rather as a clerical tool for categorizing grants after the funds were
already awarded.[Footnote 20] By assessing the relevance of these
grants to EPA‘s strategic plan after the selection process, EPA cannot
ensure that it is selecting the projects that will best help the agency
accomplish its mission.
* EPA often does not require grantees to submit work plans to explain
how a project would achieve measurable environmental results. In 2002,
EPA‘s Inspector General reported that EPA approved grantee work plans
without determining the projects‘ long-term human health and
environmental outcomes.[Footnote 21] Instead, EPA funded grants on the
basis of work plans that focused on short-term, procedural results,
such as meetings or conferences.
* EPA often does not measure what results are being achieved with
grants. We reported in September 2000 that EPA did not have criteria
to measure the effectiveness of its Science to Achieve Results grant
program.[Footnote 22] Instead, EPA‘s management of the program focused
on the procedures and processes of awarding grants. As a result, EPA
was uncertain about what the program was achieving. Similarly, the EPA
Inspector General reported in 2002 that, in many cases, EPA had not
measured whether the grants it had awarded were achieving meaningful
environmental benefits.[Footnote 23] In fact, for almost half of the
42 grants reviewed, EPA did not even attempt to measure the projects‘
outcomes. In some cases, the Inspector General concluded that what the
grant funding had accomplished was unknown or unclear.
EPA has acknowledged that its planning and performance measurement for
grants need to better focus on environmental results, and has promised
to take corrective action. EPA has recently announced that it will
upgrade its training for project officers and managers to emphasize the
importance of planning grants to achieve environmental results. EPA has
also announced that it will issue guidance to help ensure that all
grant work plans include a discussion of how grantees plan to measure
and report on environmental progress. However, the agency has also
expressed reservations about the extent to which grant projects can be
planned to achieve environmental results. The Assistant Administrator
for EPA‘s Office of Administration and Resources Management stated that
the Paperwork Reduction Act and OMB regulations may affect EPA‘s
ability to request that recipients collect information to measure the
results of EPA-funded activities. The Assistant Administrator also
stated that the limitations that currently exist in environmental
outcome measurement could affect the agency‘s ability to measure the
results of funded projects.
Planning for grants to achieve environmental results--and measuring
those results--is a difficult challenge, especially for projects such
as outreach or training. However, in view of the fact that EPA spends
about half of its budget on grants, it is imperative that EPA
wholeheartedly accept this challenge. Certain EPA-funded projects have
already demonstrated that outcome-based grant planning and measurement
are possible. For example, in seeking funding for outreach to local
building code officials about indoor air quality issues, a nonprofit
organization designed a grant project to deliver tangible environmental
results. That is, the project measured results in terms of actions that
affect human health--in this case, the construction of homes that
resist the release of radon into the indoor air. Regarding the
Assistant Administrator‘s concerns about the state of environmental
outcome measurement, it should be noted that EPA‘s Office of
Environmental Information and Office of Research and Development are
currently collaborating on developing a new generation of outcome-based
goals and measures using environmental indicators to help improve
performance measurement. As EPA improves its planning and measuring of
environmental results, it is important that the agency fully integrate
these improvements into its grants planning and performance management.
EPA Needs to Better Administer Grant Resources to Maximize Results:
Along with improved planning and performance measurement for grants,
EPA also needs to improve its stewardship of grant funding to maximize
the impact of available resources. The effective management and
oversight of grants helps ensure that the agency funds the best
projects at the least cost, that grant money is properly used to
accomplish the intended results, and that funded projects are completed
in a timely manner. Historically, EPA has experienced various problems
in grants management and oversight, and these problems have persisted
in recent years, as shown below:
* EPA has not ensured that it obtains the best price through
competition for project grants. EPA‘s Inspector General reported in
2001 that EPA officials gave grants to the same recipients year after
year without competition or selected certain grantees without
competition on the basis of the undocumented belief that the grantee
was ’uniquely qualified.“[Footnote 24] In 2002, the Inspector General
reported that grant recipients, in turn, awarded contracts for EPA-
funded work without determining the reasonableness of the contractor‘s
price, instead selecting contractors on the basis of familiarity or in
some cases awarding contracts to their own subsidiaries
without competition.[Footnote 25]
* EPA has not provided effective oversight to ensure that grant funds
are used only for allowable purposes. In 2001, we reported that EPA‘s
oversight of nonprofit grantees was not sufficiently rigorous to
uncover expenditures for unallowable costs.[Footnote 26] Specifically,
we found that EPA conducted oversight reviews of only 4 percent of its
nonprofit grantees and that these reviews were not designed to identify
unallowable costs.
* EPA has sometimes not ensured that its grantees have proper financial
and internal controls in place to ensure that federal funds are
properly used. For example, the EPA Inspector General found that one
grantee could not adequately account for over half of its $300,000 in
EPA grant funding. Another grantee submitted multiple financial status
reports showing conflicting ending balances for its grant funding.
* EPA has often not ensured that grant projects are completed in a
timely manner. In September 2000, we reported that EPA had not tracked
its Science to Achieve Results research grants to ensure their on-time
completion.[Footnote 27] We found that 144 of the nearly 200 grantees
reviewed had missed their deadline for submitting final reports, even
after extensions had been granted.
* EPA does not have an automated data system that it can rely upon to
provide consistent and accurate information to support grants
management. EPA‘s system does not generate reports needed to
effectively monitor grants, and individual grantees do not always have
unique identifiers in the system but may appear under multiple names or
identification numbers.
EPA has recently taken various actions intended to improve its
management and oversight of the grants it awards, such as (1) issuing
an order to require competition in the award of many grants and to
require detailed justifications for noncompetitive awards;
(2) conducting training sessions about competitive procurement
requirements for grant recipients and EPA personnel; (3) revising
agency policy to require EPA staff to conduct more on-site reviews of
grant recipients and to check for unallowable costs in grantee
spending; (4) developing a new data system to better track funding
amounts, project milestones, and agency oversight activities; and
(5) developing a long-term strategic plan for grants management that is
intended to improve accountability, coordination, and resource
management for EPA grants.
Although these actions appear promising, EPA has a long history of
undertaking initiatives to improve grants administration, and, despite
years of corrective actions, problems persist. The EPA Inspector
General recently concluded that some agency actions to address grant
weaknesses have not been effective, and in May 2002 recommended that
EPA designate grants management as a material weakness under the
Federal Managers‘ Financial Integrity Act. OMB also recommended that
EPA identify grants management as a material weakness. OMB believes
that a strong grants competition policy, along with improved
prioritization, oversight, and enforcement procedures, is needed to
improve EPA‘s grants management and will ultimately lead to better
environmental outcomes.
Notwithstanding the Inspector General‘s and OMB‘s recommendations, in
November 2002, the Administrator concurred with the recommendations
of EPA senior managers not to declare the agency‘s grants management to
be a material weakness under the Integrity Act. The agency justified
its decision on the basis of the policies it had recently issued to
improve competition in awarding grants and to strengthen the agency‘s
monitoring of grant recipients. EPA does, however, consider grants
management to be an ’agency level“ weakness under the Integrity Act--a
weakness that does not merit the attention of the President or Congress
but is significant enough to require regular reporting to the
Administrator. While EPA‘s classification of grants management under
the Integrity Act may be the subject of debate, it is clear that
improving grants management must be a top priority for the agency. With
about half of EPA‘s budget devoted to grants, the agency‘s ability to
efficiently and effectively accomplish its mission largely depends on
how well it manages its grant resources.
EPA Needs to Improve Internal Controls over Its Financial Reporting:
EPA‘s Inspector General issued an unqualified opinion on EPA‘s
consolidated financial statements for the fiscal year ended 2001.
However, when it considered internal controls over financial reporting,
the Inspector General identified three reportable conditions that could
adversely affect the agency‘s ability to process, summarize, and report
financial statement data. Additionally, in its assessment of compliance
with laws and regulations that relate to financial statement reporting,
the Inspector General identified two instances of noncompliance, only
one of which was substantial. While noteworthy, neither instance of
noncompliance would result in material misstatements to the audited
financial statements.
EPA had three reportable conditions in fiscal year 2001. The first was
its failure to implement Statement of Federal Financial Accounting
Standard (SFFAS) No. 10, Accounting for Internal Use Software, until
the end of fiscal year 2001, even though the standard was applicable
for the entire fiscal year. SFFAS No. 10 requires the capitalization of
the full cost (direct and indirect) of internal use software whether it
is commercial off-the-shelf, contractor developed, or internally
developed. In addition, some of the supporting documentation used to
identify capitalized software cost was insufficient to determine
whether such costs exceeded the capitalization threshold. Because EPA
issued guidance at the end of fiscal year 2001 for capitalizing
internally developed software, the Inspector General did not believe a
recommendation was warranted.
The second reportable condition concerned the interagency agreement
invoice (IAG) approval process. EPA project officers did not fulfill
oversight duties related to reviewing and approving interagency
agreement invoices. The Inspector General has continued to find
instances where program offices did not receive support for IAG
invoices paid, did not promptly approve payable IAG invoices, or did
not identify the proper account to be charged. EPA agreed with the
Inspector General‘s findings and, according to the agency‘s management,
EPA has implemented an automated project officer approval system that
addresses this finding.
The third reportable condition dealt with automated application
processing controls for EPA‘s Integrated Financial Management System
(IFMS). The lack of system documentation made it impossible to assess
the adequacy of the automated internal control structure as it related
to automated input, processing, and output controls for the IFMS
system. The Inspector General found that EPA has taken tangible steps
to replace the IFMS with the Financial Replacement System (FinRS)
project. However, the Inspector General will not be able to
sufficiently assess the adequacy of the automated internal control
structure until the new system is in place.
The Inspector General‘s tests of compliance with the Federal Financial
Management Improvement Act of 1996 disclosed an instance where EPA‘s
financial management systems did not substantially comply with SFFAS
No. 4, Managerial Cost Accounting Concepts and Standards for the
Federal Government. Specifically, EPA did not comply with the
requirements to provide cost per output to management in a timely
fashion. In addition, under EPA‘s current cost-accounting structure,
when costs by output are produced, such costs are not described in
sufficient detail to be useful to managers. EPA took exception to these
Inspector General findings, stating that the agency believes it is in
compliance with the managerial cost accounting standard. According to
EPA‘s management, cost-per-output information is provided to program
managers on a regular basis. The resolution of this issue will likely
be the topic of future discussions between EPA management and the
Inspector General.
EPA was noncompliant with appropriation law when making disbursements
for grants funded with more than one appropriation. Specifically,
disbursements for these grants were made using the oldest available
funding (appropriation) first, which might or might not have been the
appropriation that benefited from the work performed. Consequently, EPA
was not in compliance with title 31, U.S. Code, section 1301, which
requires EPA to match disbursements to the benefiting appropriation. In
fiscal year 2001, EPA adopted new procedures for allocating costs on
such grants for new awards. Therefore, it is anticipated that the
problem will be corrected as the remaining obligated balances are
liquidated.
Although the Inspector General has identified several internal control
weaknesses, it appears that corrective actions are well under way. The
successful completion of these efforts to correct identified reportable
conditions and compliance issues will assist EPA in providing its
managers and the Congress with more timely and reliable financial
information.
[End of section]
GAO Contacts:
Subjects covered in this report: Improving environmental information
; Strengthening EPA‘s human capital management
; Making regulatory innovation successful
; Improving EPA‘s grants planning and management; Contact person: John
B. Stephenson, Director; Natural Resources and Environment; (202) 512-
3841; stephensonj@gao.gov.
Subjects covered in this report: Maintaining EPA‘s information
security; Contact person: Robert F. Dacey, Director; Information
Technology; (202) 512-3317; daceyb@gao.gov.
Subjects covered in this report: Accounting for EPA‘s financial
resources; Contact person: McCoy Williams, Director; Financial
Management and Assurance; (202) 512-6906; williamsm1@gao.gov.
[End of table]
[End of section]
Related GAO Products:
Performance and Accountability Series:
Major Management Challenges and Program Risks: A Governmentwide
Perspective (GAO-01-241, January 2001).
Major Management Challenges and Program Risks: Environmental Protection
Agency (GAO-01-257, January 2001).
High-Risk Series: An Update (GAO-01-263, January 2001).
Environmental and Performance Management Information:
Managing for Results: Agency Progress in Linking Performance Plans with
Budgets and Financial Statements (GAO-02-236, Jan. 4, 2002).
Environmental Information: EPA Needs Better Information to Manage Risks
and Measure Results (GAO-01-97T, Oct. 3, 2000).
Toxic Chemicals: Long-Term Coordinated Strategy Needed to Measure
Exposures in Humans (GAO/HEHS-00-80, May 2, 2000).
Managing for Results: EPA Faces Challenges in Developing
Results-Oriented Performance Goals and Measures (GAO/RCED-00-77,
Apr. 28, 2000).
Water Quality: Key EPA and State Decisions Limited by Inconsistent and
Incomplete Data (GAO/RCED-00-54, Mar. 15, 2000).
Environmental Information: EPA Is Taking Steps to Improve Information
Management, but Challenges Remain (GAO/RCED-99-261, Sept. 17, 1999).
Information Technology and Security:
Computer Security: Progress Made, but Critical Federal Operations and
Assets Remain at Risk (GAO-03-303T, Nov. 19, 2002).
Critical Infrastructure Protection: Significant Challenges Need to Be
Addressed (GAO-02-961T, July 24, 2002).
Information Technology: Enterprise Architecture Use across the Federal
Government Can Be Improved (GAO-02-6, Feb. 19, 2002).
Computer Security: Improvements Needed to Reduce Risk to Critical
Federal Operations and Assets (GAO-02-231T, Nov. 9, 2001).
Information Security: Fundamental Weaknesses Place EPA Data and
Operations at Risk (GAO/AIMD-00-215, July 6, 2000).
Human Capital:
A Model of Strategic Human Capital Management (GAO-02-373SP, Mar. 15,
2002).
Human Capital: Attracting and Retaining a High Quality Information
Technology Workforce (GAO-02-113T, Oct. 4, 2001).
Human Capital: Implementing an Effective Workforce Strategy Would Help
EPA to Achieve Its Strategic Goals (GAO-01-812, July 31, 2001).
Innovative Regulatory Approaches:
Environmental Protection: Overcoming Obstacles to Innovative State
Regulatory Programs (GAO-02-268, Jan. 31, 2002).
Environmental Protection: Challenges Facing EPA‘s Efforts to
Reinvent Environmental Regulation (GAO/RCED-97-155, July 2, 1997).
Environmental Protection: Status of EPA‘s Initiatives to Create a New
Partnership with States (GAO/T-RCED-96-87, Feb. 29, 1996).
EPA Grants Management:
Environmental Protection: Grants Awarded for Continuing Environmental
Programs and Projects (GAO-01-860R, June 29, 2001).
Environmental Protection: EPA‘s Oversight of Nonprofit Grantees‘ Costs
Is Limited (GAO-01-366, Apr. 6, 2001).
Environmental Protection: Information on EPA Project Grants and Use of
Waiver Authority (GAO-01-359, Mar. 9, 2001).
Environmental Research: STAR Grants Focus on Agency Priorities,
but Management Enhancements Are Possible (GAO/RCED-00-170,
Sept. 11, 2000).
Environmental Protection: Grants for International Activities and Smart
Growth (GAO/RCED-00-145R, May 31, 2000).
EPA Financial Management:
Debt Collection Improvement Act of 1996: Major Data Sources Inadequate
for Implementing the Debtor Bar Provision (GAO-02-462, Mar. 29, 2002).
Debt Collection Improvement Act of 1996: Status of Selected Agencies‘
Implementation of Administrative Wage Garnishment (GAO-02-313,
Feb. 28, 2002).
Inspectors General: Information on Resources and Selected
Accomplishments of 18 Inspectors General (AIMD-00-149R, Apr. 14, 2000).
[End of section]
Performance and Accountability and High-Risk Series:
Major Management Challenges and Program Risks: A Governmentwide
Perspective. GAO-03-95.
Major Management Challenges and Program Risks: Department of
Agriculture. GAO-03-96.
Major Management Challenges and Program Risks: Department of Commerce.
GAO-03-97.
Major Management Challenges and Program Risks: Department of Defense.
GAO-03-98.
Major Management Challenges and Program Risks: Department of Education.
GAO-03-99.
Major Management Challenges and Program Risks: Department of Energy.
GAO-03-100.
Major Management Challenges and Program Risks: Department of Health and
Human Services. GAO-03-101.
Major Management Challenges and Program Risks: Department of Homeland
Security. GAO-03-102.
Major Management Challenges and Program Risks: Department of Housing
and Urban Development. GAO-03-103.
Major Management Challenges and Program Risks: Department of the
Interior. GAO-03-104.
Major Management Challenges and Program Risks: Department of Justice.
GAO-03-105.
Major Management Challenges and Program Risks: Department of Labor.
GAO-03-106.
Major Management Challenges and Program Risks: Department of State.
GAO-03-107.
Major Management Challenges and Program Risks: Department of
Transportation. GAO-03-108.
Major Management Challenges and Program Risks: Department of the
Treasury. GAO-03-109.
Major Management Challenges and Program Risks: Department of Veterans
Affairs. GAO-03-110.
Major Management Challenges and Program Risks: U.S. Agency for
International Development. GAO-03-111.
Major Management Challenges and Program Risks: Environmental Protection
Agency. GAO-03-112.
Major Management Challenges and Program Risks: Federal Emergency
Management Agency. GAO-03-113.
Major Management Challenges and Program Risks: National Aeronautics and
Space Administration. GAO-03-114.
Major Management Challenges and Program Risks: Office of Personnel
Management. GAO-03-115.
Major Management Challenges and Program Risks: Small Business
Administration. GAO-03-116.
Major Management Challenges and Program Risks: Social Security
Administration. GAO-03-117.
Major Management Challenges and Program Risks: U.S. Postal Service.
GAO-03-118.
High-Risk Series: An Update. GAO-03-119.
High-Risk Series: Strategic Human Capital Management. GAO-03-120.
High-Risk Series: Protecting Information Systems Supporting the Federal
Government and the Nation‘s Critical Infrastructures. GAO-03-121.
High-Risk Series: Federal Real Property. GAO-03-122.
FOOTNOTES
[1] See U.S. General Accounting Office, Toxic Chemicals: Long-Term
Coordinated Strategy Needed to Measure Exposures in Humans, GAO/
HEHS-00-80 (Washington, D.C.: May 2, 2000).
[2] Pursuant to section 305(b) of the Clean Water Act, states report
biennially to EPA on the quality of their waters. EPA summarizes this
information in a biennial report, the National Water Quality Inventory.
The most recent such report is the report for 2000. For that report,
states assessed only 19 percent of the nation‘s river and stream miles;
43 percent of its total acres of lakes, ponds, and reservoirs; 36
percent of its square miles of estuaries; and 6 percent of its ocean
shoreline miles. Furthermore, as we reported in March 2000, on the
basis of our survey of 50 states and the District of Columbia, only 3
states indicated that they had the majority of the data needed to
identify and assess nonpoint sources of pollution, generally considered
to be the greatest contributor to water quality impairment at present.
[3] See U.S. General Accounting Office, Major Management Challenges and
Program Risks: Environmental Protection Agency, GAO-01-257
(Washington, D.C.: January 2001).
[4] See U.S. General Accounting Office, Environmental Information: EPA
Is Taking Steps to Improve Information Management, but Challenges
Remain, GAO/RCED-99-261 (Washington, D.C.: Sept. 17, 1999).
[5] This standard refers to the classification of biological organisms
in established categories, such as kingdom, phylum, class, order,
family, genus, species, and subspecies.
[6] One such registry, the Environmental Data Registry, contains
descriptive information about data managed by the agency, with special
emphasis on data elements used by EPA‘s national systems. The registry
is a single comprehensive source of information about the definition,
origin, source, and location of environmental data and is the primary
tool used by EPA for implementing data standards.
[7] See U.S. General Accounting Office, Environmental Protection
Agency: Protecting Human Health and the Environment through Improved
Management, GAO/RCED-88-101 (Washington, D.C.: Aug. 16, 1988).
[8] Examples of end outcomes would include ensuring that drinking water
is safe or maintaining healthy air with respect to levels of pollutants
such as carbon monoxide, sulfur dioxide, nitrogen dioxide, and lead.
[9] See U.S. General Accounting Office, Information Security:
Fundamental Weaknesses Place EPA Data and Operations at Risk, GAO/
AIMD-00-215 (Washington, D.C.: July 6, 2000).
[10] See GAO/RCED-99-261.
[11] See GAO-01-257.
[12] See U.S. General Accounting Office, Human Capital: Implementing an
Effective Workforce Strategy Would Help EPA to Achieve Its Strategic
Goals, GAO-01-812 (Washington, D.C.: July 31, 2001).
[13] See GAO-01-812.
[14] See Resources for the Future, Industry Incentives for
Environmental Improvement: Evaluation of U.S. Federal Initiatives
(Washington, D.C.: September 1996).
[15] See U.S. General Accounting Office, Environmental Protection:
Status of EPA‘s Initiatives to Create a New Partnership with States,
GAO/T-RCED-96-87 (Washington, D.C.: Feb. 29, 1996). Also, see U.S.
General Accounting Office, Environmental Protection: Challenges Facing
EPA‘s Efforts to Reinvent Environmental Regulation, GAO/RCED-97-155
(Washington, D.C.: July 2, 1997).
[16] See U.S. General Accounting Office, Environmental Protection:
Overcoming Obstacles to Innovative State Regulatory Programs,
GAO-02-268 (Washington, D.C.: Jan. 31, 2002).
[17] States also cited as a significant obstacle a cultural resistance
among many in EPA toward alternative approaches--a resistance that,
they maintained, often manifested itself in a lengthy and costly EPA
review of their proposals. But this cultural resistance was often tied
to the regulations themselves--participants were often concerned that
strict application of the regulations was needed to reduce the risk of
lawsuits filed by private interest groups.
[18] See Environmental Protection Agency, Innovating for Better
Environmental Results (April 2002).
[19] The fiscal year 2002 budget amount does not include unobligated
balances from previous budget authority.
[20] See U.S. General Accounting Office, Environmental Protection:
Information on EPA Project Grants and Use of Waiver Authority,
GAO-01-359 (Washington, D.C.: Mar. 9, 2001).
[21] See EPA Inspector General, Surveys, Studies, Investigations, and
Special Purpose Grants, Report No. 2002-P-00005 (Mar. 21, 2002).
[22] See U.S. General Accounting Office, Environmental Research: STAR
Grants Focus on Agency Priorities, but Management Enhancements Are
Possible, GAO-RCED-00-170 (Washington, D.C. Sept. 11, 2000).
[23] See footnote 21.
[24] See EPA‘s Competitive Practices for Assistance Awards, Report No.
2001-P-00008 (May 21, 2001).
[25] See Environmental Protection Agency, Procurement Made by
Assistance Agreement Recipients Should Be Competitive, Report No. 2002-
P-00009 (Mar. 28, 2002).
[26] See U.S. General Accounting Office, Environmental Protection:
EPA‘s Oversight of Nonprofit Grantees‘ Costs Is Limited, GAO-01-366
(Washington, D.C.: Apr. 6, 2001).
[27] See footnote 22.
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