Environmental Protection Agency
Actions Needed to Improve Planning, Coordination, and Leadership of EPA Laboratories Gao ID: GAO-12-236T November 17, 2011In Process
EPA has taken some actions but has not fully addressed the findings and recommendations of five independent evaluations over the past 20 years regarding long-standing planning, coordination, and leadership issues that hamper the quality, effectiveness, and efficiency of its science activities, including its laboratory operations. First, EPA has yet to fully address planning and coordination issues identified by a 1992 independent, expert panel evaluation that recommended that EPA develop and implement an overarching issue-based planning process that integrates and coordinates scientific efforts throughout the agency, including the important work of its 37 laboratories. Second, EPA has also not fully addressed recommendations from a 1994 independent evaluation by the MITRE Corporation to consolidate and realign its laboratory facilities and workforce--even though this evaluation found that the geographic separation of laboratories hampered their efficiency and technical operations and that consolidation and realignment could improve planning and coordination issues that have hampered its science and technical community for decades. Third, EPA has not fully addressed recommendations from the independent evaluations regarding leadership of its research and laboratory operations. On the basis of our analysis of EPA's facility master planning process, we found that EPA manages its laboratory facilities on a site-by-site basis and does not evaluate each site in the context of all the agency's real property holdings--as recommended by the National Research Council report in 2004. EPA's facility master plans are intended to be the basis for justifying its building and facilities spending, which was $29.9 million in fiscal year 2010, and allocating those funds to specific repair and improvement projects. Master plans should contain, among other things, information on mission capabilities, use of space, and condition of individual laboratory sites. In addition, we found that most facility master plans were out of date. EPA's real property asset management plan states that facility master plans are supposed to be updated every 5 years to reflect changes in facility condition and mission, but we found that 11 of 20 master plans were out of date and 2 of 20 had not been created yet. EPA does not use a comprehensive planning process for managing its laboratories' workforce. For example, we found that not all of the regional and program offices with laboratories prepared workforce plans as part of an agencywide planning effort in 2007, and for those that did, most did not specifically address their laboratories' workforce. In fact, some regional management and human resource officials we spoke with were unaware of the requirement to submit workforce plans to the Office of Human Resources. Some of these managers told us the program and regional workforce plans were a paperwork exercise, irrelevant to the way the workforce is actually managed. Managers in program and regional offices said that workforce planning for their respective laboratories is fundamentally driven by the annual budgets of program and regional offices and ceilings for full-time equivalents (FTE).
GAO-12-236T, Environmental Protection Agency: Actions Needed to Improve Planning, Coordination, and Leadership of EPA Laboratories
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United States Government Accountability Office:
GAO:
Testimony:
Before the Subcommittee on Energy and the Environment, Committee on
Science, Space, and Technology, House of Representatives:
For Release on Delivery:
Expected at 2:00 p.m. EST:
Thursday, November 17, 2011:
Environmental Protection Agency:
Actions Needed to Improve Planning, Coordination, and Leadership of
EPA Laboratories:
Statement of David C. Trimble:
Natural Resources and Environment:
GAO-12-236T:
Chairman Harris, Ranking Member Miller, and Members of the
Subcommittee:
I am pleased to be here today to discuss the research and development
activities of the Environmental Protection Agency (EPA) and the
findings of our recent report on the agency's laboratory enterprise.
[Footnote 1] EPA was established in 1970 to consolidate a variety of
federal research, monitoring, standard-setting, and enforcement
activities into one agency for ensuring the joint protection of
environmental quality and human health.[Footnote 2] Scientific
research, knowledge, and technical information are fundamental to
EPA's mission and inform its standard-setting, regulatory, compliance,
and enforcement functions. The agency's scientific performance is
particularly important as complex environmental issues emerge and
evolve, and controversy continues to surround many of the agency's
areas of responsibility. Unlike other primarily science-focused
federal agencies, such as the National Institutes of Health or the
National Science Foundation, EPA's scientific research, technical
support, and analytical services underpin the policies and regulations
the agency implements. Therefore, the agency operates its own
laboratory enterprise. This enterprise is made up of 37 laboratories
that are housed in about 170 buildings and facilities located in 30
cities across the nation. Specifically, EPA's Office of Research and
Development (ORD) operates 18 laboratories with primary responsibility
for research and development. Four of EPA's five national program
offices[Footnote 3] operate nine laboratories with primary
responsibility for supporting regulatory implementation, compliance,
enforcement, and emergency response. Each of EPA's 10 regional offices
operates a laboratory with responsibilities for a variety of applied
sciences; analytical services; technical support to federal, state,
and local laboratories; monitoring; compliance and enforcement; and
emergency response.
Over the past 20 years, independent evaluations by the National
Research Council and others have addressed planning, coordination, or
leadership issues associated with EPA's science activities.[Footnote
4] The scope of these evaluations varied, but collectively they
recognized the need for EPA to improve long-term planning, priority
setting, and coordination of laboratory activities; establish
leadership for agencywide scientific oversight and decision making;
and better manage the laboratories' workforce and infrastructure. When
it was established in 1970, EPA inherited 42 laboratories from
programs in various federal departments. According to EPA's historian,
EPA closed or consolidated some laboratories it inherited and created
additional laboratories to support its mission. Nevertheless, EPA's
historian reported that the location of most of EPA's present
laboratories is largely the same as the location of its original
laboratories in part because of political objections to closing
facilities and conflicting organizational philosophies, such as
operating centralized laboratories for efficiency versus operating
decentralized laboratories for flexibility and responsiveness. Other
federal agencies face similar challenges with excess and underused
property. Because of these challenges, GAO has designated federal real
property as an area of high risk.[Footnote 5]
This statement summarizes the findings of our report issued in July of
this year that examines the extent to which EPA (1) has addressed the
findings of independent evaluations performed by the National Research
Council and others regarding long-term planning, coordination, and
leadership issues; (2) uses an agencywide, coordinated approach for
managing its laboratory physical infrastructure; and (3) uses a
comprehensive planning process to manage its laboratory workforce. In
preparing this testimony, we relied on the work supporting our July
report. In conducting that work, we reviewed agency documents and
independent evaluations, visited EPA laboratories, interviewed agency
officials, and examined agency databases; our recent report contains a
detailed description of our scope and methodology. All of the work for
our July report was performed in accordance with generally accepted
government auditing standards.
EPA Has Not Fully Addressed Findings of Evaluations on Long-standing
Planning, Coordination, or Leadership Issues:
EPA has taken some actions but has not fully addressed the findings
and recommendations of five independent evaluations over the past 20
years regarding long-standing planning, coordination, and leadership
issues that hamper the quality, effectiveness, and efficiency of its
science activities, including its laboratory operations.
First, EPA has yet to fully address planning and coordination issues
identified by a 1992 independent, expert panel evaluation that
recommended that EPA develop and implement an overarching issue-based
planning process that integrates and coordinates scientific efforts
throughout the agency, including the important work of its 37
laboratories.[Footnote 6] That evaluation found that EPA's science was
of uneven quality and that the agency lacked a coherent science agenda
and operational plan to guide scientific efforts throughout the
agency. Because EPA did not implement the evaluation's recommendation,
EPA's programs, regional officials, and ORD continue to independently
plan and coordinate the activities of their respective laboratories
based on their own offices' priorities and needs.
Second, EPA has also not fully addressed recommendations from a 1994
independent evaluation by the MITRE Corporation to consolidate and
realign its laboratory facilities and workforce[Footnote 7]--even
though this evaluation found that the geographic separation of
laboratories hampered their efficiency and technical operations and
that consolidation and realignment could improve planning and
coordination issues that have hampered its science and technical
community for decades. In its evaluation, MITRE recommended that EPA
(1) realign and consolidate the ORD laboratories; (2) consolidate
program laboratories in the Office of Prevention, Pesticides, and
Toxic Substances[Footnote 8] and the two laboratories under the Office
of Radiation and Indoor Air; and (3) through consolidation, reduce the
number of regional office laboratories to a few laboratories with a
national service focus. In response to the MITRE study, an agencywide
steering committee formed by EPA to consider restructuring and
consolidation options issued a report to the Administrator in July
1994.[Footnote 9] The steering committee report stated that combining
ORD laboratories at a single location could improve teamwork and raise
productivity but concluded that, for the near term, ORD should be
functionally reorganized but not physically consolidated. Regarding
program office laboratory consolidations, the Office of Radiation and
Indoor Air did not physically consolidate its laboratories but did
administratively and physically consolidate its Las Vegas laboratory
with ORD's Las Vegas radiation laboratory, and the Office of
Prevention, Pesticides, and Toxic Substances colocated three of four
laboratories with the region 3 laboratory. As for the regional
laboratories, the steering committee's report endorsed the current
decentralized regional model but did not provide a justification for
its position.
Third, EPA has not fully addressed recommendations from the
independent evaluations regarding leadership of its research and
laboratory operations.[Footnote 10] More specifically, EPA has not
appointed a top science official with responsibility and authority for
all the research, science, and technical functions of the agency--even
though one study found that the lack of a top science official was a
formula for weak scientific performance in the agency and poor
scientific credibility outside the agency. Instead, EPA's efforts to
establish leadership over its laboratory enterprise have relied on
advisory positions and councils to achieve consensus and voluntary
cooperation of ORD and the agency's program and regional offices.
Because of the limited success of EPA's advisory positions and
councils and in the absence of a central science policy authority, the
National Research Council in 2000 recommended that EPA request
authority from Congress to create a new position of deputy
administrator for science and technology, with managerial authority to
coordinate and oversee all the agency's scientific and technical
activities. To date, EPA has not requested authority to create a new
position of deputy administrator for science and technology and
continues to operate its laboratories under the direction of 15
different senior officials using 15 different organizational and
management structures. As a result, EPA has a limited ability to know
if scientific activities are being unintentionally duplicated among
the laboratories or if opportunities exist to collaborate and share
scientific expertise, equipment, and facilities across EPA's
organizational boundaries.
EPA Has Not Taken an Agencywide, Coordinated Approach to Manage Its
Laboratory Physical Infrastructure:
On the basis of our analysis of EPA's facility master planning
process, we found that EPA manages its laboratory facilities on a site-
by-site basis and does not evaluate each site in the context of all
the agency's real property holdings--as recommended by the National
Research Council report in 2004.[Footnote 11] EPA's facility master
plans are intended to be the basis for justifying its building and
facilities spending, which was $29.9 million in fiscal year 2010, and
allocating those funds to specific repair and improvement projects.
Master plans should contain, among other things, information on
mission capabilities, use of space, and condition of individual
laboratory sites. In addition, we found that most facility master
plans were out of date. EPA's real property asset management plan
states that facility master plans are supposed to be updated every 5
years to reflect changes in facility condition and mission, but we
found that 11 of 20 master plans were out of date and 2 of 20 had not
been created yet.[Footnote 12]
Because EPA makes capital improvement decisions on a site-by-site
basis using master plans that are often outdated, it cannot be assured
it is allocating its funds most appropriately. According to officials
responsible for allocating capital improvement resources, they try to
spread these funds across the agency's offices and regions equitably
but capital improvement funds have not kept pace with requests. The
pressure and need to effectively share and allocate limited resources
among EPA's many laboratories were also noted in a 1994 National
Academy of Public Administration report on EPA's laboratory
infrastructure, which found that EPA has "too many labs in too many
locations often without sufficient resources to sustain a coherent
stable program."[Footnote 13]
In addition, because decisions regarding laboratory facilities are
made independently of one another, opportunities to improve operating
efficiencies can be lost. Specifically, we found cases where
laboratories that were previously colocated moved into separate space
without considering the potential benefits of remaining colocated. In
one case, we found that the relocation increased some operating costs
because the laboratories then had two facility managers and two
security contracts and associated personnel because of different
requirements for the leased facility. In another case, when two
laboratories that were previously colocated moved into separate new
leased laboratories several miles apart, agency officials said that
they did not know to what extent this move may have resulted in
increased operating cost.
EPA also does not have sufficiently complete and reliable data to make
informed decisions for managing its facilities. Since 2003, when GAO
first designated federal real property management as an area of high
risk, agencies have come under increasing pressure to manage their
real property assets more effectively.[Footnote 14] In February 2004,
the President issued an executive order directing agencies to, among
other things, improve the operational and financial management of
their real property inventory.[Footnote 15] The order established a
Federal Real Property Council within the Office of Management and
Budget (OMB), which has developed guiding principles for real property
asset management. In response to a June 2010 presidential memorandum
directing agencies to accelerate efforts to identify and eliminate
excess properties,[Footnote 16] in July 2010 EPA reported to the OMB
that it does not anticipate the disposal of any of its owned
laboratories and major assets in the near future because these assets
are fully used and considered critical for EPA's mission.[Footnote 17]
EPA stated that decisions regarding facility disposal are made using
the Federal Real Property Council's guidance but we found that EPA
does not have the information needed to effectively implement this
guidance. Specifically, EPA does not have accurate, reliable
information regarding (1) the need for facilities, (2) property usage,
(3) facility condition, and (4) facility operating efficiency--thereby
undermining the credibility of any decisions based on this approach.
* First, EPA does not maintain accurate data to determine if there is
an agency need for laboratory facilities because many facility master
plans are often out of date. According to EPA's asset management plan,
the master plans are tools that communicate the link between mission
priorities and facilities. However, without up-to-date master plans,
EPA does not have accurate data to determine if laboratory facilities
are needed for its mission.
* Second, the agency does not have accurate data on space needs and
usage because many facility master plans containing space utilization
analyses are out of date. EPA also does not use public and commercial
space usage benchmarks--as recommended by the Federal Real Property
Council--to calculate usage rates for its laboratories. Instead, EPA
measures laboratory usage on the basis of interviews with local
laboratory officials. According to EPA officials, they do not use
benchmarks because the work of the laboratories varies. In 2008,
however, an EPA contractor created a laboratory benchmark based on
those used by comparable facilities at the Centers for Disease Control
and Prevention, the National Institutes of Health, the Department of
Energy, and several research universities to evaluate space at two ORD
laboratories in North Carolina. Consequently, we believe that
objective benchmarks can be developed for EPA's unique laboratory
requirements. In addition, the contractor's analysis concluded that
EPA could save $1.68 million in annual leasing and $800,000 in annual
energy costs through consolidation of the two ORD laboratories. Agency
officials told us they hope to consolidate the laboratories in fiscal
year 2012 if funds are available.
* Third, the agency does not have accurate data for assessing
facilities' condition because condition assessments contained in
facility master plans are often outdated. The data may also be
unreliable because data entered by local facility managers are not
verified, according to agency officials. Such verification could
involve edit checks or controls to help ensure the data are entered
accurately.
* Fourth, EPA does not have reliable operating cost data for its
laboratory enterprise, because the agency's financial management
system does not track operating costs in sufficient detail to break
out information for individual laboratories or for the laboratory
enterprise as a whole. Reliable operating cost data are important in
determining whether a laboratory facility is operating efficiently, a
determination that should inform both capital investment and property
disposal decisions.
EPA Does Not Use a Comprehensive Workforce Planning Process for Its
Laboratories:
EPA does not use a comprehensive planning process for managing its
laboratories' workforce. For example, we found that not all of the
regional and program offices with laboratories prepared workforce
plans as part of an agencywide planning effort in 2007, and for those
that did, most did not specifically address their laboratories'
workforce. In fact, some regional management and human resource
officials we spoke with were unaware of the requirement to submit
workforce plans to the Office of Human Resources. Some of these
managers told us the program and regional workforce plans were a
paperwork exercise, irrelevant to the way the workforce is actually
managed. Managers in program and regional offices said that workforce
planning for their respective laboratories is fundamentally driven by
the annual budgets of program and regional offices and ceilings for
full-time equivalents (FTE).[Footnote 18]
In addition, none of the program and regional workforce plans we
reviewed described any effort to work across organizational boundaries
to integrate or coordinate their workforce with the workforces of
other EPA laboratories. For example, although two regional workforce
plans discussed potential vulnerability if highly skilled laboratory
personnel retired, neither plan explored options for sharing resources
across regional boundaries to address potential skill gaps. According
to EPA's Regional Laboratory System 2009 Annual Report, many of the
regional laboratories provide the same or similar core analytical
capabilities--including a full range of routine and specialized
chemical and biological testing of air, water, soil, sediment, tissue,
and hazardous waste. Nonetheless, in these workforce plans, each
region independently determines and attempts to address its individual
workforce needs. As a result, by not exploring options for sharing
resources among the ORD, program, and regional boundaries to address
potential skill gaps, EPA may be missing opportunities to fill
critical occupation needs through resource sharing.
Moreover, EPA does not have basic demographic information on the
number of federal and contract employees currently working in its 37
laboratories. Specifically, EPA does not routinely compile the
information needed to know how many scientific and technical employees
it has working in its laboratories, where they are located, what
functions they perform, or what specialized skills they may have. In
addition, the agency does not have a workload analysis for the
laboratories to help determine the optimal numbers and distribution of
staff throughout the enterprise. We believe that such information is
essential for EPA to prepare a comprehensive laboratory workforce plan
to achieve the agency's mission with limited resources. Because EPA's
laboratory workforce is managed separately by 15 independent senior
officials, information about that workforce is tracked separately and
is not readily available or routinely compiled or evaluated. Instead,
EPA has relied on ad hoc calls for information to compile such data.
In response to our prior reports on EPA's workforce strategy[Footnote
19] and the work of the EPA Inspector General, EPA hired a contractor
in 2009, in part to conduct a study to provide information about the
agency's overall workload, including staffing levels and workload
shifts for six major functions, including scientific research. In its
budget justification for fiscal year 2012, however, the agency
reported to Congress that a survey of the existing workload
information provided by the contractor will not immediately provide
information sufficient to determine whether changes are needed in
workforce levels. As of October 2011, EPA had not released the results
of this study, and we therefore cannot comment on whether its content
has implications for the laboratories. The agency asked its National
Advisory Council for Environmental Policy and Technology to help
address scientific and technical competencies as it develops a new
agencywide workforce plan. However, the new plan is not complete, and
therefore it is too early to tell whether the council's
recommendations will have implications for the laboratories.
Finally, in our July 2011 report on EPA's laboratory enterprise we
recommended, among other things, that EPA develop a coordinated
planning process for its scientific activities and appoint a top-level
official with authority over all the laboratories, improve physical
and real property planning decisions, and develop a workforce planning
process for all laboratories that reflects current and future needs of
laboratory facilities. In written comments on the report, EPA
generally agreed with our findings and recommendations.
Chairman Harris, Ranking Member Miller, this concludes my prepared
statement. I would be happy to respond to any questions that you or
other members of the subcommittee may have at this time.
GAO Contact and Staff Acknowledgments:
For further information on this statement, please contact David
Trimble at (202) 512-3841 or trimbled@gao.gov. Contact points for our
Congressional Relations and Public Affairs offices may be found on the
last page of this statement. Other staff that made key contributions
to this testimony include Diane LoFaro, Assistant Director; Jamie
Meuwissen; Angela Miles; and Dan Semick.
[End of section]
Footnotes:
[1] GAO, Environmental Protection Agency: To Better Fulfill Its
Mission, EPA Needs a More Coordinated Approach to Managing Its
Laboratories, [hyperlink, http://www.gao.gov/products/GAO-11-347]
(Washington, D.C.: July 25, 2011).
[2] Reorganization Plan No. 3 of 1970, 35 Fed. Reg. 15623 (Dec. 2,
1970) (5 U.S.C. Appendix 1).
[3] The national program offices with laboratories are the Office of
Air and Radiation, the Office of Enforcement and Compliance Assurance,
the Office of Chemical Safety and Pollution Prevention, and the Office
of Solid Waste and Emergency Response.
[4] The National Research Council is the principal operating agency of
both the National Academy of Sciences and the National Academy of
Engineering.
[5] High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-11-278] (Washington, D.C.: February
2011).
[6] Environmental Protection Agency, Safeguarding the Future: Credible
Science, Credible Decisions, The Report of the Expert Panel on the
Role of Science at EPA, EPA/600/9-91/050 (Washington, D.C.: March
1992).
[7] MITRE Corporation, Center for Environment, Resources, and Space,
Assessment of the Scientific and Technical Laboratories and Facilities
of the U.S. Environmental Protection Agency (McLean, Va., May 1994).
[8] Now known as the Office of Chemical Safety and Pollution
Prevention.
[9] Environmental Protection Agency, Research, Development, and
Technical Services at EPA: A New Beginning, Report to the
Administrator, EPA/600/R-94/122 (Washington, D.C.: July 1994).
[10] National Research Council, Interim Report of the Committee on
Research and Peer Review in EPA (Washington, D.C., National Academies
Press, 1995); Environmental Protection Agency, Office of Inspector
General, Regional Laboratories (Washington, D.C., Aug. 20, 1997); and
National Research Council, Strengthening Science at the U.S.
Environmental Protection Agency: Research-Management and Peer Review
Practices (Washington, D.C., National Academies Press, 2000).
[11] National Research Council, Investments in Federal Facilities:
Asset Management Strategies for the 21st Century (Washington, D.C.,
National Academies Press, 2004).
[12] Master plans are created for owned properties only. We found
there were no master plans for two laboratory properties located in
Research Triangle Park, N.C., and Fort Meade, Md. We also found that 9
of the 11 outdated master plans were over 10 years old.
[13] National Academy of Public Administration, A Review, Evaluation,
and Critique of a Study of EPA Laboratories by the MITRE Corporation
and Additional Commentary on EPA Science and Technology Programs
(Washington, D.C., May 1994), 10.
[14] High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-011-278] (Washington, D.C.: February
2011).
[15] Federal Real Property Asset Management, Exec. Order No. 13327, 69
Fed. Reg. 5897 (Feb. 4, 2004).
[16] Presidential Memorandum, Disposing of Unneeded Federal Real
Estate, 75 Fed. Reg. 33987 (June 16, 2010).
[17] Environmental Protection Agency, Real Property Cost Savings and
Innovation Plan (Washington, D.C., July 23, 2010.
[18] An FTE consists of one or more employed individuals who
collectively complete 2,080 work hours in a given year. Therefore, one
full-time employee or two half-time employees equal one FTE.
[19] GAO, Human Capital: Implementing an Effective Workforce Strategy
Would Help EPA to Achieve Its Strategic Goals, [hyperlink,
http://www.gao.gov/products/GAO-01-812] (Washington, D.C.: July 31,
2001); Human Capital: Key Principles for Effective Strategic Workforce
Planning, [hyperlink, http://www.gao.gov/products/GAO-04-39]
(Washington, D.C.: Dec. 11, 2003); Clean Water Act: Improved Resource
Planning Would Help EPA Better Respond to Changing Needs and Fiscal
Constraints, [hyperlink, http://www.gao.gov/products/GAO-05-721]
(Washington, D.C.: July 22, 2005); EPA's Execution of Its Fiscal Year
2007 New Budget Authority for the Enforcement and Compliance Assurance
Program in the Regional Offices, [hyperlink,
http://www.gao.gov/products/GAO-08-1109R] (Washington, D.C.: Sept. 26,
2008); Environmental Protection Agency: Major Management Challenges,
[hyperlink, http://www.gao.gov/products/GAO-09-434] (Washington, D.C.:
Mar. 4, 2009).
[End of section]
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