&EPA
          United States
          Environmental Protection
          Agency
               Prevention, Pesticides
               and Toxics Substances
               (7506C)
EPA-730-R-95-001
September 1995
I
Office of Pesticide Programs:
Report on Customer
Satisfaction With
Program Services
Targeting OPP Customer Service Improvements
ENVtRONMENTAL
       &
  PUBLtC
                                    PUBLIC
      Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Poslconsumer)

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                                  ACKNOWLEDGMENTS
  Univer    ?W™ °f Pes!!cide PTO&ams (OPP) ^ould like to thank Dr. Denise Scheberle of the






  su*ey 4^T °^^     f°r ^ aSS1StanCC * successMy Completing the "General Public"

                       OPP CUSTOMER SURVEY WORK GROUP
                            Ameesha Mehta/FOD: Project Leader
Karen Angulo/EFED
Marjorie Fehrenbach/OPP-IO
Michael Hardy/FOD
Anne Lindsay/PSPS
 Peter Caullkins/RD
AlanGoozrier/BEAD
Susan Lewis/RD
Richard Petrie/EFED
                             Penelope Fenner-Crisp:  Advisor

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                           TABLE OF CONTENTS

                                                                    	 5
I.    GLOSSARY OF TERMS 	

                                                                     .... 6
II.   EXECUTIVE SUMMARY	

                                                                   	 7
III.   INTRODUCTION	

     A    CUSTOMER SURVEY FRAMEWORK              	 ?

     B!    OPP'S INITIATIVE	

ffl.   THE NATIONAL TELECOMMUNICATIONS NETWORK SURVEY                10

                                                                      ... 10
      A.   INTRODUCTION	          10
      B.   METHODOLOGY	    n

      C.   FINDINGS	' " '     .13
      D.   CONCLUSIONS	

 IV   INTERGOVERNMENTAL RELATIONSHIPS BETWEEN EPA HEADQUARTERS AND ^

      REGIONAL OFFICES AND STATES

                                                                     .... 15
      A.    INTRODUCTION	        16
      B.    METHODOLOGY	     16

      C.    FINDINGS	• • • • • ' •;	   . .  18
            1.     statftProprarr-g «H State-Level Support	...18


                  a)    Federal-State Relationships	
                  b).   State-Regional-Federal Relationships	

                                                                      .... 21
       D.   CONCLUSIONS	        21

            1     St?tesperceive  	'....... 21
            2.    gtat?P ttenomrnend;	     21
            3.    ttfigtrms Perceive."	 25
            4.    Ktj-gtons Recommend:	

  V.    NATIONAL SURVEY OF PESTICIDE PROGRAM SERVICES                    25

                                                                    '  .... 25
        A.    INTRODUCTION	•••••'	        25
        B.    METHODOLOGY	  25
             1.   Sample	:     ..;...  26
             2.   Questionnaire	•"	:	  	  26
             3.   Ttftsfponse tn the Survey	• • • •	

                               •                           .            	  26
        C.   SURVEYRESULTS	•••••' ' '	  26
             1_    fiegpondents	         31
             2.    Jrppnrtance of V^tf*™ Services	

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        E.
               3'     Program Performance Ratings    	.		          34
               4.     Overall Approval Rating		  35
               5.     Benchmarking	                        36
        D.    ANALYSIS
                                                                                           36
1.     Performance Gaps	                          37

CONCLUSIONS	
 VI.    RECOMMENDATIONS
                                                                            39

                                                                            37
 I.      GLOSSARY OF TERMS
 Benchmarking: refers to analyses of customers, competitors, trends in the market, differences in
 products or service characteristics and organization's performance.  It allows organizations to focus
 attention on where it is most needed.

 Core Processes: any process or system, in place, that centers on the review of applications and data
 submitted by the pesticide industry, leading to decisions to approve or deny registration or reregistration.

 Customer Satisfaction: an emotional and intellectual reaction to one or more characteristics of a
 product, service, or quality.

 Customer Service Standards:  set by OPP for services we provide to all our customers  It is used to
judge the quality of the service provided.

Performance Gaps:  a method of comparison whereby the difference between the importance rating and
performance rating is assessed. This method allows decision-makers to prioritize program improvements
and allocate scarce resources to targeted areas.

Performance Standards/ Goals: Not the same as individual performance stand ards, though two could
be connected.  It is a specified outcome or result on one or more criterion.  It is the desired state or level
or future performance of a service.

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H.    EXECUTIVE SUMMARY
       EPA's Office of Pesticide Programs (OPP) is committed to improving the quality of our customer
services  In the fall of 1994, OPP conducted a series of baseline "customer surveys  m order to identify
"hatl most important to all customers, and better target the areas where improvements are
       e   OPP's customer service initiative is also in response to the President's Executive Order
       which requires all Federal agencies to identify their customers, the kind and quality of semces
desired by their customers, their customer's level of satisfaction with existing services, and to compare
their own performance against the "best in the business."

       OPP conducted three customer surveys that were designed to encompass the diverse spectrum of
               are affected by and interested in pesticide regulatory and implementation issues (e.g.,
             stiy, States, environmental groups, fanners and other user groups, other government
        congreSonal staff, the public, etc.).  The results of a preliminary "pilot survey,' conducted m
 mid 1994, were used in the development of the final survey instruments.

        Several opportunities for improvement were identified from the survey results.  The general
 public (survey #1) rated as satisfactory or above OPP's performance in responding to the public  the
 qul ry oSo'rmaL that they received from OPP, and OPP's ability to protect the environment and
 food supply OPP received lower ratings for the public's ability to access pesticide information. The
 EPA Reg ons and States (survey #2) identified under funded mandates, few opportunities ^ early in^ut
           decision making process, and OPP's poor telephone *y?^^™££m
          srant and Environmental/Public Interest community (survey #3) rated OPP s overall
           ? 4 4 on a scale of 10, identifying the lack of timely decisions, lack of consistency in policy
 CtUUl W
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   III.   INTRODUCTION
  th v 7he/reS!dent! Exec«tive Order 12862 requires all Federal Agencies to identify their customers
  the kind and quality of services desired by their customers, their customer's level of salfac ont^h
  exis ing services, and to compare their own performance against "the best in the business - A M™ ch
  1995 Memorandum from the President (part of Reinventing Government II) reaffirmed the

  sizK^ssrto fxecutive °rder 12862'caiiing for the pubucation °f cust°mer -
  standards by mid-1995  and a customer service report assessing performance against those standards
        A.    CUSTOMER ASSESSMENT FRAMEWORK
                         SEisfa  °n is a i
                 TSTr SEsa  °n s a "**™** ^d systematic approach a, illustrated by the
             re.  It involves identifying the customers who and should be served by the organization;


Identify
0 u s torn ers .
& Services


•^-*


Develop
P erform anoe
(8u rvey
M ethodc)






Conduct
Baselin e
C u stom sr
Assecem enf






Establish &
Post
Custom er
Service 8 td 's
(Benchmark)





Establish
Perfo rm an ce
G oals/S td's


                       CUSTOMER ASSESSMENT FRAMEWORK
' t                            (SUrV6y meth°ds) md C0nductin8 baseline assessments to determine
 the kind and quality of services they want and their level of satisfaction with existing services- estaSL

 ^posting customer service standards and goals, and measuring results against £££?

                                 Vhe ^ " thC busineSS' s^^g front-line employees on the

                  fin       t      'f l^ bUSineSS; making fnformatio» ^ inf 'rmatio« -rvices
   sily accessible, and finally, systematically addressing customer complaints.


       B. OPP'S INITIATIVE:
          ^f6/PeStidde Pr0§rT (°PP) iS C0mmitted t0 imProvinSthe ^ua% of our customer
          , oart of th,s commitment, and in response to the President's Executive Order 12862 and


Task Force, OPP create^S^                                    ™> *"**•

of conducting a series of baseline assessments and recommending areas where ii


      The OPP workgroup began planning for the customer



                                          5
                                                   service survey early in 1994. The

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* stomer^ho ™4Med by and h*£tod in pesticide regulatory and imptementatton .ssues:

              State/Local pesticide regulatory officials
              EPA Regional & Headquarters Offices
              Other Federal Government Agencies
              Congressional Staff
              Industry/user group representatives including:
               Chemical manufacturers
               Formulators
               Distributors (agricultural, biological, structural, lawn care)
              Farmers
              Certified pesticide applicators
              Environmental public interest groups (including groups
              representing environmental equity issues)
              Press and media
              Representatives of the public health and medical fields
              International community
               General public

        The pilot survey proved to be very useful in developing the final survey Particularly ™P°^
  were Jcritiques o7the survey instrument itself.  A significant percentage of the respondents found the
  Ce*t o te J too long, somewhat confusing, and containing many questions that were relevant to some
  types of customers.

        As a result of the pilot surveys preliminary findings, OPP abandoned the "one-instrument-fits-aU"
  survey ££±? afpro^h and developed three survey instruments.  Each of the three surveys targeted a
  grouping of customers with similar service needs, as follows:

  •     Snrvev#l: Users of the National Pesticide Telecommunications Network (NPTN) (primarily the

         general public).

  •     Survey #2: EPA Regional Pesticide Program Officers and State Pesticide Program Directors.

  •     Survey #3: Users of pesticide program services including: pesticide registrants, producers, and
         formulators, and environmental and public interest groups.
       The chapters that follow provide an in-depth look at each of the 3 1
methodologies, findings, and an analysis of the survey results. The last chapter
workgroup's recommendations for improvement in targeted areas.
                                                                                     OPP

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                                                                                                      1
 IV.   THE NATIONAL TELECOMMUNICATIONS NETWORK SURVEY
       A.     INTRODUCTION

       The Office of Pesticide Programs (OPP) has conducted this survey to measure the satisfaction of
 services provided to its "general public" customers.  This chapter focuses on the responses of private
 citizens who were polled by EPA's pesticide hotline, the National Pesticide Telecommunications Network
 (NPTN).

       NPTN is a toll-free telephone service that provides a variety of information about pesticides to
 anyone in the contiguous United States, Puerto Rico, and the Virgin Islands. The service is designed to
 provide accurate and prompt responses to requests for information about pesticides. Answers are given
 on the telephone or in the next day's mail.  Any requested information that is outside NPTN's expertise or
 authority is referred to the appropriate contact within the Agency.

       OPP used NPTN for this customer service survey because the service is regularly used by a broad
 cross section of the general public.  OPP recognizes that NPTN may not reach all types of private
 citizens, and does  not consider this survey to represent the opinions of all private citizens affected or
 associated with OPP's services.  Nevertheless, OPP believes that the use of NPTN for this survey has
provided a starting point (baseline) for measuring customer satisfaction of private citizens.

       B.    METHODOLOGY

       NPTN agreed to ask 150 callers to the hotline if they would agree participate in OPP's customer
service survey. A  systematic caller selection process was used, where every four caller to NPTN was
asked if they would agree-to participate in the survey.

       The following is a summary of those questions asked:

       4      How did you obtain the Hotline number?
       *      How often do you contact the EPA or the Hotline?
       +      Demographic data, including city, state, gender, race, education, profession, number of
             persons in the household, pets?
       *      How satisfied were you with the verbal information received?
       +      How satisfied were you with any written material received?
       *      Was the information understandable?
       4      Is pesticide-related information accessible to the public?
       +      Do you have confidence in EPA's ability to protect the food supply?
       +      Do you have confidence in EPA's ability to protect the environment?
       +      Overall, is OPP responsive to the public?

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C.     FINDINGS

The following charts provide summaries of the survey responses obtained by NPTN.
       Concerning the verbal information received: 78% of the respondents were very satisfied,
       21% were somewhat satisfied, and  1% were not satisfied.
                      After Contacting, how satisfied with
                              information received?
                          Not Satisfied  11%
                      Somewhat satisfied  j^B 21%
                          Very Satisfied
                                                    78%
                                    0%  20% 40%  CO1/.  80V. 1190%
                                      Percent of Respondents
        Accessibility of pesticide information: 12% were very satisfied, 42% were somewhat
        satisfied, and nearly 46% of the respondents were not satisfied.


                       Do you feel that pesticide information
                          is readily accessible to the public?
                                 Not Satisfied
                             Somewhat satisfied
                                Very Satisfied
                                           0% 20% 40% 60% 80% 100%
                                          Percent of Respondents
                                         10

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Confidence in EPA to ensure food safety: 20% of the respondents were very satisfied
61% were somewhat satisfied, and 19% were not satisfied.
           How much confidence do you have in EPA
                  regulating pesticides - safe food
                      No confidence
                   Some Confidence
                  A lot of Confidence
                                0% 20% 40% 60% 80% 100%
                               Percent of Respondents
Confidence in EPA to protect the environment: 19% were veiy satisfied, 62%
somewhat satisfied, and 19% were not satisfied.
                                                                  were
               How much confidence do you have in EPA
               regulating pesticides-safe environment
                       No confidence
                    Some Confidence
                   A lot of Confidence
                                 0% 20% 40% 60% 80% 100%
                                 Percent of Respondents
                             11

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            OPP's responsiveness to the public:  31% were very satisfied, 62% were somewhat
            satisfied, and 7% were not satisfied.

                       Overall, how would you rate EPA-OPP
                        Program responsiveness to the public
                             Not Satisfied • 7°/
                        Somewhat satisfied
                            Very satisfied
                                                     62%
                                          I    I    I   I    II
                                       0%  20%  40% 60% 80% 100%
                                         Percent of Respondents
       D.     CONCLUSIONS

       OPP recognizes that this survey has its limitations.  The surveys sample size was limited tc> 150
persons and a majority of the respondents were white females with children and/or pets.  Therefore, the
SSShfiited the need for better communication to the public regarding the availability of the
Hotline services, especially to low income and minority populations.

       In addition  many of the callers were "first-time callers," which limits the accuracy of responses
for one foUow^g question, "satisfaction of verbal information received."  As with other surveys of this
nature thereTs an hiherent degree of bias because NPTN was conducting the survey while at the same
Te SsfsSe^th potential problems.  The average caller may have felt  some pressure to respond
favorably to the person whose assistance they needed.

       Overall OPP received satisfactory or above satisfactory ratings for every question except the one
oertaining to accessibility to pesticide information. OPP believes that this survey  even with its
Sons prides an adequate baseline for measuring the general public's satisfaction with the services
that OPP provides.
                                                12

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13

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        MTIRffOIMffMNTMREMT/ONM/PS
STATtS
                     RCG/0M
                    FEBRUARY 1995
                        14

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V.
        INTERGOVERNMENTAL RELATIONSHIPS BETWEEN FPA
        HEADQUARTERS AND REGIONAL OFFICES AND STATES
              INTRODUCTION
           -                °f thiS CUSt°mer Survey is to acc»r*tely characterize the perceptions that
  the nan    H Pr°gramfdirectors and Reg^ Pesticide program offices have about their pro-ams Id
  n oT ? f T6 °f ferSovemme^l relationships with EPA's Office of Pesticide Programs (Om
  dev±±f "f fTZf thf! Perceptions> one raust first have an appreciation of the history 17     '
  development of federal and State pesticide programs, and some of the issues, that they face today.

  red.tr Jo! ** T^ ff ^ V •** federal Sovernment to ^gulate pesticide distribution through
  registration was the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) of 1947  The

  rZ±6ntS H° FIFRA " l %2 rCSUlted " ^ Changes k how the fede^ government approached the
  he1±s "S T7T ^^ PeStiCidu S by CreatinS a partnershiP between *• ^^ govemmtt and
  Itr S^  , J I !   amendments authorized the development and maintenaince of cooperative
  agreements to State governments for the establishment of State pesticide programs  The States who
                                               pr°8ram «*» have experienSd dSm
        s and deletions of programs mandated by the statute, and many resource fluxuations  These
 frequent changes have made it difficult for OPP, Regions, and States toV«ivelyde^op and maintain
 good working intergovernmental relationships.                              ucveiop ana maintain
affected how they approach the implementation of pesticide programs, resulting in the numerous program
and policy varurtions that currently exist among Regions, among States, and befween O pTheadquZs
±t InH^81011'   T *• ^^ Pr0gram and P°Iicy insistencies have proved to be problemS [he
past and have strained intergovernmental relationships.                            uuiemanc in tne

      B.     METHODOLOGY

      In June 1994, OPP received copies of a survey about intergovernmentd relationshios
                                          15

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this report. Note, also, that between June 1993 to December 1994 OPPTS included OHMhe Office-of
Son Prevention, and Toxics (OPPT) and the Office of Compliance Monitoring (OCM)
in December of 1994, OCM was moved to the Office of Enforcement and Compliance Assurance
(OECA).

       This study incorporates data from three sources:

       1)     Surveys mailed to State Pesticide Program Directors;
       2)     Interviews with EPA Regional Pesticide Program Offices and Headquarters staff in the
              pesticide programs; and                                     .            .
       3)     EPA documents, including the guidance documents for State pesticide cooperative
              agreements.

       Forty-four State pesticide program directors (88%) responded to the survey questionnaires^
 Phone Sews were conducted with 9 EPA regional offices and 11 States. Phone calls were made to
 State pesticide program officials who chose not to respond to the survey m order to determine
 ^te^S^ the survey itself influenced their decision not to respond. Their responses
 suggest that there is not a non-respondent bias in the survey results.

        C.     FINDINGS

        The findings in this report are grouped into two categories:

        n     State Programs and State-Level Support. State perceptions or responses about the
               quality of the State program and State-level support for the program goals; and,

        2)     Federal-Regional-State Relationships. Perceptions or responses about the nature of the
               State-Federal and the State-Regional-Federal relationship.

        Note- to maintain the consistency of Dr. Scheberle's original report, the term perceptions is used
  instead of responTeT The usage of the word "perceptions" is not intended to invalidate the responses of
  State Program Directors or Regional Program Officers.

                1.     Stflt* Programs and Stqt?-T ftvel Support

                State pesticide programs are established programs; 71 percent have been in operation at
  least 15 years. Located in State agriculture departments, many State pesticide pro-ams ^absorbed
  pesticide regulatory duties in the mid-1970's. State pesticide programs are large with about half of the
  States operating programs with 20 or more staff.

                Perceptions.

                •      79 percent of State pesticide directors agreed or strongly agreed that the number
                       of State pesticide personnel were too few.
                                                16

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        The availability of federal funding is viewed as very important by State directors.

        Perceptions

        •      79 percent believe that EPA grants are very important to their programs
        •      57 percent of State pesticide directors agreed or strongly agreed that the amount
               of federal funding was too little.  39 percent responded that federal funding
               adequate.
                                                                      ; was
       Pesticide directors perceive high levels of administrative, legislative and public
 support.

       Perceptions;

       •     82 percent believe that their top-level State administrators support the pesticide
              programs.
       •     48 percent feel that State legislators view the regulation of pesticides as an
              important policy issues and support the programs.
       •     66 percent believe that citizens consider the State pesticide programs were
              addressing an important public health and environmental issue.

       State pesticide program directors expressed a high degree of confidence in their
program.

       Perceptions:

       •      74 percent of State pesticide directors agreed that their staffare adequately trained
              to run a pesticide program.
       •      77 percent believe the State programs work effectively.
       •      91 percent indicated that the pesticide program in their'State is now more effective
             than a few years ago.
       •      48 percent of State pesticide directors agreed or strongly agreed that certified
             pesticide applicators in their State were well trained and did a good job
       •      68 percent agreed or strongly agreed that the responsibility for regulating
             pesticides  most appropriately rests with the States rather than the federal
             government.
      2.
 Federal-Regional-State Relationships

a).     Federal-State Relationships.

Perceptions of State nesticide program directors;

•      EPA Regional Offices are supportive of State programmatic efforts.

       •      84 percent believe that their EPA regional office supports their

                          17

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       program.
•      61 percent feel that EPA regional staff fairly evaluate State
       cooperative agreements.
•      57 percent of pesticide directors agreed or strongly agreed that
       EPA regional staff are valuable resources for their, program.

State and regional program staff are in frequent contact.

•      80 percent of State pesticide directors maintain daily or weekly
       contact with EPA regional staff.

The level of perceived support and cooperation decreases when the
State directors assess their relationship with EPA Headquarters staff
or talk about the EPA in general.

 •     48 percent believe that EPA Headquarters staff support their
       program, much lower than the perceived regional support.

 One in four pesticide directors believe that the EPA pesticides
 program works effectively, and not a single State director believes that
 a stronger national program is warranted.

 One State director commented:  "The emphasis of the federal program is
 based on delivery of commitments in a form understandable to Congress,
 not necessarily to produce effective State programs.  Recently, the stress
 on EPA officials at Headquarters and regions has been to justify everything
 they do  The resulting effect on States is much stronger oversight by the
 EPA to the point of pettiness.  This has eroded the relationship between
 EPA and States, as well as the amount of time State personnel can spend
 accomplishing program objectives."

 EPA's  communication with the States.

  •      75 percent of State pesticide directors believe that the EPA does
         not clearly communicate program goals and requirements,
         effectively.

  Pesticide program directors express both of the following concerns
  with greater frequency, which may partially explain the much higher
  percentage satisfaction with the Regional program officers.
   •     Headquarters staff simply aren't available (don't answer or return
         phone calls).
         Communication tends to be
         opportunity for State input.
phone calls).
Communication tends to be one direction (top-down), with little
                      18

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  EPA's arbitrary decision-making and perceptions about the direction
  01 the pesticide program.

   These comments are typical of pesticide directors' concerns:

  •      "Like all other relationships, open lines of communication are
         critical. It is imperative that current information be readily available
         and appropriate technical assistance be accessible for the
         relationship to work effectively."

  •      "The EPA should seek more State input prior to developing new
        initiatives."

  •     "EPA should coordinate release of documents, make releases more
        timely, and be certain there are enough copies for the States to
        distribute.  This is simply a matter of poor planning and
        communication."

 EPA tends to increase requirements under cooperative agreements,
 without increasing funding or State flexibility.

 Unfunded and/or under-funded mandates to States is the most
 frequently expressed complaint among pesticides program directors.

 Concerns about flexibility are often expressed  in two ways:

 •     The methods used to evaluate State programs.
 «     In the ability of States to focus on State priorities.

 Some variants of the phrase "bean-counter" are used often by State
 directors when expressing their concerns about the federal-State
 relationship, such as the following comments;:

 •     "EPA is more interested in bean counts to  show numbers  The
       State is more interested in accomplishments with real impacts  An
       example is the EPA requirement that we tab; 300 ground water
       samples. Dedicating staff to that means less focusing on the
       hundreds of pounds of excess pesticides that will be disposed of
       improperly."

•      "As long as the State can accomplish more than the feds ask for
       everything is fine.  But, the feds tend to be  bean counters and don't
       necessarily look at  the whole program picture "
                  19

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           b).    State-Regional-Federal Relationships

                  p?{,inn?l Project ftfffryr*' Perceptions:

                  •     Perceive themselves as "buffers" in the system: simultaneously
                         responsible for maintaining State performance to achieve national
                         goals while also assisting State program directors in running their
                         program.                             .
                   •     Perceive their position as more collaborative and less
                         confrontational toward State directors. This may, at times, put
                         them at odds with EPA Headquarters.
                   •     Comments of Regional Project officers:

                          •      "There's more than just geographical distance that makes
                                 Headquarters (staff) seem remote. There's a philosophical
                                 difference.  I trust my State, and see my role as onepart ot a
                                 partnership. Sometimes, I think Headquarters (staff) are so
                                 concerned about their own accountability, they forget that
                                 States have come a long way, and basically want the same
                                 thing we do.

                    •      RegionalstaffagreethatEPAHeadquartersoccasionallysends
                           inconsistent messages about program goals and priorities, and
                           would like to have greater input into and influence on the central
                           decision-making process.

D.     CONCLUSIONS

Many general conclusions can be drawn from this survey.
       1.     Staff Perceive;

              a).

              b).
              c).
               d).
Their staff, while too few, are adequately trained and run an effective State
pesticide program. State programs are continuing to improve;
EPA regional staff are valuable resources who are frequently contacted
who areconsidered to be supportive of State programmatic efforts, and are
fair in their appraisals of State programs;
EPA Headquarters staff are less supportive of State programs, are not
available (don't return phone calls),  and don't provide adequate opportunity
for State input into decision-making;
The federal pesticides program does not work effectively and a stronger
federal role is not warranted.
        2.
               a).
 All mandates must be adequately funded (no increase in requirements
 without commensurate increase in funding);
                                         20

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                     b).     More flexibility in tailoring federal funds to support State priorities;
                     c).     Less rigid accountability (bean-counting);
                     d).     Improved Headquarters communication of national program goals and
                            requirements, improved EPA Headquarter stiff responsiveness (return
                            phone calls), and more opportunity for State input into the headquarters
                            decision-making process.

              3.      Regions Perceive;

                     a).     Political constraints exist on both State program directors and on
                            headquarters;
                     b).     There is a need for cooperative relationships between Regions and States.

              4.      Regions Recommend;

                     a).     Recognition of their expertise by headquarters;
                     b).     Headquarters must send consistent messages about program requirements.
                     c).     Greater opportunity for their input into policy decisions.

              The following tables provide a summary of characteristics and perceptions of State
Pesticide programs.
                       Table 1: Characteristics of State Pesticide Programs
           Program longevity

                       Six years or less

                       at least 15 years

                      Personnel

                        Six or fewer

                         at least 20

              Contact with Regional staff

                        Daily/weekly

    Federal funding is very important to the program

              Federal funding is adequate

               Matching requirements (a)
   2%

   71%


   7%

   52%


   80%

   79%

   39%

15%; 50%
  (a) The matching requirements for die pesticides grant depend upon the program: federal govianment contributes 85% of the
         cost for groundwater, worker protection and endangered species programs; 50% for certification program.
                                               21

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                             Table 2
Perceptions about State pesticide programs and State-level support.
                           Pesticides

Administrative support for program
      State program is effective
  Legislative support for program
     Citizen support for program
  State staff is adequately trained
State program is more effective than
          three years ago
     States staffing is adequate
% Agree
   82
   77
   48
   66
   74
   91

   21
 n=44
                             Table 3
    Perceptions about Nature of the Federal-State relationship
   Perceptions related to Regional Offices
       Regional staff valuable resource
   Regional staff are supportive of program
      Evaluated fairly in program review
     Perceptions related to Headquarters
   EPA clearly communicates program goals
 Headquarters staff are supportive of program
     EPA Program is working effectively
   Perceptions related to program strength
     Need for a stronger national program
      Need for a stronger State program
   % Agree

       57
       84
       61

       22
       48
       25

       0
       19
                               22

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       A&Eff/M MT/ffMT/ON IEWI
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                                   TO
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                                PROGRAM



                                &RWCES
                 /H/ty/995
                    24

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  VI.   NATIONAL SURVEY OF PESTICIDE PROGRAM SERVICES


        A.     INTRODUCTION

        EPA's Office of Pesticide Programs (OPP) has as its main function the issuance of regulatory
  decisions for the registration and reregistration of pesticides under the Federal Insecticide, Fungicide and
  Rodenticide Act (FIFRA).  The objective is to safeguard human health and the environment from the
  risks associated with the beneficial use of pesticides.  In its effort to improve the services to registrants
  and environmental and public interest groups, OPP revised its pilot survey amd sent it to 700+
  respondents.

        B.     METHODOLOGY

               L     Sample

               The target population for this survey included industry "registrants" and
 environmental/public interest groups. Half of the registrants in OPP's "company name and address"
 database ( about 700 ) were randomly selected and sent the survey, as well as 40 environmental and
 public interest groups.

              2.     Questionnaire

              Survey recipients were asked to rate OPP's performance on core processes within its
 Registration and Reregistration programs (which include special reviews, reregistration eligibility
 decisions, product reregistration, new active ingredients, biologicals, fast tracks and non-fast tracks)
 Each core process had two categories to be ranked - performance and importance. The performance
 category rated the level/quality of service provided, whereas the importance category rated how
 important the service is to the respondent. Ranking was from one to five; one represented "strongly
 disagree" - to - five "strongly agree." Each category asked basically the same types of questions
 regarding timeliness, understandability, consistency, communication of decisions,  whether the process
 has improved and if the process is open to the public.

              Respondents were further asked to "benchmark" OPP's services against other comparable
 government/private sector organizations whose services, in the respondent's opinion, were viewed as
  high quality." Factors to be considered for the Benchmarking were courtesy/professionalism timeliness
 attention to detail, telephone responsiveness, understandability of our product output, consistency
 competence, product knowledge, openness to customer concerns and relevance.

             The survey included a section where respondents were asked to provide an overall rating
 of product/service performance ranging on a scale from 1 to 10, where 1 represented "highly
 dissatisfied," and 10 represented "highly satisfied."

             The survey also had a section devoted to identifying the type of respondent (e g  pesticide
producer, pesticide formulator, environmental group, public interest group and other.)
                                              25

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             3.     Response to the Survey

             The questionnaires were mailed out in mid-February and responses were requested by
March 17,1995. Atotal of 326 responses were received (47 percent).

       C.    SURVEY RESULTS
              1.
                    Respondents

             Of the 326 responses received - 307 were recognized as complete and usable as of the
cutoff date By respondent category the numbers responding were: 112 pesticide producers, 138
pesticide formulators, 4 environmental interest groups representatives, 1 public interest group
representative and 52 other or unknown.
Table 1: National Survey of Users of Pesticide Program Services
Number and Percent of Total Tabulated Questionnaires by
Respondent Category
Respondent Group
Pesticide Producers
Pesticide formulators
Environmental Interest Groups
Public Interest Groups
Other/Unknown
Total
Number Percent
112 36.5
138 45.0
4 1.3
1 0.3
52 16.9
307 100.0
               2.     Importance ^f Program Services

               Respondents were asked to rate 45 customer service statements as to the importance of
  that service being provided as part of OPP's Reregistration, Registration and Special Review core
  processes. For example the first statement under  Special Review Regulatory Decisions was:

               "Risk assessments are understandable."

               The respondent was asked to circle one response out of 5 that were provided with 1
  representing "not at all important," 2 representing "not very important," 3 representing "neutral," 4
  representing "fairly important" and 5 representing "very important".  The 7 subareas in the core
  processes listed were:
                                                26

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                  Reregistration
                                Reregistration Eligibility Decisions (REDs)
                                Reregistration of End-use Products
                  Registration
                                New Active Ingredients/Tolerances
                                Biologicals
                                Fast Track Applications (Me-Too's/Amendments)
                                Non-fast Track Applications (New Uses/Formulations)
                 Special Review
                               Special Review Regulatory Decisions

                           s as a group (including pesticide producers and pesticide formulated
   noD.        	°'—tlon of Pesticide products is the most imoortant cnfp «,•„,>»/•
   OPP's program. Their highest program agereeat   f II f      ""P0™"1 core process/service area of
   Too's/Amendments) with an imnottan^ oSL AP A°I i     ,tors rated 1S for Fast Track Applications (Me-
                   v^/ vTiui an uupuildnce SCOre Or 4 31 on the S nnint cr>a1o  TU   ^ -i      .        v-iv
   program area indicated is non-fast track application    th   4          •    •        m°St imPortant
   received a 4.19 and new active in&tv>/r  * + i             a       Rcregistration of end-use products
      •                   <»wuvc ingreuient tolerances 4 06  Snepial rox/i^nr t>cr»   j i •  <   .
   received, 4.05, 3.99 and 3.59 respectively  Therefo     ''        review, KfcDs and biologicals
  important side of the scale All core                  registrants rated all prognam areas on the
  important and very important. None of tSatTmenL n^h ^^^ ^ REI>S Were rated between fairly
  the registrants.                            statements on the survey were raited as being unimportant by

                                    Core Process/Service Area Importance
                                          Ratings by Registrants
                        Fast Track (Me-Too's/Amendments)
                      Non-Fast track Applications (New Uses)
                        Reregistration of End-Use Products
                         New Active Ingrediant/Tolerances
                                    Special Review
                                         REDs
                                      Biologicals
•he
                                                                         ..  ...     aggregate of all
                                                               point scale.  The next most important
                               were rated at T '^k'f~^°7C"^ of end-use products received a 4.04.
                               were rated at 3.85 followed by new active ingredients/tolerances with a
                                               27                       :

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3.84. Non-fast track appucationsCnewuses^
             ^"^^^^
     offte statements on the survey were rated as being urumportant.
                                 Core Process/Service Area Importance
                                     Ratings by Enviro/P I Groups
                                    BEDs

                               Special Review

                  RtrefMratioii of End-Use Products

                  Fart Track (M«-Too'a/Amendments)

                    New Active Ingredient/Tolerances

                Non-Fast track Applications (New Uses)

                                  Blologicals
                 The statements on the survey
fall into eight categories of customer service standards:
                                     scientifically sound
                                     adequate guidance - clearly written
                                     timeliness
                                     consistency                    .   .
                                     understandability/effective communication
                                     adequate resources
                                     process has improved
                                     open to the public





     boTh with a rating of 4.18 on the 5 ^^^^"^Lted received a rating of 4.06.
     4.10 and 4.13. Having guidance ^^f1^16^^dS got ratings of 4.02.  The only
                                                28

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                               Service Standard Aspect Importance
                                      Ratings for Registrants
                                      scientifically sound
                            adequate guidance - clearly written
                                              timely
                                           consistent
                         understandable/effectively communicate
                                     adequate resources
                                    process has improved
                                      open to the public
                The most important service standard aspect across all program areas as indicated bv
                 Pf IiVnt*reSt,?r°UpS 1S ^x™^/^™ communication with a rating of
         the 5 point scale. Timeliness and consistency follow both with ratings of 3.92  Scientifically
 sound and open to the public both got a 3.90.  Having adequate resources is rated at 3 87 The
 process being improved  received ratings of 3.75. The lowest rating was for adequate'   '
 guidance/clearly written with a 3.66.  However, this is still well above the neutral rating of 3
 Therefore all aspects of customer service rated on the survey are identified as important to the
 environ/public interest groups.
                              Service Standard Aspect Importance
                                   Ratings for Enviro/P I Groups
                         understandable/effectively communicate
                                              timely
                                           consistent
                                      scientifically sound
                                      open to the public
                                      adequate resources
                                    process has improved
                            adequate guidance - clearly written
A   '  •   /  u'
the environ/pubhc interest groups with two exceptions. Environ/public interest gnmps
 ±1PU,  *  ^I'^^^ble/effectively communicated" higher at 3.90 aJ U J
registrants rated these aspects at 3.62 and 4.06 respectively.
                                                °f
                                             29

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statements.
was:
             3.     ffrftgram Performance Ratings.

             Resoondents were asked to rate OPP's customer service performance using 45
                 P  pie "he &st of the 45 statements under Special Review Regulatory Decisions

                    •'Risk assessments are understandable."

             Respondents were instructed to circle one response per statement using a scale of 1 to


major program areas of Reregistration, Registration and Special Review.
              Registrants generally "disagreed" with statements regar




 end of performance ratings with 2.78 and 2.73 respectively.
                                Core Process/Service Area Performace
                                        Ratings for Registrants
                                             REDs

                                          Biological*

                                        Special Review

                            fUrtfllstratton of End-Use Products

                             Hew Active Inflrediant Tolerances

                            Fast track (Me-Toos's/Anwndmenis)

                          Non-Fast Track Applications (New Uses)
                                                               i  i
                                                                 s
                Ratines from environmental/public interest groups are generally neutral, not
                             disagreement wirti the statements regarding OPP's level of performance.
                               n of end-use products receives the highest performance rating wi h a
   REDs wt  a .   an  no-
   category falling below the neutral rating was new active ingredient tolerances with a 2.87
                                                30

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                             Core Process/Service Area Performance
                                   Ratings for Enviro/P I Groups
                       Registration of End-Use Products
                                    Special Review
                       Fast track (Me-Toos's/Amendments)
                                      Biologicals
                                          REDs
                    Non-Fast Track Applications (New Uses)
                        New Active Ingrediant Tolerances

aSp6Ct S6tting the highest ratinS is bein§
the public withalTh                                       e  ges ratnS  s  en§ °P^ to
Th/irv    !  A  A'      1&  u6 Only aSpCCt fated above neutral (toward the 4 rating of 'agree ")
The service standard receiving the lowest rating is timeliness with a 2 54
                               Service Standard Aspect Performance
                                       Ratings for Registrants
                                       open to public
                           adequate guidance - clearly written
                       understandable/effectively communicate
                                  process has Improved
                                          consistent
                                    scientifically sound
                                    adequate resources
                                            timely
                                            31

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              For the environmental/public interest groups the service standard aspect getting
the highest rating is  being open to the public with a 3.41. Four other aspects were rated above a 3.
Sen~a 3.31, understandable/effectively communicated with a 3.26  adequa*
guidance/clearly written with a 3.22 and process has improved with a 3.13, The aspect ot service
receiving the lowest rating is having adequate resources with a 2.58.
                            Service Standard Aspect Performance
                                 Ratings for Enviro/P I Groups
                                   open to public
                                      consistent
                    understandable/effectively communicate
                       adequate guidance - clearly written
                               process has Improved
                                 scientifically sound
                                         timely
                                 adequate resources

               Furthermore, registrants rated every service standard aspect of performance lower
            n/puw£ interest groups except for having adequate resources. This is rated more toward
              of levels of OPP's performance at 2.42, than registrants rating of 2.70.
                The following Table 3 provides a summary of importance ratings delineated by
  customer service standard and customer group.
                                                32

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              4.     Overall Approval Rating

              Respondents using a 10 point scale, with 1 representing "toghly dissatisfied" and 10
representing "highly satisfied," the following question received a 4.39.

              "Overall, how do you rate our product/service performance?"

              The rating category respondents most selected was a "4" (54 respondents).  Almost
70 percent of the respondents rated OPP below the mid point on the "overall approval" scale.
Table 4:
Rating Category

1 Highly dissatisfied
2
3
4
5
6
7
8
9
10 Highly satisfied
Missing/Unknown
Total
Overall
Number

22
34
46
54
44
43
22
15
6
1
20
307
Approval Rating
Percent

7.7
11.8
16.0
18.8
15.3
15.0
7.7
5.2
2.1
0.4

100.0

Cumulative
Percent(%)
7.7
. 19.5
35.5
54.3
69.6
84.6
92.3
97.5
99.6
100.0

100.0
                                          33

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                Overall Approval Rating  Average=4.39
                        Percent for each 10 point category
                                      10
                                     9 (0.35%
                                      (2.09%;
                                    (5.23%!
                                (7.67%;
                              .67%)
                            (14.98%!
                                (15.33%;
                                  11.85%)
                                                        (16.03%)
                                                  (18.82%)
             The 5 environmental\public interest groups gave a slightly higher rating for overall
performance with an average 5.0 rating. There were 3 responses with a rating of 3, and 2 responses
at 8.
              5.
Benchmarking
              Benchmarking refers to the analyses of customers, competitors, trends in the market,
differences in products or service characteristics, and the organization's performance.  This method
of analyses allows organizations to focus service area improvement on where it is most needed.

              The overwhelming areas identified for improvement are timeliness and telephone
responsiveness. Over 65 respondents specifically state that "timeliness" is an issue and over 60
highlight phone calls not being returned. A significant portion of the respondents state that other
agencies/companies are generally able to respond in a faster and more reliable time-frame. One
respondent state that the endless reassignment of personnel may be good for cross-training, but is to
the efficiency of the organization.  Another example given regarding poor timeliness is not receiving
study results as soon as possible - especially when there are problems. The respondent indicated new
studies/information could be ongoing while other reviews progress. This could shorten time to
registration.

              Concerning telephone responsiveness, numerous respondents indicate that they did
not receive a timely response to phone calls; that calls often are not returned for several days.  This
 appears to be a source of great frustration. The general indication is that the Agency needs to work
 on customer responsiveness, i.e., returning phone calls.  In addition, the manner in which we
 communicate was highlighted.  Some feel courtesy/professionalism is lacking in our communication
 style.
                                             34

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             The third element most frequently mentioned is the lack of consistency for both regulatory
   decisions and science reviews.
              Some respondents provided general comments under the Benclimarking section. Praise is
 given to the rejection rate analysis which provided needed guidance to better conducting the studies,
 Lack of resources was also acknowledged.  One comment states "many of us in the industry recognize
 that most of the issues (timeliness, telephone responsiveness, consistency) are reflections of decreasing
 Agency resources in a time when Agency responsibilities are certainly not decreasing." Another comment
 states that although the Agency appears to be understaffed, they feel that the Agency has wasted
 resources in other areas. "I feel the Agency is trying to do too many things for too many people."

               Table 4 which summarizes counts from the competitive Benchmarking and service
 activities are provided in the Appendix IV.

       D.     ANALYSIS

              !•     Performance Gaps

              With many dimensions of data available, a means of prioritization provides valuable
information for management decision-makers to concentrate scarce resources for program improvement
One method of comparison is to look at the difference between ratings. This is called the performance
gap. Subtracting the performance rating from the importance rating gives a, negative performance gap for
every aspect rated under every program component of the survey.  If the gap were to be positive it
would indicate that OPP's level of performance exceeds what customers want. With  importance being
equated as customer's expectations, customer expectations are not being met.
Table 5: Difference of Performance from Importance (Performance Gaps) by Core
Process/Service Area
Core Process/Service
Area
Biologicals
REDs
Special Review
New Active
Ingredients/Tolerances
Reregistration -
End-use Products
Non-Fast Track
Applications (New
Uses/Formulations)
Fast Track
Applications (Me-
roo's/Amendments)
Importance Rating
3.65
3.97
4.04
4.08
4.19
4.26
4.29
==========
Performance Rating
======^======
299
3.07
2.89
2.79
2.81
2.76
2.78
==============
Difference (Gap)
0^66
0.90
1.15
1.29
1.38
1.50
1.51
                                             35

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             By program core process/service area, Biologicals show the smallest performance gap of
only 0 66  This is followed by REDs with a 0.90.  The area with the largest performance gap is  Fast
Track (Me-Too's) with a 1.51.  This is closely followed by Non-Fast Track Applications (New
Uses/Formulations) with a 1.50.

              When rating OPP's services to the public, timeliness receives the greatest gap between the
importance rating and the performance rating (1.61); the smallest gap was for openness to the public
(0.40) followed by "understandable/effective communication (0.98).

    !SSS«^==============^
    Table 6:  Difference of Performance from Importance (Performance Gaps) by Service
                                      Standard Aspect
  Ot
       Customer Service Standard
ublic
Importance
Rating
_—
3.67
                                            Performance
                                            Rating
                                            ___

                                            3.27
Difference
 'Gaf
 _^>.
0.40
  Understandable/effectively
                           4.06
                                                       3.08
                                                                0.98
         ih
    sroved
                                      4.01
                                             2.88
                                                                           1.13
   Scientifically sound
                           4.18
                                                        2.93
                                                                1.25
   Adequate guidance/clearly written.
                           4.16
                                                        2.89
                                                                 1.27
                                      4.11
                                             2.79
                                                                           1.32
   Adequate resources
                                      4.02
                                             2.69
                                                                           1.33
                                                        2.51
                                                                 1.61
        E.     CONCLUSIONS

               These survey results provide the Pesticide Program with very useful information. The
  respondent group included pesticide producers, formulators, environmental interest groups and public
  interest groups.  The results indicate that the Agency has not met the expectations of the registrants or
  the environmental groups. The overall approval rating was a 4.39 on a scale of 10.

               The environmental/public interest groups gave a slightly higher rating for overall
  performance with an average 5.0.  Over 70 percent of the respondents rated the program below the mid
  point of the scale. The analysis of the program's current performance compared to the importance rating
  resulted in negative gaps for every service standard ranked. The service with the largest gap was
  timeliness of decisions, followed by consistent decisions.  The core processes with the largest gaps were
  Fast Track Applications followed by Non-fast track.  Additionally, comments provided in the
  Benchmarking segment clearly state that telephone responsiveness and professionalism needed
  improvement.
                                                36

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              Registrants rated scientifically sound written decisions and receiving Agency policy
guidance which is clearly written and easily accessed as the most important to them. For Agency
programs, registrants rated fast track application then non-fast track as the most import.  On the
performance side, with the exception of REDs, all other categories were raited below average.  (Less than
a 3 rating).

              The environmental/public interest groups rated effective co>mmunication of decisions
followed by timely decisions as the most important to them. For Agency programs, they rated
reregistration eligibility decisions and product reregistration as they're most important. On the
performance side, timeliness of decisions received the lowest rating.
                                              37

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VH.   RECOMMENDATIONS
       Several opportunities for improvement were identified from the survey results.  The general
public (survey #1) rated as satisfactory or above, OPP's performance in responding to the public, the
quality of information that they received from OPP, and OPP's ability to protect the environment and
food supply. OPP received lower ratings for the public's ability to access pesticide information. The
EPA Regions and States (survey #2) identified under funded mandates, few opportunities for early input
into OPP's decision making process, and OPP's poor telephone responsiveness as their areas of concern.
The Registrant and Environmental/Public Interest community (survey #3) rated OPP's overall
approval at a 4.4 on a scale of 10, identifying the lack of timely decisions, lack of consistency in policy
decisions, and poor telephone responsiveness as their areas of concern.  The Registrants and
Environmental/Public Interest group also indicated that no service, provided by OPP, met their
expectations.

       In providing three recommendations for targeted areas of improvement, the OPP workgroup
Examined the following: service areas that each customer group identified; poor service standards that
were consistently noted by all three customer groups; if the service area improvements were within OPP's
domain; whether the improvements in one area amplify or detract the improvements in another service
area; the upcoming OPP reorganization in 1996; and, other ongoing streamlining/re-engineering efforts.

       Poor telephone responsiveness was noted by both the States and Regions, and the Registrants and
Environmental/Public Interest community. Though the general public noted its inability to access
pesticide information as its major area of concern, improvements in the telephone responsiveness of the
program would assist in increasing their information accessibility.  The level of telephone responsiveness
will also be affected in the upcoming reorganization of OPP. In addition, any improvements in the
telephone responsiveness also enhances the earlier involvement of States and Regions into the decision-
making process which then amplifies timely and consistent regulatory decisions. Hence, by targeting
improvement efforts (resources) towards this service standard, OPP will realize greater benefits.

        The second targeted area for improvement includes timely and consistent regulatory decisions,
identified as the second major concern by the Registrants and Environmental/Public Interest community.
Other service areas identified by States and Regions were earlier involvement in the decision-making
process and under-funded mandates.  The OPP workgroup chose the earlier involvement into the decision
making process over under-funded mandates,' since this service area is in OPP's domain. Thus, the under
funded mandates issue could be  addressed by the earlier involvement of all parties in the decision-making
and priority goal setting process. In addition,  the above service areas are also of concern during the
upcoming reorganization.

       Therefore, the OPP Customer survey workgroup recommends the following 3  service areas for
improvement:

       1.     Telephone responsiveness;

       2.     Timely and consistent regulatory decisions; and,

       3.     Earlier involvement of States and Regions in the decision-making and priority setting.
                                               38

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       The information gained from these surveys will assist OPP in setting mew customer service
standards. The OPP workgroup recommends that to set new, effective and realistic customer service
standards for the above service areas, staff and managers must be involved in the process.  The
workgroup also emphasizes that the Program must clearly communicate it's expectations to both its
external and internal customers, especially in light of the upcoming reorganization. This will then enhance
the credibility of the organization and its improvement efforts.

       Finally,  effective and lasting improvements in OPP's ability to provide services to the satisfaction
of its myriad of customers can be attained through the systematic integration of these data into the
priority and budget  planning process (i.e., adequate resources), reorganization activities, and other
ongoing streamlining efforts.
                                               39

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