&EPA
United States
Environmental Protection
Agency
Office of Administration
and Resources Management
(3631)
EPA/210-R-93-004
December 1993
Creating A
U.S. Environmental
Protection Agency
That Works Better And
Costs Less
Phase I Report
National Performance Review
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The following report "Creating A U. S. Environmental Protection
Agency That Works Better & Cost Less - Phase I Report" is the product
of a very dedicated group of over 400 EPA employees. This report,
formerly titled "Using The Workforce In New Ways", contains over 400
recommendations for improvement developed by 20 subject area teams.
This report has been reviewed by the National Performance Review
Implementation Steering Committee. The Committee's goal was to sort
through all the recommendations and prioritize them according to which
recommendations would have the most positive overall impact. The
Committee's recommendations for what the Agency should act on
immediately is contained in the report entitled "Creating A U. S.
Environmental Protection Agency That Works Better & Cost Less -
Phase II Report." This report will be available by mid-December, 1993.
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'O,
Creating A
U.S. Environmental Protection Agency
That Works Better And Costs Less
Phase I Report
National Performance Review
December 1993
NATIONAL
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REVIEW
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CONTENTS
INTRODUCTION AND OVERVIEW
AWARDS/RECOGNITION
ECOSYSTEMS
ENVIRONMENTAL JUSTICE
ENVIRONMENTAL TECHNOLOGY
EXTRAMURAL RESOURCES
RNANCIAL MANAGEMENT
INTERGOVERNMENTAL PARTNERSHIPS
INTERNAL COMMUNICATIONS
MANAGEMENT AND LEADERSHIP DEVELOPMENT
PERFORMANCE MANAGEMENT
PERMIT STREAMLINING
PLANNING AND BUDGETING
POLLUTION PREVENTION
POSITION CLASSIFICATION
QUALITY MANAGEMENT
QUALITY SCIENCE
REGULATORY DEVELOPMENT
WORKFORCE CAPACITY
WORKFORCE DIVERSITY
LEADERSHIP TEAM SUPPLEMENTARY REPORT
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INTRODUCTION & OVERVIEW
NATIONAL
PERFORMANCE
REVIEW
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REINVENTING EPA
National Performance Review (NPR)
Introduction and Overview (I&O)
Table of Contents
I. Vision/Goal
II. EPA's Internal NPR Process
III. Successes
IV. Relationship of EPA's Internal NPR to the Vice
President's (VP) NPR
V. Major Cross-Cutting Issues
VI. Lessons Learned/Process Improvements
VII. Conclusions
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I&O 2
ACKNOWLEDGEMENT
The employees who participated in the EPA's internal NPR
wish to acknowledge the foresight of the current Administration
in providing EPA employees with this opportunity. President
Clinton, Vice President Gore, and Administrator Browner have
begun a journey toward continuous improvement of the Federal
Government. We recognize the need for further application of the
NPR at the EPA and acknowledge and appreciate the Administrator's
commitment to this process. The NPR teams also wish to thank the
EPA employees who accepted the responsibility to provide their
opinions, perspectives and suggestions for this improvement
effort.
The challenges that senior management will face in
prioritizing and implementing these recommendations will be
enormous. It will be difficult to evaluate and make decisions
about the teams, findings and recommendations (i.e., the
feasibility and practicality of reinvention ideas; possible
timetables and schedules short-term versus long-term;
reallocation of resources [investment and disinvestment]; ideas
which need further study and refinement; and, proposed strategy
for statutory and regulatory changes.) We wish them luck!!
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REINVENTING EPA
Introduction and Overview
I. Vision/Goal
The vision of EPA's internal NPR effort is for EPA to emerge
as a national and world leader in preparing for the environmental
challenges that lie ahead in the 21st century, while meeting the
pressing needs of this decade. Our goal is to invent an Agency
equipped to fulfill its vision by restructuring, redesigning, or
reorganizing our environmental missions and administrative
operations. We are searching for ways to change to work
better and smarter so that the Agency can deliver high quality
results at a reduced cost. Our aim is to treat citizens as
customers, improve the service and delivery of our programs, and
eliminate waste and inefficiency. The NPR has given us an
opportunity to examine the way we conduct our business and
identify internal opportunities for improvement.
Toward this end, our objectives have been to empower
employees from across EPA and to capitalize on their diversity.
The employees were asked to identify improvement and reinvention
opportunities.
II. EPA's Internal NPR Process
A. Organization of the NPR
To achieve the goal of the NPR, EPA focused on its mission
and on the barriers that impede the fulfillment of the mission.
The Administrator identified topics and appointed a Leadership
Team and 19 Policy/Process Teams to formulate the ideas for
change. Selection of individual participants began with a
process of self-nomination and recommendations from senior
managers.
The NPR effort used a multi-disciplinary, cross-functional
approach which was free of organizational constraints.
Participants in the reinvention effort were encouraged to think
"outside the box," not to focus exclusively on administrative
systems, processes or EPA programs, and to think in terms of
structural changes outside EPA's control which could
significantly improve the operations of government in general.
The teams were also encouraged to identify opportunities for
significantly improving the quality of the environment for
ourselves and for future generations.
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The Senior Leadership Council was involved in reviewing the
initiatives and will work with representatives of the EPA's
internal NPR teams to devise an implementation strategy.
Policy/Process Teams. The 19 Policy/Process Teams were
staffed with over 400 EPA employees, from Headquarters, Regional
Offices, laboratories, and other locations. These teams were
truly diverse (i.e.; discipline, culture, program, time employed,
location, etc.). The teams also provided the forum for
reinvention ideas submitted by other EPA employees.
Team members identified a wide range of improvement
opportunities for administrative and management systems, as well
as the policies that form the foundation for how EPA approaches
and accomplishes its mission. The teams formulated innovative
alternatives to address the specific problems which were
identified, and they prepared reports which are included in this
document. The 19 Policy/Process Teams are:
Awards/Recognition
Ecosystems
Environmental Justice
Environmental Technology
Extramural Resources
Financial Management
Intergovernmental Partnership
Internal Communications
Management and Leadership Development
Performance Management
Permit Streamlining
Planning and Budgeting
Pollution Prevention
Position Classification
Quality Management
Quality Science
Regulatory Development
Workforce Capacity
Workforce Diversity
Leadership Team. The Leadership Team was established to
provide guidance and assistance to the Policy/Process Teams; to
focus on issues not being addressed by the other teams; and to
coordinate preparation of the final report.
Senior Leadership Council. The Senior Leadership Council,
which is comprised of the Administrator, Deputy Administrator,
and the Assistant and Regional Administrators and their deputies,
is charged with advising the Administrator on EPA's internal NPR
recommendations and working with representatives of EPA's
internal NPR to develop an implementation plan.
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Quality Advisory Group (QAG). The EPA's QAG is responsible
for coordinating the Agency's TQM efforts. The QAG staff
provided consultation, facilitation, and logistical support to
the NPR, and they will continue to do the same for the Senior
Leadership Council during the implementation of EPA's NPR
reinvention ideas.
B. Process Activities
EPA's internal NPR was initiated on May 27, 1993, by the
Deputy Administrator at a two-day meeting attended by the
Leadership Team and the 19 Policy/Process Team Leaders. At that
meeting, the Vice President's (VP) NPR staff presented an
overview of the government-wide reinvention effort.
After the May meeting, the EPA's internal NPR teams worked
independently. The teams used various data gathering techniques
and were guided by TQM principles and tools. In addition, the
teams were asked to use a peer review process.
The Administrator concurrently invited EPA employees to
submit their ideas, recommendations, or suggested areas for
improvement. Approximately 1500 ideas were received from
employees and referred to the appropriate internal NPR team. The
ideas ranged from simple to complex and local to national.
EPA's internal NPR process relied on the six principles
adopted by the government-wide NPR initiative:
Measurement: EPA should move from measuring activities
to measuring results.
Customer Satisfaction: EPA should continuously
evaluate its services and increase its public outreach
efforts.
Competition: EPA should improve its overall public
service, cost containment, and excellence to products
and services, particularly as they relate to the
Agency's interactions with its Federal, state, and
local partners, the regulated community, and the
public.
Market Orientation: EPA should continue to use its
leverage to influence market forces positively to help
achieve the nation's environmental goals.
Empowerment of Communities: EPA should shift from
command and control to a process of empowerment in
order to enhance state and local capacity.
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Decentralization: EPA should move from a hierarchical
style to one of consultation and empowerment, placing
value and emphasis on teamwork.
III. Successes
EPA's internal NPR process recorded a very successful
beginning. It created a climate for a new way of thinking, and
it was a laboratory for piloting a new management process
gathering people from across the Agency to work on a common goal.
The process empowered over 400 employees with diverse backgrounds
and varying grade levels from different geographic locations.
The internal NPR teams developed a synergy which resulted in the
many new ideas which are described in their reports. This effort
is just the beginning, and it represents a new management
strategy for EPA.
Another success involved the realization that EPA needs to
approach problems from a multi-media and/or multi-office
perspective. This "common thread" was evident in many of the
team reports. Another involved better strategies for using,
empowering, and developing employees. It takes motivated
employees to help improve management, to develop other staff, to
do a good job, and to ensure that EPA customers are satisfied.
EPA's reinvention effort is an excellent example of how this type
of effort can work and work well.
IV. Relationship of EPA's Internal NPR to the Vice President's
(VP's) NPR
Although the VP's NPR and EPA's internal NPR began as two
separate initiatives, the efforts quickly became complementary.
The Administrator independently established EPA's NPR to help
find ways to improve and streamline EPA's internal processes.
The VP's NPR was established to reinvent the role, of the federal
government and to find ways to streamline its processes. Since
the VP's NPR staff worked very closely with EPA's internal teams,
their issues and recommendations were consistent and
complementary. The VP's NPR report addresses issues from a macro
perspective while the EPA's internal NPR report provides a more
detailed perspective on how these changes can be addressed
throughout the Agency.
V. Major Cross-Cutting Issues
During "Reinventing EPA," several major cross-cutting themes
and issues emerged, and this section addresses those themes/
issues which appeared to be the most significant: (1) "EPA's
Current Organization" the need to restructure how we do our
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work; (2) "Oversight" the need to eliminate excessive scrutiny;
and, (3) "Quality" the need for an Agency commitment to the
concepts of quality and continuous improvement.
Human resources, intergovernmental partnerships, tribal
relationships, internal communications, and pollution prevention
were issues that appeared in many of the team reports. These
issues are fully developed in the individual team reports and are
included elsewhere within this document.
The Administrator's themes (environmental leadership,
partnerships, sustainable development, pollution prevention,
sound science, integrated environmental management, environmental
justice, and management of human and financial resources) emerged
as subjects of specific reports or are included in a combination
of reports.
A. ORGANIZATIONAL STRUCTURE OF EPA
The teams were asked to provide a wide range of
recommendations, including those that might result in
organizational change. The teams found organizational and
"traditional mindset" barriers that have negatively impacted
EPA's ability: to address multi-media or ecosystem types of
problems and to institutionalize pollution prevention.
Media-specific approaches often create duplication among
program offices. Some team reports (e.g., permit streamlining,
pollution prevention, environmental technology) suggest that
these barriers and hindrances to problem-solving can be overcome
by reorganizing, by making more use of cross-media work groups,
or by making special efforts to collaborate on special areas
(e.g., sectors, industries, or customer base.) Using the same
multi-media processes, similar improvements could be made in the
development of budgets.
Proposals, for overcoming organizational barriers, range
from changing the organizational structure of the EPA to using
more cross-program work groups. The need to tackle more complex
issues through prevention and control, in a more "holistic"
fashion, appears to require a new organizational approach. As
EPA strives to solve more complex issues, its current structure
works to inhibit or impede success. The EPA also needs to
address the barriers which are created by multiple pieces of
enabling legislation.
Option - Reorganization. EPA could be organized by
function, geographic area, specific ecosystem problems, or
industry. Centralizing enforcement and compliance functions is
one way to view EPA from a functional perspective. There should
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ISO 8
be efficiency and accountability benefits associated with any
change (e.g., eliminate duplication and waste, increase
responsiveness to priorities, expand multi-media capacity.)
The Agency conducted a functional assessment of its 1994
budget base (e.g., regulation and standards development;
compliance monitoring and enforcement; technical assistance,
education and public outreach; permitting and licensing;
emergency response, site cleanups, and remediation; environmental
data and environmental information management; research; and
management.) Although it was not a perfect budget exercise, it
did look at EPA's organizations from a functional basis.
Option - Multi-media Work Groups. EPA should establish an
infrastructure to enable cross-media teams to be organized
quickly in order to work on specific issues related to
ecosystems, geographic locations, or pollution prevention
initiatives. The Agency has demonstrated success in similar
efforts (i.e.; team building, breaking down organizational
barriers, and solving problems, Clusters, the ten Regional
National Geographic Initiatives, cross-program scientific review
RfD/RfC Workgroup, and the 1993-1995 Strategic Plan
Initiatives/Action Plans.) The Agency needs to resolve the
sensitive issues related to the responsibility, accountability,
and financing (ownership of FTEs and financial resources) of
multi-media work groups.
B. OVERSIGHT
Oversight is an issue that affects all EPA employees and its
customers. It has been addressed in many of the Team Reports.
The gridlock experienced across government appears to be
heightened in EPA. The key guestion is how to balance
appropriate oversight and accountability while maintaining trust.
Example - Hierarchical Oversight. Regional offices review
the work of state agencies with respect to the implementation of
Federal rules and regulations. Headquarters offices (e.g., the
Program offices, the Office of Enforcement, and sometimes the
Office of General Counsel) review the Regional Offices' work and
their review of the State work. In order to reduce oversight and
duplication of effort, more trust is required among the partners
along with a clarification of roles. EPA needs to get rid of
oversight that adds no value.
Example - External Administrative Oversight. The Inspector
General, General Accounting Office and other Congressional
oversight activities and inquiries are repeatedly being conducted
in areas like management of extramural funds. Recently, there
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has been an increased level of oversight, and EPA should conduct
a comprehensive assessment of the positive and negative impacts
of administrative oversight on program services and
administrative operations.
Team reports, employee suggestion forms, and discussions at
the Vice President's Town Meeting at EPA indicate that the
current level of oversight is adversely affecting the contracting
process. Employee fears of making mistakes and fear of
disciplinary (including criminal) actions, are alleged to be
causing delays in the contracts, management process. Employees
believe that these effects are documented because of the time now
required for contracts and grants to be awarded and for work
assignments to be issued.
Those who advocate reduced oversight are often criticized
for trying to escape accountability. The impact of reduced
oversight may have the opposite effect, and current management
trends (supported by research and data) indicate that empowered,
trusted employees accept greater responsibility and
accountability. There are internal control systems within the
government (e.g., FMFIA) which, if staffed and operated
effectively, should provide redundancy to external oversight
groups, such as GAO.
Example - Internal Management Oversight. A third example of
oversight is within EPA. There are multiple reviews, changes,
reviews of the field units, and there are always numerous changes
in the preparation of senior management briefing papers, reports
and draft regulations. One way of dealing with excessive
internal oversight is to flatten the organization A primary
recommendation of the Workforce Capacity Team is to "flatten
management hierarchy." This was echoed in several reports and by
EPA employee suggestions to the internal NPR teams.
Example - Cross-Program Oversight. The final example of
what may be defined as oversight, is within EPA and across
Program Offices. This occurs when EPA staff from different
offices review draft regulations and reports through EPA work
groups. This results in an oversight that promotes duplication
of effort, rework and "second guessing." EPA must be able to
calculate the added value of this oversight, and determine
whether the time invested is worth the return.
3. QUALITY
Quality is a concept that appears in team reports, and it is
also one of the major motivators behind the EPA internal NPR
effort. TQM is not an end, an objective, or a goal it is a
way of conducting business. It is a tool that assumes a
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consultative and participative culture. This overall finding by
the EPA's internal NPR teams is consistent with the President's
strategy on "Reinventing Government" to make government work
better and cost less.
An Agency commitment to TQM will require a cultural change
and re-evaluation of priorities. Senior leadership must provide
the vision, and employees must strive to share in achieving the
vision and the values it holds.
The Quality Science Team recommends that EPA focus on
quality, not quantity. Both the Quality Science and Workforce
Capacity Teams independently identified impediments to quality at
EPA, and they have suggested improvement ideas. Quality is
greatly hindered by what has been described as EPA's "balkanized"
structure and by EPA's reliance on contractors.
Improving the basis for Agency decisions means the science-
policy interface needs to be better addressed. Scientists and
policy-makers need to understand each other's positions, needs,
and expectations. The affected parties must be integrated into
the regulatory development process at an early stage.
Delivering a quality product a safe and healthful
environment at a reasonable cost to the American people will
require the retention and development of a highly qualified
staff. Team reports addressing human resources issues identified
a number of very important recommendations that must be seriously
considered.
VI. Lessons Learned/Process Improvements
Throughout EPA's internal NPR process, several lessons were
learned, and a number of process improvements flow from these
lessons. These suggestions assume that the NPR process will
endure at EPA. It is important to note that these observations
apply to the NPR process rather than the content of the reports.
A. Need for Management Support and Understanding
One of the principal lessons learned from EPA's internal NPR
experience is that political and career managers must demonstrate
commitment to the concept of reinventing government and middle
managers must share in that commitment. All senior managers must
have a thorough understanding of the process and how the
workforce is to be used in new ways during the process.
Commitment to the NPR process starts at the top, and senior
management must assure that the importance of reinvention is
communicated to the entire workforce. It must be made clear that
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reinvention is a top Agency priority, and achievement of this
goal must involve all EPA employees.
B. Need to Identify and Prioritize Outcomes
Most of EPA's internal NPR team reports were written without
reference to the relative importance of individual reinvention
ideas or with guidance for strategically linking the ideas. The
implementation process was started when the Administrator formed
an implementation task force, co-chaired by the Deputy
Administrator and the Leadership Team chairperson. The roles of
the task force will be to prioritize the ideas from team reports
and to develop an implementation plan for these ideas. This
prioritization and implementation plan should include
consideration of the proposed reinvention laboratories which have
been received.
C. Need to Identify Disinvestment Opportunities
The VP's goal for the NPR was to "make government work
better and cost less." A common characteristic of the team
reports is the conviction that each proposed initiative is a
panacea for the Agency's problems. It is not surprising that
most teams did not calculate the costs associated with
implementing their proposals. Similarly, the teams rarely
identified opportunities for disinvestment to counteract proposed
investments as part of their initiatives.
The implementation task force will be obligated to perform
cost analyses to determine which proposals to accept and
activate, and which to defer or reject. Many proposals require
initial start-up costs but may ultimately result in substantial
savings to the government (e.g., avoiding duplication of
oversight). Some proposals are essentially revenue neutral and
simply represent an innovative way of doing business (e.g.,
restructuring.) Future reinvention exercises should require a
more rigorous identification of opportunities for disinvestment,
as well as the costs of proposed initiatives. This omission in
the current process is mostly due to the limited time available
to undertake and complete the NPR effort.
D. Need for Adequate Time
Several Policy/Process teams were already operational when
EPA began its internal NPR effort, but most teams were formed in
May. For logistical and other reasons, some of the new teams
were unable to begin the work immediately. In some instances,
time constraints precluded new and in depth consideration of
every possible barrier. The analysis performed by the different
teams varied with the availability of, and
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access to, relevant information. Future reinvention endeavors
should allocate adequate time to fully develop and analyze the
ideas generated.
VII. Conclusions
Through discussions with team members and observations of
the process, the EPA's internal NPR Leadership Team concludes
that the initial EPA NPR effort was a good experience and a
successful beginning. Employees within and across the Agency
have started thinking and communicating differently. However,
the process can backfire if employees do not see concrete,
follow-up actions in a timely manner.
Although individuals brought different perspectives to
issues and problems, it was relatively easy to agree on our
"desired state" and what we believe must happen within EPA in
order to succeed. We should strive to:
be an organization that welcomes change; be comprised
of people that are flexible;
be an organization that is quick to respond to new
challenges and knowledge;
be comprised of people that think holistically (e.g.,
to better address ecosystem and health protection);
form effective partnerships with states, industry, and
the public, all of whom share a common goal;
nurture ourselves and each other - invest in ourselves;
have trust present in all areas at all levels (e.g.,
EPA must regain the public trust; have no turf among
organizational units).
EPA was founded by people who care about the public. EPA
employees are driven by the desire to be of service to people and
the desire to protect the World's natural resources. Such
commitment is evidenced by the level and quality of participation
in the EPA NPR process. As a group, the workforce wants to do
well and wants the Agency to succeed. In many ways, EPA is
succeeding, but continual improvement must always its goal. EPA
must find ways to harness and focus the energy of its employees
and to develop a high performance organization and teams at EPA.
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REPORT OF THE
AWARDS/RECOGNITION
TEAM
NATIONAL
PERFORMANCE
REVIEW
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A/R 1
EXECUTIVE SUMMARY
In compiling this report on the EPA Awards and Suggestion
Programs, the National Performance Review (NPR) Team studied
previous reports on the same subject. One such report, "An
Inquiry into the Effectiveness of the EPA Awards Program," was
completed in 1992 by a Quality Action Team (QAT) composed of
employees at all organizational levels and representing
thirteen different program offices, including a Regional and
Laboratory office. This Final Report is an adaptation the
work of that group.
The purpose of the EPA Awards Program is to motivate and
reward employees. Focus groups and a nationwide survey showed
widespread dissatisfaction with some aspects of EPA's Awards
Program, centering on the issue of fairness. There is a
perception that important work which does not have high
visibility is not properly recognized, that employees in
support/technical positions are slighted, that favoritism
influences awards, and that managers receive too many awards.
However, employees believe there is much that is good about
the program. This was especially evident in the focus groups
where participants could speak at length and share ideas.
Most feel that much can be done to improve the program.
Eleven recommendations address the perceived deficiencies in
the Awards Program.
EPA's Suggestion Program is seen as generally inactive
and ineffective. Efforts to revitalize it over the years have
been unsuccessful. A "Two-Pronged Solution" is suggested:
1. REVAMP THE EXISTING PROGRAM. Three factors severely
limit the effectiveness of the existing program: 1)
suggestions about employees' current jobs are not
allowed; 2) there is no money set aside for the
program; and 3) there is competition from other
awards, such as time-off and on-the-spot. Six
recommendations, most notably adequate funding,
address the deficiencies,
2. CREATE A NEW SUGGESTION PROGRAM. The study,
including benchmarking with other organizations,
recommends supplementing the OPM-mandated Suggestion
Program with a new program more responsive to EPA
employees' needs. Several recommendations are made
for the new program, including allowing suggestions
about employees' current jobs, and simplifying the
entire process.
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VISION - Awards Program
EPA employees show widespread dissatisfaction with some
aspects of the EPA Awards Program, but few would do away with
it and many have suggested changes to improve it. These ideas
can build an Awards program that motivates and rewards
employees.
Findings and Recommendations
Overall, 61% of employees think the Awards Program
is unfair. Among non-whites it is 73%.
**** i. important work of excellent quality/ that does
not have high visibility and is not "hot11 or
"glitzy," should receive much more recognition
than it does now.
73% of the Survey respondents felt this way. In
Labs it was 83%. The Focus Groups showed this even
more emphatically; participants in all groups, some
with strong feeling, spoke about this neglect of
good behind-the-scenes work. No one spoke against
this recommendation, although one or two supervisors
said such work could be rewarded at performance
evaluation time.
**** 2. Employees in assistant/technician positions should
receive more recognition than they do now.
62% overall think this group receives too few
awards. 79% of those in grade 10/below feel that
way, as do 69% of non-whites, and 67% of females.
The smallest majority for any group was 59%. There
is a general feeling among employees, and not just
among assistants and technicians, that employees in
these positions are left out or slighted. The
Survey data is consistent with and reinforced by the
Focus Group findings.
3. Employees in administrative support/clerical
positions should receive more recognition than they
do now.
57% overall think this group receives too few
awards. 84% below grade 10 agree, as do 64% of
females and 63% of non-whites. The smallest
majority was 55%. Focus group survey data
reinforced these findings.
*** 4. The results of Awards Program should be made public
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and readily available to interested employees. It
should include the number of awards by category and
organization, the amounts of the awards, grades of
recipients, and other relevant data. It should not
include identities of individuals.
This recommendation partially addresses the concern
of many employees about the fairness of the program.
71% overall think there should be an Agency group to
monitor equity in the Awards Program. Among non-
whites it is 90%, and for grade 10/below. 84%.
Clearly, there is much concern. In the Focus
Groups, things were not so clear cut - employees,
though acknowledging the problem, were not much in
favor of creating another layer of bureaucracy.
Several employees made suggestions similar to the
above recommendation.
This recommendation would also help address another
expressed employee concern: that managers receive
too many awards for too much money. (This sentiment
was very strong in non-supervisory Focus Groups; it
did not exist in supervisory groups.) One item on
the Survey asked which categories of employees
receive too many awards. 103 employees responded,
and 66 (64%) wrote in some form of management. (This
was not one of the check-off choices and had to be
written in.)
If implemented, the recommendation would also
address the concern of some about the secrecy of the
process. It would put everything in plain view.
Overall, 71% of employees believe the Awards Program
fails to motivate employees to be the best they can
be. in the labs it is 80%.
*** 5. Each Lab, Region, and Program Office or Assistant
Administrator should maintain its own Awards Cash
Pool. The amount that each organization sets aside
should be made open to comparison.
This was the most lopsided response in the Survey.
85% overall wanted the Pool, and every subgroup was
heavily in favor of it. The Focus Groups were also
for it, although not so heavily.
Money is a good indicator or organizational
priorities. Publicizing award pools would help to
eliminate disparities.
*** 6. Whenever possible employees should be allowed
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A/R 4
to choose the type of award, e.g., cash vs.
time off.
76% overall were in favor of choice. 89% in grade
10/below, and 88% of non-whites like this option.
The smallest majority was 75%. The Focus Groups
were very much in favor of it. Most supervisors,
while believing that employees should be consulted
about their preferences, think the final decision
should rest with management.
** 7. Peer awards and employee nominations of supervisors
for awards should continue, but care should be
exercised.
66% overall are in favor of peer awards; 91% of non-
whites and 64% of whites. 76% overall are in favor
of employees nominating supervisors for awards; 85%
for grade 10/below. Focus Groups pointed out that
awards like those already exist in some offices.
Employees were worried about such things as
collusion "you scratch my back, I'll scratch
yours." Several said such awards can be very
useful, but they should be for relatively small
amounts to avoid pressure, collusion, and other
complications. In the offices where such awards
exist, the dollar amounts are small. In fact, the
award does not necessarily have to be cash.
*** 8. The process for nomination and award should be made
as simple and straightforward as possible.
In the Focus Groups supervisors, especially,
complained about the time it takes to write up award
nominations, the time of the year that they are due,
etc. Both employees and supervisors know that
whether one gets an award often depends as much on
the knowledge and skill of the nominator as on the
work of the nominee. Something needs to be done
about this.
Other concerns of employees regarding giving of
awards for process rather than results, lack of
awareness of all aspects of the Awards Program, and
possible differences in concerns in different
components of the Agency
** 9. Great caution should be exercised in giving awards
just for practicing the principles of Total Quality
Management (TQM) in one's work.
Only about 25% of employees believe that the Awards
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A/R 5
Program rewards and encourages those who practice
TQM in their work. In the Focus Groups the feeling
was very strong that there should not be recognition
just for practicing TQM. Emphasis should be on
results, not process. Some negativity and hostility
is directed at TQM. A few did say that since TQM is
a "hot" topic, those involved with it are more
likely to get awards. Others pointed out that if
the Agency wants to encourage TQM, its practice must
be rewarded. This recommendation addresses these
various issues.
** 10. EPA should launch a comprehensive, long-term effort
to educate all employees about the Awards Program.
It should include the kinds of awards, criteria for
awards, processes for nomination, tips on how to
write the nomination, etc.
This strong recommendation came mainly from Focus
Group employees and supervisors who said they knew
too little about various awards to apply for them or
nominate others. Nearly all said they needed to
know more. Each group had people who were unaware
of some of the awards discussed.
** 11. Further studies should be considered in components
of the Agency.
The data indicates variation in awards practices
among organizations and locations. Laboratory
employees seem to be especially dissatisfied with
the Awards Program; particularly about recognizing
low visibility work and the work of assistants and
technicians. This level of dissatisfaction in the
Labs points to a need for further study. This may
also be true for other locations or Agency
components.
VISION - Suggestion Program
EPA's Suggestion Program should be active and effective.
In FY 1991, 102 suggestions were received Agency-wide, 19 were
adopted and $8,110 was paid to the successful suggesters.
Efforts to revitalize it over the years have been
unsuccessful. We can and should do better, and envision a
"Two-Pronged Solution" to: 1) Revamp the existing suggestion
program; and 2) Establish new programs at the AA/RA/LD levels.
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Findings and Recommendation
The existing OPM-mandated program is limited by three
factors: First, suggestions about employees' current
jobs are not allowed. Second, there is no money set
aside for the program. Finally, there is competition
from other awards, such as time off and on-the-spot.
Implementation of the following suggestions will improve
the existing Suggestion Program:
** 1. Make $100,000 available annually for the
program.
As it stands now, the office which adopts a
suggestion has to pay any award to the suggester - a
strong disincentive to adopt the suggestion.
** 2. The program should be actively and continuously
publicized, and it should receive support from
the highest levels of the Agency.
* 3. The national program office should maintain and
publicize a master status list of suggestions
including all relevant data.
* 4. Evaluators should be recognized by some non-
monetary token when suggestions are adopted.
* 5. There should be a Review Board for suggestions
having an Agency-wide impact.
* 6. Other recommendations: a) include a tear-off on
the suggestion form so suggestions can be
acknowledged immediately; b) have a contest to
come up with a new name for the program; c)
design attractive boxes and display them
prominently.
After much study, including bench marking with
several organizations, the QAT concluded that the
OPM program should be supplemented by an entirely
new program, more responsive to EPA employees'
needs, more aligned with the principles of TQM, and
which avoids major problems with the existing
program. Implementation of the following
recommendations will get the new suggestion program
up and running:
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A/R 7
*** 1. Delegate to each AA/RA/LD the authority to
create an improvement award system (they can
pick the name) within their organizations, with
the option of redelegating the program to a
lower level.
**** 2. Consider all suggestions whether or not they
fall within the scope of the suggester's
current duties.
*** 3. Give "winners" the choice of cash or time-off
awards whenever feasible
*** 4. Keep the program very simple, with a minimum of
paperwork.
* 5. Send top improvement ideas from each AA/RA/LD
to a Selection Board each year.
The Board will select the top 1-3 from the entire
Agency. These would be recognized at the Annual
Awards Ceremony and would receive an additional,
appreciable cash award, funded from the Suggestion
Program pool.
CONCLUSION
We believe that EPA's Awards Program can become a
model for the Federal government. The
recommendations, while likely causing some
organizational discomfort, are not difficult or
costly to implement. Employees will be pleased to
see tangible results of their participation, the EPA
Awards Program will be perceived in a more favorable
light, and EPA will be an even better place to work.
As the recommendations for the dual Suggestion
Program are implemented, EPA's existing Suggestion
Program will be improved by adequate funding,
increased organizational support, publicity, and
process streamlining. The New Program will
revitalize the employee suggestion concept by making
it more relevant, placing it closer to suggesters,
providing options in awards and minimizing
paperwork.
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Attachment
TEAM MEMBERS ~
OF THE EPA AWARDS AND SUGGESTIONS PROGRAM QAT
Diane Bazzle, OA
Michael Binder, OIG
Sandy Bowman, Cincinnati
Ron Blakely, OCR
Amy Brooks-Jones, OSWER
Thorne Chambers, OHRM, Chairman
Roger Connor, OHRM
Margie Fehrenbach, OPTS
Jacque' Hawkins, OGC
Yvette Hellyer, OPTS
Portia Johnson, OARM
Pat Miller, OE
Pam Parker, OHRM
Edna Rodriguez, OHRM
Laurel Seneca, Region I
Sherri Sheppard, OPPTS
Robert Stevens, OHRM
Donna Thomas, ORD
OTHERS WHO HELPED
Linda Adams, Region 8
Randy Brady, RTP
Richard Brown, OHRM
Dave Eisner, OHRM
Joe Sullivan, OHRM
Sylvia Dodge, OARM
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REPORT OF THE
ECOSYSTEMS
TEAM
NATIONAL
PERFORMANCE
REVIEW
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The Ecosystem Protection Paper was prepared by members of
the NPR Ecosystem Protection Team with input from other EPA
staff. This paper resulted from review of previous documents
on ecosystem protection, several day-long meetings, soliciting
ideas from colleagues and other experts, and reviewing EPA
staff suggestions. Issues raised, background information, and
recommendations were all developed by the Team. Three writing
groups were set-up to prepare the paper. Peer review
consisted of individual comments from offices of the Team
members, other EPA staff, and the Senior Leadership Council.
ECOSYSTEM PROTECTION TEAM MEMBERS
Team Leaders:
Maurice LeFranc
Jim Serfis
Team Members:
Rochelle Araujo
Vicoria Atwell
Cory Berish
Fred Chanania
Pete Fontaine
Steve Glomb
Susan Gordon
Chris Grundler
Kathy Gunn
Jacgues Kapuscinski
Thomas Kelsh
Renee Lamb
Laura Lopez
Suzanne Marcy
Menchu Martinez
Ossi Meyn
Doug Norton
Sue Norton
Randy Pomponio
Michael Rexrode
Bob Springer
Ann Stephanos
Leila Yim Surratt
Betsy Tarn
Molly Whitworth
Gaylene Vasaturo
Office of Policy, Planning and Evaluation
Office of Federal Activities
Office of Research and Development, Athens
Office of Air and Radiation, RTP
Region 4
Office of Solid Waste
Office of Enforcement
Office of Water
Region 7
Great Lakes Program, Region 5
Region 5
Office of Administration and Resources
Management
Office of Water
Office of Prevention, Pesticides and Toxic
Substances
Office of Solid Waste
Office of Water
Office of Water
Office of Prevention, Pesticides and Toxic
Substances
Office of Water
Office of Research and Development
Region 3
Office of Prevention, Pesticides and Toxic
Substances
Region 5
Office of Prevention, Pesticides and Toxic
Substances
Region 6
Office of Water
Office of Policy, Planning and Evaluation
Office of General Counsel
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EXECUTIVE SUMMARY
Ecosystem protection is often seen as a goal which is in
conflict with other societal and economic values and
interests. There is increasing recognition, however, that
economic stability is in fact interrelated with healthy,
functioning ecosystems. Many sectors of our society are
directly and indirectly affected by past and present ecosystem
degradation. The Florida Everglades and the Chesapeake Bay
are both examples showing how the cumulative effects of human
activity can destroy the inherent capacity of natural systems
to sustain themselves, leading to significant economic
dislocation. The unabated destruction of these natural
systems, which sustain us today and our children tomorrow,
must be halted. A national effort is needed to promote
balanced and sustainable uses of our natural resources. To
fulfill its obligation to, and role in, this effort the
federal government and the EPA must change the way in which
they function.
First, a broad national vision for change is needed. The
federal government must focus this vision by creating and
implementing a cohesive and comprehensive national policy on
ecosystem protection. To reduce the fragmentation and
inconsistency which rendered ineffectual prior ecosystem and
natural resource management efforts, the Executive Branch
should: (1) develop a national ecosystem management policy
which is implemented jointly by the appropriate federal
agencies pursuant to an executive order; (2) develop and
implement coordinated ecosystem protection initiatives among
federal, state, and local governments, such as inventories.
resource assessments, joint budget proposals; and. (3)
eliminate gaps and inconsistencies in existing laws and pass
new laws such as establishing a "Green Bank Program." and
other programs.
Second, EPA should be a catalyst to the national vision
for change by establishing and disseminating a set of
organizing principles for ecosystem protection that can be
used by federal, state, and local governments, citizens and
other organizations. EPA should also implement structural
changes through an ecosystem protection policy issued by the
Administrator which establishes ecosystem task forces and
ecosystem plans, and institutionalizes ecosystem management
principles. EPA should make better use of its existing tools
by: (1) amending guidances and regulations to promote
ecosystem protection; (2) improving the implementation of the
National Environmental Policy Act and the Endangered Species
Act; (3) more fully utilizing grants, education, and
nonregulatory programs such as ecosystem training and
educating the public; and (5) improving the ecological science
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base and sharing data. Further, the Agency should practice
ecosystem protection through geographic enforcement
initiatives and regional landscape initiatives, while
promoting ecosystem protection to others through coordinated
grants and using anticipatory planning.
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VISION
The United States will develop and implement a national policy
to protect the sustainability of the natural systems which
provide economic prosperity and a high standard of living for
the American people. The Environmental Protection Agency will
play an important role in developing and implementing this
policy by providing leadership, by promoting the sustainable
use of our natural resources, and thereby protecting our
natural heritage for present and future generations.
INTRODUCTION
Ecosystems the complex of living and non-living
components that function together as a unit in a given area
such as wetland communities, estuaries and prairies form
the core organizational structures of the natural world.
Ecosystems have a degree of inherent stability which helps
them to resist some disruption. Significant man-made
stressors, however, such as over-grazing, unbridled commercial
and residential development, over-population, pollution and a
host of others, can alter ecosystems, affecting their ability
to sustain life, including human life. The quality of life
for humans is thus linked inextricably to the sustainability
of ecosystems.
Ecosystem sustainability can be defined in a variety of
contexts. For purposes of this document, it is the concept
that humankind's interaction with the environment should
strike a balance between the need to: (1) use natural
resources to maintain a good standard of living; (2) prevent
the destruction of natural resources; and, (3) accommodate
future uses by subsequent generations.
Sustaining the ecosystems that comprise our natural world
will require us to shift to a more holistic and coordinated
approach to environmental protection one which recognizes
that protecting human interests ultimately requires us to
protect the natural systems upon which we depend for survival.
Only in this manner will our efforts begin to match the
interrelatedness that is the defining characteristic of
ecosystems themselves. Recognition of this interrelatedness
should be the first step toward reinventing our governmental
and societal approach to ensure the protection and
sustainability of ecosystems and natural resources.
The Executive and Legislative branches must undertake
specific and coordinated actions in order to overcome existing
barriers to ecosystem protection, which are both numerous and
fundamental. A national ecosystem management strategy should
be based on: (1) cooperative interagency institutional
structures and public support; (2) sound scientific principles
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EP 5
and research; (3) ecological rather than political boundaries;
(4) resolving conflicting agency missions and statutory
mandates; and, (5) addressing connections between social,
political, and environmental concerns.
EPA should be a catalyst for Executive Branch leadership
by developing ecosystem protection principles, by working to
integrate federal actions, and by establishing ecosystem
protection partnerships with state and local governments and
private entities. EPA must also enact internal changes to
integrate principles of ecosystem management at every level
and in all functions of the Agency. Agency planning,
decision-making, and actions must be guided by the underlying
principles of ecosystem management and protection, such as
sustainability.
Ultimately, through "environmental protection" statutes,
the EPA protects the various attributes of ecosystemsfor
example, clean air and clean water. An ecosystem, however, is
more than a simple sum of its parts. Disruptions to one part
of an ecosystem ripple throughout the whole ecosystem,
sometimes in unpredictable ways. Thus, government
intervention to address one component of the system will not
effectively protect the entire system.
Although existing environmental statutes require in
varying degrees that EPA consider the impacts on the entire
environment in the development of standards, most standards
are based primarily on human health impacts. Moreover, to the
extent that environmental impacts are considered in standard
development, such assessments are generally confined solely to
those impacts which are of immediate concern to the program
office developing the standard. Regulatory standards
therefore often fail to consider cross-media impacts that can
impair ecosystem viability, such as heavy metal air deposition
into water bodies, or contaminated sediment resuspension.
Although changes must occur within governmental
institutions and at different levels of society, they must be
phased over a period of time in a coherent and integrated
approach. This paper presents a national strategy for
ecosystem protection and EPA's role in ecosystem protection.
Specific timeframes for implementing the recommendations
contained in this document vary depending on their complexity
and scope, and on the differing capacities of governments and
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society to change. Also, several key aspects of this
integrated approach need to be highlighted at the outset to
emphasize central themes that infuse many of the
recommendations contained in this document.
First, a stronger link between science and policy is
stressed in many of the recommended actions. The concept of
ecosystem sustainability involves many areas of policy, for
example economics and land-use planning. In approaching
environmental protection from the ecosystem standpoint,
however, the government, and EPA in particular, needs to
ensure that sound science is available and part of the
ultimate decision-making process. Second, more than any other
form of environmental protection, achieving ecosystem
sustainability will involve partnerships between all levels of
government and its citizenry. The need to arm governments
and citizens with information and education is paramount to
achieving the goals set forth herein.
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I. A NATIONAL STRATEGY FOR ECOSYSTEM MANAGEMENT
In order to manage, protect and restore our vital natural
resources and ecosystems, the United States needs to develop a
national strategy for ecosystem management. Past efforts to
protect the environment and to manage natural resources have
been fragmented, often working at cross purposes. Most of the
man-made and natural problems that have led to degradation and
loss of ecosystems are still present. Policies and programs
of federal, state, and local agencies, as well as private
organizations have in some cases resulted in degradation of
our ecosystems and component natural resources. The President
and Executive Branch should provide leadership by setting
forth this national policy that establishes a means for
protecting ecosystems and directs federal agencies to
coordinate and collaborate to implement this national policy.
Target/Action Category: A national policy should be
established through Executive Branch leadership for the
protection of ecosystems based on the principles of
sustainable use. This policy should be applicable to all
federal agencies responsible for protecting the environment,
managing natural resources, and infrastructure development.
Initiatives:
Coordinated Approach to Ecosystem Management.
Coordinated approaches to ecosystem management are
necessary for federal agencies to have a common
understanding of the ecosystems for which they are
charged to protect and manage. The Office on
Environmental Policy (OEP) should organize a series of
"sustainable ecosystem summits" comprised of agency
representatives, academics and stakeholders to establish
this operational government definition and to set common
goals for ecosystem management.
Better Use of the NEPA Process: The President should
direct agencies to more effectively implement the NEPA
process to plan, coordinate, and integrate other
environmental statutes for ecosystem protection. The
NEPA process can serve to coordinate consideration of the
substantive requirements of other environmental statutes,
and can serve as a tool by which agencies can consider
overall ecosystem-related issues. NEPA also requires a
broad examination of environmental impacts not
necessarily addressed by media-specific laws, and it is
this integrated assessment that is particularly well
suited to address ecosystem management.
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Executive Order: The President should issue an Executive
Order that establishes a national policy for ecosystem
management and establishes a process for interagency
cooperation. This policy should set goals for ecosystem
management such as viable populations, sustainable use,
and maintenance of biodiversity.
Target/Action Category: All federal agencies should establish
and incorporate ecosystem protection goals at all levels of
activity.
Initiatives:
Regulatory Coordination: Federal agencies should
coordinate the implementation and enforcement of
environmental laws with a view toward achieving
protection at the ecosystem level. Federal agencies will
also need to identify barriers to full implementation of
ecosystem protection, and identify statutory mandates and
policies which conflict with the national policy of
ecosystem protection.
Impacts of Federal Subsidies: Federal agencies should
assess impacts of federal subsidies, and where
appropriate modify them to ensure ecosystem protection
(e.g., grazing fees, mining, timber, agricultural water-
use commodities).
Budgets Based on Ecosystem Priorities: The Executive
Branch should submit a re-structured budget that is fully
consistent with the interagency coordination and research
needed for ecosystem protection.
Target/Action Category: A federal policy should be developed
that accounts for ecological values equally with economic
values.
Initiatives:
Developing Measures of Ecological and Economic Value:
The Executive Branch should form a national task force
comprised of ecologists, social scientists and
economists, to develop measures which reflect the true
value of ecological resources both in ecological and
economic terms.
Revising GDP indices: The Executive Branch should direct
OMB and the Council of Economic Advisors (CEA) to work
with all federal agencies to review existing natural
resource accounting methods and to revise GDP indices and
other economic measures to include the loss of natural
resources through exploitation.
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Executive Order 12291: The Executive Branch should
revise Executive Order 12291 requiring cost-benefit
analyses to reflect all societal and ecological costs and
benefits over the long term (e.g., 100 years), including
non-market values.
Target/Action Category: The United States should ensure that
national policies take into account protecting global
ecosystems.
Initiatives:
International Ecosystem Management: Natural resource and
environmental agencies, particularly EPA, USDI, and NOAA,
should join with U.S. Agency on International Development
to develop a joint strategy (and accompanying budget
request) for the use of U.S. government expertise to
assist in integrated ecosystem protection in other
countries and in areas beyond national jurisdiction.
This effort would both help the United States to fulfill
its existing international obligations (e.g., Convention
on Biological Diversity, Agenda 21), to suggest future
directions in international policymaking in the ecosystem
protection area, and to provide a useful international
perspective on more effective ecosystem protection
domestically. The Department of State should work
closely with the agencies involved in this effort to
promote innovative ecosystem management approaches in
cooperation with other countries and in the negotiation
of future international agreements.
Evaluating National Policies/International Obligations:
The Executive Branch should direct federal agencies to
evaluate national policies on environmental protection
and resource management in light of international
policies and obligations, and to amend national policies
to more effectively achieve international objectives.
The State Department, USDI, EPA, USFS, NMFS, and other
involved agencies should be directed to further develop
national and international policies related to ecosystem
management. In addition, the U.S. should develop human
population policies that are consistent with sustainable
economies and ecosystems.
Target/Action Category: Federal agencies should work with each
other, as well as state and local governments to use all
available mandates in a cooperative and integrated manner.
Initiatives:
Geographic Initiatives: Interagency work groups should
develop coordinated ecosystem management programs in
specific geographic areas (e.g., ecoregions, watersheds,
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EP 10
physiographic provinces) in which multiple agencies or
multiple-programs are currently operating (e.g., San
Francisco Bay Delta, Gulf of Mexico, Oak Savannah).
Coordinated Budget Submissions: Federal agency budget
proposals should reflect intra-agency and interagency
efforts to coordinate ecosystem protection (e.g., a
specific percentage of budget must be joint submissions
for ecosystem-related activities).
Managing Sustainable Ecosystems: Federal agencies should
convene summits for negotiating change in regional
economics as a means for managing sustainable ecosystems.
Coalitions of stakeholders in an ecosystem should examine
ways in which to accomodate their respective interests
while protecting the ecosystem.
Coordinated Inventory and Resource Assessments:
Agencies with primary responsibilities for biological
inventory, monitoring, and assessment (e.g., NBS, EPA,
EMAP, and USGS) should coordinate resource expenditures
in carrying out these essential but costly functions.
EPA should cooperate with the USDI's National Biological
Survey (NBS) in ecological inventories. EPA should
improve the coordination of monitoring and resource
assessments currently being done by different agencies
(such as the Interagency Task Force on Monitoring).
Target/Action Category: The Administration and Congress
should work together to promote coordinated ecosystem
management efforts.
Initiatives:
Coordinating Legislative Mandates: An OEP-led
interagency task force should identify conflicts and gaps
in pollution control and resource management laws and
present recommendations to Congress for legislative
changes necessary to ensure national laws are consistent
with the national policy for protecting ecosystems. For
example, the task force would recommend federal
legislation that provides agencies with the authority to
anticipate and prevent biodiversity loss.
Directing Appropriations: The Administration and
Congress should work together to direct appropriations so
that ecosystem protection plans are implemented through
coordinated efforts of federal agencies.
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EP 11
Establish "Green Bank": The Executive Branch (e.g., DOJ,
OMB, Treasury, EPA) should work with Congress to develop
appropriate legislation that establishes a "Green Bank
Program," in which permit fees, use fees, and enforcement
penalties collected by federal agencies (e.g., USFS,
USDI, NOAA, NMFS) can be earmarked for ecosystem
protection and restoration.
Congressional Committee Coordination: The Committee on
Congressional Reform should examine opportunities to
coordinate the functions of the various committees that
have jurisdiction over ecosystem management.
Ecosystem Protection Act: An Ecosystem Protection Act
(similar to the Pollution Prevention Act of 1990) should
be developed which requires federal agencies to integrate
ecosystem management principles into their various
functions, including their scientific, regulatory,
permitting, policy, and enforcement activities.
II. EPA'S ROLE IN ECOSYSTEM PROTECTION
EPA has both the legislative authorization and expertise
to play a crucial role in federal ecosystem efforts. Agency
regulations, however, under these existing statutes have not
been developed with full regard to ecosystem protection. As
the regulator of the environment and a sponsor of basic
ecological research, EPA is uniquely situated to expedite the
dynamic two-way exchange of understanding between researchers
and practitioners of ecosystem management, and to assure that
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current knowledge advances the protection of ecosystems.
Success ultimately depends on EPA integrating ecosystem
management at every level and function of the Agency. In
particular, Agency planning and actions should be guided by
underlying principles of ecosystem management and protection,
and effects on ecosystem sustainability should be routinely
weighed in EPA decisions.
Historically, EPA has primarily focused on the protection
of human health with less consideration of the impacts on
ecosystem issues. Congress has developed, in response to
immediate concerns with critical environmental issues (e.g.,
toxic wastes, safe drinking water), media specific
legislation. These actions have been translated into the
organization and decisionmaking of the Agency. In order to
achieve a successful cultural change, senior management must
be fully committed to the underlying principles of ecosystem
protection, provide the necessary training, and make
organizational adjustments as needed. EPA must make ecosystem
protection a primary goal of the Agency, on par with human
health, as recommended by the EPA Science Advisory Board.
Gaps in the science and information base, an insufficient
investment in EPA information management, and inexperience in
new risk assessment methods hinder EPA's progress in ecosystem
management. As the foundation for ecosystem management, EPA
should use a comparative risk-based approach for setting long-
term priorities and making Agency decisions. EPA can improve
the scientific tools for ecosystem protection through its
support of ecological research, environmental monitoring and
assessment, and ecological information management.
EPA is now challenged to successfully integrate its risk-
based methods, science and information base, and its varied
authorities into a cohesive and effective ecosystem management
approach. Outlined below are a series of initiatives,
presented in a temporal seguence, that will build upon on-
going Agency efforts at ecosystem protection. These
initiatives emphasize pollution prevention, multi-media
enforcement, research into the causes and cures of
environmental stress, education, and constituency building -
all to sustain the integrity of our nation's natural resources
and the ecosystems that support them.
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Actions that should be implemented immediately.
Target/Action Category: The Administrator should issue a
policy statement mandating the integration of ecosystem
protection principles into all Agency programs and actions.
Initiatives:
Ecosystem Task Force: An intra-agency task force should
be convened to develop the Agency policy statement and
provide guidance on its implementation. Coordination of
ecosystem protection initiatives and actions would also
be a function of the task force. The task force will be
staffed on a full time basis with representatives from
Headquarters and regional offices. Members of the Senior
Leadership Council would serve as advisors to this task
force.
Incorporating Ecosystem Principles: Each AA and RA should
prepare an ecosystem protection implementation plan as
part of their overall Strategic Plans and Agency
Operating Guidance, with assistance from the Ecosystem
Task Force. Additionally, specific changes to
programmatic and Regional priorities should include:
dedication of portions of the EPA budget specifically to
fund ecosystem protection projects; reorientation of the
STARS system to give credit for ecosystem management
accomplishments; and use of regional/state ecological
status and trends reports in planning and as a means of
holding the Agency accountable for ecosystem protection.
Ecosystem management principles should be incorporated
into Agency operations such as performance standards,
training for management and staff, performance awards,
and Agency hiring.
Comprehensive Evaluation of Opportunities for Ecosystem
Protection: To better utilize existing authorities, EPA
should undertake a comprehensive evaluation of each
program, to determine whether each fulfills its potential
in ecosystem protection. Moreover, EPA should promote
more explicit ecosystem protection mandates in the
reauthorization of EPA's statutes, where applicable, and
in any new environmental legislation. In conducting a
review of its authorities, each office should identify
opportunities for ecosystem protection and barriers that
may interfere. Subsequently, program offices should
determine priorities for action to overcome the barriers
and explore new opportunities. One example is including
ecosystem values in the cost/benefit analysis during the
regulatory process (e.g., regulation of chemical
substances under Section 6 of TSCA).
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Implementing Ecosystem Management in Program Activities:
Each program office should amend existing regulations and
guidance as appropriate to allow for and promote
ecosystem protection. For example, the Superfund program
could institutionalize ecological risk assessment by
revising the Remedial Investigation/Feasibility Study
Guidance to integrate ecological and human health risks.
In addition, each program office should integrate
regulatory authorities (e.g., permitting decisions) into
resource planning initiatives (e.g., Watershed Protection
Approach, Wetlands Advance Identification) where
appropriate.
Barriers:
1. lack of knowledge regarding ecosystem issues
2. ecosystem level data is unavailable or difficult to
access
3. resistance to organizational change
4. lack or senior management support
Measures of Success:
1. track specific ecological functions/values for
improvement
2. substantive change in organizational structure, and
cross-program initiatives
Actions that should be completed in the
next 6 to12 months.
Target/Action Category: The Agency should focus its
regulatory efforts as a means to protect ecosystems.
Initiatives:
Improved Implementation of the National Environmental
Policy Act (NEPA): NEPA can serve to coordinate
consideration of overall ecosystem-related issues. To
make more effective use of the Agency's NEPA authorities,
the Office of Federal Activities should develop criteria
and guidance to ensure the assessment of cumulative
impacts during NEPA review and require program offices to
support NEPA documentation review to consider ecosystem
impacts. Also, EPA should use Clean Air Act Section 309
authorities to require ecological considerations in NEPA
analyses and reviews of regulations by other Federal
agencies. If EPA programs continue to rely on procedures
deemed to be functionally equivalent to NEPA, they should
still ensure that the goals of NEPA are fully met.
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EP 15
Improved EPA Implementation of Endangered Species Act
(ESA): The ESA is a statutory tool available to the
agency for ecosystem protection, with multimedia and
terrestrial applicability. Each EPA office should fully
comply with the requirements of the ESA. Each program
office should enter into an agreement (e.g., MOU) with
the Fish and Wildlife Service and National Marine
Fisheries Service to clarify EPA's roles and
responsibilities to ensure full compliance with
Endangered Species Act (ESA). Clear guidance for ESA
compliance on a program-by-program level should be
developed and provided to regions and states.
Barriers:
1. lack of knowledge
2. ecosystem level data is unavailable or difficult to
access
3. medium-specific nature of EPA's statutes
Measures of Success:
1. track specific ecological functions/values for
improvement
2. number of ecosystem-based enforcement actions taken
Target/Action Category: The Agency has the opportunity to
focus its enforcement efforts on ecosystem level activities to
more effectively protect human health and the environment.
Initiatives:
Multi-media Enforcement Approach: Given limited
enforcement resources, the Office of Enforcement should
issue a policy statement emphasizing the importance of a
multi-media approach (e.g., air, water, land) in
inspections and, where applicable, enforcement actions.
The Office of Enforcement staff should coordinate with
the program offices to ensure consistency with program
goals through regularly scheduled ecosystem protection
meetings. Moreover, the Office of Enforcement should
provide multi-media training to Regional/State inspectors
and other compliance staff.
Including Ecological Considerations in Enforcement
Actions: The Office of Enforcement should cluster
enforcement actions on a geographic/ecosystem basis to
address the cumulative impact of multiple facilities on
ecosystems. These multi-media enforcement initiatives
would focus on specific ecosystems (e.g., San Francisco
Bay Delta). Ecosystem status and trends on a landscape
basis should be used, with some measure of program-
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EP 16
specific flexibility, to direct compliance inspections
and enforcement activity at those facilities adversely
impacting vulnerable and/or endangered ecosystems. In
addition, opportunities for the restoration, enhancement,
and protection of local ecosystems should be
mandatorily
assessed in every enforcement action undertaken by EPA,
and where appropriate, should be incorporated into all
settlements negotiated by Agency enforcement officials.
Barriers:
1. lack of knowledge
2. ecosystem level data is unavailable or difficult to
access
3. primacy of state enforcement
4. medium-specific nature of EPA's statutes
Measures of Success:
1. track specific ecological functions/values for
improvement
2. number of ecosystem-based enforcement actions taken
3. number of Supplemental Environmental Projects
Target/Action Category: EPA should support state, local and
private activities that lead to ecosystem protection and
restoration.
Initiatives:
Awarding Grants: Each EPA grant program should develop
ecological management and assessment criteria for
awarding grants, where appropriate, to benefit priority
ecosystems. In addition, the Office of Information
Resources Management (OIRM) should develop a network for
grant managers to coordinate grant efforts. For example,
EPA could favor providing funding to farmers, through the
states, who practice Integrated Pest Management. The
Clean Lakes Program could increase the weight of criteria
in ranking applications that place a high priority on
aquatic habitat restoration. The same could be done for
Outstanding Natural Resource Waters.
Increasing the Use of Anticipatory Planning: EPA
regional programs should increase the use of anticipatory
planning approaches (e.g., watershed protection,
comparative risk assessment and ranking, critical
terrestrial systems identification) to protect key
ecosystems and to enhance public awareness and
involvement.
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EP 17
Barriers:
1. lack of information on where and what to protect
2. lack of sense of priorities
3. local political reluctance to do this
4. EPA has little influence over state and local
policies
Measures of Success:
1. number of grants conditioned on ecosystem management
practices implemented by state and local governments
2. improvements in state capacity
Actions that should be completed in the
next 1 to 2 years.
Target/Action category: EPA should continue to support
efforts to determine ecosystem status and trends and to make
information readily available as an effective tool for
decisionmakers.
Initiatives:
Secondary and Cumulative Impacts: Each program and
regional office should assess secondary and cumulative
impacts on ecosystems resulting from individual permit
actions, as appropriate. For example, pesticide risk
assessments should take into account cumulative impacts
of all pesticides used in a given area such as a
watershed.
Coordinating Status and Trends Data: EPA should closely
coordinate with FWS, NOAA, USGS and other federal
agencies on the timing, geographic coverage, and methods
of their environmental monitoring programs to better
document national ecological status and trends.
Specifically, EPA should coordinate data on ecosystem
extent, distribution, and changes, location and abundance
of stressors, and the occurrence of widespread patterns
of ecosystem impairment through its Environmental
Assessment and Monitoring Program (EMAP).
Assessing Ecosystem Values: EPA/ORD should develop
methods for assessing the relative ecological and
economic value of ecosystems that can be applied at the
national, regional or state level. Regions, with
partners, should use these methods to identify a priority
list of areas that are critical to region-wide ecosystem
sustainability.
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EP 18
Improving the Incident Monitoring of Ecosystems: The
Agency should develop an improved system of monitoring
the status and trends of ecosystems. An Incident
Monitoring Program should be established that indicates
the effects of all toxicants that can result in
detrimental effects to the environment (i.e., fishkills,
birdkills, etc.)
National Geographic Information System (GI8): EPA should
strongly endorse the development of a national GIS data
base as a key component of the Vice President's national
information initiative. To date, establishment of a
national GIS infrastructure has not been included in this
initiative.
Barriers:
1. inconsistent data and information among agencies
2. reluctance to develop coordinated efforts for
information exchange
3. ecosystem issues have not traditionally been an
Agency priority in developing information resources
4. reluctance to invest in information collection and
management systems
Measures of Success:
1. greater accessibility of data to agency staff, other
agencies and the public
2. coordinated or at least complementary
data/information systems
3. generation of information on status and trends
Target/Action Category: An informed workforce and educated
public are essential to developing and implementing ecosystem
management initiatives.
Initiatives:
Ecosystem Training: EPA should develop training modules
for EPA management and staff on ecosystem management
principles, including general ecology, underlying Agency
goals, and the fundamentals of ecological risk
assessment.
Ecological Risk Management: EPA/ORD and other EPA
programs should accelerate technical transfer of
ecological risk management principles and methods through
the development of guidance and training courses for EPA
programs and staff, as well as other federal and state
agencies and non-governmental organizations.
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EP 19
Environmental Education: The Office of Environmental
Education (OEE) should evaluate environmental education
curricula and other Agency outreach programs to assess
how well ecosystem values and protection are being
addressed. OEE should also educate the public on how
they can take actions to protect ecosystems. This would
include efforts to reach the state and local land use
decision makers.
In addition, OEE should direct its work within the Agency
to determine each EPA office's projected staffing and
skill mix needs.
Barriers:
1. conflicting priorities
2. education and training are not always priorities
3. reluctance to participate in education/training
programs
4. conflicting priorities
Measures of Success:
1. number of trained EPA staff
2. number of cooperative education efforts
3. number of guidance packages generated
Target/Action Category: EPA should support state/ local and
private activities that lead to ecosystem protection and
restoration.
Initiatives:
Coordinating EPA Programs within the Agricultural
Community: EPA should conduct a state-level pilot
to coordinate all EPA programs affecting a particular
sector of the agricultural community to assist farmers
in complying with these programs (e.g., pesticides, non-
point source pollution, wetlands, groundwater
protection).
Local Geographic Initiatives: Regional comparative
ecological risk analyses should be followed by new, local
scale initiatives that enhance or maintain critical
priority ecosystems. Such initiatives may include,
restoration or rehabilitation of priority areas (or their
critical components as a means of protecting whole
ecosystems), targeted enforcement, and acquisition
programs.
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EP 20
Ecosystem Protection Partnership Project: No single
agency has the resources or expertise to independently
address the threats to the nation's ecosystems. EPA
currently maintains numerous clearinghouses for
technology and information transfer, a number of which
could be consolidated into an ecosystem clearinghouse.
To facilitate information transfer among all agencies and
the formation of inter-agency partnerships for ecosystem
protection at all levels, EPA would promote the wide use
of this resource by locating it on the Internet platform.
The Ecosystem Protection Partnership Project would serve
as a clearinghouse for information transfer as well as
for matching partners with complementary skills,
interests, and funding.
Regional Landscape Planning: EPA can take a number of
actions that would stimulate land use planning by state
and local governments in a constructive manner, and which
would not result in an overly intrusive federal role in
land use planning. EPA should direct grants to states
and local governments to form regional planning units
around ecosystem protection and sustainability values.
EPA should provide technical assistance to the state and
local governments, and will develop a list of suggested
criteria for use by the state and local governments in
their planning decisionmaking.
Barriers:
1. lack of information on where and what to protect
2. lack of sense of priorities
3. local political reluctance to do this
4. EPA has little influence over state and local
policies
Measures of Success:
1. number of grants conditioned on ecosystem management
practices implemented by state and local governments
2. improvements in state capacity
Actions that should be completed within
the next 2 to 4 years.
Target/Action Category: EPA should continue to support
efforts to determine ecosystem status and trends and to make
information readily available as an effective tool for
decisionmakers.
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EP 21
Initiatives:
Consistency and sharing of Data: EPA should continue to
cooperate with USGS, NOAA, and USFWS to develop national,
up-to-date land cover/land use maps and remote sensing
tools and make these data available to all EPA regional
CIS programs and users. The Office of Information
Resources Management (OIRM) should increase its
information exchange with other agencies and
organizations.
Linking Data Networks: OIRM should explore ways to link
all ecological stressor-related information from the
Agency's data bases in a comprehensive network. This
effort could involve developing an inventory of all
facilities which includes references to specific EPA
program data bases. Potential non-point sources may be
included via interpretation of CIS and other data.
Promoting the Sharing of Information : Internet is the
world's largest computer network that stores and provides
access to information on an array of subjects. To
promote information sharing, EPA should be fully
connected to the Internet and put its databases and other
information on Internet. Access to information on the
Internet will aid EPA in its data collection efforts, and
reduce duplication of research efforts. By providing
EPA's data, other federal and state agencies, the
international community, and local groups and communities
will have access to the information. EPA should use its
money from the High Performance Computing Act of 1991 to
fund grants to local groups and communities to enable
them to connect to the Internet.
Addressing Scientific Information Gaps: With funding from
EPA and other sources, the EPA Office of Research and
Development (ORD) should address critical ecological
science gaps as a high priority. These gaps generally
include ecosystem structure and function relationships,
indicators of ecological condition or stress, predictive
methodologies for ecosystem-level response to stress,
techniques for ecological restoration, creation and
enhancement, and spatial and temporal scale issues.
Barriers:
1. inconsistent data and information among agencies
2. reluctance to develop coordinated efforts for
information exchange
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EP 22
3. ecosystem issues have not traditionally been an
Agency priority in developing information resources
4. reluctance to invest in information collection and
management systems
Measures of Success:
1. greater accessibility of data to agency staff, other
agencies and the public
2. coordinated or at least complementary
data/information systems
3. generation of information on status and trends
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EP 23
Potential Reinvention Laboratories
Listed below are several geographic areas that should be
considered as possible reinvention laboratories in which to
test the ecosystem protection recommendations.
1. Ecological risk assessment in an ecosystem/watershed
context: Snake River, Clinch River, Middle Platte River,
Waquoit Bay
2. Emphasis on ecosystem protection in a terrestrial
context: Adirondacks, Greater Yellowstone Ecosystem,
Southern Appalachians
3. Interagency cooperation to determine the effectiveness of
using land cover/land use information (CIS) for ecosystem
level enforcement, pollution prevention, and education:
Savannah River, Pacific Northwest
4. Establish a case study to compare conventional management
criteria (e.g., chemical) to biological/ecological
criteria: Upper Tennessee River
5. Developing a framework, in partnership with others, for
ecological restoration: Oak Savannah, Indiana Dunes
(Lake dunes)
6. Working with its federal partners, EPA will develop a
joint plan on how to recover endangered, threatened, and
candidate species on an ecosystem basis: Clinch River,
South Florida (Florida Bay, Everglades), Southern
California
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EP 24
References
Fischman, R.L. 1992. Biological diversity and environmental
protection: authorities to reduce risk. Environmental Law
22(2) .
Environmental Law Institute. 1992. Nongovernmental
perspectives on EPA's options for protection of habitat.
Unpublished Report. 15 pp.
Environmental Law Institute. 1992. Interagency perspectives on
EPA options for the protection of habitat. Unpublished Report.
8 pp.
Environmental Protection Agency. 1993. Protecting habitats and
ecosystems: an EPA strategy. Environmental Protection Agency,
Habitat Cluster. 23 pp.
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REPORT OF THE
ENVIRONMENTAL JUSTICE
TEAM
NATIONAL
PERFORMANCE
REVIEW
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EJ1
ENVIRONMENTAL JUSTICE
EXECUTIVE SUMMARY
The National Performance Review Environmental Justice Team
believes the Agency has an opportunity to set policy and to
develop an Agency-wide ACTION PLAN to implement and sustain
Environmental Justice throughout EPA. This also allows EPA to
serve as a model for the Federal sector and with our partners in
state/local governments.
CURRENT STATE
The Agency continues to fall short, in spite of making much
progress, in recognizing Environmental Justice as a very critical
and significant issue. EPA must address the disproportionate
impact of environmental pollution on minority and low-income
persons and communities and the risk associated with such
pollution through specific programs and funding mechanisms.
To date, many of the Agency's efforts have been somewhat
disjointed. EPA lacks an effective process to ensure
accountability and to direct and implement a viable environmental
justice focus that ensures Environmental Justice is incorporated
and sustained in the daily work of EPA in all aspects of EPA
programs and activities.
The identification of these eight areas will highlight where EPA,
through the environmental justice focus, must initiate and
continue to address the short and long-term issues affecting
people of color in predominantly low income and rural
communities.
MAJOR RECOMMENDATIONS
TIMELINE INITIATIVE
6 mos The Administrator should immediately empower the
existing Environmental Justice Team or a
reconfiguration of the Team to develop an ACTION PLAN
to address the three major themes: Policy;
Communication/Education; and Data Needs and Uses.
Action on this recommendation will ensure the
following are addressed:
Support and ensure implementation of goals of the
Environmental Justice Executive Order, Environmental
Justice Act and EPA Cabinet Bill. [Administrator]
Appoint/designate one person with the accountability
and authority to oversee the Environmental Justice
issue in the Agency. [Administrator]
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EJ2
Create and provide the resources for one office
reporting directly to the Administrator with overall
responsibility for coordinating all Environmental
Justice issues and activities. [Administrator]
Treat Indian matters as a unigue issue in need of a
well-focused and coordinated effort to ensure
appropriate application of environmental justice laws
and practices. (May reguire a separate ACTION PLAN.)
Establish a government-wide strategy and coordinating
body to ensure incorporation of environmental justice
principles throughout all levels of government.
[Administrator]
Look for opportunities to target compliance and
enforcement actions to protect Native Americans,
minority, and low-income populations to reduce
disproportionate burden of environmental pollution
exposure and risk. [Office of Enforcement]
Through the implementation of these major recommendations and the
identification of barriers, we will be better able to develop and
measure viable actions.
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EJ3
ENVIRONMENTAL JUSTICE VISION STATEMENT
Environmental Justice must be consistently and routinely
integrated into the agency's strategic planning, operational
and policy decisions. This includes, but is not limited to,
decisions in the following areas: rulemaking, permitting,
enforcement, education, hiring, grants, contracts and
outreach efforts.
STRATEGIC POLICY DEVELOPMENT
VISION: Ensure strategic development and implementation of
environmental laws, regulations, and policies to prevent the
disproportionate adverse impact(s) to vulnerable populations.
Apply all civil rights laws to appropriate federal and federally-
delegated environmental activities.
RECOMMENDATIONS FOR INITIATIVES:
TIMELINE INITIATIVE
2-6 mos. Identify major relevant program actions, regulations,
policies
3-12 mos Set draft policy objectives for major actions with
appropriate offices
3-20 mos. Develop workplans for actions which require Fed.
Register or EPA guidance for states, local governments,
or other agencies
BARRIERS:
- Lack of Commitment to address problem
- Commitment to existing cultural mindset
- Absence of accountability
- Political resistance (esp. state & local)
- Lack of Knowledge (awareness/sensitivity)
- Lack of contact/communication with communities
PROJECT RESOURCES:
- Part-time workgroup assignment in policy development and
coordination with other offices (unknown FTE, partial)
- Shifting of some existing priorities, merging with other
existing priorities and program actions, development of
measures and reporting operations, oversight and feedback
(FTE details and shifts)
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EJ4
VALUE/BENEFITS:
- Coordinated strategy, credibility, consistency with risk
priorities, protection of most polluted populations,
consistency in implementation of federal and state programs
- Full/fair implementation of environmental laws
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EJ5
POLICY AND STRATEGY
VISION: EPA will develop a coordinated structure with authority
and resources to implement a comprehensive environmental justice
policy and strategy for the Agency.
RECOMMENDATIONS FOR INITIATIVES:
Reorganize the existing Environmental Equity Office and place
it within the immediate office of the Administrator. This
office should include a Policy Coordination Unit, an Outreach
Unit, and a Native American Coordination Unit. These units
would be charged with the following responsibilities:
A. Policy Coordination Unit
* Coordinates all environmental justices issues and activities
* Serves as liaison for intra- and inter-agency coordination
on environmental justice issues
* Develops and issues policy guidance
* Consults and coordinates with program offices on program
specific environmental justice issues
* Coordinates the implementation of environmental justice
* Identifies environmental justice issues where programs or
offices fail to identify or implement
* Assists in resolving intra- or inter-program office
conflicts
* Coordinates environmental justice policies with other
regulatory bodies
* Reviews the implications of environmental justice on
previous decisions, policies and regulations
B. Outreach Unit
* Outreach and communication with community groups
* Educates the agencies on environmental justice issues
* Provides technical and financial assistance to community
groups and other bodies
* Provides community economic development assistance and
establish pilot projects
C. Native American Coordination Unit
* Specifically deals with the unique Native American and
tribal issues through all activities described above.
Creation of at least one full-time Environmental Justice
Program Manager (EJPM) in each program, regional office, and
laboratory.
* Dedication of new FTEs and/or reallocate existing staff
resources within these organizations.
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EJ6
* Coordinates and monitors environmental justice issues within
each organization by advising organizations' managers
regarding application of environmental justice to daily
activities.
* Serves as liaison to the Agency Environmental Justice Office
by ensuring that existing and future program specific
regulation and policies incorporate the environmental
justice element
Provide ongoing Environmental Justice training for EPA
decision-makers at every level. Recommendations include:
TIMELINE INITIATIVE
2/94 Develop and continually update appropriate definitions
for, understanding of, and training of Environmental
Justice and establish training agenda for EPA decision
makers. (EJ/OARM)
2/94 Incorporate established Environmental Justice training
module into current program specific training
requirement all managers/employees. (OARM)
2/94 Make managers accountable for ensuring training
participation of staff. (OARM)
Provide improved involvement opportunities for affected
communities, which include:
8/93 Establish Environmental Justice review team with
participation from all programs and environmental
justice advocates. (Administrator)
12/94 Review permitting, enforcement and grant procedures
that improve the opportunities for participation of
affected communities. (EJ Team)
12/93 Review levels of decision making to determine need for
diversity to ensure environmental justice
considerations. (EJ/OARM)
6/94 Review and approve changes and timeliness for
incorporating changes into agency procedures. (EJ
Team/Senior Managers)
8/94 Identify opportunities for piloting effectiveness and
success of new procedures. (EJ Team/Senior Managers)
Community involvement at grassroots level is absolutely
imperative to environmental justice activities, credibility,
and acceptance (see Outreach to Grassroots Communities,
Native American Tribes, and US Territories)
EPA develops an Environmental Justice budget sufficient to
successfully implement and sustain this initiative
* line item in the budget
* designated funding for affected community groups to
implement their own Environmental Justice programs (e.g.
community outreach and education)
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EJ7
* allocate sufficient FTE's in all program offices and regions
BARRIERS:
- Lack of management recognition that Environmental Justice
issues are equally as important as the Agency's other
initiatives (i.e., pollution prevention mission)
- Mid-level leadership are not be prepared to accept the
legitimacy of environmental justice concerns
- Media-specific nature of EPA organizational structure tends
to preclude effective coordination across media lines
- Reluctance to re-invest limited resources (or shift under-
utilized staff) to environmental justice activities
- An apparent lack of comprehension of the unique relationship
between the Federal and tribal governments (see discussion on
Indian/Tribal Programs)
- Inadequate external support to allocate more funding for
environmental justice issues
- Lack of accountability for implementing strategies (e.g. lack
of performance management criteria for environmental justice)
- The dynamics of Environmental Justice require anticipatory
and proactive strategies as opposed to reactive crisis
management.
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EJ8
COMMUNICATIONS
VISION: EPA establishes an effective integrated approach to
internal and external communication of environmental justice
issues, uniformly across programs to convey a consistent message.
RECOMMENDATIONS FOR INITIATIVES:
TIMELINE INITIATIVE
Immediate Establish workgroup to conduct analysis and develop
standardized communication protocol (product w/in 1 yr)
lyr Implement protocol agency-wide, work in conjunction
with Equity/Justice office
On-going Provide regular and continuous updates of the protocol
Develop new and creative methods to effectively
communicate with affected communities (i.e. radio
broadcasts, plays, musicals)
BARRIERS:
Internal
- Lack of effective communication of environmental justice
priorities
- Lack of senior management buy-in
- Resources
- Resistance to changing the way we do business
External
- Lack of EPA credibility in community, industry, academia, etc.
- Statutory limitations
- Environmental Justice issues currently are not required under
all statutes
- Political forces
- Conservatively-owned media resisting the message
- Industry's influence on media
- Hardline resistance (Old Boy's Network)
PROJECT RESOURCES:
- Workgroup of approximately 3 FTEs, travel and staff time; 1
year
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EJ9
VALUE/BENEFITS:
- Better informed, involved and empowered communities and other
constituents
- Increased credibility for the agency
- Formal communications vehicle in place
- Consistency of the message
- Motivational sense of mission
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EJ10
EDUCATION, TRAINING AND DEVELOPMENT
VISION: Institute a comprehensive multilingual and multicultural
approach to environmental education, training and development
opportunities relating to environmental justice.
RECOMMENDATIONS FOR INITIATIVES:
EDUCATION:
(Implemented by Outreach Unit of Office of Environmental Equity)
TIMELINE INITIATIVE
1 yr.
1 yr.
6 mos,
6mo-l yr
Current
1 yr.
1-2 yrs.
1 yr.
Require current K - 12 education efforts to include
environmental justice component
Utilize alternative forms of communication (e.g.
Hispanic Radio Network)
Create educational materials to be included as
environmental justice component to environmental
education
Create Speaker's Bureau on environmental justice (may
come under the auspices of the Public Affairs Office)
Adopt-a-school program focus on environmental justice;
encourage and sponsor student research in environmental
justice
Earmark additional grants for community-based
organizations and territories
Expand MOUs/MOAs (Memorandum of Understanding,
Memorandum of Agreement) to more Historically Black
Colleges and Universities (HBCUs), tribal colleges, and
other institutions of higher learning with significant
enrollment of people of color; and include an
environmental justice focus when targeting schools and
developing programs
Expand environmental justice education opportunities to
grassroots communities (e.g., flyers, pamphlets,
community forums, fairs)
TRAINING:
(Implemented by Office of Human Resources Management and EPA
Institute)
(a) Internal
6 mos. New employee orientation package insert
6 mos. Expand sensitivity training course development
1 yr. Develop a module on environmental justice for SES
candidate training
1 yr. Include environmental Justice component in media-
specific training (CERCLA, RCRA)
Current Include environmental justice discussions during senior
management retreats
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EJ11
(6) External
1 yr. Improve community/tribal/territory knowledge of TAGs
(Technical Assistance Grants), develop TAG guidebook,
and make literature on TAGs multi-lingual
6 mos. Initiate and expand presentations on environmental
justice throughout Federal government and other
government agencies (state, local, and Native American
tribes)
DEVELOPMENT:
(responsibility for implementation lies with Office of
Environmental Equity, EPA Education Center, Office of Civil
Rights)
lyr. Enter into joint projects with HUD, Dept. of Commerce,
Dept. of Labor to fund initiatives to develop
technical/career skills in environmental justice
(e.g.,lead, asbestos, PCBs (polychlorinated biphenyls),
recycling, solid waste) for people of color, especially
members of affected communities
lyr. Provide multi-lingual career/technical training
BARRIERS:
- Lack of resources - curricula, training personnel, funding
- Managerial support
- Organization culture
- Lack of and poor use of existing information mediums
- Unclear and inconsistent objectives of environmental justice
within the agency have made producing materials difficult
PROJECT RESOURCES:
- 1 FTE to coordinate speakers bureau (EPA outside, outside
leaders to EPA); outreach to school, churches, tribal
colleges, etc.; modification of EPA education lesson plans to
schools to include environmental justice.
- 1 FTE to modify human resources training, new employee
initiation to include environmental justice, sensitivity
awareness program, media specific training to include
environmental justice
- 1 FTE in public affairs office to initiate dialogue with
other Federal agencies/departments to begin environmental
justice career development plan
- Cost of developing, distributing etc., training materials
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EJ12
- Funding for minority scholarships in environmental justice
topics and student initiated research in this area
- Resources to improve communication methods in affected
communities/territories
VALUE/BENEFITS:
- Greater diversity in environmental justice discussion with
more well-informed citizens of affected communities and
territories
- Less opposition, legal challenges etc., from affected
communities and territories if brought into the policy
discussion early through more equal and free exchange of
information
- EPA gains credibility as a provider of good and useful public
information for affected communities and territories to make
environmental justice decisions and to form opinions
- EPA at forefront of this issue
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EJ13
OUTREACH TO GRASSROOTS COMMUNITIES,
NATIVE AMERICAN TRIBES, AND US TERRITORIES
VISION: Ensure communities have sufficient information,
education, and tools to make informed decisions which affect
their communities. Grassroots communities are included
throughout the process (i.e., from the onset of specific
environmental concern/actions/issues/decisions).
RECOMMENDATIONS FOR INITIATIVES:
(to be carried out by the Office of Environmental Equity and
regional offices)
TIMELINE INITIATIVE
6 mos. Agency commitment to openly communicate with grassroots
organizations and communities
1 yrs. Produce Environmental Justice kit (written and video):
* FOIA (Freedom of Information Act) process/procedures
* Public Advisory Committees
* How to review EISs (Environmental Impact Statement)
* How to organize as a group
* How to obtain financial assistance through public-
private partnerships
* Public comment period information/explanation
* Listing of EPA training classes (to be listed)
1-2 yrs. Ensure that all information is multi-lingual
1-2 yrs. Rely more heavily on alternative methods of
communicating, i.e. Hispanic Radio Network, church,
tribal college visits
On-going Improve community access to EPA data and provide
knowledge of how to use data
On-going Provide routine two-way communication with grassroots
to provide better understanding of EPA's decision
making processes and to seek opportunities for
improving current "ways of doing business."
- Develop and provide appropriate tools to grassroots
communities.
BARRIERS:
- No buy-in" from some parts of government/private industry
- Resource constraints
- Some affected communities and territories are difficult to
access through traditional forms of media
- Lack of internal and external coordination
- Lack of coordination with other Federal Agencies
- Lack of respect for existing grassroots organizations and
sovereign governments
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EJ14
- EPA's lack of credibility with grassroots organizations and
communities
PROJECT RESOURCES:
- 1 FTE to coordinate and develop environmental justice kit.
This effort has begun and should continue in the Office of
Environmental Equity
- 1 FTE whose sole job it is to communicate with affected
communities and territories, respond to inquiries involving
environmental justice. Also involved in the planning of all
EPA conferences and public meetings concerning environmental
justice.
- 1 summer intern to research information to be included in the
environmental justice kit
- Empower current Office of Environmental Equity to better
achieve these goals
- Devote more resources on the regional level to addressing
environmental justice concerns
VALUE/BENEFITS:
- EPA is more accessible to affected communities/territories
- Value of environmental decision-making is greater
- Lessen the mistrust toward Agency
- Help create a more informed and active citizenry
- Better quality of life
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EJ15
INDIAN/TRIBAL PROGRAMS
VISION: Equitable treatment of Tribes through EPA's reaffirmation
of its Indian policy, which recognizes the unique relationship of
the Federal government with Tribes. The policy was written based
on EPA's Congressional delegated authority to work with Tribes
on a government-to-government basis/ with recognition of Tribal
sovereignty and recognition of EPA's trust responsibility.
RECOMMENDATIONS FOR INITIATIVES:
- Develop a detailed action plan for EPA to integrate legal,
policy, personnel, budget, legislative and program
considerations to provide for Tribal environmental equity.
- Provide adequate funding for Tribal Environmental Programs by
including a line item in the Agency's budget. The EPA Tribal
Resources Study Committee, in 1990, recommended an Agency line
item of $37M for Tribal programs.
- Review, reaffirm and implement the 1984 EPA Indian Policy,
which will honor Tribal sovereignty and provide for a
government-to-government relationship and execute EPA's trust
responsibility to Tribes.
- There is a need to increase Indian hiring due to the
under representation of American Indian staff, both in the
Regions and at Headquarters. EPA would have to hire 10 more
Indians in the Regions and 26 at Headquarters to be
commensurate with the 0.052% national labor statistics for
Indians in the work force.
- The Administrator should consider seeking Indian preference
hiring authority from President Clinton, creating special
hiring registers or allocating FTE's for American Indians.
- Create an Office of Associate Administrator for Indian lands or
Assistant Secretary for Indian lands pursuant to Senator
McCain's amendment in the EPA cabinet elevation bill.
- Modify EPA legislation to enable Tribes to have both delegated
program authority and equitable funding.
- The EPA Tribal Lands Environmental Science Scholarship Program
should be included as a line item in the Agency budget at a
funding level of $300K/year.
- Create an EPA/Tribal Operations Committee comparable to the
EPA/State Operations Committee.
- Create an EPA Tribal Clearinghouse to capture lessons learned
by Tribes for technology transfer to other Tribes.
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EJ16
Establish an EPA wide Tribal news letter to notify Tribes
of environmental conferences, funding opportunities and
information on program changes.
- EPA should continue to sponsor bi-annual Tribal
conferences for full discussion of Tribal issues and joint
planning of issue resolution.
BARRIERS:
Lack of support and commitment from top management
Lack of cultural awareness and sensitivity and under
utilization of Indian staff as resource people to provide
needed Indian input in all levels of planning and
implementation.
Lack of interest of hiring American Indians at any level
particularly at the management level. EPA has no strategy to
hire, recruit and retain American Indians, and there has been
no outreach efforts on the part of managers and supervisors.
Some EPA managers and decision makers are still unaware of
the obligation EPA has to Tribes and still believe that EPA
has the option to exclude Tribes.
- Previous EPA Administrators did not direct subordinates to
comply with the EPA Indian Policy and therefore managers were
not responsible or accountable.
There is no mechanism in place to solicit Tribal input on
decisions that have an impact on Tribal people and their
lands. EPA projects a paternalistic attitude toward
Tribes, believing that EPA has the resources, technology
and all of the expertise required.
- Many Tribes lack an EPA environmental infrastructure
acceptable to EPA to manage their own environmental
programs. This is due in part to 23 years of inadequate
funding (no line item in the Agency budget for Indians)
with the Tribe's fair share of the resources being
channeled to the States to assist them in developing their
environmental infrastructures.
Many Tribes lack the resources, monitoring data, technology
and expertise to properly assess the environmental threats
to their people and lands.
PROJECT RESOURCES
- 3 FTE's for 6 months to develop a detailed action plan.
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EJ17
VALUE/BENEFITS:
- The implementation of the above recommendations should move
EPA forward in meeting the goal of environmental equity for
Tribes.
- The position of Native American ombudsman should be created
and the incumbent should report to the Administrator to
insure that the Administrator in informed fully and on a
regular basis of the deficiencies and progress made in the
Indian Program.
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EJ18
GOVERNMENT ROLES
VISION: EPA is recognized champion for Environmental Justice
considerations and that actions are taken at all levels of
government in both domestic and international arenas to resolve
all related Environmental Justice issues.
RECOMMENDATIONS FOR INITIATIVES:
TIMELINE INITIATIVE
Immed. Support and ensure promulgation of an Environmental
Justice Executive Order and Environmental Justice Act
Immed. Develop an overall strategy for the government sector.
The strategy should establish objectives, targets and
initiatives for the major environmental roles of all
government agencies including the government as
manufacturer/generator, policy maker/regulator and
enforcer
Immed. Address tribal issues as a unique entity incorporating
the recommendations from the NPR Environmental Justice
Indian/Tribal Program Subgroup
Immed. Review existing Environmental Justice initiatives and
ensure incorporation in each agency's planning and
budgeting process
Immed. Include Environmental Justice in each agency's
programmatic components in order to build a national
network of strong environmental management. These
should include programs comparable to EPA's State/EPA
Operations Committee, State Capacity Building Task
Force, Local Government Policy Dialogue Advisory
Committee, Small Communities Task Force, Local
Government Roundtable and Tribal Capacity Task Force
10/93 Establish effective EPA policy and utilize it to
require other federal agencies, state and local (tribal
where applicable) agencies to include Environmental
Justice considerations in their programs, activities or
actions that impact human health and environment
11/93 Establish a coordinating council chaired by EPA
including all stakeholders (e.g., HHS, DOI, DOD, DOA,
DOE, FDA, states, tribal and local governments, small
or affected communities, etc.) that will ensure
implementation of Environmental Justice principles
11/93 Ensure that Environmental Justice considerations are
addressed in the international arena and establish a
coordinating council to ensure implementation of
Environmental Justice principles
12/94 Develop partnerships, MOUs and other implementation
mechanisms with federal, state, local (tribal) and
other agencies, domestic and international
organizations to ensure that desired action is taken
On-going Include environmental justice in the regulatory
decision-making processes of each agency (e.g.,
steering committees) to ensure that regional, state,
local (tribal) points of view are heard
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EJ19
On-going Establish outreach and information-sharing efforts
through inter and intra-agency data bases that are
accessible to all stakeholders
BARRIERS:
- Lack of Administration and management recognition, commitment
and support for addressing Environmental Justice in a
comprehensive manner that impacts international, federal,
state, local (tribal) programs and activities.
- Lack of global vision or position relative to developing
countries.
- EPA and other federal agencies are not sufficiently engaged
in the national Environmental Justice dialogue.
PROJECT RESOURCES:
- A minimum of 2 FTEs in each Agency to assure incorporation of
environmental justice and increase the outreach efforts
through partnerships and MOUs with international, federal,
state, local (tribal) agencies.
VALUE/BENEFITS:
- Provides leadership in all agencies and create a national
network of strong environmental management.
- Restores credibility of government agencies with regard to
the issue of Environmental Justice.
- Provides inter- and intra- agency data exchange.
- Establishes measures of success that assures initiatives
achieve the desired impact.
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EJ20
ENFORCEMENT
VISION: EPA, Native American tribal organizations, and the
States should look for opportunities to target compliance and
enforcement action to protect Native American, minority and low-
income populations to reduce any disproportionate burden of
environmental pollution exposure and risk.
CURRENT STATUS: Compliance inspections have traditionally been
targeted by EPA and States through single media (e.g., CAA, CWA)
and without full multi-media consideration of exposure to
pollution by highly exposed or multiply-exposed populations.
In addition, EPA does not comprehensively interpret and enforce
the Civil Rights Act, Native American law and policy, and other
civil rights laws to ensure that EPA and delegated federal
programs are being implemented consistently with civil rights
requirements.
RECOMMENDATIONS FOR INITIATIVES:
TIMELINE INITIATIVE
1-8 mos. Develop environmental justice as an enforcement
priority and incorporate into strategic planning
mechanisms
1-3 mos. Develop Native American lands/federal facilities
enforcement strategy
2-18 mos. Finalize and implement Enforcement Management Council
recommendations for action and enforcement
implementation strategy, identifying resources and data
needs
3-18 mos. Develop data systems and resources to enable
environmental justice considerations to be
more fully integrated into enforcement
3-18 mos. Explore opportunities for, provide resources for, and
undertake appropriate actions for multimedia and
geographic targeting enforcement initiatives
2-18 mos. Coordinate with other federal agencies, state, Native
American, and local authorities on joint opportunities
for addressing compliance problems
2-18 mos. Reevaluate farmworker protection priorities and federal
facility priorities and resources
2-18 mos. Develop adequate civil rights oversight and compliance
programs to ensure that civil rights laws apply
appropriately to all EPA and delegated federal program
implementation activities
On-going Support appropriate citizen compliance and pollution
reduction efforts
On-going Look for enforcement case pollution prevention
opportunities which reduce risk in enforcement cases
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EJ21
BARRIERS:
- Historical lack of recognition of issues and commitment to
address problem result in lack of priority
- Lack of coordinated structure to assure multimedia and
geographic approaches to include environmental justice
considerations, impeding a more comprehensive approach to
protecting highly exposed populations
- Absence of accountability in identification of problems,
measurement, oversight, and management
- OCR role in Agency program oversight limited to Title VI
programs rather than ensuring equal protection of all EPA
programs and delegations
PROJECT RESOURCES:
- Workgroup participation in policy/guidance development
- Resource investment (management, inspection, oversight,
enforcement case development) in under-utilized programs and
new priorities (such as FIFRA)
- Resource priority shift in data needs, planning,
coordinating, and evaluating initiatives in targeting
- Workgroup participation to coordinate with other agencies,
states, Native American organizations
- Resource investment (policy development, oversight,
reporting) in new oversight functions
VALUE/BENEFITS:
- Establish environmental justice as a working priority in all
aspects of compliance and enforcement
- Consistency with EPA risk priorities, equal protection of
most-exposed populations
- Coordinated strategy, consistency in implementation of
federal and state programs, full/fair implementation of
environmental laws
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EJ22
SCIENCE
VISION: Incorporation of racial, ethnic, economic and cultural
data into scientific assessments of exposure and health impacts.
RECOMMENDATIONS FOR INITIATIVES:
TIMELINE INITIATIVE
6 mos. Support annual conference of all potentially affected
groups (i.e., women, Native American, minority and low
income) on Environmental Justice issues resulting in a
collaborative action agenda (note: Such a conference is
being planned for Jan., 1994 with EPA, NIEHS, ATSDR,
and DOE)
1 yr. Develop databases that establish risk-based information
on affected populations for use by decision makers and
contractors
2 yrs. Develop EPA standardized format for disseminating
database information throughout EPA and making it
accessible to community groups, state and local
governments, academia, industry and general public
1 yrs. Require all programs to incorporate low income and
minority group data into decision-making processes
Contin. Develop and implement pollution prevention strategies
for affected communities including low cost remedies
and corrective practices.
2 yrs. Develop and implement evaluation system to measure and
monitor improvements/changes in application of database
information in science decisions; (monitor, revise and
update annually)
BARRIERS:
Internal
- Poor use of or lack of available information on risks to
affected populations
- Lack of the mindset of EPA employees to change traditional
methods and thinking
- Absence of accountability and understanding of the roles and
responsibilities of EPA staff for Environmental Justice issues;
"Diffusion of Responsibility"
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EJ23
External
- Industry resistant to including affected group data, they may
view it as an impedance to profit making
- Lack of scientific and technical knowledge from grassroots
communities
PROJECT RESOURCES:
- 5 FTEs for 1 year to complete baseline study (input of all 10
regions for information)
- Contract support to develop standardized collection of
information
VALUE/BENEFITS:
EPA would have consistent, available, standardized information
for monitoring the agency's progress in Environmental Justice in
risk assessment and management. There would also be the benefit
of not re-inventing procedures every time risk assessments are
performed on affected populations. Lastly, an historical record
would be established from which the agency could plot its
progress and change (from the initial establishment of the
baseline incorporating affected population data and later make
comparisons).
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REPORT OF THE
ENVIRONMENTAL TECHNOLOGY
TEAM
NATIONAL
PERFORMANCE
REVIEW
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ET 1
TABLE OF CONTENTS
PAGE
Environmental Technology
Team Members and Acknowledgements ET 2
Abstract ET 3
Executive Summary ET 4
Detailed Recommendations ET 13
Real World Examples of the
Benefits of Innovative Environmental ET 33
Green Enterprises, Inc:
A Hypothetical Case ET 35
Bibliography ET 38
Reinvention Laboratories ET 40
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ET
EPA
NATIONAL PERFORMANCE REVIEW
ENVIRONMENTAL TECHNOLOGY TEAM
Joe Carra - OPPTS - Chairman
Don Barnes - OA/SAB - Facilitator
Stanley Austin - OW
John Cross - OPPTS
Frances Eargle - OW
Alfred Galli - ORD
Santana Ghose - Region 6
Yvette Hellyer - OPPTS
Oscar Hernandez - OPPTS
Eric Koglin - ORD/Las Vegas
Barry Korb - OPPE
Kim Kreiton - ORD
Alfred Lindsey - ORD
David Lynch - OPPTS
Sue McMaster - OPPTS
Steven McNeely - OUST
Timothy Oppelt - ORD
John Quander - OSWER
Jan Rogers - Region 4
Karl Simon - OAR
Gail Tomimatsu - OPPTS
Mary Ellen Weber - OPPTS
The Team would like to acknowledge the indispensable help of
Bill Hanson in the preparation of this report and the
secretarial support of Bobbe Ward.
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ET
ABSTRACT
Environmental technology is a big and growing business
that spans a wide spectrum, from pollution prevention
to site clean-up technologies. EPA is, through its
regulations, policies and procedures the major shaper
of this market. In order to meet the future
environmental needs of the nation at a reduced cost,
this market needs to be more competitive, dynamic and
innovative, and it needs to be directed more at
pollution prevention. There are barriers (both
internal and external to EPA) to the development of
such a market. To overcome the barriers, our Team
identified a series of recommendations listed under
five target/action categories. Our recommendations are
actions EPA could take which would reshape the
environmental technology market by helping to unleash
the energy and resources of the private sector and
other government agencies. We have also recommended
several pilot programs, as a way of moving beyond the
"just-talking" stage, to find out exactly what works
and what doesn't.
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ET
EXECUTIVE SUMMARY
ENVIRONMENTAL TECHNOLOGY TEAM
NATIONAL PERFORMANCE REVIEW
BACKGROUND:
Environmental technology plays a fundamental role in the
protection of public health and the environment. However, the
pace of innovation in this technology has been disappointingly
slow in the United States. Unfortunately, what has worked in the
past is not working today and will not work in the future. Over
the years our ability to define environmental threats to the
public and the environment has outstripped the Nation's ability
to bring new technology choices to deal with these threats to
market. As a result, costs of environmental protection have
increased dramatically and many environmental threats are not
adequately addressed because of the limitations of current
technologies.
Today, the domestic environmental protection industry is a
big business: the market for now exceeds $150 billion per year.
(The worldwide market is approximately $300 billion per year.)
The environmental protection industry can expect growth rates
higher than the general economy and increasingly that growth
will be expected to occur in source reduction and recycling. In
the manufacturing sector, capital investment in process changes
for environmental purposes now accounts for approximately one-
quarter of total environmental investments as industry
increasingly recognizes the long range cost savings of this
approach. (According to US Census Bureau surveys, process
changes as a percent of total environmental investments in the
manufacturing sector have increased from 13% in the early 1983 to
25% in 1991.)
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ET 5
Accelerating the introduction and broad commercialization of
innovative environmental technologies will result in many
benefits:
improved ability to solve seemingly intractable
environmental problems
reduced compliance costs
reduced releases of toxic substances and reduced risk
of toxic release
better environmental performance
reduced chemical and energy use
job creation and new company growth
increased U.S. competitiveness
expansion of international markets
VISION:
Improvements in environmental protection will flow from a
thriving environmental technology market characterized by:
rapid new technology introductions
increasing use of recently commercialized innovative
technologies
increasing proportion of environmental technology
investment in pollution prevention and recycling
PROBLEMS:
A. Most of the current investment in environmental
technology is still focused on pollution control or
clean-up. This focus on end-of-pipe technology reduces
the pool of resources available for investment in
technologies to prevent pollution at the source or to
recycle. Although industry has allocated an increasing
proportion of their environmental expenditures to
process changes, all parties acknowledge that much more
can be done to fully exploit available opportunities.
B. We are not getting innovative technologies at the pace
we should expect. Other industries are successfully
introducing new products; for example, the medical
devices industry, which is heavily regulated by the
Food and Drug Administration, successfully brings new
technologies to market. However, there are many
barriers - both internal and external to EPA - that
limit innovative environmental technologies. These
barriers include:
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DEFINITIONS;
ET 6
statutes, regulations, permitting, and enforcement
procedures which favor the use of tried-and-true
technologies and then lock these technologies into
place.
mistrust of new technologies due to:
a) lack of consistent and credible testing
protocols and performance data
b) scarcity of locations where regulations and
local communities will allow untried
technologies to be tested
c) lack of an independent review and
verification of vendors' performance claims
difficulty in obtaining financing for:
a) development of new pollution control or
clean-up technologies
b) permitting and early commercialization of
full-scale application of technology
c) implementation of fundamental process or
product changes to enable recycling or
source-reduction efforts.
inadequate mechanisms for the dissemination of
information among individuals, businesses and
Federal agencies on the availability,
applicability, costs, and performance of new
environmental technologies.
Environmental Technology -
Environmental technologies are processes or products that
play a direct or indirect role in improving environmental
quality. There are many different situations where environmental
technologies play an important role:
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ET 7
Remediation and site cleanup, including natural resource
restoration and protection
Pollution control (capture, control, or management of
pollution)
Recycling (recovery and reuse of waste products and energy)
Pollution prevention and clean technologies (source
reduction and in-process reuse)
Environmental and manufacturing process monitoring and
assessment
innovative Technology -
Innovative technologies are those technologies that
represent either a new environmental process or product, or a new
application of an existing technology.
GENERAL APPROACH
To deal with the problems identified above, the team took
the approach looking at the Best Ways to do Preferred Things:
Best Way - Wherever possible, action areas were
identified that EPA could take to unleash the energy
and resources of the private sector and other Federal
agencies (i.e., have EPA do more steering than rowing).
Preferred Thing - This plan addresses the need to
direct more effort to the development and use of
technologies to either stop pollution at the source or
recycle wastes, which are EPA's stated preferences (in
that order) for managing environmental problems.
The team has also taken the approach of recommending several
"reinvention laboratories." By "reinvention labs" we mean pilot
programs that are deliberately designed to break away from
business-as-usual and to test new paradigms. Such reinvention
labs have the potential to break through the gridlock of talk and
no action. Many of the problems and even some of the potential
solutions presented in this report have been debated and
discussed before. It is now time to experiment and find out what
works and what doesn't.
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ET 8
SUMMARY OF RECOMMENDATIONS:
These recommendations are organized and listed under five
target/action categories (labelled A through E).
A. Clean Technologies
Promote clean technologies in order to advance the pollution
prevention / resource conservation goals of the Agency.
1. EPA should develop and promote information and analysis
packages to assist industry in identifying pollution
prevention opportunities and making informed,
responsible choices in the design (or redesign) of
their
information and analysis tools for assessing
performance and costs of environmentally
preferable technologies
cost accounting systems for properly allocating
environmental costs to specific technologies
information on current regulations and permitting
requirements, as well as the future regulatory
outlook.
2. Establish partnerships with industries to re-engineer
common products and processes in order to promote
environmentally cleaner manufacturing, use and
disposal.
Each partnership should include the suppliers and
customers of the industry
One possible Reinvention Lab is the design of more
environmentally friendly computer work stations
3. Direct a greater percentage of technology research and
development and resulting applications to clean
technologies.
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ET 9
B. Statutes and Mainstream Operations
Improve the governing statutes and the mainstream operations
of EPA (i.e. regulations, permits, enforcement) to encourage
the introduction of environmental technologies.
1. Develop an action plan for the Agency which:
- identifies barriers
recommends new approaches to writing regulations
- establishes new implementation policies and
procedures
2. Create a Reinvention Laboratory, consisting of a
special team of EPA and State implementors, to
facilitate permits for innovative technologies and
demonstrate new ways to incorporate innovation.
This team should be insulated from the current
accountability systems that have been recognized
as barriers
The team should identify regulatory and statutory
obstacles that changes to policy and procedures
alone cannot penetrate.
3. Create Reinvention Laboratories aimed at one or more
problem sectors.
For example, DOE and DOD would be encouraged to
renegotiate remediation agreements with the State
and EPA where there are opportunities for
implementing an innovative technology.
- Likewise, the State and EPA would be encouraged to
rapidly evaluate requested to use innovative
technologies.
The Reinvention Laboratory approach could also be used
at several model farms in partnership with USDA. The
Laboratory would examine innovative techniques to
reduce pesticide and nutrient emissions while keeping
crop yield high. Innovative approaches could include:
establishment of riparian corridors to pretreat and
filter pollutants, and development nutrient/yield
curves.
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ET 10
C. Credibility
Enhance the credibility of new technologies by assessing
their performance, thereby facilitating their acceptance by
users, financiers, regulators, and the public.
1. Establish a Reinvention Laboratory to pilot an
environmental technology verification program to
evaluate and validate the claims of environmental
technology vendors.
Designate independent group(s) to perform the
assessments
Develop consistent and credible procedures and
test protocols will be developed
2. Expand available sites where developers and vendors can
test and evaluate their technologies. A Reinvention
Laboratory is being established at McClellan Air Force
Base, California.
D. Finance
Improve the ability of vendors to obtain financing, thereby
expanding technology options available in the market place.
1. Establish a small business center as a Reinvention
Laboratory to pilot a program to help small business
innovators with funding, technology assistance, and
environmental marketing information.
2. Explore government funding mechanisms to reduce the
risk to parties who are willing to develop and try
innovative technology. (Several potential mechanisms
are listed later in this report.)
3. Challenge the private sector to develop technologies
which address critical environmental needs. For
example, fund competitions to produce more
environmentally friendly products and establish
contingency standards which become self-implementing
when a new technology is demonstrated to meet the
standard.
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ET 11
E. Information Dissemination
Improve information dissemination and awareness of
environmental technologies to support their diffusion.
(Diffusion is defined as the spread and adoption of a
technical idea following its first successful commercial-
scale use.)
1. Map and evaluate current dissemination mechanisms.
Survey the experiences, needs and desires of vendors
and users.
2. Develop a strategy to improve these mechanisms
3. Create a clearinghouse for innovative technologies,
which includes a library, data bases, and directory of
experts, and is tied into a network of other
clearinghouses and local information sources.
CULTURAL CHANGE
As the Agency confronts the new challenges of the 90's and
beyond, it must stand ready to guestion, and where necessary
change, its culture and the associated paradigm and beliefs which
successfully guided it in the last two decades. To fully achieve
the Vision in this report will require an accompanying effort to
inculcate the ideas and recommendations into the culture of the
Agency.
What are some of the things that can be done to accomplish
this? We considered a recent GAO report entitled,
"Organizational Changes: Techniques Companies Use to Perpetuate
or Change Beliefs and Values." Adapting these techniques to
innovative technology suggests the following steps:
1. Adopt and communicate an Agency VISION statement.
2. Establish measurable GOALS to determine progress toward
the vision statement.
3. Officially designate the Innovative Technology Council
to CHAMPION the vision.
4. Each program office develops a STRATEGY that identifies
its own programmatic barriers to change and develops an
action plan to overcome them.
5. Provide INCENTIVES and AWARDS to programs and
individuals that make significant changes.
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ET 12
6. Discourage "BUSINESS-AS-USUAL" practices. Identify
when people must take individual risk to make changes,
recognize those risks, and grant amnesty for those who
take them.
7. Top management COMMUNICATES the changes inside the
Agency and train staff on how to implement the changes.
8. Hold up SUCCESS stories.
9. GET THE WORD OUT on what we plan to accomplish, how we
plan to encourage more rapid innovation, and what we
would like the private sector to do. Engage key
groups to illicit their input and interest.
CONCLUSION:
EPA needs to operate with the clear recognition that it
creates and shapes the environmental technology market through
its policies, procedures, and regulations.
EPA has the influence and EPA has the responsibility, but it
needs the will to reshape the market to:
1. insure that the environmental technology market is
more dynamic and adaptable to change, i.e. more
innovative and,
2. to help continue the shift from pollution control
to clean technologies.
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ET 13
DETAILED RECOMMENDATIONS
The following sections describe the recommendations of EPA's
Environmental Technology Team in more detail including, where
appropriate, cost estimates. Each section covers this
recommendations of one of the five target/action categories.
The recommendations in this report could be funded under the
President's Environmental Technology Initiative (ETI). The
implementation of these recommendations could be coordinated by
the Agency's Innovative Technology Council (ITC).
A. Encouraging Clean Technologies
CURRENT STATE:
Industry, federal agencies and universities are constantly
designing and developing new products, processes and
systems. Freguently, these designs proceed with little or
no consideration for the environment.
IMPACT:
Environmental impacts must be dealt with afterwards in the
form of costly pollution control and clean-up.
DESIRED STATE:
Design and development of new products, processes and
systems incorporate environmental considerations into the
early design step.
STATUS:
Work started in some areas.
REQUIRED ACTION:
Promote clean technologies in order to advance the pollution
prevention resource conservation goals of the Agency.
1. EPA should develop and promote an information and
analysis packages to assist industry in identifying
pollution prevention opportunities and making informed,
responsible choices in the design or redesign of
processes, products and systems. These packages will
include:
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ET 14
information and analysis tools to assess the
performance, costs and environmental impacts of
various alternative technologies.
cost accounting systems for realistically
assessing and properly allocating the true
environmental costs of a specific process or
product.
In some industries much design work is done with
the aid of sophisticated computer assisted design
software. An effort would be made to integrate
these analytical tools and systems into the
standard industry software.
Schedule Estimates:
Develop information and analytical tools
and cost accounting systems 9/30/94
Complete Pilot Testing 9/30/95
Complete Dissemination of Tools 9/30/96
Budget Estimates ;
FY £M FTE
'94 1.75 2
'95 2.75 2
'96 3.00 2
2. Establish partnerships with industries to re-engineer
common products and processes in order to promote
environmentally cleaner manufacturing, use and
disposal.
Build on the Design for Environment (DfE) Program
by expanding industry collaboration focussing on
those industries that
generate large quantities of toxic chemicals
and wastes
are made up primarily of small businesses
(Examples include metal finishing, dry
cleaning, printing.)
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ET 15
The EPA/industry partnerships should include:
suppliers and customers of the target
industry
trade associations representing the business
The program would attempt to get the trade
associations to adopt voluntary environmental
goals and codes of conduct for the industry as
well as to establish technical assistance programs
on alternative technologies to achieve those
goals.
A partnership of EPA, industry, DOE-National Labs
and DOE-Manufacturing Centers has already begun an
initiative to identify alternative chemicals and
technologies to significantly reduce environmental
impacts of computer products.
Schedule Estimates:
Establish a total of 5 Partnerships:
Two by
An additional one by
Two more by
Budget Estimates:
FY
194
95
96-98
9/30/94
12/31/94
9/30/95
4.0
7.0
7.0/yr
FTE
8
10
10/yr
3. Direct a greater percentage of technology of research,
development, and applications effort by EPA and others
to clean technologies.
Continue to support the development of new, more
environmentally friendly ways to make chemicals
through grants to universities and research
centers.
Create university centers to incorporate pollution
prevention and clean technology concepts into
engineering curricula.
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ET 16
B. Statutes and Mainstream Operations
CURRENT STATE:
Statutes and regulations are often designed in a way that
discourages innovative technology. In the environmental
technology field, the market primarily is driven by Federal
and State environmental regulatory requirements. A
substantial portion of environmental rules in the United
States are based in some way or some how on Best Available
Technology or "BAT." Usually, the regulations are written in
performance terms, but the required performance levels are
usually based on what can be achieved by the Best Available
Technology.
Short compliance deadlines and enforcement consent orders
usually demand fast action and, thereby, favor the adoption
of tried and true techniques usually BAT. Permit writers
and remediation project managers are not encouraged to take
risks, and there is no incentive for permit writers to
approve innovation technologies.
The Congressional staff have said they think we have the
authority to actively promote innovative technologies (and
pollution prevention) in regulations and permits. The
Agency either feels it does not have the necessary
authorities or that we will be criticized for stretching our
authority. The permit writers and project managers feel the
system does not allow them to take risks. We have got to
try to promote innovation in permitting and enforcement and
then either:
1. demonstrate that the permitting process can encourage
innovative technologies or
2. prove that the problem(s) require regulatory and/or
statutory solutions
IMPACT:
Existing standards often lock-in existing technologies and
lock-out new innovative ones. Often the easiest way to
comply with the rules is by simply adopting the technology
on which the government has based its standard. Adopting
other technologies is risky; because the innovative
technologies may not work, even though it might do a better
job than the "BAT" levels.
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ET 17
Innovative technologies may face barriers to approval during
permitting and enforcement negotiation. It is much easier
to approve BAT technology than face the risks of approving
innovative technologies that may not work as expected. In
addition, those installing innovation technologies face
financial "double jeopardy" if the innovative technology
fails and must be replaced by the "BAT" to achieve
regulatory compliance.
DESIRED STATE:
Statutes, regulations, standards and guidelines are designed
in a way that encourages the development and use of
innovative technologies.
The most promising innovative technologies not only face
reduced barriers but are encouraged by the Agency. Permit
writers, enforcement officials, and remediation project
managers are encouraged to try new technologies and are
"allowed to fail."
STATUS:
The new Clean Air Act has certain provisions that provide
incentives to install technologies that go beyond
compliance. However, this is a rare situation.
Very few innovative technologies are being permitted and
commercialized.
POTENTIAL NEXT STEPS:
Improve the governing statutes and the mainstream operations
of EPA (i.e. regulations, permits, enforcement) so the
introduction of environmental technologies is encouraged.
1. Develop an action plan for the Agency which:
- identifies barriers
recommends new approaches to writing regulations
- establishes new implementation policies and
procedures:
Develop implementation plan by June 30, 1994
Fiscal impact: None
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The plan should build upon on-going efforts to
identify existing barriers to innovative
technology development and emphasize
implementation actions such as developing new
approaches, to address these barriers including
new regulatory approaches (such as the use of
trading allocation programs), data credibility,
and information dissemination. The net result
should be new policies and procedures to
facilitate permitting for innovative technologies.
Implementation of such a plan will encourage the
introduction of innovative environmental
technology. After the action plan is completed it
should be pilot tested and evaluated.
Establish new policies and procedures for
reviewing and processing permits with significant
innovative features, including extra compliance
time to allow innovative technologies to be
adequately tested and installed, providing
additional time to install a standard technology
if the innovative technology does not work,
incentives to encourage innovative technologies
(e.g. reduced monitoring), rapid permit and
document review, and expedited processing of any
other media permits (when there are cross media
impacts).
Using approaches pioneered under the Source
Reduction Review Project (SRRP) promote the design
of regulations which encourages innovative
technologies. Alternative approaches to writing
regulations should be clearly articulated and
encouraged. Alternative approaches include:
a. Develop regulatory standards based upon
current best technology includes provisions
to phase-in incremental improvements over
the levels achieved by current technology.
b. Emission trading provisions which encourage
companies to go beyond compliance by allowing
them to sell improvements upon regulatory
deficits at other installations.
c. Explore the possibility or contingent
regulations that impose a standard based upon
a qualifying new technology only if and when
that new technology becomes available.
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d. Use regulatory approaches that require
measurement reporting (like TRI) which
encourage action but with maximum flexibility
Use settlement authorities (e.g. SEPs) and
imminent and substantial endangerment enforcement
authorities to encourage the adoption of
innovative technologies.
Work with Congress to develop statutes with
provisions that will encourage innovative
technologies especially of a source reduction
nature. Specifically, EPA should:
a. Analyze the proposed new Clean Water Act with
such provisions in mind.
b. Identify and analyze other environmental
statutes that are under development again
looking to include such provisions.
c. Prepare a report for Congress which points
out the problems of traditional statutory
approaches and gives them a blueprint of
better alternatives.
Streamline state review of water treatment
technologies. Small communities are struggling to
meet new drinking water requirements and upgrade
wastewater systems. EPA is working with western
states to develop a common framework of reviewing
water filtration technologies. This effort needs
to be expanded to the national level.
Create a Reinvention Laboratory (consisting of
experienced permit writers from EPA and States) to
facilitate permits for innovative technologies,
demonstrate new ways to incorporate innovation, and
identify regulatory and statutory barriers that need to
be corrected.
Establish innovative permitting team by June 30, 1994
Initiate 20 permit reviews Sept 30, 1995
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Fiscal impact:
FY £M FTE
'95 1.0 10
'96-98 2.0/yr 20/yr
A special team, to be established by June 30,
1994, consisting of permit writers from EPA and
the states will initiate 20 new permit reviews.
This team would be insulated from the current
accountability systems that have been recognized
as barriers. The reviews would determine whether
the permits could be changed or modified to allow
the use of more innovative technology to
accomplish the environmental mandate dictated by
the permits. This would demonstrate what works,
and what doesn't work, from the action plan, and
may require changes in the plan. This team will
also identify regulatory and statutory obstacles
that policy and procedural changes alone cannot
penetrate.
Work with alternative approaches to conventional
permitting processes, for example:
integrated or coordinated permits under
several environmental statutes;
waivers of compliance deadlines, which might
be eased to allow time to develop, install,
and perfect the technology.
waivers of substantive requirements;
expedited permit processing for innovative
approaches, (where the regulated party is
willing to bear the risk of non-performance) ;
increased use of expedited permitting
authorities for testing;
It is envisioned that the permitting team would be
comprised of a small headquarters staff (1-2
FTE) , with "leadership directors" coming from
headquarters, regional offices and state agency
or state organizations. The balance of the team
would be comprised of individuals in the Regions
and States who review "innovative permits."
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3. Create Reinvention Laboratories aimed at one or more
problem sectors. For example, DOE and DOD would be
encouraged to renegotiate remediation agreements with
the State and EPA where there are opportunities for
implementing an innovative technology. Likewise, the
State and EPA would be encouraged to rapidly evaluate
requested to use innovative technologies.
The Reinvention Laboratory approach could also be used
at several model farms in partnership with USDA. The
Laboratory would examine innovative techniques to
reduce pesticide and nutrient emissions while keeping
crop yield high. Innovative approaches could include:
construction of wetlands, establishment of riparian
corridors to pretreat and filter pollutants, and
developing nutrient/yield curves.
C. CREDIBILITY
CURRENT STATE:
The credibility of environmental technology performance is
limited by a lack of consistent, thorough, and impartial
evaluations. In addition, technology performance
measurements are limited by a lack of permitted testing
venues. Industrial consumers, regulators, financiers, and
others are not confident that technologies will perform as
touted by technology developers and equipment vendors.
IMPACT:
New environmental technologies are under-utilized, slowing
the pace of innovation. The impetus for continuing research
and development is stifled due to the difficulty of
commercializing innovations. Older technologies, therefore,
are used to protect communities and ecosystems since
newer technologies are rarely introduced and commercialized.
DESIRED STATE:
The performance of promising innovative technologies are
evaluated with the results widely disseminated. The process
and specific procedures for bringing innovations into the
market place is predictable. Industrial consumers,
regulators, investors, and host communities have confidence
that they are making decisions based upon the reliable data.
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Developers and vendors of innovative technologies have
venues in which to test and evaluate the full-scale
operation of the technology under realistic conditions,
where permitting issues and/or community resistance will not
delay testing and evaluation.
STATUS:
The Superfund Innovative Technology Evaluation (SITE)
Program evaluates the performance and costs of remedial
technologies, as well as, monitoring and assessment
technologies appropriate for site remediation. The SITE
program was the first of its kind at EPA, but has now been
followed by the Municipal Waste and Recycling Innovative
Technology Evaluation (MITE) program and the Waste Reduction
Innovative Technology Evaluation (WRITE) program. MITE
evaluates the performance of municipal waste reduction and
recycling technologies and WRITE evaluates pollution
prevention and waste minimization technologies.
The Department of Defense operates DCAS, the Defense
Contracts Audit System, which oversees qualification testing
of equipment developed under DOD contract.
EPA has entered into a partnership with McClellan AFB, the
State of California, and several companies to test
innovative treatment at the air force base.
EPA is beginning the fabrication of testing chambers for in-
situ soil remediation technologies.
POTENTIAL NEXT STEPS:
Enhance the credibility of new technologies by assessing
their performance, thereby facilitating their acceptance by
users, financiers, regulators, and the public.
1. Establish a Reinvention Laboratory to pilot an
environmental technology verification program to
evaluate and validate the claims of environmental
technology vendors. EPA would establish third-
party (ies) to provide independent assessments of
environmental performance.
Select third-party organization(s) Sept 30, 1995
Protocols developed for first
technology applications Sept 30, 1996
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Fiscal impact1 :
FY £M FTE
95 2M 3
'95-98 20M/yr 5/yr
Under this program, EPA would designate an
independent group, with the assistance of the
National Institutes of Standards and Technology,
to perform the assessments. These assessments
would be similar to those conducted by
Underwriters Laboratories for electrical
equipment. The program would provide users,
financiers, EPA and others with consistent and
credible protocols and testing data, and
independent review and verification of performance
claims. Finally, the program should be able to
provide specific, predictable procedures and
processes that are known by people working through
the system.
2. Expand available sites where developers and vendors can
test and evaluate their technologies. A Reinvention
Laboratory is already being established at McClellan
Air Force Base, California to test site remediation
treatment techniques.
Identify two additional partnerships
where developers and vendors can
test and evaluate site remediation
technologies Mar 31, 1994
Identify three additional Dec 31, 1994
partnerships
Fiscal impact:
FY jjM FTE
'94-96 4.5M/yr 4 . 5/yr
1 By using third parties EPA FTE requirements are
significantly reduced.
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Collaborate with DOD and DOE to designate "test
beds" for full-scale testing and evaluation of
innovative, environmental technologies under real
world conditions. Permitting would be waived
under the assurance that releases would meet
regulatory requirements with waste releases held
and re-treated, when necessary.
EPA and possibly the National Environmental Labs,
should make available environmental simulation
chambers for the development and evaluation of
innovative, environmental technologies. Chambers,
likely would be installed in facilities already
permitted for research and testing.
D. Finance
CURRENT STATE:
Financing involves both the need for venture capital for
start up firms wanting to develop new technologies, and
financing for project implementation on the part of
companies looking for funding for fundamental changes of
processes, products, or end-of-pipe treatment. Currently,
venture capitalists are not funding new environmental
technology projects. They do not consider innovative
technologies to be a worthwhile risk. Over the past five
years approximately 90 per cent of the environmental
technology projects funded by venture capitalist failed
because it took longer and was more expensive than
anticipated to reach commercialization.
EPA has the authority to do research but does not have the
authority to fund product development.
IMPACT:
Technology options available in the market place are limited
resulting in the use of existing technologies which are
costly and/or don't meet environmental needs.
DESIRED STATE:
Financing is available for promising new technologies and
for the permitting and commercialization of proven
technologies.
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STATUS:
The problem has been studied by the NACEPT committee but
little else has been accomplished.
POTENTIAL NEXT STEPS:
Improve the availability of financing, thereby expanding
technology options available in the market place.
1. Establish a business center as a Reinvention Laboratory
to help small business expand the technology options
available in the market place by helping these
businesses overcome barriers to initial
commercialization and provide financial information for
new technologies.
The Reinvention Laboratory would assist the
entrepreneur in obtaining those services necessary
to commercialize an innovation. Services to be
provided will include: aiding in market
assessments and cost evaluation efforts; arranging
for testing by an independent group to provide the
data needed to assure permit writers, users,
investors, and the public that the innovation's
performance claims are valid; identifying sources
for financing, managerial support, sales, and
business partners; assisting in the loan
application process and locating or researching
other funding mechanisms; and advising on EPA,
State, and local regulatory permitting and
enforcement requirements and procedures.
The Lab would have an independent Board made up of
businessmen, venture capitalists, regulators,
environmentalists, and representatives from the
user industry to insure that candidate selection
is based on its chances for business success as
well as environmental benefit.
Direct financial support would not be
provided.
Laboratory efforts could be combined with other
special EPA programs designed to advance
innovative technologies by addressing issues such
as compliance contingency plans and special
monitoring needs.
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ET 26
The laboratory would be run by an organization
independent of EPA (e.g., a NIST center or a non-
profit group) to separate it from EPA's
permitting and enforcement programs.
Projects selected for support would have to meet a
rigorous set of criteria designed to ensure the
environmental desirability of the innovation and
maximize its chances for commercial success.
Criteria would include: identified market need,
significant investment by sponsoring firm, active
participation by outside partners, high ranking by
an independent advisory panel, and emphasis on
pollution prevention oriented solutions.
Provide assistance
for projects September 30, 1994
Provide assistance for an
additional 20 projects September 30, 1995
Fiscal Impact:
FY £M FTE
94 0.5M 1.0/yr
95-98 l.OM/yr 2.0/yr
2. Challenge the private sector to develop technologies
which address critical environmental needs. Programs
would include funding competitions to produce more
environmentally friendly products and establishing
contingency standards which become self-implementing
when a new technology is demonstrated to meet standard.
Complete report December 31, 1995
Fiscal impact: none
Some of the mechanisms that should be explored
are:
Establishing a demonstration fund to cost
share the first commercial application(s) of
innovative technologies that address critical
environmental needs. (Similar to an on-going
program for air pollution control technology
funded by Germany . )
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ET 27
- Encouraging a contractor to propose an
innovation during the life of a contract and
share in any savings and be rewarded for
technologies that yield improved results.
Sharing the cost of installing replacement
technology with private industry to comply
with regulations. Cost sharing by EPA would
occur where EPA approved the initial
innovative technology installation.
Using privately developed and publicly
authorized securities an insurance policies
("risk premiums") to allow for risk sharing
and some amount of certainty in the case of
failure.
Providing financial and technical incubator
assistance.
Establishing an insurance fund to fund
developing technologies and to spread the
risk.
Providing a Federal tax credit for companies
trying innovations.
3. Offer awards for the first companies that develop
technologies which address environmental needs as
identified by EPA. Awards could be a financial prize
or a standing solicitation to encourage the development
of advanced technology.
Develop two new awards programs
in conjunction with the
private sector. December 31, 1995
Fiscal impact:
FY
'95 100K
'96-98 100K per year
(EPA provides its "good offices" and "coaching", but no
direct financial support)
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The two new awards would take the following forms:
1. Form partnerships with industry and public
interest groups that offer a substantial
financial award for the first companies that
market a product that meets predetermined
specifications or excel above its
competitors.
2. Develop "standing solicitations" (with bonus
awards) for the first company(ies) to meet
specifications for needed technology, e.g.
totally chlorine free craft paper
manufacturing.
OTHER:
Embark on collaborative activity with the lender
community to educate them on the potential risk
and benefits associated with financial support for
pollution prevention approaches, green
technologies, and innovation.
Use government procurement authorities to create
demand for green products, and the products of
environmentally sound technologies.
Assist business in developing credible technical,
economic, and market data for understanding
potential markets and developing environmental
technologies.
Offer extended patent protection to selected
innovations as a bonus and as a means to offset
review times. This action would require an act of
Congress.
Use the Export-Import Bank to support the use of
American technology overseas. Similar to the
support provided by foreign governments, allow the
Export-Import Bank to fund engineering feasibility
and design studies conducted by American firms.
The country that does the initial feasibility and
design studies is often the country that will be
most successful in furnishing advance equipment.
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E. Information Dissemination
CURRENT STATE:
Although, enhanced EPA technology dissemination programs are
considered to be essential to diffusion of new technologies,
the EPA and the private sector do not have effective
dissemination programs. The lack of strong government or
private sector dissemination programs hinders the
development, evaluation, and use of innovative environmental
solutions.
IMPACT:
Inadequate dissemination results in available new
technologies not being used because decision makers do not
know about them. This increases costs and reinforces the
reliance on existing tried and true technologies. It also
means that technology developers can be working on products
for which there is no market.
DESIRED STATE:
Industrial customers and regulators fully understand the
technological options available them. Government supports
information dissemination methods for diffusing innovative
technology. The Agency support partnerships that are
oriented toward direct diffusion of technology.
STATUS:
EPA has a number of separate technical outreach programs to
"get the word out" on technology transfer.
POTENTIAL NEXT STEPS:
Improve information dissemination and awareness of
environmental technologies to support their diffusion.
(Diffusion is defined as the spread and adoption of a
technical idea following its first successful commercial
scale use.)
1. Map and evaluate current dissemination mechanisms
Survey EPA's major technology diffusion programs,
and categorize and evaluate the adequacy of the
approaches, resources, and relative emphasis on
the environmental protection hierarchy.
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Ask vendors and users what happens now when they
seek information on markets or available
technologies. Determine their needs, how the
process could best work for them, and how well
their needs are meet by the private sector.
Determine existing, private sector mechanisms and
evaluate what actions EPA could take to use these
existing mechanisms.
Survey the Agency to identify major technology
diffusion programs, and evaluate the adequacy of
the approaches, resources, and relative emphasis
(e.g., prevention vs. treatment vs. remediation);
Identify what kinds of innovative technologies are
available or "out there?"
identify goals and "intended" purposes of
each technology, key players, and "cross-
programs" in the Agency
Link with players on Environmental Technology
Panel and in other administrative or
technology agencies (DOC, DOD, DOE)
Develop a compendium of public/private sector
funding mechanisms
Complete compendium: June 30, 1995
Fiscal impact:
FY
94-95: 0.2M/yr
Develop a strategy to improve dissemination mechanisms
Develop a strategy that involves:
mapping out a new process;
identifying key players;
working with them to implement the new
process;
developing and maintaining communication
links.
Issue strategy: September 30, 1994
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ET 31
Build on the Design for the Environment model for
diffusion environmental technologies. Focus
delivery of information to particular industries
that can most encourage reduction of toxic use,
energy efficiency, and resource conservation.
Develop awards and recognition programs, modeled
on Alaska's "Green Star" program for encouraging
the diffusion of prevention approaches and
innovative technologies among small business.
Develop partnerships with other Agencies that
provide assistance to industry for purposes of
enhancing economic competitiveness. (For example,
EPA should work with other Federal agencies to
coordinate clearing houses and computer networks.)
Integrate the Agency's technology diffusion
enterprises. The bulk of the Agency's resources
for encouraging innovation and diffusing
innovative technology are focused on remediation
technologies, not prevention.
Strengthen EPA's support for existing and emerging
programs for diffusion of pollution prevention
technologies at the State, Regional and local
level. This support would include increased
funding for these programs, a Pollution Prevention
Clearinghouse that serves this network of
programs, national support for programs that use
retired engineers for technical assistance.
Build on the Green Programs model for diffusing
selected environmental technologies across
industries.
Develop awards and recognition programs, modeled
on Alaska's "Green Star" program for encouraging
the diffusion of prevention approaches and
innovative technologies among small businesses.
Develop partnerships with other Agencies that
provide technical assistance to industry for
purposes of enhancing economic competitiveness, to
encourage them to support prevention and
innovation in their technology diffusion
mechanisms.
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Create computerized links among EPA offices and
labs and between other technology agencies in the
Federal Government.
Create a focal point for EPA's environmental
technology activities which would integrate agency
efforts and facilitate dissemination of
information.
3. Create a clearinghouse for innovative technologies,
which includes a library, data bases, directory of
experts, and is tied into a network of other
clearinghouses and local information sources.
Establish clearinghouse December 31, 1995
function
Fiscal Impact
FY £M FTE
'94 0.5M 2.0
95-98 l.OM/yr 1 . 5/yr
This central clearinghouse would catalog
technologies, experts, training, conferences and
publications.
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Real World Examples of the Benefits of Innovative
Environmental Technology
Pollution Prevention Small Business Support
EPA assisted a small manufacturer of orthopedic devices
switch from harmful TCA (a halogenated solvent that
destroys the ozone layer) to a dilute, terpene-based
cleaner. Product is now cleaned in a heated ultrasonic
bath used to degrease the parts. The new cleaning
system is saving the small business $4,800 per year
with a pay back of only 4 1/2 months.
New Microelectronics Manufacturing Process Virtually
Eliminates Waste
Electrochemical micromachining (EMM) is being developed
and implemented as an environmentally sound and high
speed metal removal process for microfabrication of
electronic components. The use of EMM technology
significantly reduces (and in some cases eliminates)
the generation of wastes saving approximately 10 -
25 per cent of total production costs. Similar
environmentally clean technologies are being employed
for metal plating and chemical etching.
Pollution Prevention Technology in the Electronics
Industry
EPA and the State of California worked with Hewlett-
Packard to develop an advanced reverse osmosis system
that allows nickel and other chemicals in the
electroplating process to be reused. End of pipe
treatment is substantially reduced and purchase of
nickel and electroplating chemicals is much less.
Annual cost savings are approximately $17,000 per year
with a payback period of about 4 1/2 years. This
technology has wide applicability in the electronics
industry.
Pollution Prevention Technology - Freon
The State of California, EPA, and General Dynamics
joined forces to reduce CD's use of freon by installing
a freon recovery still and water separation equipment
to effect recycling of freon. The freon recovery
equipment had a pay back of 6.6 months.
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Reusing Dredge Spoils for Wetland Restoration
EPA and the Corps of Engineers is examining the
potential to use dredged material from lower
Mississippi River and using this material for wet land
restoration. Each year approximately $75 million is
spent restoring coastal wetlands in Louisiana. And
each year approximately 90 million cubic yards of
dredged material is generated.
Air Pollution Control
An industry/TVA/EPA consortium is field testing an
innovative sulfur removal device that can replace flue
gas scrubbers. If successful, savings could exceed $1
billion per year.
Superfund Site Remediation
EPA found that the use of innovative treatment
solutions saved up approximately $140 million at seven
sites. The savings were identified from the
feasibility study.
Immunochemistry ysed for Monitoring at Hazardous Waste
Sites
Medical immunoassay techniques are now being used to
determine the concentration of some types of organic
contaminates at hazardous waste sites. Immunoassays
can be conducted in the field at 10 % of the cost of
standard laboratory analysis.
Continuous Water (and Wastewater) Quality Monitoring
The Automated Volatile Organic Analysis System provided
on-site, real-time measurements of a ground water
treatment facility. Sampling was done every 8 hours,
with results back within one hour compared to 3 days
to two weeks using conventional laboratories. Cost
savings are expected to be substantial for a fully
operating system.
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Green Enterprises, Inc:
A Hypothetical Case
The five major target areas identified by the Environmental
Technology Team were described in the previous pages. In
order to facilitate understanding of the Team's intent in
these areas, a hypothetical case study, Green Enterprises,
Inc. is presented. The interactions among Green
Enterprises, EPA, and others will be described for each of
the major action areas. Assume that Green Enterprises
consists of a very small, start-up company. Some wonderful
concepts in pollution prevention and remediation
technologies are found there, but Green requires guidance as
to how they can bring those concepts through development and
become integrated in the market give the barriers before
them.
Following Item 1: Promote Clean Technologies
Our hypothetical start-up firm, Green Enterprises, Inc., is
interested in becoming a player in the environmental market.
They have a few vague ideas about contributions they can
make in this area, but they are not closely affiliated with
any major industries and aren't sure which small businesses
would require their services.
EPA would make a clearer effort to communicate the pollution
prevention problem areas in various small businesses, such
as finding alternatives for PCE among dry cleaners, and in
larger manufacturing industries,such as finding alternatives
for TCE as degreasing solvent, through forum which are
easily accessible to Green Enterprises. EPA would also make
a clearer effort to communicate these priorities to the
subject businesses and industries so that they can extend
their search for consulting and R&D expertise to firms like
Green Enterprises.
Following Item 2: Improve Statute & Operations
Green Enterprises has now developed a couple of prototype
solutions to the PCE and TCE situations above, and in so
doing has developed a remediation strategy for PCE and TCE
releases which have become environmental contamination.
They have developed a prototype, pilot-scale remediation
technology as well as an initial plant-scale TCE control
system for use while industries phase out their use of TCE
and phase in the alternate solvent. Green is now confronted
with the problem of attempting to sell their TCE control
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system to an industry which cannot obtain a permit for this
innovative, unproven technology. While Green can provide
laboratory data and theoretical evidence of the technology's
probable success, the EPA permit writer is unwilling to risk
writing a permit for the technology, and the industrial
client cannot accept the risk of operating the TCE control
system without the permit writer's approval.
EPA would turn this permitting issue over to a special
permitting team focussed on writing appropriate permits for
innovative technologies. Meanwhile, a special task force of
EPA, State, and others, is examining more broad solutions to
the problem of writing permits for innovative technologies.
Following Item 3: Enhance the Credibility
A large part of the reluctance of permit-writers to accept
the validity of Green Enterprises' solution to the search
for alternatives to processes and practices involving the
use of PCE and TCE is in the limited data that Green has
been able to generate. This is similar to the college
graduate's dilemma: one can't get a job without experience,
and can't get experience without a job. Green can't get
their technology in the industrial market without operation
experience, and can't get operations experience without an
industrial client. Likewise, the PCE/TCE remediation
technology is rejected for consideration for hazardous waste
cleanup activities by EPA Remedial Project Managers and
others because little operational data can be provided.
EPA would utilize the Environmental Performance Program
which had recently been established on the model of the
SITE, MITE, and WRITE programs to assess, through
independent, reliable evaluation, the ability of the
pollution prevention technology to avoid environmental
damage, the ability of the TCE control system to remove the
solvent from the process or wastewater stream, and the
ability of the PCE/TCE remediation technology to achieve
destruction or removal of the contaminant.
Following Item 4: Improve availability of Financing
Green Technologies, Inc. had developed a pollution
prevention, a pollution control, and a remediation
technology. Without a defined and accepting market,
however, they could not obtain venture capital or bank loans
to finance further development, production, and installation
of pilot- or full-scale units.
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EPA would utilize a newly established pilot program to a
assists Green in locating government or private-sector
funding and in obtaining information about the prospective
markets for their technologies. Further, Green may have
been motivated to develop their technologies due to the EPA
program to offer a prize to the first developers who filled
the advertised high-priority, unmet needs. The bonus prize
may be used by Green to cover some of their development
costs or to reduce the price to initial clients. EPA would
also share some of the financial risk with the initial
clients, such as by offering to cover a proportion of
replacement or upgrade costs if Green Enterprises technology
failed to perform as expected. Finally, thanks to the EPA-
established Environmental Performance Program, Green would
have the commercial-scale data required to convince
financial backers of the potential for technical as well as
market success.
Following Item 5: Improving Information Dissemination for
Diffusion
In 1993, Green Enterprises, Inc. has few forums to obtain
regulatory acceptance for their innovative technologies.
Their pollution prevention application receives little
publicity partly because there is no single source of
information on innovative technologies in that area. Also,
without testing and evaluation by a potential client or
independent third party, Green's marketing efforts are
rebuffed due to lack of confidence in the performance data.
Their pollution control and remediation technologies receive
only slightly more attention. Multiple sources of limited
information confuse potential clients. The lack independent
verification of the technologies performance and publication
of the results further hinders diffusion.
Following the Environmental Performance Program evaluation,
EPA would help to facilitate the diffusion of Green's
technologies into the appropriated markets through
continued publicity of their successful efforts. All
Environmental Performance Program participants would receive
similar public exposure in order to facilitate responsible
decision making in the private sector and by Federal, State,
and local regulatory and enforcement officials through
increasing the awareness of alternatives.
Prepared by:
Kim Lisa Kreiton
Member of EPA's Environmental
Technology NPR Team
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BIBLIOGRAPHY
Environmental Technology Team
References:
Technology Performance Group, "Report on Current State and
Desired Direction", July 12, 1993.
Economic Barrier Group, "Economic and Institutional Barriers to
Innovative Environmental Technology," July 12, 1993.
Institutional Barriers Group, "Institutional Barriers," July 12,
1993.
Information Management, Technology Transfer/ Diffusion, and
Communication Subgroup, "Problem Statements and Desired States,"
July 12, 1993.
"Situational Map of Environmental Technology"
Other References:
Anderson, Earl V., "Slower Growth, Shift in Emphasis Expected for
Environmental Business: Preventing pollution and minimizing
waste generation gradually will replace cleaning up the 'sins of
the past1," Chemical and Engineering News, June 28, 1993.
Ashford, Nicholas, et al; "Using Regulation to Change the Market
for Innovation," Harvard Business Review, Volume 9:419, 1985.
Gibbons, John H., Director, Office of Science and Technology
Policy, "Environmental Technology," before the Committee on
Environment and Public Works, U.S. Senate, May 21, 1993.
Osborne, David and Gaebler, Ted, Reinventing Government. Addison-
Wesley, 1992.
Sussman, Robert M., Deputy Administrator, U.S. EPA, "Encouraging
the Development and Use of Environmental Technologies," before
the Committee on Environment and Public Works, U.S. Senate, May
21, 1993.
Innovative Technology Council (ITC), U.S. EPA, "Initial Meeting
of the EPA Innovative Technology Council," by Walt W. Kovalick
and Alfred W. Lindsey.
ITC, U.S. EPA, "DRAFT - EPA's Innovative Technology Strategy,"
June 14, 1993.
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ET 39
National Advisory Council for Environmental Technology Transfer
(NACETT), U.S. Environmental Protection Agency, "Report and
Recommendations of the Technology Innovation and Economics
Committee. Recommendations for Action on Technology Innovation,"
EPA A-101 F6, December 1989.
National Advisory Council for Environmental Policy and Technology
(NACEPT), U.S. Environmental Protection Agency, "Report and
Recommendations of the Technology Innovation and Economics
Committee. Permitting and Compliance Policy: Barriers to U.S.
Environmental Technology Innovation," EPA 101/N-91/001, January
1991.
NACEPT, U.S. Environmental Protection Agency, "Improving
Technology Diffusion for Environmental Protection. Report and
Recommendations of the Technology Innovation and Economics
Committee," EPA 130-R-92-001, October 1992.
NACEPT, U.S. Environmental Protection Agency, "Transforming
Environmental Permitting and Compliance Policies to Promote
Pollution Prevention: Removing Barriers and Providing Incentives
to Foster Technology Innovation, Economic Productivity, and
Environmental Protection," EPA 100-R-93-004, April 1993.
Office of General Council, U.S. EPA, "Survey of the Impact of the
Air and Water Permitting Processes on Technological Innovation by
Permittees," (by John Manthei).
U.S. Bureau of the Census, "Current Industrial Reports:
Pollution Abatement Costs and Expenditures," 1983 through 1991
U.S. Environmental Protection Agency, "Environmental Investments:
The Cost of a Clean Environment," EPA-230-12-90-084, December
1990.
U.S. Government Accounting Office, "Organizational Culture:
Techniques Companies Use to Perpetuate and Change Beliefs and
Values," GAO/NSIAD-92-105, February 1992.
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ET 40
REINVENTION LABORATORY
Initiative:
Proposal:
Unique
Features
Outcome:
Rules Needing
Waivers:
How Public
Benefits
Encouraging Innovation through Environmental
Permitting
Environmental innovation is often slowed or
curtailed at the permit stage. Form a team of
"innovative permit writers" (comprised of EPA
headquarters, regional offices and States) to
encourage the implementation of new technologies
and new solutions. Process "innovation permits"
quickly, grant additional time to install
innovations, arrange for a "soft-landing" if the
innovation fails. Set annual targets for permits
that contain innovative technology including
targeting certain innovative technologies.
Designate resources to regional offices and states
that set "innovation targets." It is envisioned
this permitting team would be lead by a small
Headquarters staff (1-2 FTE), with several
leadership directors coming from a Regional office
and a State or State organization. The balance of
the team would be comprised of individuals in the
Regions and States actually reviewing the
"innovative permits."
This team would identify and resolve policy issues
that would need to be resolved to evaluate and
grant a permit for the innovation. The team would
also monitor annual progress.
Encouragement of innovative technology and greater
use of innovative technologies to solve
environmental problems.
On a case by case basis various rules may require
revisions or waivers. The Agency should support
innovative permitting in the Clean Water Act
reauthorization.
By reversing the culture towards environmental
technology innovation, we should see a more rapid
pace of innovative technologies being permitted.
More choices in available technologies would
improve environmental protection and, at the same
time, create jobs.
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ET 41
Initiative:
Proposal :
Unique
Features:
Outcome:
Rule Needing
Waivers:
REINVENTION LABORATORY
Evaluation of environmental technologies to
support their commercial use.
Many environmental technologies are not moving
from the laboratory and pilot states of
development to full scale demonstration and
commercialization. The lack of credible
performance data for these new environmental
technologies is one of the primary limitations.
Inadequate cost and performance data impedes
permitting and commercialization of technologies.
EPA would establish and oversee the performance
evaluation program and would use one or more third
parties conducting the tests evaluations.
Evaluations could be performed by private
institutions or by governmental agencies such as
the DOE's National Labs.
EPA should use the expertise of third parties to
conduct the technical evaluations.
By using third parties, technical evaluations
could be completed sooner.
None Known.
How the Public
would Benefit: Using third parties, performance evaluations would
be conducted faster than if EPA were to do the
evaluations themselves.
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ET 42
Initiative:
Proposal:
Unique
Features:
Outcome:
Rules Needing
Waivers:
How the Public
Will Benefit:
REINVENTION LABORATORY
Use Federal Facilities to test and evaluate site
remediation technologies
Evaluate Steam Injection/Vacuum Extraction (SIVE)
technologies at McClellan Air Force Base, CA. SIVE
would be used in place of incineration
Other than EPA and Air Force, private parties are
actively involved, lead by Clean Sites Inc. and
eight computer, utility and chemical companies.
There are two expected outcomes: First, the
McClellan Air Force Base is in a unique position
to test real world problems at hazardous waste
sites. The testing of SIVE technology here can be
expanded to the evaluation of the environmental
technologies at the Federal facilities. Second,
the evaluation of the SIVE technology could lead
to successful commercialization.
Not Known. Future technology evaluations may
require waivers or rapid and flexible permitting.
Should SIVE prove to be more effective and/or less
costly than incineration, companies (and
governments) responsible for remediation cost,
which would improve their competitiveness. In
addition, SIVE equipment vendors and technical
consultants would be able to expand their
international market with this technology.
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ET 43
REINVENTION LAB
Initiative:
Proposal:
Unique
Features:
Design Computer Work Stations for the Environment
Evaluate the technology, processes and chemicals
used in the manufacture of computer work station
component parts to characterize environmental
impacts and to incorporate risk reduction and
pollution prevention objectives in computer
products. The evaluation would encompass the
environmental management hierarchy including
evaluating substitutes and would use principles of
life cycle analysis and cross media risk
characterization methods. The focus would be on
developing innovative technologies and processes
which would improve environmental impact and in
disseminating results across a broad spectrum of
small and medium sized businesses.
A partnership team made up of EPA, DOE/National
Laboratories, DOC/MTCs and industry would work
together to develop and disseminate results.
Outcome: Identify and put in use alternate chemicals,
technologies or processes in manufacturing
computer work stations which significantly reduce
the environmental impact of computer products.
Rules Needing
Waivers: Permitting and enforcement; anti-trust and
proprietary information rules; industry interns in
government.
How the Public
will Benefit: Reduced impact on the environment of computer
manufacturing; increased jobs through enhanced
international competitiveness of more
environmentally friendly computer products.
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REPORT OF THE
EXTRAMURAL RESOURCES
TEAM
NATIONAL
PERFORMANCE
REVIEW
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£R 1
EPA Internal National Performance Review
Extramural Resource Team
Report
SUMMARY
As ona of several initiatives to integrate management with
mission and improve EPA's resource management, EPA Administrator
Browner began a series of focus groups to identify cross-Agency
issues in extramural (procurement and assistance) resource
management. Because of the importance of these issues, EPA
included this effort in its internal National Performance Review.
The goal of the focus groups is to more efficiently link EPA's
stewardship of fiscal resources and EPA's protection of
environmental resources. The linkage will occur as a result of
increased management attention, as well as improved
communication, coordination and guidance processes developed
together by EPA's resource management staff and environmental
mission staff.
VISION
Accountable extramural resource management that strengthens
EPA's role as a sound fiscal manager as well as strongly supports
its mission to protect the environment.
BACKGROUND
EPA relies very heavily on contracts and grants (extramural
resources) for accomplishing its mission. EPA, throughout its
history, has awarded contracts for many different activities,
such as data processing input, regulatory impact analysis, water
quality testing, information systems development and clean up of
hazardous waste sites, to name just a few. About two thirds of
the Agency budget is spent through contracts and grants.
The regulatory nature of most of EPA's work means that it
uses contracts that require an unusually high level of oversight
and monitoring by the Government. Since 1984, there have been a
series of Inspector General and General Accounting Office audits
that identified problems in the way EPA has managed contracts.
Problems have included cost control issues, inherently
governmental functions, lack of competition, personal services
and inadequate oversight of contracts.
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ER 2
EPA, in the past, tended to respond to these reports as
individual problems, but recently began to deal with them as an
overall Agency-wide problem. Because EPA's work is highly
leveraged with contracts and grants, accountable extramural
resource management is essential to the overall sound management
of the Agency. Congress is holding the Agency accountable for
the use of taxpayer's funds, and intends to ensure that these
problems are solved.
In the early 1990's, EPA began an effort to correct these
problems through comprehensive, systemic improvements rather than
on a case-by-case basis. In June 1992, EPA issued a report on
Contracts Management at EPA; Managing Our Mission;
Recommendations of the Standing Committee on Contracts
Management, with actions to improve EPA's contract management.
The Standing Committee on Contracts Management, with top
level staff from every office, oversees the implementation of
changes. Under the leadership of Administrator Carol Browner,
the Agency began to define the problems more broadly in terms of
accountable extramural resource management and develop ways to
integrate the importance of managing resources into EPA's
environmental mission. By June 1993, the scope of the Standing
Committee on Contracts Management was expanded to all extramural
resources, and was renamed the Resource Management Committee.
Administrator Browner made management, accountability and
discipline major priorities that support her determination to
make sound management a cornerstone of her Administration. She
developed several initiatives to assure that the Agency's
approach to these problems is strategic rather than piecemeal,
and address not only contracting, but all extramural resources
and financial management.
The effort to change the Agency's approach to managing
resources has begun to take effect. While the improvements were
noted favorably by outside oversight groups, the process of
change has been difficult. There are concerns about consistent
management involvement, communication problems, longer processing
times, and the need to balance stewardship of EPA's fiscal
resources with ability to effectively protect the environment.
AFFECTED SECTOR
EPA staff in every office have been affected by EPA's
resource management deficiencies. Members of Congress have
indicated that the seriousness of these problems have affected
their confidence in EPA's ability to manage its budget and
administer cabinet status responsibilities.
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ER 3
GOALS and MILESTONES
One of the Administrator's initiatives was to hold a series
of Agency focus groups to improve communication between EPA's
mission staff and resource management staff. The idea for the
focus groups arose from a meeting of the Administrator with EPA
Office Directors. There was concern that, although the Agency
was dedicating much effort to improving contracts management,
there were still many EPA staff whose thoughts and ideas were not
heard. The focus groups were meant to be a listening exercise as
well as provide feedback on the status of EPA's efforts to
improve contracts management.
In April 1993, the Administrator's staff formed an
Extramural Resource Focus Group Steering Committee to develop the
process and oversee the implementation of the groups.
The results of the group's work, with recommended solutions
to identified problems, is to be reported to the Administrator by
October 1993. A report will also be made to the Resource
Management Committee as feedback on how the actions to improve
resource management are taking effect, and what additional
measures are needed.
Because of the comprehensive impact on EPA, the focus groups
on extramural resources are designed to get input from the widest
range of staff, including diverse geographic, cultural, career
and other perspectives, to provide the most inclusive views of
the issues.
The first series of focus groups held in late June 1993
consisted of working level staff to identify operational problems
and opportunities for improvements in contracts and grants. The
groups were organized by their professional positions; e.g.,
Contracting Officers, Grants Managers, Work Assignment Managers;
in the Programs and Regions, along with their supervisors.
The focus group team leaders reported preliminary findings
to EPA's Senior Leadership Council on July 27, 1993. There was
general agreement with the findings, along with more comments
that fit into the major categories of concerns.
In addition, one external focus group of contractors and one
of grantees is being held by outside non-profit groups to gather
ideas from these communities on how to improve EPA's resource
management.
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ER 4
CURRENT STATE
The first round of Extramural Resource Focus Groups resulted
in over 60 comments regarding contracts and grants. 16 comments
were received through NPR Suggestion Forms. In addition to
widespread concern about the need for resources to reduce
reliance on contractors and improve contract oversight, the
comments fall into the following 3 categories:
1. Lack of Agency management consistency in application of
extramural resources practices is leading to confusion at
staff level.
2. Need to deal with concerns about perceived high risks in
managing contracts and grants to improve efficiency.
3. Adequate contract process, training and guidance are needed
to continuously improve contracts management.
The comments on need for Agency management consistency and
atmosphere of fear were not identified as such in the 1992
Standing Committee on Contracts report. These comments reflect a
broad perspective of EPA's highly leveraged status, and require
management attention.
TARGET/ACTION CATEGORIES
Action/Initiative 1:
Form a representative focus group of EPA Office Directors
and Division Directors, with representative participation
from the first focus groups, to:
recommend solutions to the first two findings, and
- reconcile internal and external perspectives of EPA's
contract management, after reviewing the external
National Performance Review report on EPA contracts
management, which emphasizes accountability, cost control
and competition.
Action/Initiative 2:
Because the third finding concerns development of tools and
lends itself to TQM processes, refer the comments to the
already ongoing efforts in the areas of streamlining the
process, improving training and developing "how-to"
guidance.
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£R 5
Implementation:
Who: Extramural Resources Focus Group Steering Committee
When:
Managers Focus Group meeting: 8-9/93
Report Out to: 9-10/93
- EPA Office Directors
Resource Management Committee
The Administrator
National Performance Review
Barriers:
Although the process of change in how extramural resources
are managed involves many large and small changes in EPA's
organizational functions, EPA has already begun to break
down the resistance to change. The Agency's resolution to
improve will motivate the search for solutions.
Cost:
Because the Administrator, as well as EPA's Congressional
oversight groups, have identified as extremely essential the
need to improve EPA's resource management, it is clear that
the Agency must institutionalize changes in the way it does
business. Investment for this vital effort is already being
made through reallocation of resources and increased
management and staff attention to these issues.
Success:
The work of the focus groups in itself is a means to
evaluate the mid-term success of the effort to make
comprehensive, systemic changes in the Agency's management
of extramural resources.
REFERENCES
The June 1992 Contracts Management at EPA: Managing Our
Mission; Recommendations of the Standing Committee on Contracts
Management and Monthly Status Reports are available in EPA
libraries. For further information on the recommendations or the
Resource Management Committee, please contact the Committee staff
at (202) 260-9248.
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REPORT OF THE
FINANCIAL MANAGEMENT
TEAM
NATIONAL
PERFORMANCE
REVIEW
-------
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FM
FINANCIAL MANAGEMENT TEAM
Barbara Elkus, OW, Team Leader
Stephen Perkins, Region 1, Facilitator
Barbara Artis, OARM
Sheldon (Ted) Brandt, Region 6
Marilyn Smith Church, OPPE
Carol A. Cowgill, OGC
Debbie Dietrich, OSWER
Sheila Pagan, OARM
Michael Kosakowski, OSWER
Paul Kraman, OW
Jim Newsom, Region 3
Barbara Niebauer, Region 8
Richard Phillips, OARM
Joseph Powers, OPPTS
Andy Privee, OPPTS
Vonda Robinson, OAR
Marilyn Sabadaszka, Region 5
Benjamin Smith, OW
Dale Turner, OAR (Ann Arbor)
Octavia Wesley, OAR
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FM 2
FINANCIAL MANAGEMENT
EXECUTIVE SUMMARY
Over the years, insufficient time, attention, and funds
have been available to attain the best management of current
year funds. The complexity of the various financial
management systems and processes has aggravated this
situation. Among EPA managers, there is a wide disparity in
expertise and in attention paid to financial management as
well as a tendency to focus on budgeting for future years
rather than on the management of current funds.
The Financial Management Team interviewed over 100 Agency
staff and managers to identify barriers to effective financial
management and to develop initiatives to remove those
barriers. Implementing the initiatives presented in this
paper will help to achieve the Team's vision: The Agency has
a sound, flexible, user friendly, and readily accessible
financial management process which ensures that EPA directs
resources in ways that maximize achievement of the Agency's
mission.
There are three Target/Action Categories, and nine
initiatives:
Target/Action Category #1: Increase Flexibility With
Accountab i1ity
Initiative #1: Flexibility in Ceilings.
Establish a reinvention lab (pilot) where one or more
organizational units are freed from the normal operating
constraints (e.g. FTE, travel, administrative expense,
ceilings, and quarterly allowances).
Initiative #2: Establish a Collaborative Planning Process.
Substantially decrease the time between passage of the
Agency's budget and the time that programs receive their
funding targets, with any "taps" taken prior to funds being
disbursed. All appropriate parties participate in an open
program planning process.
Initiative #3: Automatically Recertify Multi-Year Funds.
Automatically recertify multi-year funds for expenditure in
the second or subsequent years.
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FM 3
Initiative #4: Flexibility at OMB/Congress.
Investigate with OMB and Congressional staff ways to
eliminate the various funding ceiling categories, limit
subappropriation restrictions, and reduce Congressional
earmarking of funds.
Target/Action Cateqorv#2: Increase the Importance of
Financial Management
Initiative #5: Clarify and Explain the Process.
Increase managers' awareness of financial management issues,
systems, and processes. Clarify roles, responsibilities and
processes, and disseminate the information in a variety of
plain English, user-friendly forms.
Initiative #6: Create Incentives for Good Financial Management.
Create incentives for managers to benefit from prudent
financial management practices.
Initiative #7: Review Organizational Structure and Career
Paths for Financial Management Functions.
Break down barriers between budget and financial management
responsibilities. Review career paths and the grade
structure for financial management staff and make equivalent
to budget formulation staff.
Target/Action Category #3; Improve Financial Management
Information Systems
Initiative #8: Short-Term Improvements in IFMS.
Implement a number of short-term actions to increase the
access of both staff and managers to the system. Develop
and administer a customer survey to determine unmet needs.
Initiative #9: Long-Term Improvements in Financial
Management Information Systems.
Develop and maintain a financial management system that
efficiently collects, processes, tracks, and reports
financial information in a way that optimizes utility for
its users and uses, but is not dependent on, contractor
employees. The system is readily accessible to all Agency
managers.
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FM 4
FINANCIAL MANAGEMENT
VISION;
The Agency has a sound, flexible, user friendly, and readily
accessible financial management process which ensures that EPA
directs resources in ways that maximize achievement of the
Agency's mission.
BACKGROUND;
Financial management is part of a process that includes strategic
planning, budget formulation and execution, and sound accounting
procedures. The financial management team addressed issues
related to the management of current year funds. Although the
past decade has generated a proliferation of statutory mandates,
appropriations have not kept pace with these requirements.
Nevertheless, Agency personnel have generally maximized results
in the attainment of a wide variety of important environmental
objectives. The focus of this report is to define some
improvement opportunities particularly focused on giving
managers the appropriate authority, incentive, and tools to
better manage and account for their resources.
The Financial Management Team included 20 EPA staff representing
all of the major headquarters program offices and four regions.
Several have had experience in financial management in other
agencies. Interviews were conducted with over 100 EPA staff.
While not thorough in its analytical methods, the team feels that
a number of important issues have been identified and clarified
in the peer review process. Additional analysis to more
thoroughly analyze the situation and barriers may be appropriate.
CURRENT STATE;
Over the years, insufficient time, attention, and resources have
been available to perform the necessary management of current
year expenditures. The complexity of EPA's organizational
structure, the various systems, variations in appropriations and
allocation processes, and changing procedures and definitions
complicate efforts to effectively manage funds. Although some
managers devote substantial time and attention to financial
management, many delegate such responsibilities solely to their
administrative support staff. Financial management expertise is
largely confined to staff and managers who directly engage in
financial management, with few incentives or opportunities for
program managers to acquire essential financial skills. Many
managers focus more on out-year budget formulation to obtain
resources and less on the execution of the current year operating
plans, which are often considered mundane. Knowledge about
financial management, systems, processes, accounts, etc., varies
widely among program managers.
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FM 5
Several aspects of the current financial system create barriers
to effective financial management of current year funds:
1) Lack of certainty in funding levels. "Taps" in contract and
administrative expense funds can occur at any time of the year.
To avoid the disruption these unpredictable "taps" can cause,
managers may attempt to accelerate the spending of available
funds. Conversely, funds that are suddenly released at the end
of the fiscal year may be "parked" (e.g., added to a
level-of-effort contract) until they can be spent. Because these
funds do not always find their way back into the coming year's
planning process, less than efficient funding can occur. Delays
in developing and providing budget levels early in the fiscal
year also lead to uncertainty.
2) Lack of flexibility in spending. The many individual (and
sometimes duplicative) ceilings and quarterly allowances hamper a
manager's ability to efficiently meet program goals.
3) End of year spending. Several factors lead to a large number
of funding actions in the fourth quarter which swamp the system.
First, quarterly allocations force incremental funding of
contracts, requiring that modifications be pushed to year-end.
Secondly, uncertainty in funding levels until late in the year
leads to a flurry of activity to get the funds obligated before
the close of the fiscal year. This leaves little time available
to analyze the cost effectiveness of alternatives. Lastly,
pressure to spend available funds and limitations (including
cut-off dates) on funding mechanisms late in the fiscal year
further compound the problem.
4) Multi-year planning is difficult. For example, funding for
large pieces of equipment over two years is difficult because of
the risk of not receiving carry-over funds and the difficulty in
partially funding such procurements.
5) Availability of data is limited. Managers often do not have
access to sufficient information about their operating plan to
make the best funding decisions due to the limits of the various
systems and lack of understanding of data in the system.
6) Career Development Limitations. Generally, grade levels for
staff doing financial management are lower than those for budget
formulation staff, another indication of the perception that
these jobs are of lower importance. In order to get promotions,
staff move from financial management to budget formulation.
In addition to these barriers, there are different issues in
offices with growing or fully-funded programs than those where
programs are being phased down or where appropriations have not
been commensurate with mandates. This dichotomy has contributed
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FM 6
to situations where large sums are used to forward fund contracts
for the next fiscal year by some programs while in others, urgent
priorities, including court orders, cannot be funded.
IMPACTS;
Negative impacts include inadequately funded programs,
ineffective or unwise year-end spending due to unnecessary
forward funding of contracts, and expenditures on "nice to have"
items and projects. In some cases, programs cope by trading
among various categories of dollars. In underfunded programs,
there can be schedule delays with resultant inefficiency as key
projects are stopped and restarted in the next fiscal year. There
is frustration among staff because of the extra paperwork
involved in the stopping and starting of contractor work as well
as the difficulty in obtaining information. The Team believes
that across the Agency a measurable percentage of the Agency's
budget may not be spent on priority needs.
DESIRED STATE:
Barriers to effective financial management are removed, with more
emphasis placed on planning and achieving controlled expenditures
of current year funds. There is a well understood and functional
link among strategic planning, budget formulation, and the
operating plan, with some staff common to all three processes in
program offices as well as the Office of Administration and
Resources Management (OARM) and the Office of Policy, Planning
and Evaluation (OPPE). Managers have a greater appreciation of
the financial management system and develop detailed financial
plans, including priorities for activities (developed early in
the fiscal year), which are communicated to all involved in
executing the plans. There is periodic monitoring of spending,
with a mechanism to link funding with results and a process to
redirect resources if priorities change. Managers, not just
administrative staff, are actively involved in this process.
Managers know as early in the fiscal year as possible what
resources they will have available, with taps at the
Administrator, Assistant Administrator(AA) or Regional
Administrator(RA) level taken early in the fiscal year.
Managers have at their disposal effective financial management
information systems which are easy to use, readily available, and
comprehensive. End of year spending levels decrease because more
funds are expended during the fiscal year, according to the
programs' needs. Resource management is evaluated at regular
intervals, with managers held accountable for the efficiency and
efficacy of expenditures. Managers demonstrating sound fiscal
management have increased flexibility to use funds to meet
program goals (e.g. moving funds among ceiling categories,
eliminating quarterly allowances, and recertifying carry-over
funds.)
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FM 7
TARGET/ACTION CATEGORIES;
Three Target/Action Categories are discussed below. These are 1)
Increase Flexibility With Accountability, 2) Increase the
Importance of Financial Management, and 3) Improve Financial
Management Information Systems. For each initiative under a
Target/Action Category there is a discussion of the initiative,
who should take action and when, the barriers to implementation,
and the potential costs. Since benefits and measures of success
are similar for all, they are discussed at the end of the paper.
TARGET/ACTION CATEGORY fl; INCREASE FLEXIBILITY WITH
ACCOUNTABILITY
Lack of flexibility in budget formulation and execution inhibits
effective resource management and leads to perverse incentives
and managers "gaming the system." The focus is often full
expenditure rather than effective expenditure. Because of
ceiling limitations, funds may be available for a lower priority
item which can be acquired under a certain account (e.g.,
contracts), but funds are not available for a higher priority
expenditure (e.g., computers for staff so that they can do the
work in-house). These constraints also limit the ability of
programs to use their funds most effectively (e.g., being unable
to purchase and operate videoconferencing equipment to save
travel funds). This lack of flexibility (along with other issues
discussed) causes excessive forward funding of contracts and the
overloading of grants, contracts, and procurement processes
during the fourth quarter of the fiscal year.
INITIATIVE #1: FLEXIBILITY IN CEILINGS
The Initiative; Establish a reinvention lab (pilot) where one or
more organizational units are freed from the normal ceiling
constraints (e.g. FTE/travel/administrative expenses,
intramural/extramural controls, quarterly allowances). This
pilot would run for at least two years in order to get the new
systems in place, allow the program to realize the benefits of
this flexibility, and evaluate the pilot. If this pilot
demonstrates feasibility, allocate to each office or program a
single block of funds to implement its management plan.
Who/When; The Senior Leadership Council should choose one or
more units (Offices or Divisions in the DC area or field
locations and, perhaps, one region) as pilots to receive a total
budget without any of the normal constraints. Such a pilot would
allow the Agency as a whole to remain within its ceilings as the
process is evaluated. If started very soon, this initiative
could be implemented in FY94 in at least one location. The
Assistant Administrator or Regional Administrator responsible for
the pilot office would be responsible for tracking the pilot,
and, in conjunction with OARM, evaluating the results.
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FM 8
Barriers: OMB and the Congress may object to this pilot because
a successful outcome might result in pressure to provide the
Agency with increased flexibility and fewer ceilings thereby
limiting their control over the way the Agency spends its funds.
Cost of Implementing; There will be some system development
costs to the pilot organization for tracking the block of funds
and associating the expenditures with program activities.
INITIATIVE #2: ESTABLISH A COLLABORATIVE PLANNING PROCESS
The Initiative; Establish a revised and collaborative planning
process within the Agency for determining operating plans and
quarterly allowances. This will provide program managers with
more flexibility in the timing of expenditures. This process
needs to start early in the fiscal year and needs to
substantially reduce the time between passage of the Agency's
appropriations and the time that programs receive their funding
targets, less any taps at the Administrator or AA/RA level. More
emphasis should be placed on developing realistic, prioritized
operating plans which are then communicated to all involved in
executing the plans. Schedule periodic reviews to evaluate and
modify the plans. In order to review the plans, develop criteria
for effective financial management. Using these criteria,
provide constructive feedback to each manager so that they can
continuously improve their performance in this area.
Who/When; This initiative could be implemented immediately but
there could be some lag in the availability of the data reports.
Interim reports could be developed by OARM and by program staff
for the current year planning, tracking, and plan modifications.
Barriers; There is likely to be resistance from program managers
to any formal review process. There may also be some resistance
from managers in the financial management community and managers
in programs to the more "open book" process envisioned.
Congressional approval of the Agency's operating plan could also
cause delays in providing funding targets.
Cost of Implementing; Low. Can be done in-house, with some
limited resources to develop additional reports. Increased
management involvement in the process should be more than repaid
by more focused and effective spending.
INITIATIVE #3: AUTOMATICALLY RRECERTIFY MULTI-YEAR FUNDS
The Initiative; Automatically recertify multi-year funds for
expenditure in the second or subsequent years to complete the
implementation of office and program management plans. The
proportion of funds recertified may be linked with the incentives
discussed in Initiative #6.
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FM 9
Who/When: In a July 8, 1993 memo, the Acting Assistant
Administrator for OARM stated that the Agency's policy for
FY93/94 will be to carry over all unobligated AC&C and R&D funds
for the programs continued use. If this new policy proves to be
successful, it should quickly become permanent Agency policy and
be expanded to include all relevant Agency appropriations.
Barriers; There may be some resistance, particularly in the
resource community, to these changes. Also, this would limit
funds available to be tapped for additional requirements to those
tapped at the beginning of the year. (See Initiative #2)
Cost of Implementing: Very low. Part of the Team's
recommendation regarding carryover funds was already adopted for
FY 93/94.
INITIATIVE |4: FLEXIBILITY AT OMB/CONGRESS
The Initiative: Limit the number of appropriations and ceilings.
Establish a revised, collaborative planning process between EPA
and OMB for the determination or elimination of quarterly fund
allocations to EPA. Request the Congress to consider
appropriations without sub-appropriation restrictions and
earmarking of funds. Eliminate differences in the various
appropriations (e.g., training is funded by both the
Administrative Expense and Extramural ceiling in the AC&C
appropriation, but only the Extramural portion of the Superfund
appropriation.)
Who/When; The Administrator or Assistant Administrator for OARM
should lead this initiative. Staff support from OARM will be
required to develop and present detailed options and to develop
and implement necessary modifications to EPA financial systems to
accommodate these changes.
Barriers; OMB and the Congress may be reluctant to make such
fundamental changes to the Agency budget structure.
Cost of Implementing; Low cost, but high investment of energy to
address these issues.
TARGET/ACTION CATEGORY *2; INCREASE THE IMPORTANCE OF
FINANCIAL MANAGEMENT
Elevate financial management and associated administrative
functions to the same level of importance as program activities,
Increase managers' understanding of and appreciation for good
financial management. Remove barriers to managers' involvement
in financial management.
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FM 10
INITIATIVE #5: CLARIFY AMD EXPLAIN THE PROCESS
The Initiative; Increase managers' awareness of financial
management issues, systems, and processes. Clarify roles and
responsibilities of all levels in the financial management chain,
in both the financial management staff as well as in program
staff. Insure that this information is widely disseminated in a
"plain English" format, such as a financial management primer,
training modules, and interactive computer systems. Include
experience in financial management as a key factor in selection
of supervisors and managers.
Who/When; A workgroup of staff and managers representing OARM,
the program financial management staff, program managers, and the
regions should compile available information and clarify gaps in
information as well as policies and procedures. The Resource
Management Committee may be able to provide assistance. The EPA
Institute should have the lead to work with this group to
assemble the material in formats that are easy to use by Agency
personnel.
Barriers; To the extent that managers do not perceive financial
management to be a high priority, it will be difficult to get
their support for becoming more informed about, and more involved
in the financial management of their organization.
Cost of Implementing; Low. Can be done in-house, with workgroup
and some OARM and program resources to develop methods of
disseminating information. Some resources will be needed to
develop customized interactive computer training.
INITIATIVE #6: CREATE INCENTIVES FOR GOOD FINANCIAL MANAGEMENT
The Initiative; Create personal and programmatic incentives for
managers who practice prudent financial management practices.
These incentives may include 1) personal awards, 2) additional
program funding, and 3) having fewer or no ceiling limitations
(as discussed in Initiative #1).
Who/When; The same workgroup mentioned in Initiative #5 could be
tasked with the development of an incentive program. Work should
begin early in FY94 to take advantage of incentives that may
affect year-end spending.
Barriers; Some may feel that this is part of management's job
and should not require a specific incentives program. Also,
funding may be required to implement the system, depending upon
the specific recommendations.
Cost of Implementing; Can be done in-house, with a workgroup.
Depending upon recommendations, may require shifting of resources
or additional funding.
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FM 11
INITIATIVE #7: REVIEW ORGANIZATIONAL STRUCTURE AND CAREER PATHS
FOR FINANCIAL MANAGEMENT FUNCTIONS
The Initiative: Break down barriers between budget and financial
management responsibilities, and review the grade structure for
financial management functions. Traditionally, these positions
have not been classified as high as comparable budget positions.
Also, review the criteria used to assign staff to the various job
series and determine any training needs for financial management
staff to continue to advance. Encourage career paths which
include experience in both financial management and budget
formulation. Also, encourage rotational assignments by program
staff to financial management positions and vice versa so that
there is a better understanding of the needs and responsibilities
of these two groups.
Who/When: The Office of Human Resources Management, working with
the Comptroller, should undertake a review of the grade and
classification structure for financial management positions and
develop options for a one or two year program for staff which
would include a wide variety of financial and budget tasks. This
initiative could begin immediately, depending upon resource
availability. All offices should evaluate the organizational
hierarchy and develop options to encourage equity between
financial management and budget staff. This evaluation should
include the identification of opportunities for rotational
assignments.
Barriers; Current requirements to reduce staff as well as
specific reductions at the higher grade levels create a
significant barrier to this initiative. Additional funding may
be required to support any increase in grades. Existing 0PM
requirements for the various job classifications will also impede
efforts to encourage breadth of experience.
Cost of Implementing; Can be done in-house, with a workgroup.
Depending upon recommendations, may require shifting of resources
or additional funding.
TARGET/ACTION CATEGORY »3; IMPROVE FINANCIAL MANAGEMENT
INFORMATION SYSTEMS
The Agency relies on a system of sometimes incompatible,
contractor owned and/or maintained computer systems to store,
process, and retrieve financial data. There is a proliferation
of information systems within the Agency (including planning,
budget, finance, property, program accomplishment) that are not
linked in a way that permits managers to use information in
making sound program and financial decisions. Data input is
often duplicated and information input into multiple systems
often cannot be reconciled.
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FM 12
INITIATIVE #8: SHORT-TERM IMPROVEMENTS IN IFMS
The Initiative; Implement a number of short-term actions to
increase access to the current system. 1) Improve training, both
for staff and managers. Also, increase access to data by working
with users to set short-term goals for defining data needs and
developing more useful reports. 2) Improve communication to all
potential users, including managers, about available services
such as training and user groups. Evaluate a number of
communication methods (e.g., do not assume that everyone has
access to E-MAIL). 3) Conduct periodic customer surveys (via
written questionnaires to current and potential users, especially
managers) and regular meetings of focus groups composed of system
developers and users in the program offices.
Who/When: As soon as possible, the Office of Administration and
Resource Management should develop additional training,
investigate options for increased communication, and develop
customer surveys. The EPA Institute may be a resource to assist
in training development.
Barriers: Many managers have little interest in financial
management and, thus, may be unwilling to devote resources to
improving the utility of IFMS or other financial management
systems. There are many stakeholders with a vested interest in
the current system which was designed to provide Agency level
data for external reporting, rather than data needed by
individual programs.
Cost of Implementing; There may be some costs involved,
particularly in the development of additional training and in the
development and administration of the customer surveys.
INITIATIVE #9: IMPROVED FINANCIAL MANAGEMENT INFORMATION SYSTEM
The Initiative; Develop a system that continues to meet both the
Agency's legal accounting requirements and provides the
additional flexibility that program managers require to perform
good financial management. The system aiust efficiently collect,
process, track, and report financial information in a way that
optimizes utility for all users in the financial process.
Utilization of contractors may remain essential to the process,
but it is important to maintain control of, and expertise in the
system within the Agency.
Develop the system based on uniform global guidelines to assure
data compatibility and comparability and require adherence to
these guidelines. Allow data from program systems to be
summarized and linked to an aggregate system. Output options
must be user friendly and available in hard copy or directly from
PC applications so that managers have greater access to pertinent
financial data. Data collected from the customer surveys and
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FM 13
focus groups discussed in Initiative #8 is critical to the
effective design of the new or revised system. Additional input
could be obtained through an evaluation of one or more systems
currently operating in other Federal Agencies.
The following are three possible implementation options:
1) Continue to improve IFMS with renewed emphasis on
linkage to other systems, user interface (especially
with program managers) and output needs;
2) Design a new, thoroughly planned custom system,
preferably developed in-house with qualified new EPA
staff; and
3) Purchase another "off-the-shelf" software package that
can be modified and maintained by EPA staff.
Who/When: First, an internal workgroup of representatives from
the financial, information management and program communities
should evaluate the three options and recommend the best to the
Administrator. OARM should have the lead in developing the
chosen option, with continued input from the user community. A
process to quickly resolve any issues that arise must also be in
place. The workgroup evaluation should happen early in FY94 but
the development or revision of the system may take several years.
Barriers; There is no "quick fix" for this problem. There are
many stake holders and many with a vested interest in the current
systems. The integration of program subsystems may lead to
resistance from the current owners of those systems because they
may fear loss of control. Since some program managers do not see
the need to have such data readily available, there may not be
support for the potentially large expenditures and time required
to achieve the goal. The current dependence on contractor
support may hamper the Agency's ability to develop a new/revised
system because essential expertise is outside the Agency.
Cost to Implement; The cost to revise the current system or
develop a new system is likely to be large. To date, the Agency
has spent about $10-$15 million on the development of IFMS. In
FY92, a $2 million cut at the beginning of the fiscal year slowed
additional planned development and created some start-up problems
when funds became available later in the year. It is difficult
to estimate the costs for this initiative before the options are
evaluated, but an estimate of $10 - $15 million over 3 to 5 years
seems reasonable.
BENEFITS
The financial management improvements recommended in this report
will increase the Agency's ability to direct its limited
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FM 14
resources to the most critical environmental priorities. There
will be a better link between strategic planning, budget
formulation and budget execution, as well as an increased ability
to evaluate spending against the budget and adjust future budgets
as necessary. Managers will understand financial management, be
involved in the management of their funds, and be able to assure
that funds are expended in a cost-effective manner on priority
projects. Increasing flexibility will empower managers to seek
creative and innovative ways to maximize resources and to realize
efficiencies in the overall management of their programs. By
more effectively targeting the Agency's resources on key
environmental priorities, some resources may become available to
fund additional projects.
MEASURES OF SUCCESS
Qualitative Measures;
1) The ability of the Agency to direct resources to the most
pressing environmental problems.
2) Effective obligation of multi-year funds, but not
necessarily in the first year of availability.
3) Management accountability based on real program
accomplishments as specified in the office or program
management plan.
Quantitative Measures;
4) There is an increase in the number of managers who have
control of their budgets and are routinely involved in
financial management planning and review of spending.
5) There is a steady, planned flow of obligations and outlays
throughout the entire fiscal year as well as a significant
decrease in end-of-year spending activity.
6) An integrated financial management system will provide
real-time data needed for reporting requirements, day-to-day
program operations, and other managerial functions.
7) There is a decrease in the resources required for data entry
and reconciliation of data in subsystems because of clearer
data requirements and the elimination of redundant systems.
8) There is a decrease in FMFIA vulnerability in financial
management areas throughout the Agency.
9) There is a decrease in long-term unliquidated obligations.
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REPORT OF THE
INTERGOVERNMENTAL
PARTNERSHIPS
TEAM
NATIONAL
PERFORMANCE
REVIEW
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IP
INTERGOVERNMENTAL PARTNERSHIPS
August 6, 1993
Executive Summary
In the past decade, there has been a dramatic increase in number of
federally mandated environmental programs that state, tribal, and
local governments must implement. With numerous competing
responsibilities, many states, tribal, and local governments find
themselves hard pressed to meet environmental requirements.
EPA needs to build the capacity of state, tribal, and local
governments to manage and finance the programs essential to meet
environmental goals. Processes that are needlessly complex and
resource intensive need to be streamlined. Barriers to innovative
technology and cost-effective regional solutions need to be reduced
and eventually eliminated. EPA staff assigned to largely oversight
roles should be redirected to providing managerial, financial, and
technical assistance to state, tribal, and local environmental
authorities.
The following initiatives should help "reinvent" the way EPA does
business with EPA's intergovernmental partners. Specifically, the
initiatives are designed to encourage state, tribal, and local
governments to set priorities based on risk; promote innovative
technical, financial, and managerial approaches to meeting
environmental goals; replace confrontation with a new spirit of
collaboration; simplify environmental rules and regulations; and
build the infrastructure necessary for the future.
Two decades of operating in a command-and-control mode have created
a culture that can not be changed quickly. The initiatives
proposed here would experiment with ways to make some difficult
transitions in roles and long-standing policies. Depending upon
the results, these pilots could provide the basis for more
effective intergovernmental partnerships.
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IP
INTERGOVERNMENTAL PARTNERSHIPS INITIATIVES
Address Multimedia Priorities: New York State Pilot IP 3
Target Greatest Risks: Commonwealth of Massachusetts IP 4
Determine Priorities for New England Communities IP 5
Provide Flexibility for Risk-Based Priorities:
Ohio Pilot IP 6
Encourage Innovative Approaches to Water Quality Issues IP 7
Streamline State Review of Water Treatment Technologies IP 8
Create New Capital with Partners Rebuilding America IP 9
Foster Regional Bond Banks to Finance Infrastructure IP 10
Facilitate Restoration of Contaminated Properties IP 11
Promote State/EPA Dialogue on Nonpoint Source Program IP 12
Build Tribal Partnerships IP 13
Convene Regulatory Revision Task Force IP 14
Ensure Input into Regulatory Development Process IP 15
Streamline Reporting for Emergency Planning IP 16
Promote a Network of "Data Highways" IP 17
Develop a Learning-Based System: Wastewater Pilot IP 18
Build Multimedia Training Centers IP 19
Provide Access to Existing Training Resources IP 20
Increase Outreach with Volunteers and
Storefront Offices IP 21
Promote Jobs and Small Environmental Businesses IP 22
Build Tribal Capacity IP 23
Interagency Cooperation to "Empower" Tribes IP 24
Sponsor Charrettes to Advise Local Governments IP 25
Promote Consensus Building and Alternative Dispute
Resolution IP 26
List of Task Force Members IP 27
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IP 3
ADDRESS MULTIMEDIA PRIORITIES: NEW YORK STATE PILOT
WHAT:
In this project, EPA will work with New York State to conduct
multimedia inspections, permitting, and enforcement actions
directed toward the most significant sources to achieve greater
risk reduction and pollution prevention.
WHO:
This project will involve EPA (Region 2, OAR/OW/OSWER/OE) and New
York State training and compliance coordinators for the various
programs. In addition, representatives from different regions,
NEIC, industry, academia, environmental interests, and associations
(such as STAPPA/ALAPCO) will be involved.
WHEN:
This project has three stages. The first consists of developing a
multimedia approach to inspections and training staff. New York
State has already developed a multimedia inspection protocol and
has requested assistance from EPA in training. The second stage
will involve evaluation of the multimedia approach, beginning
during the 1993 inspection season and continuing through 1994. The
final stage will transfer these approaches to other states.
BARRIERS:
Among the barriers are the entrenchment of media-specific programs
and staff resistance; need for cross-cutting offices or committees
to overcome organizational barriers; the complexity of existing
regulations and training inspectors; and lack of flexibility in EPA
and state regulations. Understanding of these and additional
barriers will be refined during the second stage.
COSTS: Not available at this time.
BENEFITS:
By taking a multimedia approach, true reductions in pollutant
loadings can be achieved instead of shifting pollutants among
media. By examining a facility comprehensively, the inspector and
facility manager can identify the problems that pose the greatest
risks. A coordinated enforcement approach would reduce the number
of inspections and conflicting reports. Moreover,it should foster a
greater sense of partnership as environmental regulators understand
the perspectives of facility managers better.
EVALUATION CRITERIA:
Evaluation criteria will include the effectiveness of the training;
the success of the multimedia inspection program; adoption of these
programs in other states; and pollution prevention measures taken.
CONTACT: Mark Siegler, SSCD/OAR (703-308-8673).
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IP 4
TARGET GREATEST RISKS: MASSACHUSETTS
WHAT:
In this pilot project, the Commonwealth of Massachusetts will be
working with Region 1 to provide greater flexibility to target the
highest priority facilities for inspection and enforcement actions.
The project will include developing improved protocols for the
inspection of facilities under the Clean Air Act, Clean Water Act,
and Resource Conservation and Recovery Act. In addition, this
initiative will develop new parameters and systems for reporting
inspection and enforcement data and measures of success.
WHO:
Program staff and attorneys from Region 1 and the Commonwealth of
Massachusetts.
WHEN:
The current schedule calls for piloting the protocols for
inspection of facilities in fiscal year 1994. The time frame for
the development of new parameters and systems for reporting
inspection and enforcement data will follow.
BARRIERS:
It will be difficult to reconcile the inspection requirements in
the three programs. In addition, there have been long-standing
compatibility and data systems problems with state reporting.
COSTS:
A rough estimate for the total state/federal FTE commitment is two
workyears, including facilitators. There are no contract dollars
required for this.
BENEFITS:
The project should improve the ability to do multimedia inspections
which would lead to improved compliance as well as to identifying
emission reduction possibilities. Improved reporting will also
focus managers more on environmental results.
EVALUATION CRITERIA:
Success will be measured by how well the protocols for inspection
of facilities worked in the pilot conducted in FY 1994 and the
extent to which they are adopted by Massachusetts and potentially
other states. In addition, success will be measured by the extent
the data reporting systems are improved from both EPA and the
state's perspectives.
CONTACT: Harley F. Laing, ORC, Region I (617-565-3432)
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IP
DETERMINE PRIORITIES FOR NEW ENGLAND COMMUNITIES
WHAT:
This initiative would identify the most significant environmental
mandates for communities in New England. It would assess the
financial capability of communities to implement competing mandates
as required by existing laws. Where a community does not have
adequate financial capacity, the states and EPA will assist the
community in seeking alternative financing solutions. If that
fails, the states and EPA will consider environmental risk and
benefits in negotiating alternative schedules with the community.
WHO:
New Hampshire (lead State), other New England States, Region 1.
WHEN:
New Hampshire has already initiated the project. EPA will work
with New Hampshire and the other New England States to compile the
data on mandates and costs in the Spring of 1994.
BARRIERS:
Cost assumptions are uncertain although EPA will provide guidance
on consistency. If alternative schedules are necessary for some
communities, affected regional and headquarters programs and
attorneys are likely to resist. Also, conducting risk and cost
assessments for hundreds of communities may be difficult to do.
COSTS:
The initial costs will be moderate, involving mostly staff time at
the states and EPA, and $50,000 of contractor support to refine
cost estimates. It would also be beneficial to develop a data
management system to input the data. Contractor assistance to help
develop risk and benefit evaluations may also be needed.
BENEFITS:
The initial phase of this project will provide invaluable data to
the States and Region 1 on the true cost of environmental mandates
to communities in New England. If we have to negotiate alternative
schedules with some communities, it will demonstrate that all
levels of government can successfully work together to assure that
the greatest benefits can be attained for the dollars available.
EVALUATION CRITERIA:
The success of the first phase of this project will be judged on
the quality of the assessment of New England communities.
Ultimately, success will be judged on finding alternative financing
or negotiating schedules as needed.
CONTACT: David Fierra (617-565-3478)
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IP 6
PROVIDE FLEXIBILITY FOR RISK-BASED PRIORITIES: OHIO PILOT
WHAT:
With assistance from EPA and the State of Ohio, eight Ohio cities
including Columbus and Cleveland are going to conduct comparative
risk studies. Once the results are in, these cities will want
flexibility to address the greatest risks first. Over the next two
years, EPA will work closely with the state and those cities to
develop a process that provides for flexibility.
WHO:
OPPE/OW/OSWER/OAR/EPA; State of Ohio; Columbus, Cleveland, and six
other cities; industry, environmental, and citizen representatives;
academic experts; Congressional representatives; and other
interested parties. This effort may be broadened to include the New
England states and their communities as well as others which are
developing comparative risk assessments.
WHEN:
Over the next two years.
BARRIERS:
Many environmental statutes are very prescriptive and do not
provide for flexibility. EPA may lack the resources to revise
problematic regulations. Environmental groups may perceive that
efforts to provide flexibility will thwart achievement of national
environmental goals.
COSTS:
EPA has already committed $200,000 over 2 years for the risk
assessments. Another $250,000 could be used to develop a process
for providing greater flexibility.
BENEFITS:
The issue of unfunded mandates is becoming increasingly important.
EPA needs to pursue ways to accommodate local governments who can
not afford to comply with mandates within the existing compliance
schedules or for whom the costs of compliance are not justified by
the benefits that would be achieved.
EVALUATION CRITERIA:
Will EPA be able to be flexible and allow local governments to set
priorities and address problems in a cost-effective way? Are the
national environmental goals being met? Will Congress agree to
provide authority, if necessary, to balance costs and benefits and
consider alternative strategies to achieving environmental goals?
CONTACT: Mike Pompilli (614-645-6228)
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IP 7
ENCOURAGE INNOVATIVE APPROACHES TO WATER QUALITY ISSUES
WHAT:
EPA needs to provide flexibility to states and water resource
management authorities to achieve water quality objectives by
allowing trading and other innovative approaches. This initiative
is designed to (1) further our understanding of the role for
economic incentives and other environmental innovations in
achieving water quality objectives, and (2) advance their use at
the local, state, and Regional levels.
WHO:
OW/OPPE/EPA, state, tribal, and local officials; industrial,
academic, environmental, and citizen representatives; Congressional
officials.
WHEN:
Over the next year, EPA will work with state and local governments
to locate potential waterbodies for analyzing the feasibility of
trading and develop a trading program. As additional trading
programs develop, EPA will promote them by providing fact sheets,
sponsoring workshops, and other means. Over the next two years,
EPA will develop guidance to states, tribes, and water resource
management authorities in the use of non-traditional strategies.
Finally, EPA will encourage inclusion of appropriate language in
the Clean Water Act.
BARRIERS:
Many states and water resource management authorities may be
reluctant to use economic incentives, trading, or other innovative
approaches. The Clean Water Act is silent on the use of these
approaches. Developing the water quality information necessary for
trading can be resource intensive.
COSTS: To be determined.
BENEFITS:
The costs of achieving water quality goals by reductions from
uncontrolled or non-traditional sources are far less than trying to
ratchet down on conventional sources. With creative, less costly
approaches, water quality goals should be met far sooner.
EVALUATION CRITERIA:
Training EPA, state, tribal, and local staff in trading and
economic issues; pilot projects; amendments to Clean Water Act.
CONTACT: Richard Kashmanian, OPPE (202-260-5363)
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STREAMLINE STATE REVIEW OF WATER TREATMENT TECHNOLOGIES
WHAT:
This initiative will build upon ongoing work to develop both
drinking water and wastewater technology design review protocols.
These protocols will establish common frameworks between States so
that technologies can be introduced across borders without
conflicting requirements.
WHO:
Office of Ground Water and Drinking Water; Office of Wastewater
Enforcement and Compliance; state and local governments; and
equipment suppliers will be the primary participants.
WHEN:
The Office of Water (OW) has been working for several years on the
development of some design review protocols. These efforts will be
accelerated. Once the protocols have been reviewed, EPA will engage
in training for the state engineers, local officials, and other
parties.
BARRIERS:
The major barrier to the success of this effort will be the deeply
rooted conservatism of many State design review engineers.
COSTS:
The costs are about $500,000 over 2 years to help develop consensus
protocols, provide incentives to states to adopt such protocols,
and for training.
BENEFITS:
This project, if successful, would yield enormous benefits.
Potentially thousands of small drinking water systems and
wastewater systems would be able to utilize lower cost technologies
to comply with drinking water and wastewater treatment regulations.
Cumulative cost savings could easily be hundreds of millions of
dollars. More water systems would be capable of complying with
drinking water standards leading to substantial public health
benefits as the exposure of thousands of individuals to drinking
water contamination is reduced.
EVALUATION CRITERIA:
This is an ongoing, long-term effort. We would hope to see
meaningful changes in state design review practices starting in
about 2 years. Success would be measured by the number of states
which adopt a revised and improved drinking water or wastewater
technology design review protocol.
CONTACTS: Peter E. Shanaghan, OGWDW, 202-260-5813, and Sylvia Bell,
OWEC, 202- 260-7255.
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IP 9
CREATE NEW CAPITAL WITH PARTNERS REBUILDING AMERICA
WHAT:
American communities face a severe shortfall in funding the federal
and state mandates for environmental services and infrastructure.
EPA's Partners Rebuilding America initiative will remove regulatory
impediments to private investment in municipal wastewater treatment
plants and allow communities to take advantage of a potential new
source of capital to meet environmental needs.
WHO:
The partnership would include participating municipalities and
sewer districts, private sector investors, and the financial
market. OW would have the lead for EPA.
WHEN:
EPA is preparing for public meetings to facilitate broad public
involvement in regulatory and policy changes. Because our
constituents have advised us to proceed expeditiously and because
of the critical need for additional wastewater infrastructure
capital we intend to begin the public participation process in
early fall of 1993.
BARRIERS:
EPA regulatory and procedural impediments will be addressed by an
internal work group. There are no statutory impediments.
COSTS:
The Agency will spend approximately $100,000 to support public
meetings and to research the potential market and benefits.
BENEFITS:
Thousands of American communities with little hope for State
Revolving Fund loans may replace, expand, or upgrade wastewater
treatment works, preserving the infrastructure that made possible
our progress toward clean water, and supporting our growing
economy. Proceeds can be used for other environmental or high
priority needs such as increased police protection or better
education. States gain new flexibility to use State Revolving
Funds for high priority pollution challenges such as storm water
runoff, combined sewer overflows, and non-point source pollution.
EVALUATION CRITERIA:
The number and dollar value of privatized wastewater treatment
plants, and the value to ecosystems of improved wastewater
treatment and other environmental initiatives undertaken.
Contacts: Ben Lesser (202-260-4060) and Michael Deane (202-260-
4060), both of OW.
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IP 10
FOSTER REGIONAL BOND BANKS TO FINANCE INFRASTRUCTURE
WHAT: Many small communities simply cannot afford to access the
capital markets to finance environmental facilities. Most states do
not have bond banks or other special environmental finance programs
to help small communities access the capital markets. This
initiative would create regional (multi-state) pooling mechanisms
provides low cost financing for the planning, design, construction,
replacement, and rehabilitation of drinking water, wastewater, and
solid waste facilities, and best management practices.
The regional bond banks would be federally-chartered to provide
finance assistance in at least two ways: (1) purchasing the debt
obligations of local communities using the proceeds from the bank's
bond sales, or (2) pooling several issues into one large issue and
selling it on behalf of the communities involved.
WHO:
The partnership envisioned would include the federal government,
participating states, participating local communities, the credit
markets, and the regional bond banks. EPA lead is OARM.
WHEN:
In the near-term, the first step is to complete a feasibility
analyses of the financial, legal, and institutional requirements
inherent in the creation of regional bond banks.
BARRIERS:
There is no precedent for establishing regional bond banks and it
would be necessary to fully examine all financial, legal and
institutional issues.
COSTS:
There would be no revenue loss to the U.S. government as a result
of the bond banks' debt issues since local communities already have
the authority to issue tax-exempt debt.
BENEFITS:
The significant cost advantages of regional bond banks lie with the
larger credit pools they create. Greater diversification from
pooling a large number of small issues improves the banks' credit
rating, lowering interest rates for participating communities. The
annual savings to a small system of an interest rate reduction of
1.5-2.5 percent amounts to $15,000-25,000 for each million dollars
of loan outstanding.
EVALUATION CRITERIA: The feasibility analysis successfully
identifies the key requirements to establish regional bond banks
and accurately specifies the steps necessary for implementation.
CONTACT: George Ames (202-260-1020) Of RMD/OARM/EPA.
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IP 11
FACILITATE RESTORATION OF CONTAMINATED PROPERTIES
WHAT:
Hundreds of potentially valuable properties in urban and former
industrial areas are not undergoing clean up or redevelopment for
fear that the site will later be declared a Superfund site. In this
pilot project in Elkhart, Indiana, Region 5 will provide technical
assistance and possible limits on future liability in order to
expedite the assessment and clean up of several of the city's
properties.
WHO:
EPA's Superfund program and Region 5; Elkhart, Indiana; State of
Indiana; developers, property owners, citizens, and other
interested groups.
WHEN:
Region 5 will begin working with Elkhart to assess the properties,
characterize the risks, and take removal actions, if necessary. EPA
Headquarters will be involved in policy discussions concerning what
liability protection EPA can provide for the city, developers, and
other parties. The pilot may begin as early as this fall.
BARRIERS:
The extent of protection from future liability under Superfund will
be a major issue for the developers. Whether EPA and those
interests can reach an agreed upon approach will be critical to the
success of the pilot.
COSTS:
The costs associated with EPA's technical assistance to Elkhart
will be outweighed by the potential savings of returning inner-city
properties to commercial or other purposes in a cost-effective way.
BENEFITS:
If this pilot is successful, millions if not billions of dollars
can be saved over time as properties are returned to productive use
faster and at far less cost than under the current Superfund
approach.
EVALUATION CRITERIA:
The success of the pilot will be measured in terms of how long it
takes to return the properties to commercial or other purposes and
at what cost, assuming that restored site meets acceptable health
and environmental goals.
CONTACT:
Judy Beck, Region 5 (312-353-9391).
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IP 12
PROMOTE STATE/EPA DIALOGUE ON NONPOINT SOURCE PROGRAM
WHAT:
This initiative is intended to reach agreement on improvements
needed in EPA's administration of the nonpoint source programs
(NSP) to attain better state nonpoint source programs and overall
long term improvement in water quality. An initial meeting of
managers and staff of the New England states and New York and New
Jersey and Regions 1 and 2 was held on July 8, 1993. At that
meeting barriers were identified and action plans developed to
address the most significant barriers.
WHO:
The New England States and Region 1; possibly New York, New Jersey
and Region 2.
BARRIERS:
The existing EPA culture and guidance, particularly relating to
competitive grants, inhibits states from performing long range
planning and integration of the NPS program into their overall
strategic plans. In addition, some states have not developed an
effective management institution of their NPS programs.
COSTS:
The only additional costs will be state and EPA staff time to
develop and follow through on action plans and monitor the desired
changes.
BENEFITS:
This effort should allow the states to better address the highest
priority water quality problems identified in their strategic plans
through better long-term planning for their NPS programs, more
effective integration of their programs and targeting their highest
priority resources. An additional benefit will be the saving of
staff time at the states in preparing and managing competitive
grants and at EPA in rating and ranking competitive grants. These
freed up resources will be used to significantly improve the
planning and management of the NPS programs and allow EPA to
provide better technical assistance to the States.
EVALUATION CRITERIA:
The states will be able to determine if the nonpoint source program
is administered by EPA in a way that furthers the goals in the
states' strategic plans. Also, the states will be able to assess
the administrative savings in managing the grant. EPA should be
able to assess the overall improvement of a state's nonpoint spurce
program. Region 1 will survey the states on the impact of changes
made to the program.
CONTACT: David Fierra (617-565-3478)
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IP 13
BUILD TRIBAL PARTNERSHIPS
WHAT:
Several models now exist for forging strong communication links and
partnerships for cooperative efforts across different government
levels to address environmental problems. Yet they often do not
include tribes or are in effect only in certain parts of the
country. A Task Force will explore how the models can be used with
tribes and will develop new approaches where none currently exist.
These may include establishing an EPA/Tribal Committee, building
tribal partnerships with states and/or locals, enhancing
communication within EPA on Indian issues, building electronic
networks for tribes, and instituting Regional Liaisons to work
directly with tribes.
WHO:
Representatives from EPA, tribal, state, and local governments.
WHEN:
Establish Tribal Partnerships Task Force in fall, 1993. Explore
successful models of partnerships and communications systems and
develop plan for expanding existing models and establishing new
models. Report recommendations by fall, 1994, then implement.
BARRIERS:
There are many tribes including some that are quite small with
limited resources. There is also a general lack of understanding
of Indian issues and EPA's responsibilities to tribes. Tribes will
be skeptical given feebleness of past efforts. State power
rivalries with tribes may hamper some efforts.
COSTS:
The task force may require 1-2 FTE and $25,000 travel costs. Costs
of implementing recommendations will be evaluated later.
BENEFITS:
A strong system of communications will allow tribes to learn from
each other what approaches work for them, encourage coalitions to
be formed, and help break down the barriers that prevent
cooperation. Solutions to environmental problems can be developed
quicker and more effectively and relationships will immeasurably
improved. Tribes will be better able to negotiate solutions to
environmental risks caused outside reservations. Tribal coalitions
and partnerships with other governments could lead to significant
economies of scale in solving environmental problems.
EVALUATION CRITERIA:
Have tribes become more articulate and effective in solving
environmental problems because of the improved communications and
partnerships? Is EPA more knowledgeable about tribal issues and
dealing more effectively with them?
CONTACT: Catherine Tunis, 202-260-2698
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IP 14
REGULATORY REVISION TASK FORCE
WHAT:
This initiative would convene state, tribal, and local officials to
determine what regulatory requirements interfere with achieving
environmental goals in a cost-effective and efficient manner. EPA
would identify the most significant regulatory problems and revise
them as appropriate. The task force may also identify needed
statutory changes.
WHO:
EPA (OPPE lead); State, tribal, and local officials; industrial,
environmental and citizen representatives; Congressional officials.
WHEN:
EPA could take advantage of national meetings of state and local
government associations (e.g., NGA, NLC, NACo, ICMA) and convene
meetings this fall. The project should result one or more
regulatory revision initiatives or legislative reform proposals by
next spring and become an on-going process, consistent with the
section 610 of the Regulatory Flexibility Act which requires rules
to reviewed within 10 years after promulgation.
BARRIERS:
Program offices will be reluctant to undertake revisions to
existing regulations when they are hard pressed to issue new ones,
often with statutory or court-ordered deadlines.
COSTS:
$200,000 over two years to support convening officials and analysis
of regulatory issues. Headquarters offices will need to direct
resources necessary to develop revised regulations.
BENEFITS:
Regulatory revisions could provide the flexibility that state,
tribal and local governments have been seeking to take innovative
approaches that meet environmental goals with fewer resources.
Millions of dollars could be saved annually, for example, by
allowing entities to find alternative ways to meet standards for
stream quality rather than installing expensive technologies
(Boulder, CO saved $15 million by taking alternative approaches to
improving Boulder Creek).
EVALUATION CRITERIA:
EPA could assess the effectiveness of revisions by comparing the
costs of compliance to the existing and revised regulations.
REFERENCES: Section 610 of Regulatory Flexibility Activities
CONTACT: Paul Lapsley (202-260-5480)
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IP 15
ENSURE INPUT INTO REGULATORY DEVELOPMENT PROCESS
WHAT:
The Regulatory Development Team is proposing that before developing
a new regulation senior managers consider the extent to which
state, tribal, and local governments should be involved. This
initiative is to explore alternative ways in which EPA can involve
state, tribal, and local governments in EPA's regulatory
development process and to pilot these approaches on three to five
rulemakings.
WHO:
EPA senior managers (OPPE lead); state, tribal, and local
government officials; environmental and industry groups; trade and
professional associations; and other interested parties.
WHEN:
In fall 1993, EPA will convene focus groups to analyze the existing
barriers to involving state, tribal and local government
representatives and develop ways to ensure they have opportunities
to have timely input. Three to five rulemakings will be selected to
pilot these approaches over the next two years.
BARRIERS:
EPA often finds itself short of time and resources necessary to
bring state, tribal, and local officials to Washington, D.C. or
other places for meetings. Environmental or industry groups may
threaten to sue EPA on procedural grounds if EPA does not strictly
follow the Administrative Procedures Act.
COSTS:
To support the focus groups and pilot projects, $150,000 would be
needed to identify participants, arrange for meetings, and provide
training to workgroup chairmen on the new techniques of involving
state, tribal, and local government representatives.
BENEFITS:
Over the past decade, EPA's regulations have placed a significant
burden on state, tribal and local governments to manage and finance
environmental programs. This initiative would help EPA understand
the impacts of various options and develop more flexible, cost-
effective regulations.
EVALUATION CRITERIA:
EPA can evaluate the degree to which participation in regulatory
development efforts by state, tribal, and local governments has
increased, especially in the pilot projects. EPA can also assess
the degree to which state, tribal, and local governments are able
to implement the requirements in a cost-effective way.
CONTACT: Maryann Froehlich (202-260-4034)
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IP 16
STREAMLINE REPORTING FOR EMERGENCY PLANNING
WHAT:
State, tribal, and local governments would work closely with
industry to define the usefulness of information required under
various authorities and attempt to streamline the information
reported. The pilot would specifically look at the burden to local
governments of storing and making use of this information and
propose ways to make the reports more "user friendly".
WHO:
EPA (OCEPP lead), state, tribal, and local officials, industry
representatives; Local Emergency Planning Committee (LEPC) members.
WHEN:
This project should begin in fiscal year 1994. Over a period of a
year, the pilot should assess the federal and state reporting
requirements on industry, which in turn must provide information
based on this to local government and LEPCs.
BARRIERS: To do a thorough project, there should be involvement
and cooperation from various offices in EPA and possibly other
government agencies as well (OSHA, DOT). This could mean a delay
in the time frames outlined.
COSTS:
Resources will need to be directed to States to conduct the pilots;
an estimated $500,000 over two years to conduct 5 pilots and
evaluate the results. EPA would need to allocate 2 FTE (HQ/Region)
to oversee the projects, analyze the results, and disseminate the
lessons learned from pilots.
BENEFITS:
Local, tribal, and state governments should be able to conduct
comprehensive emergency planning without being overburdened by
reports. Information from facilities should not duplicate other
reporting requirements and thus ease the burden on industry.
EVALUATION CRITERIA:
As part of the pilot, determine the extent to which reporting is
reduced and whether state and local governments are more easily
able to use the information received for emergency planning
purposes. To the extent possible, measure resource savings for
participating industries as well as state, tribal, and local
governments.
CONTACT: Sherry Fielding (202) 260-6174; David Speights (202) 260-
5338
REFERENCES: SARA - Title III, Clean Air Act Amendments, Oil
Pollution Act
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IP 17
PROMOTE A NETWORK OF "DATA HIGHWAYS"
WHAT:
Take advantage of the explosion of information highways and develop
user friendly technologies to access and exchange environmental
information among federal, state, tribal, local, and foreign
governments, the public and regulated communities.
WHO:
OIRM (lead), OPPE, OCEPA, OIA, OCEM, Regional Operations and
State/Local Relations Office
WHEN:
An intergovernmental task force would be convened in the next few
months to address key issues: cost-effective ways to build upon
existing networks (e.g., State/EPA Network for Data Sharing,
Internet/National Research Education Network (NREN), EPA's Online
Library System (OLS), Fedworld). Pilot projects would test
usefulness and access before development of data highways and
public access mechanisms.
BARRIERS:
Among the barriers are programmatic offices' reluctance to share
information; lack of investment in environmental and policy-
relevant data; lack of support to implement data integration work;
and cultural barriers to using information technology.
COSTS:
Task force would cost approximately $100,000. Implementation costs
depend upon the complexity of the pilot projects. [Several options
have been developed by OIRM] Baseline for a national program is
estimated at $4 million, would include public access to EPA data
via INTERNET, electronic bulletin board access to the inventory of
EPA services, products, holdings, and systems, and comply with
Federal Locator requirements.
BENEFITS:
Qualitatively, the proposed "data highway" would result in better
informed decision-makers and improved understanding of
environmental quality and relative risk issues by the public as
well as regulators. Would provide information for better risk-based
priority-setting and pollution prevention measures.
EVALUATION CRITERIA:
Flow of data over "highways" and environmental results. Paradigm
shift in managing resources, using environmental data to set
multimedia priorities in geographic regions and empowering state,
tribal and local governments.
REFERENCES:
The need for improved access to environmental data bases is well
documented (i.e., by OTA, GAO, Office of Science and Technology).
CONTACTS: Jacques Kapuscinski (703-235-5626), Emma McNamara (202-
260-1522)
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IP 18
DEVELOP A LEARNING-BASED SYSTEM: WASTEWATER TREATMENT PILOT
WHAT:
EPA's current "training" model is a classroom-style training
program focused on a single issue or media program. This initiative
would develop a more holistic learning process for wastewater
treatment operators to: (1) improve internal wastewater treatment
plant processes and (2) to work with their industrial users to
identify pollution prevention opportunities. The goal is an on-the-
job learning and performance support system (Learning, Information,
and Performance Support System or LIPPS) that is generally
available on the "technology highway".
WHO:
EPA (lead OARM), state, tribal and local government agencies; the
regulated industry; universities experimenting with learning
technologies; and other interested parties.
WHEN:
This proposed project will begin in the fall (FY 1994), assuming
resources are available. The project will inventory existing
training tools, identify the gaps, and build an integrated system
that is user friendly. The project will require approximately 2
years to complete.
BARRIERS:
Participants need to have access to computer systems and have
adequate training to use the new system effectively. The
information needs to be accurate and kept current or it will not be
credible.
COSTS:
Up to $500,000. If developed under a partnership arrangement with
a private sector cooperator, rents or royalties payable to EPA
could recoup some of the expenditures.
BENEFITS:
The system should offer more competency-driven, appropriately
targeted, and cost-effective training. EPA will be able to
substantially reduce its traditional training efforts. It will also
be able to centralize guidance, policy, and training while still
providing a greater degree of autonomy for wastewater treatment
operators and regulatory oversight personnel.
EVALUATION CRITERIA:
One measure would be the degree of customer satisfaction with the
new system versus traditional training opportunities. Another
would be the number of wastewater systems in compliance.
CONTACT: Renelle Rae (202-260-3297)
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IP 19
BUILD MULTIMEDIA TRAINING CENTERS
WHAT:
EPA will assist states and local governments in planning and
conducting multimedia inspections and enforcement by providing them
with access to tools, training, and technical assistance. States
will be able to learn from one another and from EPA's experience to
avoid "reinventing the wheel." The training and technical
assistance will be provided by multimedia centers that will be
based in EPA's existing network of training resources.
WHO:
This project will be a partnership between EPA and current training
centers sponsored by universities and other academic institutions,
state agencies and consortia of state and/or local agencies, and
private organizations. OAR will lead this.
WHEN:
The initial stage will identify topics and existing curricula for
multimedia training (4 to 6 weeks). Next, EPA will design a
multimedia training program for a region or target audience (one
year). Finally, materials and technical assistance will be
provided to interested EPA, state, and other organizations.
BARRIERS:
Designing the curricula and training programs will be difficult,
especially given the diversity of inspection and enforcement
approaches under different programs and as run by different states.
Funding and time constraints might restrict EPA and the states'
ability to invest in a coordinated approach.
COSTS:
Not available at this time.
BENEFITS:
This project will build upon work begun by EPA program offices,
regional offices, and the NEIC. Multimedia inspections and
enforcement could be far more effective in achieving pollution
prevention and reduction of pollutant loadings that the current
single program/media approach.
EVALUATION CRITERIA:
Criteria include the extent to which multimedia training can be
developed and implemented, the quality of the training provided,
and the effects of the training on participants and their
organizations.
CONTACT:
Mark Siegler, SSCD/OAR (703-308-8673)
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IP 20
PROVIDE ACCESS TO EXISTING TRAINING RESOURCES
WHAT:
This initiative will develop a means of accessing existing training
resources through a single "pointer system" (e.g., a 900 telephone
number). The project would not replace existing clearinghouses and
training calendar systems but provide easy and efficient access to
them.
WHO:
The project would operate in partnership with all of the current
sponsors of training programs and training calendar databases. OAR
and OIRM will lead this effort.
WHEN:
The first stage will be to incorporate existing training into the
system. (2 to 3 months). Next, the system will be designed with
easily accessed "doorways" that lead to training databases. (3
months). The third stage will emphasize outreach and updating the
information as on-going responsibilities.
BARRIERS:
There are few barriers to a system such as this. It will require
modest resources and time to work with the various sources of
information. The major barrier is that the various training
calendar databases now in operation may use slightly different
software so that programming will be required to allow the doorways
to operate smoothly.
COSTS; Not available at this time.
BENEFITS:
EPA, state, tribal, and local government staff as well as industry
representatives will have much better access to training resources
than currently. Greater use of existing training resources is also
likely to (1) reduce the likelihood of duplication, and (2)
increase the potential for self-sufficiency for some federally-
funded training programs.
EVALUATION CRITERIA:
The project will be evaluated in terms of the use of training
resources and satisfaction of both the users and the training
providers with the system and its services.
CONTACT:
Mark Siegler, SSCD/OAR (703-308-8673)
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IP 21
INCREASE OUTREACH WITH VOLUNTEERS AND STOREFRONT OFFICES
WHAT:
EPA needs to invest more in educating citizens, small businesses,
and community leaders to understand environmental issues and win
their support and participation. In order to provide greater
outreach to these groups, this initiative would form an EPA/ACTION
partnership that would provide volunteers from the VISTA program at
little or no cost to open storefront offices in inner city and
rural neighborhoods and provide retired volunteers from the RSVP
program to help in state, tribal, and local offices.
WHO:
EPA regional offices would work with ACTION regional offices as
well as state, tribal, and local governments. EPA should explore
working with professional organizations and other networks to
identify retirees with a wide array of skills. Region 5 will lead
this in the initial phases working with OARM.
WHEN:
Region 5 is exploring setting up a storefront EPA office in
southeast Chicago with ACTION/VISTA. This project will document the
steps and barriers to establishing a storefront office. If
successful, VISTA volunteers will work in the community to explain
how to get environmental information, present workshops, and leave
behind a community organization concerned and equipped to deal with
community environmental problems.
BARRIERS:
It may be difficult to identify highly capable and qualified
volunteers through the ACTION programs. Renting a storefront could
be expensive a complicated process for regional offices. EPA may
not have the resources to train the volunteers properly and provide
on-going support.
EVALUATION CRITERIA:
EPA could survey the level of awareness of environmental issues at
the beginning and end of the pilot to evaluate whether the
storefront office has been successful in providing outreach. The
general environmental conditions of the community could also be
assessed before and after to determine whether this program has had
an impact.
CONTACT:
Judy Beck, Region 5 (312-353-9391)
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IP 22
PROMOTE JOBS AND SMALL ENVIRONMENTAL BUSINESSES
WHAT:
This initiative proposes to direct existing federal and state
training programs to create new local, environmentally-related jobs
and small businesses. Emphasis will be on inner city unemployed and
underemployed. Pilot projects will select a specific media (i.e.,
lead abatement) to train women and minorities and develop small
lead abatement businesses.
WHO:
A proposal has been submitted by the City of Los Angeles,
Environmental Affairs Department, to EPA's Office of Cooperative
Environmental Management, in conjunction with EPA's Office of Small
and Disadvantaged Business Utilization. OCEM will have the initial
lead.
WHEN:
This project would have three phases: (1) Evaluate federal and
state agency programs for opportunities to meet local needs for
job-training, job creation, and environmentally-related small
business development. Develop a strategy (6-9 months). (2) Design
one or more pilot programs to test the strategy (6 months). (3) If
pilot programs are successful, begin implementation to foster
environmentally-related jobs (24-36 months).
BARRIERS:
Lack of funding and interest at the federal level could result in
failure to develop a sound strategy. Lack of local support could
stymie pilot efforts and jeopardize buy-in from small businesses.
COSTS:
Phase 1: $125,000; phase 2: $50,000; phase 3: to be determined upon
completion of phase 2.
BENEFITS:
This pilot would develop a process to assess local needs and direct
federal and state resources to foster environmentally-related jobs
and small businesses in local communities.
EVALUATION CRITERIA:
Project will evaluate the number of persons employed in the field
after the training programs and the number and success of the
environmentally-related businesses established.
REFERENCES: EPA Grant Proposal #822041-01-0 submitted by City of
Los Angeles.
CONTACT: Joe Sierra, OCEM (202) 260-6839.
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IP 23
BUILD TRIBAL CAPACITY
WHAT:
Most tribal environmental programs are just beginning to develop
the staff expertise, laboratories, monitoring capabilities, and
other infrastructure that are standard for their state
counterparts. A Tribal Capacity Team will develop a strategy for
building the technical abilities needed to manage their own
environmental programs and become full partners on the Nation's
environmental team. The strategy will build upon current efforts
and coordinate efforts for implementing a comprehensive program.
Some of the actions may include: 1) environmental curricula for
Native American schools, 2) scholarships for Native Americans
pursuing environmental careers, 3) internships and IPAs for Native
Americans at EPA, 4) direct technical assistance to tribal
environmental programs, 5) comparative risk analyses to assist in
priority-setting, 6) more equitable formulae for program funding,
7) volunteers for hands-on training, 8) more effectively sharing
research results, and 9) improved outreach. Other initiatives will
be developed where needed. By coordinating capacity-building
efforts and using priority-setting tools such as comparative risk,
the effectiveness of all efforts are increased.
WHO:
EPA program and Regional offices, representatives of Indian tribes,
Congressional staff, and other agencies as appropriate.
WHEN:
Establish the Tribal Capacity Team in fall, 1993, with a report and
recommendations to Administrator by fall, 1994. Implementation of
the recommendations will be ongoing.
BARRIERS:
Tribal needs are great due to years of neglect and vary from tribe
to tribe. There is considerable competition for scarce resources.
State programs may be viewed as more important.
COSTS: Perhaps 1 or 2 FTE will be needed to staff the Team. An
estimated $35,000 will allow Tribal representatives to travel to
meetings.
BENEFITS:
By better understanding the risks found in diverse tribal
environments, coordinating across programs, and targeting efforts
where they will do the most good, the investments made to meet
tribal needs will have the highest possible payoff.
EVALUATION CRITERIA:
Has the strategy included an effective mix of initiatives that will
enhance tribes' ability to manage environmental problems? Is EPA
implementing the Team's recommendations?
CONTACT: Catherine Tunis, 202-260-2698
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IP 24
INTERAGENCY COOPERATION TO "EMPOWER" TRIBES
WHAT:
By working together with each other and tribes, Federal agencies
can cut red tape and eliminate duplication of efforts. Several
federal agencies have responsibility for environmental issues on
Indian reservations yet agency requirements are not coordinated and
sometimes conflict. (To close a landfill, a tribe must have IHS
build a transfer station, get funding from BIA to match a USGS
grant to monitor groundwater, then go to IHS for engineering
support, then to EPA for contract support to develop a closure plan
for EPA approval. Then tribes must go to Congress for a special
appropriation to actually move the dirt.) EPA will lead a Task
Force that will review Federal responsibilities and identify areas
for cooperation. An "Empowerment Pilot" will show how tribes can
accomplish the work themselves using the same resources. This
effort would also assist federal agencies achieve statutory
environmental requirements on reservations, thereby reducing
vulnerability to tribal lawsuits.
WHO:
EPA, Bureau of Indian Affairs, Indian Health Service, USGS, HUD,
other Federal agencies, Indian tribes, Congressional staff.
WHEN:
Task Force established by fall, 1993, "Empowerment Pilot" begun by
early 1994, Task Force report on applicability of interagency
cooperation to full range of tribal efforts to Vice President and
agency heads by 1/95, implementation of recommendations by 4/95,
ongoing (but reduced) Task Force effort to continue cooperation.
BARRIERS: There may be legislative and/or regulatory barriers to
some multi-agency efforts. Strong leadership is needed to focus on
results and overcome bureaucratic inertia.
COSTS: Perhaps 1 or 2 FTE will be needed to staff the Task Force.
An estimated $20,000 would enable tribal officials to travel to
meetings. The cost of the pilot could be funded from existing
program funds that would be spent on the project anyway.
BENEFITS: Tribes estimate that they could increase efficiency for
some actions by two or three fold. With a $50 K grantless than
the cost of contract support for one landfill closure planthe
Menominee Tribe hired an engineer, drilled monitoring wells,
collected data, and developed five closure plans. This initiative
would encourage cost-effective programs, reduce federal liability
for failure to meet environmental requirements, and build tribal
capacity for solving environmental problems.
EVALUATION CRITERIA: How much additional environmental protection
is achieved? To what extent can the Federal government adjust to
achieve these benefits?
CONTACT: Catherine Tunis, 202-260-2698
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IP 25
SPONSOR CHARRETTES TO ADVISE LOCAL GOVERNMENTS
WHAT:
Convening a charrette or panel of experts in a given field is an
inexpensive but valuable technique for providing advice to local
government officials. This proposal would significantly expand the
use of charrettes to help local governments explore possible
financial and technical alternatives for meeting their
environmental infrastructure needs.
WHO:
The charrettes held thus far have been organized by the
Environmental Finance Center (EFC) at the University of Maryland
under an EPA grant. Experts may come from EPA, other federal,
state, and local agencies; industrial, engineering, finance,
environmental, health, or legal professions; and academia. The EPA
lead is RMD/OARM.
WHEN:
This is a long-term project to make charrettes a permanent function
of the Environmental Finance Centers.
BARRIERS:
There may be a reluctance on the part of municipal officials to
openly air their problems, although our experience to date has
proven this usually to be a short-lived concern. Experts must be
carefully screened to be sure that their advice is impartial and
reliable.
COSTS:
The charrettes are quite economical to hold. Using university
facilities and relying on pro bono contributions of panelists1 time
helps keep costs down. The major expenses are for organization of
the session and any travel expenditures required. Total costs per
charrette may range from $2,500 to $5,000. The recommended EPA
support is $300,000 divided among the several Environmental Finance
Centers.
BENEFITS:
Two major benefits directly result from charrettes. The
participating municipalities receive authoritative advice on
important environmental issues and the lessons learned are useful
guides for other communities and EPA.
EVALUATION CRITERIA:
Each charrette has an evaluation sheet filled out by all
participants, covering organization, focus, usefulness and
suggestions.
REFERENCES: Elizabeth Granata, U. of MD, 301-405-6376.
CONTACT: George Ames, RMD/OARM (202-260-1020)
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IP 26
PROMOTE CONSENSUS BUILDING AND ALTERNATIVE DISPUTE RESOLUTION
WHAT:
Traditional command-and-control approaches to regulatory devel-
opment and enforcement creates unnecessarily adversarial
relationships among state, local, and tribal governments and EPA.
Regulatory negotiation, alternative dispute resolution as a
settlement tool, and similar techniques should become standard
operating procedures. This initiative is to promote the use of
these tools.
WHO:
EPA (OPPE/OE lead); state, tribal, and local officials; industrial,
environmental, and citizen representatives; Congressional
officials.
WHEN:
In the near term, convene a task force to address EPA's use of
consensus-building, alternative dispute resolution as a settlement
tool under the auspices of EPA's dispute resolution specialist
(i.e., the AA/OE as designated by the Administrator under the
Alternative Dispute Resolution Act of 1990), and other cooperative
techniques. The task force will provide EPA insight into the
effectiveness of these techniques, where EPA could incorporate
them, and possible pilot projects.
BARRIERS:
The largest threat to regulatory negotiations and collaborative
policy dialogues at present is OGC's latest interpretation of the
Federal Advisory Committee Act which prevents EPA from using
contract money to assist participants with travel expenses. Greater
use of alternative dispute resolution techniques hinges upon
addressing the funding shortages, administrative disincentives, and
EPA managers' general inexperience with ADR techniques.
COSTS:
To be determined.
BENEFITS:
By using regulatory negotiations, alternative dispute resolution,
and similar approaches, EPA can make more fully informed decisions
that are likely to be more timely, cost-effective, and not subject
to litigation.
EVALUATION CRITERIA:
Success of the project will be measured by the extent to which use
of these tools improved the timeliness and cost-effectiveness of
EPA's decisions, policies, and settlements.
CONTACTS: Chris Kirtz (202-260-7566) and David Batson (202-260-
8173).
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IP 27
INTERGOVERNMENTAL PARTNERSHIPS TEAM
Cynthia C. Kelly, Chairman
Team Members
Susan Absher, OSWER
Paul Almeida, OIA
Robin Baily, ORD-EMSL Los Vegas
Judy Beck, Region 5
Sylvia Bell, OW
David Coursen, OGC
Joel V. Davilla, OAR Ann Arbor
Roxanne DiLaura, Region 7
Eileen Fesco, OPPTS
Sherry Fielding, OSWER
David Fierra, Region 1
Franklin Hill, Region 4
Anna Garcia, OW
Patricia Gaskins, OCLA
Lisa Harris, OPPTS
Judith Kane, OSW
Lou Kerestesy, OROSLR
Emma McNamara, OIRM
Meredith Miller, OMS
Lin Moos, OPPTS
Jonathan Packman, OPPTS
Anne Randolph, OROSLR
Lee Roberts, Montana Operations
Peter Shanaghan, OGWDW
Mark Siegler, OAR
Joe Sierra, OCEM
Susan Susanke, OPPTS
Alexander Wolfe, OAR
Adjunct Members
George Ames, OARM
Karen Blanchard, ORD-RTP
Michael Deane, OW
Brendan Doyle, OPPE
Bob Martin, OSWER
Renelle Rae, OARM
David Speights, OCEPP
Catherine Tunis, OPPE
-------
-------
REPORT OF THE
INTERNAL COMMUNICATIONS
TEAM
NATIONAL
PERFORMANCE
REVIEW
-------
-------
NPR - INTERNAL COMMUNICATIONS TEAM
1C
NAME (ORGANIZATION)
McConathy, Jane (OCEPA)
Teamleader
Bonney, Melissa (AO)
Brent, Sharon (OSW)
Bryant, Evette (R-5, WMD)
Burke, Kym (OCEPA)
Cheatham, Anthony (OPPT)
Connor, Roger (OHRM)
Frazier, Paul (OGC)
Gibbons, Karen (OPPE)
Gillispie, Vicki (OW)
Hahn, Robert (OARM/OA)
Hanley, Mary (OPPT)
Hewlett, Mary Louise (OPPT)
Jennings, Jeanette (OARM/OA)
Job, Chuck (OW)
Petruska, Michael (OSW)
Powers, Christine (OW/OWOW)
Shubert, Jan (OW)
Sportsman, Valerie (R-8, HR)
Terrell, Twanna (AO)
Thornton, Kecia (OSWER)
Williams-Berkley, Tonya (OHRM)
PHONE #
202/260-6347
202/260-8808
202/260-4627
312/353-5655
202/260-0336
202/260-9555
202/260-3312
202/260-8052
202/260-7521
202/260-7818
202/260-2024
202/260-1624
202/260-8126
202/260-1284
202/260-7084
202/260-9888
202/260-1770
202/260-7011
303/294-7121
202/260-4057
202/260-4480
202/260-0031
MAIL CODE
A-107
A-100
OS-300
HSM-5J
A-107
TS-790
PM-212
LE-130
PM-219
WH-556
PM-215
TS-793
TS-794
PM-273
WH-550G
OS-332
WH-556F
WH-550G
8PM-HR
A-101
OS-100
PM-224
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1C 2
I. EXECUTIVE SUMMARY
Blessed with a very motivated workforce, EPA is a young
Federal agency. The cobbled-together personality of 1970 is
outdated and obstructive of the mission of environmental
protection. The most fundamental internal communications
problem EPA must address is a crisis of organizational culture
which inhibits and defeats a spirit of unified mission. This
crisis is the result of many negative factors, such as poor
management practices, turfism, lack of understanding of the
big picture, apathy, and lack of commitment to a well-
organized, comprehensive, and responsive Agencywide system for
internal communications.
Our team defines "internal communications" as the way EPA
employees communicate with each other to convey information on
Agency business and personnel matters. Our business mandates
serious attention to communicationmistakes can be costly,
dangerous, and embarrassing, especially when they occur in
policy and regulatory matters. With over 19,000 employees
located among seven HQ locations, ten Regions, ten
laboratories, and over 20 satellite program offices, as well
as the Cincinnati and RTP complexes, we face a formidable
task.
Internal communications have been the subject of several
recent intensive analyses. During 1991-92, the Office of
Administration and Resources Management (OARM) worked with the
Office of Communications, Education, and Public Affairs
(OCEPA) to qualitatively evaluate EPA's internal
communications. Fourteen focus groups were conducted which
involved 140 employees at HQ, three regions, and two
laboratories. Several reports with recommendations were
completed as noted in the reference list. These efforts
yielded a general agreement that internal communications need
significant improvement. The Internal Communications
Publishing Interest Group (ICPIG) has already begun
implementing some of the recommendations. During the same
time period, one office (Office of Pollution Prevention and
Toxics) initiated an ambitious evaluation and improvement plan
for internal communications which is currently being
implemented. (See References for all reports.)
Our NPR Team, consisting of 20 employees (including two
regional representatives) convened for ten sessions to
identify specific problems and recommended initiatives. We
then commissioned an independent survey of 83 employees, and
the majority concurred with the problems and initiatives
outlined by our NPR Team. All of these reports repeat the
same problems, barriers, and solutions in general categories.
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1C
As an immediate priority, our team decided to make the
installation, availability, and mandated use of electronic
communications the infrastructure on which to base improved
practices of internal communications.
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1C 4
II. VISION
Internal communications is perceived as a worsening
problem that is impeding EPA's mission performance. A good
example is the all-employee invitation to participate in the
NPR process that was hindered by the lack of a mass
communication system in use, such as integrated EMAIL.
Employee morale is negatively impacted when information about
EPA is not shared in a timely and efficient manner.
Successful internal communications requires the dedicated
efforts of individuals committed to the goals of the
organization. The goals and objectives of all the National
Performance Review teams rely very fundamentally upon the
success of EPA's internal communications. Therefore, the NPR
team for Internal Communications recommends that the Senior
Management Council adopt INTERNAL COMMUNICATIONS as a priority
concern. This will assist the Administrator in making changes
to the Agency's culture and management practices.
As the foundation for other communication activities, our
NPR Team also recommends that the Agency stand behind current
efforts to establish an integrated electronic messaging system
throughout the Agency (see IV.A.3. and Attachment A:
Target/Action Matrix for EMAIL). Other barriers to internal
communications are addressed in this report; however, we
believe that the Administrator's use of the Agency's
electronic communication system, which is currently under
utilized, will provide an Agencywide incentive to begin using
this pollution-preventing and almost instant method of mass
communication.
III. BARRIERS
Applying TQM principles in its discussions, our NPR Team
cited the following as major communication concerns:
A. Many EPA employees do not feel connected to the big
picture of what EPA is doing. While they are often viewed by
colleagues and friends in the rest of the world as
environmental experts, employees have reported that the most
common way they learn of EPA policy is from external sources.
Except for EPA Insight and the Policy Paper series (two of
ICPIG's responses to the OARM Internal Communications Report),
there is no frequent, regular system for informing the entire
agency of policy developments. This could become an even more
serious problem as EPA and other agencies begin to govern in
more holistic ways (e.g., ecosystem protection, pollution
prevention, credible and collaborative science, public-private
partnerships, environmental justice).
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1C 5
B. EPA employees want a better relationship between
staff and management, regions and Headquarters. Although the
issue of not knowing Agency policy will be addressed through
better top-down and bottom-up communications, there is a human
resources value in developing trusting and thoughtful
communication relationships. Rank and file employees are
infrequently included in staff meetings. Clerical staff want
to know more of substance. Program staffs want to know what
other programs are doing. Regions feel isolated and do not
contribute their field experience. This issue was frequently
mentioned in terms of negative impact on general morale and
the fostering of "turfism". Improving these lines of
communication will require commitments to significant changes
in EPA's culture and the installation and use of a user-
friendly integrated electronic communication system within the
Agency.
C. There is a paper information overload which causes
delays in distribution and receiver processing. Some types of
paper information are not necessary to everyone, but
frequently staff does not receive paper communications in
enough time to even prepare to respond. This persistent
problem contributes to frustration and low morale. Although
EPA is near a goal of 1:1 employee/ personal computer, the
lack of access and support for an agencywide interactive
electronic communications system keeps EPA at a disadvantage
in the age of the super "information highway". There is a
widely held opinion that our current E-mail system is
difficult to use, so many employees refuse to use it. Other
employees are more computer literate, are not intimidated, and
use it often. Despite these differences in opinion, our team
believes that the longer we postpone the adoption of a uniform
electronic communications system, the worse internal
communications will be within EPA, thereby furthering our
inadequacies in comparison to our Federal counterparts.
D. Some related problems associated with internal
communications:
1. Knowledge of work done in other offices may be
helpful.
2. There is a need to know what each component in
EPA is doing.
3. Orientation programs lack standardization,
resulting in employees either having too much
information "dumped" on them or not enough
pertinent information that lends itself to a
"welcoming" environment.
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1C 6
4. Human resources information on training and
educational opportunities arrives too late to
respond.
IV. INITIATIVES
A. QUICK-STRIKE INITIATIVES: These items may not
actually materialize "quickly," but the decision to make them
happen can.
1. Senior Leadership Council (SLC) adopts internal
communications as a priority concern; The
Internal Communications and Publishing Interest
Group (ICPIG) will serve as an advisory board
for immediate and long range projects and
evaluation.
2. More Regular All-Hands Meetings: Administrator
Browner has stated that she intends her
administration to be open to the opinions of
all employees. The first all-hands meeting she
held was popular not only because the Vice
President attended, but because Ms. Browner
spent so much time with employees that may
never be able to talk personally with her about
issues that concern them. The rest of senior
management face the same circumstances. Face-
to-face communication is always the best way to
develop understanding and commitment among the
rank and fileit may be the only way to change
the culture. The Office of Communications,
Education and Public Affairs is currently
developing plans for the Administrator and
individual Assistant Administrators to host
Town Meetings with entire program staffs.
Office Directors should follow. The
desirability of these type of meetings is
increased as this Administration changes the
mainstream direction of government.
3. Administrator's Mandate of Increased Use of
Electronic Mail: Office of Administration and
Resource Management (OARM) has committed to the
Administrator to nationally integrate EPA
electronic mail by installing an Extended LAN
Facility (ELF) by January 1994. This will
allow all LANs and PCs to seamlessly connect
through a variety of e-mail systems, including
All-in-One which is universally available upon
request to PC owners. (All-in-One does receive
complaints over its complexity to operate which
has led to the purchase of other systems by
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1C 7
some office organizations.) OARM and its
Office of Information Resource Management
(OIRM) are working with the 1995 budget
planning and procurement cycle to request
resources to complete EPA coverage by LAN and
thus cost/benefit will be justified.
Comprehensive LAN coverage will improve user
ease and encourage individual access of
networks like CompuServe and Internet which are
already available in some organizational
settings. All of this is already in the works
and the Administrator is involved. Information
to be communicated through integrated EMAIL
bulletin boards:
a. All-hands memos, surveys, suggestions;
b. Announcement and text of Administrator's
speeches (Administration's direction);
c. Policy orders and directives;
d. Press releases and advisories;
e. Administrator's "fireside chats";
f. Vacancy announcements;
g. EPA organization index and functional
statements;
h. Expert database and scientific network);
i. Daily news; and
j. Human resources announcements and
calendars.
SMC and all managers participate in some form
of electronic communication training or confirm
proficiency.
Charge OARM/OIRM/OHRM (Administration and
Resource Management, Information Resource
Management, and Human Resource Management) with
developing an analysis of what are the barriers
to using All-in-One, including lack of basic
computer skills and incentives/disincentives.
Investigate modification to the program to
enhance usability by employees with rudimentary
wordprocessing skills. Examine manual for ease
of use and mistakes:
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1C 8
a. Design and provide basic function
instruction card that speaks to on/off;
read/send; access to bulletin boards; and
trouble shooting guide.
b. Organize Personal Computer Coordinators
(one to each major office) to form a
taskforce to develop strategy to organize
supplementary volunteer EMAIL tutors
within smaller office settings to
compensate for the limited availability of
training classes. This will be vital to
bringing a majority of non-users on board
as quickly as possible.
6. Make better use of other non-paper
communication methods, such as closed circuit
television, video-conferences, public address
announcements, bulletin boards.
B. INTERIM INITIATIVES
1. Develop an Agency-wide communication strategy
for the recommendations of the National
Performance Review. The NPR has a high profile
and employee expectations for significant
positive change are high.
2. Begin implementation of ICPIG recommendations
in conjunction with the NPR process and
initiatives.
3. Increase the amount of EMAIL information from
the Administrator and other prestigious
sources.
4. Develop definitive directories to be installed
on EMAIL bulletin boardsthis will require
multiple organizations to conceive and execute.
5. Conduct an all-employee survey on the NPR
recommendations as a follow-up to the stated
intention of including everyone.
C. LONG-RANGE INITIATIVES:
1. Bring accountability to EPA culture and
management to prioritize internal
communications. Administrator require that
management of internal communications be
identified in Assistant Administrators' and
managers workplans and performance agreements.
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1C 9
AAs market collegial value of improved internal
communications.
Work on making EMAIL and other internal
communications systems user-friendly. In
addition to investigations into EMAIL
programming modifications, employees need
better access to contributing to traditional
communication methods. Similar to the Federal
Communications Commission's provision that
local communities have access to television
programming, EPA employees deserve a
comprehensive vehicle for timely peer
communication.
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1C 10
V. ATTACHMENTS:
A. Matrix: Analysis of Installation of National EMAIL
B. Visual Presentation Documents
1. Quotation from Government Executive July 1993
2. Team Approach to Driving Forces
3. "The Problems ... (As Characterized by Multiple
Recent EPA Surveys)"
4. Pie Chart of OPPT Survey
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1C 11
VI. REFERENCES:
A. Report: "A Qualitative Evaluation of the EPA
Internal Communication System" (Office of
Administration Resource Management) (March 1992)
B. Report: "Improving Internal Communications"
(Internal Communications Workgroup, Communications
Strategy Committee) (November 1992)
C. Report: "Improving Internal Communications and
Staff Training and Development in OPPT" (Office of
Pollution Prevention and Toxics) (March 1992)
D. Report: NPR-Internal Communications Team Survey of
OPPTS Staff (July 1993)
E. Article: "Federal Communications Guide" Government
Executive (June 1993)
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1C
12
ATTACHMENT A
TARGET/ACTION MATRIX OF EMAIL SYSTEM
HARDWARE
CONTENT
TRAINING
OARM/IC
STAFF SUPPORT
MARKETING
OBJ/INITIATIVES
To have a nat ' I
interface
Useful info
accessible in a
timely, accurate,
and consistent
manner
Clusters/teams will
bring co-workers up
to speed
Strong priority:
statement to clearly
emphasize importance
of i nt .
communications
Make accessibi-
lity known -- easy
to learn; will make
channels more
effective/efficient
CURRENT STATE
Patch work
Online: ECATS
(trn'g), EPA
Insight, EPA
Journal, EnviroNews
(summ. of major
headlines); FUTURE:
LEGISLATION
State of flux:
calendar juggling
Existent -- 1 FTE
in OCEPA
Negative attitude
towards usage;
ignorance of its
value
BARRIERS
Budget
Human Will
FTE's to maintain
system for input/
compatibility
High vol. of
users; Lack of
FTE; short
timeframe; Human
will/resistance;
succinct ref. doc
FTE's/Budget;
Lack of holistic
planning and
prioritizing
Prioritization
Ignorance/
uninformed
Attitude
Perceived lack
of need
IMPLEMENTATION
CMB Mandate -- 6
months; OARM
commi tment
target: January
1994
IMMEDIATE
"Fireside"
Weekly
communications
Wkly White House
rpts
IMMEDIATE
Charge ICPIG or
OCEPA w/dev.
strategy for empl
to be trained by
Jan 1
CMB Mandate
IMMEDIATE
During the next 6
months as
referenced in CMB
mandate memo
LEAD OFC
OARM
ALL
(Content
owners)
OARM
OCEPA/
OARM
OCEPA/
OARM
AFFECTED
AUDIENCES
ALL
ALL
ALL
ALL
ALL
COST/.
BENEFIT
Cost: S500K
Benefit: Incr.
morale,
communication,
less paper
used
Cost: Time to
install/input;
FTE to
maintain
Benefit:
improved
effectiveness
Cost: Time
Benefit: Est.
contact points
Cost:
Intangible
Benefit:
Backup of
investments
EVAL.
CRITERIA
Qtrly
Usage rpt
fr OIRM
(identify
prob.
areas/
high
flyers)
Online
survey/
Auto del
from dist.
lists
survey
# of
people
using
Qtrty
usage
reports
Qtrly
usage
reports/
survey
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1C
13
COMMITMENT
"THE MANDATE"
EXTERNAL
APPLICATIONS
Will establish
conformity to
standard operating
procedures as
decreed by CHB
Will promote
effective, timely
communication with
external customers
Ad hoc usage
?
Resistance to
change
o
«
IMMEDIATE
9
OA
OCEPA/
OARM
ALL
Public/
Regulatory
community
Benefit: Std
of
communication
Cost:
Attitudes
Cost:
Potential
impacts on
budget; pro
and con
Qtrly
usage
reports/
survey
Public
response
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NPR Internal Communications Team
1C
ATTACHMENT B.2,
TEAM APPROACH
TO DRIVING FORCES FOR
INTERNAL COMMUNICATIONS
THE NEED TO KNOW
PROFESSIONALISM
ACCOMPLISH MISSIONS OF THE AGENCY
DESIRE TO COMMUNICATE BETTER
INCREASE EFFICIENCY BETWEEN REGIONS, LABS, HQ
DESIRE TO BE MORE EFFECTIVE
AVOID DUPLICATION/INCONSISTENCY
AVOID EMBARRASSMENT
RAISE MORALE
BROADEN PERSPECTIVES
INCREASE OPPORTUNITIES BY BEING INFORMED OF
THEM
IMPROVE TIMELINESS
-------
REPORT OF THE
MANAGEMENTAND
LEADERSHIP DEVELOPMENT
TEAM
NATIONAL
PERFORMANCE
REVIEW
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M/LD 1
Management and Leadership Development
Executive Summary
EPA should be more aggressive in selecting, developing
and evaluating supervisors, managers and executives based on
values and skills fundamental to fostering higher team
performance throughout each organization. The challenge is to
strategically build a management/leadership corps which
fosters participation and empowerment while avoiding a crisis-
oriented culture which encourages micro-management of issues
and neglect of employees.
Overall, the Agency's investment in developing effective
managers and leaders should be increased. It should be noted,
however, that EPA is not starting from a zero base. Through
the cooperation of the Office of Human Resources Management,
the Agency's Human Resources Council and Program and Regional
Offices, systematic efforts to impact the effectiveness of
EPA's management/leadership corps began several years ago.
But, much more needs to be done.
Current efforts should be expanded and new actions
initiated to accomplish the following goals:
o Change attitudes to value effective management and
leadership skills as vital to environmental success;
o Align support systems in selection, development and
evaluation to reinforce the need for effective
management and leadership; and
o Deliver support services to build the knowledge,
skills and abilities needed by supervisors, managers
and executives to be effective managers and leaders.
In order to advance management and leadership development
within EPA, the following action areas are of utmost
importance:
(1) Gaining commitment to an agencywide, competency-based
definition of an effective EPA supervisor, manager and
executive;
(2) Aligning the recruitment, selection, development and
evaluation processes to support effective management;
(3) Achieving a diverse management corps;
(4) Incorporating subordinate assessment/feedback into the
management/leadership performance appraisal process; and
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M/LD 2
(5) Investing and focusing resources commensurate with need.
The recommendations which follow in this report have been
developed to address the above action areas.
Vision;
An Agencywide management and leadership development initiative
which: is based on a consensus definition of effective
management/ leadership, utilizing competency-based criteria at
three levels of management; addresses the recruitment,
selection, development and evaluation of supervisors, managers
and executives in a systematic and clearly understood manner;
and facilitates a quality-oriented, diverse and highly
effective EPA management team.
Action Category #1;
To gain EPA consensus for an agencywide, competency-based
definition of an effective supervisor, manager and executive
and implement a communications strategy to transmit the
definition to the Agency.
Surveys of hundreds of studies and professionals involved
in quality and change initiatives provide a picture of the
type of culture needed for success: management commitment,
upward and downward communications, employee participation,
pushing decision making down, focused development, investment
in people and systematic planning. In order to do this
throughout an organization, managers and leaders must be
positive change agents and facilitate teamwork and individual
empowerment. A clear understanding of expectations and a
definition of effective management is essential to impacting
change in EPA's management corps.
Initiatives
o Utilize the current EPA definition for a "model
manager" and the Office of Personnel Management
(0PM) criteria outlined in the Management Excellence
Framework (formally FAME criteria), to develop a
draft guidance document outlining competency-based
criteria for an effective supervisor, manager and
executive.
o Provide the draft guidance document to all Agency
organizations, special interest groups and
supervisors, managers and executives for comment.
o Redraft the guidance document, incorporating
comments, as appropriate, and present to the Senior
Management Council for final review.
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M/LD 3
o Implement a communications/awareness strategy to
transmit the definition to all EPA supervisors,
managers and executives, and those individuals
interested in a career in management.
Implementation
Who: The Office of Human Resources Management.
When: 120 days after endorsement.
Barriers: Inability to reach Agencywide consensus.
Cost: Minimal; can be done within current resources.
Benefits: Increased awareness and understanding of what
is expected of EPA's management corps and the
competencies that are most important at each
level of management. Provides a framework for
management development planning, including
application to recruitment, selection, training
and evaluation processes.
Success: Official agreement to an Agencywide,
competency-based definition of an effective
supervisor, manager and executive.
Action Category #2;
To align the recruitment, selection, development and
evaluation processes with an Agencywide, competency-based
definition of an effective supervisor, manager and executive.
The quality of any management team depends on the people
selected to be on it. To achieve the type of management corps
needed for EPA to be successful, barriers to selecting the
right individuals for management positions must be broken
down, including the belief that technical expertise is the
only important skill. Once selected, developmental systems
must be directed at the knowledge, skills and abilities
desired by the organization and must be available when needed.
To reinforce these knowledge, skills and abilities, the
management corps must be evaluated against a consistent set of
expectations and values. Each administrative process in EPA
which impacts the selection, development and evaluation of
managers must be aligned with EPA's expectations and criteria
of effective management and leadership.
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M/LD 4
Initiatives
o Incorporate the Agencywide, consensus definition of
an effective supervisor, manager and executive in
all EPA administrative systems and processes
affecting the recruitment, selection, development
and evaluation of EPA's management corps.
o In the area of recruitment:
D Utilize the definition of an effective manager
to outline rating and ranking criteria for all
management positions;
D Assure that there is an effective and
appropriate balance between the management
skills and technical/
scientific/professional credibility
requirements of managerial positions.
o In the area of selection:
D Implement an SES Candidate Development Program
(CDP) which meets EPA's need for future
executives; redesign the application/selection
process to emphasize the "potential" for
meeting the primary competencies of an
effective manager and to allow greater
consideration of grade 14 employees;
D Establish an AA/RA-based management succession
planning initiative requiring organizations to
identify and develop future leaders, beginning
at the grade 11/12 level in a systemic manner,
utilizing the effective manager definition;
D Formalize the one-year probationary period,
evaluation process for new supervisors,
managers and executives including a requirement
for a positive certification before
probationary period clearance; link the
definition of an effective manager to the
probationary period decision; implement a
process to provide guidance to the new
supervisor regarding EPA's expectations and on
what basis they will be evaluated; include
employee evaluations, a review from outside the
chain-of-command and/or completion of
management skill training as positive
certification points, as appropriate;
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M/LD 5
o In the area of development:
D Continue to emphasize an Agencywide, structured
approach to developing all managers,
incorporating an Individual Development
Plan/Career Planning process utilizing the
"competency-based" manager definition;
D Implement a mandatory core curriculum for
management and leadership development,
including transition, and Agency priority theme
courses/learning experiences, which develops
individuals to meet the definition of an
effective manager and delivers the needed
skills and learning at the appropriate time;
D Develop and implement an automated system which
routinely identifies new supervisors, managers
and executives to allow for direct
communication about required "transition"
courses, career planning and EPA's expectations
and definition for effective managers.
o In the area of evaluation:
D Make management and leadership performance
expectations the primary basis for all
performance agreements for supervisors,
managers and executives and assure that there
is performance feedback occurring in all
organizations on a periodic (hopefully
continuous) basis;
D Utilize the probationary period to remove
supervisors, managers and executives who are
not capable of performing within the definition
of an effective manager;
D Promote more formal and informal ways of
recognizing managers who model the definition
of the effective manager.
Implementation
Who: The Office of Human Resources Management; EPA's
Human Resources Officer community; Program and
Regional Offices.
When: A number of these initiatives have already
begun; additional support and endorsement will
help to continue the efforts; all initiatives
can be addressed over the next two years.
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M/LD 6
Barriers: Lack of Agencywide commitment to effecting
change; lack of resources.
Cost: 5 FTE's and 300K to address core curriculum
requirements and managerial assessment
services; 1.7M over three years for an SES
Candidate Development Program covering 100
candidates; the $ level of commitment defined
by AA/RA's for succession planning for their
organizations; 50K for ADP system support.
Benefits: A systematic and comprehensive, agencywide
approach to developing an effective management
corps; a well trained and motivated management
corps.
Success: More systematic succession planning throughout
Program and Regional organizations; greater
TQM/empowerment implementation; greater
productivity and utilization of employees.
Action Category #3;
To achieve a diverse management corps.
EPA should increase efforts to ensure the selection of an
appropriate representation of minorities, women and people
with disabilities in its management ranks, consistent with the
changing composition of the general workforce in the United
States. To this end more focus to this issue is needed
amongst EPA's selecting officials and within the Agency's
review and approval process.
Initiatives
o Reaffirm EPA's commitment to affirmative action
goals for management positions by:
D Issuing a clear and firm message from the
Administrator to all selecting officials
regarding affirmative action expectations for
EPA's management corps and hold senior career
management accountable for results;
D Pushing goal planning to the Office level in
Headquarters, the Division level in the
Regions, and Labs and Installation Head level
for Field components;
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M/LD 9
o Review the management performance review process for
streamlining purposes; consider a "pass-fail" set of
expectations with a well defined balance between
programmatic requirements and management/leadership
abilities, and focuses appropriate attention on
managers' performance as "managers of people"; build
an infrastructure that links evaluation, IDP's and
career planning.
Implementation
Who: The Office of Human Resources Management, the
human resources community, and Program and
Regional Offices.
When: All initiatives can be addressed over the next
year.
Barriers: Lack of organizational resolve to implement and
value a subordinate feedback process; lack of
resources to provide the computerized
infrastructure.
Cost: FTE's or committed workyears from OHRM and
OIRM; 100K in system development costs.
Benefits: A management corps which focuses attention on
its management/leadership impact on the
workforce will increase organizational
productivity and better support implementation
of new environmental themes.
Success: Higher levels of positive feedback to
management from subordinate assessments.
Action Category #5;
To provide adequate resources and planning to advance
management and leadership development initiatives.
An adequate, stable resource base, established through
organizational planning, is essential if consistent, regular
management and leadership development is to be a reality in
EPA. The current "pay-as-you-go" approach has resulted in
very uneven training and development in the Agency.
Furthermore, individuals should not be penalized because of
geographic location or because their supervisor does not
personally consider management and leadership development
important. A consistent Program and Regional Office planning
process should be established and a funding mechanism should
be established to set aside the travel and developmental
dollars necessary for an effective, agencywide effort.
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M/LD
10
Initiatives:
o Establish a goal of 3% of the PRO (travel) and AC&C
(training) accounts, as appropriate, for all
managerial positions being set aside for succession
planning and management/leadership development
purposes, and consider formal inclusion as a line
item in the budget process;
o Require Program and Regional Offices to establish a
management/leadership development senior task force
which establishes an organizational plan, updated
annually, to address enhancement actions for
management/leadership knowledge, skills and
abilities, diversity concerns and succession
planning issues.
Implementation:
Who:
When:
The Office of the Administrator, Program and
Regional Offices, the Office of Human Resources
Management, the Office of Civil Rights and the
human resources community.
Process requirements can be outlined and
Program and Regional Offices can begin
implementation within 180 days.
Barriers: Lack of commitment to management/leadership
development as an important issue; lack of
planning skills; budget process concerns.
Cost:
Success;
Conclusion;
Planning and implementation time by Program and
Regional Offices.
More Agency focus and resources support for
management/leadership development.
EPA can increase its ability to be an effective
environmental leader through a combination of consultative and
participative management styles which promote productivity.
Total Quality Management and Reinventing Government principles
cannot be implemented unless an appropriate management culture
is defined and action is taken to assure its implementation.
Without this, the chance for the success of any changes EPA
wants to make is minimal. Let's capitalize on this
opportunity to make a difference which truly allows us to
implement the changes necessary to foster high performance
teams at EPA.
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M/LD 11
List of Team Members and Input Sources
Team:
Tonya Williams-Berkley PM-224
Janis Butler PM-224
Judy King PM-224
Bettie Reilly PM-224
Donald Sadler PM-224
Clare Shea PM-224
Thomas Wyvill PM-224
Input Sources:
45 National performance Review Suggestion Forms
17 respones from DAA's, DRA's and HRO's to the
draft team report provided at the July 1st NPR
Meeting
Senior Leadership Council critique
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REPORT OF THE
PERFORMANCE MANAGEMENT
TEAM
NATIONAL
PERFORMANCE
REVIEW
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THE PERFORMANCE MANAGEMENT QUALITY ACTION TEAM
HECTOR SUAREZ, OHRM (PROCESS OWNER)
LINDA ADAMS, REGION 8
MICHAEL BINDER, OIG
RICHARD BROWN, OHRM
BRUCE ENGELBERT, OSWER
STEVE JOHNSON, REGION 3
DORIS MCCURDY, OPHRM
CHARLOTTE NORTHERN, OHRM
ROZ SIMMS, OHRM
ROBERT THORLAKSON, OIG
RICHARD WALSH, REGION 8
BEVERLY WEISE, OHRM
SANDY WILLIAMS, OHRM
KENNETH WRIGHT, OHRM
Support provided by:
OARM'S Office of Printing, Distribution Services,
and Recycling; especially Bob Kelly, Chris Thomas,
Sylvia Dodge
Kim Harrison, OHRM
Tiaya Harvey, OHRM
Lisa McCoy, OIG
Barbara Perkins, OHRM
Anthony Peters, OHRM
Ed Thrasher, OSWER
Tabitha Thorne, OHRM
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Executive Summary
Over 100,000 staff hours go into conducting the
performance management process each year at the Environmental
Protection Agency. There is considerable evidence and
sentiment that much of this time and effort is not well spent.
The Performance Management Quality Action Team presents the
following preliminary conclusions based on its research and
findings.
The Agency needs to move away from a performance
management system characterized by infrequent feedback and
unproductive emphasis on labels and rewards. Instead, there
should be more focus on meaningful dialogue, directed at
personal development and organizational improvement and
teamwork.
* The system should incorporate more feedback from
customers and other important affected parties.
* The system should better link individual performance
standards with Agency goals and priorities.
* The Agency needs to improve supervisors' and managers
capabilities for coaching, counseling and mentoring.
* There should be experimentation with a variety of
approaches to foster development of a better system.
These findings are based on three major data gathering
efforts: a statistically valid survey with responses from
over 700 EPA employees; a benchmarking study of performance
evaluation practices in twenty other public and private
organizations; and employee focus groups that included a broad
representation of special interests, grade levels, and
occupations across the Agency.
The survey results show that half the respondents are not
satisfied with how performance is evaluated and communicated,
that the system does not effectively guide and develop
employees and that ratings are not fairly given. This
confirms that there are some serious problems with the way
performance is evaluated in this Agency. The good news is
that most respondents believe they know how their performance
is viewed and that high quality performance is recognized.
The data shows that there is a clear consensus among employees
for more frequent feedback, more focus on team efforts and
contributions, and greater use of our customers' perspective
in performance assessment (including subordinate input to the
evaluation of management).
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The benchmarking study uncovered a wide variety of
practices, with no single, predominant approach. Some
organizations are stressing team rather than individual
accomplishments. Many are utilizing customer, peer and
subordinate views during the evaluation process. Some are
trying to delink awards/bonuses from rating categories, scores
and adjectives and toward more frequent oral feedback or
narrative assessments. In the focus group discussions,
employees clarified and reiterated similar concerns,
perspectives and preferences that were identified in both the
survey and benchmarking process.
At this point, the PMQAT has identified five areas of
focus for system improvements/reinvention. Additional time is
needed to develop a specific action agenda.
Vision
Background
This is an interim report from EPA's Performance
Management Quality Action Team (PMQAT). The team was
established in January 1992 as part of the Office of Human
Resources TQM Alignment Project. The purpose of the entire
Alignment Project is to align EPA's human resources systems
with TQM. This QAT's mission is to make EPA's performance
management systems more effective by aligning them with the
Agency's core values, including Total Quality Management
(TQM).
There are twelve members of the team, representing the
Offices of Solid Waste and Emergency Response, Inspector
General, Human Resources, and Regions 3 and 8. The team has
also been supported by the efforts of numerous others. The
team met weekly from February - September 1992, and began with
literature searches and fruitful policy discussions. Focus
group sessions were held during the period November 1992
through June 1993.
When we first started meeting, we shared the view that,
"everyone dislikes the performance appraisal system." Many
members of the team also thought they understood what was
wrong with performance management in EPA. Through a
brainstorming exercise, the group developed a problem
statement which reflected their views of problems with the
current system. We thought we were familiar enough with what
was possible with performance appraisal. Many team members
wanted us to immediately write recommendations. However,
there wasn't a complete consensus, so we turned to our TQM
methodology. TQM taught us to:
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PM 4
* review the current process
4 ask our customers what they need
4 benchmark best practices
4 consider doing focus groups to get more customer
input
The quality action team began its review process by going
through a brainstorming exercise and developing a problem
statement. The problem statement represented the groups ideas
on what problems exist with EPA's current performance
management systems. The group than began a data gathering
process that included a customer survey, benchmarking best
practices and focus groups with customers to validate or
disprove the hypothesis developed in the problem statement.
Problem Statement
The current performance management systems are considered
ineffective because they:
4 Don't provide meaningful, timely feedback
* Are impossible to administer in an equitable manner
4 Are driven by the "numbers"
* Are focused too closely on awards
Impact:
4 Low moral 4 Adverse effect on
productivity
4 Discourages teamwork 4 Discourages risk-taking
4 Avoidance 4 Feeling judged v.
appreciated
4 Doesn't foster trust 4 Encourages quest for high-
visibility
General Description of Agency Systems
Employees in EPA are covered by three performance
management systems. A system that covers Senior Executive
Service Members, another that covers Supervisors and Managers
(GM employees), and a third system that covers General
Schedule and prevailing rate employees (wage grade).
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Each system falls under the authority of different laws
and regulatory requirements, which is the primary cause for
differences in many of the system features. Current
regulatory requirements do allow each of the systems to have
similar features such as:
* five rating levels
* higher level approval for performance
agreements and ratings
* monetary or nonmonetary recognition for
outstanding performance.
Within these similarities there still exist variations on
how any one of these features might operate in a given system.
For example, there are minimum and maximum budgetary limits
on performance awards for GM employees, while there are no
such limits for GS and prevailing rate employees. For SES
employees, there is a budget limit and a minimum and maximum
bonus amount.
Each system has a wide range of differences, while on the
surface there appear to be a number of similarities. The
following provides a brief overview of the major elements each
of the systems have in common. Each system operates on an
annual appraisal cycle and includes:
Written performance expectations that must be
communicated to employees at the beginning of each
appraisal cycle:
These expectations are communicated in the form
of critical job elements (CJE's) that identify a
major job responsibility or duty that is required of
the employee. For each CJE, standards of
performance may be written at three performance
levels to identify how performance results will be
measured to determine successful or unsuccessful
accomplishments (Outstanding, Fully Successful, and
Unsatisfactory).
Performance expectations are documented in a
performance agreement form which is often developed
by both the employee and supervisor, but requires
approval from a higher level official in the
organization.
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A written evaluation at the end of the appraisal
period:
The evaluation results in one of five rating
levels: Outstanding, Exceeds Expectations, Fully
Successful, Minimally Satisfactory, and
Unsatisfactory. The rating is recommended by the
immediate supervisor and must be reviewed and
approved by an official at a higher level in the
organization.
Basic pay increases to employees who perform at the
fully successful level or higher:
These come in the form of within-grade
increases for GS and prevailing rate employees based
on their years of tenure, and annual merit increases
for GM employees. For SES, bonuses, special act
awards and rank-level increases are available forms
of pay for performance.
Performance awards granted to employees who
demonstrate exceptional levels of performance.
Some other similar system features include assistance to
employees performing below the fully successful level, minimum
appraisal periods, and annual progress reviews.
The Agency makes a substantial commitment of time and
effort to implementing these systems. The PMQAT estimates
that at least 100,000 hours, and perhaps more, are devoted to
the performance management process. While for any one
individual this is a very small amount of time, for the Agency
it is a big investment. The estimate of effort is based on
the following assumptions:
Preparation of Standards 2 hours
initial draft 1 hour
employee/supervisor discussion .5 hour
(15 minutes each)
rewriting, signatures, copying .5 hour
Mid-Year Evaluation 1.75 hours
employee preparation .25 hour
supervisor preparation .25 hour
employee/supervisor discussion 1 hour
(30 minutes each)
signatures, copying .25 hour
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End-of-Year Evaluation 2.5 hours
employee preparation .5 hour
supervisor preparation .5 hour
employee/supervisor discussion 1 hour
(30 minutes each)
final write-up, signatures, copying .5 hour
6.25 total hours per evaluation multiplied by 18,000 employees
equals 112,500 hours.
Status of Current System
We conducted a survey of our customers and (72%) of the
survey population responded. They told us we had read them
wrong. More than half gave us narrative comments.
Surprisingly, about half of EPA's workforce said they were
satisfied with EPA performance management. Nearly three-
fifths said they strongly agree or agree with the current 5-
level system. Two-thirds said high-quality performance is
recognized in their organizations. Three-fourths said they
know how their performance is viewed.
But, we also learned more about problems. Three-fifths
said ratings are not awarded fairly. Just as importantly,
three-fifths also said the current system does not effectively
guide and develop subordinates' work. There was considerably
stronger agreement (ranging from 80-96%) on several survey
items concerning options for system improvement. We also
learned more about what motivates EPA workers and management.
The benchmarking work, meanwhile, showed us that there is
a greater range of approaches to performance management than
we had anticipated. After an extensive literature search, we
contacted 41 private and Federal organizations. Twenty of
them allowed us to interview them. Many of them told us how
they had implemented concepts strongly supported by our
customers in response to our survey.
In summary, through our survey and benchmarking efforts,
we learned from our customers much about what they want. From
EPA's workforce and TQM organizations outside EPA we learned
about a new philosophy of performance management, and some
alternatives for carrying it out. Also the information
obtained through focus groups reiterated many of the concerns
and ideas generated in the survey and benchmarking process.
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Customer Survey
In order to get input from the customers of the
performance management process (EPA's managers, supervisors,
and employees), we mailed a questionnaire to a random sample
of EPA's workforce. Of 1,000 surveyed, 724 responded (72%),
and 390 also gave us narrative comments.
Because of the size of the sample and its randomness, the
odds are high that the responses reflect the views of EPA's
entire workforce.
Findings
The conventional wisdom is, "Everyone hates the
performance appraisal system." The survey results, however,
show that EPA performance appraisal has strengths as well as
weaknesses. There is strong consensus on certain improvements
needed. There are also possibilities for greater alignment
with TQM.
Signs of strength
4 75% say, "I know how my performance is viewed."
4 67% say, "High-quality performance is recognized in
my organization."
4 Rules on the development and use of performance
standards and required discussions are largely being
followed.
4 System design issues (number of rating levels,
generic standard, rating cycle) do not appear to be
major concerns.
4 What motivates employees the most to perform well?
- Self-satisfaction or self-esteem; Customer service
Signs of Weakness
4 "I am satisfied with how performance is evaluated
and communicate in EPA." (53% say "No")
4 "The current system provides an effective tool for
guiding and developing subordinates' work." (60%
say "No")
4 "Ratings are fairly awarded in my organization."
(57% so "No")
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4 Performance management is not as effective in
headquarters as in the regions.
4 Managers and supervisors were more critical of
performance management in EPA than were employees.
Consensus on Desired Improvements
Four TQM-based options for improvements received
extremely strong support from our customers (employees):
4 "Performance management which acknowledges team
contributions and group collaboration" (96 % agreed)
4 "Employee feedback used to help identify supervisory
development need" (95% agreed)
4 "Performance discussed more often and less formally
ongoing feedback and collaboration" (89% agreed)
4 "Clear organizational goals, set at least annually:
individuals' performance standards written to
accomplish those goals" (84% agreed)
Narratives
Of the 724 people responding 394 (54%) sent us narrative
comments, from a sentence to several pages. We appreciate the
effort that went into that work, which affirmed many of our
findings from the overall survey and confirmed many
benchmarking observations. Following is a sample of responses
received.
* The current system is corrupt. Everyone knows it is. It
can't be salvaged. Performance should be evaluated
continuously and by team or group. The current method is
meaningless and dehumanizing.
4 System is used to "beat down" individual or "award all"
though falsely creeping grades-needs to be divorced from
"bean" approach and quality factors need to be
incorporated.
4 "Subordinates" an insulting concept. I think entire
rating system is insulting (by the way I have never
received a "bad " rating). I think this subordinate bull
implies class distinction do away with it!
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4 Formal; appraisals once a year on anniversary. Quarterly
work review meetings with employees. Monetary awards for
specific performance, no general/annual ratings. Cut the
paper work. Focus on content and quality of review with
employees. Focus on improvement.
* Keep it simple. Make it fair. Train supervisors in how
to use it.
4 Need more quality in communications between supervisors
and subordinates. PMS is not the problem.
* Given what I've seen elsewhere and what the options are,
I think it's a pretty good system. Some optional, "no
cost" training in how to work within the current system
could help tremendously though.
* EPA managers should be regularly evaluated by those whom
they manage.
Benchmarking Study
Based upon a literature review of the performance
management systems of more than 200 federal and private sector
employers, we selected 45 organizations for further study.
These organizations had all received some recognition of their
achievements in the area of Total Quality Management, such as
the Malcolm Baldridge National Quality Award.
We surveyed these organizations with questionnaires,
followed by personal interviews. Nineteen of these employers
have responded to date with sufficient information to be
included in this report.
Federal Organizations:
Information in this report is provided from the following
federal agencies:
* Dept. of Navy, HQ * IRS, HQ
* Norfolk Naval Shipyard * IRS, Ogden
Service Center
* EPA, Las Vegas Lab. * VA, Kansas City
* VA, Tide 38 alternate system 4 VA, Headquarters
* General Services Administration
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Private Sector:
Information is also provided concerning the following
private sector firms:
* Eastman Chemical 4 AT & T
+ Microsoft 4 Corning
* Metropolitan Property and + Solectron
Casualty Insurance Company
* Xerox USA + Xerox Canada
+ Steelcase * Esso Chemical
This reports is also based on descriptions in the
literature of innovative practices in the following
Federal/agencies:
* Defense Logistics Agency * Dept. of Labor
* Transportation * Army
+ Federal Quality Institute * 0PM
* Dept. of Energy 4 EEOC
* Naval Weapons Support Center * Defense Finance and
(Crane, IN) Accounting
Service
+ Navy proposals
Findings
We found widespread interest in change in the area of
performance management, both in the federal and private
sectors. Many Federal agencies have tried to modify their
existing systems under current law and regulation to better
meet the challenges they've identified. Others have suggested
building new systems under demonstration project authority or
proposals for revised legislation. The most far-reaching
changes were found in the private sector. These employers, of
course, have considerably more flexibility to design and
implement non-traditional performance management systems.
Dr. W. Edward Deming suggests eliminating performance
appraisals, claiming that they are not a good idea in any
organization and particularly so in a total quality
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organization. However, this is not a viable option for the
Federal government under present law. The following
innovations support the total quality philosophy and could be
implemented in the federal sector without any modification to
law or regulation.
Innovations
Standards and Measures
Some critics argue that individual performance appraisal
does not sufficiently focus on the organization's goals and
may result in individual goals that do not contribute to the
mission of the organization as a whole. Employers are
realizing the importance of linkage of individual performance
standards to the organization's business plan and strategic
initiatives. Xerox Canada describes this as "policy
deployment." An individual's performance standards are
specific work projects and activities, "cascading" from
organizational goals based on the company's overall
objectives. This concept has been implemented, at least
partially, in both the federal sector (IRS, Navy) and the
private sectors (Solectron, ATT, Microsoft, Metropolitan
Property and Casualty).
Generic performance standards for core occupational
groups are used in many organization as "work-saving" devices
to facilitate the paper process. These are generally
developed by large organizational task forces, sometimes with
union input. Most organizations provide that these standards
may be modified or supplemented as needed by individual
managers. (IRS, VA, Navy, Solectron, Metropolitan Property
and Casualty). Some use of generic performance standards
currently exist within EPAe.g., supervisors and managers
required CJE's, contracts management standards and generic
model language that describes three performance levels
(Outstanding, Fully Successful and Unsatisfactory).
Some attempts have been made to integrate development of
position descriptions and performance standards to assure
performance expectations are formally linked to the duties of
the position. (IRS, DOD proposal, Metropolitan Property and
Casualty Company, Solectron). This is sometimes accomplished
as an organizational initiative to develop standard position
descriptions and performance standards together. This
approach has been applied in EPA, Region 10.
Statistical Process Control (SPG) is an inherent part of
Deming's quality model. SPC deals with process variation, the
differences in performance processes that occur each time a
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product is made or a service is carried out. The goal is to
reduce variation associated with forces within the work system
so that overall variation is reduced. SPC is based on
statistical methods to provide a basis for reducing process
variation.
Navy has incorporated SPC techniques in its proposal to
easure process and team performance against baseline measures
of the quality of the process, product or service, and
customer satisfaction. The US Army Corps of Engineers has
recommended linkage of each individual's pay to measurable,
critical productivity outcomes.
Teamwork
Achieving the objectives total quality invariable relies
upon teamwork and cooperation. Our review of the literature
indicates that team efforts include improvement teams, work
teams, multi-skilled teams, semi-autonomous work groups, and
self-managed work teams.
Team performance is evaluated in several ways. Some work
teams require employees to learn the job of every person on
the team, and evaluate members on a broad work-skill basis.
The Department of Navy has proposed an approach with a
combination of group and individual performance measurements.
An individual's overall performance appraisal would be a
function of: a measurement of team performance combined with
a measurement of an individual's contribution to overall team
performance. Solectron bases their compensation on both
individual and team performance.
Most agencies have provisions for team-based awards (DOE,
Navy, IRS). The Naval Weapons Support Center (Crane, Indiana)
has developed a process providing team involvement in awards
money distribution. Non-monetary recognition is also being
used, such as FAA's non-monetary recognition for managers in a
TQM integrated system. EPA appears to be moving in the
direction of recognizing and rewarding more team achievements.
Multiple Sources/Input
Some critics of the current system maintain that the
appraisal process may be too complex for any single appraisal
to conduct with any degree of accuracy. Several organizations
have adopted appraisal from both supervisor and peers (DLA,
FQI, Navy proposal; limited use in several pilots at Xerox
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Canada). Though not a formal part of many plans, other
agencies indicate that supervisors often informally consider
peer input. This largely occurs by exception, such as
lowering ratings due to peer complaints.
Several agencies consider subordinate input into
manager's appraisals (DLA an OPM group, Navy proposal). We
also found several cases of this in the private sector (Xerox,
ATT). Several organizations within EPA currently use various
assessment tools to obtain input from employees on
supervisor's developmental needs.
As with peer input, subordinate input may be informally
considered by the rater, even when not part of the official
performance management system.
Customer input was considered essential to most private
companies surveyed (Xerox, Corning, 3M, solectron, Eastman
Chemical). The Navy has proposed formal customer surveys as
input to individual performance appraisals. Other agencies
reported the informal use of customer input, especially when
problems exist.
One System v. Multiple Systems
Several companies have adopted one system for employees
of all levels (Xerox Canada, Corning, Metropolitan). Current
regulations have established three performance management
systems in the federal sector: PMS, PMRS, and SES. GSA has a
attempted to integrate aspects of these various systems. For
example, awards are given for all "highly successful" and
"outstanding individuals" at the GS/GM/WG levels.
Several agencies have recommended elimination of within-
grade increases to allow higher salary increases to top-
performing employee (Navy, former EPA proposal, Defense
Finance and Accounting) This would require a waiver of law.
The most recent information from the Office of Personnel
Management (OPM) indicates that a combined GS/GM system may be
implemented and within-grade increases would be retained for
all employees (GS & GM). However, the merit increase payments
that supervisors and managers presently receive would be
eliminated.
The private sector has implemented other reforms, some of
which have been proposed as demonstration projects or
recommended for legislative reform in the federal sector.
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Rating Levels
Numerous major companies have eliminated rating levels.
Appraisals are a narrative description of the employee's work
activities (Xerox, ATT, Eastman Chemical, ESSO Canada,
Metropolitan Insurance). These corporations have delinked
performance evaluations and awards/bonuses.
The Department of Labor has proposed a demonstration
project based on these concepts. Their system would have no
summary rating, just a narrative description. Awards would be
separated from appraisals. Standards would be developed by
the group, with individual performance to be appraised by the
group.
Focus Groups
Focus groups were held to obtain the ideas of employees
representative of various special interest groups, grade
levels, and supervisory and non-supervisory occupations at
headquarters, and in the regions and laboratories. A total of
10 focus groups were conducted which included five sessions in
the regions and labs. All ten (10) focus groups agreed on the
following positive aspects of the performance management
system at EPA:
Communication:
* provides one-on-one interaction with supervisors
* serves as a planning tool
Self Assessments:
4 serves as a memory booster for management
* allows the employee to reflect on performance
Recognition/Awards:
* provides incentive to productivity for some employees
Mid-year performance reviews:
4 any shifts/changes can be discussed
4 placing emphasis on areas of development
+ early feedback on performance
All ten (10) focus groups also agreed on the following
negative aspects of the performance management system at EPA.
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Lack of accountability/credibility on performance
rating/process:
* discussions are not enforced
4 insufficient feedback
* planning with numbers
* finagling with numerical ratings
4 perceived rating quotas
4 forced distribution
Systems unfair:
4 tied to too many other processes
4 tied to position selection process; to much importance on
actual ratings; not enough emphasis on meaningful feedback
4 subjective
* focuses on what is not done rather what has been
accomplished
Favoritism:
* certain employees receive high visibility projects
* same individuals receive "outstanding" ratings
Rating levels:
There were mixed feeling among the focus groups regarding
the number of rating levels the system should include.
Preferences deferred on ideas such as eliminating numerical
ratings; pass/fail; three rating levels; and meets
expectations/need to improve.
De-linking performance from awards:
There was a positive reaction to delinking awards from
the performance rating process. However, some employees
expressed a concern about awards being given to only those
employees with "high visibility" jobs/projects. Concern
focused on employees who would not have the opportunity to
receive high visibility assignments or those who do not
perform project type work.
Timing of performance rating/reviews:
There were mixed feelings on the timing of appraisals.
The majority would like to stagger performance ratings/reviews
(to EOD or anniversary date). A small minority would like
them to remain the same.
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Peer/Subordinate Feedback:
Participants of the managerial focus group believed that
feedback should be obtained, but not tied into the rating
process nor for the purpose of evaluation. On the other hand,
employees and non-managerial focus groups believed that the
feedback should go up the chain just as well as down and that
their input should be a part of management evaluations and
ratings. The majority of the focus groups agreed that being
rated by peers may not be a widely accepted practice.
Priorities for Change:
There were various thoughts and ideas on what changes
should be implemented first. The majority of the focus groups
agreed on changes such as:
t trust between the employees and supervisors;
* accountability of the overall performance management system
and enforcement of requirements
* a system that avoids forced distributions on money and
outstanding ratings, etc.
* better communications/on-going communications;
* training focused on developing the coaching and counseling
skills of managers and supervisors
* a system that addresses the concerns of employees
Target/Action Category
The QAT identified five general recommendations. We are
in agreement that the Performance Management system needs to
be improved and simplified. However, there are no quick
fixes. We strongly recommend that identification of near-
term, and long-term changes be developed in a thoughtful way,
one that includes more customer improvement at both the
managerial and non-supervisory levels.
While we believe that system enhancements are needed and
can be developed, we believe that there is a greater need for
a cultural change in the way we view performance appraisals in
EPA. We want to ensure that necessary underlying conditions
for success are present so that the cultural change can occur
and flourish. There was agreement that this culture change is
needed but that it will be a challenging journey.
With that premise in mind, here are the five
recommendations. Additional time is needed to flesh out the
detailed action plans to accomplish these general
recommendations.
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Reinvention Idea #1 Refocus the Philosophy of
Performance Management
We need to move from a performance management system of
infrequent feedback, labelling and reward focus toward a
performance development/enhancement system that focuses
on continuous meaningful dialogue with emphasis on
personal/organizational growth that encourages teamwork.
The system should clearly define a purpose or philosophy
of performance management, should focus on guiding and
developing employees; should encourage teamwork and
cooperation; should avoid labelling performance and
should delink evaluations from the awards process.
Almost 90% of survey respondents indicated that the
current system is not effective as a tool for guiding and
developing subordinates' work. Benchmarking identified a
number of corporations that have delinked performance
evaluations and awards/bonuses. This concept met with a
neutral response in the EPA customer survey. Further
exploration through focus groups provided a mixed
response. Some employees view it as a good idea to de-
link appraisals and awards while others expressed mixed
feelings and a concern on issues i.e., employees with
high visibility projects being recognized and rewarded,
running out of funds before the end of the fiscal year,
etc.
Reinvention Idea #2 Expand System Flexibility
The system needs to allow flexibility and
experimentation throughout the Agency. The system
needs to allow excellence to occur rather than
trying to control and dictate excellence-thus a
flexible system is needed. Through the Benchmarking
exercise, the Group identified a number of
innovative ideas and concepts that could be piloted
under the current rules and regulations, e.g.,
emphasis on team performance; encourage employee
empowerment and involvement; focus on coaching and
counseling; include customer feedback, peer
feedback, feedback up the chain, etc. Pilots could
begin during FY 94.
Reinvention Idea #3 Conduct training targeted to
provide supervisors and managers with skills to be
successful at coaching and counseling employees
We need to improve supervisor's and managers
capabilities for coaching, counseling and mentoring
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PM 19
to support personal/organization growth and teamwork.
Supervisors are the key to an effective performance
enhancement system. We cannot envision any system being
effective, unless the current and future supervisory
cadre become skilled in these areas. Coaching can be
defined as communicating a vision and then getting people
insist on being responsible. The importance of the role
of the leader in this change process cannot be
overemphasized. We encourage Senior Management to take
advantage of every opportunity to emphasize and recognize
the importance of the leader in this change process. As
self-directed teams become more common, we need to ensure
that our leadership team has the skills necessary to
coach the teams toward excellence.
Reinvention Idea #4 Include various input sources
to identify developmental needs of all employees.
The system needs to incorporate feedback to gauge
success, i.e., from all sources, above, below, internal
and external. The survey respondents most often cited
"customer service" as the highest motivating factor;
therefore, gathering input from a variety of customers
should be an integral part of the system. In addition,
it is a major tenet of the Agency's quality initiative.
Benchmarking also supported this as an essential
ingredient.
Reinvention Idea #5 Improve communications and
training on the system to help employees understand
the relationship and connection between
organizational goals and individual
responsibilities.
The system should incorporate the concept of
"Cascading," which is providing a link between the
organization's goal and objectives (strategic plan)
and individual responsibilities. Almost 85% of the
survey respondents indicated preference for a system
linking clear organization goals to individual
performance standards. Many of the private sector
companies contacted through the Benchmarking
exercise recognized the importance of linking
individual performance standards to the
organization's business plan and strategic
initiatives.
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A. Responsibility/Timeline/Barriers
The responsibility for implementing these changes
which are broad in scope and representative of a
change in organizational culture, as well as system
processes and procedures, must begin at the top of
the organization. Communications and specific
actions that support this new direction must come
from the Administrator and the Agency's senior
leadership team. This will help promote a change in
performance management philosophy, system procedures
and past practices among EPA employees. This change
effort should be supported by the Office of Human
Resources Management and other administrative
systems. The role of these resources would be to
provide various forms of communications and training
to inform employees and provide needed skills
development.
Obvious barriers to these changes would be current
Agency philosophy and past practices and procedures
that are in current use. A significant barrier to
making system changes are current regulations that
have been established based on legal requirements.
Obtaining demonstration authority from 0PM to test
alternative approaches to performance management
would allow us to overcome this particular obstacle.
It would be difficult to identify a time frame for
completing such an initiative, but actions can begin
immediately to develop communications, policy and
needed guidance to implement changes.
1. Cost/Benefits/Success Measures
The benefit in doing this should result in
greater organizational effectiveness. If
the emphasis of the performance management
process is focused away from labelling and
award based performance appraisal
decisions we would anticipate the
following benefits:
* meaningful feedback being given to
employees that provides an effective guide
for continuous improvement in work
products and professional development
+ improvement in the skills and ability of
supervisors to promote staff development
and receive feedback about their own
effectiveness and developmental needs
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* the energy of supervisors and employees
refocused on individual development,
future expectations and challenges, and
organization accomplishments
* improved customer service in response to
feedback from internal and external
sources
We can began to measure success when
employees inform us that this process
provides an effective tool for guiding and
developing them to perform their jobs and
managers share this same perspective. A
fixed cost can not be identified but
elements of implementing change would
include costs associated with development
and production of materials used to
communicate new policies and procedures,
as well as providing training for all
Agency employees and resource documents.
The possibility of contracting services to
assist in this process should also be
considered.
References:
Hector E. Suarez, Director
Policy & Research Division
Office of Human Resources Management
(202) 260-3308
Sandy Williams, Program Manager
Performance Management Systems
Policy & Research Division
Office of Human Resources Management
(202) 260-3308
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REPORT OF THE
PERMIT STREAMLINING
TEAM
NATIONAL
PERFORMANCE
REVIEW
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VISION
Permits are issued only where necessary to apply tailored
or site-specific requirements. Permits, market incentives,
regulations, and voluntary programs are all used to control
and prevent pollution and improve environmental quality.
Systems are established that give real time, geographic
information on the status of each permit, permissible releases
to the environment, and incremental improvements in
environmental quality. Through electronic means, such as
bulletin boards or phone calls, permit applicants and
interested citizens can get information on permit
requirements, technical information, or geographic/ecosystem
impacts of permits. The regulated community understands EPA's
permit process (including appeals) and priorities; and
acknowledges that permits are issued efficiently and
predictably. Permit writers are recognized by their peers,
management and the regulated community as achieving a standard
of excellence through completion of a core curriculum that
promotes technical expertise and public service. Permit
decisions are made on a targeted basis, considering sensitive
populations, environmental justice, and using tools such as
comparative risk or geographic approaches. Permits create
opportunities for pollution prevention, encourage innovation,
address cross media impacts, and facilitate enforcement.
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NATIONAL PERFORMANCE REVIEW
PERMIT STREAMLINING TEAM
EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency (EPA) and its
State partners have traditionally used permits to regulate
facilities that discharge, treat, store and/or transport
pollutants. These permits have brought about substantial
reductions in pollutants released to the environment and
their use should be continued. However, the present permit
programs can be cumbersome and generally do not encourage
cross-media considerations or the use of innovative
alternatives, including new treatment technology and
pollution prevention. Whereas the permitting programs have
worked well in the past, the charge of the Permits
Streamlining Team was to identify opportunities for
improvement in the future.
Specifically, the characteristics of the current
environmental permitting process that should be considered
include:
Permitting procedures, including a large universe
of existing permit applications and renewal requests,
contribute to delays in processing and uncertainty by
the applicant and the surrounding community. Staff
turnover and lack of comprehensive training also
contribute to permit quality concerns.
The existing statutes and regulations often restrict
EPA and the States' ability to promote innovative
treatment technologies, pollution prevention
strategies, and market-based incentives.
Permits are typically media specific with little
information about the impact on other media
(e.g., the movement of pollutants from air to water)
or ecosystem protection (e.g., protection of airsheds
or watersheds).
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EPA, the States and some municipalities have created
a number of media-specific permits data bases which
are frequently incompatible. While these data bases
generate useful facility information, there is
little information on local environmental conditions
from which to make ecosystem or human health
risk determinations.
The Permits Streamlining Team recommends the
following major actions to address these concerns:
Standardize permit processes (applications, reviews,
appeals). Revise existing policies and regulations
governing permit issuance, as well as the appeals
process, to make them more efficient and effective
without compromising due process.
Revise the public participation procedures for
permits to encourage early input from affected
citizens.
In collaboration with the States, design a core
curriculum for each program for permit writer
training to retain and strengthen permit staff.
Also, seek input from industry on the design
of the curriculum. Create rewards and other
incentives for outstanding permit writing.
Establish a National Permits Clearinghouse as a
"one-stop" permits information and referral service
so industry and the public can contact one
place to obtain information about regulations and
permitting requirements.
Amend statutory and regulatory authorities to enable
the Administrator to target permit issuance
opportunities for technology-forcing innovations,
cross media considerations, and pollution prevention
strategies. Work within existing statutes to create
opportunities and incentives for pilot projects.
Engage in pilot projects to test targeting proposals
as well as the feasibility and scope of permit fees.
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Issue permits only when necessary to apply site-
specific controls, and "permit" other facilities
by self-implementing regulations. Prioritize the
applicant universe and permit decisions according to
the human health risk, ecological risk, and
environmental justice factors.
Prioritize EPA programs (data collection, oversight,
accountability, priorities) to emphasize improvements
in environmental quality as well as permit
programmatic goals.
Develop and reorganize administrative systems in EPA
and the States to encourage coordination of the
various media permit programs. Integrate
significant permit decisions to provide for
more effective protection of the environment.
In addition, the Agency should continue to
investigate the feasibility of consolidated and
industry or pollutant-specific clustered permits.
Modify existing environmental media-specific data
bases to make them compatible with the Geographic
Information System (CIS) approach to identifying
sensitive populations and geographic areas at risk
and measuring environmental trends.
Ask permits1 stakeholders to identify other
remaining barriers in the permitting process.
Survey successful permitting programs outside of
EPA for ideas.
EPA and the States face a growing number of small,
diverse, decentralized sources of pollution. Each increment
of pollution control poses greater cost, technology and
enforcement challenges. Given this expanding universe of
permits, EPA needs to invest in, and improve its existing
permit programs if it is going to be successful in its
efforts to further identify and reduce environmental risks,
protect human health, foster pollution prevention, and
encourage ecosystem protection.
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BACKGROUND
Historically, EPA and its State partners have relied
heavily on permits (often as mandated by Congress) as the
primary vehicle to achieve environmental protection by
prescribing the level of protection that must be achieved.
The permit sets forth the limitations within the parameters
established by the statutes for pollution discharges and
handling of hazardous wastes. Permits may be general or
specific. General permits specify exactly what a class of
facilities is required to do (e.g., the dry cleaning
industry or the pulp and paper industry). General
permits are used when it is impractical and/or unnecessary
to issue specific permits for each facility, e.g., numerous
small facilities with similar operations. Individual
permits specify exact operating conditions for a given
facility and are often site specific. Permits also provide
a strong basis for any subsequent enforcement action to
ensure that limits are met and protection achieved.
While this strategy has succeeded in controlling
sources of pollution from large, centralized facilities, the
permitting universe has expanded to include many small,
diverse, decentralized sources of pollution (e.g., storm
water discharges). Thus, EPA must modify its permitting
processes to address these new challenges.
Currently, EPA and the States are responsible for
processing close to a million permits. EPA has annually
budgeted over 1,000 positions (most of which are located in
Regional and field offices) and several hundred million
state grant and contract dollars to conduct permit
activities. Despite this resource investment, it is not
always possible to make permit decisions or reissue permits
in a timely manner. As a consequence, permit issuance can
appear slow and inefficient. Excessive paperwork
requirements add to the administrative burden at both the
State and Federal level and can create a real backlog in the
permit process. Depending on the type of permit, the time
it takes from application to issuance may range from one
month to two years. If an applicant appeals a permit
decision, lengthy public hearings may add to the time it
takes for issuance of a permit.
Given the large volume and kinds of permits requiring
processing, neither the Agency nor the States can
effectively or expeditiously address the current universe of
permit applications needing attention. Since a permit may
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not always be the best method for achieving environmental
protection and risk reduction, it is essential to
prioritize, group, and target permitting activities
according to types of facilities, geographic location, and
the nature of the required permits.
ESTIMATED UNIVERSE OF FACILITIES REQUIRING PERMITS
(as of July 1993)
STATUTE
NPDES
AIR
RCRA
UIC
TSCA
CATEGORY WITHIN STATUTE
Major and minor dischargers
Facilities covered by general
permits
Industrial storm water
NPDES/sludge
Title V (projected)
New Source & Modified
Operating
Post Closure
Class I
Class II
Class 11,1
Class V
Total for all Classes
PCB Disposal
NUMBER
65,000
10,000
100,000+
20,000
350,000
40,500
per
year
2,425
1,834
514
161,204
34,026
208,600
404,344
53
The Class V rule is currently under development and the permit number is
likely to change significantly as a large number of wells will likely
close instead of applying for permits.
As more States receive program delegation and the
permitting processes become established, the EPA/State
partnership is evolving. States have indicated that it
would be more appropriate for EPA to focus on technology
transfer, rather than state oversight. These States would
prefer more flexibility, along with the delegated authority,
to carry out their program responsibilities.
Furthermore, the lack of an integrated data base in the
States or Regional Offices of EPA make it very difficult to
conduct an integrated or multi-media permit program.
Partnerships with the States need to be developed to
cooperatively build the necessary data bases. This would
greatly enhance monitoring and compliance as well as provide
information for emergency responses to environmental
accidents (e.g., floods).
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Finally, the current permitting procedures and programs
generally do not encourage innovative approaches to the
process because of the requirements established through
existing regulations and statutes. According to a report by
the National Advisory Council For Environmental Policy and
Technology (NACEPT), the current permitting and compliance
systems, as they function today, discourage all stakeholder
groups from taking the risks necessary to develop innovative
technologies whether for pollution prevention or for
pollution control and to bring them into routine use to
solve environmental problems. Innovative approaches include
any new treatment technologies or changes in emission
controls that differ from the historic or traditional
method. In addition, innovative approaches include
pollution prevention, emission fees, marketable emission
rights, and other less orthodox emission controls. It may
also include flexible permits for testing and or research
and development of innovative technologies for pollution
prevention.
ISSUE/DISCUSSION
With respect to the issues listed below, the Permit
Streamlining Team identified recommendations, implementation
steps, and where available, the resource and programmatic
implications of implementation:
Improving Administrative Processes
Designing Training and Incentives for Permit
Professionals
Facilitating Meaningful Public Participation
Increasing Access to Permitting Information
Enabling Innovative Approaches to Permitting
Targeting Permit Priorities
Implementing a Cross Media Perspective
Measuring the Environmental Success of Permitting
The permitting programs are not all alike and
therefore, some of the discussion is not relevant to each
program. The discussion is intended to be a broad overview
of many of the concerns identified by EPA, the States, the
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PS 8
regulated community, and the interested public. The
recommendations also reflect a mix of initiatives some of
which may be started immediately and others which require
regulatory/statutory or organizational changes.
Finally, note that some of the recommendations within
this report overlap or depend on each other, and are also
likely to be seen in other Agency National Performance
Review Reports.
ISSUE; IMPROVING ADMINISTRATIVE PROCESSES
The permitting processes are cumbersome and
administratively burdensome. Final permit issuances or
denials, and appeals often involve extensive delays, and use
a tremendous amount of the Agency's and States' resources.
RECOMMENDATIONS AND IMPLEMENTATION STEPS;
Encourage States to take full delegation1 and
responsibility for permit programs and develop the
capability of other states to assume more responsibility for
permit programs. Modify oversight procedures to tailor
guidance and review to help States implement environmentally
effective permit programs.
IMPLEMENTATION STEPS: Office of Regional Operations
and State/Local Relations (OROSLR) working with a
group nominated by the State/EPA Committee and EPA
management would address the delegation issue and
develop oversight procedures in FY'94.
Evaluate EPA's current requirements for State reports
regarding program compliance and eliminate excessive or
artificial commitments.
IMPLEMENTATION STEPS: National program managers
should work with Regions, States and others to revamp
accountability/measurement system for FY 1996
during FY 1994-1995.
In this document the term "delegation" includes all mechanisms that allow a non-EPA agency to review
and issue permits to comply with Federal requirements. This includes delegation of authority to implement EPA
regulations and State permit regulations that have been approved fay EPA (e.g., New Source Review Permitting
Regulations in State Implementation Plans for the Air Program).
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Consider the expansion of alternative permit mechanisms
(e.g., general permits, permits-by-rule) for "minor"
permittees or those in similar industries or geographic
regions.
Set up teams with States to further review and streamline
the permit processes. Ask the stakeholders to identify
barriers and obstacles in the permitting process. Survey
successful permitting program organizations for more
efficient approaches to permitting or similar processes.
IMPLEMENTATION STEPS: OROSLR should take the lead to
identify team members and get them started within 90
days. The teams would have six months to develop
their recommendations.
Establish an expert system or other software to guide
applicants through application preparation or States through
application review. Such uniform systems should provide
permit applicants with an up-front understanding of the
permit requirements for their specific source and add
certainty and consistency to the permit application and
review process.
Centralize permit application data, self audit information
and compliance data in one information system to promote
cross media, targeting opportunities. As part of the permit
application process, require each applicant to provide
environmental quality data associated with its
release/discharge/emission. Such a data system would
improve permit development as well as coordination between
the media programs. For example, an applicant seeking the
ability to trade pollutants in its wastewater permit would
provide information on the discharge from the second
facility receiving the "credit", to ensure that the
additional pollutants do not degrade the second site's
aquatic conditions.
Standardize the appeals process for all federal permit
programs eliminating unnecessary steps and consider setting
reasonable time limits for permit applicants, permit
reviewer and the Environmental Appeals Board. Encourage
states to adopt these streamlined provisions.
Review and standardize data quality requirements in
Quality Assurance Project Plans on a national basis to
accelerate approval.
Establish model permit processing procedures and "Measures
of Success" to set standards and provide incentives for EPA
and States to process and issue permits in a timely manner.
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IMPLEMENTATION STEPS: A national cross-program
permit review team would need to be established
to examine and amend permit application requirements,
develop expert systems, establish permit time frames,
and standardize the permit appeals process. Some of
this review may be able to be done by individual
programs. The team should complete its more
detailed review in FY'94 with specific draft
regulatory changes as an outcome.
IMPLICATIONS;
Additional authorization of State permit programs will
require a shift in EPA permit resources in the Regions, from
permit issuance activities to work with States to get
authorization done. This will result in a short term
reduction in permit issuance, but long term should save the
Agency a portion of permit issuance resources.
Expanding use of alternative permit mechanisms like
general permits and permits-by-rule for certain lower risk
or lower priority permittees would allow a better focus of
Federal and State resources on higher risk geographic areas,
pollutants, and industry types. EPA and States might,
through this approach, be able to reissue or issue lower
risk permits which would otherwise receive no controls due
to permitting backlogs. This Cross Program Review team
would require the efforts of several people from each permit
program full time, including regional (and maybe State)
members. These resources would be shifted from other permit
regulatory, oversight and outreach activities. Resources to
follow through with regulatory changes would be needed in
each program for the next 3-4 years. When completed, these
changes should result in more efficient permit processing
and improve the Regions/States ability to focus resources on
environmental decisions rather than administrative
processing.
To design a data system to centralize permit application
data would entail a significant investment in hardware,
software and FTEs. It would provide to the public the ease
of accessibility they have long requested. Estimates of the
cost to design and maintain the system would be obtained
through existing permit contract services already involved
in other central permit contract systems.
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ISSUE; DESIGNING TRAINING AND INCENTIVES FOR PERMIT
PROFESSIONALS;
Staff turnover and lack of comprehensive training,
particularly at the State level, are significant obstacles
to producing quality permits on a timely basis. Obstacles
to the permitting process often diminish Federal and State
permit writers' sense of accomplishment.
RECOMMENDATIONS AND IMPLEMENTATION STEPS;
Establish an EPA Permits Institute. Reguire all permit
professionals, State and Federal, to complete a core
curriculum of permit writing courses within a specified time
frame. The curriculum could include both general and media
specific courses focusing on:
general permit processes
state specific information
innovative strategies and approaches
targeting
cross media permits
regulatory and statutory updates
Schedule the courses often and investigate alternative
approaches (e.g., satellite down links, video conferences,
self-study) to making the courses accessible. Explore
desirability and option to certify permit professionals upon
completion of the core curriculum.
Review the staffing of permit organizations to assure
appropriate skills mix so that they have the staff with the
necessary expertise to make scientific and technical permits
decisions. Assign the general administrative and paralegal
work to the appropriate staff.
Provide financial and other incentives and awards to
permit professionals. The Remedial Program Manager of the
Year award in the Superfund program is a good model.
Investigate a mechanism for including State employees in a
Federal incentive programs.
IMPLEMENTATION STEPS: OHRM, the EPA Institute, and EPA
program office permitting experts work with a team of
State and EPA program professionals to design a core
curriculum and an incentive program. An initial
proposal should be distributed to stakeholders in FY
1994.
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IMPLICATIONS;
Requiring all permit professionals to complete core
curriculum of permit writing courses will produce higher
quality permits on a timely basis. Providing incentives and
awards will reduce Federal and State permit writer turnover.
Consolidating existing training modules into a core
curriculum will take some resource commitment in time, and
awards will require some additional funds. This dedication
of resources should, however, improve quality and the
timeliness of the issuance of permits, and reduce costly
staff turnover.
ISSUE; FACILITATING MEANINGFUL PUBLIC PARTICIPATION
Under the existing programs, the Agency does not
address the public concerns early in the process which can
result in general dissatisfaction and delays in permit
decisions. Permittees often complain that public
participation is used to delay permit decisions. The public
feels the decisions have already been made before they have
an opportunity to comment.
RECOMMENDATIONS AND IMPLEMENTATION STEPS;
Revise the permitting procedures to encourage meaningful
public involvement early in the process. Require permitting
authorities and permittees to hold meetings with the public
prior to submitting a permit application on controversial or
significant permits.
Identify more effective methods to notify the public of a
permit application, other than through notices in the
newspapers. Benchmark other organizations for successful
approaches, such as the State of Maryland which issues a
monthly publication that notifies the public of all the
permits in Maryland that are open for public participation.
In addition to the existing public comment process,
develop communication strategies for each year's expected
permit issuance workload, targeting more extensive public
outreach for the more significant and/or controversial
permit decisions. Allow for informal meetings with citizens
groups prior to the development of a draft permit. Expand
permit fact sheets to incorporate comments and issues raised
by the public early in the process. This would make the
post draft permit public participation more effective.
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PS 13
Use the Superfund Community Relations Program as a model
to develop programs to educate interested citizens regarding
the purpose and scope of the permit process, including the
use of public comments and the issues appropriate for
consideration in the permit process.
IMPLEMENTATION STEPS: Public Affairs Specialists
from OCEPA and State pollution control agencies
should be appointed in FY 1994 to develop specific
implementation steps for each of these public
participation areas. These program improvements
could be implemented immediately.
IMPLICATIONS;
The recommendations for this issue focus on early and
expanded involvement of the permit applicant and the public
in the permitting process. This process will provide more
effective and expanded participation and education for the
public. In general, these processes could be initiated
immediately for all new permits without changes in
regulatory requirements. Additional resources would be
required by the permit applicant rather than by the EPA or
State pollution control agencies.
ISSUE; INCREASING ACCESS TO PERMITTING INFORMATION
Direct and timely access by the public and permitting
agencies to accurate, comprehensive and understandable
information regarding permit programs, permit applicability
and requirements is key to ensuring that applications are
complete and processed in a timely and consistent manner.
Permit information outreach can be accomplished through
permits information resources.
Multiple information resources exist (e.g., information
centers, guidance manuals, automated procedural programs and
data bases and training instruments) for assisting
State/local agencies, the regulated community and the public
with regard to the procedural and technical requirements of
the various permitting programs mandated by federal
environmental statutes. These information resources are not
always user friendly; they are media-specific; they do not
cross-reference; they can be costly and difficult to access.
The existing systems are not viewed as totally successful
tools in streamlining the permit processes or for providing
mechanisms for ensuring compliance.
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RECOMMENDATIONS AND IMPLEMENTATION STEPS;
Establish a National Permits Clearinghouse as part of
EPA's Public Information Center so that industry and the
general public have one place to obtain information about
regulations and permitting requirements. This would include
general, simple-to-understand information, as well as names
and numbers of State and/or EPA contacts who are available
to address permitting questions. Where the permit program
is delegated to the State, the National Permits
Clearinghouse will provide referrals to State experts.
Create electronic bulletin boards to disseminate permit
information. An electronic bulletin board can provide
almost instant access to permitting resources including
general and technical documents, data bases, checklists,
policy and guidance, training materials, computer models,
program contacts and events.
Establish, and assign the responsibility to maintain, a
compendium for each permit program of all relevant program
policy and guidance. Also include external informational
resources, such as trade and State agency organizations who
can provide additional insights or knowledge about permit
requirements.
IMPLEMENTATION STEPS: Within six months, form a
work group to be responsible for the coordination
and collection of permit data and referral lists
from each Program Office. Also this work group
would be responsible for identifying existing
centralized focal points/centers, starting with
the EPA Public Information Center.
Encourage national Regional and State permit programs to
develop ways to be more responsive to the public. One
example is the rotating "Duty Officer" used in Region VI and
OPPE. The daily "Duty Officer" responds to inquiries from
the public, refers callers, mails out information, aided by
a notebook of references, hotline numbers, technical
documents, state contacts, etc.
Draft clear and understandable guidance manuals to explain
the permit requirements. The manuals should include
examples and should be available to the permit applicants,
the States and the general public. A good model is the
Virginia layman's guide to RCRA. For non-English speaking
targeted audiences, documents and fact sheets should be
available in the appropriate language.
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PS 15
IMPLEMENTATION STEPS: Each permit program office will
either develop or review a checklist of the key
elements of its permit application and provide a copy
to the clearinghouse. The development or modification
of the checklist should take 3-6 months. It should be
used as a screening tool by both the applicant and
permit reviewer to assure that all the permit
requirements are addressed. The checklist should also
list innovative technologies, pollution prevention and
cross media issues to encourage both the applicant and
the review to focus on these alternative areas. The
list should also check for electronic data entry
capabilities and ease of public access to information.
Collaborate with state associations, trade associations
and citizens' groups to regularly offer training workshops
throughout the country. Courses could be targeted for
specific groups such as small businesses or technicians who
select and maintain appropriate control technologies or
processes. The workshops could focus on issues such as
resolving common problems found in permit applications,
determining completeness, compliance with reporting and
monitoring requirements and guidance on effectively working
with the process to achieve a "hitch-free" application.
Within three months each program office should review the
practicality and benefits to be derived from implementing
any of the above strategies not already in place.
Appropriate additional measures should be implemented within
six months thereafter.
IMPLICATIONS;
High printing costs currently limit the free
distribution of larger publications. However, some larger
publications can be accessed on line at no charge (i.e.,
Access EPA, etc.). Also, access to public data bases can be
done from the Centers, again for no charge. Collecting,
maintaining and dispersing the information may require
additional contract resources, since the centers probably
would be run by contractors. For example, the National
Drinking Water Hotline handles an average of 4,000 calls a
month at a cost of $450,000 a year.
The costs of implementing these recommendations varies
from permit program to permit program. The Air Program has
set up a Technology Transfer (Computer) Network for 1-3 FTEs
and $200,000 of contract funds. The New Source Review Air
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PS 16
Permitting Program established a compendium of relevant
materials with $50,000 of contract funds. This same office
of New Source Review for Air drafted a comprehensive
guidance document for 1-2 FTEs. Collaboration with non-EPA
organizations to put on courses also requires EPA resources.
The New Source Review Air Program estimates that each
workshop uses 1/4 FTE and applicable travel funds.
ISSUE; ENABLING INNOVATIVE APPROACHES TO PERMITTING
Under most of the environmental statutes and
regulations, requirements prescribe, often in very specific
terms how pollution should be controlled. For instance,
control technologies are often specified, and particular
sources of pollution are typically identified. These
conditions are not conducive to innovation, pollution
prevention initiatives or ecosystem approaches. Even when
regulations and statutes allow innovative approaches the EPA
budgeting/planning process does not allow the evaluation up-
front investments of proactive resources rather than
expending reactive resources at a later time, resulting in a
lack of resources for developing full and complete guidance
for permittees on how to utilize innovative procedures in
the permitting process. Since environmental improvement is
the ultimate goal of any permit, permitting programs should
encourage, or at least allow, sources to find cost-
effective, efficient, flexible or innovative methods of
achieving that goal. Innovative approaches include any
emission control strategy that differs from the traditional
method. Specifically, this includes pollution prevention,
emission fees, marketable emission allocations, and other
less orthodox emission control techniques.
RECOMMENDATIONS AND IMPLEMENTATION STEPS;
Identify which statutes and regulations currently allow
the use of innovative strategies, and prepare guidance for
permit writers and permittees that explains how to implement
those approaches.
Identify which statutes and regulations currently do not
allow full use of innovative strategies. Where the statute
allows innovative strategies and the corresponding
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PS 17
regulation(s) do not, the Agency should revise the
regulations. Where the statutes do not allow flexibility,
the Agency should work with Congress to amend those
statutes.
IMPLEMENTATION STEPS: OGC should be the lead in
performing the statutory and regulatory analysis to
determine what, if any, changes are necessary to
allow the use of innovative technologies. The analysis
should take approximately six months.
For permitting programs which have authority for
implementing innovative strategies, develop guidance up-
front that explains how to utilize innovative procedures in
the permitting process. Many permittees who wish to apply
innovative strategies are discouraged by the lack of clear
and concise guidelines on what is approvable by the
permitting authority.
IMPLEMENTATION STEPS: Program office permitting
experts coordinate work groups for the development
of guidance over a six month period.
Recommend that Congress provide the Agency with the
statutory authority to establish a program for encouraging
pilot projects to test the effectiveness of environmentally
beneficial innovative controls that may not initially meet
all existing programmatic or legislative requirements.
IMPLEMENTATION STEPS: OPPE should coordinate the use
of pilot projects. Approximately 1% of the programs
budget should be used on evaluation and implementation
of pilot projects.
Encourage the regulated community to demonstrate
innovative strategies and then publish and widely
disseminate success stories that can be used by other
permittees.
IMPLEMENTATION STEPS: A team of representatives from
permit organizations should solicit success stories
from industrial groups and States and periodically
publish in a guide.
Encourage the establishment of tradeable emission
allocations that allow the private sector to reduce
emissions in the most cost effective manner. Trading may
have limited geographic flexibility due to the site specific
impacts of certain pollutants in some media.
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PS 18
IMPLEMENTATION STEPS: OPPE should coordinate the
further study of this effort and prepare a proposal
within six months.
Establish permit fee programs that cover the cost of
developing and issuing the permit. The fees in excess of
the administrative costs should fund research into pollution
prevention and other more cost effective control strategies
such as marketable permits, or tradable allowances.
Explore an emission fee program that sets the cost based
on the risk of the specific pollutant that is discharged or
use a graduated scale based on the toxicity of the active
ingredient.
IMPLEMENTATION STEPS: OGC and OARM should research
how the procedural barriers can be changed and
develop a recommendation for the Administrator.
A risk based fee system will be complex and costly
to establish, but EPA should examine State fee systems
that use this approach.
Create incentives for pollution prevention and good
performers, in general, by allowing participating facilities
additional flexibility. For example, increasing permit
duration, allowing self-reporting, reducing monitoring
frequencies or deferring permit renewals.
IMPLEMENTATION STEPS: Where no legislature barriers
exist, begin immediately; phase in other changes as
legislative reauthorization opportunities arise.
Use the permitting process as an opportunity to seek
voluntary commitments to pollution prevention or other
reductions in pollution. Provide tools and technical
support for voluntary actions to address environmental
problems. Go beyond mere permit writing to forge
partnerships between public and private sector to improve
environmental quality.
IMPLEMENTATION STEPS: Each of the permitting programs
should establish an administrative framework to provide
support for innovative projects within 30 days.
Allow flexibility to meet release reduction targets in a
single media. An example is the Amoco/EPA Pollution
Prevention Project, where the participants determined that
pollutant releases could be reduced much more cost-
effectively than actually under the terms of the facility
permits.
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PS 19
IMPLEMENTATION STEPS: OPPE should take the lead to
identify other industries interested in pilot programs,
and once identified, work with EPA program staff
(Headquarters and the Regions) and States to develop
a workplan. It will take approximately 9 months to
develop the workplan.
IMPLICATIONS;
In the long term, increased use of innovative
strategies will result in cost savings for industry and
permitting authorities because by definition innovative
strategies are optional programs that permit applicants
choose to utilize or permitting authorities allow to be
used in permits. This choice will only be made in cases
where cost savings are realized. Specifically:
Increased authority for pilot projects will speed the
development of innovative strategies producing greater and
more rigid cost saving for affected industries.
Tradeable emissions encourages creativity in obtaining
environmental results. Tradeable emission allocations will
require greater government investment in the monitoring and
modeling of pollutants on a geographic basis. Many of the
monitoring and modeling techniques are currently available,
however, they have only been applied on a limited basis.
Economic studies show that in many cases the application of
these technologies on a geographic basis can lead to
substantial cost savings.
In the long run this will result in cost savings for
the permitting authority and the permitted community.
The cost of the up-front guidance development could be
considerable (5 FTEs per permitting program), but this
will result in considerable cost savings as innovative
permits are issued in a more timely, less-resource
intensive manner and industry realizes the cost savings of
using innovative approaches.
Permit fees collected by the permitting authority will
allow the authority to devote more resources to quickly and
accurately process permits, which could result in real
savings for permit applicants.
Flexibility in the statutes would help to stimulate and
enhance the development of innovative technologies for
environmental improvement.
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PS 20
However, the up front resources of setting up programs
can be considerable, such as explained below:
Setting up a marketable emission allocation program has
taken over three years and more than 15 FTEs in the South
Coast Air Quality Management District for three air
pollutants (sulphur dioxide, nitrogen oxides and particulate
matter). However, South Coast District management believes
that this is less resource intensive than the traditional
method of determining emission reductions and controls for
each source.
For determining risk-based emission fees, the initial
research and development efforts needed to determine
relative risks and subsequent societal costs of emissions
requires extensive resources and technical capabilities that
have already been expended and must be forecasted to be
spent in the future. However, several states, e.g., New
Jersey and Pennsylvania have developed risk based permitting
programs for toxic emissions. Additional data must be
gathered to determine costs and benefits of implementing the
innovative strategy approaches on an agency-wide basis.
ISSUE; TARGETING PERMIT PRIORITIES
Neither EPA nor the States can expeditiously or
effectively address the current universe of almost a million
permit applications, nor is a permit always the best method
for achieving environmental protection/risk reduction. It
is necessary to prioritize, group and/or target permitting
activities.
While the need to target permit activity has been
accepted for several years, to date our efforts have focused
more on site-specific factors within individual media and
less on environmental justice geographic factors, and
ecosystems.
RECOMMENDATIONS AND IMPLEMENTATION STEPS;
Issue permits only where it is necessary to apply tailored
or site specific requirements; use alternatives where
possible such as compliance with self-implementing
regulations or class permits. For example, a recent study
of the implementation of the RCRA program concluded that
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PS 21
non-commercial storage facility permits could be obviated by
permit-by-rule or class permits. The study also concluded
that post-closure permits for land disposal facilities could
be replaced by enforcement orders or agreements.
- Write self-implementing regulations. In the interim,
use general or class permits for sources that do
not need site-specific requirements.
- Revise statutes as necessary to allow EPA and
approved States the discretion to not require
a permit for particular sources or classes of
of sources as necessary.
IMPLEMENTATION STEPS: Beginning immediately and for
the next 4-5 years, program offices should review
existing regulations and those under development to
identify opportunities. Over the next 3 years, amend
statutes as opportunities arise, including the Clean
Water Act, Safe Drinking Water Act, Resource
Conservation and Recovery Act; in the same time frame,
consider developing an Administration Bill to implement
the changes recommended in this report.
Prioritize permit issuance based on human health and
ecological risk concerns, or on a geographic basis. The
Agency should make more frequent use of geographic,
environmental justice and other risk-based targeting
considerations, particularly ecosystem approaches, to
improve regional environmental quality and focus on the most
critical environmental resources.
- As an interim step, within each media permitting
program, set priorities for reissuance on a pollutant
basis, industry basis and geographic bases.
Pollutants, industries and geographic areas can be
targeted based on risk. Targeting by industry also
ensures that permit writers and the Agency gain
expertise about the industry and that requirements
are consistent from plant-to-plant and permit-to-
permit. This approach requires substantial planning
on the part of permit managers.
- Each Region has developed an individual, media-
specific, permitting priority scheme. Headquarters
should foster these efforts and encourage stronger
commitments to targeting by folding it into the
Regional strategic plans.
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PS 22
IMPLEMENTATION STEPS: Begin immediately to have the
National Program Managers meet with the Regions.
Beginning in FY'94, encourage Regions to implement
ecosystem, environmental justice-oriented and
geographic approaches. Negotiate specific transition
to more targeted programs for FY'95 budget and
Operating Plans. Immediately identify the barriers and
opportunities for revision. In FY'94 make changes in
the FY'95 Operating Plans and in grant negotiations for
FY'95.
Establish a system of State incentives and rewards,
including revisions to the State oversight mechanisms to
encourage States to adopt the risk-based targeted approach.
- Review existing allocation formulas used to award
State grants and, where possible, reserve funds to
reward or assist those States which embrace the risk-
based, targeted approach to permit issuance.
- Establish other incentives for States to conduct
targeted permit issuances (e.g., renegotiate
Memoranda of Agreements, support changes to
State permit processes such as longer permit
durations and pilot arrangements, reorient
EPA's State oversight approach to provide relief
from the need to reissue 100% of permits).
IMPLEMENTATION STEPS: Establish a work group of
program staff, Grant Administration Division,
and State representatives to conduct a nine month
study exploring existing incentives and opportunities
in the future.
IMPLICATIONS;
Reducing the number of permits that must be issued enables
permit writers to better focus on the quality of each permit
that is issued, thereby maximizing resources and
environmental improvements. For example, by covering RCRA
non-commercial storage facilities with permits-by-rule or
class permits and by covering post-closure permits with
enforcement orders, the universe of RCRA permits could be
reduced by two-thirds. In the NPDES program, site specific
requirements, and thus permits, may not be necessary for
many storm water point sources, feedlots, oil and gas
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PS 23
discharges, minor POTWs (Privately-owned Treatment Works)
and other point sources which are not impairing water
quality. In the UIC program, the issuance of 80% of Class V
UIC permits could be avoided, eliminating the need to issue
at least 150,000 permits. In the Air Program, the issuance
of certain permits may be reduced especially in attainment
areas. This shift away from site specific permitting could
reduce the issuance of tens of thousands of permits. The
savings are roughly estimated to be 20% of the EPA permit
FTE and permit grant or contract dollars. However, 6-7 FTE
per national program per year over 3-5 years would be
required to make the necessary regulatory changes.
Resources will be needed to revise standards to make them
self-implementing. These short term costs will be more than
compensated by long-term savings. For example, the
administrative resource savings for facilities no longer
covered by permits may be between $10,000 and $100,000 per
permittee (estimated cost for a facility to obtain a
permit).
Lapses or delays in permit issuance will be necessary to
begin issuing permits on a risk and ecosystem basis due to
data collection analysis needs. Some permits will not be
reissued at all. Self-implementing regulations will need to
be developed to ensure that these sources continue to be
required to meet environmental standards.
When setting priorities, the Agency should ensure that,
while focusing on cleaning up the worst environmental
problems, it does not neglect pristine areas that should
also be protected.
The Agency will need to revise its compliance strategy to
address self-implementing regulations. Compliance and
enforcement strategies must be cognizant of geographic and
other targeting schemes and not hinder these efforts.
ISSUEt IMPLEMENTING A CROSS MEDIA PROSPECTIVE
Agency permit programs are media specific, and cross
media impacts are not frequently addressed in assigning
permit limits. Following traditional permitting approaches,
pollutants can be transferred from one medium to another, or
even escape regulation altogether. In one recent example,
Philadelphia attempted to control emissions within its
airshed by requiring installation of precipitators on urban
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PS 24
smokestacks. The solids and sludges that were removed found
their way to the Delaware River, either directly through
discharge or indirectly through runoff from land disposal.
Once in the river, metals and other constituents that had
been removed from smokestacks through air pollution controls
were pushed upriver by natural tidal action until they
entered the city's drinking water intake. Extra funds had
to be allocated to remove these pollutants from drinking
water supplies.
The immediate reaction to this example is to recommend
a consolidated permit system. In fact, every time a permits
reform study is undertaken, the consolidated permits
question is revisited. The Agency promulgated regulations
establishing such a system in 1980, but in response to broad
based criticism these regulations were "de-consolidated"
within three years. The Federal consolidation of permits
did not produce the benefits expected. As part of the RCRA
Implementation Study, people from industry, environmental
groups and regulatory agencies were interviewed in Region
VI. Both industry and environmental group representatives
favored an integrated multi-media approach to permitting,
while EPA and State regulators felt the approach could not
work. Permit programs regulate inherently different
activities, requirements are unique and the consolidated
format is difficult to follow.
A recent study by the State of California on multi-
media permitting concluded that while no states are
currently permitting solely on a multi-media basis, several
states are moving in this direction and endorsed the idea
that further exploration is warranted.
RECOMMENDATIONS AND IMPLEMENTATION STEPS;
Coordinate permit issuance/reissuance for environmentally
significant sources to encourage the development of cross
media pollution reduction strategies. One method of
coordination might be the creation of permitting teams in
the Regions to review permits and identify cross media
transfer issues. Alternatively, EPA could phase in cross-
media permitting with several pilots covering a wide range
of alternatives, (e.g., combining UIC/RCRA; air/water;
water/RCRA; or sludge/ground water). The pilots may involve
volunteer permittees who are willing to invest in the
process in exchange for the potential flexibility.
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PS 25
IMPLEMENTATION STEPS: Implement this initial
strategy immediately and continue through FY'95.
Consider reorganization of OW, OAR, OSWER and OPPTS (both
HQ and Regions) along functional lines rather than media
lines similar to OE, OARM, OGC, ORD, IG, OIA and OPPE. This
structure will better promote cross media analysis and
consistency from program to program. For example, one
office may establish and update national, self-implementing
pollutant or industrial standards, while another is
responsible for site specific permitting of individual
facilities.
IMPLEMENTATION STEPS: Within nine months, OARM will
prepare a draft report for the Administrator, that
also examines the implications of reorganization and
evaluates other alternatives that effectively
promote/facilitate cross media considerations with a
final report within 12 months.
Invest in compatible data systems to allow for cross media
analysis of impacts when setting permit limits.
IMPLEMENTATION STEPS: Starting immediately, and
continuing for an additional 2-4 years.
Develop a coordinated approach across media programs in
dealing with similar pollutants. There are significant
differences with respect to pollutants considered important
under RCRA, the Clean Air Act and the Clean Water Act.
While the pollutant's effect in each media may account for
some of this disparity, it does not justify it all.
IMPLEMENTATION STEPS: On-going.
Amend statutes/regulations which mandate the use of
specific control technologies (as opposed to merely setting
a pollutant reduction target). These barriers must be
removed for the Agency to be able to successfully implement
cross media, pollution prevention and innovative
"technology-forcing" approaches.
IMPLEMENTATION STEPS: Over the next 3 years, amend
statutes as opportunities arise, including the Clean
Water Act, Safe Drinking Water Act, Resource
Conservation and Recovery Act; in the same time frame,
consider developing an Administration Bill to implement
the changes recommended in this report.
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PS 26
Before implementing a consolidated permit program,
establishing a pilot, or even empowering another task force
to revisit the idea, OPPE should prepare an issue paper for
the Administrator that consolidates the findings of past
studies and task forces with the results and recommendations
from the California study, the New Jersey pilot and other
state efforts. These results can be combined with a survey
of permit stakeholders focusing on the feasibility of a
consolidated permits program.
IMPLEMENTATION STEPS: OPPE should conduct the
historical review and the survey of stakeholders
and present the Administrator with an issue paper
within 4 months.
IMPLICATIONS;
To effectively conduct cross media permitting will require
an investment in environmental data collection by both EPA
and the permittee. The up front data collection costs will
be high, but generally will be offset by acceptance and use
of the data system and by savings to the permittee in
overall pollution control costs. Rough estimates of CIS
implementation are almost $15 million over the next five
years for initial set up to implementation in all ten
regions. Savings in outyears go from design to maintenance
to reduce overlap. System training will be needed.
Cross media permits offer the opportunity for greater net
environmental gain by promoting greater facility-wide risk
reductions and discouraging those cross media pollution
transfers that tend to increase risk. One result is more
environmental protection for about the same cost. Data
needs to be collected from various pilot studies to further
document cost savings.
Cost savings will be realized by examining pollution
prevention alternatives as well as end-of-pipe controls.
Cross media concerns may also spur technological innovation.
The Amoco study showed that, given the flexibility, the
Amoco Yorktown refinery could remove about 97% of tons of
airborne hydrocarbons at about 25% of the cost of reducing
them under current and anticipated permit requirements.
Developing a permit to consider cross media impacts may
delay permit issuance due to data constraints and the
analysis of alternatives and several media specific permits
may lapse. EPA oversight responsibilities will need to be
modified to allow the use of alternative and/or innovative
cross media considerations by Regions and states.
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PS 27
ISSUE; MEASURING THE ENVIRONMENTAL SUCCESS OF PERMITS
Currently, the Agency measures the success of some of
its permit programs based on how many permits are
issued/reissued. Moreover, these administrative measures do
not necessarily provide the Agency with an indication of the
effectiveness and degree of environmental improvement gained
from the permit programs.
EPA has made several false starts creating a risk data
base. The result is a proliferation of inconsistent, media-
specific, data systems. These existing information systems
are limited in their utility as tools for targeting or
priority setting. Generally, these data systems track
quantitative, administrative information rather than
environmental impacts. Data on the most cost-effective
means for pollutant reduction is lacking. Moreover, most
Federal media specific systems are not compatible with each
other or with State systems. Similarly, data linkages with
other Federal agencies, such as the Fish and Wildlife
Service and NOAA, are limited at best.
RECOMMENDATIONS AND IMPLEMENTATION STEPS;
Designate the Geographic Information System (CIS) as the
Agency's single approach to integrating environmental risk
assessment. Improve the system to allow risk analysis by
permit writers, strategic planners and managers. It should
look across media and identify releases/emissions/discharges
of concern. Ensure that CIS can interface with other
Federal and State agencies concerned with pollution control
and that State data can be uploaded into the Federal system.
IMPLEMENTATION STEPS: OARM will take the lead and
coordinate with other Assistant Administrators, to
conduct a one year study and present recommendations
to the Administrator on the feasibility of CIS to
be a single system and recommend any appropriate
alternatives.
In the interim, improve and use existing data systems
(i.e., TRI, PCS, STORET, and FRDS) to independently
determine appropriate geographic areas for targeting permit
issuance. In addition, make greater use of external data
sources such as the Nature Conservancy's Heritage Data
(biodiversity); U.S. Fish and Wildlife Service (threatened
and endangered species); National Institute for
Environmental Studies (species inventory); U.S. Geological
Survey and National Oceanic and Atmospheric Administration.
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PS 28
IMPLEMENTATION STEPS: Continue work on existing data
systems to provide geographic data for permitting
work with the PIC and the EPA library to assure
increased access to external data systems.
Revise application regulations and forms to solicit data
on key environmental indicators. Use latitude and longitude
data to coordinate facility information between permit
programs. Make the submission of environmental data a pre-
condition for obtaining administrative continuation of a
permit.
IMPLEMENTATION STEPS: Develop criteria by FY'95 on both
an agency-wide and program specific-basis;
implementation will follow.
In the interim, revise boilerplate conditions to require
environmental data to be submitted as an enforceable
condition of the permit. Incentives for voluntary
submission can also be used until regulations are revised
(e.g., less frequent monitoring, longer term permits).
IMPLEMENTATION STEPS: Within 12 months, each program
office should issue a policy that every permit issued/
reissued must include specific environmental data.
Revise existing program oversight criteria to account for
the quality and environmental results gained by the various
permits, in lieu of some of the Federal and State
programmatic activities currently tracked (e.g., issuance,
reissuance).
IMPLEMENTATION STEPS: Each office, beginning with
FY'95 Budget, operating guidance and accountability
systems will move beyond traditional oversight and bean
counting approaches and include new measures geared to
environmental results.
EPA and States should develop a joint effort to randomly
check and ensure permit compliance to ensure vigorous
enforcement of permit schedules and limitations.
IMPLEMENTATION STEPS: The Office of Enforcement would
work with Regions and States to develop goals and
guidelines within six months.
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PS 29
IMPLICATIONS;
Obtaining data on key environmental indicators is a
prerequisite to establishing a risk-based, permitting
priority scheme and allowing more innovation and flexibility
with in Agency's various permitting programs. Current
information systems can only crudely perform this function
and must be improved.
The cost of starting up and maintaining a single
Federal/State system will be substantial (see cost estimates
on page 25). Requiring each applicant to provide
environmental quality data will be expensive as well,
particularly for small business. However, the data entry
efficiencies and environmental effectiveness gained are
expected to offset the expense. Moreover, expenses can be
mitigated by shifting them to the regulated community,
(e.g., by providing for electronic data entry). Centralized
data reporting will also result in additional savings by
States.
Centralization of permit application data will also
facilitate public awareness and participation in the permit
process.
Creating a new single data system is likely to be
controversial and require a substantial transition period.
EPA itself may need to reorganize to allow the existing data
bases to be consolidated, (e.g., create an Assistant
Administrator for Environmental Data). Media programs and
the States have invested in individual data systems.
However, this may be offset by the flexibility of a targeted
permit system and the ability to conduct more precise
analysis of environmental concerns.
The system will enable the Agency to better evaluate
environmental risk, predict emerging problems and react
quickly to changes in environmental quality. Such a system
will also be able to relate the conditions (or success) of a
permit in improving and maintaining local environmental
conditions.
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PS 30
Access EPA (a directory of EPA's and other public sector's
environmental contact information resources and a
description of their services) is available at a
minimal charge in hard copy form from the EPA's PIC and
online at no charge.
Access Express (a quick reference guide to major EPA
information contacts and services throughout the
country) is available at no charge from EPA's PIC.
"Administrator's Point/Nonpoint Source Trading Initiative
Meeting." U.S. Environmental Protection Agency,
Durham, North Carolina, April 1992.
Air and Waste Management Association Surveys.
"Air Pollution: Difficulty in Implementing a National Air
Permit Program." GAO Report. GAO/RCED-93-59, February
1993.
American Academy of Environmental Engineers. Environmental
Quality and Industrial Competitiveness, Proceedings of
the Workshop on Environmental Issues Related to
Industrial Competitiveness. April 1989.
Amoco-U.S. EPA Pollution Prevention ProjectExecutive
Summary. December 1991.
Amoco-U.S. EPA Pollution Prevention Project, Yorktown,
Virginia Project Summary. January 1992.
"An Approach to the Regulation of Bioremediation of
Polychlorinated Biphenyls."
Ashford, Nicholas A., Christine Ayers, and Robert F. Stone.
"Using Regulation to Change the Market for Innovation."
Harvard Environmental Lav Review. Vol. 9, pp. 419-
466.
"A State Resource Guide." (a quick reference to some of the
many sources of environmental data and information
assistance programs and services that are currently
available to States and Native Americans) For the
States, through the State/EPA Data Management Program,
this publication is available at no charge from the
EPA's PIC.
Barnwell, Thomas O. "National Performance Review
Memorandum." Athens, 9 July 1993.
BID on Federal Notice on promulgation, December 1992. EPA-
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PS 31
450/3-92-006b.
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PS 32
Boomer, Bruce A., Paul G. Gorman, Thomas P. Dux, Jared
Flood, Joan Blake, Denise M. Keehner, and John H.
Smith. "Guidance Manual for Writers of PCB Disposal
Permits for Alternate Technologies." Midwest Research
Institute and the U.S. Environmental Protection Agency.
1 October 1988.
Carra, Joe and Hanson, Bill. "Situational Map of
Env i ronmenta1 Techno1ogy."
Carroll, Lynda. "Region VI TQM Projects Involving Permits."
Dallas: USEPA, July 1993.
Certification Programs for Banking and Trading of Oxides of
Nitrogen and Particulate Emission Credits for Heavy-
Duty Engines, Federal notice on 25 May 1989, p. 22652.
"Challenges for the Future." Water Quality 2000. Interim
Report, June 1991.
Commonwealth of Virginia. U.S. Environmental Protection
Agency. Action Plan for Permitting Efficiency and
Effectiveness.
Compliance extensions for early reductions (for Hazardous
Air Pollutants), proposed 13 June 1991 56FR27338,
promulgated 29 December 1992, 57FR61970.
"Consolidate Permit Regulation," 45 Federal Register 33291.
19 May 1980.
Consolidated EPA Permitting Procedures, Code of Federal
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Conversation with Jim Michael of Office of Solid Waste and
Emergency Response. Washington, D.C., July 1993.
"Deconsolidated Permit Regulations." 48 Federal Register
14146. 1 April 1983.
Draft Guidance on Long-Term Averaging to Meet the Nitrogen
(NOX) Reasonably Available Control Technology (RACT)
Requirement, currently under development.
Draft Guidance on Reasonably Available Control Technology
(RACT) for Oxides of Nitrogen (NOX) Trading Guidance,
currently under development.
Economic Incentives, Options for Environmental Protection,
March 1991.
-------
PS 33
Emissions Trading Policy Statement; General Principles for
Creation, Banking and Use of Emission Reduction
Credits; Final Policy and accompanying Technical Issues
Document, Federal Register. 4 December 1986, p. 43814.
Employee Commute Options Guidance, ANR-443, December 1992.
Enabling Document for regulations governing compliance
extensions for early reductions of HAPS,
EPA-450/3-91-013, July 1991.
Environmental Community Agreement Between the Kenai
Peninsula Borough and the Alaska Department of
Environmental Conservation.
"Environmental Enforcement: EPA Needs a Better Strategy to
Manage its Cross-Media Information." GAO/IMTEC-92-14,
2 April 1992.
Environmental Law Institute. "Biological Diversity and
Environmental Protection: Authorities to Reduce Risk."
9 August 1991.
Environmental Law Institute. "Interagency Perspectives on
EPA Options for the Protection of Habitat." February
1993
Environmental Law Institute. "State Hazardous Waste
Enforcement Summary." October 1987.
Environmental Law Institute. "Nongovernmental Perspectives
on EPA's Options for Protection of Habitat." January
1993.
EPA/State Multi-Media Permitting Pilot Initiative.
Faigenblum, Jacques, ed. "The Puget Sound Urban Bay Action
Program Action Team Accomplishments." The Urban Bay
Action Program; Action Team Accomplishments 1985-1990
Olympia: Washington State Department of Ecology,
June 1990.
Federal Register. 40 CFR Part 761.
Fetzer, Richard M. "An Evaluation of the Pennsylvania
Department of Environmental Resources Permit
Coordination Policy and Procedure."
Fischman, Robert L. "Biological Diversity and Environmental
Protection: Authorities to Reduce Risk."
Environmental Law. Vol. 22:435, 1992, pp.437-502.
-------
PS 34
Guidance for Emission Reduction Credit Generation by Clean
Fuel Fleets and Vehicles. Ann Arbor: USEPA, February
1993.
Guidance for the Implementation of Accelerated Retirement of
Vehicles Programs. Ann Arbor: USEPA, February 1993.
Guidance for Mobile Emission Credit Generation by Urban
Buses. Ann Arbor: USEPA, February 1993.
The Habitat Cluster. "Protecting Habitats and Ecosystems:
An EPA Strategy." Washington, B.C.: USEPA, 14 January
1993.
Highlights of the EPA Innovative Strategies workshop,
Market-Based Incentives and Other Innovations for Air
Pollution Control, June 1992.
Hudiburgh, Jr., Gary W. "Issuance of NPDES Permits."
Washington, D.C.: USEPA, 20 March 1991.
Humphries, John. "Options for Improving the Permit
Process." June 1993.
"Increase State Oversight of the Liquidator/Receiver's
Office of the State Board of Insurance." Texas
Performance Review. July 1991, pp. 61-62.
Industrial Economics, Inc. "Integrated Permits: What Are
the Data Requirements?" Cambridge: September 1990.
"Information Resources: Summary of Federal Agencies'
Information Resource Management Problems." GAO/IMTEC-
92-13FS, 13 February 1992.
"Information Technology Issues." GAO/OGC-89-6TR, November
1988.
"Injection Wells: An Introduction to their Use, Operation
and Regulation."
Innovative Regulatory Strategies Workshop handbook, January
1992.
Interim Guidelines on the Generation of Mobile Source
Emission Reduction Credits, notice. Federal Register.
23 February 1993, p. 11134.
Klee, Ann R. "Small-Business Woes." Legal Times. 31 May
1993, pp. 15-20.
-------
PS 35
Kling, David K. Briefing on Pollution Prevention and
Permitting Under the Clean Air Act. Washington, D.C.:
USEPA, 1993.
Leif, Frederick S. "Permit StreamliningNational
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July 1993.
Loehr, Raymond C. "Multi-Media Aspects of Waste
Management." Public Interest in Private Lands.
"Making Information Work Conference Proceedings."
National Governors Association: January 18 - 23, 1992.
"Major Source Permitting An Overview."
Manthei, John. "Survey of the Impact of the Air and Water
Permitting Processes on Technological Innovation by
Permittees." Environmental Protection Agency,
Office of the General Counsel, Washington, D.C.
Mehan III, G. Tracy. "Review of TQM Permitting Projects
Underway in Regions."
Morell, David L. "Effective Toxics Management: A Multi-
Media Perspective." Public Interest in Private Lands.
"Municipal Solid Waste Landfill (MSWLF) Criteria
Permitting." U.S. Environmental Protection Agency.
The National Advisory Council for Environmental Policy and
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Technology Innovation and Economics (TIE) Committee.
April 1991.
National Environmental Developmental Association Clean Air
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National Governors Association. "Making Information Work."
Conference Proceedings. 18-23 January 1992.
Novello, David P. "The New Clean Air Act Operation Permit
Program: EPA's Final Rules." Environmental Law
Reporterf February 1993, pp. 10080-10094.
Novotny, Dr. Vladimir, ed. "Nonpoint Pollution: 1988
Policy, Economy, Management, and Appropriate
TechnologySymposium Proceedings." American Water
-------
PS 36
Resources Association.
-------
PS 37
NPDES Permit Program. Permits Division OWEC. 7 May 1993.
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1993, the Federal Page.
"Perceived Barriers to Effective Information Resources
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GAO/IMTEC-92-67, September 1992.
The Permit Dilemma: Deadlines vs. Need
Podar, Mahesh and Luttner, Mark. Economic Incentives in the
Clean Water Act; Some Preliminary Results.
Washington, D.C.: USEPA Office of Water, 1993.
Procedures for Establishing Emissions for Early Reduction
Compliance Extensions, EPA-450/3-91-12a, February 1992.
Proposed Rulemaking on Economic Incentive Program Rules.
Federal Register. 23 February 1993, p. 11110.
"The PSD Program: An Overview." May 1993.
Quarles, John and Lewis Jr., William H. "The New Clean Air
Act: A Guide to the Clean Air Program as Amended in
1990." Washington, D.C.: Morgan, Lewis, & Bockius,
1990.
Questions and Answers on the Early Reduction Program (for
HAPS), EPA-450/3-92-005, January 1992.
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Regulation of Fuel Additives; Banking of Lead Rights; Final
Rule, Notice in Federal Register. April 2, 1993,
p.13116.
"Setting Environmental Priorities: The Debate About Risk."
EPA Journal. March/April 1991.
STAPPA/ALAPCO correspondence with EPA.
State of California. Secretary of Environmental Protection.
"Draft Recommendations for Consolidating and
Streamlining the Cal/EPA Permit Processes." March
1992.
Survey of Permits Branch Chiefs, Regions I-X; State contacts
and Permittees in the Air, NPDES, RCRA, TSCA, and UIC
programs.
Training course evaluation forms.
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PS 38
Tschirgi, Dan. "Permits Section Quality Management
Initiative." State of Missouri Department of Natural
Resources, 1 March 1993.
"Unit Resource and Cost Comparisons for Potential Regulatory
Options."
U.S. Environmental Protection Agency. "Clean Air Act Title
V: Operating Permits Workshop." Durham: USEPA, 10-11
August 1992.
U.S. Environmental Protection Agency. "Incentives for
Development and Registration of Reduced Risk
Pesticides." Draft Federal Register Notice, January
1993.
U.S. Environmental Protection Agency. "The Nation's
Hazardous Waste Management Program at a Crossroads:
The RCRA Implementation Study," EPA/530-SW-90-069.
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U.S. Environmental Protection Agency. "Project 88Round
II. Incentives for Action: Implementing Market-Based
Environmental Policies and Programs." Washington,
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U.S. Environmental Protection Agency. Task Force Draft
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Capacity, Strengthening Environmental Management in the
United States." Washington, D.C.: USEPA, 3 November
1993.
U.S. Environmental Protection Agency. Environmental Appeals
Board. EPA 100-F-93-001. Washington, D.C., February
1993.
U.S. Environmental Protection Agency. Federal Highway
Administration. U.S. Army Corps of Engineers. U.S.
Fish and Wildlife Service. National Marine Fisheries
Service. Interagency Task Force. "Integrating
NEPA/404 Processes for Transportation Projects." July
1992.
U.S. Environmental Protection Agency. Information Resources
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USEPA, June 1989.
U.S. Environmental Protection Agency. North Carolina
Department of Environment, Health, and Natural
Resources. "Administrator's Point/Nonpoint Source
Trading Initiative Meeting, A Summary." April 1992.
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PS 39
U.S. Environmental Protection Agency. Office of the
Administrator. Report and Recommendations of the
Technology Innovation and Economics Committee.
Permitting and Compliance Policy; Barriers to U.S.
Environmental Technology Innovation." The National
Advisory Council for Environmental Policy and
Technology (NACEPT). EPA 101/N-91/001, January 1991.
U.S. Environmental Protection Agency. Office of the
Administrator. Transforming Environmental Permitting
and Compliance Policies to Promote Pollution
Prevention: Removing Barriers and Providing Incentives
to Foster Technology Innovation. Economic Productivity.
and Environmental Protection. The National Advisory
Council for Environmental Policy and Technology
(NACEPT). EPA 100-R-93-004, April 1993.
U.S. Environmental Protection Agency. Office of Air Quality
Planning and Standards. New Source Review Workshop
Manual: Prevention of Significant Deterioration and
Nonattainment Area Permitting. October 1990.
U.S. Environmental Protection Agency. Office of General
Counsel. "Survey of the Impact of the Air and Water
Permitting Processes on Technological Innovation."
U.S. Environmental Protection Agency. Office of Information
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Systems."
U.S. Environmental Protection Agency. Office of Policy,
Planning and Evaluation. "AMOCO/USEPA Pollution
Prevention Project." Washington, D.C.: USEPA, May
1992.
U.S. Environmental Protection Agency. Office of Policy,
Planning and Evaluation. "Environmental Eguity,
Reducing Risk for All Communities." EPA230-R-92-008,
June 1992.
U.S. Environmental Protection Agency. Office of Policy,
Planning, and Evaluation. "Environmental Protection
Agency Fiscal Year 1994 Base Budget Review." May 1993.
U.S. Environmental Protection Agency. Office of Policy,
Planning, and Evaluation. Understanding and Managing
Cross-Media Effects of Pollutants in RCRA
Reauthorization. 20 June 1991.
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PS 40
U.S. Environmental Protection Agency. Office of Policy,
Planning, and Evaluation. The United States Experience
with Economic Incentives to Control Environmental
Pollution. July 1992.
U.S. Environmental Protection Agency. Office of Pollution
Prevention and Toxics. Notes from Woods Hole.
"Thursday Discussion Group Summaries: Environmental
Technologies and the Role of Federal Government."
U.S. Environmental Protection Agency. Office of Solid
Waste. RCRA Permit Appeals Guidance Manual. OSWER
Policy Directive #9521.00-01. Washington, D.C.,
January 1993.
U.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response. EPA/53O-SW-90-069. The
Nation's Hazardous Waste Management Program at a
Crossroads, RCRA Implementation Study. July 1990.
U.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response. STATS Report. 31 May 1993.
U.S. Environmental Protection Agency. Office of Toxic
Substances, Chemical Regulation Branch. Draft
Guidelines for Permit Applications and Demonstration
Test Plans for PCB Disposal by Non-Thermal Alternative
Methods. Washington, D.C.: USEPA, 21 August 1986.
U.S. Environmental Protection Agency. Office of Toxic
Substances, Chemical Regulation Branch. "Guideline for
Permit Applications and Demonstration Test Plans for
PCB Incinerators." Washington, D.C.: USEPA, 28 May
1986.
U.S. Environmental Protection Agency. Office of Wastewater
Enforcement and Compliance, Permits Division.
"Overview of the Storm Water Program." Washington,
D.C.: USEPA, March 1993.
U.S. Environmental Protection Agency. Office of Wastewater
Enforcement and Compliance. "The National Sewage
Sludge Program." Sludge Use or Disposal Regulations
Fact Sheet Series. 9 March 1993.
U.S. Environmental Protection Agency. Office of Water. "A
Primer on the Office of Water Enforcement and Permits
and its Programs." Washington D.C.: USEPA, March
1990.
-------
PS 41
U.S. Environmental Protection Agency. Office of Water.
"Effluent Charges and Water Quality: A Preliminary
Assessment." Draft Report. Research Triangle Park:
Research Triangle Institute, May 1992.
U.S. Environmental Protection Agency. Office of Water.
"Geographic Targeting: Selected State Examples." EPA-
841-B-93-001, February 1993.
U.S. Environmental Protection Agency. Office of Water.
"The Watershed Approach: An Overview." Washington,
B.C.: USEPA, December 1991.
U.S. Environmental Protection Agency. Office of Water.
"The Watershed Protection Approach: Annual Report
1992." January 1993.
U.S. Environmental Protection Agency. RCRA Permits Branch,
Region VI. "Model Permit Documents: TQM Project 1."
March 1993.
U.S. Environmental Protection Agency. RCRA Permits Branch,
Region VI. Hazardous Waste Management Division.
"Corrective Action Customer AlignmentConference
Proceedings." Dallas: USEPA, 27-28 January 1993.
U.S. Environmental Protection Agency. RCRA Region VII.
MDNR/EPA Joint RCRA Permit and Closure Procedures. 17
October 1986.
U.S. Environmental Protection Agency. RCRA Region VII.
Missouri Interim Authorization Transition Plan for
Corrective Action.
U.S. Environmental Protection Agency. RCRIS Office of Solid
Waste and Emergency Response. Baseline Performance
Measures Report. Washington, D.C., 24 June 1993.
U.S. Environmental Protection Agency. Science Advisory
Board. Reducing Risk: Setting Priorities and
Strategies for Environmental Protection. September
1990.
U.S. Environmental Protection Agency Region III. Air,
Radiation and Toxics Division. "1990 Clean Air Act
Amendments Impacts on the Business Community."
September 1991.
U.S. Environmental Protection Agency Region VI. "Corrective
Action Customer Alignment, Conference Proceedings."
January 1993.
-------
PS 42
U.S. Environmental Protection Agency Region VI. "Region VI
Comparative Risk Project." November 1990.
U.S. Environmental Protection Agency Region IX, April 1993.
"Strategic Plan, Fiscal Years 1995-1998."
U.S. Environmental Protection Agency Region X. Proceedings
from "Reaching Out: Improving Environmental Services to
Small Communities. A Workshop for Providers of
Financial, Technical, and Regulatory Assistance."
Portland: USEPA, 16-17 April, 1993.
U.S. Environmental Protection Agency. TQM, RCRA Permits
Branch, Quality Action Team. "Project Documentation:
TQM Project 1." March 1991.
"Virginia makes headway on environmental permits." Virginia
Natural Resources Newsletter. May 1993, pp. 1-2.
Virginia Natural Resources Newsletter. May 1993.
Washington State Department of Ecology, Water Quality
Program. "Wastewater Discharge Permit Action Plan:
Report to the House Environmental Affairs Committee."
19 September 1991.
Wegman, Linda and Stolpman, Paul. Title IV-Title V
Interface Guidance for States. U.S. Environmental
Protection Agency, Office of Air Quality Planning and
Standards, Office of Atmospheric Programs: Washington,
D.C., 1993.
"What Cost Public Information?" Washington Post. 21 June
1993, p.4, Business section.
Willey, Zach. "Implementing Market-Based Instruments for
Clean Water in America." Environmental Defense Fund,
Session 7.
Yee, Dr. Mon. "Streamlining of EPA's Permit Program Would
Improve Agency Efficiency and Customer Service." Vice-
President's National Performance Review. July 1993.
Yee, Dr. Mon. Draft: "Streamlining of EPA's Permit Program
Would Improve Agency Efficiency and Customer Service."
Washington, D.C.: National Performance Review, July
1993.
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PS 43
ADDITIONAL DATA COLLECTION EFFORTS
NPR Suggestion Forms
Survey of Regional Permit Branch Chiefs (attached)
Review and Comment of Early Draft by Acting Assistant
Administrators and Acting Regional Administrators
Focus Groups and Interviews With EPA Employees and
State Representatives
-------
PS 44
CONTRIBUTORS
PERMITS STREAMLINING TEAM
Elaine Wright, Team Leader
William Rhea, Facilitator
Karl Bremer, Workgroup Leader
Mark Charles, Workgroup Leader
Wanda Haxton, Workgroup Leader
Nancy Mayer, Workgroup Leader
Ken Adler
Kathryn Allen
Voicetta Bryant
Cynthia Dougherty
Carol Glasgow
Randolph Hill
Susan Hodges
Mark Jen
Claudia O'Brien
John Pai
Margaret Moore Smith
Rita Smith
David Solomon
Adib Tabri
Harriet Tregoning
Region III
Region VI
Region V
Office of Water
OPPE
Office of Air & Radiation
OPPE
OGC
OPPTS
Office of Water
OPPTS
OGC
Region III
Office of Water
OPPTS
Office of Water
Region VI
Office of Water
Office of Air
ORD
OPPE
TEAM ADVISORS
Marcie Eskin
Rob Forrest
David Heckler
Jim Pendergast
Marcia Spink
Alissa Strauss
Rob Wood
Region V
OPPTS
Environmental Appeals
Board
Office of Water
Region III
Region III
Office of Water
SUPPORT STAFF
Myrtle Bingham
Harriet Smith
Joe Jackson
Helen McCue
Marie Owens
Office of Air & Radiation
Region III
Region III
Region III
Region III
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PS 45
GLOSSARY
Class Permit- or Permit-by-Rule
This option is a form of authorization to operate similar to a
permit, but is applied on an industry-, size-, or class of
facility-^wide basis. Administrative and operating standards are
established in regulation. A facility owner or operator then may
be deemed to have a permit upon notification to the appropriate
office of the facility's intent to operate pursuant to the
regulations, certification of compliance with the regulations,
and/or receipt of an approval from the program. This option
provides yet more flexibility in establishing operating standards.
Cross Media
Anything that affects more than one end point for pollution (often
referred to as "environmental medium" i.e., air, water, ground-
water) .
Ecological Risk
The species that may suffer harm when their environment is altered
in cleanup.
Ecosystem
Community of different species and their physical environment.
Emission Fees
Fees levied on permittees by a permitting authority based on
the amount of pollution emitted into the environment. The
fees could be structured to only cover the administrative
costs of issuing the permit or could also cover additional
expenses, such as pollution prevention, research projects or
extra emission controls.
Environmental Justice
The concept of insuring that all individuals are protected equally
from environmental risks, (i.e., that members of low-income and
minority communities do not bear a disproportionate environmental
risk). In the permitting context, this would mean that permits at
sites in underprivileged areas are written and enforced to insure
the same degree of protection as are permits in areas with higher
visibility.
General Permit
This option operates the same as permit by rule, but provides more
regulatory flexibility in that the permit conditions can be
adopted administratively rather than being subject to a rulemaking
process. The permit can also be reviewed periodically, and
necessary changes made more easily.
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PS 46
Geographic Information Systems (GTS)
CIS are an advanced computer technology that combines map, model,
and monitoring data into one comprehensive analytic framework,
which assists engineers, scientists, and managers in identifying
and assessing environmental problems and trends. A CIS provides
sophisticated tools for data base creation, data base management,
analysis of spatial and parametric information, and map
production. A major CIS analytical function is to assign colors
or patterns to multiple map themes and overlay them to reveal
spatial relationships. Used properly, CIS has the potential to
illustrate to EPA managers and decision-makers the impacts of
environmental policies and programs.
Innovative Strategies
Any emission control strategy that differs from the historic
method for meeting environmental goals. Specifically, this
includes pollution prevention, emission fees, marketable emission
allocations, and other less orthodox emission control
techniques.
Major Permit or Minor Permit
A system for classifying permittees by their level of
environmental risk or regulatory concerns. Each EPA permit
program uses different criteria (and sometimes different terms to
classify and characterize "major"/llminor11 permittees.
Market-Based Incentives
Any scheme or policy designed to induce environmentally acceptable
behavior through non-regulatory means. For example, a scheme
whereby permittees may trade the rights to emit pollutants to an
environmental medium for monetary compensation.
Marketable Emission Rights
A market-based incentive that allows for trading of authorization
from the permitting authority to emit levels of pollutants.
Media-specific
Anything relating to activities, policies or controls within a
single environmental medium. Also, since most EPA permit programs
ate organized to control the addition of pollutants to a single
environmental medium, the term also refers to activities of an EPA
Permit program.
Permit
A required legally defensible document issued by EPA or the States
and to a facility that tells them what they can and cannot do and
reporting requirements. A means to achieve environmental quality.
Pennit-ty-Rule or Class Permit
See Class Permit
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PS 47
Pollution Prevention
Refers to the use of materials, processes, practices or products
which reduce or eliminate the generation of pollution. It is a
tool which can be applied to all sectors of economic activity to
conserve natural resources, minimize risk to human health, and
protect ecosystems.
Post-Closure Permits
A permit issued under the Hazardous Waste Program which specifies
requirements for the continued monitoring and oversight of closed
hazardous waste treatment, storage, or disposal facilities.
Regulations
A regulation is issued by EPA and has the full force of law. They
are, in effect, "administrative statutes" providing clarification
and refinement of statutes. Because they impose obligations and
affect the rights of the public, EPA must follow certain policies
and procedures when it develops rules. These policies and
procedures are found in general statutes (e.g., The Administrative
Procedures Act, Paperwork Reduction Act, Regulatory Flexibility
Act, etc.), specific states (EPA's authorizing legislation,
Executive Orders (i.e., E.O. 12044; E.O. 12291), judicial
decision, and the Agency's own internal regulation management
system.
Site-specific
Anything relating to activities, policies or controls within a
single facility. For instance, controls on a waste water
treatment plant that are based on information about the volume and
types of pollutants, typically found at that particular location
as opposed to controls based on the "typical waste water treatment
plant."
Statutes
Statutes are laws enacted by Congress and can be quite specific.
Some establish clear goals, criteria for determining what and how
to regulate and timetables for doing so. All statutes require
clarification or refinement before a regulatory program can be put
in operation. EPA must frequently define key statutory terms and
specify numerous details regarding how regulated parties will
comply with the law. EPA is responsible for providing
clarification and refinement through its regulations. Some of
EPA's statutes are the Clean Air Act (CAA), Clean Water Act (CWA),
Safe Drinking Water Act (SDWA), Toxic Substances Control Act
(TSCA), Federal Insecticide, Fungicide and Rodenticide Act
(FIFRA), Resource Conservation and Recovery Act (RCRA), Emergency
Planning and Community Right-to-Khow Act of 1986, Title III of
Superfund Amendments and Reauthorization Act (SARA), Comprehensive
Environmental Response, Compensation, and Liability Act (CERCIA).
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PS 48
Superfund
The popular name for the Comprehensive Environmental Response,
Compensation, and Liability Act (CERdA), which specifies
requirements and makes available federal funds for the cleanup of
old hazardous substance disposal sites.
Targeting
Any of several approaches for establishing risk-based priorities
for issuance and enforcement of environmental permits (e.g., on a
geographic basis, industry basis, or pollutant basis).
-------
STATUS OF STATE EEIBGATION**
PS 49
STATES
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of
Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Ma i ne
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
NPDES
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
PSD
X
X
X
X
X
X
X
X
/
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
/
X
NSR
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
TITLE
V
RCRA
/
*
/
/
/
/
»
/
/
/
/
/
/
/
/
»
/
/
/
/
/
/
UIC
X
/
X
/
/
X
X
/
X
X
X
/
X
X
X
X
X
X
X
X
X
X
X
X
PWSS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
PS 50
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
American Samoa
Guam
North Marianas
Puerto Rico
Trusted
Territories
Virgin Islands
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
.
.
-
.
-
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
/
X
X
X
.
.
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-
-
/
*
»
*
/
/
/
/
/
/
*
/
*
»
/
/
/
/
/
X
X
X
X
X
X
X
X
/
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Note regarding Title V: States are not required to submit operating permit programs
until November 15, 1993
EPA retains authority over designated Native American reservations.
-------
PS 51
LEGEND:
X States that are fully authorized under the given statute
/ States that are partially authorized under the given statute
+ States that will receive delegation in November 1993
States that are authorized for most major requirements; joint Federal/State permits may be necessary
- Information currently unavailable
NPDES National Pollutant Discharge Elimination System
PSD Prevention of Significant Deterioration (one section of NSR)
HSR New Source Review (other than the PSD section)
Includes major dischargers only in nonattainment areas and minor dischargers in all areas
TITLE V Operating programs under Title V of the Clean Air Act
RCRA Resource Conservation and Recovery Act
UIC Underground Injection Control
PUSS Public Hater System Supervision program
-------
-------
REPORT OF THE
PLANNING AND BUDGETING
TEAM
NATIONAL
PERFORMANCE
REVIEW
-------
-------
PB 1
BUDGET AND PLANNING WORK GROUP
SUMMARY
The Budget and Planning Work Group has been meeting since
October 1992. The Work Group has focussed on improvements to
the planning and budget processes rather than devising new
processes. The Work Group has broad-based representation from
the Headquarters' and Regional resource communities. The
recommendations developed by the Work Group are based on a
survey of the Agency's senior political and career executives
and the expertise of the Work Group members.
The recommendations are not directly affected by changes
in leadership at the Agency and the emergence of a new
relationship with OMB. Major policy decisions are required to
implement these recommendations. The deliberations of the
Work Group have helped to frame these decisions and served as
a forum to discuss the strengths and weaknesses of various
strategies to improve the Agency's planning and budget
processes.
RECOMMENDATIONS
1. The functions of planning, budgeting, and financial
(extramural) management need to be integrated into a
single process.
2. The Agency's integrated planning, budgeting, and
financial management process needs to be clearly
articulated, step-by-step, delineating roles, timing,
responsibilities, and outcomes.
3. The Regions should have an enhanced role in this process,
especially regarding budget development.
4. The process should provide the opportunity for the states
to participate in the Agency's planning and budgeting
activities.
5. Basic planning and budget decisions should be made as
early as possible.
6. The Agency needs to develop incentives for disinvestments
and redirections at all levels in Headquarters and in the
Regions.
7. The Agency should investigate the following improvements
that are beyond the Agency's control.
a. The necessity and utility of the OMB exhibits
that accompany the Agency submission.
b. Developing a two-year budget cycle.
c. Consider multi-year appropriations.
d. Provide incentives to Agencies that save money.
e. Resolve the apparent inconsistency between
empowerment and decentralization concepts of
the NPR and the centralization and
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micromanagement realities of FMFIA,
the IG, the GAO, and the Congress.
Make the appropriations process more
meaningful.
Review reporting requirements to OMB and the
Congress and eliminate unnecessary reports.
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VISION
The Agency has a fully integrated, clearly
articulated strategic planning, budget development,
and financial accountability process that is used by
senior managers to make resource decisions and to
demonstrate commitment to and progress towards the
Agency's strategic priorities.
INTRODUCTION
The Planning and Budget Work Group was convened at the
direction of the Deputy Administrator in October 1992. The
primary goals for the group are to examine the process used
during the development of the FY 1994 budget and to lay out a
process for the development of the FY 1995 budget based on the
Agency's strategic priorities. The composition of the Work
Group is broad-based with representatives from the planning
and budget functions at the Assistant Administrator level, as
well as representatives from OPPE, the Office of the
Comptroller, the 12th floor, and the Regions.
The Work Group views the National Performance Review as a
source of legitimacy for the review of the Agency's planning
and budget development functions and as an important forum to
discuss ways to reinvigorate and refocus these processes. The
Work Group has had an active exchange of information and
experiences and has also relied on the information collected
in the client survey to develop the recommendations that
follow.
PREVIOUS EFFORTS OF THE BUDGET REFORM TASK FORCE
The Planning and Budget Work Group is the successor to
the Budget Reform Task Force that had been in existence for
the preceding two years. The members of this Task Force were
Assistant Administrators and Regional Administrators. In
January 1992, the Task Force issued recommendations to guide
the FY 1994 budget development process. The Task Force
strongly recommended the integration of the Agency's planning
and budget functions and proposed a general process for this
purpose. The Task Force recommended that the Agency and the
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media strategic plans should be multi-year documents; the
annual budget request represents a one-year plan to move
towards the goals and objectives outlined in the strategic
plans.
The Task Force also recommended that the resource
community participate in the formulation of a
linking/integrating mechanism between strategic plans and the
budget. The Task Force outlined a process for the internal
development of the FY 1994 budget beginning with Agency-wide
planning efforts.
PLANNING AND BUDGET WORK GROUP ACTIVITIES
At the first meeting, the members of the Work Group
concluded that, for a variety of reasons, the process outlined
by the previous Task Force in January 1992 had NOT been
implemented successfully. The Work Group determined that
"Guiding Principles" used by the Budget Reform Task Force were
sound and they were used by the work group as recommendations
were developed to integrate planning and budgeting. The
principles are:
1. Seek broader, more informed participation in the budget
process.
2. Provide opportunity for senior management input at
critical stages of the process.
3. Identify all potential claimants early in the process.
4. Encourage meaningful Regional participation.
5. Enhance the Agency's decision-making process by
establishing and communicating evaluation criteria up
front, and by providing timely feedback.
6. Clearly articulate major roles and responsibilities of
all parties.
7. Provide adequate time for developing an Agency strategy
for packaging and effectively marketing the budget to OMB
and the Congress.
8. Utilize personnel effectively by providing clear
guidance, realistic deadlines, and recognizing the
limited resources dedicated to planning and budget
formulation. Rework should be eliminated, whenever
possible, to allow time for value-added work.
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9. Continuously improve the interaction and communication
among the various parties that comprise the resource
community.
The Work Group determined that it was important to have
information from the "clients" of the budget process, the
Agency's political and senior career managers, regarding the
usefulness of the process in meeting their management needs
and their ideas to improve this process.
In order to collect information from the "clients" of the
budget process, the Work Group developed a survey instrument
and distributed it to approximately 50 political and career
executives. The Work Group was particularly interested in
knowing if the Agency's senior management viewed the budget
process as focussing on the right issues and if it was
providing them with timely information to make decisions and
develop recommendations for the Administrator's consideration.
Although the interviewers used the survey to guide the
interviews, the responses did not always fall into precise
categories. As a result, the responses did not lend
themselves to statistical analysis; however, they did provide
interesting views of the Agency's planning and budget
activities and ideas for improvement.
SUMMARY OF THE RESULTS OF THE CLIENT SURVEY
The comments and responses regarding the use of themes
and initiatives as an organizing framework for the budget
indicated that there were too many initiatives and there was
no sense of priority among them. For the most part, each
office could define the themes and initiatives to suit their
own purposes which had the effect of creating an unclear
picture of activities and resources for the themes and
initiatives from an Agency-wide perspective. The large number
of initiatives and the lack of a single definition for each
created confusion and lead to "gaming." There was no
consensus among the clients regarding the effectiveness of
theme/initiative structure as a marketing tool for the
Agency's budget.
Headquarters clients indicated that the theme/initiative
structure complicated media planning activities with little
apparent benefit. Regional clients appeared to have more
success in using the theme/initiative structure to link
planning and budgeting. Several clients commented on the use
of the theme/initiative structure to develop multi-media
activities and suggested that the development of cross-media
and multi-media activities should be handled outside the
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budget process. However, it should be noted that two 12th
floor clients commented that it was their specific intent to
use the budget process to drive the Agency toward cross-media
and multi-media activities.
The linking mechanism between planning and budgeting in
the FY 1994 budget process was a one-page document referred to
as an "action plan." In general, Regional clients believed
the action plan worked better than Headquarters' clients.
Most Headquarters' clients indicated that action plans were
not useful and were not the proper mechanism to link planning
and budgeting.
Almost half of the clients commented about the confusion
over roles and responsibilities during the development of the
FY 1994 budget. The roles of the 12th floor, OARM, and OPPE
were not clear or understood. Therefore, clients did not know
where to turn for informed answers to questions or
authoritative clarification of guidance. Clients reported a
lack of communication between OPPE and the Office of the
Comptroller throughout the process. Others observed that
there were simply too many people involved in the budget
process.
Budget targets were viewed as a good concept. However,
some clients reported that the targets were too high and,
therefore, not realistic. Unrealistic targets raised
expectations and generated unnecessary work.
Many clients supported the concept of early decision-
making in order to allow time to prepare to sell the budget to
OMB. However, early decisions are only good if they stick.
Early decisions raised the issue of discipline in the budget
process. The comment by one client concisely states the
problem, "decisions weren't decisions." Procedures and
targets were changed when a manager had a side conversation
with a member of the Agency's senior leadership. Once an
adjustment was made in one case, others petitioned for
adjustments to meet their specific requirements and the
process lost integrity. The lack of discipline and integrity
fueled confusion about roles, responsibilities, and
procedures.
One of the goals of the Budget Reform Task Force was to
reduce the paperwork attendant to internal budget development.
There was no consensus from the clients that efforts to reduce
the paper associated with budget development were successful.
Some clients indicated that the paperwork had expanded
geometrically while others thought that excessive budget
documentation workload had remained relatively constant.
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The FY 1993 and FY 1994 budgets focussed almost entirely
on the incremental increase; the base activities and resources
were not part of the deliberations. There was substantial
consensus among clients that the Agency must incorporate the
base in all budget discussions. Several clients suggested
that additional resources would be very difficult to obtain
and the Agency must look to the base for resources to support
new activities and programs. Although the budget request
should discuss the base as well as the increment, the clients
indicated that a base review is not needed every year. The
clients indicated that the most significant barrier
restricting candid discussion on the base is the lack of
incentives for managers to identify disinvestment
opportunities. The existing budget documents and hearing
process with OMB and the Congress are not adequate vehicles to
explain and demonstrate the benefits and accomplishments of
the base programs.
The clients supported the concept of continuous
improvement of the existing planning and budget processes
rather than adopting new processes. The Agency should not
start entirely new planning and budgeting processes each year.
Based on the experiences of the previous budget cycles, many
clients believed that an open and disciplined decision-making
process was crucial.
TOWARDS CHANGE
The Work Group recognized that the development of the FY
1995 budget request would occur on a compressed schedule
because of the change of Administration. Further development
of recommendations was postponed. Subsequently, the Work
Group became one of the teams for the National Performance
Review and is using the NPR structure to present
recommendations for review and approval.
In the early summer, the Director of the Office of
Management and Budget indicated that OMB was going to refocus
the budget process. OMB will be more interactive with the
Agency and policy decisions will be made prior to the formal
submission of the annual budget request on October 1.
Although OMB has proposed significant changes in the
Agency's interactions on the budget, many of the issues
considered by the Work Group still require attention in order
to have a rational, meaningful process to prepare to discuss
budget issues with OMB. The deliberations of the Work Group
have served as an important forum to discuss ideas, to learn
from our successes and failures, and to improve communications
among the various constituents of the Agency's resource
community.
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Implementation of some of these recommendations will
require policy decisions by the Administrator while others can
be accomplished by individual program offices. For the most
part, additional resources are not required to carry out these
recommendations as the existing planning and budget staffs in
the Agency can implement the Administrator's decisions. The
one potential exception involves an enhanced role for the
Regions in the planning and budget process. The Regions have
resources for planning and financial management. However,
they have not been staffed to participate actively in the
budget development process. Therefore, depending on the final
recommendation regarding the role of the Regions in the budget
development process, additional resources may need to be
devoted to this activity in the Regions.
RECOMMENDATIONS
The following recommendations have been developed to
improve internal planning, budgeting, and financial management
activities to enhance the Agency's messages to OMB, the
Congress, and other constituencies contained in annual budget
requests. Many of these recommendations require the
endorsement of the Administrator. With this concurrence, the
Work Group is ready to develop specific implementation plans
including roles and responsibilities for various Agency
offices and a detailed process and schedule for an integrated
planning, budget, and management process. The implementation
plans will be submitted to appropriate Agency officials for
review and approval.
1. The functions of planning, budgeting, and financial
(extramural) management need to be integrated into a
single process.
CURRENT STATE
The Agency's planning, budgeting, and financial
management activities too often are treated as independent
processes and functions. Annual changes in the Agency's
strategic directions and priorities waste resources and send
confusing messages to managers, the Congress, and the public.
Changes of this nature make it difficult to demonstrate that
the Agency's strategies and investments are linked to
improvements in the environment and reductions in risks to the
environment and public health. Managers tend to focus on a
single function in order to meet a due date or to respond to
some other pressure. The planning, budget, and financial
management implications of the multi-media and support offices
(OE, ORD, OGC, OPPE, and OARM) are not factored into media
office plans and budgets. The Agency is not adequately
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prepared to substantiate the relationship between resource
investments identified in the budget and outputs as required
by the CFO Act and the Government Performance for Results Act.
DESIRED STATE
The Agency and each National Program Manager (NPM) should
have a structured process that covers the complete spectrum of
resource management activities from broad strategic goals and
directions to outputs and results. The spectrum involves the
following major components:
Goals-> Plans-> Budget-> Financial and Extramural
Managements Outputs/Results-> Feedback
The planning and budget decisions of the multi-media and
support offices should be coordinated and integrated with the
media offices in the planning and budget development
components through a consultative process. Alternatively, the
media offices should articulate requirements allowing time for
the multi-media and support offices to prepare plans and
budgets in response to these requirements. Changes in
services and costs should be identified and coordinated with
all affected offices in the Agency. Special interest items
(i.e., FMFIA) should be identified early in the development of
goals and plans rather than added on to the budget request.
The Agency's planning and budget functions provide the
information required by the CFO Act and the Government
Performance and Results Act.
2. The Agency's integrated planning, budgeting, and
financial management process needs to be clearly
articulated, step-by-step, delineating roles, timing.
responsibilities, and outcomes.
CURRENT STATE
Planning, budget development, and financial and
extramural management have not been effectively linked at the
Agency level or in some offices. The lack of a comprehensive
resource management process and the uncertainty about roles
and responsibilities creates confusion. Further, it is
difficult to make informed strategic resource investments and
document progress towards Agency and NPM goals.
DESIRED STATE
Resource management should be viewed as a spectrum of
integrated activities. The Agency should have a clearly
articulated step-by-step process to serve as a guide through
the resource management spectrum. For each step in the
process, the objectives, timing, roles, responsibilities, and
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outcomes should be clearly spelled out. Managers at all
levels should understand the relationship among the various
steps and functions in the process. Agency and NPM strategic
plans should be used to guide resource investment decisions
and to identify program outputs.
3. The Regions should have an enhanced role in this process.
especially regarding budget development.
CURRENT STATE
The role of the Regions in the development of the
Agency's budget is unclear. There is no consensus among the
Regions or the NPM's regarding the precise role the Regions
should have in the budget development process. The Regions
are involved in two important aspects of resource management:
strategic planning and extramural management. National
Program Managers use the "Lead Region" concept to collect
information on Regional resource needs in the development of
budgets; however, the NPM and Regional roles vary.
DESIRED STATE
As the resource management process is developed, the
Regions should be provided with the opportunity to participate
in each step of the process. Regional planning and extramural
activities should be coordinated with the NPM's and a new, as
yet unspecified, role for the Regions in budget development
should be specified. The role for the Regions may simply be
an enhanced role for the "Lead Region" or provisions could be
made for the Regions to develop their own budgets or some
other possibility.
4. The process should provide the opportunity for the states
to participate in the Agency's planning and budgeting
activities.
CURRENT STATE
The states are not provided with any direct roles in the
Agency's planning, budgeting, and extramural activities. The
report of the State Capacity Task Force needs to be evaluated.
DESIRED STATE
The Agency should enhance its partnership with the states
by providing them with specific opportunities to offer ideas,
identify needs, and report accomplishments. This subject has
been tentatively scheduled for discussion at the "All States"
meeting being convened by the Administrator this fall. The
Agency should prepare a range of options to discuss with the
states.
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5. Basic planning and budget decisions should be made as
early as possible.
CURRENT STATE
Too often decisions regarding Agency and media planning
and budget activities are delayed to the last minute. The
delays in making these important decisions often result in a
rush to meet deadlines rather than a focus on quality
proposals and documents. There has not been adequate time to
develop strategies and plans to "market" our proposals to OMB
and the Congress.
DESIRED STATE
Decisions affecting the strategic directions of the
Agency and programs should not change every year. These types
of decisions should be carefully considered and maintained for
several years, with the recognition that some amendments will
occur. NPM decisions regarding the budget should be made as
early in the process as possible to allow time for the
development of well thought out, quality proposals. Agency
decisions regarding proposals to OMB and the Congress should
be made as early as possible to allow for coordination within
the Agency and to provide sufficient time to develop
strategies to "sell" these proposals.
6. The Agency needs to develop incentives for savings.
disinvestments, and redirections at all levels in
Headquarters and in the Regions.
CURRENT STATE
There are no incentives for managers to identify
activities and resources that can be reduced or may not be
needed at all. In fact, the reverse is true. Budget and
financial processes penalize managers who do not spend their
allocations by basing the next budget on prior year spending
levels. Managers who terminate activities or free up existing
resources have those resources taken away.
DESIRED STATE
Managers at all levels of the Agency should focus on
saving resources, redirecting resources to new and/or higher
priority activities, and terminating programs that are no
longer needed. Managers who are successful in these
activities should be recognized and rewarded. They should not
necessarily lose control over all of the resources they have
saved or redirected. The Work Group will continue to work on
developing more specific actions for implementing this
recommendation.
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7. The Aaencv should investigate the following improvements
that are beyond the Agency's control.
a. The necessity and utility of the OMB exhibits that
accompany the Agency submission.
b. Developing a two-year budget cycle.
c. Consider wider use of multi-year appropriations.
d. Provide incentives to agencies that save money.
e. Resolve the apparent inconsistency between the
empowerment and decentralization concepts of the NPR
and the centralization and micromanagement realities
of FMFIA, the IG, the GAO, and the Congress.
f. Make the appropriations process more meaningful.
g. Review reporting requirements to OMB and the
Congress and eliminate unnecessary reports and
paperwork.
The Planning and Budget Work Group is ready to develop
specific implementation plans for each of these
recommendations.
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13
NATIONAL PERFORMANCE REVIEW
PLANNING and BUDGET WORK GROUP
TEAM MEMBERS
Richard White
Susan Absher
Derry Allen
Diane Bazzle
Martha Berger
Mike Binder
Helga Butler
Beth Cavalier
Beth Craig
Bob Currie
Mary Free
Rick Carman
Prudence Goforth
Kathy Gordon
Sallyanne Harper
Nancy Hunt
Lek Kadeli
Judy Kertcher
Jerry Kurtzweg
Terry Ouverson
Kathi Payne
Sharon Payne
Al Pesachowitz
Kathy Petrucelli
Barbara Pastalove
Joann Rodman
Mike Schultz
Bill Stewart
Lisa Tychsen
Cheryl Wasserman
Jim Wieber
Alex Wolfe
Team Leader
OPPTS
OSWER
OPPE
OA
OPPE
IG
OA
OPPTS
OARM
OPPE
OPPE
OARM
OARM
OSWER
OARM
OE
OIA
OROSLR
OAR
OARM
OW
OPPE
OARM
OARM
REGION II
ORD
REGION IX
OGC
OE
OE
OROSLR
OAR
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REPORT OF THE
POLLUTION PREVENTION
TEAM
NATIONAL
PERFORMANCE
REVIEW
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pp 1
EPA NPR POLLUTION PREVENTION TEAM MEMBERS
Joe Abe
Dave Bassett
Bob Benson
Belentia Choyce-Epps
Harlal Choudhurry
Becky Cuthbertson
David Duster
Mark Greenwood
*Ann Hardison
David Hindin
*Greene Jones
Steve Lingle
Karen Lumino
Amal Mahfouz
Jim Nelson (Team Leader)
Diane Niedzialkowski
Susan Offerdal
Louis Paley
Libby Parker
Neil Patel
Mahesh Podar
Yvette Price
Eric Schaeffer
Anita Schmidt
Paul Shapiro
Betsy Shaver
Nathan Wilkes (Facilitator)
OPPE
OPPTS
OPPE
Region VI
ORD/Cincinnati
OSWER
Region VIII
OPPTS
OA
OE
Region III
ORD
Region V
OW
OGC
OAR
OE
OAR
OPPTS
OW
OW
OARM
OA
OAR
ORD
ORD/RTP
OPPE
[*Denotes original members who were unable to participate.]
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PP 2
I. EXECUTIVE SUMMARY
A. Introduction
Environmental policy is undergoing important changes that
reflect a fundamental shift in approach to environmental
protection and management. The new approach to environmental
policy-making is based on foresight, systematic thinking, and
pollution prevention, and should be viewed in a context of
sustainability. There is a growing concern that the current
relationship between a consumption-based society and a healthy
environment is not sustainable and may contribute to many social,
economic and cultural problems around the world.
Pollution prevention is the preferred approach for
environmental improvement and promoting a sustainable economy.
EPA must build its programs, both regulatory and non-regulatory,
on a foundation of pollution prevention. EPA must encourage
state, local, and tribal governments and other federal agencies
to do the same. EPA must work with its partners to develop clean
technologies, to promote innovation, to ensure that the maximum
amount of pollution is prevented, and to ensure that the minimum
amount of our natural resources is consumed.
The President, the Administrator, and other leaders across
the spectrum recognize that this is the "era of pollution
prevention and sustainability". EPA, other federal agencies,
state, local, and tribal governments, and industry have made
substantial progress towards integrating pollution prevention
into their environmental management programs. However, there is
a great deal still to do. This Report is intended to promote
significant progress in developing and promoting pollution
prevention. The time is ripe to move from an ad hoc approach to
a comprehensive strategy for pollution prevention and
sustainability.
B. General Background
In the very limited time available, the Pollution Prevention
Team identified and reviewed several hundred ideas relating to
P2, including both new ideas and initiatives that are already
underway in EPA. At the same time, employees from throughout EPA
responded to the Administrator's outreach efforts and submitted
hundreds of additional ideas to the NPR (many of which concern
pollution prevention). In performing its work, the Team
recognized that important progress had already been made in many
areas within EPA and beyond EPA. The Team utilized work already
done and experience gained in EPA's ongoing efforts to expand use
of pollution prevention and intends that this Report build on the
pioneering work already done in this area.
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C. Themes in the Initiatives in this Report
The 28 Initiatives featured in this Report (as well as the
32 summarized in the Appendix) have many themes in common. The
Initiatives recognize that the status quo will not realize the
promise of pollution prevention. Change (including in EPA's
organizational structure) is important, inevitable, and necessary
to accomplish pollution prevention and sustainability. EPA must
establish momentum and credibility by acting immediately on many
different pollution prevention fronts.
EPA can be a leader for pollution prevention and
sustainability. This requires leading by example, sustained
commitment from top EPA management, putting resources where our
rhetoric is, integrating pollution prevention into all our
programs, creating trust within EPA and between EPA and other
parties, being accountable for Agency activities, and
incorporating pollution prevention into the very culture of EPA.
The entire Federal Government must provide leadership in
pollution prevention. Through its own actions, through its
influence on the activities of others, and in how it uses its
resources, the Federal Government can promote and encourage
pollution prevention.
Information, technology development, and training are
essential elements of establishing and encouraging pollution
prevention. EPA staff needs to be trained in pollution
prevention so they can carry the message to others. EPA has an
important role in promoting education of the public, other
government agencies, and business in pollution prevention.
Effective pollution prevention activities require effective
partnerships because EPA alone cannot make pollution prevention a
reality. This requires close work with and support of other
Federal agencies, state, local, and tribal governments, the
international community, business and financial institutions,
labor groups, academia, public interest groups, and the public at
large. Effective partnerships help EPA leverage its limited
resources to promote pollution prevention and develop new,
environmentally friendly technologies.
EPA can create incentives for changes in private sector
behavior, stimulate voluntary adoption of pollution prevention,
and promote enlightened self-interest in the business community.
EPA can cooperate in research and pioneer pilot projects.
Sector-based policies and programs should be considered as an
innovative means of linking economic and environmental
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PP 4
priorities. EPA can provide flexibility in its regulatory
programs to allow and encourage pollution prevention solutions to
environmental problems.
EPA's success must be measured in environmental results, not
bean counting. Pollution prevention must be a continuing process
aimed at environmental improvements. Innovation and risk-taking
must be rewarded not punished. EPA must seek a broad, private
and public sector commitment to (and investment in) strategic,
forward-looking approaches to environmental management
approaches that take the private and public sectors beyond
baseline compliance.
D. Conclusions and Recommendations
Given the time constraints of this effort, the Pollution
Prevention Team had virtually no time to review the ideas
provided by EPA employees to the NPR in response to the
Administrator's outreach efforts. The Team believes there is a
wealth of good ideas embodied in that unreviewed material and
strongly recommends that a followup group be given the task of
reviewing, evaluating, and developing additional ideas beyond
those presented in this Report so the value of all that good
thinking is not lost.
From the many ideas it did review, the Team developed many
Initiatives grouped in 10 Categories. This Report describes the
Categories and presents Initiatives under each Category. The
Initiatives include actions for which EPA has the primary
responsibility, and actions for which EPA shares that
responsibility with others. Twenty eight detailed Initiatives
appear in the body of this Report, and another 32 Initiatives are
presented in more abbreviated form in the Appendix.
The Team strongly recommends that the Administrator
designate individuals, organizations, or groups to follow up on
the 28 featured Initiatives and a group to further evaluate and
develop the 32 Initiatives in the Appendix, perhaps the same
group that follows up on the employee ideas submitted to the NPR.
The Team decided to present a broad array of Initiatives to
show the many areas that present opportunities for action in
pollution prevention across the wide spectrum of EPA and the
Federal Government. Because of the limited analytical time
available to the Team, more work will be required to refine the
information on time frames, resources needed, barriers, benefits,
and measures of success for some of the Initiatives. However,
the Team believes that each of the Initiatives can be carried
forward and fully developed by followup groups.
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PP 5
The time element is also important. The Initiatives contain
actions that can be accomplished within the next six months,
within the next year, and within the next two years, and others
that represent an ongoing commitment for the long term. Short-
and long-term items often appear in a single Initiative. Most
Initiatives can begin immediately, even if the ultimate payoff is
several years away. It is important to invest in both long- and
short-term Initiatives. If we are to make pollution prevention
our central ethic, we must undertake longer-term, substantive
changes in the way we do business, and not just go for the "quick
fix11" of isolated, ad-hoc projects.
The Team recognizes that the ultimate costs of the many
Initiatives taken together appear to be high and may be hard to
fund in the current fiscal climate. However, it is important to
note that the payoff to business and society from the
implementation of principles of sustainability and pollution
prevention is likely to be many fold greater than the initial
investment in this area. Effective use of pollution prevention
will result in short- and long-term resource savings for Federal,
state, local, and tribal governments and for business. It will
also provide improvements in efficiency for both governments and
business. Pollution prevention promotes U. S. competitiveness
around the world and creates business opportunities. It is sound
public policy to invest promptly in pollution prevention. Only
by doing so, can we achieve the combination of economic savings,
enhanced environmental protection, and technological
competitiveness that are the ultimate promise of pollution
prevention.
The Initiatives in this Report will require forward thinking
and long-term planning to carry out. EPA can start the action on
virtually all of them, but we must encourage others to join us
throughout the Federal Government, state, local, and tribal
governments, business, labor, and the public.
The goal set by the Administrator for incorporating
pollution prevention throughout EPA is an ambitious one. The
Initiatives presented in this Report are just a starting point.
Other ideas will continue to be developed, and EPA and the rest
of the Federal Government must have an ongoing process for
encouraging, developing, evaluating, and implementing new
pollution prevention ideas.
Many of the Initiatives featured in this Report are "ready
to roll" and can meet the need for immediate progress with a
relatively small expenditure of resources in the beginning.
Other "big picture" initiatives may take longer to implement and
show results, but it is still important to get started on them.
For the most part, these are the Initiatives which will help us
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PP 6
make the change to a pollution prevention culture, and many can
be begun with low resource levels. Each of the 28 Initiatives
featured in this Report should start up quickly, and significant
immediate progress can be made by establishing work groups to
carry them out or to perform necessary analysis and planning in
the near-term.
The Team recognizes that some will react to this Report by
concluding that this is "more of the same old rhetoric about
pollution prevention. However, the reader must judge the work of
this Team by the specific Initiatives that we offer. The ten
Categories and 28 specific Initiatives featured in the body of
this Report are summarized immediately following this Executive
Summary. Read them before you make a judgment.
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PP 7
LIST OF CATEGORIES AND FEATURED INITIATIVES
Target/Action Category A: EPA SHOULD PROMOTE SUSTAINABILITY
THROUGH ITS POLICIES AND PROGRAMS AS THE CENTRAL OPERATING
PRINCIPLE FOR THE COUNTRY
A.I. Link Federal Policies and Programs to Sustainability and
Pollution Prevention
A.2 Recognize and Address the Role of Key "Drivers" (Such As
Population, Consumption Patterns, and Technology) Affecting
Mankind's Ability to Create a Sustainable Future
Target/Action Category B: EPA SHOULD DEMONSTRATE THE BENEFITS OF
P2 TO ENVIRONMENT, BUDGET & EFFICIENCY BY USING P2 STRATEGIES IN
ALL ITS OWN OPERATIONS
B.I. Demonstrate a Commitment to Pollution Prevention in All EPA
Internal Operations
Target/Action Category C: EPA SHOULD CHANGE ITS CULTURE AND
ORGANIZATION TO MAKE POLLUTION PREVENTION THE CENTRAL OPERATING
PRINCIPLE OF THE ORGANIZATION AND ITS EMPLOYEES
C.I. Identify Ways to Structure EPA to Promote Risk Taking,
Exposure Reduction and Pollution Prevention
C.2. Require That Senior Level Managers be Accountable for
Implementing Pollution Prevention Throughout EPA's Programs
Target/Action Category D: EPA SHOULD INTEGRATE POLLUTION
PREVENTION INTO ALL PROGRAMS INCLUDING REGULATION DEVELOPMENT,
PERMITTING OPERATIONS, COMPLIANCE ACTIVITIES, AND ENFORCEMENT
D.I. Develop and Implement Every Regulation, Guidance Document,
and Policy to Integrate Pollution Prevention into the Menu
of Options for the Regulated Community
D.2. Provide flexibility in Permit Compliance, Fee Schedules, and
Processing Time for Permit Applications to Encourage
Pollution Prevention
D.3. Develop Pilot Projects for Integrating Pollution Prevention
into Development and Implementation of Regulations, Guidance
Documents, or Policies for Two or More Media for the Same
Industry
D.4. Harness Enforcement Activities to Help Promote and Implement
Pollution Prevention
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PP 8
Target/Action Category E; EPA SHOULD ENHANCE PARTNERSHIPS WITH
STATE, LOCAL, AND TRIBAL GOVERNMENTS TO IMPLEMENT POLLUTION
PREVENTION
E.I. Work With the States on Pollution Prevention at as High a
Management Level as in Other Programs
E.2. Improve Funding for Pollution Prevention Activities by
States
E.3. Promote One-stop Shopping for Environmental Regulatory
Assistance, Pollution Prevention Technical Assistance, and
Other Assistance Programs
E.4. Adopt Standard Practice of Allowing Flexibility for States
and Local Governments to Comply with Environmental
Reguirements Through Pollution Prevention
E.5. Facilitate Pollution Prevention by Native American Tribal
Governments
E.6. Develop a "Demand-side Management" Strategy for Municipal
Water Programs
E.7. Develop Municipalities' Capabilities to Use Pollution
Prevention as a Centerpiece of Their Pre-treatment Programs
Target/Action Category F: EPA SHOULD TAKE AN ECONOMIC SECTOR-
BASED APPROACH TO THE DEVELOPMENT OF ENVIRONMENTAL POLICIES AND
PROGRAMS, WITH POLLUTION PREVENTION AS A KEY MEANS OF ACHIEVING
COST-EFFECTIVE ENVIRONMENTAL PROTECTION.
F.I. Develop Sector or Sub-Sector Specific Policies, Projects,
and Programs to Most Effectively Drive Private Sector
Behavior and Promote Desired Private Sector Actions.
F.2. Establish Multi-Disciplinary Working Groups Within EPA and
With Outside Entities to Develop Sector and Subsector
Strategies.
F.3. Take a More Proactive Role to Develop Legislation That Would
Provide Greater Flexibility for EPA to Promote Innovative
Programs, Pursue Regulatory Trade-offs, and Prioritize Risks.
Target/Action Category G; EPA SHOULD CULTIVATE PUBLIC/PRIVATE
PARTNERSHIPS TO FOSTER POLLUTION PREVENTION
G.I. Assist Industry Groups in Measuring Environmental Results of
Their Codes of Conduct
G.2. Develop a Facility-based System for Organizing All of EPA's
Data
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PP 9
Target/Action Category H; EPA SHOULD TAKE A LEADERSHIP ROLE IN
PROVIDING EDUCATION AND INFORMATION ABOUT POLLUTION PREVENTION
H.I. Begin General Pollution Prevention Education Initiative
H.2. Facilitate the Sharing of Pollution Prevention Information
with Industry
H.3. Develop a Chemical Use Inventory
Target/Action Category I; EXECUTIVE BRANCH SHOULD INTEGRATE
POLLUTION PREVENTION INTO ITS PROCUREMENT AND DEVELOP FEDERAL
AGENCY RELATIONSHIPS TO PROMOTE POLLUTION PREVENTION NATIONWIDE
I.I. Advance Principles of Pollution Prevention in Executive
Branch Through Procurement of Goods and Services
1.2. Establish a Permanent, Inter-agency Team Reporting to the
Vice President to Gather, Evaluate, Develop Ideas for
Pollution Prevention Throughout the Federal Government and to
Coordinate Pollution Prevention Activities Throughout the
Federal Government
Target/Action Category J; GOVERNMENT SHOULD USE MARKET
INCENTIVES, INTERNALIZING THE EXTERNALITIES AND FISCAL POLICIES TO
PROMOTE POLLUTION PREVENTION
J.I. Develop "Take Back" Legislation and Regulations
J.2. Establish a Federal Environmental Sales Tax
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PP 10
II. VISION
EPA believes that pollution prevention is the preferred
approach for environmental improvement and promoting a sustainable
economy. We seek to build our programs, both regulatory and non-
regulatory, on a foundation of pollution prevention, and encourage
state, local, and tribal governments and other Federal agencies to
do the same. We work with our partners, including state, local,
and tribal governments, businesses, the financial community, and
others, to develop clean technologies, to promote innovation, to
ensure that the maximum amount of pollution is prevented, and to
ensure that the minimum amount of our natural resources are
consumed.
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pp 11
III. TARGET/ACTION CATEGORIES AND INITIATIVES
Target/Action Category A;
EPA SHOULD PROMOTE SUSTAINABILITY THROUGH ITS POLICIES AND
PROGRAMS AS THE CENTRAL OPERATING PRINCIPLE FOR THE COUNTRY
Environmental policy is undergoing important changes within
the private and public sectors that reflect a fundamental shift in
society's approach to environment protection and management. The
new approach to environmental policy-making, which is based on
foresight, systemic thinking, and pollution prevention, is in re-
sponse to a growing global awareness that the current relationship
between a consumption-based society and the environment is not
sustainable. Non-sustainable activities are, in fact, a major
contributing factor to many social, economic, and cultural
problems around the world.
The importance of sustainability issues is reflected in the
recent establishment of the President's Council on Sustainable
Development (PCSD) and the United Nations Commission on
Sustainable Development. EPA and the other public and private
sector organizations represented on the Council have been charged
by the President to develop sustainability initiatives that will
link economic and environmental priorities, at both the domestic
and international levels. Pollution prevention will be a key tool
in moving society toward a sustainable future. The initiatives in
this category reflect specific actions that EPA and the rest of
the Federal government can take to promote sustainability.
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PP 12
Category A Initiatives;
A.I. Link Federal Policies and Programs to Sustainabilitv and
Pollution Prevention
a. What. Environmental problems are created and aggravated by
forces often beyond EPA's control, such as land use, trans-
portation, agriculture, small business assistance programs,
and federal facility operations. Federal agencies should be
required to take all necessary actions to incorporate
sustainability and pollution prevention into the development
and implementation of their policies, programs, and
activities (as well as the operation of their facilities).
To begin, each federal agency should develop a pollution
prevention strategy that is based on concepts of sustainable
development.
For its part, EPA should (1) assist other agencies in
evaluating and revising their policies and operations to
minimize pollution, maximize pollution prevention oppor-
tunities, and stimulate progress toward sustainable
development; (2) consider innovative approaches to link
economic and environmental priorities (e.g., sector-based
policies, public-private partnerships, incentive-based
policies); (3) continue its leadership role on the PCSD.
b. Who. Other federal agencies would be required to evaluate
their policies, programs, and operations, with EPA review of
P2 strategies. EPA's sustainability initiatives should be
coordinated by the Administrator's office and the Senior
Leadership Council. The Administrator could create a multi-
disciplinary EPA team to support her work on the PCSD.
c. When. Immediate.
d. Barriers. Institutional inertia to change and lack of
familiarity with sustainability and P2 concepts at EPA and
other agencies. Agencies also may discover that their
policies and programs are not consistent with principles of
sustainable development.
e. Costs. Some FTE resources in each federal agency will be
required to coordinate the efforts. While there may be
short-term costs at federal agencies in adopting pollution
prevention practices, in the long-term significant cost
savings should result from the adoption of pollution
prevention practices and policies.
f. Benefits. Potentially significant reductions in pollution;
resource savings and environmentally sound growth.
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PP 13
Measuring Success. Short-term: reductions in TRI releases.
Long-term: other measures of sustainability and pollution
prevention (some of which are not yet fully developed).
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PP 14
A.2 Recognize and Address the Role of Key "Drivers" (Such As
Population. Consumption Patterns, and Technology) Affecting
Mankind's Ability to Create a Sustainable Future
a. What. There are a number of key forces affecting the earth's
resources and ecosystems, including pressures from a growing
population, disproportionate and non-sustainable consumption
rates among different nations, and the rapid pace of techno-
logical change. To promote sustainable development, the
federal government must identify the role that these and
other driving factors play in environmental problems,
particularly in this country, and how they relate to a
sustainable future. Failure to do so will significantly
weaken U.S. and international sustainable development
policies. The White House should e_stablish a multi-
disciplinary panel, composed of representatives of key
federal agencies (including EPA), academia, and various
interest groups from all sectors of society, to support the
PCSD by (1) reviewing the body of work done to date on
sustainable development issues, (2) identifying the role that
the various driving factors play in U.S. and world
environmental problems, and (3) recommending possible
solutions to address the problems.
b. Who. White House establishes panel in consultation with the
PCSD, with EPA playing a significant role.
c. When. Panel should be given one year to study issue, review
existing data and report to President. Start in Fall 1993.
d. Barriers. There are significant barriers for the Executive
Branch entering this area. Some of the driving factors,
such as population growth and consumption patterns, are
politically sensitive subjects.
e. Costs. Several EPA FTEs to participate on panel.
f. Benefits. The benefits can be tremendous if we can identify
the factors that drive socio-economic development patterns
and then develop workable strategies to reduce and/or
mitigate their impacts on the environment.
g. Measuring Success. In the short-term, success will be
achieved by public and political recognition of the "win-win"
nature of sustainable development (i.e., that properly
developed economic and environmental policies are mutually
supportive). In the long-term, success will be seen in many
ways, including improvements in the quality of life in both
developed and developing countries, reduction in societal
expenditures for environmental control and remediation,
preservation of natural ecosystems, and mitigation of global
environmental and socioeconomic problems.
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PP 15
Target/Action Category B;
EPA SHOULD DEMONSTRATE THE BENEFITS OF POLLUTION PREVENTION TO
ENVIRONMENT, BUDGET & EFFICIENCY BY USING POLLUTION PREVENTION
STRATEGIES IN ALL ITS OWN OPERATIONS
There are four reasons why EPA must lead on pollution prevention:
(1) opportunity to demonstrate both environmental and cost/
competitive advantages; (2) EPA staff's skepticism about P2; (3)
severe resource constraints; and (4) the Pollution Prevention Act
of 1990 directs EPA to do it.
There are numerous examples where a reevaluation of a process or
product resulted in something that is both environmentally
cleaner, and less expensive or more effective. Once demonstrated,
such products and processes may be marketed throughout the country
and exported to other countries. EPA should take the lead in
using its own Agency-wide internal operations - communications,
transportation, building services, and purchasing of products and
services, to perform additional P2 demonstrations. Furthermore,
we should establish the framework or incentives for others to
demonstrate similar results.
The Administrator's call to make P2 EPA's "decision of first
choice" requires that EPA vigorously expand P2 into every corner
of EPA. EPA has completed numerous "pilot scale" P2
demonstrations, e.g., electronic mail, high efficiency lighting.
These provide ample foundation for launching Agency-wide
implementation of them now. Taken together, it is imperative that
staff and management begin, and continue to see real environmental
and resource-saving benefits from P2.
The government's budget deficit is large and growing; yet public
demands an ever-increasing level of environmental protection.
While not a panacea, fully developed and implemented P2 approaches
offer EPA a real chance to reduce the cost of its operations while
increasing its effectiveness.
The Pollution Prevention Act directs EPA to: "promote source
reduction practices in other federal agencies;" and "identify
opportunities to use federal procurement to encourage source
reduction." EPA should become a "P2 demonstration laboratory".
Furthermore, EPA has the opportunity to substantially affect the
purchasing, consumption and manufacturing habits of the entire
federal government and this country.
The specific Initiatives under this Category are primed for
immediate and meaningful Agency-wide application. (See Appendix
for more detailed Initiatives).
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PP 16
Category B Initiatives;
B.I. Demonstrate a Commitment to Pollution Prevention in All EPA
Internal Operations
a. What. Agency-wide implementation of P2 actions to improve
environment & efficiency & reduce cost: (1) Paper
conservation - build upon QMS, NDPD, OSW, Regions V & IX,
payroll, OAR "Communic. QAT", & OARM's "PaperWISE" projects
paper-less faxing; "low-paper office"; use of electronic
"standard forms"; transmittal and storage of internal
documents; electronic mail & bulletin boards, industry
electronic reports; (2) Green purchasing - build upon
Judiciary Sq. lighting, Denver airportprocure "green"
(e.g., less toxic/more efficient materials, equipment, &
services); reduce consumption and toxicity of existing items;
P2 analysis for major purchases; get partners to develop
innovative/green products and services; & establish a price
differential for green products and services. (3) P2
transportation - conform to "Alternative Motor Fuels Act of
1988", & Sec. 11 of E.O. 12759; increase bicycling & walking
to work; increase carpooling & vanpooling; (if available)
increase employee use of mass transit systems using "Metro
Passes" or other subsidies; award a transit benefit to a "P2
employee-of-the-Month"; encourage use of "flexiplace" work
arrangements; use only green rental cars; purchase only green
vehicles; partner with manufacturers to produce innovative,
green vehicles; and use 2-way video-conferencing to reduce
travel; (4) building services conservation - build on
Judiciary Sq., Denver airport, P2 audit of White House and
BOB. Reduce energy consumption by at least a 20% by the year
2000 (e.g., conduct agency-wide building services P2
assessment; use green lights and motion sensors; use "energy
efficiency leader" in every facility; promote "job sharing" &
11 f lexiplace" to use office space and services more
effectively; use larger, but fewer buildings; use "gray
water" systems; buy or lease new green facilities.
b. Who. teams of AA or facility, 1-2 years; then Agency-wide.
c. When. teams start by 10/93; EPA-wide starts 10/95.
d. Barriers. Few products, services, training, purchasing, and
management procedures, and sufficient resources.
e. Costs. Significant near-term costs; significant savings in
long-term.
f. Benefits. Improve environment & competitiveness; overcome EPA
staff's skepticism and resource constraints; and comply with
statute, regulations and policies.
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PP 17
g. Measuring Success. Quantify reductions in: products,
services, natural resources, energy and in waste products.
Target/Action Category C:
EPA SHOULD CHANGE ITS CULTURE AND ORGANIZATION TO MAKE POLLUTION
PREVENTION THE CENTRAL OPERATING PRINCIPLE OF THE ORGANIZATION AND
ITS EMPLOYEES
For EPA to adopt pollution prevention fully as a way of doing its
business, the "culture" and the organization of the Agency and its
employees must change. EPA must break away from "business as
usual". P2 must become the first option EPA thinks of in
addressing any environmental issue. The organization and the
people must see P2 as their primary way of doing business. To
show that EPA is serious about changing how it does business,
organizational change may be necessary. Ways must be found to
motivate both the organization and the individuals within it to
search for creative P2 opportunities. Money must flow toward P2
activities. This cannot be achieved without strong management
commitment at all levels. Change of this nature will help EPA
better focus P2 efforts in a coherent, comprehensive, integrated
manner and facilitate interaction and cooperation among EPA, other
Federal agencies, State, local, and tribal governments, industry,
and the public.
Category C Initiatives;
C.I. Identify Ways to Structure EPA to Promote Risk Taking.
Exposure Reduction and Pollution Prevention
a. What. Action Group, chaired by the Deputy Administrator,
assesses alternative approaches to EPA's current structure.
Group identifies at least 3 pilot projects (may utilize
pilots already underway) to assess success, problems, &
issues associated with different models for organization of
EPA's work (include at least one sector-based & one multi-
media) . Pilots encompass different media, include both
regulatory & non-regulatory components (to speed evaluation,
pilots selected in part based on ability to complete analysis
within a year). Group evaluates pilots & applies lessons
learned to restructuring options & examines EPA experiences
with partnerships, multi-media approaches, regulation
negotiations, & other programs. Group formulates
restructuring options/recommendations for Administrator after
evaluation of the pilots & any other studies.
b. Who. Deputy Administrator. Action Group represents all
Offices/Regions.
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PP 18
c. When. Group selected by 1/94. Select pilots by 6/94 with
schedules for progress reports & completion of activities.
After completion of evaluation, Group proposes timeframe for
development & delivery of restructuring proposal/options to
the Administrator.
d. Barriers. Inertia; existing regulations & statutory
constraints; existing relationships between offices & ties
among current co-workers & projects; reluctance to change
status quo; Congressional constituencies & interests;
disruption of on-going activities & of staff.
e. Costs. Significant short-term disruption; significant
resources to ensure success, perhaps up to 10 to 15% of EPA's
budget; moving costs.
f. Benefits. Opportunity to test premise for reorganization &
identify issues/problems & potential solutions prior to
undertaking development of a broader restructuring plan;
could revitalize EPA & get management & staff (& the public
and private sector) to rethink old ways of doing business;
enhanced opportunities to identify and implement P2 as a core
element in EPA's "thinking" process.
g. Measuring Success. Short-term, success of pilot projects by
lessons learned & usefulness in formulating options for
reorganization that enables EPA to meets its goals; long-
term, success of restructuring by improvement in meeting
goals, including establishment of P2 as central EPA ethic.
C.2. Require That Senior Level Managers be Accountable for
Implementing Pollution Prevention Throughout EPA's Programs
a. What. One way EPA can change its "culture," and in
particular the expectations of its employees, is to make P2 a
priority with senior level managers by making them
accountable for P2 performance and results. To do so, P2
should be an explicit element of agency tracking systems
(e.g., MOARS and STARS commitments, workload models, and
workload planning) & incorporate P2 into to performance
standards of senior level managers. Such accountability
ensures that their job performance is judged in part on how
well they have promoted P2 in their areas of responsibility.
Where appropriate, performance standards for mid-level
managers, supervisors, and staff should also incorporate P2
into their CJEs.
b. Who. Administrator/Deputy ensure that P2 is addressed in
MOARS/STARS, workload models, and work plans and in
performance standards of senior managers. Mid-level managers
ensure that P2 is incorporated into CJEs, where appropriate,
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PP 19
of subordinate staff. A working group drafts several
possible versions of CJEs for use by
managers/supervisors/staff at various levels & in various
jobs.
c. When. Administrator/Deputy require incorporation of P2 into
MOARS/STARS commitments, workload models, and work plans
beginning in FY 1994. Working group prepares & distributes
versions of P2 CJEs by 9/93. CJEs appear in all senior level
managers' performance agreements signed beginning in 10/93.
d. Barriers. Competing commitments; competing mandatory CJE's;
cynicism about performance review system & management
accountability systems.
e. Costs. Time & resources for working group; time
discussing/negotiation/incorporation into performance
agreements by 10/93; time incorporating P2 into MOARS/STARS
commitments, workload models, & work plans.
f. Benefits. Senior level managers, mid-level managers,
supervisors and selected staff increasingly recognize that P2
is part of their job & are motivated to identify P2
opportunities; provides accountability up and down management
chain.
g. Measuring success. None identified.
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PP 20
Target/Action Category D;
EPA SHOULD INTEGRATE POLLUTION PREVENTION INTO ALL PROGRAMS
INCLUDING REGULATION DEVELOPMENT. PERMITTING OPERATIONS,
COMPLIANCE ACTIVITIES. AND ENFORCEMENT
EPA should integrate pollution prevention into all aspects of
implementation of its environmental laws. Many existing laws
generally address a specific part of the environmentair, water,
and land; other statutes deal with chemicalspesticides or
industrial chemicals. In implementing these laws, EPA offices
frequently encounter situations where action under one
environmental law causes an undesirable chemical to be shifted to
a different environmental medium, without reducing the overall
amount of that chemical being released to the environment.
To integrate P2 into regulations, permits, compliance
promotion, enforcement, policies, and guidance, each action should
have as many of the following attributes as possible:
1. performance-based standards (not based on end-of-pipe
technology)
2. on-going program to assist the regulated community in
compliance through P2
3. multi-media orientation
4. economic incentives such as trading, averaging, banking
5. flexibility/framework to accommodate/encourage risk-taking by
all parties; promotes innovative technology development
6. promotes trust between EPA and other parties
7. promotes long-term cost savings as the basis for regulated
parties making decisionsP2 generally cheaper over time
8. regulated parties are accountable through clearly stated
measures; focus on environmental benefits
9. promotes use of full-cost accounting in EPA and industry
decision-making
10. predictability/certainty in requirements and timing of
changes in requirements
11. P2 as the starting point, not an add-on
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PP 21
Category D Initiatives:
D.I. Develop and Implement Every Regulation. Guidance Document.
and Policy to Integrate Pollution Prevention into the Menu of
Options for the Regulated Community
a. What. More comprehensive effort to encourage facilities to
consider P2 before other options by explicitly providing P2
options, and give them preference, in regulations, policies,
guidance documents, permits, & other regulatory activities.
Identify statutory & regulatory barriers that preclude the
use of P2 in regulations, policies, guidance, permits, or
compliance. Change regulations, policies, and guidance
documents that are barriers to the use of P2. Propose
legislative changes to laws that are barriers to the use of
P2. Much work has already started. By expanding this
approach EPA will be further clarifying and strengthening the
message in the near-term and institutionalizing it in the
long-term.
b. Who. All Offices/Regions involved in regulatory/policy
development, enforcement, & permitting.
c. When. Immediately begin to increase the activities already
underway.
d. Barriers. Legislative requirements prescribe technologies in
many cases; legislative/regulatory requirements allow limited
time to comply with requirements when development &
implementation of P2-oriented technologies need more time.
Risk-based standards have been difficult to set.
e. Costs. Time & resources to identify and eliminate barriers
under EPA's control; political capital to pursue legislative
changes.
f. Benefits. By focusing on P2 & strengthening the message, EPA
will be ensuring that in the long-run, quantities of wastes
generated and released to the environment will continue to
decline; facilities realize cost savings, including liability
costs, as they will treat & dispose smaller quantities.
g. Measuring Success. Number of regulations, guidance
documents, & policies developed & implemented with P2 as the
central focus; reductions in the quantities of wastes
generated as a result of P2 & cost savings to facilities.
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PP 22
D.2. Provide flexibility in Permit Compliance. Fee Schedules, and
Processing Time for Permit Applications to Encourage
Pollution Prevention
a. What. To encourage permittees to rely more on prevention
than on treatment and disposal, EPA & states work together to
develop means of promoting P2 in environmental permits such
as(1) allowing extra time to comply; (2) expediting permit
applications utilizing P2; & (3) using differential (perhaps
lower) fee for permits that rely primarily on P2 as a means
to comply with the requirements. Create an EPA/State Permits
Group to assess means for encouraging P2-oriented permits.
Develop & implement options to remove barriers identified
through the pilot projects; modify permit regulations &
guidance as appropriate to foster P2.
b. Who. EPA & State permit & enforcement staff
c. When. Establish Permits Group or empower existing group by
10/1/93; identify opportunities to pilot test ideas by 12/93;
start pilots in different Regions & States by 3/94.
d. Barriers. Existing regulations/legislation may limit ability
to provide extra time needed to promote P2-oriented
technologies; laws/regulations may limit fee flexibility;
lost revenue to State programs that use fees for funding
programs; difficult to define & agree on what is P2 & how
much P2 is acceptable for differential treatment; how to
define "good faith" noncompliance while trying to achieve P2
solutions.
e. Costs. Additional FTEs to process permit applications
guickly, primarily at State level; perhaps lower State
revenues from lower permit fees.
f. Benefits. Long-term reduction in quantities of wastes
generated, treated, & disposed; more efficient utilization of
resources for both permittees & permit issuing agencies;
potential cost savings to permittees in the long-run; better
long-term environmental results because less is released;
lower permit fees and/or speedy processing of permit
applications may elicit better cooperation from facilities
thus potentially reducing permit backlogs.
g. Measuring Success. Number of permits with P2 focus; compare
releases from prevention-focused & non-prevention-focused
permits; cost savings & efficiency gains to both permittees
and permit writing agencies.
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PP 23
D.3. Develop Pilot Projects for Integrating Pollution Prevention
into Development and Implementation of Regulations. Guidance
Documents, or Policies for Two or More Media for the Same
Industry
a. What. Source Reduction Review Project (SRRP) provides
information on the list of regulations in various programs
that will attempt to include a P2 focus in their development.
These regulations are being developed separately for each
medium & mostly on different schedules. Work has also been
done on clusters. Experience on the integrated rulemaking
for the Pulp & Paper Industry to date has been positive &
needs to be reaffirmed with other efforts. Combine the
concept of P2 & multi-media by selecting two or more
regulations affecting an industry to be developed together &
on the same schedule. Pilot test concept on a couple of
industries. Create an Action Group to make recommendations
on potential pilot projects. Fund the projects rather than
specific Offices/Regions doing them.
b. Who. Administrator creates an Action Group from across EPA.
Offices/Regions participate.
c. When. Select Action Group by 9/1/93; identify candidate
industries by 12/1/93; select pilots by 2/1/94; develop
action plan including schedules, resources & FTEs & obtain
Administrator's approval & begin pilots by 3/1/94.
d. Barriers. Existing regulations & statutory constraints;
court-ordered deadlines; entrenched attitudes among
regulation/policy development staff & implementation staff;
lack of trust among other parties and EPA; different media
offices have little incentive to cooperate on developing
multi-media regulations, policies, or guidance documents.
e. Costs. FTEs and resources will have to be reallocated to
ensure that the schedules are met.
f. Benefits. Coordinated & improved environmental & human
health protection; more cost-effective environmental results;
minimize opportunities for transferring pollution from one
medium to another; industry/sector can realize improved
resource efficiencies through better planning; EPA operates
more efficiently.
g. Measuring Success. Indicators of environmental improvement
or degradation in a geographic areas where specific target
pollutant or industry is affected by the regulation or
guidance/policy and its enforcement; quantify cost savings to
the industry/sector in the pilot; quantify potential
reductions in multi-media releases to the environment.
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PP 24
D.4. Harness Enforcement Activities to Help Promote and Implement
Pollution Prevention
a. What. Expand the use of pollution prevention in enforcement
activities. Encourage & fund multi-media inspections &
compliance activities. Use settlements both as a means of
achieving compliance & to reduce or prevent pollution.
Expand use of Supplemental Environmental Projects (SEPs) &
other compliance activities that can be used creatively to
encourage P2. Ensure that enforcement policies do not act
against P2 & work to encourage it. Develop integrated
reporting systems to support compliance & P2. Expand
training for enforcement personnel in available P2
technology, source reduction techniques, etc. that may be
relevant to the specific kinds of violations found at
facilities. Gather information on use of P2 in settlements.
Build upon prior efforts to remove barriers to P2 in
enforcement.
b. Who. Headquarters & Regional enforcement staff. NETI
provides more comprehensive and increased quantity of
training for both technical and legal staff.
c. When. Preliminary efforts already underway to develop
training for Regional enforcement staff on P2. Other
activities can begin immediately.
d. Barriers. Opportunities for promoting P2 through enforcement
are limited to cases where violations have occurred; current
regulatory and/or statutory requirements may preclude EPA
from making the maximum use of P2; Congressional/GAO
criticism of SEPs.
e. Costs. FTEs to educate staff & travel money for training
f. Benefits. Promoting P2 through enforcement settlements
informs general public that EPA is very serious about
prevention; encourages facilities to fully consider
prevention in developing their compliance strategies;
facilities may realize cost savings, including reductions in
potential liabilities, when they rely on prevention as
opposed to treatment and disposal approach.
g. Measuring Success. Number of enforcement actions resolved
using SEPs that rely on P2 to achieve & maintain compliance;
decreases in the quantities of pollution generated & released
to the environment; cost savings to the facility vis a vis
costs of treatment & disposal.
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Target/Action Category E:
EPA SHOULD ENHANCE PARTNERSHIPS WITH STATE. LOCAL. AND TRIBAL
GOVERNMENTS TO IMPLEMENT POLLUTION PREVENTION
The majority of EPA programs are implemented at the state, tribal,
and/or local level. As the Administrator has stated, for EPA to
make P2 its central ethic, it must solicit and engage in an active
partnership with state, local and tribal governments. This
requires a paradigm shift in the manner in which EPA has
historically interacted with these entities. Changes have already
been made in this direction. EPA needs to view its
state/local/tribal partners as customers, providing them with the
necessary tools and funding to implement P2. EPA must also bring
them into the regulatory development and policy development
process to verify that P2 initiatives can be carried out as
designed.
Many state governments have been leaders in implementing P2
programs. The majority of states have established technical
assistance programs, either within the state environmental
regulatory agencies, or within non-regulatory entities, such as
universities or non-profit organizations. In addition, several
states have enacted facility planning or toxics use reduction
legislation. EPA should use the experience gained from these
existing state P2 programs in establishing specific federal P2
programs, regulations, and legislation. The states may also
provide a useful "laboratory" to test other creative ideas to
cost-effectively prevent pollution.
EPA has a crucial role as a catalyst and facilitator in promoting
P2 within environmental programs at the state/local/tribal level.
This role is best served through providing consistent and adequate
funding to state/tribal and local P2 efforts, providing for more
reasonable state and tribal matching requirements, and sharing
appropriate P2 information and technologies with and between our
state/tribal/local "customers".
Category E Initiatives;
E.I. Work With the States on Pollution Prevention at as High a
Management Level as in Other Programs
a. What. EPA should communicate P2 to state governments through
every program, to assure that they understand our commitment
and support for state P2 activities, both regulatory and non-
regulatory. The Regional Administrators must be held
responsible for working with the state Directors (or even
higher levels in state government) to encourage P2 activities
within the state regulatory agencies. Program managers
should also be held responsible for encouraging state P2
efforts within their programs. This can be done through
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performance agreements, STARS credit, or changes in the
workload models to base funding on the P2 activities to be
undertaken. At the same time, states should not be pushed to
do additional activities unless EPA provides new money. For
the most part, this effort should focus on "integrative"
work; i.e. putting P2 into permits, compliance orders,
inspections, etc. Additional activities would require
decisions on which current activities to disinvest.
b. Who. EPA's Senior Management Council.
c. When. Begin immediately; implement first round of
accountability measures by end of FY 1994.
d. Barriers. Statutory requirements that keep staff busy and
tie up available resources; institutional reluctance to
change; uneasiness about the legality of some P2 projects
(such as certain Supplemental Environmental Projects); the
common view that P2 is something "extra."
e. Costs. Disinvestments in different areas.
f. Benefits. Provides an effective mechanism for
institutionalizing P2 into state activities to implement
federal environmental programs; states will be more willing
to implement P2 within their regulatory programs, and will
more readily generate & share success stories with EPA; net
societal effect should be more cost-effective environmental
protection.
g. Measuring Success. Using performance appraisals and STARS;
reduction in chemical releases (perhaps through Toxics
Release Inventory).
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E.2. Improve Funding for Pollution Prevention Activities by States
a. What. Consistent funding is critical to imbed P2 in state
programs. Money allocated for P2 activities in EPA state
grants is far less than for control; this gives the message
that pollution control is still the first priority. EPA must
redirect resources to support state/local/tribal P2
activities. Increase funding for state/local/tribal P2
activities: 1) use program office P2 grant flexibility to
integrate P2 in media-specific regulatory programs (include
specific P2 activities within annual program grant guidance);
2) set aside percent of media grant funds for multi-media P2
activities; 3) request increased funding for grants under the
Pollution Prevention Act to support technical assistance &
other programs not necessarily housed in regulatory agencies;
4) develop guide to help state programs to become self-
sustaining; (5) provide information on non-EPA sources of
funds & work with other agencies to encourage use of their
funds to support P2 programs; (6) decide which activities to
drop to allow P2 projects; (7) address 50% matching problem:
reprogram money into programs with lesser match or lower
matching requirement.
b. Who. Each Office/Region. OPPT lead on matching problem.
c. When. Grant flexibility in FY 1995 program grants; request
increased PPA grant funding for FY 1995 by 10/93; revise 1995
media program grant guidance in FY 1994.
d. Barriers. Pollution control "beans" currently determine
grant activities, "extra" money for P2 activities; current
grant guidance does not generally require P2 activities, &
only occasionally encourages it; new money hard to come by,
even for a top priority; requirement for 50% match to receive
P2 grants (prohibits development of P2 programs in state &
tribal governments where the need is the greatest; other
media grants do not require this level of matching).
e. Costs. Increase in funding through PPA; staff time to change
guidance and re-structure accomplishment "beans".
f. Benefits. States will believe EPA's commitment to P2, & will
be able to do more to foster its adoption; discretionary P2
funds allow states & tribes to address environmental problems
that are currently not addressed under an existing regulatory
mechanism; better, more cost-effective compliance &
environmental protection.
g. Measuring Success. Extent to which states use their grants
to promote P2; document P2 activities undertaken by states
(states to do it as a part of grant) and results.
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E.3. Promote One-stop Shopping for Environmental Regulatory
Assistance, Pollution Prevention Technical Assistance, and
Other Assistance Programs
a. What. States have many disparate programs whose goal is to
provide regulatory & technical assistance to businesses.
Most states have P2 technical assistance programs. Many also
have industrial & agricultural extension services, OSHA
assistance programs, RCRA small guantity generator programs,
NIST-sponsored manufacturing centers and/or SBA small
business assistance programs. In addition, Clean Air Act
(CAA) Amendments of 1990 require all 50 states to have a CAA
small business assistance program in place by 11/93.
Proliferation of small business assistance programs can make
obtaining appropriate assistance difficult & confusing for a
particular business. Coordinate (if not consolidate) all
small business assistance programs sponsored or mandated by
the Federal Government so they appear as "one-stop shopping"
to the small businesses. Work with these federally-sponsored
or mandated programs to help them incorporate P2 into their
assistance to improve manufacturing & competitiveness. Work
with state, university & other assistance programs,
particularly P2 technical assistance programs, to encourage
them to interact with the federally-sponsored or mandated
programs, & to help them incorporate P2 assistance where they
do not already.
b. Who. Working group with representatives of all affected
programs to determine a mechanism for coordination. May be
most effectively done with Regional Offices and
clearinghouses.
c. When. Initiate FY 1994. Will require negotiating with a
large number of programs so may take a while to complete.
d. Barriers. Because programs were set up by different parts of
EPA, other federal agencies, and state and local entities
under a number of different authorities, with a number of
different, but related, purposes, authorities, turf, and
purposes would have to be brought closer together.
e. Costs. EPA staff time; resources to establish information
linkages.
f. Benefits. Various resources currently split among these
programs could be used in a more coherent & efficient
fashion, to help business improve production with cleaner,
environmentally compliant technology.
g. Measuring Success. Degree to which small businesses turn to
one source to locate the services they need.
[FILL BACK IN HERE]
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E.4. Adopt Standard Practice of Allowing Flexibility for States
and Local Governments to Comply with Environmental
Requirements Through Pollution Prevention.
a. What. Set concrete goals based on acceptable environmental
and human health protection criteria, then allow compliance
by the most cost-effective means. With this flexibility,
state and local governments are able to implement creative,
cost-effective, protective, P2 approaches. EPA promotes use
of P2 in meeting these criteria by publishing guidelines that
promote the P2 options. Many past regulations have been
promulgated with little or no input from the state and local
governments responsible for implementation. EPA should
involve these "customers" more in the regulatory development
process to ensure the implementability of regulations.
b. Who. All EPA Offices that regulate state and municipal
governments' environmental operations.
c. When. Begin immediately to notify appropriate authorities of
impending change.
d. Barriers. Institutional approaches to reviewing and revising
existing regulations; existing requirements may act as
barriers.
e. Costs. EPA staff time.
f. Benefits. Decreased compliance costs for state/local
governments and industry; increased P2.
g. Measuring success. Cost (to agencies & industry) of
achieving compliance; rate of compliance.
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E.5. Facilitate Pollution Prevention by Native American Tribal
Governments
a. What. Tribal governments have special difficulties
implementing P2, and require federal action to overcome them.
Due to financial difficulties, Tribal governments have not
been able to utilize EPA P2 funds (which require a 50%
match), or develop their own programs. They are also at a
disadvantage for obtaining currently available EPA support
because they must compete with many much larger state
governments and universities for the few available awards.
Establish a working group with the affected Tribal
governments to find a way to overcome these barriers and meet
their needs for P2. May include making funds reasonably
available to the Tribal governments, and providing necessary
training and culturally appropriate informational materials.
b. Who. OPPT and EPA Institute
c. When. Begin immediately (this has already been under
discussion). May take a while to accomplish if legislative
changes are found to be necessary.
d. Barriers. Financial/legislative, since the legislation
requires a match most tribes cannot afford; cultural
differences.
e. Costs. EPA staff time; travel expenses for Tribal
representatives; training expenses, including the costs of
generating educational materials.
f. Benefits. Provides more environmental justice for Native
Americans, and cleaner economic development of Native
American lands.
g. Measuring Success. Number of grant awards made to tribal
governments for P2; effectiveness of P2 actions taken.
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E.6. Develop a "Demand-side Management" Strategy for Municipal
Water Programs
a. What. Demand-side management programs are currently underway
by various electric utilities to provide incentives & other
means to reduce demand for power. Demand-side water programs
can be a cost-effective way of reducing need to treat water.
Several cities have implemented demand-side water
conservation programs which cost less than the supply-side
option (new treatment plants). Encourage this as an option
in construction of new wastewater treatment plants & drinking
water facilities through annual program guidance, state
grants and/or state revolving fund. First step: determine
whether revolving fund can be used to support demand-side
management projects. Then alter program guidance to
encourage this approach. Note: Region IX has been
encouraging this approach in their Regional grant guidance.
b. Who. Office of Water.
c. When. Begin feasibility assessment and planning immediately.
d. Barriers. Cultural change in how we do business;
appropriation issues about use of money in this way.
e. Costs. Staff time to make changes.
f. Benefits. Decreased need to expand POTW capacity and
associated cost savings (in Boston, the cost was 1/3 to 1/2
that of building new capacity); reduction in cost to comply
with POTW sludge regulations; reduction in depletion of water
supplies; economic benefits of reduced water use; reduced
need to expand or build new drinking water supply units and
associated costs.
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E.7. Develop Municipalities' Capabilities to Use Pollution
Prevention as a Centerpiece of Their Pre-treatment Programs
a. What. Several municipal wastewater programs currently
provide P2 assistance to their business and industrial
customers to help them meet or exceed pre-treatment
standards. Through this assistance, companies are able to
reduce their water use and the waste and release of other raw
materials. Several POTWs in Region IX have been implementing
P2 programs with their dischargers. Capture this existing
experience and put it into a manual for use by other POTWs.
Region V is currently working with the Metropolitan Sanitary
District in Chicago to set up a P2 technical assistance
program for its dischargers. Encourage this more widely.
Request additional authority to require BMP's, not just
encourage their adoption.
b. Who. Office of Water, state water programs.
c. When. Already being done in some municipalities. Program
guidance to encourage others to undertake it, begins with FY
1994 funding. Training developed & provided to appropriate
personnel beginning in FY 1994.
d. Barriers. Different way of doing business; local officials
will need to acquire new expertise. Costs to local
governments.
e. Costs. EPA staff time for re-writing program guidance;
training and publication costs; costs to local governments to
implement; local government training & travel costs.
f. Benefits. Local water treatment programs can greatly
influence amount of pollutants generated by local businesses
once they start educating them about P2; local officials are
closest to the problem, and are more familiar with the
particular businesses in their area than are EPA or state
officials; higher rates of compliance; lower costs of
compliance; lower sewer surcharges and water costs for
businesses; reduced loss of raw materials; reduced demand for
expansion of treatment facilities.
g. Measuring Success. Number of facilities a municipality has
helped with P2; how many of a POTW's clients are in
compliance; reduction in wastewater flows, BOD, COD or other
water-borne contaminants from facilities involved in the pre-
treatment program; reduction in total pollutants discharged
to all media by these facilities (This will be especially
easy if they report to TRI).
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Target/Action Category F:
EPA SHOULD TAKE AN ECONOMIC SECTOR-BASED APPROACH TO THE DEVELOP-
MENT OF ENVIRONMENTAL POLICIES AND PROGRAMS. WITH POLLUTION PRE-
VENTION AS A KEY MEANS OF ACHIEVING COST-EFFECTIVE ENVIRONMENTAL
PROTECTION
As noted in the Vision Statement, the societal goals of
sustainability and innovative technological development make it
increasingly important for government policies and private sector
actions to adopt a strategic approach to environmental management.
For government, this means addressing environmental problems in
the context of long-term socioeconomic goals. For businesses, a
commitment to strategic environmental management requires an
investment in long-term, cost-effective pollution prevention as
part of an overall commitment to develop innovative new products,
improve production quality, and achieve sustainable development.
In order to effectively promote a culture change of this
magnitude, EPA needs to effectively link its own environmental
programs with long-term socioeconomic goals. The Administrator
already has noted her commitment to this goal, but at present the
strategies and policies to establish that linkage have not been
developed, and it is not clear that the Agency's traditional
media-specific approach is adequate to achieve such a broad-based
culture change across all economic sectors.
Many respected environmental commentators have recommended
that EPA break away from the media-based programs of the past and
think in terms of long-term, sustainability goals, starting by
developing environmental policies and programs by economic sector.
A sectoral focus would enable EPA and the federal government as a
whole to more effectively integrate environmental concerns with
long-term economic strategy. A sectoral approach also would help
to break down the organizational barriers that prevent EPA from
becoming more efficient in achieving desired environmental
results.
Because of the innovative nature and long-term focus of this
category, we believe that EPA should focus initially on assembling
the right groups and initiating the right projects to start to
determine how best to pursue a sector-based approach.
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Category F Initiatives;
F.I. Develop Sector or Sub-Sector Specific Policies. Projects, and
Programs to Most Effectively Drive Private Sector Behavior
and Promote Desired Private Sector Actions
a. What. EPA should conduct sector-specific analysis, develop
pilot projects, and implement programs to promote strategic
environmental management in the private sector (i.e., linking
innovation and product quality with P2 and sound
environmental management; promoting investment in innovative
technologies and processes that are environmentally sound).
Build on sector-based work done to-date or ongoing (e.g.,
Amoco Project, OPPE's Industrial Sector Project, OPPT's DFE
projects,). Demonstration projects should be public/private
partnerships to test analyses and implement sector-specific
policies. These policies should reflect a greater customer
(assistance) orientation for EPA, but also should go beyond
outreach and technology transfer to provide incentives for
innovative private sector actions. Ensure that adequate
attention is given to sub-sectors within broad economic
sectors.
b. Who. EPA working groups and external network identified in
Initiative F.2.
c. When. As task force work proceeds.
d. Barriers. Reluctance to break away from the status quo;
restrictive statutory and regulatory requirements; cultural
(i.e., trust) barriers.
e. Costs. To be determined as sector-specific initiatives are
developed; implementation costs kept down because of
networking and leveraging described in Initiative F.2.
f. Benefits. Long-term benefits are public and private sector
culture change -- linking economic and environmental policies
in government, establishing strategic environmental programs
in the private sector that go beyond baseline compliance,
greater "customer" focus for EPA programs and less emphasis
on costly regulatory programs over time. Clearly multi-media
in nature. Consistent with the concept of EPA as a leader,
not merely a reactive Agency. Long-term societal pay-off is
a more profitable, competitive, innovative, quality-oriented,
and prevention-oriented private sector, plus a cleaner
environment at lower cost.
g. Measuring success. Measure P2 accomplishments and cost-
effectiveness of pilot projects (e.g., pay-offs in terms of
profitability, competitiveness, innovation, product quality,
investment in prevention, impacts on compliance costs, and
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environmental benefits).
F.2. Establish Multi-Disciplinary Working Groups Within EPA and
With Outside Entities to Develop Sector and Subsector
Strategies
a. What. Establish and empower multi-disciplinary working
groups in EPA to develop and implement sector-based
activities described in Initiative F.I. (from analysis,
through demonstration, to implementation). Establish
partnerships with other Federal departments/agencies and the
private sector to contribute to these activities with
expertise, resources, complementary activities, etc.
b. Who. Establish internal working groups, communicating
directly with the Administrator and coordinating through the
Senior Leadership Council. EPA should seek innovative
thinkers and employees who already have done work in this
area, though not necessarily from media-specific and even P2-
oriented programs. Also, establish public/private working
groups, with participants drawn from the President's Council
on Sustainable Development; the Departments of Commerce,
Energy, Agriculture, and Transportation; the Office of
Technology Assessment; the U.S. Trade Representative; and the
White House Office of Environmental Policy. Private sector
network partners also should include NGOs, regions and
states, trade associations, academia, individual industry and
business representatives. Contacts should occur at both EPA
management and staff level. Connect with groups that are
focused on sustainable development, not just single-issue
groups.
c. When. Set up working groups by December 1993.
d. Barriers. Current organizational structure and reluctance to
break away from the status quo; restrictive statutory and
regulatory requirements; cultural (e.g., trust).
e. Costs. FTEs and money reallocated from existing activities
(but low in relation to the possible benefits).
f. Benefits. Such task groups are a logical follow-up to the P2
NPR team. EPA working groups would clearly be multi-media in
nature and would help break down organizational barriers. Ad
hoc groups would generate maximum interest, draw upon a wide
range of expertise and experience, and promote innovative
thought. Networking outside EPA will ensure that sector
initiatives are well coordinated; will leverage non-EPA
interest, expertise, and resources; will identify and pursue
more cost-effective strategies to achieve strategic
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environmental goals; will foster public-private partnerships
with more of an economic focus than such partnerships have
had in the past.
g. Measuring success. See Initiative F.I.
F.3. Take a More Proactive Role to Develop Legislation That Would
Provide Greater Flexibility for EPA to Promote Innovative
Programs. Pursue Regulatory Trade-offs, and Prioritize Risks
a. What. Statutory requirements often pose significant
barriers to innovation, R&D investment, P2, and strategic
environmental management (beyond the baseline). EPA should
show Congress that sustainable development policies require
flexibility for government and the private sector to
experiment with innovative approaches. EPA should develop
and promote specific legislative proposals to increase
flexibility and reduce current statutory barriers to
innovation and the prioritization of risks.
b. Who. Sector-based task groups.
c. When. Begin ASAP and continue on an ongoing basis.
d. Barriers. Congressional and agency turf; reluctance to
compromise stringent environmental standards even on a trial
basis; slow legislative process.
e. Costs. Relatively low EPA FTE and extramural costs;
requires expenditure of political capital to promote
changes.
f. Benefits. A successful legislative program would provide
EPA with greater flexibility to develop innovative programs,
initiatives, etc.; would help to move Congress away from
single-medium framework and make Congress part of the
solution rather than part of the problem; would reduce
private sector compliance costs over time (even as
environmental performance improves); would provide better
environmental results in a more cost-effective way.
g. Measuring success. None identified.
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Target/Action Category G;
EPA SHOULD CULTIVATE PUBLIC/PRIVATE PARTNERSHIPS TO FOSTER
POLLUTION PREVENTION
The Clinton Administration has highlighted the need to
"reinvent" government in order to energize government and public
entities to accomplish goals. The EPA Administrator has
emphasized the importance of creating partnerships with state,
local, and tribal governments, business, other agencies, and the
public in carrying out EPA's mission. Public/private
partnerships can be a way of reinventing the relationship between
government, industry and the public to accomplish the objective
of pollution prevention. In fact, pollution prevention can only
be effectively implemented by changing the way people think about
doing business. In particular development and selection of
pollution prevention options involve value choices amongst trade-
offs and can only be successfully implemented through the
participation of all stakeholders. By successfully working with
partners at all levels of government, in the various business
sectors, and in the public, EPA can provide the leadership to
catalyze change, inform change and ensure the priority of
pollution prevention in the support of sustainable development.
While forming effective partnerships is reflected in Initiatives
throughout this Report, this category focuses on developing new
partnerships with industry and the public to promote, implement
and measure pollution prevention activities.
Category G Initiatives;
G.I. Assist Industry Groups in Measuring Environmental Results of
Their Codes of Conduct
a. What. Several industries have developed environmental
stewardship programs to guide the behavior of their members
(e.g., chemical industry's Responsible Care program.) A key
to making these codes credible with the public is to develop
tangible measures of environmental improvement that result
from implementation of the codes. Various offices within
EPA have worked to develop environmental indicators. EPA
would develop partners with one of the industry groups
having a stewardship program to develop, implement, and
promote a publicly accessible information system to track
the industry's progress. Coordination of multi-media risk
and policy issues would be accomplished with an agency-wide
work group which would help direct the project. In addition
to developing a measurement system, elements of a successful
stewardship program will be identified with the objective of
expanding both the measurement system and stewardship
program to other groups.
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b. Who. EPA program office, presumably one with greatest
interest in the industry advancing the stewardship program.
c. When. Partner industry would be identified and development
of the tracking system would be begun in FY 1994. The
tracking could begin in 1995.
d. Barriers. Finding a willing, cooperative partner; difficult
to develop the measures, verify the claims made, and find an
effective way for delivering the information to the public.
e. Costs. Should mainly be FTEs; we would expect the industry
to provide contractor support.
f. Benefits. Would enhance the credibility of these codes of
conduct, which can be a positive influence on industry;
would also help improve the methodology for measuring P2
progress. Would help expand the stewardship effort by
providing systematic tracking and standards for success.
g. Measuring Success. Success will be measured by increased
industry efforts to develop stewardship programs and by the
reduced pollution tracked by the measurement/indicator
systems.
G.2. Develop a Facility-based System for Organizing All of EPA's
Data
a. What. TRI has been a very effective system for organizing
and informing the public on what EPA knows about the
environmental performance of facilities. EPA has collected
a great amount of other data about these facilities as well.
EPA has already developed IDEA and other facility data
systems. Build upon TRI and other facility data systems to
devise a facility-based information system that adds to the
TRI data the information collected by the air, water and
waste programs. Private groups have begun to build such
integrated systems (i.e., RTK Net) and EPA may simply need
to provide financial assistance and data access to such a
group. Explore ways of describing releases per unit of
production.
b. Who. All EPA programs with facility-specific data would
need to participate; coordination could take place through a
cross-Agency task force chaired by OPPT or OIRM.
c. When. System design - FY 1994. Implementation - FY 1995.
d. Barriers. There would be bureaucratic inertia that would
need broad program office to overcome.
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e. Costs. The information management costs could be
significant.
f. Benefits. Having all of EPA's facility-specific data
organized in a single system would give the fullest possible
picture of what progress is being made toward pollution
prevention. Through this system EPA could also begin to
identify opportunities for data harmonization, elimination
of duplication and reconciling incompatible reporting
schedules.
g. Measuring Success. At one level this system is successful
if it is used. It could also be viewed as a contributor
toward more positive trends in facility performance.
Target/Action Category H;
EPA SHOULD TAKE A LEADERSHIP ROLE IN PROVIDING EDUCATION AND
INFORMATION ABOUT POLLUTION PREVENTION
EPA needs to increase its investment in Environmental
Education as a means of preparing existing staff at EPA, other
federal and state agencies, industry and the public with respect
to pollution prevention. In addition, such education is needed
to reach consumer-age audiences, and to help raise new
generations of environmentally conscious Americans. The first
priority of EPA's education activities should be to assure that
its own staff is sufficiently trained in pollution prevention to
equip them to develop a P2 ethic, to be effective in their P2
outreach and technical assistance, and to train other personnel.
Secondly, EPA should proactively educate the public and private
sectors about pollution prevention opportunities. Educational
programs should be formulated or enhanced for all levels of
learning. Through P2 education, the public can learn how to help
conserve energy, natural resources and money, and how to improve
the competitiveness of the nation's products and services.
Four target groups are addressed by the education
initiatives: EPA's own staff, other government agencies, private
industry, and the general population (e.g., schools and
universities). In addition, one initiative in this category
addresses the development and dissemination of a chemical use
inventory.
Two essential items which must be present to ensure
integration of pollution prevention into EPA's and the nation's
ethic are: pollution prevention education and training of
existing and new generations of Americans; and identification and
dissemination of potential emission reductions to the public and
industry.
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Category H Initiatives:
H.I. Begin General Pollution Prevention Education Initiative
a. What. Education and training of EPA staff is one of the
essential building blocks in EPA's efforts to promote P2
throughout the nation. Convene an EPA P2 Training Work
Group to develop minimum training standards and prepare a
draft EPA Order on P2 training. Build on environmental
education initiatives EPA has already undertaken. Develop
increased societal interest in and support for P2 by
investing in an Environmental curriculum of school age
children K-12. Work with higher education to increase
curricula development such as those developed by UCLA, NJIT
and the EPA (OPPT) sponsored program at the University of
Michigan. Aggressively educate populations and communities
that experience the majority of environmental inequities to
give them leverage in fighting against those inequities.
The goal is to develop environmental awareness through
curriculums, workshops, training programs and information
resource centers. Leverage industry public education
programs as well. Consider using techniques such as "town
meetings", satellite/cable TV broadcasting; Public and
educational TV broadcasts; P2 "infomercials", etc.
b. Who. A broadly representative group of EPA trained
staff would work with state/local environmental agencies and
school systems, various higher education systems, and
industry.
c. When. Work group prepares guidelines for the programs by
the close of FY 1994. Training sessions and other public
outreach techniques are organized by mid FY 1995. Such
programs are devised and arranged for the 1995 school year,
and for the general public during calendar 1995.
d. Barriers. Resources; lack of sufficient networks of
professional and educators; lack of trust among federal,
state/local and industry personnel; lack of previous
experience on similar topics.
e. Costs. Estimated $2,000,000 plus FTE commitment.
f. Benefits. Would help make the general public, including
young people, aware of the environmental impacts of their
actions and provide choices that will have positive
consequences for their own health and the health of the
environment. These programs would provide opportunities for
young Americans to become future partners of the environment
through science and technology. These programs could result
in improved competitiveness of our products and services.
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g. Measuring Success. None identified.
H.2. Facilitate the Sharing of Pollution Prevention Information
with Industry
a. What. Currently, private industry receives information
from EPA program offices about causes and effects of
polluting, ways to control and prevent pollution, and
benefits of using pollution prevention. State technical
assistance programs and industrial extension services
provide much of the P2 information to individual facilities.
EPA should work to:
1) Develop more information about P2 opportunities, working
with industries;
2) Support organization and activities of the National
Roundtable of State Pollution Prevention Programs (the
Roundtable).
3) Continue ongoing effort to delegate operation of the
Pollution Prevention Information Clearinghouse (PPIC) to the
Roundtable.
4) Encourage & fund support of Regional Pollution
Prevention Resource Centers (similar to the one in Region
IV, Great Lakes Technical Resource Library, NEWMOA, and the
Pacific Northwest P2 Research Center) to help bring together
P2 information & make it accessible to all state, local, &
tribal governments and EPA.
5) As in Region IX, bring EPA Regional libraries &
information centers into the national P2 information
network, and empower existing library system to be an agent
for disseminating P2 information.
b. Who. EPA Program Offices, OPPT, EPA libraries.
c. When. Much of this has begun on a small scale, or in
limited geographical areas. These activities should be
expanded now.
d. Barriers. Large number of assistance programs to
coordinate.
e. Costs. About $150-200,000 per Region to support Regional
Centers.
f. Benefits. P2 information more easily available to everyone
who needs it, increasing the adoption of P2; state P2
programs will have a coordinated forum for interacting with
EPA and others. Enhanced partnerships between public and
private sectors.
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g. Measuring Success. None identified.
H.3. Develop a Chemical Use Inventory
a. What. Current efforts to track progress in pollution
prevention have been facility-based (i.e., Toxic Release
Inventory). Another useful way to track progress in
pollution prevention is to monitor changing patterns in the
use of toxic chemicals (i.e., is the trend toward safer,
less toxic materials). Under this initiative EPA would
require chemical manufacturers and processors to report on
how their products are used every ten years, along the same
schedule as TRI. This data would be made available to the
public along with the TRI results.
b. Who. EPA (OPPT).
c. When. System design - FY 1995. Implementation - FY
1996.
d. Barriers. It will be difficult to develop a system for
describing use patterns that is informative to the public
and will protect confidential business information. Also,
some manufacturers claim they do not know how their
customers use their products. OMB approval due to the
Paperwork Reduction Act if this is deemed a survey.
e. Costs. None identified.
f- Benefits. EPA has rather limited data on how chemicals are
used in this country. This data would help the entire
Agency set priorities for what industries and processes
deserve greatest attention. Also, the public reporting will
help push industry toward development of safer products. It
will also push manufacturers and processors to be more
attentive to how their products are used.
g. Measuring Success. The project is successful if the data is
used by government and industry to guide behavior.
Target/Action Category I;
EXECUTIVE BRANCH SHOULD INTEGRATE POLLUTION PREVENTION INTO ITS
PROCUREMENT AND DEVELOP FEDERAL AGENCY RELATIONSHIPS TO PROMOTE
POLLUTION PREVENTION NATIONWIDE
The federal government is one of the largest employers of
personnel, generators of pollution, buyers of products and
services, and performers of research and development in this
country. According to the GSA, there are over 350,000 federal
buildings on more than 700 million acres of public land. As one
of the largest purchasers of goods and services in the nation, it
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should establish a market for innovative and environmentally
sound products and services. In this manner the government could
significantly influence manufacturing, marketing, application and
disposal habits of the entire nation, and perhaps the world.
Furthermore, by demonstrating the cost and benefits of such
innovative pollution prevention equipment and procedures, it can
substantially improve the competitiveness of the nation's
manufacturers and service organization. Therefore, it plays a
crucial role in shaping the country's environmental agenda and in
developing an environmental ethic.
The federal government is rapidly being required by statute,
regulation, and policy to reduce its consumption of natural
resources and to reduce the quantity and toxicity of its releases
to the environment during a period of increasing budgetary
constraints. As a result, pollution prevention is increasingly
seen as a cost-effective approach to meeting these requirements.
In response to the mandate of the Pollution Prevention Act
of 1990, EPA prepared the "EPA's National Pollution Prevention
Strategy of 1991". The goal of the EPA Strategy is to:
"Establish the federal government as the national leader in
implementing pollution prevention policies and practices across
all missions, activities, and functions in order to promote the
sustainable use of natural resources and protect human health and
the environment."
Recommended objectives and key targets for each opportunity
are addressed in the initiatives in this Category. The President
must lead in this effort. To the extent possible, EPA should be
prepared to provide technical assistance to other federal
agencies to accomplish these P2 goals.
Category I Initiatives;
I.I. Advance Principles of Pollution Prevention in Executive
Branch Through Procurement of Goods and Services
a. What. Implement affirmative environmental procurement
programs & life-cycle costing practices throughout federal
government to influence and help create markets for
environmentally acceptable products & innovative
technologies, & to demonstrate cost benefit of such
products. Over 100,000 federal government specifications
and standards currently on the books. Build on the
experience gained by DOD in pursuing environmental
considerations and hazardous materials concerns. Under E.G.
12780, EPA is required to issue procurement guidelines for
recovered materials; & other agencies must routinely report
their progress in adopting affirmative procurement programs.
Federal facilities should at least achieve the targets in
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the Interim Federal Government P2 Strategy, including: (1)
DOD reduction of use of TRI chemicals; (2) by 10/93, GSA
revision of FPMR handbook to require environmental review of
all specifications for civilian use; (3) by 6/93 revision of
each agency's procurement guidelines to minimize purchase of
ozone-depleting compounds; & (4) procurement of energy
efficient products based upon life-cycle analysis.
b. Who. President directs through Executive Order. OFCCP
develops procurement guidelines and regulations. Each
agency responsible for compliance. Technical assistance
from EPA.
c. When. President issues appropriate orders or directives by
1/1/94.
d. Barriers. Temporarily increased time and resource needs
during the transition period; insufficient funding and
personnel, particularly at EPA which has to provide so many
of the support services to other departments; possible lack
of suitable products and services; lack of suitable
training, purchasing, and management procedures.
e. Costs. High during start-up; major savings in long-term.
f. Benefits. Demonstration of Government leadership;
potentially significant reductions in the quantity of
pollution generated and consumption of natural resources;
reduced long-term costs of materials and services to the
Government; acquisition of experience and data to influence
purchasing and manufacturing habits of the entire country;
and experiences which should result in industrial leadership
in "quality", environmental and innovative technologies
which can be exported.
g. Measuring Success. Quantify the reductions in the amount of
pollution generated & released; quantify long-term cost
savings using total cost accounting methods.
1.2. Establish a Permanent. Inter-agency Team Reporting to the
Vice President to Gather, Evaluate. Develop Ideas for
Pollution Prevention Throughout the Federal Government and
to Coordinate P2 Activities Throughout the Federal
Government
a. What. In a brief time, EPA's NPR Pollution Prevention Team
identified several hundred ideas on P2 opportunities and
initiatives. At the same time many EPA employees responded
to the Administrator's request & submitted hundreds of other
P2 ideas for consideration in the NPR. Well over 600 ideas
were identified during the brief NPR effort. Many of these
ideas involved activities that extend beyond EPA to other
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Federal agencies. The Team did not have time to evaluate,
let alone review, many of the these ideas. In addition it
is anticipated that there will continue to be a stream of P2
ideas which affect more than a single federal agency, and
which can most effectively be handled by an inter-agency
team with a continuing mandate to review the ideas already
collected and to develop, solicit, and review new P2 ideas
from throughout the Executive Branch. Team is responsible
for reviewing, evaluating, and developing P2 ideas to the
point where they could be handed off to specific agencies
for implementation. Due to the likely synergism developed,
a great deal of benefit could result if the Team also
coordinated the P2 activities of all federal agencies
looking broadly at ideas, facilitating cross-pollination of
all agencies' P2 activities, and regularly reporting to the
Vice President. Team, comprised of voluntary members from
across the federal government, has a permanent staff and
some contractor funding to assist its activities.
Participation is considered a regular part of members'
regular agency jobs.
b. Who. President appoints Team. Team members drawn from
across Federal Government. Vice President monitors
development and handoff of ideas.
c. When. Team is selected by 11/15/93.
d. Barriers. Lack of management support for employees to take
on duties outside regular job description.
e. Costs. Limited to commitment of FTE to staff the Team;
minor resources for information gathering and report
production.
f. Benefits. Keeps the momentum begun in NPR going; Government
does not lose P2 ideas that could not be evaluated or which
applied to Executive Branch; facilitates synergism and
shows a continuing commitment to P2 and quality process.
g. Measuring Success. How many ideas go from Team to agencies;
how much pollution reduction and energy saved by government.
Target/Action Category J:
GOVERNMENT SHOULD USE MARKET INCENTIVES. INTERNALIZING THE
EXTERNALITIES. AND FISCAL POLICIES TO PROMOTE POLLUTION
PREVENTION
In our market economy, the price of goods and services generally
does not include all the environmental costs associated with the
production, distribution, use, or disposal of a particular good
or activity. For example, the price an individual pays for
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driving a car does not fully recover the cost to society of
maintaining the roads or the air pollution generated. As another
example, the price of cigarettes does not include the cost of
picking up and disposing the discarded cigarette butt and the
health and environmental impacts of the smoke. Unless such costs
(especially long-term costs), called externalities, are factored
into prices (internalized), the market will not properly allocate
resources among competing demands in society. Initiatives in
this category use financial adjustments to internalize the
environmental externalities which will promote pollution
prevention and lead us to a sustainable economy.
Category J Initiatives;
J.I. Develop "Take Back" Legislation and Regulations
a. What. With some exceptions, after a company sells a
consumer product, the company has no responsibility for the
environmental costs associated with the disposal of the
product. In other words, the cost of disposal of the
product is an invisible cost that is not factored into the
company's decision-making or pricing of the product which
contributes to a considerable waste management problem.
Other countries have started to enact such "take back"
requirements, while in this country the most common and
virtually only "take back" program, "bottle bills", are
fragmented across states, with many states having no such
requirements. EPA should review "take back" legislation and
its effectiveness in other countries and develop proposals
for such programs for appropriate consumer goods in our
economy, starting with those consumer goods whose disposal
creates the most significant environmental problems. Take
back programs could be based on a refundable deposit to
encourage recycling of the product, or on other financial
incentives, taxes or ways to encourage the reuse, recycling
or proper disposal of the product.
b. Who. White House, Congress, EPA, and other stakeholders.
c. When. This initiative can begin immediately.
Implementation can be phased-in with targeted industries and
pilot programs within two years.
d. Barriers. There will be institutional resistance associated
with developing and implementing a new program, changing
existing standards and methods of operation in the public
and private sectors, and educating the public and private
sectors.
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e. Costs. Unknown. Some companies are already beginning to
make "take-back" products in order to sell them in the
European market. Initially the implementation costs could
be higher until products are modified.
f. Benefits. Reduced disposal costs, increased efficiency and
recycling of product and resources.
g. Measuring Success. Success will be measured by quantifying
the benefits from reduced environmental impacts from
production and consumption of the product.
J.2. Establish a Federal Environmental Sales Tax
a. what. The cost of products and service often do not reflect
the environmental costs (the externalities not already
included in the market price) associated with the
manufacturing, packaging, advertising, distributing,
selling, using and disposing of the product or service.
White House establishes study group to determine if a
federal environmental sales tax could be developed to
internalize externalities. Other existing federal taxes
could be reduced or eliminated as appropriate.
b. Who. White House, interagency study group from Commerce,
Treasury, EPA, academia, industry, public interest,
Congressional staff, and other groups would be formed to
study the idea and make recommendations.
c. When. Study group would commence work in 1994 with report
by end of 1994.
d. Barriers. Considerable institutional barriers to change.
Problems in developing values to measure environmental
externalities. Public opposition to "another" tax unless
was clearly communicated that this would replace or reduce
existing taxes that did not promote pollution prevention and
sustainable development. No infrastructure to collect tax;
no experience.
e. Costs. FTE and political resources to develop and
implement idea.
f. Benefits. Market would now efficiently allocate resources,
with recognition for costs of pollution to society as a
whole.
g. Measuring Success. Adoption of the new tax structure.
Changes in consumption patterns to reflect environmental
costs.
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APPENDIX
POLLUTION PREVENTION TEAM REPORT
[Note: Initiative Numbers follow sequentially those featured in
body of Team Report]
Target/Action Category A:
EPA SHOULD PROMOTE SUSTAINABILITY THROUGH ITS POLICIES AND
PROGRAMS AS THE CENTRAL OPERATING PRINCIPLE FOR THE COUNTRY
A.3. Develop a Pollution Prevention/Sustainability Mission
Statement for EPA
EPA should develop a revised mission statement, based on the
principles of P2 and sustainable development. The mission
statement would be incorporated into EPA's official
Statement of Organization set forth in 40 CFR Part 1. As
part of the development of the mission statement, EPA should
evaluate whether measurable goals could be established to
enable the public and EPA to determine whether progress was
being made in meeting these goals. If measurable goals
could be formulated, EPA would commit to formally evaluating
its progress in meeting the goals every five years and
revising the goals as appropriate. To eliminate any
political influences in evaluating EPA's progress in meeting
the goals, an independent organization (e.g., a university,
GAO, the SAB) could be chosen to conduct the evaluation
process. EPA itself would be responsible for formulating
the mission statement and measurable goals. A team of
senior staff and managers across the Agency would be tasked
with developing a draft. Input and comments from other
agencies and organizations should be sought.
A.4. Assert EPA's Leadership Role on Council on Sustainable
Development
The formation of the White House Council on Sustainable
Development represents a strategic opportunity for EPA to
influence non-EPA policies and programs that are driving
forces in creating and maintaining our environmental
problems. The Administrator should assert a major,
leadership role on the Council on Sustainable Development.
The Administrator could create a multi-disciplinary EPA team
to support her work on the Council.
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Target/Action Category B;
EPA SHOULD DEMONSTRATE THE BENEFITS OF POLLUTION PREVENTION TO
ENVIRONMENT. BUDGET & EFFICIENCY BY USING POLLUTION PREVENTION
STRATEGIES IN ALL ITS OWN OPERATIONS
B.2. Reduce EPA's Internal Use of Paper & Paper Products
Two phase, Agency-wide implementation of a number of inter-
related paper conservation actions, building upon many
previous demonstrations (QMS, NDPD, OSW, Regions V & IX,
payroll), in addition to harnessing the findings of OAR's
"Communications QAT" on electronic mail and OARM's
"PaperWISE" office project. This initiative is designed to
accomplish three things: prevent pollution by reducing
EPA's use of paper; reduce EPA's total cost of paper use;
and improve EPA's efficiency in the acquisition, use,
management, storage and transmission of data and
information.
Phase One - a few (perhaps competing) "prototype teams" of
AAships (or geographic locations) will immediately: (1)
improve upon simple activities (e.g., use of centralized
(paper) bulletin boards; recycling, double-sided copying;
Agency-wide materials distributed via electronic media or
via one copy per Section; use of electronic forms [EDI-
electronic document interchange] in lieu of standard
government paper forms; routine use of voice mail;
methodical reduction in the quantity of paper copies made);
and (2) begin working out the details for Agency-wide
application of the more complicated or less developed paper
reduction projects (e.g., electronic mail, electronic
bulletin boards, electronic training, electronic proofing
and processing of memoranda). Phase Two will build on the
previous experiences to implement low-paper procedures
throughout the entire Agency, including changing regulatory
reporting to electronic forms.
B.3. Purchase "Green". P2-Friendly Products and Services
In two phases EPA develops, implements, & measures the
effectiveness of P2 procurement activities within its
facilities & operations by purchasing energy-efficient & P2-
based products & services. In Phase 1: (1) revise EPA
procurement (materials, services, & contracts) policies to
ensure that they are "green"; (2) revise procurement
guidelines & specifications to encourage the purchase of
less toxic chemicals; (3) ensure that major procurement
programs require a P2 analysis prior to implementation; and
(4) reduce procurement needs by establishing improved system
for recycling & reusing office equipment within facilities.
In Phase 2: (1) use revised procurement specifications &
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guidelines to purchase P2-friendly products & services; (2)
form partnerships to support the development of innovative,
P2-friendly equipment or services for government use; (3)
promote use of innovative applications of existing and/or
lower risk materials to avoid developing new or more toxic
items; and (4) ensure that contractors providing services to
EPA utilize P2 fully in their internal operations.
B.4. Reduce Environmental Impact of EPA's Transportation
Activities and of Staff Commuting
Pursuant to the "Alternative Motor Fuels Act of 1988", and
Executive Order #12759) work with other agencies to maximize
the number of alternative-fueled vehicles that are acquired
by the Federal government. Implement this initiative in two
phases. Phase 1, establish a team to develop, perform &
measure success for a model "P2 transportation initiative"
to reduce air pollution & save resources: (1) find means to
encourage more carpooling/vanpooling by EPA employees (even
further subsidizing carpool parking or eliminating any
subsidy to non-carpool vehicles); (2) promote use of mass
transit systems (where available) by offsetting some of
employees' costs; (3) use shuttle vehicles more efficiently;
(4) analyze benefits of CAA Clean Fuels Fleet & Employee
Commuting programs; (5) encourage bicycling & walking to
work; & (6) award a "choice" transit benefit to a "P2
employee-of-the-Month" at each location to provide a highly
visible reminder of the personal benefits of implementing
P2. Phase 2, Agency-wide, broaden & merge with other P2 EPA
initiatives to: (1) evaluate impact of its vehicle
transportation; (2) purchase only "green vehicles"; (3)
authorize EPA employee payment for travel on "green rental
vehicles"; (4) use two-way video-conferencing (inside &
outside EPA) to reduce employee travel; & (5) reduce staff
commuting by making "flexiplace" (work at home) available to
more employees.
B.5. Reduce EPA Use of Energy & Natural Resources in the
Operation of its Facilities
Building on previous OAR & OFFE experiences, implement a
prevention & conservation plan in two phases. In Phase 1,
establish a team (specific Offices/Regions or across EPA) to
develop, implement, & measure effectiveness of P2 building
services conservation activities such as(1) minimizing
energy usage by turning off unused equipment & judiciously
using outside air, drawing shades/blinds, etc.; (2)
selecting an "energy efficiency leader" in every facility to
develop a plan to reduce energy (& other services) & to
motivate others to follow the plan; and (3) in accordance
with Energy Policy Act of 1992, begin implementing an energy
reduction strategy for at least a 20% reduction, compared to
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1985, by year 2000. In Phase 2, broaden building service
conservation activities Agency-wide: (1) use "green lights"
& motion sensors to reduce lighting load when not needed;
(2) reduce water consumption in all activities & install
"gray water" systems where it makes sense; (3) promote "job
sharing" & "flexiplace" to more effectively use office space
& services; (4) use larger, but fewer buildings; (5) build
or lease new facilities designed to reduce usage of energy,
water, & other resources, minimize waste associated with
services, maximize natural lighting, heating, & cooling, use
optimum quantities of insulation, & use efficient motors,
equipment & plumbing.
Target/Action Category C;
EPA SHOULD CHANGE ITS CULTURE AND ORGANIZATION TO MAKE POLLUTION
PREVENTION THE CENTRAL OPERATING PRINCIPLE OF THE ORGANIZATION
AND ITS EMPLOYEES
C.3. Establish a Permanent. Broad-based EPA Team to Gather.
Evaluate, and Develop Ideas for Pollution Prevention for
Action
In the brief time it had, the NPR Pollution Prevention Team
identified several hundred ideas on P2 opportunities &
initiatives. At the same time, dozens of EPA employees
responded to the Administrator's request & submitted
hundreds of other P2 ideas for consideration in the NPR.
Well over 600 ideas were identified during the brief NPR
effort. The Team did not have time to evaluate, let alone
review, many of the ideas Team members identified & most of
those received from fellow EPA employees. There is a wealth
of ideas that should be examined & evaluated. To this end,
establish a followup Team, drawn from across EPA, with a
continuing mandate to review the ideas already collected &
to develop, solicit, & review new P2 ideas. Team reviews,
evaluates, & develops P2 ideas to the point where they can
be handed off to someone inside or outside EPA to determine
whether they can be implemented. Team looks broadly at
ideas & regularly reports to the Senior Management Council
on its activities. Team is centered in an existing unit
(possible Pollution Prevention Staff) & has a small
permanent staff to assist its activities. Participation is
considered a regular part of members' jobs.
C.4. Devote a Significant Portion of EPA's Budget to Developing
Innovative Activities that Promote Pollution Prevention
Allocation of office budgets over time should be judged in
part by past P2 performance and results. In the near term,
this initiative is to encourage innovative P2 activities by
allocating a significant part of the operating budget to
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jump start new P2 activities or to expand small-scale P2
activities that show promise on a larger scale. [This is
not intended to affect existing P2 activities which already
represent a significant portion of EPA's budget.] There are
two approaches. During budget cycle, set P2 funding goal,
e.g. % or otherwise (this is not related to the current 2%
set-aside program). Aas & Ras identify, develop & fund
innovative new P2 projects for next fiscal year. An
alternative approach, in the first two years, take money off
top of agency budget, not from individual programs. This
money would be allocated to new, innovative P2 projects
based on recommendations of EPA Pollution Prevention Board
representing all EPA Offices/Regions. Offices/Regions
cooperatively develop innovative P2 programs & submit
proposals for spending money in next fiscal year on new P2
activities. Administrator allocates funds based on
evaluation of proposals by the Board. Activities can be
multi-media or single medium.
C.5. Reward EPA Employees for Their Efforts and Successes in
Fostering Pollution Prevention Inside and Beyond EPA
Recognize employees who foster P2 inside and beyond EPA
with: (i) monetary awards tied to yearly performance
appraisals based on P2 performance during year; (ii) special
act, time off, on-the-spot awards tied to performance in P2,
(iii) medals or specially named honor awards for P2
performance & initiative inside EPA, & (iv) honor awards for
employees who foster P2 outside of their EPA jobs. Honor
awards given in public ceremonies. A Pollution Prevention
Awards Board established (could be a subgroup of current
Awards Board but with P2 expertise). Specific fund of award
money for P2 awards. After 5 years, P2 achievement would be
recognized as part of EPA's existing awards process, no
longer separate.
C.6. Allow EPA Employees to Take Time to Work or Train in
Pollution Prevention Outside of Their Normal Duties
Managers cannot conveniently "backfill" an employee seeking
leave from regular duties. An employee may seek time off
(or away from regular duties) to pursue professional
development, train, or try new professional outlets. In the
P2 area, employees may want time away to train in P2, to
work on P2 task forces, to accept details to P2 jobs
elsewhere in EPA, to do P2 work at other institutions under
Intergovernmental Personnel Act assignments, & to do
research or participate in technology development activities
in the P2 area, among other things. This can only work when
a manager is willing to let an employee go. Given the
severe current & future limits on EPA resources & growing
mandates, this is not often done. EPA should address this
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issue by creating an FTE pool of 10-15 unfilled
Administratively Determined (AD) positions. These FTEs
would be available to allow managers to backfill an employee
who is away from regular duties pursuing P2 opportunities.
In future years, a FTE set-aside program would be initiated
Agency-wide to supplement the AD pool, if need warrants. A
high level manager would control the pool & would make
decisions to allocate FTE for P2 backfill purposes.
Target/Action Category D;
EPA SHOULD INTEGRATE POLLUTION PREVENTION INTO ALL PROGRAMS
INCLUDING REGULATION DEVELOPMENT. PERMITTING OPERATIONS.
COMPLIANCE ACTIVITIES. AND ENFORCEMENT
D.5. Utilize Management Tools to Ensure That EPA Promotes
Pollution Prevention in Every Regulation. Guidance Document.
Policy Decision, and Permit Action
The Administrator has already issued a number of questions
that must be addressed when regulations or policies are sent
to her for approval. Build on the Administrator's list of
questions at every level in EPA to ensure that every
regulation, policy, guidance document, & permit action
promotes consideration of P2 in every regulation, guidance
document, & policy. Ask questions at every management level
in EPA early in the development process to ensure that P2 is
considered while there is still time to develop it in the
action. Develop a list of generic P2 questions that need to
be answered at every level of EPA before a decision is made
that might include P2.
Target/Action Category E:
EPA SHOULD ENHANCE PARTNERSHIPS WITH STATE. LOCAL. AND TRIBAL
GOVERNMENTS TO IMPLEMENT POLLUTION PREVENTION
E.8. Identify and Overcome Federal Barriers to Integrating
Pollution Prevention into State Regulatory Activities
EPA establishes a Task Force with the responsibility to seek
out instances where claims are made of federal regulatory or
policy barriers to the adoption of P2 activities by
state/local governments. Task Force includes
representatives of EPA & state & local governments. EPA
staff of the Task Force work to remove barriers by working
with the EPA Program Offices & Office of General Counsel.
All EPA personnel who deal directly with states can provide
input to Task Force. Change EPA regulation/policy barriers.
Take action to initiate legislative changes.
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E.9. Help Coordinate State Programs and Facilitate the Sharing of
Pollution Prevention Information
Make EPA's relationship with the states a full-fledged P2
partnership. Support organization and activities of the
National Roundtable of State Pollution Prevention Programs
(the Roundtable) in a manner similar to relationship with
other state coordinating organizations such as ASIWPCA and
ASTSWMO. Continue ongoing effort to delegate operation of
the Pollution Prevention Information Clearinghouse (PPIC) to
the Roundtable. Encourage & fund support of Regional
Pollution Prevention Resource Centers (similar to the one in
Region IV, Great Lakes Technical Resource Library, NEWMOA,
and the Pacific Northwest P2 Research Center) to help bring
together P2 information & make it accessible to all state,
local, & tribal governments and EPA. As in Region IX, bring
EPA Regional libraries & information centers into the
national P2 information network, and empower existing
library system to be an agent for disseminating P2
information. Ensure delivery mechanism for assistance is
easily accessible. Provide adequate training of EPA, state,
local, & tribal personnel.
Target/Action Category F;
EPA SHOULD TAKE AN ECONOMIC SECTOR-BASED APPROACH TO THE DEVELOP-
MENT OF ENVIRONMENTAL POLICIES AND PROGRAMS. WITH POLLUTION PRE-
VENTION AS A KEY MEANS OF ACHIEVING COST-EFFECTIVE ENVIRONMENTAL
PROTECTION
F.4. Work With (and Leverage the Resources and Expertise of)
Public and Private Sector Entities in the Development and
Implementation of Sector and Sub-sector Strategies.
Establish partnerships with other Federal departments and
agencies (including departments focusing on economic
recovery and innovation) and the private sector to pursue
sector or sub-sector strategies. Link with EPA working
groups (see Initiative F.2). Develop demonstration projects
that test sector-based policies (see Initiative F.I. and the
Public/Private Partnerships Category of this Report).
Examples of Federal network partners include the President's
Council on Sustainable Development; the Departments of
Commerce, Energy, Agriculture, and Transportation; the
Office of Technology Assessment; the U.S. Trade
Representative; and the White House Office of Environmental
Policy. Private sector network partners include NGOs,
regions and states, trade associations, individual industry
and business representatives. Contacts should occur at both
EPA management and staff level. Connect with groups that
are focused on economic growth, not just groups focused on
environmental issues.
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Target/Action Category G;
EPA SHOULD CULTIVATE PUBLIC/PRIVATE PARTNERSHIPS TO FOSTER
POLLUTION PREVENTION
G. 3. Assist Green Label Efforts
Several private groups, foreign countries and States are
developing "green labeling" programs that recognize consumer
products that are preferable from an environmental
perspective. EPA has been asked by one such group (Green
Seal) to help it identify the consumer product categories of
greatest environmental impact. In carrying through the
theme of developing new partnerships, EPA would choose a
community having strong public interest activity. EPA would
then convene a working group of local businesses, public
interest groups and government to target products of
greatest concern. Choice would be informed by a multi-media
work group participating in the discussions. A continuing
work group made up of EPA, government, industry and
community groups would develop information and labeling for
the products. In follow up to the labelling effort, the
group would evaluate how consumers react to different forms
of environmental labeling and advertising. This pilot
effort would assist other labeling entities to set better
priorities and deliver more effective messages.
G.4. Assist Small Business in Finding Incentives for Pollution
Prevention
Effecting behavior change in pollution prevention depends
upon providing incentives for companies to search out and
apply strategies for improvement. The most powerful
motivator is demonstrating that the improvement would be in
the best interest of the company and would contribute to the
profitability and marketability of the company. Three areas
provide fruitful avenues to develop projects in conjunction
with small businesses: cost accounting, financing and
insurance. This pilot project would involve representatives
from the three areas in a partnership with a selected
industry to develop guidelines and information products
tailored to that industry which would enable accountants to
properly identify the cost savings from pollution
prevention; financial institutions to provide loans for
pollution prevention projects, and guidelines for insurance
companies to take pollution prevention actions into account
in liability insurance premiums. By forming new
partnerships through work groups made up of small
businesses, associations, financial institutions and EPA a
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synergism will be created to develop incentives to promote
pollution prevention activities in small business. The
pilot projects can build upon existing projects that work
through industry partnerships.
G.5. Develop Clean Technology for Small Business
Joint research conducted with the National labs, the private
sector, universities and others that targets on the needs of
small businesses on an industry-wide basis. Small
businesses have fewer technical and financial resources
available to them as individual businesses to address long-
term, "breakthrough" research needs. EPA can perform a
leadership role in helping to define what constitutes "clean
technology" so as to ensure multi-media risk impacts and
pollution prevention considerations remain in the forefront
of targeted technology development. EPA can catalyze
public/private research partnerships with specific
industries that are characterized by lots of small
businesses to fill the need for cleaner technologies and
processes. Industrial partners, however, would also include
suppliers, clients, and large companies in the same
industry. In addition, EPA could play a role in ensuring
the diffusion of clean technology to small business
partners, as well as, ensuring incentives to employ it.
G.6. Undertake Voluntary Pilot Projects for Multi-media Facility-
wide Assessments of Environmental Releases and Develop
Options and Strategies to Reduce These Releases Through
Pollution Prevention
EPA and Amoco Corp. conducted a two year voluntary project
to assess releases to all media from a petroleum refinery
and identified P2 options to reduce these releases. The
project found that prevention-based options were generally
more cost-effective than treatment and disposal options.
This project generated information on releases that we did
not know about and identified options in a much shorter time
than it usually takes EPA for developing regulations. EPA
should pilot test this approach in several different
industrial facilities.
Target/Action Category H:
EPA SHOULD TAKE A LEADERSHIP ROLE IN PROVIDING EDUCATION AND
INFORMATION ABOUT POLLUTION PREVENTION
H.4. Educate All Levels of Governments About Pollution Prevention
Training of EPA staff is one of the essential building
blocks needed before EPA can change its work ethic. A
minimum of one day training in Pollution Prevention for
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every EPA employee and a minimum of one week for those
employees who work directly and actively in P2 or in other
activities that directly relate to emission reductions or
controls. Convene an EPA P2 Training Work Group to develop
minimum training standards and a draft EPA Executive Order
on EPA training. In the interim, make the current EPA
Institute's P2 orientation course available to the entire
staff. Affected staff could opt out of such training by
certifying that they previously received equivalent training
or work experience.
Similarly, pollution prevention education in the federal
government and the state/local levels is essential if one
desires significant changes in their work ethic to occur.
Partnerships will be forged between state and local
governments, other federal agencies, and EPA to launch
educational programs to advance P2 efforts. Efforts will be
made by EPA to help educate other Federal agencies about P2.
Programs would focus on educating state, local and federal
employees (including legislative bodies) in P2 activities.
With the help of EPA employees trained in P2, state/local
governments and other federal agencies would be able to
implement awareness programs in the government workplace.
Target/Action Category I:
EXECUTIVE BRANCH SHOULD INTEGRATE POLLUTION PREVENTION INTO ITS
PROCUREMENT AND DEVELOP FEDERAL AGENCY RELATIONSHIPS TO PROMOTE
POLLUTION PREVENTION NATIONWIDE
1.3. Direct the Federal Budget Toward Pollution Prevention
Direct expenditures in entire Federal Budget toward P2
purposes. In the interim, initiate a variety of Set-Aside
Programs as an immediate bridge. Three examples: (1)
Support innovation programs at Department of Energy to
efficiently target, promote and encourage innovative P2
technologies using existing DOE infrastructure. Build on
under-funded DOE capabilities and "steer" DOE in the
direction of promoting environmental, P2 technologies, in
addition to their current priority based on energy savings
alone. Provides environmental sorting criteria to DOE to
catch environmentally worthy technologies that would
otherwise slip through the DOE sorting screens. (2) U.S.
Information Agency (USIA) funds international demonstrations
of P2 techniques and technologies. USIA empowered to use
its informational infrastructure to advance P2 worldwide.
(3) Promote Industrial Competitiveness through Efficiency
to further demonstrate that P2 and saving energy can be
highly profitable; expand NICE Grant Program through more
DOE and Commerce funding.
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1.4. Reduce Significantly Quantity and Toxicity of Wastes
Executive Branch Produces
Significantly reduce quantity & toxicity of pollutants
released & wastes generated by federal facilities & on
public lands; make P2 approach of first choice in all
environmental management decisions. Expand on & adapt
experiences acquired during individual department
initiatives, such asDOD's announcement in August, 1992
that it had reduced its hazardous waste disposal by 54%
(including a 85% reduction in the waste generated at its
industrial-type facilities); & Tidewater Interagency P2
Program, started in 1991. Federal facilities achieve at
least items specified in Interim Federal Facility P2
Strategy, including(1) 50% reduction in releases of 17
priority chemicals at all government owned/contractor
operated (GOCO) facilities by end of 1995; & by end of 1997,
non-GOCO facilities reduce these chemicals by 33%; (2)
report all releases consistent with TRI requirements,
starting with beginning of calendar 1993; & (3) by end of
1992, adopt an energy efficiency implementation plan for
each agency to achieve goals & requirements set forth in
Executive Order #12759 & Energy Policy Act of 1992.
1.5. Use All Available Tools to Ensure That Executive Branch
Programs. Policies, and Regulations Incorporate Pollution
Prevention Concepts
Utilize all available tools, including the National
Environmental Policy Act (NEPA), to ensure that programs,
policies, and regulations of federal agencies incorporate
pollution prevention concepts and approaches; and provide
appropriate incentives for the private sector to undertake
such practices. Achieve the specific targets enumerated in
the Interim Federal Facility P2 Strategy. Each Agency looks
for and implements P2 opportunities, either alone, or as
part of federal government-wide initiatives, such as
reducing small airborne particles (PM-10) by removing crop
land from cultivation; working to develop environmental
labeling and other activities to facilitate "green
marketing"; early consideration of prevention in all major
activities affected by the NEPA; and in reviewing curriculum
items directed at students in grades K-12 and in college.
Furthermore, EPA performs at least 50 multi-media
enforcement inspections of federal facilities, and
incorporates P2 into at least 25% of its enforcement case
resolutions with the federal facility to sensitize the
agencies to P2 opportunities.
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PP 59
1.6. Foster Development and Transfer of Pollution Prevention
Technologies by Executive Branch to Private Sector
Develop technical solutions & foster technology transfer
among Federal agencies & between the public & private
sectors to address P2 needs & to enhance United States
competitiveness. The primary theme contained in the Interim
Federal Government P2 Strategy is for various agencies to
work cooperatively to foster development & dissemination of
P2 approaches to industry so that they may reduce costs of
compliance, and/or to develop marketable innovative
technology to the rest of the world. Government will
achieve at least the targets contained in the Interim
Strategy. Continued development of methods to assess the
effectiveness of P2 approaches in reducing emissions and in
demonstrating compliance with environmental regulations; in
FY 1993 expansion of the breadth and effectiveness of EPA's
Pollution Prevention Information Exchange System (PIES)
database; in FY 1993 form an interagency committee to
identify emerging P2 technologies that can be demonstrated
at Federal facilities; development and scheduling new P2
technology transfer workshops, particularly "train-the-
trainer" ones; and demonstrations of new P2 technology or
new applications.
1.7. Develop National Pollution Prevention R&D Agenda
EPA should lead the development of a national R&D agenda for
pollution prevention to(1) promote a longer-term R&D
perspective, (2) bring into play public and private sector
resources, (3) coordinate Federal P2 R&D efforts, (4) lead
to more effective use of national capabilities to do P2 R&D,
(5) leverage EPA and Executive Branch R&D resources, and (6)
lead to more cooperative public/private R&D efforts.
Federal Coordinating Council on Science, Engineering, and
Technology (FCCSET) sets up a separate working group,
chaired by EPA, to develop a national R&D agenda for the
public and private sectors on P2. If it is not possible to
have a FCCSET working group, EPA could take the initiative
to create an interagency P2 R&D council, chaired by EPA.
1.8. Develop an Executive Branch Technology Scanning Initiative
to Promote the Identification of Pollution Prevention
Technology Developments
Link files of Department of Commerce (relating to industrial
and commercial data, including Patent and Trademark Office),
Office of Environmental Statistics, EPA program offices,
Department of Energy, other Federal agencies, and the White
House Offices of Science and Technology Policy and
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PP 60
Environmental Policy, for the purpose of fostering
integration of technology with pollution prevention
opportunities.
1.9. Establish a Revolving Fund for Energy Efficiency and
Community Heating and Cooling Systems
Community heating and cooling systems are an integrated
approach to using energy and P2. Waste heat from
fossil-electric power plants is captured for heating or
cooling buildings in urban centers, rather than being
released to the atmosphere or the aquasphere. For example,
three power plants in Washington, D.C. make electricity for
federal buildings and use the waste thermal energy to
simultaneously heat or cool public buildings. Other cities
in the U.S. are finding that Community Heating and Cooling
Systems provide an economic stimulus to the center city
(Newark, NJ). In Sweden and the Baltic Countries, waste
heat is routinely used at sites up to 30 miles away from the
generating facility. (1) Develop a Revolving Fund (with
DOE, HUD, and Commerce, others) to temporarily provide loans
for community heating and cooling systems to prevent
pollution associated with making electricity; to recapture
half of the waste thermal energy released by
fossil-steam-electric power plants; to overcome high
capital costs of initiating projects; revolving fund of
$500 million to be repaid via shared savings. Modeled on
EPA's revolving fund for construction grants, with
improvements. (2) Expanded (or another) Revolving Fund
(with DOE and Commerce, NIST) to finance capital-intensive
investments in energy efficiency. This funds projects with
pay-back times longer than the Green Programs, but with
major prevention benefits.
I.10 Reduce Use of Paper & Paper Products by Federal Agencies
Builds on experiences gained at EPA other agencies and
industry. In addition, it supports those agencies by
providing electronic media "printing" of all official
documents that have been printed in hard copy by GPO or NTIS
(e.g., federal laws, regulations, and policies, as well as
federal reports and manuals). This initiative is designed
to accomplish three things: prevent pollution by reducing
the Government's use of paper; reduce the Government's total
cost of paper usage; and improve the Government's efficiency
in the acquisition, use, management, storage and
transmission of data and information. Since the Government
is one of the largest buyers and users of paper and paper
products, it has the potential to substantially affect the
nation's paper using habits.
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This initiative will include easy and/or inexpensive
activities, such as: centralized paper bulletin boards;
recycling, double-sided copying; agency-wide materials
distribution via electronic media or via one hard copy per
individual office or building floor; use of electronic forms
[EDI-electronic document interchange] in lieu of standard
government paper forms; routine use of voice mail; and
methodical reduction in the quantity of paper copies made.
It will also include complicated and/or expensive
activities, such as: government-wide electronic printing and
electronic mail, electronic bulletin boards, electronic
training, electronic proofing and processing of memoranda,
and changing regulatory reporting to electronic forms.
I.11 Develop Four-phase Metro Initiative for Washington D.C. Area
Promote transportation P2 measures for all federal agencies
in Washington D.C. First component is full participation in
Metro's MetroPass program that will help "level the field"
by offsetting a current bias toward automobile commuting via
parking subsidies. A second component is the Metro Green
Station where EPA and other agencies work with Metro to
suggest additional energy-efficiency measures that Metro
might consider as a means of reducing operating costs,
particularly utilizing PEPCO's demand-side management
programs and the support of the D.C. Public Service
Commission. Targets include lighting, motors for railcars,
ventilating fans, escalators and elevators. The P2 benefits
of the retrofits are quantified and become the basis for a
third component, the "Metro as the Green Alternative"
advertising campaign that publicly celebrates P2 and energy
savings, introduces a broad public (including Hill
policymakers) to P2 technologies and approaches, and induces
additional ridership on Metro as a "green" commuting
alternative. A fourth component, Innovative Technologies,
might occur under a MOU with Metro. In this phase, EPA and
other agencies can work with Metro as a testbed for new and
emerging transportation technologies, particularly
load-controllers and innovative proposals for propulsion
systems for Metro buses.
Target/Action Category J;
GOVERNMENT SHOULD USE MARKET INCENTIVES. INTERNALIZING THE
EXTERNALITIES. AND FISCAL POLICIES TO PROMOTE POLLUTION
PREVENTION
J.3. Modify Existing Federal Financial Assistance Programs (Loans
and Grants) to Promote Pollution Prevention Investments
The federal government can encourage and ultimately require
public and private organizations to consider pollution
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prevention in lending practices. Existing federal loan and
grant fund programs (e.g., small business assistance) should
be revised to fund pollution prevention investments (e.g.,
by designating specific funds for pollution prevention,
offering a more favorable interest rate for pollution
prevention, or requiring a pollution prevention analysis
before approving certain loans/grants). Success is not
required for funding.
J.4. Develop a Green GNP
Develop a green GNP that incorporates: the value of
degrading the quality of the environment as a result of
economic activity; the depletion of natural resources
extracted for sale; and "defensive " expenditures to prevent
or correct environmental damage. The first would introduce
into the national accounts measurements associated with
changes in the environment. The second and third items
would involve exchange for money and are therefore already
covered in the national accounts, but would be treated
differently. The United Nations is currently developing a
new standard for national accounts that can be used as a
model for the development of a U.S. Green GNP.
J.5. Establish Minimum Global Environmental Standards for the
Manufacturing of Goods.
Given the global nature of environmental problems, U.S.
efforts alone to establish environmental standards for
industry are not adequate if companies can simply move their
operations to another country in order to avoid the costs
often associated with complying with U.S. environmental
standards. Companies that remain in the U.S. and
manufacture their products in compliance with U.S.
environmental standards can be at a competitive disadvantage
if they must compete with imported products that were
manufactured at a lower cost as a result of less stringent
or no environmental standards in the other country. The
White House should work to create minimum global
environmental standards. Companies that manufacture goods
in noncompliance with these global standards would be
subject to an import tax that would increase the price of
the goods. The level of the tax could be based on the
average per product cost of environmental compliance costs
experienced by industry. Could also give affirmative
benefit to companies doing business in U.S. who maintain
high environmental standards in operations abroad.
J.6. Promote Total Cost Accounting Principles
Most companies treat environmental costs as "overhead
expenses" and thus do not fairly attribute environmental
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expenditures to the process and material choices they have
made. This tends to understate the value of pollution
prevention. Total cost accounting, which tries to link
environmental costs with the production decisions that cause
these costs, is a means of correcting his problem. Under
this initiative EPA would work with outside groups to
standardize and disseminate total cost accounting
principles. EPA work could include the development of
guidelines for total cost accounting and techniques for
allocating costs to particular processes or materials.
EPA's Design for the Environment Program currently has an
excellent project on Accounting and Capital Budgeting for
Pollution Prevention that should be continued and broadened,
to encourage the spread of the principles to the general
accounting and business communities.
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REFERENCES
References relating to many of the Initiatives in the Report are
available upon request from the Pollution Prevention Team.
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REPORT OF THE
POSITION CLASSIFICATION
TEAM
NATIONAL
PERFORMANCE
REVIEW
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PC
POSITION CLASSIFICATION
Executive Summary
Position Classification is at the heart of the employment
process. The decisions made jointly by the selecting manager
and the human resources (HR) specialist dictate the salary
level of the job and the selection factors that will be used
to judge the qualifications of the applicants. The current
system, with its hundreds of occupational titles and arcane
grade level differentiations, promotes a confrontational,
rather than collaborative relationship between the HR
specialist and program managers. This initiative seeks to
streamline and simplify the process of writing a position
description (p.d.) so that managers and HR specialists can
focus on other areas such as EEC-/Affirmative Action
responsibilities, recruitment strategies, and
staff/organizational development.
Vision
We aim to implement a simplified, streamlined approach to
position description development that fosters a collaborative
relationship between HR specialists and their client managers.
Target/Action Category
Reinvention Idea #1 - Simplify Position Descriptions
Simplify and streamline position descriptions for all
agency positions.
A. Reduce position descriptions to their most
simplified form while maintaining their legal
sufficiency.
1. Three basic position descriptions to cover all
Agency positions one for
professional/technical positions, one for para-
professional positions, and one for supervisors
and managers.
a. generic descriptions pre-developed at each
applicable grade level
b. selecting managers can choose to tailor
position descriptions with position
specifics if desired (not necessary,
however)
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PC 2
c. information will "flow" into what is
needed to develop the vacancy announcement
and qualifications criteria.
2. Implementation Time Line - Testing is already
underway. Headquarters test sites will be
chosen by August 31, 1993 with a decision on
implementation due about January, 1994.
3. Barriers - The primary barrier is the
willingness of the program offices to accept
their share of the responsibility. Senior
level support of this initiative is imperative.
4. Benefits - The primary benefit will be a more
positive relationship with
managers/supervisors. Another benefit is the
time savings.
5. Success measurement - Success will be measured
by the length of time needed to classify a
position. Customer satisfaction with the
overall HR program will be measured with
customer focus groups.
References
Additional information can be obtained by contacting
Michael Ha'mlin at (202) 260-3266.
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PC
POSITION CLASSIFICATION TEAM MEMBERS
Michael Hamlin, Team Leader
Francine Butler
Sharon Furrow
Rita Jones
Helga Butler
Roz Simms
Ken Henderson
John O'Brien
Chuck Smith
Ken Kurtz
Leigh Diggs
Robert Pavlik
Nancy Hunt
Randy Brady
Sandy Bowman
Tom Davison
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REPORT OF THE
QUALITYMANAGEMENT
TEAM
NATIONAL
PERFORMANCE
REVIEW
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QM
EPA's Quality Management Team
Team Leader: Mike Ward, Region 10
Team Members:
George Alapas ORD
Nancy Allinson OSWER
John Alter OW
Jim Baca OARM
Helga Butler OA
Maureen Delaney OAR
Eudora Edwards OGC
Bob Heiss OE
Pam Herman OPPE
Tom Hooven OPPTS
Lila Koroma Region 4
Tom Maloney DIG
Wayne Naylor Region 3
Pam Shenk Region 8
Alan Sommerman Region 2
Becky Tudisco Region 9
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QM 2
EPA NATIONAL PERFORMANCE REVIEW
QUALITY MANAGEMENT TEAM REPORT
Executive Summary
Vision
EPA employees serve their internal and external customers
and those the Agency affects with timely and responsible
decisions and efficient, effective, and ethical
operations.
Background
EPA was created in 1970 to take a holistic approach to
the complex task of environmental protection. Although EPA's
employees share a commitment to the goals of preserving
natural systems and protecting public health and welfare, many
external and internal influences have contributed to
continuing divisions along media, functional, and geographic
lines within the Agency.
EPA has achieved impressive environmental gains and is
now the premier environmental organization in the world.
However, we cannot afford to be content with the status quo.
The context of environmental protection is changing.
Governments, private-sector institutions, interest groups, and
the general public all recognize that fundamental changes are
needed in the way we work and relate to each other. We
believe EPA can serve the American people better and
accomplish more with its resources if we draw upon our
employees, our customers and affected groups to:
develop and articulate a clear vision of what EPA should
be doing;
commit to a strategy describing how EPA should carry out
its mission, incorporating the Administrator's priorities
of leadership on environmental issues; partnerships;
sustainable development; pollution prevention; sound
science; integrated environmental management;
environmental justice; and management of human and
financial resources; and
adopt a unifying, disciplined management philosophy
following these widely-accepted quality principles:
inclusion of and respect for people as we exercise
leadership; a focus on the customer in forming
partnerships; and working smarter through fact-based
continuous improvement.
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QM 3
The management approach known as "Quality Management" is based
on organizations having a clear vision, a comprehensive
strategy, and an integrated management philosophy well-
understood throughout the organization. We believe that
Quality Management is EPA's best hope for achieving its
environmental mission. An open, inclusive, customer-focused
Quality Management philosophy is EPA's key to sorting out its
complex and conflicting priorities and making best use of
scarce resources.
Much more remains to be done to achieve our vision of
Quality Management. To continue implementing Quality, we
recommend that the Agency focus on three major categories of
action: Leadership; Partnership and Working Smarter.
Our report recommends Initiatives within each of these
areas (with a brief "desired state" for each). We identify
Barriers to change; a number of Suggested Actions; Measures of
Success; and Costs and Benefits. Our suggestions include:
Rotate executives within HQ and within each Region
Conduct periodic, comprehensive Organizational Culture
surveys of EPA Employees
Promote a positive climate for risk-taking and
innovation; celebrate "failures" that were learning
opportunities
Pilot self-directed Work Teams
Build and improve on innovative outreach efforts to
children, such as Partners in Education
Create resource incentives for organizations to spend
more wisely, reduce expenditures, or enhance revenues
Experiment with "flattening" organizations, by converting
some managerial and supervisory positions to non-
supervisory technical experts
Expand use of dual ladder career tracks through the SES-
level to reduce the financial incentive for entering
management
AAs and RAs serve as Quality Consultants to each other
Expand the "informal advisor" role of experts within the
Office of the Inspector General and other EPA compliance
monitoring organizations to help prevent problems
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QM 4
All of the teams' suggested actions build on the Agency's
past efforts to implement Quality. They reflect the
collective creativity of our team and incorporate many of the
suggestions and comments which EPA employees provided to the
NPR staff.
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QM
EPA NATIONAL PERFORMANCE REVIEW
QUALITY MANAGEMENT TEAM REPORT
Vision
EPA employees serve their internal and external
customers and those the Agency affects with timely
and responsible decisions and efficient, effective,
and ethical operations.
Background
EPA was created in 1970 to take a holistic approach to
the complex task of environmental protection. Although the
great majority of people who work in EPA share a common
commitment to the goals of preserving natural systems and
protecting public health and welfare, many external and
internal influences have contributed to continuing divisions
along media, functional and geographic lines within the
Agency.
EPA has achieved impressive environmental gains and is
now the premier environmental organization in the world.
However, we cannot afford to be content with the status quo.
The context of environmental protection is changing.
Governmental units, private-sector institutions, interest
groups, and the general public all recognize that fundamental
changes are needed in the way we work and relate to each
other. We believe EPA can serve the American people better
and accomplish more with its resources if we draw upon our
employees, our customers and affected groups to:
o develop and articulate a clear vision of what EPA
should be doing;
o commit to a strategy describing how EPA should carry
out its mission, incorporating the Administrator's
priorities of leadership on environmental issues;
partnerships; sustainable development; pollution
prevention; sound science; integrated environmental
management; environmental justice; and management of
human and financial resources; and
o adopt a unifying, disciplined management philosophy
following these widely-accepted quality principles:
inclusion of and respect for people as we exercise
leadership; a focus on the customer in forming
partnerships; and working smarter through fact-based
continuous improvement.
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QM 6
The management approach known as "Quality Management" is
based on organizations having a clear vision, a comprehensive
strategy, and an integrated management philosophy well-
understood throughout the organization. We believe that
Quality Management is EPA's best hope for achieving its
environmental mission. An open, inclusive, customer-focused
Quality Management philosophy is EPA's key to sorting out its
complex and conflicting priorities and making best use of
scarce resources.
Current State
EPA IS AT A CROSSROADS. Now is the time for EPA's
leaders to take an honest look at the values reflected in the
Agency's systems, processes, and structures. Those that work
as intended should be strengthened and promoted, while those
that do not should be changed or eliminated. Quality
Management can be used to facilitate these assessments. The
Agency has already made a significant investment in Quality
Management training, and many of the principles have taken
root and produced genuine successes throughout EPA.
Yet much more remains to be done to achieve our vision of
Quality Management. To continue to implement Quality, we
recommend that the Agency focus on three major categories of
action: Leadership; Partnership and Working Smarter.
Our report recommends Initiatives within each of the
three major categories. We also identify Barriers to bringing
about the changes desired; a number of Suggested Actions (with
"whos" and "whens" indicated), Measures of Success, and our
assessment of Costs and Benefits.
The Quality Management Team fully recognizes that these
sets of Suggested Actions represent an extensive agenda.
However, we want to provide the Administrator, the EPA Senior
Leadership Council, and EPA's National Performance Review team
with a broad range of potential improvements. Some of the
ideas build on past and current efforts to implement Quality
Management, while others are pilot-test actions. They reflect
the collective creativity of our team, and they also
incorporate many of the suggestions which EPA employees
provided to EPA's National Performance Review (NPR) staff. We
look forward to the recommendations of the other NPR teams for
their perspectives on quality management.
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QM
LEADERSHIP
World-class quality organizations don't just happenthey
are created by effective leaders. These individuals
communicate well, take planned risks willingly, and work with
and through others to achieve the organization's mission.
True leaders are visionaries. And they share their vision of
what can be, model their values and create working
environments that encourage and enable their followers to do
their best.
Leaders recognize that when they empower others, they
themselves become more effective. Because EPA is at a
crossroads, we need effective leaders to keep the organization
on course to achieve our important mission. Leadership is
"steering not rowing."
Initiative 1. Reinforce Quality
EPA's leaders reinforce quality principlesinclusion of
and respect for people and a focus on our customersas
the way we do business in our efforts to reinvent
government.
Barriers
Senior managers fear loss of control
Managers can "stone-wall"
"Fad" mentality
Payoff too far down the road
Suggested Actions
What Who When
Rotate Executives Extensively
within HQ and Within Each Region A/SLC 4/94
Develop/use External Customer
Surveys OA/HQ/Reg 11/93
Conduct Periodic, Comprehensive
Organizational Culture Surveys
of all Employees (as done in
NASA and other departments) OA/OARM FY 94
Conduct Employee Evaluation of
Supervisors AAs/RAs Vols FY 94
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QM
8
Require SLC Members to Teach
Quality and Ensure Implementation
of Quality
Promote EPA-Customer Executive
Interchanges (Targeted IPAs,
Swaps, Rotations)
Use Federal Quality Institute
Criteria to Assess EPA's Progress
in Quality, Beginning with
Leadership Criteria
Hold "Executive Brownbag" Lunches
with Employees
Arrange Onsite/Offsite Visits with
Quality Organizations
SLC
HQ/Reg Vols
SLC
SLC
A/RAs
10/93
10/93
1/94
10/93
4/94
Costs; External survey would cost approximately $150k;
$100k for the Organizational Culture Survey.
Employee Evaluation of Supervisors would cost
roughly $7-10k for a pilot of 100 employees.
Travel, related costs for IPAs; morale implications
involved in rotating SESers.
Benefits: Continuation of quality management progress and
solid top management commitment will put EPA on the
track toward becoming a world-class quality Agency.
Interchanges will expose executives to external
customer perspectives. SES rotations will induce
change by forcing "new kids on the block" to focus
on customer needs in their new assignments. This
will also encourage a broader perspective and
thinking "outside the box."
Measures; Suggest established Government or private-sector
quality measures (President's Quality Criteria or
Malcolm Baldrige Award criteria). Internal/external
surveys and employee evaluations of supervisors will
establish baselines and measure progress over time.
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QM 9
Initiative 2. Demonstrate Quality Management
Management at all levels articulates a vision and
direction and demonstrates, expects, and rewards Quality
behaviors.
Barriers
Low trust level
Lack of managerial skills
Managers feel that they have to know all and do all
Rewards are based on individual achievements, rather than
team successes
Not marketing genuine mission-related successes
Suggested Actions
What Who When
Revitalize, Streamline, Monitor
Employee Suggestion Process
Address Backlog OHRM/Reg HROs 6/94
Pilot-test the Use of a Customer
Needs Checklist for Regulations
or Policies to Record Input,
Incorporation by EPA OPPE/2AAs/2RAs 6/94
SES Award Winners ($10k, $20k)
Showcase Quality Principles
and How They Use Them SES Awardees FY 94
Expand Use of Employee Shadow
Assignments Employee/Exec
Volunteers 10/93
Monitor Managerial Individual
Development Plans (IDPs),
Fund/Enforce 40-hour Requirement
for Management Skills Training OARM/Mgrs. 4/94
Costs; No additional training costs, since this should be
part of existing requirement for 40 hours of
training for Managers and Supervisors. The employee
suggestion program and awards could be conducted
within existing resource levels.
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QM 10
Benefits; Employees, customers, affected groups, potential
partners will believe EPA is serious when managers
at all levels practice quality techniques and model
behaviors.
Measures; Regular, random spotchecks stop employees and ask
about quality principles and Agency priorities.
Observe meetings at any level for use of quality
management approaches. Monitor IDPs, training
records. Spot-check performance agreements for
managers and supervisors to make sure quality is
expected and evaluated.
PARTNERSHIP
EPA alone cannot protect the environment. We need to
share this complex mission with our Federal, State, and local
counter-parts. As in any partnership, EPA and its partner(s)
need to determine what is required to achieve our common goals
and how each partner can contribute to the effort. Successful
partnerships depend on open, honest communication, trust, and
respect.
Initiative 1. Make Decentralization Work
EPA implements delegated authority in its daily
operations so that, to the extent possible,
responsibility for making improvements is exercised by
those who actually do the work and/or deal directly with
customers and affected groups. Externally, this means
working with States, Tribes, other Federal Agencies,
local governments, affected interest groups, and private
industry. EPA Regional and Program Offices provide
guidance, operate consistently with delegations of
authority and responsibility, and "let go.11
Barriers
EPA's interest in maintaining power and authority
Congressional oversight and reporting requirements
Concern about State and Local capacity/capabilities
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QM 11
Suggested Actions
What Who
Pilot a Direct EPA Region/State
Relationship with Minimal HQ
Involvement EPA Reg/State FY 94
Pilot-test a Direct EPA HQ/State
Relationship EPA HQ/State FY 94
Expand Collaborative Planning
with Customers Pattern after
State/EPA Agreement Process AAs/RAs FY 94
Costs: Conduct these activities within existing resource
levels.
Benefits: Reduces role/responsibility confusion, duplication
of effort, waste, resentments. Timely decisions and
actions benefit ultimate customers.
Measures; Survey of external customers demonstrates successes.
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QM 12
Initiative 2. Empower Employees
Managers invest in giving employees the skills and tools
to do their best, encourage them to be innovative and
take planned risks without fear, and let the employees do
the work. Respect and trust levels rise. Employees have
ownership and take pride in the Agency's work.
Barriers
Ineffective people skills
Poor internal communications
Hierarchical structure, systems
Incomplete understanding of "empowerment"
Suggested Actions
What Who When
Promote Positive Climate for
Risk-Taking and Innovation
Celebrate Learning Agency Vols 4/94
Conduct Agency-wide Work Life
Survey OA/QAG/QCs 1/94
Create "AA/RA-For-A-Day"
Opportunities for Staff
(Swap Jobs) 2AAs/2RAs 10/93
Pilot Self-Directed Work
Team Concept at Section
or Branch Level 2Reg/2HQ Vols FY 94
Pilot "Match-Time" for Wellness
Activities (Employee and EPA
Match 2-3 Hours) OW/Reg 4 FY 94
Provide Targeted Training in
"Success Skills" (e.g., Customer
Service; Facilitation; Conflict
Resolution; Negotiation; Teamwork;
Communications; Coaching and
Counseling) OARM/Regions 1/94
Costs; See above for survey costs. Training from current
resources. Administrative leave for wellness
activities.
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QM 13
Benefits: Improved morale. Faster response to customer needs,
higher guality products with less rework, cost-
savings. Supports managers' focus on leadership,
planning, etc. Supervisors able to do coaching,
counseling, planning, career assistance. Job swaps
can be "breakthrough" experiences for staff,
executives.
Measures: Agency-wide employee survey provides baseline and
progress measurement. Monitor Employee Counseling
and Assistance Program, grievances/complaints, exit
interviews, employee suggestions. Use of short-term
sick leave declines.
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QM 14
Initiative 3. Involve Others
EPA seeks input early and often from those who use its
products and services or are affected by its decisions.
The Agency consistently meets or exceeds their needs.
EPA includes a broad range of customers, partners, and
affected groups in the processes of making decisions, in
the development of policies that affect them, and in
determining how the Agency does its work.
Barriers
EPA managers' resistance to involvement
Perceived lack of time, resources
Inability to use the feedback we get
Perception that deadlines preclude involvement
Restrictions (OMB) on surveying customers
Suggested Actions
What Who When
Follow up on Daily Customer
Interactions for Satisfaction 3Reg/3HQ Vols 1/94
Conduct Face-to-Face Customer
Contacts (Focus Groups;
Interviews) OA/AAs/RAs/QCs FY 94
ID Customer(s) for Major
Internal and External Processes OA/OARM/OPPE
Regions FY 94
Build on Innovative/Successful
Outreach to Children (e.g.,
Partners in Education; OW's
National WETWAY Sessions;
Videos and Posters AAs/RAs 9/93
Pilot Use of Customer Input in
Accountability/Performance
Management Systems AA/RA Vols FY 95
Minimize/Automate Reporting
Requirements EPA/States FY 94
Costs: EPA management and staff time, travel for pilot
tests. Costs of developing and producing outreach
materials.
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QM 15
Benefits; Make sure we do the right things. Improves EPA
credibility, customer support for decisions, program
actions. Improves cooperation, responsiveness, and
working relationships.
Measures; Interactions will yield on-the-spot feedback from
customers. Monitoring response times of
organizations will indicate changes and trends.
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QM 16
WORKING SMARTER
The days of plentiful fiscal and human resources are
gone. However, we find ourselves dealing with a greater
number of more complex challenges. We want to respond more
quickly to internal and external customer needs and involve
others in productive partnerships. We must ask ourselves, "Is
there a better way to do business?" "Can we improve our
processes and systems?" "Is there a way to 'speed up1 or
eliminate the bureaucracy?"
The answers to these questions are found in working
smarter, not harder. We need to enable our employees, our
customers, and our partners to become more self-sustaining.
We need to find innovative approaches to solving our problems
and doing our work, we need to be more creative in the use of
our resources. By applying quality principles and tools to
our daily work practices, we can serve our customers better
and regain the public trust.
Initiative 1. Set, and Work Toward, Environmental Goals
EPA sets broad, realistic environmental goals with input
from its customers, partners and the public. State/Local
governments and the private sector determine how to
achieve environmental goals.
Barriers
Technical staff unwilling to give up "doer" role for
roles of leadership, oversight, advisory, outreach and
assistance
Existing congressional mandates
Insufficient infrastructure in place to manage by
data/facts
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QM
17
Suggested Actions
What Who
Expand Use throughout the Agency
of Integrated Environmental
Approaches like OW's
Watershed/Attainment Approach,
Region 10's Coeur d'Alene Initiative,
Geographic Initiatives, and
Targeted Enforcement
Complete Environmental Goals
Project and Monitor Results
Pilot-test Creation of
Executive-level
"Sustainability" Outreach
Person to Work with Customers
and Affected Groups
When
Strengthen Outreach to Congress,
State Legislatures to Get useful
Input
Pilot "Environmental Results
Report Card" Tracking of our
Organizational Performance
Using Customer Input and
Environmental Indicators
Negotiate State/EPA Agreement
Applying Quality Principles
SLC
Task Force
FY 94
FY 94
Reg 10/3 Reg
Volunteers
SLC
12/93
FY 94
OPPE/OARM FY 95
3 Reg. Vols FY 95
Evaluate "No Net Gain" Approach
to Reporting Every New Report
Offset by the Elimination of an
Existing one OPPE/SLC
FY 95
Costs; EPA Management and staff time, travel costs.
Benefits; Clarifies roles and responsibilities. Reduces
misunderstanding and resentment among levels of
government, duplication and overlap of work, permits
redirection of resources to more effective
activities (subject to statutory limitations),
enhances innovation.
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QM 18
Measures; Publication of goals by EPA, adoption of goals by
States and local governments. Acceptance and use of
goals by citizens, news media, etc., as legitimate
and understandable. Quality, usefulness, frequency
of recommendations from diverse groups on EPA
performance.
Initiative 2. Integrate Management Systems
Management and administrative systems and processes
(planning, budgeting, human resources, accountability,
grants and contracts management, etc.) link together to
achieve EPA's strategic objectives using Quality
Management.
Barriers
Crisis mode rather than effective long-range planning
"Use-or-lose" budget practices
Turfism
Narrow-focus thinkers
Accountability systems measure the wrong things
Budget appropriation structure and process (statutory)
Suggested Actions
What Who When
Create Resource Incentives for
Organizations to Spend More
Wisely, Reduce Expenditures,
or Enhance Revenues OARM/CFO FY 95
Work with Other Agencies to
Identify Opportunities to Improve
Ineffective Government-wide
systems and to Find and Market
Best Practices SLC/OARM 9/93
Promote Rotational Assignments
to and from Other Agencies,
Especially in Administrative
and Management Areas OHRM/HQ,
Reg Vols 11/93
Costs; Dollar cost is minimal, involving primarily travel
costs for rotational assignments.
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QM 19
Benefits: Clear, consistent set of priorities supported by
fiscal and human resources to get the job done.
Appropriate balance of intramural and extramural
resources, with the right people with the right
skills in the right jobs at the right time.
Measures: Compare budget with strategic plan(s) to determine
degree of alignment. As a result of benchmarking
activity, EPA systems are acknowledged to be among
the best in government. Follow up on interagency
rotations.
Initiative 3. Design for Quality
Quality-focused organizational structures/ processes and
systems promote and support the goals of leadership,
partnership, and working smarter. EPA's decisions,
responses and actions are timely and effective. We
select, evaluate, promote and reward our managers based
on managerial effectiveness, and provide alternative non-
managerial career paths for high-performing scientific,
technical and administrative staff.
Barriers
Human Resources Systems, policies, procedures (many
statutory) are not customer-friendly
Limited non-managerial career tracks
Fear of losing job status, position
Suggested Actions
What Who When
Experiment with "Flattening"
Organizations by Converting
Managerial and Supervisory
Positions to Technical Experts 2 Reg/2 HQ FY 94
Expand Use of Dual Ladder
Career Tracks through the
SES-level to Reduce the
Financial Incentive for
Employees to Want to Enter
Management Ranks ORD/Reg 10 1/94
Revisit OPM, EPA Span-of-Control
policies, guidance (3 staff =
supervisory grade, 5 staff+
supervisor = Section Status) OHRM/M&O 11/93
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QM 20
Suggested Actions
What Who When
Create Customer-Focused
Organizational Structures
(e.g., One-Stop Shopping
Customer Service Centers) OARM/OHRM/
Reg HROs FY 94
Costs: Negligible can be done in-house.
Benefits: Fewer bottlenecks, sign-offs, delays; quicker
response to customer needs. Greater creativity and
innovation improves communication. Selection of
managers and supervisors who want to manage and
supervise and have people skills and other requisite
capabilities. Enables technical or legal
"superstars" to remain happy, motivated and
productive in their chosen professions.
Measures: Detailed evaluations of pilot projects. Comparison
of baseline Employee Evaluation of Supervisors data
with results in subsequent years.
Initiative 4. Mainstream Quality Practices
The Agency adopts Quality concepts, practices, and
techniques in its daily operations.
Barriers
Lack of confidence in process
Fear of Change
Existing systems don't support Quality (Evaluation,
Rewards)
Lack of skills
Fear of giving up managerial power
Suggested Actions
What Who When
AAs/RAs Serve as Quality (or
Customer Service) Consultants
to Each Other SLC Vols/QCs 4/94
Communicate Quality Success
Stories and Market Applicability
to Other Processes QCs 12/93
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QM 21
Suggested Actions
What
Pilot-test Jargon-free,
EPA-Relevant, "Just-in-Time"
Refresher Quality Training
Market Concept of "Desktop
Quality" Each Employee Applies
Principles to own Work
Who
OARM/QCs
QCs
When
10/93
FY 94
Costs: Staff time; training costs would be minimized by
using existing facilitators.
Benefits; Decision making, meetings and communications would
yield desired results. See Benefits of "Leadership"
initiatives.
Measures: Ask employees at random about quality principles.
Observe meetings at any level for use of quality
management approaches. Spot-check performance
agreements for managers and supervisors to make sure
quality is expected and evaluated.
Internal/external surveys and evaluations of
supervisors will establish baselines and measure
progress over time.
Initiative 5: Redirect Key Functions
EPA redirects functions to move toward error prevention
and away from error detection work such as inspections
and audits. Major EPA activities can be evaluated; we
operate with disciplined goal-setting, automated
monitoring and reporting, and timely feedback on goals
achieved.
Barriers
Inspection and compliance ("Gotcha!") mentality
No model demonstrating the desired state
Inspector General legislation prescribes roles
Congressional support for inspection activities
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QM 22
Suggested Actions
What Who When
Create Cradle-to-Grave Measurement
Team for EPA Programs and Processes,
Incorporating Front-end Groups
(OPPE, OARM), Monitoring Groups,
and Audit/Inspection Groups (DIG,
other OARM, Enforcement Units) A/OARM/M&O FY 95
Expand the "Informal Advisor"
Role of Experts within the Office
of the Inspector General
and Other EPA Compliance Monitoring
Organizations (Focus on Prevention) A/DA/OARM FY 94
Evaluate EPA and Contractor
Resources Now Devoted to Audit
and Inspection Functions Reality
Check on Front-End Quality OARM/CFO 10/93
Benchmark Major Accounting Firms
to Assess Shift to Front-end
Consulting, TQM. CFO/QCs 11/93
Revisit FOIA, Congressional
Correspondence Requirements AX/AL 1/94
Costs: Redirection of in-house resources. Benchmarking may
involve travel costs, staff time, or contract
dollars.
Benefits: Mobilizes highly skilled and educated staff to
improve quality up front. Reduces rework, resource
waste, repeated problems, and undetected errors.
Improves morale of staff and those receiving
services. Changes from product- to process focus,
which has a higher quality improvement pay-off.
Measures; Morale measurements from internal survey would
indicate baseline and future trends. Cost/benefit
standards established. Proper customer service
standards developed.
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QM 23
Concluding Remarks
Implementing Quality is about changefundamental change.
It requires a willingness to challenge the status quo and to
question the conventional mindset. Change is about creating
new forms, about implementing a new paradigm.
EPA is at the crossroads. As an Agency, we are
experiencing the growing pains of maturation. This normal, if
uncomfortable, process is made more difficult for us because
Congress and the public are watching us so closely. The
Quality Management Team chooses to view this situation as an
opportunityan opportunity in which we can make a difference.
And, we will make a difference if we seek fundamental changes
in the way in which our
organization is structured and lead,
employees and partners are considered and involved, and
work is planned and designed around customers and
processes.
We must seize the opportunity now! If we act with vigor
and vision and apply Quality practices in making those
fundamental changes, we can lead the Nation (and the world) in
new approaches that will both protect and sustain the
environment. If we act timidly and depend on old ways of
doing business, we will look back and wonder "What if...?"
Our challenge as public servants calls for us to venture
forward using new, creative ways and to choose the path of
vigor and vision. We must ask "Why not?"
By integrating Quality into the way we work, we can make
a difference in achieving better environmental protection and
improving our worklife. We believe that the recommendations
offered in this report will help EPA create the fundamental
changes necessary to achieve our environmental mission.
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REPORT OF THE
QUALITY SCIENCE
TEAM
NATIONAL
PERFORMANCE
REVIEW
-------
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QS
Quality Science Team Members
Co-Chairs: Wil Wilson - OAR, fie Bill Raub - OA
Tyrone Aiken - OPPTS
Kay Austin - OPPTS
Ambika Bathija - OPPTS
Timothy Backstrom - OGC
Steven Bayard - ORD
Joseph Breen - OPPTS
Douglas Campt - OPPTS
Jose Cisneros - Region 5
Mary Clark - OAR/NAERL
Larry Cupitt - ORD/AREAL
Charles Hensley - Region 7
Steven Hedtke - ORD/Duluth
Dominique Lueckenhoff - Region 3
Edward Ohanian - OW
Ronald Patterson - ORD
Sally Perreault Darney - RTP
Rosemarie Russo - ORD/Athens
Stephanie Sanzone - OA/SAB
Rita Schoeny - ORD/Cincinnati
Robin Sega11 - OAR/RTP
Babasaheb Sonawane - ORD
Silvia Termes - OPPTS
Ramona Travato - OW
Darlene Watford - OPPTS
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QS
REPORT OF THE QUALITY-SCIENCE TEAM
EXECUTIVE SUMMARY
Rule-making and other policy decisions at USEPA almost invariably
rely on science, with the nature and extent of that reliance varying
considerably from one instance to another. But one factor is
invariant: quality must be a first-order concern in deciding what
scientific information is relevant, how it is presented, and how it
is used. Quality science is a condition precedent for quality
decisions.
The quality-science team embraces a unifying vision:
... that USEPA be recognized throughout the world as a science
agency, as well as a regulatory agency, by virtue of
1) decisions consistently based on high-quality science;
2) leadership in all major areas of environmental science,-
and 3) effective communication and coordination of environmental-
scientific issues and policies.
The team recommends initiatives in the following four areas:
A. ACHIEVEMENT OP QUALITY SCIENCE IN USEPA
1. Quality-Science as a Continuing Policy Objective
2. Procedures that Promote Scientific Excellence
3. Science Advice within Program and Regional Offices
4. Science/Congressional-Liaison Team
B. THE SCIENCE/POLICY INTERFACE
1. Preparation of Policy-Makers for the Science/Policy Interface
2. Preparation of Scientists for the Science/Policy Interface
3. CASE BOOK on the Science/Policy Interface
4. Management of Differential Risks among Population Subgroups
C. NURTURING QUALITY SCIENTISTS
1. Job Enhancement and Resource Support for Scientists
2. Career Ladders and Promotion/Incentive/Reward Systems
3. Employee-Empowered Scientific Recognition Committee
4. Training For Scientists
5. Recruitment of Scientists
The words in this text are intended to be inclusive, not exclusive. "Environmental science" is used
from a holistic perspective, encompassing both ecological science and human health science. "Science" (and
"scientists") is used to represent not only the traditional natural sciences, but engineering (and engineers),
the mathematical sciences, and the many other sciences (e.g., economics, social sciences) that may become more
and more important over the next decade.
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QS 3
D. COMMUNICATION AND COORDINATION
1. Prioritization of Intra-Agency Communication and Coordination
2. Exchange of Scientists (internally & externally) For Purposes of
Exchanging Science
3. Communication and Coordination with Other Federal Agencies,
State and Local Agencies, and International Organizations
4. Communication and Coordination with Academia and Industry
5. Communication and Coordination with Congress, OMB, News Media,
and the General Public
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QS 4
I. VISION
... that USEPA be recognized throughout the world
as a science agency,as well as a regulatory agency,
by virtue of
1) decisions consistently based on high-quality science;
2) leadership in all manor areas of environmental science; - and
3) effective communication and coordination of environmental-
scientific issues and policies.
II. BACKGROUND/CURRENT STATE
Rule-making and other policy decisions at USEPA almost invariably
rely on science, with the nature and extent of that reliance varying
considerably from one instance to another. But one factor is
invariant: quality must be a first-order concern in deciding what
scientific information is relevant, how it is presented, and how it
is used. Quality science is a condition precedent for quality
decisions.
USEPA's science activities range from fundamental, basic research to
highly applied, problem-solving efforts. Basic research may be
driven by critical, media-specific environmental problems; or it may
create the foundation for unprecedented, multimedia approaches to
the nation's most critical environmental challenges. While applied
research may be used to fulfill immediate needs, it may also
contribute to attaining long-term strategic goals.
Scientific activities at USEPA are performed both by its research
laboratories and by its program and policy offices3. These
activities directly impact the national and international environ-
mental-science community. For example, USEPA's analytical methods,
predictive models, and risk-assessment guidelines are used as
standards by other agencies, both nationally and abroad.
USEPA is on the cutting edge of many areas of environmental science,
and contributions of its scientists and other technical personnel
are respected world-wide. However, the role of quality science in
USEPA policies, decisions, and actions is often questioned. USEPA1s
major agenda is unquestionably that of a regulatory agency charged
with promulgation and enforcement of air-, water- and land-quality
The words in this text are intended to be inclusive, not exclusive. "Environmental science" is used
from a holistic perspective, encompassing both ecological science and human health science. "Science" (and
"scientists") is used to represent not only the traditional natural sciences, but engineering (and engineers),
the mathematical sciences, and the many other sciences (e.g.. economics, social sciences) that may become more
and more important over the next decade.
References to "program and policy offices" in this document are intended to address both Headquarters
and Regional operations.
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QS 5
statutes. Science often is or seems to be a secondary
priority. In fact, USEPA decisions all too frequently are perceived
by OMB, Congress, other Federal agencies, industry, or the public as
not grounded in sound science. To the extent that the Agency does
not support and use quality science, this perception will be
repeatedly reinforced.
USEPA1s ability to conduct an effective and coherent quality-science
program is impacted by numerous congressional mandates and highly
compartmentalized appropriations. Program offices within USEPA are
divided by media-specific statutes that sometimes erect seemingly
insurmountable barriers to cross-media initiatives. Moreover, about
75% of the budget is directed toward problems of high visibility and
relatively low risk rather than to environmental concerns considered
by the scientific community to present significantly greater risks
to human health and the environment (Problem Area Analysis of the
FY94 Budget. OPPE, June, 1993).
Another manifestation of this balkanized governance is that the
Agency's research and development is not driven by a holistic, long-
term, strategic plan. Instead, program offices, dependent upon the
Office of Research and Development (ORD) for support of regulatory
actions, have seen critical research cut back substantially or
eliminated outright, as ORD is forced to respond to new policy
mandates without a commensurate increase in funds and staff.
Neither ORD laboratories nor the program offices historically have
had sufficient resources to address all high-priority short-term
needs and a substantial long-term research agenda simultaneously.
Contributing to the perception that USEPA's decision-making is not
always rooted in sound science is the Agency's severely limited
ability to support and nurture its scientific staff. There are
numerous inconsistencies throughout the Agency regarding job
functions, training and development, opportunities for advancement,
and recognition for scientists. In the face of attrition and loss
of institutional memory in specific subject-matter areas, the Agency
has fallen behind with respect to training and career development
programs for its technical staff. Further, reductions in science
and engineering career positions not only have bred undue dependence
on contractors to meet scientific and technical needs but also have
encumbered USEPA scientists increasingly with contracting duties
thereby shifting their focus and their talents away from science
toward administration.
Ineffective communication between USEPA policy-makers and scientific
staff also tarnishes USEPA1s reputation with respect to science.
Evaluating and communicating the sources of uncertainty in
predictive exposure and risk assessment are not deeply ingrained
practices across the Agency. Scientists do not always fashion their
recommendations and/or risk assessments so that all major
assumptions and findings are made explicit. Likewise, many managers
do not frame their questions to enable scientists to address the
issues in the best way. Neither risk assessors nor risk managers
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QS 6
consistently convey their findings, decisions, and the associated
uncertainties using the language and communication tools most
appropriate for the target audience. USEPA cannot be said to be
fulfilling its mission if it cannot adequately convey levels of risk
to the public.
Communication and coordination among USEPA's science programs
both internally and externally are beset by problems as well.
Inadequate coordination among programs and the laboratories has led
to science being practiced in isolation, and perhaps, redundantly.
There is no comprehensive, cross-referenced data base that
identifies in-house expertise and on-going activities for access by
Agency scientists. Scientists working on similar or closely related
issues or projects find difficulty in establishing peer review and
support elsewhere within USEPA because there is no accessible
Agency-wide listing of scientific personnel, training, and
expertise. The same applies to USEPA publications, scientific
findings, and decisions.
Communication and coordination of efforts with scientists in other
Federal and State agencies and international organizations also are
inconsistent. USEPA research efforts often have no apparent impact
on the research agendas of other agencies, nor is there a well-
established mechanism for USEPA staff to access the results of their
counterparts at other agencies. While there are examples of
successful collaborative efforts between USEPA and industry, (such
as pollution prevention and product stewardship,) interactions with
academia and industry should be considerably strengthened.
Inflexibilities in the contracting mechanism, relative to contract
types, inhibit the Agency's ability to adequately address specific,
research needs. Currently, the governing process for all contracts,
whether scientific or non-scientific, is the same. Laboratory
scientific and technical staff are required to purchase equipment
utilizing the same procurement criteria as staff with completely
differing needs. Due to the vastly differing nature of laboratory
scientific needs from other types of procurement needs, utilizing
universal procurement criteria for both of these areas greatly
stifles the timely actions and operations of laboratory scientific
and technical staff.
Against this sobering backdrop of needs, opportunities and problems,
USEPA must take deliberate steps if it is to achieve its vision of
being recognized as a science agency. The remainder of this
document presents an overall strategy and some specific proposals
toward that end.
III. DESIRED STATE/GOALS
Not only can science support the over-arching environmental-
protection strategies of today; it also can define the strategies of
tomorrow. Thus, changes in the way USEPA staff do science should
include, but not be limited to, a greater emphasis on the following
strategic themes: risk-based priority setting; pollution
prevention, ecosystem approaches, and product stewardship; and
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QS 7
environmental education and equity for all population groups.
Underlying it all should be a strong, sustained program of basic and
applied research in all major domains of environmental science.
Cross-media issues
Today, environmental issues are more complex than ever before; and
environmental protection strategies must cut across all
environmental media and all routes of exposure. Rarely is it
sufficient to deal with environmental media individually. Rather,
the quality of science across all program offices that exercise
statutory authority over specific media should reflect a consistent,
holistic approach to protecting and enhancing both ecosystems and
human health and, at the same time, should ensure adequate
environmental resources to meet future needs.
Quality data and application
To ensure that science within USEPA is of the highest quality, USEPA
must improve the quality of data and promote its appropriate
application in decision-making processes. This can be accomplished
by improving the methodologies used to acquire data; ensuring that
models properly reflect the latest scientific information, data, and
concepts including uncertainty analysis; applying models
responsibly and consistently; and incorporating current scientific
knowledge into risk-based decision-making.
Communication and Coordination
Effective communication and coordination among USEPA scientists,
between scientists and policy-makers, and between the Agency and the
rest of society are essential to achieve high-quality science.
USEPA must improve across the board in this area. Interactions
between risk managers and risk assessors warrant special emphasis,
as do USEPA interactions with other federal agencies, state and
local agencies, OMB, Congress, academe, industry and international
organizations. Above all, the Agency must improve its communication
to the general public.
Recognition and Resources
Public recognition, including that of the Congress, is essential for
USEPA to achieve the above vision. USEPA requires not only
effective environmental legislation but also resources sufficient to
identify risk-based priorities and to implement appropriate
environment protection and research strategies. USEPA's resources
must also include a well-trained, well-equipped, and highly-
motivated scientific and technical work force.
Planning
Strategic planning and appropriate resource allocation are necessary
to ensure: 1) the success of both short-term and long-term projects
and 2) adequate environmental protection for the future.
Ultimately, USEPA can do the right science and do the science right
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only when the policies, methods, and infrastructure, as well as the
public, actively support the undertaking.
IV. TARGET/ACTION
To achieve its vision that quality science undergird all
environmental decisions and to strongly support its leadership role
in all areas of environmental science, USEPA must identify those
elements forming the basis of credible science and make a commitment
to implement specifically targeted initiatives to achieve the
vision. Broadly interpreted, a quality science agenda addresses the
following:
Clearly identifies and prioritizes the most important scientific
questions to be addressed;
Identifies and uses the most appropriate and powerful
experimental and analytical designs;
Employs state-of-the-art experimental techniques;
Makes accurate measurements to generate reliable data;
Evaluates and interprets the results appropriately to obtain
accurate answers to the questions;
Uses the results in mathematical models to apply science
knowledge efficiently and coherently;
Subjects the methods, results, interpretations, and models to
field validation and independent review processes; and
Provides an infrastructure that recruits, retains and rewards
high quality scientific personnel and an on-going core
capability.
V. TARGET/ACTION CATEGORIES
Development and implementation of an Agency-wide quality science
agenda can be accomplished through the target/action areas and
associated do-ables/initiatives that are summarized in this section.
Details on each of the do-ables/initiatives are presented in the
next section.
A. ACHIEVEMENT OF QUALITY SCIENCE IN USEFA
TARGET/ACTION STATEMENT; Over the last few years, several expert
panels have conducted thorough reviews of science at USEPA (e.g..
Safeguarding the Future; Credible Science. Credible Decisions.
Reducing Risk; Setting Priorities and Strategies for Environmental
Protection, and Future Risk: Research Strategies for the 1990s.)
These panels have identified what needs to be done to improve both
the quality and the relevance of science at USEPA. Now, USEPA's
leadership needs to implement the recommendations.
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Several recommendations have consistently emerged from the expert
panel reviews: (1) To deal effectively with today's complex
environmental problems, the Agency needs to develop a coherent
science agenda that moves toward cross-media, anticipatory research;
(2) the Agency should take steps to ensure that quality science
enters the decision-making process early and consistently for
effective environmental protection programs; and (3) Agency
leadership must undertake a deliberate and continuing effort to
create the climate, culture, and incentives necessary to encourage
superior science.
SPECIFIC DO-ABLES;
1. Quality-Science as a Continuing Policy Objective
2. Procedures that Promote Scientific Excellence
3. Science Advice within Program and Regional Offices
4. Science/Congressional-Liaison Team
B. THE SCIENCE/POLICY INTERFACE
TARGET/ACTION STATEMENT; Efficacious use of science in support of
policy decisions is the responsibility of both policy-makers and
scientists. The credibility of USEPA decisions, the efficient use
of USEPA resources, and the cost-effectiveness of USEPA regulations
are all critically dependent on the maintenance of a clear
distinction and a proper balance between science and policy. The
place where scientific analysis ends and policy choices begin is not
always easy to determine. In the context of a regulatory agency
with many pressing responsibilities, the tendency to blur the line
between science and policy is difficult to resist for scientists and
policy makers alike.
The key to crafting and maintaining an appropriate relationship
between scientific inquiry and policy making is the nature of the
interaction between policy makers (or "risk managers") and
scientists (or "risk assessors"). The timing, frequency, and nature
of such communications are all important. Scientific analyses that
are informative and policy decisions that are informed can best be
achieved through implementation of specific practices and procedures
governing communication across the science/policy interface.
SPECIFIC DO-ABLES
1. Preparation of Policy-Makers for the Science/Policy Interface
2. Preparation of Scientists for the Science/Policy Interface
3. CASE BOOK on the Science/Policy Interface
4. Management of Differential Risks among Population Subgroups
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QS 10
C. NURTURING QUALITY SCIENTISTS
TARGET/ACTION STATEMENT: As USEPA works to advance the high-
quality performance of science and technology in its organization,
it must develop, increase and support the skills and talents of its
scientific workforce.
SPECIFIC DO-ABLES
1. Job Enhancement and Resource Support for Scientists
2. Career Ladders and Promotion/Incentive/Reward Systems
3. Employee-Empowered Scientific Recognition Committee
4. Training For Scientists
5. Recruitment of Scientists
D. COMMUNICATION AND COORDINATION
TARGET/ACTION STATEMENT: USEPA has the responsibility to
communicate its environmental scientific findings to properly
reflect the high-quality scientific basis for decisionmaking.
Communication of findings and decisions must take into account the
specific audience for whom the information is intended and include
the appropriate language and tools to attain the most effective
results. The Agency must coordinate its activities to avoid
replication of tasks and attain coherent products (regulations,
guidelines, regulatory decisions, research findings). Risk managers
and scientists must establish good communication to ensure that
regulatory decisions are based on high-quality science.
SPECIFIC DO-ABLES
1. Prioritization of Intra-Agency Communication and Coordination
2. Exchange of Scientists (internally & externally) For Purposes
of Exchanging Science
3. Communication and Coordination with Other Federal Agencies,
State and Local Agencies, and International Organizations
4. Communication and Coordination with Academia and Industry
5. Communication and Coordination with Congress, OMB, News
Media, and the General Public
VI. DO-ABLES/INITIATIVES
A. Achievement of Quality Science in USEPA
A.I Quality-Science as a Continuing Policy Objective
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QS 11
WHAT: Make a public commitment to use and support high-quality
science in all of the Agency's deliberations and actions.
This would consist of several actions:
(1) The Administrator would publicly adopt the vision
statement of the Quality Science Team and commit the
Agency to accomplishing the vision statement.
(2) The Administrator would establish a process by which to
implement the changes needed to ensure that USEPA is a
science agency with high-quality science underpinning all
of its actions.
WHO: The Administrator must publicly affirm the vision for quality
science at USEPA. She must also establish and empower the Agency-
wide Committee for Quality Science, and task it with overseeing the
Agency's "deliberate and continuing effort to create the climate,
culture, and incentives necessary to encourage superior science."
TIME LINE: One legacy of the National Performance Review should be
the establishment and empowering of an Agency-wide team, a Committee
for Quality Science, to develop and implement policies and
procedures to enhance Quality Science at USEPA. This Committee for
Quality Science should be part of USEPA1s effort to "reinvent" the
Agency. The Committee will be "continuing", providing suggestions
for changes and assessing progress made in improving quality
science. The Committee should incorporate and build upon efforts
already underway, including the Council of Science Advisors, the
Sci/Tech Committee, and the Quality Science Team itself.
BARRIERS: There is skepticism that USEPA, with its regulatory role,
can also be a "science" Agency. Overcoming this skepticism within
USEPA itself, in the Administration, and in Congress will be a major
challenge. Adoption of the vision statement by the Administrator
will not be adequate to bring about needed changes: the same vision
must also be shared by the AAs and other upper- and mid-level
managers. Demoralizing rumors of lab consolidation should be
replaced by better administration of decentralized science.
Finally, the vision must bring about changes in attitudes and
actions.
COSTS: There are no additional costs to be incurred by having the
Administrator affirm the vision statement and establish a Committee
for Quality Science to advise her. Undoubtedly, some actions
recommended by the Committee to improve the "climate, culture, and
incentives" will have investment costs: quality science does cost,
both in terms of funds and personnel. Nonetheless, there are a
number of specific recommendations can be accomplished with no
additional costs.
BENEFITS: The benefits to supporting the quality science vision are
significant. Quality science used to support Agency decision-making
will increase Agency credibility with the scientific community, the
public, impacted industries, and Congress. Improved credibility of
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QS 12
USEPA as a science organization with Congress and OMB will likely
lead to increased resources and greater flexibility. The recogni-
tion resulting from increased public confidence will improve work
force morale, which will, in turn, provide further improvements in
the Agency's rules and decisions. Only when high-quality science
undergirds the Agency's deliberations can more effective and less
costly solutions be identified. Better solutions to environmental
problems will provide significant savings to the affected industries
and will improve the national economy while still protecting our
health and ecology.
MEASURES OF SUCCESS: This initiative will be successful only if the
vision is put into action. The ultimate goal is to improve the
quality of the Agency's science not quantity and quality is
much more difficult to measure. Actions recommended by the
Committee for Quality Science should each contain their own measures
of success. The success of the overall effort to improve the
quality of science can be estimated through periodic surveys of
public (including scientific community, affected industries, and
Congress) perceptions and confidence in the Agency's decisions.
A. 2 Procedures that Promote Scientific Excellence
WHAT: Reaffirm USEPA's commitment to basic scientific research,
peer review, quality assurance, Good Laboratory Practices, and other
policies that are designed to promote excellence in science.
Sustained excellence in science does not come about spontaneously.
Quality science must be promoted regularly across the Agency through
the application and continuing refinement of procedures created
especially for this purpose.
WHO: Administrator, Assistant Administrators, Regional
Administrators, Council of Science Advisors
TIME LINE: continuing; evaluate progress after 5 years
BARRIERS: Although the vast majority of USEPA managers and their
staffs advocate quality science in principle, considerable
disagreement remains as to how that goal can best be achieved. Many
regulatory officials are concerned that, in some instances, expanded
use of peer review and the other quality-promoting procedures will
constrain operations unduly or require unnecessary expenditures of
time and money. Further, even in instances when managers are eager
to invoke these procedures, budgets and staffing constraints often
preclude it. There is currently more emphasis on administrative
procedures than on achieving flexibility.
COSTS: No adequate basis exists for estimating the absolute costs
of this proposed initiative. Historical USEPA-wide records for
budgets and staffing levels do not break out the costs associated
with peer review and the other quality-promoting procedures. OARM,
in cooperation with the program offices, ORD and the Regions, should
begin a systematic review of the current dollars and FTEs that
constitute the current operating level of these quality promoting
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QS 13
activities. An estimate of the FTEs and dollars needed to eliminate
the operating shortfall and a short-term strategy for shifting
resources would be developed and implemented over 18 months. After
the shortfall is erased, a systematic, multi-year effort to increase
the scope and intensity of the quality-science thrust could take
place.
BENEFITS: Broader and more intense promotion of excellence in
science will be manifest almost immediately in the quality and
credibility of the technical work-products that support decision-
making throughout the Agency. This should lead to regulations and
policies that are cost effective and thus gain broad acceptance from
the regulated communities. And, if decisions are easier to
understand, less likely to invite legal challenge, and less likely
to be reversed in court when challenged, then costs of litigation
and enforcement should go down.
MEASURES OP SUCCESS: Success would be indicated by progressively
more numerous decisions that win broad support for their
cost/effectiveness in achieving environmental protection.
A. 3 Science Advice within Program and Regional Offices
WHAT: Continuing the development of a strong science advice program
within the Agency.
One role of science in EPA is to reduce uncertainties in
environmental decision-making. Because laboratory-animal testing is
the model used most frequently to predict the potential for human
health effects due to exposure to a chemical pollutant, there is
uncertainty in extrapolating from effects seen in laboratory animals
to predict effects in humans. Other areas of uncertainty in policy
decision-making arise as a result of limited knowledge about
exposure and the effect of numerous chemicals or chemical mixtures
on environmental components.
While policy decisions require a strong science base to reduce
uncertainty, USEPA policy or regulatory decisions are often
perceived as not based on the relevant science. The science advice
function, ensuring that policy decisions are based on a clear
understanding of the relevant science, is currently not well-defined
or systematically organized within USEPA. This would include a
science advisor within ORD, each program office and region. The
science advisor's function, analogous to that of an OGC legal
advisor to a specific project or program, is to ensure that USEPA
policy decisions and regulatory actions are based on superior
science and a clear interpretation of relevant science and are
scientifically defensible.
The science advisor within ORD, each program office and Region
should be a senior scientist or recognized expert who works closely
with the Science Advisor to the Administrator and serves as a
program-office liaison to the Agency's Science Advisory Board.
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WHO: Science Advisor within ORD and Each Program Office
TIME LINE: Develop and implement plan by fall 1994
BARRIERS: Decision makers may object to what is perceived as an
additional layer of bureaucratic oversight. Programs which do not
function in traditional line management approach may find the
additional review inefficient in meeting statutory deadlines.
Resource allocation for science advisor positions may compete for
continuing education, training, and travel for program office career
scientists.
COSTS: Variable, but a senior scientist or science expert may
require GM/GS-15 and above salary range.
BENEFITS: The development of a strong science advice program within
the Agency would result in consistency in Agency policy decision-
making and the perception that USEPA is a "science" Agency.
Decisions in one program office would not adversely impact those in
other program offices. Another benefit would be more direct use of
ORD science and less reliance on contractors to program offices.
Career scientists would view their contribution to science at USEPA
as valuable, if work products were reviewed by a well-trained peer.
This would increase morale and incentives to do superior science.
Then the public would be less likely to challenge USEPA policy
decisions, avoiding costly delays (economic and environmental
quality) in implementation. Additionally, enhanced career
development and recognition would be provided for career scientists,
both within and outside the Agency, for their contribution to
excellence in science.
MEASURES OF SUCCESS: Policy decisions based on clear interpretation
of science leading to more consistency in decision-making. Public
support, news media perception enhanced, state and local
environmental sectors support USEPA decisions. Congressional
support, increased resource allocations.
A. 4 Science/Congressional-Liaison Team
WHAT: Establish a Congressional-liaison team representing Quality
Science throughout the Agency.
The team would communicate actively with Congress and its staff
about important issues of environmental science. Science issues
should be communicated by scientifically-trained experts, not left
solely to Public Relations personnel. USEPA should identify topic-
area technical experts, train them to interact with Congress, and
encourage them to communicate with Congress about their areas of
technical expertise. Only when Congress and their staff understand
the scientific and technical issues behind today's critical
environmental problems can they deal effectively with these complex
environmental problems. USEPA scientists should play a major role
in educating Congressional staff about environmental science.
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WHO: The Assistant Administrator for Research and Development,
together with the Science Advisory Board, should champion this
effort; however, the team should represent the interests of science
throughout the Agency, including the Program Offices and Regions.
Topic-area experts should be drawn from all sectors of the Agency.
TIME LINE: The liaison staff would be established as part of the
National Performance Review effort to reinvent government and should
remain a permanent part of USEPA.
BARRIERS: There are possible legal restrictions against "lobbying"
Congress. Controls may need to be established to ensure that this
initiative is clearly a component of public education, outreach and
communications. Other science agencies seem to be able to use
articulate, respected scientists to communicate effectively with
Congress: USEPA should do no less. Potential barriers may be
overcome by using NOAA or NASA as a model.
COSTS: Costs will be minimal. Current public relations or liaison
staff could be re-assigned and augmented with a few additional FTEs.
Topic-area experts would be recruited from current scientific staff,
trained to communicate effectively with Congress and the public at
reasonable costs and provided travel funds. The topic-area experts
would not be permanently assigned to the Liaison Team, since they
have to remain involved with their research programs in order to
retain their expertise and credibility. Programs sponsored by the
liaison staff (for example, periodic briefings for Congressional
staff on critical environmental issues) should not be expensive.
Travel costs for regular visits by topic-area experts to USEPA
Headquarters and Congress could be absorbed within the Agency's
current budget.
BENEFITS: Two major benefits will be: enhanced recognition by
Congress of the high quality of scientific and technical expertise
present in USEPA; and improved environmental legislation. USEPA has
the foremost experts in many areas of environmental science, and
this effort will help them be recognized for their expertise by
Congress, other federal sectors, and the public. As USEPA becomes
respected as a science agency by Congress, it will be treated more
like a science agency. This effort will also help educate Congress
(and Congressional staff and the public) about the scientific issues
involved in today's environmental problems. Such increased
understanding, together with the availability of identifiable topic-
area experts to provide counsel and advice, should make for better,
more-effective, and less-costly environmental legislation.
Legislation that is well-founded in science will provide substantial
savings for the U.S. through more effective programs with fewer
ineffective, but costly, controls. Better legislation will also
save considerable time and effort by reducing the political battles
entailed in frequent revisions and re-authorizations of
environmental legislation.
MEASURES OF SUCCESS: The goal of enhanced recognition of USEPA as
the premier environmental science agency by Congress and
Congressional staff can be assessed through periodic surveys.
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QS 16
Success should also be reflected in increased requests for Agency
scientists to testify before Congress on technical environmental
issues.
B. Science Policy Interface
B.I Preparation of Policy-Makers for the Science/Policy
Interface
WHAT: Establish a training program to help policy makers
communicate more effectively with scientists.
EPA policy makers may fail to indicate the specific technical
questions that need to be answered to achieve a particular risk-
management objective; and scientists charged with preparing relevant
analyses may fail to seek such clarification. Even when both
parties are of one mind as to the key questions, the decision-making
process often does not allow sufficient time for scientists to
prepare a thorough assessment. Moreover, scientists rarely have the
opportunity to help determine how their analyses actually are used
to shape policy.
When any of these scenarios occurs, EPA science is not kept in the
decision process. Over time, some scientists have come to feel that
they are not an integral part of the decision-making process. The
latter is a commonplace outcome whenever scientists focus on issues
they personally believe are important and later learn that the risk
managers consider those issues to be peripheral to the main
question(s).
WHO: Agency-wide work group appointed by the Administrator; review
by Council of Science Advisors
TIME LINE: Training program should be developed and instituted by
the spring of 1994.
BARRIERS: The idea of yet another training program may meet
resistance in principle, especially from those who feel that prior
efforts in other subject-matter areas such as Total Quality
Management have diverted staff from important work without
commensurate positive effect on the quality of the decisions being
made. Others may believe that the recommended training would merely
restate at length ideas that really are only common sense. Still
others may fear that, by adopting the recommended communication
practices and procedures, they would be inviting unwarranted
incursion into their programmatic discretion.
Policy makers will need to be assured that the objective is not to
supplant their decision-making prerogatives but rather to ensure a
proper relation and balance between science and policy. To promote
cooperation by policy makers in the training, it must incorporate
substantial flexibility and use the time of policy makers
efficiently. The best time for an individual to take the proposed
training would be when he or she is first appointed or promoted into
a policy-making position.
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QS 17
COSTS: The cost of developing the training program would be
approximately one person-year of effort. This could be accommodated
within the normal duties of the staff involved.
BENEFITS: If policy makers were to make even modest modifications
in their standard practices and procedures in response to the
recommended training, the benefits could be very large. When
scientific analyses are properly focused on the precise questions
presented by the enabling statute or regulations, the resultant
decision will be less vulnerable during judicial review. Scientists
also will be more productive and not waste time and resources on
peripheral issues. If outside scientists and the public believe
that EPA scientific analyses have not been unduly influenced by
policy/political requirements, the credibility of EPA decisions will
be enhanced. Moreover, the benefits to the public of even a single
regulation or action that is more cost-effective in achieving
environmental goals than otherwise would have been the case in the
absence of the proposed training program would far exceed the cost
of developing and implementing the proposed program.
MEASURES OF SUCCESS: Because the recommended procedures for
communication across the science/policy interface are largely
objective, specific decisions can be examined to determine whether
policy makers and scientists have followed them. For example,
scientists can be asked whether they were advised early in the
regulatory process concerning the specific questions their analyses
should focus on. In addition to such objective measures, changes in
attitudes will also be important. If the program succeeds,
scientists will be less likely to complain that their work has been
distorted by policy requirements and policy makers will express
greater confidence in the objectivity of the analyses they receive.
This would result in a more coherent and relevant research agenda.
B.2 Preparation of Scientists for the Science/Policy Interface
WHAT: Establish a training program for scientists to assist them in
communicating effectively and appropriately with policy makers.
USEPA needs the best scientific and technical information to make
credible and scientifically defensible decisions. To ensure that,
the scientist must present to the policy maker a comprehensive risk
characterization (scientific analysis) and not just numbers.
The scientist must present both the qualitative and quantitative
features of the assessment and also identify any uncertainties in
the assessment based on confidence in the data and methods used to
develop assessments. The scientist should present consistent
assessments of risk ranges, principal assumptions and their
underlying rationale. Also, where possible, he/she should quantify
the uncertainties along with comment about their influence on the
assessments.
The policy makers should specify whether the traditional scientific
extrapolation models are appropriate in specific cases; strive for
early peer review, both inter- and intra-agency; and identify when
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QS 18
additional information would be beneficial. Scientists should
stress that the risk assessment process employs a varying number of
judgmental positions to help bridge gaps in data and in
understanding of underlying biological processes. Risk assessors
should not attempt to overstate or understate risks, but rather give
estimates and the range of uncertainty.
WHO: Agency-wide work group appointed by the Administrator;
review by the Council of Science Advisors
TIME LINE: Develop the guidance by fall of 1993.
BARRIERS: Some policy makers seem reluctant to interface with
program office or ORD scientists prior to communicating major risk-
based regulatory decisions to the public. Also, they may choose not
to reveal the degree of uncertainty or what influence uncertainty
had on their final decisions. At times, scientists are not given
adequate time to collect acceptable data to perform credible
assessments. Research scientists are often brought into the process
very late, as reviewers, rather than early on, as developers. At
times, USEPA is pressured by external forces into making rush
decisions that are not based on good science. Many times scientists
are not advised what specific questions the decision makers need
answered early on in the process. Some policy makers are resistant
to involving scientists in the decision making process because of
their perception that scientists should be excluded from risk
management-based policy decisions.
COST: $100,000 for workshops, consultants and contractor assistance
to develop the guidance document(s).
BENEFITS: Adherence to Agency wide guidance will improve the
understanding of Agency risk assessments, lead to more informed
decisions, and improve the credibility of Agency assessments and
decisions and ultimately decrease costly challenges to regulations
and enforcement actions. Recognition of USEPA risk assessments will
improve scientists morale which in turn will lead to their enhanced
productivity.
MEASURES OP SUCCESS: Decisions based on credible risk assessments
will decrease the number of challenges from environmentalists,
industries and the public.
B.3 CASE BOOK on the Science/Policy Interface
WHAT: Create CASE BOOK, a collection of agency cases documented
sufficiently to allow scientists and policy makers the opportunity
to study the following:
Exemplary cases of science and policy interfacing.
Examples of problem solving approaches.
Orientation workbook for risk assessors and risk managers.
A guide to help new employees assess and manage risks.
A primary reference for science/policy approaches.
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QS 19
WHO: Council of Science Advisors. Contributions to CASE BOOK will
be prepared by each program, that is, the offices serving under the
various statues, (e.g., TSCA, FIFRA, etc.).
TIME LINE: Continuing; evaluate program after 2 years. The time
for completion of the first edition of CASE BOOK will be one year
after the agreement that this proposal is to be accepted and
implemented. Approximately, September 1994.
BARRIERS: Some risk managers and risk assessors may be reluctant to
relinquish their analysis for agency wide review. Additionally, a
manual that is circumspect of decisions may cause paralysis of
analysis, that is, CASE BOOK may cause risk assessors/managers to
equivocate rather than make well-timed decisions. These are common
barriers and should not prevent the idea of the CASE BOOK from being
successful. Most scientific organizations compile reference
information for use when making risk assessments and doing
research/experiments.
COSTS: $25,000 for consultants and publication assistance.
BENEFITS: Circulation of a high quality manual containing
instructive Science and Policy Case Studies will benefit the agency.
CASE BOOK will provide substantive examples of what is expected of
risk assessors and risk managers. Specifically, risks assessors and
risks managers who know before hand what is expected of them have an
advantage over those that do not. Communication is critical in
order to facilitate problem solving. CASE BOOK will be a lexicon of
Science and Policy and reveal the process of science and policy
interfacing.
A well-prepared inventory of science and policy issues will require
few resources compared to the benefits. Circulation of exemplary
science and policy decisions will raise the morale of Scientists and
Policy makers. The agency standards will be open to scrutiny and
forced to stand the test of critique from agency scientists and
policy makers. The peer review process, good laboratory practices
and other practices designed to promote quality science would be
enhanced by CASE BOOK. Promoting quality science and policy
interfacing and publishing examples will gain support from the
Congress and the public through better risks communication.
CASE BOOK will be an excellent tool for orientation of Risk managers
and Risk assessors, both new and existing employees. In conclusion,
the substance of CASE BOOK is already contained within the records
of the agency and would not create a new or unreasonable burden on
the risks managers and assessors.
MEASURES OF SUCCESS: The measures of success will be identified by
evaluating how well CASE BOOK is received, that is, how often it is
used and cited in the continual efforts to manage and assess risk.
Feedback and input into CASE BOOK will identify the effectiveness of
the document. Commentary sections on each case cited in CASE BOOK
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QS 20
could acknowledge the effectiveness of the document. Similarly, if
CASE BOOK is cited as a guideline in future examples of Science and
Policy Interface in the agency, we will know it is working.
B.4 Management of Differential Risks among Population
Subgroups
WHAT: Enhance the capabilities of health-risk assessors to
differentiate among population subgroups wherever practical by
developing a long-term research plan and associated risk-assessment
strategy.
Attempts to estimate the likelihood of adverse human-health effects
from known or putative environmental hazards traditionally have
focused on the risks faced by the population on the average; the
principal exception has been selected reference concentrations or
doses that are calculated using arbitrary uncertainty factors to
protect potentially sensitive populations. Yet experience
increasingly is making clear that, for any given hazard, some
population subgroups may be at substantially greater risks than
others as a consequence of stage of development, gender, or other
manifestation of genetic make-up. Moreover, current research in
cell biology, molecular genetics, and epidemiology is offering
evermore powerful means to assess subgroup-specific risks; and an
expanded effort would yield significant return. The time has come
for USEPA risk assessors, as well as the other scientists whose work
supports them, to obtain and use subgroup-specific data wherever
practical as a matter of policy.
For example, in view of the possibility that infants and children
may be a greater risk from certain pesticides than are adults, the
National Academy of Sciences recently recommended revamping the
pesticide-registration process so that it includes better tests and
better data relevant to this subgroup. This line of reasoning can
be extended to include the possible differential vulnerabilities of
infants and children to hazards other than pesticides. And
essentially the same logic can be applied to other population
subgroups under various circumstances especially the elderly,
women, and racial and ethnic minorities for a wide spectrum of
environmental hazards.
WHO: The Administrator could appoint an agency-wide working group to
develop a two-part product: (1) a research agenda to expand the
knowledge base relevant to subgroup-specific risks and (2) a
strategy for progressively incorporating this ever-growing knowledge
base into the health-risk assessment process.
TIME LINE: Appointment of working group by January, 1994.
BARRIERS: As with pesticides, little data is available regarding
the differential risks that most environmental hazards pose for
various population subgroups; therefore, some commentators may
assert that the proposed emphasis is premature. Others may
acknowledge the reality of biological differences and endorse the
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QS 21
proposed initiative in principle but oppose it out of fear that the
costs and time required for risk assessments could rise unduly.
COSTS: $100,000 for a workshop and consultant fees related to
developing the research agenda and upgrading risk-assessment
strategy. USEPA staff costs would be absorbed as part of normal
duties.
BENEFITS: The initiative would introduce a new level of scientific
rigor and sophistication into health-risk assessment. The
initiative also would stimulate research toward better tests and
better data pertinent to differential risks. Subgroup-specific risk
assessments would lead to better tailoring of protective measures
for the special needs of vulnerable subgroups, to improved public
health, and thus to more cost/effective regulation.
MEASURES OP SUCCESS: Progressively more emphasis on subgroups in
environmental regulations; accelerated emergence of new or improved
subgroup-specific tests and data bases.
C. Nurturing Quality Science
C.I Job Enhancement and Resource Support for Scientists
WHAT: Tailor Jobs and the Work Environment to Make the Best Use of
Scientific and Technical Talents
The first step in promoting quality science at USEPA is to ensure
that the jobs we create are of high quality - stimulating,
rewarding, and as free from administrative distractions as possible.
This may require shifts in job assignments among other components of
the work force. More scientific projects should be done in-house to
enable our scientists to share scientific contributions and to link
science to Agency policy, rather than merely reviewing the work of
others, as with contract activities.
In addition, we must ensure that, as we nurture quality scientists
within USEPA, we provide them with the necessary guidance,
equipment, and general resources to perform and produce quality
scientific outputs. The development of specific standards for
laboratory practices and the placement of emphasis on quality
assurance for all areas of scientific work, including the facility
and staff, not merely procedures, are essential. Adequate resources
should also be provided for implementing these standards and
procedures.
WHO: Scientists and engineers throughout the Agency
TIME LINE: By fall of 1994, review all relevant job assignments;
develop and implement plan to decrease reliance on contract support;
develop and implement set of standards and QA plans for scientific
work; increase resources and remove institutional barriers to
scientific activities
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QS 22
BARRIERS: There are currently many inconsistencies throughout the
Agency on the functions and grade levels of scientists. Although
ORD has a career advancement system in place, it cannot be applied
to other USEPA program scientists due to differing duties and
functions. Limitations on federal positions and resulting reliance
on contractors continues to be a serious problem. In-house
expertise and public confidence in Agency decisions cannot be
nurtured while much of the scientific work is delegated to
contractors. While ethical standards exist, their emphasis is on
legal and regulatory constraints rather than on opportunities.
Similarly, QA is being developed for laboratory procedures, rather
than as a framework for Agency scientists to produce quality
products. Constraints on travel have a particularly devastating
effect on scientists, since exchange of scientific information and
the enhancement of the Agency's image are the two primary objectives
of participation at environmental conferences and professional
meetings.
COSTS: Converting much of the budget for the contract work to in-
house resources should have no effect on the budget. Establish a
travel budget of at least $15,000 per scientist.
BENEFITS: Decreased staff turnover and increased job satisfaction
throughout the Agency
MEASURES OP SUCCESS: Increased public confidence in Agency
decisions, policies, and regulations and increased representation of
EPA scientists on national panels.
C.2 Career Ladders and Promotion/Incentive/Reward systems
WHAT: Create a system that links grade assignments to the
contributions of the individual.
A traditional approach to position classification is no longer
responsive to the Agency's need for flexibility in creating career
ladders linked to organizational goals and individual achievement.
If we agree that "science" forms the backbone of this Agency,
scientists should be able to reach senior levels (through their
"scientific" contributions and achievements) in the Agency, without
having to assume "Management" positions. Promotion systems should
provide the structure and criteria for advancement, but should not
limit them with artificial ceilings (glass or otherwise).
Aspects of the Merit Promotion Program should be re-examined in
order to support the concept that jobs are created by employees,
based upon programmatic needs, rather than employees created by
jobs. All employees should have a sense of the types of (multiple)
"careers" they can have at USEPA.
An Agency-wide Policy Statement should be implemented in order to
delineate the criteria for scientists to advance within the Agency.
It should require that each program, office and laboratory adopt the
policy, while further specifying these criteria, as related to the
unique functions and operations of that program, office or
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QS 23
laboratory. High quality performance of scientists in these
positions should be motivated and rewarded as an on-going process
(not just through the annual appraisal cycle). Reward systems
should be more competitive, innovative and prestigious, and less
routine, "bean-oriented" and automated. New award categories,
nomination (including external nominations) and peer review
procedures may be incorporated. Incentives and rewards may be
expressed through fellowships, advisor/instructor assignments, mini-
sabbaticals, state-of-the art laboratory equipment, rotations or
time and support to pursue other USEPA mission-oriented endeavors.
WHO: Task Force with cross section of USEPA scientists, Human
Resources experts and 1st & 2nd line supervisors (particularly
"Science" Managers - scientists managing scientists)
TIME LINE: Develop Agency-wide policy for career paths, promotions
and incentive/reward systems to be implemented in FY95.
BARRIERS: Management may have reservations about implementing a
policy due to potential budgetary impacts. If "benchmarking" all of
the various scientific positions within the Agency is used in order
to develop the criteria, this could be a very cumbersome process and
it may end up falling under its own weight - well before a policy
statement could be developed. There may also be some hurdles with
0PM to get over. Supervisors may feel that this only presents more
obstacles for them. They would need to receive extensive support
(training, incentives, time, etc.) to do this. It would also
require time and resource support to develop the policy and criteria
for this type of personnel management system.
COSTS: Development: $100,000, plus 6 FTEs for a year;
Implementation: $75,000 for training agency-wide
BENEFITS: Decreased staff turnover; it's getting increasingly
difficult for the Agency to recruit and retain quality scientists.
More emphasis on rewards rather than punishments would improve
morale. Increased job satisfaction and sense of career direction.
Decreased perceptions of "hidden" rules for advancement of
scientists in the Agency. Increased importance placed upon our
scientific workforce; increased pride. Improvement in the quality
of science in USEPA.
MEASURES OF SUCCESS: An Agency-wide Policy and Criteria in place.
Adoption by all USEPA programs (HQ's and Regions) and labs.
Increased job satisfaction, pride and sense of career/direction -as
gained through regular employee surveys.
C.3 Employee-Empowered Scientific Recognition Committee
WHAT: Improve the way we reward scientists and technicians for
innovation, creativity and continuing scientific excellence by
establishing employee-empowered Scientific Recognition Committees at
the Divisional level.
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QS 24
WHO: Create a "reinvention lab" to test this concept. This do-able
is modeled on an existing committee in ORD/HERL/DTD (contact person,
Dr. Robert Kavlock) , but should be extended to other sectors
(Regions, HQ's) of USEPA
TIME LINE: The model for this concept became operative within about
6 months of conception and is now in its second year. Briefly, the
Division Director appoints a chairperson and, with the chair's help,
drafts a committee consisting of 2 technical staff, 2 principal
investigators (non-supervisory) and two supervisors (with two
members replaced each year) . Award nominations are solicited at
least twice a yearanyone can submit a nomination at any time. The
committee is convened as nominations come in. It makes
recommendations to the Division Director who becomes the nominating
official. The scope of activities that DTD currently deems worthy
of recognition is broad, and has been developed with much discussion
and debate. It is specific to the potential contributions of bench
scientists and technicians, but is consistent with current USEPA
award vehicles (on-the-spot, or special act awards). The concept of
employee-empowered Recognition committees could be extended to other
groups within USEPA but each group would have to decide their own
criteria.
BARRIERS: Inflexible interpretation of current USEPA award
criteria. Resistance of managers to empower staff at all levels of
the organization.
COSTS: None: funds for these awards would come from the
established award pool (for on-the-spot and special acts).
BENEFITS: Two years' experience with such a committee in DTD has
already produced measurable benefits: 1) Staff like being recognized
at the time of their contribution. It gives them positive feedback
and this leads to increased motivation, loyalty and productivity.
2) The number of nominations has increased as staff gain familiarity
with the process and confidence that it operates fairly. This helps
assure that meritorious actions are recognized by both peers and
supervisors. 3) Communication and trust is fostered between
supervisors, principal investigators and technical staff. This
promotes team efforts in the laboratory. 4) All staff are
empoweredthey make nominations and set criteria for recognition.
They "own" this committee. This diminishes jealousy and fractious
competition and eliminates the suspicion of "supervisor's
favorites." 5) A potential long range goal would be to use this
approach to recognize and reward good science, and remove cash
awards associated with the official performance appraisal process.
Then, the performance review unencumbered by the cloak of
financial intrigue could be used productively to evaluate whether
goals have been met and to set new goals and IDPs for the coming
year.
MEASURES OF SUCCESS: Annual review at DTD staff meeting to obtain
feedback on success of recognition program. Increased productivity
measured by established methods.
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QS 25
C.4 Training For Scientists
WHAT: Establish innovative career-development program to ensure
that scientists remain challenged and stimulated while fostering a
greater exchange and interaction between USEPA and the academic
research communities.
The Agency needs to develop a system that maximizes the human
potential of our scientists and thus the quality of science at
USEPA. The system should establish, in advance, a cohesive training
plan and budget for each position that is filled.
The program will require the establishment of a team of scientists
(working with Human Resources) to develop a step-by-step mapping of
advance career-development activities for each scientific position,
which should include: (1) methods to ensure active participation in
the rotation of USEPA scientists to outside science organizations to
broaden the knowledge base of the individual, as well as the Agency;
(2) financial support by the Agency for employee membership to
scientific professional organizations; (3) establishment of an
Agency-wide long-term training program for scientists who are
interested in advanced training and remaining with the Agency; and
(4) establishment of agreements with local colleges and universities
to offer a wider variety of scientific courses at USEPA.
WHO: USEPA management
TIME LINE: Develop training plans for scientific positions by April
1994 and begin implementation by September 1994.
BARRIERS: Tight budget constraints exist, and USEPA lacks the
support of Congress to provide the needed funding. Managers may
resist spending funds on training scientists and opt for spending it
on travel or oversight of extramural projects (especially non-
scientific managers). Managers may discourage training when it
involves allowing the employee to use government time and may make
it difficult for scientists to participate in a rotational
assignments. Aggressive means of exchanging technical information
with international scientists, especially if it involves travel
funds or other resources, may be viewed as only benefiting the
scientist, and not the manager or the Agency.
COSTS: Development: $200,000, plus 4 FTEs; Implementation: $0
rotational assignments; $50 fee for each member of professional
associations; $300-1000/training course.
BENEFITS: Recognition of USEPA as a high-quality science Agency;
development of a strong base of top quality, stimulated scientists;
retention of quality scientists with institutional knowledge;
decrease the turnover rate of quality scientists; increase
productivity of quality scientific outputs through advanced
training; and, eliminate partial training of select scientists.
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QS 26
MEASURES OF SUCCESS: Gain public confidence; decrease turn-over
rate of quality scientists; increased morale; produce defensible
quality outputs; decrease in number of scientific challenges to the
Agency.
C.5 Recruitment of Scientists
WHAT: Develop a short-term and long-term strategy for the
recruitment and retention of qualified in-house scientists,
engineers and technicians.
Such a strategy is crucial if USEPA is to achieve status and
credibility as a "Science Agency." Deficiencies in sustaining an
adequate scientific staff are increasingly evident as the Agency is
rapidly losing its institutional technical knowledge through
attrition. The strategy must sanction the recruitment of junior
scientists, engineers and technicians, who, under the mentorship of
senior scientists, will conduct in-house research and develop into
Agency experts.
Participation in the recruitment and hiring processes by peer-level
scientists from inside and outside the Agency should be a key
element of the recruitment policy. The strategy must also encourage
cooperation and coordination with external researchers. USEPA must
include in its long-term recruitment strategy a more sophisticated
plan for improving cultural diversity, including fostering
relationships with colleges and universities to attract top-notch
recruits. Another important part of the recruitment strategy should
include the placement (by recruitment or promotion from within) of
several world-class scientists (including current EPA experts) into
key policy and decision-making positions, as well as critical
research areas that are essential to reducing uncertainties in USEPA
decision-making.
WHO: Task force consisting of key Agency personnel and outside
scientists appointed by the Administrator
TIME LINE: Develop an implementation plan by the 2nd quarter of
1994
BARRIERS: Barriers to the successful implementation of this
recruitment strategy include the following: limited FTE ceiling,
limited dollars for FTEs allocated by Congress, non-competitive
salaries compared to industry, limited career tracks and inflexible
Human Resource Management guidelines for scientists, procurement and
ethics regulations that restrict communication between scientists,
limited travel budgets, limited and un-focused training program for
scientists across the Agency, recent policy to reduce 300+ GS
14/15/SES positions, recent policy to suspend cash performance
awards for FY94 through FY98, very low morale of the current
technical staff.
COSTS: The political will to approach Congress and OMB with a
request for a significant increase in FTE ceiling. Part of the
argument should address switching R&D dollars for PRO dollars to pay
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QS 27
for FTE ceiling increase. This approach would not increase the
total dollars allocated to the Agency.
BENEFITS: The following benefits would be derived from the
implementation of this recruitment strategy: increased respect for
Agency decisions, increased respect for Agency scientists and
engineers, increased confidence in Agency data, recognition and
acceptance of USEPA as a science agency, increased morale and
productivity within the Agency technical workforce.
MEASURES OF SUCCESS: The ultimate measures of success would result
from environmental scientists around the world recognizing USEPA as
the source of expertise in environmental science and technology, the
primary training ground in environmental science and technology, a
reliable source of quality environmental data, a leader in
environmental methods and technology development, and a promulgator
of regulations with sound technical basis.
D. Communication and Coordination
D.I Prioritization of Intra-Agency Communication and
Coordination
WHAT: Give special emphasis to communication and coordination of
scientific activities within USEPA.
Effective intra-Agency communication and coordination is essential
to achieve high-quality science products (research, regulations,
guidelines, policies and decisions). The scientific resources
throughout the Agency must be identified to facilitate direct and
productive interaction of scientists working on related issues. In
addition, readily available information on projects/activities
currently on-going within the Agency (Headquarters, Regions, ORD-
Laboratories) must also be identified and periodically updated.
Identification of resources and projects/activities will serve to
coordinate scientific efforts within the Agency.
Thus, it becomes essential that coordinators be designated in all
programs to foster communication among scientists and avoid
replicate efforts. Communication between risk managers and
scientists involved in risk assessments requires that risk managers
convey clearly what information they need from scientists, so that
scientists can respond clearly and factually (including the
uncertainties in the risk assessment). Training of scientific
personnel in media communication should be made available (and in
some cases, mandatory) to allow proper identification of the needs
and level of communication required by the target audience. Non-
scientific personnel should be encouraged (and in some cases,
required) to receive scientific training as part of their career
development.
WHO: USEPA-wide task initiated by the Administrator and implemented
at each program, Region and ORD-Laboratory.
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QS 28
TIME LINE: This should be a continued effort supported by the
Agency. The first phase of this task (identification and
coordination of scientific resources and projects/programs) should
be in operation by Fall 1994.
BARRIERS: Major barriers in communication and/or coordination of
scientific efforts would be those imposed by statutory restrictions,
which would limit the amount and nature of the information that can
be shared. Although these are intrinsic and may not be easily
removed, the need for improved communication and coordination of
scientific efforts within the Agency should be recognized by the
Administrator, Assistant Administrators and other upper- and middle-
level managers as a vital key to achieve high-quality science.
COSTS:
a. Low Cost- Identify (through a survey) the scientific resources
within the Agency. Identify the components of the different
programs/projects in Headquarters, Regions and Laboratories.
Create a document, database or other form of transmission media
for disseminating the gathered information, with periodical
update of the information. This could build on the Scientific
Registry being piloted by the Sci/Tech Committee.
b. Medium to High Cost- Training of non-scientific personnel;
Training in risk communication; Training in communication skills.
Designation of intra-agency coordinators in FTE positions.
BENEFITS: The benefits of communication and coordination of
scientific activities within the Agency are significant. Replicate
efforts can be avoided, which would result in savings in time and
costs. Improvement in communication and coordination within the
Agency (among scientists and between scientists and managers) will
improve the quality of science. This will have a direct effect in
the quality of the decisions, regulations, research and risk
assessments generated by the Agency. In turn, the Agency's
credibility by the public, the scientific community in other
agencies and academia, industry and Congress will improve. The
increased credibility of the USEPA as a high quality science agency
and a leader in all aspects of environmental science could result in
increased funding to further expand the Agency's capabilities.
MEASURES OF SUCCESS: The success of an improved communication and
coordination system within the Agency can be measured by the gains
in the quality of science products generated by the Agency.
The ultimate measure of this success would by the recognition by
others (the scientific community, industry, other agencies and
organizations, Congress and the general public) that the USEPA is a
high quality science agency and the leader in all aspects of
environmental science.
D.2 Exchange of Scientists (internally & externally) For
Purposes of Exchanging Science
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QS 29
WHAT: Increase scientific contact and openness within USEPA as well
as with other government and private sector organizations.
The coordinated exchange of USEPA scientists within USEPA
laboratories, Headquarters, and the Regions, as well as among other
federal agencies, academia, and international organizations, will
make its scientific and technical efforts more widely known. Such
an exchange program would ensure that USEPA scientists are
continually exposed to current knowledge and methodologies.
To accomplish this the Agency should promote and increase the number
of details and rotational opportunities within USEPA. USEPA should
require that every laboratory and program office, whether in Region
or in Headquarters, mandate that rotational assignments/details
outside of a scientists own immediate program take place at some
optimal level of their career. These rotational assignments should
last for a minimum of 30 days. Administrative and management
procedures should be checked to ensure that no barriers exist to
inhibit these rotational/detail activities.
In promoting the exchange and sharing of science between USEPA and
other government and private sector organizations, the Agency should
implement the recommendation contained in Safeguarding the Future:
Credible Science, Credible Decisions., The Quality of Scientists at
USEPA, Recommendation 3 (pp.31-32). The details for the
implementation of this recommendation would be left to the Agency to
determine.
WHO: USEPA-wide, coordinated by personnel offices in the Regions,
laboratories and Headquarters.
TIME LINE: Develop an implementation plan for the intra-Agency
rotational/detail assignments by the end of FY94. Develop an
implementation plan for the exchange of scientists between USEPA
and the outside scientific community by early FY95.
BARRIERS: Coordination with other programs to allow the optimal
exchanges will be complicated. Some may object to the disruption of
their staff. The rotations involving relocation may require special
attention, due to cost considerations. Some entrenched employees
may object to the mandatory nature of the rotations. Concerns may
exist over the opening of USEPA offices to non-USEPA employees,
especially over Confidential Business Information (CBI).
COSTS: Costs will be minimal for internal rotations, with
relocation and per diem costs being the largest out-of-pocket
expense. Two (2) million dollars might be set aside for the
external rotation program for the first year; that budget could be
altered as the success and size of the program is determined.
BENEFITS: Cross-program understanding; a more multi-media,
pragmatic workforce; greater future sharing of information as a
result of networking. All of these would help improve the quality
of science in the Agency.
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QS 30
MEASURES OP SUCCESS: Improved sharing of information across
program; high number of rotations/details reflecting interest in
program; better relationship with other governmental and
private-sector organizations.
D.3 Communication and Coordination with Other Federal
Agencies, State and Local Agencies, and International Organizations
WHAT: Create frequent opportunities for USEPA scientists to be
exposed to current knowledge, data, and methodologies from other
agencies and organizations, as well as to communicate findings and
advice to them.
Among the federal agencies, USEPA is fifth in the dollars spent on
environment research. The states have five times more scientists
monitoring the status of the environment than does USEPA. Many
international organizations (WHO, OECD, World Bank, Japan, United
Nations, etc.) look to USEPA for scientific advice.
Within USEPA, scientists are separated by organization (four
programs, ten regions, and the Office of Research and Development
(ORD)) and location (35+ laboratories facilities). State agencies
often cannot explain the science behind the regulations and
regulatory actions to the public. The public is willing to comply
if they could understand the rationale behind the Agency's
decisions. Communication of USEPA scientists with their
counterparts in international organizations, e.g., OECD, is crucial
to the USEPA efforts on guideline harmonization. The communication
to other agencies/organizations should be consistent, accurate, and
frequent to build credibility as a strong scientific agency.
USEPA should plan and co-host meetings and workshops on scientific
issues with other federal agencies which senior USEPA senior
management would be expected to attend. Scientists from across
USEPA would attend in numbers proportional to the other federal
agencies. Regions would host similar meetings for states and field
offices for federal agencies. USEPA should develop a focal point
for scientific expertise to ensure that we provide accurate,
current, consistent advice to international organizations.
WHO: USEPA-wide task force appointed by the Administrator. The task
force would include scientists from ORD, programs, and Regions.
TIME LINE: First meeting planned for February 1994 with full
implementation plan by October 1994.
BARRIERS: The greatest barrier would be the budget and managers'
approval to travel. Travel dollars to attend these types of meetings
do not exist in the present budget. The present culture will not
invest the time and funds in this kind of long term investment.
There also would be resistance to the formation of another task
force.
COSTS: For four national meetings and ten regional meetings per
year - $60,000. Travel funds for these meetings - $500,000.
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QS 31
BENEFITS: Improved communication between USEPA scientists and
scientists in other federal, state, and international
agencies/organizations would result in more credible environmental
science, better compliance with our regulations, and reduction of
wasted and duplicate efforts.
MEASURES OF SUCCESS: Survey developed by the task force for USEPA
scientists, other federal agencies' scientists, and state
scientists, to be completed by February 1994. The same survey
instrument would be used again in February 1995 and February 1997.
D.4 Communication and Coordination with Academia and Industry
WHAT: Develop Environmental Technology Re-invention Laboratories
based on collaborative efforts of the Agency with universities and
industry.
USEPA's environmental protection strategies are undergoing important
paradigm shifts. The most important include: risk-based priority
setting, pollution prevention as the preferred approach over
pollution control, and increased attention to reducing ecological
risk.
USEPA should encourage and legitimize the open collaboration of
Agency scientists with academia and industry in the development of
innovative approaches to pollution prevention and cleaner production
technology. Such creative and non-traditional efforts will help
ensure an American scientific, technological and industrial presence
in the international marketplace. Open and unfettered communication
and coordination with industry, in particular, will serve as the key
to success.
WHO: The Administrator's Science Advisor, in collaboration with the
Office of Prevention, Pesticides and Toxic Substances (OPPTS) with
its links to industrial and agricultural chemistry and Design for
Environment Program (DfE), and the ORD Office of Science, Planning,
and Regulatory Evaluation (OSPRE) would serve as the Agency-broker
on communication and coordination for a FY94 pilot program. The
program would be conducted jointly with the National Science
Foundation's (NSF) Environmentally Benign Chemical Synthesis and
Processing Program and the NSF Industrial-University Cooperative
Research Center at the University of Washington's Center for Process
Analytical Chemistry. The industrial sector would be represented by
the Dow Chemical - Perkin-Elmer Strategic Alliance Ventures Group
recently established to extend the practical use of advanced
analytical technology into applications of real-time industrial and
environmental monitoring.
TIME LINE: Fifteen months to produce a report to Administrator
Browner and Vice President Gore on the feasibility, limits and
opportunities of USEPA/NSF coordinating innovative Design for
Environment and Pollution Prevention programs with environmentally-
based advanced technology ventures in the private sector.
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QS 32
BARRIERS: Three types of barriers to success exist:
Historical and cultural reluctance of USEPA to aggressively,
openly, and effectively collaborate as equal partner with
industrial sector subject to Agency regulations, and with
technology-based firms who may benefit from close and
privileged Agency ties.
Interagency turf battles where USEPA and other science agencies,
each protective of their own perceived sphere of influence and
control, will stifle coordination.
Intra-agency resistance between and among Program Offices and
ORD. Current USEPA measurement and monitoring programs are
predicated on pollution control with virtually no experience or
expertise in pollutant transformation processes. Reluctance of
Air, Water, Solid Waste and RCRA programs to adapt and adopt
Performance-based measurements as opposed to USEPA Approved
Methods-based measurements.
COSTS: Extramural investment modest primarily to support
meetings and report development and production plus travel budget to
Dow, Perkin-Elmer facilities and to CPAC. Intramural resources
modest senior scientists from Administrator, Program and ORD
Offices and Labs, plus travel budget to support staff.
BENEFITS: Effective and efficient communication and coordination of
pollution prevention activities between the Agency and the industry-
university communities will significantly leverage modest federal
resources with private sector investments. Creating a mutually
supportive culture between USEPA and industry supportive of national
environmental and economic goals will reap long-term economic
benefits.
MEASURES OF SUCCESS: The success of effective and efficient
communication and coordination of this effort may be measured in a
series of agreements between USEPA and industry to adopt specific
advanced analytical technology to replace outdated and costly Agency
methods and procedures. The October 1994 report would clearly
identify quantifiable measures of savings, where appropriate, or the
generation of better data for decisionmaking and compliance at
comparable costs.
D.5 Communication and Coordination with Congress, OMB/ News
Media/ and the General Public
WHAT: Develop new and improved means to present its science-based
activities to lay audiences.
USEPA's greater emphasis on cross-media planning and scientific
efforts will result in a more coherent and efficient effort by the
Agency to resolve complex environmental problems. This cross-media
emphasis will require enhanced cross-media budgeting. This presents
a serious communications challenge with respect to OMB and with the
various Congressional oversight and appropriations committees and
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QS 33
subcommittees. The issue of how the communication of USEPA's
research and science accomplishments affect the budget process is
critical to the financial health and well-being of the Agency's
science program and its scientists.
Specifically, USEPA need to take the following steps:
when presenting its programmatic and research projects to
OMB, reflect the cross-media perspective rather than the
perspective that fragments environmental protection into
different media
adopt a communication strategy that aggressively supports the
Agency budget i.e., obtain and disseminate to the public
and affected industrial and agricultural sectors the best
possible scientific information and ensure the nation's
scientific expertise is enlisted in the service of USEPA's
mission
increase the number and quality of Congressional briefings
offering Congress an open invitation to utilize USEPA
resources, as needed, to gain further information on topics
of interest
increase the number of its personnel/scientists on loan to
Congress/White House
interact more positively with the news media on releasing
important environmental issues/decisions associated with the
Agency, emphasizing press releases that reflect high-quality
of science, convey it in a clear manner, and contain
information that precludes conjecture and avoids negative
publicity
hold public forums on science for selected target audiences
in order to adequately present the information and address the
audience's concerns as well as enable the audience to provide
necessary feedback to USEPA scientists
serve as a leader in fostering environmental education for the
general public, taking advantage of community-based
organizations and placing special emphasis on educating and
informing the public on issues of exposure and risk analysis,
risk assessment and management, and risk communication
encourage public outreach by its scientists, emphasizing
environmental education, in grades K-12, as well as in
colleges and universities (especially schools with scarce
resources) this outreach effort would also include a strong
focus on stimulating students to follow science and
engineering careers
The Agency should reexamine its present approach of using non-
technical staff versed in communications and trying to bring them up
to speed on the technical issues. A more effective approach would
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QS 34
be to employ individuals with strong technical backgrounds and train
them to be skilled in the effective use of communication and public
relations tools. There already are many scientists at USEPA who
possess excellent communications skills. Their abilities should be
tapped to explain scientific principles as a complement to the
communications staff.
WHO: This should be a high-priority team effort on the part of the
Program Offices, ORD, the Office of Congressional and Legislative
Affairs (OCLA), and the Office of Communications and Public Affairs
(OCPA). The communication materials should be prepared in terms
non-USEPA scientists, Congress, and the public can understand.
TIME LINE: A Workgroup should be convened to develop a workplan and
schedule to meet the near-term and long-term objectives of
communicating with Congress, OMB, the news media, and the general
public. The workplan should be submitted to the Administrator by
February 1, 1994. The lead Offices would be OCLA and OCPA with
scientific staff detailed from ORD, OPPTS and other Program Offices.
BARRIERS: Historical roles of professional communicators versus
professional scientists, engineers, and technologists will make
implementation of some objectives problematic. Top management
support will be required if true change is to be accomplished.
COSTS: Significant intramural and extramural resources will be
required over the long-term. In the short-term, current staff may
be assigned to scope out the program and develop the workplan.
BENEFITS: The short- and long-term benefits to the Agency are
significant. Improved understanding of the Agency's scientific
basis for decisionmaking by Congress and OMB is desirable in its own
right. The improvement of communication with the news media is
obviously in the Agency's own self interest. Communication in an
effective and meaningful manner with the general public is an Agency
obligation.
MEASURES OF SUCCESS: Short-term measures of success may be measured
in numbers of events, i.e., briefings, articles, public meetings,
where USEPA science is presented and discussed. Longer-term
measures will require some normative assessment of the perception,
positive and negative, by Congress, OMB, the news media and the
public on the "quality of science and decisionmaking" at USEPA.
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QS 35
REFERENCES
"A Global Marshall Plan: Developing and Sharing Appropriate
Technologies," Earth In The Balance: Ecology and the Human Spirit.
by A. Gore; Published by Plume, New York, 1993.
"Aiming Before We Shoot: The Quiet Revolution In Environmental
Policy"; Address by William K. Reilly, Administrator, U.S.EPA to The
National Press Club, Washington, D.C, September 26, 1990.
"Cabinet Fever," Government Executive, published by National Journal
Incorporate, Volume 25, Number 7, Washington, D.C., July 1993.
Communicating Risk to Senior EPA Policy Makers: A Focus Group Study.
Produced by D.L. Bloom, D.M. Byrne and J.M. Andresen for the Office
of Air Quality Planning and Standards, U.S. Environmental Protection
Agency; March 1993.
Reducing Risk; Setting Priorities And Strategies For Environmental
Projection, U.S. Environmental Protection Agency,
Science Advisory Board (A-101); SAB-EC-90-021, September 1990.
SfltfguardJPg the Future; Credible Science, Credible Decisions.
Report of the Expert Panel on the Role of Science at EPA to
William K, Reilly, Administrator, U.S, Environmental Protection
Agency; EPA/600/9-9I/050, March 1992.
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REPORT OF THE
J^GULATORYDEVELOPMENT
TEAM
NATIONAL
PERFORMANCE
REVIEW
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RD
THE REGULATORY DEVELOPMENT TEAM
The National Performance Review Team was the Regulatory
Development Improvement Team a team composed of
representatives from each of the Agency offices routinely
involved in regulatory decisionmaking:
Michael Alushin
Dan Barolo
Dick Bauer
Jay Benforado
Wendy Cleland-Hamnett
Tom Eagles
Chuck Elkins
Len Fleckenstein
Maryann Froehlich
Scott Furlong
Kathleen Knox
Mark Luttner
Ken Munis
Gail Robarge
Margaret Schneider
Bruce Smith
Pam Stirling
Maggie Thielen
Office of Enforcement
Office of Prevention, Pesticides and
Toxic Substances
Office of the Administrator
Office of Research and Development
Office of Policy, Planning and
Evaluation (co-chair)
Office of Air and Radiation
Office of General Counsel
Office of Policy, Planning and
Evaluation
Office of Policy, Planning and
Evaluation (co-chair)
Office of Policy, Planning and
Evaluation
Office of Prevention, Pesticides and
Toxics Substances
Office of Water
Office of Policy, Planning and
Evaluation
Office of Research and Development
Office of Solid Waste and Emergency
Response
Region III
Office of Policy, Planning and
Evaluation
Office of Regional Operations and
State and Local Relations
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RD
Betty Walter Office of Policy, Planning and
Evaluation
John Wilson Office of Policy, Planning and
Evaluation
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RD
TABLE OF CONTENTS
I. EXECUTIVE SUMMARY 1
II. VISION 5
III. TARGET ACTION CATEGORIES
Recommendation 1 Strategically allocate
resources 9
Recommendation 2 Improve the quality of
data and analysis upon
which regulations depend 11
Recommendation 3 Strengthen workgroup
operations and management 13
Recommendation 4 Continuously evaluate and
improve the process 15
Recommendation 5 Develop a process to manage
non-regulatory activities 16
IV. COSTS AND BENEFITS 17
V. NEXT STEPS 18
VI. SUPPORTING MATERIALS 19
VII. REFERENCES 21
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RD
I. EXECUTIVE SUMMARY
Making decisions about environmental policy is
increasingly difficult. The complex nature of environmental
problems being assessed and the societal consequences of our
decisions have increased significantly. For this reason, it
is critical that EPA have a well-tuned and efficient process
to manage its decisions.
The Regulation Development Team has evaluated the
Agency's current process, including consultations with over
200 Agency staff and external representatives. The team has
identified several actions critical to ensuring the Agency's
process facilitates development of quality regulations and
policies. In addition to these actions, the Agency's current
culture must change. The rulemaking and policy development
environment must foster teamwork, accept different
perspectives among participants, support cross-Agency and
multi-disciplinary perspectives, actively seek and consider
the views of affected parties outside the Agency, and promote
timely issue elevation and resolution.
The Regulation Development Team recommends the following
specific target actions:
set and implement priorities by developing and using a
tiering system that matches the scope of the development
process to the significance of the action;
improve the quality of data and analysis upon which EPA
regulations depend;
improve the effectiveness of workgroup operations and
strengthen management of specific regulations;
continuously evaluate and improve the process; and
develop a process to similarly manage non-regulatory
activities which establish important policies or which
have significant effects on the environment.
The opportunity exists now for implementing these
improvements. The Regulation Development Team proposes to
immediately establish an implementation team, led by OPPE and
comprised of representatives from all key program offices,
whose sole job will be to carry out these recommendations.
Implementation of the target actions would begin immediately
with full implementation projected by January 1994.
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RD 5
II. VISION
A. Desired State
An open regulatory and policy development process that
effectively develops quality rules, creates the opportunities
for active involvement of key players inside and outside the
Agency, ensures consideration of all relevant issues and
alternatives, and ensures a level of analysis commensurate
with the scope and potential impact of the action under
development. The process must facilitate decisionmaking about
environmental problems and policies that cut across the
boundaries of single regulations and statutes. As a result,
the process must be dynamicit must accommodate and adapt to
competing priorities and be fluid enough to change course as
new information becomes available without getting stalled by
shifting priorities and issues.
The Regulatory Development Team found a large degree of
agreement on the elements that constitute a quality
regulation. These key features are:
protect human health and the environment;
promulgated in a timely manner;
address a clearly identified, high risk,
environmental problem;
analytically sound from an economic, scientific,
legal, political and technical perspective;
consider potential multimedia effects;
reflect the views of groups outside EPA;
cost-effectively achieve environmental objectives;
clear and concise;
enforceable and implementable; and
include Agency-wide involvement, especially regional
input, as appropriate.
In order to develop a successful regulation development
process that produces a quality product, the NPR Team
recommends some specific target actions and initiatives.
Inherent in the actions and initiatives, however, is a
fundamental change in the way EPA's decisionmaking system
operates. Agency culture needs to change. An environment
that rewards decisionmakers and staff who encourage and
support cross-Agency, multi-disciplinary perspectives needs to
be nourished. Senior managers, especially the Administrator.
Deputy Administrator and 12th floor staff, will need to resist
any actions which support or could be perceived to support
parochial decisionmaking and reluctance to raise issues on a
timely basis as they arise rather than at the end of the
process.
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RD 6
A second major cultural change is warranted if a new
system is to succeed. Along with teamworkf the Agency must
become more accepting of the different perspectives Agency
staff bring to rulemakings, and must enforce a disciplined
process which raises and resolves issues throughout the
process rather than becoming paralyzed while trying to reach
consensus, or allowing "late hits" at the end of the process.
B. Current State
The current process requires that all regulations,
regardless of their significance or precedent-setting nature
follow the same formal process during development unless case-
by-case exemptions are sought. Cross-agency workgroups are
formed for rules even though this may not be a necessary to
produce a quality regulation in every circumstance.
Rulemaking activities lack clear policy direction
throughout the rule development process, especially at the
beginning. Senior managers do not routinely make decisions
early in the process to guide rulemaking or the selection of
alternative regulatory options. This inhibits identification
and resolution of major cross-cutting policy issues, and
leaves major issues to be argued at the workgroup level. The
process relies on "inspection" to assure quality at the end of
the process when is more costly to correct problems, rather
than building in steps to assure quality throughout the
process.
Many delays and much rework result from differing
opinions on the quality and adequacy of data collection and
analysis in rulemaking. For example, the Office of Research
and Development typically views scientific and technical
defensibility as paramount whereas the lead office often puts
more weight on other factors such as meeting court-ordered
deadlines. These differences of opinions frequently are not
resolved during rule development, leading to delay at the end
of the process and criticism that EPA rules do not have a
sound analytical basis.
The views of external constituencies often come to EPA
late in the process, making it more difficult for EPA to
incorporate legitimate concerns from affected parties into its
activities. EPA often fails to benefit from the informal, and
potentially greater exchange of information early in the
process that would allow the Agency to better gauge the
opinions of external groups on issues, identify key
constituencies, garner support, gather information, determine
implementability, or negotiate a rulemaking.
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RD 7
Workgroups are not formed or operated in a way which
makes efficient use of resources and staff expertise. Members
are reviewers of the work, not contributors to a team effort.
Chairs and members often lack the necessary experience,
skills, and training.
Few data are available on performance of the regulation
development process or on customer satisfaction. Adequate
data are not collected to allow the Agency to continuously
measure and evaluate the regulation development process and
the Agency does not routinely assess the efficiency of its
process or the quality of its product. Under the new process,
appropriate monitoring and evaluation data must be routinely
collected and senior managers must view evaluation and
improvement of the process as a priority.
Non-regulatory programs, legislation, and policy guidance
play an important role in EPA's overall efforts yet these
products are produced on an ad hoc basis with no formal
process for contributions by EPA programs, regions, senior
management, or external stakeholders. These activities do not
benefit from the resources and collaborative efforts now
focused solely on regulation development.
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RD 8
III. TARGET/ACTION CATEGORIES
The Regulatory Development team has grouped its
recommendations into five target/action categories. These
categories are:
strategically allocating Agency resources;
improving the quality of data and analysis upon which EPA
regulations depend;
strengthening workgroup operations and management;
continuously evaluating and improving the process; and
developing a process to manage non-regulatory activities.
Inherent in all of these initiatives is change in Agency
culture. As discussed earlier, regulation and policy
development must be embedded in an environment that encourages
and rewards cross-agency and multi-disciplinary approaches and
teamwork.
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RD
Recommendation 1
EPA must allocate its scarce resources strategically by:
adopting a system that matches the scope of the internal
process to the nature and scope of the action using a
three-tier approach:
Administrator Priority Tier actions that require
active senior manager involvement throughout the
development process, expansive issue analysis, and
input from diverse parties;
Cross-Agency Tier actions that require cross-
Agency involvement to fully develop and evaluate
options, and produce a quality rule;
Lead Office Tier actions where the nature and
scope allow a quality rule to be produced by a
single program office; and
emphasizing early policy guidance by senior managers.
The Agency is increasingly asked to do more with fewer
resources. By creating and implementing a tiering system, we
can better ensure that the most complex, controversial, or
other critical actions receive the guidance, analytic
development, and attention that is commensurate with their
potential significance.
To write quality regulations, EPA need not apply the same
process for each and every rulemaking. The idea of "one size
fits all" is frustrating for program offices and leads to
attempts to circumvent the formal development process whenever
possible. In addition, cross-media offices cannot and should
not devote the same level of time and attention to each and
every rulemaking.
The recommended tiering system would have three levels
each designed to meet the needs of a particular regulation or
policy. The differences in the tier assignments would result
from the degrees to which:
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RD 10
the Administrator or Deputy Administrator needed to
be involved in decisions throughout the various rule
development stages (as opposed to other senior
managers);
cross-agency interaction is needed;
comprehensiveness of analyses performed; and
formal decision points need to be identified and
documented.
Critical to the success of these recommendations is for
senior officials to provide guidance, demand appropriate
analyses, resolve issues, make timely decisions, and monitor
progress throughout the regulatory process. Senior management
involvement is especially critical early in the process. By
better engaging senior officials throughout the process, major
cross-cutting policy issues and alternatives can be addressed
appropriately and promptly rather than leaving these issues to
be argued at the workgroup level. If officials assigned to a
rule do not have the time, they should delegate the
responsibility to someone who does and they should not
second-guess subsequent decisions.
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RD 11
Recommendation 2
EPA must improve the quality of data and analysis upon which
its regulations depend by:
requiring an "analytic blueprint" to guide rule
development; and
expanding external involvement.
Sound economic, scientific, legal, political and
technical analysis was identified as one of the most important
elements of a quality regulation. The Agency needs to
consider the appropriate analytic support needed to produce
quality for all of its actions although the actual scope of
these activates will vary depending on the regulation. By
openly and explicitly addressing the type and scope of
analysis needed, especially early in the process, the Agency
can avoid some of the delays and debates that currently take
place late in the process over the adequacy of the data.
A specific initiative in this area is to require an
"analytic blueprint" for all agency actions to map out the
analysis required to achieve a quality regulation. Just as
architects create blueprints of buildings before construction
begins, so too EPA needs to create a blueprint before
regulation development begins. The blueprint process does not
end there howeverit needs to be a living document so that
all parties involved in the regulation development understands
the analytical support that will be available to
decisionmakers.
The scope of the blueprint should match the nature and
scope of the regulation it guides. The more complex the
regulation, the more detailed the analytic blueprint. The
minimum amount of analysis should be conducted that ensures a
quality regulation. For example, the analytic blueprint for a
very complex and contentious regulation may need to be a
detailed schedule of what analyses will be done, which office
will manage the analysis, and when it will be complete. For
routine regulations being developed by a single office,
however, the blueprint should be a more concise document that
briefly documents what analytical support will be completed.
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RD 12
A key way to improve the support for Agency activities is
to enhance its outreach to external groups. Particular areas
where this outreach could greatly benefit the Agency is by
identifying key constituencies, gathering data, garnering
political support and evaluating implementability. Therefore,
the appropriate level of external involvement should be
considered early on and included in the analytic blueprint.
EPA must also improve the quality of data and analysis
upon which regulations are developed by ensuring that the
process involves the identification, formulation and selection
among, feasible options. Innovative approaches such as
market-based incentives and other non-traditional (i.e.,
approaches other than command-and-control) should be promoted
and evaluated whenever possible.
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RD 13
Recommendation 3
EPA must strengthen workgroup operations and management of
specific regulations by:
clarifying the roles and responsibilities of workgroup
chairs and members;
providing a clear set of expectations for workgroup
members with commensurate recognition and rewards;
enhancing the skills of workgroup chairs and members;
assigning facilitators, as appropriate; and
creating and implementing a systematic dispute resolution
process.
Workgroup members are responsible for contributing to the
development of a quality rulenot solely monitoring and
critiquing the work of others. Chairs and members must be
selected for their knowledge, skills, and experience related
to the effort at hand and work as a team. Members of the team
must have a clear understanding of their role and be accepting
of the different perspectives other members bring to
rulemakings. Workgroup chairs and members should also be
rewarded for identifying and raising major policy issues to
senior managers in a timely manner rather than trying to reach
an artificial consensus or coming in with "late hits" at the
end of the process.
The Agency must support its workgroups by providing the
training and fulfilling the other needs to build workgroup
skills and promote a healthy workgroup process. Appropriate
recognition for workgroup participation must be provided to
"elevate" the importance of activity. Management oversight
must also be made a higher priority throughout the process.
For controversial or complex rules, the Agency should
provide facilitators to improve the workgroup process. The
role of the facilitator will be to ensure that there is an
open process that creates the opportunity for active
involvement of key players, consideration of all perspectives,
and steady progress toward completion.
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RD 14
An effective workgroup process also needs a clearly
understood dispute resolution process. Rather than having
disagreements result in endless delays, the workgroup needs to
have access to an efficient and effective process to resolve
issues up through the chain of command.
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RD 15
Recommendation 4
EPA must continuously evaluate and improve the process by:
identifying and collecting data on the effectiveness of
the process;
improving the process as soon as problems arise.
Because there is limited data available on the
performance of the regulation development process or on
customer satisfaction, this redesign of the regulation
development process had to rely largely on its own data
collection activities. The Agency must identify key
performance measures (e.g., analytic plan was developed and
implemented; feasible alternatives were identified and
evaluated; timeliness of dispute resolution, rules steadily
progress towards completion) of the new system and routinely
collect this information. Without such data, EPA will not
have the data readily at hand to diagnose and correct process
problems when they first occur. Timely access to senior
management to approve and implement improvements must also be
afforded.
Data collection methods that should be considered are:
routine, broad-based surveys of all workgroup participants and
managers; targeted surveys and interviews covering a limited
set of rules; field evaluation of selected stakeholders, both
within and outside of EPA; and continuous data collection by a
centralized office.
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Recommendation 5
EPA must develop a process to manage non-regulatory activities
Non-regulatory programs, legislation, and policy guidance
increasingly play an important role in EPA's overall efforts
yet these products are produced in an ad hoc basis. The
quality of these types of activities can be improved by
implementing a process that makes efficient use of EPA
resources, staff expertise across the Agency, and reflects
stakeholder needs. This process need not be the same as the
one used for regulations, but should reflect the same
principles of tiering, appropriate cross-agency and senior
management involvement, and early planning and scoping.
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RD 17
IV. COSTS AND BENEFITS
The costs of not implementing the recommended changes in
the regulation development process are great. There is
widespread frustration with the current process and it is
generally viewed as "broken." Lead program offices waste time
by routinely acquiring case-by-case exceptions from the
process, major cross-cutting policy decisions are imbedded in
single-media regulations and debated time and time again in
each regulation rather than addressed comprehensively,
significant delays result over debates on the analytic support
developedor not developedat the end of the process,
disputes often remain unresolved until it is too late to
incorporate decisions into the regulation, and staff and
managers in the process are not rewarded for their
participation.
In the short-term, the effort required to implement the
new process will be substantial. Offices will be expected to
dedicate FTE equivalent resources to develop detailed process
requirements. Managers will need to find time to fix problems
with rules too far along to benefit from the improvements
recommended here while increasingly turning their attention to
rules earlier in development to provide the guidance and
direction needed to build in quality throughout the process.
As the new process is implemented, however, the
frustration associated with the current process will
dissipate. Tiering will reduce the administrative burden
associated with having to get case-by-case exemptions, the
scope of Agency's resources on a given regulation will be more
commensurate with the scope of the problem EPA is addressing,
fewer delays in regulations will occur as issues are raised
and resolved in a timely manner, and the analytic support for
the Agency's decisions will be stronger since it will have
been planned and thoroughly considered early in the process.
Managers will spend more time providing policy guidance
direction up front rather than trying to fix crises at the end
of the process. Finally, when problems in the process do
occurwhich they willthe Agency will have adequate data to
quickly recognize, diagnose and correct the problem before it
gets out of hand.
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RD 18
V. NEXT STEPS
Fall 1993 provides a unique opportunity to implement
needed changes to the regulatory development process; career
staff are anxious for change, new management is coming on
board and EPA is forging a new relationship with the Office of
Management and Budget. With this in mind, the Regulation
Development Team is moving forward to implement these
recommendations.
Establishment of an Implementation Team
An intra-agency implementation staff is being chartered
by the Administrator to develop a detailed set of procedures
that implement the recommendations outlined in this report.
Full implementation of the process is expected to be completed
by January 1, 1994. Deputy Administrator Sussman will oversee
the implementation process and the Team will be led by Wendy
Cleland-Hamnett and Maryann Froehlich of OPPE. Each of the
key program offices will be asked to provide dedicated staff,
with adequate experience in regulation development, to assist
in implementation. In addition, program offices will be
expected to make other staff available to participate on
process design teams. These design teams will work over the
next four months and focus on particular recommendations
discussed in this report including: strengthening workgroup
operations, specific process elements such as the analytic
blueprint, and expanding external involvement. Design teams
will be expected to complete their work by December 1, 1993.
A memorandum announcing formation of the Implementation
Team and a call letter asking program offices to "tier"
regulations will be sent out in August. The Regulatory
Development Team will continue to provide guidance and
direction for the Implementation Team.
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VII. SUPPORTING MATERIALS
To guide implementation of its recommendations, the
Regulatory Development Team has developed the following
materials. These materials provide the context and the
recommended framework for an improved regulatory and policy
development process and include:
"Draft Findings, Problems in Regulation Development,"
December 7, 1992
Summary of data gathered from focus group, interviews,
and other communication with persons involved in
regulation developmentinternal and external to EPA;
"Flow-Charting the Regulation Development Process
Initial Findings," September 29, 1992
Provides general flow charts of how regulations are
developed in media offices and presents findings drawn
from these charts;
"Establishing a Baseline for Evaluating Future
Performance of a Reinvented Rulemaking," February 11,
1993
Discusses why evaluation is important and discusses
various evaluation options;
Guiding Principles/Conclusions
Provides overall themes for development of a new
regulation development process;
Workgroup Operations
Discusses ways of improving the operation and management
of workgroups;
Suggestions on Dispute Resolution
Presents ideas on a mechanism to resolving policy
disputes between offices;
Suggestions on Process for Cross-Agency Policy Decisions
Presents a mechanism for managing major non-regulatory
policy issues and programs;
Alternatives Selection Process
Discusses the goals and a mechanism for identifying,
analyzing and considering reasonable policy alternatives;
Early Guidance/Scoping
Presents the notion of early policy guidance and scoping
of issues;
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What Approaches do Federal Agencies use to Develop
Regulations and Policy?
Summarizes several regulation development "models" used
by Federal Agencies based on information presented in
Reinventing Rationality. The Role of Regulatory Analysis
in the Federal Bureaucracy by Thomas O. McGarity.
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RD 21
VII. REFERENCES
Because limited data existed on the current system, the
Team's data collection strategy included reaching out to as
many regulation development process "customers" as possible.
Team members consulted with over 200 Agency staff to obtain
information related to "program" experiences (i.e., air,
water, research, etc) and "position" perspectives (senior
management, workgroup chair, workgroup member, etc.) and with
over 60 representatives from OMB, industry and environmental
groups. In addition to talking to people, Team members drew
upon information from previously conducted evaluations,
relevant literature and Agency knowledge of other federal and
state rulemaking processes. Data developed during this
process include:
summaries of cross-Agency focus groups of workgroup
members, workgroup chairs, and mid-managers;
summaries of DAA/DRA focus groups;
summaries of interviews with Assistant Administrators for
OAR, ORD, OSWER, OPPE, OW, and OPPTS;
summaries of focus groups/interviews with staff within
OAR, OW, OPPTS, OSWER, OPPE, OGC, OE, and regional
offices; and
summaries of focus groups/interviews of external groups
including OMB, local governments, environmental groups,
and industry groups.
Additional major references used by the Regulatory
Development Team included:
The Cadmus Group, A Study of Rulemaking Procedures in
Regulatory Agencies. Draft Report Prepared for the EPA
Regulatory Development Branch, September 29, 1989.
Thomas O. McGarity, "The Internal Structure of EPA
Rulemaking", Law and Contemporary Problems. Vol 54:No. 4,
1991.
Clean Air Act Implementation Task Force, "Report to the
Deputy Administrator," July 1990.
Cornelius M. Kerwin, "The Management of Rulemaking,"
draft manuscript, 1992.
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REPORT OF THE
WORKFORCE CAPACITY
TEAM
NATIONAL
PERFORMANCE
REVIEW
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we
PREPARED BY:
GEORGIANNA BISHOP (CHAIR), Region 1
JEULI BARTENSTEIN (CO-CHAIR), OHRM
LISA ALMODOVAR, OW
CYNTHIA BASS, OHRM
JOHN BEIER, OPPTS
MARY BELEFSKI, OW
EILEEN BURROWS, Region 3
ANGELA CARSON, OSWER
BERNADETTE CHAN, OSWER
ANTHONY ERB, OAR
ELOISE FURBUSH, OE
FRANKLIN GEE, OPPTS
MARIAN HESS, Region 7
MARY JACANIN, OSWER
PATRICIA LYTTLE, OPPE
LOIS MARSHALL, OPPTS
BETTY MOBLEY, OGC
KEVIN PERRY, OW
HOLLY PUGLIESE, OAR
MARY ROGERS, Region 8
DENISE ROY, OSWER
SHRUTI SANGHAVI, OPPTS
MARION KELLY THOMPSON, OW
ART SANDOVAL, ORD
Special thanks: To the Office of Underground
Storage Tanks, the EPA Training Institute,
particularly Virginia Rheinhardt, and the Region I
EPA Human Resources Development Staff,
particularly Carol Krasauskis, Brenda Biondi, and
Jennifer Luckett.
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WC 2
I. EXECUTIVE SUMMARY
"Learning is not a task or a problem it is a way to be in
the world." Sidney Jourard
The capacity of the EPA work force to carry out our
strategic priorities is the first implicit goal of the
Agency before all other goals can be reached. Assessing and
developing work force capacity must become an explicit goal.
We want to change our culture to one in which learning is
part of the way we do our environmental work every day.
Our vision is to recreate EPA's culture to that of a
learning organization, which implies a work community in
which individuals anticipate the results of their actions
and look for creative, long-term solutions to environmental
and operational problems; they are empowered to learn in
pursuit of the Agency's mission. Building work force
capacity through proactive learning goes far beyond a
traditional view of training and career development. It
requires our work force to develop a new perspective and new
skills; it requires alignment between individual competency
and organizational competency; it requires a management team
which reflects and acts on a new set of organizational
values.
The five target action areas we have explored, and the
related recommendations, are the building blocks of cultural
change. Each is dependent upon the existence and stability
of the other, and cannot be disengaged, one from the next.
If we choose to address some, and not all, we will risk
reducing the changes to cosmetic rather than systemic and
cultural.
CREATE AN ORGANIZATIONAL CULTURE TO SUPPORT LEARNING AND
GROWTH
*Flatten management hierarchy
*Develop ongoing feedback systems
*Provide models of excellence
BUILD MANAGEMENT CAPACITY TO DEVELOP STAFF
*Change management selection criteria
*Improve and expand management training
*Build "360-degree" feedback systems
*Reassign managers with negative reviews
ENGENDER INDIVIDUAL OWNERSHIP
*Provide centers and systems for self-assessment
*Provide information on professional competencies
*Link individual competency development to budget
process
DEVELOP ORGANIZATIONAL SYSTEMS AND PARTNERSHIPS TO ENSURE
ALIGNMENT OF WORK FORCE CAPACITY WITH AGENCY NEEDS
*Strategically plan for human resources
*Restructure resource allocations
*Build career matrix
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WC 3
DEVELOP "TECHNOLOGY TOOLS" TO SUPPORT LEARNING AND
PERFORMANCE
*Design a work force capacity network
*Create Learning Information and Performance Support
System
Our vision of a learning organization demands powerful
leadership, tremendous awareness and compassion for the
fundamental changes these proposals bring to our existing
work force.
II. THE VISION
The capacity of the EPA work force to carry out our
strategic priorities is the first implicit goal of the
Agency before all other goals can be reached. Assessing and
developing work force capacity must become an explicit goal.
In order to address the challenges we face in the next
century, which will be characterized by their complexity and
interrelationship with other environmental and societal
issues, we need to learn more and share more of what we
learn in an integrated way. We want to change our culture
to one in which learning is part of the way we do our
environmental work every day.
Our goal is to recreate EPA's culture to that of a
learning organization, which implies a work community in
which individuals anticipate the results of their actions
and look for creative, long-term solutions to environmental
and operational problems; they are empowered to learn in
pursuit of the Agency's mission. Employees in a learning
organization share a common vision of the future; apply a
systems approach to their work; develop themselves to attain
mastery, both in subject and process; and are team players,
committed to coordinated action and group learning.
Building work force capacity through proactive learning goes
far beyond a traditional view of training and career
development. It requires our work force to develop a new
perspective and new skills; it requires alignment between
individual competency and organizational competency; it
requires a management team which reflects and acts on a new
set of organizational values.
This new, and broader, perspective looks beyond
programs and media, jurisdictions and areas of technical
expertise, to long-term systemic solutions. The ability to
pool the collective expertise of the Agency is key to
developing this perspective. As an organization, we need to
explore emerging technologies to communicate and share
information rapidly, and to help us learn from our mistakes.
The technology itself is driving fundamental change. We
need to direct it and guide it, or it will become an
obstacle rather than a vehicle to becoming a learning
organization.
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The culture we envision is one in which our leaders and
employees value growth and learning as the foundation of the
Agency's environmental mission, not as separate from, or
competing with the "real work." Our management team is
selected, promoted, and valued for their willingness to
develop staff as their highest priority. Our staff is
selected and valued for their willingness to learn and
initiate their own continuous growth. All organizational
systems are aligned to ensure that EPA's mission and goals
are inextricably linked to the capacity of the work force to
carry them out. Work force capacity and strategic planning
are interdependent and are coupled from the outset. The
Agency's learning experts are consultants to the planning
and budgeting processes. All employees have access to
consistent learning, information, and performance support
systems through state-of-the-art technology.
The five target action areas we have explored are the
building blocks of cultural change. Each is dependent upon
the existence and stability of the other, and cannot be
disengaged, one from the next. To address some, and not
all, risks reducing the changes to cosmetic rather than
systemic and cultural.
Our vision of a learning organization demands powerful
leadership, tremendous awareness, and compassion for the
fundamental changes these proposals bring to our existing
work force. Our employees are very adept at adjusting to
programmatic or strategic redirections. However, they are
rarely faced with having to redefine their work, their view
of themselves, and their competencies in terms of the growth
and direction of the organization. These proposals require
a careful and thoughtful approach to managing comprehensive
change in a tenured work force. All employees, in every
type of job, will need the psychological protection provided
through safe opportunities to relearn and practice,
experiment and fail, grow and change.
III. TARGET/ACTION CATEGORIES
1) Change the Agency culture to one which encourages
people to learn and develop in ways which support EPA's
goals and engenders desired organizational behaviors and
values. We envision a culture where learning is on-going
and supported systemically. Healthy organizational behaviors
exist that foster growth and create an environment of
respect for the individual, where honesty, trust,
leadership, empowerment, encouragement, and fairness are
inherent organizational values.
2) Select, promote, and reward managers based on their
capacity and willingness to develop their staff. Their
efforts enhance the professional development of their staff
by providing, for example, coaching, mentoring, ongoing
feedback and overall support for each individual.
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3) Promote individual ownership of professional
development through a personal competency plan which
incorporates a self-assessment. The individual employee
takes the initiative to find opportunities for growth.
4) Design Agency-wide systems to ensure alignment of:
professional development with the EPA mission and goals;
present work force skills with future organizational needs;
management capacity to develop staff with employee
initiative.
5) Provide all employees with consistent, "just in time"
access to learning systems, information systems and
performance support systems through state-of-the-art
technology.
Our specific recommendations will affect the entire EPA work
force in many ways and will also impact recommendations in
several of the other National Performance Review reports.
The reports with the most obvious overlaps or impacts are :
Management/Leadership Development, Performance Management,
Awards and Recognition, Quality Management, Quality Science
and Intergovernmental Partnerships.
IV. INITIATIVES (DO-ABLES)
ACTION CATEGORY 1: CREATE AN ORGANIZATIONAL CULTURE TO
SUPPORT LEARNING AND GROWTH
RECOMMENDATION 1A: FLATTEN MANAGEMENT HIERARCHY
The Agency needs to eliminate levels of management to
provide greater opportunities for growth, learning and
efficiency at the staff level. Shifting responsibility for
the productivity and quality of the work to the lowest
possible organizational levels expands the opportunities for
learning, creates flexibility and focuses energy at the
levels where work products are best conceived and produced.
SPECIFIC ACTIONS: Immediate steps should be taken to freeze
hiring into all management positions. A thorough review of
existing or projected management vacancies should be
undertaken to potentially eliminate the position or extend
the span of control. The agency should begin by assessing
the need for layers of management between the first-line of
supervision and the senior management level. Reorganization
may or may not be the obvious outcome of the delayering.
The process will, however, result in new roles and
responsibilities, greater spans of control, and different
ratios at the existing management levels. The Agency should
use all reasonable methods to flatten the management
hierarchy and provide real growth opportunities for managers
who wish to remain with EPA in non-managerial positions.
All reasonable methods should be utilized such as early out
programs, reassignment, reorganization, career counseling
services and learning opportunities.
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WHO IS RESPONSIBLE: The EPA Administrator and the Deputy
Administrator are ultimately the only people who can be
responsible for reorganizing the management hierarchy of
EPA. Their personal values regarding diversity and
supporting individuals throughout the change process will
establish the tone and ultimate success of the redesign.
TIMELINE: Reorganizing of the management hierarchy at EPA
can begin immediately, but real agency-wide change could
take three years.
BENEFITS: A flattened organizational structure will improve
and expand growth opportunities for all employees. There is
tremendous potential and a real need for empowerment and
flexibility at the staff level where the work is done.
Managers and employees will feel greater personal
flexibility as movement into and out of management positions
becomes routine and acceptable. The focus of our work can
be directed towards the customer and the work product and
less on servicing the management hierarchy.
COSTS: The time and expertise of human resource specialists
throughout the agency to re-engineer and retrain the
existing management hierarchy will initially be significant.
There will be financial costs associated with lump sum
payments and early out incentives. The retention of high
quality performers who will move out of management positions
will require the time of human resources specialists to
assist in relocation and retraining as needed. All
employees will need to become more skilled at working in
self-directed teams where responsibility for work products
is shared.
EVALUATION MEASURES: To truly measure progress in the re-
engineering of the management hierarchy, an accurate base-
line picture of the existing management structure is
necessary. Review of the changes in the hierarchical
structures should be monitored at the Administrator level
every quarter for the first 18 months and annually as part
of the on-going organizational review by the Administrator
and Deputy Administrator. There needs to be assurance that
senior managers at the local level are held accountable for
restructuring their individual organizations through their
performance standards. Using organizations such as
Department of Defense or any number of private sector
companies to benchmark our progress towards a more flattened
organizational structure is also an important method of
measurement.
BARRIERS: The existing civil service system with its linear
professions and classification standards are critical
barriers. The existing organizational hierarchy promotes
followership rather than stewardship. The managers
responsible for executing an organizational redesign have a
vested interest in the employees whose work functions may be
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in question. We presently reward the creation of larger
organizations and growth; this equates to survival and
longevity. Management resists investment in existing
employees and prefers to hire new employees and work around
people who need redirection and retraining.
ACTION CATEGORY 1: CREATE AN ORGANIZATIONAL CULTURE TO
SUPPORT LEARNING AND GROWTH
RECOMMENDATION IB: DEVELOP ONGOING FEEDBACK SYSTEMS
Develop organizational feedback systems to ensure that
feedback is comprehensive, both up and down as well as
lateral, with input from peers, partners and customers. The
focus of the feedback process should be organizational
behaviors which exhibit honesty, trust, ability to work on
teams, leadership, integrity, fairness, respect for the
individual, balancing work, and life issues.
SPECIFIC ACTIONS: Every EPA office, region, and laboratory
must use an organizational assessment tool to get feedback
from the employees, their partners (states, environmental
groups, etc.) and their customers (public). The instrument
should be consistent agency-wide and conducted once a year
for the first two years and then every 18 months (ongoing).
The survey must address the specific values and behaviors
(described above) which support a healthy, learning culture.
All employees, both managers and employees, should receive
specific feedback about their individual behaviors as they
relate to supporting a learning culture. Managers would be
reviewed by staff, peers and their supervisors. Staff would
be reviewed by peers and their supervisors. The survey
instrument should be used agency-wide and simple to complete
with the same focus on behaviors such as honesty, respect
for others, trust, leadership, fairness, integrity, team
skills, etc. The behaviors affecting the work environment
and the capacity of employees to grow and learn should be
treated as seriously as the intellectual skills needed to
produce quality work products.
WHO IS RESPONSIBLE: Changing the organizational culture
through honest feedback around values and behaviors must be
driven from the highest level (Administrator and Deputy).
We have organizations where attempts at getting this type of
organizational and individual feedback have been successful;
but, in general, it is inconsistent and not value-oriented.
TIMELINE: The design and use of organizational and
individual assessment instruments could be done within six
months. Coaching managers and employees on how to give and
receive feedback effectively may take six months to a year.
BENEFITS: The benefits would be constant feedback on how we
need to redirect and realign our course to create an
organizational learning ethic. The potential to assure
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alignment between the organizational values and individual
behavior will create a more productive and less stressful
work environment.
COSTS: The primary costs will involve the time to design
the organizational and individual survey tools. The
implementation will involve a great deal of initial
investment on the part of human resources development
specialists to communicate the use of the assessment
instruments, coach people on how to share feedback
effectively, conduct the survey and analyze the data. Work
also needs to be done at the local and national levels with
the labor unions.
EVALUATION MEASURES: To assure that the assessment systems
are in place and being used effectively, form random focus
groups throughout the country after each assessment cycle.
Focus groups should be led by a headquarters team. The
initial surveys and their results will serve as baseline
data to show improvement over time.
BARRIERS: Many of the existing organizational systems,
i.e., position descriptions, performance appraisals, etc.,
have a "mythical" quality. They don't really reflect
reality. It will be difficult to get buy-in to a new system
because of the existing cynicism. People will be afraid of
the exposure from this type of assessment. There may also
be ethical and legal problems. People are not used to
getting this type of feedback and most people have
difficulty giving or receiving feedback. There is no real
belief in amnesty.
ACTION CATEGORY 1: CREATE AN ORGANIZATIONAL CULTURE TO
SUPPORT LEARNING AND GROWTH
RECOMMENDATION 1C: PROVIDE MODELS OF EXCELLENCE
SPECIFIC ACTIONS: All employees, particularly the
organizational leaders, need to be exposed to models where
people see a better way to behave around the ideal behaviors
which foster a learning environment. Centers of excellence
need to be created within the agency. We should look for
managers and employees who truly behave in ways that promote
growth and learning. Model organizations need to be
supported and publicized. Employees should be encouraged to
rotate into these model organizations. Excellent performers
could be paired with those who need exposure to different
ways of behaving. Training should be provided that is
specifically geared to help people see themselves through
the eyes of others. This will help people to get the
feedback they need with the help of trained professionals.
Examples of training that are geared to the behaviors that
are critical to creating a learning ethic are: The Looking
Glass course, Covey's 7 Habits, The National Training Lab's
course, Myers-Briggs Workshops, American Managements'
Executive Effectiveness course, etc.
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WHO IS RESPONSIBLE: Learning through exposure to training
or excellent models becomes the responsibility of each
individual, their supervisor, and the human resources
development specialists or learning specialists who
essentially broker the opportunities. Managers,
particularly, need to support and encourage their employees
as they attempt to learn or improve their behaviors and work
performance.
TIMELINE: This is an on-going process; however, immediate
attention can be focused on the need for leaders to assess
themselves in light of a new organizational value system.
All employees should begin immediately to assess their
abilities as learners as well as their capacity to encourage
and support others as learners.
BENEFITS: Exposure to excellent models and training provide
people with the tools and opportunities to change their
behaviors. The possibility of changing the EPA culture to
one which values growth and learning is only possible if
employees are given what they need to make the change.
COSTS: The costs are very real with many of the suggested
training courses costing $500.00 - $1200.00 per person.
Rotational or coaching opportunities often involve time and
travel expenditures. There will also be in-house overhead
expenditures for some of the training to be offered in-
house.
EVALUATION MEASURES: Conduct follow-up interviews with
people four weeks and eight weeks after they have taken a
training course or returned from a coaching experience.
Make sure that the supervisor and the employee have a
conversation about their expectations before the employee
takes the training or goes on the assignment. This
preparatory discussion has proven to have the most
significant impact on the learner's retention and behavior
change when they return to the workplace.
BARRIERS: Employees rarely experience any interchange with
their supervisors before a learning experience or after.
The present organizational ethic rarely connects a learning
experience to any actual results or expectations for change.
Employees are often not acknowledged nor given more
opportunities to use their new skills when they return to
the workplace. The major complaint for most learners is the
lack of resources, both travel and training dollars, which
are limited particularly for those who want intermediate-
and senior-level skills training or experiences.
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ACTION CATEGORY 2: MANAGEMENT (LEADERSHIP) CAPACITY TO
DEVELOP STAFF
RECOMMENDATION 2A: SELECT AND RETAIN MANAGERS/LEADERS BASED
ON THEIR CAPACITY TO DEVELOP STAFF
The criteria for the selection of individuals into the
leadership corps must include examples of their capacity for
coaching, mentoring, motivating and developing people.
Individuals selected into the corps would be required to
take formal training in fields related to human development.
As an integral part of the selection process, selected
candidates would serve an 18-month probationary period. At
the end of the first nine months, their performance would be
evaluated by superiors as well as subordinates.
SPECIFIC ACTIONS: The agency should develop standard
quality ranking factors for leadership positions with
significant weight placed on the applicant's capacity for
coaching, mentoring, motivating and developing.
Candidates for leadership positions would be required to
submit as part of their application package at least four or
five written recommendations from peers, addressing the
candidates capacity for coaching, mentoring, motivating and
developing. The recommendations would be submitted directly
to the Human Resource Office to ensure confidentiality and
heavily weighted in the selection process.
Leadership candidates would serve probationary periods with
each new position and with every promotion to a new level of
management.
WHO IS RESPONSIBLE: A team comprised of Human Resource
Office professionals, line managers and staff members would
develop a well defined selection process which would include
quality ranking factors, application criteria and
probationary assessment procedures.
TIMELINE: One week of devoted time to develop a pilot for a
selected organization would be necessary. An additional
week of devoted time would be needed for the teams to
develop a model process.
Eighteen months would be needed to pilot the process in the
selected organization and to evaluate its progress.
BENEFITS: The most significant benefits would be the
creation of a more productive and energized work force where
continuous growth and learning is valued. This may result
in less turnover and a more motivated work force.
COSTS: The primary costs would involve the development of
the selection criteria and the time involved in peer
submissions and review. Additional coaching and feedback
for those who were not selected would be critical.
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EVALUATION MEASURES: Randomly audit all EPA offices, labs
and locations to assure that their selection criteria and
process includes the recommended actions above. Review peer
assessments of selected candidates as well as the nine-month
assessments of selected managers by their employees. These
audits should be consistent and ongoing to assure that real
change is in progress.
BARRIERS: The present selection process places heavy
emphasis on whether you are liked by the selecting official
and your technical expertise. Little or no emphasis is
placed on your ability to grow and learn (role model) nor
whether you can develop staff. There is a lack of internal
role models for managers and supervisors to learn from.
When managers don't succeed, we send them to training when,
in fact, they may lack both the commitment and capacity.
ACTION CATEGORY 2: MANAGEMENT (LEADERSHIP) CAPACITY TO
DEVELOP STAFF
RECOMMENDATION 2B: PROVIDE ONGOING LOCAL MANAGEMENT
TRAINING WHICH INCLUDES SKILLS TRAINING
ON COACHING, MENTORING, ETC.
SPECIFIC ACTIONS: Create a high quality core curriculum for
the entire management/leadership corps with emphasis on
coaching, mentoring and human development skills. The
sessions should be practicums with feedback. These training
modules should be a part of a larger ongoing curriculum for
managers that would be available to them at their local
offices, regions or labs. The program should extend over a
period of time and involve skills that have direct practical
applications to the working environment.
WHO IS RESPONSIBLE: An experienced team of learning
specialists from the EPA Training Institute with members of
the leadership corps and staff should develop the training
modules for the agency. These modules should be targeted to
specific skills to help managers improve their coaching and
mentoring. The delivery of the training sessions would be
the responsibility of the EPA Training Institutes throughout
the country.
TIMELINE: One week of focused time would be necessary to
develop the training modules. It would take one year to
test and evaluate the pilot.
BENEFITS: Managers/leaders will potentially be able to
facilitate the growth and capacity of their staff as a
continuous process.
COSTS: Time and expertise will be required at each office
and lab to maintain an ongoing training program available to
all managers/leaders. In addition, for those Training
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Institutes who already offer an ongoing curriculum, they
will need to incorporate additional offerings related to
facilitating staff growth and development.
BARRIERS: The agency has never valued ongoing skills
training "just in time" for managers. The present offerings
at the national levels are two- or three-day awareness
courses which, in many cases, will be the only training a
supervisor will receive. Many attempts have been made to
change this approach but few organizations have made the
commitment necessary. Management training is seen as an
event and not an ongoing part of a leader's professional
growth. The leaders are often not role models for their
staff and do not take their own development seriously.
EVALUATION MEASURES: Randomly sit in on training offerings
at local Training Institutes. Send experienced human
resources development specialists to give feedback to local
Institutes on their management/leadership curricula. If
experienced specialists reviewed the course evaluations on a
routine basis, this would indicate that the courses were
being offered and indicate the quality of the offerings.
ACTION CATEGORY 2: MANAGEMENT (LEADERSHIP) CAPACITY TO
DEVELOP STAFF
RECOMMENDATION 2C: PROVIDE ANNUAL FEEDBACK ON THE
MANAGERS/LEADERS CAPACITY TO DEVELOP
STAFF
Managers/leaders need to receive ongoing feedback from
their staff on their coaching and mentoring skills. See our
Specific Actions IB for a complete description of this
feedback process.
ACTION CATEGORY 2: MANAGEMENT (LEADERSHIP) CAPACITY TO
DEVELOP STAFF
RECOMMENDATION 2D: REASSIGN TO NON-MANAGEMENT POSITIONS
AFTER CONSECUTIVE NEGATIVE STAFF REVIEWS
SPECIFIC ACTIONS: Managers should receive feedback from
their staff and their supervisors about their capacity to
develop staff; however, consecutive reviews which indicate a
mismatch with the necessary competencies should result in
reassignment to a non-managerial position. It is important
that opportunities to move into and out of management
positions be handled constructively. Many outstanding
technical experts find themselves in management positions
and they are inappropriately matched to the competencies of
the job. We would hope that thoughtful support for the
individual would assure their continuation with EPA in a
position that truly utilizes their skills and contributions.
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WHO IS RESPONSIBLE: The group with primary responsibility
would be the supervising manager in conjunction with the
human resources development staff who would oversee the
organizational and individual feedback systems described in
IB. Reassignment and counseling services could also be
handled by the entire human resources staff. A manager
could voluntarily opt out of the managerial profession;
however, an external peer review board would be the most
constructive way to determine if someone should be invited
out after reviewing two years of unsatisfactory feedback
results.
TIMELINE: We are recommending reassignment after
consecutive negative reviews. This would occur after two
years.
BENEFITS: Both managers and employees would understand that
the agency has a plan for moving employees who are not in
positions where they can be most effective. It is critical
for the agency to have a strategy, particularly for our
leadership positions which directly affect the productivity
and work of our employees. The benefits of this would be
greater productivity and the potential for greater job
satisfaction.
COSTS: Initially, time will be required to complete the
feedback surveys and counsel managers on the results.
Subsequent time investments might involve coaching,
counseling and training to help managers to improve their
skills. For managers moving out of the managerial
profession, counseling and retraining will also be required.
EVALUATION MEASURES: Offices, regions, and labs should be
audited to assure that management review panels are in
place. Follow-up interviews should be conducted with
managers who leave their managerial positions to assure that
counseling and support were provided. Reviews could be
conducted as part of the other audits that are recommended
throughout this report. The management review panels in
each office, region, and lab should also prepare annual
summary reports.
BARRIERS: The EPA culture perceives that anyone leaving a
management position has failed so the move is viewed as
punitive. Managers who truly take time to develop staff are
rare and often not reinforced for their behavior. We are
not successful at reassigning people to mutually
satisfactory new positions, particularly at the senior
management level.
ACTION CATEGORY 3: INDIVIDUAL OWNERSHIP
RECOMMENDATION 3A: PROVIDE CENTERS AND SYSTEMS FOR SELF
ASSESSMENT AND
CAREER INFORMATION
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SPECIFIC ACTIONS: The agency needs to create self-
development centers and systems to provide employees with
the opportunities to conduct self-assessments and gain
professional career information. The centers should be
linked to the existing network of Training Institutes and
self-learning centers. See Recommendation 5A for specific
systems examples. Professional human resources development
specialists trained in human development need to staff the
centers at each EPA location and office.
WHO IS RESPONSIBLE: The decision to provide employees with
both trained counselors and systems to support their career
growth is a senior management investment decision. The
existing human resources development offices would need to
be staffed appropriately to offer these opportunities to all
employees.
TIMELINE: With immediate commitment, this would take at
least two budget cycles to implement.
BENEFITS: Employees could self-direct their own
professional growth with the tools and professional
assistance available to them.
COSTS: Some of the EPA regions are developing self-learning
centers as part of their Training Institutes. These centers
are still relatively rare. To create or expand existing
centers, costs would include facilities/space, hardware,
software systems, professional counselors and initial
advertising.
EVALUATION MEASURES: Users of the development centers and
systems should be surveyed as they use them. This would
allow you to measure the level of usage and satisfaction.
A voice-mail feedback system might also be user friendly and
a good way of getting input on the quality of the services.
It is always helpful to use other successful organizations
with established career centers as a benchmark.
BARRIERS: Lack of resources and commitment have
consistently been the primary barriers to offering these
services. Most offices with professional counselors utilize
their resources to produce and deliver training. Offices
are understaffed in both the training and career counseling
areas. Providing meaningful counseling services usually
suffers as a result of the demand for training services.
ACTION CATEGORY 3: INDIVIDUAL OWNERSHIP
RECOMMENDATION 3B: PROVIDE INFORMATION ON COMPETENCIES
NEEDED FOR GROWTH IN A PROFESSION
SPECIFIC ACTIONS: Provide all EPA employees with up-to-date
information on the competencies required for growth in their
profession. This information needs to be linked directly to
the organizational strategic directions and our customers'
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needs. The speed of change requires us to create an on-line
system that would be designed around the competencies
required within professional families. See Recommendation
5A for complete description.
ACTION CATEGORY 3: INDIVIDUAL OWNERSHIP
RECOMMENDATION 3C: LINK INDIVIDUAL COMPETENCY DEVELOPMENT
TO THE LOCAL BUDGET PROCESS. UPDATE
ONCE A YEAR.
SPECIFIC ACTIONS: Individual competency development
planning and the local (region, lab, office) budget planning
process need to be connected annually. Local budget
planning is ad hoc and handled very differently at each EPA
location which affects the local training and development
allocations for each year. In addition, the individual
competency plans should be updated at least once a year at
the mid-year review and possibly again six months later.
WHO IS RESPONSIBLE: The importance of funding and
supporting employees' competency needs must be a clear
message from the Administrator to each of the RAs, AAs and
lab directors. The timing of the competency development
plans and the local budget planning should be strategic.
Work needs to be coordinated between the local senior
managers, the comptroller's office, and the human resources
development staffs to assure linkage and appropriate
funding.
TIMELINE: Local budget planning usually occurs in the
fourth quarter for the following fiscal year. The next
budget that could be affected would be FY'95 during the
spring and summer of 1994.
BENEFITS: Employees would understand that the agency truly
valued their planning process and supports their development
needs. The training and development budgets would be more
directly linked to real employee development needs.
COSTS: There are no consistent organizational systems to
assess employee training and development needs. Few if any
of the existing assessments are linked to the strategic
goals; most are programmatically linked. Without a
comprehensive integrated assessment process, cost estimates
are not possible. Time will be required to update the
competency plans. These will be on-line so the time
involved should be minimal.
EVALUATION MEASURES: When budgets are formulated at the
macro level (two years in advance) and at the local levels,
learning specialists (human resources development
specialists) need to be involved in the planning.
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We will have succeeded if EPA integrates its learning
specialists into preparing the work force with each new
initiative, legislation, administration, and policy or
technology. Senior managers should be routinely asked by
the Administrator and Deputy Administrator how they will
make the linkage between work force capacity and their
organizational goals; what has changed in their assessment
of work force development needs; and how this is reflected
in their budgeting process.
BARRIERS: The present training and development budgets are
an afterthought and dependent on what was budgeted the year
before or what is left over. The individual competency
planning presently known as IDPS are not done consistently
and often never completed. For the most part, neither
managers nor employers take them seriously.
ACTION CATEGORY 4: DEVELOP ORGANIZATIONAL SYSTEMS AND
PARTNERSHIPS TO ENSURE ALIGNMENT OF WORK
FORCE CAPACITY WITH AGENCY NEEDS
RECOMMENDATION 4A: STRATEGIC PLAN FOR HUMAN RESOURCES
Our strategic planning process must include the means by
which the work is done: our work force capacity. In
planning for future challenges, we must also plan for and
create the capacity in our employees to understand,
anticipate, and adapt to these future demands. Learning and
strategic planning are not isolated activities; they are
interdependent and should be linked at the outset of the
process. The agency's learning experts need to be involved
and active in the process of setting EPA's strategic
direction to ensure that opportunities to learn are created
in the workplace, wherever, whenever and however needed, and
that human potential and motivation are considered in
long-term planning. A review of the agency's competency
database, as described in our Recommendation 5A, will be
included in this process. A strategic plan which includes
consideration of work force capacity will allow top agency
officials to make more complete decisions regarding not just
WHAT will be done, but also HOW it will be done what gaps
need to be filled or overlaps minimized in terms of
learning, competencies, succession, recruitment, management,
etc.
SPECIFIC ACTIONS: As many progressive corporations have
done, separate the function of developing work force
capacity and learning from the traditional personnel
operations function. In high-performance organizations,
this function resides at the top-most level (see Reference
section for specific citations). Write guidelines and begin
with the next strategic planning and budget formulation
cycles to identify competencies needed to do the work and
achieve the proposed results. Start building a list of
competencies by professional "families" and begin to
identify critical gaps.
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TIMELINE: This process could begin as early as the next
strategic planning and budget formulation cycle.
BENEFITS/COSTS: Strategic planning for human resources
makes development investments much more intentional and far
less reactive. Costs to implement the strategic planning
process are negligible, but the process results will require
a significant shift in how and where we invest our
resources.
EVALUATION MEASURES: Progress on this recommendation will
be clearly marked by the inclusion of work force capacity as
a critical item in formulating an office budget.
Organizational placement of the work force capacity
responsibility in the Administrator's Office will indicate a
change in the way the agency addresses work force
development.
BARRIERS: The most significant barrier to implementation of
this recommendation is the culture in which we currently
operate. Learning and development are not valued as the
"real work" of the Agency, and yet no work can be done
without it. A recent 0PM study found that only a quarter of
EPA's work force believes they need training, though 50
percent stated past training had improved their performance.
The same study found that 43 percent of EPA's work force
felt they were "too busy on the job" to attend training,
and 42 percent cited a lack of funds as reason for not
getting the training they need.
ACTION CATEGORY 4: DEVELOP ORGANIZATIONAL SYSTEMS AND
PARTNERSHIPS TO ENSURE ALIGNMENT OF WORK
FORCE CAPACITY WITH AGENCY NEEDS
RECOMMENDATION 4B: RESTRUCTURE RESOURCE ALLOCATIONS
We recommend a restructured approach to human and financial
resource allocation, which funds projects and priorities
rather than organizations and invests more in proven
successes than potential failures. Our present resource
allocation process results in individual organizational
budgets and the initiation of similar projects which creates
enormous redundancy and waste. For example, there are
currently 43 separate Training Institutes and initiatives
sponsored and funded by EPA, and we create more and more
chaos with every identified "problem area." It will also
provide the necessary support and impetus for employees to
grow in the direction of the agency's goals by eliminating
"tenured" positions and programs, broadening our cross-media
perspective, and focusing on measurable results.
SPECIFIC ACTIONS: Refer to EPA's Planning and Budgeting
NPR team and/or the government-wide Mission-Driven Budgeting
NPR team. This is neither a new theme nor is it exactly
within our subject area, but our team supports the concept
and validates it from a work force capacity perspective.
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BENEFITS/COSTS: Many key decisions made in the isolation
of a program office have systemwide consequences that
stretch over years and environmental consequences that
extend for decades. EPA's compartmentalization creates
redundancies of effort and product, sustains parochial
concerns, creates a high risk for surprises and alienation,
and misses too many opportunities for creative
problem-solving.
BARRIERS: The Congressional appropriations structure and
process is, perhaps, an insurmountable barrier.
ACTION CATEGORY 4: DEVELOP ORGANIZATIONAL SYSTEMS AND
PARTNERSHIPS TO ENSURE ALIGNMENT OF WORK
FORCE CAPACITY WITH AGENCY NEEDS
RECOMMENDATION 4C: BUILD CAREER MATRIX
Professional flexibility and ease of movement are paramount
to this recommendation. The career matrix is an alternative
to career ladders or dual career paths. We propose a system
which has a matrix orientation to career competencies and
development, such that, if depicted graphically, it
resembles a grid rather than a series of stovepipes
indicating growth as linear upward progression. There are
many ways to develop professionally, including lateral
movement, assuming different job types and categories,
building expert skills, broadening competencies. For
example, an individual should be able to move into
management positions if they want to and have the requisite
skills, but they also should be able to move out of
management positions as a choice: with grace and non-
punitively. Support staff positions without career options
for growth would cease to exist. Rather, we would develop
competency areas for administrative system managers,
logistical experts, etc. Leadership competencies are
developed for all employees, regardless of job type or
grade. The career matrix allows the individual freedom of
movement throughout the agency, based on competencies, and
allows the organization to locate people through
competencies rather than job classifications for short-term
work groups or long-term assignments. The ease of movement
may extend to other environmental partners states, other
federal agencies, related congressional committees.
SPECIFIC ACTIONS: Develop clear families of competencies.
Establish pay bands for flexibility. Create a
career-brokering system, both automated and a physical
place, where an individual can obtain information about
different competency families, career counseling, and
assistance.
TIMELINE: This is a long-term, iterative cultural change.
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BENEFITS/COSTS: This eliminates focus on individual
knowledge in isolation of the working environment and better
utilizes the full range of competencies of each individual.
EVALUATION MEASURES: Compile statistics on movement through
the agency. Survey the work force to determine areas of
satisfaction and dissatisfaction.
BARRIERS: The current personnel classification system is
the most significant barrier to this concept; it is the
antithesis of what we envision. Other barriers fall out
from the culture created by the Civil Service system: the
only way to grow is up, management is the only path to
"success," "I own my job" mentality, "I own my staff"
mentality, security that comes with inflexibility.
ACTION CATEGORY 5: DEVELOP "TECHNOLOGY TOOLS" TO SUPPORT
LEARNING AND PERFORMANCE
RECOMMENDATION 5A: WORK CAPACITY NETWORK
This is a multi-faceted, agency-wide system, accessible by
all employees, which links (at least) eight applications
related to work competencies. The "centerpiece" of the
system is a list of competencies, grouped by major job
families, needed to do the work required by the agency.
This is a dynamic list which expands, contracts, and changes
with agency priorities, customer needs, and expert
assessment. It is updated annually, in conjunction with the
strategic planning process. The next most critical element
of this system is the individual checklist against which all
employees self-assess their own competencies for their job
twice a year. Individual competencies may be developed
through work or life experience, individual study, or course
work, but must be demonstrable. These self-assessments are
validated by professional peers, customers, subordinates or
other team members, and supervisors. Once individual
competencies are validated, the information is stored in the
system.
In aggregate, the system will be able to track and show work
force competency gaps (creating opportunities for individual
development) and surpluses (indicating areas in which
individuals need to divest and so be able to update
different skills). In this way, employees have control of,
and can make choices about, their own development needs in
the direction of identified agency needs. Read and/or write
access is limited, based on the application or the private
nature of the information. IBM has a similar prototype
which the agency can learn from and use as a benchmark.
Some other applications/capabilities of this system include:
Competency Database allows searches and sorts based on
type and level of competency to create teams of employees
with desired skill mix for specific projects (e.g., select
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expert in groundwater testing AND good facilitation skills,
select all employees with base competency in Polish
language)
Individual Competency Development Plans a "reinvented"
version of the current IDP, more focused and in alignment
with the agency's priorities
Organizational Competency Development Plans
organizational versions of the above, used as part of the
strategic planning process
Electronic Bulletin Board accessible by all employees;
advertises permanent positions and temporary opportunities,
based on types and levels of competencies required
Electronic Catalogue of Computer-Based Training (CBT)
all on-line courses are linked to listed competencies and
level of proficiency (e.g., basic familiarity, expert, etc.)
upon successful completion
On-Line Registration for In-House Courses allows on-
line tracking, tallying, etc.
SPECIFIC ACTIONS: Start immediately building lists of
competency "families" by interviewing every program area and
special agency group (e.g., Women in Science and
Engineering, Secretarial Advisory Council, Human Resources
Council, Science Advisory Board, etc.). Research
prototypes, other than IBM, and establish partnerships with
critical functions like OIRM.
WHO IS RESPONSIBLE: This system needs to be run centrally
and at a high enough level to give credence and full
organizational support to the process. The process should
be managed by the agency's human resources development and
learning experts, with support from Information Resources
Management.
TIMELINE: This process could begin immediately;
implementation of the system would take three to five years.
Some organizations are already beginning to build local
systems.
BENEFITS/COSTS: EPA needs to cultivate a learning
organization in which individuals anticipate the results of
actions and look for creative, long-term solutions to
environmental and operational problems. This requires all
individuals to view their jobs expansively, to focus on
competency and performance, and be empowered to act. This
change in perspective begins with an investment in our work
force.
EVALUATION MEASURES: The best indicator of a viable
state-of-the-art system would be if private industry and
others use EPA's system as a benchmark model. On-line spot
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checks and surveys of the system to determine frequency of
use by employees could be used. Another measurable
indicator would be that 100% of employees (over time) are
updating their personal competencies on line twice per year
and the agency has a process in place for identifying
competencies based on mission and strategies.
BARRIERS: The current performance management system is a
barrier to implementation of this network which virtually
eliminates traditional performance reviews. Lack of
resources, both human and financial, will be a barrier to
set-up and maintenance.
ACTION CATEGORY 5: DEVELOP "TECHNOLOGY TOOLS" TO SUPPORT
LEARNING AND PERFORMANCE
RECOMMENDATION 5B: LIPSS (see Reinvention Lab Proposal)
(Attachment C)
A learning, information, and performance support system
(LIPSS) is a means of producing consistent, "just-in-time"
access to material needed to do a job. Every competency is
developed through learning, which can be defined as a change
in behavior. To do some tasks, real learning must take
place; for others, one requires supporting information, such
as reference books, data tables, or regulations. Many
tasks, however, need "support" tools so they can be
completed quickly and efficiently, like on-line form
templates, checklists of procedures, or boilerplate
language. These are the hallmarks of a LIPSS, and they can
be created to support aspects of every job.
SPECIFIC ACTIONS: EPA has a number of pieces of different
LIPS systems already, but they are disjointed, not widely
used, and not networked for general access. Our Reinvention
Lab proposal comes from this recommendation. It requires a
hardware and communications network, reaching all 42 EPA
facilities, to support applications designed for CD-ROM and
interactive video, networked databases, and expert systems.
Safety and health training is our recommendation for the
first LIPSS; contracts and grants management and other
competency areas will follow.
TIMELINE: The Safety and Health LIPSS (Attachment C) could
be operational within one year.
BENEFITS/COSTS: Benefits are more competency-driven,
appropriately targeted, cost-effective training which also
allows a "refresher" boost when needed. Savings will accrue
to the agency in travel costs and both direct and indirect
training costs. Employees have greater ownership of their
own development. Products will be a direct benefit to all
programs that have field personnel and will be directly
applicable to other federal, state, and local government
agencies and private sector firms.
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An estimated 1800 EPA employees are required to have health
and safety training annually, at a cost in excess of $1
million per year. EPA just awarded a $45 million contract
to provide health and safety training to federal and state
personnel. Development costs may be up to $3 million.
Capital costs are fixed and, once courseware is created, the
operating costs are low. If developed under a partnership
arrangement with a private sector cooperator, rents or
royalties payable to EPA could recoup some of the
expenditures. Two private firms have already inquired about
establishing such a partnership with EPA.
EVALUATION MEASURES: Pre- and post-competency tests can be
given and tracked on-line.
BARRIERS: There are regulatory barriers governing
acquisition of products and services, the Federal Technology
Transfer Act, OSHA and EPA series of health and safety rules
and regulations, EPA's internal rules and procedures
governing ADP equipment and software, and OSHA's hours-based
(not results-based) training requirement.
There are also cultural barriers. EPA is an information-
intensive agency which doesn't take the time to learn or use
its own resources. EPA has invested heavily in information
and data processing equipment, establishing Local Area
Networks, and placing computers on employees desks. Yet
there is no evidence that this investment has translated
itself into learning and, therefore, productivity gains.
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ATTACHMENTS
A. EPA Reports and Reference Documents
B. General Bibliography and References
C. Reinvention Lab Proposal
D. Names and Addresses of the Work Force Capacity
Work Group
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EPA Reports and Reference Documents
Environmental Law Institute. "Training for States: The EPA
Institute and Federal-State Training. (Draft Report)"
January 1988.
The Environmental Law Institute examined state training
needs and the organization of state training programs
for the EPA Institute in order to identify ways in
which a federal-state training partnership might be
developed. The study discusses the finding of the ELF
based on looking at eleven state programs and talking
with EPA and state officials.
National Academy of Public Administration. "Steps Toward a
Stable Future: An Assessment of the Budget and Personnel
Processes of the Environmental Protection Agency" May 1984.
This study is an assessment of EPA's personnel
management and budgeting systems in the summer of 1983
done at the request of William Ruckelshaus. The panel
conducted extensive interviews with EPA's top
leadership, agency employees, and outside experts. It
also administered a survey questionnaire to more than
one-tenth of EPA's employees. The finding,
conclusions, and recommendations of this study are
presented and discussed.
National Academy of Public Administration. "Steps Toward a
Stable Future II: A Progress Report on Human Resources
Management at the Environmental Protection Agency." August
1985.
This document is a progress report on the
implementation of the 1984 study "Steps to Stable
Future." It discusses the results of a 1985 survey and
compares it to the one done in 1984.
U.S. EPA. "The Impact of Technological Changes on the EPA
Work Force." June 1989. A report prepared for William
Reilly by the Human Resources Council.
This document looks at the changes technology has
brought to the work place and recommends what steps
should be taken to prepare for the future. The study
explores the impact of technology on the following
major areas: human resources management programs,
communications and information, space and facilities
planning, and the resource planning process.
U.S. EPA. "EPA Institute Advisory Committee Annual Report."
November 1991.
This report takes a holistic view of the agency
training activities and policy rather than a narrower
view of the institute's operations and delivery
functions. It also identifies responsibilities and
initiatives of the EPA Institute and the development of
an action plan called "Vision of Training at EPA."
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U.S. EPA. "Administrative Support Careers Management
System." November 1991. A report prepared by the National
Human Resources Council.
This document reflects the changes in traditional
secretarial and support roles. It provides
alternative career paths for administrative
support staff and specific examples of position
descriptions and implementation procedures.
U.S. EPA. "EPA Training Professionals' Symposium, Final
Report." September 1991. Prepared by Mary Fillmore.
This report begins by focusing on the accomplishment of
training professionals throughout the agency, followed
by a discussion of how training contributes to the EPA
mission. It also examines the organizational climate
and explores the supporting factors and obstructions to
implementing the "Curriculum of the Nineties" program.
U.S. EPA. A memorandum to Hank Habicht updating the
"Curriculum of the Nineties" core curriculum. April 1992.
This memo contains a summary outline of the "products"
produced by the EPA Institute as of April 1992 in
support of the "City Model" vision of training.
U.S. EPA. "Cultural Diversity Challenges for EPA: A
Strategy for Bold Action." November 1992.
This document discusses the findings of a Cultural
Diversity survey questionnaire that was administered to
all EPA employees in May 1990. Various human resource
issues were evaluated within the context of the survey
and an implementation strategy is proposed to improve
work force diversity.
U.S. EPA. "A Career Management System for EPA." (Contract
68-01-6925. JWK International Corporation) (February 25,
1986).
U.S. EPA. Task Analysis of Job Series 1301
(Physical/Environmental Scientist) and 1320
(Chemist)(Contract No. 68-01-6925. JWK International
Corporation) August 20, 1986.
U.S. EPA. ORD Policy and Procedures Manual for Promotion of
Scientist and Engineer to GS-14 and GS-15 Research,
Development and Expert Positions. September 11, 1989 memo
transmitted with attachment from Erich Bretthauer to ORD
Office Directors and Lab Directors.
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Career Ladders for ORD Scientific and Engineering Positions.
Handbook. 1985.
"Career Management Manual." Drafted by Bernie Unger. 1980.
Draft manual which proposed policy and structure needed for
a career management system within EPA.
"Charting Your Career in EPA: A Brochure for Employees on
Career Ladders and Paths." Draft, September 1990.
U.S. EPA. "Improving Career Opportunities for Scientists
and Engineers at EPA." Position paper presented by the
Women in Science and Engineering (WISE) Council of the
Environmental Protection Agency as an attachment to May 30,
1991 memorandum to F. Henry Habicht, Deputy Administrator.
U.S. EPA. "Mapping Career Paths at EPA." April 1992 (202-F-
92-001). Tool kit for career counselors and employees for
understanding careers within EPA. As a minimum the kit
includes two publications entitled, "Step One: Career
Planning Workbook- matching Your Skills, Abilities, and
Interests with EPA Needs," and Step Two: Finding Your Career
Direction."
U.S. EPA. ORD Science Management Career Track Project.
Memorandum from August - September 1992:
"Proposed Survey on Science Management Career Track
Project." Memo from Michael E. Cohen, E. H. Pechan &
Associates, Inc. to Walt Galloway, EMSL/Las Vegas and
Art Sandoval, HRO/Las Vegas, August 13, 1992.
"Proposed Detailed Survey on Science Management Career
Track Project." Memo from Linda K. Smith, Office of
Research Program Management (ORD) to Walt Galloway,
EMSL/Las Vegas and Art Sandoval, HRO/Las Vegas, August
26, 1992.
"Survey of Knowledge, Skills and Abilities (KSAs) for
Science Management Position Roles." Memo from Linda K.
Smith, Office of Research Program Management (ORD) to
Laboratory Focus Group Leaders.
U.S. EPA and U.S. Department of Labor. Environmental
Protection Careers Guidebook. 1980(7).
Joint publication explaining the various types of jobs
included in the field of environmental protection.
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BIBLIOGRAPHY
This bibliography is intended to provide the reader with a
list of references related to human resource planning and
career management. The format separates the references by
books and reports, and periodicals. Where appropriate, an
abstract of the reference is included.
Books and Reports
Bowers, David G. and Franklin, Jerome L. "Survey-Guided
Development: Using Human Resources Measurement in
Organizational Change," in Organization Development: Theory.
Practice and Research. (French et al, Editors). Richard D.
Irwin, Inc. Homewood, IL. 1989. p. 244-253.
Burack, Elmer H. "Why All the Confusion About Career
Planning?" in Career Management for the Individual and the
Organization (Jelinek, Editor). St. Clair Press, Chicago,
IL. 1979. p. 319-325.
Discusses similarities and differences of organization,
career planning, and individual career planning.
Carnevale, Anthony; Gainer, Leila J.; and Schultz, Eric.
Training the Technical Work Force. Jossey-Bass, Inc. San
Francisco, CA. 1990.
Cascio, Wayne F., Editor. Human Resource Planning Employment
and Placement. Bureau of National Affairs, Inc., Washington,
D.C. 1989. p. 2-205 - 2-235.
Craig, Robert L., Editor. Training and Development Handbook;
A Guide to Human Resource Development. McGraw-Hill Book Co.,
New York, NY. 1987.
Cummings, Thomas G. and Huse, Edgar F. Organization
Development and Change. West Publishing Company. St. Paul,
MN. 1989. p. 321-388.
DeSio, Robert W. "Engineers and Scientists," in Training and
Development Handbook: A Guide to Human Resource Development.
(Craig, Editor). McGraw-Hill Book Co., New York, NY. 1987.
p. 630-640.
Explains that science and engineering is an important
resource and asset. Discusses concept of half-life
phenomenon which is defined as technical obsolescence
of engineers and scientists. Thirty years ago the half
life for engineers was 12-14 years, now it is 2-3
years. Also reviews how to keep up with training and
concludes that future success depends on training and
education.
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Dunham, Randall B. "The Design of Jobs," in Organization
Development; Theory. Practice and Research, (French et al,
Editors). Richard D. Irwin, Inc. Homewood, IL. 1989. p. 320-
334.
Feldman, Daniel C. Managing Careers in Organizations. Scott,
Foresman and Co. Glenview, IL. 1988.
Ference, Thomas P. "The Career Plateau: Facing Up to Life at
the Middle," in Career Management for the Individual and the
Organization (Jelinek, Editor). St. Clair Press, Chicago,
IL. 1979. p. 175-180.
Reviews myths around careers, particularly that moving
up is the only way to a successful career. Looks at
realities in organizations.
Forrer, Stephen E. and Leibowitz, Zandy B. Using Computers
in Human Resources. Jossey-Bass, Inc. San Francisco, CA.
1991.
French, Wendell L.; Bell, Jr., Cecil H.; and Zawacki,
Robert, Editors. Organization Development; Theory. Practice
and Research. Richard D. Irwin, Inc. Homewood, IL. 1989. p.
139-146.
Golembiewski, Robert T. "Organization Development in Public
Agencies: Perspectives on Theory and Practice," in
Organization Development: Theory. Practice and Researchr
(French et al, Editors). Richard D.Irwin, Inc. Homewood, IL.
1989. p. 540-549.
Gutteridge, T.G. and Otte, Fred L. Organizational Career
Development; State of the Practice. American Society for
Training and Development. 1983. p. 6-12.
Hackman, J. Richard and Suttle, J. Lloyd. Improving Life At
Work; Behavioral Science Approaches to Organizational
Change. Goodyear Publishing Company, Inc. Santa Monica, CA.
1977.
Hackman, J. Richard; Lawler III, Edward E.; Porter, Lyman W.
(Editors). Perspectives on Behavior in Organizations.
McGraw-Hill Book Co., New York, NY. 1977.
Hall, Douglas T. and Morgan, Marilyn A. "Career Development
and Planning," in Career Management for the Individual and
the Organization (Jelinek, Editor). St. Clair Press,
Chicago, IL. 1979. p. 325-349.
Provides definition of careers and discusses obligation
of the individual and the organization with respect to
career development. Also reviews training needs within
various career stages.
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Harrison, Roger. "When Power Conflicts Trigger Team Spirit,"
in Organization Development: Theory. Practice and Research.
(French et al, Editors). Richard D. Irwin, Inc. Homewood,
IL. 1989. p. 210-218.
Jelinek, Mariann, Editor. Career Management for the
Individual and the Organization. St. Clair Press, Chicago,
IL. 1979.
Leibowitz, Zandy B.; Farren, Caela; and Kaye, Beverly L.
Designing Career Development Systems. Jossey-Bass, San
Francisco, CA. 1986.
London, Manuel, and Mone, Edward M. Career Management and
Survival in the Workplace; Helping Employees Make Tough
Career Decisions. Stay Motivated, and Reduce Career Stress.
Jossey-Bass, San Francisco, CA. 1987.
London, Manuel, and Mone, Edward M. (Editors). Career Growth
and Human Resource Strategies: The Role of the Human
Resource Professional in Employee Development. Quorum Books.
1988.
Mallory, W. J. "Technical Skills," in Training and
Development Handbook: A Guide to Human Resource Development.
(Craig, Editor). McGraw-Hill Book Co., New York, NY. 1987.
p. 641-658.
Reviews technical training issues within an
organization using a corporate point of view as opposed
to an educator or consultant point of view. Also
explains how to effectively involve existing work force
members as trainers.
McGregor, Jr., Eugene B. Strategic Management of Human
Knowledge, Skills, and Abilities. Jossey-Bass, Inc., San
Francisco, CA. 1991.
McMahon, John E. and Merman, Stephen K. "Career
Development," in Training and Development Handbook: A Guide
to Human Resource Development. (Craig, Editor). McGraw-Hill
Book Co., New York, NY. 1987. p. 756-770.
Provides basic definitions relating to the professional
area of career development. Discusses current state-
of-the-art tools for career development programs.
Explains the tools in the context of 1-0 relationships
(individual-organization). Career planning comparable
with growth and development, not just upward mobility.
Discusses five career planning criteria dialogue,
guidance, individual's involvement, feedback to
individual, and mechanisms by which the career planning
process operates.
Miller, Donald B. "Career Planning and Management in
Organizations," in Career Management for the Individual and
the Organization (Jelinek, Editor). St. Clair Press,
Chicago, IL. 1979. p. 353-360.
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Rogers, Thomas H. "Strategic Planning: A major OD
Intervention," in Organization Development: Theory. Practice
and Research. (French et al, Editors). Richard D. Irwin,
Inc. Homewood, IL. 1989. p. 200-202.
Roseman, Edward. Confronting Nonpromotability; How to Manage
a Stalled Career.. AMACOM, New York, NY. 1977. p. 3-18 and
220-238.
Senge, Peter. The Fifth Discipline, Doubleday, New York, New
York 1990.
Schein, Edgar H. "How Can Organizations Learn Faster? The
Challenge of Entering The Green Room" in Sloan Management
Review/ Winter 1993. p. 85-92.
Schein, Edgar H. Career Dynamics: Matching Individual and
Organizational Needs. Addison-Wesley Publishing Company.
Reading, MA. 1978. 276 p.
Shepard, Herbert A. "Life Planning," in Organization
Development; Theory. Practice and Research. (French et al,
Editors). Richard D. Irwin, Inc. Homewood, IL. 1989. p. 275-
281.
Staw, Barry M., and Cummings, L. L., Editors. Research in
Organizational Behavior (Volume 6). JAI Press, Greenwich,
CT. 1984.
Van Maanen, John, Editor. Organizational Careers: Some New
Perspectives. John Wiley and Sons, Ltd., New York, NY. 1977.
Varney, Glenn H. "Organization Development," in Training and
Development. Handbook; A Guide to Human Resource Development.
(Craig, Editor). McGraw-Hill Book Co., New York, NY. 1987.
p. 537-563.
Provides a concise overview of organization development
reviewing its history, definitions, and techniques and
skills needed by practitioners. Also provides a list
of universities and organizations involved with
organization development.
Wellbank, Harry L.; Hall, Douglas T.; Morgan, Marilyn A.;
and Hamner, W. Clay. "Planning Job Progression for Effective
Career Development and Human Resources Management," in
Career Management for the Individual and the Organization
(Jelinek, Editor). St. Clair Press, Chicago, IL. 1979. p.
361-369.
Discusses using job evaluation schemes for career
development, not just for compensation. Uses project
at Sears as an example.
Willis, Sherry L. and Dubin, Samuel S. (Editors).
Maintaining Professional Competence: Approaches to Career
Enhancement. Vitality and Success Throughout a Work Life.
Jossey-Bass, Inc., San Francisco, CA. 1990.
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Wurman, Richard Saul. Information Anxiety. Bantam Books, New
York, NY. 1989. p. 317.
Zaleznik, Abraham; D. Falton, Gene W.; and Barnes, Louis B.
(Editors). Orientation and Conflict in Career. Harvard
University, Boston, MA. 1970.
Zuboff, Shoshana. In The Age Of The Smart Machine. The
Future of Work and Power. Basic Books Inc., U.S.A. 1988
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Periodicals
(Includes review of Training and Development Journal from
12/87 to 12/90)
Burgower, Barbara. "Compensation: Sweetening the Lure of the
Lab," in Business Month. August 1990, Vl36n2, p. 76-77.
Cacioppe, Ron. "Bringing the Tribe Into the Bureaucracy," in
Training and Development Journal. December 1989. p. 70-74.
Discusses how modern organizations can learn by
studying the structure and interrelationships of early
societies or "tribal organizations."
Carew, Jack. "Four Steps to Selling Your Programs," in
Training and Development Journal. June 1989. p. 68-75.
Discusses how to present proposals and programs for
training to upper management.
Foster, Badi G.; Jackson, Gerald; Cross, William E.;Jackson,
Bailey; and Hardiman, Rita. "Workforce Diversity and
Business," in Training and Development Journal. April 1988.
p. 38-42.
Discusses how work force diversity affects competitive
abilities within organizations.
Goldstein,, Mark L. "Dual Career Ladders: Still Shaky but
Getting Better," in Industry Week. January 1, 1980, v230nl,
p. 57-60.
Hanamura, Steve. "Working with People Who Are Different," in
Training and Development Journal." June 1989. p. 110-114.
Discusses the needs of a diverse work force and how
trainers and human resource specialists can take the
lead at helping change an organization.
Hartenstein, Annette. "Building Integrated HRM Systems," in
Training and Development Journal. May 1988. p. 90-95.
Discusses changes needed in organization structure and
functions with respect to personnel management and
human resource management.
Karp, H. B., "HRD for Scientists: A Right-Brain Force Meets
a Left-Brain Object," in Training and Development Journal.
September 1990. p. 48-54.
Discusses reasons why scientists are skeptical and
resistant to management training.
Kimmerling, George F. "The Future of HRD," in Training and
Development Journal. June 1989. p. 46-55.
Discusses where organizations are headed in the 1990s
with respect to the organization structure and human
resource development activities.
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Leibowitz, Zandy B.; Farren, Caela; and Kaye, Beverly L.
"Career Gridlock," in Training and Development Journal.
April 1990. p. 29-35.
Discusses issue of "baby-boomer" generation of
employees now trying to make it to the top in
organizations to obtain career success. Reviews what
models and tools human resource professionals can use
to deal with this issue.
Mainiero, Lisa A. "Early Career Factors That Differentiate
Technical Management Careers from Technical Management
Careers," in Journal of Management. Winter 1986, v!2n4, p.
561-575.
McDermott, Lynda C. "Strategic Marketing For HRD," in
Training and Development Journal. June 1989. p. 65-67.
Discusses how HRD professionals can market their
services within an organization. Once considered
"unethical," marketing practices are new ways to
disseminate information.
Nickle, Blair Warman and Maddox, Robert C. "Fortysomething:
Helping Employees Through the Midlife Crisis," in Training
and Development Journal. December 1988. p. 49-51.
Discusses what midlife crisis means to an organization
and the individual. Explains how the issue can be
addressed through the human resource office.
Raelin, Joseph A. "Work Patterns in the Professional Life
Cycle," in Journal of Occupational Psychology. September
1985, v50n3, p. 177-187.
Schein, E. H. "The Individual, the Organization, and the
career: A Conceptual Scheme," in Journal of Applied
Behavioral Science, v7 1971, p. 401-426.
Scott, Cynthia D. and Jaffe, Dennis T. "Survive and Thrive
in Times of Change," in Training and Development Journal.
April 1988. p. 25-27.
Discusses how "change" has increased in the business
organization and how organization development
consultants can help the individual and the
organization cope with this issue.
Stump, Robert W. "Evaluating Career Development: Fact and
Fantasy," in Training and Development journal. December
1987. p. 38-40.
Discusses a case study on evaluating a career
development project including the highs and lows of
collecting and evaluating data.
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WC 34
Toppins, Anne D. "Research on HRD Research," in Training and
Development Journal. October 1989. p. 90-92.
Discusses the conclusions from a survey done on current
areas of human resource development research.
Concludes that the focus is on human practice areas of
training and development, organization development, and
career development. Also concludes that principle
researchers do unfunded projects and are primarily
professors and graduate students in the academic fields
of education and business.
White, Michael. "Linking Compensation to Knowledge Will Pay
Off in the 1990's," in Planning Review. Nov./Dec. 1991,
vl9n8, p. 15-17.
Wolff, Michael F. "Building Careers at Procter & Gamble," in
Research Technology Management. Sept./Oct. 1990, v33n5, p.
9-11.
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MEMORANDUM
SUBJECT: Reinvention Lab Proposal
FROM: Georgianna Bishop, NPR Team Leader
for Career Development
TO: The Administrator
The capacity of our work force to carry out your strategic
priorities is the first implicit goal of the Agency before
all other goals can be reached. Assessing and developing
work force capacity must be an explicit goal. In order to
address the challenges we face in the next century, which
will be characterized by their complexity and
interrelationship with other environmental and social
issues, we need to learn more and share more of what we
learn in an integrated way. We need to change our culture
to one in which learning is part of the way we do our
environmental work every day. Learning, which presently
takes place one person at a time, one course at a time, will
never get us to that goal.
Our "blue sky" ideal desired state is to recreate EPA as a
learning organization, which implies a culture in which
individuals anticipate the results of their actions and look
for creative, long-term solutions to environmental and
operational problems; they are empowered to learn in pursuit
of the Agency's mission. Proactive learning goes far beyond
a traditional view of technical training. It reguires our
work force to develop a new perspective and new skills; it
requires alignment between individual competency and
organizational competency.
Our team's reinvention lab proposal is the first part of the
first step in realizing our vision of EPA as a
technology-linked, competency-based, mission-directed
learning organization. We chose it because it is
broad-based, achieves a far better result than the current
state, and costs less.
PROPOSAL: Build one learning application of a "Technology
Highway" which reaches all 42 EPA facilities, and has a
positive impact on other Federal agencies and state and
local governments, by creating a learning, information, and
performance support system [LIPSS] to achieve the intended
result, rather than complying with the stated means of the
Federal health and safety requirements.
AUDIENCE; Federal, state and local government agencies with
on-site personnel at locations with hazardous substances.
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-2-
AREAS FOR REGULATORY FLEXIBILITY: FAR and EPAAR regulations
governing acquisition of products and services, the Federal
Technology Transfer Act, OSHA and EPA series of health and
safety rules and regulations, EPA's internal rules and
procedures governing ADP equipment and software, and OSHA's
hours-based (not results-based) training requirement.
BACKGROUND; EPA must comply with OSHA's health and safety
training requirements, which demand up to 40 hours of
initial training and eight hours of annual refresher
training for employees going to locations where hazards are
present.
EPA hires contractors in most cases to develop and deliver
this training which is offered throughout the year at
predetermined locations. Generally, a single training
course is offered to all attendees, despite differences in
the programs and types of hazards that they will encounter
on-site. Because of the difficulty in scheduling courses
and travel, EPA's own review has found that compliance rates
are low.
PROJECT DESIGN: This proposed project combines
technology-based training tools (CD-ROM and interactive
video), on-line databases, and performance support aids
(on-line checklists and expert systems) to create a
comprehensive training and planning system which exceeds
OSHA's health and safety and site safety planning
requirements. The system uses proven technologies that can
be inexpensively distributed or networked to make it widely
available.
Pieces of the system already exist. The Office of
Underground Storage Tanks has developed an interactive video
to provide health and safety training to UST workers and a
hypertext version of the UST regulations. Florida's Storage
Tank Program was the first to use these learning tools to
comply with the rules. The Office of Emergency and Remedial
Response has developed an expert system for site safety
planning; and the Office of Administration's Health and
Safety Division is using commercial databases and developing
CD-ROM based health and safety training. The project will
integrate these tools and build a comprehensive system that
cuts across all EPA programs and lab facilities.
Our federal, state and local partners are also subject to
the same health and safety training requirements, as is the
private sector. The project would look at ways of marketing
or distributing the compliance system to these other groups.
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-3-
CURRENT COSTS: The OSHA 1986 regulatory impact analysis
estimated national expenditures at $148 million per year.
An estimated 1800 EPA employees are required to have health
and safety training annually, at a cost in excess of $1
million per year. EPA just awarded a $45 million contract
to provide health and safety training to Federal and State
personnel.
DEVELOPMENT COSTS: Up to $3 million. If developed under a
partnership arrangement with a private sector cooperator,
rents or royalties payable to EPA could recoup some of the
expenditures. Two private firms have already inquired about
establishing such partnership with EPA.
BENEFITS: More competency-driven, appropriately targeted,
cost-effective training which also allows a "refresher"
boost when needed. Savings will accrue to the Agency in
travel costs, and both direct and indirect training costs.
Employees have greater ownership of their own development.
Products will be a direct benefit to all programs that have
field personnel and will be directly applicable to other
Federal, state, and local government agencies and private
sector firms.
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38
LISA ALMODOVAR
Office of Water
401 M ST. S.W. WH-586
WASHINGTON, DC 20460
PHONE 202-260-1310
FAX 202-260-3762
JEULI BARTENSTEIN (Co-Chair)
Office of Human Resources
Management, EPA Institute
401 M. ST S.W. PM-224
WASHINGTON, DC 20460
PHONE 202-260-5847
FAX 202-260-6786
CYNTHIA BASS
Office of Human Resources
Management
401 M ST. S.W. PM-224
WASHINGTON, DC 20460
PHONE 202-260-3342
FAX 202-260-0523
JOHN BEIER
Office of Prevention,
Pesticides, and Toxic
Substances
401 M ST. S.W. TS-796
WASHINGTON, DC 20460
PHONE 202-260-9417
FAX 202-260-1279
MARY L. BELEFSKI
Office of Water
401 M ST. S.W. WH-553
WASHINGTON,DC 20460
PHONE 202-260-7061
FAX 202-260-7024
GEORGIANNA M. BISHOP (Chair)
US EPA Region 1
Office of Human Resources
Development
JFK FEDERAL BUILDING
BOSTON, MA 02203
PHONE 617-565-3393
FAX 617-565-3736
EILEEN BURROWS
US EPA Region 3
Office of Human Resources
Development
CHESTNUT BLDG.
PHILADELPHIA, PA 19107
PHONE 215-597-1899
FAX 215-597-7906
ANGELA CARSON
Office of Solid Waste and
Emergency Response
401 M ST. S.W. PM-220
WASHINGTON, DC 20460
PHONE 202-260-2750
FAX 202-260-0174
BERNADETTE U. CHAN
Office of Solid Waste and
Emergency Response
401 M. ST S.W.
WASHINGTON, DC 20460
PHONE 703-308-8879
FAX 703-308-8505
ANTHONY ERB
Office of Air and Radiation
401 M ST. S.W. 6405J
WASHINGTON, DC 20460
PHONE 202-233-9259
FAX 202-233-9596
ELOISE FURBUSH
Office of Enforcement
401 M ST. S.W. LE-133
WASHINGTON, DC 20460
PHONE 202-260-4140
FAX 202-260-6848
FRANKLIN M. GEE
Office of Prevention,
Pesticides, and Toxic
Substances
401 M ST. S.W. H7508W
WASHINGTON, DC 20460
PHONE 703-308-8008
FAX 703-308-8005
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39
EPA NATIONAL PERFORMANCE REVIEW TEAM FOR WORK FORCE CAPACITY
(Formerly Career Development)
MARIAN HESS
US EPA Region 7
Office of Human Resources
Development
726 MINNESOTA AVE/PLMGHRBR
KANSAS CITY, KS 66101
PHONE 913-551-7271
FAX 913-551-7579
MARY JACANIN
Office of Solid Waste and
Emergency Response
401 M ST. S.W. OS-305
WASHINGTON, DC 20460
PHONE 202-260-0095
FAX 202-260-1038
MARY ROGERS
US EPA Region 8
Office of Human Resources
Development
999 18TH ST./8PM-HR
DENVER, CO 80202-2405
PHONE 303-293-1487
FAX 303-293-1681
DENISE ROY
Office of Solid Waste and
Emergency Response
401 M ST. S.W. OS-301
WASHINGTON, DC 20460
PHONE 202-260-9872
FAX 202-260-4196
PATRICIA LYTTLE
Office of Policy, Planning,
and Evaluation
401 M ST. S.W. PM-219
WASHINGTON, DC 20460
PHONE 202-260-4339
FAX 202-260-0275
LOIS T. MARSHALL
Office of Prevention,
Pesticides, and Toxic
Substances
401 M ST. S.W. EN-342
WASHINGTON, DC 20460
PHONE 202-260-7825
FAX 202-260-0641
BETTY MOBLEY
Office of General Council
401 M ST. S.W. LE-130
WASHINGTON, DC 20460
PHONE 202-260-8064
FAX 202-260-8046
KEVIN PERRY
Office of Water
401 M ST. S.W. WH-556F
WASHINGTON, DC 20460
PHONE 202-260-6833
FAX 202-260-8742
HOLLY PUGLIESE
Office of Air Radiation
2565 PLYMOUTH RD.
ANN ARBOR, MI 48105
PHONE 313-668-4288
FAX 313-741-7869
SHRUTI N. SANGHAVI
Office of Prevention,
Pesticides, and Toxic
Substances
401 M ST. S.W. EN-342W
WASHINGTON, DC 20460
PHONE 703-308-8291
FAX 703-308-8218
MARION KELLY THOMPSON
Office of Water
401 M ST. S.W. WH-552
WASHINGTON, DC 20460
PHONE 202-260-7117
FAX 202-260-7185
ART SANDOVAL
US EPA Facilities
Office of Human Resources
P.O. BOX 98516
LAS VEGAS, NV 89193-8516
PHONE 702-798-2414
FAX 702-798-2416
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REPORT OF THE
WORKFORCEDTVERSnr
TEAM
NATIONAL
PERFORMANCE
REVIEW
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WD
WORKFORCE DIVERSITY TEAM MEMBERS
Margaret Beason
Brenda Brown
Brooks Hamlin
LaShan Haynes
Carmen Johnson
Joseph Merenda
Paul Riederer
Laurel Seneca
Leanne Stahl
Richard Traub
Marylouise Uhlig
Ann Goode
Team Leader
Office for Prevention, Pesticides and Toxic
Substances
Office of Administration and Resources
Management
Office of Administration and Resources
Management
Office of General Counsel
Office of Civil Rights
Office for Prevention, Pesticides and Toxic
Substances
Region VIII
Region I
Office of Water
Region V
Office for Prevention, Pesticides and Toxic
Substances
Office of Air and Radiation
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WD 2
WORKFORCE DIVERSITY
DEFINITIONS: In this context, workforce diversity refers to
increasing the representation of minorities and women, consistent
with their representation in the civilian labor force, at all
levels within EPA, and achieving federal goals for hiring persons
with disabilities. Increasing workforce diversity is consistent
with our affirmative action obligations.
The term diversity is used to describe the differing values
and social forms, including unspoken rules of social interaction,
held by ethnic, racial, and other groups. In a broader sense,
the term refers to a range of differences held by people
belonging to various groups, including differences related not
only to race and ethnicity, but also gender, sexual orientation,
disability, problem solving approaches, professional disciplines,
management, styles, etc.
Affirmative action is the law. Diversity training can
provide the awareness and guidance to make needed changes in
organizational systems, structures, and management practices to
remove barriers that could keep some members of EPA from reaching
their full potential.
SUMMARY:
Equitable representation and quality of life are the primary
issues of concern relative to workforce diversity in EPA.
Since 1987, the overall number of minorities and white females
has increased at EPA. According to data provided by the EPA
Office of Civil Rights (OCR) for fiscal year 1992, minorities
represented 16.4 percent of the EPA positions classified as
Professional and Administrative, and white females represented 32
percent of those positions. Compared to their representation in
the civilian labor force, both groups would appear to be well
represented. Disaggregated data reveals, however, that serious
underrepresentation continues to exist at various grade levels
and for different organizational units, with some having achieved
better success than others. This underrepresentation is most
apparent when you look at the senior management ranks where
certain groups have never been represented and the representation
of others remains minimal.
The chart below, developed from OCR data, summarizes agency-
wide underrepresentation at various grade levels. Each group
noted there indicates a missed opportunity to achieve our goal of
parity representation of minorities and white females within the
EPA workforce. On balance, it is clear that much remains to be
done.
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WD 3
PROFESSIONAL POSITIONS
GS 5-8 American Indian men (CA)*
GS 9-12 American Indian men (MI)**
GS/GM 13-15 White women (MI)
African American women (MI)
Hispanic women & men (MI)
American Indian men & women (CA)
SES White women (MI)
African American women (CA)
Hispanic women & men (CA)
Asian/Pacific Islander women & men (CA)
American Indian women (CA)
ADMINISTRATIVE POSITIONS
GS 5-8 Hispanic men (MI)
GS 9-12 American Indian women & men (CA)
Asian/Pacific Islander men (MI)
American Indian men (MI)
GS/GM 13-15 Hispanic women & men (MI)
Asian men (MI)
American Indian men (MI).
SES White women (MI)
African American women (CA)
Hispanic women & men (CA)
Asian/Pacific Islander women & men (CA)
American Indian women & men (CA)
* Conspicuous Absence - nearly or totally absent
** Manifest Imbalance - substantially below their representation
in the appropriate civilian labor force.
The Agency is much closer to achieving overall federal goals
for hiring people with disabilities. In fiscal year 1992, people
with disabilities constituted 3.8 percent of the EPA workforce.
The federal goal was 4.16 percent. However, only .72 percent of
the Agency's workforce were people with targeted disabilities
while the federal goal for that year was 1.4 percent.
All employees should be treated fairly and feel that they
are respected members of the EPA community. In 1992, a survey of
over 5000 Headquarters employees revealed that many EPA minority
employees, to a greater extent than other employees, feel that
they are not respected or fairly treated at EPA, especially with
regard to recruitment and promotion, particularly beyond the
GS/GM 13 level. That same survey also revealed that 33 percent
of the EPA employees completing the questionnaire said that they
had experienced some form of discrimination at EPA. Those who
said they had experienced discrimination indicated that the most
frequent forms of discrimination were related to race, gender,
and age. Twenty-two percent of the female respondents and six
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WD 4
percent of the male respondents also reported experiencing sexual
harassment at EPA. The survey results clearly indicate that many
EPA employees perceive that there are serious quality of life
issues which the Agency needs to address more effectively.
In order to achieve greater progress in diversifying EPA and
ensuring that all employees are appropriately valued and
utilized, this administration will need to lead by example,
provide sustained, meaningful top level scrutiny of progress, and
be creative. The Administrator must also personally and
periodically require accountability of all top EPA managers.
Short-term, managers must be held accountable for utilizing
existing opportunities to address underrepresentation in their
workforce, and to try to leverage new opportunities.
This administration must also be equally committed to
looking beyond tomorrow to develop strategies designed to broaden
EPA's recruitment networks to include more applicants from
underrepresented groups, and ensure that there is an equitable
process for selecting them.
VISION: We want an EPA that, at all levels, looks like America
and provides a work environment free of discriminatory barriers
which penalize people for their differences, particularly
differences related to race, gender, ethnicity, and disability.
I. ACTION CATEGORY:
To make the representation of those groups currently
underrepresented in EPA, particularly in the supervisory and
managerial ranks, approximate their numbers in the civilian labor
force by 1997, for the appropriate occupational category.
A. INITIATIVES:
1. Establish Action Plans - Each AAship, region, and lab
will develop a plan of action, and incorporate it into
their affirmative action plan, by October 1993. to
address any underrepresentation in their organization.
The plan should include both short and long-term
strategies to identify potential internal and external
candidates. The only required element of the plan will
be that there be a standing internal peer panel, which
includes minority and female representation, for each
professional and administrative selection. The panel
will be picked by the selecting official. It will
review the recruitment plan utilized for the posting
and the qualifications of the applicants. The panel
will provide the selecting official with written
comments on the recruitment plan and make a written
recommendation to the selecting official concerning the
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applicants. The selecting official may set the
timeframe for the panel's deliberations. The panel's
recommendations in no way impinge on the selecting
official's right to make the final selection.
2. Certify Action Plans - The Office of Civil Rights will
certify the adequacy of the action plans and the affirmative
action goals to the Administrator by December 1993.
3. Quarterly Reviews - Every quarter, beginning May 1994. the
' Administrator will review progress against available
opportunities and the affirmative action goals set by each
organization, and will utilize an appropriate Assistant
Administrator/Regional Administrator forum to discuss Agency
progress. Results of the quarterly reviews will be
published and widely distributed to EPA managers and
supervisors. The Office of Civil Rights will be responsible
for analyzing the data for these reviews.
4. Early Out Study - Achieving real improvements in the
representation of minorities and women, particularly in the
supervisory and managerial ranks, will be more difficult
because of the reduced overall hiring opportunities in
fiscal year 1994 and possibly beyond, due to budget
constraints, and the prospective reduction of the number of
GM-14 through SES level positions. For that reason, we
recommend that the Office of Human Resources Management
explore the feasibility of an early retirement proposal with
the Office of Personnel Management, for GM-14s - SES, to
create new hiring opportunities in the senior managerial
ranks. A progress report on this will be provided to the
Administrator by October 1993.
5. SES Candidate Program - The Office of Human Resources will
develop a plan for an SES candidate program which can
produce certified candidates by the beginning of fiscal year
1995. This plan will be completed by November 1993.
II. ACTION CATEGORY:
To create a work environment where differences, particularly
related to race, gender, ethnicity, age, and disability, are
understood and this understanding leads to improved
communication and interaction.
A. INITIATIVES:
1. Executive Training - All top Agency executives,
including Assistant Administrators, Regional
Administrators, and members of the SES should
receive diversity training, by a highly skilled
outside contractor, by January 1994. The first
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WD 6
session for senior managers should be in November
1993, the second in January 1994. The Office of
Human Resources Management should be responsible
for arranging for the contractor.
2. Diversity Assessment - Each Assistant
Administrator, Regional Administrator, and lab
director should develop a process to review what,
if any, issues exist within their organizations
relative to diversity, which may be barriers to
creating a workplace free of discrimination, and
review organizational procedures and policies
as they relate to these issues. The process
should involve broad based employee input and
should be designed to address the concerns of all
employees. A report of the findings should be
submitted annually to the Office of Human
Resources Management, beginning November 1994.
in. ACTION CATEGORY:
To create improved guidance mechanisms to assist managers in
addressing issues of diversity and the underrepresentation
of women and minorities.
A. INITIATIVES:
1. Data System - The Office of Civil Rights and the
Office of Human Resources Management should
develop an effective agency-wide system to provide
accurate and timely information on
underrepresentation, in user friendly formats, to
each AAship, Region, and laboratory. This
information shuold be available at the beginning
of each quarter and should provide the data by
AAship, Region and laboratory, in addition to a
breakout by division. This process should be in
place and fully operational by January 1994.
2. Guidance Materials - The EPA Library, in
conjunction with the Office of Civil Rights and
the Office of Human Resources Management, should
develop an appropriate set of materials, including
books and videos, on equal employment opportunity,
affirmative action, and cultural diversity. The
EPA Library should provide an announcement to all
supervisors and managers of its holdings in this
area by January 1994. The Office of Human
Resources Management should update the EPA
Cultural Diversity Vendor Catalog annually. That
update should be housed in the EPA library and
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WD 7
sent to each Agency training officer. The Office
of Human Resources Management should complete this
update by January 1994.
3. Training - The Office of Civil Rights, in
conjunction with the EPA Institute, should develop
a course on sexual harassment and age and race
discrimination. This course should be offered at
least once every quarter through the Institute and
arrangements should be made to ensure its
availability to the regions and labs. This course
should be available by January 1994.
IV. ACTION CATEGORY:
The following recommendations are directed to the
government-wide National Performance Review team.
There are many government-wide policies and procedures that
make it extremely difficult to attract talented entry level
staff. These policies have resulted in EPA hiring few
entry-level people in professional and administrative job
series. This has also decreased Agency flexibility in
attracting talented minority candidates.
A. INITIATIVE:
We recommend that the Office of Personnel Management
(OPM) do an analysis of the impact of the
Administrative Careers With America exam on recruiting
talented minorities and women at the entry level. That
analysis should also consider how and where information
about the exam is distributed and the accessibility of
exam locations. Information about selection through
the Administrative Careers With America process should
be presented by race, ethnicity, gender, and job
categories. That assessment should be completed by the
beginning of fiscal year 1995.
We recommend further that the national OPM review the
efficacy of current government promotion policies that,
in some instances, create administrative hurdles to
assuring the broadest possible range of career
advancement opportunities, particularly for persons
interested in advancement in non-managerial career
tracks. Additionally, we recommend that the national
OPM consider providing the broadest possible hiring
authorities for every job category and making that
authority consistent in all federal regions. These
recommendations are related to increasing the numbers
of underrepresented groups in the workforce to the
extent in that improvements in these areas would
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WD 8
increase federal competitiveness in hiring the best and
the brightest candidates.
V. BARRIERS:
There are three principal barriers to achieving a completely
diverse workforce at all levels:
A. Despite policy statements in support of diversity
and equality, the Agency needs to demonstrate more
effectively that these are important organizational
values.
B. Agency leadership has not been held accountable
for achieving affirmative action goals and top
level attention to this as an issue has not been
sustained.
C. Support mechanisms to provide information and
guidance to offices is not currently adequate,
e.g., timely data to assess progress, guidance in
developing strategic plans for short and long-term
efforts, inadequate guidance materials available
at the Agency level, etc.
VI. INVESTMENT COSTS AND BENEFITS:
Data does not currently exist to quantify whether or not
cost savings would accrue from the proposed recommendations.
Likewise, data does not exist to document significant
additional costs associated with the recommendations.
Significant latitude was provided as to how these
recommendations could be met. The planning and periodic
reports which are recommended do not, for the most part,
constitute new requirements and therefore should not result
in new expenditures and are basically nothing more than is
already required for effective affirmative action planning.
The cost for the training of EPA's senior executive's will
not represent a significant financial burden.
Appropriately diversifying our workforce from the policy
level on down and working to create a climate where that
diversity is appreciated and utilized to improve the way EPA
does business, presents us with the opportunity to create an
even more effective organization. Valuing diversity and
making it work for EPA is, in fact, a matter of business
necessity. It means utilizing the creative energy arising
from the wealth found in the diversity of our current
workforce to enhance EPA's effectiveness and productivity.
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WD 9
VI. EVALUATION CRITERIA:
Success should be measured against our ability to resolve
identified problems. Our yardstick for workforce diversity
is whether the profile of the organization becomes more
diverse with regard to race, gender, and ethnicity in each
grade level. The proposed quarterly reviews will reveal
that.
Improving problem areas identified by the individual office
diversity assessments should be used to gauge organizational
improvement at the office level. Evaluations relative to
improvements should be done six months after efforts have
been put in place to resolve problems. The results of those
assessments should be made available at the office level and
should also be part of the quarterly review process.
VII. REFERENCES:
Affirmative Employment Program Plan for Minorities, Women,
and People with Disabilities, FY 1993 Affirmative Employment
Program Plan Update and FY 1992 Accomplishment Report, April
15, 1993.
Affirmative Employment Program Plan for Minorities, Women and
People with Disabilities, Fiscal Years 1988-1992,
April 15, 1992.
Cultural Diversity Challenges for EPA, November 1992.
Cultural Diversity Training Strategy for EPA, July 12, 1991.
EPA Cultural Diversity Vendor Catalog, November 1991.
EPA Headquarters Cultural Diversity Survey Final Report,
December 4, 1992.
Women, Minorities and People with Disabilities, Status
Report, First Quarter of FY 1993.
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LEADERSHIP TEAM
SUPPLEMENTARYREPORT
NATIONAL
PERFORMANCE
REVIEW
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LT1
SUPPLEMENTARY REPORT OF THE LEADERSHIP TEAM
INTRODUCTION
The Leadership Team was formed as part of EPA,s National
Performance Review, and its mission was to coordinate the efforts
of the 19 Policy/Process Teams. One of the Leadership Teams
roles was to identify and address issues which were not covered
by the 19 Policy/Process Teams. This responsibility initiated
the appointment of a subcommittee.
Issues which converged with those already under
consideration by one of the 19 Policy/Process Teams were simply
referred to the appropriate team leader for action. Issues which
merited additional attention and were unclaimed by Policy/Process
Teams were handled by the Leadership Teams subcommittee. The
subcommittee issues addressed in this report are:
Section A: Leadership Philosophy
Section B: Environmental Literacy
Section C: Marketing EPA
Section D: Green Border Review
Section E: Recapturing Civil Penalties
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SECTION A:LEADERSHIP PHILOSOPHY
SUMMARY: Management research has shown that the most competitive
businesses are those that have adopted principles generally
encompassed under the heading, Total Quality Management (TQM.)
These principles include a focus on high performance, continuous
improvement, non-hierarchical management, and examination of
barriers to success. TQM cannot be implemented successfully
until the culture accepts and promotes its principles and ideals.
EPA has talked TQM but has been.slow to make the necessary
cultural changes to allow its most effective use. Quality cannot
be legislated or dictated; it must be taught many times at all
levels, accepted, and fostered by leadership.
EPA can become an effective environmental leader nationally
and internationally by placing emphasis on high performance. The
needed cultural changes must begin with removal of hierarchical
barriers to success and a focus on team effort and empowerment.
This is most effectively done through a combination of
consultative and participative management styles as described.by
Likert. Research has shown that these styles have been
effectively implemented at a number of private businesses and
government agencies with a concomitant increase in productivity.
TQM is reliant on measuring all things against a common vision
and set of values that have been identified by the leadership.
There is a perception within EPA that there is no clear
VISION for the entire Agency. VISIONS have been developed for
some program offices, some legislative mandates appear clear, and
there are consistent demands from a variety of customers. Once
the VISION is communicated throughout the Agency, then systems,
structures and strategies can be examined for their support of
the common VISION. Our current systems, structures and strategy
may not be effective in promoting and developing high performance
teams; in fact, they most likely are detrimental.
Until the leadership philosophy is altered, the chance for
success of any changes suggested in this review is minimal. The
leaders within EPA have, unfortunately, been constrained by the
hierarchy of government, but changes in the systems alone will
not allow for successful implementation of our suggestions. We
must get at the heart of the organization and begin to break down
hierarchical walls by implementing a new leadership philosophy.
EPA,s NPR should capitalize on this unigue opportunity to make a
difference that will truly allow us to make the changes necessary
to develop high performance teams at EPA and to strive for
continual improvement.
VISION: To adopt a leadership philosophy and create a culture
that results in the development of high performance teams at EPA.
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LT3
ISSUE: How can we best bring the energy of our people to focus
on constant improvement? We need to adopt a leadership
philosophy that shares power and empowers people. We must move
from the hierarchical style that has been imposed upon us to a
participative management style that focuses the energy of EPA
employees. This simply means that we must begin to share
leadership responsibilities at all levels of our organization.
This concept is not being suggested simply because it is
morally correct or currently fashionable, but because the data
indicate that the implementation of such a philosophy results in
a more efficient, effective and productive organization, capable
of being measured and monitored for success. Studies further
indicate that shared leadership is the ONLY way to improve
performance over the long term. Organizations such as Xerox,
Ford, Motorola, U.S. Geological Survey (USGS) have succeeded
because they have challenged themselves to fully implement this
style throughout their organizations and at all levels.
Organizations that have not fully implemented this style (e.g.,
U.S. Forest Service in its first attempt) have not been as
successful. Thus, we must challenge ourselves if we are to
recognize change and success throughout our Agency.
INITIATIVE(S): Implement a comprehensive four-stage process:
Focus on our mission and articulate an Agency vision. Take
time to evaluate and re-evaluate.
Make the mission and vision current and relevant. Top
leadership must set the Agency's direction and vision,
ensuring that it evolves as our environment changes by
consulting with our customers and those who supply us with
resources.
Share power and empower people. Embracing this concept is
necessary for success in everything we choose to implement.
Empowerment is defined as joining together to accomplisn a
shared vision.
Unit-by-unit implementation across all of EPA. We are
talking about a basic cultural and behavioral change which
can only be done if we get into the "guts" of the Agency.
With targeted training, this is a feasible goal. Costs
could be kept to a minimum and, in fact, savings could be
realized as we move away from unplanned, unfocused
leadership training toward a targeted, consistent approach.
Additional savings can be made by providing the ability to
implement constructive change following existing Federal
Executive Institute and Total Quality Management training.
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LT4
It is important to note: "If organizations are to truly
transform management philosophy and practice, people must
critically explore the values, beliefs, behavior" (Larson)
REFERENCES:
Block, Peter. 1991. The Empowered Manager: Positive
Political Skills at Work (San Francisco: Jossey-Bass).
Larson, Colleen L. 1991. "Transforming Management
Philosophy: Beyond the Illusion of Change" New Directions
for Program Evaluation, No. 49, pg 74:
Likert, Renis. 1961. New Patterns of Management (New York:
McGraw Hill)
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LT5
SECTION B:ENVIRONMENTAL LITERACY
SUMMARY: EPA should enhance its role as an advocate of
environmental literacy. Beyond the environmental protection
field, people in business, economics, engineering, etc., usually
react to the need for environmental protection because of various
regulatory requirements, rather than because they understand and
agree that it is both necessary and good business to conserve
natural resources. This reaction may be due to the fact that
they have not been exposed to this concept throughout their
education. Consideration of environmental protection should be
integrated into college textbooks in the study of economics,
business, engineering, etc.
EPA has taken a leadership role in educating children and
teachers in secondary schools. More attention may be needed to
change curricula at the college level (beyond disciplines in
environmental sciences) to help the private sector become more
efficient in the use of natural resources and energy (such as in
the design of products), and reduce the adverse impacts of their
activities on the environment. Dialogue is needed to determine
whether the efforts suggested below are contradictory to,
redundant with, or complementary to existing efforts.
VISION: A society that believes that preservation of natural
resources is essential and acts upon that belief.
INITIATIVES:
Expand EPA's emphasis on environmental education at the
college level. Part of the effort should include a review
of the existing strategy and a consideration of the
resources currently devoted to college level environmental
education and a comparison with the resources devoted to the
kindergarten through secondary school level. The evaluation
should include an examination of the legislative
requirements, along with the potential benefits which can be
achieved by targeting college level curricula. The study
should document the relevant EPA activities currently being
sponsored by program offices and laboratories. In addition,
it should document related activities and plans outside of
EPA (e.g. The United Nations or Tufts University.)
A patchwork of unrelated activities currently exists; the
Agency should look for opportunities to leverage these
scarce resources into a more comprehensive strategy (similar
to NIOSH's program for Health and Safety.) More dialogue
with the Environmental Education Division is needed to
calculate the potential value of this recommendation.
Potentially, one FTE and $150,000 could make a substantial
first step. If grant funds become available, consideration
should be given to targeting the college level.
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LT6
If it is determined that more emphasis should be placed on
targeting the college level, a strategy should be developed
to facilitate that outcome. The barriers are likely to
include organizational issues and the belief that various
initiatives underway currently address the most important
environmental education needs. In addition, the entire
environmental education budget appears to be underfunded,
and refocusing emphasis on the college level could result in
disinvestments of equal or more important areas. The
evaluation may take about six months, given the many
organizations potentially involved. The benefits would be
long-term and difficult to quantify at this time.
Provide rotational opportunities for EPA staff to work with
non-profit organizations whose mission is environmental
literacy and/or with universities to help identify pollution
prevention opportunities and identify opportunities for
changes in textbooks in various disciplines.
Barriers would include the need to identify and/or develop
the process to enable this to happen, and the need to
disinvest from other activities within the agency in order
to invest in this new area. This initiative would.broaden
the experience of EPA employees, as well as benefit the
receiving organizations.
A possible investment option would be to assign two FTE,s
from each program office and Regional Office to this effort,
in six-month temporary details. A pilot program could be
instituted with the equivalent of two FTE's for the first
year, after which performance and results could be evaluated
for further investment options. Measures of success could
include the number of courses and students affected,
organizations contacted, etc. The benefits would be short
term and easier to quantify than in the first initiative.
The concept would be for EPA to help "seed" ongoing efforts.
REFERENCES:
1. Cortese, Anthony, "Education for an Environmentally
Sustainable Future", Environ. Sci. Technol., Vol. 26, No. 6,
1992, pp. 1108-1114.
2. Second Nature: Education for the Future, Mission Statement,
May, 1993. Board of Directors, John F. Kerry, Honorary
Chairman, Anthony Cortese, President, Bruce F. Droste,
Douglas Costle, Ted Danson, Theresa Heinz.
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LTV
SECTION C:MARKETING EPA
SUMMARY: EPA is involved in a number of beneficial activities
that go unnoticed, while lawsuits and negative publicity prevail.
This tendency has been noticeable in the research, technical
support, and compliance/enforcement areas; no doubt there are
others. EPA's contributions to science and engineering are not
publicized; our support of, and efforts to, assist State and
local governments and the general public are seldom acknowledged;
and the partnerships we have with universities, national
organizations and international organizations are little known.
Nor are creative enforcement remedies, such as Supplemental
Environmental Projects, widely recognized. The proposal is that
EPA begins to take credit for its positive impact and do a better
job of marketing itself, both internally and externally.
VISION: To create a marketing system that allows for clear and
continued communication between EPA and its customers (the public
at large) regarding Agency activities and products and the
rationale behind all Agency decisions, resulting in improved
image, increased impact, and a larger resource base.
ISSUE: Despite the credible efforts of the Agency, lawsuits and
negative publicity prevail. Perhaps this dilemma is a
consequence of being a public agency ripe for scrutiny. We
believe, however, that this situation can be turned around. The
impacts of such negativism reverberate throughout the Agency;
morale suffers, affecting productivity. Our desire is for our
customers to have a clear understanding of our efforts and
decisions and for our "value added" to be recognized by our peers
and colleagues (some of whom may not even know we existl).
INITIATIVE(S):
Develop a marketing strategy. While this task should be
done internally by EPA staff, we need to seek help in
learning how to develop a strategy. EPA must take credit
for the positive effects it has on science, engineering,
risk management, management, etc. Marketing efforts must be
focused both internally and externally; EPA cannot be
successful in communicating to the public when some of our
internal colleagues don't recognize our value.
1. Internally: There are communication systems in place.
We must analyze them for their effectiveness and
redesign them, where necessary. (Note: EPA's NPR
process presents a wonderful opportunity for cross-
Agency marketing). Following this analysis, an
internal marketing plan must be developed.
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LT8
2. Externally: The Agency must learn the basic concepts
of external marketing and determine what to include in
its marketing strategy (and what not to include.) EPA
has been gracious in promoting community-wide
activities (e.g., Earth Day, recycling, "Pandy
Pollution"), building tours, school outreach and
hosting international guests. But we have not been as
successful in marketing and communicating to the
general public our process and progress in meeting our
mission and specific goals. How to successfully
transmit this type of message must be planned. A
marketing strategy must be a part of every action taken
by the Agency (effort, tasks, and accomplishments), and
each individual strategy should be governed by an
overall marketing plan.
COST: The costs associated with such an effort can be minimal.
We have many activities currently in place which are an FTE drain
and to which few benefits can be attributed (e.g., quarterly
reports). If the Agency refocuses its activities, costs could be
kept to a minimum.
Build upon existing partnerships and consortia with
universities for idea and personnel exchanges. (See the
report on "Quality Science" for additional benefits of such
a program).
COST: 3-4 FTE,s; $250,000 per year
Arrange for rotational assignments within the Agency and
between Agencies (also discussed in "Quality Science").
COST: Pilot 4-5 FTE's (as exchanges); $250,000 per year
Provide travel dollars specifically for the purpose of
information sharing in Regions, at public meetings, and
conferences etc. and place a priority on such travel.
COST: Could range from 20-50% of total travel dollars,
depending on the organization.
CONCLUSION: This concept is not unique but the Agency needs an
innovative marketing strategy. There is much good work done at
EPA - let's take credit for itl
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LT9
SECTION D:GREEN BORDER REVIEW
SUMMARY: The Agency created the "Directives System" to establish
a systematic process for identifying, writing, reviewing,
approving, and disseminating internal Agency policy and operating
procedures. By virtue of this system, Agency employees can
utilize established directives to assist them in performing their
responsibilities uniformly Agency-wide. Through this system, the
Agency communicates internally and sets the administrative and
legal basis for its internal operations.
The Assistant Administrator for Administration and Resources
Management, through the Director, Office of Administration, has
overall management responsibility for the EPA directives program.
The Director, Management and Organization Division, has direct
responsibility for the program. The process, from origination of
a directive to approval, is commonly called the "Green Border"
process because of the form used to obtain clearance for the
issuance. A parallel system for regulation development is
managed by the Office of Policy, Planning and Evaluation, and.
called the "Red Border" system.
Unfortunately, it is difficult to change and improve an
administrative system, despite obvious flaws or inefficiencies,
or how outdated it is ("we,ve been doing it this way for years").
Yet this system needs reform. Not only has the system not
"continually improved," it has actually deteriorated.
As the barriers to improvement (below) indicate, the process
is viewed as flawed, but operational at least until an AA, RA,
Office Director, or other official is "burned." It is time to
reinvent the system, make it customer-oriented and functional.
Currently, the Agency,s "Green Border" process for internal
"Issuances (Directives/Orders, Reorganizations, Delegations of
Authority)" does not focus on stakeholders as customers,
functions inconsistently, and is inefficient. Listed below are
some of the problems:
Stakeholders are seen more as process inputs than partners.
There are few written procedures and policies, and those
that exist are not well understood within the Agency some
written procedures are inconsistent (e.g., who determines
which.offices should comment during clearance/review).
Crucial stakeholder offices may not be involved in the
development or clearance of issuances (e.g., State P2 grant
delegations have not always included the Regional Offices,
and OPPTS was not included in clearance of the Internal P2
Order).
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LT10
The process is decentralized, with originators often having
little knowledge of system and M&O having little control.
Proposals may be held hostage because of inconsistent
application of rules (e.g., Region 8,s reorganization was
held up for .issues not included in the reorganization).
Even though it is the Agency,s internal process for
issuances, some Offices are covered by the process and some
are not. (e.g., ORD has few delegated grant authorities,
while other Offices are covered under the process).
Regional Offices, interests may be overlooked during the
process (e.g. comments from RO's often are not considered
seriously, unless nonconcurring which are treated
negatively), and it may be inferred that there is no real
provision for Regional Administrators to submit requests for
delegation.
Delays occur during clearance/comment reconciliation caused
by lack of knowledge of the process and result in
inefficiencies; and there is no required closure time (pre-
Green Border and Clearance period may go on interminably).
Impact statements and rationales for delegations of
authority requests are not always submitted or available.
They are not required to accompany the delegation (as
reorganization impacts are) during clearance, making it hard
for reviewers to understand the delegation or evaluate the
impact.
Administrative actions which should be included in the
formal system are outside it (e.g., delegations may be
transferred as part of reorganization approval memos) and,
thus, render tracking and accountability difficult.
Lack of uniform procedures and inconsistencies in
implementation make the Agency vulnerable (example: in ORD
grants official delegatees for enforcement or compliance
authorities may not be correct.) These efficiency and
effectiveness issues inhibit Agency operations and has made
the Agency vulnerable to the IG and GAO.
Delegations should be routinely and substantively reviewed.
This has not occurred, and there are "out of date"
delegations (e.g., unnecessary concurrence requirements, as
pointed out in Region 8's study of the value added by
limitations).
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LT11
VISION: There are customer oriented, written procedures and
policies for the Green Border process that are well understood,
accepted and applied consistently, with all stakeholder interests
being represented. We are no longer vulnerable from legal and
administrative perspectives.
INITIATIVE: The initiative proposed is to review the Green
Border Process and to develop one that is well understood,
accepted and applied consistently, so that:
All stakeholder interests are represented;
The Agency is no longer vulnerable from legal and
administrative perspectives; and
Roles and responsibilities are clear. In addition, it is
proposed that the recommendations of Region 8's analysis of
"Limitations" in Delegations of Authority be used in the
review (e.g., purging the Manual of limitations not adding
value, evaluating the concept of limitations, and revising
the Manual as necessary).
A work group led by M&O Division should conduct the review.
Work group membership should consist of an equal number of
field/Regional and HQ representatives.
The review should start ASAP, and it should be concluded
within 60 Days. Revised procedures for Green Border reviews
should be issued 30 days later.
Possible barriers to improvement:
1. Continued political pressures within the Agency to
short cut and "use" the system;
2. Process viewed as flawed but operational;
3. Neither the extent of the problem is well known, nor
the risks of not correcting it;
4. Process seen as barrier to getting things done quickly;
5. Consensus within the Agency for keeping things "loose"
and avoiding processes and procedures; and
6. Lack of resources within M&O Division for running a
more centralized, customer oriented, administratively
efficient, and analytically sound process.
COST: The start-up costs for the work group and system changes
would be more than offset by the savings realized through the
improved efficiency.
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LT12
BENEFITS: EPA will gain efficiency, predictability, and
credibility. Delays and confusion would be avoided. It would
also reduce wasted energy, time, and ill will.
MEASURES OF SUCCESS: Reduced process time and fewer IG and GAO
reviews with fewer adverse findings.
REFERENCES:
1. EPA Directives Manual 1315 (1987 Edition)
2. Clearance Record, EPA Form 1315-16 (Rev 8-86)
3. Directives System - Agency Overview (M&O Division - unknown
date)
4. EPA Delegations Manual 1200 (Introduction, 1220 TN 219,
1/2/90)
Request for Change in Organization Structure, EPA Form 1110-
1 (Rev 7-83)
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LT13
RECAPTURING CIVIL PENALTIES
SUMMARY: Because of the limits of federal law, EPA is not able
to receive or put to good use the substantial civil penalties
which the government collects as a result of the Agency,s civil
enforcement program. Amendments to existing statues would enable
EPA to recapture all or part of the civil penalties which are
assessed and paid through its administrative and judicial
enforcement actions. We propose that such penalties be paid
directly to EPA for the specific purposes of funding EPA
laboratories (regional labs and NEIC) and supporting enforcement-
related training, particularly NETI. However, it may be
preferable to use civil penalties collected by the Agency to fund
non-enforcement activities, such as state grants or state
training programs. There may be other discrete areas to which
penalty dollars could be directed, such as the Compliance Audit
Program (CAP) or the Agency's Internal Pollution Program.
EPA, through its civil judicial and administrative
enforcement actions, collects millions of dollars annually in.
penalties ($78.7 million in fiscal year 1992). Except where
specific statutes provide otherwise, the penalties collected are
paid directly into the United States Treasury and become part of
the general revenues. EPA receives no resource benefit from, or
credit for, the penalties realized from its enforcement efforts.
The exceptions to this general rule are the trust fund
programs which are statutorily authorized to receive monies
collected for the United States. Under CERCLA, for example, EPA
can recover monies it expends at various stages of the Superfund
program (removal, RI/FS, RD/RA, etc.), as well as penalties
collected as a result of defendants, non-compliance with orders
issued. Both the costs recovered and the penalties collected are
paid into the trust fund for use in financing future Superfund
actions. In addition, natural resource trustees (e.g.,
Department of Interior) can collect for restoration purposes,
natural resource damages assessed under Superfund. Costs
recovered and penalties assessed under the Oil Pollution Act are
also payable to the Oil Pollution Act Trust Fund. See. Clean
Water Act, Section lll(s).
Currently, EPA is prohibited from receiving non-trust fund
penalty dollars for its own use. The Miscellaneous Receipts Act
(MRA), 31 U.S.C. 3302(b), mandates that funds received for the
United States be deposited directly into the Treasury, "without
deduction for any charge or claim." The MRA has been strictly
interpreted to prohibit receipt of government funds by entities
other than the U.S. Treasury. Although there may be creative
legal arguments around MRA restriction, Congressional action to
amend the MRA provides an unassailable approach to permitting an
agency such as EPA to receive, for its own use, penalties which
would otherwise be payable only into the Treasury.
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LT14
EPA currently has a policy of allowing defendants to perform
Supplemental Environmental Projects as a means of mitigating
civil penalties which would otherwise be assessed through civil
enforcement actions. Such projects consist of environmentally
beneficial activities which are negotiated as part of consent
decrees or consent orders. The activities undertaken must bear a
relationship (nexus) to the original violation(s) addressed by
the enforcement action, but must be in addition to, or different
from, whatever injunctive action is required to rectify the
violations. Furthermore, the SEP policy requires that the
government recover from the defendant, as a civil penalty, the
full amount of any economic benefit of non-compliance realized by
the defendant and some measure of the gravity component.
Recently, the Office of Prevention, Pesticides and Toxic
Substances has considered a proposal whereby some portion of the
penalties collected under the TSCA Section 8(e) Compliance Audit
Program (CAP) would be directed to a trust fund in support of
research into what constitutes a "substantial risk" for Section
8(e) reporting purposes.2 There is legal support for the
proposition that this idea is consistent with the Agency,s SEP
policy and does not violate the Miscellaneous Receipts Act.
However, the trust fund proposal for the CAP program could be
greatly strengthened through the legislation recommended here.
VISION: EPA recaptures, in whole or in part, the civil penalties
collected through both administrative and judicial enforcement
actions in a manner that permits those penalty dollars to be
dedicated to specific Agency needs and programs.
Civil penalties could be directed to funding EPA
laboratories around the country and to underwriting enforcement-
related training. In addition, programs such as the TSCA Section
8(e) CAP program could be authorized to recapture penalties
collected for a trust fund dedicated to scientific research. The
fund could be used for research directed toward improved
compliance with Section 8(e).
1. There are six categories of projects which can be
considered for credit - pollution prevention, pollution
reduction, environmental restoration, environmental auditing,
public awareness, and support for research on "substantial risk."
2. Section 8(e) of TSCA requires that a manufacturer,
processor, or distributor of a chemical substance or mixture who
acquires information which reasonably supports a conclusion that
such substance or mixture presents a substantial risk of injury
to health or the environment must inform the administrator. In
February 1991, EPA initiated a voluntary Section 8(e) Compliance
Audit Program (CAP) which set a penalty ceiling of $1 million per
company. These "capped" penalties would go into the trust fund.
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LT15
As noted above, the most certain means of achieving the
desired state, i.e.. enabling EPA to collect penalties for its
own use is through Congressional amendment of the MRA. Such an
amendment could extend to agencies and departments other than EPA
that may be desirous of recapturing penalties they collect for
their own uses. (This proposal could have cross-agency utility
as part of the government-wide NPR process.)
It may also be necessary for Congress to amend each of EPA,s
statutory enforcement authorities in order to permit civil
penalties to be paid directly to EPA. (Such language appears in
CERCLA and in Section 311 of the Clean Water Act for enforcement
of the Oil Pollution Act.) In addition, the appropriations bill
for each statute EPA administers should probably include specific
authorization for the Agency to receive civil penalties assessed
through enforcement of that statute. Since Congress is unlikely
to authorize EPA to commit the penalties it collects for general
agency revenues, any legislation to implement this proposal
should specify particular uses for the funds collected.
Because this proposal does not contemplate any forgiveness
of penalties, it should not be subject to the SEP condition that
only that portion of the penalty which exceeds the sum of the
economic benefit, plus some gravity component, can be credited.
Under this proposal, the defendant/respondent would pay the
entire amount of the penalty, without benefit of tax deduction.
However, rather than writing a check to the United States
Treasury, the defendant/respondent would write a check to a
specific account or trust fund administered by EPA. The account
or trust fund would be expressly dedicated to avoid any risk of
diversion of funds from their legally-designated objective.
Use of the Agency,s civil penalty collections to support
enforcement-related training and laboratory needs has the
potential for rendering those programs self-sufficient. If
collections exceed Agency needs in some years, unused funds could
be carried over to less prosperous years. Alternatively, funds
unneeded in a particular year could revert to the U.S. Treasury.
INITIATIVE: At a minimum, this proposal would require
legislation to amend the Miscellaneous Receipts Act, as well as
the enforcement provisions .of each statute to which it is
intended to apply. It is also recommended that the appropriation
bills for each statute pursuant to which the Agency conducts a
civil enforcement program include a reference to or specific
authorization for civil penalties to be paid to EPA for discrete
agency programs.
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LT16
The Office of General Counsel, Office of Enforcement, and
the legislative arms of the various program offices would need to
collaborate to draft legislation. Timing of such legislation
could be tied to statutory reauthorization or to annual budget
cycles, although amendment of the Miscellaneous Receipts Act
could occur at any time.
BARRIERS: Barriers to implementing this initiative are likely to
be found principally within the regulated community, which may
object to providing EPA with a financial incentive to enhance its
civil penalty collections. This same objection may be heard from
certain members of Congress. However, the argument for using
penalties collected by the Agency, through its own enforcement
efforts,to fund related Agency functions - e.g., laboratory
support and training - should prove extremely compelling. As an
alternative, the funds collected from civil penalties could be
directed to non-enforcement related activities, such as state
grants or training programs.
COST: Implementation of this proposal should generate more
revenue than it consumes. There will be an initial resource
investment for drafting necessary legislation and subsequent
minimal costs of administering collection and distribution of
penalty dollars received. However, this proposal should
definitely be counted as an asset in the Agency's accounting
system.
In addition to enhancement of agency resources, the benefits
to the Agency are obvious. Rather than watching penalty dollars
blend into the general revenues, Agency enforcement personnel
will have the satisfaction of knowing that civil penalties are
supporting environmental protection efforts. Furthermore, Agency
programs which have been historically underfunded could be
adequately financed, if not self-sustaining. In fact, the
principal measure of success for this proposal would be that the
EPA labs and enforcement training could be entirely funded by
civil penalties.
REFERENCES:
1. February 12, 1991, memorandum from James M. Strock, "Policy
on Use of Supplemental Enforcement Projects in EPA
Settlements."
2. Miscellaneous Receipts Act, 31 U.S.C. #3302(b)
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