EPA-350-R-98-002
\ Office of Inspector General
/ Audit Report
The Effectiveness and Efficiency
of EPA's Air Program
Report No. E1KAE4-05-0246-8100057
February 27, 1998
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Inspector General Division
Conducting the Audit:
Inspector General Divisions
Contributing to the Issue Area:
Northern Audit Division
Chicago, IL
Headquarters Audit Division
Washington, DC
Eastern Audit Division
Boston, MA
New York, NY
Mid-Atlantic Audit Division
Philadelphia, PA
Southern Audit Division
Research Triangle Park, NC
Central Audit Division
Dallas, TX
Western Audit Division
San Francisco, CA
Office of Internal Audits
Washington, DC
Engineering & Science Staff
Washington, DC
Program Offices Involved:
Office of Air and Radiation
Office of Research and
Development
Office of Communications,
Education, and Public Affairs
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
February 27,1998
OFFICE OF
THE INSPECTOR GENERAL
MEMORANDUM
SUBJECT:
FROM:
TO:
The Effectiveness and Efficiency of EPA's Air Program,
Report No. E1KAE4-05-0246-8 100057
Michael Simmons
Deputy Assistant Inspector General
for Internal Audits
Richard D. Wilson
Acting Assistant Administrator
for Air and Radiation
Henry L. Longest II
Acting Assistant Administrator
for Research and Development
Loretta M. Ucelli
Associate Administrator
for Communications, Education, and Public Affairs
Attached is a copy of our report entitled "The Effectiveness and Efficiency of EPA's Air
Program," Report No. El KAE4-05 -0246-8 100057. This report provides important findings and
recommendations that should significantly improve the efficiency of the Air Program and its
relations with other offices. The final report incorporates the comments each of your offices
provided on position papers we previously issued.
We appreciate your staffs' efforts in working with us to develop this report. We
particularly want to thank the Office of Air and Radiation management and staff for their
cooperation and the high level of attention they gave to our work in the Air Program over the past
several years. Without that cooperation and attention, we could not have produced this report.
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Action Required
In accordance with EPA Order 2750, we have designated the Acting Assistant
Administrator for Air and Radiation as the action official for this report. As the action official,
he is required to provide us with a written response within 90 days of the date of this report. The
response should incorporate actions from the Offices of Research and Development, and
Communications, Education, and Public Affairs. The response should also address all
recommendations. For corrective actions planned but not completed by the response date, please
describe the actions that are ongoing and provide a timetable for completion. This information
will assist us in deciding whether to close this report.
We have no objections to the release of this report to the public. Should your staff have
any questions, please contact Kimberly O'Lone, Audit Manager, at 312-886-3186 or Janice
Miller, Team Leader, at 312-886-3084.
Attachment
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The Effectiveness and Efficiency
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EXECUTIVE SUMMARY
INTRODUCTION
Since 1993, the Office of Inspector General (OIG) has been
conducting a coordinated body of audit work in the U.S.
Environmental Protection Agency's (EPA) Air Program, that led to
this overall report. We began this effort with a general survey in
1993 and issued a strategic plan in May 1994. We have issued
reports on air grants, toxics, enforcement, state implementation
plans, emission factors, and voluntary programs. This report
culminates our efforts, pulling together overall issues from OIG
and U.S. General Accounting Office work.
The Office of Air and Radiation (OAR) is responsible for carrying
out EPA's Air Program. Its mission is to protect and enhance the
quality of the nation's air resources and protect human health and
the environment from airborne pollutants and radiation. OAR
carries out this mission by implementing the Clean Air Act, as
amended in 1990 (Act), and the 1993 Climate Change Action Plan.
OAR also develops programs to reduce risk from indoor air
pollution and radiation. This report primarily focuses on OAR's
activities under the Act.
OBJECTIVE
The objective of this audit was to determine whether the Air
Program was working effectively and efficiently to make the
nation's air cleaner.
This report is separated into three parts based on the above
objective. Part 1 is the introduction, providing background
information on the Air Program and our audit work. Part 2
discusses whether the Air Program has been effective. Part 3
summarizes our conclusions on whether the Air Program has been
efficient.
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RESULTS IN BRIEF
The Air Program Has
Been Effective in
Reducing Emissions
The Air Program Could
Be More Efficient
OAR data show that the Air Program has been effective in cleaning
the air and reducing the potential for depleting the ozone layer.1
We also concluded that, while the Air Program has generally
operated efficiently, it could also be more efficient.
Between 1987 and 1996, U.S. emissions of all criteria pollutants
declined. Much of this reduction was due to emission controls
placed on motor vehicles and utilities. OAR estimates that,
without the emission reductions, there would have been more
health problems, such as heart disease and respiratory illnesses.
Also, because of OAR's Acid Rain Program, the damage to lakes
and forests has been reduced.
Emissions of ozone depleting chemicals have decreased, through
the phase out of the production of certain chemicals, such as
chlorofluorocarbons (CFCs). Without the phase out of CFCs,
OAR predicts that the depletion of the stratospheric ozone layer
would increase, accompanied by an increase in skin cancer.
The Air Program has generally operated efficiently. Several prior
audit reports found that OAR had good management practices and
good internal controls over operations reviewed. OAR officials,
however, could increase their program efficiency in several ways.
For instance, Air Program officials could improve their relations
with other parties that OAR needs to carry out its mission. These
parties include the Office of Research and Development (ORD),
the Office of Communications, Education, and Public Affairs
(OCEPA), and outside stakeholders, such as states. OAR officials
could also direct more attention to several ongoing activities to
improve their efficiency. These issues are summarized in the
following paragraphs.
1 We did not independently verify information relating to emissions or the health effects of emissions.
Instead, we relied on EPA or other published sources for information in this part of our report.
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OAR and ORD Needed One way the Air Program could be more efficient is if its research
to Ensure That Air and monitoring needs were adequately met. To do this, officials
Research and Monitoring from OAR and ORD agreed they needed to work together.
Needs Were Met Although the officials generally worked well together and agreed
on most of their activities, some areas of disagreement existed.
The disagreements mainly focused on how ORD used its budget
for air activities. ORD has not established a consistent process for
making Agency-wide research planning and budgeting decisions.
Both offices agreed, however, that the fiscal year 1999 process was
an improvement over prior years. The two offices also did not
have a method for resolving disagreements or sharing decisions
with all managers and staff in both offices. Disagreements
between the two offices have resulted in impaired working
relationships. If the offices do not work well together to resolve
disagreements, they may not be making decisions to use their joint
resources in the most efficient ways.
OAR and OCEPA
Needed to Work
Together to Raise
Public Awareness
OAR Needed to Give
Stakeholders
Sufficient Feedback
The Air Program could also be more efficient if it worked with
OCEPA to raise public awareness about air pollution. The public
is important to the success of OAR programs. Officials from the
two offices agreed they have not communicated or coordinated
sufficiently with each other in the past. As a result, OAR did not
always use its resources efficiently. Recently, officials in both
offices have taken steps to improve their working relationship.
They must continue working together to resolve past differences.
A third way the Air Program could be more efficient is if OAR
was more responsive to stakeholders, such as EPA regional offices,
states, and industry and environmental groups, in implementing the
Act. OAR frequently consulted stakeholders for ideas; however,
some stakeholder relationships could have benefitted from more
feedback from OAR. Stakeholders may have perceived a lack of
feedback because (1) they may not have had a clear understanding
of how the stakeholder process worked and entered the partnership
with high expectations, (2) there was not always a formal
mechanism to provide feedback, and (3) the process for working
with stakeholders was lengthy. As a result, some stakeholders
were reluctant to work with OAR again. OAR cannot efficiently
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OAR Needed to
Give Attention to
Several Activities
carry out the Act without the cooperation and help of its
stakeholders.
Finally, the Air Program needs to devote attention to several
ongoing activities to improve efficiency. These activities have
been discussed in prior audit reports and include: leading the state
implementation plan process, developing and improving emission
factors, and issuing air toxic standards. OAR has not considered
these activities high priorities, compared with other program areas.
This resulted in delays and limited funding. Consequently, these
activities have operated inefficiently and may not be achieving
their desired results. For example, state plans to achieve emission
reductions could be delayed. The plans may also be incorrect if the
state's estimates of emissions from major sources are based on
inaccurate emission factors. Also, industry deadlines for installing
controls over emissions of air toxics will be delayed if OAR is late
in issuing standards.
RECOMMENDATIONS
We recommend that the Acting Assistant Administrator for Air and
Radiation:
1. Along with the Acting Assistant Administrator for
Research and Development continue the improvements
made in the fiscal year 1999 research planning process.
2. Work with the Associate Administrator for
Communications, Education, and Public Affairs to establish
procedures to ensure that the offices work up-front with
each other when developing projects to raise public
awareness of air pollution.
3. Establish a process to ensure that feedback is provided to
all stakeholders when OAR has not addressed their
concerns, or has not used the input.
Additional and expanded recommendations are included at the end
of each chapter, beginning in Part 3.
IV
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AGENCY COMMENTS
AND OIG EVALUATION The Acting Assistant Administrators for OAR and ORD and the
Associate Administrator for OCEPA concurred with our
recommendations. They need to provide specific corrective
actions and milestone dates for implementing the
recommendations. See appendices 1,2, and 3 for the OAR, ORD,
and OCEPA responses.
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Table of Contents
EXECUTIVE SUMMARY i
ABBREVIATIONS «
PART 1: INTRODUCTION 1
INTRODUCTION 2
Purpose 2
Background 2
Scope and Methodology 5
PART 2: WAS THE AIR PROGRAM WORKING EFFECTIVELY TO
MAKE THE NATION'S AIR CLEANER? 7
THE AIR PROGRAM HAS BEEN EFFECTIVE IN REDUCING EMISSIONS 8
Criteria Pollutants 8
Stratospheric Ozone Depletion 10
Conclusion 11
PART 3: WAS THE AIR PROGRAM WORKING EFFICIENTLY TO
MAKE THE NATION'S AIR CLEANER? 12
THE AIR PROGRAM COULD BE MORE EFFICIENT 13
CHAPTERS
1 OAR AND ORD NEEDED TO ENSURE THAT AIR RESEARCH AND MONITORING
NEEDS WERE MET I4
Background 14
OAR and ORD Generally Worked Well Together 15
Some Disagreements Existed - 16
Causes of Disagreements 17
Disagreements Impaired Relations and Efficiency 17
Conclusion 1°
Recommendations 18
Agency Comments and OIG Evaluation 19
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2 OAR AND OCEPA NEEDED TO WORK TOGETHER TO
RAISE PUBLIC AWARENESS 20
Background 20
Changing Working Relationship for OAR and OCEPA 20
OAR and OCEPA Did Not Always Work Well Together 21
Relationship Impacted Efficiency 21
Conclusion 23
Recommendations 23
Agency Comments and OIG Evaluation 23
3 OAR NEEDED TO GIVE STAKEHOLDERS SUFFICIENT FEEDBACK 24
Background 24
OAR Asked for Input From Stakeholders 26
OAR Did Not Always Give Feedback 26
Stakeholders Perceived Lack of Feedback 27
Stakeholders Hesitant to Work With OAR 28
Conclusion 29
Recommendations 29
Agency Comments and OIG Evaluation 30
4 OAR NEEDED TO GIVE ATTENTION TO SEVERAL ACTIVITIES 31
Background 31
SIP Processing Needed to be Improved 33
Emission Factors Needed to be Developed and Improved 34
Timely Air Toxic Standards Needed 35
Conclusion 37
Recommendations from Prior Audit Reports 38
EXHIBITS
1 EPA OIG AND GAO REPORTS 40
2 SCOPE, METHODOLOGY, AND PRIOR AUDIT COVERAGE 42
3 ISSUES NEEDING FURTHER STUDY 45
APPENDICES
1 OFFICE OF AIR AND RADIATION RESPONSE 47
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2 OFFICE OF RESEARCH AND DEVELOPMENT RESPONSE 49
3 OFFICE OF COMMUNICATIONS, EDUCATION, AND
PUBLIC AFFAIRS RESPONSE 51
4 DISTRIBUTION 53
Vlll
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Act
CCAP
CFC
EPA
GAO
MACT
NOAA
OAR
OCEPA
OIG
OMB
QMS
ORD
SIP
Subcommittee
UV
Abbreviations
Clean Air Act, as amended in 1990
Climate Change Action Plan
Chlorofluorocarbon
Environmental Protection Agency
U.S. General Accounting Office
Maximum Achievable Control Technology
National Oceanic and Atmospheric Administration
Office of Air and Radiation
Office of Communications, Education, and Public Affairs
Office of Inspector General
Office of Management and Budget
Office of Mobile Sources
Office of Research and Development
State Implementation Plan
Clean Air Act Advisory Committee subcommittee for Ozone, Paniculate
Matter, and Regional Haze Implementation Programs
Ultraviolet
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PARTI
Introduction
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PARTI
Introduction
PURPOSE
BACKGROUND
Since 1993, the Office of Inspector General (OIG) has been
conducting a coordinated body of audit work in the U.S.
Environmental Protection Agency's (EPA) Air Program. We
began this effort with a general survey in 1993 and issued a
strategic plan in May 1994. We have issued reports on air grants,
toxics, enforcement, state implementation plans, emission factors,
and voluntary programs. This report culminates our efforts,
pulling together overall issues from OIG and U.S. General
Accounting Office (GAO) work. See exhibit 1.
The objective of this audit was to determine whether the Air
Program was working effectively and efficiently to make the
nation's air cleaner.
The Office of Air and Radiation (OAR) is responsible for carrying
out EPA's Air Program. OAR's mission is to protect and enhance
the quality of the nation's air resources and protect human health
and the environment from airborne pollutants and radiation. OAR
carries out this mission by implementing the Clean Air Act, as
amended in 1990 (Act), and the 1993 Climate Change Action Plan.
OAR also develops and implements programs to reduce risk from
indoor air pollution and radiation.
OAR is headquartered in Washington, D.C., and is comprised of
four main program offices, as shown in figure 1.
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Figure 1: Office of Air and Radiation
Organization Chart
Air Quality
Planning and Standards
(Research Triangle
Park, NC)
Atmospheric Programs
(Washington, DC)
Mobile Sources
(Washington, DC
and Ann Arbor, MI)
Radiation and
Indoor Air
(Washington, DC, with
labs in Las Vegas, NV
and Montgomery, AL)
OAR Responsibilities
OAR has defined four areas of fundamental responsibility:
implementing the Act; carrying out the Climate Change Action
Plan (CCAP); reducing risks from radon and other indoor air
pollutants; and protecting health and the environment from
radiation. Figure 2 shows OAR's fiscal 1996 resources (excluding
grants), as allocated among these responsibilities.
Figure 2: OAR FY 1996 Resources
(in Millions)
Other
$8.4
Radiation
$13.9
Indoor Air
$18.1
OAR spent the bulk of its resources on responsibilities associated
with implementing the Act. For instance, in fiscal 1996, OAR
spent about $175 million on its own programs to:
• set health-based national ambient air quality standards for
specific pollutants, and help state, local, and tribal
governments develop and implement programs to prevent
and control those pollutants;
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• develop standards to control the release of air toxics, which
are pollutants that are known or suspected to cause cancer
or other serious health effects;
• set standards to reduce emissions from motor vehicles
through tailpipe standards, evaporative emissions controls,
on-board vapor recovery systems, and cleaner fuels;
• operate the Acid Rain program, a market-based program to
reduce sulfur dioxide and nitrogen oxide emissions from
utilities; and
• oversee U.S. efforts to stop stratospheric ozone depletion
by regulating the production, use, and disposal of ozone-
depleting substances, and implementing U.S.
responsibilities under the revised Montreal Protocol.2
Another OAR fundamental responsibility is to implement
provisions of the CCAP. OAR's role is to develop and implement
programs to stimulate and transform the markets for technologies
that reduce emissions for carbon dioxide, methane, and other
compounds that contribute to global warming. OAR allocated over
$69 million from its fiscal 1996 budget to implement the climate
change programs.
A third area of fundamental responsibility is aimed at reducing the
public health risks from radon and other indoor pollutants. OAR
spent almost $18 million on its indoor environments programs.
These activities are authorized by the Indoor Radon Abatement Act
and the Superfund Amendments and Reauthorization Act.
OAR's remaining fundamental responsibility is to protect the
public health and the environment from radiation exposure, upon
which it spent about $14 million. Because our work focused on the
Air Program, we did not evaluate any of OAR's radiation
programs.
2The Montreal Protocol is an international agreement on ozone-depleting substances. The agreement was
originally signed in 1987, and was substantially amended in 1990 and 1992.
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State Responsibilities
SCOPE AND
METHODOLOGY
State and local agencies are responsible for carrying out many of
the Act's provisions. The Act had states take the lead in carrying
out its provisions, because pollution control problems often require
special understanding of local industries, geography, housing
patterns, and other factors. While the law requires OAR to set
limits on how much of a pollutant can be in the air anywhere in the
U.S., it also allows individual states to establish stronger pollution
controls. States are not, however, allowed to have weaker
pollution controls than those set for the whole country.
OAR provides funding to state and local agencies to assist in their „
programs. In Section 105 of the Act, OAR is authorized to provide
grants to state and local agencies. These grants are designed to
help the agencies establish and operate air pollution control
programs. In fiscal 1996, OAR allocated just over $163 million to
these grants. OAR also provided $6.6 million to state and local
agencies for indoor environments programs.
We performed our audit in accordance with the U.S. GAO's
Government Auditing Standards, as issued by the Comptroller
General of the United States (1994 Revision).
As part of this audit, we relied on reports OIG and GAO auditors
prepared. A complete listing of audit reports is included in exhibit
1. The reports we used for this audit were also performed in
accordance with the Government Auditing Standards with the
following exceptions:
OIG Special Reviews3
EPA's Air State Implementation Plan Program
Consolidated Report
EPA's Development of its Proposed Open Market
Trading Rule
3These special reviews were more limited in scope than an audit and were conducted in accordance with
OIG Manual Chapter 150.
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PIG Surveys4
Region 3 Title V State Operating Permit Program
Acid Rain Allowance Trading Program
The standards the OIG and GAO followed gave us reasonable
assurance of the quality and accuracy of the information. We
relied on the information in the reports to reach conclusions on
how the Air Program was managed and cited examples from the
prior reports in this report.
For our audit objectives, we performed a limited assessment of
internal controls, which included reviewing OAR's Assurance
Letters for fiscal years 1994,1995, and 1996. The 1994 report
identified inaccurate data in the state implementation plan tracking
system as an Agency level weakness, but this weakness was shown
as corrected in 1995. We did not detect any material internal
control weaknesses during this audit. However, we continue to
believe that the emission factor program is a material weakness, as
identified in our September 30,1996 report, Emission Factor
Development, EPA OIG Report No. 6100318. We discuss this
issue further in chapter 4.
See exhibit 2 for scope and methodology details, as well as prior
audit coverage. See exhibit 3 for issues needing further study.
4These surveys did not identify potential issues warranting additional audit work. As such, reports were
not issued to the Air Program. They were performed in accordance with Government Auditing Standards, with the
exception of the reporting requirement.
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PART 2
Was the Air Program Working
Effectively to Make
the Nation's Air Cleaner?
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PART 2
The Air Program Has Been Effective
In Reducing Emissions
CRITERIA
POLLUTANTS
Background
Office of Air and Radiation (OAR) data show that the Air Program
has been effective in cleaning the air and reducing the potential for
depleting the ozone layer.5 Between 1987 and 1996, U.S.
emissions of all criteria pollutants declined. Much of this
reduction was due to emission controls placed on motor vehicles
and utilities. OAR estimates that, without the emission reductions,
there would have been more health problems, such as heart disease
and respiratory illnesses. Also, because of OAR's Acid Rain
Program, the damage to lakes and forests has been reduced.
Emissions of ozone depleting chemicals have decreased, through
the phase out of the production of certain chemicals, such as
chlorofluorocarbons (CFCs). Without the phase out of CFCs,
OAR predicts that the depletion of the stratospheric ozone layer
would increase, accompanied by an increase in skin cancer.
The Clean Air Act of 1970 required EPA to identify air pollutants
that it anticipated endangered public health. EPA identified six
"criteria" pollutants, for which it has promulgated the National
Ambient Air Quality Standards. These pollutants are: (1) lead, (2)
carbon monoxide, (3) sulfur dioxide, (4) particulate matter, (5)
ground-level ozone, and (6) nitrogen dioxide. The standards
specify acceptable air pollution concentrations for a geographic
area. The Clean Air Act, as amended in 1990 (Act), classified as
non-attainment areas those places that exceeded the standards and
established deadlines for states to achieve them.
We did not independently verify information relating to emissions or the health effects of emissions.
Instead, we relied on EPA or other published sources for information in this part of our report.
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Emissions Have
Gone Down
According to the most current OAR data, the concentrations of all
six criteria pollutants have gone down, as shown in table 1.6
Table 1:
Criteria Pollutants
Pollutant
Lead
Carbon Monoxide
Sulfur Dioxide
Particulate Matter
(1988 -1996 data)
Ozone/Volatile
Organic Compounds
Nitrogen Dioxide
Air quality
concentrations
% decrease
1987 - 1996
75%
37%
37%
25%
15%
10%
These reductions have occurred in a time of growth. Since the Act
was passed in 1970, the U.S. economy, population, and on-road
miles driven have all increased. These factors are all traditional
causes of air quality problems.
OAR also reported that some emissions have been reduced ahead
of schedule. Sulfur dioxide emissions, which form one of the
components of acid rain, were reduced from the 1980 level of
almost 11 million tons to just over 5 million tons in 1995. This
was 39% below the 1995 allowable emissions level of 8.7 million
tons the Act required.
National Air Quality and Emissions Trends Report, 1996, EPA-454/R-97-013, January 1998.
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The Act Has
Led to the
Reductions
Reductions Help
People and the
Environment
In the National Air Quality and Emissions Trends Reports from
1995 and 1996, OAR attributed the reductions of criteria pollutants
to steps taken under the Act. OAR concluded that changes in
gasoline (oxygenated fuels and unleaded and reformulated
gasoline) and other motor vehicle controls resulted in decreases in
carbon monoxide, lead, and ground-level ozone. Utilities using
new control technologies, such as scrubbers, and switching to low
sulfur fuels, affected sulfur dioxide and nitrogen dioxide
emissions. Finally, a decrease in residential wood burning resulted
in reduced particulate matter emissions.
According to OAR, the emission reductions achieved may help
improve public health and the environment. Exposure to
carbon monoxide, particulate matter, lead, and sulfur dioxide can
result in serious health threats to people with heart disease.
Nitrogen dioxide, ground-level ozone, particulate matter, and
sulfur dioxide can also cause or aggravate respiratory illnesses.
Exposure to lead may also result in neurological impairments, such
as mental retardation and behavioral disorders.
A study prepared for the U.S. Geological Survey found that rainfall
in the Eastern half of the country was 10 to 25% less acidic
because of OAR's Acid Rain Program. As a result, lakes and
streams affected by acid rain will be able to recover, restoring fish
and other life. Forests will also be restored and visibility will
improve.
STRATOSPHERIC
OZONE DEPLETION
Background
Under the Act and the 1987 Montreal Protocol, OAR was required
to write regulations to phase-out the production and sale of CFCs
and several other chemicals.7 These chemicals may be causing the
destruction of the stratospheric ozone layer.
7The Montreal Protocol is an international agreement on ozone-depleting substances. The agreement was
originally signed in 1987, and was substantially amended in 1990 and 1992.
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Emissions Have
Gone Down
Production Bans
Have Led to Reductions
Reductions Will
Help People and
the Environment
CONCLUSION
Emissions of ozone depleting chemicals have gone down. For
example, scientists from the Department of Commerce's National
Oceanic and Atmospheric Administration (NOAA) reported that,
in 1995, the total amount of ozone-destroying chemicals in the
lower atmosphere declined for the first time.
Production bans under the Act led to decreases in ozone depleting
chemicals. NOAA scientists concluded that the decline in ozone
destroying chemicals in the atmosphere occurred because many
nations have limited the production of those chemicals. In July
1992, OAR issued its final rule that limited the production and
consumption of these chemicals. OAR issued allowances or
permits for producing and importing the chemicals. Most major
ozone depleting substances were phased out by December 1995. A
remaining chemical, methyl bromide, may be produced and
consumed through the year 2000, when it will also be phased out.
Halting the depletion of the stratospheric ozone layer will reduce
harmful effects of exposure to the sun, such as skin cancer. Ozone
depletion allows more ultraviolet (UV)-b radiation to reach the
Earth's surface. According to OAR, increased UV-b radiation
causes human skin cancers, cataracts, and impairs human immune
systems. Increased UV-b radiation also reduces crop yields and
threatens plant and animal life.
OAR data show that the Air Program has been effective in cleaning
the air and reducing the potential for depleting the ozone layer.
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PART 3
Was the Air Program Working
Efficiently to Make
the Nation's Air Cleaner?
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PART 3
The Air Program Could Be More Efficient
The Air Program has generally operated efficiently. Several prior
audit reports found that the Ah" Program had good management
practices and good internal controls over operations reviewed. For
instance:
• The voluntary programs for Radon and ENERGY STAR®
used good management practices and developed ways to
estimate their environmental results.
• The Green Lights program had adequate program
operations and internal controls, and it had direct and
specific plans for addressing program barriers.
• EPA regions (1) had adequate procedures in place for
obtaining, reviewing, and approving state implementation
plans (SIPs), (2) established a good working relationship
with Headquarters and states, and (3) worked up-front with
states to get SIPs submitted on time.
• The Office of Air and Radiation's (OAR) Acid Rain
Division developed procedures and effectively
implemented the Acid Rain Permits Program, Allowance
Tracking System, and Continuous Emissions Monitoring
System.
While the Air Program has been efficient in many ways, it can still
improve its efficiency. For instance, Air Program officials could
improve their relations with other parties that OAR needs to carry
out its mission. These parties include the Office of Research and
Development, the Office of Communications, Education, and
Public Affairs, and outside stakeholders, such as states. OAR
could also be more efficient if it directed more attention to several
ongoing activities. The following chapters discuss in detail how
the Air Program could work more efficiently to make the nation's
air cleaner.
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PART 3
CHAPTER 1
OAR and ORD Needed to Ensure That
Air Research and Monitoring Needs Were Met
One way the Air Program could be more efficient is if its research
and monitoring needs were adequately met. To do this, officials
from the Offices of Air and Radiation (OAR) and Research and
Development (ORD) agreed they needed to work together.
Although the officials generally worked well together and agreed
on most of their activities, some areas of disagreement existed.
The disagreements mainly focused on how ORD used its budget
for air activities. ORD had not established a consistent process for
making Agency-wide research planning and budgeting decisions.
Both offices agreed, however, that the fiscal year 1999 process was
an improvement over prior years. The two offices also did not
have a method for resolving disagreements or sharing decisions
with all managers and staff in both offices. Disagreements
between the two offices have resulted in impaired working
relationships. If the offices do not work well together to resolve
disagreements, they may not be making decisions to use their joint
resources in the most efficient ways.
BACKGROUND
OAR has many research and monitoring needs to support its air
programs. Air Program officials perform some of this research and
monitoring, while outside organizations, such as ORD, other
government agencies, or contractors, also perform some. ORD's
activities include a range of functions: technical support, such as
monitoring to detect air pollution trends; long-term research to find
new ways to prevent and control ah* pollution; risk assessments for
new standards and other pollutants; developing measurement and
reference methods; research on the health and ecological effects of
air pollutants; and working on Air Program reports, such as the
Mercury Report to Congress.
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In fiscal year 1997, ORD allocated just over 20% of its Enacted
Operating Plan budget to Air Program activities. ORD used $91.4
million of its $439.4 million budget for air-related research and
technical support activities. As shown in figure 3, of the $91.4
million, about three quarters was for research activities and one
quarter was for technical support.
Figure 3: ORD's Air-Related Resources
FY 1997
Research
Technical Support
The past several years have been a period of change for ORD and
the Agency's research, development, and technical support
planning process. In July 1994, an Agency-wide Steering
Committee issued a report to the Administrator, Research,
Development, and Technical Services at EPA: A New Beginning.
To implement the report's recommendations, in 1996, ORD issued
a Strategic Plan after obtaining input from both within and outside
the Agency. The plan identified priorities, as well as areas for
disinvestment. ORD also established a new planning process
based on priorities identified by the program and regional offices
and risk-based decision-making.
OAR AND ORD
GENERALLY WORKED OAR and ORD generally worked well together and agreed on most
WELL TOGETHER of their activities, such as then" coordination on the newly revised
ambient air standards for ozone and particulate matter. While the
two offices have an overall positive working relationship, officials
from both offices agreed that their working relationships could
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improve if they better resolved disagreements. They need to build
upon this relationship to address the issues cited in this chapter.
SOME
DISAGREEMENTS
EXISTED
Some areas of disagreement existed between the two offices. The
disagreements mainly focused on (1) how ORD used what it
described as its limited resources, and (2) which of the two offices
would perform needed monitoring activities. For instance, ORD
officials decided that, with declining resources, their office could
not continue performing both research activities and all monitoring
activities. Therefore, consistent with its 1996/1997 Strategic Plan,
ORD chose to disinvest in "routine" monitoring activities, while
maintaining the more technical or research-oriented monitoring
networks.8 Air Program officials disagreed with ORD's decision
to phase out some air monitoring activities.
The two offices also disagreed about which office should perform
the monitoring activities. ORD officials believed that, as the
monitoring activities evolved from being research in nature to
more routine, the Air Program should take over the activities. This
transition would allow ORD's limited resources to be devoted to
research. However, OAR expected ORD to continue its traditional
role in providing monitoring support and believed much of the
monitoring in question was not "routine." Air Program officials
stated that they did not have enough time to adequately reallocate
their resources to handle the monitoring when ORD presented
them with a disinvestment plan. OAR also believed that, if
monitoring functions were to be transferred, they should be
accompanied by the associated resources.
One example of a distinction between routine and research-oriented monitoring involved the Agency's
ultraviolet-b radiation monitoring network. Although ORD had considered transferring responsibility for the
network to the Air Program, ORD instead decided to maintain the network, because calibration and operation of the
current state-of-the-art monitors were very technical and, as such, did not constitute routine monitoring.
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CAUSES OF
DISAGREEMENTS The disagreements between the two offices occurred for several
reasons. For instance:
• OAR was concerned that ORD had not established a
consistent process for making planning and budgeting
decisions that provided clear opportunities for input by
stakeholder offices, such as OAR. Although an Air
Program official said the just-completed planning process
for fiscal year 1999 was better than it had been in prior
years, he did not think it was well-defined. Other Air
Program managers also were not sure how, or even if, they
had input to ORD's decisions.
• ORD expressed concern that OAR had not always set
priorities for its research and monitoring needs, or indicated
what activities ORD could eliminate if sufficient funding
was not available to meet all of the needs. According to
ORD, program offices need to convey and prioritize their
research, development, and technical support needs, so
ORD can put the needs in context with those of other
offices.
• Neither office had a mechanism in place for resolving
disagreements over the decisions they made. They also did
not have a way of sharing decisions affecting air research
and monitoring between the two offices and among the
managers and staff within each office.
• The two offices had not agreed on the definition of routine
monitoring and which office should perform such
monitoring.
DISAGREEMENTS
IMPAIRED RELATIONS Disagreements between the two offices impaired working
AND EFFICIENCY relationships and efficiency. Air Program managers were very
frustrated with ORD, because they were not always aware of, or
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did not understand, ORD's decisions on air research and
monitoring activities. ORD officials, in turn, were frustrated with
Air Program officials, because they requested many research and
monitoring projects, without establishing priorities, especially
across the different OAR offices.
If the two offices do not work well together, they may not be
making decisions to use their joint resources in the most efficient
ways. For example, because OAR did not clearly identify its top
priorities, ORD officials could not always make informed
decisions about which Air Program research and monitoring
activities were the most important. If ORD chose not to perform
some activities OAR considered critical, then Air Program officials
would need to find other resources to fund those activities. If the
two offices worked together to establish their joint priorities, then
they could conduct the most important activities, while less
important activities could wait until resources were available.
CONCLUSION
RECOMMENDATIONS
If OAR and ORD worked together to resolve their disagreements
over how air research and monitoring resources should be spent,
and what activities each office should do, they could improve the
efficiency of their joint efforts.
We recommend that the Acting Assistant Administrator for Air and
Radiation and the Acting Assistant Administrator for Research and
Development work together to:
1 -1. Continue the improvements made in the fiscal year 1999
research planning process including making sure that in
future processes:
a. ORD provides a consistent process for making
planning and budgeting decisions, which identifies
opportunities for input from the program offices and
regions at key decision points.
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b. OAR identifies up-front its cross-office priorities,
and both offices agree on the lower priority
activities that will be eliminated if resources are
limited.
c. each office informs its managers and staff at each
critical stage of the planning and budgeting process.
d. both offices commit to resolve differences on short-
term or time-critical issues expeditiously, seeking
higher resolution of disagreements only as a last
resort and doing so together.
1 -2. Use the Agency's Environmental Monitoring Management
Council as a forum for addressing multi-office technical
support issues, such as defining routine monitoring and
which offices should perform it.
AGENC^OMMENl?"
AND OIG EVALUATION Following our briefing on the results of our fieldwork, OAR and
ORD officials concurred that they needed to work together to
resolve their disagreements. In a conference call on September 3,
1997, officials from the two offices proposed several actions they
could take to resolve these concerns. These actions are included in
the recommendations.
Both Acting Assistant Administrators for OAR and ORD
concurred with our findings and recommendations. They need to
provide specific corrective actions and milestone dates for
implementing the recommendations.
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PART 3
CHAPTER 2
OAR and OCEPA Needed to
Work Together to Raise Public Awareness
BACKGROUND
CHANGING WORKING
RELATIONSHIP FOR
OAR AND OCEPA
A second way the Air Program could be more efficient is to work
with the Office of Communications, Education, and Public Affairs
(OCEPA) to raise public awareness about air pollution. The public
is important to the success of Office of Air and Radiation (OAR)
programs. Officials from the two offices agreed they have not
communicated or coordinated sufficiently with each other in the
past. As a result, OAR did not always use its resources efficiently.
Recently, officials in both offices have taken steps to improve their
working relationship. They must continue working together to
resolve past differences.
EPA's program offices individually develop education and
marketing materials, but are to coordinate them through OCEPA.
For example, OCEPA reviews, approves, and distributes education
and marketing materials that the Air Program develops.
Education and awareness are pivotal for OAR's voluntary
programs, such as those to reduce radon exposure, greenhouse
gases, and energy consumption. OAR's Office of Mobile Sources
sees public education as a key to convincing people to reduce
future automobile emissions and accept other alternatives to
driving. The Organization for Economic Cooperation and
Development agrees, and recommended in 1996 that the U.S.
strengthen education to increase public understanding about the
effects of air pollution caused by vehicle use.
Recently, OAR and OCEPA officials have agreed they needed to
improve their working relationship and have begun taking steps to
do so. OCEPA has had a change in management, and plans to
reorganize soon. Anticipation of the reorganization and other
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OARANDOCEPA
DID NOT ALWAYS
WORK WELL
TOGETHER
RELATIONSHIP
IMPACTED
EFFICIENCY
changes have helped OCEPA officials streamline their efforts,
allowing them to concentrate on areas where they will have the
most impact. OAR officials reported that OCEPA staff members
are now more responsive and helpful. Officials from both offices
also meet together frequently. Communication is more open and
constructive, fostering a cooperative relationship, instead of an
adversarial one.
Conflicts between OAR and OCEPA caused tension and resulted
in staff members not working well together. The two offices had
not always coordinated on projects to raise public awareness of air
pollution. For instance, OCEPA officials said that OAR should
involve OCEPA early in educational and outreach projects.
Because Air Program officials did not always do this, OCEPA did
not review the products until they were completed. OCEPA then
questioned the effectiveness or cost of some products. OAR
officials thought OCEPA needlessly delayed the projects with
extensive questions and did not always add value to the projects.
The lack of communication and coordination between OAR and
OCEPA resulted in OAR not always using its resources in the most
efficient way. Staff in both offices were frustrated and had
difficulty working together. Officials felt they were working
against each other, not together to accomplish OAR's mission.
Among other instances, tension was created when:
• OCEPA was not involved with OAR's development of a
refrigerator-style magnet for the ENERGY STAR program.
(See figure 4 for a representation of the magnet.) OAR
created the magnet for contractors to give to the public,
providing information about types of equipment that have
met the ENERGY STAR energy efficiency criteria. OCEPA
officials were disturbed because (1) they thought OAR
should have consulted them about information to include
on the magnet, and (2) the magnet was printed without
OCEPA's approval. An OCEPA official stated that the
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magnet was difficult to read and did not contain useful
information, such as a phone number. OAR officials stated
that it was not clear that OCEPA was supposed to review
magnets before they were released.
Figure 4: OAR Energy Star Magnet
f «*S4=18£B HEA.TPUMPS* "FURNACES
• The two offices could not arrange to work together on a
fast-track project with the American Lung Association.
The American Lung Association and OAR planned to enter
a cooperative agreement to develop a public service
announcement about ground-level ozone. To complete the
announcement in time for ozone season, the project needed
to proceed quickly. OCEPA officials, however, could not
accommodate OAR's request for a fast-track review.
OCEPA's workload would not allow it to look at the
announcement until after the ozone season, in September.
OAR officials were frustrated that OCEPA officials could
not make time to review the project, even though it was
important to them. OAR eventually did not finalize the
planned cooperative agreement with the American Lung
Association because the project could not be completed
timely.
By not working together, the two programs were not operating as
efficiently as possible.
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CONCLUSION
RECOMMENDATIONS
Recognizing that they needed to improve their communication and
coordination, OAR and OCEPA officials have taken steps to begin
improving their working relationship. Working together, OCEPA
and OAR can inform the public about air pollution causes, effects,
and remedies, in common sense ways.
We recommend that the Acting Assistant Administrator for Air and
Radiation work with the Associate Administrator for
Communications, Education, and Public Affairs to:
2-1. Ensure that product review requirements are followed.
2-2. Establish procedures to ensure that the offices work up-
front with each other when developing projects to raise
public awareness of air pollution.
We also recommend that the Associate Administrator for
Communications, Education, and Public Affairs:
2-3. Establish concise product review procedures that serve as a
clear and simple guide to the product review process.
AGENCY COMMENTS
AND OIG EVALUATION Following our briefing on the results of our fieldwork, OAR and
OCEPA officials agreed they needed to improve their coordination
and communication. In August 1997, officials from the two
offices committed to work together. Several of their proposed
actions are included in the recommendations.
Both the Acting Assistant Administrator for OAR and the
Associate Administrator for OCEPA concurred with our
recommendations. OCEPA provided corrective actions, but needs
to provide a milestone date for recommendation 2-2. OAR needs
to provide specific corrective actions and milestone dates.
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PART 3
CHAPTER 3
OAR Needed to Give
Stakeholders Sufficient Feedback
A third way the Air Program could be more efficient is if the
Office of Air and Radiation (OAR) was more responsive to
stakeholders, such as EPA regional offices, states, industry, and
environmental groups, in implementing the Clean Air Act, as
amended in 1990 (Act). OAR frequently consulted stakeholders
for ideas; however, some stakeholder relationships could have
benefitted from more feedback from OAR. Stakeholders may have
perceived a lack of feedback because (1) they may not have had a
clear understanding of how the stakeholder process worked and
entered the partnership with high expectations, (2) there was not
always a formal mechanism to provide feedback, and (3) the
process for working with stakeholders was lengthy. As a result,
some stakeholders were reluctant to work with OAR again. OAR
cannot efficiently carry out the Act without the cooperation and
help of its stakeholders.
BACKGROUND
OAR officials recognize that working with stakeholders is critical
to the success of their programs. According to OAR, "by working
together as stakeholders with common goals, federal, state and
local agencies can help each other in attaining and preserving
clean air in the United States."9
OAR does not have the mandate or the resources to carry out the
Act itself. Instead, the Act encouraged OAR to consult
stakeholders and made state and local entities, with EPA oversight,
largely responsible for implementation. With that responsibility,
Federal funds have also gone to state and local entities. For
example, as shown in figure 5, of OAR's fiscal year 1996
9OAR Stakeholders Page, September 1997.
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resources, 37% went to state and local entities as grants to establish
and operate air pollution control programs.10
Figure 5: OAR Air Grants to State
and Local Entities
500
400
e
.2300
100
OAR Resources
Air Grants
*«'•'
$411.6
$448.2
$441.1
1993
1994
1995
1996
State and local entities also contribute their own resources toward
cleaning the air. In September 1995, the State and Territorial Air
Pollution Program Administrators/Association of Local Air
Pollution Control Officials reported that Section 105 grant funding
accounted for between 4 and 65% of overall air program funding
for selected state and local entities.
Table 2: OAR Air Grants As a Percentage
of Overall Air Program Funding
Number Sampled
14 States
1 1 Locals
High
65%
32%
Low
8%
4%
Average
29%
19%
OAR and its stakeholders share a common goal, working to make
the nation's air cleaner. Together, OAR and its stakeholders can
achieve more than if they worked independently.
10These grants are referred to as Section 105 grants, based on the Act section in which they are authorized.
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OAR ASKED FOR
INPUT FROM
STAKEHOLDERS
OAR often turned to stakeholders for input. According to OAR
officials, one of their most important stakeholders is the Clean Air
Act Advisory Committee, which they were required to establish
under the Act. The committee provides advice to OAR on policy
and technical issues associated with implementation of the Act.
Committee members include a variety of people representing:
states, local entities, tribes, public interest groups, environmental
groups, industry and trade groups, consultants, academia, and
Federal Government agencies.
OAR also involved stakeholders in a wide variety of projects. For
example, the Office of Mobile Sources (QMS) worked with
automobile manufacturers on proposed regulations and to develop
new technology. OMS had also established partnerships with other
governmental agencies, such as the Department of Energy and the
Department of Transportation. OAR worked with 37 states
through the Ozone Transport and Assessment Group to develop
solutions for ozone transport. OAR also solicited input from the
regions on planning and priority setting.
OAR DID NOT ALWAYS
GIVE FEEDBACK
Some stakeholders, however, did not believe they received
sufficient feedback from OAR. Several stakeholders told us that
OAR frequently asked them to provide input, but did not tell them
of the results. For example, members of the Clean Air Act
Advisory Committee subcommittee for Ozone, Paniculate Matter,
and Regional Haze Implementation Programs (subcommittee) said
EPA did not keep them informed of progress on the
implementation plan for the new ozone and particulate matter
standards. OAR received subcommittee recommendations on how
to implement the new standards and later, without further
consultation or input from the subcommittee, released a broad
outline describing how it planned to implement the new standards.
The subcommittee members were initially disappointed with
OAR's outline, and that they were "never briefed on the strategy"
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STAKEHOLDERS
PERCEIVED LACK
OF FEEDBACK
Stakeholders may have perceived a lack of feedback from OAR
because (1) they may not have had a clear understanding of how
the stakeholder process worked and entered the partnership with
high expectations, (2) there was not always a formal mechanism to
provide feedback, and (3) the process for working with
stakeholders was lengthy.
First, OAR and its stakeholders may have entered the stakeholder
relationship with different expectations, when stakeholders did not
clearly understand the process. A U.S. General Accounting Office
report found that stakeholders often worked with EPA expecting to
reach a consensus.11 However, from OAR officials' perspective,
when they ask for input from stakeholders, especially on a
proposed rule, consensus could not always be achieved. In one
example, the State of Washington and OAR worked together on
the Maximum Achievable Control Technology (MACT) standard
for aluminum mills. A state official said that she learned OAR's
expectation of the state role in the MACT development was
different from the state's initial expectation. In this case, state
officials were disappointed that OAR did not use all of their input
when developing the final standard. While OAR officials
considered the state comments, they could not reflect all of the
comments in the final rule, because they were not technically
feasible. Because of their varied expectations, state staff were
frustrated.
Second, stakeholders provide input to OAR and some may expect
to be kept informed of the status. When a stakeholder provides
formal comments to EPA on proposed rules, a mechanism is in
place to address the comments, by either including them in the
final rule or at least responding to the comments, if changes are not
made to the rule. However, there is no such formal mechanism to
1 ^Environmental Protection: Challenges Facing EPA's Efforts to Reinvent Environmental Regulation,
GAO/RCED-97-155, July 2, 1997.
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provide feedback to stakeholders at other stages of the rulemaking
process.
Finally, participating with OAR as a stakeholder is a very lengthy
process. If stakeholders want to ensure their comments are
included in the final rule, they must submit formal comments
throughout the rulemaking process. This process can take up to
two years. OAR often asks stakeholders to provide input when
developing a proposed rule. For example, OAR consults the Clean
Air Act Advisory Committee or the appropriate subcommittee to
get stakeholder input prior to developing a proposal. OAR then
writes the proposed rule and submits it to the Office of
Management and Budget (OMB). OMB can take up to 90 days to
review a proposed rule, and sometimes does not take any action
during the first 60 days. At this time, OMB usually works only
with OAR on the proposed rule. This results in a long waiting
period where stakeholders are left out and do not know what is
going on with the rule.
STAKEHOLDERS
HESITANT TO WORK
WITH OAR
OAR cannot efficiently implement the Act without the
cooperation and help of its stakeholders. Stakeholder expectations
are often higher than what OAR can or intends to meet. These
high expectations can create misunderstandings and hurt OAR's
stakeholder relationships. Relationships that lack sufficient
feedback can leave stakeholders feeling misguided and hesitant to
work with OAR again. For example:
Clean Air Act Advisory Committee subcommittee
members were upset at not being briefed on OAR's final
implementation plan for the new ozone and particulate
matter standards. Several subcommittee members initially
thought "EPA must either redefine the group's role in the
process or disband it entirely." The members were left
wondering why EPA officials asked for input if they did
not intend to use it. The members also wanted EPA to
refine the group's mission, to better direct resources to areas
where EPA would be receptive to suggestions.
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• A state air director said he saw his staffs work on the
MACT standard for aluminum mills as being of limited
value. His staff is currently working on other MACT
standards with OAR, but with a lower amount of effort than
was spent on the aluminum mill MACT. He also has a
lower expectation of results and of what the state's input
can accomplish.
Poor stakeholder relationships result in OAR potentially alienating
a vital resource. If stakeholders enter a partnership with high
expectations, they will likely be disappointed when those
expectations are not met. Stakeholders that do not feel their input
was addressed in a final regulation are more likely to challenge the
regulation through lawsuits.
CONCLUSION
RECOMMENDATIONS
OAR officials need to see working with stakeholders as a process
that involves much more than just accepting input. OAR and the
stakeholders need to have a clear understanding of their
relationship up-front. OAR also needs to provide stakeholders
with sufficient feedback, especially when unable to incorporate the
stakeholders' suggestions. Informal feedback is crucial when there
is no formal mechanism available. Assuring solid relationships
with stakeholders is vital to efficiently achieving the common goal
of cleaning the nation's air.
We recommend that the Acting Assistant Administrator for Air and
Radiation:
3-1. Develop a process to work with stakeholders up-front to
define expectations of the results or outcome of the
stakeholder relationship.
3-2. Require OAR officials to explain to stakeholders the
process for proposing a regulation, including: OMB
involvement, that comments at some stages will not
formally be addressed, and that it can be a lengthy process.
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3-3. Establish a process to ensure that feedback is provided to
all stakeholders when OAR has not addressed their
concerns, or has not used the input.
AGENCY COMMENTS
AND OIG EVALUATION The Acting Assistant Administrator for OAR concurred with our
findings and recommendations. He needs to provide specific
corrective actions and milestone dates for implementing the
recommendations.
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PART 3
CHAPTER 4
OAR Needed to Give Attention
to Several Activities
The fourth way in which the Air Program could be more efficient
is to devote attention to several ongoing activities. These activities
have been discussed in prior audit reports and include: leading the
state implementation plan (SIP) process, developing and improving
emission factors, and issuing air toxic standards. The Office of Air
and Radiation (OAR) has not considered these activities high
priorities, compared with other program areas. This resulted in
delays and limited funding. Consequently, these activities have
operated inefficiently and may not be achieving their desired
results. For example, state plans to achieve emission reductions
could be delayed. The plans may also be incorrect if the state's
estimates of emissions from major sources are based on inaccurate
emission factors. Also, industry deadlines for installing controls
over emissions of air toxics will be delayed if OAR is late in
issuing standards.
BACKGROUND
SIPs, emission factors, and air toxic standards are vital to
achieving some of OAR's fundamental responsibilities, as they
have defined them. For example, to meet its responsibility of
helping state, local, and tribal governments develop and implement
programs to achieve the air quality standards, OAR must assure
that approved SIPs are in place and emission factors are reliable.
To meet its responsibility to develop standards to control the
release of air toxics, OAR must assure that it has a current,
practical plan to develop the standards.
SIPs SIPs are the major mechanisms used to attain air quality standards.
A SIP is a plan made up of the regulations a state will use to clean
up polluted air. The Clean Air Act, as amended in 1990, (Act)
established deadlines for states to submit the plans to EPA for
review and action. States develop a separate plan for each standard
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or air pollutant of concern, such as: ozone, carbon monoxide, and
particulate matter.
Emission factors are sometimes used to estimate emissions from
major sources of air pollution. They are primarily used when more
reliable emissions data, such as monitoring data from continuous
emission monitors or stack tests, are not available for a source.
EPA and states use these emission estimates in many parts of their
air pollution control programs, including: (1) preparation of
emission inventories used in air quality models to develop and
evaluate pollution control strategies, (2) permitting and fee
programs, and (3) emission trading programs.
Air toxic standards, called Maximum Achievable Control
Technology standards, establish pollution controls for all sources
that emit significant amounts of toxic substances into the air.
Potential sources of air toxics include printers, dry cleaners, and oil
and natural gas producers. The standards require all major sources
to install control equipment or change manufacturing processes to
reduce toxic emissions to levels at least as stringent as those
already achieved by the best-performing facilities in a source
category.12 The Act established deadlines for OAR to issue air
toxic standards, requiring OAR to regulate certain percentages of
source categories by November of 1994,1997, and 2000, as shown
in table 3.
Table 3: Air Toxic
Standards Due
(Shown Cumulatively)
Year Due
1994
1997
2000
Percentage of
Standards Due
25%
50%
100%
I2A source category is a group of facilities that generally employ similar manufacturing processes or
produce similar products.
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SIP PROCESSING
NEEDED TO BE
IMPROVED
While regional offices had several good management practices
in the SIP program, OAR could improve parts of the program on a
national basis. For instance, OAR and states had not always met
Act deadlines for submitting and processing SIPs. Late OAR
guidance was the greatest single cause for states submitting their
SIPs late.13 State legislatures often have to pass SIPs into law.
Because this can be a lengthy process, some states need a long lead
tune to develop and put their SIPS in place.
Another major cause of late SIPs was OAR delays in bringing
policy issues to closure. Both our review and an OAR SIP
Improvement workgroup found that some issues were left
unresolved for a long time. For example, OAR needed to resolve
national issues before regions could process some SIPs. In several
instances, Region 2 officials delayed processing state SIPs because
they identified a national issue that needed to be resolved. They
had to wait for a decision from an OAR workgroup before
processing the SIPs. The OAR SIP Improvement workgroup cited
low priority with management as a root cause of this delay.
While states have already submitted many of the original SIPs
required under the Act, they will be required to submit new SIPs to
meet the ambient air quality standards for ozone and particulate
matter that were revised in 1997. As states begin to design
programs to achieve these new standards, they will again need
OAR's guidance and prompt policy decisions to develop their SIPs
efficiently. The longer it takes to get SIPs processed and in place,
the longer it will take to achieve cleaner air.
13EPA's Air State Implementation Plan Program Consolidated Report, EPA DIG Report No. 6400100,
September 30, 1996.
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EMISSION FACTORS
NEEDED TO BE
DEVELOPED
AND IMPROVED
Emission factor development had not met users' demands for new
and revised emission factors.14 Emission factors were unavailable
for many sources of air pollution, and those that were available
were often unreliable. Moreover, OAR had not met the Act's
requirements to develop emission factors for all sources of ozone
precursors. State and industry officials had to use the unreliable
factors to estimate emissions. In cases where no factors were
available, users were forced to rely on "best engineering
judgement," or an educated guess.
OAR cited resource limitations as causing problems with emission
factors. Developing or revising emission factors can be expensive
and can take several years to complete. For example, one revision
cost OAR about $1 million in contract funds and took over five
years to complete. An OAR official said that recent budget cuts
significantly hindered OAR's efforts to revise and develop high
quality emission factors. Resources for emission factors decreased
from $5.8 million in contract dollars and 17.6 full time equivalents
(FTEs) in fiscal year 1992 to $1.4 million and 8.8 FTEs in fiscal
year 1996. This is shown in figure 6.
Figure 6: Emission Factor Funding
FY 1992 through FY 1996
FTEs
Contract Dollars (in Millions)
1992
1993
1994
1995
1996
14Emission Factor Development, EPA OIG Report No. 6100318, September 30, 1996.
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Without reliable emission factors, OAR and the states who use
them cannot be sure that their: (1) air pollution control strategies
target the right industries or products, (2) permitting programs
include all required sources and establish proper emission limits,
and (3) emission trading programs are effective in reducing air
pollution. If these programs are not effective, the nation's air
quality could be adversely affected and people could be subjected
to the health hazards associated with excessive exposure to air
pollutants.
TIMELY AIR TOXIC
STANDARDS NEEDED
OAR has been behind schedule for promulgating air toxic
standards. As shown in figure 7, OAR missed its statutory
deadlines for most of the 21 air toxic standards due in 1992 and
1994. OAR also missed more than 85% of its 26 statutory
deadlines for 1997.
Figure 7: Air Toxic
Standard Deadlines
30
25
20
15
10
5
E3 Standards Due
Deadlines Missed
26
19
V////////////A
13
23
1992
1994
1997
Although the Agency was behind schedule for promulgating air
toxic standards, in 1995, OAR officials actively sought and put to
use many initiatives to speed and improve the process. An Office
of Inspector General (OIG) review of various OAR initiatives
revealed that many had already proven effective at speeding up the
35
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The Effectiveness and Efficiency
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process and others had merit.15 However, to meet the deadlines set
by Congress for future standards (58 are due in November 2000),
OAR must continue and even accelerate the issuance of
regulations.
U.S. General Accounting Office (GAO) reports have identified
limited funding as a reason the Air Toxics Program has had limited
success. In 1991, OAR officials stated that they planned to have
larger budgets for the program in future years. However, those
plans never materialized. For instance, GAO reported that OAR's
1994 budget was reduced by $32 million. The Air Toxic Standards
Program faced a significant reduction to its funding request, when
it was reduced by 51 percent. See figure 8.
Figure 8: Air Toxic Funding
FY 1994
15
n
n
= 10
i
5
n
$14.5
<
\ \ \
' <. ••
•• \ x
<;
—
',
s^-
51%
? $7.1
, • ', 4-
" ^**"*'
Requested
Fnnded
If OAR does not issue the remaining air toxic standards timely, it
will (1) allow industry additional time to operate without using the
best methods available to reduce the air toxics it emits and (2) face
challenges to the standards.
Issuing standards late allows industry more time before it has to
change its methods to reduce emissions. Industry does not have to
change its processes until an air toxic standard becomes effective.
If OAR does not issue an air toxic standard within 18 months of its
^Development of Maximum Achievable Control Technology Standards, EPA OIG Report No. 6100140,
March 19, 1996.
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statutory due date, states are then required to set emission limits for
sources through the state operating permit. State officials are
supposed to determine, on a case-by-case basis, what limit they
think would apply, had a standard been timely issued. If OAR
later issues a different or more stringent air toxic standard, the new
standard does not apply to the permitted source until the next
permit renewal. The Act allows up to eight years for this to occur.
Because of problems with the air toxic standard program, OAR
may be vulnerable to lawsuits. For instance, environmental
organizations may sue OAR to force it to issue standards that are
already late. These groups and the regulated industry may also sue
OAR, because budget problems may impact the quality of the
newer standards. For example, in a December 1994 memorandum,
an OAR official stated that the fiscal year 1995 budget level would
have a significant impact on the Office's ability to meet its
requirements. He said this was especially true for developing and
issuing the 1997 and 2000 standards.16 In an attempt to meet as
many deadlines as possible, OAR reduced the amount of data
collected and analyzed in developing the standards. However,
OAR officials expressed concern that the quality of the newer air
toxic standards may suffer.
CONCLUSION
Because OAR had not considered its ongoing activities of:
• leading the SIP process,
• developing and improving emission factors, and
• issuing air toxic standards
as high priorities, the activities had not operated as efficiently as
possible, experiencing delays and limited funding. If these
activities continue to be low priorities, it is likely that the problems
^Information on EPA's Air and Radiation Program's Budget, 1990-95, GAO/RCED-96-201R, July 1,
1996.
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identified in this chapter will also continue. SIPS will still be
delayed and will be based on unreliable emission factors. Industry
deadlines for installing air toxic controls will also be delayed. As a
result, OAR and state air programs may not be as efficient or
effective as they could be, resulting in continued air pollution.
RECOMMENDATIONS
FROM PRIOR AUDIT Prior audit reports included recommendations to address the
REPORTS concerns discussed in this chapter. For instance, in our 1996 report
on SIPs, we recommended that the OAR Assistant Administrator:
(1) place priority on implementing the SIP workgroup's
recommendations for developing guidance and bringing
policy issues to closure;
(2) place priority on promptly resolving national SIP issues,
including those that impact guidance documents; and
(3) establish realistic deadlines for future SIPs that allow EPA
time to develop useful guidance.
In her April 1997 response to that report, the Assistant
Administrator agreed with the recommendations and provided
steps for implementing them. She also stated that OAR had
emphasized up-front planning for the new ozone and particulate
matter SIPs to ensure that the SIP revisions were submitted in a
timely manner. She identified several actions that she believed
would substantially ease the SIP development effort and result in
SIPs being submitted more timely and being fully approvable.
These actions, when fully implemented, should address our
concerns with late guidance and unresolved national issues. As a
result, we are not making additional recommendations in this area.
In the prior OIG audit of emission factors, we recommended that
OAR declare the program as a material weakness, until adequate
resources were obtained to assure satisfactory progress. OAR
submitted its emission factor strategy to the EPA Senior
Leadership Council and the OIG on November 25,1997. The
strategy provided some actions for correcting the program
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weaknesses. For instance, beginning in fiscal year 1998, OAR will
focus its efforts on upgrading and developing factors for air toxics
and the revised particulate matter standard, as well as those for
non-road mobile sources. We accepted that these actions, when
fully implemented, will address our concerns with emission factor
development. However, we still believe that the program should
be declared a material weakness, until OAR implements the
corrective actions. We do not have any additional
recommendations in this area.
GAO recommended, in 1991, that OAR revise its air toxics
strategy to include all actions, activities, and tasks mandated or
reasonably believed to be necessary to carry out the objectives of
the Act. As of October 1997, this had not been completed. We
believe OAR should still update the air toxics strategy for issuing
the remaining air toxic standards.
39
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The Effectiveness and Efficiency
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Exhibit 1
Page 1 of 2
EPA OIG and GAO Reports
EPA OIG Reports Included in the Scope of this Report
Report Name,
Issuing Office
Survey of EPA Green Lights Program,
Headquarters Audit Division
Regional Management of CAA Section 105 Air Grant Program,
Southern Audit Division
Acid Rain Allowance Trading Program,
Eastern Audit Division
Region 3 Title V State Operating Permit Program,
Mid-Atlantic Audit Division
Development of Maximum Achievable Control Technology
Standards,
Headquarters Audit Division
EPA's Development of its Proposed Open Market Trading Rule,
Eastern Audit Division
Emission Factor Development,
Southern Audit Division
EPA's Air State Implementation Plan Program Consolidated
Report,
Northern Audit Division
Risk Reduction Through Voluntary Programs,
Northern Audit Division
Report
Date
01/17/95
09/29/95
12/12/95
02/06/96
03/19/96
03/28/96
09/30/96
09/30/96
03/19/97
Report
Number
5700002
5100510
(1)
(1)
6100140
6400046
6100318
6400100
7100130
(1) No report number was assigned, because it was an internal survey report.
40
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Exhibit 1
Page 2 of2
GAO Reports Included in the Scope of this Report
Report Name
Air Pollution: EPA's Strategy and Resources May Be
Inadequate to Control Air Toxics
Indoor Air Pollution: Federal Efforts Are Not Effectively
Addressing a Growing Problem
Asbestos Removal and Disposal: EPA Needs to Improve
Compliance with its Regulations
Air Pollution: Unresolved Issues May Hamper Success of
EPA's Proposed Emissions Program
Air Pollution: Actions to Promote Radon Testing
Air Pollution: Difficulties in Implementing a National Air
Permit Program
Air Pollution: EPA's Progress in Determining the Costs and
Benefits of Clean Air Legislation
Air Pollution: Reductions in EPA's 1994 Air Quality
Program's Budget
Air Pollution: Allowance Trading Offers an Opportunity to
Reduce Emissions at Less Cost
Air Pollution: EPA Data Gathering Efforts Would Have
Imposed a Burden on States
Information on EPA's Air and Radiation Program's Budget,
1990-95
Global Warming: Difficulties Assessing Countries' Progress
Stabilizing Emissions of Greenhouse Gases
Peer Review: EPA's Implementation Remains Uneven
Environmental Protection: Challenges Facing EPA's Efforts
to Reinvent Environmental Regulation
Date
06/26/91
10/15/91
02/25/92
09/25/92
12/24/92
02/23/93
02/1 1/94
1 1/29/94
12/16/94
08/07/95
07/01/96
09/04/96
09/24/96
07/02/97
Number
GAO/RCED-91-143
GAO/RCED-92-8
GAO/RCED-92-83
GAO/RCED-92-288
GAO/RCED-93-20
GAO/RCED-93-59
GAO/RCED-94-20
GAO/RCED-95-31BR
GAO/RCED-95-30
GAO/AIMD-95-160
GAO/RCED-96-201R
GAO/RCED-96-188
GAO/RCED-96-236
GAO/RCED-97-155
41
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Exhibit 2
Page 1 of3
Scope, Methodology, and Prior Audit Coverage
SCOPE
We began this work with a general survey of the Air Program in
November 1993. In May 1994, we developed a strategic plan for
the air area. The plan identified ten reviews needed for a
comprehensive program evaluation. The suggested reviews and
the work completed are shown in table 4.
Table 4: Audits Included in the Air Strategic Plan
Planned Audits
Title V Permits
Green Programs
Section 105 Grants
State Implementation Plans
Enforcement17
Acid Rain Emissions Trading
Non-Acid Rain Emissions
Trading
Air Toxics
Indoor Air18
Emission Inventories/Factors
Work Completed
Survey without report
Survey with report
Audit report
Special review report
Audit reports
Survey without report
Special review report
Audit report
Audit report
Audit report
17We originally planned to include air enforcement in this report. Because OAR is no longer responsible
for enforcement, it was not included in this report. Instead, the OIG issued a report (7100306) on ah- enforcement to
the Office of Enforcement and Compliance Assurance on 09/30/97. The OIG also issued reports on validation of air
enforcement data in the states of Pennsylvania, Arkansas, Maryland, and Massachusetts.
18We refocused this audit from indoor air to an audit of Air Voluntary Programs.
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Exhibit 2
Page 2 of 3
After completing the individual assignments, in October 1996, we
began fieldwork to prepare this report on the Air Program's
effectiveness and efficiency. We issued fully-developed position
papers to OAR, ORD, and OCEPA on November 4, 1997. We
held meetings with each office in December to obtain comments
on the position papers. Because we had agreement on the
recommendations included in the position papers, we did not issue
a draft report, and instead obtained formal written responses on the
position papers. Those responses are included as appendices 1 , 2,
and 3.
Following is the methodology we used to answer our objective for
this report.
The first part of our objective was to determine if the Air
Program was operating effectively to make the nation's air cleaner.
To accomplish this objective, we obtained and reviewed EPA,
international, and other government reports. We did not perform
direct tests of the data contained in these reports, because it was
not practical to do so. As a result, we cannot be certain of the
data's validity and reliability.
The second part of our objective was to determine if the Air
Program was operating efficiently to make the nation's air cleaner.
To accomplish this objective, we:
• reviewed prior OIG and GAO audit reports, issued since
November 1990, to identify common concerns.
• discussed these concerns with Air Program management
and reviewed relevant documents they provided to
determine why the similar concerns existed and whether
they were indicators of program- wide problems.
43
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Exhibit 2
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• interviewed officials from regional and state air programs,
and environmental groups, to obtain their opinions on the
efficiency of the national Air Program.
• interviewed officials from other EPA program offices that
OAR works with, including the Offices of Research and
Development; Communications, Education, and Public
Affairs; and Enforcement and Compliance Assurance. We
also reviewed documents they provided, to evaluate how
well the offices worked together to achieve the Air
Program's goals.
PRIOR AUDIT
COVERAGE The OIG and GAO have performed many audits on various
activities of the Air Program, as shown in exhibit 1. We relied on
these audit reports for general information in preparing this report.
We also highlighted four of these audits as containing issues
needing attention, as discussed in chapter 4. Those reports are:
1. EPA's Air State Implementation Plan Program
Consolidated Report, 09/30/96, Report No. 6400100.
2. Emission Factor Development, 09/30/96, Report No.
6100318.
3. Development of Maximum Achievable Control Technology
Standards, 03/19/96, Report No. 6100140.
4. EPA's Strategy and Resources May Be Inadequate to
Control Air Toxics, 06/26/91, Report No. GAO/RCED-91-
143.
For specific details on the findings and recommendations in these
reports, see chapter 4.
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Exhibit 3
Page 1 of2
Issues Needing Further Study
Acid Rain
Emissions Trading
Non-Acid Rain
Emissions Trading
Monitoring Data
Achieving Attainment
During our work in the Air Program, we identified several areas
that may need future study. A brief summary of those areas
follows.
When we performed a survey of this program in 1995, the program
was not yet fully operational. We may want to perform additional
work on the results of the "True-Opt" reconciliation process, where
actual utility emissions are reconciled to the allowances held. This
reconciliation began in January 1996. We may also want to review
the status of states receiving approval of their acid rain permit
programs, which were due in July 1996.
We performed our work on this program in 1996, but EPA had not
established its final open market trading rule, so no trades had been
completed. Since the time of our review, EPA decided not to issue
a rule, but instead issued guidance. We may want to perform
additional work once some trades have been completed under this
guidance to evaluate the internal controls over the process.
This is an area we may want to consider looking at, because it is
critical to how EPA evaluates the results of its air pollution
programs.
We may want to determine whether non-attainment areas are
achieving attainment on schedule. For instance, moderate carbon
monoxide and ozone non-attainment areas were supposed to meet
the standards by December 1995 and November 1996,
respectively. If these areas have not met the standards, we should
evaluate whether the states have fully implemented their state
implementation plans and whether the implementation has resulted
in anticipated reductions in pollution. Furthermore, we should
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Exhibit 3
Page 2 of2
look at what actions EPA took when areas did not meet the
standards timely.
Title V Permits After states have had time to implement the Title V state operating
permit program, we should consider reviewing it. We performed a
survey in 1996, but the program was not fully operational at that
time. Potential audit issues include (1) EPA and state review of
companies that changed from major sources to synthetic minor
sources, thus avoiding the need for a Title V permit, and (2) how
EPA and states have addressed companies who admitted they had
been out of compliance on their permit applications.
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Appendix 1
Page 1 of2
Office of Air and Radiation Response
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
FEB 12 1998
-•i PROI«-& OFFICE OF
AIR AND RADIATION
MEMORANDUM
SUBJECT: OAR's Comments on the Air Theme Report - "The Effectiveness and Efficiency
ofEPA's Air Program" OIG Report ElKAE4-05-0246-xxxxxx
FROM: Richard D. Wilson
Acting Assistant Administrator
for Air and Radiation (6101)
TO: Michael D. Simmons
Deputy Assistant Inspector General
for Internal Audits (2421)
Thank you for the opportunity to comment on the Office of the Inspector General's Air
Theme Report - "The Effectiveness and Efficiency ofEPA's Air Program" (OIG Report
E1KAE4-05-0246-XXXXXX). We have reviewed the OIG's position papers and concur with the
findings and recommendations.
I am pleased that OAR and ORD have made great strides in identifying research priorities
with then- respective programs in the current budget cycle. We will continue to work with ORD
to strengthen OAR's presence and results with the research community. Similarly it is
encouraging that OAR and OCEPA's roles have been clarified and we are proceeding with a
better working relationship between our offices.
As you can see, even after half a decade with this Air Theme Audit, there remains much
work to be done. So I ask not only for the OIG's continued cooperation but also for OCEPA and
ORD to work with OAR to develop plans for implementing the report's recommendations under
the subsequent ninety day review. Please have your offices continue to coordinate any responses
through Pete Cosier (260-7755) of my staff. Thank you. I believe with everyone's cooperation
we will soon be able to complete this theme audit effort.
cc: Henry L. Longest II (8101)
Loretta M. Ucelli (1701)
Kevin Teichman (8104R)
Arnold Bloom (8102R)
Ernest Ragland (2421)
Anthony Carrollo, Director OIG, Northern Audit Division
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)
Note: The original response was signed by Richard D. Wilson.
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Appendix 1
Page 2 of2
Kimberly O'Lone, OIG, Northern Audit Division
Janice Miller, OIG, Northern Audit Division
Rob Brenner (6103)
Margo Oge (6401)
JohnSeitz(MD-lO)
Paul Stolpman, (6201J)
Larry Weinstock, (661J)
Jerry Kurtzweg (6102)
Steve Page (6101)
Carl Mazza (6101)
Kevin Teichman (8104R)
Omayra Salgado (6102)
Pete Cosier (6102)
Arnold Bloom (8102R)
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Appendix 2
Page 1 of2
Office of Research and Development Response
ssy
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
S WASHINGTON, D.C. 20460
FEE-4 1998
OFFICE OF
RESEARCH AND DEVELOPMENT
MEMORANDUM
SUBJECT: Response to DIG Position Papers - "The Effectiveness and Efficiency of
EPA's Air Program"
FROM: Henry L. Longest II
Acting Assistant Administrator
for Research and Development (8101)
TO: Michael Simmons
Deputy Assistant Inspector General
for Internal Audit (2421)
Purpose
The purpose of this memorandum is to convey ORD's response to the Office of
Inspector General's Position Papers - "The Effectiveness and Efficiency of EPA's Air
Program," issued to us in final form on February 3, 1998.
Discussion
We have reviewed the OIG position papers and concur with the findings and
recommendations pertaining to ORD. We are pleased to note that ORD has already
taken certain steps, as part of its FY 2000 planning process, to implement the OIG's
recommendations. Specifically, last month, ORD met with OAR to discuss OAR's
strategic priorities for ORD research and technical support. We will continue to
work with OAR to forge our corrective action plan to the OIG's report
recommendations. We understand that this corrective action plan must be
submitted to the OIG within 90 days from the issuance of the final audit report.
We appreciate the opportunity to work with the OIG and OAR representatives
in developing and reviewing various iterations of these position papers. We believe
this process was insightful and important. We particularly appreciate the extensive
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)
Note: The original response was signed by Joseph K. Alexander for Henry L. Longest II.
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Appendix 2
Page 2 of2
and outstanding efforts of the OIG Northern Audit Division Team Leader in working
with us on this important assignment.
Once again, thank you for your responsiveness to our suggestions on this
effort. Should your staff have any questions or require further information, they
may contact Arnold Bloom at (202) 564-6687.
cc: Richard Wilson (6101)
CarlMazza(6101)
Pete Cosier (6102)
Joseph Alexander (8101R)
Thomas Clark (8101R)
Kevin Teichman (8104R)
PeterDurant(8102R)
LekKadeli(8102R)
Colleen Lentini (8102R)
Arnold Bloom (8102R)
Ernest Ragland (2421)
Janice Miller (OIG/OA/NAD)
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Appendix 3
Pagel of 2
Office of Communications, Education,
and Public Affairs Response
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
COMMUNICATIONS, EDUCATION AND
DEC 16 1997 PUBLIC AFFAIRS
MEMORANDUM
SUBJECT: OCEPA Comments for the Air Theme Report
FROM: Loretta M. Ucelli
Associate Administrator
TO: Michael Simmons
Deputy Assistant Inspector General
For Internal Audits (2421)
We have reviewed and discussed your position papers from the Air Theme audit.
OCEPA is in agreement with the recommendations that effect our office ( Part 2, Chapter 2).
We met with your staff and suggested a few minor revisions, which Janice Miller
assures me are being made to the position papers.
Recommendations and proposed actions:
2-1. Carry out and work within the planned OCEPA reorganization to ensure that
product review requirements are followed and discourage OAR officials from
bypassing the product review requirements.
OCEPA's proposed reorganization plan is being reviewed hi the Office of the Administrator.
We anticipate sign-off before the first of the year and clearance by the Agency by the end of
January. An integral part of the reorganization is the placement of the product review system
within the new Office of Communication. We believe that the program offices will benefit from
a new approach to planning and approving the Agency's information products. OCEPA also
intends to conduct a two day work shop, in mid-to-late February, with representatives from the
program offices and outside stakeholders to assist the Agency in defining and producing the
types of information products that will be useful to various audiences and the general public.
2-2. Establish procedures to ensure that the offices work up-front with each other
when developing projects to raise public awareness of air pollution.
OCEPA intends to update all communications planning procedures to ensure that initial contact
Note: The original response was signed by Diane H. Esanu for Loretta M. Ucelli.
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between ourselves and any program office begins early and is a collaborative effort that will lead
to increased public awareness.
2-3. Establish concise product review procedures that serve as a clear and simple
guide to the product review process for program offices.
An additional benefit of the February product review workshop will be discussions that will lead
to new guidelines (procedures) that program offices will reference when planning to develop
information products. We anticipate that written guidelines, after program input and review,
should be finalized by May, 1998.
If you or your staff have other questions or need additional information, please contact
Diane Esanu, Acting Deputy Associate Administrator at (202) 260-2190.
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Appendix 4
Page 1 of 1
Distribution
Headquarters
Assistant Administrator for Air and Radiation (6101)
Assistant Administrator for Research and Development (8101R)
Associate Administrator for Communications, Education, and Public Affairs (1701)
Agency Followup Official (2710)
Arm: Chief Financial Officer, OCFO
Agency Followup Coordinator (2724)
Audit Followup Coordinator, Office of Air and Radiation (6102)
Audit Followup Coordinator, Office of Research and Development (8102R)
Audit Followup Coordinator, Office of Communications, Education, and Public Affairs (1104)
Associate Administrator for Congressional and Legislative Affairs (1301)
Headquarters Library (3401)
Office of Inspector General
Inspector General (2410)
Regional Offices
Regional Administrators
Regional Air Directors
Regional Audit Followup Coordinators
Regional Directors of Public Affairs
Regional Libraries
All State Directors
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U.S. Environments! P/oteuio,} ,VvnC
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