United States
Environmental Protection
Agency Region 5
905R85105
May 13 - 15, 1985
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SENIOR\MAftAGEMENT CON£Effl:NCE
MAY 13 - 15, 1985
Lee Thomas has been delivering a basic 4-point management plan when
addressing the public. These four points are:
1. Make sure our priorities are those that can have important
environmental results. Implement programs so that we
focus our resources to achieve important environmental
results. Agency management must take steps to ensure that
measuring those results becomes central to accountability.
Over the next few years, adjust internal accountability
system to complement and sometimes replace administrative
measures with indicators of environmental progress.
(In his address to our employees, Mr. Thomas a.ltared thi$-.topic to
good implementation of basic programs. Our summary includes all already
cited above, and what follows:
Improve Agency planning process. Identify and quantify
objectives. Move away from the in-box. Move forward to
make environmental progress. Emphasize Superfund and Hazardous
Waste, but don't divert attention from Water and Air.)
2. Basic management responsibility should be at point closest
to the problem, but still capable of maintaining account-
ability. Continue statutory thrust to decentralize.programs
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and delegate added responsibility to Regions and States.
Define roles at various levels. Establish good, formal
agreements in grant programs.
Increase flexibility for States and localities to implement
Federal standards. Make sure we strengthen our technical
support and oversight. Change policies and practices that
impede this movement.
3. Make sure we have a strong scientific and technical
capability to support decision-making. Collect information
from a multimedia perspective for planning pollution control.
Improve our monitoring, reduce risk, not merely transfer it.
Measurable risk management integrated across environmental
media. Knowledgeable participation of States and localities.
Improve monitoring capabilities to ensure measurement of
environmental results. Ensure good technical capabilities
of staff.
4. Openness to assure that the public knows what we're doing
and that we know their concerns. Increase the emphasis given
to community involvement and public education. All line
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programs develop community relations and public outreach
strategies. Establish forums that consistently provide
input from the public as we make decisions. Explain agency
actions to the public.
He has expanded his 4-point management plan, with two added points.
These are:
5. Strong enforcement emphasis in each program. Division Director
is an accountable manager in every medium. Assure Federal
agencies comply with environmental laws. Work to achieve
compliance. Timely and appropriate enforcement.
6. Assure that we have a strong, competent staff. Recruit the
best people. Retain and reward staff. Develop staff -
provide career growth and challenges. Develop and implement
human resources management concepts in EPA,
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The total of 6-points in the Lee Thomas management agenda serve as
the basis for our senior staff conference. Prior to the conference,
several topics were proposed by employees and managers, which fit
into the Thomas management agenda, additional topics suggested are
listed under the headings of "Supervision and Performance" and "General
Management."
All 8-points are summarized below:
ENVIRONMENTAL RESULTS
0 State involvement in the process must be fostered from
the top (i.e., RA's office).
— employee group
0 What long-term environmental improvement are we seeking;
have we systems in place to get us there? How will we
know (indicators)? What is the State role?
— Springer
0 What are the payoffs from EMRs, etc.? Can we cite them?
— senior staff meeting
Aim's question about managing for environmental results -
are we leaving matters at the level of each medium's
existing program contribution to environmental improvement?
— Al Aim
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Does this Region want to be creative and daring in this
area?
— Springer
0 What are feedback mechanisms to RA/DRA on priorities?
— Springer
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DECENTRALIZE PROGRAMS AND DELEGATE
0 Are our relations with the States working well (e.g.,
Illinois' complaints)? Can they be improved and how?
(see tab section)
-— Adamkus
0 The quality assurance regulation needs to be fully
implemented so that grants are not endangered. ESD's
capacity to implement the Regs, was questioned.
— employee group
0 Compliance with QAPP.
— Sanders
0 Sanctions/Incentives: performance based grants. The
States need to see both sanctions and incentives to
complete their program obligations. While the draft
policy on performance based grants does include both
sanctions and incentives, the incentives portion in
particular is somewhat inadequate, (see tab section)
— employee group
0 State workplan quality varies for each program area. We
need to insist that the quality of workplans is the same
(e.g., RCRA and Water).
— employee group
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Major program growth such as is occurring in Superfund
requires quick, easily updatable materials to:
a. get new people up to speed
b. keep people current as changes occur.
Perhaps HQ could prepare basic issue training cassettes
for this purpose.
— employee group
Support organizations need briefings on major new
requirements, e.g., SCAP.
— Springer
What is the post-delegation workforce supposed to do?
Does it really require changes in behavior and skill?
How do we do that?
— Springer
State relations: what are the strengths and weaknesses
of our current systems? What improvements should be
made?
— Springer
Enforcement: is the partnership with the States real?
Are the agreements adequate?
— Springer
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Are we satisfied with progress on implementation of
Headquarters/Regional relationships (Executive Summary
and PAB analysis under tab).
— PAB
State Coordinators' role.
—- last retreat
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SCIENTIFIC AND TECHNICAL CAPABILITY
0 The EPS classified employees are too often perceived as
"second class" citizens within the organization. They
are, however, technical people and should be treated the
same as technical people in the "scientist" and other
series. (N.B. Cross reference Bollo memo under General
Management Topics, "Results of Performance Standards
Review" — Region V has abnormally high percentage of
EPSs, compared to other parts of EPA.)
— employee group
0 Is the Region V monitoring effort effective?
National Journal raises several issues, regarding the
data, collection and use (see tab).
— PAB
0 Are the TCC, 6WCC, and in-place pollutants task force
effective or appropriate means to address these issues
across media lines?
— Springer
0 What is the future of the GWCC: how well is it operating;
how to get WMD more involved?
— Sutfin
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Are we and States planning our monitoring programs
effectively? Are the resources there to do the job?
— Springer
What is Region V perspective on National Monitoring
Strategy workgroup? (Enclosure)
— Springer
Effective use of PC technology by mid to upper level
management.
— Sanders
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PUBLIC OUTREACH
Has PAO gotten the feedback on its outreach strategy it
needs to work with programs effectively? (see tab.)
— Springer
Does the RA have emphasis or special initiatives for the
Region?
— Adamkus
Does Superfund community relations strategy suggest
changes for other media programs? (see tab.)
— Thomas
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ENFORCEMENT EMPHASIS
0 Federal facility compliance questions continue to plague
the Region's management.
— Levin
0 Do Division Director's standards reflect an enforcement
approach?
— Thomas
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HUMAN RESOURCES MANAGEMENT
0 The need to strengthen the bonds of communication,
cooperation and mutual support among our secretaries
at all levels. Do we need a secretarial management
retreat?
— Kee
0 Rotational training program, high potential program
for professional staff.
— Sanders
0 More aggressive training of clericals to better utilize
word processing equipment; upgrading clericals (money).
— Sanders
0 Personnel/Recruitment Standards
Attention should be paid to the personnel system in order
to assure that high standards are set and that we get
excellent people. There seems to be too much of a tendency
to accept mediocrity. The performance standards could be
used to grant raises. We need more ways to reward a job
well done.
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In order to prevent mediocrity once people are hired, we
must strive to select the best people at the beginning.
The checklist approach of the SF-171 hurts our recruitment
of top people.
Alan noted at this juncture that while some things could
be done to make the system work better, there are real
constraints which limit us. For example, veterans
preference is part of the system.
— employee group
Need to develop people with experience across Division
lines for current and future openings. PAB, GW, and
other jobs are appropriate for rotation.
— Sutfin
Senior staff rotation should be real possibility, so
future career paths open.
— Levin
Supervisors and managers are not using direct hire,
Schedule 8 and other flexible recruiting techniques
(see tab).
— Springer
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0 Human Resources
Before AT Aim left the agency, he circulated a memo urging
a strong human resource policy/program. Questions as to
the implementation status of that program were raised.
Alan Levin traced some of the history of the program and
highlighted some examples of what was being done. He noted,
however, that the failure to make employees aware of these
activities was a major problem.
— employee group & Levin
0 Human Resources
Prior to the senior staff retreat, Nick Bollo interviewed
several members of the senior staff regarding human
resources management; his summary is behind the tab.
— Bollo
Upward Mobility
The upward mobility program was praised as a good idea.
However, participants felt that the program could be
better defined for each individual. There was a sense
that specific training on the roles/responsibilities of
the individual would help. Some sort of "measuring stick"
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was also suggested to guide the employee and help them
assess how well they were doing the requirements of their
job title.
— employee group
0 Training
A number of issues related to training were raised. The
issue of timeliness in regard to training was viewed as a
problem. While the training calendar does come out early,
there should be some sort of follow-up system to remind
people about specific training opportunities.
There was also concern voiced as to whether or not training
information was filtering down quickly or at all. Do
notices of training opportunities stop at the Branch or
Section Chief's desk?
— employee group
0 Affirmative Action
How well are the affirmative action goals for minorities
in supervisory positions being met? Recruiting for
minorities has been confined to the 6-state Region V area.
We need to tap a wider area and particularly focus on
Black colleges.
— employee group
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Supervisory Grooming
We should do more than just formally train supervisor.
People with supervisory potential should serve on
rotational assignments in areas like PAB, State project
officers, and State coordinators. The assignment would
provide the necessary agency perspective as well as
acquainting them with specific program, budget, planning
and policy activities.
— employee group
Awards System
The award system is sometimes viewed as too politicized.
There also is some perception that performance reviews rate
low in order to keep down the number of awards, especially
in time of tight budgets.
Alan Levin noted at this point that the performance
appraisal system would be discussed and assured participants
that the Region had no quota for awards. In regard to
finding more ways to reward good work (see above) noted
that we didn't want to cheapen awards by having too many.
— employee group & Levin
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A calendar of awards should be developed along with a
month in advance "tickler" system to remind people.
Region V gives less awards than other Regions. We are
getting better and we don't want to cheapen the award
process but more could be done.
— employee group
Review Panels
Review panels provide reviewers with a good opportunity
to learn more about the hiring policies, how successful
SF-171's are prepared, and what the various job classifica-
tion skills are.
— employee group
Awards
Do we have an adequate dollar range in our awards?
— anonymous managers
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SUPERVISION AND PERFORMANCE
0 Supervisors need better training especially in relation
to dealing with the problem employee. They should learn
to recognize problems before they become full blown.
Supervisors need both the knowledge and confidence to
deal with problems before they become major.
Alan Levin noted that many supervisors have had supervision
thrust upon them. He also explained the supervisory
training already begun.
— employee group & Levin
0 In considering issues for the retreat, I've some up with
a number of items which can all be related to the performance
management system. Briefly, these items are:
Ratings:
- the curve concept, its implementation and how
management presents it to our employees
- the use of the same curve for supervisory
employees
- training, or workgroups to discuss performance
evaluations and foster a more consistent approach
across the Region
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Performance Standards:
- establishing standards that have greater
consistency across the Region
- periodic additions to standards to recognize
"the latest initiative"
- appropriate standards for office/divisions
which provide support to program implementation,
but are not directly accountable for the actual
outputs they impact.
— Constantelos
Proliferation of generic items for incorporation into
managers performance standards. We are deviating from the
original intent, formal agency guidance and, in the process,
restricting usefulness of the standard.
— Sanders
Personnel has completed another analysis of standards,
scores, and awards. That analysis is under the tab.
— Bollo
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GENERAL MANAGEMENT TOPICS
0 Compressed Work Week Schedules
It appears that senior management does not support the
idea of the compressed work week. However, based on an
informal survey in one Division, it appears that middle
management sees an improvement in the use of sick/annual
leave because of the compressed work schedule.
The staff conceded that compressed work week might cause
some problems for supervisors but that the benefits for
staff were significant.
The 6:30 a.m. starting time was criticized. One attendee
felt that the tme between 6:30 and 7:00 was non-productive
time and suggested that a 7:00 start time should be the
earnest, it was also suggested that the earliest end time
should be after 3:30 p.m., due to the tendency of work to
stack up in the late afternoon. Staggering departure
times would also be a way of assuring that adequate coverage
for the office was available.
— employee group
0 Compressed work week/flextime: should the "standard" work
day be compressed to eliminate very early start times and
very late completion times?
— Sanders
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0 Prior to the conference, Personnel completed an analysis
of alternate work schedules. Their analysis is under the
tab.
— Bollo
° Timeliness
Citing the invitation to this meeting as an example, the
issue of timeliness was raised. Often by the time letters,
requests, etc., get to the person responsible for answering
the turn around time is extremely short. Designation of
someone with each office to expedite and track these things
might help get requests to the proper people and responses
back in a timely fashion.
— employee group
0 SPMS
This problem may be unique to the Air Program. The Air
program needs specific input from Regional Counsel as
part of its SPMS reporting process. The crunch comes at
the end of the quarter when Regional Counsel has their
hands full with their own SPMS reporting. Could some SPMS
reporting be done on a month-to-month basis to avoid the
crunch at the end of the quarter? Is this a problem
between other Divisions and Regional Counsel?
— employee group
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"Turf Issues"
There appears to be a lot of competition between the
program offices with resultant insularity and turf battles.
It would be more productive to articulate the agency goals
and make these known to all employees. By fostering an
integrative approach (i.e., how each piece fits into the
articulated "whole" or mission) some of the worst excess
of turf battles might be overcome.
— employee group
0 Data Processing
What are the implications of the number of PC's coming into
the Region. How will this affect work station design,
time budgeting, etc.?
— employee group
0 Grade Inequity
The growing inequity between staff attorney grade levels
and those of program professional staff doing equal level
work.
— Kee
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0 Lapse
Who controls lapse? Some Divisions are hiring as if
they do, not the RA.
— Springer
0 A review of some of our management successes, e.g.,
managing lapse and awards.
— Kee
0 Perceived need for more personnel in Personnel Branch.
. — Sanders
u How can Personnel Branch and Divisions work together more
constructively?
—- Sutfin
FOLLOW UP
These types of sessions are useful and should be held more
often and at the Division/Branch level.
We agreed to report back to the participants on the outcome
of the retreat. We agreed to hold a second session with
the group after the retreat.
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The group suggested that a memo on the retreat be sent to
all employees afterwards. This memo should detail the
issues discussed and their resolutions.
RA/DRA need to get around to the various work areas more
just to be seen.
— employee group
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rf» EDA United States
Environmental Protection
Agency
Washington DC 20460
"The Next Four Years:
An Agenda for
Environmental Results"
Address by
Lee M. Thomas
Administrator
U.S. Environmental Protection Agency
at the National Press Club
April 3, 1985
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George Bernard Shaw once observed that there were
two kinds of work in the world. The first consisted
of moving objects from place to place on the surface of
the earth and the second consisted of telling other
people to do so. While environmental protection consists
largely of the first type—moving stuff from a place
where it may do harm to a place where it won't-EPA's
role is to define when, where, and how the move should
take place.
Doing this sort of work right requires an enormous
amount of careful thought. "Careful" because the laws of
nature, which rule that work, are unforgiving, and not
subject to amendment on Capitol Hill. Doing it right also
requires a minimum amount of stability, continuity, and
consistency. It can't be done in a firehouse atmosphere.
If it is done "carefully" and "right", the benefits for us
and our children can be immense.
For that reason, we must dedicate the next four years
to obtaining measureable environmental results. We
must improve the management of our programs and
increase our understanding of what the Federal
environmental protection enterprise can really
accomplish.
Beyond that, we must begin to pursue a neglected
facet of EPA's original charter. That is the integration of
all environmental programs into a managed system,
capable of focusing Federal authority on the reduction ol
environmental impacts wherever they are found, in the
most effective and efficient way.
This is a pragmatic approach to a set of issues that
have often been dominated by symbolic and political
concerns, but I think its time has come. EPA has been
given—perhaps not in the most thoughtful way
possible—an almost frightening armory of powers. It can
affect almost every aspect of American life—what we eat
and drink and how much we pay for it. what we drive,
what kind of gas we use, the kinds of jobs we can work
at—from the laundry room to the board room. EPA is
there.
This power makes it vital that we stay smart about
where and how we insert it into our society. Americans
have said over and over again that they want
environmental protection, and that they are willing to
sacrifice other goods to get it. What they haven't said.
and won't say. is that they are willing to make sacrifices
for nothing, or. at any rate for not much.
That is why I stress results. EPA is under obligation tc
show what we have accomplished in terms ot concrete
environmental values. Not how much money we •-• at.
or how many people we employed or how mui ,jer
we moved. People want to know, is the air death i' Is
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the water cleaner? Have risks been reduced? Have the
most risks been reduced for our cost and theirs?
We must make sure that our efforts over the next four
years are concentrated on the reduction of important
environmental risks, at places and in situations where
the Federal power is essential. It is not efficiency alone
that demands this discipline.
Nothing erodes the public's tolerance of a regulatory
agency more than the imposition of burdens that appear
to have only petty results in terms of some substantive
public benefit. At the same time, nothing erodes the
public's faith in a regulatory agency more than the
appearance that it is not, for whatever reason, acting
aggressively in the public interest.
v My perception is that we have at this point achieved a
reasonable balance between these two poles. I don't
want to see the pendulum start swinging again, because
if it does, the Agency will once again be distracted from
its important goals by controversy and political friction.
We have to be particularly careful at present because
we are moving to control areas that will have a more
direct effect than ever before on the daily lives of our
people. For example, we have implemented inspection
-and maintenance programs that Congress mandated for
automobiles in about thirty metropolitan areas that do
not meet air pollution standards. We are in the process
of removing most of the lead from gasoline, which will
affect millions of people across the country. And we are
looking at controlling the vapor released when you fill
your gas tank, which may add to the inconvenience of
filling up the family car.
As we continue to focus on improving the
performance of our sewage plants, people may see their
sewage bills going up. In extreme cases, as happened
recently in one major city, new connections may have to
stop until the necessary improvements are made. The
imposition of expanded federal drinking water standards
requiring increases in monitoring costs for local
governments may result in water bill increases in many
communities.
Perhaps the most widespread of these more personal
impacts will occur in the thousands of communities
affected by our programs to control hazardous waste. We
must decide how much to clean up Superfund sites and
where to treat, store and dispose of the more than 250
million tons of hazardous waste we produce each year.
These decisions are site-specific. They may change from
site to site, depending on unique site characteristics of
each. In every instance, however, there is a concerned
community that will be affected by what happens.
With that potential to affect people, the obligation to
focus our resources to achieve important environmental
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results should be obvious. But it isn't that simple.
In the first place, we always—always—underestimate
the complexity of the environmental problem we want to
control and the difficulty of operating the control
program. In other words, what comes out of a committee
room in Washington as a mandate often has little
connection with what comes out of some pipe in Ohio.I
consider this to be one of the greatest lessons that can be
derived from fifteen years of Federal environmental
protection efforts.
In the second place, EPA is not so much a coherent
national program to manage pollution as it is a reflection
of the success that many independent interests have had
in getting their positions established in the law. There
are air interests, drinking water interests, fish interests,
and interests devoted to particular diseases.
There is the regulated community, of course, with
another host of interests. And the pollution control
industry, a new big business, has interests of its own.
Carried to the extreme, the success of these interests
could burden EPA with a set of mandates so vast that no
resource base within the realm of economic reason could
possibly cany all of them out.
We must choose to do the things that seem to us to be
important, and do them well. We must tell people why
we think they are important and why we didn't do other
things we think are less important.
This is a sure recipe for getting flak, since the interests
that your priorities have served take it for granted, and
the interests you have not served pillory you for neglect.
But the alternative is to pretend to do all the things we
are on the hook for doing, and set up programs that
create a lot of sound and fury without really
accomplishing much. Nobody at EPA wants to do that.
What, then, are some of the important problems?
Where do we think our efforts must be concentrated over
the next four years to achieve the maximum
environmental improvement? Such efforts must involve
taking fresh looks at the problems of the older programs
that form the backbone of EPA. They also include
ensuring that some of the newer ones are making
progress in real environmental terms.
Sewage treatment is important. We have spent nearly
$40 billion on this program. The good news is that a
steadily increasing percentage of Americans are being
served by adequate treatment; 57 million people have
been added to the system since 1972.
However, 13% of the 3600 largest systems do not
comply with their permits. Others are overloaded or
subject to frequent breakdowns. Many communities have
chosen not to, or are not able to. operate and maintain
their plants properly.
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In addition, in order to meet the legal requirement for
universal secondary treatment there remains billions of
dollars worth of new construction needs. But half of this
"unmet need" exists on streams that meet water quality
standards already. Is this a good investment? If so, who
should make it?
Our efforts in this area will be focused on stiffening
our enforcement against municipal facilities, and
providing technical advice to the states on operation and
maintenance problems. Additionally, we must do this
while exploring ways for converting the federal
construction grants program to something states and
localities can manage on their own. It was never
intended to be a permanent federal program.
Controlling ozone and the other major air pollutants is
another important area. While I appreciate the concern
about more exotic toxic air pollutants, we should not
forget that controlling the criteria pollutants remains the
best way of preventing public health and property
damage from the effects of air pollution.
There are still 54 urban areas that clearly do not meet
ozone standards and 72 areas that do not meet carbon
monoxide standards. We have until 1987 to bring all of
them into compliance. Also, we are starting to see that
our basic strategy for dealing with these pollutants, a
strategy that assumes that the major environmental
effects are in the airshed where they are released, may
be mistaken in some important cases. We may have to
start taking a regional view when establishing pollutant
limitations.
It is now also becoming apparent that atmospheric
chemistry is far more complicated than we imagined
only a few years ago. Many pollutants interact; changing
the level of one may decrease or increase the level of
another. Part of the difficulty we have faced in deciding
on the best way to deal with the acid rain issue is only
the most familiar of these problems. There are others.
We intend to take this new understanding into
account as we work with the states over the next four
years. Naturally, we hope that they are also taken into
account as Congress considers reauthorization of the
Clean Air Act.
Non-point source water pollution — another important
area. If we don't do something about this kind of water
pollution, which comes from drainage off farms and
urban areas, then on many water bodies we will never
reach the ambitious goals of the Clean Water Act. It
won't matter how hard we clamp down on point sources
such as industrial outflows, the water will stay dirty.
Dealing successfully with this kind of water pollution
is a much more difficult matter than establishing
required control technologies for industrial plants.
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Successful attacks must vary with locality and often
involve changes in land use or agricultural practices.
What we do about non-point pollution will have an
enormous impact on the nation's wetlands—and
wetlands are important. They are the most productive
areas for a host of environmental values. In the past two
centuries we have converted about half of America's
original body of wetlands in the lower 48 states to other
uses.
While we have been successful in protecting some
particularly critical wetlands, it remains a fact that
Federal, state and local programs do not deal with
wetlands consistently. Some may encourage conversion
while others try to halt it. At EPA. decisions affecting
wetlands are typically made case-by-case, without an
adequate strategic context, and they consume inordinate
amounts of time and effort.
I have the sense that we are observing an enormously
important part of our heritage being nibbled away
without us taking the time to state how we would like it
to be, now and into the indefinite future. We need a
strategy that incorporates an analytic basis for making
decisions about wetlands so that EPA's activities in this
area will make long-term sense.
Finally, we have the problem whose apparent
importance has eclipsed that of all others in'recent
years—what to do about toxic substances and all that
hazardous waste.
I think we recognize that nothing is more critical than
continuing and completing our review of all existing
chemical and pesticide products. We must ensure that
our most stringent health-based standards are complied
with. At the same time we cannot neglect the thorough
review of new products proposed for the market.
As far as hazardous waste is concerned. I am
beginning to sense a change in attitude on the Superiund
side of this issue reflected in the kinds of questions we
have been getting from Congress. I believe this is the
result of our increased understanding of the dimensions
and complexity of the problem.
In its recent report, the Office of Technology
Assessment came to an important realization, one that
we in EPA had reached through first-hand experience. It
is that our clean-up program is operating on the cutting
edge of pollution control technology. Each site presents
a complex and unique problem, whose solution strains
current analytic tools.
Although we do not want to slow the momentum of
the Superfund program, we must realize that we run the
risk of serious errors if we try to force technical
solutions at sites where they are really not appropriate.
OTA recognized that it makes little economic or
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environmental sense to undertake costly long-term
clean-up projects until we are sure that we have the
technology to do it right.
Of course, we must continue to locate immediate
environmental and public health threats and deal with
them effectively, which is what we have been
concentrating on. Our proposed extension of Superfund
will enable us to continue with these important actions.
If Congress keeps this in mind, I think we will get a
better reauthorization than we could have expected a
year ago. And four years hence we will have a good
chance of saying that this seemingly intractable problem
is under adequate social control.
On the RCRA side, we have created a program that is
going to rattle through the entire economy of this
country like a golf ball down a drain pipe. We generate
over 250 million tons of hazardous wastes every year.
During the next four years I would like to see us settle
the debate about whether, where and when we should
bury it, burn it, detoxify it, shoot it down a well, or stop
it from being produced at all. I would like to see us
make these decisions, and those connected with
Superfund remedial action, on the basis of solid analysis
of the risks and costs involved in all the options.
Additionally, I believe we need to pay a lot more
attention to community relations in those places most
affected by hazardous wastes, in the belief that local
people can help us make intelligent risk management
decisions when we share the available information with
them. For that matter, citizens can contribute to making
better decisions in all environmental areas. I intend to
stress community involvement in each of our line
programs.
I have been talking about concentrating on the
important problems, but just as important is the manner
in which we exercise this concentration. It is by now
well known that pollution can move among the
environmental media—from air to water, from surface
water to groundwater, from water to soil, and so on.
But EPA is composed of individual programs, each
carrying out a particular statutory mandate. These are
typically focused on individual media. It is
understandable that someone under the gun for
instituting water cleanup may not have paid the closest
attention to the effect on the air resulting from that
cleanup. But someone should have. From now on,
someone will.
Let me give you a few examples. I mentioned
non-point source pollution as a priority. One way of
preventing pollution of surface water from agricultural
run-off is to institute certain management practices
designed to keep water on the land for a longer time, so
-------
that it will soak into the soil. But when it soaks into the
soil it carries with it the whole chemical
brew—pesticides, fertilizers, herbicides—that we use to
keep our farms productive. We now have a
pesticide-in-groundwater problem of unknown
proportions. Obviously, anything we do to correct
non-point-source pollution will have to take this transfer
into account.
I also mentioned the importance of controlling criteria
pollutants. Look at the foundry industry. This is a
classic "smokestack" industry where we have done a
good job in controlling these pollutants. Now the
foundry industry has a serious water pollution problem,
over eighty percent of which, in some foundries, comes
from the wet scrubbers we mandated to control the air
pollution.
Finally, I mentioned the importance of improving
sewage plant performance. I will add that the settling
ponds and lagoons used in many of these plants are, in a
number of industrial areas, a significant source of toxic
air pollutants. The toxics come from industrial plants
that discharge into the sewer system.
We will be able to control much of this problem
through pre-treatment—the removal of the toxic material
at the source. But if you have followed my argument you
can see that this is yet another inter-media
transfer—from water into hazardous "solid" waste,
which will have to be disposed of in some way.
This circle game has to stop. It is expensive. At best it
is misleading—we think we are solving a problem and
we aren't. At worst, it is perverse—it may increase rather
than reduce pollution risks. It seems to me that the
solution to this problem is the consistent application
across all Agency programs of what we have been calling
risk management.
Reducing risk—to human health and environmental
values—is after all the reason we remove pollutants from
the environment. It is the currency of our business. By
closely watching the movement of pollutants that results
from regulatory options and calculating the attendant
risks for each we can assure the public that our actions
are indeed connected with a measureable, permanent
good.
Of course, once you start working with a risk
currency, EPA becomes something more than the sum of
its programs. We can start looking at the risk-reduction
potential of the various programs and directing resources
where this potential appears to be greatest. We intend to
begin doing this as a normal part of our budgetary
process in the coming years.
The approach has, of course, some obvious problems.
It is relatively easy to compare the risk of a single public
-------
health effect delivered via two different media. We can
agree that a one in a million chance of getting cancer
from drinking water is pretty much equal to the same
chance of getting it through breathing something in the
air. But what about comparing the chance of human
disease with the chance of harming the marine
environment?
I'll give you a concrete example. Let us say that if you
incinerate particularly toxic wastes on land there is
always some residual risk to the surrounding human
population. If you incinerate at sea, that risk virtually
disappears. But there is a quite small though still
calculable possibility that something could happen to
the incineration ship, with unpredictable effects on
marine organisms. Do you allow the ship to sail?
I can't see how you could solve dilemmas such as this
without a lot of information on risks, costs and
probabilities, and without the ability to respond flexibly,
depending on what that information yielded. Most
important, you need that kind of information to
communicate to the public how the decision was made,
what your values are, and how you balanced all the
factors involved.
In summary, then, I see a four-point environmental
management plan emerging over the next four years.
First we will make sure that our priorities are those that
can have important environmental results. We will take
steps to ensure that measuring those results becomes a
central part of Agency management. Over the next few
years I want to complement and in some cases replace
the largely administrative measures in our internal
accountability system with indicators of environmental
progress for each program.
Second, we will continue the strong movement
envisioned in our environmental statutes to decentralize
our programs and delegate additional responsibility to
Regions and States. Environmental protection is too large
a dog to be wagged by a tail clutched in Washington. We
intend to do everything we can to increase the flexibility
with which states and localities may implement Federal
standards. We will also strengthen our technical support
and oversight role. We must continue to change policies
and long-standing practices that impede this movement.
In this regard, we will continue our efforts to collect
information on risk in particular areas subject to unusual
environmental stress. Such information gives us the
ability to work with states and localities to tailor
environmental solutions to the varying needs of dift'ereai
geographical areas. We have launched a number of
projects aimed at giving states and localities the kind of
information they need to make intelligent risk
management decisions.
-------
Third, we will increase the emphasis we give to
community involvement and public education. At
present, we require a detailed community relations plan
for all Superfund sites. We have recommended that this
be embodied in law. I have also asked that all the line
programs develop community relations and public
outreach strategies. If what we are doing makes sense,
we ought to be able to communicate that to the grass
roots better than we have in the past. We must also
establish forums that consistently provide input to us
from the public as we make decisions which affect
peoples' lives.
Finally, we must plan control solutions with a
multimedia perspective. We have to reduce risk and not
merely transfer it. Building an integrated management
structure at EPA will not be easy. But we have some of
the elements in place, and we have the will to do it. We
must focus our resources on the most important
problems, and fix them so that they stay fixed.
And we can't do that without some kind of
measurable risk management integrated across
environmental media. We can't do that without the
knowledgeable participation of states and localities.
Most of all. we can't do that without strong public
support.
Thank you.
-------
United States
Environmental Protection
Agency
Office of .
Public Affairs (A-107)
Washington DC 20460
April 12, 1985
&EPA Management Memo
THOMAS MAPS
PLANS FOR EPA'S
NEXT FOUR YEARS
JfiNET 3. MflSON
US/EPfl REGION 5
230 SOUTH DEflRBORN STREET
CHICflGO
IL 60604
In his first major environmental policy statement,
Administrator Lee Thomas outlined a four-point
environmental management plan to guide EPA operations
over the next four years.
Speaking before "the National Press Club in
Washington, D.C., Thomas presented his management plan
in the course of a program-by-program review of the
Agency's operations.
The first item on his agenda as EPA Administrator,
Thomas said, 'is to encourage Agency management to
concentrate its efforts on projects that promise
"important environmental results."
"We will take steps to ensure that measuring those
results becomes a central part of Agency management,"
Thomas said. He added that "over the next few years,
I want to complement and in some cases replace the
largely administrative measures in our internal
accountability system with indicators of environmental
progress for each program."
Saying that environmental protection is "too large
a dog to be wagged by a tail clutched in Washington,"
Thomas gave as his second management objective a step-up
in efforts to delegate additional responsibility to
Regions and states. He said EPA would encourage states
and localities to employ greater flexibility in
implementing federal environmental standards. This
would be accompanied by stronger technical support
and oversight on the part of EPA.
"We must continue to change policies and long-
standing practices that impede this [delegation]
movement," Thomas said. He noted that -EPA has launched
a number of projects aimed at giving states and
localities "the kind of information they need to make
intelligent risk management decisions."
As the third element in his environmental management
plan, Thomas said EPA "will increase the emphasis we
give to community involvement and public education."
He called on all the Agency's line programs to
develop community relations and public outreach
strateqies similar to those used by the Superfund
program.
"If what we are doing makes sense, we ought to be
able to communicate that to the grass roots better
than we have in the past," he said. As a companion
action, Thomas said the Agency also would establish
forums to encourage the public to have a voice in the
Agency's decision-making orocess-
T'.is final ite"*. en his ^aends for EPA, Thorns" said,
is -.' expand efforts re ouild an integrated "anaqement
=,•:••-••: . •vjr'3 in tSia Aa^nc--. He called for F?A to plan
€.'V.'ii":v'->.-er,t ?1 ?. ~ t i :: r 3 frcn 3 "mu1. ti •n.?~5 i? perspective,"
-------
LEE THOMAS - MANAGEMENT APPROACHES
SELECTED OUTLINE OF SPEECH BEFORE REGION V EMPLOYEES
APRIL 1985
I. GOOD IMPLEMENTATION OF BASIC PROGRAMS
0 Review all statutory authorities
0 Improve Agency planning process
0 Identify and quantify objectives
0 Move away from in-box
0 Move forward to make environmental progress
0 Emphasize Superfund and Hazardous Waste, but don't divert attention
from Water & Ai r
0 Look at cross-media problems to avoid movement of pollution to least
regulatory resistance
II. CONTINUATION OF BASIC RESPONSIBLITIES OF STATUTES
0 Full accountability for laws
0 Decentralize responsibilities from HQ to Regions to States
0 Define roles at various levels
0 Establish good formal agreements in grant programs
0 Take timely and appropriate enforcement actions
III. BUILD STRONG TECHNICAL AND SCIENTIFIC CAPABILITIES
0 Improve data collection and evidence techniques
0 Improve monitoring capabilities to ensure measurement of environmental
results
0 Ensure good technical capabilities of staff
IV. ENFORCEMENT EMPHASIS-PROMOTE A STRONG ENFORCEMENT COMPONENT
0 Division Director seen as accountable manager
0 Enforcement is fully integrated in program and put in context of
program goal
0 Ensure compliance
V. OPENNESS IN OPERATING PRINCIPLES
0 Operate in fishbowl, but beyond
0 Expand outreach, public education and community relations programs
0 Explain Agency actions to public
VI. EMPLOYEE PROGRAMS
0 Create opportunities for mobility and promotion
0 Develop strategy to recruit, develop, retain, attract, reward and
redi rect employees
0 Emphasis on training and personnel programs
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
: REGION 5
? 230 SOI TH DEARBORN ST.
CHICAGO. ILLINOIS 6061)4
PR° RUM v mini \ttf\rioNOF
Richard J. Carlson, Director
Illinois Environmental Protection Agency
2200 Churchill Road
Springfield, Illinois 62706
Dear Mr. Carlson:
During the coming months, the Agency will be preparing the 1985 Environ-
mental Management Report (EMR). To ensure that the most significant
environmental problems continue to be addressed, the Administrator has
requested that each Regional Administrator develop an EMR which documents
important environmental changes and plans that might indicate a shift in
program priorities from those established in the Agency's Operating Guidance.
Region V's EMR, which is due to the Administrator on September 3, 1985, will
assist in preparing the Agency's Priority List and Operating Guidance for
Fiscal Years (FY) 1987 and 1988.
The EMR we submit in September will be a senior management report, approxi-
mately 35 pages long, and will be organized into 3 major parts, as follows:
0 Part I, The Regional Administrator's Overview, an executive summary
introducing tne Region's significant environmental problems and
discussing issues and concerns which underlie the Region's ranking
of those problems;
0 Part II, Regional Environmental Problems, a discussion focused on
Region's 10 most significant environmental problems, ranked across
media, including the Regional agenda, requested Headquarters actions
to address the problem, and expected environmental results;
° Part III, Recommendations for the Agency's Priority List FY 1987-1988,
a presentation of the Region's recommendations about any changes,
deletions, and additions to the environmental and management priorities
suggested in the priority list.
Because I believe that a strong Federal/State partnership is essential to
solve the environmental problems facing us and to ensure this partnership
extends to our priority setting process, I would like you to provide me with
a brief assessment of the major environmental problems facing your State
now, and any emerging problems you will face in the future. I am partic-
ularly interested in your reaction to the enclosed preliminary list of
major environmental problems which we have developed.
-------
From your perspective, are there other major environmental problems that
should be included in our EMR? Also, a ranking of these environmental
problems would be helpful, as it will assist us in our final ranking of
10 major environmental problems which will become the basis of our EMR.
The enclosed outline will give you an idea of the specific topics to be
addressed in the EMR; please feel free to direct your comments toward
topics in the outline. I have also enclosed a copy of the Agency's
FY 1986-87 Priority List. Any changes, deletions, or additions you can
recommend for FY 1987-1988 would be helpful.
In order to factor your responses into our report, I will need to have
them by June 3, so they can be reviewed and incorporated, as appropriate,
into our EMR submittal. You will receive a copy of Region V's draft EMR
in August for your final review and comment. Because of the number and
possible diversity of submittals, I cannot assure that each of your com-
ments will be fully reflected in the final EMR, but I will respond to
any significant concerns you raise. Your comments will also assist us
in our own internal Regional planning process. I will use the EMR in
setting Regional priorities, planning the use of our grant funds, pro-
viding a focus for our accountability systems, and to advise Agency
management on emerging Regional environmental problems. Additionally,
I would appreciate any other comments you can provide which will assist
us in making the EMR a valuable management report. If you have any
questions, please do not hesitate to call me.
Sincerely,
Valdas V. Adamkus
Regional Administrator
Enclosures (3)
-------
REGION V PRELIMINARY LIST OF MAJOR ENVIRONMENTAL PROBLEMS
HAZARDOUS WASTE MANAGEMENT AND RESPONSE
CONTAMINATION OF GROUNDWATER
DISCHARGE OF TOXIC MATERIALS TO WATER
IN SITU POLLUTANTS
0 PCBs
VIOLATION OF PRIMARY AMBIENT AIR QUALITY STANDARDS
0 Ozone
0 Particulates
0 Sulfur Dioxide
SYNTHETIC ORGANIC CHEMICAL CONTAMINATION OF DRINKING WATER
TOXIC SUBSTANCES - EXISTING CHEMICALS
0 Pesticides Misuse
0 Asbestos
AIR TOXICS
GREAT LAKES AREAS OF CONCERN
NON-POINT SOURCE DISCHARGES TO WATER
PROTECTION OF WATER QUALITY IN INLAND LAKES
0 Eutrophication
0 Loss of Wetlands
COMBINED SEWER OVERFLOW
EMERGING PROBLEMS:
INDOOR AIR POLLUTION
VEHICULAR AND INDUSTRIAL EMITTED LEAD IN SOIL
-------
AGENCY PRIORITY LIST FOR FY 1986-87
X. Stabilize imminent threats at uncontrolled hazardous waste sites
through Superfund removal and enforcement actions.
2. Use all available authorities to complete long term hazardous waste
site clean-up including: Superfund Remedial program, Superfund
Enforcement program, RCRA Corrective Action permits and RCRA
Corrective Action enforcement. Pursue cost recovery where Fund
expenditures are involved.
3. Take enforcement actions to reduce the number of RCRA Class I
violations by major hazardous waste handlers and enforce compliance
with issued permits, paying special attention to ground-water
monitoring, closure, pest-closure and financial responsibility
requirements.
4. Issue Part B RCRA permits, giving highest priority to those
facilities where there are the greatest potential environmental
risks or those which provide alternatives to land disposal.
5. Pursue the acid deposition research and analysis program.
Consider issues of damage to lakes and forests, long range
transport, and control technology. Work closely with the States
on standby regulatory mechanisms.
6. Promulgate RCRA regulations and take other actions to strengthen
the existing RCRA program and carry out RCRA reauthorization
requirements. In particular, address alternatives to land
disposal for hazardous wastes, including disposal in the marine
environment. Promulgate regulations for underground storage
tanks, air emissions from treatment, storage, and disposal
facilities, and ocean disposal.
7. Reduce significant risks from existing chemicals. Initiate and
promulgate regulatory actions under the TSCA existing chemicals
program. Accelerate re-registration of pesticide products and
conduct special reviews where cancellation or suspension may be
necessary to mitigate unwarranted health and environmental risks.
8. Address hazards from asbestos by strengthening the asbestos in
schools and public buildings programs. Promulgate and enforce
other regulations to address commercial manufacture, use of
asbestos products, and exposures to asbestos in public buildings
or ambient air (under Clean Air Act) as necessary.
9. Achieve and maintain compliance with air quality standards in
nonattainment areas, especially for ozone. This should include
increasing continuous compliance by regulated facilities,
ensuring compliance by new and in-use vehicles, and monitoring
implementation of revised SIP schedules.
10. Implement the National Municipal Policy to ensure the construction
and effective operation of municipal facilities and take enforcement
actions to improve compliance with industrial and municipal
NPDES permit requirements.
-------
-2-
11. Complete reissuance of NPDES major and environmentally —v
significant minor facility permits. Apply the new treatment
requirements contained in the revised effluent guidelines
and, where necessary, water quality based limits derived
from water quality standards and use of effluent toxicity
monitoring.
12. Implement the ground water protection strategy by supporting
the development of State programs and addressing uncontrolled
sources of contamination; give priority to ground-water
contamination resulting from hazardous wastes and pesticides.
13. Address drinking water contaminants by promulgating
the drinking water standards and expanding the program of
issuing health advisories for unregulated contaminants in
support of Superfund cleanup activities/ State agencies'
responses to contamination incidents, and other purposes.
14. Protect wetlands through vigorous attention to reviews
of dredged and fill applications under Section 404 of the
Clean Water Act and enforcement actions against unpermitted
activities.
> i
15. Implement a comprehensive national strategy for the control
of hazardous air pollutants. Continue development and
enforcement of NESHAPs. Emphasize implementation of SIP and
other program measures that also reduce hazardous air compounds
Support State and local agency efforts to assess and regulate
specific hazardous air pollutants.
16. Control indirect discharges by implementing the pretreatment
program, giving priority to: approving State pretreatment
programs; assessing the adequacy of approved pretreatment
programs; and enforcing categorical standards.
17. Work with States to incorporate water quality and sediment
criteria for toxics into State water quality standards;
issue additional water quality and sediment criteria for
toxics; revise waste load allocations for water quality-limited
segments to include toxic limits.
18. Implement an underground injection control program focusing
permit issuance and enforcement efforts on those existing
facilities that present the greatest threat to underground
sources of drinking water and on those new facilities
which must be permitted to prevent an unnecessary adverse
impact on oil and gas production. Implement the ban on
underground injection of hazardous waste into or above an
aquifer used for drinking water.
19. Complete the review and revision of National Ambient Air
Quality Standards as necessary. Provide support to State —-
and local agencies, including technical and procedural guidanc
for the development of State Implementation Plan (SIP) revisions
necessitated by revised standards. Specifically, support
the development of PM^o SIPs.
-------
-3-
20. Work with States to incorporate nonpoint source control
measures in their water quality programs, where nonpoint
source pollution is a major problem in surface or ground
waters.
21. Work with States to develop and achieve high quality
programs under interim and final RCRA authorizations.
Make every effort to assist States in meeting criteria for
a quality RCRA program.
22. Implement a coordinated approach to solve multimedia
pollution concerns in discrete geographic areas. Identify
candidate areas and develop mutually agreed upon local,
State, and Federal plans to reduce risk to human health
and the environment.
23. Ensure the Federal Government shows leadership in
environmental control practices through Federal facility
compliance with air, water, toxics, and hazardous waste
requirements.
24. A6hieve compliance with PCB rules and regulations focusing
inspection and enforcement actions on the greatest potential
sources of harmful PCB exposure.
25. Promulgate regulations to implement a program for management,
reuse and, where necessary, disposal of municipal sewage
sludges.
26. Complete the regulatory program for control of exposure to
radioactive wastes. Publish standards or guidance for
disposal of high-level and low-level radioactive .wastes,
and for addressing residual radioactivity at decommissioned
nuclear facilities. Develop criteria for review of permit
applications for ocean disposal of radioactive wastes.
27. Implement the dioxin strategy.
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ATTACHMENT A
FY 86 RA/ORA PRIORITIES
For FY 86, as for FY 84 and this year, our priorities supplement the Agency's
priorities found in the national guidance, and fall into four main categories:
program management, State relations, employee development and special environ-
mental initiatives. We are proud of the progress already made toward our
FY 84/85 priorities.
In program management, the Region has flagged areas for improving inter-
divisional coordination in FY 85, and is moving forward to better communication
across program and organization lines. We are taking steps to control toxics
across media, e.g., S.E. Chicago and the Great Lakes. We have a new Toxics
Coordinating Committee and an up-and-running Groundwater Coordinating Com-
mittee to take us further. Our programs have been aggressive in enforcemnt
and received national recognition, accordingly.
In State/relations for FY 84 and 85, we continued to increase opportunities
for more effective input by our midwestern States in Agency management
systems. In particular, we brought our States into the very early stages of
guidance and Agency priorities development. Also, we clearly set forth
enforcement expectations -- for both the Region and the States — in State/
EPA Enforcement Agreements.
In the area of employee development, we have a fully participative training
program that is providing more training opportunities than ever to our employees,
We met our affirmative action goals in FY 84 and set more challenging ones for
FY 85.
Each Region V media manager must take the national priorities, our priorities
and their own assessment of environmental needs into account when planning
media objectives, organizational objectives, and State guidances for FY 1986.
Alan and I continue to see Region V as a pacesetter in many areas critical to
Agency operations. We are asking you to maintain that momentum in FY 86.
Our most serious environmental challenges are increasing in complexity;
they are often unprecedented and involve real uncertainty. These environ-
mental problems need cross-media control and Federal/State cooperation to
be solved effectively. In the future, our sense of accomplishment will rest
not only on successfully meeting these environmental challenges, but having
met them as a team — with one another, with our State partners, and the
involved Region V citizenry.
Our priorities for FY 86 follow:
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PROGRAM MANAGEMENT
An overall, guiding principle for FY 86 is to continue to improve our
MULTI-MEDIA APPROACH to solving environmental problems. In particular,
we want to emphasize a multi-media approach for:
* Solving "areas-of-concern" identified within the Great Lakes'
basin, where other organizations in the Region need to
contribute to remedial plans.
* Superfund clean-up, so that water and air resources are
protected as we change land disposal practices. (Also, we
need to ensure that cost recovery is thoroughly and correctly
documented.)
* Groundwater, so that diverse programmatic efforts to protect,
clean-up and enhance this vital resource are conducted in a
coordinated manner.
* Enforcement, so that, where we can, we conduct multi-media
j inspections and pursue compliance having considered problems
across media - then take action.
* Control of toxics, so that transfer of these contaminants from
"scrubber to sludge" is no longer left unchecked. This means that
the Region continues our initiative for an integrated approach in
identification of toxicant sources, pathways and fate so that
adequate safeguards are provided.
We want to emphasize FEDERAL FACILITIES COMPLIANCE for FY 86. We are
in a position to make the Federal government a leader in environmental
compliance, and have a responsibility to take steps to do so. In Region V,
we need active support from top managers in sorting out what needs to
be done and who needs to do it - assuring that States take action where
they have the lead. We will be involved in Federal Facility problem
resolution as a Region.
We look to all media for INTEGRATING WATER POLLUTION PROBLEMS ASSOCIATED
WITH THE GREAT LAKES into wor
-------
Region V operates an effective ENFORCEMENT program. We are in a position
where we can think in terms of innovative approaches. This effort links
to other priorities. We can make improvements through: use of multi-medl
inspections; making Federal Facility compliance a model; better criminal
enforcement; better enforcement-related management accountability systems;
and, shared efforts with the States. Also, we need to maintain our mo-
mentum in pursuing new cases while assuring follow-through on cases
previously initiated.
In FY 86, the Region will need to implement a comprehensive approach to
fulfilling its responsibilities under MBE/WBE/EEO and SMALL BUSINESS
programs. Efforts in FY 85 are directed toward sorting out those
responsibilities — what they are and where they are.
Part of our team responsibilities is to effectively inform and involve
the public in the Region's decisions. Region V needs to continue to
OUTREACH to all our constituencies to gain understanding and support.
STATE RELATIONS
Region V is a leader in establishing and maintaining good State relations.
For FY 86, we must continue to reinforce our partnerships with the States
particularly through EARLY STATE INVOLVEMENT in EMR, guidance, and SPMS
measures development.
We must INCREASE our efforts to FOLLOW THROUGH on State concerns as
expressed through the above means and as gathered during technical
assistance, program evaluation and end-of-year, close-out meetings.
We will continue to articulate, our enforcement expectations through the
STATE/EPA ENFORCEMENT AGREEMENTS.
We will review the various STATE DELEGATION AGREEMENTS to assure that they
are current and reflect changes in regulation.
We must continue to examine and define State needs and to REFINE our
processes for OVERSIGHT, accordingly.
We must move forward to help our States assume RCRA AUTHORIZATION and
increase the number of CERCLA COOPERATIVE AGREEMENTS.
We must assure that all Region V employees are sensitive to the importance
of maintaining COOPERATIVE FEDERAL/STATE RELATIONS.
A-3
-------
EMPLOYEE DEVELOPMENT
The Region needs to continue to clarify responsibilities and activities needed
to conduct an effective human resource development program.
° We need to open OPPORTUNITIES for CAREER GROWTH and development so that our
employees see their career future at EPA.
0 To be effective we need to focus our efforts on instilling a SENSE OF
ACCOMPLISHMENT and a SENSE OF WORKING AS A TEAM in the Region.
0 We must place more of our attention on the employee PERFORMANCE EVALU-
ATION AND FOLLOW-UP. We need to work with supervisors and employees to
make clear the requirements of good performance.
0 New employees and new supervisors will need orientation to the Region
and management TRAINING.
0 We must sensitize our ^nanagers and supervisors to the various opportunities
M for fulfilling our EEO/AA RESPONSIBILITIES in the areas of recruiting, training
and promotion in addition to hiring.
SPECIAL ENVIRONMENTAL INITIATIVES
Our Regional environmental problems were prioritized in the FY 85 EMR Update.
For FY 86, we will perform a similar exercise. Because these Regional EMR
Updates drive development of Agency priorities and guidance, we have our most
significant problems clearly in view. Additionally, for FY 86 we will look
to senior management for initiatives to complement our EMR efforts through
selection of geographic areas for cross-media approaches to environmental
problem solving, and development of envi ronmental-quality indicators and
measures of success.
The Region will also support State agencies' efforts for environmental manage-
ment pilots in FY 86 and in the future. This will lead to more effective
use of existing data for measuring environmental results and in environmental
decision-making.
A-4
-------
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
FATE: MAY 0 ? ^
SUBJECT: Task Force on Headquarters - Regional Relationships
FROM: Robert Springer, Assistant Regional Administrator
for Planning and Management
T0: Division/Office Directors
This memorandum is an analysis of the recommendations from the September 1933,
Headquarters - Regional Relationships Task Force report. I had this analysis
conducted to determine the number of recommendations from this report that
were completed and to decide if we want further action taken. The sequence
of the review parallels the report and is broken down into four areas, which
are: The policy framework for decentralized management of EPA's mission
(Policy); the guidance, accountability, and evaluation support for the
policy (Guidance); Regional involvement in planning and budgeting (Budget);
and, Regional organizational structure (Organization).
Please review these items and let me know if you would like to pursue them
further. The majority of the recommendations were implemented, those that
were not are starred **. Attached is the Executive Summary which contains
the recommendations from the Task Forces. Following is the status of the
recommendations:
POLICY
Decentralization
Recommendation: EPA should reaffirm and restate our policy on Decentrali-
zation. In order to do this the report contained recommendations on
adopting five policy statements. These statements outlined the responsi-
bilities of the Administrator, Assistant Administrators, and Regional
Admini st rator.
Status: (Partially Implemented and Working) We did not ascertain whether
all five policy statements have been issued. However, two of them have
been implemented. These recommendations were: AAs or the AA for Regional
Operations were to recommend delegations of authority and changes thereto;
and, the AA for Administration was to manage the process of delegating
authority. These were implemented; see next recommendation.
Assignments of Authority
Recommendation: Specific policy statements for each area of operational
activity be adopted as an extension of the general policy statements.
This includes delegating the authority of several activities to the Re-
gional Administrator.
EPA FORM 1320-6 IREV 3-76)
-------
Status: (Implemented and Working) On July 24, 1984, there was a major n
vision to the Delegation Manual involving 197 different delegations. Tl
revision was undertaken to address the goals of assuring that appropriai
authorities are decentralized and are exercised at the lowest possible
operating levels. According to Steve Martin, Management and Organizatic
Division, these revisions to the Delegation Manual implemented the recon
mendations of the task force and have proved to be very workable.
GUIDANCE
Improve Accountability System
Recommendation: To reinforce the Administrator's Management Accountabil
System (MAS) by issuing annual guidance, based on the Administrator's
Guidance which is fully coordinated with relevant HQs organizations.
Status: (Implemented and Working) The Office of Management Systems and
Evaluation (OMSE) completed a study in March 1983, on the way regional
targets were set, reported on, and changed. OMSE found several problems
with the system at that time. Because of this, procedural changes were
made to remedy the problem. The Task Force concurs in the approach that
resulted from the management review and was adopted and agreed to by the
RAs and HQs Offices. Also, the MAS has been included in both FY 85-86
and FY 86-87 Agency Operating Guidance Documents.
Centralize Directives
Recommendation: The Management and Organization Division (MOD) should
upgrade and administer a system to keep current a central repository of
Agency di rectives.
** Status: (Implemented but, Not Working) MOD attempted to administer an
integrated EPA Directives System. They sent a memo to the Offices at
Headquarters asking them for all of their policies and program guidance.
The response they received was poor and they decided to abandon this
approach.
MOD then decided to get this information from one program office at a
time. They are currently working with OSWER. They have received most
of OSWER's policy and guidance documents and are now indexing this infor-
mation into a manual. This approach has been successful. After the
OSWER documentation is completed, they will begin to work with another
program office.
Controlled Reporting Burden
Recommendation: Program offices are encouraged to limit the reporting
burden on the Regions and States. Where feasible, computerized systems
should be extended into State offices. Regions should routinely assess
each program and provide recommended changes concerning burdensome
reporting requirements.
-------
Status: (Partial Implementation) Guidance was received from OMSE on
limiting the number of reporting measures. If a program office decides
to add a reporting measure they must delete a measure that is in the
sytem.
** The Regions have not assessed the programs to recommend changes concerning
burdensome reporting requirements. (This issue may be the normal, un-
resolvable plight of HQ/Regional relationships.)
Program Evaluation
Recommendation: Comprehensive periodic evaluations of program results
are essential for decentralized operations.
Status: (Partial Implementation) The degree and type of periodic evaluations
varies from program to program. See Attachment A.
BUDGET
Define Responsibilities
Recommendation: Define the responsibilities for the National Program Manager
(NPM)and lead Region for the initial stages of the budget development process.
Formally recognize regional viewpoints in the NPM budget presentation.
Status: (Implemented and Working) An expanded lead region system (more than
budget) was established in an Al Aim memo of June 11, 1984. This memo
set forth the process and roles for incorporating regional viewpoints in
EPA's Planning and Budgeting system.
Regional Perspective
Recommendation: The DA should convene an annual budget hearing to provide
RAs the opportunity to present their views on both media-specific and cross-
cutting budget issues.
Status: (Implemented) At the Administrator's budget hearings, a special
hearing for regional issues has been established.
Expand the Lead Region Selection Process
Recommendation: The Comptroller should lead a broadened process for
selection of lead Regions to work with each NPM.
Status: (Implemented) The lead region selection will occur on a rotational
basis, with the leads being replaced by their back-ups. The first rotation
will occur on 10/1/88. Office of Regional Operations absorbed the role of
managing the lead region selection process.
Expand Regional Participation
Recommendation: The participation of Senior regional staff in the Head-
quarters budget process should be instituted within operating procedures
developed by the Comptroller.
Status: (Implement ad, Panrc'paTPon Vanes) Eacn NPM 'ias ^staol^sned
procedures for involving the Regions in the budget process.
-------
ORGANIZATION
The Review concluded that the current standard regional organization is
working adequately given current resource allocations and functional
relationship to Headquarters. However, the Review suggested that Regional
Counsel and Environmental Services Division should be highlighted.
Regional Counsel
Need: Establish a more direct relationship between the RA and the Re-
gional Counsel. And, modify the current standard regional organization
to provide the appropriate changes in reporting lines.
Result: The DA, in an August 3, 1983 memorandum, announced that the
Regional Counsels (RC) will report to the RA on day-to-day activities
while reporting to the HQ General Counsel on matters involving national
consistency and the management of Regional Counsel personnel.
** Status: The changes in reporting lines have not been made. Although
establishing a line of direct communication between the RA and RC has
been done, the RA still has no authorized authority over RC. The
Agency does not appear to be planning any further action on this
item.
Environmental Services Division
Need: To establish a better method for allocating resources for the
ESD function and to provide clear lines of communication between ESD
and Headquarters.
Recommendation: The Agency should continue to monitor and assess ESD's
viability in line with changes in program direction and resource allo-
cations.
** Status: (Slow Progress but Right Direction) The Office of Regional
Operations (ORO) has been working closely with ESD Directors on estab-
lishing a resource tracking system for ESD. A matrix of functions
has been developed which contains ESD functions that can be crosswalked
with ESD activities. The ORO (staff of one) is currently going out
to the Regions to do program reviews of all ESD work activities.
Because of the amount of information that is needed and a limited
staff, this will not be totally completed for the FY 87 Budget but it
may have an impact on specific activities, i.e., QA and ESD Superfund
resources.
In September 1984, Al Aim established a position for a National Environ-
mental Service Officer. With this position established, a direct communi'
cation link was formalized between the Regions and Headquarters. Since
that time, the ORO has been working with the RAs and DRAs and developed
a Mission Statement in December. This mission statement defined the
specific activities of ESD.
Attachments
-------
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-------
POLICY AND MANAGEMENT REVIEW OF
HEADQUARTERS - REGIONAL RELATIONSHIPS
EXECUTIVE SUMMARY
I. DECENTRALIZATION IS CRITICAL TO EPA MISSION PERFORMANCE
The National strategy for achieving environmental goals
is built upon cooperative efforts of Federal, State and
local governments. Vhis strategy is largely based upon
statutory provisions relating to actual implementation respon-
sibility. The principal Federal responsibilities are to
establish national policies, develop standards and participate
with State and local governments in implementing environmental
programs.
o The vast majority of the environmental workforce
is in State and local governments which, accordingly,
requires the adaptation of national policies and objec-
tives to unique State conditions and fosters close
Federal/State relationships.
o The National environmental strategy relies on use of
traditional State and local authorities and the National
government's role of leadership and financial support.
Achieving the adaptation of Federal environmental policies
and objectives to State and local programs is logicslly assigned
to the EPA regional offices closest to where the work is being
done. This issue paper provides suggested Agency policy and
principles which transcend program an^i media lines to achieve
this decentralized management.
We Have Drifted From the Original
Framework of Decentralization
In recent years, the Agency has begun direct administra-
tion of new program authorities in Headquarters with no plan
for decentralization. We have gradually drifted from the
original Agency position of balancing national policy develop-
ment and consistency against regional implementation flexibil-
ity, to a lack of clear understanding of how the Agency
should pursue its goals. The Agency needs a clear statement
of policy on authorities, accountability, resource a3location
processes, and organization.
11
-------
We Should Reaffirm and Restate
Our Policy of Decentralization
EPA's organization is based upon the purposeful stratifi-
cation of the Administrator's authorities and commensurate
responsibilities. The Task Force has concluded that the
Agency needs a clear statement of policy on decentralization
to emphasize this framework.
Therefore, we recommend that the Administrator adopt the
following policy statements:
11 Assistant Administrators are responsible for developing
and promulgating policy and guidance and in consulta-
tion with the Regions, assuring consistent implementa-
tion of national policy, providing oversight and
evaluating progress, and taking actions which are of
national significance or multiregional in nature,
1f Regional Administrators are responsible for implemen-
ting programmatic policies consistent with national
policy and direction; and, in the absence of overriding
reasons to the contrary (e.g., statutory prohibition,
unusual technical complexity, etc.), for execution of
those environmental activities which relate to the
jurisdiction of an individual region.
1( Assistant Administrators and/or the Associate Administrator
for Regional Operations are responsible for recommend-
ing delegations of authority to the Regions and changes
thereto.
11 The Assistant Administrator for Administration is respon-
sible for managing the process of delegating authority,
recommending proper placement of authorities and permit-
ting exceptions to specific policies.
AGREE
DISAGREE
OTHER
Several Specific Assignments of Authority
Are Generally Agreed Upon
We recommend adopting specific policy statements for each
area of operational activity as an extension of the general
policy statements. These specific policy statements would
provide the framework for which decisions on individual
delegations of authority would be made and any exceptions
to the policy justified. The impact of implementing specific
policy statements is summarized in the body of the Report.
111
-------
11 Permitting, engineering and environmental impact review
activities wil] be delegated to the Regional Administrators,
including final approval and disapproval, except for
those actions specifically reserved for the Administrator,
or assigned to Headquarters based upon exceptional fac-
tors.
K Product review and registration activities will be dele-
^ • gated to the Assistant Administrators, except for
.--'" those actions specifically reserved for the Administrator.
11 Listing and designation of particular pollutants,
products, geographic areas activities or source cate-
V- gories for further regulation with national or multi-
'\;-. regional impact, will be delegated to the Assistant
Administrators. Listing and designation activities
which occur solely within the geographic boundaries
of a specific region will be delegated to that Regional
Administrator.
, \ 11 Hazardous Substance Emergency Response and Site Manage-
.^^ ment activities should be delegated to the Regional
"y- ° :LJ~.v-oJ" Administrators, as a near term goal, except those
<..:• "^->-> "—- actions specifically reserved for the Administrator
^° --. '',-"' or assigned to Headquarters based upon exceptional
^ '~l ~~ V" factors.
11 Testing/Monitoring and Inspection Activities will be
shared between Regional Adminis ".raters and Assistant
Administrators. The Regions will have primary respon-
sibility for most of these activities. Headquarters
will be delegated nationally significant cases and
nationally managed areas (e.g., the Motor Vehicle
Manufacturers Program and testing, monitoring, and
inspections under The Toxic Substances Control Act).
11 Administrative Orders and Noticej of Violations con-
cerning Enforcement Actions will be delegated to the
Regional Administrators, including final approvals
and disapprovals. Administrative Orders and Notices
of Violations which are of national significance or
multiregional will be delegated to the Assistant
Administrators.
1f Referrals to the Department of Justice (DOJ) for
Judicial Enforcement Actions v,ill be delegated, upon
concurrence by the Department of Justice, to the
Regional Administrators. Judicial Enforcement
Actions, including referrals to DOJ for those programs
assigned to Headquarters, and for cases which are of
national significance or multiregional will be
delegated to Headquarters Enforcement Counsel.
iv
-------
Execution of State and local grants and cooperative
agreements, including Superfund Cooperative Agreements
will be delegated to the Regional Administrators.
Execution of grants and cooperative agreements of centrally
managed programs, (e.g., Research and Development) will
be retained by Headquarters.
AGREE
•DISAGREE
OTHER
There are Differences of Opinion on Delegating Authority for
Approving State Programs and Plans, and Devolutions (Delegations)
to the States
This activity includes the authority for approving State
programs and plans, and devolutions (delegations) to the
States, and includes determining the EPA activities to be
performed by individual State agencies, negotiating and
approving agreements which define the standards to which
States will adhere, and specifying the manner in which they
will administer programs. The Regions perform these activities
if they are not delegated to the States.
The Regions believe that review and approval of these
activities is a logical extension of their responsibilities
in providing oversight of Federally supported State programs.
They argue that if Headquarters officials retain these authorities
it compromises the Regional Administrator's standing to serve as
the EPA focal point for operating regional environmental programs.
Some of the program offices believe that Headquarters
involvement in these decisions is essential to assure national
consistency. They argue that since approval of the "State programs
constitutes an operational delegation of national program respon-
sibilities it is a function appropriately reserved to the
Administrator; therefore, a Headquarters function.
The majority of Task Force participants support delegating
the authority for approving State prooram plans and delegations
to the Regional Administrators. They believe that delegating
this authority is generally consistent with proposed decentrali-
sation policy since it is a form of "implementing" national
policy guidance.
There is an Office of Policy and Resource Management (OPRM)
proposal on this issue that is currently under Agency review.
The OPRM draft report recommends regional approval of State
plans, subject to a time limited Headquarters veto. The regional
participants on the Headquarters - Regional Relationships Task
Force believe that the veto approach is better than the existent
method because it resolves the problem of time delays in granting
-------
approvals. However, they would prefer full delegation to the
Regional Administrators with no strings attached. They believe
the time limited veto still results in Headquarters retention of
final authority.
Since there are sharply divided positions on this issue
and the OPRM effort will soon be concluded, we recommend:
1[ The Administrator defer his policy decision regarding
authority to approve State programs and plans, and
devolutions (delegations) to the States until it can
be made within the context of the comprehensive issue
analysis formulated by OPRM and currently under Agency
wide review.
AGREE
DISAGREE
OTHER
We Need a Specific Policy Controlling
the Use of Advance Concurrences
An advance concurrence requirement occurs when the Regional
Administrators are restricted from making decisions until they
receive approval from Headquarters. Advance concurrence re-
quirements can be contained in the delegation of authority
or result from regulations or guidance that calls for Head-
quarters action before the decision officials can act.
Advance concurrence requirements are intended to maintain
national consistency, especially when the regions have little
or no experience in the particular area. Headquarters
believes that its involvement will avoid inappropriate prece-
dent in new program areas while they are developing adequate
national guidance. In practice, the record indicates that
after Headquarters has issued necessary guidance it has
often shown reluctance to rerrove the requirement for an
advance concurrence. Headquarters reviews also result in
duplication of effort and significant delays.
One option is to totally eliminate any continuing require-
ment for advance concurrence. Alternatively, we could adopt
a process of disciplined limitation in the use of advance
concurrences for new programs if maintenance of national
consistency is potentially a problem. These concurrences
could then be subject to periodic evaluations and full delega-
tions made to the Regions as programs mature and the necessity
for a Headquarters concurrence role declines.
VI
-------
We recommend that the Administrator adopt the following
policy statement:
*i When the Administrator delegates authority to the
Regional Administrator, advance concurrence from
Headquarters is inappropriate. Headquarters should
monitor and evaluate regional decisions to assure
conformance with national policy. When, in unusual
cases, it is essential that Headquarters examine and
approve a certain type of decision the authority
should be delegated to the Assistant Administrator
with the Regional Administrators designated as
recommending officials, or delegated to the Regional
Administrators with a temporary concurrence require-
ment (the ending date for the advance concurrence
requirement will be established in the delegation of
authority).
AGREE
DISAGREE
OTHER
VII
-------
II. GUIDANCE, ACCOUNTABILITY, AND EVALUATION
SHOULD SUPPORT THE POLICY
Decentralized management can be improved through an inte-
grated Agency wide system of program guidance, accountability,
and evaluation.
Therefore, we recommend that the Administrator adopt the
following policies on guidance, accountability, and evaluation:
11 The current Administrator's Management Accountability
System (MAS) process should be reinforced. Every
program should continue its practice of issuing annual
guidance, based on the Administrator's Guidance and
fully coordinated with relevant Headquarters organiza-
tions.
11 The Management and Organization Division (MOD) should
be directed to administer an integrated EPA Directives
^T? System with regional/program participation. MOD
would upgrade and administer the system to maintain a
current central repository of Agency directives,
including those not currently incorporated in the
formal directives system. New program and policy
issuances and updates should conform with the format
and mechanics of the Agency directives system; however,
we should gradually convert to the new system. Assistant
Administrators should maintain current authority to
develop and <• pprove program specific documents while
adhering to the mechanics of the Agency directives
system.
11 Programs should be encouraged to incorporate model re-
porting traits suggested in this Review. Where
feasible, computerized systems should be extended
into the State offices. Regions should routinely
assess each program and provide recommended changes
concerning burdensome reporting requirements.
11 Comprehensive periodic evaluations of program results
are essential for decentralized operations and should
be standard practice for every program.
AGREE
\ DISAGREE
OTHER
Vlll
-------
REGIONS SHOULD BE MORE INVOLVED
IN PLANNING AND BUDGETING
During the development of the FY 1983 budget, the Agency
replaced the 2t?ro Based Budgeting process, with its layers
of review and ranking teams with a centralized and shortened
process. The nature of the regional role changed, from
participation on a variety of ranking committees, to the
interaction of lead Deputy Regional Administrators (DRA)
with National Program Managers (NPMs) during the budget
formulation process and thei in the budget hearings. The
lead Region concept evolved as an efficient, productive
method to represent regional concerns and interests in the
new process.
Our objective in reviewing the regional role in planning
and budgeting is to examine the current role of regional managers
in the Agency's planning and budgeting process, to determine
whether that role is sufficient to properly represent the
requirements of regional programs in the decision making
process, and to recommend alternatives to such process if it
proves to be inadequately addressing all dimensions of
Agency program needs.
The criticisms most frequently heard of the current budget
development process, from the regional perspective, are:
o The extent and effectiveness of lead Region "partici-
pation" is too dependent on the whim of the NPM.
Participation ranges from extensive regional involve-
ment to total exclusion.
o The effectiveness of lead DRA participation varies
greatly depending on a number of factors including
time and staff availability.
The Associate Administrator for Regional Operations be-
lieves that a critical element in effective decentralized
management is to ensure that Regional Administrators, as
general policy officers, are provided opportunity to present
their views on both media specific and crosscutting budget
issues.
Our Recommendations Strengthen
The Current Process
Our recommendations enhance the strength and structure
of the current lead Region concept. They also ensure that
regional concerns are heard, without weakening the preeminent
role of the National Program Manager in developing and pre-
senting budget recommendations for the national program.
IX
-------
We recommend that the Administrator adopt the following
policies increasing Regional involvement in the budget process:
1i General performance expectations during the initial
stages of the budget development process, for both
the NPM and lead Region should be clearly defined and
regional viewpoints should be formally recognized in
the NPM budget presentation.
\\ Regional budget development meetings should be convened
each spring to provide regional representatives the
opportunity to advise National Program Managers of
regional needs, problems and other issues.
11 The Deputy Administrator should convene an annual
hearing to provide Regional Administrators the oppor-
tunity to present views on both media and cross cutting
budget issues. The hearing should be held following
submission of National Program Manager budget submis-
sions to the Comptroller, but prior to finalization
of the Administrator's budget proposal,
11 The Comptroller should continue to lead the process
for selection of lead Regions to work with each National
Program Manager. The expanded process should include
active participation of regional officials, National
Program Managers, and the Associate Administrator for
Regional Operations, with final approval by the Deputy
Administrator.
,_ 11 Participation of senior regional staff in the Head-
.„ quarters budget process should be instituted within
'' operating procedures developed by the Comptroller and
discussed with the Associate Administrator for Regional
Operations.
AGREE
DISAGREE
OTHER
-------
IV. REGIONAL ORGANIZATIONAL STRUCTURES SHOULD NOT BE
EXTENSIVELY CHANGED AT THIS TIME
The Environmental Protection Agency has always maintained
a relatively unchanged Regional organization structure. Our
Review suggest that the current standard regional organiza-
tion is working adquately given current resource allocations
and functional relationships to Headquarters.
For the most part, the flexibility provided in the cur-
rent structure meet" the varying needs of individual Regions.
For example, three regional offices have separated the emerging
waste-related functions from the air functions with a minimum
of disruption. The Regional Administrators are able to
structure branch and section level organizations and functions
to reflect their own approach, i.e., geographic, functional,
or "process step" variants; experiment with establishing
sub regional offices; and assign staff functions.' The current
policy allows the Regional Administrator flexibility in
selecting the ARA/OPM or Management Division option.
The Regional Administrators have discretion (pending the
outcome of concurrent management streamlining efforts and with-
in current Agency rules and practices) in formally structuring
staff activities, such as Congressional and Intergovernmental
Relations, Public Affairs, and Civil Rights with their place-
ment as staff to the Regional Administrator, Deputy Regional
Administrator, Associate Regional Administrator, or Management
Division Director.
Major revisions at this time are not warranted, however,
our Review suggests that the Regional Counsel and Environmental
Services Division should be highlighted. In addition, managers
believe that the creation of the Regional Operations Office
will improve communications to top management on issues of
regional concern.
The Regional Administrator Should Exercise
Management Authority Over Enforcement Activities
and the Office of Regional Counsel
Our Review indicates a need to establish a more direct
relationship between the Regional Administrators and the
Regional Counsel. The Regional Administrators believe this
would strengthen their management authority. The Deputy
Administrator, in an August 3, 1983, memorandum announced
that the Regional Counsels will report to the Regional
Administrators on day-to-day activities while 'reporting to
the Headquarters General Coui.sel on matters involving national
consistency and the management of Regional Counsel personnel.
The current standard regional organization is being modified
to provide for appropriate changes in reporting lines.
XI
-------
Headquarters and the Regions Should
Continue to Monitor and Assess the Viability
of the_Environmental Services Division
The Environmental Services Division (BSD), which provides
a full range of laboratory, testing and monitoring capabil-
ities in most of the Regions, was raised as an area of concern
by many people. Several Regions believe BSD is, and should
continue to be, an integral component of regional operations.
The principal issues are the need for a method of better
allocating resources for the function and the need to prov.de
clear lines of communication between BSD and Headquarters
(e.g., potentially a National Program Manager).
Many other decisions will have to be made before a final
decision on the concept of the ESD would be appropriate. A
decision on ESD's viability must be considered in the context
of legal/enforcement and air/waste alignments in the regional
offices. In addition, the possible effects of laboratory
consolidation and the impact of increased contracting and
automation are important factors.
While theoretically it is possible to move the ESD func-
tion into the respective regional program Divisions, it is
probably impractical because of the interdependence between
field and lab staff, the cross media nature of ESD work, and
the need to maintain a central core of such expertise. The
Agency should continue to monitor and assess the Environmental
Services Division's viability in line with changes in program
direction and resource allocations.
XII
-------
v • M F C / 7 0
I !- 252 • l NJTKO S l ATKS ENVIRONMENTAL PROTECTION AGtNCY
j, V-V ••/- WASHINGTON, D.C. 20460
5* * • » '
fc
i April 24, 1985
I
in i M 11»
*|li!li\M I MM K N)|l
MEMORANDUM
SUBJECT: Review of Proposed Pal-fee^on Per4-arniancfi-\Based Grants
/ / ' - }/ ( / /*• ^ /
FROM: Carolyn M. Clinton \^£Sc>t^^-t^ S\* • \O^X->-.-*—
Associate Administrator for .Regional Operation/
TO: Regional Administrators
As you will recall, Lee Thomas asked representatives from
headquarters/ the regions, and the states to recommend an agency-
wide policy on performance-based grants. After several months of
intense effort and lively discussion, this group has finished
its work and has produced the attached recommended policy.
Given the wide-ranging impact of this policy on your opera-
tions, Lee has requested that you review this proposal in its
final form before signing it. The implementation plan for this
policy calls for phasing it into effect in FY86, depending on
the status of individual grant negotiations at the time the
policy is signed* Therefore, it is important that we provide
our feedback to the Administrator as quickly as possible.
I have attached the proposed policy, the implementation
plan, a background document/ and a list of the people on the
two workgroups in the event that you^need further information,
I have also set up a conference call' for Thursday, May 2 at
1:30 pro EOT to hear your views on this proposal.
Attachments
cc: Lee M. Thomas
A. James Barnes
7
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EPA POLICY ON PERFORMANCE-BASED ASSISTANCE
URPOSE
This policy establishes an Agency-wide approach which links
u s EPA's assistance funds for continuing State environmental
programs to recipient performance. The approach employs assistance
as a management tool to promote effective State environmental pro-
grams. The policy's goal is the consisieTrf and predictable appli-_
cation of the performance-based approach' across Agency programs
and among Regions.
Mechanisms for tying EPA assistance to a recipient's accom-
plishment of specific activities agreed to in advance afe contained
in EPA's regulations governing State and Local Assistance (40 CFR
Part 35, Subpart A). The degree and manner in which EPA programs
and Regions have applied these regulations has varied greatly.
Through this policy, the Agency articulates how it will consistently
manage its intergovernmental assistance.
SCOPE
EPA's Regions will be expected to implement the portions of
this policy governing the management of assistance agreements
("Oversight" and "Consequences of Oversight" sections) upon the
policy's issuance. To the greatest extent possible, this policy
should also guide the negotiation of grants and cooperative
agreements for fiscal year 1986.
This policy supersedes all previous policies on performance-
based assistance to the extent they conflict with the approach
outlined below. It elaborates on regulations governing state and
and Local Assistance (40 CFR Part 35, Subpart A) promulgated
October 12, 1982, and the General Regulation for Assistance Programs
(40 CFR Part 30) promulgated September 30, 1983. This policy does
not replace funding or grant/cooperative agreement requirements
established by Federal statutes or EPA regulations.
The policy complements and is in complete accordance with
PPA'S Policy on Oversight of Delegated Programs (April 4, 1984)
and the Policy Framework for State/EPA Enforcement "Agreements"
(June 26, 1984).
While this policy will refer to all assistance recipients as
"States" (since states receive most of EPA's assistance for con-
tinuing environmental programs), it applies equally to interstate
and local agencies which receive similar support.
-------
-2-
PRINCIPLES AND APPROACH
PRINCIPLES
This policy on performance-based assistance is designed to
strengthen the EPA/State partnership by ensuring that EPA assis-
tance facilitates the implementation of national environmental goals
and promotes and sustains effective State environmental programs.
The policy provides a framework within which EPA and States can
clarify performance expectations and soi$e''vproblems through a system
of negotiation, according to a predictable but flexible set of
national guidelines. This framework is built around several funda-
mental principles which will also guide the policy's imp1ernehtation:
o EPA will use performance-based assistance as a management
tool to promote and recognize the "effective performance
of State environmental programs, and to ensure mutual
accountability;
o EPA Regions and programs will retain flexibility to tailor
the^performance-based approach to their needs and the policy's
guiding principles;
o States and EPA should share a common set of expectations
regarding performance- commitments and likely responses
to identified problems. There should be no surprises as
EPA and States relate to each other under this policy;
o In negotiating State performance objectives, EPA and the
States will seek realistic commitments and presume good
faith in their accomplishment;
o EPA and the States should maintain continuous dialogue
for the rapididentification, solution and escalation
of problems to top level managers; '
o EPA is fully committed to the success of State environ-
mental programs and will seek opportunities to acknowl-
edge their accomplishments.
APPROACH
The policy consists of three basic parts. The first section
describes components of assistance agreements and how they are to
be negotiated. The second section lays out EPA's expectations for
the review and evaluation of assistance agreements and escalation
of significant findings. The final section describes how EPA should
respond to the findings of oversight: rewarding strong performance;
applying corrective actions to solve problems; escalating signif-
icant conflicts to top management; and, in cases of persistent per-
formance problems, imposing sanctions.
-------
-3-
ASSISTANCE AGREEMENT
Clear expectations for program performance are crucial to an
effective EPA/State partnership. Annual assistance agreements pro-
vide a key vehicle for expressing these performance expectations.
Negotiated work programs, contained in an assistance agreement, form
a fundamental basis for evaluation of State performance.
An assistance agreement should include three components: 1) a
work program; 2) identification of suppQr^t^Xother than federal -:
assistance funds) a State needs from EPA:~to accomplish work program
commitments; and, 3) a monitoring and evaluation plan.
APPROACH
EPA and states should negotiate outputs which reflect a mix
of national and State priorities* National priorities should be
clearly articulated in the annual Agency Operating Guidance. To
better facilitate the negotiation of assistance agreements, the
Guidance should be strengthened through early State involvement
in defining the order and scope of Agency priorities, and the more
specific identification of top priorities by Program Offices.
Funding limitations should be recognized throughout development
of the national priority list and program-specific guidance.
As EPA Regions and States negotiate outputs, national prior-
ities should be tailored to the real environmental conditions of
each State and Region. Assistance agreements should also allow
for outputs based on a State's priorities. State priorities should
represent those activities allowable under federal statute which
will produce significant environmental results.
•
The development and oversight of an assistance agreement should
be supervised by one senior Regional manager, but EPA Regional
Administrators are ultimately accountable for all assistance agree-
ments made with States and should be familiar with the significant
outputs and conditions of each agreement. They will be respon-
sible for all major assistance-related decisions, particularly
decisions related to sanctions.
Assistance agreements may be amended by mutual agreement of
the Regional Administrator and his/her State counterpart. A major
change in national or State priorities, environmental emergencies,
and the discovery of greatly overestimated corr.rni tnents are examples
of the types of circumstances which may necessitate renegotiation.
-------
V 0 TT
-4-
WORK PROGRAM
i The work prograrr. should specify the outputs a State will pro-
duce under its federal assistance award (including the State match
£ and level of effort) and the resources and timeframes for completing
^ • the outputs.
? • o Outputs should be measurable commitments, reflective
I to the extent possible of real environmental results.
\ They should be ambitious but realistic commitments —
> achievable objectives rather than lofty goals.
| o Work programs should focus on";tVe objectives a State "
r will meet, not how the State will accomplish an output.
{ o Past performance should affect work programs. The. good
| or poor performance of a State (or EPA) identified through
[ oversight should influence the outputs and conditions
{ contained in the next annual assistance agreement.
I
: o Work programs should specifically identify completion
timeframes for outputs. EPA may also specify interim
milestones and reporting requirements based on the
priority needs of national programs and in keeping with
good management practice. Reporting required under an
assistance agreement should be consistent with EPA's
information systems.
o States should draft their work programs but may request
assistance from EPA Regions in developing them.
o States should be encouraged (not required) to volunteer
a comprehensive work program that indicates activities,
if any, outside those paid for with the federal and State
funds included in the federal assistance agreement budget.
Awareness of State responsibilites not related to federal
assistance greatly enhances EPA's understanding of the
scope of State environmental programs. Should a State
choose to submit plans for its entire program, it need
not indicate resource levels, but only program activities
EPA will not examine these activities in the course of
assistance oversight except when necessary to ascertain
the cause of a performance problem or to identify the
corrective action which can best address a problem.
I
1 SUPPLEMENTAL EPA SUPPORT TO STATES
\ An assistance agreement should describe the types of suppo
| £?A will endeavor to provide in addition to an assistance aware
I enable a State to meet its work program outputs. Regions shoul
* consult with Headquarters about support which will require Heac
$ quarters action.
-------
1 v - v ••• i-
* -5-
1
agreement? the State will be relieved of output commitments
contingent upon that support.
_,O"i~"
| EVALUATION PLAN
The final component of an assistance agreement is * plan
for EPA's evaluation of State performance. The evaluation plan
should be mutually acceptable to EPA and a State.
o The olan should outline the schedule and scope of review
EPA Sill conduct and should identify areas the evaluation
will focus on.
o An evaluation plan must specify at least one onsite
review per year, performance measures, and reporting
requi
should oversee assistance agreements both informally and
" rt
finance Oversight should identify 'the successes and problems
isrssi. srsusu.
in EPA and the State.
i APPROACH
i The forna' assessment of State performance under assistance
f aoreemonts should occur as part of EPA's comprehensive review
\ animation of State programs. This -process is governed by
* EPA's Policy on Oversight of Delegated Programs which states
1 that evaluations should focus on overall program performance,
i ratheJthan individual actions; they should be based on objective
* measures and standards agreed to in advance; they should be con-
's Suited onsite at least once a year by experienced, skilled EPA
f
-------
-6-
written report
ag
reement
S
states regarding
ight and to
*
4
I
o supply pro.i..a support.
accorop 1 i s hrne nt s
ssistance
^^^^
use existing reporting .n* ev.l.at:
^rr^pTvTrMrES OF OVERSIGHT
p.
lems.
7303824
-------
APPROACH TO OVERSIGHT RESPONSE
The Agency's goal in providing performance-based assistance
is to support and promote effective State environmental programs.
Actions in response to oversight findings will be oriented toward
finding the most effective ways to maintain or improve a State
program's performance. Wherever possible, EPA should acknowledge
- excellent performance and help States solve problems which impede
f performance through corrective actions.
If problems regarding State acn-ievement of work program ~
commitments persist, EPA should pursue progressively more de-
manding corrective steps as necessary based on experience with
a given State. In general/ sanctions should be imposed only
when corrective actions have failed to solve persistent, signif-
icant performance problems. Before taking any sanction against
a State, EPA should raise the performance issue to the highest
levels of the Region and State necessary to negotiate an effec-
tive solution to the underlying problem. Sanctions should not
be necessary if both parties are explicit, straightforward and
realistic in their expectations of one another and approach the
assistance agreement process in the spirit of cooperation.
INCENTIVES
o When a State meets its negotiated commitments or other-
wise demonstrates success, the EPA Regional Office
should take steps to acknowledge excellent State
performance at the conclusion of the oversight review
or at the end of the assistance agreement period.
o EPA is committed to publicizing State program success.
Assured recognition of a State's environmental achievements
is one of the most effective incentives at EPA's disposal.
Publicizing accomplishments also benefits States with per-
formance problems by providing them with models for success.
o In general, when a State demonstrates steady progress or
a sustained level of high performance against negotiated
commitments, EPA will institute the most appropriate rewards
for achievement and incentives to promote continued success.
possible actions include but are not limited to:
Reducing the number, level, scope and/or
frequency of reviews, reporting, or in-
spections to the minimum necessary for
effective national program management;
Increasing State flexibility in using funds
for special projects or State priorities;
Offering financial incentives (within existing
resources), such as supplemental funding;
d. /o 4 1 o • o r< 7o ft o ft
-------
I
Publicizing program successes through joint
media presentations, awards, special letters of
cO.T.mencJation to the Governor, or technology
transfer to other States, EPA Regions and
Headquarters.
CORRECTIVE ACTIONS . .
o When oversight review uncovers a performance problem and "
determines its cause, EPA and the State must act on those
findings by taking appropriate corrective steps.
o Regions and states should follow a corrective action strat
egy based on the unique history and needs of a given Statt
This policy does not prescribe any particular sequence of
corrective actions which must be undertaken, nor does it
link specific corrective actions to particular types of
performance problems.
o Regions must initiate discussions with those States where
problems have emerged, and work cooperatively with them tt
establish effective remedial strategies. This negotiated
strategy should specify the timeframe during which EPA wi.
expect the problem to be resolved, and any interim milest«
that will be necessary to monitor State progress.
o Possible corrective actions include but are not limited t
providing EPA technical or managerial assistance, trainin
or additional resources; increasing the number and/or fre
quency of reporting and oversight requirements; and shift
State resources or otherwise re-negotiating the assistanc
agreement.
4
o If a Region is not able to provide a particular essential
type of specialized assistance to a State, the Region she
bring this corrective action requirement to the attentior
of Headquarters program managers for action as appropriat
o The intent of this policy is to see that EPA assumes a
constructive approach in responding to State performance
problems. when corrective actions have failed, or EPA ar
a State cannot agree on a corrective action, the Region
may consider imposing a sanction* If a sanction is conte
plated, the performance issue should be escalated to the
highest appropriate level of EPA and the State. The folJ
iny sequence should be observed'whenever possible:
a. The Regional Division Director responsible for
managing the assistance agreement will raise the
issue to the attention of the Deputy Regional
Admininstrator or Regional Administrator and advise
his/her State counterpart of this notification.
1P:?3
-------
-9-
b. The Regional Administrator will personally contact
the State Environmental Director or other appropriate
State manager to attempt to reach agreement on a
corrective action, and to discuss the contemplated
sanction.
c. National Program Managers should be advised of any
State program problems warranting a sanction, and
should be notified of any final decision to take
such action. <>^_.
d. If negotiations between the Regional Administrator
and State counterpart fail to solve the problem,
the Regional Administrator should judge under what
circumstances notification of the Governor,.--should
occur.
SANCTIONS
o Regional Administrators must recognize that national re-
sponsibility for any State environmental program continues
after the imposition of a sanction* They should make ar-
rangements for completion of crucial outstanding outputs
and should take steps to promote and sustain activities
the State is performing effectively.
o As with corrective actions, any decision to impose a
sanction must be based on EPA's particular experience
with any given State. The Regional Administrator is
responsible for determining when a problem may be signif-
icant enough to warrant such action, and for determining
the appropriate type of sanction to apply.
o Current regulations detail those sanctions traditionally
available to EPA, They include: stop-work actions,
withholding payment, suspension or termination of agree-
ment for cause, agreement annulment, and other appropriate
judicial or administrative actions.
o Adjusting the schedule for award or release of assistance
funds, or anything other than annual release or prompt
payment of assistance funds is considered a sanction under
the terms of this policy.
o 40 CFR Part 30 Subpart L details formal procedures for
resolving EPA/State disputes concerning assistance
agreements. These procedures provide the opportunity
for a State to document the grounds for any objections
to the imposition of a sanction and for EPA to review
its decision and address the State's objections on the
basis of a written record.
R4/?4 12: ?7 7383RP4 #01
-------
<*•
"Iss3n-»a^I3^ffiss"«"-s™!»"!~'«
M^^^>£s!-g&£? •>
BS~— -~
IMPLEMENTATION OBJECTIVES; •"
Activities to implen,ent the policy shouid serve the
following objectives:
• r SL? s^:^^'^^'^^ S^-
5ollS? 2n Performance-Based Assistance?
' Ton" S'U^l^tiS ifas-leVt^I* S.SS.n..
cycle;
• ss5.-Si5trs?^ras as SB.'-
T ; ^~.^rs«-a<-irtn hevond FY eo.
program opera
implementation beyond FY'86
roMMUNICATIO^'- Getting th» v^ord Out Fast
,
officers and Regional 9""".°" thev m.J5t understand its
this policy. More lmP°r"^^; *^ds to be a quick effort
substance and relevance. *£" ^'£. poiicy, followed by
t0 ""^KnitiwilSn'.!'- "=h "nderltLding. This section
leafs witt nc.isse"inatU the polley quickly
II JKt^iUc? iv ^ers(staeprora™ lr.etor..
Governors orP|tate Bnviron.ental Co^iss.oner s> ,
aSd to feature it in their nev^etters.
. EPA provides briefings on policy -.t upcoming EBO ...ting
7303S24
-------
- 2 -
c Administrator sends the policy to designated Headquarters
and Regional program managers.
* Regional Management Di v i e ior>c sponsor bri*fjnr>e fr>r
Regional staffs within one month of policy's release.
Work Group and/or Policy Group members present the policy.
i Headquarters program managers may elect to send staff to
explain the policy's application to their program.
0 Deputy Administrator convenes Assistant Admininstrators -
for briefing on po3icv- e$SB"staff available to provide,
briefings to program staff if requested.
* OMSE prepares and distributes questions and answers
to ensure consistent policy interpretation...,
LONGER-TERM ACCOUNTABILITY AND FEEDBACK:
1•Assuring Consistent and Ongoing Implementation
A one-time effort to disseminate the policy will not
ensure successful policy implementation. The Policy Group
believes that program managers must play an active role in
putting this policy in place. Accountability must be
clearly assigned for follow-up.
e Within one month of the policy's release, Assistant
Administrators advise the Deputy Administrator of
actions planned or taken to conform their program
guidance to this policy.
0 The Office of Management Systems and Evaluation
advises the Deputy Administrator of plans to
strengthen the Operating Year Process to-
achieve early State participation in the Agency
priority-setting process, and to ensure a clearer
articulation of programs' top priorities.
0 EPA Regional Administrators and Division Directors
incorporate the policy's implementation into
their performance standards for FV'86.
; 2. Evaluating Policy Results
i
| Monitoring progress in implementing the policy should
t ensure that the Agency in fact speaks with one consistent
£ voice on performance-based assistance." Reinforcinq success
t quickly, or noting implementation problems early on, should
i help institutionalize the policy.
|v * OMSE briefs the State-EPA Operations Committee in June
04/24 1£:£9 7363024
-------
- 3 -
and discusses their possible oversight role in
monitoring implementation.
0 Designated Work Group members including OHSE will
evaluate Regional experience in implementing the policy,
including a review of incentives and corrective action
strategies, and may undertake other projects as necessary
to support implementation,
* Regional Administrators shotjQrA-submit progress report
at the conclusion of mid-arid end-of-year reviews,
including steps taken to recognize State success.
Assistant Administrators' annual Regional evaluations
will measure the Regions' success in implementing
the performance-based policy. »"''
"7 •"' ft 0 ft 2 d I ft
-------
BACKGROUND
POLICY ON PERFORMANCE-BASED ASSISTANCE
WHY WAS THE POLICY NEEDED?
o To promote improved EPA/State performance under federally-
funded continuing environmental programs.
o To provide clear expectations between EPA Regions and
States in managing assistance under a performance-based
system.
o To provide for consistent approaches across all EPA*
programs in applying existing regulations on State and
local assistance (e.g., RCRA and OW were developing
different approaches)*
HOW WAS THE POLICY DEVELOPED?
o In February, 1985, the Task Force on Performance-Based
Assistance was formed. It was composed of a Policy
Group and a Work Group. OMSE developed the schedule
for the Task Force and coordinated the work. Task
Force groups met during a number of all day and half
day sessions.
•o EPA Headquarters, EPA Regions, and States were represented
on both levels of the Task Force and all had an equal
voice in shaping the policy. This structure fostered
the principle of "no surprises" between EPA and States
by allowing for ideas and issues to be raised and resolved
through an open forum.
o The Policy Group, chaired by Jim Barnes, agreed on over-
riding policy principles and key concepts, discussed
outstanding issues, provided guidance to the Work Group
for resolving issues, and refined policy language. (A
list of Policy Group members is attached.)
o The Work Group, coordinated by OMSE, developed the initial
framework for the policy and provided the Policy Group
with proposed policy choices and rationale for making
those choices. (A Work Group membership list is attached.)
04/24 1£:32 7363824 $05
-------
-2-
WHAT ~I
.TURES OF THE POLICY
,^ eranne Agreement
ISSUES?
Features
The assistance agreement has three components:
o Work Program
.*£-.—
"" y-"1*1"
- Specifies outputs, resources, and timeframes;
- Lays out measurable and realistic commitments;
- Is the product of negotiation between EPA F
and States,
o Supplemental EPA Support to States
- Describes support (other than the assistance award)
EPA expects to provide within a given year;
- Recognizes that a State's fulfillment of outputs may
be contingent upon the receipt of EPA support.
o Evaluation Plan
- Outlines EPA's schedule and scope for review;
- Specifies at least one on-site review per year, perfor-
mance measures, and reporting requirements.
Policy Group Discussion
«
The Policy Group discussed one major issue:
° Should the policy define how to achieve the correct
balance of National versus State priorities in assistance
agreements?
The Policy Group examined how assistance agreements might
address and balance both EPA and State interests. In
general, members agreed that outputs should reflect National
State, and Regional priorities. But differences surfaced
over precisely where and how to strike this balance between
State and National interests.
The Policy Group decided that a formula for balancing
National and State priorities would be impractical to
set because of differences between programs. Rather,
they decided that everything in the grant is negotiable,
but Regions and States should clearly understand that EPA
7303624 #06
-------
-3-
will insist through negotiations that top National priorities
as stated in the Operating Guidance be included in the
work program.
This approach recognizes that a workable mechanism for
defining (and limiting the number of) National priorities
exists within the Operating Guidance, and should bf enhanced
if necessary to support this process. The approach also
recognizes the importance of allowing States to negotiate
activites which may not directly, match National priorities,
\ but which may yield significan»Cpre"nvironmental results,
i
Ass is tance Overs i ght
Major Features ""
o Oversight should be conducted formally as part of EPA's
comprehensive program oversight of delegated programs;
o Oversight should be conducted informally through continuous
dialogue between Regions and States;
o Oversight is aimed at identifying successes and problems
of States in meeting their commitTtients;
o Oversight entails joint analysis of problems to determine
their nature, cause, and appropriate solutions;
o Oversight findings should be documented to establish
an accurate record.
Policy Group Discussion
The Policy Group discussed onetmajor issue:
o What should the scope of grant oversight be as compared
to comprehensive program evaluation/oversight (governed
under EPA's Policy on Oversight of Delegated Programs)?
The Policy Group discussed the relationship between
; comprehensive program oversight and the more narrow
I review and evaluation of State performance under assistance
{ agreements (i.e., assistance oversight). In general,
• members agreed that program oversight involves a broader
L range of reviews and responses undertaken to promote the
| overall health, quality and proyress of delegated programs.
£ The Policy Group agreed that assistance oversight should
I focus on how well a State program accomplishes the outputs
| committed to in its work program. Assistance oversight
I should occur as one component of EPA's comprehensive
? program oversight, not as a separate process.
I
r
1P:3=; 7303624 #87
-------
-4-
Features
o£
oversight findings:
incentive* for Good
and States should taVe corrective actions before
.. -. e ai-iff- \On J
CJC-aw^-' "• .
impose a sanction;
o sanctions as a Last^gsort
.
and type of sanction;
t.<«n«» defined by regulation (withholding
- in addition to sanctions defined Dy r « includes
Y Group Discussion
The Policy Group raisecJ one major issue:
c
#08
-------
-5-
whn these coope fail.
f1?4 #09
-------
Administrator's TasV. Force on Performance-Based Assistance
Policy Group Membership
Chairman; A. James Barnes, Acting Deputy Administrator
States
Robert Arnott, Director -.?>--"
Health and Environmental Protection Office
Colorado Department of Health
Richard Carlson, Director
Illinois Environmental Protection Agency -,--
Kenneth Hagg, Director
Department of Environmental Affairs, Massachusetts
j. Leonard Ledbetter, Commissioner
Department of Natural Resources/ Georgia
Wallace Stickney, Director of Environmental Affair?
New Hampshire
EPA
jack Campbellr Deputy Assistant Administrator
Office of Policy, Planning and Evaluation
Lee A. DeHihns, Associate General Counsel
Office of General Counsel
Gerald Emison, Director
Office of Air Quality Planning and Standards
Alan Levin, Deputy Regional Administrator
Region V
Henry Longest, Deputy Assistant Administrator
Office of Water
Alvin Morris, Director
Water Management Division
Harvey Pippen, Director
Grants Administration Division
John Skinner, Director
Office of Solid Waste
7363024
-------
Administrator's Task Force on Performance-Based Assistance
Work Group Membership
Chairman - John Thillmann
Corinne Allison
Bill Becker
Kevin Bricke
Allan Brown
Rita Calvan
Truett DeGeare
Jim Home
Chuck Kent
jerry Kurtzweg
Harley Laing
John Martin
Sue Moreland
Cynthia Puskar
rd Richards
• arla White
ALTERNATES
Don Brady
Howard* Corcoran
George Faison
Richard Mitchell
STAFF
Katherine McMillan
Lawrence Leahy
Matt Perl
Betsy Shaw
Organization
OMSE/OPPE
OARM
STAPPA*
Region II
OGC
OIL/OEA
OSWER
OC
ORO
OAR
Region I
OCM/OPTS
ASTSWMO*
OMSE/OPPE
OW
ASIWPCA*
Region V
OECM
OW
OGC
OSWER
OARM
OMSE/OPPE
OMSE/OPPE
OMSE/OPPE
OMSE/OPPE
Telephone *
382-5332
**^/*^^*
38 ~2- 5 29 4
. 624-7864
8-264-4296
382-5313
382-4454
382-2210
382-4221
382-4719
382-7435
8-223-2226
382-5572
624-5828
382-5446
382-7160
624-7782
8-353-2147
382-7550
475-8638
382-5313
382-2221
382-5*297
382-5360
382-5346
382-5350
382-5357
Room *
445WT
M3317
New York
W1031
W825*"
S-256
W-719A
W1201
W941
Boston
M-2507
W-743
E-945C
Chicago
W-G1
E-945A
W-1031
S-256
W-3317
W-443
W-409
W- 4 0 5
W-405
Mail Code
PM-222
PM-216
Suite 306
City
LE-132G
A-100EA .
WH-563B
PM-225
A-100
ANR-443
EN-342
Suite 345
PM-222A
WH-586
Suite 330
LE-13033
WH-586
LE-132G
WH-565
PM-216
PM-222
PM-222
PM-222
PM-222
*Hall of States
444 North Capitol
Washington, D.C.
20001
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
DATE MAR 2 01985
SUBJECT- Improving State Relations
tef-
FROM.- Ken Fenner/-T3«
Chief, Water Quality Branch
TO: Section and Unit Chiefs
We can do some simple things to improve relations with our States that we
do not need training for. We do need a little self-discipline and a conscien-
tious, consistent, concerted effort to do them. We can also apply these to our
staff and each other around the office. The results may take some time to see,
but the effort should be worth it. ?
»
Are you ready for a WQS 60-second lesson in improving relations with your
State counterparts and getting some results. Here it is: Please,
1. Smile at them, even when you're on the phone. Throw in a few chuckles
every so often.
2. Show some interest in them. Ask them how their weekend or vacation was,
etc.
*
3. Compliment them on any and every positive and good thing that they
have accomplished, however small. Do this first or as soon in the
conversation as possible. Give them honest praise.
4. Be nice, even when it is difficult, and keep smiling.
5. If a problem arises, minimize it to the extent possible and get on to
the solution. Don't rub it in.
•
"6. Ask for things, don't tell them to do things.
7. Say "please" and "thank you".
8. Let them know that you know they are busy, but "could they provide ...
so on and so forth...?" You recognize their importance by doing this.
9. Recognize their good ideas and give them emphasis. Ask them their opinion
first, regardless of whether you think you already have the answer
you want. (You may change your mind.)
10. Be enthusiastic and encouraging about what they are doing.
11. When you are wrong or have inadvertently mislead them through the
regulatory maze say to them as soon as possible and without hesitation:
"I goofed, I'm sorry, I apologize for ..." and "now how can we move
ahead from here?"
EPA FOAM 1320-6 (REV 3-781
-------
12. No matter how bad you think things have been in the past or how many
wrongs have been committed or promises broken, the past is over and done.
Today is fresh and new. Take any and every opportunity to improve matters
regardless of how small.
13. Follow up phone calls with letters and letters with phone calls -
take nothing for granted. Communicate with them. Keep lines of
communication open, even when you disagree. This will show them
that you are concerned about them and their work.
14. Remember, they want their concerns to be just as important as yours,
they want to be trusted and regarded just as much as you. And in a large
measure, your results depend on their results. They are important to us.
Treat them like you would want to be treated. You will then truly become
a manager of people with positive, productive results.
*
Thank you, and have a good, productive day. •
-------
ENVIRONMENTAL REPORT
No One Knows for Sure if Pollution
Control Programs Are Really Working
EPA has no centralized pollution monitoring system. It relies on states and localities
and even the polluters to gather data that may not tell the agency much.
BY ROCHELLE L STAN FIELD
As a nation, we spend $45 billion a
year to control air and water pollu-
tion, but we don't know whether we are
getting our money's worth.
"Once the laws are passed and the
regulations written, it has been assumed
the problem was taken care of," said
Martin D. Halper, director of
the Environmental Protection
Agency's (EPA) exposure
evaluation division in the Of-
fice of Toxic Substances. "But
what, in fact, is happening out
there? Are the regulations do-
ing what they are supposed to
do to solve the problem?"
Each EPA pollution control
program—and there are hun-
dreds of them aimed at spe-
cific environmental problems
such as contaminated drink-
ing water, auto emissions and
municipal land fills—includes
requirements to monitor what
is released into the environ-
ment.
But the leap from requiring
this monitoring to obtaining
useful information is long and
high, involving technical
twists, political and bureau-
cratic somersaults and inter-
governmental back flips.
There are a host of different steps "in
monitoring, and each one is fraught with
innumerable problems," said J. Clarence
Oavies, executive vice president of the
Conservation Foundation.
There are two basic types of monitor-
ing, each with its own purpose and prob-
lems. To get a general impression of what
the environment is like and whether we're
making progress in cleaning it up, EPA
and the states sample the air and water—
ambient monitoring. To clean up the air
and water, the government limits the
level of pollutants that each source can
spew into the air or dump into the water.
That requires a different, more precise,
emissions monitoring because it is used as
the basis fcr enforcement actions that
must withstand legal challenges.
EPA has no centrali2gdj5ysiemjojmon-
itoFIil types of pollution. Each program
the types of monitoring, the placement of
the monitors and the meaning of the data
obtained.
There isn't enough money to purchase
sufficient monitors, train those who must
operate them and analyze the resulting
data. Critics such as Davies say that is
because monitoring is a "political or-
phan."
"It's not a sexy subject, so
not only hasn't it received
much manpower, it hasn't
been taken very seriously,"
said Clifford S. Russell, direc-
tor of the quality of the envi-
ronment division of Resources
for Jhe Future Inc^ a Wash-
jngton think tank. ~~
"lf~w"erre~going to spend
that much money to control
pollution, you'd think they'd
put a little more money to-
ward knowing whether we're
making progress, how fast,
where we're not and why
we're not," added his col-
league, senior fellow Paul R.
Portney, who estimates that
federal, state and
A utility employee monitors air pollution.
office has its own approach and even its
own ideHfflc^jqn^odeI.Cbr_.BoiIutg''s
whose emissions might be subjcctjo sev-
eral monitoring systems. EPAcioesn't col-
lect most of the data but relies on states
and localities, and the quality of the data
can vary widely. The age and condition of tf
some air monitoring equipment worries!
some analysts, and the reliability of water/
data is questioned because the monitor/
ing is conducted by the polluters. MeaiH
while, scientists and engineers fight about
ernments spcnd__about_$lQO.
million _a_iear_on _ moni tori ng.
"In no city can I get in-
formation collected on a regu-
lar basis that tells me here's
what is in the air I breathe if I
walk down Main Street," said David G.
Hawkins, assistant EPA administrator
for air and radiation in the Carter Admin-
istration and now an attorney with the
Natural Resources Defense Council Inc.
(NRDC).
The situation is worse for water, critics
say, because the monitoring system is
even more decentralized'and the data less
reliable because they come from ihe pol-
luters. And monitoring of hazardous
wastes and toxic substances is even spot-
NATIONAL JOURNAL 3/23/85 643
-------
tier because there is no consensus on what
levels are safe.
But there is good news, even some of
the harshest critics acknowledge. For the
past two years, EPA management offi-
cials have been trying to bring some sense
and coherence to the disparate monitor-
ing systems through a quality control
program. "I think EPA is serious about
trying to pay more attention to environ?
mental results now," said Portney.
"With tTie expansion of the Quality
assurance program, we're beginning to
get to where I feel we should be," said
Halpcr.
"Is everything a mess? If you look at it
as a purist, the answer is probably yes,"
said Ronald Brand, director of EPA's
management systems and evaluation of-
fice. "If you look at it realistically and
ask. 'Has it been good enough to get us to
make real progress?'—as far as I know,
nobody denies the air and water arc
cleaner now."
AMBIENT MONITORING
It sounds simple enough to find out
how clean the air and water are: sample
them and analyze the samples.
But it's actually quite complicated.
What kind of sam-
plers do you use? '
Where do you put
them? How many
samples do you
take? How often?
Are the data from
different samplers
comparable?
"You can deter-
mine the outcome of
monitoring by where
you put lhe moni-
tor." said Oavies.
"How far is it from
the nearest factory
outlet into a stream
or smokestack? That
makes a big differ-
ence in the results."
A Burbank (Calif.)
air sampler once was
located at the end of
an airport runway.
for example, result-
ing in incredibly
high, and misleading, air pollution read-
ings for the city.
EPA has_a national ambientjir quality
monitoring sysTenT'bj^ nd""nationa^jiet;
*>or_k for ambient waTFr''mormgrifijr Jn--
stead, the agency contracts with the" indT"
vidual states to monitor water as a
condition of receiving federal water pollu-
tion aid. While EPA has uniform guide-
lines for collecting the samples, analyzing
them and reporting the results, quality
assurance has always been a problem.
Researchers who want to use the data say
they have a lot of trouble making sense of
it. They are never sure how comprehen-
sive the sampling is and whether the data
are comparable across state lines..
EPA does not even use the data for its
national reports, relying instead on sepa-
rate national surveys that it conducts. But
those survey results are generally spotty,
providing a snapshot of water conditions,
not a well-rounded picture over time, say
the critics. To get the full picture. EPA
and researchers use data collected bv the
U.S. Geological Survey.
But that has problems too. While re-
searchers have a lot of confidence in the
data collected by the Geological Sur-
vey—it takes plenty of samples and exer-
cises good quality control—they com-
plain that because the Geological
Survey's network was set up to measure
quantity, not quality, of water, the sam-
plers arc in the wrong pluccs. fur from the
sources of pollution at the end of water-
shed basins.
"It's terrific for long-life pollutants
that don't degrade or_sink_ to the bottom"
of the river. said~Pavjes. BUP'trlat's'not
many pollutants. The large particles that
sfnkto the bottom don't show up Because
Clifford S. Russell of Resources for the Future Inc.
™> -y
thcy^ye disappjcaredlLby. the. time The wa-
_ _
gPAj_arjhi<»nt air" monitoring
is more successful. While the bulk of the
data collection and analysis is done by
state and local governments, the monitor-
ing is more uniform and is conducted
under a much more watchful federal eye.
Nearly all the 5,000 state and local air
monitors are in the right place, operating
properly and in compliance with EPA
rules, an agency audit found last year.
The audit also concluded that "most
agencies are providing the required preci-
sion and accuracy [of] data."
The program did not always receive
such high marks. In 1979, the General
Accounting Office (GAO) found that 72
per cent of the monitors were in the
wrong place, 58 per cent of the equip-
ment was the wrong kind and 81 per cent
of the sites had problems "which could
adversely affect the data's reliability."
Following that study, EPA imposed new
monitoring requirements on state and lo-
cal air pollution control agencies. A fol-
low-up study in 1982 found some im-
provements—made slowly and at great
cost—and many remaining problems and
inadequacies.
"1 think a fair characterization [of the
national air monitoring system] is that it
had fairly large problems through the
mid-1970s, that it's really getting better
but that everything's not hunky-dory,"
said S. William Becker, executive secre-
tary of the state and local air pollution
control administrators' organizations.
The expected life of an air monitor is five
years, for example, and an air adminis-
trators' survey last year found that the
average age of monitors was 5.1 years.
The monitors
might work and the
states might be
sending in accurate
data, but too few
data are collected to
get an accurate
reading of the air's
condition, critics
say. "It's as if you
had a television set
which showed only
every IOth line and
everything else was
black," t he NR DCs
Hawkins said
"Even though that
line is clear, you
don't get a very good
picture of what's
happening."
EPA requires
metropolitan areas
to have two or three
carbon monoxide
monitors, for exam-
ple, while many more are necessary, he
said. In fact, many large cities voluntarily
have installed several times the required
number, according to Hawkins. But to
get an accurate reading of the air sur-
rounding a rural power plant, the plant
should be ringed with sulfur dioxide mon-
itors, said Hawkins, and one monitor is
the norm.
"There's not enough money—not just
in the budget but in the whole universe—
to monitor every place where people
644 \ATinsiAi
-------
breathe," said Joseph A. Cannon, until
recently assistant EPA administrator for
air and radiation and now a Washington
attorney. "So you have to make assump-
tions."
Those assumptions take the form of
complex mathematical models of the air
quality based on information gathered by
monitoring, climatic conditions and other
factors. Critics question the data used in
the models. Robert W. Crandall, a senior
fellow at the Brookings Institution, at-
tacks the sulfur dioxide models, for exam-
pie, because they assume that scrubbing
devices on utility boilers work all the time
even though they are frequently broken.
Mathematical models are often used
by government to justify requiring the
installation of expensive pollution con-
trols and by industry to avoid those con-
trols. Cannon recalled an instance where
EPA models showed the need for pollu-
tion controls on a power plant, while New
York State and industry models showed
there was no need.
Models versus monitors is becoming_a
more controversial issue as EPA makes a
_
soot, dust and other particles in the air.
Instead of measuring the total amount of"
panicles, it is going
to"reojiiire that the
tiny particles —
which^are^ the most
d a ngerous __ to
h e alth— be mea-
sured separate 1 y.
(See HJ. 3/17/84. p.
516.)
That wilt require
new air samplers.
which EPA has just
purchased. But
there was only
enough money in the
budget to buy 665
new machines —
only about a UjjnLaf
what is needed, ac-
cording to Becker.
Cannon says more
monitors aren't re-
quired because the
mathematical mod-
els show that many
areas are very un-
likely to violate the new standards, and, so
would not need the new monitors. The^
models will be used to predict which
area has a 50 per cent probability of
exceeding the standard, you need to
spend SI million putting on controls,'
that's not going to fly," said Becker. "We
need good monitoring data so we can say,
'Listen, you are operating in an area in
violation of the standard so, we have to
crunch down on the controls.' "
EMISSIONS SAMPLINGS
Controlling pollution at the source is
this country's approach to cleaning up the
environment.
Before a potential industrial polluter
can release anything into the air or water,
it must get a government permit that
spells cut how much pollution is permit-
ted and what equipment must be installed
to meet those limits. The best way to
check compliance with these require-
ments is to monitor what comes out of the
smokestack or sewage pipe.
A regulator's dream would be for each
stack and pipe to be equipped with a
machine to keep track of emissions and
ring a bell when the rules are violated.
For the foreseeable future, that's techno-
logically, politically and economically im-
possible. Instead, federal, state and local
governments have established emissions
5. William Bicker of the state administrators' group
areas are mostJikeiy_to violate the new
standards and thus require _thejiew_air
samplers ^nd stricter controls.
Becker strongly disagrees that states
wjjl be~a1bT^b ehforcVregulations based
on mathematical probabiliu« of npjTCorn- fuels (the source of most sulfur dioxide
pliance with the new standard. "If I'm an pollution) are equipped with these moni-
industry and a state regulator comes to tors. But EPA and the stales are permit-
me and says. 'We think that because this ted to use the data collected from the
monitoring systems based on periodic in-
spections of the polluters thai everyone
agrees have a lot of problems.
The closest thing to the regulator's
dream machine are continuous emissions
monitors on some utility and industrial
smokestacks. Several hundred of the
many thousand boilers that burn fossil
handful of monitors on brand new boilers
only to enforce the sulfur dioxide stan-
dards against those pollution sources.
EPA is working on regulations that
would allow the agency to use the data
from more monitors as an enforcement
tool. But even when these regulations are
implemented, the majority of old boil-
ers—probably also the dirtiest—will still
not be required to install continuous emis-
sions monitors.
In the absence of continuous emissions
monitors, sulfur dioxide pollution^Jrgm
most coaKfired_BQwcr_jiajus_is measured
by sampling the, coaLand calculating the
emission from the sulfur content of jhe
coaj. EPA enforcement officials say this
is an imprecise measure, at best.
Regular monitoring of polluters for
compliance with otherjair quality regula-
tions^ is practicany~ nonexistent. 'Slate en-
forcement agencies inspect the pollution
control equipment to make sure it is in-
stalled and working properly. But these
inspections are very expensive, and so the
states average only one inspection of each
polluter a year—twice a year for the very
large polluters—according tr a survey by
Resources for the Future.
"An inspector is sent in once a year, so
you know that they
'•',**;>...„. • .{ are in compliance
;' \ " .-•.,". "*':..i right now," said
-" "."r* •••_. - • »~ Bern Steigerwald,
. » director of the office
of regional programs
in EPA's air quality
policy and standards
division. "But you
don't know whether
_ . . they are in compli-
ance 10 hours after
your visit or two
weeks before it."
An additional
problem is that
. nearly all of these in-
spections are an-
nounced a week in
.• . advance, in part be-
*... cause of the ambigu-
""""^"M ities in the case
law concerning so-
,~ called warrantless
searches.
"It's not really as
bad as it sounds," said Becker. "It's tough
{for the polluters] to sweep everything
under the rug because the inspectors go
through all their records. And the stales
generally know who the bad actors are.
t*
Emissions monitoring for water pollu-
tion is more consistent than for air pollu-
tion, put the reliability of the data lends
tQj5C_guestioned because_the_monitonn§
is donejy iHe'poirut'ers. 'Holderrof wa'ier
pollution pefrnuTfFave to take samples of
NATIONAL JOURNAL 3/23/85 645
-------
the effluent they discharge, have it ana-
lyzed in a certified testing lab and report
the results to the state or EPA. Filing
false reports carries a heavy fine.
In addition, state pollution control
agencies told Resources for the Future
that they inspect large sources of pollu-
tion about three times a year, small
sources about every eight months. "If the
fox is guarding the chicken coop, you'd
like someone to go in from time to lime
and check his teeth for feathers," said
Russell, who conducted the survey.
The NROC has found other reasons
for the polluters to file accurate reports—
generally nothing happens to them when
they report violations of their permits.
NROC studied monitoring reports for
1200 major industrial permit holders in
21 states and found that 90 per cent of
them had at least one violation over the
course of a year and more, than 30 per
cent reported significant recurring viola-
tions. In very few cases did the state take
action against them, says the NRDC.
NROC and other environmental orga-
nizations have filed suits in all 21 states.
NRDCs suit against Bethlehem Steel
Ca's Baltimore (Md.) plant for consis-
tently violating its permit, cites the com-
pany's own reports as evi-
dence. The company,
however, contends that the re-
ports are inaccurate.
TOXIC POLLUTANTS E
After 13 yean of wrestling
with the problems of monitor-
ing air and water pollution
control efforts, ~EPA now
faces the far more complex
job of tracking toxic pollut-
ants.
"There arc a whole lot of
toxics, many times the num-
ber of conventional pollut-
ants." said the Conservation
Foundation's Davies. "There
are no good methods of moni-
toring them. The methods
they have arc very very expen-
sive and they're not willing to
spend a lot of money," he said.
The fundamental problem
lack of agreement within
ised Congress in 1983 that EPA would
evaluate all 37 by the end of this year.
-------
Monitoring
In FY 84, the Agency in an effort to give greater emphasis and focus to monitoring,
required each National Program to develop a monitoring strategy. For the effort
begun in FY 84, all the National Programs were required to update thei r monitoring
strategies annually by May 25, of each fiscal year. Attachment A is a copy of
the Guidance given to each National Program for updating the monitoring strategies
in FY 85. Listed below are the current monitoring activities of each Program:
Air - Part 58 of the Air Monitoring regulations are being revised and are
expected to be promulgated by the end of FY 85. The revised regulations will
reflect greater emphasis on quality assurance.
The Toxics Monitoring Program is another major activity for FY 85. It is being
implemented at a snail pace at the State and Regional level. Also, the recently
completed Philadelphia study tested out 4 or 5 different methods for monitoring
air toxicants. Chicago (SE Chicago) is 1 of 3 cities that is a continuation of the
study began in Philadelphia. The Region and IEPA are monitoring for heavy metals
and toxic organic compounds.
Water - The Office of Water (OW) as a result of last year's monitoring strategy is
revising the Water Monitoring and WLA program guidance and will be implemented
in FY 86. There have been 2 drafts; none final as yet. The Guidance asks
for more bio-monitoring, ames test, toxics data, and more site/and specific
analyses to support the issuance of toxic based permits. This is a slight shift
away from the ambient data focus. Also, data integration is another major activity
in FY 85. The Region and Headquarters want to be able to look at ambient data
and effluent data to do better water quality modeling.
Pesticides - The National program is working closely with OSWER (RCRA program
staff) and OW to better define and support groundwater contamination and non-point
source incidents resulting from pesticides. Also, the National program has been
tasked with the Lust survey. The survey is looking at health effects and other
implications due to product use or misuse of pesticides.
Groundwater Strategy - The National strategy is to fill the gaps where the regu-
lations of the programs are not covering monitoring and synthesize the data that
are produced by the different agencies (USGS, Agriculture, EPA, State and local
agencies) for the purpose of improving the methods for doing ground-water moni-
toring. Also, Headquarters is working with EMSL and the Illinois Water Survey
Agency on better collection and analyses methods. This is a pilot project.
RCRA Groundwater monitoring - OSWER will be coming out with better regulations
on ground-water monitoring for the RCRA program. Promulgation date for these
regulations is not known.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D C 20460
MAR 11 1985
THE ADMINISTRATOR
MEMORANDUM FOR: Assistant Administrators
SUBJECT: FY 1985 Monitoring Strategy Updates
EPA's environmental policy requires programs to develop
monitoring strategies and update them annually. This memorandum
provides guidance to programs on preparing these updates which
are due May 25,1985.
If you have any questions on the following guidance, please
contact Ron Brand, in the Office of Policy, Planning and Evaluation
at 382-4028.
1985 Monitoring Strategy Updates
For all the offices that prepared strategies last Spring I
am requesting a brief (five to twenty page) update. The strategy
updates should contain two major sections which:
o Document substantial changes in monitoring policies,
plans, networks and activities which have occurred
since the 1984 strategies were submitted, and
o Describe a few (e.g., two to five) monitoring activities
or programs which you determine are most in need of
improvement during the next year or more.
The offices developing new monitoring strategies, such as
ground water, should refer to the 1984 monitoring strategy guidance
(attached), although some modifications may be appropriate.
A. Information on Substantial Changes in Monitoring
The first section of the monitoring strategy update
should document any substantial changes in the office's monitoring
policies, plans, programs and activities since the last strategies
were completed. Examples of "substantial changes" include:
o Newly identified information needs
o New monitoring networks
o Shifts in the pollutants and parameters of interest
o Major changes in the areas where monitoring is performed
o Progress in the development of new monitoring data
systems
o New research monitoring programs.
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-2-
If basic changes in policy or extensive changes to monitoring
programs have been made, you should provide revised monitoring
strategies rather than summarize the changes.
B* Information on Monitoring Areas For Improvement
The second section should present a few areas the program
proposes for improvement in order to meet critical program,
Regional and State information needs. In selecting these areas,
programs should first consider their overall environmental goals
and priorities and explain briefly how the monitoring proposals
are related to achieving them. Possible areas for improvement
include maintaining or enhancing existing programs, cross-cutting
issues such as providing improved data processing and quality
assurance, and developing new monitoring networks. This section
should also include a brief explanation of why each monitoring
area is in need of improvement and what actions are proposed to
address these shortcomings. The Regional Administrators for
each lead Region are responsible for advising the appropriate
Assistant Administrators in this process.
The preparation of the 1985 monitoring updates should provide
a basis for your planning for the FY 1987 monitoring budget
requests. We will have a special review on EPA's monitoring
budget again this summer.
Review of EPA Monitoring Strategies
In reviewing the 1985 monitoring updates, I am particularly
interested in how changes in environmental monitoring activities
relate to meeting our environmental goals and priorities. I will
be raising very basic questions, some of which are described below.
You may find them useful in deciding what areas to focus on and
what changes to recommend.
o Do the changes in monitoring move the program closer to
the goals of EPA's monitoring policy?
o Are the areas for improvement closely linked to Agency
and program goals?
o Does the program have the monitoring information it needs
to:
- Measure progress in meeting EPA's longer-term
environmental goals?
Assess achievement of nearer-term program operating
objectives?
o Where improvements are proposed, are there clear definitions
of the manor uses and users of the monitoring information
to be collected? Are unmet information needs identified?
-------
-3-
o Do the proposals take advantage of opportunities to
coordinate activities across programs?
o In the areas selected for improvement, do the updates
address how Headquarters programs will provide technical
leadership and what actions are needed to build improved
monitoring capabilities in the Regional, State, and
private laboratories?
*
o Do proposals for improvement in selected areas provide
adequate information for analyzing their feasibility,
resource and timing needs, and the organizations which
must work together to bring about effective changes?
o What will the program office and EPA be able to do better
as a result of implementing the proposals for improvement
and, conversely, what would be lost if we do not move
forward with them?
Schedule for the 1985 Monitoring Strategies
I will review the monitoring strategy updates in June. The
special analysis of the FY 1987 monitoring budget requests will
be conducted in July.
Lee M. Thomas
Attachment
cc: Regional Administrators
ESD Directors
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Attachment
Guidance for the
1984 Environmental Monitoring Strategies
December 14, 1983
-------
GUIDANCE FOR PREPARING ENVIRONMENTAL
MONITORING STRATEGIES
INTRODUCTION
This document is the companion piece to the Environmental
Protection Agency's Monitoring Policy Statement and provides
guidance to the program offices for preparing environmental
monitoring strategies. Programs' draft strategies are due
April 4, 1984; final strategies are due May 25, 1984.
PURPOSE OF STRATEGIES
Systematic and well thought out environmental monitoring that
meets the Environmental Protection Agency's needs for a wide range
of information is essential for the overall credibility of the
Agency's programs.
The Monitoring Policy specifies that each line program
(Office of Air and Radiation, Office of Water, Office of Solid
Waste and Emergency Response, Office of Pesticides and Toxic
Substances, and Office of Research and Development) will develop
program monitoring strategies. Having written monitoring
strategies for each program that address similar aspects of
monitoring should give managers and staff throughout the Agency
a better understanding of the many environmental monitoring
efforts under way. It should also improve coordination of moni-
toring activities between programs, between Headquarters and the
Regions, and between EPA and State and local agencies conducting
environmental monitoring. Finally, preparing monitoring strategies
will also be a way to identify where monitoring that is needed
is not under way, problems with monitoring that need improvement,
and activities that are duplicative of other programs' efforts
or that are not effective and need to be corrected.
APPROACH
This guidance follows the outline for monitoring strategies
included as an attachment to the Monitoring Policy. Each program's
monitoring strategy should:
o Define the full range of its environmental data needs,
o Outline how those needs are being and will be met,
o Identify problem areas and present specific actions
that will be taken to address them, and
o Provide schedules for achieving key interim and final
monitoring milestones.
In preparing its strategy, each program office should consider
each point of the Policy Statement to ensure that the strategy
is consistent with the Policy. Specifically the goals and objec-
tives for Agency monitoring activities stated in the Policy are
to:
o Meet the full range of current and future Agency needs
for environmental data.
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o Ensure monitoring is technically and scientifically
Sound.
o Ensure environmental monitoring data are managed to
facilitate both access and appropriate use in Agency
decision making.
o Ensure effective and coordinated Agency-wide processes
for planning and execution of monitoring activities.
o Ensure that' roles and responsibilities are clear in
regard to monitoring management and implementation by
EPA and State officials.
More than one strategy may be necessary for some offices.
For example, a program might choose to develop one strategy to
deal with compliance monitoring and data reported by sources and
another strategy to deal with ambient and other types of moni-
toring. Also, some programs may already have existing strategies
that fulfill most or all of the elements of a strategy as specified
by the Policy. If so, programs may use existing strategies and
supplement them as needed. Because many offices will be reviewing
the strategies to ensure coordination, the strategies or supple-
mental material should adhere to the outline as closely as possible.
The strategies should be succinct, with the length of each
strategy not expected to exceed 50 pages.
This guidance is not intended to be comprehensive for every
aspect of a strategy, nor is it intended to inhibit a program
office's creativity in preparing its strategy. Furthermore, not
all elements of a strategy outlined in the guidance will be
equally applicable to all monitoring activities. For example,
some programs require much more coordination with States than
other programs. Therefore, programs should try to cover the
items in the guidance but should not be constrained to those
items.
CONTENT OF STRATEGIES
SECTION 1; PROGRAM'S MONITORING GOALS AND OBJECTIVES AND
ENVIRONMENTAL INFORMATION NEEDS
A clear statement of the program's monitoring goals, objec-
tives and environmental information needs, including both narrow
operational and broader long-term needs, is perhaps the most
important section of the strategy. This section should answer
why such information is needed, what questions are to be answered,
what decisions will be based on the monitoring information, and
what the relative priorities of these needs are.
Some statutes mandate certain monitoring, or specify
activities that require monitoring, in order to carry out the
activities. These legislated activities and related monitoring
requirements should be identified in this section of the strategy.
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-3-
In preparing this section of their strategies, programs
should refer to the information needs that are listed in the
Monitoring Policy. Examples of questions that a program should
consider when developing its strategy are:
A» What Data Will the Program Collect to Make Assessments
of Status, Trends/ and Emerging Problems?
o For which chemicals, class of chemicals, or other
parameters will national, Regional/ State and local
environmental baselines and measurement of trends
be established? Some baselines and trends may have
already been established by existing monitoring
networks or programs, and these should be identified
in the monitoring strategy.
o For which populations or species will monitoring data
be collected to allow exposure and risks to be assessed?
What environmental damage, such as corrosion and/or
impairment of aesthetics, will be assessed?
/
o For what types of problems and for which chemicals or
class of chemicals will monitoring be done to detect
emerging problems?
B> What Monitoring Will the Program Do to Support Operational
Needs?
o What rulemaking, including the chemicals, class of
chemicals or industrial processes, will be supported
by monitoring?
o For which sources or classes of sources is compliance
to be determined? What are the relative priorities
of these sources for compliance monitoring?
o For which ambient standards will compliance be
determined?
o What is the anticipated level of enforcement monitoring
that will be required?
o What specific control activities will be monitored to
evaluate program effectiveness? In what terms will
effectiveness be measured (e.g., environmental quality,
exposure, and/or risk)?
C. What Research is Planned for Developing New or Improving
Existing Monitoring Methods Such as Instrumentation,
Network Design, Sample Collection and/or Analysis?
This list of questions is not intended to be an exhaustive
list or apply equally to all programs. However, programs should
define their monitoring data needs as precisely as possible.
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-4-
Also, because some data often can be used for more than one
purpose/ programs may want to display their needs in a table or
matrix.
SECTION 2; DESCRIBE THE EXTENT TO WHICH NEEDS ARE NOW BEING MET
This section of the strategy should describe the existing
networks and/or other monitoring efforts. In addition, the strategy
should describe which environmental information needs identified
in Section 1 are being fulfilled by the current monitoring efforts
and how they are being met.
This section should identify each monitoring program or
individual project and describe for each the:
o Goals and objectives
o Data needs that are being satisfied or will be
satisfied.
This section also should identify the additional monitoring
needed, beyond that which currently is conducted, to fulfill the
environmental information needs identified in Section 1 of the
strategy. This additional monitoring should be described in
terms of the type and extent of the networks and/or other projects
or special studies, or the source oriented monitoring efforts
that are needed.
Limitations exist with any monitoring system; not all
environmental information needs can be met by any one given
monitoring effort. These limitations should be discussed. For
example, if the network or monitoring system design is stratified
to develop a national baseline but not to target on potential
hot spots or localized concentrations, or if monitoring is for
hot spots or priority areas and not for an overall baseline,
this should be made clear. If exposure to pesticides is being
monitored by an adipose network, it should be made clear what
pesticides can be detected using that network and how or whether
the program plans to track pesticides that would not show up
using that method (e.g., plans to analyze for metabolites in
body fluids).
SECTION 3; OUTLINE THE PROGRAM'S PLAN FOR MONITORING TO MEET
THESE NEEDS
This section should clearly identify the program's priorities
for the current and proposed monitoring activities described
above. (Provide the relative priority and approximate costs of
each program in terms of personnel and contract dollars.)
Programs should indicate priorities in two ways: (1) assuming
existing approved levels of program resources, including transfers
of resources into or out of monitoring activities; and (2) assuming
some additional resources. The strategies should clearly indicate
alternatives regarding allocation of resources to monitoring.
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-5-
The quality assurance project plans that are reouired and
their status should be referenced. For each monitorinq effort,
the title and date of issuance of completed quality assurance
project plans should be included. If quality assurance pl^ns
have not been prepared, the schedule for completion of the project
plans should be included.
SECTION 4; DESCRIBE. HOW DESIGN, SAMPLING, HANDLING, CHEMICAL
ANALYSIS, DATA ANALYSIS AND DATA PROCESSING WILL BE CARRIED
OUT TO ASSURE (1) REPRESENTATIVENESS AND (2) QUANTIFICATION
OF OVERALL ERROR BOUNDS
The strategy should include sufficient detail about how
the monitoring will be conducted to give the reader a clear
understanding of the data that will be produced by the effort.
It is important that the representativeness and the confidence
one can expect in the data be as clear as possible.
SECTION 5; DESCRIBE LINKAGES WITH OTHER PROGRAMS, INCLUDING
MONITORING PROGRAMS, CRITERIA AND STANDARDS, PISK ASSESSMENT
AND ENFORCEMENT; DESCRIBE LINKAGES WITH OTHER FEDERAL AGENCIES
There are -several areas where improved coordination would
be very beneficial. Some linkages may have already been established
between or among monitorinq programs and need only be described
in the strategy. Other coordination efforts need to be developed
and clarified. The strategies should address the areas that
generally need better coordination and provide specific plans
for improving coordination. The areas to be covered are:
o Intra-Proqram Coordination. Monitoring activities within
programs that potentially should be better coordinated
include a program's monitoring to support criteria and
standards, risk assessment and enforcement activities
within a program or across programs.
o Inter-Program Coordination. Perhaps the greatest short-
term opportunities for improved coordination are inter-program
monitoring of ground water contaminants by the Drinking
Water, RCRA, and Superfund programs, and coordination of
toxic air pollutant monitoring and data reporting among
the Air, RCRA, and Superfund programs.
o Coordination among Federal Agencies. Some legislation is
very specific about establishing coordination among different
Federal agencies. The Clean Water Act and Federal Insecti-
cide, Fungicide, and Rodenticide Act state this clearly.
Other legislation, while not as specific, also requires
coordination, such as between Superfund and the Centers
for Disease Control. Tn qeneral/ Federal monitorinq is
not well coordinated despite significant potential benefits.
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-6-
o Research and Development Support. Each program office will
need to identify the research support it will need from
ORD. ORD should address analytical methods development,
development and distribution of quality control samples,
development of standard reference materials through the
National Bureau of Standards, development of anticipatory
monitoring networks, and monitoring for developing models
as well as other areas.
o Technical Assistance to the States. What technical assis-
tance is needed by the States in order to help ensure that
programs can be carried out?
- Lab support for the more difficult samples
- Training
- Quality control assistance
o EPA Regional Labs and Field Support. What lab and field
support do the Regions need to provide to carry out the
monitoring objectives? This support should be stated
specifically enough to be used in planning equipment
purchases and staffing.
o Contract Support. The contract support that is planned
to support monitoring should be described, including the
provisions for ensuring the quality control of the data.
SECTION 6; IDENTIFY TECHNICAL BARRIERS, ISSUES, AND OPPORTUNITIES
Many monitoring efforts can be envisioned that can not be
readily implemented due to lack of appropriate analytical pro-
cedures or other technical limitations. Also, opportunities may
exist for collecting data more directly related to a program's
needs by developing or incorporating new techniques.
This section should clearly identify any barriers, issues,
and opportunities so that they can be dealt with as systematically
as possible.
SECTION 7; CLARIFY THE RESPECTIVE RESPONSIBILITIES OF VARIOUS
HEADQUARTERS OFFICES, THE REGIONS, AND STATE AND INCLUDING
LOCAL PROGRAMS
It will become increasingly important to clarify the respective
roles and responsibilities of EPA Headquarters, Regional Offices,
and State and local agencies. This will be particularly important
for State and local agencies, since many States and communities
have multiple agencies responsible for EPA monitoring, which can
further complicate coordination.
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SECTION 8; IDENTIFY DATA PROCESSING AND DATA ANALYSIS TASKS
In order to ensure that the monitoring data collected are
used most effectively, programs should develop a strategy for
using environmental data and explain how data will be stored
and made accessible to users, and how such data will ultimately
influence program management.
Storage Systems
o Programs should describe existing and planned storage
systems for environmental data, including current
problems.
- What system will be used to store data from each
monitoring activity or network?
- Who will input the data and how often will this be
done?
- What problems have there been?
Processing and Analysis
o Programs should describe current and needed data processing
and data analysis capability.
- What types of analyses are and will be conducted with
the data? Who will carry out the analyses and how often?
How will data be made accessible and to whom?
How compatible are systems within a program? With the
systems of other programs?
Program Management Support
o Programs should explain how the data supports program
management.
How will the results of analyses be used?
- What types of reports will result from the analyses?
For whom are they prepared?
Coordination of Activities
o Where programs have identified potential and existing
multiprogram use of monitoring data, the strategy
should describe how data storage, retrieval, and analysis
will be coordinated to support multiprogram application.
-------
-8-
SECTION 9; PROVIDE A SCHEDULE FOR IMPLEMENTATION
The strategy should be written specifically enough so that
once Sections 1 through 4 have been completed, milestones can be.
identified and included in the Strategy. Some of the milestones
may relate to developing networks, some to completing final products,
and some to assessing compliance of a certain class of sources.
Some of the final products may be more than a year in the future;
interim milestones should be included.
APPENDIX; COST AND OTHER RELEVANT RESOURCE ISSUES
For information to be available in development of
the FY 1986 Agency budget, programs should include in a separate
section (not for Agency-wide distribution) a more detailed presen-
tation of their resource needs. This section should elaborate
on the costs described in Section 2, and discuss costs of moni-
toring activities and relative priorities. Ideally, costs should
be described in terms of funding, positions, extramural funding,
and State grant funding. The costs should be identified in terms
of planning, field efforts and sampling, laboratory support, data
handling, quality assurance, data analysis, and data interpretation.
(Guidance for this appendix needs to be developed with the
Comptroller's Office.)
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FY185-86 OUTREACH STRATEGY
OFFICE OF PUBLIC AFFAIRS
INTRODUCTION
The need for active public involvement in the Agency's programs has long
been recognized. Points of access into the agency's decision-making
process are numerous and well known. As a result, the agency's various
constituent publics have been able to positively improve the agency's
policy and program initiatives.
This strategy addresses the need for the Region to be proactive in
informing and educating the public about itself — our mission, goals and
objectives, as well as the limitations under which we must work. There
has not been a coordinated, comprehensive attempt to target our outreach
efforts in such a way as to maximize the exposure of the Region's spokes-
persons.
The outreach strategy seeks to identify, in a coherent and coordinated
fashion, opportunities to explain the agency's programs and the rationale
which underline them. The overall goal is to create a broad based understanding
of the agency's mission.
The strategy is proactive. We cannot simply wait for opportunities to
come to us. We must identify which constituents we want to speak to and
identify the most advantageous opportunities to do so. We must then
actively promote our participation. In targeting constituents for outreach,
we must be careful not to overlook any our various publics. We will consider
all of our constituents,' but will direct our efforts toward areas of particular
importance based on Agency and Regional priorities and needs.
While this "Outreach Strategy" has been developed by the Region's Office of
Public Affairs (OPA), its success is dependent on the commitment of the
Region as a whole to keep the public informed about and involved in our
activities.
It should also be recognized that Region V programs conduct public outreach
efforts which are not addressed in this Strategy. The Strategy presents
three aspects of outreach for increased emphasis over the next year and a
half; it is not meant to be all inclusive.
Time Frame. The strategy's planning and implementation time frame goes
from March 1, 1985 to October 1, 1986.
The complexities of the outreach process - including contacts, scheduling,
and the like, requires a time line which stretches beyond the current
Fiscal Year. This is dictated more by the olanning horizons necessary to
impact the activities of targeted constitutent groups than ay constraints
on our own activities.
-------
DEFINITION OF THE STRATEGY
The Outreach Strategy has three major components each involving a number of
activities: Press Outreach, RA/DRA Outreach, and Program Specific Outreach.
I. PRESS OUTREACH.
Goal: To increase opportunities to better acquaint the press with the Agency's
roles and activities.
Press releases, press inquiries, interviews, story background, and briefing
comprise the normal press/EPA interaction. However, beyond these routine
activities, Region V will notify editors/reporters in advance of the selected
visits of the RA, ORA, or Division/Office Directors in their area. The purpose
of the notification is to allow local media representatives to request and
schedule interviews/background briefings with top EPA managers. It is not a
process which attempts to manufacture news or to set up pointless briefings.
It is a process designed to increase opportunities for local media to meet with
EPA officials.
Recognizing that it is not always practical (or desirable) to be available to
the press, the RA/DRA and Division/Office Directors will select which trips
from their schedule travel they wish to flag for "Outreach". In order to
give advance notice to the media, OPA must be informed about planned speaking
engagements as early as possible. Programs should routinely inform OPA of
planned speaking engagements. OPA will develop a speaking calendar which
will be continuously updated and "forwarded to Headquarters for inclusion in
their speakers' calendar.
Media sources will be notified of selected scheduled speaking engagements for
the RA, DRA, and Division/Office Directors and sent information packets which
will include: The name of the speaker, the date, place and time of the speech,
the name of the groups being addressed, the speech topics, and if possible, a
speech abstract. (For this to work, it is important that the OPA media
listing update be completed and on-line.)
Once committing to an "Outreach" visit, travelers must be prepared to factor
in the additional time necessary to meet with media representatives. OPA
will inform travelers of any intended press coverage learned from media
contacts and any other "Hot Issues" in the vicinity. Travelers should be
prepared to de-brief upon return. Issues which may be raised outside the
program area of the traveler need to be relayed to the proper program person
for response. OPA will contact programs after "outreach" visits to learn about
results.
II. RA/DRA OUTREACH.
Goal: To select and schedule in advance the RA/DRA "Outreach" efforts so
that speaking engagements are targeted toward the midwest/national groups
most important to the Agency's success.
;jiven both the 3A's and DRA's stature dnd limitations on time, it is
imperative that speaking forums selected oe the most visiole, newsworthy,
and policy focused. In addition, the RA and DRA should reach the widest
possible audiences per venture.
-------
In order to accomplish these objectives OPA will identify potentially
important groups (business/industry, politicial/governmental, environmental)
and their representative associations, including regional chapters. OPA
will obtain from the association representatives, meeting calendars and/
or meeting planning schedules. In addition, OPA will request from EPA-Head-
quarters National meeting calendars in order to identify national meetings
occurring in the Region.
Using the combined meeting calendars, OPA, in consultation with the RA and
ORA, will identify approximately 10 to 20 targeted speaking engagements
for both the RA & ORA over a 12 month period. Selecting targeted groups
will be coordinate with senior managers, when appropriate. Efforts will
be focussed on areas important to Agency/ Regional priorities and needs.
Travel and schedule limitations will, of course, have to be considered.
OPA will contact the targeted meeting representatives and actively promote
the participation of the RA/DRA. Appropriate programs will be notified
when speech arrangements are confirmed (e.g., APCA - AMD). Speech
preparation will be coordinated with specific programs when needed.
A second component of the RA/ORA outreach strategies involves contacting
and briefing state elected officials. It is more and more important that
State elected officials understand their role in the State/Federal partner-
ship. These efforts could be particularly important for programs where
either State or Federal dollars are diminishing, current regulatory
protection is inadequate, or State authorization is an issue.
^••s
Working with State agency personel, OPA will schedule a series of briefings
for — state legislative (e.g. environmental committee members) and
executive personnel. These efforts will be State specific. Potential
visits, presentation topics, and strategies will be carefully considered
and fully coordinated with Region V program and State management. In
addition, the the briefing visit should include a courtesy call to the
Governor.
The briefings are not intended to be a major road show. They are a per-
sonal briefing by the RA/DRA for legislative personnel.
III. PROGRAM SPECIFIC OUTREACH.
Goal: To provide programs with specific "Outreach" services that reflect
individual needs and priorities.
Each year, OPA will consult with each of the Division/Office Directors on
their communications and outreach needs. These consultations should be
completed in time to be included in OPA workplanning. (For this year,
program consultations have been completed and workplans revised, accordingly.)
Tailored "outreach" efforts can include: special fact sheets, brochures,
public workshops/meetings preparation, magazine/journal articles, etc.
-------
ASSUMPTIONS
A primary assumption is that public "outreach" is an important and significant
responsibility for the Region's top managers. This is reflected in the
RA/DRA's priorities for FY 86, as well as in the individual requirements of our
various environmental laws and programs. Successful implementation of the
"Outreach Strategy" is contingent upon support and commitment from the Region's
senior managers to keep the public involved and informed in the Agency business.
However, "outreach" implementation will involve resources costs - sufficient time
and travel money must be available. Any future severe travel cuts could diminish
"outreach" efforts. Additionally, unforeseen program crises may devert managers
attention away from "outreach" plans.
FOLLOWTHROUGH
OPA will be charged with tracking and reporting success on all of our "outreach"
efforts. Adjustments and revisions may be called for as "outreach" results
are determined or as assumptions changes. Major strategy changes will be coor-
dinated with top management before they are finalized.
-------
"OUTREACH" IMPLEMENTATION PLAN AMD SCHEDULE
I. Press Outreach
A. Programs should routirrl;' i'lforn OPA of accepted speaking invitations.
At the end of each quarter (month), OPA will distribute a "draft"
speakers calendar for verification by Division/Office Directors.
OPA will include known presentations on the calendar; and, ask for
changes and additions to the calendar and selection of which speeches
can be covered by the press. OPA will circulate a final Region V
speakers calendar the first week of each quarter (month).*
B. OPA will notify media sources of selected, upcoming speaking engagements
weeks in advance of the visit. Information packets will also be
distributed to the media at that time.
C. OPA will contact Division/Office Directors and the ORA within one week
after "outreach" visits to learn about results.
D. OPA will report on "outreach" visits at each quarterly DRA update.
E. OPA will evaluate the "Press Outreach" program at six months (September,
1985) and make recommendations to senior staff.
* Speaking calendar will be distributed to all Directors and the ORA so that
other programs may inform speakers of "hot issues" in the vicinity of
schedule presentations.
II. RA/DRA Outreach.
A. OPA to identify potential target groups and obtain meeting calendars for
1985 and 1986. (end of April)
B. OPA presents possibilities to the RA and DRA. Programs are contacted,
if appropriate. ORA/OPA make draft choices.
C. OPA contacts groups notifying them of the availability of the RA/DRA
for presentations, (end of May)
D. Speaking invitations are confirmed and a RA/DRA speaking calendar is
prepared and circulated to Region V divisions/offices and Headquarters.
(end of 3rd quarter)
E. RA/DRA speaking calendar is updated.
Note: Throughout the year, programs should feel free to suggest to OPA
possibilities for RA/DRA "outreach" that would help their programs.
-------
"Outreach Implementation"
page 2
III. State Legislative Outreach.
A. OPA will survey the ORA and the programs for potential legislative
outreach topics in July and early August. Possibilities will be
presented to the ORA by the end of August.
B. "Legislative Outreach" will be coordinated with programs and State
personnel during early Septemeber so as to avoid end-of-year
crunch but to tie to RA/DRA State "close out" meetings.
C. OPA will prepare draft "Legislative Outreach" presentation(s) during
the end of September.
D. "Legislative Outreach" visits will take place at same time as State
close-out meetings.
-------
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III. GUIDANCE
A. FEDERAL FACILITIES PROGRAM (Administrator's Priority No. 20)
1. FY 1985 Guidance
Initiatives within the Federal facilities program in FY 85 are designed
to bring Federal facilities into compliance with environmental laws and
regulations in the most cost-effective and timely manner possible. During
1985, emphasis will be placed on obtaining accurate information relative to
compliance status of Federal facilities, returning facilities to compliance,
and initiating programs to prevent Federal facilities from falling into
noncompliance. Emphasis will also be placed on developing approved self-
conitoring and environmental auditing programs within Federal agencies, so
that scarce EPA resources dedicated to Federal facilities can be utilized on
programs aimed at preventing pollution. OFA will coordinate the efforts of
various Headquarters and Regional offices to ensure control of air and water
pollution and hazardous wastes at Federal facilities. Because the Federal
facilitiss program is a. multimedia program which crosses EPA organizational
lines and draws on resources from many sources, its success depends upon the
cooperation of the many different program offices. The Regional Federal
facilities coordinator should be identified as the focal point and responsible
party in the Region for overall management of the program. It is essential
that a credible Federal facilities program be developed to demons, I rate the
commitment and capability for achieving the stated goals of EPA's laws and
regulations throughout the Federal system.
Priority Activities
(1) Increase Technical Assistance to Federal Facilities. In recent
years, EPA has developed a number of new programs in all media with many new
regulations, criteria and standards. The large numbers of regulations and
their complexity have frequently left Federal facility managers and their
environmental coordinators unclear as to what specific actions they need to
take, to comply with the new rules. Because of inherent delays in the Federal
program and budgeting system, installation managers must act: quickly to plan
for new environmental controls, or they most certainly will be unable to
budget, design and contract facilities rapidly enough to get into compliance
by effective dates of regulations. In FY 85 EPA Regional personnel involved
with compliance matters at Federal facilities will become more familiar with
..the significant Federal facilities:* in their Region and provide advice on best
techniques and methods available for pollution abatement including alternative
and innovative methods and techniques.
(2) Increase Number of Inspections at Federal Facilities. Compliance j
inspections at Federal facilities are the responsibility of the media program
offices and are conducted by Regional media and state personnel in delegated
States in accordance with the general guidance of those programs and the
supplemental guidance in this section.
Effective compliance monitoring systems are an essential first element in
improving Federal facilities compliance. The current inventory of all Federal
facilities subject to pollution control requirements of each medium will be
updated. In FY 1985 focus will be on obtaining better information relative to
the compliance status of Federal facilities.
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With better information on compliance, inspections of Federal facilities
can be better focused. The compliance status of each facility will be -
verified by on-site inspections and/or reviews of self-monitoring reports.
Inspections will be neformed at major sources of pollutants at least once a
year. Significant minor sources** will be conicored through inspections, at
least once every ^wo years. All other sources will be monitored through the
review of self-monitoring, reports and through inspections when a violation is
suspected. (PCB compliance monitoring inspections will be conducted as neces-
sary to monitor compliance schedules described in Federal facility compliance
* Significant Federal facilities are facilities classified as major by at
least one media program plus facilities identified as significant minors by
the Regional Federal facilities coordinator working cooperatively with
media program representatives.
** Significant minor Federal facilities not meeting criteria as major, but are
designated by their Regional Federal facilities coordinator (working
cooperatively with media program representatives) because of the unique
character of the facility, and/or it produces particularly hazardous
pollutants, and/or its chronic compliance problems. Limited to no more
than 10% of minor facilities.
(6) Increase Assistance to Federal Facilities to Prevent Them From
Falling Into Non-Corapliance With RGRA Regulations. The National Hazardous
Waste Management Program at Federal facilities will continue to be a top
priority in FY 85. In addition to normal budget and compliance monitoring
! efforts, priority emphasis will be placed on: conducting inspections at all
' groundwater monitoring facilities and initiation of appropriate compliance
', agreements; coordination with Federal facility personnel on ragional schedules
i for calling in Part 3's to permit these facilities to develop an in-house
j capability or hire a contractor to prepare the application; and coordination
; with DOD in their program to locate and construct 172 hazardous waste con-
I forming storage sites at Army, Navy, Air Force and Defense Logistics Agency
installations; coordination with DOD in their Research and Development effort
\ to develop technical data relating to environmental effects of open burning/
$ open detonation of unusable munitions.
(7) Emphasize Development and Implementation of Environmental Auditing
Programs by Federal Agencies. Environmental self-auditing is a technique
which offers benefits to both EPA as well as the regulated Federal agency.
A comprehensive auditing program assures the Federal manager that he is in
compliance with environmental regulations. EPA compliance personnel can then
concentrate their scarce monitoring resources in other problem areas where
such programs have not bean implemented. During FY 1985, OFA will initiate a
strategy to develop environmental auditing programs at as many Federal
1 agencies and installations as possible. The first will be a PCB program at
I DOD installations. Headquarters will provide substantive support for Regional
environmental auditing workshops.
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2. FY 1986 Guidance
In FY 86 Che Federal facilities program will emphasize prevention through
specific technical advice and assistance, site visits, office consultations,
meetings and.workshops. While emphasis on proper design and construction of
control facilities will continue, greater emphasis must beplaced on correction
operation and maintenance problems at facilities.
Inspections will be increased at significant minor facilities in order to
assure that the most environmentally important Federal facilities are being
operated in compliance with all environmental regulations.
In FY 86, Federal agencies will have, to a large extent, completed the
identification phase of their CERCLA program. EPA emphasis will shift to
reviewing Federal Agency progress in assessing those sites previously identi-
fied and closely reviewing their proposed remedial actions.
Federal agency RCRA programs will also be in midstream. Hazardous waste
conforming storage sites will be under construction. Many facilities will be
permitted but many will remain in interim status. Closure of sources of
pollution including surface impoundments will require close EPA attention.
Detailed guidance will be needed to assist Regional perrnif writers in permit-
ting DOD open burning/open detonation sites.
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RECRUITMENT METHODS
I. Direct Hire Authority.
A. Allows the use of streamlined examining and hiring procedures that
enables the Agency to make offers of employment to eligible candidates.
The occupation applicable to Direct Hiring Authority for Region V is:
Environmental Engineers, GS-819-5/7
B. Recruitment under Schedule B/PAC Authority.
Occuptions covered:
Environmental Protection Specialist, GS-028-5/7
Management Analyst, GS-343-5/7
Program Analyst, GS-345-5/7
Budget Analyst, GS-560-5/7
Public Information Specialist, GS-1035-5/7
This Authority expires September 30, 1985. Announcement must be
posted. Eligible applicants on OPM's Displaced Employee and Interagency
Placement Assistance Program must be given priority consideration.
C. Delegated Examining Authority.
Environmental Protection Specialist, GS-028-9 thru 15
Since U.S. EPA hires the vast majority of Environmental Protection
Specialists, the Office of Personnel Management has delegated
examining authority to Regional Personnel Offices. This means we
do OPM's work but hopefully faster. However, all laws and procedures
such as Veteran's preference, rating and ranking of eligibles, and
the requirement to select from among the top 3 interested and
available eligibles must be adhered to.
Method
Personnel recruits these positions through posted vacancy announcements.
DOD's can help find candidates; but Personnel (only) decides eligibility
and grade.
D. Temporary Appointments NTE 1 year.
Under delegated authority, Personnel can make outside-the-register appoint-
ments of 1 year or less to positions at GS-12 and below. We also have the
authority to extend these appointments for up to an additional 36 months
in 12 months increments. Extensions may be made only when the following
conditions exist:
The original temporary appointment was made in good faith;
the extension is required to complete the work in which the temporary
appointee is engaged;
the extension is not so long that in the interest of the competitive
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system a career or career-conditional appointment would be preferable;
and the position is not continuing.
Method
A general Notice listing vacacies has to be sent to Job Information
Center as well as the State employment service. Applications are
accepted, rated for minimum qualifications and referred to supervisors
in ranking order.
Appointees under this authority must meet the qualification standards for
the positions including written tests if appropriate.
Appointees must also compete in an open competitive examination
to receive consideration for career-conditional appointments.
II. Additional Recruitment Methods
A. 1040 hour appointments.
These appointments are filled by college students pursuing degrees/courses
that are directly related to the field in which they may be employed.
Examples are:
Engineering Technician
Accounting Technician
Environmental Protection Assistant
Computer Technician
Program Analyst
These students can be recruited from any of the colleges within our commut-
ing area. The appointments are terminated once the student works 1040
hours, or the student ceases to be enrolled in school, whichever comes
first.
Method
Divisions and Offices may work directly with schools to obtain candidates
and name requests. Prior to this, the divison should have classified
PD's, and make no official commitment until designee's eligibility and
grade are determined by Personnel.
B. Student Aide Appointments (non-ceiling positions)
Filled by students appointed under the Stay-in-School Program. Students
may be appointed if they need the earnings from this employment to
continue in school or if they are mentally retarded or severely physically
handicapped, provided that the following conditions are met:
(1) Appointees are enrolled in secondary school or other appropriate
school for mentally retarded students.
(2) Employment does not exceed 20 hours per week, except students may
work full-time whenever their school is officially closed and during
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any vacation period.
(3) Appointees must meet the economic criteria prescribed by 0PM,
EXCEPT that this does not apply to the mentally retarded or severely
physically handicapped students.
(4) Student Aides are employed to perform duties such as - xeroxing,
simple filing, typing envelopes, labels, answering of phones. Because
student aides are paid minimum wages they are not expected to perform
duties comparable to our clerk-typists.
Method
Students are recruited by Personnel from any Chicago High School,
College, or specially designated schools for the mentally or physically
handicapped. Potential candidates are sent to division for selection.
C. Summer Employment
All applications for summer employment must be received by April 15th of
each year. Applicants must be at least 18 years of age, or at least 16
years of age and a high school graduate at the time of employment. Most
of the jobs also require education or experience. The following table
shows the amount of education or experience generally required for
eligibility at each grade level:
GS-2 High School graduation
GS-3 1 year college or 1 year experience
GS-4 2 years college or 2 years experience
To be considered for summer positions in grades GS-5 and above applicants
must meet the following educational requirements.
GS-5 4 years college
GS-7 1 year graduate work
GS-9 Masters degree or 2 years graduate work
All recruitment actions for summer employment must be accompanied by
classified position descriptions. Personnel rates and ranks applicants
and depending on Division/Office needs for summer employment sends
listings of eligible candidates to the programs.
D. Co-Op Appointments - OPFT Appointment
Cooperative education provides one method for strengthening the career
service in professional, administrative and technical occupations. By
providing students with study-related work experience before graduation,
we help to create a more enlightened and work oriented labor base for
entry level positions which could not be fully realized except through a
program like this. The Co-Op program gives us another dimension in
recruiting, including an opportunity to help us in meeting our affirmative
action goals.
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Method
Candidates can be in any professional series. Personnel maintains a
listing of schools with which EPA has agreements; we can form agreements
with virtually any accredited school. Programs/divisions should approach
this like the 1040 hour appointments.
Eligibility for the Program
A student must:
1. Be actually in attendance at a qualifying institution on a substantially
full-time basis.
2. Be enrolled in the institution's cooperative education curriculum.
3. Be recommended by the appropriate staff of the educational institution.
4. Meet citizenship requirement.
5. Maintain at least a 2.0 overall scholastic average on a 4.0 scale or
the equivalent and an average grade of C.
Selection
1. Students are not required to meet any economic criteria.
2. Supervisors have responsibility for selection of students recommended by
the colleges.
Appointment
1. All Co-Op students are given excepted conditional appointments.
2. All Co-Op appointments can remain in effect for up to 120 days after
the student graduates.
3. Student positions in the Co-Op program provide for an arranged schedule
of attendance at an institution combined with at least 26 weeks or 1040
hours of study-related work in a Federal Agency. The combination of
work and study together must satisfy the requirements for a bachelors
degree and must provide the experience necessary for a career or
career-conditional appointment in the Federal service.
Responsibilities
Managers/Supervisors should:
1. Provide supervisory guidance and challenge as well as technical advice
to participating students.
2. Plan the work so as to provide progressively more challenging work
assignments closely related to the academic goals of the student trainee
and prepare him/her for a related career field. This can be accomplished
-------
by establishing a comprehensive on-the-job training schedule for the
student.
3. Evaluate the student in writing at the end of a trial period.
4. Make every effort to convert eligible students upon graduation to
permanent positions.
EPA Policy Guidelines
1. Program Design and Scheduling Proposed work schedules in the EPA Co-Op
program must be full-time corresponding with or approximating, semesters,
trimesters, or quarters with interspersing periods of study, whenever
possible. Part-Time Co-Ops are not permitted. In addition:
a. Supervisors must prepare work schedules which assure that the student
will have the required hours and periods of employment necessary for
non-competitive appointment upon graduation.
b. Supervisors are encouraged to make arrangements whereby two or more
students occupy a single position, alternating work and study periods.
Below is a listing of schools that have participated in Region V's Co-Op
program:
Chicago State University, Chicago, IL
Grambling State University, Grambling, LA
Illinois Institute of Technology, Chicago, IL
North Carolina State University, Raleigh, NC
Northwestern University, Evanston, IL
Purdue University, West Lafayette, IN
University of Illinois, Chicago-Circle & Urbana-Champaign, IL
University of Michigan, Ann Arbor, MI
Veterans Readjustment Act Appointment (VRA)
A veterans readjustment appointment is a non-competitive appointment which
leads to competitive status and career or career-conditional tenure after
satisfactory completion of service and education or training.
Basic Eligibility
(1) Must be a veteran of the Vietnam Area (period beginning August 5,
1964 and ending May 7, 1975).
(2) Must be a United States Citizen.
(3) Nondisabled veterans must have completed no more than 14 years of
education. (2 years of education above high school or the
equivalent). However, this educational requirement is waived for
compensably disabled veterans and veterans discharged because of
service connected disabilities.
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Appointment Authority
Veterans can be appointed to full-time or part-time positions at GS-7 or
below. These appointments are subject to the following conditions:
a. For jobs at grades 1,2, and 3 the veteran's military service meets
all qualification requirements (including written tests) if the
agency believes the veteran can do the job.
For jobs at grade 4 through 7 the veteran must meet the minimum quali-
fications requirements. Written tests may be waived.
b. The veteran must agree to participate in a program of education and
training.
Education and Training Requirements
Before making a VRA appointment agencies must assure themselves that the
veteran will undertake a suitable program of education or training while
serving under the appointment.
Developmental programs should be prepared jointly by the veteran and
employing agency.
Developmental activities may include:
-planned on-the-job training
-rotational job assignments
-off-job classroom training
-remedial education
-vocational education
-scientific or technical education
-high school or high school equivalency; and/or
-college education
Conditions of Employment
VRA appointments are "excepted appointments" for a period of two years
and they can be converted to career conditional after the two years
provided the veteran's performance has been satisfactory.
Method
If you feel you have a position ideally suited for someone under the
VRA appointment, call us in Personnel (353-2026) and we will contact
the local Veterans Administration Office, or State Employment Service
for eligible applicants.
F. Employment of the Handicapped
Many physically handicapped people who are unable to obtain appointments
even with examination modification can profit greatly from an opportunity
-------
to demonstrate what they can do under a trial appointment. For these
handicapped persons such an appointment can overcome employer reluctance
to hire them on a regular basis for fear they will not be able to
perform on the job efficiently or safely, or that they will not fit in
with and be accepted by the workforce. For this purpose, 0PM has made
available a temporary not to exceed 700-hour trial appointment authority
for handicapped applicants. The agency makes no commitment for permanent
employment; however, the temporary limited appointment is usually long
enough (approximately four months) for the severely handicapped person
to establish their job readiness. Eligibility is determined by one of
two ways:
(1) Certification from either Veterans Administration or a State
Vocational Rehabilitation Agency.
(2) The agency may apply 0PM's minimum qualifications standards for
the position concerned including administering a written test,
if required.
Candidates can be in any job series. Applicants may be non-competitively
converted to competitive status after two years of successful performance.
Conversion to career or career conditional appointment is dependent on
determining the length of creditable service.
Method
Applicants can be recruited from the Veterans Administration, State
Vocational Rehabilitation Agency, Rehabilitation Institute or any of the
many schools servicing the handicapped.
There are other appointing authorities and ways designed to facilitate
the hiring of handicapped individuals. The above information is an
overview to acquaint supervisors with an alternative recruitment mechanism.
The personnel staffing specialists can provide additional information
to supervisors who are looking at their projected affirmative action
goals.
-------
Enclosure A
-DRAFT-
February 17, 1984
HUMAN RESOURCE MANAGEMENT:
A OSNCEPT FOR EPA
Recent studies have focused on the need to strengthen EPA's management
of human resources, i.e., how well Agency managers plan for and utilize their
people. The consensus seems clear: The Agency, as a whole, must develop
better strategies for: (1) placing the right people in the right jobs;
(2) capitalizing on the creativity/ enthusiasm, and competence of the career
workforce; and (3 ) reducing any unnecessary and artificial barriers to high
quality performance. To address these problems, the Agency is planning to
create an Office of Human Resources Management.
The term "Human Resources Management" (HRM), means a comprehensive,
systematic approach to assist the Agency in accomplishing its goals through
workforce planning, policy development, and program evaluation aimed at the
best use of the EPA workforce as an organized body and as individual emplovees
current and future. &g9SBB&SS&6S&KIE&^^
__ ,. .^^^M^yiSS^ennefelvwitK^
As managers~"plah programs and allocate resources,
they must likewise deal with the issues of what kinds of people will be needed
to do the job.
Fundamental to an effective, results-oriented program are several key
principles :
1. A motivated workforce is indispensable to the achievement of Agency
goals.
The Agency's employees are its most valuable asset. They are not
only vital to EPA's mission; they are important as people.
2. The Agency must provide incentives for people to want a career (rather
than a job) at EPA.
The proper tangible and intangible rewards and recognition should
create a greater "corporate" identity, and encourage more employees
to make a career commitment to EPA.
3 . Workforce planning and all related personnel management programs
should be an integral part of EPA's program planning process.
An HRM program should consist of a series of building blocks in a
logical progression keyed appropriately to the Agency's planning.
-------
Enclosure B
MAJOR NEEDS TO BE ADDRESSED BY
HUMAN RESOURCES MANAGEMENT
1. Skill mix.
Skill mix problems are caused by changing programs, resource management
by attrition and "last-in first-out" rules, lack of available skills in
'\ some areas, underutilization in others, and the inability to compete in
A the marketplace. Forecasting human resource requirements by projecting
v ^ various indicators of foreseeable change in technology, program plans
/y" and economic trends, is needed.
2. Career development.
Employees need training (largely technical), management development (for
managers-to-be and managers), and executive development (for executive
candidatesandupper management). J^3S^3SB^i^gy4sS^ff^yS?^«giS^^iippjjf
Managers are expected to hire and grow talent yet we do not hold them
accountable for it and the system does not reward the manager or the
employee for career development.
Managers have not been trained to complete individual development plans
and often do not know how to develop employees.
Lack of cross-fertilization among programs, between geographic locations,
and between Headquarters, regions and states, accentuates program conflict.
Identification and development of replacement candidates.
A vacancy in a key job generally leaves a void in an operation.
Managers want to promote from within but no one is "ready" or will move. •
The Agency is unable to identify and shift people quickly to meet shifts
in needs.
Workplace productivity.
Productivity is measured by program outputs with little concern for inputs,
particularly human development, motivation, recognition, ccmmuniction,
decisionmakirsg, planning, organization and control, delegation and work
facilitation.
-------
Seme employees and professions are underutilized. We need to obtain an
accurate understanding of human resource capabilities available within
the organization, and of hew well these capabilities are currently being
utilized.
We need to be able to predict the consequences on morale as well as the
basic configuration of human resources that would probably result from
specified changes in staffing strategies or changes in other personnel
policies and practices.
5. Evaluation.
The organization needs to have a variety of mechanisms to examine itself
so that it can make improvements where they are needed.
6. Performance.
The employee and manager must trust one another as they are mutually de-
pendent upon one another for their individual success. The organization
must support this through performance agreements, frequent evaluation,
individual development plans and the existence of training and develop-
ment programs.
The systems tend to foster adversarial, instead of cooperative, supportive,
relationships between managers and employees. Our appraisal systems are
perceived to be closely tied to pay instead of performance.
There are no institutionalized methods for managers to get feedback from
their subordinates on their performance.
7. Continuity of Leadership.
There is little continuity of leadership from administration to adminis-
tration in goals. There are no well-known, clearly articulated basic
beliefs that transcend changes in policy.
-------
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NON-MERIT PAY EMPLOYEES.
-------
Summary of Human Resource Management Interests
In connection with previously scheduled visits, Nick Bollo, Regional
Personnel Officer, surveyed Division Chiefs to determine their views of
Human Resource Management. The HRM concept received broad but cautious
support from Division Chiefs. Several chiefs expressed a concern that
the Personnel Branch should not embark on projects which would detract
from or slow down the regular basic personnel functions. The following
are those HRM initiatives which were suggested by Senior Staff.
Rotational assignments both within and between Divisions was the consensus
item of interest. Rotational assignments below the SES were more favored
than SES rotations. The minimum period of time seemed to be six months
to a year. Some jobs were viewed as likely ones to be identified for
rotational assignments. The analyst positions in the Planning and Analysis
Branch of PMD were mentioned by several.
In connection with positions identified as target jobs for rotational
assignments, Division Chiefs suggested establishing a Regionwide assessment
and selection process for "high performers" or high potential employees.
Those selected under that process would be placed in the next developmental
(or rotational) position. In order to be most successful it was felt
that this program would have to include candidates and positions from
more than one Division.
The internal rotation of supervisors within one Divsion was mentioned but
such an initiative could be taken unilaterally without the involvement of
other Divisions.
The present state of the IPA Program was mentioned. For the program to
remain viable placements into it must be seen as positive. Also, some
interest was shown in increasing the use of IPA to bring non-Federal
employees into Region V.
Finally, broad training applicable to most employees was suggested.
These could include skill courses such as writing, negotiation, etc., or
knowledge courses such as EPA Congressional Briefing. Broad attendance
at certain seminars and symposia was also suggested both for its educational
value and as an acknowledgement of accomplishments.
-------
PERFORMANCE MANA3EMENT SYSTEM (PMS) SURVEY
Overview and Recommendations
In November 1984, EPA surveyed 6,000 employees to see how effective the
Agency's performance appraisal process is as a management tool. Over
3,000 employees responded to the survey. Examination of demographic
characteristics (grade, location, pay plan) showed the respondents to be
representative of the EPA population as a whole.
MAJOR FINDINGS OF THE PMS SURVEY
Most of the Agency is following the PMS procedures, but following the
procedures doesn't necessarily mean that PMS is helping employees improve
their performance or providing managers with an objective means of
evaluating performance.
The vast majority (90 percent or more) of all respondents:
o Have written performance agreements,
o Signed their agreements (over half signed them within 30 days of the
beginning of the rating period),
o Were given performance appraisals on time, and
o Completed self-appraisals.
BUT
o Only 1 out of 2 supervisors responded that PMS helped them to improve
employee performance.
o More than half of all respondents (56.6%) reported they did not
receive feedback in their appraisal that would help them improve
performance.
o 40% felt they were rated on something other than how well they
performed the work in their performance agreements.
o More than 2 out of 3 employees felt that ratings were not given out
in a consistent or fair manner within their Office or Region.
The survey indicates that many of the reasons PMS falls short relate to
its implementation rather than the system design.
Respondents were more likely to report receiving feedback that helped them
improve performance and to report that they were rated on their performance
if their supervisor:
o Gave them suggestions for professional development or training during
the appraisal,
o Met with them routinely to discuss performance, and
o Had discussed office priorities and expectations for employee perfor-
mance before the performance agreement was signed.
-------
-2-
Most supervisors are not spending the time it takes to give employees
meaningful feedback on performance!
o Half the respondents either didn't have performance appraisal
meetings or had meetings that lasted less than 20 minutes.
o Half met to discuss performance with their supervisor once a year
or less.
o Fewer than 1.in 5 employees had supervisors who meet with
them routinely to discuss performance.
o Only 1 in 4 respondents received suggestions for training.
Employees perceived the PMS as an objective system if their agreements
were revised when priorities changed, if they had clear standards that were
used to measure performance, and if they knew their ratings were not changed
by the second level supervisor.
o Just over half the respondents (58%) felt that their standards were
clear enough to measure performance.
o The majority of employees (70%) indicated that their agreements needed
revision, yet fewer than 1 in 6 employees revised their agreements
when appropriate.
o PMS requires second level review be conducted before ratings are dis-
closed to employees, yet most respondents (70%) knew if their scores
had been changed at the second level. Employees who knew their scores
were changed perceived the PMS more negatively than employees who knew
their scores were not changed.
o Many respondents wrote voluntary comments expressing the view that
final scores reflected forced distributions or quotas, not actual
performance.
It appears from the results that some employees are not spending enough time
to make their own performance appraisal effective; others are spending more
time than is warranted. Most of the time spent is in writing the
performance agreement and doing the self-appraisal.
o The group that most often reported receiving useful feedback, and were
most likely to feel their ratings were based on performance, spent one
day on their own performance related activities.
o Nearly half the GS respondents spent less than one day on PMS
activities.
o Half the SES and GM respondents spent two days or more—about 1 in 4
spent more than 4 days.
The performance appraisal process is integrated with the Agency's program
planning process, the Strategic Planning and Management System (SPMS) at the
top levels of the organization.
o 70% of the SES reported having SPMS goals (targets) in their
performance agreements.
o Slightly more than 1 in 3 GM respondents (36%) had SPMS targets written
in their performance agreements compared to about 1 in 9 GS employees
(12%).
-------
-3-
GONCUJSIONS AND RECOMMENDATIONS
Supervisors need to talk with employees about performance throughout the .
year
The survey results make a strong statement about the necessity of
performancerelated discussions between supervisor and employee. In
discussions, employees and supervisors can reach consensus on what is to
be accomplished and how it fits with organizational priorities. The
employee can get information that will allow correction and improvement
of performance during the year. Employees who met with supervisors more
frequently than two times a year were more likely to view the system
positively, in terms of usefulness and objectivity, than those who met
less frequently.
Supervisors need to place greater emphasis on employee development and
training by careful consideration of employees' strengths and weaknesses.
Four out of five employees who received suggestions for training or
development felt their appraisal provided them with helpful information
for improving performance; without suggestions, fewer than 1 in 6 said
their feedback was helpful. To give meaningful suggestions for training
and development, managers must think carefully about employees' strengths
and shortcomings that help or prevent employees from meeting their standards.
Unfortunately, the design of PMS makes it possible for supervisors to rate
an employee solely on the outputs defined in the standards. The supervisor
does not have to discuss any of the employee's characteristcs that
influenced performance. In addition, the complicated scheme of numerical
weights and values used to derive employee scores can distract supervisors
from thinking about development. Employees' comments indicate that
manipulating weights and values assigned to standards to arrive at a
specified score creates a focus on improving scores, without attention to
performance, training or development.
Agreements should be simple and flexible enough to revise when programs
change.
As in other appraisal processes based on management by objectives, the PMS
performance agreement can be a valuable record of accomplishment, but survey
results show it is important that agreements be kept simple and flexible
enough to be useful to managers and employees and to make it easy to revise
them during the year, writing complicated agreements, designed to make it
difficult to give low ratings, can be counterproductive if agreements are
not modified easily to reflect changing program priorities.
Supervisors and employees need to work toward developing clear performance
standards.
Employees who said they were rated on their performance also said their
performance measures were clear. Clarity does not necessarily mean standards
are quantifiable—it means they are understandable.
-------
-4-
Second level reviews, based on knowledge of employee performance, should be
conducted prior to disclosing scores to employees
The credibility of PMS as an objective performance appraisal process depends
greatly on the integrity of the second level review — all changes in scores
must be based on the first hand knowledge of performance of all employees
under review — not preconceived numbers of how many employees can receive
outstanding ratings. When scores are changed in the second level, it is the
performance-based reason for the change that should be communicated to the
employee — not the fact the score was changed.
IMPACT OF THE PERFORMANCE MANAGEMENT SURVEY
Top Managers to be briefed on survey findings
The Study Group on Performance Management Improvement and OARM are
sponsoring briefings for all of the Assistant Administrators, Regional
Administrators and their staff to make them aware of the overall problems
with PMS implementation and to give them individual feedback on how their
organizations are implementing the performance appraisal process. Briefings
for other groups are being done by special request.
The Office of Administration and Resources Management (QARM) is designing
new supervisory training in performance appraisal
Conducting successful performance appraisal meetings often entails difficult
and sensitve issues. Existing training related to PMS covers the more
procedural aspects of PMS, particularly writing the performance agreement.
EPA currently has no training designed specifically for the purpose of
teaching supervisors how to conduct meaningful appraisals. All newly
appointed supervisors will be given 3 days of training emphasizing the
communication and the human relations aspects of supervision. O^RM is
investigating a variety of ways to give all supervisors at EPA the skills
necessary to appraise and develop the talent of those they supervise.
The Office of Administration is considering modifications to the PMS to
encourage greater emphasis on employee development, and more flexible
application of the system
Although much of the design of the PMS is required by law, the Office of
Administration, in conjunction with the Personnel Management Division, is
looking at modifications that would re-emphasize employee growth and
development in the context of the basic Performance Management System.
They are also considering revisions in the system that will make it easier
for supervisors and employees to apply PMS to the diverse population of
EPA employees, to develop simple, understandable performance agreements
and reduce the current emphasis on quantification.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
DATE May 6, 1985
Results of Performance Standards Review
Nicholas R. Bollo
PROM: Regional Personnel Officer
Division/Office Directors
TO:
Our office, with the assistance of supervisors and managers from throughout
the Region, conducted a review of performance standards that have been
submitted to our office. This memorandum contains the results of those
review efforts, and should be helpful in consideration of modifications- to
standards that are being contemplated in conjuction with the mid-point
review.
Our initial goal in reviewing performance standards was to conduct a 20% .
review of our current performance standards. In preparation for the review,
we found that approximately 75% of Region Y's positions are in nine different
series. For example, 671 employees occupy the following positions:
Environmental Protection Specialists, GS-028 grades 5 thru 13 - 190 employees,
Environmental Engineers, GS-819 grades 5 thru 15 - 139 employees,
Clerk Typists, GS-322 grades 2 thru 4-78 employees,
Secretaries, GS-318 grades 4 thru 8-73 employees,
Environmental Scientists, GS-1301 grades 5 thru 13-82 employees,
Attorneys, GS-905 grades 11 thru 15 - 46 employees,
Chemists, GS-1320 grades 5 thru 12 - 30 employees,
Environmental Protection Assistants, GS-029 grades 4 thru 7-23 employees,
Computer Programmers, GS-334 grades 7 thru 12-10 employees.
The remaining 25% of Region V's employees occupy positions in 62 different
classification series. We have an estimated total of 215 employees occupying
the 62 different series positions. A number of the latter group of positions
are occupied by only one or two employees in each series. However, we do
have groups of 10 or more employees in the following positions:
Clerks, GS-303 grades 4 thru 7.- 10 employees,
Program Anaylsts, GS-345 grades 9 thru 12-11 employees,
Biologists, GS-401 grades 12 and 13 - 17 employees,
Chemical Engineers, GS-893 grades 12 and 13-12 employees,
Geologists, GS-1350 grades 9 thru 12-12 employees.
Our office, as well as supervisors who were at the GS-12 grade level and
above, performed the review of the performance standards. A total of 135
performance standards were reviewed. The breakdown of performance standards
reviewed by Division and Office are as Follows:
Office of Regional Administrator - 4,
£?A FORM 1320-3 'Re/3-76)
-------
Great Lakes National Program Office - 5,
Office of Regional Counsel - 9,
Environmental Services Division - 12,
Air Management Division - 17,
Planning & Management Division - 19,
Waste Management Division - 33,
Water Division - 36.
Each reviewer was provided a copy the Performance Management System Manual
which explains the development of critical job elements and performance standards,
the requirements of which were established by the Civil Service Reform Act.
Additionally, each reviewer was provided with copies of the position
descriptions that corresponded to the performance standards that they were
assigned to review. Each reviewer examined the performance standards
against a pre-established checklist. The checklist was developed by a review
of requirements set forth in 5 C.F.R. Section 430, Chapter 430 of the Federal
Personnel Manual, and the Performance Management System Manual. Therefore,
the checklist contained elements to be examined that were required by law,
Federal Personnel regulations, and our own Personnel Management System.
The following are the results of tne review as provided by the reviewers
and consolidated by the Personnel Branch. The first element of review
dealt with critical job elements themselves. A critical job element is a
reflection of the more important duties of a position and should bare a
significant relationship to the basis or purpose of the position and to the
major goals and functions of the organization. 94% of the standards that
were reviewed had critical job elements that were considered a major
responsibility of the position. 17% of the performance standards reviewed
had at least one critical job element which did not identify the reason or
purpose of performing the major function which was being described. Our
Performance Management System Manual indicates that between 4 and 7 critical
job elements should be identified in the development of performance standards.
Our reviewers indicated only 75% of the standards reviewed had between 4 and
7 critical job elements. More standards had fewer than 4 critical job
elements than those that had more than 7.
The second part of the evaluation criteria dealt with a review of the
performance standards themselves. Performance standards are measurements
of an accomplished work objective. They must be an accurate description of
expected job performance in relation to the requirements of the position.
The reviewers indicated that only 87% of the performance standards reviewed
had a high correlation between the critical job elements, performance
standards, and the position descriptions. This percentage is low, as the
law, regulations and Performance Mananagement System Manual requires that
there be a close link between these factors. Concerning workplans, 78% of
the standards had a high correlation to organizational workplans. Additionally,
91% of the standards were considered to be understandable and simply stated.
93% of the standards reviewed measured all parts of critical job elements
that were identified.
The Performance Management System Manual indicated each level of a performance
standard should clearly state how well or how accurate (quality), how soon
or when (timeliness), ^ow Tiany or how Tiucn 'Quantity), and i-n ^hat manner
-------
each performance element is to be carried out. In reviewing the performance
standards against this criteria, it was revealed that only 50% of the
reviewers felt that the standards reflected this concept.
The reviewers felt that 36% of the standards reviewed had fully successful
levels described as truly reflective of fully successful performance. Fully
Successful performance was defined as that which can be reasonably expected
of a qualified experienced employee in completing assignments. Although
only 71% of the standards were considered to have levels of performance
within the control- of the employee, the reviewers felt that 83% of the
standards had levels that where attainable by the employee.
One of the problems noted by the review of performance standards is the
differentiation between performance levels as described in the performance
standards. Only 52% of the standards had performance levels of outstanding
which could be clearly distinguished from the fully successful performance
level. The major comments were that there was little, if any, distinction
between the way these two performance levels were written in many of the
standards. Additionally, only 63% of the standards were written so that an
unacceptable performance was clearly identified and of such a quality that a
personnel action such a removal or downgrade could be justified based on such
a level of performance.
A number of merit pay employee's performance standards were also reviewed.
One of the requirements of 5 C.F.R §540 is that merit pay performance
standards must measure a supervisor's or manager's individual performance
in relationship to organizational accomplishments. Our reviewers indicated
that 90% of the merit pay employee's standards conform to this requirement.
Additionally, 93% of the merit pay employee performance standards evaluate
the employees performance in meeting affirmative action goals and achieving
equal employment opportunity requirements to the extent that the positions
involve such responsibilities.
The Performance Management Systems Manual recommends that each standard
have a weighted factor of at least 10 points. The reviewers indicated that
only 69% of the standards reviewed met this recommendation. Most of the
problem areas involved standards that had a 5 point weight factor assigned to
them. The Performance Management Systems Manual also requires that the weighted
factors equal 100 points. 91% of the standards met that requirement i.e.,
one standard had weighted factors that equalled 140 points, the remainder
of the standards reviewed had weighted factors that were less than 100 points.
The review also indicated that only 88% of the performance standards were
properly signed and dated by the employees, their supervisors, and the
reviewer/approver official. Most of the problem areas involved a lack of
an approver signature.
The reviewers were also asked to give an overall assessment of the standards
that they were assigned to review. The choices given to the reviewers were:
Excellent, Above Average, Adequate/Average, Needs revision-can be improved,
and Poor. The reviewers indicated that 28.2% of the performance standards
reviewed were rated as either needing revision or were rated as Poor. 38.8%
were rated Adequate/Average. 26.3% of the standards were rated Above
-------
The performance standards review indicated several problem areas, the
problem most notable was the concept of how well the standards reflected
levels of performance that identified quality, quantity and timeliness
factors in the systems of measure. Although some positions do not readily
lend themselves to this type of measurement, the fact that only 50% of the
standards reviewed met the criteria clearly indicates a need for modifica-
tion of some of those standards. Another problem area dealt with the poor
distinction between the fully successful level of performance and the
outstanding level of performance as identified in performance standards.
As indicated earlier, only 52% of the standards reviewed had clear distinc-
tions between these two levels. This low rating indicates that there is a
need to review standards to assure that there are clear differences between
performance levels within the standard.
Another major problem, was the fact that only 63% of the standards were
written so that unacceptable performance could be clearly identified and
support a remedial action. This problem relates to the same concept
identified above, whereas there is a lack of clearly identified levels of
performance at 3 distinct levels.
While the review of the performance standards was not a technical or scientific
study, it does confirm our perception that performance standards could be
improved. While the information contained in this memorandum is a general
overview of the results of the study it should assist you in revisions you
are considering relating to the Mid-Year Review. We are in the process of
further analyzing the standards for each individual Division and Office,
and will distribute that information within the next week.
-------
REGION V EMPL.OVFE RATINGS
MALE / FEMALE
RANGES 10O/2Q9 3OO/349 35O/399 400'449 450/50O
MALE 9 64 12~- 131 46
FEMALE 4 55 93 93 32
MALE 2.39% 16. "37. 33.69% 34.?5% 1.2.2'.'%
>rEMAL E 1 „ 44% 19. 86% 73. 57% 3 7., 5'-'% 1 1 „ 55%
GRADE LEUEL
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23. 33% 44. !. 6%
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MINORITY CODE
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27., 45% 79,, 2.2% 25.49% 5., I
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-------
PEGfON
EMPLOYEE'S
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
DATE WAY 0 2 1985
SUBJECT: Loss of Productive Worktime Due/£o Compressed Workweek and Flexitour Programs
Nicholas R. Bollo ' //
FROM: Regional Personnel Officer
Robert Springer, Director
TO.- Planning & Management Division
On January 30, 1985, you indicated that one of the major internal control
weaknesses which Region V identified was the loss of productive worktime due to
compressed workweek and the flexitour programs. You felt that there was a need
to (1) develop a new Regional Order on each program, (2) review Division and
Office compliance with Mr. Adamkus1 memorandum of November 26, 1984, concerning
assignment of acting supervisors for early and late hours of the day, (3)
present the Senior Staff with the recommended changes and the results of our
review, and (4) issue the results.
As you may recall, only three managers responded to Mr. Adamkus' November 26,
1984, memorandum. Based on the limited number of responses, I sent a memorandum
to all Division and Office Directors on March 12, 1985, asking them to provide
me with detailed information concerning the implementation of the provision
requiring staff employees to function as acting supervisors during hours of the
extended workday when supervisors are absent.
Based on the latter memorandum, I received seven responses, five of which were
very brief and two of which gave us useful information. Attachment A is a
review of the comments submitted by the three managers who responded to the
November memorandum. Attachment B contains comments I received in conjunction
with my memorandum of March 12, 1985. Attachment C contains proposed revisions
of current policies on the alternate work schedule and compressed workweek programs
The following is an analysis of the comments and recommendations received from
both groups of managers and supervisors who responded to us.
Productivity.
Out of the ten respondents nine felt that productivity suffered as a result
of compressed workweek and alternate work schedules. The main reason cited
was the lack of supervision over the early arrivers and late departers. Of
those responding that commented on the the "acting supervisor" concept of
controlling potential abuse, none felt that it worked very well and most
felt that it was placing an undue burden upon employees when they are
expected to observe the arrivals or departures of their peers. Of the ten
managers responding, one manager abolished compressed workweek schedules
altogether, one felt that he could not abolish it because it was tantamount
to an employee benefit but decided that he will modify the core hours, and
one manager felt that there was no need to make any changes. The other
seven expressed varying degrees of dissatisfaction with the programs.
The most common problems cited by the managers are: (1) a lack of productivity
E?A FOSM 7320-6 (REV 3-7S>
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during the extended hours of the workday, and (2) coordination and scheduling
difficulties as a result of early departures and off days.
Other problems cited in administering the programs are:
V
(1) Difficulties in administration/supervision.
(2) Increased overtime (when employee works on offday).
(3) Lack of clerical support.
(4) Office coverage.
Positive Aspects.
While all but one manager expressed varying degrees of dissatisfaction with
the program, all conceded that there were at least positive perceptions, if
not positive aspects to the program, but mostly on the part of their
employees. It appeared to be a commonly held view by the responding managers
that it would be hard to abolish the programs because they are viewed by
many as "employee benefits" and therefore, quasi-sacrosanct. Most managers
cited accomodation of personal needs such as commuter schedules as the most
common positive aspect of either program. None cited increased service to
the public or increased productivity, or better job performance.
The survey conducted by one Division Director revealed interesting results.
For example, question number 5 states, "Under CWW, my immediate work unit
meets its deadlines." The responses were as follows: More frequently -
19%, No change - 78%, Less frequently - 3%. This indicates that 97% felt
that there was either no change from the past or they were meeting deadlines
more frequently. Similarly, question number 6 states, "In general, how
would you rate your units service to the States and Public since the start
of CWW?" The responses were as follows: Better - 39%, no change - 55%,
worse - 6%. The perception here is that 94% felt that there was either no
change in service or better service since the start of the Compressed
Workweek program. However, the concept that coordination is a problem is
somewhat substantiated as only 6% felt that it was enhanced while 27% felt
it was hindered. When asked if they would prefer to discontinue using the
compressed workweek 79% said "No", 21% said "Yes."
Conclusions.
Most respondents expressed varying degrees of dissatisfaction with the way
CWW and AWS programs were working in their organizations. The majority
felt that 1) there was less productivity because of less supervision, 2)
there were problems with coordination and scheduling, 3) the programs should
be modified or changed but not abolished in total, and 4) most felt that
the "acting supervisor" concept was not a workable alternative to direct
supervison for controlling abuses.
The following is a review of the recommendations for modifying the compressed
workweek and alternate work schedule programs.
Core Hours and Deviation Time.
As stated earlier, most respondents felt that, short of radical changes which
-------
would be perceived too negatively, there is room for improvement. Most
felt that improvement equated to tighter controls on core times and arrival
and departure times. The following is a commonly suggested as a core time:
9:00 a.m. to 4:00 p.m.
The following are suggested as the parameters for early arrivals and late
departers:
1) 7:00 a.m. to 5:30 p.m.
2) 7:00 a.m. to 6:00 p.m.
3) 7:30 a.m. to 5:30 p.m.
The general consensus is that the span of core hours should be made longer.
It should be noted that core hours, as established by our regulations, are
from 9:00 a.m. to 3:30 p.m. Managers also recommended that the span of
starting and ending hours should be shortened to reflect an arrival time of
7:00 a.m. or 7:30 a.m., and end at 5:30 p.m. Again, it should be noted
that the compressed workweek plan for Region V indicates that employees can
arrive as early as 6:30 a.m., and leave as late as 6:00 p.m., with supervisory
approval.
The subject of "acting supervisors" to cover the extended workday drew
considerable criticism from the respondents that addressed the subject.
While they did not recommend abolishing the concept, they did state that it
was not perceived as a good idea and many felt that it was not effective.
It should be noted that not all supervisors responded as to whether or not
they are even implementing the concept, thus, lacking the affirmation that
they are, we assume that not all offices are in compliance with the directive.
I recommend that the concept be retained with more emphasis on accountability
for actual compliance. For example, the AO's should maintain a roster of
those who are designated as "acting supervisors" for their respective
divisions. The Division Director or Office Director should certify compliance
annually or as requested.
The Alternate Work Schedules (AWS) program was authorized on July 23,
1982, for a 3 year period, under subchapter II of Chapter 61 of Title 5,
United States Code. The Office of Personnel Management (0PM) is required
to evaluate the overall program prior to the expiration of the current
statutory authority in July 1985. In order to accomplish this, they asked
us for a report on our AWS programs last September. At that time, they
wanted to find out whether there was any adverse impact that could reasonably
be attributable to the AWS programs. They cited adverse agency impact as
defined in Section 6131(b) of Title 5, U.S.C., as (1) a reduction of the
productivity of the Agency; (2) a diminished level of services furnished to
the public by the Agency; or (3) any increase in the cost of Agency operations
relating to AWS. We reported that 43% of our employees were on a compreisad
work schedule, and"32.2% were on a flexitour. uur Kegion aid not report
"•any adverse impact as a result of AWS programs. In view of the comments
received in response to the November 1984 and March 1985 memorandums, there
seems to be a perception of lost productivity, among other problems. 0PM1s
report asked a number of important questions which could serve as a focal
point for an internal review of our program. As stated in the review of
the comments in Attachment B, one manager has decided to ask for a Planning
-------
and Analyis Branch review of the program within his Division. It may be
advisable to have PAB conduct a Region-wide study to determine if the
perceived loss of productivity or service to the public actually exists
before we decide on major program changes.
The following are a list of questions that 0PM asked us concerning the AWS program:
(1) Has there been any measurable changes in agency productivity?
(2) Were services to the public enhanced, diminished or unchanged?
(3) Has there been a change in costs of agency operations?
(4) What increased costs or losses in productivity are attributable to
employees on compressed work schedules and the fact that they have more
than eight hours off on holidays?
(5) Do current statutory and regulatory provisions provide managers with
sufficient management controls to effectively manage these programs, to
prevent problems from developing, or to deal with them if they do?
(6) For each AWS program your agency has terminated, if any, specify the
reason(s) or basis for the decision to terminate?
(7) Has the agency encountered any problems terminating a program established
by a negotiated agreement?
(8) Has the agency terminated any programs in mid-contract?
(9) Has the agency encountered any problems terminating a program that was not
established under a negotiated agreement?
(10) What impact have flexible and compressed work schedules had on mass
transit facilities?
(11) How have traffic patterns been affected?
(12) Has the use of carpools increased or decreased?
(13) Has there been a change in the level of energy usasge within the
facilities of your agency?
(14) Have opportunities for full-time and part-time employment increased?
(15) Are employees more satisfied with their jobs and nonworklife?
(16) Have there been any judicial decisions or administrative decisions by
the Comptroller General, the FLRA or the FSIP affecting programs in the Agency?
(17) What statutary or regulatory changes are needed to make AWS programs
more manageable or more cost effective?
(18) What materials and/or assistance from 0PM might be helpful in the overall
-------
management of the AWS program?
Even without a review of our program by the Planning and Analysis Branch,
there are considerable changes which can be made to overcome some of the
problems identified by our managers. The core hours can be changed from
the current 9:00 a.m. to 3:30 p.m. to the suggested 9:00 a.m. to 4:00 p.m.
Additionally, the starting and ending hours can be changed from the current
6:30 a.m. to 6:00 p.m. to the suggested 7:00 a.m. to 5:30 p.m. Using the
above suggested changes, an employee on compressed workweek who arrives at
7:00 a.m. and works 9 hours and takes a 30 minute lunch can go home at 4:30
p.m. An employee on compressed workweek can come in as late as 8:00 a.m.,
work 9 hours, take a 30 minute lunch and leave at 5:30 p.m. Therefore,
using the suggested changes, a CWW employee can arrive between 7:00 a.m.
and 8:00 a.m., and still leave by 5:30 p.m.
Using the same suggested core hours and starting and ending times, an
employee who works eight hours can arrive at 7:30 a.m., work eight hours,
take a 30 minute lunch, and leave at 4:00 p.m. Those working late under
this concept can arrive as late as 9:00 a.m., work eight hours, take a 30
minute lunch, and leave by 5:30 p.m. Under the suggested changes, an 8
hour per day flexitour employee can arrive between 7:30 a.m. and 9:00 a.m.
and still comply with the 9:00 a.m. to 4:00 p.m. core hour requirement, and
can still leave by the 5:30 p.m. departure time.
The Region's written guidance on these programs is contained in Order No.
RV 3160.1 Flexible Work Schedules, dated October 1, 1976, and a memorandum
subject, "Compressed Workweek" dated October 12, 1979. It is recommended
that these documents be superceded by the proposed order contained in
Attachement C, Titled, "Alternate Work Schedules." The proposed order
combines the current flexitour and compressed workweek progam into a single
comprehensive document and updates them in accordance with changes in the Law.
Summary
As you indicated on January 30, 1985, one of the major internal control
weaknesses identified by Region V was the loss of productivity due to
compressed workweek and flexitour work schedules. Based on comments received
from Mr. Adamkus1 memorandum of November 26, 1984, and my memorandum of
March 12, 1985, these perceptions are shared by the majority of those who
chose to comment. With regard to assessing compliance with Mr. Adamkus1
memorandum's provision requiring assignment of "acting supervisors," we
detected considerable criticism of the concept and presume that it is not
being enforced unilaterally within the region, as most managers who responded
to us either did not comment on whether or not they were in compliance, or
else they expressed considerable dissatisfaction with the policy.
Concerning the results and recommended changes, it appears that there is
little support for terminating the AWS programs, yet there is considerable
support for making changes and modifications. In consonance with those
recommendations, we have drafted a proposed order which should make life
easier for most of the managers who expressed concerns to us. And finally,
there is the subject of whether or not Region V should consider a PAB study
-------
on productivity and service to the public under AWS. I recommend that the
Region hold the final decision on a Region-Wide study in obeyance until
after final legislation is enacted in July 1985, as there could be significant
changes in the law that could affect our programs. Notwithstanding the
possibility of significant legislative changes, I recommend that the Region
proceed with conducting a study of selected work units to determine whether
a larger Region-wide study should be made. If the limited review reveals
problems, then I believe we should conduct a broader study after July 1985,
to ascertain the scope of the problems and use it as a basis to change the
direction of our AWS program.
-------
The following are comments received from three Region V Managers who
responded to Mr. Adamkus1 memorandum.
The first manager indicated that most of the work in his unit required
continuous interaction with his counterparts in Headquarters, other
Federal agencies, as well as State entities. He indicated that the
majority of his staff was currently on a compressed workweek although
few or none of the offices with which they dealt with on a regular basis
utilized such a schedule. He indicated that the implementation of the
compressed workweek contributed to the difficulty of his office providing
a full service and was thus inhibited from properly discharging its
responsibilities to its clients. He indicated further that it was his
firm opinion that an office such as his must operate full-time to adequately
serve the interest of EPA and its clients.
The manager pointed out as a separate issue that administering the compressed
work schedule system has proved difficult because it is susceptible to
abuse, i.e., long lunch hours, late arrival for work, and early departures.
He indicated close supervision of the system was difficult, if not impossible,
since a compressed workday often spans a 10-hour period.
The second manager commented on the Compressed Workweek Plan as well as the
flexitime schedule. She indicated that based on her experience, the
compressed workweek offers greater personal productivity but occasionally
compromises group productively. She stated there was no simple way to
measure which out weighs the other and, because the Compressed Workweek Plan
is perceived to be a tremendous employee benefit, felt that the Agency
should continue to support it. Her recommendation concerning the compressed
workweek policy was that the starting time should be no earlier than 7:00
a.m. although she did not offer specific reasons for the recommendation.
She indicated she supported retaining the Flexible Work Schedule but
recommended that the hours for starting and quiting times be reduced.
Currently, the standard starting time and quiting time is 8:15 a.m. and
4:45 p.m. respectively. She recommended that employees be allowed to
flex these times by 45 minutes on either end of the standard schedule,
this would mean that people could start work as early as 7:30 a.m., or
stay as late as 5:30 p.m. This change, she felt, would still accommodate
varying commuter schedules but would make supervision easier where it was
a problem because it increases the time employees are in the office with
direct supervision. Additionally, she felt it would enhance group pro-
ductivity because more people would be present in the office at the same
time, which makes interaction and coordination easier and it gives those
who like to start early, and those who prefer to stay late, equal consider-
ation because the amount of flexitime allowed in the morning and in the
evening would be the same.
The last manager provided what he emphasized to be his own personal
comments on the Flexible Work Schedule Program. He indicated that the
comments where strictly his opinion and not reflective of those of his
position within the Agency. He stated that the purpose of the Flexible
Work Schedule Program is to "improve productivity in the Federal Government
and provide greater service to the public." He stated that, based on his
personal experience, he felt that if these two purposes were truly evaluated,
the evidence would overwhelmingly support the fact that overall productivity
significantly decreases and that service to the public deteriorates.
-------
He felt the only thing resulting from the program was personal convenience
to the individual employees. In his opinion, that is clearly not the
criteria for finding the program acceptable.
The manager states that there are a group of employees that require
constant supervision, and unless closely monitored, will not perform a
day's work for a day's pay. He felt that this group of employees would
take advantage of the system and opted for a flexible work schedule
because they could arrive early and spend their time talking to relatives
on the telephone, reading the newspaper, and then pass the time socializing
until such time that their supervisors arrive. In order to control the
system, a senior staff person has to be assigned to the role of acting for
the supervisor in matters of time and attendance and this, in actuality,
does not work. He felt that people are reluctant to "report" their fellow
employees and they generally feel no responsibility to provide supervisory
functions when they are not supervisors. As a result, the system is abused
and it fails. He felt that productivity is definitely not enhanced under
the Flexible Work Schedule because employees waste time before a supervisor
arrives or after a supervisor leaves.
This manager also addressed the concept of service to the public. He
stated that with office hours starting as early as 6:00 or 6:30 a.m. the
public is not being served by those early arrivals. When the public trys
to obtain answers after 3:30 p.m., they find that key staff members are
gone for the day. He stated that, in a broader sense of service to the
public, it was nearly impossible to schedule trips, meetings, or conferences
on Mondays or Fridays or to hold meetings after 3:30 p.m. because of the
alternate work schedule.
This manager strongly urged that before Region Y continues to utilize the
Alternative Work Schedule, we do a complete and thorough evaluation to
determine whether productivity is being improved and whether there is
greater service to the public. It was this manager's strong personal
belief that it was impossible to properly manage an Flexible Work Schedule
Program to the benefit of the Government with the result of improved
productivity and greater service to the public. He felt that the only
result of the Flexible Work Schedule was in personal convenience of those
taking advantage of it.
The Federal Employees Flexible and Compressed Work Schedules Act of 1982,
Codified as 5 USC 6120, was enacted because Congress felt that the use
of flexible and compressed schedules had the potential to improve
productivity in the Federal Government and provide greater services to
the public. We have recognized that, under certain circumstances, certain
work schedules may be detrimental to EPA's ability to accomplish its
mission efficiently and effectively and it is also entirely possible
that, in certain organizations within our Region, these programs have an
adverse agency impact. In such instances, supervisors have had the authority
to limit flexible and compressed workweek schedules.
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Labor relations laws in the Federal sector define adverse agency impact
as: (1) A reduction in the productivity of the Agency; (2) a diminished
level of services furnished to the public by the Agency; (3) an increase
in the cost of Agency operations (other than reasonable administrative
costs relating to the process of establishing a flexible or compressed
schedule).
I draw these parallels between labor relations laws and the impact of
these programs upon EPA because several agencies have determined that
these programs have an adverse agency impact, and they do provide us with
a valid process for evaluation.
When a Federal agency and a recognized labor organization reach an impass
over an agency's determination not to establish a flexible or compressed
work schedule because of an adverse agency impact, 5 USC §6131 provides
for the Federal Service Impasses Panel to resolve the matter. To date,
the Federal Service Impasses Panel has issued only a handful of decisions
under §6131. Several of the cases provide insight into the criteria used
by agencies to determine if there has been adverse agency impact. There
are many parallels between the kinds of issues raised in the comments
referenced above, and the concerns on the part of other Federal agencies
who have had to bargain over the same issues with labor unions. Agencies
that have had to bargain over flexitime and alternative work schedules
have had to develop sufficient evidence to prove adverse agency impact.
For example, Department of the Army, Fort Rucker, Alabama v. Local 1815,
AFGE, case number 83 FSIP 45, (25 October 1983), involved a union proposal
to consider a revised alternate schedule workplan for their Procurement
Division which essentially replaced a very similar plan discontinued by
the agency. Management opposed the union's proposal and was able to
introduce specific evidence concerning its backlog of orders, quality of
customer service, and level of overtime costs. Management argued principally
that these problems result, in large part, from the fact that employees
work schedules did not coincide to a great enough degree with those of
contractors, customers, and other employees. The agency was able to back
up its arguments with testimony detailing with specific examples and
difficulties encountered under the former plan. The agency also introduced
evidence to establish that the backlog, customer complaints, and overtime
costs had all declined substantially when the former alternative work
schedule plan was discontinued. The Impasses Panel was persuaded by
these arguments, and upheld the agency's determination of adverse impact.
It is obvious, that the agency's prior unfavorable track record with an
alternative work schedule was a major element in the favorable outcome of
the case. From this particular case, the Agency reacted to factual
information rather than perception and speculation.
In considering further the comments provided by the three managers who
responded to Mr. Adamkus' memorandum, we must consider whether or not
these flexitime programs have achieved the results for which we were
looking when they were initiated. For example, the following is a list
of reasons many Federal agencies adopted and have continued flexitime
programs.
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1. Reduction of absenteeism.
2. Reduction of tardiness.
3. Reduction of employee turnover.
4. Reduction of overtime.
5. Improved employee morale and satisfaction.
6. Improved internal coordination of jobs.
7. Gain flexibility in assigning employees to different jobs.
8. Allow for reduced work hours without laying off employees.
9. Make jobs more attractive for recruiting.
10. Improve commuting conditions for employees and surrounding
community.
In assessing the Compressed Workweek and Flexible Work Schedule programs
we must, as a Region, determine whether we were able to measure the
reasons for the program. For example, one of the comments referenced by
one of the managers indicated that the only result of the Flexible Work
Schedule was personal convenience. It was his opinion that personal
convenience is a key factor, however, it should be factored out of the
evaluation process in such a way as to arrive at an objective analysis of
determining whether or not there was increased productivity and greater
service to the public. Adopting that philosophy ignores many significant
positive program attributes. For example, improving morale, commuting
conditions, and making jobs more attractive for recruiting purposes are
indeed important factors to be considered in an overall or even partial
evaluation of the program.
Management has many options to consider in dealing with these two programs.
While it would be difficult because of a lack of data/statistics to make
a definite recommendation concerning the future of these programs or
possible changes in them, there are alternatives and options available
which management should be aware of. First, we have the prerogative to
exempt certain positions or, for that matter, entire organizations, from
the Compressed Work Week and/or Flexible Work Schedule program. Secondly,
the existing regulations provide that each Branch Chief is responsible
for developing an overall plan of scheduled days off to ensure maximum
office coverage with a goal of at least 75% of the staff scheduled to
work on all workdays. Each Branch's plan is subject to approval by the
Division Director. In this context, Branch Chief's have the responsibility
for assuring adequate office coverage. Supervisors should be aware, due
to their unique characteristics, some positions do not fit well in these
programs and can be designated as exempt from them.
If it is determined that organizational efficiency of any work unit is
impaired by such a program the responsible Division or Office Director
could request, through the Regional Administrator and the Personnel
Branch, that his/her Division or Office be excluded from such programs.
An organization that is excluded from the program will return to a regular
tour of duty.
As Mr. Adamkus pointed out in his memorandum of November 26, 1984, the
success of these programs requires mutual cooperation on the part of all
supervisors and employees. While this memorandum did not generate a
large number of responses, the responses that were received deserved to
be given serious consideration. Some problems that are identified in
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one division may or may not surface in another division. Individual
divisions may want to conduct a self assessment of the benefits and
detriments of these programs and make decisions accordingly. Other
Federal agencies have reviewed their programs and have raised the same
issues and concerns, and have dealt with them in a number of different
ways. For example, some Federal agencies require each employee to annotate
a time sheet which documents their morning arrival time, their departure
and arrival to and from lunch, and their departure at the end of the
workday. It also captures the amount of leave/credit hours used, credit
hours earned and hours carried over from one pay period to the next.
While I am not necessarily advocating this approach, it is being used
successfully to correct some of the real or imagined abuses that have
been identified by those managers that have submitted comments to me.
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ATTACHMENT B
The following are comments received from seven Region V managers who
responded to Personnel's memorandum of March 12, 1985.
The first manager indicated that his staff utilized both Flexible Work Schedules
and Compressed Workweek. He stated that the programs provided good office
coverage and recommended that no modifications should be made to the Region's
current policies.
The second manager commented that flexitime policies should be changed to reduce
the breadth of the core hours, although he did not make a specific recommendation
as to the extent to which they should be reduced. With respect to the compressed
workweek program, he stated that it should be eliminated because it was too
difficult to:
a. schedule meetings,
b. rely on clerical help, and
c. obtain staff advice from management on important issues on an as needed
basis.
The third manager stated that he gets in before the early staff arrives and
leaves after the late ones have gone home, thus he supervised throughout the
extended workday. He stated that he was not a fan of the alternate work schedule
because of the supervisory problems, the loss of productivity over the 9 hour
day, and the observed fact that the 5 to 6 p.m. timefram is generally 90% non-
productive.
The fourth manager expressed support of the compressed workweek and flexitime,
and indicated the region should keep the programs while making minor changes.
He recommended that the core hours be changed, and suggested to 9:00 a.m. to
4:00 p.m. He also recommended that the earliest starting time should be 7:00
a.m., and the latest quitting time should be 5:30 p.m. He recommended these
changes because in his opinion, the Government does not get full advantage of
the employee's time because of a general lack of supervision and a tendency for
employees to catch up on their newspaper reading and make personal calls. He
feels that employees should not be permitted to work more than 30 minutes in
the morning or evening without supervision.
The fifth manager, a Division Director, expressed the personal view that the
compressed workweek is a flawed concept, but felt that it was a recognized
employee benefit that would be virtually impossible to retract. Therefore, he
intended to institute reasonable reforms in his division. He stated that the
idea that nonsupervisory staff can be charged with overseeing peer staff conduct
in the absence of the supervisor is unworkable in practice. The major source
of the problem is that employees who need close supervision are in the office
for long periods of time without it. Further, he indicated that trying to
separate responsible employees from irresponsible ones generates incredible
stresses within the organization. He indicated he will alleviate the problem
somewhat by shortening the period of nonsupervision. To do so he will establish
a core period from 9:00 a.m. to 4:00 p.m., and establish 7:00 a.m. and 5:30
p.m. as the earliest and latest arrival and departure times.
The sixth manager, a Deputy Division Director, commented that while they utilize
senior staffers as "acting supervisors" during the hours of the extended day,
its effectiveness has not been measured an it places an unreasonable burden on
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a nonsupervfsor to report on his/her peers.
The managers also indicated that it was the overwhelming opinion of his
division's managers and supervisors that the hours outside of the 7:30 a.m. to
5:30 p.m. timeframe are of no advantage to the Government, and that productivity
probably suffers.
Their evaluation of the AWS is as follows:
Positive Aspects
0 Opportunity to accommodate the employee's personal needs
0 At times, reduces the need for OT/CT.
Negative Aspects
0 Difficult to supervise
0 Increases possibility for errors in timekeeping and reporting.
0 Work hours do not coincide with normal business hours.
0 Further complicates scheduling of meetings, work and office coverage.
0 Increases the need for OT/CT when employee has to work on scheduled day off.
0 Deadlines may be missed.
0 Productivity may decrease.
The manager indicated that, based on their own evaluation by supervisors and
managers, the AWS was not given a favorable review. He stated that he will ask
the Planning and Analysis Branch to perform the assessment for a non objective
evaluation.
The seventh manager, a Division Director, indicated that his supervisors were
aware of the need to designate employees to act in their absence during the
hours of the extended workday. It was his opinion that, with regard to the
Compressed Workweek and Alternate Work Schedule, the coordination and communication
problems between individuals and between (and within) organizations were
heightened. He felt that part of the problem could be resolved by simply
reestablishing the earliest starting time to 7:30 a.m.
In addition to his own comments, he provided the results of a brief survey
concerning the compressed workweek among his supervisors. The results of that
survey are as follows:
1. Your Work Schedule
a. Flexitime only (35%)
b. Compressed Workweek (CWW) (65%)
2. Did you participate in CWW at the beginning but later drop out?
a. Yes (10%)
b. No (90%)
3. Did you choose not to participate in CWW at first but later change your
schedule from flexitime to CWW?
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a. Yes (29%)
b. No (71%)
4. Since CWW began, coordination between my work unit and other units has
been:
a. Enhanced ( 6%)
b. No change (67%)
c. Hindered (27%)
5. Under CWW, my immediate work unit meets its deadlines:
a. More frequently (19%)
b. No change (78%)
c. Less frequently ( 3%)
6. In general, how would you rate your unit's service to the States and public
since the start of CWW?
a. Better (39%)
b. No Change (55%)
c. Worse ( 6%)
7. Because of CWW, contacts with individuals outside EPA are now:
a. More easily made (39%)
b. No change (48%)
c. More difficult (12%)
8. Because of CWW, contacts with individuals inside EPA, Region V are now:
a. More easily made (12%)
b. No change (48%)
c. More difficult (39%)
9. Would you prefer this Division to discontinue using CWW?
a. Yes (21%)
b. No. (79%)
10. Please provide a summary of the work schedules your employees use (example attached
Excluding Including
Supervisors Supervi sors
CWW (57%) (59%)
Flexitime (43%) (41%)
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I. Purpose: This Order describes policy on Alternative Work Schedules for Region V.
II. Policy: It is the policy of this Region to implement provisions of the Alternate
Work Schedules (AWS) programs in accordance with Public Law 97-221, The Federal
Employees Flexible and Compressed Work Schedules Act of 1982.
i
Employees will be permitted to select a starting time other than 8:15 a.m. by
working under a flexible work schedule or compressed workweek plan, provided:
a. Employee's immediate supervisor approves.
b. Each employee continues to meet his or her job commitment in performance
of duties and responsibilities.
c. The Division or Office Director determines operations and functions of
the work unit, productivity, service to the public and the mission of
the Region will not be impaired.
d. Employees request changes in their AWS tour no more frequently than
once per pay period for Flexible Schedules and once per quarter for
Cmpressed Workweek. Approved changes become effective on the first
Monday of the first full pay period following approval unless stated
otherwise by the approving supervisor.
e. Management reserves the right to terminate the AWS program in part or
in its entirety at anytime that it is determined that employees are
abusing the provisions of the program, productivity or quality of
work are declining, service to the public is hindered, or mission
accomplishment is being adversely affected.
III. Coverage. The AWS program is applicable to all full-time employees in Region V
(including Public Health Service Commissioned Officers) and to part-time employees
scheduled to work at least 16 hours per week. Temporary employees may be
included in the AWS program subject to approval of the immediate supervisor.
IV. Responsibilities: The AWS program is designed to accommodate most employees,
however, it must have no adverse impact on Region V's ability to meet its
mission.
a. Regional Administrator.
(1) Reviews and approves or disapproves AWS requests for the Regional
Administrator's staff, and Division and Office Directors.
(2) Reviews and approves or disapproves Division and Office Director's
requests for termination of the AWS program within their functions.
b. Division Directors and Office Directors.
(1) Review and approve or disapprove AWS requests for all personnel
reporting directly to them.
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(2) Are responsible for insuring that the AWS program does not inhibit
accomplishment of the mission, cause delays in accomplishment of
assigned duties and tasks, or hinder productivity or service to the
and tasks, or hinder productivity or service to the public.
(3) Assure that all subordinate supervisors are aware of their
responsibilities under the AWS program.
c. Branch, Section, or Unit Chiefs.
(1) Assures that there is adequate office coverage each work day.
The goal is to have at least 75% of staff scheduled to work on
all work days.
(2) Reviews and approves or disapproves AWS requests for all personnel
reporting directly to them.
(3) Assures that accurate records are maintained covering time and
attendance of employees.
(4) Assures that the Branch, Section or Unit operation is not impaired
as a result of approving AWS requests.
d. Employees.
(1) Prepare and submit EPA Region V Form RV 3110.1, Request of Flexible
Hours or Compressed Schedule for Compressed Workweek form if they
desire to take part in the AWS program.
(2) Employees are responsible for adhering to their AWS schedules as
approved in advance by their supervisors.
(3) Employees are responsible for assuring that the quality and quantity
of work are maintained.
V. General Provisions.
a. All employees are required to work the core hours of 9:00 a.m. to
4:00 p.m., which includes a minimum lunch period of 30 minutes.
b. Lunch periods will not begin prior to 11:00 a.m., nor end after 2:00
p.m., and can be 30, 45, or 60 minutes.
c. Compressed Workweek: EPA Region V will be open five days a week
Monday through Friday. Employees utilizing a compressed workweek
are not permitted to start work earlier than 7:00 a.m., and are not
permitted to work later than 5:30 p.m. The compressed workweek
schedule compresses 80 hours of work into nine days of scheduled
work every pay period. This means one week per pay period of five
days, the other week of four days. Eight of the days are nine-hour
days, and one day is eight hours. Each employee must secure their
supervisor's approval of the intended schedule before they begin to
work under it.
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Part-time employees (those working from 16 to 32 hours per week) are
allowed to work compressed workweek with approval of their supervisors.
d. Flexible Schedule: Employees who wish to work a tour of duty other
other than that of 8:15 a.m. to 4:45 p.m., must submit a request to
their supervisor for approval of their schedule. Flexible work
schedules will involve a set tour of eight hours of work per day.
Core hours and lunch hours are the same as those identified in a.
and b. above. Core hours must be worked. An employee is not permitted
to start work before 7:00 a.m. and is not permitted to start work
later than 9:00 a.m. Employees are not permitted to leave before
4:00 p.m., or later than 5:30 p.m. For example, an employee arrives
(on a scheduled tour) at 7:30 a.m., takes 30 minutes for lunch, and
goes home at 4:00 p.m.. Eight hours of work is required to be
performed each day, employees cannot work six hours one day and ten
hours the next. Employees are required to take a minimum lunch
period of 30 minutes. When it is necessary to make a temporary
adjustment to an employee's flexible tour schedule, the supervisor
should explain in specific terms and in writing why, and how long
the flexible tour will be modified, not less than 1 working day
prior to such adjustment. Emergency situations will not require prior
written notice by the supervisor. Please not that part-time employees
as identified in c above may take part in flexible schedules, with
the approval of their supervisor.
e. Under c. and d. above, a supervisor can change the tour of duty of
the employee to conform with hours of training or other particular cases.
VI. Absences and Leave Under Compressed Workweek
a. Holidays - Full-time employees.
When a holiday falls on one of the full-time employee's regularly
scheduled workdays, the employee will be credited with Holiday Leave
for the number of hours he/she was scheduled to work that day. When.
a employee has three consecutive non-workdays off (Friday, Saturday &
Sunday) and a holiday falls on the employee.1 s first or second non-
workday, (Friday or Saturday) the preceding workday (Thursday) shall
be designated as the "in lieu of holiday." When the holiday falls on
the third non-workday, (Sunday) the next workday (Monday) shall be
designated as the "in lieu of holiday." When an employee's designated
day off is Tuesday, Wednesday or Thursday and a holiday falls on that
day, the employee will be allowed either the day before or the day
following as an "in lieu of holiday," subject to supervisor's prior
approval.
B. Holidays - Part-time Employees.
All preselected schedules for part-time employees will serve as the
individual tour of duty in determining holiday and leave hours for
part-time employees.
When a holiday falls on one of the part-time employee's regularly
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scheduled workdays, the employee will be credited with holiday leave
for the number of hours he/she Is scheduled to work that day (not to
exceed 8 hours). Part-time employees are not entitled to holiday
leave when a holiday falls on a day when they are not scheduled to work.
c. Scheduling Compressed Day Off.
Employees may request their day off, subject to management approval,
anytime during the bi-weekly pay period. The off day must be scheduled
In advance and, if approved, will be in effect for 3 months. It may be
changed only in the case of extenuating circumstances and with management
approval. The chosen day off must remain constant each pay period
for a full quarter, i.e., the same day every two weeks. For example,
any employee wishing to change their day off for the months of October,
November and December, should submit their request and receive approval
sometime in September. Supervisors can make changes in the tour of
duty and off day of the employee to conform to hours of training, appropriate
office coverage, or other particular cases.
d. Time off during an employee's scheduled workday must be charged to the
appropriate leave category. For example, an employee who takes one
day of annual or sick leave will be charged leave for the number of
hours he or she was scheduled to work that day, i.e., if the employee's
schedule calls for 9 hours of work, then 9 hours of leave must be
charged.
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COMPRESSED SCHEDULE TOR COMPRESSED WORKWEEK
To:
Supervisor)
I request that under the Compressed Workweek Program the following days
and work hours be established as my tour of duty effective .
WEEK 1
MONDAY
TUESDAY
WEDNESDAY
THURSDAY
FRIDAY
START
STOP,
JEEK 2
START
STOP
MONDAY
TUESDAY
•
.
WEDNESDAY
THURSDAY
•
FRIDAY
Signature of Employee
Date
1st Level Supervisor ___________
Signature
approved disapproved
Date
REQUEST FOR FLEXIBLE HOURS
10:
(Supervisor)
I request that my work hours be established from __
to daily. I request that my lunch hour be
(30, 45, or 50) minutes in length.
Employee Signature
Gate
Approved
/ / Disapproved
Immediate Super/iscr
Cate
Reason for Disapproval
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