/c? 100R83101
POLICY AND MANAGEMENT REVIEW OF
HEADQUARTERS - REGIONAL RELATIONSHIPS
SEPTEMBER, 1983
TASK FORCE LEADERSHIP BY THE GRANTS ADMINISTRATION DIVISION
WITH SUPPORT OF THE OFFICE OF THE COMPTROLLER, THE OFFICE OF
POLICY AND RESOURCES MANAGEMENT, THE MANAGEMENT AND
ORGANIZATION DIVISION, AND REGIONAL OFFICES
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TABLE OP CONTENTS
PAGE
PREFACE
EXECUTIVE SUMMARY ii
I. Decentralization is Essential to EPA Mission 1
Performance
Decentralization of EPA is a Core Concept 1
of the National Environmental Strategy
We should State a Clear General Policy 4
on Decentralization and Policies
to Guide Specific Delegations
II. Integrated Guidance, Accountability, and Evaluation 15
are Essential To Effective Decentralization
The Administrator's Management Accountability 16
System has Already been Improved
A Disciplined Agencywide Directives System 17
Does not Exist
Effective Program Guidance, Accountability, 18
and Evaluation Systems have Common Characteristics
III. We Should Encourage Greater Regional Involvement 25
in Planning and Budgeting
Regions Have Some Concerns with the Current 26
Process
Our Recommendations Will Strengthen the 27
Current Process
IV. The Regional Organizational Structure Should Not 32
Be Changed Extensively at this Time
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LIST OF ATTACHMENTS
Figure A Distribution of Responsibilities
Decentralized Activities
Figure B Permanent Policy and Guidance Systems
Figure C Program Reporting Systems
Appendix A Delegations of EPA Authorities
by Activity
Attachment 1 List of Task Force Participants
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POLICY AND MANAGEMENT REVIEW OF
HEADQUARTERS - REGIONAL RELATIONSHIPS
PREFACE
Upon his return as Administrator of EPA, William D. Ruckelshaus
established a series of Task Forces to assist him in resolving
a number of major policy and management issues. Alvin Aim/
then Special Assistant to the Administrator and now Deputy
Administrator, was responsible for Task Force oversight.
This is the report of the Task Force on Headquarters/
Regional Relationships.
Through a structured Agency wide dialogue the scope of
major issues to be considered in the Review was narrowed to
four:
I. The policy framework for decentralized management
of EPA's mission;
II. The guidance, accountability, and evaluation
support for the policy;
III. Regional involvement in planning and budgeting;
and,
IV. Regional organizational structure.
This Report presents recommendations in each area for re-
view and decision by the Administrator. The Report and
recommendations attempt to transcend program and media bound-
aries and establish a general policy framework for resolution
of issues in Headquarters/Regional office working relation-
ships.
Two other efforts had significant influence on this Report.
Those efforts concerned related activities of Policy and
Management Review VI ("Delegations within EPA") which has
been incorporated in the Review, and VII ("State/Federal
Roles"). We attempted to avoid conflict or redundancy with
other relevant policy reviews. We have also benefited from
extensive previous and ongoing initiatives of the Office of
Planning and Resource Management and the Management and
Organization Division on the allocation of authorities and
responsibilities to Regions and States.
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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. This 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
progress.
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 logically 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 and 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 allocation
processes, and organization.
11
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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:
U Assistant Administrators are responsible for developing
and promulgating policy and guidance and in consulta-
tion with the Regions, assuring consistent implementa-
tion of national ->olicy, providing oversight and
evaluating progress, and taking actions which are of
national significance or multiregional in nature.
f 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.
fl Assistant Administrators and/or the Associate Administrator
for Regional Operations are responsible for recommend-
ing delegations of authority to the Regions and changes
thereto.
f 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
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Permitting, engineering and environmental impact review
activities will 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.
Product review and registration activities will be dele-
gated to the Assistant Administrators, except for
those actions specifically reserved for the Administrator.
Listing and designation of particular pollutants,
products, geographic areas activities or source cate-
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.
Hazardous Substance Emergency Response and Site Manage-
ment activities should be delegated to the Regional
Administrators, as a near term goal, except those
actions specifically reserved for the Administrator
or assigned to Headquarters based upon exceptional
factors.
Testing/Monitoring and Inspection Activities will be
shared between Regional Administrators 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).
Administrative Orders and Notices 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.
Referrals to the Department of Justice (DOJ) for
Judicial Enforcement Actions will 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
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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 plc^s, 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.
S
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 program 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
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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:
U 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 remove 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
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We recommend that the Administrator adopt the following
policy statement:
fl 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
vil
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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:
fl 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.
1 The Management and Organization Division (MOD) should
be directed to administer an integrated EPA Directives
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 approve program specific documents while
adhering to the mechanics of the Agency directives
system.
1f 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
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III. REGIONS SHOULD BE MORE INVOLVED
IN PLANNING AND BUDGETING
During the development of the FY 1983 budget, the Agency
replaced the Zero 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 rocess and then 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
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We recommend that the Administrator adopt the following
policies increasing Regional involvement in the budget process:
f 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.
K 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.
U 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,
f 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.
K 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
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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 meets 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. The current standard regional organization
is being modified to provide for appropriate changes in
reporting lines.
XI
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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 provide
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 BSD 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 BSD 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 BSD 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
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POLICY AND MANAGEMENT REVIEW OF
HEADQUARTERS - REGIONAL RELATIONSHIPS
I. DECENTRALIZATION IS CRITICAL TO EPA MISSION PERFORMANCE
DECENTRALIZATION OF EPA IS A CORE CONCEPT
OF THE NATIONAL ENVIRONMENTAL STRATEGY
The national strategy for achieving environmental goals was
initially built upon cooperative efforts of Federal and State
governments. The principal Federal responsibilities were to
establish national policies, develop standards, and participate
with State and local governments in implementing environmental
programs.
Over the past decade the scope of environmental programs
has been extensively broadened. Simultaneously, the technical,
economic and political complexity of environmental issues has
increased. The overall Federal-State approach to managing
environmental programs has been continued during this period.
The challenge now is to better shape and balance the respective
Headquarters, Regional and State roles and responsibilities
in a coherent fashion.
EPA's Organization is Designed
for Decentralization
When EPA was organized in 1970 the ten regional offices
were designed to carry out coordinated Federal participation
in integrated environmental management. Authorities for admin-
istering State and local programs were assigned to these full-
service regional offices.
A major objective of this regional office strategy was to
provide a single point of responsible Federal contact for
State and local government officials. This includes the
authority to negotiate the terms and conditions of financial
assistance awards that undergird State and local government
implementation efforts.
In 1972, during Administrator Ruckelshaus1 first tenure
with EPA, an EPA report on decentralization indicated that
"there is a high degree of decentralization of both authori-
ties and resources in EPA." The report concluded that "exist-
ing delegations generally are considered sufficient by both
Regional Office and Headquarters officials".
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The Administrator Supports Decentralization
The Administrator recently advised the Congress of his
continuing support of the Agency's underlying concept of
decentralized management and operations. He reaffirmed his
belief "in the strong Regional Administrator concept" and
noted that the Regions needed "much clearer guidance from
Headquarters as to how they are to carry out those responsi-
bilities that they have been given."
Getting Back To Our Roots
In contrast to the 1972 report, our current Review suggests
that many EPA managers believe that the original EPA policy
of decentralization has not been consistently maintained as
program responsibilities have grown.
The need for improved policy guidance in sorting out appro-
priate relationships is evidenced by the following competing
viewpoints identified in our study.
A Headquarters program manager commented, "If an AA is
to be held responsible for program success, he must
have some control over the organization which operates
and manages the program .... If we delegate a lot of
authority to the RAs . . . the AAs will be basically
just staff to the Administrator, with little line author-
ity or responsibility."
A Regional manager commented, "The purpose of Regional
Offices is to assure that national programs are imple-
mented at the State and local levels. Each Region should
be responsible for implementing all EPA programs in their
Region .... It should be the responsibility of the
Regional Administrator to raise any questions of national
policy to the appropriate Assistant Administrator."
Ve Have Drifted From The
Original Framework Of Decentralization
In recent years, the Agency has gradually drifted from an
accepted organizational concept which balances national program
policy development and consistency with regional implementation
flexibility. (There is now a lack of agreement as to how
the Agency will organizationally pursue its goals).
There have been several examples of increased centraliza-
tion that have been made without reference to, or benefit of,
a current policy statement on allocation of responsibilities:
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o The Agency has begun direct administration of new
program authorities in Headquarters with no plan for
decentralization.
o Strings have been attached to some of the authorities
traditionally vested with Regional Administrators.
o Other authorities previously delegated to Regions, such
as Administrative Orders for NPDES, have been pulled
back to Headquarters.
This perceived shift away from decentralized management
has coincided with a decade of growth in national environmental
programs and increasing complexity in Federal/State relation-
ships.
The Regions offer a sizable list of specific areas in which
they believe additional authority should be delegated. In
addition, they identify several other areas where they believe
their authority is compromised. Alternatively, Headquarters
program offices have identified problems with regional delega-
tions of authority that are not preceded by a full and clear
resolution of all major issues and concerns. The absences
of a clear statement of policy preferences on those issues
will result in continued confusion and unnecessary tension
in program implementation.
Making Decentralization Vork
Requires Common Understanding
The Agency should develop and maintain a plan for decen-
tralization that establishes basic philosophy, defines
basic responsibilities, and fosters common understanding
regarding the roles of both Headquarters and the Regions.
Agency staff agree that a clear statement is needed on policy
and authorities, accountability, resource allocation, and
organization. This paper addresses each of these areas.
Figure A identifies the general distribution of basic respon-
sibilities under decentralized management.
Throughout the review process we have accepted the follow-
ing premises as fundamental to effective decentralized
management.
o Assistant Administrators and Regional Administrators
must have the necessary tools to accomplish their
individual missions consistent with the degree of
their responsibility.
o We assume the ability of the Regions to perform an
assigned function given adequate guidance and
resources.
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We Should Adopt Specific Policy Statements
For Categories of Activities
The Agency has two basic options in dealing with specific
delegations of authority:
(1) We can continue our current practice of reviewing
individual delegations without providing additional
policy to guide decision-making.
(2) Alternatively, we can provide an expanded policy frame-
work to guide such decisions, and then review proposed
individual delegations within this broadened frame-
work, allowing exceptions to specific policies when
ample justification is provided.
The Task Force proposes the establishment of the follow-
ing policy statements for each category of major activity.
Adopting such functional policy statements does not preclude
exceptions to the policy if the unique character of a program
justifies a deviation. To implement the policy statements,
current delegations would be individually reviewed. Delega-
tions that do not conform with the general policy would be
changed unless an exception on the particular delegation is
justified. In selecting the activity areas, we intentionally
used the classification system (compatable, but not identical)
established by the Office of Policy and Resources Management
in their "Profile of EPA Activities".)
Permitting, Engineering and Environmental Impact Review8
If ill Be Delegated To The Regional Administrators
EPA activities in this category take place in individual
regions and are "geographically stable" (e.g., they pertain
to a specific activity located in a particular place and do
not and can not be relocated or redistributed to another
area). In most cases, the environmental consequences can be
evaluated in terms of a single Region. Most of these author-
ities are already delegated to the Regional Administrators.
The rationale supporting this delegation is that the
actions are confined to a particular Region and that the
Region is in the best position to address the issues. When
these authorities are not given to the Regions it can hamper
the Regional Administrator's ability to make balanced deci-
sions within his/her Region and moves the primary decision
maker to a level where there may be less relevant information
concerning the action.
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Factors that may justify deviation from this policy and
result in assignment of responsibility for specific approvals
to Headquarters should generally be limited to:
o Involvement of multiple Regions;
o Establishment of national precedent;
o Absence of adequate policy;
o Review of actions of other Federal agencies; and
o Disapprovals of items which are so sensitive in nature
as they require the Administrator as final decision
official.
Therefore, we recommend that the Administrator adopt the
following policy statement:
1 Permitting, engineering and environmental impact review
activities will 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.
Product Review And Registration Will Be
Delegated To The Assistant Administrator
EPA activities in this category relate to products or acti-
vities that have an actual or potential nationwide impact.
Thus, the environmental consequences must be evaluated from
a national perspective. Headquarters offices have the resour-
ces, information, or national perspective to evaluate national
implications. Factors justifying a delegation to Regional
Administrators would be limited to special circumstances,
such as when the product distribution is confined to a partic-
ular location for a limited purpose (e.g., testing a new
pesticide).
Therefore, we recommend that the Administrator adopt the
following policy statement:
1f Product review and registration activities will be del-
egated to the Assistant Administrator, except for
those actions specifically reserved for the Administrator.
Designation Of Particular Pollutants, Products,
Geographic Areas Or Source Categories Should ^e
Delegated To The Assistant Administrators
These EPA activities include decisions relating to the
designation of particular pollutants, products, geographic
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areas or source categories for further regulatory action.
The decisions are similar to the product registration activ-
ities and as such have national impact requiring Headquarters
management. This is a category where the need for integrated
and coordinated approaches to the control of chemicals is
great. These decisions frequently have significant multi-
media ramifications where authority should be retained by
the Administrator.
Therefore, we recommend that the Administrator adopt the
following policy statement:
1 Listing and designation of particular pollutants,
products, geographic areas activities or source cate-
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 regions will be delegated to the Regional
Administrators
Hazardoue Substance Emergency Reeponse And
Site Management Will Be Delegated To The
Regional Administrators, Ae A flea* Term Goal
EPA activities in this category are usually confined to a
particular location. However, the consequences may have the
potential for affecting another area (a spill incident in one
Region that moves down river to another Region). Frequently,
quick decisions must be made on-site in order to minimize the
environmental damage.
While it would seem on the surface that the regional per-
sonnel are better positioned to assess the specific environ-
mental conditions, most of these authorities are delegated
to the Assistant Administrator for Solid Waste and Emergency
Response. These authorities have been retained in Headquarters
primarily because the Agency has inadequate experience and
has not yet developed guidance that would allow the Regions
to operate the program consistent with a national policy.
Additionally, a major problem facing the Regions is the
retention of a wide enough variety of skills to respond to
highly specialized problems surrounding a particular environ-
mental incident.
Retention of Headquarters authority must be tempered by
the consideration that problems may arise if the response
time by Headquarters is too long or decisions are not ade-
quately coordinated with the Regional personnel. Thus,
while we may not be in a position to fully delegate this
program immediately, we should establish the policy that
delegation to Regional Administrators is a top priority.
*, .
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Therefore, we recommend that the Administrator adopt the
following policy statement:
1 Hazardous Substance Emergency Response and Site Manage-
ment activities should be delegated to the Regional
Administrators, as soon as possible , except those
actions specifically reserved for the Administrator
or assigned to Headquarters based upon exceptional
factors.
Delegations For Testing/Monitoring And Inspection
Activities Will Be Shared Between Regional
Administrators And Assistant Administrators
These EPA activities take place within regional boundaries.
Sometimes two or more regions may be concerned with the same
environmental problem, thus requiring a coordinated response.
The regional personnel are geographically positioned to con-
duct monitoring and inspection most effectively.
While the Regions exercise this authority for most EPA
programs, the Assistant Administrators also have the authority
for those activities where it would be appropriate for
Headquarters to take the lead due to the need for a national
perspective or due to the lack of specialized skills in the
Regional Offices. In practice, this Headquarters authority
is rarely exercised. The outstanding exceptions are in the
Motor Vehicle Manufacturer Program, and activities under
the Toxic Substances Control Act.
Therefore, we recommend that the Administrator adopt the
following policy statement:
1 Testing/Monitoring and Inspection Activities will be
shared between Regional Administrators and Assistant
Administrators. The Regions will have primary responsiblity
for most of these activities. Headquarters will be de-
legated 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).
Administrative Orders And Notices Of Violations
Conerning Enforcement Actions Will Be
Delegated To the Reqional Administrators
These EPA activities consist of notifications or orders
issued to responsible parties, usually permittees, or manu-
facturers, distributors, or users of products certified by
EPA. Responsibility for these actions generally rests
with the Regional Administrators since decisions in this
category are based on the technical and scientific data
-------
collected by regional monitoring and inspections. Since
the Regions collect the compliance data they are best situated
to determine the problems and take appropriate actions
(e.g., Administrative Orders and Notices of Violations).
Headquarters exercises this authority only in cases which
have national significance or which are multi-regional.
Therefore, we recommend that the Administrator adopt the
following policy statement:
t Administrative Orders and Notices 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 significants or
multi-regional will be delegated to the Assistant
Administrators.
Referrals To The Department Of Justice For Judicial
Enforcement Actions Will Be Delegated To The Regional
Administrators, Upon Concurrence By The Department Of Justice
These EPA activities are primarily referrals to the
Department of Justice (DOJ) to take civil or criminal action.
A 1977 agreement between DOJ and EPA centralized all such
referrals. To decentralize the referral authority to the
Regions we would need to obtain concurrence from DOJ in
revising our current agreement. However, these referrals
may relate to noncompliance actions within individual
regional boundaries. Placing the authority in Headquarters
requires that the Enforcement Counsel be directly involved
in operating a program, reviewing individual regional actions
and making final decisions where the scope of the action is
within a single Region.
The objective in centralizing all referrals was to assure
quality and encourage consistent application of enforcement
policy. It is generally recognized that the Regions are in
the best position to understand the technical merits of indi-
vidual cases. However, there are differing views on whether
the Regions are best positioned to adequately evaluate the
legal merits of a case. In delegating authority to the
Regions, we need to assure that they have the necessary
resources, policy and procedural guidance and legal talent
available to comply with Agency policy and the quality stan-
dards required by DOJ.
Therefore, we recommend that the Administrator adopt the
following policy statement:
1 Referrals to the Department of Justice (DOJ) for Judi-
cial Enforcement Actions will be delegated, upon
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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 significants or multiregional will be
delegated to Headquarters Enforcement Counsel.
Execution Of State And Local Grants And Cooperative
Agreements, Including Superfund Cooperative Agreements
Will Be Delegated To The Pegional Administrators
These EPA activities include actions which EPA undertakes
to influence the central direction of programs not directly
administered by EPA. The authority to approve and to execute
grants and cooperative agreements is divided between Head-
quarters and the Regions. Headquarters is responsible for
establishing the regulatory framework, providing policies
and procedures, allowing deviations from regulatory require-
ments and administering grants and cooperative agreements of
national significance (principally research and development
grants). The Regions have authority to approve and to execute
State and local assistance agreements.
A major exception from this division of authorities is
Headquarters approval and execution of Superfund cooperative
agreements. In our review we found no compelling reason that
the authority to approve and to execute Superfund cooperative
agreements should not be brought in line with other grant
authorities and, hence, delegated to the Regions.
Therefore, we recommend that the Administrator adopt the
following policy statement:
1 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 cen-
trally managed programs, (e.g., Research and Develop-
ment) will be retained by Headquarters.
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 activi-
ties if they are not delegated to the States.
10
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The Regions believe that review and approval of these
activities is a logical extension of their responsibilities
in providing oversight of State programs. They argue that
if Headquarters officials retain these authorities it hampers
the Regional Administrators efforts to serve as the EPA
focal point for 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 responsibilities it is a function appropriately
reserved to the Administrator; therefore, a Headquarters
funtion.
The majority of the participants in this Task Force review
support delegating the authority for approving State programs,
plans, and delegations to the Regional Administrators. They
believe that delegating this authority is generally consistent
with the proposed decentralization policy.
There are three options for increasing the Regional
Administrators role in State program approvals.
(1) We could delegate authority to Regional Administrators
for State program approvals, with no strings attached.
(2) Alternatively, we could delegate the authority to the
Regional Administrators with a provision that approval
would be subject to either a narrowly defined prior
review or a time limited veto by Headquarters.
(3) Finally, approval authority could be retained by the
Administrator/ Assistant Administrator with execution
supported by a well-defined process which includes
involvement of the Regional Administrator.
There is also 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 timelimited Headquarters veto.
The regional participants on the Headquarters - Regional
Relationships Task Force believe that the veto approach is
better than what currently exist 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:
11
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f The Administrator defer his policy decisions regarding
authority to approve State programs and plans, and
devolutions (delegations) to the States until a deci
sion can be made within the context of the comprehen-
sive issue analysis formulated by OPRM and currently
under Agency-wide review.
We Need a Specific Policy Controlling
the Use of Advance Concurrences
An advance concurrence requirement exist when the Regional
Administrators are restricted from making decisions/ on which
they are the decision official, until they receive approval
(agreement, concurrence, etc.) from Headquarters. Advance
concurrence requirements can be contained in the delegation
of authority, or result from regulations or guidance that
calls for Headquarters action before the decision officials
can act.
The advance concurrence requirement was intended to main-
tain national consistency, when the regions had little or no
experience in the particular area. Headquarters believed
that its involvement would avoid inappropriate precedent
while it was developing adequate national guidance. However,
in practice, Headquarters reviews result in duplication of
effort and significant delays. Furthermore, after Headquarters
has issued necessary guidance, it has also shown reluctance
to remove the requirement for an advance concurrence.
One option is to totally eliminate any continuing require-
ment for advance concurrence. Alternatively, any identified
problems could be moderated by a disciplined limitation in
the use of advance concurrences for new programs where main-
tenance of national consistency is potentially a problem.
These concurrences could then be subject to periodic evalua-
tions and full delegations made to the Regions as programs
mature and the necessity for a Headquarters concurrence role
declines.
Therefore, we recommend that the Administrator adopt the
following policy statement:
1 When the Administrator delegates his authority to the
Regional Administrator, a standing requirement for an
advance concurrence from Headquarters is inappropriate.
Headquarters should monitor and evaluate regional de-
cisions to assure conformance with national policy.
When 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 recom-
mending officials or delegated to the Regional
12
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Administrators with a temporary concurrence require-
ment (the ending date for the advanced concurrence
requirement will be established in the delegation
of authority).
Adopting and Fully Implementing These Specific Policy
Statements Would Have Varying Impacts on Authorities
Where the current delegations conform to the proposed
policy the impact of adopting these specific policy statements
is minimal. However, in some of the categories, as indicated
in the following, the recommended changes have substantial
impact. (A complete listing of the approximately 300 specific
delegations, arrayed by category of activity, is Appendix A
to this Report.)
o Impact on Permitting, Engineering, and Environmental
Impact Reviews is minimal since most of these delega-
tions already conform to the proposed policy. Delega-
tions which do not currently conform would be reexamined
to determine where exceptions to the policy are justi-
fied.
o There is no impact on Product Review, and Registration
since current delegations conform to the proposed policy,
o There is substantial, but not immediate impact on Haz-
ardous Substance Emergency Response and Site Management,
as OSWER and the Regions prepare to shift the authority
from Headquarters to the Regions.
o There is no impact on Testing, Monitoring and Inspec-
tions since current delegations conform to the proposed
policy.
o There is substantial impact on the exercise of Admin-
istrative Enforcement Actions authority since the
Regions currently are required in many areas to
obtain advance concurrences from Headquarters. There
is minimal impact on who has the authority since
current delegations conform to the proposed policy.
Headquarters program offices would have to shift from
case-by-case reviews to the issuance of adequate
guidance and program monitoring and evaluation system.
o There is substantial impact on Judicial Enforcement
Actions giving the Regions authority which they do
not currently have. This first requires renegotiating
the agreement with DOJ to allow referrals from the
Regional Administrators. The Enforcement Counsel and
13
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the Regions would have to take the necessary steps to
shift the authority, including the issuance of Head-
quarters guidance, and design a monitoring and evalua-
tion system.
There is moderate impact on financial assistance in
general since most authority already rests with the
Regional Administrators. The impact that does occur
is on specific programs such as Superfund which do
not currently conform to the proposed policy.
There is substantial impact on Review and Approval of
State Programs, if the options that support a strong
regional role are adopted. This delegation would
give the Regions authority which they currently do
not have. The Headquarters program offices would
have to make a concei :ed effort to assure that adequate
guidance was provided to the Regions and design a
monitoring and evaluation system to provide oversight.
There is no impact on Designations of Particular Pollu-
tants, Products, Geographic Areas of Source Categories
since current delegations conform to the proposed
policy.
There is substantial impact on the formal and informal
operating relationships between Regions and Headquarters
program offices (as discussed above) if the Task Force
recommendation to eliminate advance concurrences is
accepted. Regional Administrators would have full
responsibility for their decisions in delegated areas.
Headquarters, on the other hand, would have to shift
their focus from case-by-case reviews to an oversight
role with an emphasis on guidance, program monitoring,
and evaluation.
14
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II. INTEGRATED GUIDANCE, ACCOUNTABILITY, AND EVALUATION
ARE ESSENTIAL TO EFFECTIVE DECENTRALIZATION
The Task Force examined the Agency's guidance, account-
ability and evaluation systems because there was general
agreement that effective performance of these systems was
essential to decentralized operations.
Concerns Are Limited
We began by looking at a series of options for these sys-
tems ranging from no change to radical adjustments. The
comments on the earlier drafts of this paper made it very
clear that the concerns are quite limited, but important:
o Better schedule management of the guidance process;
o Improved linkage between the Administrator's Guidance
and program guidance;
o Increased policy and informational value (the guidance
was too general); and
o Greater regional participation in determining what
activities were to be tracked, measured and evaluated.
We responded to these concerns by outlining a single
Agency system which can foster effective decentralization by
providing more order to the relationships among Headquarters,
Regions, and States.
An Integrated System
Is Needed
Decentralized management can be improved through an inte-
grated Agency-wide system of program guidance, accountability,
and evaluation. The Administrator, through system components
such as the Administrator's Annual Guidance, the Administrator's
Management Accountability System (MAS) and the EPA Directives
System, establishes the basic structure for the Agency guidance
and accountability system. Subordinate to, and part of the
Administrator's system are, systems employed by Assistant
Administrators to manage their specific program areas. These
include specific program policies, objectives, and performance
measures. Regional Administrators also manage their own par-
ticular responsibilities through subsystems covering regional
staffs and authorized State activities.
Because of the parallel work of the Task Force on Federal
and State relations, we have addressed the system only as it
relates to Headquarters and Regional offices. We have men-
tioned States only where their inclusion is obvious and
15
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essential. The following section discusses the MAS the EPA
Directives System and effective program guidance and evalua-
tion systems.
ADMINISTRATOR'S MANAGEMENT ACCOUNTABILITY
SYSTEM HAS ALREADY BEEN IMPROVED
The MAS serves as the Agencywide system under which pro-
gram and regional commitments are negotiated and tracked to
achieve the Administrator's principal goals as published in
the annual Guidance. It contains the primary program objec-
tives tracked in the systems of each program.
In March 1983, the Office of Management Systems and
Evaluation (OMSE) conducted a review of the way regional
targets were set, reported on, and changed. The review
responded to concerns that some commitments were being set
unilaterally by the Headquarters programs without adequately
involving the Regional Administrators in the process of
negotiating the commitments or reporting quarterly performance.
OMSE staff surveyed 43 Regional and Headquarters managers to
determine the extent of problems resulting from past approaches
and to recommend procedural changes to remedy these problems.
The Task Force concurs in the approach which resulted from
the management review and which was adopted and agreed to by
the Regional Administrators and Headquarters Offices. That
approach is outlined below.
The Setting of Regional Commitments
is Well Structured
Negotiations of regional commitments are conducted along
program lines, i.e., between the Headquarters office and the
corresponding regional division. The national program office
has the lead in discussions with the Regions on measures and
commitments.
o Once initial negotiations are concluded, the Regional
Administrator submits his/her targets both to OMSE
and to the appropriate Assistant Administrator to be
entered into the MAS as Regional commitments. This
requirement ensures that the Regional Administrator
has the opportunity to review the results of the
negotiations and to make adjustments or reopen nego-
tiations as he/she believes necessary.
o The Assistant Administrators confirm their agreement
with Regional Administrators' commitments when submit-
ting national program commitments to OMSE for the MAS.
o An appeals process which begins in OMSE and can reach
to the Deputy Administrator is available to the nego-
tiators.
16
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Reporting on Regional Performance
is Reasonable and Effective
The Assistant Administrators submit a quarterly report
on Regional Performance to OMSE. The Assistant Administrators
send information copies to the Regional Administrators at
the same time they report to OMSE.
o This step provides for review by regional management
before performance is reported to the Administrator.
o The Regional Administrator notifies OMSE of exceptions
such as errors, oversights, or differences of inter-
pretation.
Change Procedures
are Appropriately Participatory
All regional performance targets are the Regional Admin-
istrator's personal commitments. The Regional Administrator
and the Assistant Administrator must concur in any changes.
o Prior to sending a change request to OMSE, the Regional
Administrator sends an advance copy to the appropriate
Assistant Administrator.
o The Assistant Administrator recommends approval or
denial of the Regional Adminisrtators requested change.
o Where all parties, i.e., the Regional Administrators
Assistant Administrator, and Deputy Administrator
(represented by OMSE) agree, the change is entered into
the MAS.
o Disagreements will be resolved through an appeals pro-
cess like the one used during commitment negotiations
at the beginning of the year.
Therefore, we recommend that the Administrator adopt the
following policy statement:
1 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.
A DISCIPLINED AGENCYWIDE DIRECTIVES
SYSTEM DOES NOT EXIST
Supporting the Agency's annual guidance process are sys-
tems for promulgating more permanent Agency guidance, includ-
17
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ing those policies covered by the EPA Directives System.
The System contains an Agencywide numbering scheme for index-
ing major policies for all program areas. The EPA Directives
Manual outlines a systematic process for preparing all Agency
operating policies and procedures.
Historically, program offices have not used the Agencywide
system, preferring to develop their own processes or working
without permanent policy directives. Currently, only two
Headquarters offices (OA and OPRM) use the Directives System
extensively. Of the forty-one manuals contained in the System,
only one the Toxics Substances Control Act (TSCA) Confiden-
tial Business Information Manual addresses a programmatic
area. Numerous policy directives are addressed from Head-
quarters program managers directly to regional division
directors; a system which by passes the Regional Administrators
and others with relevant multi-media responsibilities.
Nowhere in Headquarters, Regions, or States does a
complete record of Agency policy issuances exist. This lack
of a disciplined Agency directives system contributes to
the perception on the part of some Regions that Headquarters
programs occasionally ignore Regional Administrators and
deal directly with their regional counterparts. Some programs
maintain their own formal system; others do not.
Some argue that general program and technical promulga-
tions should continue to be handled independently from pro-
gram and management guidance, accountability systems and
evaluations. While this has been the traditional practice
for most programs, cursory review of the general and technical
documents indicates a close relation between those materials
and guidance and accountability issuances. Further, these
general and technical issuances establish the operating
context within which annual program and management guidance
must be implemented. Viewed from an external perspective,
the current diverse range of issuances presents a complex
mosaic that can undermine public understanding, Agency credi-
bility and reasonable accountability to the public.
t
A more disciplined Directives System is discussed again
under "program-specific approaches".
EFFECTIVE PROGRAM GUIDANCE, ACCOUNTABILITY, AND
EVALUATION SYSTEMS HAVE COMMON CHARACTERISTICS
Although no mandatory Agency System exists, Headquarters
program offices have tended to use five formal approaches in
issuing guidance, explaining policies, and assessing perfor-
mance of Regions. The following chart shows common approaches
used by each program office:
18
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Office
OW
OSWER
OPTS
OA
OANR
Program Guidance
Annual
X
X
X
X
Permanent
Policy
partial
partial
X
X
National
Meetings
X
X
X
X
X
Reporting
System
X
X
X
X
X
Formal
Evaluation
X
partial
X
partial
partial
The annual program guidance sets national direction and
emphasizes priorities for the forthcoming year. Permanent
Policy Systems contain basic operating policies which are not
expected to change appreciably from year to year. Through
national meetings, Headquarters staff and Regions share prob-
lems and gain a better understanding. Reporting systems
contain commitments/ accomplishments and performance measures
for Regions and States. Evaluations are conducted at regional
offices by Headquarters programs. The following sections
describe these five approaches.
Effective Annual Program Guidance Communicates Priorities
and Integrates Program Activities
Programs have issued annual guidance in one form or another
for many years. Issuance of the annual program guidance
signals the start of program planning by Regions and States.
The following features in annual guidance stand out as being
most useful.
o Annual program guidance should clearly relate to the
Administrator's Guidance. The areas highlighted by
the Administrator need to be translated into practical
program activities, expressed as national priorities.
o Program guidance should be practical in orientation
and provide the basis for regional and State program
plans. Regional Administrators and, as needed, the
States should have early and full participation
during development.
19
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o Annual program guidance should be distributed in ad-
vance draft form in February with finishing touches
added in April so that States can use it in preparing
workplans.
o Annual guidance should address all formal overview
activities and integrate them into a single program.
Performance measures should reference the MAS, where
appropriate. The measures should be appropriately
quantitative and qualitative and generally establish
how Regions will be evaluated.
o Regions have responsibility, as needed, for including
in the guidance system activities of delegated States.
Headquarters has the responsibility for providing sched-
ules of major policies and technical standards that
affect the conduct of regional activities.
Permanent Policy Systems Have Not Been Used Consistently
In Providing Guidance for the Continuing Conduct
of Mission Activities"
Permanent policy systems contain program-specific, national
policy documents which provide direction to regional and State
managers. As contrasted to annual guidance documents, these
are relatively permanent documents which remain in effect un-
til they are specifically terminated or superseded by updated
issuances.
Instead of using the EPA Directives System, program offices
have chosen either to create and maintain their own systems
or just to issue ad hoc policies through memoranda to Regional
Administrators or direc egional program managers. The
completeness of such systems varies not only within an indivi-
dual Assistant Administrator's jurisdiction, but also within
a single program. Air (OAPQS) and Superfund (OSWER) have
been commended by the Regions for maintaining useful permanent
policy systems.
Regional managers consider a formalized system for com-
municating policy necessary to aid them in interpreting
regulations. Absent a central Agency system, some individual
program managers keep their personal desk set of policy
issuances for their programs. Others are often unaware of
these policies.
The permanent policy and guidance systems of each major
program are summarized in Figure B.
20
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The most useful systems have the following traits:
o Documents are numbered, indexed, cross-referenced,
regularly updated, and readily available upon request.
Directions on replacing existing documents accompany
each new issuance.
o All segments of a program (i.e., permitting, compliance,
monitoring) are included in the system. Regions and
States participate in formulation of policies as they
are developed. A Headquarters contact for each
program area is listed. A central office for each
national program manages the guidance system to avoid
duplication and overlap.
o Issuance of new policies is accompanied by specific
operating procedures, and workshops are provided when
needed to ensure consistent implementation. Signature
authority for documents is delegated to the appropriate
Headquarters office level and distribution is appro-
priate and constant.
The major issues identified relate to the basic organiza-
tional structure, mechanics and completeness of issuance sys-
tems. Significant problems of content conflict among programs
have not been identified and existing coordination processes
should be adequate to avoid duplication and inconsistencies.
Therefore, we recommend that the Administrator adopt the
following policy statement:
1 The Management and Organization Division (MOD) should
be directed to administer an integrated EPA Directives
System with regional/program participation. MOD
would upgrade and administer the system to keep current
a central repository of Agency directives including
those not currently incorporated in the formal direc-
tives 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 Adminis-
trators should maintain current authority to develop
and approve program specific documents while adhering
to the mechanics of the Agency directives system.
MAS and Program Accountability
Should Be Mutually Reinforcing
and the Reporting Burden Should Controlled
Accountability systems employed by programs, and program
objectives contained in the MAS, should be mutually reinforcing,
Regions report two major problems concerning program account-
ability:
21
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o Regional Administrators have occasionally been left
out of negotiations between Headquarters and regional
programs on regional commitments.
0 The reporting burden required by some programs is greater
than the Regions believe is necessary.
The first issue has been addressed by OMSE's work on the
MAS. However, the concern with the reporting burden is
still the subject of considerable discussion.
Programs have generally been permitted to develop their
own reporting requirements provided they fulfill the require-
ments of MAS. Some Regions complain that, absent a central
control point, programs have no incentive to limit the report-
ing burden. What occurs is that programs add a few items
annually without eliminating previous requirements. While
none of the new items may be burdensome in themselves, the
cumulative reporting load becomes increasingly heavy.
Items reported through national computerized data systems
are not a problem since many of these items are routinely
gathered for internal management use. While the computerized
data systems probably should be streamlined, new manual
requirements are the source of most complaints. The problem
is most serious when Regions must rely on the cooperation of
States to gather the data. While regional managers recognize
the legitimate needs of National Program Managers for data,
they believe legitimate needs at times are confused with
information of convenience. The cumulative effect of all
programs upon a Region is not well understood or considered
when Headquarters asks for additional data.
Despite this one problem area, many programs do have very
good systems for collecting data and reporting on regional
(and State) activities. The program reporting systems employed
by the major programs are identified in Figure C. Features
of these reporting systems are:
o Systems contain both programmatic data (e.g., source
compliance) and management data (e.g., quantitative
measures of accountability). These measures provide
the basis for Headquarters evaluations of Regions and
regional evaluation of States.
o Negotiations and reporting communications flow from
Headquarters program to regional programs, but Regional
Administrators and State Directors retain final appro-
val authority over accountability measures and repor-
ting requirements. Formal reporting occurs quarterly.
22
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Therefore/ we recommend that the Administrator adopt the
following policy statement:
1 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.
Regional Program Evaluations Should Apprise Head-
quarters and the Regions on the General Conditions
of Regional Programs and the National Program
The following chart shows reporting systems employed by
major programs.
Evaluations of Regional Programs
PROGRAM
Air
Pesticides,
Toxics
RCRA
CERCLA
Water
Administration
CHARACTERISTICS OF EVALUATION
Only Air Enforcement now conducts evaluations.
Representation by all HQ offices is needed to give
is needed to give balanced evaluation.
HQ audits Regions annually with indepth look every
with indepth look every two years.
Had first formal evaluation recently. It was help-
ful, but needs to go into more detail such as ac-
tually looking at permits issued by Regions and
States
None .
Conducts coordinated mid-year evaluations of all
water programs based on the quantitative and
qualitative measures in the annual accountability
system. Regions do an initial self evaluation;
Water then does on-site evaluations consisting of
a technical review followed by a senior management
review.
Personnel Management evaluations have been
conducted. Grants Management evaluations are more
recent.
Most Headquarters program offices conduct some form of
annual on-site evaluation of regional performance. These
evaluations are similar to State program evaluations which
many Regions conduct.
23
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The principal purpose of these evaluations is to apprise
Headquarters on the general condition of a regional program
and to provide the basis for assessment of the national
program. Generally, regional managers believe objective
evaluations conducted by Headquarters are helpful in managing
programs.
Therefore, we recommend that the Administrator adopt the
following policy statement:
1 Comprehensive periodic evaluations of program results
are essential for decentralized operations and should
be standard practice for every program.
24
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III. WE SHOULD ENCOURAGE GREATER REGIONAL
INVOLVEMENT IN PLANNING AND BUDGETING
The objective of this aspect of the Review was 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 aspects of Agency program needs.
THE BUDGET DEVELOPMENT PROCESS
RELIES ON STRONG NATIONAL PROGRAM MANAGER LEADERSHIP
AND ACTIVE PARTICIPATION OF A DESIGNATED LEAD REGION
With the development of the FY 1983 budget, the Zero Based
Budgeting process, with its layers of review and ranking
teams, was replaced 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 in the budget hearings themselves. The lead Region
concept evolved as an efficient, productive method to repre-
sent regional concerns and interests in the new process.
The new approach relies on strong National Program Manager
leadership and well prepared regional representatives propos-
ing and defending resource levels to the Administrator and
top Agency management.
Note: The National Academy of Public Administration is
conducting an in-depth review of the Agency's planning and
budgeting process. Therefore, the scope of the present
Review has been drawn very narrowly and is limited to issues
of regional involvement in the budget development process.
A number of broader issues were identified during the
Review process which could be addressed in the NAPA study.
These
include:
1. The linkage between program planning budget develop-
ment; and, separation of program planning from the
technical budget process.
2. The amount of regional flexibility in budget implemen-
tation.
3. The adaptation of the process to changing regional
program priorities.
4. The role of workload models and appropriate methods
and procedures to account for expenditure of funds.
25
-------
The National Program Manager is charged with developing
the request for the regional component of his or her program
in conjunction with the lead Region for each media. The lead
Deputy Regional Administrator is charged with becoming the
media "experts" and with objectively representing the ten
regional program needs and viewpoints, while at the same
time maintaining a national perspective on the program.
During the summer budget hearings, the lead Region repre-
sents all the regions as the NPM presents his or her budget
request before the Administrator and Deputy Administrator.
During the final preparation of the OMB request and the OMB
passback and appeal process, the regional interests are carried
largely by the Comptroller and the NPMs. The Comptroller's
Office is responsible for maintaining an information flow to
the Regions for each step of the process.
The lead DRAs play an active role as the workload model
process begins in January of each year. The workload models
define regional program activities and priorities and then
distribute regional workyears among the ten offices. The
National Program Managers are charged with keeping the lead
DRA involved throughout the workload development process.
The lead DRAs are charged with accurately representing the
needs and views of all ten regional offices and avoiding
parochial views.
REGIONS HAVE SOME CONCERNS
WITH THE CURRENT PROCESS
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
involvement to total exclusion.
o The degree of lead DRA participation varies greatly
depending on a number of factors including time and
staff availability.
o Lead Regions are in a "reactive" mode from the very
start of the process; very few NPMs involve the regions
in the initial development of the regional budget
request. For the most part, the Regions see NPM
drafts or initial allocations after the NPM has virtu-
ally finalized his or her decisions. Scarce regional
resources make it difficult for Regions to react in a
short timeframe.
26
-------
o Lead Regions are not in a strong enough position to
have much impact on Headquarters/Regional splits in
allocation of resources because budget guidance for
program development is unclear.
o Some lead Regions involve their fellow Regions early
in the development of the request, others involve
their counterparts too late in the process or not at
all. The process lacks structure. Non-lead Regions
who see the budget requests for the first time in
final form are presented with a "fait accompli" which
is difficult to change.
o The scrutiny which regional programs receive by Head-
quarters offices should be balanced Regions should
have an opportunity to examine Headquarters resource
allocations and comment on them.
o Since the "targets," issued at the start of the process
are at the NPM level, there is a tendency to think of
an increase in the regional program as being at "the
expense" of a Headquarters program or vice versa. As
a result, there is a tendency to make changes at the
margin rather than to discuss the merits of resource
specific allocations.
o Regions don't always know if budget comments will have
an effect until the final agency budget is prepared.
The NPM is charged with identifying and prioritizing regional
program activities and then distributing finite regional
resources among the ten regional offices, this workload
model process is of crucial importance to the Regions, but
there is no incentive for the NPM to allocate top policy
staff to the process.
Headquarters offices' reaction to criticisms of non-
involvement is usually defensive, e.g., there is insufficient
time scheduled in the budget development process to allow for
full involvement by regional staff; there are cross-country
difficulties in communication.
OUR RECOMMENDATIONS WILL
STRENGTHEN THE CURRENT PROCESS
The National Program Manager and lead region concept rests
on the assumption that as soon as the NPM receives the
Administrator's program guidance, he or she sets specific
policy and direction for the program at a national level
with regional input. The Regional Administrator's role is
to implement that policy.
27
-------
With a few dissenting opinions, there is a consensus among
regional and Headquarters managers that the current lead Region
process can and does work when two essential commitments exist:
o First, the NPM assures regional involvement, schedules
the time, listens, is open and collegial.
o Second, the lead Region takes the time to be informed
and is willing to do the legwork and the travel neces-
sary for active participation.
Water has been cited almost uniformly as the most success-
ful Headquarters office in seeking open and complete involve-
ment from the Regions; clearly a great deal of the credit
must go to the lead Region as well. The partnership works
only when the commitment exists on both sides.
However, the current process permits, without penalty and
even quite openly, an essential part of the budget development
process to simply not happen: with schedules, forms and de-
tailed instructions for every other part of the process, an
NPM or a lead Region may still choose not to communicate
with each other at the very start of the process.
The recommendations outlined below would strengthen and
provide structure to the lead Region concept rather than
substantially revamp it. They assume that the Assistant
Administrators of the Agency, in their roles as National
Program Managers, have the responsibility for budgeting for
their programs at the national level and, in the process,
shaping the policies, directions and resource levels of the
regional programs.
The extent of the Regions' role in the budget and planning
process depends primarily on the degree to which this adminis-
tration intends that Regional Administrators influence the
national policy and direction of a program as well as carry
out its implementation. We feel that the recommendations
presented here would ensure that regional concerns are heard,
without weakening the pre-eminent role of the National Program
Manager in the development and presentation of his/her budget
recommendations.
Responsibilities of the National Program Manager and Lead
Deputy Regional Administrator Should Be Better Defined
As noted earlier, there is little formal guidance to the
NPM or lead Regions on how effective regional involvement is
to be achieved. The resulting inconsistency could be limited
by formalizing internal budget development procedures.
Specifically, this could be accomplished by the Deputy
28
-------
Administrator through issuance of schedules, specification
of interim products, and definition of a detailed process
for development of the budget by the NPM. This would define
the nature of involvement by the lead Region and the nature
and timing of involvement of non-lead Regions. The final
NPM budget submission would be accompanied by a memorandum
from the lead Region expressing the regional view of issues
in the regional as well as Headquarters portion of the
request.
The benefit of this approach is that the nature of regional
involvement would not be left to chance or personal preference.
However, the NPMs may resent having a structure imposed on
their internal decision-making process. Care should be taken
that the process for involvement which is issued is flexible
and adaptable so that current NPM procedures which are suc-
cessful are not pre-empted.
Therefore, we recommend that the Administrator adopt the
following policy statement:
K General performance expectations during the initial
stages of the budget development process for both the
NPM and lead Region should be clearly defined and re-
gional viewpoints should be formally recognized in
the NPM budget presentation.
Regional Budget Development Meetings
Should Be Held Prior to Development
of the National Program Managers Submission
and Before Finalization of the Administrator's Budget
An additional technique to promote full involvement of
all Regions would be to schedule meetings of regional repre-
sentatives to discuss, define and prioritize resource require-
ments.
If the sessions were held during the spring of each
year, DRAs could meet to discuss program by program (within
the constraints of the Administrator's Guidance) their
perception of current shortfalls, where programs are going
and optimum levels for each program. This analysis would
include their view of directions and resource requirements
for Headquarters programs as well. The host for these
meetings (Comptroller) would record, analyze and notify each
NPM of results early enough to permit incorporation of regional
thinking into the development of the NPM submissions. The
lead Region would have guidance and benefit of thinking from
all other Regions on program levels and would be charged
with assuring that the NPM considers the results of the
29
-------
regional review. This meeting could be incorporated into
the Comptroller/DRA midyear review meeting which takes place
in April of each year.
We recommend that the Administrator adopt the following
policy statement:
1 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.
This summer, a regional budget hearing with the Deputy
Administrator was held for the second year. Each lead Region
presented the outstanding budget issues in his or her lead
media, several cross-cutting issues were discussed, and the
relative importance of various program increases was developed.
It was generally agreed to be a valuable addition to the
budget hearing process.
The Associate Administrator for Regional Operations be-
lieves that a critical element in effective decentralized
management is to ensure that Regional Administrators, as
generalist policy officers, present their views on both
media-specific and crosscutting budget issues.
Therefore, we recommend that the Administrator adopt the
following policy statement:
1 The Deputy Administrator should convene an annual hear-
ing to provide Regional Administrators the opportunity
to present their views on both media-specific and cross-
cutting budget issues. The hearing should be held
following submission of National Program Manager budget
submissions to the Comptroller, but prior to finaliza-
tion of the Administrator's budget proposal,
The Lead Region Selection Process Should be Broadened
The Assistant Administrator for Administration and the
Comptroller are solely responsible for designating "lead Re-
gions". Extension of the selection process to include regional
officials, NPMs and other senior policy officials could be
beneficial.
A revised process could include having each Region select
a priority list of three media they would like to be lead
and making the selection based on Regions' and NPMs' desires
with final approval of the Deputy Administrator. By including
NPMs in the selection of the lead Region, the likelihood of
a good working relationship between the Region and NPM will
be enhanced. The final selections would be approved by the
Deputy Administrator.
30
-------
The Comptroller believes that his office is better able
to assess the program strengths of individual regions which
enables him to effectively broker this selection process,
Therefore, we recommend adoption of the following policy state-
ment:
f The Comptroller should lead a broadened process for
selection of lead Regions to work with each National
Program Manager. The expanded process will include
active participation of regional officials, National
Program Managers, and the Associate Administrator for
Regional Operations, with final approval by the Deputy
Administrator.
Regional Participation In the Budget Development Process
Should be Expanded
As a technique to further ensure that regional concerns
are fully considered in the final steps of the budget develop-
ment process, senior regional personnel could be designated
to work with the Comptroller. Several regional people,
either the Deputy Regional Administrator, Associate Regional
Administrator, or Management Division Director would spend
the period immediately prior to and after the budget hearings
participating in the budget process; identifying and collec-
ting regional issues, preparing regional presentations and
generally insuring that regional issues are heard. During
the OMB Passback and Appeal process, the same people would
return to Headquarters to continue their participation. The
additional analytic activity, focused entirely on regional
program issues selected by the Regions themselves, would
ensure that regional concerns are voiced.
However, since the Comptroller is charged with devel-
oping and implementing the budget process in a manner which
protects the Administrator's options and his ability to make
budget decisions in a manner unconstrained by forces outside
the Agency. The scope and nature of all staff involvement
Headquarters or regionalin the process should be defined
by his Office
Therefore, we recommend adoption of the following policy state-
ment:
1 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.
31
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IV. REGIONAL ORGANIZATIONAL STRUCTURE SHOULD NOT BE
CHANGED EXTENSIVELY AT THIS TIME
The Environmental Protection Agency has maintained since
its inception a relatively unchange Regional organization
structure. Our Review suggest that the current standard
regional organization is working adequately given current
resource allocations and functional relationships to Headquar-
ters. Major revisions at this time are not warranted, however,
our Review suggests that the Regional Counsel and Environmental
Services Division issues 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.
For the most part, the flexibility provided in the current
standard meets 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 within current Agency rules and practices) in formally
structuring staff activities, such as Congressional and
Intergovernmental Relations, Public Affairs, and Civil Rights
with their placement as staff to the Regional Administrator,
Deputy Regional Administrator, Associate Regional Administrator,
or Management Division Director.
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
Administrator. The current standard regional organization
is being modified to provide for appropriate changes in
reporting lines.
32
-------
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 capabili-
ties in most of the Regions, was raised as an area of concern
by many people. Several Regions believe ESD 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 provid-
ing clear lines of communication between ESD 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 con-
text of legal/enforcement and air/waste alignments in the
regional offices. In addition, the possible effects of
laboratory consolidation and the impact of increased contrac-
ting and automation are important factors.
While theoretically it is possible to move the ESD func-
tion into the respective program Divisions, it is probably
impractical because of the interdependence between field
and lab staff, and because of the need to maintain a critical
mass 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 allo-
cations.
33
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Figure A
DISTRIBUTION OF RESPONSIBILITIES - DECENTRALIZED ACTIVITIES
HEADQUARTERS
ESTABLISHES POLICY
REGIONS
EXECUTES POLICY
STATES
IMPLEMENTS PROGRAM
0 interpret national
objectives
j ° establisn regional objectives
j ° establisn strategy for
J interaction witn States
I
establish operational capability
i° define State objectives
1
' establish basic
requirements
0 assign responsibilities
0 delegate EPA authorities
|
' ° provide guidance
0 communicate program requirements
t
0 negotiate State/EPA agreements
as to responsibilities
0 execute EPA authorities
or devolve to States
0 assist States in building
0 manage the State program
* agree to specific outputs -
meet requirements
0 negotiate/meet responsibilities
0 execute authorities
capabi lities
0 maintain capabilities
establish boundaries of
flexibility
0 recognize State constraints
(e.g. budget packages. State
legislation, etc.)
|° inform Region of proolers/
j needs unique to State in
carrying out program
0 request resources
0 allocate resources
" establish basic reporting
requirements
e allocate resources
0 reach agreement on fund support
0 negotiate States' reporting
requirements
° provide matching funds
0 negotiate reporting requirements
negotiate outputs
0 negotiate outputs
I° negotiate outputs
° monitorresults
' monitor State progress
0 report results to KQ.
report results against ot
-------
Appendix A
DELEGATIONS OF EPA AUTHORITIES BY ACTIVITY
AUTHORITY
DELEGATION
1 TITLE
CITATION
DELEGATEE
HDQRS RAs
I. DIRECT PROGRAM ADMINISTRATION
a. PERMITTING
2-1
2-6
2-7
2-11
2-16
2-17
2-18
2-19
2-20
2-21
2-23
2-24
2-37
2-44
3-2
3-3
3-4
3-5
3-6
4-1
Storage Facilities
WWT Construction Grants
Advanced Construction Grants
Waste Loads
Clean Lakes Program
Thermal Discharge
Aquaculture
Federal License or Permits
NPDES
Monitoring State Permit Programs
Contained Dredging Spoil
Facilities
Sewage Sludge Permit Program
Vessel Waste Management
Decisions on Eligibility for
Secondary Treatment Variances
Ocean Dumping Permits
Ocean Dumping Sites
Research and Emergency Ocean
Dumping Permits
Denial of Ocean Dumping of
Dredged Materials
Research and Special Incineration
at Sea Permits
Liberty Ships
102(b)(3)
201
206
303(d)
314 (b)
316(a)
318(a)
401(a)&(b)
402
402(d)(l)&(2)
404
405
312(F)(3)
301(h)
102,104
102
102,104
103(c)
3
X
X
X
X
OW X
X
X
X
X
X
II,III
X
OW
X
X
OW
OW X
X
OW
X
-------
AUTHORITY
DELEGATION
7-3
7-4
7-24
8-6
8-19
9-1
9-8
b.
2-28
5-1
5-2
5-3
5-8
5-33
7-12
7-13
7-26
9-9
11-3
11-8
# TITLE
New Hazardous Source Review
Haz. Emission Source Waivers
Implementation Procedures for
Preconstruction Review
Permits for Treatment, Storage,
or Disposal of Hazardous Waste
De-Listing Petitions (Exclude
Particular Waste and Source
Certify Potable Water Supplies
Variances Review and Issuance
Product Review and Registration
Letters of Acceptance
- Chemical Agents
Registration
Certification of Applicators
Experimental Use Permits
Registration of Establishments
Supplemental Registrations
Tampering Restriction Exemption
Uncertified Vehicles
Tanpering Restriction Exemption
Registration of Fuels and
Fuel Additives
Exemption Receipt and Issuance
Product Exemptions
Low-Noise Product (LNEP)
CITATION
112(c)(l)(A
112(c)(l)(B
40 CFR 52
3005
3001 &
7004
361
1415
311(c)(2)(G)
3
4
5
7
3(e)
203(b)(l)
203(c)
211(a) & (b)
1416
10(b)(l)
DELEGATES
HDQRS RAS
X
X
X
X
OSWER
X
X
OSWER
OPTS
X
OPTS
OPTS X
X
OANR
OANR
ORD
X
OANR
OANR
Certification
12-16 Granting Exemptions from
Test Rules
15
4(a)
OPTS
-------
AUTHORITY
DELEGATION
12-18
c.
14-1-A
14-1-B
14-2-A
14-2-B
14-3
14-4-A
14-4-B
14-4-C
14-5
14-7
d.
2-13
2-14-A
2-14-B
2-14-C
2-14-D
2-15
2-22
2-30
# TITLE CITATION
Petitions for Exemptions fron
PCB Ban
DELEGATEE
HDQRS RAs
OPTS
Hazardous Substance Emergency Response and Site Management
Immediate Removal Actions 104 (a)
Planned Removal Actions 104(a)
Continued Removal Actions 104(c)(l)
Continued Removal Obligations
Removal Contracts and Coop Agrmts
Planning Remedial Actions 104(a)&(c)
Select Initial Remedial Measures
Remedial Contracts & Coop Agrrats
Select Remedial Actions
Combination of Facilities
Compliance and Enforcement
Inspections and Information 308
Gathering
Enforcement, Civil Judicial 309,311,
402(h)
Enforcement, Criminal 309(c),
311(b)5
Settlement/Concurrence - Civil
Judicial Actions NA
Emergency Restraining Orders 309,311,402
504 & 506
Oil/Hazardous Spill Threat 311 (e)
Administrative Enforcement 403 (b)
Listing/Delisting Violating
OSWER X
OSWER
OSWER
OSWER
OSWER
OSWER
OSWER X
OSWER X
OSWER
OSWER
OLEC X
OLEC
OLEC
OLEC X
OLEC X
OLEC
OW X
Facilities 508
3-1-A Ocean Dumping - Complaints and
Consent Agreements 105
OLEC
OW
-------
AUTHORITY
DELEGATION
3-1-B
3-1-C
5-4
5-5
5-7
5-9
5-12
5-14
5-15-A
5-15-B
5-16
5-17-A
5-17-B
5-17-C
5-17-D
5-18
7-6
7-8
7-10
7-11
7-16
7-17
1 TITLE
Ocean Duitping - Agency Repre-
sentation in Hearings and
signing Consent Agreements
Ocean Dumping - Issuance of
Consent and Final Orders
Use of Pesticides Under
Experimental Use Permits
Revocation of Experimental Use
Permits
Cancellation and Suspension
Inspections of Books and Records
Stop Sale, Use or Removal Order
Issuance of Complaints and
Signing of Consent Agreements
Agency Representation in Hearings;
Signing of Consent Agreements
Issuance of Consent and Final
Orders
Indemnity Payments
Civil Actions
Criminal Actions
Settlement or Concurrence
Emergency TRO's
Publication of Judgments
Adm. Enforcement Section 113
Inspections and Information
Gathering
Determination of Confidentiality
Energy Related Authorities
Mtr. Vehicle Mfgrs. Inspectors
Mtr. Vehicle Mfgrs. Record
CITATION
105
NA
5(C)
5(e)
6
8
13(a)&(b)
9(c)&14
9(c)&14
15
16
9(c),12&14(b)
NA
16 (c)
16(d)
113(a)
114,203,206(c)
208(a) & 211
119(c)&(d)
206(c)
DELEGATES
HDQRS RAs
OLEC
HQJO X
OPTS X
OPTS
OPTS
OPTS/ X
OPTS X
OPTS X
OLEC
HQJO X
OPTS
OLEC
OLEC
OLEC
OLEC X
OPTS
OANR X
OLEC/
OANR
OLEC
OANR X
OANR
Maintenance and Access Req.
208
OANR
-------
AUTHORITY
DELEGATION
7-18
7-19
7-22-A
7-22-B
7-22-C
7-22-D
7-29
7-30
7-31
7-32
7-33
7-34
7-37
7-38
7-41-A
7-4 1-B
7-41-C
7-42
7-43
I TITLE
Determination - Confidentiality
Mitigation, Remittance or
Settlement of Penalties
Civil Judicial Enforcement
Criminal Enforcement
Settlement or Concurrence
in Settlement
Emergency TRO's
Listing/Delisting violating
Facilities
Mtr.Vehicle/engine Enforcement
Auditing Procedures
Recall Remedial Plans
Fuels/Additives Regulations
Subpoenas and Oaths
Fuel and Fuel Additives
New Source Review Orders
Prevention of Significant
Deterioration:
Assessment and Signing of
Consent Agreements
Agency Representation
Issuance of Consent
Orders and Final Orders
Assessment vice State Action
Granting of Exenptions
CITATION
208(b)
211{d)
113(b),204,205
302(a)(2)&305
113(c)(l)&(2)
NA
113(b),204 &
205
306
206(b)(l)
207(c)
211(s), (b)
(C) & (d)
307(a)(l)
211(f)
110(a)(2)(I)
113(a)(5) &
129(a)(l)
107(d)(l)(D)
107(d)(l)(E)
120(a)(2)(A)
120
?
120(a)(A)
& (B)
120(a)(2)(B)
DELEGATEE
HDQRS RAs
OLEC
OLEC
OLEC
OLEC
OLEC
OLEC X
OLEC
OANR
OANR
OANR
OANR
OLEC
OANR X
OANR X
OLEC
OLEC
HQJO X
OANR X
OANR X
-------
AUTHORITY
DELEGATION 1
7-44
7-45
7-46
7-47
7-49
7-50
7-51
8-5
8-8
8-9-A
8-9-B
8-9-C
8-10-A
8-10-B
8-10-C
8-10-D
8-12
8-20
8-22
9-4
TITLE
De Minimis Exemptions
Notice of Nonccrpliance
Review of Expenditures and
Adjustment of Penalty
Independent Calculation
Emergency Admin. Powers
Emissions Recall Determination
Enforcement Audit Failures
CITATION
120
120
120(b)(8)&(9)
120(d)(4)
120 (c)
303
207(c)(l)
206(b)(2)
DELEGATEE
HDQRS
OANR
OANR
OANR
OANR
OANR
OANR
Reports on Quantities and 3002,3003,
Disposition of Hazardous Waste 3004&3005
Inspections and Info. Gathering
Compliants, Consent Agreements
Representation in Hearings -
Signing Consent Agreements
Consent and Final Orders
Civil Judicial Enforcement
Criminal Enforcement
Settlement/Concurrence - Civil
Judicial Actions
Emergency TRO's
Notification - Hazardous
Waste Movement Reporting
Monitoring, Testing, Analysis
and Reporting
Imninent Hazard Admin. Orders
State Primary Enforcement
3001(b)(3)(B)
& 3007
3001(b)(3)(B)
3001(b)(3)
(B)(V)&3008
NA
3008,3013
3008(d)&(e)
NA
3008,3013 &
& 7003
3010
3013
7003(a)
OLEC/
OSWER
OSWER
OLEC
HQJO
OLEC
OLEC
OLEC
OLEC
OSWER
OSWER
OSWER
RAs
X
X
X
X
X
X
X
X
X
X
X
X
Responsibility, Determination 1413
9-5 Primary Enforcement
Responsibility, Annual Review 1413
-------
AinHORITY
DELEGATION t
9-7
9-12
9-16-A
9-16-B
9-16-C
9-16-D
9-17
11-1
11-2
11-5
11-6-A
11-6-B
11-6-C
11-6-D
11-7
11-9
12-1
12-2-A
12-2-B
12-2-C
12-3-A
12-3-B
12-3-C
TITLE
Federal Enforcement
Inspections and Info. Gathering
Civil Judicial Enforcement
Criminal Enforcement
Settlement or Concurrence -
Civil Judicial Actions
Emergency TKO's
Emergency Administrative Powers
Inspect/Info Gathering
Require Manufacturers to Test
Administrative Orders
Civil Judicial Enforcement
Criminal Enforcement
Settlement/Concurrence -
Civil Judicial Actions
Emergency TRO's
Subpoenas and Oaths
Post Certification Testing
Inspections and Subpoenas
Issuance Complaints and
Signing Consent Agreements
Agency Rep in Hearings and
Consent Agreements
Issue Consent/Final Orders
Civil Judicial Enforcement
Criminal Enforcement
Settlement/Concurrence
CITATION
1414
1445
1450(f)
1414 (c)
NA
1431,1450(f)
1431
13(a)
13(a)
ll(d)(l)
ll(c)&(d)
ll(a)&(b)
NA
ll(c) 7 (d)
16(a)
15(f)
ll(a)&(c)
15,16
16
NA
17(a)&(b)
15 & 16(b)
DELEGATEE
HDQRS RAs
X
OW/OLEC X
OLEC
OLEC
OLEC
OLEC X
OW X
OANR
OLEC X
OANR
OANR X
OLEC
OLEC
OLEC
X
OANR
OLEC
OANR
OPTS
OLEC X
OPTS X
OLEC
HQJO X
OLEC
OLEC
Civil Judicial Actions
NA
OLEC
-------
8
AUTHORITY
DELEGATION I
12-3-D
12-3-E
12-11
14-6
14-8-B
14-10-B
14-12
14-13-A
14-13-B
14-13-C
14-14
14-17
TITLE
Emergency TRO'S
Imminent Hazard Actions
Protection Against Unreasonable
Risks
Inspections and Information
Gathering
Studies and Investigations -
Cost Recovery and Enforcement
State Legal Assistance
Civil Judicial Enforcement
Criminal Enforcement
Settlement/concurrence - Civil
Judicial Actions
Emergency TRO's
Admin. Determination and
Abatement Actions
Guidelines for Use of Imminent
Hazard, Enforcement and
Emergency Response Authority
CITATION
17(a)&(b)
7
5
104(e)
104(b)
104(d)(3)
106(a),107(f)
112(c)(3)
103(b)(3)
103(c)&(d)
NA
106(a)&(b)
106(a)
106 (c)
DELEGATEE
HDQRS RAS
OLEC X
OLEC
OPTS
OSWER/
OLEC X
OLEC/
OSWER X
OLEC
OLEC
OLEC
OLEC
OSWER X
OLEC
e. Program Direction and Interpretation
1-1-AU2)
2-2
2-3-B
2-8
2-32
2-39
2-40
2-43
Interagency Agreements
Operator Training
State Program Grants
Areawide Planning Grants
Great Lakes - Lake Restoration
WPC - Professional Training
WPC - Fellowships
State Permitting Program
104(g)(l)
106
208(b)&(g)
104 (h)
104(g)(3)(A)
104(g)(3)(B)
AA, ODs X
OW X
X
X
OW X
OW/ORD
OW
Assistance Award
106
OFA
-------
AUTHORITY
DELEGATION
2-43
5-24
5-26
5-27
5-28
5-31
7-1
7-35
7-36
8-1-A
8-1-B
8-3
8-4
8-15
8-17
8-18
8-21
8-23
f TITLE
Water Quality Mgt. Planning
Grants
Soliciting Views
Interagency Cooperation
State Cooperative Agreements
Personnel and Facilities
State Cooperative Agreements
State Programs
Cooperative State Extension
Service (Interagency)
State and Interstate Program
and Planning Grants
APC Training Assistance
APC Fellowships
State Solid Waste Management
Plans/Programs
State Solid Waste Management
Grants
Resource Recovery and
Conservation Panels
Discarded Tire Disposal Grants
Distribution of $ Assistance
Within States
Technical Training
Management Training Assistance
Federal Agency Assistance
Cooperative Agreements for State
CITATION
205,208,303
21(a)&(b)
22(b)
23(a)(l)
23(a)(2)
23(c)
105
103(b)
103(b)(5)
3011
4008
2003
2004
4008,4009
7007(b)
8001(a)
6003
DELEGATES
HDQRS RAs
X
OPTS
OPTS X
OPTS
X
OPTS
X
OANR/
OANR
OSWER X
OSWER X
OSWER X
OSWER X
OSWER X
OSWER/ X
ORD
OSWER/
ORD/OPA
OLEC/OSWER
ORD X
Waste Site Inventories 3012
9-10 Providing Training Assistance
Info and Facilities 1442(b)
OW/OPA
-------
10
AUTHORITY
DELEGATION * TITLE
9-11 Approve Public Water System
Supervision Assistance
9-15 Occupational Training
10-1 Agency Connents/Recatinendations
11-10 Program Assistance Approval
12-9 State Agreements (Toxic
Substances Control Projects)
14-8-A Studies and Investigations -
Response Actions
14-11 State Expenditure Credits
14-15 Claims Against Funds
15-1 Certification Under Regulatory
Flexibility Act
II. TECHNICAL SUPPORT
c.
Direct Assistance - Person to Person
2-33 Alternate Test Procedures
5-13 Disposition of Pesticides
14-10-A State Technical Assistance
d.
2-4
8-16
9-13
2-31
e.
2-38
2-39
2-40
Special Projects
Great Lakes Demo. Agreements
Employment Shifts/Loss analysis
Rural Water Survey consultation
Great Lakes Program
Training
Water Pollution Control -
General Training
Water Pollution Control -
Professional Training
Water Pollution Control
CITATION
1443(a)
1442(b)&(d)
204(3)
14
28
104fb)
304(g)
13(c)
108
7001(e) &
3
5 U.S. C. 554
104(b)(3)
104(b)
104(g)
104 (g)
DELEGATEE
HDQRS RAs
X
OW/ORD X
X
OANR/ORD
OPTS
OSWER
OSWER
OSWER
AAs X
ORD X
OPTS X
OSWER X
iif in, rv
OSWER/
OW
OLEC
V
OW,ORD
OPA
OW,ORD
OW
Fellowships
-------
11
AUTHORITY
DELEGATION * TITLE
2-41
5-29
5-30
WPC - Technical Training
Interagency Applicator Training
Applicator Training Contracting
CITATION
109,1104111
23(b)
23(b)
DELEGATEE
HDQRS RAs
OW
OPTS X
X
III. STATE PROGRAM APPROVAL AND OVERSIGHT
a.
2-3
2-5
2-9
2-12
2-27
2-34
2-47
5-6
5-32
7-9
7-48
9-14
14-9
7-1-A
7-25
7-27
8-1-A
Review of State Programs/Plans/Delegation Applications
State Program Approval
State Certification WWT Grants
Areawide Plan
State Continuing Plans
Areawide Designation Approval
St. Permitting-Fed. Facilities
State General Permits Programs
State Programs for
Experimental Use Permits
State Registration for Special
Local Needs
Approval of State Procedures
Nonccmpliance Penalty-Delegation
to States
Monitoring Public Water Systems
State Consultation - Cooperative
Agreements and Contracts
State and Interstate Program
Approval
Delegation Authority for
Preconstruction Review
State Implementation Plan
Revision
State Solid Waste Management
Plans/Proqrams
106
Title II
208(b)&(g)
303(e)
208(a){7)
402
402
5(f)
24(c)
114(b)
120
40 CFR 149.29
104(c)&(d)
105
40 CFR 52.0
40 CFR 51
4007
X
X
X
X
X
OW
OW
X
X
X
OANR X
X
OSWER X
OANR X
X
X
X
-------
12
AUTHORITY
DELEGATION # TITLE CITATION
8-2 Interstate Solid Waste Mgt.
Agencies/Regions (Approval) 1005
8-7 State Hazardous Waste Program 3003,3006
Submittals & 3010
8-13 State Hazardous Waste Grants 3011
b. Review of Individual Proposed State Actions
2-45 Certification of Regulatory
Flexibility Act-State
Permitting of Fed. Fac. 313,402
5-22 Emergency Exemptions 18
7-28 Modification Attainment &
Maintenance Requirements 40 CFR 51
7-39 Economic Emergency Suspension 110 (g)
of SIP Requirements
7-2 Approval of State NSPS Plans lll(c)
7-5 Hazardous Emission Standards 112(d)
9-2 Approval of State Laboratories 1412
9-3 Certification of Laboratories &
State Officials 1412
9-6 Primary enforcement
Responsibility Reporting 1413
9-9 Receipt and Issuance of 1416
Exemptions
13-1 Comment on Recommendation for
River Designations 4(c)
IV. REARCH
a. Standard-Setting Support
5-23 Research 20 (a)
V. STANDARD-SETTING
a. Listing Decisions/Designation Activities
DELEGATEE
HDQRS RAs
X
X
X
cw
OPTS
X
OLEC X
X
X
X
X
X
X
X
ORD
2-10 Water Quality Standards 303{a)&(c)
-------
13
AUTHORITY
DELEGATION 1 TITLE
2-35
2-36
5-19
5-20
5-21
6-1
6-2
6-3
8-14
12-4
12-5
12-6
12-7
12-8
12-10
12-14
13-1
b.
2-29
Exclusion of Certain Pollutants
and Point Sources
State Requests for Population
Projection Variances
Importation Activities
Notification of State Dept.
Consultation with Treasury
Prescribing Tolerances for
Poisons
Prescribing Tolerances for
Pesticides
Prescribing Safe Use of
Food Additives
Inventory Open Dumps
Health/Safety Study Rules
Notice of Receipt -
Preraanufacture Notice/Data
Monthly Premanufacture Notices
Summary
Premarket Notice Exemption
Preraanufacture Notice Period
Extension
Regulation Pending the
Development of Information
Notice of Receipt of Test Data
Comments on Wild and Scenic
River Designations
Technical Regulations
Spill Prevention Control
and Countermeasure Plan
DELEGATES
CITATION
301,304
40 CFR 35,
8(a)l
17(a)&(c)
17(b)
17(e)
346
346(a)
348
4005
8(d)
5(d)(2)
5(d)(3)
5(h)(6)
5(c)
5(e)
4
4{c)
311(j)(l)(c)
HDQRS
OW
OW
OPTS
OPTS
OPTS
OPTS
OPTS
OPTS
OSWER
OPTS
OPTS
OPTS
OPTS
OPTS
OPTS
OPTS
OSWER
RAS
XX
X
X
VI. MANAGEMENT SUPPORT
a.
Policy Activities
5-25 Administering Oaths
22(a)
OPTS
-------
14
AUTHORITY
DELEGATION
*
TITLE
CITATION
DELEGATES
HDQRS RAs
12-12 Preliminary Assessment
Information Reporting for
ITC Chemicals 8(a) OPTS
12-13 Approval and Annual Review of 4(a) OPTS
Testing Protocols
12-20 Adoption of Study Plans 4(a) OPTS
c. Administrative Regulations
12-15 Notices of Receipt of ITC
Reports 4{e) OPTS
12-17 Notices of Receipt of Intended
Change of Study Plans 4(a) OPTS
-------
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-------
Attachment 1
LIST OF TASK FORCE PARTICIPANTS
CHAIRMAN
CO-PROJECT MANAGER
CO-PROJECT MANAGER
LEAD STAFF
Harvey Pippen
Thomas Hadd
Stephen Allbee
Paul Wagner
Thomas Nessmith
Steven Martin
Daiva Balkus
Donald Patton
James Vickery
PROJECT COORDINATORS
HEADQUARTERS
AIR Jack Hidinger
WATER Betsy Laroe
OSWER Thad Juszczak
R&D Mike Mastracci
ORO Barbara Ludden
OPTS Jake Mackenzie
REGIONS
Region I
Region II
Region III
Region IV
Region V
Region VI
Region VII
Region VIII
Region IX
Region X
Lou Gitto/
Pat Meaney
Herb Barrack/
Kathy Callahan
William Wisnieski/
Henry Brubaker
Tom Nessmith
Robert Springer
Myron Knudson
Gene Ramsey
Irv Dickstein
John Wise/
Charles Murray
Nora McGee
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