Everyone '$ lousiness:
Working Towards Sustainability
Through Environmental
Stewardship and Collaboration
National Advisory Council for
Environmental Policy and
Technology (NACEPT)


March 2008

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The National Advisory Council for Environmental Policy and Technology (NACEPT) is an
independent federal advisory committee that provides recommendations to the Administrator
of the U.S. Environmental Protection Agency (EPA) on a broad range of environmental
issues. This report has not been reviewed for approval  by the Agency,  and hence, the con-
tents of this report do not necessarily represent the views and policies  of the EPA, nor of
other agencies in the Executive Branch of the Federal Government, nor does mention of
trade names or commercial products constitute a recommendation for use. Reports of
NACEPT are posted  on the EPA Web Site at http://www.epa.gov/ocem/nacept.
                                EPA 130-K-08-001
                        U.S. Environmental Protection Agency
                   Office of Cooperative Environmental Management
                              http://www.epa.gov/ocem
                                   March 2008

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Everyone 's "Business:
Working Towards Sustainability
Through Environmental
Stewardship and Collaboration
National Advisory Council for
Environmental Policy and
Technology (NACEPT)


March 2008

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Photo Credits: The background picture of mountains appearing on the cover and at other places in the
report and the three photos in the top row and the three photos in the bottom row of the cover are stock
photos available from Dreamstime (http://www.dreamstime.com). The photo  in the middle row of the cover
was taken by Memphis Sierra Club volunteer James Baker (http://sierraclub.typepad.com/scrapbook/2007/
10/wolf-river-harb.htmt).

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                                      nvironmentai Policy
The Honorable Stephen L. Johnson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Dear Administrator Johnson:

    The National Advisory Council for Environmental Policy and Technology
(NACEPT) is pleased to transmit the enclosed recommendations and report in
response to your charge of May 2006. You asked for the Council's views on how
the U.S. Environmental Protection Agency (EPA) might advance its efforts on envi-
ronmental stewardship and cooperative conservation. Our report, entitled
Everyone's Business: Working Towards Sustainability Through Environmental
Stewardship and Collaboration, advances five key recommendations, supported
by specific findings and immediate steps for EPA.

    Our key message  is straightforward.  EPA should reframe its mission with stew-
ardship as the unifying theme and ethic and strive to become the world's premier
stewardship model and catalyst.

    As EPA's Innovation Action Council stated in its November 2005 report,
Everyday Choices: Opportunities for Environmental Stewardship, "(S)tewardship
means taking responsibility for our choices." Stewardship is a systemic approach
to addressing the challenge  of sustainability—economic, environmental and
social. Strong regulatory programs are key tools in fostering responsibility, espe-
cially when they are integrated with the full policy toolbox that also includes
grants, voluntary partnerships, and information programs. To deliver on this chal-
lenge, EPA must invest in building the skills and competencies necessary for stew-
ardship and drive stewardship deep into its organizational culture.

    The concept of stewardship is a logical—and timely—step in EPA's ongoing
evolution.  It is not a new idea.  The National Environmental Policy Act (NEPA) of
1969 provides the direction and underlying authority to implement our recom-
mendations. We commend  EPA for already doing much to advance stewardship
but, as we state in our report, there is much more to do.

    Although EPA has a critical  role to play in stewardship, its role is only one
piece of the overall systemic solution.  The success of EPA's stewardship efforts will
be determined by the extent to which other institutions and individuals become
stewards.  Collaborative governance, which engages all stakeholders in the
design and direction of environmental policy, is a key strategy toward that end.
Working towards sustainability through environmental stewardship and collabora-
tion is indeed everyone's business.

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   Fully embracing environmental stewardship will not be easy for EPA or the rest
of society, but it is one of the best ways to ensure future prosperity.  Implementing
the full scope of our recommendations will require continuing EPA management
attention and a long-term, sustained investment. Paradigm shifts take time and
patience as well as strategic implementation. EPA's successful implementation of
pollution prevention illustrates how this can be accomplished.

   The Council advances these recommendations and makes its findings with a
sense of great humility. Over its 37 year history, EPA has provided leadership over
and over again for the American people. We appreciate the professional and
personal courage you demonstrated in seeking  out constructive advice in order
to help the Agency to be more effective in surmounting the problems of an
increasingly complex and fast-changing world.

   Every day individuals and institutions make a myriad of choices that affect
the environment for better or worse. Interest in sustainability and environmental
stewardship is surging throughout the country and the world. Now is the time for
EPA to recast its role to provide the leadership needed for society to reach the
next level of environmental quality.

   With EPA at the forefront, environmental stewardship that is pursued in a vig-
orously collaborative manner should be everyone's business. Informed actions by
millions of individuals and institutions can truly put us on the path to sustainability.
This is the Council's vision and its hope for the future.

   I would be happy to brief you in person about this report. I think NACEPT also
might be able to be helpful by participating in dialogues with EPA headquarters
and regional offices to present the report and seek feedback from Agency man-
agers and staff on what opportunities they see for stewardship and collaboration
from their operational vantage points. The Council would welcome the prospect
of continuing to assist you and the Agency in your efforts and wants to thank you
for the opportunity to provide this report.

                          John L. Howard, Jr.
                          NACEPT Chair

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Key Recommendations	2
Recommendations, Findings, and Immediate Steps	3
Interim Letter	10
Current Opportunity and Challenge	10

Appendix 1:  Environmental Stewardship and Cooperative Conservation
           Workgroup and Acknowledgements 	35

Appendix 2:  Charge to the NACEPT Workgroup	37

Appendix 3:  NACEPT's Interim Advice Letter to Administrator
           Stephen L. Johnson	43

Appendix 4:  Example Opportunities for Environmental Stewardship	46

Appendix 5:  Stewardship Traditional and Historical Usage	51

Appendix 6:  Alignment of NACEPT Recommendations with
           Everyday Choices	54

Appendix 7:  List of Acronyms	56

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                — EPA Administrator Stephen L. Johnson1
    In May 2006, Administrator Stephen Johnson asked the National Advisory
Council for Environmental Policy and Technology (NACEPT) to review the U.S.
Environmental Protection Agency's (EPA) recent response to two priorities— envi-
ronmental stewardship and cooperative conservation. In this concluding report
to the Administrator, the Council advances key recommendations, findings, and
steps the Administrator and the Agency should take immediately to demonstrate
their clear and bold vision of environmental stewardship made possible through a
deliberate strategy of collaborative governance involving all sectors of American
society.

    Our key message is straightforward. EPA should reframe its mission with stew-
ardship as the unifying theme and ethic and EPA should strive to become the
world's premier stewardship model and catalyst.

    As the EPA Innovation Action Council (IAC) stated in its November 2005
report, Everyday Choices:  Opportunities for Environmental Stewardship2,
"(S)tewardship means taking responsibility for our choices." Stewardship is a sys-
temic approach to addressing the challenge of sustainability— economic, envi-
ronmental, and social.  Strong regulatory  programs are key tools in fostering
responsibility, especially when they are integrated with the full policy toolbox that
also includes grants, voluntary partnerships, and information  programs. To deliver
on this challenge, EPA must invest in building the skills and competencies neces-
sary for stewardship and drive stewardship deep into its organizational culture.

    The concept of stewardship is a logical — and timely — step in EPA's ongoing
evolution. It is not a new idea. The National Environmental Policy Act  (NEPA) of
1 969 provides the direction and underlying authority to implement our recom-
mendations. We commend EPA for already doing much to advance  stewardship
but, as we state in this report, there is much more to do.

    Although EPA has a critical role to play in stewardship, its role is only one
piece of the overall systemic solution.  The success of EPA's stewardship efforts will
be determined by the extent to which other institutions and individuals become
stewards. We need a nation of 300 million environmental stewards, not just
approximatelyl 7,000 EPA staff.  Collaborative governance, which engages all
stakeholders in the design and direction of environmental policy, is a key strategy
toward that end.  Working towards sustainability through environmental steward-
ship and collaboration is everyone's business.

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    Fully embracing environmental stewardship will not be easy for EPA or the rest
of society, but it is one of the best ways to ensure future prosperity. Implementing
the full scope of our recommendations will require continuing EPA management
attention and a long-term, sustained investment. Paradigm shifts take time and
patience as well as strategic implementation.  EPA's successful implementation of
pollution prevention illustrates how this can be accomplished.

    Every day individuals and institutions make a myriad of choices that affect
the environment for better or worse. Interest in sustainability and environmental
stewardship is surging throughout the country and the world.  Now is the time for
EPA to recast its role to provide the leadership needed for society to reach the
next level of environmental quality.

    With EPA at the forefront, environmental stewardship that is pursued in a vig-
orously collaborative manner should be everyone's business. Informed actions by
millions of individuals and institutions can truly put us on the path to sustainability.
This is the Council's vision and its hope for the future.

    This report focuses primarily on EPA's environmental stewardship activities and
opportunities. We begin this report by offering a summary of our key recommen-
dations,  findings, and immediate action steps. We then describe NACEPT's work
to date in the area of environmental stewardship and the opportunity and chal-
lenge before us. We define environmental stewardship as taking responsibility for
our choices and explore what taking responsibility means. With this introduction,
we present our recommendations, as well as the reasoning behind them, in
greater depth. We conclude with seven appendices.           1 provides a list
of the Workgroup members and our acknowledgments.          2 is a copy of
the charge to our Workgroup.           3 is our interim advice letter to EPA
Administrator Stephen Johnson.           4 contains three examples that illus-
trate opportunities for environmental stewardship and the array of approaches
needed to convey the stewardship message.          5 is a discussion of the
traditional roots of environmental stewardship.          6 is a table that shows
areas of overlap between our recommendations and those contained in EPA's
Everyday Choices report. Finally,          ? defines the acronyms used in this
report.
1.                    its                      as the
                   to         the
        by
                                               a

    ERA                        by                   in
                           in                     by

                                in the                                for
    the                                      in

                   the                  of                     the
    of the

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•i                        Findings,
                         EPA should reframe its mission with stewardship as the
     Finding 1.1
EPA has achieved many successes, but it cannot guar-
antee and sustain a clean and healthy environment on
its own.  Environmental stewardship encourages all
parts of society to take active responsibility for improv-
ing environmental quality and achieving sustainable
results.  Increased emphasis on the concept of steward-
ship is a further step in EPA's ongoing evolution.
     Finding 1.2
NEPA Section 101 clearly articulates a statutory basis for
encouraging stewardship. The laws and executive
orders under which EPA operates support and are con-
sistent with encouraging stewardship.
     Finding 1.3
Strong regulatory programs are key tools for fostering
responsibility, especially when they are integrated with
the full policy toolbox that also includes grants, volun-
tary partnerships, and information programs.
     Finding 1.4
Fully embracing environmental stewardship will not be
easy but it is one of the best ways to ensure future pros-
perity.
     Finding 1.5
Stewardship and sustainability are related concepts, but
quite different in meaning.  Environmental stewardship is
an ethic and practice of shared responsibility for envi-
ronmental quality. It is the best means of achieving the
environmental component of sustainability, a charac-
teristic of natural and human systems that embodies
"the possibility of flourishing forever."3
     Finding 1.6
Working towards sustainability through environmental
stewardship and collaboration is everyone's business.
     Immediate Step 1.1
The Administrator should convene a committee drawn
from across the Agency to redraft EPA's current mission
statement and formulate possible commitments to a
diverse set of specific national, regional, and local initia-
tives that exemplify good stewardship practices. The
commitments should integrate strong regulatory pro-
grams with other tools, such as grants, voluntary part-
nerships, and information programs. This task could be
done as an early step towards the next EPA Strategic
Plan.
     Immediate Step 1.2
Using multiple channels, including speeches, memos,
and informal communications, the Administrator should
announce the new mission statement to EPA staff mem-
bers and request their engagement. The message
should underscore that: EPA's challenge lies in using
effectively its entire set of tools to get the best environ-
mental results. Fully embracing environmental steward-
ship will not be easy but it is one of the best ways to
ensure future prosperity for all citizens.
     Immediate Step 1.3
The Administrator should share and promote the envi-
ronmental stewardship message with other cabinet-
level agencies; Congress; tribal, state, and local gov-
ernments; as well as private-sector firms, nongovern-
mental organizations (NGOs), and the American public.
                                      e

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Finding 2.1
                   j^iriipMaM^
                   ardship model and Kssrtalptt hf intesgiwtlqg r^ytateif
                            iiiirti, wttiwrteif pirto*iiWp»' infcriwBttert,' in-
                   JbnMii* operations, and Qtbw twate We m, smumen 1mm»-
                   uwrte,
By being an outstanding model in its policies, programs,
and in-house operations, EPA can learn first hand what it
takes to be a good environmental steward and also
can use its visibility to help inspire others to become
good environmental stewards.
Finding 2.2
There is a widespread misperception that EPA's primary
stewardship tool consists of voluntary partnership pro-
grams.  The reality is that the Agency has many addi-
tional assets to promote stewardship, such as regulatory
programs, grants, information, public speeches, and in-
house operations. EPA achieves its most effective results
when these tools are used in concert.
Finding 2.3
As EPA and others apply various tools of environmental
stewardship, everyone must recognize that some efforts
will be very successful and others will be less successful.
As is often the case with innovation, continuous
improvement, experimentation, and tenacity are key.
Immediate Step 2.1
In order to make EPA the world's premier stewardship
model and catalyst, the Deputy Administrator should
ensure that stewardship is more fully integrated through-
out the EPA Strategic Plan and Budget. EPA should set
specific benchmarks for implementation of environmen-
tal stewardship throughout the Agency and should
include stewardship more fully than it is now in all five
goals, rather than covering it mainly in Goal 5. When
EPA meets the benchmarks, it should celebrate; when it
does not, the Agency should redirect its efforts and
keep moving forward.
Immediate Step 2.2
Consistent with Immediate Step 1.3, the Administrator
should regularly use the platform his office provides to
speak to the American public and institutions about their
importance as partners in applying environmental stew-
ardship concepts and behavior to enhance the nation's
sustainability.  The Administrator should offer audiences
specific examples of how to be stewards and showcase
success stories.
Immediate Step 2.3
The Administrator should communicate EPA's interest in
exchanging ideas and information on the best environ-
mental stewardship practices to leaders of foreign envi-
ronmental agencies. The upcoming Organisation for
Economic Co-Operation and Development (OECD) and
G8 environmental discussions present initial opportunities
to seek such exchanges. EPA should benchmark against
other countries and aim to put the United States and
EPA in a leadership position.
Immediate Step 2.4
The Office of Administration and Resources
Management (OARM) should continue its commend-
able efforts to make EPA an excellent steward in its in-
house operations.

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                    collaborative governance and participating in partner-
Finding 3.1
Stewardship has taken root in other countries as well as
in many states, tribes, communities, and private-sector
organizations within the United States. EPA can learn
much from these stewardship policies and programs.
The principles of collaboration that businesses and oth-
ers are finding essential also apply to government.
Finding 3.2
Increased complexity of environmental challenges
requires that multiple parties be involved in the problem
resolution.
Finding 3.3
Collaborative partnerships will give the Agency's stew-
ardship efforts greater impact. EPA can leverage its lim-
ited resources by engaging in stewardship efforts organ-
ized by others.
Finding 3.4
EPA has proven ability to convene, catalyze, and other-
wise support collaborative efforts of others.
Finding 3.5
EPA should be strategic in using collaboration, set clear
goals and measures, and evaluate results.
Immediate Step 3.1
The Administrator should ask each Regional Administrator
and Assistant Administrator to identify his or her three
best examples of collaborative governance in pursuit of
stewardship, analyze these examples for lessons learned,
and compile these into a report for broad distribution.
The Administrator should establish a program to collect
data systematically and analyze the successes of priority
EPA collaborative efforts.
Immediate Step 3.2
Each program office should set goals with measures of
progress and success for each major collaborative
effort—in cooperation with collaborators—taking into
account cultural, social, and economic benefits along
with environmental benefits.
Immediate Step 3.3
Program and regional offices should, when they have
the opportunity and resources, join in collaborative
efforts in pursuit of stewardship organized by others, par-
ticularly when invited.
Immediate Step 3.4
EPA's Office of Human Resources (OHR) should lead the
implementation of the Collaboration Training Strategy
for the Senior Executive Service (SES) Corps, supervisors
and managers, and staff. The training will enhance col-
laboration and partnering competencies throughout the
Agency.
Immediate Step 3.5
As recommended in Immediate Steps 1.3 and 2.2, the
Administrator should share and promote the environ-
mental stewardship and collaboration message with
other public and private organizations.

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                4
Finding 4.1
j^iHpMfjpii$m^
tense*; tmaeaastiyr f»r th« ,Afpnsf^domeistte «nd global
Every EPA employee has the potential to be a steward-
ship ambassador.
Finding 4.2
Although EPA has outstanding scientific expertise, many
staff members are not familiar with the principles and
tools of stewardship, including collaborative problem
solving, nor have they utilized traditional knowledge4 sig-
nificantly.
Finding 4.3
The pending generational turnover of EPA's workforce
presents a compelling opportunity to recruit and equip
new employees with skills needed for stewardship and
collaborative governance.
Finding 4.4
EPA's substantial information capabilities can be used to
help define and encourage others to use responsible
environmental practices.
Immediate Step 4.1
The Innovation Action Council (IAC) should work with
OHR to appoint a subcommittee to focus on recruiting
and training strategies. The subcommittee should review
existing strategies and reaffirm or modify them as neces-
sary to build a new generation of EPA employees with
collaborative governance and stewardship skills that
they are able to use both on the job and in their own
personal lives. The new subcommittee should be
assigned to:
  •  review EPA's Human Capital and Cooperative
    Conservation Competencies plans and the work of
    the SES "Stronger EPA"  team;
  •  consider the necessary stewardship skills and com-
    petencies, including traditional knowledge, and
    identify gaps that need to be filled to instill steward-
    ship ethic and  practices;
  •  reaffirm or recommend EPA recruiting strategy;
  •  recommend a strategy that  builds on current efforts
    for training on stewardship and collaborative gover-
    nance principles, practices, and expectations with
    the aim of reaching every employee;
  •  recommend a strategy to recognize and reward
    stewardship champions as present and future lead-
    ers of the Agency; and
  •  lead and support implementation of these strategies.
Immediate Step 4.2
The Deputy Administrator and Assistant Administrators
should work with the Assistant Administrator for
Administration and Resources Management to deter-
mine how best to utilize retired EPA employees effective-
ly to promote the stewardship ethic within the Agency
and externally.
Immediate Step 4.3
The Office of the Chief Financial Officer (OCFO) and the
Office of Policy, Economics, and Innovation (OPEI)
should enhance EPA's evaluation and measurement of
the full range of stewardship activities, publicize the
results of such analyses inside and outside of the
Agency, and highlight success stories.

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Immediate Step 4.4
The Office of Research and Developmenf (ORD) should
strengthen EPA's research fo identify the most effective
tools to motivate stewardship behavior in individuals and
publicize the results inside and outside of the Agency.
Such an effort would directly support ORD's
Sustainability Research Strategy.
Immediate Step 4.5
The Office of Environmental Information (OEI) and the
Office of Public Affairs (OPA) should work with the pro-
gram and regional offices to review and enhance EPA's
information dissemination, disclosure, and educational
activities to strengthen the stewardship practices of oth-
                    ers.
iKBomOTMtrtatlsn i
Finding 5.1
Finding 5.2
Finding 5.3
Finding 5.4
Immediate Step 5.1
Immediate Step 5.2
Immediate Step 5.3
Immediate Step 5.4
1 fPL«he>yhl drh» the «Jhte and of stewardship
iwte tip «tJiyp ^ftwj^fpiii.
Stewardship is linguistically difficult because it is both an
ethic and a set of practices.
Stewardship would benefit from an express set of princi-
ples, such as exists with pollution prevention.
The way that EPA currently is evaluating its stewardship
approaches focuses almost exclusively on its voluntary
partnership programs.
EPA's program and regional offices are at the front lines
of stewardship and practical innovation.
The EPA Administrator and the senior leadership team
should clearly and consistently communicate the ethic
and practice of stewardship to all employees and
establish a learning process to engage all employees in
understanding the stewardship ethic and applying stew-
ardship practices. The Administrator also should consid-
er asking the committee suggested in Immediate Step
1 .1 to develop a brief set of stewardship principles for
EPA.
The Administrator should regularly encourage Assistant
and Regional Administrators to use stewardship
approaches to address program and regional priorities.
Consistent with Immediate Step 2.1, the Deputy
Administrator should align EPA strategic planning, budg-
eting, and accountability processes to explicitly address
stewardship goals.
OHR should establish a new generic performance stan-
dard that EPA staff members can use in their individual
performance agreements that will recognize and
reward superior performance in the service of steward-
ship.

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Itlllftl?^;:	;.•.
•?'v; !/:•: '•".'".M'«"  '''
•'*%;• "
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Workgroup are listed in Appendix 1. The Workgroup's charge is provided in
Appendix 2 of this report.

   With its deepest appreciation, NACEPT wishes to acknowledge Administrator
Johnson for the spirit of collaboration and the confidence he showed in asking
for the Council's views and recommendations on these critical matters. In the
same collaborative spirit, we respectfully offer our report and recommendations.
While applauding all that EPA has accomplished to date, we believe that it can
become even more effective in protecting the environment and safeguarding
human health by adopting environmental stewardship as an overarching theme
and by becoming truly expert and engaged in collaborative governance in mat-
ters significantly affecting the environment.

Interim Letter

   In December 2006, NACEPT sent its initial thoughts on environmental steward-
ship to the Administrator (see Appendix 3). That letter outlined key questions and
several observations made by the Council about environmental stewardship at
that stage in our work. Among the points the Council made in the letter were the
following:

   • The vision of environmental stewardship—"where all parts of society active-
     ly take responsibility to improve environmental quality and achieve sustain-
      able results"—as proposed by the IAC and endorsed by the Administrator in
     his foreword to Everyday Choices is not only appropriate but echoes the
     earlier call contained in the National Environmental Policy Act (1969). NEPA
     states in part that:  (T)he Federal Government, in cooperation  with the
     State  and local governments and other concerned public and private
     organizations, (should) use all practicable means and measures.,. to foster
      and promote the general welfare, to create and maintain conditions under
      which man and nature can exist in productive harmony, and fulfill the
     social, economic, and other requirements of present and future genera-
      tions of Americans.5

   • For such a vision to take hold at EPA, there will need to be a shift in the
     Agency's organizational culture and such a shift can only occur if EPA's
     leadership is clear about the urgency and magnitude of the change need-
     ed.

   • In our view, an enhanced leadership role for EPA in environmental steward-
     ship will require much more than a rebranding of its current voluntary part-
     nership programs. We  identified the need for the implementation of the
     vision  of stewardship to include EPA's regulatory programs and, indeed, all
     of its modes of acting  as well as the voluntary partnership programs.

Current Opportunity and  Challenge

   EPA already has embarked  on the journey of environmental stewardship and
has made impressive contributions to improving the environment through its stew-
ardship programs. The Agency now has a greater opportunity, however, to
announce stewardship as its vision for the future and to engage legions of willing
Americans in the effort to enhance environmental quality, use resources wisely,
and ensure  a more prosperous and just future for all. The vision of stewardship
need not stop at our national borders. Today's environmental challenges are
                                  ©

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increasingly global in scale and the solutions need to be of a similar scale. We
see environmental stewardship as an opportunity to engage a broadening circle
of international partners as well as an opportunity for domestic engagement.
Regardless of the specific tool selected for action to achieve a given objective,
the theme of stewardship should be, we think, the unifying concept.

    EPA's draft 2007 Report on the Environment underscores the urgency of EPA's
stewardship task.6 This report seeks to identify answers to key questions about the
status and trends of the environment.  Many, perhaps a majority, of the factors
chosen to illustrate the status of national ecological and human health are not
directly addressed by any EPA regulatory mandate. Thus, the Report on the
Environment reveals that EPA is highly dependent on the successful engagement
of other elements of society for improving environmental quality and public
health. In other words,  the report underscores the fact that EPA needs the help
of many other institutions and individuals to accomplish its  mission.

    A few specifics from the Report on the Environment^ illustrate these points:

   • Groundwater. Thirty times more extensive than surface water volume,
     groundwater is the chief source of drinking and agricultural water in the
     United States. EPA has no control over withdrawals and  can exercise only
     limited regulatory authority on application of pesticides and fertilizers and
     the disposal of toxic materials that can leach into groundwater resources.

   • Water Supply. Much groundwater is, for practical purposes, a nonrenew-
     able resource.  The development of new sources of energy through tech-
     nologies such as biofuels will consume vast quantities of  water.7 Congress
     has yet to authorize any federal agency the responsibility for water supply
     planning.

   • Air Quality.  The number of U.S. homes with indoor air quality problems from
     radon was double the rate of those remediated. This means more
     Americans than ever are at risk from adverse impacts of radon exposure, a
     problem the EPA staff and the Science Advisory Board described as one of
     the top items of the Agency's unfinished business nearly two decades ago.
     Congress has not given EPA any regulatory authority so prevention and
     remediation depend on the Agency's ability to influence the actions of
     others outside of EPA.

   • Land Use Changes. A huge factor in health of surface and ground waters,
     air quality, and ecosystems, the extent of developed land increased at
     twice the rate of U.S. population growth in the latest period measured
     (1982-2002). EPA has very limited regulatory authority to affect the location,
     design, use, or timing of development;  exceptions include a couple of
     Clean Water Act sections, some Clean Air provisions, and contaminated
     site clean-up authorities. The ability to forestall most new problems (includ-
     ing sediment and additional nutrients, CO2 releases,  and criteria air pollu-
     tants caused by the combination of land disturbance and such accompa-
     nying aspects as more vehicles and impervious surfaces) lies outside of
     EPA's regulatory purview.

   • Ecosystems or Ecological Condition. Although EPA has an important regula-
     tory foothold in toxic substance regulation and over  wetlands conversion,
     the Agency lacks any control  over forestry conversion or land cover gener-

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     ally.  Thus, for example, the Agency must rely on stewardship or other
     institutions to affect decisions on biofuels production that would greatly
     expand corn-based ethanol production at the expense of stressed regional
     water resources and the ecosystems that rely upon them.

   A reader of the Report on the Environment is left with the compelling impres-
sion that among EPA's most powerful tools are its ability to provide accurate pub-
lic information, motivate changes in behavior from individuals to institutional
actors, and being creative in its use of regulation to move all parties to a higher
position on the scale of environmental quality. The same points emerged from
several examples of environmental stewardship that we studied: a cotton shirt,
an office building,  and a river (see "Examples of Environmental Stewardship
Opportunities" on page  13 and Appendix 4).  Stewardship, in short, seems essen-
tial for the  Agency to generate new environmental gains. The critical role of
stewardship motivates this report.

   Working towards sustainability through environmental stewardship and collab-
oration is everyone's business. The short title of our report, Everyone's Business, is
explicitly meant to invoke the seminal work of prior EPA reports and similarly
advance the Agency's efforts along the path to sustainability.  EPA's ground-
breaking 1987 report, Unfinished Business9, and the EPA Science Advisory Board's
follow-up 1990 report, Reducing Risk9, highlighted the risks of environmental prob-
lems and how we should be addressing those problems through risk-based man-
agement, which can be achieved only though strategic, comprehensive efforts
by all of us working together—governments, universities, businesses, and con-
cerned citizens (see "Learning From the Past:  EPA's Experience in Adapting New
Management Ideas" on page 19 of this report for further discussion).  EPA's 2005
stewardship report, Everyday Choices™, recognized that every day, we each
make choices that impact our own and others' quality of life, health, and envi-
ronment. Environmental stewardship follows risk-based management as an
important next step in the ongoing evolution of environmental protection.
                                  ©

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               Stewardship Opportunities
The Workgroup developed several examples of environmental stew-
ardship to provide a snapshot of the opportunities that exist in every
day contexts. Virtually everyone can relate to these examples and
begin to understand the various opportunities for stewardship that we
have to make a difference in our world. These examples are described
in more detail in Appendix 4.

Cotton Shirt— There are many environmental stewardship opportunities
associated with growing and manufacturing cotton products as well
as with cleaning cotton shirts during their life cycle.  These opportuni-
ties include purchasing t-shirts made with organic cotton, which is
grown without synthetic fertilizers, pesticides, herbicides, insecticides, or
defoliants; developing manufacturing processes that require less
water; using cold water to wash t-shirts, which decreases the energy
demand; purchasing shirts that need as little care as possible (can be
washed in cold water and do not require tumble drying); and purchas-
ing  Energy Star washers.

Office Building—The opportunities for environmental stewardship relate
principally to building location, design  and construction, and opera-
tion and maintenance.  Buildings can be sited and designed to con-
serve energy, to maximize the uses of passive and active solar energy,
and to assure maximum natural water infiltration and flows. Smart
Growth principles can be applied to site selection (e.g., locating near
public transit).  During construction, durable materials can be obtained
locally and from deconstructed buildings, and products that may
impact indoor air quality can be avoided.  In operating and maintain-
ing  a building, the opportunities include seeking green-sourced power,
installing solar panels, using natural pest control techniques, supplying
collection systems for recycling, maintaining the HVAC system at peak
operating capacity, installing motion and photo-sensor lighting switch-
es, and using energy efficient lighting.

River—The principal environmental stewardship  opportunities focus on
reducing water usage and protecting water quality. Homeowners can
install  low-flow showerheads and toilets, fix leaks and drips, and maxi-
mize onsite infiltration and use of technologies such as rain collection
barrels and rain gardens. Farmers can  prevent livestock from entering
the river; grow climate-appropriate, disease-resistant crops that elimi-
nate or minimize the need for irrigation and pesticides/herbicides; and
minimize the use of fertilizers and pesticides and avoid overspray into
aquatic areas. Farmers, landscapers, and forestry managers can
install  and maintain riparian buffers of native species and use swales to
control wet weather flows.  Additional stewardship opportunities
include restoring streams enclosed in culverts or pipes to daylight
(helps eliminate bacteria in watersheds) and preserving/restoring natu-
ral stream meanders and pools. With respect to river recreational use,
the opportunities include maintaining boat motors in good repair, exer-
cising  care in filling gasoline storage containers, keeping gasoline stor-
age in a catchment basin, and navigating at lower speeds near erodi-
ble or otherwise sensitive shorelines.

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   The idea of taking responsibility is central to stewardship. In its 2006-2011
Strategic Plan, for example, EPA refers to environmental stewardship as "the
sense of responsibility and ownership that goes with not only meeting, but
exceeding, existing regulatory requirements."11 According to Everyday Choices,
"stewardship means taking responsibility for our choices."12  NACEPT endorses this
definition.

   But what does taking responsibility mean? Because responsibility is so central
to the idea of environmental stewardship, it is worth stepping back to consider
this question.  Philosophers since the time of Aristotle have grappled to define
taking responsibility. Shifting through this long and extensive literature, three
themes emerge.  First, taking responsibility requires that people see themselves as
agents whose choices and actions make a difference in the world.  They are
"response-able," that is, able to respond and bring about a response.13 EPA
touches upon this idea in its 2006-2011 Strategic Plan when it writes of stewardship
as a sense of ownership. Taking responsibility means owning the consequences
of one's actions.
    Second, those who take responsibility acknowledge that they may be
blamed or praised for their actions; that they may fairly be held responsible. Part
of taking responsibility is accepting that it is appropriate for others to expect cer-
tain behaviors. Those who take responsibility understand that their actions are
the "fair target" of the reactions of others.14

    The third condition for taking responsibility is that the first two conditions be
based on evidence.15  People must see that their actions have an impact in the
world.  People must experience blame or praise for their actions.  Taking responsi-
bility must be  based on actual experience, not some theoretical concept.

    These three conditions for taking responsibility help clarify the meaning of
environmental stewardship.  Environmental stewardship implies that people take
ownership of the environmental consequences of their actions. They acknowl-
edge that others have the right to review and evaluate the impact of their
actions upon  environmental quality. In addition, they experience direct evi-
dence of the  consequences of their actions,  both in terms of the environmental
harms and benefits they cause as well as the judgments of others.  Stewardship
thus points to  the central role of information in informing choices, assessing con-
sequences, and changing behavior.

    Stewardship and sustainability are  related concepts, but quite different in
meaning.  Stewardship is an ethic and practice of shared responsibility for envi-
ronmental protection.  EPA is on a journey from pollution control, to pollution pre-
vention, to stewardship, to sustainability. Stewardship can  be seen as the foun-
dation of a bridge that takes us into the realm of sustainability.  The process of

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taking responsibility for the environmental consequences of our actions through
ownership, acknowledgement, and change contributes to sustainability.
Stewardship focuses on a set of environmental behaviors and the role of evi-
dence in informing our choices. It is fundamental to sustainability, but sustainabil-
ity encompasses a broader set of ideas and actions.  Sustainability is a character-
istic of living systems that embodies "the possibility of flourishing forever."16

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;j3^^

\,  EPA should        its mission with            as the unifying
   ethic,


2,                  to         the
        by integrating                           voluntary            infor-
   mation, in-house                other     into a common framework.


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   ernance     participating in                     by


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                                        jj» L'.'K	

 Finding 1.1
EPA has achieved many successes, but it cannot guar-
antee and sustain a clean and healthy environment on
its own.  Environmental stewardship encourages all parts
of society to take active responsibility for improving envi-
ronmental quality and achieving sustainable results.
Increased emphasis on the concept of stewardship is a
further step in EPA's ongoing evolution.
 Finding 1.2
NEPA Section 101 clearly articulates a statutory basis for
encouraging stewardship. The laws and executive
orders under which EPA operates support and are con-
sistent with encouraging stewardship.
 Finding 1.3
Strong regulatory programs are key tools for fostering
responsibility, especially when they are integrated with
the full policy toolbox that also includes grants, volun-
tary partnerships, and information programs.
 Finding 1.4
Fully embracing environmental stewardship will not be
easy but it is one of the best ways to ensure future pros-
perity.
 Finding 1.5
Stewardship and sustainability are related concepts, but
quite different in meaning.  Environmental stewardship is
an ethic and practice of shared responsibility for envi-
ronmental quality. It is the best means of achieving the
environmental component of sustainability, a character-
istic of natural and human systems that embodies "the
possibility of flourishing forever."17

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 Reeommendatien 1
 Finding 1.6
Working towards sustainability through environmental
stewardship and collaboration is everyone's business.
 Immediate Step 1.1
The Administrator should convene a committee drawn
from across the Agency to redraft EPA's current mission
statement and formulate possible commitments to a
diverse set of specific national, regional, and local initia-
tives that exemplify good stewardship practices.  The
commitments should integrate strong regulatory pro-
grams with other tools, such as grants, voluntary partner-
ships, and information programs. This task could be
done as an early step towards the next EPA Strategic
Plan.
 Immediate Step 1.2
Using multiple channels, including speeches, memos,
and informal communications, the Administrator should
announce the new mission statement to EPA staff mem-
bers and request their engagement. The message
should underscore that: EPA's challenge lies in using
effectively its entire set of tools to get the best environ-
mental results.  Fully embracing environmental steward-
ship will not be easy but it is one of the best ways to
ensure future prosperity for all citizens.
 Immediate Step 1.3
The Administrator should share and promote the envi-
ronmental stewardship message with other cabinet-
level agencies; Congress; tribal, state, and local govern-
ments; as well as private-sector firms, nongovernmental
organizations (NGOs), and the American public.
   Our recommendations flow from our understanding of the meaning of stew-
ardship. As noted above, stewardship and sustainability are related concepts,
but quite different in meaning. Environmental stewardship is an ethic and prac-
tice of shared responsibility for environmental quality.  EPA has achieved many
successes, but it cannot guarantee and sustain a clean and healthy environment
on its own.  Environmental stewardship encourages all parts of society to take
active responsibility for improving environmental quality and achieving sustain-
able results. Strong regulatory programs are  key tools in fostering responsibility,
especially when they are integrated with the full policy toolbox that also includes
grants, voluntary partnerships, and information programs.

   Fully embracing environmental stewardship will not be easy but it is one of
the best ways to ensure  future prosperity. Implementing the full scope of our rec-
ommendations will require EPA to make a long-term, sustained investment and
provide continuing management attention.  Paradigm shifts take time and
patience as well as strategic implementation. EPA's successful implementation of
pollution prevention illustrates how this can be accomplished. By incorporating
environmental stewardship into all of its activities, EPA will move closer to helping
the United States achieve sustainable outcomes across a wider range of activity.
Effective stewardship is as challenging for EPA as it is for all elements of society,
but unless stewardship practices become more widespread, the goal of protect-
ing American environmental quality and  achieving a high quality of life will lie
beyond society's reach.  EPA has successfully articulated new management
ideas  in the past (see "Learning From the Past:  EPA's Experience in Adapting
New Management Ideas" on      19).  Increased emphasis on the concept of
stewardship is a further step in EPA's ongoing evolution.
                                  0

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   Our view is consistent with the statutes and executive orders that provide the
basis for EPA's authority.  As noted in our December 22, 2006, letter to
Administrator Johnson (see Appendix 3), NEPA Section 101 clearly articulates a
statutory basis for stewardship. The laws and executive orders under which EPA
operates support stewardship concepts. For example, the Congressional decla-
ration of policy and goals for the 1972 federal Clean Water Act Amendments18
exhorts the nation to achieve fishable and swimable rivers, streams, and other
surface waters for both nonpoint and point pollution sources. Together with the
regulatory requirements of the Act are roles for EPA to collect and disseminate
information, fund wastewater treatment facilities, provide grants for planning,
conduct watershed assessments, and undertake many other actions working with
tribes, states, and local governments as well as a host of other  parties to achieve
the fishable/swimable goal. Writing to the Chairman of the Council on
Environmental Quality on August 24, 2007, EPA's General Counsel noted, "(W)e
conclude that EPA's enabling statutes and cross-agency laws provide a strong
framework for using collaborative approaches with partners, stakeholders, and
the public to protect human  health and the environment."19
          ADAPTING NEW MANAGEMENT IDEAS

   EPA has a rich history on incorporating cutting-edge ideas into its overall
   management approach. Risk-based management, pollution preven-
   tion, and the watershed approach are a few examples of past success-
   es. With each of these efforts EPA fundamentally changed the
   Agency's approach to environmental protection and its decision-mak-
   ing processes. These frameworks gave managers a different way to set
   priorities, direct management energies, involve multiple stakeholders,
   and achieve environmental successes.

   Each of these approaches had several common elements that led to
   their success. Top-level political leadership reinforced the importance of
   these efforts through multiple channels. Externally, the Agency's politi-
   cal appointees consistently built these concepts into their speeches, dis-
   cussions with elected officials, and consultations with state and tribal
   partners. Internally, these concepts were included in EPA's strategic
   plan, reflected in the allocation of resources, and included in the
   Agency's performance management and awards systems. An expec-
   tation was created that the Senior Executive Service (SES) Corps, and
   other Agency managers, would find innovative ways to promote these
   concepts both inside and outside the Agency. Management encour-
   aged staff to be leaders and to explore ideas. EPA made substantial
   investments of funds and time to train managers and staff in these new
   principles. Performance reviews by the Deputy Administrator and testi-
   mony to Congress included these management concepts. Where possi-
   ble, EPA also encouraged the use of these tools internationally. In short,
   EPA used all possible tools to inculcate these approaches into the man-
   agement fabric of the Agency, its state and tribal partners, the regulat-
   ed community, and other stakeholders.

   Increased emphasis on the concept of stewardship is a further step in
   EPA's ongoing evolution. The techniques that were successful in the
   past could once again be used to infuse this ethic into a  national and
   international approach to environmental protection.
                                  ©

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   We recommend the following immediate steps. The Administrator should
convene a committee drawn from across the Agency to redraft EPA's current
mission statement and formulate possible commitments to a diverse set of specif-
ic national, regional, and local initiatives that exemplify good stewardship prac-
tices.  This task could be done as an early step towards the next EPA Strategic
Plan.  Using multiple channels, including speeches, memos, and informal commu-
nications, the Administrator should announce the new mission statement to EPA
staff members and request their engagement. The message should underscore
that:  EPA's challenge lies in using effectively the entire set of tools to get the best
environmental results. Fully embracing environmental stewardship will not be
easy but it is one of the best ways to ensure future prosperity. In addition, the
Administrator should share and promote the environmental stewardship message
with other cabinet-level  agencies; Congress; tribal, state, and local governments;
as well as private-sector firms, NGOs, and the American public.
                     Efift sheuJsl sM»» te        than msM *§.• pMtiweti1 -stew-
 Finding 2.1
By being an outstanding model in its policies, programs,
and in-house operations, EPA can learn first hand what it
takes to be a good environmental steward and also can
use its visibility to help inspire others to become good
environmental stewards.
 Finding 2.2
There is a widespread misperception that EPA's primary
stewardship tool consists of voluntary partnership pro-
grams. The reality is that the Agency has many addi-
tional assets to promote stewardship, such as regulatory
programs, grants, information, public speeches, and in-
house operations. EPA achieves its most effective results
when these tools are used in concert.
 Finding 2.3
As EPA and others apply various tools of environmental
stewardship, everyone must recognize that some efforts
will be very successful and others will be less successful.
As is often the case with innovation, continuous improve-
ment, experimentation, and tenacity are key.
 Immediate Step 2.1
In order to make EPA the world's premier stewardship
model and catalyst, the Deputy Administrator should
ensure that stewardship is more fully integrated through-
out the EPA Strategic Plan and Budget. EPA should set
specific benchmarks for implementation of environmen-
tal stewardship throughout the Agency and should
include stewardship more fully than it is now in all five
goals, rather than covering it mainly in Goal 5. When
EPA meets the benchmarks, it should celebrate; when it
does not, the Agency should redirect its efforts and
keep moving forward.
 Immediate Step 2.2
Consistent with Immediate Step 1.3, the Administrator
should regularly use the platform his office provides to
speak to the American public and institutions about their
importance as partners in applying environmental stew-
ardship concepts and behavior to enhance the nation's
sustainability.  The Administrator should offer audiences
specific examples of how to be stewards and showcase
success stories.

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 Recommendation 2   (continued)
 Immediate Step 2.3
The Administrator should communicate EPA's interest in
exchanging ideas and information on the best environ-
mental stewardship practices to leaders of foreign envi-
ronmental agencies. The upcoming Organisation for
Economic Co-Operation and Development (OECD) and
G8 environmental discussions present initial opportunities
to seek such exchanges. EPA should benchmark against
other countries and aim to put the United States and
EPA in a leadership position.
 Immediate Step 2.4
The Office of Administration and Resources
Management (OARM) should continue its commend-
able efforts to make EPA an excellent steward in its in-
house operations.
   Stewardship requires EPA to use every tool in its toolbox. The toolbox includes
environmental regulations, standards, and permits.  It includes grants, technical
assistance, and educational programs, as well as mandatory approaches and
voluntary partnership approaches. All of these tools are necessary, but none on
its own is sufficient. It is the combination of tools thoughtfully aligned to support
the development of environmental stewardship across businesses, federal and
other levels of government, individuals, and globally that creates major environ-
mental quality improvements. It would be the rare instance in which one tool on
its own could accomplish any significant environmental quality improvement
objective.

   There is a widespread misperception that EPA's primary stewardship tool con-
sists of voluntary partnership programs.  The reality is, however, that the Agency
has many additional assets to promote stewardship, such as regulatory programs,
grants, information, public speeches, and in-house operations.  EPA achieves its
most effective results when it uses these tools in concert. Environmental regula-
tion is the Agency's most powerful stewardship tool. EPA's ability to foster stew-
ardship comes primarily from the major environmental statutes and the system of
environmental regulation, standards, and permits that it has promulgated to
achieve the goals laid down in law.  EPA's environmental permitting requirements
call upon facilities to take responsibility for the environmental consequences of a
defined set of behaviors.  Such requirements mandate facilities, for example, to
take responsibility for their wastewater effluent by installing best available tech-
nology, or to take responsibility for the air pollution from their products by meet-
ing fuel efficiency standards. Environmental rules require facilities to collect and
share information about the environmental consequences of their  behavior and
hold  them to account through inspections and the possibility of fines.  Environ-
mental regulation, and associated standards and permits, define facilities'
responsibilities directly and explicitly: facility managers must take responsibility for
certain aspects of their behavior under penalty of law.

   EPA's voluntary partnership programs extend the Agency's reach and com-
plement its regulatory tools. Although programs such as SunWise Schools,
Performance Track, Climate Leaders, and Energy Star, to name just a few, do  not
carry the authority of mandatory regulation, they address a broader array of
consequences.  Such programs should not be viewed as alternatives to regulato-
ry programs, but rather as complementary tools to be applied in tandem and
integrated with other environmental tools.
                                  o

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    EPA's authority to prevent pollution relies on a mix of approaches and exem-
plifies what we mean by an integrated approach to stewardship.  EPA's authority
to require pollution prevention is established by statute.  For example, under
Section 13106 of the Pollution Prevention Act, EPA requires each facility that files
an annual toxic chemical release form to provide a toxic chemical source reduc-
tion and recycling report (which is clearly designed to encourage pollution pre-
vention).  In addition, EPA uses its authority under the Resource Conservation and
Recovery Act (RCRA) Section 6927 to require RCRA regulated facilities to
describe their waste reduction programs and to perform inspections to deter-
mine whether such programs are actually in place. In addition, EPA has devel-
oped numerous voluntary partnership programs that encourage facilities to pre-
vent pollution, such as Waste-Wise.  Although voluntary partnership programs
extend stewardship in important ways, voluntary tools must be seen in the broad-
er context of how EPA accomplishes major environmental quality improvements.
Region I's integration of compliance, incentive, and innovation tools, described
in "EPA Region I's Experience Integrating Policy Tools" on page 23, provides a fur-
ther example of how EPA can use all of its tools to promote stewardship.

    We can analyze available environmental policy tools based on whether EPA's
involvement is direct or indirect.  Some tools, such as the Agency's permit system,
involve EPA in direct one-on-one interaction with a single facility. Other tools,
such as the Executive Order on Cooperative Conservation, involve the  Agency in
discussions with groups of organizations simultaneously in which its involvement is
more diffuse.  We also can analyze tools based on the source of EPA's influence.
Some tools rely on EPA's statutory authority or financial resources, while others
draw on its expertise and credibility.  Such distinctions may be more meaningful
than the labels mandatory and voluntary, which focus on a single aspect of a
tool—whether or not it has a regulatory basis—but neglect other important char-
acteristics.

    The Administrator should  communicate EPA's interest in exchanging ideas
and information on the best environmental stewardship practices to leaders of
foreign environmental agencies. The upcoming meetings of the Organisation for
Economic Co-Operation and Development (OECD) and the G8 environmental
discussions present near-term opportunities to initiate such exchanges. EPA should
benchmark against other countries, corporations, states, tribes, and other federal
agencies, and aim to put the United States and EPA in a leadership position.

    In order to make EPA the world's premier stewardship model and catalyst,
the Deputy Administrator should ensure that stewardship is more fully included
throughout the EPA Strategic Plan and  Budget and should set specific bench-
marks for EPA's implementation of environmental stewardship throughout the
Agency. Stewardship should  be more integrated than it is now into all five goals,
rather than covered mainly in Goal 5. It will be important for EPA to celebrate
success when it achieves benchmarks. It is equally important to recognize that
the Agency is on  a path of innovation and learning from experimentation.  EPA
should strive for continuous improvement and to learn from what works and what
does not, but should not turn back from its path of supporting stewardship.

    The Administrator should  regularly use the platform provided by his office to
speak to the American public and institutions about their importance as partners
in applying environmental stewardship concepts and behavior to enhance the
nation's sustainability. The Administrator should offer audiences specific exam-
ples of how to be stewards and showcase success stories.

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   By being an outstanding model in its own policies, programs, and in-house
operations, EPA can learn first hand what it takes to be a good environmental
steward and also can use its visibility to help inspire others to become good envi-
ronmental stewards. EPA has taken the lead among federal agencies to con-
form to ISO 14001, the environmental management systems standard, and has
shown the way towards a smaller environmental footprint by buying green power
from electrical generating and distribution companies, changing its vehicle fleet
to include more hybrids and other high mileage cars, and certifying some of its
regional buildings to the U.S. Green Building Council's LEED standard. All these
steps and more exemplify Mahatma Gandhi's admonition, "You must be the
change you wish to see in the world."  Example is a powerful means of educat-
ing and inspiring, and EPA should continue to model stewardship behavior.
Moreover, the Agency can share with the public not only the completed projects
but the information about costs, suppliers, practical difficulties, and actions that
resolved any problems.
                EPA REGION I'S EXPERIENCE
                INTEGRATING POLICY TOOLS

    For the past 5 years, EPA Region I (New England) has integrated tra-
    ditional enforcement tools with beyond-compliance approaches in
    its efforts to protect the environment. Region I's efforts illustrate
    what we mean by using "all the tools in the toolbox."  In its work to
    address environmental impacts from colleges and universities, for
    example, Region I has combined enforcement with a broad range
    of compliance assistance efforts that have motivated universities to
    initiate new practices and management systems that address their
    environmental impacts comprehensively.  The goal of these efforts,
    according to Region I, "is to have facilities be responsible for their
    own environmental performance."20
   One key element in Region I's approach has been to encourage
   colleges and universities to develop environmental management
   systems (EMS).  The region has prepared an EMS guide to help these
   educational institutions identify and address all of their environmen-
   tal impacts, whether or not they are subject to regulation. It also
   has created a Best Management Practices catalogue of practices
   for universities that it considers sustainable.  Following Region I's
   enforcement action, the Massachusetts Institute of Technology
   developed the Virtual Environmental Campus, a Web-based tool for
   improving environmental performance in cafeterias, dormitories,
   and other parts of the university usually exempt from much scrutiny
   from regulators. It is the mix of approaches, including enforcement,
   assistance incentives, and innovation,  that we find most appropriate
   and beneficial  for promoting stewardship.

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                      EPA should foster stewardship by providing leadership in
                                             mi            ft BirJtti^
 Finding 3.1
Stewardship has taken root in other countries as well as
in many states, tribes, communities, and private-sector
organizations within the United States. EPA can learn
much from these stewardship policies and programs.
The principles of collaboration that businesses and oth-
ers are finding essential also apply to government.
 Finding 3.2
Increased complexity of environmental challenges
requires that multiple parties be involved in the problem
resolution.
 Finding 3.3
Collaborative partnerships will give the Agency's stew-
ardship efforts greater impact. EPA can leverage its
limited resources by engaging in stewardship efforts
organized by others.
 Finding 3.4
EPA has proven ability to convene, catalyze, and other-
wise support collaborative efforts of others.
 Finding 3.5
EPA should be strategic in using collaboration, set clear
goals and measures, and evaluate results.
 Immediate Step 3.1
The Administrator should ask each Regional Administrator
and Assistant Administrator to identify his or her three
best examples of collaborative governance in pursuit of
stewardship, analyze these examples for lessons
learned, and compile these into a report for broad dis-
tribution.  The Administrator should establish a program
to collect data systematically and analyze the success-
es of priority EPA collaborative efforts.
 Immediate Step 3.2
Each program office should set goals with measures of
progress and success for each major collaborative
effort—in cooperation with collaborators—taking into
account cultural, social, and economic benefits along
with environmental benefits.
 Immediate Step 3.3
Program and regional offices should, when they have
the opportunity and resources, join in collaborative
efforts in pursuit of stewardship organized by others,
particularly when invited.
 Immediate Step 3.4
EPA's Office of Human Resources (OHR) should lead
implementation of the Collaboration Training Strategy
for the Senior Executive Service (SES) Corps, supervisors
and managers, and staff. The training will enhance col-
laboration and partnering competencies throughout
the Agency.
 Immediate Step 3.5
As recommended in Immediate Steps 1.3 and 2.2, the
Administrator should share and promote the environ-
mental stewardship and collaboration message with
other public and private organizations.
    On August 26, 2004, President George W. Bush issued Executive Order 13352,
calling upon federal agencies to implement environmental protection laws in a
manner that "facilitates cooperative conservation." The order defined coopera-
tive conservation as "actions that relate to use, enhancement, and enjoyment of
natural resources, protection of the environment, or both, and that involve col-
laborative activity among federal, state, local, and tribal governments, private
for-profit and nonprofit institutions, other nongovernmental entities and individuals."
                                   o

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   The key word in this definition is collaborative. The President's Cooperative
Conservation order grows out of recognition that an increasing percentage of
public goals cannot be accomplished by government acting alone. In the envi-
ronmental area, in particular, increasing complexity requires the active engage-
ment of multiple parties.  Another term that captures the meaning of coopera-
tive conservation is collaborative governance. Collaborative governance is a
way of acting in which each party shares responsibility for deciding the means  by
which policy goals will be achieved, as well as particulars of the goals.21

   The ethic and practice of stewardship can be realized only if EPA works col-
laboratively with others. Collaborative partnerships will give the Agency's stew-
ardship efforts greater impact. In the pursuit of stewardship, each set of actors
offers unique and critical contributions. We have argued that EPA's role is impor-
tant  and clear. It develops regulations and standards that require private-sector
managers to take responsibility for certain unintended consequences of their
activities.  It offers technical assistance and financial resources to those who
need help. It gathers and disseminates information to inform others' choices.  In
addition to these responsibilities, EPA can and does serve as a convener and cat-
alyst for collaboration.

   The private sector's role in stewardship  is equally critical.  In addition to com-
plying fully with environmental regulatory requirements, private-sector managers
make choices every day about the goods  and services they will bring to market.
Each of these choices may generate environmental consequences or benefits.
Private-sector managers possess special knowledge about how their processes
work and where opportunities for environmental  improvement lie. For steward-
ship to take root and grow, EPA must tap the influence and  insights of private-
sector managers. The Agency can learn much from the policies and programs
that  these organizations have enacted.

   NGOs have important perspectives and capabilities to offer as well. As pro-
tectors of the public good, these organizations possess unrivaled legitimacy.
They frequently offer thoughtful and creative ideas, and they have access to
large networks of organizations and individuals that collectively can influence
policy agendas.  It is hard to imagine recycling campaigns,  energy conservation
initiatives,  or watershed protection programs working at all without the ideas and
resources of grassroots organizations.

   Tribes and tribal organizations have special insights to bring to the movement
toward stewardship. As explained in Appendix 5, the ethic and practice of stew-
ardship is deeply rooted in tribal cultures and everyday routines. We have much
to learn from tribal traditions, and collaborating with tribes in stewardship pro-
grams should be an Agency priority.

   State and local governments often are innovators of collaborative govern-
ance. Frequently, this is because they are closer  to the people of their communi-
ties, they are in tune with citizens' values, and they are able to devise creative
mechanisms to engage citizens in cooperative endeavors. EPA has the opportu-
nity to leverage its resources by working with state and local governments to
involve individual citizens, businesses, schools, organizations, and others in actions
that  extend the practice of stewardship.  EPA also should seek to learn from state
and  local  experiences.

   The role of individuals has not received systematic attention in EPA planning.
Most often we think of the role of individuals in their private capacities as home-

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owners, consumers, travelers, and so forth.  The collective impact of decisions by
individuals in these capacities is profound.  These decisions also form the back-
drop for another set of decisions by individuals. Although the Agency is charged
with regulating the behavior of facilities, facilities are run by individuals and ulti-
mately the footprint of the facility is determined by individuals' decisions.  The
range of decisions affecting that footprint is vast.  It includes business decisions,
such as what products or services to offer, what inputs and suppliers to use, and
what customers to target. It includes operating decisions such as what physical
plant to build or acquire and what technologies to use.  It includes decisions
about management practices such as who to hire and how employees are
trained, who reports to whom, and how performance is evaluated.  It includes
decisions about values and commitments, such as whether environmental per-
formance is central to the organization's identity or more of an afterthought. The
role of individuals is paramount in small businesses whose activities may be sub-
ject to little if any regulatory oversight.

    Working separately, sectors may compete with each other or duplicate
efforts.  They may  blame each other when activities are not as effective as they
had anticipated.  Working collaboratively, these actors can offer innovative solu-
tions that build on each others' competencies. They can access greater techni-
cal know-how, financial resources, knowledge, and channels of engagement.
Their actions become legitimate and influential. Collaborative approaches to
stewardship increase the possibility that policies will be effective, innovative, and
integrated. Collaboration is not appropriate, however, for every situation. EPA
should be strategic in using collaboration, set clear goals and measures, and
evaluate results.

    In this context, there are great opportunities for collaboration between gov-
ernment agencies at the federal, tribal, state, and local levels.  EPA does collab-
orate with many of these agencies, but there are  many more opportunities wait-
ing. The capabilities of these agencies are far greater than they would be other-
wise when they combine their expertise and authorities.

    As immediate  steps, the Administrator should ask each Regional Administrator
and Assistant Administrator to identify his or her three best examples of collabora-
tive governance in pursuit of stewardship, analyze these examples for lessons
learned, and compile these into a report for broad distribution. The Administrator
should establish a  program to collect data systematically and analyze the suc-
cesses of priority EPA collaborative efforts. Each program office should set goals
with measures of progress and success for each major collaborative effort—in
cooperation with collaborators—taking into account cultural, social, and eco-
nomic benefits along with environmental benefits.  Regional offices should, when
they have the opportunity and resources, join in collaborative efforts in pursuit of
stewardship organized by others, particularly when invited. EPA's Office of
Human Resources (OHR) should implement the Collaboration Training  Strategy for
the Senior Executive Service (SES) Corps, supervisors and managers,  and staff. The
training will enhance collaboration and partnering competencies throughout the
Agency.

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Recommendation 4   E PA should systematically invest in the skil Is and com -
                                      jfer tip Apiftgf^         «ni
                    global leadership in environmental stewardship.
Finding 4.1
Every EPA employee has the potential to be a steward-
ship ambassador.
Finding 4.2
Although EPA has outstanding scientific expertise, many
staff members are not familiar with the principles and
tools of stewardship, including collaborative problem
solving, nor have they utilized traditional knowledge22
significantly.
Finding 4.3
The pending generational turnover of EPA's workforce
presents a compelling opportunity to recruit and equip
new employees with skills needed for stewardship and
collaborative governance.
Finding 4.4
EPA's substantial information capabilities can be used
to help define and encourage others to use responsible
environmental practices.
Immediate Step 4.1
The Innovation Action Council (IAC) should work with
OHR to appoint a subcommittee to focus on recruiting
and training strategies. The subcommittee should review
existing strategies and reaffirm or modify them as nec-
essary to build a new generation of EPA employees with
collaborative  governance and stewardship skills that
they are able to use both on the job and in their own
personal lives. The new subcommittee should be
assigned to:

  • review EPA's Human Capital and Cooperative
   Conservation Competencies plans and the work of
   the SES "Stronger EPA" team;
  • consider the necessary stewardship skills and com-
   petencies, including traditional knowledge, and
   identify gaps that need to be filled to instill steward-
   ship ethic and practices;
  • reaffirm  or recommend EPA recruiting strategy;
  • recommend a strategy that  builds on current efforts
   for training on stewardship and collaborative gover-
   nance principles, practices, and expectations with
   the aim  of reaching every employee;
  • recommend a strategy to recognize and reward
   stewardship champions as present and future lead-
   ers of the Agency; and
  • lead and support implementation of these strategies.
Immediate Step 4.2
The Deputy Administrator and Assistant Administrators
should work with the Assistant Administrator for
Administration and Resources Management to deter-
mine how best to utilize retired EPA employees effec-
tively to promote the stewardship ethic within the
Agency and externally.
Immediate Step 4.3
The Office of the Chief Financial Officer (OCFO) and
the Office of Policy, Economics, and Innovation (OPEI)
should enhance EPA's evaluation and measurement of
the full range of stewardship activities, publicize the
results of such analyses inside and outside of the
Agency, and highlight success stories.
                                 o

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 Recommendation 4
 Immediate Step 4.4
The Office of Research and Developmenf (ORD) should
strengthen EPA's research fo identify the most effective
tools to motivate stewardship behavior in individuals
and publicize the results inside and outside of the
Agency.  Such an effort would directly support ORD's
Sustainability Research Strategy.
 Immediate Step 4.5
The Office of Environmental Information (OEI) and the
Office of Public Affairs (OPA) should work with the pro-
gram and regional offices to review and enhance EPA's
information dissemination, disclosure, and educational
activities to strengthen the stewardship practices of others.
    Interest in environmental protection throughout the country and the world is
surging. There is growing recognition that we live in a global community and that
everyone's actions impact the planet. This upswing in interest is reflected in
many actions—by organizations and individuals making socially responsible
investments,  businesses promoting corporate social responsibility, communities
adopting green building policies, and individuals making environmentally
informed purchases. There now is an opportunity, some would say an imperative,
for EPA to recast its role and continue to provide the leadership needed to reach
the next level of environmental performance.

    Every EPA employee has the potential  to become a stewardship ambassa-
dor. As EPA employees go about their jobs, they can build stewardship into their
conduct inside and outside the office. In the workplace, EPA employees can
work cooperatively with others with the understanding that each tool in the tool-
box has a contribution to make to environmental protection. EPA employees
can value stewardship projects initiated  by others and lend their expertise and
resources. Outside the workplace, they can make decisions about where to live,
what to consume, whether to use public transportation or drive to work, whether
to drive to work alone or in a carpool, how warm or cool to keep their homes,
and how to maintain their yards with stewardship in mind.

    EPA's scientific expertise is outstanding in many ways, but the Agency has not
yet begun systematic research to identify the most effective tools for stewardship.
The Agency knows relatively little about what motivates individuals' stewardship
behavior, for example. EPA has relied on strict science and incorporates tradi-
tional knowledge only rarely, despite the significant insights that could be gained
from traditional sources.
   Throughout its history, EPA has benefited by the extraordinary human capital
it has been able to attract and retain, but many experienced employees are
reaching retirement age after full careers of service at the Agency. Although
these seasoned employees will take with them much experience, incoming
newly hired employees offer EPA an opportunity to develop a new workforce for
the new types of environmental challenges.  Many of these new employees will
come to EPA with credentials that will enable them to be champions of steward-
ship,  and they may naturally embrace collaboration and learning as the drivers
of stewardship. A formal training program, however, should be established to
instill  a common language and set of skills to support the stewardship efforts. We
note that during its history, whenever there is a major paradigm shift at EPA, an
accompanying Agency-wide rollout of supporting training regimes takes place.
For example, pollution prevention, risk management, and risk communication all

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have benefited by coherent training programs backed up by adequate budg-
ets. Stewardship will require a comparable effort.

    EPA can use its substantial information capabilities to help define and encour-
age others to use responsible environmental practices. Measurement is a corner-
stone of defining and managing human interaction with the environment.  It is
integral to stewardship because it provides information people need in order to
take responsibility. EPA already collects and has access to information that helps
those in government, the private sector, nonprofit organizations, and individuals
make connections between actions and environmental consequences.
Although EPA's measurement activities are significant, much more work needs to
be done to develop reliable and comprehensive outcome metrics.  Available
data, while more  accessible and integrated than in the past, are still limited.
They tell us little about the impact of policies geared to improving land use man-
agement, natural resource consumption, or other areas not addressed by federal
environmental regulation. Government does not require facilities to report how
much energy or water or other inputs they consume, despite the degradation
caused by the depletion of these resources. Many facilities are not  subject to
environmental reporting requirements at all because of their sector or size, yet
the impacts of their practices and products on environmental quality may be sig-
nificant.23

    As immediate steps,  we recommend that EPA's Innovation Action Council
work with the Office of Human Resources to appoint a subcommittee to focus on
recruiting and training strategies. The subcommittee should review existing strate-
gies and reaffirm or modify them as necessary to build a new generation of EPA
employees with collaborative governance and stewardship skills that they are
able to use both on the job and in their own personal  lives. The new subcommit-
tee should be assigned to:

   • review EPA's Human Capital and Cooperative Conservation Competencies
     plans and the work of the SES  "Stronger EPA" team;

   • consider the necessary stewardship skills and competencies, including tradi-
     tional knowledge,  and identify gaps that need to be filled to instill steward-
     ship ethic and practices;

   • reaffirm or recommend EPA recruiting strategy;

   • recommend a strategy that builds on current efforts for training on steward-
     ship and collaborative governance principles, practices, and expectations
     with the aim of reaching every employee; and

   • recommend a strategy to recognize and reward stewardship champions as
     present and future leaders of the Agency; and

   • lead and support implementation of these strategies.

    In addition, the Deputy Administrator and Assistant Administrators should work
with the Assistant Administrator for Administration and  Resources Management to
determine how best to utilize retired EPA employees to promote the stewardship
ethic within the Agency  and externally. The Office of the Chief Financial Officer
(OCFO) and Office of Policy, Economics, and Innovation (OPEI) should enhance
EPA's evaluation and measurement of the full range of stewardship  activities,
publicize the results of such analyses inside and outside of the Agency, and

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highlight success stories. The Office of Research and Development should
strengthen EPA's research to identify the most effective tools to motivate stew-
ardship behavior in individuals and publicize the results inside and outside of the
Agency.  Such an  effort would directly support ORD's Sustainability Research
Strategy.  The Office of Environmental Information (OEI) and Office of Public
Affairs (OPA) should work with the program and regional offices to review and
enhance the Agency's information dissemination, disclosure, and educational
activities to strengthen the stewardship practices of others.
fwitrrtittijfi f .ffil -fWi » ft»« 'tnH «l
tit #t» «lMij» at fc» Itgteif,
Finding 5.1
Finding 5.2
Finding 5.3
Finding 5.4
Immediate Step 5.1
Immediate Step 5.2
Immediate Step 5.3
Immediate Step 5.4
Stewardship is linguistically difficult because it is both an
ethic and a set of practices.
Stewardship would benefit from an express set of princi-
ples, such as exists with pollution prevention.
The way that EPA currently is evaluating its stewardship
approaches focuses almost exclusively on its voluntary
partnership programs.
EPA's program and regional offices are at the front lines
of stewardship and practical innovation.
The EPA Administrator and the senior leadership team
should clearly and consistently communicate the ethic
and practice of stewardship to all employees and
establish a learning process to engage all employees in
understanding the stewardship ethic and applying stew-
ardship practices. The Administrator also should consid-
er asking the committee suggested in Immediate Step
1 .1 to develop a brief set of stewardship principles for
EPA.
The Administrator should regularly encourage Assistant
and Regional Administrators to use stewardship
approaches to address program and regional priorities.
Consistent with Immediate Step 2.1, the Deputy
Administrator should align EPA strategic planning, budg-
eting, and accountability processes to explicitly address
stewardship goals.
OHR should establish a new generic performance stan-
dard that EPA staff members can use in their individual
performance agreements that will recognize and
reward superior performance in the service of steward-
ship.
   Stewardship is linguistically difficult.  It does not convey one explicit meaning,
but evokes different things in different contexts. In common conversation, the
term stewardship often does not resonate. It is two things: an ethic, and a set of
practices or behaviors. As yet, there is no set of widely recognized stewardship
principles as there is for pollution prevention, for example. Stewardship would
benefit from an express set of principles. To address these challenges, EPA needs
to engage the Agency and others in a conversation about what stewardship
means.  Clearly, it is more than the Agency's voluntary partnership programs, yet
discussions about stewardship often focus on non-regulatory initiatives exclusively.
    EPA's management systems and organizational structures must support stew-
ardship. Environmental stewardship cannot be an idea housed within one or

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more offices wifhin EPA headquarters, buf rafher if musf be an efhic fhaf perme-
ates all offices, programs, and products. Because the regional offices have the
closest connections to state, tribal, local, and community partners and stakehold-
ers, they represent the front lines for environmental stewardship and innovation.
Although some regional office personnel were involved in developing Everyday
Choices, there needs to be additional guidance and instruction from headquar-
ters to the regions with regard to implementing environmental stewardship.

    EPA's Deputy Administrator has ongoing discussions with EPA Assistant and
Regional Administrators regarding selected program and regional priorities.
These discussions should include environmental stewardship measures for the pro-
gram and regional offices.  Managers in the program and regional offices pay
attention to the performance measures that are applicable to them.  If environ-
mental stewardship is going to be implemented at the program and regional
office level, performance measures need to  be developed that incorporate
environmental stewardship concepts.

    Environmental stewardship measures should be developed so they are appli-
cable and important to  managers in the program and regional offices. Strategies
for accomplishing that include having environmental stewardship measures
relate to specific programs and incorporating environmental stewardship require-
ments into job descriptions.  If environmental stewardship is going to be integrat-
ed into the Agency's planning and management systems, it will need to be pro-
moted at the  career level in the program and regional offices. Career personnel
in the program and regional offices are sensitive to recognition programs.
Assistant and Regional Administrators should be encouraged to include promo-
tion of environmental stewardship as a category for internal recognition pro-
grams.  Such action will make supporters of environmental stewardship opinion
leaders in the  program and regional offices.

    EPA's employees do not have to be tasked with implementing environmental
stewardship inasmuch as they are all highly motivated with regards to implement-
ing the Agency's mission. EPA does,  however, need to train its staff members to
think beyond their traditional roles and find new ways to promote environmental
stewardship. Environmental  stewardship concepts should be added into regional
and program  trainings as well as those offered  by training centers. EPA staff
should  be encouraged to offer advice and referrals to other EPA  programs for
stewardship opportunities.  The Agency should consider adding environmental
stewardship skills and knowledge as a criterion in the hiring process.

    As immediate steps, the EPA Administrator and senior leadership team should
clearly and consistently communicate the ethic and practice of stewardship to
all Agency employees and  establish a learning process to engage all employees
in understanding the stewardship ethic and applying stewardship practices.  The
Administrator also should consider asking the committee convened to redraft
EPA's current mission statement (Immediate Step  1.1) to develop  a brief set of
stewardship principles for EPA. The Administrator should regularly  encourage
Assistant and Regional Administrators to use stewardship approaches to address
program and  regional priorities. The  Deputy Administrator should  align EPA strate-
gic planning, budgeting, and accountability processes to explicitly address stew-
ardship goals, and OHR should establish a new generic performance standard
that EPA staff members can use in their individual performance agreements that
will recognize  and reward superior performance in the service of  stewardship.
                                  o

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   The Council advances its recommendations and makes its findings with a
sense of great humility. Over its 37 year history, the U.S. Environmental Protection
Agency has provided leadership over and over again for the American people.
We thank the current Administrator, Stephen Johnson, for having the professional
and personal courage to seek out constructive advice and criticism in order to
help shape the Agency in ways to be more effective for the problems it faces in
today's increasingly complex and fast-changing world.

   It is a world in which humankind's imprint can be discerned with greater and
disturbing clarity.  From our rivers to the skies, from our largest cities to the most
remote corner of the globe, we now can see the impact of human activity on
our planet.  At the same time, we see the incredible creativity and compassion
of humanity in many areas, including increased agricultural production, innova-
tive and increasingly efficient energy generation, and a world of amazing new
technologies. Because the problems that obstruct the road to sustainability are
largely of human origin, we believe humans hold the key to their solution.  We
hold great hope that EPA, by consciously reframing its mission around the stew-
ardship theme, can be a major catalyst for a change in the way in which people
regard both their environment and their responsibility for its health.  Each day,
individuals and institutions make a  myriad of choices that affect the environment
for better or worse. With EPA at the forefront, environmental stewardship carried
out in a vigorously collaborative manner should be everyone's business. The
aggregate  of more informed actions by millions of individuals and institutions can
truly put us on the path to sustainability. This is the Council's vision and its hope
for the future.

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o

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Ms. Detrich (Dee) B. Allen (2006)
General Manager
Environmental Affairs Deparfmenf
Cify of Los Angeles

Dr. Paul Anastas (2007)
Director
Center for Green Chemistry and
  Engineering
Yale University

Ms. Cindy Angelelli (2006)
Managing Director
Environment, Health & Safety
Global Issue Strategy
Duke Energy Corp.

Mr. Arthur (Butch) L. Blazer (2006)
State Forester
New Mexico Forestry Division

Mr. Joel Bolstein (2006 and 2007)
Partner
Environmental Law Practice Group
Fox Rothschild LLP

Mr. Robert Gruenig (2007)
Senior Policy Analyst
National Tribal Environmental Council

Mr. Stan Laskowski (2007)
Retired EPA
Lecturer/Advisor
Masters of Environmental Studies
  Program
University of Pennsylvania

Mr. Erik Meyers (Co-Chair 2006 and
2007)
Vice President
Sustainable Programs
The Conservation Fund
Mr. Frank Stewart (2006)
Interim Executive Director
Southeastern Division
StEPP Foundation

Mr. Daniel Williams (2006)
Architect/Planner
Daniel Williams Architect
EPA
Mr. John Wise (2007)
Retired EPA
Environmental Financial Advisory Board

Ms. Melanie Worley (2006-2007)
Local Government Advisory
  Committee
Douglas County (Colorado)
  Commissioner
Board of County Commissioners
John L. Howard, Jr.
Partner
Vinson & Elkins, LLP
Ms. Sonia Altieri
Office of Cooperative Environmental
  Management (OCEM)
U.S. Environmental Protection Agency
Ms. Jennifer Nash (Co-Chair 2006 and
2007)
Director, Regulatory Policy Program
Executive Director, Corporate Social
  Responsibility Initiative
Center for Business and Government
John F. Kennedy School of
  Government
Harvard University

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Acknowledgements

    NACEPT Chair John Howard provided valuable insight, suggestions, and guid-
ance to the Workgroup throughout the course of our work. The Council and
Workgroup acknowledge with great appreciation the tireless assistance provided
by Designated Federal Officer (DFO) Sonia Altieri, and Office of Policy,
Economics, and Innovation (OPEI) liaisons Derry Allen and Pat Banner,  all from the
EPA staff. They identified and provided vital background documents, helped
identify staff to interview on topics related to the charge, organized meetings
and conference calls, and otherwise provided indispensable assistance to the
process.

    The Workgroup also would like to thank two senior EPA officials who served on
the Innovation Action Council committee for the Everyday Choices report and
who offered valuable insights to the Workgroup on several occasions:  Jay
Benforado and Stan Meiburg. Thanks  also are due to other EPA officials for their
assistance: Chris Bliley, Katherine Dawes, Dona DeLeon, Luke Hall-Jordan,
Matthew Hoagland, Noel Jamison, Christina Kakoyannis, Bill Long, Juliana Madrid,
Nat Miullo, Jeff Morin,  Stephen Perkins, and Wendy Reed. Finally, the Workgroup
thanks Olivia Barton Ferriter (U.S. Department of the Interior) and Juliana Birkhoff
(RESOLVE) for their assistance. The following graduate students from the University
of Pennsylvania developed background papers for this report: Donna Moffett,
Marguerite Murray, Andrea Mules, Lauren Kurtz, and Ikechukwu Onukogu.

    We are indebted to Rafael DeLeon, the Director of the Office of Cooperative
Environmental Management (OCEM)  and his staff at EPA. This report would have
not been possible without the support of OCEM. Thanks.

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                             Charge to the
National Advisory Council for Environmental Policy and Technology (NACEPT)
  for a Project on Environmental Stewardship and Cooperative Conservation

                              May 12, 2006
   The Administrator has requested that the National Advisory Council for
Environmental Policy and Technology (NACEPT) review recent EPA efforts on two
important and closely related priorities—Environmental Stewardship and
Cooperative Conservation—and make recommendations on how EPA can pur-
sue these priorities most fruitfully.

    I,

   On November 9, 2005, the EPA Innovation Action Council (IAC), a group of
the most senior career officials from each headquarters and regional office, sub-
mitted a report to Administrator Stephen L. Johnson, Everyday Choices:
Opportunities for Environmental Stewardship. Several state officials also partici-
pated.

   In the Administrator's charge to the IAC on May 9, 2005, he noted that "in
addition to operating  effective regulatory and enforcement programs, EPA is
gaining substantial experience with stewardship approaches - including volun-
tary programs, market incentives, recognition and leadership programs, pollution
prevention, environmental education, information and collaborative problem
solving.  Although these stewardship efforts are designed to produce environ-
mental results, EPA can improve their effectiveness with a more unified strategy
and with clear goals and priorities." With this in mind, he asked the Innovation
Action Council to "(1) Explore and better define EPA's vision of environmental
stewardship and the role of stewardship in the future of environmental protection;
(2) Assess EPA's current environmental stewardship activities to determine effec-
tiveness and opportunities for improvement; and (3) Recommend options and
priorities for how EPA, in partnership with states and tribes, can encourage stew-
ardship that addresses environmental priorities and achieves results.

   The IAC established a committee with broad membership from around the
Agency and representatives from the Environmental Council of the States to
undertake the project. In addition to its own  research, the  committee drew on
the wisdom of a number of  experts and stakeholders. The lAC's report:

       ; •!      a      for                         at EPA. "As our popula-
       tion and economy continue to expand, the U.S. can accelerate environ-
       mental progress while simultaneously strengthening our global competi-
       tiveness.  In short, we have exciting opportunities to create a more sus-
       tainable future in this country and with our partners around the world.
       However, this bold goal cannot be accomplished  by government alone;
       rather it requires the active engagement of all people. To this end, we
       have a vision of environmental stewardship—where all parts of society
       actively take responsibility to improve environmental quality and achieve
       sustainable  results."

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    •  Indicates that EPA has a number of environmental stewardship efforts
       underway, and that there is opportunity to develop them further.

    •  Identifies six important natural resource systems for which sustainable
       outcomes should be sought: air, ecosystems, energy, land, materials and
       water. It also identifies four key audiences for the stewardship message:
       individuals, companies, communities and government organizations.

    •  Suggests five major categories of options for EPA to enable and encour-
       age environmental stewardship among the key audiences:
          1.  Focus on priority environmental problems where stewardship has
             greatest potential
          2.  Engage individuals in environmental stewardship
          3.  Showcase best practices and accomplishments
          4.  Lead by example
          5.  Mainstream stewardship in EPA decision processes

    The Administrator accepted the report and wrote a Preface in which he
states:

       "This report outlines what I believe is the next step in an ongoing evolution
       of policy goals from pollution control to pollution prevention and sustain-
       ability. It also reflects an important reality - that while the Environmental
       Protection Agency (EPA) and our state partners share responsibility for
       bringing about our nation's environmental progress to date, we have not
       done so alone....Over the coming months, we will discuss the report's rec-
       ommendations and expand our efforts to make stewardship an inherent
       part of how we achieve our mission.  Environmental stewardship will help
       us build upon our nation's existing environmental efforts and ensure we,
       as a nation, are able to provide our children a safer, healthier environ-
       ment,  and a more  economically vibrant future."

    The IAC is  initiating a series of activities that respond to the report. As it
engages in this task it is clear that the agency can benefit from outside advice
on the challenges and opportunities that it faces.

    2. Cooperative Conservation

    In August,  2004, President Bush signed Executive Order #13352 entitled
"Facilitation of Cooperative Conservation." The Order directs the Departments of
Defense, Interior, Agriculture, Commerce and the Environmental Protection
Agency to work with the Council on Environmental Quality and each other to
implement laws relating to the environment and natural resources in a manner
that promotes cooperative conservation, with an emphasis on local involvement.

    The Order defines Cooperative Conservation as "actions that relate to use,
enhancement, and enjoyment of natural resources, protection of the environ-
ment, or both, and that involve collaborative activity among federal, state, local
and tribal governments, private for-profit and nonprofit institutions, other non-
governmental entities and individuals."

    To advance the spirit and  objectives of the order, the  White House Council on
Environmental Quality (CEQ) convened a Conference on Cooperative
Conservation in  August, 2005.  Over 1300 leaders from across the nation con-

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vened in St. Louis to generate innovative ideas to strengthen conservation part-
nership and promote citizen stewardship.

    In May 2005, Senator Inhofe, Chair of the Environment and Public Works
Committee, and Congressman Duncan, Subcommittee Chair of the Water
Resources and Environment Committee, introduced The Good Samaritan Clean
Watershed Act on behalf of the Administration and EPA. The legislation removes
the potential liability for volunteer organizations willing to restore watersheds
affected by acid drainage from hard rock mines. The legislation is follow-up to
an administrative initiative announced by EPA Administrator Johnson at the St.
Louis Conference.

    By August 2006, EPA will provide its input to the CEQ annual report to the
President on progress made in implementing EC 13352.

    Since January 2006, CEQ has coordinated an interagency Task Force among
the above five agencies to implement recommendations from the White House
Conference. The following four areas constitute the framework for action that
each agency is addressing:

    1.  Develop the capacity needed to hire and train federal employees in a
       manner that promotes greater collaboration. Recognize and reward out-
       standing partnership and collaboration achievements.
    2.  Further cooperative conservation through administrative, regulatory and
       legislative improvements.
    3.  Utilize communication, outreach and public education as a mechanism
       for increased stakeholder participation in cooperative conservation.
    4.  Develop tools and mechanisms for agencies and their partners to assist
       collaborative efforts in achieving desired outcomes.

    EPA activities and commitments to implement the Draft Action Plan to date
include:

    •  Collaboration and Partnering Competencies: An essential building
       block in the effort to expand the use of Cooperative Conservation
       among each of the five agencies is an Action Plan—EPA's was submitted
       to OPM and CEQ on March 31, 2006—to build knowledge and capacity
       in collaboration and partnering, and to foster collaborative leadership at
       all levels by elevating  collaboration skills in hiring, training, and recogni-
       tion of personnel. Pursuant to the Administrator's charge in the Plan, the
       Human Resources Council, the National  Partnership Council, and the
       Innovation Action Council reviewed the plan. In concert with the other
       Cooperative Conservation agencies, EPA consulted about the appropri-
       ate scope and definition of competencies with outside experts on collab-
       orative problem-solving, some of whom facilitated the White House
       Conference.

       EPA also established an internal system for recognizing excellence in col-
       laboration in 2006 and presented its first awards in 2007.

    •  EPA Leadership of and Participation in Cooperative  Conservation
       Activities: EPA is leading and participating on several Cooperative
       Conservation working groups, focusing on:
          •   Potential FACA barriers to collaboration and possible legislative
             solutions.

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        •   Innovative ways to engage the public in federal decision making
           (both regulatory and non-regulatory - i.e., regulatory negotiation
           and e-rulemaking).
        •   A user's guide to legal authorities related to cooperative conser-
           vation.
        •   Expansion of environmental conflict resolution capacity.
        •   Creating and promoting market-based incentives (EPA is sponsor-
           ing 2 workshops on the effective use of trading in March and May,
           2006).

    The Agency has also recently sponsored a workshop on use of regulatory
    negotiation with DOI. Areas of interest to conference attendees where
    workgroups have not yet  been formed include creating a more outcome
    based approach to cooperative conservation, development of scientific
    data and information to support cooperative conservation, and meas-
    urement and monitoring.

Some Questions EPA is Confronting on Environmental Stewardship
and Cooperative Conservation

 1.  For what types of environmental problems and conditions can environ-
    mental stewardship and Cooperative Conservation approaches be most
    useful?
 2.  How should EPA approach the task of enabling the Agency to focus more
    effectively and regularly on sustainable outcomes? How might we sharp-
    en the way we approach the six sustainable outcomes cited in the
    Everyday Choices report?
 3.  How can EPA best approach the major external parties which it needs to
    reach - individuals, business, communities and government organiza-
    tions? In particular,  how can EPA best reach individuals and states? As the
    White House Conference  challenged us, what are the most promising,
    productive opportunities to change EPA's culture to emphasize the
    achievement of our mission through collaboration and partnerships with
    other stakeholders?
 4.  How can EPA measure progress and success better for sustainability and
    environmental stewardship and Cooperative Conservation  and what new
    information do we  need to develop? In this connection, how can EPA
    better involve partners and stakeholders to develop clear goals, objec-
    tives, and criteria for measuring progress and success?
 5.  To build more trusting relationships with partners and stakeholders on envi-
    ronmental stewardship and Cooperative Conservation, how can we best
    ensure that outreach and information sharing are effective, communica-
    tions are clear and consistent, and decision-making processes are inclu-
    sive and transparent?
 6.  How can EPA move to a comprehensive agency-wide strategy on envi-
    ronmental stewardship and Cooperative Conservation? What else can
    EPA do to improve  the internal clarity of its role in these areas? In particu-
    lar, how can EPA do this given the nature of its organization, culture,
    statutes, appropriations and so forth?
 7.  Concerning issues of human resources and capacity building, how can
    EPA best build the collaborative competencies of its staff?  What are the
    key competencies and how should they be defined?
 8.  Where are the best opportunities for EPA to work with other federal agen-
    cies on environmental stewardship and Cooperative Conservation?
                               o

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       Should we pursue collaborations on a selective opportunity basis or
       should we develop a strategy for a more systematic approach?
   9.  What (if any) related issues concerning legislation does EPA need to con-
       sider?

III. Charge to NACEPT

   EPA requests NACEPT to provide assistance as follows. NACEPT's advice and
views would be most helpful if supplied to the Agency within approximately 12
months of receiving this charge.

   1.  Review Everyday Choices: Opportunities for Environmental Stewardship,
       plus the associated Implementation Plan. The review should address the
       following questions:
       •  Is the vision of environmental stewardship appropriate and is what it
          implies for the focus and role of EPA realistic?
       •  Is the evaluation of EPA's current environmental stewardship activities
          on target?
       •  Do the five sets of options for EPA that are described appear to include
          the most important opportunities, both overall and individually?
       •  Does the Implementation Plan direct EPA's attention  to the most
          important opportunities?
       The review should also address at least the first four questions in Part II
       above, plus any of the other questions in Part II that NACEPT decides to
       address.

   2.  Evaluate EPA's activities in support of the interagency Cooperative
       Conservation Action Plan. Consider in particular EPA's efforts in the follow-
       ing areas, as well as any questions in PART II above that NACEPT is able to
       address:
       •  Human resource systems
       •  EPA leadership of Cooperative Conservation efforts
       •  Innovative ways to engage the public in federal decision making
       •  Strategic approaches to empower states/local communities to initiate
          more collaborative problem solving (i.e. incentives, community envi-
          ronmental management systems)

   3.  Write a report to the Administrator describing NACEPT's findings and rec-
       ommendations relating to items 1 and 2 above. The report should address
       what EPA needs to do to meet the challenges of sustainability and stew-
       ardship of our natural resources by all parts of society, and of increasing
       collaborative decision-making by EPA.

       In this report NACEPT may also choose to reflect on related general issues
       and how they may affect the Agency's mission, roles, and future direc-
       tions, including:
       •  The changing nature of environmental  challenges, our evolving
          understanding of their origins and consequences, and the expanded
          goals that many members of society are adopting, especially con-
          cerning  sustainability,  and the greater realization of participatory
          democracy through stakeholder and public inclusion in governmental
          decision-making.
       •  The results of NACEPT's other recent assignments (energy and environ-
          ment, water infrastructure, new technologies, and innovative partner-
          ships and approaches).

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•  Some related activities at EPA, e.g., partnership/voluntary program
   coordination and the Sustainability Research Plan.

The report could be loosely modeled on the EPA Science Advisory
Board's 1990 report, Reducing Risk: Setting Priorities and Strategies for
Environmental Protection, in which the SAB reviewed the Agency report,
Unfinished Business: A Comparative Assessment of Environmental
Problems, and made recommendations to the agency on implementa-
tion.

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                           National Advisory Council for
                       Environmental Policy and Technology
December 22, 2006
The Honorable Stephen L. Johnson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Re: Initial Thoughts on Environmental Stewardship

Dear Administrator Johnson:

In May 2006, you asked the National Advisory Council for Environmental Policy and Technology
to review and offer advice on EPA's efforts to advance environmental stewardship and cooperative
conservation. This letter reflects the Council's initial thoughts about EPA's environmental stew-
ardship initiatives.  While we have yet to turn to cooperative conservation in any detail, we did
want to convey our initial impressions and pose some questions about the Agency's embrace of
environmental stewardship.

The National Environmental Policy Act, passed more than 35 years ago and before the
Environmental Protection Agency was established, proclaimed the following bold vision of envi-
ronmental stewardship for the Federal Government and America:

        [T]he Federal Government, in cooperation with the State and local governments and
        other concerned public and private organizations, [should] use  all practicable means
        and measures ... to foster  and promote the general welfare, to create and maintain con-
        ditions under which man and nature can exist in productive harmony, and fulfill the
        social, economic, and other requirements of present and future generations of
        Americans.

The vision of environmental stewardship proposed by EPA's Innovation Action Council in its
report, Everyday Choices: Opportunities for Environmental Stewardship, incorporates this NEPA
stewardship vision and explains how it can apply in addressing early 21s  century issues:

        As our population and economy continue to expand, the U.S. can accelerate environ-
        mental progress while simultaneously strengthening our global competitiveness.  In
        short, we have exciting opportunities to create a more sustainable future in this country
        and with our partners around the world. However, this bold goal cannot be accom-
        plished by government alone; rather it requires the active engagement of all people. To
        this end,  we have a vision of environmental stewardship - where all parts of society
        actively take responsibility to improve environmental quality and achieve sustainable
        results.

NACEPT applauds and supports this vision. Over the past several months, NACEPT has met
with EPA management and career professionals to discuss the IAC report and your charge to the
Council. NACEPT has established a Workgroup of Council members (chaired by Erik Meyers
and Jennifer Nash) to take the lead in shaping recommendations.  The membership of the
Workgroup is diverse, representing local and state government, business,  law and architectural
professions, academia, and conservation organizations.  We have held a number of working ses-
sions, in person and via teleconference, of the Workgroup and the full Council.  From these dis-
cussions have emerged several points of consensus and a few questions.
                                          V'

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First, the IAC report announces a vision of an enhanced role for EPA in promoting environmental
stewardship. While, again, we concur with the vision, we have some questions about implementa-
tion. Will EPA's new emphasis on stewardship require new activities and programs or, instead,
will the Agency reframe existing activities and programs?  In either case, will new resources be
required? If new resources will be needed to pursue the vision, does the Agency envision a real-
location within the existing overall budget or would it seek increased funding in order to address
environmental stewardship?

In our view, environmental stewardship will  require a shift in EPA's organizational culture and a
shift in the cultures of other institutions as well. We acknowledge that cultural change is difficult
to achieve and may take many years. Our view is that such a shift can occur when there is an
acknowledgement that business as usual is no longer  sufficient or efficient. From reading the
Everyday Choices report, NACEPT concludes that EPA acknowledges and supports societal
changes that embody stewardship. However, we are uncertain as to the Agency's views on the
urgency or magnitude of the changes necessary.

To help EPA career professionals appreciate  the need for change and to help the public and vari-
ous stakeholders embrace stewardship behavior, EPA will need to be more specific on the estimat-
ed time frame. Although some may believe  that successfully making the major shift to environ-
mental stewardship is likely to take at least a generation to realize, the Council believes much can
(and should) be accomplished now.  Motivating an agency of 18,000, let alone a nation of many
interests, will require a clear signal that all elements of society need to share in the effort to
achieve environmental quality, economic improvement, and social equity at home and abroad.

We believe that creating an enhanced EPA role in environmental stewardship will entail much
more than simply rebranding its current voluntary programs. NACEPT discussions to date agree
that important roles for EPA in stewardship will include supporting other actors and removing
obstacles to stewardship and sustainable action. EPA can also provide leadership by modeling
behavior, actions, and attitudes to provide illustrative case studies from which others can learn and
emulate.

However, another important message of Everyday Choices, with which we strongly agree, is that
EPA cannot achieve the goal of environmental stewardship working on its  own.  At this point in
our review, NACEPT is unclear what specific activities EPA envisions for  building support for
stewardship among all sectors of society—public and private organizations, communities, and
individuals.  We are also unclear on which EPA programs and activities the Agency believes fit
under the stewardship heading and which do not.  We expect to examine these implementation
questions during the coming months in order to make additional observations and recommenda-
tions to you in 2007.

Second, as EPA moves to embrace environmental  stewardship more fully, it should consider how
it will assess the effectiveness of these  efforts.  As a preliminary matter, EPA's evaluation of its
stewardship efforts is likely to require new measures of system effectiveness.  We suggest that
these may be more outcome-related than  output measures, such as, for example, viewing steward-
ship efforts as they simultaneously affect the community, economy, and environment—a systems
approach.

Positive improvements in environmental  quality in a region or the nation as a whole, as reflected
in EPA's Report on the Environment, may be among the best metrics, although establishing the
causal link between such improvements and  EPA's stewardship activities would be difficult.
Internally, we believe that EPA will need to begin  by  examining current employee job descrip-
tions, performance plans, office performance, and interdependence of staff and program require-
ments to  assess the degree to which stewardship is incorporated, including whether stewardship is
encouraged or inhibited.

Third, it is essential that the Agency be perceived as encouraging others to become stewards and
assume responsibility within their spheres of influence and control, while continuing to maintain
its robust regulatory role. We observe that EPA's traditional environmental regulatory role has
contributed and continues to contribute to sustainability and a higher quality of life.  We would
expect the proposed greater emphasis on  environmental stewardship will help the Agency be even
more effective in the years ahead. The IAC  report contains hints that the Agency can integrate
stewardship into its regulatory actions,  and we concur that this integration  would be valuable.

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The Workgroup and Council's next steps in responding to your charge will be to look at how the
Agency can best:

    •  Implement the IAC environmental stewardship recommendations;
    •  Reach out and engage individuals in environmental stewardship;
    •  Implement its commitment to cooperative conservation; and
    •  Involve other types of stakeholders in environmental stewardship and cooperative
       conservation.

We appreciate the opportunity to provide these initial reflections on the environmental steward-
ship portion of your charge to NACEPT. By acknowledging the need to embrace and promote
environmental stewardship, EPA also acknowledges the dynamic and interdependent natures of
the environment, economy, and society. We applaud the Agency for working to advance environ-
mental stewardship and cooperative conservation, and we look forward to submitting our report to
you in 2007.
                              Respectfully submitted,

                              /Signed/

                              John L. Howard, Jr.
                              Chair
cc: Erik Meyers, Workgroup Co-Chair
    Jennifer Nash, Workgroup Co-Chair
    Marcus Peacock, Deputy Administrator
    Charles Ingebretson, Chief of Staff
    Ray Spears, Deputy Chief of Staff
    Jay Benforado, Director, National Center for Environmental Innovation
    Derry Allen, Counselor, Office of Environmental Policy Innovation
    Rafael DeLeon, Director, Office of Cooperative Environmental Management
    Sonia Altieri, NACEPT Designated Federal Officer

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    Our hypothetical case studies—a cotton shirt, an office building, and a river-
provide in summary fashion, a snapshot of the opportunities for stewardship in
every day contexts. Virtually everyone owns at least one cotton t-shirt, we are
familiar with many types of buildings from homes to office buildings and many
other places in between, and the experience of a stream or river is familiar again
to virtually everyone. It is with these examples that we begin to look more closely
at the opportunities for stewardship to make a difference in our world.

•  i  r**ri
   Background. Cotton is grown on more than 90 million acres in more than 80
countries worldwide. The United States is the second largest cotton producer
after China.  In 1997, the 18 cotton growing states in the United States grew
enough cotton to make 9 billion t-shirts.24 Because  U.S. cotton makes up 40 per-
cent of world exports, there is a good chance that  even t-shirts bearing a "made
in China" label are made from cotton grown in the United States. The U.S.
Government provides cotton farmers more than $1  billion/year in subsidies,25

   Opportunities for Stewardship in Growing     Manufacturing Cotton
Products, Conventional cotton growing uses approximately 25 percent of the
world's insecticides and more than  10 percent of the pesticides.26 To illustrate, it
takes one-third of a pound of toxic chemicals to produce one conventional cot-
ton t-shirt. Seven of the top 15 pesticides used on cotton are "possible or known
carcinogens."27 One key stewardship opportunity is to purchase a t-shirt  made
with organic cotton. Organic cotton is grown without synthetic fertilizers, pesti-
cides, herbicides, insecticides, or defoliants.28  This is not a Utopian option; major
apparel manufacturers such as Patagonia, Nike, Timberland, and Cutter  and
Buck have been incorporating organic cotton into their product lines.

   Manufacturing a cotton shirt, whether of conventional or organic cotton,
requires large volumes of water throughout the manufacturing process, which
includes spinning, weaving, scouring,  and sizing. All of these processes require
flushing the threads or fabric with water at one point or another.  As water sup-
plies come under increasing demand, another stewardship opportunity lies with
manufacturers to devise an improved process using less water. Assuming  that the
decrease in water would lessen both economic and environmental costs, the
manufacturing innovator could realize advantages in the marketplace.

   Opportunities for Stewardship in Cotton T-Shirt Life Cycle. Beyond manufac-
turing lie even greater opportunities to apply stewardship concepts. Cleaning
cotton garments uses more energy than cleaning polyester because cotton must
be washed frequently at high temperatures and generally requires tumble drying
and ironing.  Sixty percent of the carbon emissions generated by a cotton t-shirt
comes from the 25 washes and tumble dryings it will require during its useful life,
according to a Cambridge study.29 One study performed for the American Fiber
Manufacturers Association found that consumer use and maintenance of the
product had a greater environmental/energy impact than product manufacture.
Life span (number of times a garment could be worn) and laundering practices

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•
   produced the greatest environmental impacts. Opportunities for stewardship
   exist in using cold water to wash the t-shirt that would reduce the need for water
   heating and improving efficiency of home laundering machines, thus decreasing
   energy demand.

       Choice of Stewardship Approaches. In terms of environmental stewardship,
   there are a number of everyday choices that can be made in relation to a cot-
   ton shirt.  Although EPA has a role in regulating the toxicity in pesticides and her-
   bicides used in the growing of conventional cotton, the market may send more
   powerful signals. EPA can work with other institutions to describe authoritatively
   the environmental footprint of cotton and provide information about a benign
   and effective substitute, organic cotton.  Ultimately, consumers decide and need
   to make purchasing decisions based upon better information.

       Because wear is a critical component of the environmental footprint of a cot-
   ton shirt, consumers can purchase shirts that need as  little care as possible (e.g.,
   easy care). In addition, consumers can purchase shirts that can be washed in
   cold water without the need for tumble drying—and make the decision to follow
   recommended  directions to use cold water  in washing these items. These are all
   stewardship choices with little connection to a regulatory role. Pricing  of power
   (electric or gas) provides one avenue of influencing consumer choice.

       To the extent laundering is required, consumers can choose to purchase
   Energy Star appliances. An Energy Star washer uses 18-25 gallons of water per
   load compared to 40 gallons for a standard washer.  If a cotton shirt will be
   washed 25 times before it is discarded, the water savings could be  as high as 550
   gallons if an Energy Star Washer is used to wash that cotton shirt.30  Manufacturers
   of washing machines can be encouraged to provide labels on the machines
   describing how  much energy can be saved by washing garments in cold versus
   hot water. About 90 percent of the energy consumed to wash a cotton shirt is for
   heating the water.31 A person using a standard clothes washer, doing five loads
   of laundry a week, would save 155 kWh and 517 pounds of CO2 per year if they
   switched from hot water to cold water.32 Moreover, hot water is needed only to
   clean a cotton shirt if it is greasy or heavily soiled. This information can be provid-
   ed at the point  of sale and/or on the machine to allow better choices. Again,
   information provided  by EPA creates both added market opportunities for manu-
   facturers and the basis for consumers to make improved stewardship choices on
   several levels.
The      Building Example
       7ih/s case study illustrates the opportunities for environmental stewardship con-
   siderations to be interwoven into siting, design construction, operation and main-
   tenance, and end of use. The list is not meant to be exhaustive but illustrative.
   Environmentally beneficial results that could be achieved by applying these
   stewardship approaches include: energy consumption reduction, improved
   indoor air quality and lighting, and minimization of off-site stormwater impacts,

       Location, The architect, builder, potential owners, and local governmental
   officials have a number of aspects related to a proposed location for a building
   that will have major consequences for its environmental footprint, both immedi-
   ate and longer term.  The building's placement on a site should involve consider-
   ing orientation to sun during full year and daily cycle. Lot orientation can maxi-
   mize passive and active solar considerations and will drive the building's energy
   footprint.
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    Other site level considerations include potential impact on water resources:
avoid placement over source water, in floodplain, wetlands, or riparian zone. For
greater stewardship, employ strategic, green infrastructure assessment and think-
ing to assure connected habitat not just for its human inhabitants but for wildlife
and to assure maximum natural water infiltration and flows. In addition to energy
use, water, and wildlife, there are opportunities to apply Smart Growth principles
to building site selection. These considerations could include locating near avail-
able public transit, maximizing pedestrian and bike access, giving preference to
a location with established infrastructure, and reusing a brownfield or another
previously developed site. Although some of these choices may involve EPA
using its regulatory authority—for example, preventing the location of buildings in
floodplains or wetlands—generally the opportunities are informational, building
public-private partnerships, model projects, and funding and/or recognition pro-
grams.

    Design and Construction, Not just the site, but design choices and materials
offer an exceptional set of opportunities to exercise stewardship and lighten the
environmental footprint of a building. Climatic considerations, in addition to solar
exposure, need to be addressed in a building's orientation and design. Energy
efficiency can be addressed by design features that maximize use of natural
convection and lighting that cool, ventilate, and illuminate interior spaces to the
extent possible. On the exterior, minimize surface parking and other paved sur-
faces; maximize onsite water infiltration  in landscaping,  using native species, and
building design such as onsite cisterns, rain barrels, or green greens. Further con-
siderations address human health issues. Many conventional finishes, products,
and furnishings may have indoor air quality impacts from off-gassing and odors.

    For construction purposes, the use of durable materials that can be obtained
locally will reduce the environmental impact. There also may be opportunities to
reuse materials from deconstructed buildings. During construction, local govern-
ments typically regulate impacts such as dust, sediment, water, and noise but
going beyond the minimum can create a positive opportunity for the project
developer.

    Operation and Maintenance.  Yet another set of opportunities are present
with the building's operation and maintenance. One such opportunity is to seek
green-sourced power and/or to sell power to the grid in peak sunny times if solar
panels have been installed.  Natural pest control techniques can minimize use of
pesticides and toxins inside the new structure.

    Building management can encourage recycling of any and all recyclable
materials by supplying appropriate collection systems and markets.
Management should maintain the HVAC system at peak operating capacity to
assure supply of healthful air and combat ventilation system-borne illnesses. To
cut down on unnecessary power consumption, the building should install and
keep in working repair motion and photo-sensor lighting switches. Instead of using
convention incandescent lighting, opt for compact fluorescent light bulbs  (CFL)
and even light emitting diode (LED) lighting options, as the latter become com-
mercially viable technology. Finally, the building can provide facilities for bicycle
commuters and encourage commuting via public transit or by walking.

    These actions point to research, testing, model  applications, information shar-
ing, and partnership approaches for EPA to support stewardship choices.  More
directly, the Agency might provide incentive funding, and participate in product

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   standards development and the development of some health standards for
   indoor exposures.

       End of Useful Life, Buildings tend to have relatively short life spans in the
   United States. One way to effectively minimize their footprint over time is to sup-
   port adaptive reuse of structures.  Alternatively, reuse of deconstructed materials
   and recycling sites for new and greener buildings help lighten the footprint of
   buildings on the environment.
•
The
       One way to approach river stewardship (assuming responsibility for environ-
   mental integrity, protection,  and improvement and acting accordingly upon that
   assumption of responsibility)  is by thinking about the usage of a river for different
   human purposes, directly and indirectly, and the actor(s) using it for each such
   purpose, Desirable outcomes include: maintenance of natural flow regime,
   maintenance or restoration of water quality, maintenance of habitat functions
   for naturally occurring species, and avoidance of human-induced flooding,

       Consumptive     and impacts. Home and apartment owners use water for
   consumptive needs and personal hygiene. Stewardship behaviors include instal-
   lation of low-flow showerheads and toilets and promptly fixing leaks and drips.
   Showers and baths should be monitored and excessive water use should be elim-
   inated. Externally, owners can maximize onsite infiltration and use of available
   technology such as rain collection barrels, rain gardens, and disconnected
   downspouts.

       For farmers and landscape specialists today, water is an increasingly critical
   element. Best management practices (BMPs) and the strategic conservation
   approach of green infrastructure assessment and planning underlie many specif-
   ic stewardship choices; green infrastructure assessment can inform the watershed
   community and users of essential needs for maintaining a healthy watershed and
   BMPs offer guidance, if not standards, for specific actions involving water use. For
   instance, specific stewardship actions for farmers might include fencing to pre-
   vent livestock from getting into the stream or river, growing climate-appropriate
   crops to eliminate the need  for irrigation, and not mining (using) groundwater for
   crop production. To preserve the health of the river's waters, farmers must assure
   that, if used, fertilizers and pesticides are applied only at appropriate times and in
   minimum amounts and that  overspray into aquatic areas is avoided, especially
   during spawning season. The better stewardship choice would be to seek dis-
   ease resistant varieties or change crops to eliminate the need for pesticides/ her-
   bicides.

       Farmers, landscapers, and forestry managers should consider installing and
   maintaining riparian buffers of native (tree or grass) species. Using  locally native
   species of trees and grasses for highway, street, and yard landscaping can help
   minimize the need for added water. Swales and other low impact design can
   hold and control wet weather flows to avoid the sharp peaks and drops of urban
   streams.

       Another key stewardship practice is to restore streams enclosed in culverts
   and pipes to daylight. This practice helps eliminate a significant source of bacte-
   ria in watersheds and provides other benefits as well. Natural stream meanders
   and pools need to be preserved.  Restoring riparian twists and bends will provide
   for more natural river flows and support habitat for vital aquatic species.

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    For industrial and commercial users, stewardship opportunities abound to
reshape processes to reduce or recycle or eliminate water in the production of
products or services, e.g., electricity. Water also is used, thus diverted from sur-
face water supplies such as local rivers, for cooling, washing, and landscaping.
There is some considerable overlap with building design and operational consid-
erations, such as low flow toilets and waterless urinals that can provide clear
means of expressing stewardship in the industrial sector. Industrial users also have
opportunities on occasion to remove unnecessary dams and water obstructions
and permit the management of corporate lands as natural areas to the maxi-
mum extent possible

    Non-Consumptive Impacts.  Just as there are a variety of consumptive uses of
a river,  there are many non-consumptive ones. For example, recreational boat-
ing use involves powered craft and a wide variety of sailing, rowing, and pad-
dling boats. Millions of people use the nation's rivers and streams for boating
recreation. Simple lessons of stewardship applied during these  outings will help
pass on such experiences unimpaired to  future generations. Among stewardship
practices is to keep boating motors in good repair and to exercise care in filling
gasoline storage containers. Spilled into the water or on shore near waters, gaso-
line and oil create environmental hazards and threaten wildlife. Simple measures
such as keeping gasoline storage in a catchment basin away from shoreline and
navigating at lower speeds near erodible or otherwise sensitive shorelines help
provide a  margin of protection for these  sensitive environments.

    Landowners can help maintain healthy riparian marshes, mangroves, and
other natural buffers that not only help environmentally but add to the beauty of
river recreation. What happens on land always affects the quality and quantity of
surface and ground water. Stewardship opportunities are present across the
watershed to assure that nonpoint discharges such as solid or liquid waste,  road
salts, and sediment are not washed into storm sewers or dumped directly into the
river or stream. Although Clean Water Act protections prohibit  most direct dis-
charges, nonpoint or diffuse discharges away from the stream are in the aggre-
gate of equal or greater importance to stream health. Landowner or local gov-
ernment actions that keep water onsite, such as using swales instead of pipes,
disconnecting downspouts, and constructing rain gardens, will help reduce the
nonpoint pollutant load on rivers and streams. Planting native (xeric where
appropriate) plants and minimizing or avoiding use of fertilizers and pesticides
altogether will help  keep the river healthy. For landowners, local and state agen-
cies, and corporations, the opportunity to maximize forest and woodland cover
provides the best opportunity to improve stream quality, flow, and overall health
because forest land cover is optimum for water quality.

    This example illustrates again that, although traditional EPA and state regula-
tions are vital to the health of a river, there are many other aspects of watershed
health that are either not regulated or involve a myriad of sources, potential
users, and choices.  The downstream benefits accruing from greater EPA leader-
ship on stewardship can hardly be overstated.

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    NACEPT has articulated the meaning of stewardship as an ethic of shared
responsibility to protect our environmental health, the integrity of our natural
resources and ecosystem services; and in so doing, safeguard the interests of
future generations. Thus, stewardship serves as a framework for how to place
people—with our social, cultural, economic, and environmental norms—into the
larger context of Nature.

    Stewardship is an ethic of respect for the inherent values of healthy natural
systems; and it is a set of practices that sustain those benefits for current and
future generations. Stewardship is thus embodied as both an ethic (a set of
beliefs and values) and  as a practice (a set of behaviors). The ethical and prac-
tical aspects of stewardship operate to reinforce each other—the ethic informs
the practice and the practice enriches the ethic.

    Rather than superimpose a new mental framework on society, we can gain
considerable insight by looking at traditional and historical usage—how
antecedent societies viewed their responsibility to Nature. By examining and
understanding the cultures and lifestyles of the past, EPA can gain the confi-
dence to become the leader of environmental stewardship.

    Stewardship values and norms can be found in the context of traditional
indigenous cultures (the Native American). Stewardship values and norms also
are found in the evolving American view of people's relationship to  the land.



    Indigenous peoples  manifest many cultural values and norms that give
expression to the notion of stewardship. This is profoundly so, despite the ubiqui-
tous stereotypes depicting Native Americans as living in harmony with Nature in a
peaceful, serene, and apparently static existence. A simplified recitation of such
values and norms follow:

    S  Traditional values are encompassed within the notion of traditional eco-
       logical knowledge; an understanding of Nature that has resulted from
       generations of interacting with the environment and using its bounty.

    S  Indigenous peoples exhibit a reverence for place; a geographic/spatial
       reference that orients people with their land and gives them a sense of
       history, rootedness, and belonging.

    II  Traditional cultures maintain a guiding ethic of interdependence and rec-
       iprocity; a  holistic view of people's relationship with their natural environ-
       ment.

    *?:  Native Americans have traditionally used custom to regulate the use of
       their environment for present and future generations.

    3  Indigenous peoples see their environment as a renewable resource and
       life-support system to be conserved for posterity, such that avoidance of
       waste and responsible use of resources became guiding principles.

    S  Indigenous peoples often bond together as a community with the ethic
       of responsibility and respect, to each other and to future generations.

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    From these limited examples of indigenous peoples' values and norms—tradi-
tional ecological knowledge; a reverence for place; interdependence and reci-
procity with nature; valuing renewable resources; and the ethic of responsibility
and respect for community—the origins and basis for our  current notion of stew-
ardship begin to become apparent.

    Evolving American Thinking on Stewardship

    Early in the history of European-American society, guided by Judeo-Christian
teachings of "man's dominion over Nature," we viewed our natural environment
as vast, limitless, and boundless.  We viewed it as an external system (outside of
humankind) that provided resources for people's use and as a repository for our
waste products. This view has shifted significantly over time with the develop-
ment of an American land ethic and the growth of modern environmentalism.

    The following examples illustrate the profound shift over time of American
thinking:

    •  An American vision of land use emerged with John Muir's ethic of respon-
       sibility, which focused on environmental  conservation.34 Muir's views
       included an ecological land ethic in which Muir believed that land is a
       temple, and that land has an aesthetic and spiritual value to be protect-
       ed.

    •  Aldo Leopold, in his essay "The Land Ethic," held that man was an intrinsic
       part of nature; that man had a duty of respect for the natural communi-
       ty. Leopold rejected the economically expedient use of land, and
       instead asserted that we must consider what is ethically and aesthetically
       right.  ("A thing is right when it tends to preserve the integrity, stability,
       and beauty of the biotic community. It is wrong when it tends other-
       wise.")35

    •  Theodore Roosevelt embraced conservation of the land (albeit for game
       management, forest yield, and recreational opportunities) by setting
       aside and protecting millions of acres of land under federal jurisdiction.
       This conservation movement has been sustained to this day.

    •  Franklin Delano Roosevelt,  in his New Deal, continued to support conser-
       vation efforts focused on soil erosion, wildlife management, water quality,
       agriculture,  and forestry. Federal systems were developed to regulate
       the use of the nation's natural resources. The conservation ethic was
       merged with federal regulatory authority to create the legal underpin-
       nings of the modern environmental era.

    •  In the 1960s, 1970s, and beyond, federal and state laws were enacted to
       control and abate pollution, and to attain national standards of environ-
       mental quality. Nongovernmental organizations proliferated to advocate
       (and litigate) for a variety of environmental ends:  wilderness, open space,
       land conservancies, wildlife and endangered species, forest and  range
       management, pollution controls, environmental justice, and community
       right-to-know. All of these  efforts have coalesced into the modern envi-
       ronmental era.

    From these limited examples of the evolution of American thought, the ethic
of responsibility emerges and the modern notion of stewardship takes shape.

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The National Environmental Policy Act

   Comparing the ethics exemplified by indigenous peoples with the evolution
of an American conception of a land ethic, one can distill and appreciate the
traditional and historical roots of stewardship. The merger of indigenous peoples'
ethics, values, and norms with the evolution of American environmental manage-
ment is found in the seminal purposes of the National Environmental Policy Act
(NEPA) of 1969. NEPA was written broadly to encompass the philosophy of stew-
ardship and to create mechanisms to implement and monitor its provisions.

       "The purposes of this Act are: To declare a national policy which will
       encourage productive and enjoyable harmony between man and his
       environment; to promote efforts which will prevent or eliminate damage
       to the environment or biosphere and stimulate the health and welfare of
       man; to enrich the understanding  of the ecological systems and natural
       resources important to the nation..."36

   Today, some 37 years later, NEPA remains highly relevant and increasingly
important as society strives to rediscover and inculcate the values and norms of
indigenous peoples; and to integrate the evolution of American thinking about
conservation, regulation, and people's responsibility to the integrity of ecosystems
into an overarching framework of stewardship.

   As we strive to understand and accept the traditional and historical roots of
stewardship and to embrace a community-wide consensus of stewardship as our
moral and ethical compass for our path forward, we can be inspired by the
Iroquois' decision-making criterion:

   "Will this be to the benefit of the seventh generation?"

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    In numerous instances, there is a commonality between the recommenda-
tions set forth in our report and the ideas and proposals set forth in Chapter 3 of
Everyday Choices.  Although many of our recommendations are consistent with
those in Everyday Choices, NACEPT's view is that EPA should not only embrace
the challenges and opportunities set forth in Everyday Choices, it must act imme-
diately and boldly to take advantage of the changing public mood regarding
the willingness to take collective and individual action to ensure a sustainable
environment.

  Encourage EPA staff to reach
  out locally to promote stew-
  ardship practices.
  3.2,1)
Every EPA employee has the potential to be
a stewardship ambassador.
                 4,       4.1)
  EPA should set bold public
  goals and lead by example.
  (Section 3.3.1)
EPA should strive to become the world's pre-
mier stewardship model and catalyst...
                 2)
  EPA should encourage stew-
  ardship behavior in EPA
  employees. (Section 3.3.3)
The pending generational turnover of EPA's
workforce presents a compelling opportunity
to recruit and equip new employees with
skills needed for stewardship and collabora-
tive governance.                  4,
       4,3)
  Top EPA team must "walk the
  talk" and reinforce consistent
  environmental stewardship
  messages.         3.4,1)
EPA should drive the ethic and practice of
stewardship deep into the culture of the
Agency by clearly and consistently commu-
nicating the ethic and practice of steward-
ship to all employees...
5,                5,1)
  EPA should train all staff on
  environmental stewardship
  principles, responsibilities and
  opportunities.         3.4.2)
The Innovation Action Council should work
with the Office of Human Resources to
appoint a subcommittee to focus on recruit-
ing and training  strategies...
                 4,               4.1)
  EPA should incorporate envi-
  ronmental stewardship as a
  priority in staff accountability
  systems.         3,4.3)
OHR should establish a new generic per-
formance standard ... that will recognize
and reward superior performance in the
service of stewardship.                  5,
               5.4)
  EPA should encourage stew-
  ardship in communities.
          3.6)
The Administrator should regularly encour-
age Assistant and Regional Administrators to
use stewardship approaches to address pro-
gram and regional priorities.
                 5,                5.2)
  EPA should partner with other
  countries to share experi-
  ences about product stew-
  ardship.         3.7.6)
The Administrator should communicate EPA's
interest in exchanging ideas and information
on the best environmental stewardship prac-
tices to leaders of foreign environmental
agencies.                  2,
Step 2.3)

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EPA should set clear environ-
mental stewardship goals
and objectives.
4,1.3.1)
Each program office should set goals with
measures of progress and success for each
major collaborative effort—in cooperation
with collaborators—taking into account cul-
tural, social, and economic benefits along
with environmental benefits.
                 3,                3.2)
EPA must develop a coher-
ent message by explaining
what stewardship means
and how it fits into the mis-
sion.          4.2)
EPA should reframe its mission with steward-
ship as the unifying theme and ethic. The
Administrator should share and promote the
environmental stewardship message with
other cabinet-level agencies; Congress; trib-
al, state, and local governments; as well as
private-sector firms, nongovernmental
organizations, and the American public.
                 1,                1,3)
Regional Plans can present
an opportunity for articulat-
ing the use of environmental
stewardship approaches to
achieve ongoing program-
matic outcomes.
4.4.3.2)
The Administrator should regularly encour-
age Assistant and Regional Administrators to
use stewardship approaches to address pro-
gram and regional priorities.
                 5,                5,2)
EPA should submit budget
proposals to advance envi-
ronmental stewardship.
The Deputy Administrator should align EPA
strategic planning, budgeting, and account-
ability processes to explicitly address stew-
ardship goals.                   5,
               5.3)
EPA should strengthen envi-
ronmental stewardship
through environmental edu-
cation.
The Office of Environmental Information and
Office of Public Affairs should work with the
program and regional offices to review and
enhance information dissemination, disclo-
sure, and educational activities to strength-
en the stewardship practices of others
                 4,               4.5)

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BMP       Best Management Practices

CEQ       Council on Environmental Quality

CFL       Compact Fluorescent Light Bulb

DFO       Designated Federal Officer

EMS       Environmental Management System

EPA       U.S. Environmental Protection Agency

G8        Group of Eight Nations (Canada, France, Germany, Italy, Japan,
          Russia, United Kingdom, and United States)

IAC       Innovation Action Council

LED       Light Emitting Diode

NACEPT   National Advisory Council for Environmental Policy and Technology

NEPA      National Environmental Policy Act

NGO      Nongovernmental Organization

OARM     Office of Administration and Resources Management

OCEM     Office of Cooperative Environmental Management

OCFO     Office of the Chief Financial Officer

OECD     Organisation for Economic Co-Operation and Development

OEI       Office of Environmental Information

OHR       Office of Human Resources

OPA       Office of Public Affairs

OPEI       Office of Policy, Economics, and Innovation

ORD       Office of Research and Development

P3        People, Prosperity, and the Planet

RCRA     Resources Conservation and Recovery Act

SES       Senior Executive Service

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1     Speech to the American Iron and Steel Institute, October 25, 2006. (Available on the Web
     at http://www.epa.gov/stewardship)

2    U.S. Environmental Protection Agency.  Everyday Choices: Opportunities for Environmental
     Stewardship. Washington, DC: Environmental Protection Agency, 2006, 19 pp. (Available
     on the Web at http://www.epa.gov/epainnov/pdf/rpt2admin.pdf)

3    EhrenfeldJ. Beyond Sustainability: Why an All-Consuming Campaign to Reduce
     Unsustainability Fails. Available from ChangeThis at http://changethis.com/25.03.
     BeyondSustain.

4    Traditional knowledge is described in Appendix 6 of this report.

5    U.S. Environmental Protection Agency.  ERA'S Legal Framework Supports Collaboration,
     2007, 18 pp. (http://www.cooperativeconservation.gov/library/EPALegalauthorities082407.
     pdf)

6    The NACEPT Workgroup reviewing the Report on the Environment Highlights Document was,
     still deliberating when the Council approved this report.

7    The first three NACEPT advice letters on biofuels raise the issue of impact of biofuel produc-
     tion on water supplies and water quality.

8    U.S. Environmental Protection Agency. Unfinished Business: A Comparative Assessment of
     Environmental Problems, 1987.

9    U.S. Environmental Protection Agency Science Advisory Board. Reducing Risk: Setting
     Priorities and Strategies for Environmental Protection, 1990.

10   U.S. Environmental Protection Agency.  Everyday Choices: Opportunities for Environmental
     Stewardship. Washington, DC: Environmental Protection Agency, 2006, 19 pp. (Available
     on the Web at http://www.epa.gov/epainnov/pdf/rpt2admin.pdf)

11    U.S. Environmental Protection Agency.  2006-2011 EPA Strategic Plan, Charting Our Course.
     Washington, DC: Environmental Protection Agency,  2006, 129 pp.

12   U.S. Environmental Protection Agency.  Everyday Choices: Opportunities for Environmental
     Stewardship. Washington, DC: Environmental Protection Agency, 2006, 19 pp. (Available
     on the Web at http://www.epa.gov/epainnov/pdf/rpt2admin.pdf)

13   The idea that taking responsibility embodies the three  components described here is taken
     from Fischer JM, Ravizza M.  Taking responsibility (Chapter 8). In: Responsibility and
     Control: A Theory of Moral Responsibility. Cambridge: Cambridge University Press, 1998, pp.
     207-239.

14   Ibid, p. 211.

15   Ibid, p. 213.

16   Ehrenfeld, op. cit.

17   Ehrenfeld, ibid.

18   See 33 USC §1251 (Federal Water Pollution Control Act).

19   See ""ERA'S Legal Framework Supports Collaboration,  at http://www.cooperativeconserva-
     tion.gov/library/EPALegalauthorities082407.pdf.

20   Environmental Protection Agency.  Office of Environmental Stewardship 2003 Annual
     Report. EPA-R-04-001, February 2004. (Available on  the Web at http://www.epa.gov/ne/
     enforcementandassistance/ reports/pdfs/oesannual2003.pdf)

21    Donahue JD, Zeckhauser R.  Public-private collaboration. In: Moran M, Rein M, Goodin RE,
     eds. Oxford Handbook of Public Policy.  Oxford: Oxford University Press, 2006.

22   Traditional knowledge is described in          6 of this report.

23   For a fuller discussion of ERA'S information capabilities  and needs, see National Research
     Council.  2005.  Decision Making for the Environment.  Panel on Social and Behavioral
     Science Research Priorities for Environmental Decision  Making. G.D. Brewer and P.C. Stern,
     eds. Washington, DC: The National Academies Press.

24   This information was supplied by the Organic Consumers Association. See
     http://www.organicconsumers.org/clothes/background.cfm.

25   "The World in a T-Shirt," http://www.npr.org/templates/story/story.php?storyld=4620285.
                                        o

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26   "Cotton and the Environment," http://www.ota.com/organic/environment/cotton_environ-
     ment.html.
27   "Why Organic Cotton," http://www.feelingbold.com/PoP_Organic.cfm.
28   "Green is In;" Impressions Magazine, January 2004.
29   "Fast Clothes" versus "Green Clothes," http://www.iht.com/articles/2007/01/24/business/
     clothing.php?page=2.
30   See http://www.energystar.gov/index.cfm?c=dotheswash.pr_dothes_washers.
31   From Madison Gas and Electric (MG&E) home page, http://www.mge.com/home/appli-
     ances/laundry/.
32   Ibid. MG&E provides an interactive calculator and chart for measuring the individual and
     collective energy savings.
33   Generally derived from the excellent article by Rebecca Tsosie, "Tribal Environmental
     Policy in an Era of Self-Determination: The Role of Ethics, Economics, and Traditional
     Ecological Knowledge," Vermont Law Review, 1996.
34   Fox S. John  Muir and  His Legacy: The American Conservation Movement. Boston, MA:
     Little Brown and Co., 436 pp., 1981.
35   Leopold A. The land ethic. In: Leopold L, ed. A Sand County Almanac, 1949.  (Available
     on the Web at http://home2.btconnect.com/tipiglen/landethic.html)
36   The National Environmental Policy Act of 1969, as amended (Pub. L. 91-190, 42 U.S.C. §
     4321).

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