U.S EPA Headquarters Library
National Advisory Council for .. Mail code 34Q4T
Environmental Policy and Technology 1200 Pennsylvania Avenue NW
Washington, DC 20460
202-566-0556
March 29, 2006 ^
Administrator Stephen L. Johnson
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Submission ofNACEPT Comments on Draft 2006-2011 EPA Strategic Plan
Architecture. -
Dear Administrator Johnson:
On behalf of the National Advisory Council for Environmental Policy and
Technology, I am pleased to forward to you our comments on EPA's Draft
2006-2011 Strategic Plan Architecture. We hope these comments are helpful to
you and EPA as you chart the best course for EPA to achieve its mission.
We commend EPA for undertaking a formal strategic planning process that
provides goals and objectives to assess EPA's many activities and initiatives, and
that so openly includes public participation. Enclosed are both general and
specific comments, some of which are similar to comments we offered for EPA's
2003-2008 Strategic Plan.
Our comments include:
EPA's four major strategic documents - the budget, the strategic plan, the
report on the environment, and the annual performance and accountability
report - are complementary in purpose and so should be organized
consistently and with reference to each other, which would allow readers to
more easily follow issues and track progress.
Elements of other EPA strategic reports offer opportunities for strengthening
the architecture, including adding:
o The legal provision for the objective, sub-objective, or target
o Prior performance and baseline
o Roles and responsibilities - and an assessment of capacities and
resources - of EPA, partners (including other federal agencies), and
the target audience for implementation
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o Principal tools for implementation ' /
o A strategy to effectively address identified gaps and needs
o Performance measures, indicators, milestones, and timeframes for
achievement.
The scope of the architecture's goals and objectives is very broad, and the
authors understandably are many. The preparers of the final document
should seek to harmonize the different sections' targets and formats, which
not only would help with readability but also would promote coordination
across offices and programs.
EPA's significant work on futures and emerging issues and technologies
should be integrated into the architecture as critical elements in assisting EPA
to prepare for new environmental concerns and opportunities.
Recognizing EPA's budget and resource limitations, the architecture should in
some way prioritize the various objectives and sub-objectives according to
their effectiveness in achieving EPA's mission.
On behalf of the Council, we appreciate the opportunity to offer these comments
and look forward to reviewing the Draft Strategic Plan when it is released.
Sincerely,
John L. How;
NACEPT Chair
Attachment
cc: Marcus Peacock, Deputy Administrator
- Charles Ingebretson, Chief of Staff
Ray Spears, Deputy Chief of Staff
Lyons Gray, Chief Financial Officer
Kathy Sedlak O'Brien, Director, Office of Planning, Analysis, and
Accountability/OCFO
Rafael DeLeon, Director, Office of Cooperative Environmental
Management .
Sonia Altieri, NACEPT Designated Federal Officer
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NATIONAL ADVISORY COUNCIL
FOR ENVIRONMENTAL POLICY AND TECHNOLOGY
Comments on U.S. Environmental Protection Agency's
|V\ Draft 2006-2011 Strategic Plan Architecture
March 29,2006
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GENERAL COMMENTS
In its comments on EPA's 2003-2008 Strategic Plan, NACEPT encouraged EPA to link
the Strategic Plan with the Report on the Environment, in both formatting and timing, to
facilitate the establishment of goals and objectives, and to provide a progress report on
the'Agency's accomplishments. We encourage EPA to also enhance the linkages
between those two documents, its budget, and its annual Performance and
Accountability Report. These four documents should be structured so that each serves
a specific function, yet complements the other threethe Strategic Plan establishes
goals and objectives, and means and strategies for achieving them (inputs), the budget
establishes fiscal responsibility, the annual-Performance and Accountability Report
details the Agency's activities and progress towards the stated goals and objectives
(outputs and outcomes), and the Report on the Environment discusses the effects of the
Agency's actions on the environment (impacts). As these documents are
complementary, they should be consistently organized in a manner that allows the
reader to easily follow an issue or topic across all four. To enhance clarity for the
reader, EPA should also include a discussion of the relationships between these
documents in the introduction to each.
\.
The Strategic Plan' Architecture is the "skeleton" fpr EPA's Strategic Plan and is
structured around five Goals (Clean Air and Global Climate Change, Clean and Safe
Water, Land Preservation and Restoration, Healthy Communities and Ecosystems, and
Compliance and Environmental Stewardship). There are substantial linkages across
Goals 1, 2 and 3, and more importantly, the means of achieving those objectives are
contained in Goals 4 and 5. In a number of instances, objectives and. sub-objectives
under Goals 4 and 5 address issues already addressed under Goals 1, 2 and 3, but with
substantively different quantitative targets. We recognize that this is an artifact of the
process through which the Strategic Plan Architecture is assembled, in which individual
offices across the Agency submit their own objectives independent of other offices and
EPA's partners. However, this illustrates the need for thoroughly coordinated
objectives, priority-setting, and activities across those offices and EPA's partners.
NACEPT again recommends that EPA incorporate a section in the Strategic Plan on the
roles of other federal agencies that are crucial to successful implementation of the
Goals. These federal partners are key participants in the evaluation and management
of the nation's natural and environmental resources, including conformance with the
National Environmental Policy Act. EPA should also work closely with its federal
partners to identify their most environmentally significant initiatives, with'a goal of
leveraging cross-agency activities for the greatest public benefit (i.e., energy-
environment nexus).
Our review of the 2003-2008 Strategic Plan revealed that the means and strategies
outlined by the Agency in pursuit of the Goals often lacked detail regarding the roles
and responsibilities of EPA's partners in implementing the Strategic Plan, as well as the
burdens placed on the regulated community.. As EPA moves forward in developing the
Strategic Plan, its usefulness will be dependent on a number of critical elements for
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each objective and sub-objective. From a planning perspective, the following elements
should be discussed for each objective.
In order to provide a sound basis upon which the subsequent Strategic Plan can be
based, the Strategic Plan Architecture should include:
o Prior performance relative to the sub-objective or strategic target (if
addressed in previous Strategic Plans),
o Roles and responsibilities of EPA, its partners and the target audience for
implementing the objective or target,
o An assessment of the capacities and resources of EPA, its partners and the
target audience to implement the strategy, including a discussion of capacity
gaps and resources needs of all parties,
o A strategy to effectively address identified gaps and needs, and
o Milestones for measuring progress.
Where measurable 'sub-objectives (targets) are indicated, sub-objectives should be
expressed in a consistent manner throughout the Strategic Goal Architecture and
include the following elements:
o The regulatory authority for the objective, sub-objective or target,
o Timeframe for achieving the sub-objective,
o Performance measure(s) or indicator(s),
o Baseline from which progress will be measured,
o Target audience for EPA action (e.g., regulated sector, general public)
o EPA partners (e.g., tribes, states, local governments) who will participate in
the implementation strategy, and
o Principal tools (e.g., grants, compliance assistance, incentives, enforcement)
that will be employed in the implementation strategy.
A substantial number of objectives and sub-objectives in the Strategic Plan Architecture
were incomplete, and were therefore not ripe for comment. Many of them included
references to future consultations with stakeholders for the development of appropriate
metrics. While we recognize that EPA has scheduled release of the full Strategic Plan
in May 2006, we recommend that the Agency complete as many stakeholder
consultations as possible prior to the Strategic Plan release, and to incorporate the
outcomes of those consultations into the forthcoming Strategic Plan.
Recognizing that the Agency has many responsibilities, there needs to be a process to
incorporate futures into its strategic planning effort, to understand, assess and access
emerging technologies that can facilitate the Agency's mission and avoid environmental
surprises. There are futures activities occurring throughout the Agency, such as
nanotechnology and water infrastructure sustainability, but these do not systematically
appear in the Strategic plan Architecture.
Neither the Strategic'Plan Architecture nor the Strategic Plan discusses prioritization of
the Agency's various objectives and sub-objectives. While we appreciate the difficulty
of such an endeavor, in the face of finite funding and resources, it would be worthwhile
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for EPA to assess its objectives and sub-objectives, and prioritize its activities by their
greatest value to the Agency's mission and to the public.
Finally, as with the 2003-2008 Strategic Plan, the current Strategic Plan Architecture
reads as if it was prepared by numerous authors. EPA should assign responsibility for
compiling and editing the draft Strategic Plan Architecture and the Strategic Plan to one
office, which could weave all of the disparate pieces into one cohesive and logically
.organized document.
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Detailed Comments on Draft 2006-2011 EPA Strategic Plan Architecture
Public Review Draft February 14,2006
EPA's Mission: To Protect Human Health and the Environment
Goal 1: Clean Air and Global Climate Change.
Protect and improve the air so it is healthy to breathe and risks to human health
and the environment, are reduced. Reduce greenhouse gas intensity by
enhancing partnerships with businesses and other sectors.
Objective 1.1: Healthier Outdoor Air. Through 2011, working with partners, protect
human health and the environment by attaining and maintaining health-based air quality
standards and reducing the risk from toxic air pollutants..
NACEPT Comments
Sub-objective 1.1.1 references working with partners. It is important that roles and
responsibilities be identified, and resources and capabilities of partners be assessed, to ensure
that the objectives can reasonably be achieved. This issue applies wherever partners' activities
are relied upon to achieve goals, objectives and targets.
Sub-objective 1.1.1: Ozone and PM . By 2015, working with partners, improve air
ฃ3
quality for ozone and PM as follows:
2.5
Strategic Targets:
By 2015, reduce the population-weighted ambient concentration of ozone in all
monitored counties by 14% from the 2003 baseline.
By 2015, reduce the population-weighted ambient concentration of PM in all
^.3
monitored counties by 6% from the 2003 baseline.
NACEPT Comments
Strategic targets for ozone and PM2.5 reference percent reductions of 14% and 6% respectively /-
from 2003 baselines- by 2015 in monitored counties. Does the monitoring network (counties)
sufficiently cover all areas where ozone and PM2.5 have potential impacts? Are there any
objectives to identify and add impacted areas to the network? Are goals of approximately 1 %
and 1/z% per year ambitious? Previous (2003) Strategic Plan addressed these contaminants in
terms of population in unhealthy areas whose air had improved to healthy. New targets do not
distinguish between further progress in already healthy areas vs. needed progress in unhealthy
areas. -
Targets need to be consistent with regulations. The Clean Air Act requires ozone & PM2.5
attainment, not continual improvement in all monitored counties, as the first two targets in 1.1.1
propose.
By 2011, improve air quality across states covered by Clean Air Interstate Rule (CAIR)
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to levels where 92 of the 108 areas that did not meet the standards for 8-hour ozone (as
of April 2005) achieve these health-abased national standards.
By 2011, improve air quality across states covered by CAIR to levels where 17 of the
36 areas that did not meet the standards for PM (as of April 2005) achieve these
2.5 f
health-based national standards.
NACEPT Comments
CAIR target for ozone is 85% compliance by 2011, while CAIR target for PM2.5 is 47%. Need
to explain rationale for widely divergent targets.
By 2011, reduce annual SO2 emissions from electric power generation sources by 4.3
million tons below 2003 levels across states covered by the CAIR.
By 2011, reduce annual emissions of nitrogen oxides (NO) from electric power
generation sources by 1.7 million tons below 2003 levels across states covered by
CAIR.
NACEPT Comments
CAIR targets for SO2 and NOx are expressed as tons reduced from 2003 baseline. It would be
useful to identify the 2003 baseline and what the percent change is, as well to show how
ambitious these targets are. (See NOx, VOC and PM targets for mobile sources.)
By 2011, reduce annual emissions of nitrogen oxides from mobile sources by 3.7
million tons from the 2000 level of 11.8 million tons.
By 2011, reduce annual emissions of volatile organic compounds from mobile sources
by 1.9 million tons from the 2000 level of 7.7 million tons.
By 2011, reduce annual emissions of fine particles from mobile sources by 134,700
tons from the 2000 level of 510,550 tons.
By 2011, through the National Clean Diesel Initiative, reduce emissions from the
approximately 11 million engines in the existing fleet by 20,000 tons of fine particles
since the year 2000.
By 2011, through the National Clean Diesel Initiative, reduce emissions from the
approximately 11 million engines in the existing fleet by nearly 300,000 tons of nitrogen
oxides since the year 2000.
NACEPT Comments
National Clean Diesel Initiative PM and NOx targets are expressed as cumulative goals for the
entire period 2000 to 2011. There are no references to baselines or cumulative reductions
attained 2000 to 2006. These targets would be more meaningful as annual rather than
cumulative.
By 2011, the number of tribes with the expertise and capability to implement the Clean
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Air Act in Indian country (as demonstrated by successful delegation of CAA authority
under the Tribal Authority Rule) will increase from the 2005 baseline of 30 to at least 50.
* By 2011, air quality assessments in Indian country, such as air quality and deposition
monitoring, emissions inventories, and toxics assessments, will be tribally-driven and
reflect tribal priorities and needs. At least three tribes will complete assessments each
year between 2007 and 2011, and at least two new tribes will undertake new
assessments each year between 2007 and 2011.
Sub-objective 1.1.2: Air Toxics. By 2011, working with partners, reduce air toxics
emissions and implement area-specific approaches to reduce the risk to public health
and the environment from toxic air pollutants, as follows:
Strategic Targets:
By 2010, reduce the toxicity-weighted risk for cancer by 4% from the 1993 level of
23%. ' ' ' ' '
NACEPT Comments
Have we made any progress since 1993? What is the level of improvement as of 2004? How
do we assess progress, since what we know about the health risks from toxics keeps growing?
Given that the science of toxic air pollution is evolving, shouldn't the baseline change as well?
By 2010, reduce the toxicity-weighted risk for non-cancer by 1 cumulative percent from
the 1993 level of 56%. ,
NACEPT Comments
What does this target mean? That EPA has set a goal of reducing non-cancer risk from 56% to
55% over a 17-year period? That, by 2010, "only" 55% of the population will suffer from "non-
cancer"? Should the word "effects" be inserted between "non-cancer" and "by"? This needs to
be clarified. .
By 2011, through the Clean Air Mercury Rule, reduce mercury emissions from electric
generating units by 10 tons from the 2000 level of 48 tons.
NACEPT Comments
This is a well-written target and should be used as a model for other targets, jt includes the
"audience" or "impact universe" (electric generating units), what the agency hopes to achieve
(10 ton reduction in mercury emissions), an appropriate baseline (2000 level of 48 tons), and
how the objective will be achieved (Clean Air Mercury Rule).
By 2011, through federal standards, reduce air toxics emissions from mobile sources
by 1.4 million tons from the 1996 level of 2.7 million tons.
NACEPT Comments
The 1996 baseline is based on the last time EPA developed a standard. But why are air toxics
from mobile sources under a different objective from other pollution from mobile sources?
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Sub-objective 1.1.3: Chronically-Acidic Water Bodies. By 2011, reduce the number
of chronically-acidic water bodies in acid-sensitive regions by 2% from 1984 levels.
NACEPT Comments
In 27 years we are able to achieve a reduction of only 2%? Why so modest? What is the basis
for this timeframe?
Strategic Targets: ,
By 2011, reduce national annual emissions of sulfur dioxide (SO2) from utility, electrical
power generation sources by approximately 8.45 million tons from the 1980 level of 17.4
million tons, achieving and maintaining the Acid Rain statutory SO emissions cap of
8.95 million tons.
NACEPT Comments J
Attaining the statutory cap is a desirable target, but no information is provided as to where
current emission levels are today, so it's impossible to(assess its appropriateness.
By 2011, reduce total annual average sulfur deposition and mean ambient sulfate
concentration by 30% from 1990 monitored levels.
NACEPT Comments
How do we assess this target given the number of water bodies in the US and the fact that they
vary so significantly in terms of acidity? Why does EPA refer to a "total" annual average? Does
EPA mean "nationwide" average? How does this target relate to the overall 2% goal?
By 2011, reduce total annual average nitrogen deposition and mean total ambient
nitrate concentration by 15% from 1990 monitored levels.
NACEPT Comments
See previous comment regarding sulfur deposition target.
Objective 1.2: Healthier Indoor Air. Through 2012, working with partners, reduce
human health risks by reducing exposure to indoor air contaminants through the
promotion of voluntary actions by the public.
Sub-objective 1.2.1: Radon. By 2012, the number of future premature lung cancer
deaths prevented annually through lowered radon exposure will increase to 1,250 from
the 1997 baseline of 285 future premature lung cancer deaths prevented.
NACEPT Comments ^
Given that lung cancer has the highest mortality rate {and number) and arises from a number of
factors, is epidemiology sufficiently robust to be able to measure this objective? There is no
baseline as to the number of annual lung cancer deaths to assess how ambitious this objective
is.
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Sub-objective 1.2.2: Asthma. By 2012, the number of people taking all essential
actions to reduce exposure to indoor environmental asthma triggers will increase to 6.5
million from the 2003 baseline of 3 million. EPA will place special emphasis on children
and other disproportionately impacted populations.
NACEPT Comments
This objective relies entirely on behavioral changes in the non-regulated community. What
measurable indices will be used to assess the number of respondents? What mechanisms
does the Agency contemplate to compel consumer compliance?
Sub-objective 1.2.3: Schools. By 2012, the number of schools implementing an
effective indoor air quality management plan will increase to 40,000 from the 2002
baseline of 25,000.
NACEPT Comments :
Whether this is an ambitious objective depends on the number of schools in the target universe.
Sub-objective 1.2.4: ETS. By 2012, the percentage of children six and under regularly
exposed to environmental tobacco smoke in the home will be reduced to X% (8-10%)
from a 1998 baseline of 20%, and the disparity of exposure between low-income
children and the general population will be reduced.
NACEPT Comments
This objective relies entirely on behavioral changes in the non-regulated community. What
measurable indices will be used to assess conformance? What mechanisms;does the Agency
contemplate to compel consumer conformance?
Objective 1.3: Protect the Ozone Layer. By 2011, through worldwide action, ozone
concentrations in the stratosphere will have stopped declining and slowly begun the
process of recovery, and-overexposure to ultraviolet radiation, particularly among
susceptible subpopulations, such as children, will be reduced. Specifically:
Sub-objective 1.3.1: Stratospheric Chlorine Concentrations. By 2011, total
equivalent stratospheric chlorine will have reached its peak, and begun its gradual
decline to a value less than 3.4 parts per billion of air by volume.
Strategic Targets:
By 201.1, 65% of all hydrochlorofluorocarbon (HCFC) production and import will be
phased out, further accelerating the recovery of the stratospheric ozone layer - with
further reduction steps in 2015 and 2020, concluding with complete elimination of Class
II substances in 2030. '
Through 2011, continue the transition away from ozone-depleting compounds in a way
that reduces overall risks to human health and the environment by acting on 100% of
petitions for substitutes within 90 days of receipt. .
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Sub-objective 1.3.2: SunWise. By 2011, the number of schools registered with the
SunWise program will increase to 20,000 from X in year 20XX, thereby reducing the
risks of overexposure to UV radiation through education of children in grades K-8.
NACEPT Comments .
What is the baseline of total schools in the target universe? Since reduced exposure will be
achieved by behavior change, how will the number of children who actually change behavior be
assessed? . -
Objective 1.4: Radiation. Through 2011, working with partners, minimize
unnecessary releases of radiation and be prepared to minimize impacts to human
health and the environment should unwanted releases occur.
Sub-objective 1.4.1: Waste Isolation Pilot Plant. Through 2011, EPA will annually
fulfill 100% of the Department of Energy's (DOE) requests for waste characterization
approvals to ensure that EPA requirements are met for proper disposal at the Waste
Isolation Pilot Plant (WIPP). DOE projects that the total number of drums disposed will
increase from X drums (X million millicuries) in 2003 to X drums (X million millicuries) in
2011. The estimated total drums to be deposited at the WIPP is 860,000 (2.6 billion
millicuries) over the next 35'years.
NACEPT Comments
This implies that EPA's goal is to issue all requested approvals, whether or not the requests are
complete and comply with regulations. The 100% target should apply only to complete and
lawful requests. .
Sub-objective 1.4.2: Emergency Response. By 2011, X% of EPA's radiation assets
will meet' functional requirements to implement the National Response Plan's
Nuclear/Radiological Incident Annex and National Oil and Hazardous Substances
Pollution Contingency Plan. (2005 baseline: 50%)
NACEPT Comments
This suggests that some fraction of EPA's radiation assets are "dysfunctional assets" and that it
will take 5 years to achieve some higher level of functionality. Do the assets have some interim
value that they can be measured against?
What is a "radiation asset"? And is this information sensitive?
Sub-objective 1.4.3: Homeland Security/RadNet. By 2011, Pad Net, EPA's National
Radiation Monitoring System, will have operational monitors in X% of the most populous
U.S. cities. (2005 baseline: X% of the most populous U.S. cities)
NACEPT Comments
FY05 Performance Report says that EPA expectS'to provide monitoring coverage to 65 percent
of the US population by 2009. What's vitally missing here is a discussion of providing protection
to the public through materials management and response assistance in the event of releases.
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Objective 1.5: Reduce Greenhouse Gas Intensity. Through EPA's voluntary climate
protection programs, contribute 80 million metric tons of carbon equivalent (MMTCE)
annually to the President's 18% greenhouse gas (GHG) intensity goal by 2012. (An
additional 24 MMTCE to result from the sustained growth in the climate programs are
reflected in the Administration's Business-as-Usual projection for GHG intensity
improvement.)
NACEPT Comments
This objective is difficult to comprehend. How does the 80 MMTCE contribution compare to the
MMTCE of the 18% greenhouse gas intensity goal? What is the relationship of the "additional"
24 MMTCE and is it an expected result of EPA activities?
Sub-objective 1.5.1: Buildings Sector. Through EPA's ENERGY STARฎ program,
prevent 26 MMTCE in the buildings sector in 2012, in addition to the 20 MMTCE
prevented annually in 2002.
NACEPT Comments
This and the following two sub-objectives are written to suggest that prevention occurs only in
discrete events at ten-year intervals, (2002 and 2012): Was the intent that the annual
prevention would increase from a 2002 baseline of 20 MMTCE to 26 MMOTCE in 2012?
Sub-objective 1.5.2: Industrial Sector. Through EPA's industrial sector programs,
prevent 64 MMTCE in 2012, in addition to the 34 MMTCE prevented annually in 2002.
Sub-objective 1.5.3: Transportation Sector. Through EPA's transportation
programs, prevent 13 MMTCE in 2012, in addition to the 2 MMTCE prevented annually
in 2002. ,
Objective 1.6: Enhance Science and Research. Through 2011, provide and apply
sound science to support EPA's goal of Clean Air by conducting leading-edge research
and. developing a better understanding and characterization of human health and
environmental outcomes under Goal 1.
Sub-objective 1.6.1: Use Science and Technology to Support Air Programs. Through
2011, use the best available scientific information, monitoring, models, methods, and
analyses to support air-program-related guidance, policy decisions, and accountability.
Through the Clean Automotive Technology program, EPA and industry partners will
demonstrate cost-effective engineering vehicles using cost-effective ultra clean and fuel
efficient automotive technology as follows:
Strategic Targets:
By 2011, demonstrate that the fuel economy of sport utility vehicles, urban delivery
vehicles, refuse trucks, and buses can be cost-effectively improved by 60% over the
2001 baseline.
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By 2011, demonstrate that the fuel efficiency of automotive gasoline engines can be
cost-effectively improved by 15% over the 2001 baseline.
By 2011, technologies developed under the Clean Automotive Technology program
will be in 2% of the new light/medium duty trucks sold.
NACEPT Comments
This goal seems very timid. If the technology diffusion objective for Clean Automotive
Technology'technologies is only 2% in 2011, how long will it take for this technology to diffuse
into a significant fraction of the national light/medium truck fleet? There is no corresponding
objective to move technology into the automotive gasoline engines? What about non-road
gasoline engines?
Also, where are we now (2006) in relation to the 2001 baseline?
Sub-objective 1.6.2: Conduct Air Pollution Research. Through 2011, achieve
progress toward reducing uncertainty in standard setting and air quality management
decisions through advances in understanding in the air pollution sciences and achieve
progress in assessing source to health linkages by reducing uncertainties in these
linkages.
Strategic Targets:
Progress toward reducing uncertainty in the science that supports standard-setting
and air quality management decisions. Success is defined by an external expert review
to measure the utility of the data, tools, and technologies for key Agency decisions
(metric to be established in consultation with external reviewers; measurement
methodology still under development).
Progress in assessing the linkage between health impacts and air pollutant sources
and reducing the uncertainties that impede the understanding and usefulness of these
linkages. Success is defined by an external expert review process to measure the utility
of the data, tools, and technologies for key Agency decisions (metric to be established
in consultation with external reviewers; measurement methodology still under
development).
NACEPT Comments . .
Many science-related targets make reference to consultation with external reviewers, but do not
give a timeline for completion of this review and for development of metrics and measurement
methodologies. It would seem that EPA has had adequate time to conduct these reviews since
this is the third generation Strategic Plan.
Goal 2: Clean and Safe Water.
*
Ensure drinking water is safe. Restore and maintain oceans, watersheds, and
their aquatic ecosystems to protect human health, support economic and
recreational activities, and provide healthy habitat for fish, plants, and wildlife.
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EPA Head
Objective 2.1: Protect Human Health. Protect human health by reducing exposure to
contaminants in drinking water (including protecting source waters), in fish and shellfish,
and in recreational waters.
Sub-objective 2.1.1: Water Safe to Drink. By 201 i, 95% of the population served by
community water systems will receive drinking water that meets all applicable health-
based drinking water standards through effective treatment and source water protection.
(2005 Baseline: 88.5% of population served by community water systems meeting all
applicable health based drinking water standards.)
Strategic Targets:
By 2011, community water systems will provide drinking water that meets all
applicable health-based drinking water standards during 97% of person months (i.e., all
persons served by community water systems times 12 months). (2005 Baseline:
community water systems provide drinking water that meets all applicable health-based
drinking water standards during 95.17% of person months.)
By 2011, 95% of community water systems will provide drinking water that meets all
applicable health-based drinking water standards throughout the year. (2005 Baseline:
89.2% of community water systems provide drinking water that meets all applicable
health-based drinking water standards throughout the year.)
By 2011, 95% of the population in Indian country served by community water systems
will receive drinking water that meets all applicable health-based drinking water
standards throughout the year. (2005 Baseline: 86.3% of population in Indian country
served by community water systems received drinking water that meets all applicable
health-based drinking water standards throughout the year.)
By 2011, minimized risk to public health will be achieved for 80% of community water
systems and for an associated 80% of the population served by community water
systems (i.e., "minimized risk" achieved by substantial implementation, as determined
by the state, of source water protection actions in a source water protection strategy.)
(2005 Baseline: 20% of community water systems; 28.4% of the population served by
community water systems.)
NACEPT Comments .
How does this risk-based objective relate to the prior targets related to health-based drinking
water standards? Is the Agency suggesting that 15% to 17% of community water supplies will
present public health risks even when they are in full compliance with health-based drinking
water standards?
By 2015, in coordination with other Federal agencies, reduce by 50% the number of
homes on tribal lands lacking access to safe drinking water. (2003 Baseline: Indian
Health Service data indicating that 12% of homes on tribal lands lack access to safe
drinking water; i.e.,, an estimated 38,637 homes lacking access.)
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NACEPT Comments
Prior target is 95% of population in tribal communities will receive drinking water meeting health-
based standards by 2011. This target is 94% percent of homes having access to safe drinking
water by 2015. Assuming that homes have constant number of occupants, this target appears
to retreat from the 2011 target.
Sub-objective 2.1.2: Fish and Shellfish Safe to Eat. By 2011, reduce public health
risk and allow increased consumption offish and shellfish, as measured by the strategic
targets described below.
Strategic Targets: ' """
By 2011, reduce the percentage of women of child-bearing age having mercury levels
in blood above the level of concern from 5.7% to 4.6%. (2002 Baseline: 5.7% of women
of child-bearing age have mercury blood levels above levels of concern identified by the
National Health and Nutrition Examination Survey [NHANES].)
NACEPT Comments
Because geographical population variations, consumer education and choices have substantial
impacts on consumption of mercury-contaminated fish, changes in the national percentage of
women with elevated blood mercury levels is not a valid indicator of changes in mercury levels
in fish and shellfish. A more direct and reliable indicator would be actual fish tissue mercury
levels.
By 2011, maintain or improve the percentage of state monitored shellfish-growing
acres that are approved or conditionally approved for use that are impacted by.
anthropogenic sources. (2003 Baseline: to be determined based on identification of
acres impacted by anthropogenic sources.)
NACEPT Comments . . .
Neither a baseline nor measurable targets have been identified.
Sub-objective 2.1.3: Water Safe for Swimming. By 2011, the number of waterbprne
disease outbreaks attributable to swimming in, or other recreational contact with,
coastal and Great Lakes waters will be maintained at 2, measured as a 5-year average.
(2005 Baseline: an annual average of 2 recreational contact waterborne disease
outbreaks reported per year by the Centers for Disease Control over the years 1998 to
2002; adjusted to remove outbreaks associated with waters other than coastal and
Great Lakes waters and other than natural surface waters [such as pools or water
parks].) .
Strategic Targets:
By 2011, maintain the percentage of days of the beach season that coastal and Great
Lakes beaches monitored by state beach safety programs that are open and safe for
swimming at 96%. (2004 Baseline: beaches open 96% of the 584,150 days of the
beach season; i.e., beach season days = 3,574 beaches times variable number of days
of beach season at each beach.)
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MAC E PT Comments
It is unclear why Sub-objective 2.1.3 is based on one measurable, but the associated strategic
target is based on a different measurable. The term "By 2011, implies that the sub-objective
and target will be achieved in 2011, but not necessarily in the in the intervening years.
Objective 2.2: Protect Water Quality. Protect the quality of rivers, lakes, and streams
on a watershed basis and protect coastal and ocean waters.
Sub-objective 2.2.1: Improve Water Quality on a Watershed Basis. By 2012, use
both pollution prevention and restoration approaches to protect the quality of rivers,
lakes and streams on a watershed basis, as measured by the strategic targets
described below.
NACEPT Comments ,
Since approaches such as "pollution prevention" have specific definitions within EPA's toolbox,
it is unclear if the identification of these approaches implies the exclusion of other tools, such as
compliance monitoring, compliance assistance, incentives and enforcement.
Strategic Targets:
* By 2012, attain water quality standards for all pollutants and impairments in over 3,700
waterbodies identified in 2002 as not attaining standards. Waterbodies where mercury
is among multiple pollutants causing impairment may be counted toward this target
when all pollutants but mercury attain standards, but must be identified as still needing
restoration for mercury. (2002 Baseline: 35,208 waterbodies identified by States and
Tribes as not meeting water quality standards; 1,768 of these waterbodies impaired by
multiple pollutants including mercury; baseline to be updated in April 2006.)
By 2012, remove at least 8,500 of the specific causes of waterbody impairment
identified by States in 2002. (2002 Baseline: estimate of 57,948 specific causes of
waterbody impairment identified by States and Tribes; baseline to be updated by April
2006.)
By 2012, improve water quality conditions in 250 impaired watersheds nationwide
using the watershed approach. (2002 Baseline: zero watersheds improved of an
estimated 40,000 - 50,000 impaired USGS 12 digit watersheds with one or more
waterbody impaired; improved means that one or more of the impairment causes
identified in 2002 are removed for at least 40% of the impaired waterbodies or impaired
miles/acres; estimate of impaired watersheds to be updated in April 2006.)
NACEPT Comments
A previous target identified 35,208 waterbodies as not meeting water quality standards, this
target places the number at 40,000 to 50,000. It is uncertain which is correct. It is unclear what
is meant by "improved means that one or more of the impairment causes identified in 2002 area
removed for at least 40% of the impaired waterbodies or impaired miles/acres."
By 2012, the condition of the Nation's wadeable streams does not degrade (i.e., there
is no statistically significant increase in the percent of streams rated "poor" and no
15
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statistically significant decrease in the streams rated "good". (2006 Baseline: Wadeable
Stream Survey identifies XX% of wadeable streams in good condition; XX% in fair
condition; XX% in poor condition; Wadeable Stream Survey results expected March
2006.)
NACEPT Comments '
Is this a target to be attained by 2012 or a level to be maintained through 2012?
By 2012, improve water quality in Indian country at not fewer than 10% of baseline
monitoring stations for tribal waters (i.e.,, show improvement in one or more of four
parameters; dissolved oxygen, pH, water temperature, and turbidity). (2004 Baseline:
an estimated 743 stations in EPA's STORE! data system in Indian Country, or within
1,500 meters of Indian Country, that monitored for key parameters at least once
between 1995-2005.)
NACEPT Comments
Ten percent improvement over a 5-year period implies that it will take 50 years to achieve some
level of improvement at all 743 monitoring stations. This seems particularly unambitious.
By 2015, in coordination with other Federal partners, reduce by 50% the number of
homes on tribal lands lacking access to basic sanitation. (2003 Baseline: Indian Health
Service data indicating that 8.4% of homes on tribal lands lack access to basic
sanitation; i.e., 26,777 homes of an estimated 319,070 homes lacking access.)
NACEPT Comments
This target suggests that sanitation will not be fully provided for the next 20 years, and equates
to approximately 1,300 homes per year, or approximately 4,500 to 6,000 people per year. This
likewise appears unambitious.
Sub-objective 2.2.2: improve Coastal and Ocean Waters. By 2011, prevent water
pollution and protect coastal and ocean systems to improve national coastal aquatic
ecosystem health by at least 0.2 points on the "good/fair/poor" scale of the National
Coastal Condition Report. (2004 Baseline: National rating of "fair/poor" or 2.3, where
the rating is based on a 4 point system ranging from 1.0 to 5.0 in which 1 is poor and 5
is good using the National Coastal Condition Report indicators addressing water quality
sediment quality, coastal habitat, benthic index, and fish contamination index).
NACEPT Comments
This objective, in particular, depends on actions taken by state and local governments, but no
role is identified for the partners.
Strategic Targets:
By 2011, at least maintain aquatic ecosystem health on the "good/fair/poor" scale of
the National Coastal Condition Report in the Northeast Region. (2004 Baseline:
Northeast rating of 1.8.)
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NACEPT Comments
This and the following three strategic targets call for no specific improvement in ecosystem
health even in regions with fair/poor evaluations. Most, if not all actions to maintain/achieve
these targets are taken by state and local entities. However, there is no reference to goals,
objectives and actions of partners. .
By 2011, at least maintain aquatic ecosystem health on the "good/fair/poor" scale of
the National Coastal Condition Report in the Southeast Region. (2004 Baseline:'
Southeast rating of 3.8.) /
By 2011, at least maintain aquatic ecosystem health on the "good/fair/poor" scale of
the National Coastal Condition Report in the West Coast Region. (2004 Baseline: West
Coast rating of 2.0.)
By 2011, at least maintain aquatic ecosystem health on the "good/fair/poor" scale of
the National Coastal Condition Report in the Puerto Rico Region. (2004 Baseline:
Puerto Rico rating of 1.7.) .
By 2011, 95% of active dredged material ocean dumping sites will have achieved
environmentally acceptable conditions (as reflected in by each site's Site Management
Plan). (2005 Baseline: 94%.)
Objective 2.3: Enhance Science and Research. Provide and apply a sound scientific
foundation to EPA's goal of clean and safe water by conducting leading-edge research
and developing a better understanding and characterization of the environmental
outcomes under Goal 2.
Sub-objective 2.3.1: Apply the Best Available Science. By 2011, apply the best
available science (e.g., tools, technologies, and scientific information) to support Agency
regulations and decision-making for current and future environmental and human health
hazards related to reducing exposure to contaminants in drinking water, fish and
shellfish, and recreational waters and protecting aquatic ecosystems.
NACEPT Comments .
This and the following sub-objective suggest that EPA will not apply and conducting best
available and leading science until 2011. In the interim, what science will be applied? This is
identical to comments made with regard to the 2003 Strategic Plan and Architecture. As
expressed, these sub-objectives provide no measurables by which to assess Agency
performance.
Sub-objective 2.3.2: Conduct Leading-Edge Research. By 2011, conduct leading-
edge, sound scientific research to support the protection of human health through the
reduction of human exposure to contaminants in drinking water, fish and shellfish, and
recreational waters and to support the protection of aquatic, ecosystems - specifically,
the quality of rivers, lakes and streams, and coastal and ocean waters.
NACEPT Comments
This implies that between now and 2011, EPA will conduct "trailing-edge research."
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Strategic Targets:
ORD will develop data, tools, and technologies that the Agency uses to inform
decisions for the 6 year review of drinking water standards and contaminant candidate
listing decisions. Success is defined by an external expert review process to measure
the utility of the data, tools, and technologies for key Agency decisions (metric to be
established in consultation with external reviewers; measurement methodology still
under development).
ORD will develop approaches and methods that the Agency and other key clients use
to inform the development and application of criteria for habitat alteration, nutrients,
suspended and bedded sediments, pathogens and toxic chemicals to achieve targets
for meeting designated uses for aquatic systems. Success is defined by an external
expert review process to measure the utility of the data, tools, and technologies for key
Agency decisions (metric to be established in consultation with external reviewers;
measurement methodology still under development).
ORD will develop tools that the Agency and other key clients use to assess and
diagnose the causes and pollutant sources of impairment to achieve targets for meeting
designated uses for aquatic systems. Success is defined by an external expert review
process to measure the utility of the data, tools, and technologies for key Agency
decisions (metric to be established in consultation with external reviewers;
measurement methodology still under development).
ORD will develop research products and activities that the Agency and other key
clients use for the restoration of impaired aquatic systems, protection of unimpaired
systems and to forecast the ecological, economic, and human health benefits of
alternative approaches used to meet designated aquatic us'e targets. Success is
defined by an external expert review process to measure the utility of the data, tools,
and technologies for key Agency decisions (metric to be established in consultation with
external reviewers; measurement methodology still under development).
ORD will develop approaches, methods, and tools that the Agency and other key
clients use to assess the exposures and reduce the human health risks from biosolids
contaminants in updating biosolids guidance and regulations. Success is defined by an
external expert review process to measure the utility of the data, tools, and technologies
for key Agency decisions (metric to be established in consultation with external
reviewers; measurement methodology still under development).
NACEPT Comments
Many references are made to external research reviews, but there is no discussion of what the
basis for the reviews will be, when such reviews will occur, nor is there any indication of how the
reviews will be incorporated into the Strategic Plan. Further, there is no discussion of what the
value/application of the research efforts is expected to be. .Research, in particular, is an
important area where outputs need to be identified and linked specifically to outcomes. For
example, there is no explicit link of any of the research goals to increasing access to potable
water.
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The Water Infrastructure Sustainability Initiative does not appear to be present in the
Architecture. . .
Goal 3: Land Preservation and Restoration.
Preserve and restore the land by using innovative waste management practices
and cleaning up contaminated properties to reduce risks posed by releases of
harmful substances.
Note to Reviewers: OSWER has identified in this draft strategic plan some
modified and new measures. OSWER a/so is evaluating existing performance
measures to identify areas of improvement.
Objective 3.1: Preserve Land. By 2011, reduce adverse effects to land by reducing
waste generation, increasing recycling, and ensuring .proper waste management of
waste and petroleum products at facilities in ways that prevent releases.
Sub-objective 3.1.1: Decrease Waste Generation and Increase Recycling.
Through 2011, reduce adverse effects to land by diverting materials from disposal
through increased material reuse and recycling.
Strategic Targets:
By 2011, decrease the total amount of municipal solid waste disposed at landfills and
combustion facilities by xx tons, from XX (tons) in YYYY (year)..
By 2011, increase recycling of the total annual municipal solid waste produced to 40%
from 30.6% in 2003.
By 2011, increase reuse and recycling of construction and demolition debris by XX%
from a baseline of YY% in 200X. --
By 2011, increase the use of coal combustion ash to 50% from XX% in 200X.
By 2011, increase by XX%, from XX% in year YYYY, the number of Tribes covered by
an integrated waste management plan that has been approved by an appropriate
governing body within the last 5 years. .
By 2011, reduce the number of open dumps on Tribal lands by XX%, from XX% in
year YYYY.
Sub-objective 3.1.2: Manage Hazardous Wastes and Petroleum Products
Properly. By 2011, reduce releases to the environment by managing hazardous
wastes and petroleum products properly.
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Strategic Targets:
By 2011, prevent releases from RCRA hazardous waste management facilities by
increasing the number of facilities that were brought under approved or updated
controls from XX (at the end of FY 2008) to XX.
By 2011, increase the percentage of UST facilities that are in significant operational
compliance with both release detection and release prevention requirements by 5%.
compared 'to 2006, out of a total estimated universe of approximately XXX.XXX
facilities.
NACEPT Comments
Five percent over a fivervear period equates to one percent per year. At this rate, it will take a
century to bring the universe of UST facilities into significant operational compliance.
Each year through 2011, minimize the number of confirmed releases at UST facilities
to 10,000 or fewer from a universe of approximately 650,000 UST tanks.
Objective 3.2: Restore Land. By 2011, control the risks to human health and the
environment by mitigating the impact of accidental or intentional releases and by
cleaning up and restoring contaminated sites or properties to appropriate levels.
NACEPT Comments
Restoration of brownfields sites is essential to this objective, yet brownfields sites are not
mentioned. The contribution of brownfields restoration activities under sub-objective 4.2.3
should be included here.
Sub-objective 3.2.1: Prepare for and Respond to Accidental and Intentional
Releases. By 2011, reduce and control the risks posed by accidental and intentional
releases of harmful substances by improving our nation's capability to prevent, prepare
for, and respond more effectively to these emergencies.
Strategic Targets:
i
By 2011, achieve and maintain at least 95% of maximum score on readiness
evaluation criteria in each region.
Between 2007 and 2011, complete 975 Superfund-lead hazardous substance removal
actions.
NACEPT Comments
No baseline specified. Is this a significant target?
Between 2007 and 2011, oversee and complete 650 voluntary removal actions.
NACEPT Comments
No baseline specified. Is this a significant target?
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By 2011, reduce by 25% the gallons of oil spilled by facilities subject to Facility
Response Plan regulations relative to the baseline year of 2003.
By 2011, increase the compliance rate to 90% of all facilities subject to Facility
Response Plan regulations from 50% in 2004.
NACEPT Comments
Does the relevant statute allow EPA to establish targets less than full compliance by the
regulated community?
Sub-objective 3.2.2: Clean Up and Revitalize Contaminated Land. By 2011,.control
the risks to human health and the environment at contaminated properties or sites
through cleanup, stabilization, or other action, and make land available for reuse.
NACEPT Comments
Restoration of brownfields sites is essential to this objective, yet brownfields sites are not
mentioned. The contribution of brownfields restoration activities under sub-objective 4.2.3
should be included here..
The strategic targets below all have different universe sizes. What is the origin of these varying
universe sizes?
Are these current Superfund sites, or do they reflect current sites that could become Superfund
sites if state or local governments don't take action?
Strategic Targets:
By 2011, evaluate relative risk at 40,390 potentially hazardous waste sites to resolve
community concerns on whether these sites require long-term cleanup to protect public
health and the environment, or if they can be cleared of Superfund liability for possible
redevelopment.
NACEPT Comments
No baseline specified. Are all of the sites on the current Superfund list or are these potential
new sites not yet evaluated?
By 2011, control all identified unacceptable human exposures from site contamination
to health-based levels, or below, for current land and/or groundwater use conditions at
84% (1,294)-of 1,543 Superfund human exposure sites '(as of FY 2005). This baseline
includes 172 Superfund Federal facility sites. By 2011, increase the percentage of high
priority RCRA facilities with human exposures to toxins controlled to XX% from XX% in
20YY. By 2020, control all identified unacceptable human exposures from site
contamination to health-based levels, or below, for current land and/or groundwater use
conditions at 95% of all facilities requiring RCRA Corrective Action (universe to be
finalized by end of 2007).
NACEPT Comments
There is no prioritization of sites with highest human impact potential. A remote site has less
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impact potential than an urban site.
/
By 2011, control the migration of contaminated groundwater through engineered
remedies or natural processes at 74% (1,016) of 1,381 Superfund ground-water sites
(as of FY 2005). This baseline includes 166 Superfund Federal facility sites. By 2011,
increase the percentage of high priority RCRA facilities with toxic releases to
groundwater controlled to XX% from XX% in 20YY. By 2020, control the migration of
contaminated groundwater through engineered remedies or natural processes at 95%
of all facilities requiring RCRA Corrective Action (universe to be finalized by end of
2007).
/
NACEPT Comments .
There is no indication of priority or importance of sites to be controlled. For example, are they
large or small sites? What is-the potential exposure represented?
By 2011, reduce the backlog of LUST cleanups that exceed state risk-based standards
for human exposure and groundwater migration from 27% down to 20% and complete
construction of remedies at approximately 76% (1,171) of 1,547 Superfund sites (as of
FY 2005). This baseline includes 172 Superfund Federal facility sites. (Note:
construction completion is a milestone which indicates that all significant construction
activity has been completed, even though additional remediation may be needed for all
cleanup goals to be met).
NACEPT Comments
It is unclear what is meant by backlog as a percentage of some unidentified number. Is the
percent backlog related to the 1,547 Superfund sites or some other universe?
By 2020, complete construction of final remedies at 95% of all facilities requiring
RCRA Corrective Action (universe to be finalized by end of 2007).
By 2011, ensure that 90% of the 115 Superfund Federal facility sites on the NPL that
require 5-year reviews remain protective of human health and the environment or
actions are underway to ensure such protectiveness.
NACEPT Comments
If 115 Federal facilities require 5-year reviews, then the Federal government should be
committed to 100 percent compliance.
By 2011, delete 8% (105) of 1,239 final NPL sites (as of FY 2005) that require no
further response activities to protect human health or the environment. This baseline
includes 158 Superfund Federal facility sites.
NACEPT Comments
It is unclear what-the objective is here. If the objective is to clean up 105 sites to the "no further
response" level, this should be made clear. This does not seem like an aggressive enough
goal, and implies that it will take more than a century to address all 1,239 current NPL sites.
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Sub-objective 3.2.3: Maximize Potentially Responsible Party Participation at
Superfund Sites. Through 2011, conserve Superfund trust fund resources by ensuring
that potentially responsible parties conduct or pay for Superfund cleanups whenever
possible.
Strategic Targets: .
Each year through 2011, reach a settlement or take an enforcement action before the
start of a remedial action at 95% of Superfund sites having viable, liable responsible
parties other than the Federal government.
NACEPT Comments
This target should also include and encourage voluntary clean-up actions by responsible parties
prior to settlement or enforcement action.
Each year through 2011, address all Statute of Limitations cases for Superfund sites
with unaddressed total past costs equal to or greater than $200,000.
NACEPT Comments
While this is a good objective for cases over $200,000, does this imply writing off cases less
than $200,000? What does this mean in terms of lost recovery of public expenditures related to
these sites? Is write-off of less than $200,000 sites authorized under the statute?
Objective 3.3: Enhance Science and Research. Through 2011, provide and apply
sound science for protecting and restoring land by conducting leading-edge research,
which through collaboration, lead to preferred environmental outcomes.
Sub-objective 3.3.1: Provide Science to Preserve Resources and Remediate
Land. Through 2011, provide sound science and constantly integrate partner inputs for
smarter technical solutions and protection strategies that enhance our ability to
remediate contaminated land for beneficial use, conserve resources and materials
management, and preserve land quality.
Strategic Target:
Lead the incorporation of sound science into OSWER guidance and decisions on land
preservation and remediation.
NACEPT Comments
What does this target mean, who determines that the science is sound, and how will this be
measured?
Sub-objective 3.3.2: Conduct Research to Preserve Resources and Support Land
Remediation Activities. Through 2011, conduct sound, leading-edge scientific
research to provide a foundation for preserving resources, supporting land quality and
remediating contaminated land. Research will result in documented methods, models,
assessments, and risk management options for program and regional offices, facilitating
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their accurate evaluation of effects on human health and the environment,
understanding of exposure pathways, and implementation of effective risk-management
options. Communicate research affecting Indian country in partnership with Tribes.
NACEPT Comments
The last sentence referencing Indian country seems to be disconnected from the sub-objective. .
Strategic Targets:
Through 2011, clients request and apply timely and leading edge ORD research
products and services needed to manage material streams, conserve resources and
appropriately manage waste. Success is defined by an external expert review process
to measure the utility of the data> tools, and technologies for key Agency decisions
(metric to be established in consultation with external reviewers; measurement
methodology still under development).
NACEPT Comments
For this and the following strategic target, who is the client? Is it EPA offices and partners or the
regulated community? There is substantial effort at state levels, among academic institutions,
and in the private sector. How are these other activities assessed and considered by EPA in
achieving client satisfaction? It is important that both outputs and outcomes be established and
performance reviewed against them.
Through 2011, clients request and apply timely and leading edge ORD research
products and services needed for mitigation, management and long-term stewardship of
contaminated sites. Success is defined by an external expert review process to
measure the utility of the data, tools, and technologies for key Agency decisions (metric
to be established in consultation with external reviewers; measurement methodology
still under development).
GOAL 4: Healthy Communities and Ecosystems.
Protect, sustain, or restore the health of people, communities, and ecosystems
using integrated and comprehensive approaches and partnerships.
NACEPT Comments
Although the goals expressed in this section are specific and precise, it is not clear what they
mean, what the priorities are/should be for achieving them or what their efficacy is.
Objective 4.1: Chemical and Pesticide Risks. Prevent and reduce pesticide, and
industrial chemical risks to humans, communities, and ecosystems.
Sub-objective 4.1.1: Reduce Chemical Risks. Through 2011, prevent and reduce
chemical risks to humans, communities, and ecosystems.
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Strategic Targets:
By 2011, eliminate or effectively manage risks associated with 100% of High
Production Volume (HPV) chemicals for which unreasonable risks have been identified
through EPA risk assessments.
NACEPT Comments
How will this be measured and assessed?
Through 2011, ensure that new chemicals introduced into commerce after Pre-
Manufacture Notifications (PMNs) Review do not pose unreasonable risks to workers,
2
consumers, or the environment.
NACEPT Comments
How will this be measured and assessed?
By 2011, achieve a 30.6% cumulative reduction of chronic human health risk from
o
environmental releases of industrial chemicals in commerce since 2001.
NACEPT Comments
How will this be measured and assessed?
* By 2010, eliminate childhood lead poisoning cases as a public health concern by
reducing to zero the number of cases of children (aged 1-5 years) with elevated blood
lead levels (>10ug/dl).
NACEPT Comments
This objective relies solely on consumer behavior. What strategies/tools will EPA rely on to
achieve this objective?
By 2010, reduce to 28.0% the percent difference in the geometric mean blood lead
level in low-income children 1-5 years old as compared to the geometric mean for non-
low income children 1-5 years old.
By 2011, through work with international partners, eliminate the use of lead in gasoline
in the remaining 35 countries that still use lead as an additive, affecting over 700 million
people. (Baseline: As of January 2006, 35 countries still need to phase lead out of
gasoline. Information source: United Nations Environment Program and the Partnership
for Clean Fuels and Vehicles maintain a global database on fuel quality, which they
update periodically.)
By 2011, through work with international partners, over 3 billion people will have
access to low-sulfur fuel in 15 countries, including China, India, Mexico and Brazil.
(Baseline: As of January 2006, none of the developing countries has access to low-
sulfur fuel. Information source: United Nations Environment Program and the
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Partnership for Clean Fuels and Vehicles maintain a global database on fuel quality,
which they update periodically.)
Baseline: EPA screening of data obtained through the HPV Challenge Program is commencing in 2006; actions to
obtain additional information needed to assess risks will commence subsequently as chemicals are identified as
priority concerns through the screening process. Measurement Mechanism: HPVIS and EPA risk management
action tracking tools, including RAPIDS.
Baseline: 100% in FY 2004 and FY 2005. Measurement Mechanism: Number of TSCA 8(e) Chemical Hazard
Notifications associated with PMN-reviewed chemicals verified to identify the occurrence of unreasonable risks.
Baseline: 2001 starting point is 0. Actual cumulative reduction reported from 2001 - 2003 is 6.6% (5.7% for 2001
- 2002; 0.9% for 2002 - 2003. Target assumes annual 3.0% reductions for remaining years through 2011.
Measurement Mechanism: EPA's Risk Screening Environmental Indicators model.
4
Baseline: 310,000 cases in 1999-2002. Measurement Mechanism: NHANES.
5 :
Baseline: 37.0% in 1991-1994. Measurement Mechanism: NHANES.
i
Sub-objective 4.1.2: protect Human Health from Pesticide Risk. Through 2011,
protect human health by ensuring that pesticides continue to be safe and available
when used in accordance with the label.
Strategic Targets:
By 2011, protect human health by reducing the percentage of the general population
with detectable levels of currently registered pesticides in their bodies by a cumulative
total of XX%, (Metric under development for inclusion in the full text draft.)
v
By 2011, reduce the occurrence of pesticide related illnesses and incidents in the
pesticide occupational community by XX% (agricultural workers and pesticide
applicators). (Metric under development for inclusion in the full text draft.)
Through 2011, improve protection by working with other nations to facilitate quicker
market entry, availability, and use of lower risk pesticides through worksharing with
NAFTA and OECD on a cumulative XX number of reduced risk pesticides. (Metric
under development for inclusion in the full text draft.)
Sub-objective 4.1.3: Protect the Environment from Pesticide Risk. Through 2011,
protect the environment by ensuring that pesticides continue to be safe and available
when used in'accordance with the label.
Strategic Targets:
By 2011, establish the baseline and reduce by a cumulative XX% the contribution of
pesticides to environmental impairments. (Metric under development for inclusion in
the full text draft.)
By 2011, working with states and tribes, identify XX pesticides of concern to water
quality, use available tools to manage the risk, and effect a positive change in
environmental conditions. (Metric under development for inclusion in the full text draft.)
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By 2011, protect endangered and threatened species from pesticide exposure by
reducing the exposure levels by a cumulative XX%; (Metric under development for
inclusion in the full text draft.)
Sub-objective 4.1.4: Realize the Benefits from Pesticide Use. Through 2011,
ensure the public health and economic benefits of pesticide availability and use are
achieved.
Strategic Targets:
By 2011, ensure the public health and economic benefits of pest control are achieved
by avoiding XXX (cumulative) amount of crop loss through ensuring effective pesticides
are available to address emergency pest infestations. (Metric under development for
inclusion in the full text draft.)
By 2011, decrease structural damage and vector borne disease by a cumulative XX%.
(Metric under development for inclusion in the full text draft.)
Sub-objective 4.1.5: Reduce Risks at Facilities or in Communities. By 2011,
protect human health, communities, and the environment for chemical releases through
facility risk reduction efforts and building community's preparedness and response
capabilities. i
Strategic Targets:
By 2011, reduce, by XX pounds inventories of hazardous chemicals at Risk
Managernent'Plan facilities. . v
NACEPT Comments
Is this a regulatory goal of the RMP program?
By 2011, reduce by 5% -the number of accidents and the consequences of those
accidents (including evacuation, injuries, fatalities, and property damage).
NACEPT Comments ..
This is highly dependent on factors external to the Agency and outside the regulatory jurisdiction
of the Agency. How will EPA accomplish this?
By 2011, vulnerability zones surrounding Risk Management Plan facilities will be
reduced by XX% which will result in the protection of XX people in the community.
By 2011, improve by XX% from the 2007 baseline the capabilities of Local Emergency
Planning Committees (LEPCs) to prevent, prepare for, and respond to chemical
emergencies thereby reducing the risk to communities from the devastating effects of
chemical accidents, as measured by a survey of those LEPCs. '
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NACEPT Comments
This target references a future baseline. This target is dependent entirely on actions by state
and local entities and the regulated community and outside the regulatory jurisdiction of the
Agency.
Objective 4.2: Communities. Sustain, clean up, and restore communities and the
ecological systems that support them,
Sub-objective 4.2.1: Sustain Community Health. Reduce the air, water, and land
impacts of new growth and development in 50 communities by 2011 (2006 as a
baseline) by working with communities to adopt growth strategies that perform better for
the environment, economy, and the community. (Metric under development).
NACEPT Comments .
What is the baseline of communities by which this target is measured? 50 communities over 5
years seems an extremely small number. How will this be accomplished, how will it be
coordinated with other agencies, and how will target communities be selected?
Sub-objective 4.2.2: Restore Community Health through Collaborative Problem-
Solving: Make significant environmental improvements in communities with potential
disproportionately high and adverse environmental and/or public health effects ("areas
with potential environmental justice concerns") and foster the ability of communities to
address local environmental concerns with other stakeholders through collaborative
problem-solving.
Strategic Targets:
> By 2011, an additional 30 communities in areas with potential environmental justice
concerns will achieve significant measurable environmental and/or public health
improvements through the use of collaborative problem-solving strategies. In 2006, 30
communities used collaborative problem-solving strategies to improve their
environmental and/or public health.
NACEPT Comments
What is the baseline of communities in need of collaborative problem-solving? Is this an
ongoing training program in which communities come and go or is the program capacity
expected to double by 2011 ?
What is the specific deliverable here - training, technical assistance? Does this means EPA
will be involved in a total of 60 communities or 30 different communities?
By 2011, as compared to the general population, significantly decrease the amount of
pollution that may disproportionately affect the environmental health of communities
with potential environmental justice concerns. This reduction will include, as
appropriate, pollutant sources associated with the national environmental justice
priorities.
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NACEPT Comments.
How will this be measured?
What does this mean and how will it be achieved? Will EPA develop programs over and above
the expected regulatory programs; or that go beyond regulatory requirements?
Sub-objective 4.2.3: Assess and Clean Up Brownfieids: Working with state, tribal,
and local partners, promote the assessment, cleanup, and sustainable reuse of
brownfields properties.
NACEPT Comments
What specific actions is EPA planning to take?
Brownfieids activities are essential to Goal 3: Land Preservation and Restoration, and should be
discussed under Goal 3 objectives and sub-objectives as well as here.
Strategic Targets:
By 2011, conduct environmental assessments at XXXX properties.
By 2011, make XXXX acres of brownfields ready for reuse.
By 2011, leverage XXXX in assessment, cleanup, and redevelopment funding at
brownfields properties.
Sub-objective 4.2.4: Sustain and Restore U.S.-Mexico Border Environmental
Health. By 2012, sustain and restore the environmental health along the US-Mexico
Border and enhance collaboration with communities through implementation of the
ABorder 2012,@ plan including improving water infrastructure and providing improved
water quality conditions and working toward a binational policy on land cleanup, reuse,
and revitalization of abandoned sites based on the strategic targets described below.
Strategic Targets:
By 2012, achieve a majority of currently exceeded water quality standards in impaired
reaches or segments of significant shared and trans-boundary surface waters. (2002
Baseline: 42 of water quality impairments/sources identified for 19 reaches or segments
of significant shared and trans-boundary surface waters; to be determined early 2006)
NACEPT Comments
This target is quite confusing. Is the objective to reduce the total number of impairments by
more than half, even if no individual reach actually becomes unimpaired?
How is success measured here?. Would elimination of 22 problems/exceedences be considered
success even if no individual reach actually attained all applicable water quality standards?
This target needs to be clarified.
By 2012, provide safe drinking water to 25% of homes in the Mexico Border area that
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lacked access to safe drinking water in 2003. (2003 Baseline: 98,575 homes lack
access to safe drinking water; 2000 Census estimate of homes lacking access minus
homes provided with access between 2000 and 2003)
NACEPT Comments
Since this and the next target are substantially lower than the water-related targets under Goal 2
both generally and with respect to tribal lands, is this, in effect, setting up an environmental
justice nexus in the border area? Why is this different here as opposed to under Goal 2?
By 2012, provide adequate wastewater sanitation to 25% of homes in the Mexico
Border area that lacked access to wastewater sanitation in 2003. (2003 Baseline:
690,723 homes lack access to wastewater sanitation; 2000 Census estimate of homes
lacking access to adequate wastewater sanitation minus homes provided with access
between 2000 and 2003.)
By 2012, cleanup five waste sites (two abandoned waste tires sites and three
abandoned hazardous waste sites) in the U.S.-Mexico border region, thereby reducing
the threat of infectious diseases and acute respiratory illnesses from tire fires and the
threat of acute heavy metals poisoning and long-term central nervous damage,
potentially adversely affecting approximately 1.7 million local residents.
NACEPT Comments
While this is a very specific target, how does it relate to the universe of the potential sites and
impacts in the entire border region? Are there plans to transfer the lessons learned here to
other sites?
Sub-objective 4.2.5: Reduce POPs Exposure: By 2011 reduce the mean maternal
R
serum blood levels of POPs contaminants in indigenous populations in the Arctic.
NACEPT Comments
How will these targets be achieved? Specific programs need to be identified, along with the
measurements that will link them to the projected outcomes.
Strategic Targets:
- By 2011,"reduce mean maternal blood levels of PCBs (measured as Aroclor 1260) in
indigenous populations in the Arctic to 5.65 ug/l.
NACEPT Comments
How will this and the following objective be accomplished?" How is this directly correlated to the
environment?
By 2011, reduce mean maternal blood levels of chlordane .(measured as the
metabolites oxychlordane and trans-nonachlor) in indigenous populations in the Arctic
to 1.13 ug/l.
6 ' - .
For both strategic targets - Baseline: The 2006 calculated baseline mean maternal serum level for PCBs was 6.28
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f
ug/1 and for total chlordane was 1.26 ug/1. This initial baseline was calculated based on Arctic Monitoring and
Assessment Program data (AMAP, 2003), which includes human health data points from indigenous maternal
populations across the Arctic, including Alaska, Canada, Norway, and the Russian Federation. Measurement
Mechanism: Assessment of data from AMAP, an existing international scientific working group, which advises
governments of the eight Arctic countries on issues related to pollution in the Arctic. AMAP data is presented in
periodic scientifically-based assessments (available at www.amap.no), which-are a result of cooperative efforts
involving a large number of scientists and other stakeholders, who follow agreed quality assurance and control
protocols consistent with such practices common in the United States.
Objective 4.3: Restore and Protect Critical Ecosystems. Protect, sustain, and
restore the health of critical natural habitats and ecosystems.
NACEPT Comments
By establishing "critical ecosystems" .and ecosystem-specific sub-objectives, is the Agency
devaluing non-listed ecosystems? Will this have an,impact on priority setting and resource
allocation during implementation of the Strategic Plan?
Sub-objective 4.3.1: Increase Wetlands. By 2011, working with partners, achieve a
net increase in wetlands acres with additional focus on assessment of wetland condition
as determined by the Strategic Targets described below.
Strategic Targets:
By 2011, working with partners, achieve a net increase of 100,000 acres of wetlands
per year with additional focus on biological and functional measures and assessment of
wetland condition. (2003 Baseline: annual net wetland gain/loss to be determined in
Spring of 2006 based on new Fish and Wildlife Service Report)
By 2011, in partnership with the U.S. Army Corps of Engineers, States, and tribes,
achieve no net loss of wetlands each year under Section 404 of the Clean Water Act
regulatory program, beginning in 2007. (Baseline: new baseline to be determined in
2008)
NACEPT Comments
How do these two targets fit together? Is the second target a sub-set of the first target?
How are these two targets coordinated so that the net increase of the first target is achieved if
the net outcome of Section 404 activities is zero?
Sub-objective 4.3.2: Facilitate the Ecosystem-scale Protection and Restoration of
Estuaries of National Significance Designated under the National Estuary
Program: By 2011, working with partners, protect or restore an additional (i.e.,
measuring from 2007 forward) 250,000 acres of habitat within the study areas for the 28
estuaries that are part of the National Estuary Program. (2005 Baseline: 510,910 acres
of habitat protected or restored; cumulative from 2001.)
NACEPT Comments
Protection and restoration are separate processes/programs. Although providing program
flexibility is desirable, are the two being tracked separately, to make certain both goals are being
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met?
Sub-objective 4.3.3: Improve the Health of Great Lakes Ecosystem. By 2011,
prevent water pollution and protect aquatic systems so that the overall ecosystem health
of the Great Lakes is at least 23 points on a 40 point scale. (2005 Baseline: Great Lakes
rating of 21.5 on the 40-point scale where the rating uses select Great Lakes State of the
Lakes Ecosystem indicators based on a 1 to 5 rating system for each indicator, where 1
is poor and 5 is good.)
NACEPT Comments
How is this sub-objective coordinated with activities under Goal 2 and Goal 5?
Strategic Targets: '
<
Through 2011, maintain or improve an average 5% decline for the long-term trend in
average concentrations of PCBs in whole lake trout and walleye .samples. (Baseline:
exponential decay of Great Lake dataset beginning with 1990.)
This is and the following target are confusing and should be reworded to state that the
average concentrations should decline by 5% or greater per year.
Through 2011, maintain or improve an average 7% decline for the long-term trend in
average concentrations of toxic chemicals (PCBs) in the air in the Great Lakes basin.
(2004 Baseline: Exponential decrease of average concentrations using IADN data
through 2000.) .
By 2010, restore and delist a cumulative total of at least 10 Areas of Concern within the
Great Lakes basin (2005 Baseline: 0 areas of concern de-listed as of 2005 of the 31 total
areas of concern.)
By 2011, remediate 7 million cubic yards of contaminated sediment in the Great Lakes.
(2005 Baseline: 3.7 million cubic yards of contaminated sediments from the Great Lakes
have been remediated from 1997 through 2005 of the 75 million yards estimated to need
remediation.)
Sub-objective 4.3.4: Improve the Aquatic Health of the Chesapeake Bay.. By 2011,
prevent water pollution and protect aquatic systems so that the overall aquatic system
health of the Chesapeake Bay is improved as measured by the strategic targets
described below. ,
Strategic Targets:
By 2011, 45% of the submerged aquatic vegetation goal for the Bay will be achieved.
(2005 Baseline: 39% of submerged aquatic vegetation goal achieved; the ultimate goal is
100% achievement of the 185,000 acre goal for submerged aquatic vegetation.)
By 2011, 63% of dissolved oxygen goal will be achieved. (2005 Baseline: 57% of
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dissolved oxygen goal achieved; the ultimate goal is 100% attainment of the dissolved
oxygen water quality standards in all tidal waters of the Bay.)
^
Sub-objective 4.3.5: Improve the Health of the Gulf of Mexico. By 2011, the overall
health of coastal waters of the Gulf of Mexico will be improved from 2.4 to 2.6 on the
Agood/fair/poor@ scale of the National Coastal Condition Report. (2004 Baseline: Gulf
Coast rating of fair or 2.4 where the rating is based on a 5-point system where 1 is poor
and 5 is good.)-
Strategic Targets: .
By 2011, restore water and habitat quality to meet water quality standards in 71
impaired segments (i.e., 20% of the 354 impaired- segments identified in 13 priority
coastal areas). (2005 Baseline: 28 segments restored.)
i.
By 2011, restore, enhance, or protect 20,000 acres of important coastal and marine
habitats. (2005 baseline: 16,000 acres restored, enhanced, or protected; Gulf of Mexico
coastal wetland habitats include 3,769,370 acres.)
By 2015, reduce releases of nutrients throughout the Mississippi River Basin to reduce
the size of the hypoxic zone in the Gulf of Mexico to less than 5,000 km2, as measured
by the 5-year running average of the size of the zone. (Baseline: 1996-2000 running
average size = 14,128 km2.)
Sub-objective 4.4.6: Restore and Protect Long Island Sound: By 2011, working
through the Long Island Sound Study Management Conference partnership, prevent
water pollution, improve water quality, protect aquatic systems and restore the habitat of
Long Island Sound as measured by the strategic targets described below.
NACEPT Comments
This sub-objective should be numbered 4.3.6.
Strategic Targets:
By 2011, reduce point source nitrogen discharges to Long Island Sound by 10,892 tons
from the 2004 baseline as measured by the Long Island Sound Nitrogen Total Maximum
Daily Load. (Annual reduction target: 1,556 tons/year. 2004 Baseline: 28,100
tons/year.)
By 2011, reduce the size of hypoxic area in Long Island Sound (i.e., the average
'maximum July-September <3mg/l DO) by 25%; reduce average duration of maximum
hypoxic event by 25%. (2005 Baseline: 19-year averages as of December 2005: size:
203 sq/mi.; and duration: 58 days.)
By 2011, restore or protect 300 acres of coastal habitat, including tidal wetlands, dunes,
riparian buffers, and freshwater wetlands from the 2005 baseline. (2005 Baseline: 562
acres restored and 150 acres protected; acres restored are reported to the NEP.)
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By 2011, reopen an additional 50 miles of river and stream, corridor to anadromous fish
passage from the 2005 baseline through removal of dams and barriers or installation of
by-pass structures such as fishways. (2005 Baseline: 81 miles.)
Sub-objective 4.4.7: Restore and Protect the South Florida Ecosystem. Protect
and Maintain the South Florida Ecosystem, including the Everglades and coral reef
ecosystems, as measured by the strategic targets described below.
NACEPT Comments
This sub-objective should be numbered 4.3.7.
Strategic Targets:
*
Annually, beginning in 2008, vyork with the U. S. Army Corps of Engineers and other
partners to achieve Ano net loss@ of wetlands in South Florida under Section 404 of the
Clean Water Act. (2005 Baseline to be determined in 2006.)
* By 2012, working with all stakeholders (federal, state, regional, and local), achieve "no
net loss@ of stony coral cover (mean percent stony coral cover) as in the Florida Keys
National Marine Sanctuary (FKNMS) and in the coastal waters of Dade, Broward, and
Palm Beach Counties, Florida. (Baseline to be determined using information collected
and analyzed in FY 2005 by the long-term coral reef monitoring projects.)
By 2011, maintain the overall health and functionality of seagrass beds in the FKNMS
each year beginning in 2008, as measured by the long-term seagrass monitoring project
which addresses composition and abundance, productivity, and nutrient availability.
(Baseline index of seagrass health to be determined using information collected and
analyzed in FY 2005.)
By 2011, maintain the overall water quality of the nearshore and coastal waters of the
FKNMS each year, beginning in 2008. (Baseline concentrations for inorganic nitrogen
(nitrate, nitrite, and ammonium), soluble reactive phosphorus, water clarity (turbidity and
light attenuation), and chlorophyll a to be determined using information collected and
analyzed in FY 2005 as measured by the long-term water quality monitoring project.)
By 2011, maintain the water quality of the Everglades ecosystem each year, beginning
in 2008, as measured through water quality monitoring of total phosphorus. (Baseline is
1995 water quality.)
Sub-objective 4.4.8: Restore and Protect Puget Sound Basin. By 2011, improve
water quality, air quality, and minimize the adverse impacts of rapid development in the
Puget Sound Basin as measured by the strategic targets described below.
NACEPT Comments - .
This sub-objective should be numbered 4.3.8.
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Strategic Targets: -
By 2011, improve water quality as needed to lift harvest restrictions in 1,000 acres of
shellfish bed growing areas impacted by degraded or declining water, quality. (2006
Baseline: approximately 30,000 acres of shellfish beds with harvest restrictions due to
water quality impairments.)
By 2011, remediate 100 acres of prioritized contaminated sediments. (2006 Baseline:
approximately 5,000 acres of remaining contaminated sediments requiring some level
remediation.) ' .
By 2011, restore 3,500 acres of tidally and seasonally influenced estuarine wetlands.
(2005 Baseline: xxx acres restored as of January 2006.) ,
By 2011, reduce total diesel emissions in the Puget Sound airshed by 8% through
coordinated diesel .emission mitigation efforts. (2006 Baseline: xxx tons of diesel
emissions to the Puget Sound airshed). '
Sub-objective 4.4.9: Restore and Protect the Columbia River Basin: By 2011,
prevent water pollution, improve water quality, and protect and restore Columbia River
Basin ecosystems so that risks to human health and the environment can be reduced
as measured by the strategic targets described below.
NACEPT Comments
This sub-objective should be numbered 4.3.9.
Strategic Targets:
By 2011, about 5,000 acres of farmland have best management practices, no-till
agriculture and/or precision agriculture actions in place resulting in XX% sediment
reduction by 2011. (2004 Baseline: YY,000 acres of agricultural land which have
implemented sediment reduction actions. This information will be collected by working
. with State and local agricultural partners.)
By 2011, reduce toxic chemicals (PCBs, dioxins, furans, arsenic, mercury, and all forms
of DDT and breakdown products) in fish tissue in 50% of the geographic areas of the
Columbia River and tributaries where fish were sampled and shown to be contaminated
in the EPA 2002 Fish Contaminant Survey. (Baseline: Data on fish sampling from the
EPA 2002 Fish Contaminant Survey.)
By 2011, clean up about 400 acres (5%) of known highly contaminated sediments.
(Baseline: XX acres [Approximately 8,000 acres] of highly contaminated sediments in the
main-stem of the Columbia River and Lower Willamette River as of 2006.)
Objective 4.4: Enhance Science and Research. Through 2011, provide a sound
scientific foundation for EPA's goal of protecting, sustaining, and restoring the health of
people; communities, and ecosystems by conducting leading-edge research arid
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developing a better understanding and characterization of environmental outcomes
under Goal 4.
. j
Sub-objective 4.4.1: Apply the Best Available Science. Through 2011, identify and
synthesize the best available scientific information, models, methods and analyses to
support Agency guidance and policy decisions related to the health of people,
communities, and ecosystems.
Sub-objective 4.4.2: Conduct Relevant Research.
Through 2011,' conduct research--that contributes to the overall health of people,
communities, and ecosystems. Focus research on pesticides and chemical toxicology;
global change; and comprehensive, cross-cutting studies of human, community, and
ecosystem health.
1 i
Strategic Targets - Human Health Research:
Risk assessors and risk managers use ORD's methods, models and data to use
mechanistic (mode of action) information to reduce uncertainty in risk assessment
(metric to be established in consultation with external reviewers; measurement
methodology still under development).
Risk assessors and risk managers use ORD's methods, models and data to
characterize and provide adequate protection for susceptible subpopulations; and to
characterize aggregate and'cumulative risk in order to manage risk of humans exposed
to multiple environmental stressors (metric to be established in consultation with
external reviewers; measurement methodology still under development).
Risk assessors and risk managers use ORD's methods and models to evaluate the
effectiveness of public health outcomes (metric to be established in consultation with
external reviewers; measurement methodology still under development).
Strategic Targets - Ecological Research:
States and tribes use a common monitoring design and appropriate indicators to
determine the status and trends of ecological resources and the effectiveness of
national programs and policies. Success is defined by an external ^expert review
process to measure the utility of the data, tools, and technologies for key Agency
decisions (metric to be established in consultation with external reviewers;
measurement methodology still under development).
States, tribes and relevant EPA offices have improved their ability to determine causes
of ecological degradation, and to forecast the ecological impacts of various actions
through the application of recently developed (within the previous 5 years) ORD causal
diagnostic tools and methods, resulting in positive environmental outcomes. Success is
defined by an external expert review process to measure the utility of the data, tools,
and technologies for key Agency decisions (metric to be established in consultation with
36
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external reviewers; measurement methodology still under development).
States, tribes and relevant EPA offices have improved their ability to protect and
restore ecological condition and services through the application of recently developed
(within the previous 5 years) ORD environmental restoration tools and methods,
resulting in positive environmental outcomes. Success is defined by an external expert
review process to measure the utility of the data, tools, and technologies for key Agency
decisions (metric to be established in consultation with external reviewers;
measurement methodology still under development).
Strategic Targets - Global Climate Change Research:
V ,
State, regional, and national decision makers and decision makers in EPA regional
and program offices will use scientific information about the place-based impacts of
global change to protect the people, the economy, and the environment of the United
States by adapting to global change. Success is defined by an external expert review
process to measure the utility of the data, tools, and technologies for key Agency
decisions (metric to be established in consultation with external reviewers;
measurement methodology still under development).
Air quality managers and decision makers in EPA regional and program offices will
use scientific information and models from EPA's research and assessment program to
evaluate and implement adaptation policies that protect air quality from the impacts of
global change. Success is defined by an external expert review process to measure the
utility of the data, tools, and technologies for key Agency decisions (metric to be
established in consultation with external reviewers; measurement methodology still
under development).
ORD will develop scientific information and decision tools that the Agency uses to
inform decisions for the protection of human health, water quality, and* aquatic
ecosystems by adapting to global change. Success is defined by an external expert
review process to measure the utility of the data, tools, and technologies for key Agency
decisions (metric to be established in consultation with external reviewers;
measurement methodology still under development).'
Strategic Targets - Endocrine Disruptors Research:
Reduction in uncertainty regarding the effects, exposure, assessment, and
management of endocrine disrupters so that EPA has a sound scientific foundation for
environmental decision-making. Success is defined by an external expert review
process to measure the utility of the data, tools, and technologies for key Agency
decisions (metric to be established in consultation with external reviewers;
measurement methodology still under development).
Determination of the extent of the impact of endocrine disrupters on humans, wildlife,
and the environment to better inform the federal and scientific communities. Success is
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defined by ah external expert review process to measure the utility of the data, tools,
and technologies for key Agency decisions (metric to be established in consultation with
external reviewers; measurement methodology still under development).
OPPTS uses endocrine disrupter screening and testing assays developed by ORD to
create validated methods that evaluate the potential for chemicals to cause endocrine-
mediated effects in order to reduce or prevent risks to humans and wildlife from
exposure to endocrine disrupting chemicals (EDCs). Success is defined by an external
expert review process to measure the utility of the data, tools, and technologies for key
Agency decisions (metric to be established in consultation with external reviewers;
measurement methodology still under development).
Strategic Targets - Human Health Risk Assessment Research:.
Integrated Risk Information System (IRIS) and other priority health hazard
assessments: Agency, state and local risk assessors use the state-of-the-science
health hazard assessment information provided on priority substances in their decisions
and actions to protect human health from risks posed by environmental pollutants.
Success is defined by an external expert review process to measure the utility of the
data, tools, and technologies for key Agency decisions '(metric to be established in
consultation with external reviewers; measurement . methodology still under
development).
State-of-the-science risk assessment models, methods, and guidance: EPA programs,
states and other risk assessors use the risk assessment models,, methods, and
guidance provided to enhance, through the incorporation of contemporary scientific
advances, the quality and objectivity of their assessments and decision-making on
environmental health risks. Success is defined by an external expert review process to
measure the utility of the data, tools, and technologies for key Agency decisions (metric
to be established in consultation with external reviewers; measurement methodology
still under development).
Air Quality Criteria Documents: As mandated in the Clean Air Act, the ambient air
criteria pollutants are reviewed and AQCDs revised to reflect the best available scientific
information on identifiable effects on public health and the environment from exposure
to the pollutant, and this information is used by the EPA Office of Air and Radiation in
their review and promulgation of the National Ambient Air Quality Standards (NAAQSs)
to protect public health with an adequate margin of safety. Success is defined by an
external expert review process to measure the utility of the data, tools, and technologies
for key Agency decisions (metric to be established in consultation with external
reviewers; measurement methodology still under development).
Strategic Targets - Computational Toxicology Research:
Risk assessors will use improved methods and tools to better understand and describe
the linkages of the source to outcome paradigm. Success is defined by an external
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expert review process to measure the utility of the data, tools, and technologies for key
Agency decisions (metric to be established in consultation with external reviewers;
measurement methodology still under development).
Regulators and risk assessors will use advanced hazard characterization tools to
prioritize and screen chemicals for toxicological evaluation. Success is defined by an^
external expert review process to measure the utility of the data, tools, and technologies
for key Agency decisions (metric to be established in consultation with external
reviewers; measurement methodology still under development).
Assessors and regulators will use new and improved methods and models based on
the latest science for enhanced dose-response assessment and quantitative risk
assessment. Success is defined by an external expert review process to measure the
utility of the data, tools, and technologies for key Agency decisions (metric to be
established in consultation with external reviewers; measurement methodology still
under development).
Strategic Targets - Mercury Research:
ORD will advance the research to reduce and prevent release of mercury into the
environment. Success is defined by an external expert review process to measure the
utility of the data, tools, and technologies for key Agency decisions (metric to be
established in consultation with external reviewers; measurement methodology still
under development).
ORD will conduct research to understand the transport and fate of mercury from
release to the receptor and its effects on the receptor. Success is defined by an
external expert review process to measure the utility of the data, tools, and technologies
for key Agency decisions (metric to be established in consultation with external
reviewers; measurement methodology still under development).
Strategic Targets - Homeland Security Research:
ORD will provide tools including new or refined advisory levels for various
contaminants of concern, improved risk assessment methods and communication tools,
and support to emergency and follow-up responders, enabling rapid evaluation of
chemical, biological, and radiological risks associated with a terrorist threat or attack.
Success is defined by an external expert review process to measure the utility of the
data, tools, and technologies for key Agency decisions (metric to be established in
consultation with external reviewers; measurement methodology still under
development).
ORD will develop data, methods, and technologies that the Agency uses to inform
decisions by water utilities and their support organizations, public health officials, and
the emergency and follow-up response community to identify vulnerabilities, detect
contamination, warn the public, and respond effectively in the event of a biological,
39
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chemical, or radiological attack on any of the nation's water infrastructure. Success is
defined by an external expert review process to measure the utility of the data, tools,
and technologies for key Agency decisions (metric to be established in consultation with
external reviewers; measurement methodology still under development).
ORD will provide tools, protocols and methods to the emergency and follow-up
response community, elected and appointed officials, and the general public for
locating, collecting, and analyzing environmental samples; protecting decontamination
personnel, the general public, and the environment; and the decontamination and
disposal of materials in the event of a biological, chemical, or radiological attack inside
and outside of buildings. Success is defined by an external expert review process to
measure the utility of the data, tools, and technologies for key Agency decisions (metric
to be established in consultation with external reviewers; measurement methodology
still under development).
Strategic Targets - Safe Pesticides and Products:
!
OPPTS uses the results of ORD's research as the scientific foundation for prioritization
of testing requirements and enhanced interpretation of exposure, hazard identification
and dose-response information. Success is defined by an external expert review
process to measure the utility of the data, tools, and technologies for key Agency
decisions (metric to be established in consultation with external reviewers;
measurement methodology still under development).
OPPTS uses the results of ORD's research as the scientific foundation for probabilistic
risk assessments to protect natural populations of birds, fish and other wildlife. Success
is defined by an external expert review process to measure the utility of the data, tools,
and technologies for key Agency decisions (metric to be established in consultation with
external reviewers; measurement methodology still under development).
OPPTS uses the results of ORD's research as the scientific foundation for preventing
or reducing risks to human environments within communities, homes, workplaces, and
evaluating novel or newly discovered environmental hazards. Success is defined by an
external expert review process to measure the utility of the data, tools, and technologies
for key.Agency decisions (metric to be established in- consultation with external
reviewers; measurement methodology still under development).
GOAL 5: Compliance & Environmental Stewardship.
Improve environmental performance through compliance with environmental
requirements, preventing pollution, and promoting environmental stewardship.
Protect human health and the environment by encouraging innovation and
providing incentives for governments, businesses, and the public that promote
environmental stewardship and long term sustainable outcomes.
Objective 5.1: Achieve Environmental Protection Through Improved Compliance.
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By 2011 maximize compliance to protect human health and the environment through
compliance assurance activities by achieving a 5% increase in the pounds of pollution
reduced, treated, or eliminated. (Baseline to be determined for 2006.)
Note to Reviewers: OECA will be developing statistically-valid compliance rates
for key populations associated with the national priorities of EPA's enforcement
and compliance program. In addition, .as part of a larger'review of its
performance measures, OECA will be consulting with a broad array of co-
regulators, compliance programs, and academic experts to learn more about
statistically-valid compliance rate methodologies that might be appropriate to
apply to EPA's enforcement and compliance program. We would appreciate your
comments on this matter as you review the draft architecture.
NACEPT Comments ,
Why 5%? How many pounds does this represent? What is the difference between a pound of
pollution reduced and a pound eliminated? What is achieved by "treating" pollution, and
shouldn't this objective place priority on elimination over treatment? What types of compliance
assurance activities are covered in this objective? The word "by" is confusing: does the 5%
increase in pounds of pollution reduced, treated, or eliminated lead to improved compliance, or
does improved compliance lead to the 5% improvement? If we assume EPA means the latter,
the objective might be reworded as follows: "By 2011, achieve a 5% reduction in the pounds of
pollution released by regulated entities through compliance assurance activities such as..."
Sub-objective 5.1.1: Compliance Assistance. By 2011, prevent noncompliance or
reduce environmental risks through EPA compliance assistance by maintaining, or
improving on the following percentage:. 85% of regulated entities improve their
understanding of environmental requirements; 50% of regulated entities improve
environmental management practices; and 12% of regulated entities that reduce, treat,
or eliminate pollution. (Baseline to be determined for 2006.)
NACEPT Comments
This sub-objective is particularly difficult to understand. In the first phrase, the word "or" should
be changed to "and." The sub-objective should state BOTH the number of regulated entities
that will improve their practices as well as the percentages. The sub-objective is ambiguous
with respect to whether performance improvement is a goal - it states that the agency will
"maintain" or "improve." Shouldn't improvement be expected? What is the basis for the
percentage goals, and why is only 12% of the regulated population expected to "reduce, treat,
or eliminate pollution"? Will EPA target specific sectors, or does it expect to-achieve
improvements across the board?
Sub-objective 5.1.2: Compliance Incentives. By 2011, identify and correct
noncompliance and reduce environmental risks through a 5 percentage point increase
in the number of facilities that use EPA'incentive policies to conduct environmental
audits or other actions that reduce, treat, or eliminate pollution or improve environmental
management practices. (Baseline to be determined for 2006.)
NACEPT Comments
The number of facilities that currently access incentive policies should be provided. Each sub-
objective should include the absolute number of regulated entities .affected as well as
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percentages. Shouldn't the objective be to increase the number of facilities that conduct
environmental audits, prevent pollution, and improve environmental management practices,
whether or not they utilize EPA-incentive policies? In other words, we question whether the use
of incentives policies should be an objective at all.
Sub-objective 5.1.3: Monitoring and Enforcement. By 2011, identify, correct, and
deter noncompliance and reduce environmental risks through monitoring and
enforcement by achieving: a 5% increase in the number of facilities taking complying
actions during EPA inspections after potential deficiencies have been identified; a' 5
percentage point increase in the percent of enforcement actions requiring that pollutants
be reduced, treated, or eliminated; and a 5 percentage point increase in the percent of
enforcement actions requiring improvement of environmental management practices.
(Baseline to be determined for 2006.)
NACEPT Comments
<_ Each sub-objective should include the absolute number of regulated entities affected as well as
percentages. What does it mean to take "complying actions during EPA inspections?" What
would such complying actions entail?
We find it difficult to comment on this sub-objective without baseline information. This sub-
objective appears to address three distinct environmental improvement strategies: complying
actions during an inspection; reducing, treating, or eliminating pollution; and improvement in
environmental management practices. Are we to assume that each of these strategies carries
equal weight for the agency, since EPA is striving to increase the use of each by 5 percentage
points over the next'5 years? While the first measurable is based on action by the regulated
community (increase in the number of facilities decisively responding to non-compliance
identified during EPA inspections, albeit only 5%), the second and third measurables relate only
to behavior change within EPA by inclusion of particular tools in EPA enforcement actions
(inputs) and not to behavior change (actions) in the regulated community (outcomes). Since the
vast majority of enforcement actions are initiated at the state and local levels through
enforcement program delegation, are these measurables applicable to state and local
enforcement actions as well, or limited only to actions initiated by EPA?
An example would be helpful here.
Objective 5.2: Improve Environmental Performance through Pollution Prevention
and the Adoption of other Stewardship Practices that Lead to Sustainable
Outcomes. By 2011, enhance public health and environmental protection and increase
conservation of natural resources by promoting pollution prevention and the adoption of
other stewardship practices by companies, communities, governmental organizations,
and individuals.
Sub-objective 5.2.1: Prevent Pollution and Promote Environmental Stewardship
by Business, Government and the Public. By 2011, reduce pollution, conserve
natural resources, and improve other environmental stewardship practices through
implementation of EPA's pollution prevention programs.
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Strategic Targets:
By 2011, reduce 10.5 billion pounds of hazardous materials cumulatively from the
2005 baseline.
NACEPT Comments
Who is to do this, and through what means? What is the baseline, and what percentage
reduction does the target represent? [Same comment applies to 6 bulleted points below.]
By 2011, reduce 1.5 billion pounds of non-hazardous materials cumulatively from the
2005 baseline.
By 2011, reduce, conserve or offset 4 million megawatts of energy use cumulatively
from the 2005 baseline.
By 2011, reduce, conserve or offset 1 quadrillion BTUs of energy use cumulatively
from the 2005 baseline.
By 2011, reduce water use by 73 billion gallons cumulatively from the 2005 baseline.
By 2011, reduce $1.1 billion business, institutional and government costs by x dollars
cumulatively from the 2005 baseline.
* By 2011, achieve a XXX pound (10% of baseline) overall reduction of priority
chemicals in waste using 2004 as a baseline year.
Sub-objective 5.2.2: Promote Improved Environmental Performance through
Business and Community Innovation. Through 2011, achieve measurably improved
environmental performance to achieve sustainable outcomes through sector-based
approaches, performance-based programs, and assistance to small business.
Strategic Targets:
By FY 2011, Performance Track members collectively will achieve the following
normalized annual reductions: XXX gallons in water use; XXX tons of hazardous
materials use; XXX Metric Tons of Carbon Dioxide Equivalent (MTCO2E) of
greenhouse gases; XXX tons of toxic discharges to water; and XXX tons of combined
NO and SO emissions. (In FY 2005, Performance Track members achieved
XX X
normalized annual reductions of 3,387,333,545 gallons in water use; 8,794 tons of
hazardous materials use; 151,129 MTCO2E of greenhouse gases; 186 tons of toxic
discharges to water; and 3,188 tons of combined NO and SO emissions.)
XX
NACEPT Comments
While it is difficult to comment on Performance Track targets since they are not given, how do
the reductions noted for the previous year compare to reductions of .facilities that do not
participate in the program? How they compare to water use, hazardous material use, and
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discharges of greenhouse gases, toxics, and NOx and SOx from industry generally? Are these
significant or inconsequential reductions? v
By 2011, the participating manufacturing and service sectors in the Sector Strategies
Program will achieve an aggregate 10% reduction in environmental releases to air,
water, and land, working from a 2004 baseline and normalized to reflect economic
growth. (Baseline and normalization factors to be developed in 2006.)
NAGEPT Comments
Are these gross emissions or production-normalized? How.does a 10% reduction compare to
reductions from sectors that do not participate in the program? Are reductions achieved through
non-Sector Strategies Program actions {e.g., enforcement, compliance assistance, incentives)
included or excluded as measures of Sector Strategies Program performance here?
Sub-Objective 5.2.3: Promote Environmental Policy Innovation. By 2011, achieve
measurably improved environmental results, promote stewardship behavior, and
advance sustainable outcomes by testing,' evaluating, and applying alternative
'approaches to environmental protection in states, companies, and communities. This
work also will seek to improve the organizational cost effectiveness and efficiency for
regulatory agencies as well as regulated entities.
Strategic Targets:
By 2011, innovation projects under the State Innovation Grant Program and other
piloting mechanisms will achieve, on average, a 7.5 % or greater improvement in
environmental results (such as air or water quality), compliance rates, and/or a.5% or
greater improvement in cost effectiveness and efficiency. (Note: Baselines will be
developed based on 2001-2005 innovation program activities.)
NACEPT Comments
Why 7.5%? This is a very specific target. 7.5% compared to what? "Traditional" environmental
regulation? How will this be measured?
Objective 5.3: Build Tribal'Capacity to Improve Human Health and the
Environment in Indian Country. Protect human health and the environment on tribal
lands by assisting Federally-recognized tribes to: build,environmental management
capacity; assess environmental conditions and measure results; and implement
environmental programs in Indian country.
Strategic Targets:
By 2011, increase the percent of tribes with an environmental program to 67%. (FY
2005 Baseline: 54% of Tribes; Universe: 572 tribes.)
NACEPT Comments
Would any environmental program satisfy this requirement? Shouldn't the agency specify
minimal requirements?
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By 2011, increase the percent of tribes implementing federal environmental programs
in Indian country to 9%. (FY 2005 Baseline: 5% of Tribes; Universe: 572 tribes.) .
NACEPT Comments
This should be compared to the previous target. If only 5% of tribes implement any federal
environmental programs, then 49% of tribes have environmental .programs that are not
equivalent to federal programs. A goal of increasing the number of federal programs to 9%
seems quite conservative.
By 2011, increase the percent of tribes conducting EPA-approved environmental
monitoring and assessment activities in Indian country to. 26%.-(FY 2005 Baseline: 20%
of Tribes; Universe: 572 tribes.)
Objective 5.4: Enhance Society's Capacity for Sustainability through Science and
Research. Conduct leading-edge, sound scientific research on pollution prevention,
new technology development, socioeconomic, sustainable systems, and decision-
making tools. By 2011, the products of this research will be independently recognized
as providing critical and key evidence in informing Agency polices and decisions and
solving problems for the Agency and its partners and .stakeholders. (Also see
Research, under Cross Agency and Support-Prog ram Evaluations in Appendix of this
Strategic Plan.)
NACEPT Comments
Can EPA provide any guidance about the level of priority it will place on these different research
areas? Since outcomes are difficult to measure in this area, some information about outputs
would be helpful. For example, how many RFPs does EPA expect to issue for each sub-
objective?
Sub-objective 5.4.1: Strengthening Science. The research and educational
community, the regulated community and decision and policy makers use ORD
products and services to enhance the scientific and technology base and catalyze
innovation of alternative processes, tools, technologies and systems for advanced
environmental protection; implement more efficient and sustainable practices, materials
and technologies in improved environmental performance; implement improved and
scientifically sound management decisions and policies and practices for sustainable
resource management.
Sub-objective 5.4.2: Conducting Research Through 2011, conduct leading-edge,
sound scientific- research on pollution prevention, new technology development,
socioeconomic, sustainable systems, and decision-making tools. The products of this
research will provide critical and key evidence in informing Agency polices and
decisions affecting the Agency programs in Goal 5, as well EPA partners and
stakeholders.
Strategic Targets - Sustainabilitv and Pollution Prevention:
The research and educational community apply ORD research results, products and
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services to enhance the scientific and technology base and catalyze innovation of
alternative processes, tools, technologies and systems for advanced environmental
protection. Success is defined by an external expert .review process to measure the
utility of the data, tools, and technologies for key Agency decisions (metric to be.
established in consultation with external reviewers; measurement methodology still
under development).
NACEPT Comments
What is the timetable for developing these metrics and measurement methodologies?
The regulated community applies ORD research products and services to implement
more efficient and sustainable practices, materials and technologies in improved
environmental performance. Success is defined by an external expert review process
to measure the utility of the data, tools, and technologies for key Agency decisions
(metric to be established in consultation with external reviewers; measurement
methodology still under development).
Decision and policy makers use ORD products and services to implement improved
and scientifically sound management decisions and policies and practices for
sustainable resource management. Success is defined by an external expert review
process to measure the utility of the data, tools, and technologies for key Agency
decisions (metric to 'be established in consultation with external reviewers;
measurement methodology still under de velopment).
Strategic Targets - Economics and Decision Sciences:
Through 2011 identify and reduce uncertainties and potential biases associated with
benefit transfer methods, and provide these methods and estimated values from original
studies for ecological and human health benefits analysis for use in Regulatory Impact
Analyses and similar documents by EPA's program offices, states, regions, and other
bodies. Success is defined by an external expert review process to measure the utility
of the data, tools, and methods for key Agency decisions (metric to be established in
consultation with external reviewers; measurement methodology still under
development).
Through 2011 make progress in improving the understanding of decision-making with
respect to compliance behavior and environmental performance in response to
interventions, including government enforcement, information disclosure, voluntary
initiatives, and similar programs, to support the design of policies using these
interventions. Success is defined by an external expert review process to measure the
utility of the data, tools, and methods for key Agency decisions (metric to be established
in consultation with external reviewers; measurement methodology still under
development). .
Through 2011 make progress in identifying regulated entities' responses to market
mechanisms and incentives and investigating how market-based programs can be
designed to improve environmental quality at the lowest cost, to support the design of
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policies using market mechanisms and incentives for environmental management.
Success is defined by an external expert review process to measure the utility of the
data, tools, and methods for key Agency decisions (metric to be established in
consultation with external reviewers; measurement methodology still under
development).
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