230R83006 A PROFILE OF ERA ACTIVITIES' ¦ " I Program Evaluation Division Office of Management Systens and Evaluation July- 198 3 ------- TABLE OF CONTENTS Introduct ion Part I: The Agency as Part II: Headquarters Part III: Comparisons a Whole and the Regional Offices Among EPA Programs Table LIST OF TABLES List of EPA Activities Total"BPA Workyears and Contract S By Category Total EPA Workyears and Contract S By Activity Division of Headquarters, Regional Workyears Activity Workyears at Headquarters, Regions Range of Regional Workyears Division of Program Workyears in Headquarters Of f ices Division of Contract Dollars in Headquarters Of f ices ; % EPA Workyears'and Contract S in 3 Programs Comparison of Headquarters/Regional % By Progra Program Workyear Breakdown By Category Program Workyear Breakdown By Activity Program Contract Dollars By Activity ------- A PROFILE OF EPA ACTIVITIESt Introduct ion The overall purpose of the study on meeting EPA's post- delegation responsibilities is to examine the implications for EPA of the delegation of programs to State and local • government. Such an examination requires useful, objective information about trends and opinions both inside and outside - EPA which could affect the Agency's future work. The inforrnation needed includes data on environmental trends, an analysis of, : current thinking in State-Federal relations, outside views on how other organizations handle the problems of decentralized--: management, and informed opinion on EPA's performance in meeting its current responsibilities. This report presents results from one of these information- gathering efforts. It consists of a functional profile of EPA's work, as divided among 23 different activities. The objective of this profile is to provide a factual baseline picture of what EPA does as an agency, organized by function (e.g., standard-setting, research, direct administration of programs, technical support). Further discussions of what the Agency might or should do in the future can draw on this vaseline in developing options for management choices, especially )n describing what the implications of these choices might be. Data for thi.^ report were obtained from EPA's Regional and eadquarters offices. Offices were asked to give their best estimates of the percentage of their current (1983) workyears and contract dollars which are devoted to each activity. We asked for percentages because we felt that they were appropriate to the level of precision needed for this study, and that this would encourage program managers to classify their offices' activities by reflecting on the real work of their staff. Several respondents expressed some concern that this data would be specifically used to critique their budget submissions. We addressed this concern by promising that this data would not be used in connection with resource allocation decisions, as we felt that only by making this pledge could we expect to get valid results. We believe that while the results of this effort are useful and accurate as an aggregate picture of EPA's ,, work, it would not be appropriate to compare this data to detailed budget submissions for individual offices. These budget.sub- missions are generated by a very different system which operates under a very different set of rules and assumptions. tPrepared by Stan Meiburg and Gainor Eisenlohr in the Program Evaluation Division, U.S. EPA. Special thanks are due to Pat Meaney and Lane Krahl in EPA Region 1, who served as project managers for all of the data reported from the Regions and whose rigorous review of the early proposals for this project improved it significantly. ------- -2- To collect the data reported in this profile, we used the following process. o A draft list of activities and definitions was developed by the Program Evaluation Division. This list was reviewed throughout the Agency for clarity and comprehensiveness. o Based on this review, a revised list of activities and definitions was developed. This revised list was sent to all Headquarters and Regional oftices, along with detailed instructions on how to classify each office's work among the various activities (see Attachment 1). o Regional offices reported their classifications bacu to EPA Region I, which kept track of the submissions and checked for reporting errors (e.g., percentages which failed to add up to 100). The Program Evaluation Division performed the sane function for Headquarters offices. All Headquarters and Regional offices responded to the request for information except Region Vll's Office of Regional Counsel and Region X's Alaska Operations Office. o The raw data were entered into a computer at Head- quarters, which generated the summaries presented in this report. The totals for FTE and contract funds reported by each office were used to weigh the percentages reported by that office for each activity. Several checks have been performed on the data to confirm its quality. Reported total workyears for the Agency difter by less than 2% from EPA's current budget estimate. Contract funds differ by less than 4%, and the bulk of this difference appears to stem from uncertainty about how to count carryover funds and research grants. In addition, the percentages assigned to different categories are relatively consistent among Regions, suggesting that the definitions and classifications were applied on the whole in a similar manner. Finally, while there was no attempt no "second-guess" classifications submitted by individual offices, the data submissions were reviewed and checked with offices if'the reports appeared to contain major anomalies. For these reasons, we are confident that the data is of sufficient quality to serve as a baseline profile of EPA's current activities. However, to our knowledge, there is no other sinilar profile of EPA activity. The absence of a yardstick against which to compare the results of this exercise suggests the need for caution in interpreting these results. Nevertheless, they should be useful in comparing different scenarios whicn EPA might pursue in response to changing patterns of delegation over the next five years. ------- -3- The body of the report is divided into three parts. The first part presents a look at how the Agency as a whole is divided among the 7 categories and 23 activities. Part II presents the results of some comparisons between Headquarters and Regions and among Headquarters and Regional offices. Part III compares three programs -- Air, Water, and Hazardous Waste£/— each of which have substantial Headquarters and Regional components. Since this report's intent is to be descriptive rather than prescriptive, it presents the results of our analyses in such a way that the reader can draw his or her own conclusions. A Word About the List of Activities The appendix to this report contains a definition of each of the 23 activities used as the basis for classifying each offices' work. This is not the only set of activities which could be identified, nor is it the best for all purposes, but it enables us to make the analytical distinctions necessary for this project. In developing the list, we applied three basic principles: simplicity; comprehensiveness; and attention to post-delegation support activities. We realized at the time the list was developed that our choice of a classification scheme would facilitate some analyses and elininate the possibility of others. This was an unavoidable consequence of the need to develop a list which could be used relatively quickly. Given this need, we tried to anticipate the types of analyses which would be most relevant to this study, and to structure the list so that these analyses could be successfully performed. For several of the analyses which follow, the 23 activities have been grouped into seven major categories. Both the categories and the activities are listed in Table 1. 2/as used in this report, the "Hazardous Waste" program includes both the PCRA and Superfund programs. ------- Table 1: List of tPA Activities I. DIRECT PROGRAM ADMINISTRATION A. Permitting, Engineering, and Environmental Impact Reviews B. Product Review and Registration C. Hazardous Substance Emergency Response and Site Management D. Compliance and Enforcement E. Program Direction and Interpretation II. TECHNICAL SUPPORT A. Laboratory Services B. Development and Distribution of Implementation Tools C. Direct Assistance On-Site/Person to Person D. Special Projects E. Training III. STATE PROGRAM APPROVAL AND OVERSIGHT A. Review of State Programs/Plans/Delegation Applications P. Review of Individual Proposed State Actions C. Program Review of State Actions IV. RESEARCH A. Standard-Setting Support B. Exploratory Research V. STANDARD-SETTING A. Listing Dec 1slons/Designation Activities B. Technical Regulations C. Administrative Regulations VI. MANAGEMENT SUPPORT A. Policy Activities B. Administration and Support Services C. Legal Defense VII. NATIONAL INFORMATION COT.LECTION A. Formal National Information Systems B. Special Requests for Information ------- ®iRT I: THE AGENCY AS A WHOLE The data collected for this study confirm the common impression that EPA is highly decentralized. However, they also call attention to the size of the Headquarters component. Out of all EPA workyears, 31% are assigned to Headquarters offices, while 39% are assigned :o the Regions. Not all Headquarters employees are located in Washington, of course; the Office of Research and Development (ORD) and the Office of Air, Noise and Radiation (OANR) in ^articular have large units located elsewhere which are counted in the Headquarters totals. The figures for contract dollars reflect the Agency's current practices in contract administration. In general, contracts are jssigned to allowance holders in Headquarters, which in some cases :hen reallocates a portion of these to the Regions to satisfy specific Regional needs. As a result, 97% of all the agency's rontract dollars are administered from Headquarters offices, vhile only three percent are allocated directly to the Regions.£/ / As noted in the introduction, the 23 activities into which :he Agency's work was divided can be grouped into seven general rategories. Table 2 shows how the agency divides its workyears »nd contract dollars among these seven categories.3/ Table 2; Total EPA Workyears and Contract S By Category Workyear Contract S % % :. Direct Program Administration 26 31 t. Technical Support 9 9 :. State Program Approval and Oversight 8 0 /. Research 12 17 /. Standard-Setting 9 11 :. Management Support 30 29 !. National Information Collection 5 2 A further breakdown of the data among the 23 activities jives a more detailed look at the overall patterns of the Agency's ise of workyears and contract dollars. One point to remember vhen looking at this data is that a "U%" entry does not necessarily nean that absolutely no contract dollars or workyears are •.pent in this area, but rather that that the totai figure reported was less than one percent of the Agency total. -/ Because of uncertainties in interpreting the contract dollar percentage breakdowns reported by the Regions, all contract collar discussions in the remainder of this report will address Headquarters contract dollars only. Totals in this and other tables may not add to 100% due to rounding. For rough comparisons, 1% equals about 106 workyears and S4.5 million in contract dollars. ------- -6- Table 3: Total EPA Workyears and Contract S By Activity4/ II III IV. VI VII Workyear % Cont DIRECT PROGRAM ADMINISTRATION A. Permitting and Reviews 5 1 B. Product Registration 4 2 C. Hazardous Substance Response 2 22 D. Compliance and Enforcement 10 4 E. Program Direction 4 1 TECHNICAL SUPPORT A. Laboratory Services 2 4 B. Implementation Tools 2 3 C. Direct Assistance 2 1 D. Special Projects 2 2 E. Training 1 1 STATE PROGRAM APPROVAL AND OVERSIGHT A. Review of Plans/Applications 3 0 B. Review of Individual Actions 2 0 C. Program Reviews 3 0 RESEARCH A. Standard-Setting Support 12 16 B. Exploratory Research 0 1 STANDARD-SETTING A. Listing Decisions 1 1 B. Technical Regulations 7 10 C. Administrative Regulations 1 1 MANAGEMENT SUPPORT A. Policy Activities 10 3 B. Administration/Supporr 19 2 S C. Legal Defense 1 0 NATIONAL INFORMATION COLLECTION A. Formal Systems 3 2 B. Special Requests 2 1 PART II: HEADQUARTERS AND THE REGIONAL OFFICES Another way of looking at the data is to see how workyears in the nirferent categories and activities are divided between Headquarters and the Regions. Tables 4 and 5 show how Headquarters workyears are divided is conparcd to the Regional offices. Not surprisingly, both .ables show that Headquarters and Regional offices generally do ^/Activity totals nay not exactly add up to category totals due to rounding. ------- -7- ifferent kinds of work. Regional offices are primarily involved n the direct administration of EPA programs as well as the review and oversight of State programs. Headquarters' direct program responsibilities are mainly in the pesticides and toxic substances area; in other areas, Headquarters is primarily a research, standard setting, and management support organization. The concentration of management support activities in Headquarters reflects a centralization of both administrative support services and policy-related activities. This stands out oven more when it is remembered that the Headquarters/Regional i^plit in overall resources is approximately 60/40 in favor of Headdqua rters. Table 4; Division of Headquarters, Regional Workyears Headquarters Regional Workyear % Workyear % Direct Program Administration Technical Support State Program Approval and Oversight Research Standard-Set t i ng Management Support National Information Collection 17 9 2 20 14 36 3 41 10 18 0 •*1 22 8 Table 5; Activity Workyears at Headquarters, Regions Headquarters Regional Workyear % Workyear % DIRECT PROGRAM ADMINISTRATION A. Permitting and Reviews B. Product Registration C. Hazardous Substance Response D. Compliance and Enforcement E. Program Direction 1 7 1 5 3 12 0 5 18 6 TECHNICAL SUPPORT A. Laboratory Services B. Implementation Tools C. Direct Assistance D. Special Projects E. Training 2 3 1 1 1 2 1 4 2 2 STATE PROGRAM APPROVAL AMD OVERSIGHT A. Review of Plans/Applications B. Review of Individual Actions C. Program Reviews 0 1 6 4 7 ------- .'able 5 (continued) HQ % RO IV. RESEARCH A. Standard-Setting Support 19 0 B. Exploratory Research 1 0 V. STANDARD-SETTING A. Listing Decisions 1 0 B. Technical Regulations 11 1 C. Administrative Regulations 2 1 VI. MANAGEMENT SUPPORT A. Policy Activities 12 7 B. Administration/Support 22 14 C. Legal Defense 1 1 VII. NATIONAL INFORMATION COLLECTION A. Fornal Systems 2 4 B. Special Requests 2 4 Another interesting item that showed up in the data is the range of percentages which the 10 Regional offices assigned to >ach of the seven categories. The highest and lowest workyear jercentages reported in each category are presented in Table 6. While th?re are differences among Regions, it is noteworthy that the largest difference between the high and low values for category is 15%. Table 6: Ranqe of Reqional Workyear % Low % H i qh % Direct Program Administration 34 46 Technical Support 5 14 State Program Approval and Oversight 13 28 Standard-Setting 0 3 Managenent Support 16 27 National Information Collection 6 10 ------- -9- Headquarters offices show sonewhat different patterns of activities from one office to another. Table 7 shows these patterns for the workyears of four headquarters offices: Air, Noise and Radiation; Water; Solid Waste and Emergency Response, and Pesticides and Toxic Substances. Table 8 shows the same information for contract dollars. The percentages in each of the seven categories are a percentage of each program's headquarters total. Table 7: Division of Program Workyears in Headquarters Offices (Figures are % of total office workyears) Direct Program Administration Technical Support State Program Approval and Oversight Resea rch Standard-Setting Management Support National Information Collection Table 8: Division of Contract Dollars in Headquarters Offices (Figures are * of total office contract S) OANR OW OSWER OPTS Direct Program Administration 27 25 67 31 Technical Support 6 12 12 8 State Program Approval and Oversight - 1 1 0 0 Research * o 2 3 4 Standard-Setting 60 39 5 38 Management Support 0 9 10 12 National Information Collection 0 10 2 ^ 1 1 OANR OW OSWER OPTS 22 22 35 47 12 16 8 9 5 6 7 3 4 1 0 2 38 25 21 23 16 21 23 13 3 9 5 3 ------- -10- PART III; COMPARISONS AMONG EPA PROGRAMS Another way of looking at the data collected in this study is to conpare patterns anong major programs of the agency— specifically the air, water, and hazardous waste programs-- which have large Headquarters and Regional components. For the purpose of this analysis, the "hazardous waste" program includes activities conducted under both RCRA and Superfund authorities. The "water" program includes both water qualitv (including construction grants) and drinking water programs, while the air program includes both stationary and mobile source control act ivities Table 9 presents the overall agency percentages of workyears and contract dollars applied to the air, hazardous waste, and water programs. Table 9: % EPA Workyears and Contract S in 3 Programs Workyear Contract S % % Air 10 5 Hazardous Waste 10 36 Water 16 5 Each of the three programs has a somewhat different distribution of resources between Headquarters and Regional offices. Table 10 shows this data for the three programs. Table 10: Comparison of Headquarters/Regional % By Program Headquarters Regional % % Air 56 44 Hazardous Waste 34 66 Water 31 69 ^/The Regional reports on the workyears associated with these three programs also contain work associated with the radiation and pesticides prograns, which have small Regional components. Because of inconsistencies in Regional organizations, these workyears were not all reported consistently, though radiation workyears were most commonly reported with the air resources, while pesticides workyears were most commonly reportec with hazardous waste resources. The levels of workyears involved in any event are so small that they have no appreciable effect on the overall totals. ------- -11- Table 11 compares the workyear percentages which each of the three programs reported for each of the seven major categories of activity. This comparison is further broken down in Table 12, which shows the relative percentages for each of the 23 activities. These data represent a summary of all of the percentages reported by both Headquarters and Regional components of each program. There are some striking differences among the three programs. The air program, for example, devotes a substantially larger percentage of its resources to standard-setting (a function primarily performed in Headquarters) than either of the other two programs. On the other hand, the water and hazardous waste programs do substantially more permitting and review (functions which are primarily Regional) than does air. To contrast another area, compliance and enforcement activities are a substantially larger percentage of air and hazardous waste activities than is the case in the water program. It is unclear just what these different patterns signify. One possibility is that they reflect the need for different approaches to solving environmental problems in the air, water, and land. Whatever the cause, it is important to understand that the distribution of activities among the various program areas are quite distinctly different. Table 11: Program Workyear Breakdown by Category^/ WORKYEAR % HAZARDOUS • AIR WASTE WATER Direct Program Administration 28 51 35 Technical Support 10 8 13 State Program Approval and Oversight 19 15 21 Research 3 0 1 Standard-Setting 20 8 10 Management Support 13 12 12 National Information Collection 7 6 8 ^/"Research" workyears and contract dollars for each program include program office workyears and funds only and do not include resources devoted by ORD to air, water, and hazardous waste research. ------- -12- Table 12: Program Workyear Breakdown by Activity WORKYEAR % AIR HAZARDOUS WASTE WATER I. DIRECT PROGRAM ADMINISTRATION A. Permitting and Reviews B. Product Registration C. Hazardous Substance Response D. Compliance and Enforc-ment E. Program Direction CI. TECHNICAL SUPPORT A. Laboratory Services B. Implementation Tools C. Direct Assistance D. Special Projects E. Training CI. STATE PROGRAM APPROVAL AND OVERSIGHT A. Review of Plans/Applications B. Review of Individual Actions C. Program Reviews CV. RESEARCH A. Standard-Setting Support B. Exploratory Research V. STANDARD-SETTING A. Listing Decisions B. Technical Regulations C. Administrative Regulations /I. MANAGEMENT SUPPORT A. Policy Activities B. Administration/Support C. Legal Defense CI. NATIONAL INFORMATION COLLECTION A. Formal Systems B. Special Requests 4 3 0 17 4 3 3 2 1 1 8 4 7 3 0 2 17 2 5 8 1 5 2 14 1 9 17 11 1 1 S 1 1 9 2 4 0 0 6 "b 0 4 3 14 0 0 10 10 1 3 4 2 3 7 6 9 1 0 0 7 3 7 5 0 The use to which the various programs put contract dollars can be compared using a similar analysis. About. 46% of EPA's total contract dollars are spent in the air, hazardous waste and water programs. Over three-fourths of this is spent in the hazardous waste area, reflecting the activities conducted under "Superfund." Table 13 contains a breakdown of how each program spends its contract dollars. There are larger differences in contract dollar percentages than in workyear percentages. For example, in addition to the obvious difference in the hazardous waste area because of Superfund, there are also significant differences in tne use of ------- -13- contract funds for compliance and enforcement activities, permitting and reviews, and technical regulations. Some caution should be used in interpreting the "hazardous waste" percentages. Because the "Superfund" program is so large, it makes the percentages for all other activities in the hazardous waste program seem small even though they may be conparable in absolute terms to similar activities in the air and water programs. For this reason, two columns are shown for the hazardous waste program, one which includes contract funds for emergency re ponse actions and one excludes those funds from the base level used to calculate the percentages. TABLE 13: Program Contract Dollars by Activity CONTRACT DOLLAR % DIRECT PROGRAM ADMINISTRATION A. Permitting and Reviews B. Product Registration C. Hazardous Substance Response D. Compliance and Enforcement E. Program Direction AIR 0 0 0 28 0 HAZARDOUS WASTE 1 WASTE2 1 0 60 5 1 2 0 12 2 WATER 19 0 3 2 7 II. TECHNICAL SUPPORT A. Laboratory Services B. Implementation Tools C. Direct Assistance D. Special Projects E. Training 1 3 0 1 5 8 3 1 0 1 20 8 3 0 2 4 6 1 2 1 III. STATE PROGRAM APPROVAL AND OVERSIGHT A. Review of Plans/Applicat ions 1 0 0 0 B. Review of Individual Actions 0 0 0 1 C. Program Reviews 0 0 0 0 IV. RESEARCH A. Standard-Setting Support 7 3 8 2 B. Exploratory Research 0 0 0 0 V. STANDARD-SETTING A. Listing Decisions 1 12 0 B. Technical Regulations 50 4 10 34 C. Administrative Regulations 2 0 0 1 VI. MANAGEMENT SUPPORT A. Policy Activities 0 3 7 8 B. Administration/Support 0 8 20 0 C. Legal Defense 0 0 0 0 VII. NATIONAL INFORMATION COLLECTION A. Formal Systems 0 12 9 9. Special Requests 0 12 1 ------- |