U.S EPA Headquarters UL,
Mail code 3404T
1200 Pennsylvania Avenue i
Washington, DC 20460
202-566-0556
OFFICE OF' INSPECTOR GENERA
Evaluation Report
Ongoing Management Improvements
and Further Evaluation Vital to EPA
Stewardship and Voluntary Programs
Report Number: 2005-P-00007
February 17, 2005
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Report Contributors:
Katie Butler
Manju Gupta
Erin Mastrangelo
R. Olga Stein
Thane Thompson
Abbreviations:
EPA
ERP
GPRA
IAC
LWWC
MADEP
NGO
OCFO
OECA
OIG
OPEI
OPPTS
ORD
OSWER
OW
TCEQ
Environmental Protection Agency
Environmental Results Program
Government Performance and Results Act
Innovation Action Council
Lodi-Woodbridge Winegrape Commission
Massachusetts Department of Environmental Protection
Non-Governmental Organization
Office of Chief Financial Officer
Office of Enforcement and Compliance Assurance
Office of Inspector General
Office of Policy, Economics, and Innovation
Office of Prevention, Pesticides, and Toxic Substances
Office of Research and Development
Office of Solid Waste and Emergency Response
Office of Water
Texas Commission on Environmental Quality
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
2005-P-00007
February 17, 2005
ar ftttpm viitg the En vh'tmment
Why We Did This Review
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Background
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What We Recommend
We recommend that EPA (1) develop a statement that outlines how voluntary
programs are expected to assist EPA in achieving its overall mission and its
stewardship goals and objectives; and (2) develop criteria, guidance, and an
action plan for assessing how voluntary programs will be included in the next
revision of the Agency's Strategic Plan.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
February 17, 2005
MEMORANDUM
SUBJECT: Evaluation Report: Ongoing Management Improvements and Further Evaluation
Vital to EPA Stewardship and Voluntary Programs.
Assignment No. 2003-0001451
FROM: Jeffrey K. Harris I si
Director for Program Evaluation, Cross-Media Issues
TO: Susan B. Hazen
Acting Assistant Administrator for Prevention, Pesticides and Toxic Substances
Stephanie Daigle
Acting Associate Administrator for Policy, Economics and Innovation
Attached is our final report regarding EPA's Stewardship and Voluntary Programs. This report
contains findings regarding EPA's need to continue management improvements, strategic
implementation, and evaluation of stewardship and voluntary programs. The report also contains
corrective actions the Office of Inspector General (OIG) recommends. This report represents the
opinion of the OIG, and the findings contained in this report do not necessarily represent the
final EPA position. Final determination on matters in this report will be made by EPA managers
in accordance with established procedures. EPA's Office of Policy, Economics, and Innovation
provided us with the Agency's consolidated response to our draft report on February 9, 2005.
We included EPA's consolidated response in its entirety as Appendix D.
Action Required
In accordance with EPA Manual 2750, as the action official, you are required to provide this
office with a written response within 90 days of the final report date. Because several addressees
are identified above, the Agency should identify a lead office to coordinate and consolidate
responses from all identified addressees, and that office should provide a single response to this
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final report. The response should address all recommendations. For the corrective actions
planned but not completed by the response date, please describe the actions that are ongoing and
provide a timetable for completion. Where you disagree with a recommendation, please provide
alternative actions for addressing the findings reported. We appreciate the efforts of EPA
officials and staff, as well as external stakeholders, in working with us to develop this report.
For your convenience, this report will be available at wwvv. epa. gov/oig/reports/2005/20050217-
2005-P-QQ007.pdf.
We appreciate the efforts of EPA officials and staff in working with us to develop this report. If
you or your staff has any questions regarding this report, please contact Thane Thompson at
(513)487-2361.
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Table of Contents
At a Glance
Chapters
1 Stewardship Programs Use A Voluntary Approach
to Address Environmental Issues 1
Purpose 1
Background 1
Examples of Environmental Stewardship 4
Scope and Methodology 7
Results in Brief 8
2 EPA Should Understand Stakeholder Needs To
Effectively Plan and Implement Stewardship 9
Stakeholder Definitions Varied With Stakeholder Roles 9
Selected Stakeholders Outlined Motivators and Obstacles
to Participating in Stewardship Activities 11
Selected Stakeholders Outlined Five Stewardship Roles for EPA 13
Conclusion 14
3 EPA Has Improved Voluntary Program Management,
But Additional Work is Needed 16
2003 Strategic Plan Revision Elevates Voluntary
Programs to a Strategic Level 16
EPA Working to Improve Voluntary Program Management 17
Conclusion 19
Recommendations 20
4 Further Program Evaluation Needed to Effectively Manage
Stewardship and Voluntary Activities 21
I
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Appendices
Program Information for Selected Examples
of Voluntary Programs Included in Strategic Goal 5
B List of EPA Stewardship and Voluntary Programs
C List of Selected Stakeholders We Interviewed
D Agency Comments to the Draft Report and OIG Evaluation
E Distribution
23
24
26
28
30
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Chapter 1
Stewardship Programs Use A Voluntary
Approach to Address Environmental Issues
Purpose
In its 2003-2008 Strategic Plan, EPA designated Goal 5 as "Compliance and
Environmental Stewardship." EPA expects the programs in this goal to improve
environmental performance through compliance with environmental regulations,
pollution prevention, and encouraging governments, businesses, and the public to
participate in environmental stewardship. The OIG is committed to conducting a
series of evaluations to assess the impact and effectiveness of EPA's stewardship
and voluntary programs. In this first report, our objective was to create a
foundation from which to evaluate designing, planning, and implementing EPA
stewardship activities. We sought to determine:
How selected State, industry, and community stakeholders define and
approach environmental stewardship, and what role those stakeholders
believe EPA should play in promoting and fostering stewardship
activities.
What programs EPA identified as environmental stewardship programs,
how EPA selected them, and how effective stewardship programs are in
helping EPA achieve environmental outcomes.
Background
EPA uses a variety of tools in its efforts to improve human health and the
environment. These tools include compliance and enforcement activities, such as
inspections, permits, fines, and penalties. EPA has also encouraged compliance
through technical assistance, incentives, training, and educating stakeholders on
regulatory requirements. Environmental stewardship activities and practices offer
an additional approach to environmental protection that achieves results beyond
what would normally be achieved by compliance activities alone.
EPA selected a number of programs to accomplish its stewardship goal, and
organized those programs under Goal 5. The programs in this goal were expected
to encourage pollution prevention and sustainable practices, reduce regulatory
barriers, and implement results-based, innovative, and multi-media approaches.
Table 1.1 below provides six examples of the types of voluntary programs
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included in Goal 5 and identifies the program office that implements each of these
programs. Several of the programs listed in Table 1.1 either require or
recommend the use of Environmental Management Systems (EMS) to help
participants manage and reduce their overall "environmental footprint." See
Appendix A for more information regarding these voluntary programs.
Table 1.1 - Six Examples of EPA Voluntary Programs Included in Strategic Goal 5
Program Name
Design for the Environment
Green Chemistry
Green Engineering
Performance Track
Sector Strategies
National Partnership for
Environmental Priorities
Responsible Office 1
I
Office of Prevention, Pesticides, and Toxic Substances
Office of Policy, Economics, and Innovation 1
Office of Solid Waste and Emergency Response i
EPA defined environmental stewardship as "behavior that includes, but also
exceeds, required compliance with environmental laws and regulations." These
behaviors include voluntarily reducing emissions, and considering environmental
impacts during product design, manufacture, and distribution. In its FY 2003
Annual Report, EPA said that it was working in partnership with State
governments, local communities, and other Federal agencies to integrate
compliance and stewardship activities to address the most significant
environmental and public health problems.
Stewardship Programs Are Anticipated to Generate Substantial
Environmental Benefits
EPA has determined that, in some circumstances, stewardship programs can
achieve positive environmental outcomes. Specific advantages to implementing
stewardship programs include:
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reducing releases to the environment,
reducing the regulated community's need to manage pollutants,
avoiding the transfer of pollutants from one regulated media (air, water,
land) to another, and
reducing waste and conserving materials for future generations.
While EPA acknowledged the advantages of stewardship programs, it also
identified several challenges in defining the scope of the Agency's involvement in
stewardship. Several EPA managers said that because stewardship activities are
voluntary, EPA cannot require participation in these types of programs. This is a
significant change from EPA's traditional approach as a regulatory agency, and
the Agency faces challenges regarding how to incorporate environmental
stewardship activities into existing Agency programs.
Regional EPA staff also commented that a challenge exists to prioritizing
stewardship programs because they are focused on a cross-media level, but the
Agency continues to focus on single-media issues. In addition to the difficulties
in prioritizing stewardship programs, one Agency manager questioned whether
EPA is actually increasing participation in stewardship programs, or just signing
up the same group of people over and over again for different programs. Another
EPA manager emphasized that EPA does not directly implement stewardship
activities, but rather provides information, examples, and tools to encourage its
stakeholders to voluntarily adopt more environmentally beneficial behaviors.
Stewardship Programs Are a Subset of the Agency's Voluntary
Initiatives
During our evaluation, we discovered mat the programs that EPA included in
Goal 5 are only a small subset of a much larger group of voluntary programs.
According to an Agency-wide survey completed in December 2003, EPA actually
manages 75 voluntary programs: 52 of these programs are managed by
headquarters offices; 23 are managed by EPA Regional offices. See Appendix B
for a list of the voluntary programs identified in the 2003 survey. EPA also
informed us that the population of EPA voluntary programs is quite fluid. The
Agency stated that new voluntary programs are constantly being proposed and
developed, while other programs are expanded, restructured, or even eliminated if
EPA determines that they have achieved their goals.
In 2003-2004, EPA's Innovation Action Council (IAC)1 conducted an inventory
of the Agency's voluntary programs to assess voluntary program management
Established in the Fall of 1996, the Innovation Action Council (IAC) is composed of EPA's top career
executives, and has overall responsibility for formulating and advancing the Agency's innovation agenda.
The mission of the IAC is to develop and promote innovative approaches to addressing increasingly complex
environmental challenges.
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processes, and work on identifying a definition for all of EPA's voluntary
programs. The IAC stated that establishing a firm definition for voluntary
programs was challenging, but after numerous attempts, it settled on the following
definition: "EPA voluntary programs motivate people and organizations to take
actions not required by regulation that benefit the environment. " Specifically,
the IAC said that voluntary programs:
use market forces to provide economic benefits to participants;
utilize recognition, information, and other incentives; and/or
encourage beyond-compliance, environmentally protective actions, or
provide an alternative way to achieve a regulatory/statutory objective.
The largest number of voluntary programs (21) are located in the Office of Air
and Radiation. These range in focus from voluntary emission reductions, to the
Energy Star program, to informing communities about sun exposure and sunburn
reduction. EPA's Office of Water runs eight programs, offering such voluntary
activities as community water quality monitoring, adopting a local watershed, and
helping specific customers to reduce their environmental impacts. The Office of
Solid Waste and Emergency Response implements six programs, including a
national waste reduction partnership, a used carpet recovery initiative, and a
program to help companies recycle old electronics and computers.
EPA's other program offices are also actively involved in implementing voluntary
programs. In addition to running the programs listed in Table 1.1, the Office of
Prevention, Pesticides, and Toxic Substances operates a number of voluntary
programs to help industries identify environmentally responsible supply chains,
assist hospitals in reducing their hazardous waste, and help farmers reduce the
impacts of the pesticides they use. Besides running the Performance Track and
Sector Strategies programs, the Office of Policy, Economics, and Innovation
operates voluntary programs to help communities manage the environmental
impacts of urban sprawl (Smart Growth program). The Office of Research and
Development conducts a voluntary technology verification program.
Examples of State Environmental Stewardship
The following examples are of State environmental stewardship activities that are
not generally required by regulations, and demonstrate positive outcomes from
stakeholder participation. These specific examples range from innovative
compliance assistance efforts to international cross-border partnerships. They
demonstrate a variety of technical approaches to stewardship, various levels of
stakeholder involvement, and innovative ways to achieve environmental results.
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Massachusetts Environmental Results Program
The Massachusetts Department of Environmental Protection (MADEP) operates a
small business compliance assistance program called the Environmental Results
Program (ERP). According to ERP managers, the program uses outreach and
education, self-assessment, and self-certification activities to achieve
environmental results and "enhance and measure environmental performance."
MADEP initially applied ERP to three industry sectors (dry cleaners, photo
processors, and printers) in 1997, More recently MADEP has applied ERP tools
to four other sectors, including small boilers, industrial wastewater holding tanks,
dentists who use mercury, and Stage II vapor recovery at refueling facilities.
Twelve other States also are applying ERP to additional small business sectors
beyond those targeted in Massachusetts.
The MADEP found that if small businesses clearly understand the requirements
and regulations governing their industries, then they are more willing to comply.
Regulations are often confusing to small business owners and operators. As a
result, the ERP conducts workshops and develops industry-specific workbooks
that are specifically tailored to each industry's processes and presented in
simplified language. Although ERP is not a voluntary program, Massachusetts
found that if companies are provided with assistance to comply with regulatory
requirements, they are also more likely to voluntarily go beyond compliance.
The ERP continues to help MADEP achieve environmental results. According to
MADEP, for printing press cleaning solution spills, self-reported performance
increased from 77 percent at baseline in 1998 to 85 percent in 1999. Applied to
the entire State printing industry, this performance improvement was equivalent
to 4.0 tons VOC emission reduction. For dry cleaning perchlorate leak reduction,
self-reported performance increased from 33 percent at baseline in 1997 to 66
percent in 2000. Based on average percent use per facility, and applied to the
entire State dry cleaning industry, this performance improvement is equivalent to
a total of a 22.5 ton reduction of perchlorate emissions.2
Texas Border Pollution Prevention Initiative
The Texas Commission on Environmental Quality (TCEQ) operates voluntary
programs that work with the numerous United States-, Canadian-, and Japanese-
owned facilities located within 62.5 miles (100 km) of each side of the United
States-Mexico border. The Border Pollution Prevention Initiative began working
with the facilities located in Mexico, called "maquiladora," in 1994. The program
staff developed a 5-year plan, which set goals for pollution reduction, energy and
water conservation, and environmental management training.
This information was provided by MADEP, and OIG has not independently verified its accuracy.
5
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TCEQ uses a two-prong approach to achieve results from this initiative. First,
they conduct training programs for Mexican Federal and State governments,
universities, and other institutions in developing pollution prevention and waste
minimization capability. Second, TCEQ conducts Site Assistance Visits to
survey and analyze the participating maquiladora facility's waste streams and
process operations, water and energy conservation, and current pollution
prevention activities. The Site Assistance Visits team makes recommendations on
pollution prevention and resource conservation activities that could be undertaken
by the facility. The report is sent to the facility for review and approval in order
to ensure the confidentiality of proprietary information.
TCEQ staff said that varying levels of participation occurred with the
maquiladora companies-much of the success depended on the interests of the site
management. For example, when the management was non-Mexican, the
priorities of protecting the environment were sometimes lower than if the
management was Mexican. TCEQ indicated that this situation arose because the
Mexican managers lived there and were directly affected by the day-to-day
management decisions that were made at the facility.
TCEQ collected data and measured outcomes from 17 participating Maquiladora
facilities in 2003. Together, those 17 facilities had:
reduced hazardous waste generation by more than 14,000 tons,
reduced non-hazardous waste generation by nearly 83,000 tons,
reduced volatile organic compound (VOC) emissions by 90,078 pounds,
conserved approximately 421 million gallons of water,
conserved about 446 million Kilowatt hours of electricity, and
« saved partner U.S. facilities over $85 million in avoided material and
disposal costs.3
Lodi-Woodbridge Winegrape Commission
The Lodi-Woodbridge Winegrape Commission (LWWC) in Lodi, California, a
partner in EPA's Pesticide Environmental Stewardship Program, achieved cost
savings and decreased environmental impacts of wine grape growing, through an
effort that was largely unregulated. In partnership with independent research
organizations, and through a combination of private, State, and Federal grants
(including $300,000 from EPA), the LWWC developed a self-assessment
workbook of sustainable winegrape growing practices for its members. This
workbook and the practices it included went well beyond compliance with State
and Federal environmental regulations.
This information was provided by TCEQ, and DIG has not independently verified its accuracy.
6
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LWWCs practices included weekly vineyard monitoring, using reduced-risk
chemicals, and using compost or other organic fertilizer materials. Participants
also reduced or eliminated the use of pre-emergent herbicides, implemented drip
irrigation to minimize water use, and identified economic thresholds for
determining the frequency and volume of pesticide application. After 12 years of
implementation, over 300 winegrape growers participated in LWWC program
workshops and planning activities. Participating growers decreased the amount
of insecticides used per acre, reduced insecticide costs, and reduced using
organo-phosphate pesticides to almost zero.
Scope and Methodology
We conducted our evaluation of EPA's stewardship and voluntary programs
between September 2003 and October 2004. We performed our evaluation in
accordance with Government Auditing Standards issued by the Comptroller
General of the United States. To answer our objectives, we conducted a general
literature review regarding available definitions and perceptions of the overall
concept of "environmental stewardship, and reviewed and analyzed EPA's Fiscal
Year (FY) 2003-2008 Strategic Plan (Strategic Plan), FY 2005 Annual Plan, and
FY 2005 Annual Budget documents.
We visited California, Massachusetts, and Texas to conduct interviews with
selected stewardship stakeholders. We decided to visit these States based in part
on guidance and suggestions from EPA program office staff. These States were
selected using a judgmental sample, and were States EPA identified as already
implementing stewardship activities. We interviewed staff from environmental
agencies at the Federal, State, and municipal levels. We also spoke with non-
profit organizations, corporations, and industry associations who participated in
environmental stewardship activities. During our interviews with these
stakeholders, we asked them to provide a definition of environmental
stewardship, list motivators and obstacles to participating in stewardship
programs, and outline what role EPA should play in fostering or supporting
environmental stewardship. See Appendix C for a list of the stakeholders we
interviewed.
We also interviewed EPA senior management and program staff in the Office of
Chief Financial Officer (OCFO), the Office of Prevention, Pesticides and Toxic
Substances (OPPTS), and the Office of Policy, Economics and Innovation
(OPEI). During our interviews with EPA staff, we were informed that the
programs included in the Compliance and Environmental Stewardship Goal (Goal
5) of EPA's Strategic Plan were a subset of a much larger group of the Agency's
voluntary programs. To effectively evaluate the relationship between the
programs in Goal 5 and the larger set of voluntary programs, it became necessary
to expand the scope of this evaluation.
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Results In Brief
After interviewing a selected sample of stakeholders, we determined that EPA
needs to identify motivators and barriers to participation, and continue to
incorporate stakeholder feedback into planning, designing, and implementing
stewardship programs. We also determined that EPA needs to examine what role
it should play in promoting stewardship activities. We found that EPA has
created a stewardship goal that utilizes selected voluntary programs, and has
developed a plan to improve management of its entire group of voluntary
programs. However, EPA still needs to fully implement internal
recommendations to strategically plan, coordinate, and manage its voluntary
programs, and develop a process for assessing these programs to determine how
they will be integrated into the Agency's mission and its strategic goals and
objectives.
We recommend that EPA develop a statement that outlines how voluntary
programs are expected to assist EPA in achieving its overall mission and
stewardship goals. We also recommend that EPA develop criteria and guidance
for assessing how it will integrate voluntary programs into its Strategic Plan.
We noted areas where additional program evaluation needs to be conducted.
Specifically, more evaluation should be conducted to determine (1) what
motivates participation in these types of programs and what causes voluntary
environmental behavior change to occur, (2) the most efficient ways to measure
the outcomes and impacts of stewardship and voluntary programs, and (3) which
stewardship and/or voluntary programs are more effective in encouraging
voluntary behavior change and achieving environmental results.
The Agency addressed and generally agreed with our findings and
recommendations, EPA's comments to our draft report are located in Appendix
D. The Agency also provided specific comments on the draft which were
addressed as appropriate in the final report. The Agency also informed the OIG
that, under the leadership of Acting Administrator Johnson, EPA is beginning a
new effort to determine how to best encourage environmental stewardship.
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Chapter 2
EPA Should Understand Stakeholder Needs To
Effectively Plan and implement Stewardship
We asked a selected sample of stakeholders to define stewardship, list motivators
and obstacles to participating in stewardship programs, and outline key roles for
EPA to play to encourage and foster participation in environmental stewardship
activities. Though our sample did not represent all stewardship participants, our
overall results were similar to an internal assessment that EPA conducted.4 The
definitions and views of our selected stakeholders were generally broader than
EPA's, and varied based on their role in stewardship programs. To better meet
the needs of its stakeholders, EPA should identify motivators and barriers to
participation, and continue to incorporate stakeholder feedback into planning,
designing, and implementing stewardship programs. EPA also needs to examine
what roles it should play in promoting stewardship activities.
Stewardship Definitions Varied with Stakeholder Roles
We found that definitions of stewardship varied among the stakeholders we
interviewed, but that these definitions could be grouped into three general
categories based on the role of the respondent. These categories represent the
industry perspective, the non-profit perspective, and the State and local
government perspective. See Appendix C for a list of stakeholders interviewed.
The industry and industry association stakeholders we met with approached
stewardship from a manufacturing standpoint. Their definitions of stewardship
were usually correlated to product design, impact, and environmental cost. One
stakeholder referred to the importance of maintaining an economic balance,
saying that stewardship is achieving compliance without significant economic
impact on the regulated community. Another indicated that stewardship was
maximizing returns for the minimum expense of resources. An industry
representative said that stewardship was a partnership between his company and
their supply base to improve the products that come in as raw materials. He
indicated that these products were utilized throughout the life of the production
process, and that his company uses "sustainable cost-benefit perspectives" to
select products that have overall environmental and monetary savings. For
Regarding EPA's 2003-2004 Innovation Action Council (IAC) inventory and assessment of voluntary
program management, as discussed in Chapter 3.
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example, he is generally willing to purchase a product that is initially more
expensive, but saves more energy throughout its life-span.
Generally, the non-profit organizations we interviewed believed that stewardship
represented a concept, or guiding principle, by which to achieve environmental
results. Their definitions incorporated environmental health, economic
prosperity, and social stability as factors to consider when implementing
programs and creating consumer products. One stakeholder referred to the phrase
"quality of life" to describe environmental stewardship. As an example, she said
effective public transportation services can reduce traffic gridlock, clean the air,
and provide other benefits to communities. Another referred to stewardship
participation as the desire to "do the right thing." One interviewee believed that
environmentally responsible behavior occurred at two levels: (1) shaping public
policy by requiring results and measuring resource impacts, and (2) making
personal decisions that were responsible to the environment.
State and local government officials mentioned many of the same concepts as
their stakeholders when defining stewardship. These included taking a proactive
versus reactive approach to environmental issues, and looking at outputs and
environmental results for effectiveness of programs. They also viewed personal
actions and behaviors, social responsibility, land stewardship, and caring for
future generations as important components of stewardship. Others we
interviewed defined stewardship in relation to sustainability, saying that
stewardship was a way to get to sustainability.5
Stakeholders in industry, non-profit, and government often used three similar
categories to define attitudes and behaviors of the regulated community: leaders
(early adopters), followers, and laggards. They characterized environmental
leaders, or early adopters, as companies that readily adopt new ideas and
behaviors or voluntarily go beyond compliance. Followers were described as
those who take a 'wait and see' approach, generally complying with the law or
meeting minimum standards, but going no further. Laggards were described as
the group that usually need enforcement and compliance services to bring them
into compliance with regulator)' requirements. Interviewees felt that
environmental stewardship behaviors are those that are usually chosen by the
leaders.
EPA personnel we interviewed had similar views and definitions as the State and
local government representatives. They addressed the importance of land
stewardship, and the ownership of environmental performance. They also
Stakeholders frequently mentioned the term "sustainahility" when defining stewardship. Sustainability was
generally described as making decisions that balanced economic profitability, social equity, and environmental
protection. Sustainability was viewed as a broader, more encompassing idea. However they believed that
environmental stewardship behavior served as a core component of the larger concept of sustainability.
10
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referred to the phrase of "doing the right thing" as a reason for engaging in
stewardship activities.
Selected Stakeholders Outlined Motivators and Obstacles
to Participating in Stewardship Activities
Stewardship program participants that we met with undertook stewardship
activities for reasons ranging from cost savings to personal ethics. We asked
these participants to discuss why they chose to adopt some environmental
stewardship practices (motivators) and outline what issues continued to limit their
participation (obstacles).
The selected industry representatives explained that several factors influence their
decisions to participate in stewardship activities. These include whether:
consumers, clients, and investors that hold a substantial market share in
the company require socially responsible behavior;
leaders in their field are also implementing stewardship programs,
adopting a particular technology or best practice, or to simply "keep up"
with their competitors;
cost savings serve as an incentive for participating; and
the company has a champion and a supportive corporate management
culture to encourage participating in the programs.
For the non-profit organizations that we interviewed, recognition and financial
assistance were common motivators. Specifically, the motivators for this group
and the industries that they work with are:
grants and financial assistance,
recognition they received from both government and the public,
choosing to "do the right thing for the right reasons," or
as a direct response to environmental strains upon their community or a
local ecosystem.
State and local governments typically operate stewardship programs in
partnership with EPA headquarters or Regional offices to encourage industry and
non-profits to participate. They indicated that these stewardship program
participants are usually motivated by
grants,
recognition and rewards, and
a strong organizational leadership that wants to improve environmental
results.
11
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The selected stakeholders in each category said that obstacles deterred them from
getting involved in stewardship efforts. These included:
negative financial effects, or increased costs for participation;
fear that if a company was able to reduce pollution beyond regulatory
requirements, then the State or EPA would make regulations more
stringent, and,
lack of flexibility, or a "top-down" ethic that prevents implementing new
practices.
Table 2.1 below summarizes motivators and obstacles identified by the
stakeholders that we interviewed:
Table 2.1: Motivators and Obstacles to Stewardship Participation Cited by
Selected Stakeholders Interviewed by the OIG
Motivators
Avoiding Negative Publicity
Cost Savings
Keeping up with Leaders
Consumer Demands
Grants
Recognition and/or Rewards
Strong Organizational Leadership
Avoiding Legal Threats
"Doing the Right Thing"
Barriers
Financial Impacts
Voluntary Standards Become
Regulatory Requirements
Lack of Program Flexibility
industry
*
/
/
_^
J
*
/
' :;fodUStty:;-;::-:::-:;:
/
/
Non-Profit
/
/
/
/
/
/
/
/
; Nonprofit
/
/
State and
loca!
Government
;
/
/
/
/
State and
Local
Government
/
12
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1.
Selected Stakeholders Outlined Five Stewardship Roles for EPA
Stakeholders we spoke with saw a variety of roles for EPA to play in continuing
to promote and foster stewardship. Many of them are similar to the roles EPA
described for itself in staff interviews. The following is a list of the five major
roles most frequently suggested by interviewees (not in order of priority):
Be a Model for Stewardship Behavior: EPA should use its own policies
and practices to model environmental stewardship for others, including
"leading by example," modeling stewardship behavior, internally
implementing environmental purchasing and environmental management
systems (EMS), and rewarding employees who think creatively. One
interviewee suggested that EPA promote green government operations, as
well as green purchasing, because the Agency has tremendous purchasing
power.
Provide Technical Expertise to Stewardship Participants: EPA can
provide technical assistance, help create measures, and develop
appropriate regulations and procedures. EPA can also develop
self-assessment tools that potential participants can use to determine their
environmental impacts before a project begins, so they can see how they
might apply a stewardship approach. One stakeholder suggested that EPA
can provide guidance by setting standards for green design and instituting
labeling requirements. Another stated that design standards could ensure
the producer's responsibility for the entire life span of a product.
Offer Rewards and Incentives to Participate in Stewardship Activities:
EPA can offer rewards and recognition for participation in stewardship
programs. The Agency can encourage creative problem-solving by
promoting creativity within the regulated community, and offering
incentives and developing policies that encourage participation in
stewardship. These incentives could include monetary rewards for
developing new stewardship techniques, public recognition, regulatory
flexibility, allowing for longer times between inspections, or simplifying
permitting processes. One interviewee said that EPA could create a
challenge to companies and offer a $500,000 reward and ceremony for
meeting the challenge. An EPA employee added that when the Agency
works with and identifies champions of a program, it demonstrates that
there can be "respectful" partnerships between EPA and the regulated
community.
13
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4. Identify Leaders To Serve as Stewardship Champions: EPA should
use environmental leaders to encourage competition and provide direction.
These activities could involve cataloguing the behaviors of an effective
company and fostering those behaviors in others. EPA Regional staff also
agreed that having an advocate or champion can really strengthen the
stewardship message.
5. Focus on Stewardship Outcomes and Develop Measurement Processes:
EPA should focus on developing techniques for measuring results, and
should focus stewardship efforts on identifying measures that verified
achievement of specific outcomes. Some suggestions for improved
performance measurement were to:
a. Start with a system or program that has been effective, and
replicate a national program to that standard.
b. Identify barriers through conversations with stakeholders, before
implementing a program.
c. Conduct environmental evaluations of products, so that consumers
can make informed choices based on the environmental costs and
benefits of the product.
d. Improve EPA management of stewardship programs, including
better integration of stewardship activities, and creating public
policy to encourage more involvement.
In addition to the stewardship roles outlined above, many of the stakeholders we
interviewed mentioned the need for EPA to maintain a strong regulatory and
enforcement presence. They believed that EPA needed to demonstrate its ability
to encourage participation in voluntary programs, while continuing to be a
credible deterrent for potential violators. However, some of the selected industry
groups cautioned that EPA needs to be careful when addressing regulatory issues
with stewardship program participants. These stakeholders said they would be
less interested in continuing to participate if EPA attempted to use their
voluntarily reduced pollution levels to set new regulatory thresholds.
Conclusion
The stakeholders we interviewed believe benefits exist to implementing
environmental stewardship programs, but obstacles continue to prevent some
industries and organizations from fully participating in these types of activities.
These stakeholders outlined roles that EPA should play in fostering and
facilitating stewardship, and provided definitions broader in scope and more
diverse than that of EPA. EPA should continue to engage in stakeholder input
and feedback processes to fully understand the diversity of participant definitions,
14
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motivations, and obstacles, and continue to refine the roles EPA is expected to
play in fostering stewardship behavior. Without addressing the needs of
stakeholders, the Agency may not be able to effectively plan, design, or
implement stewardship programs that encourage the highest level of participation.
15
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Chapter 3
EPA Has improved Voluntary Program
Management, But Additional Work Needed
EPA has created a strategic goal that utilizes stewardship programs to achieve
environmental outcomes and offer ways for participants to move above and
beyond compliance. The Agency has also developed a plan to improve managing
voluntary programs through better coordination, increased stakeholder
interaction, and developing measurement processes. While EPA is working to
improve its approach to stewardship and voluntary programs, issues still need to
be addressed. The Agency has yet to fully implement internal recommendations
to strategically plan, coordinate, and manage its voluntary programs, or
implement a process for incorporating these programs into the Agency's mission
and its strategic goals and objectives.
2003 Strategic Plan Revision Elevates Voluntary Programs to a Strategic Level
In its FY 2003-2008 Strategic Plan, EPA designated Strategic Goal 5 as
"Compliance and Environmental Stewardship." EPA selected a number of
voluntary programs to address stewardship, and organized those programs under
Goal 5.6 Agency planning staff said that including these programs into Goal 5
marked the first time that EPA had identified voluntary programs that could
achieve Agency-level strategic targets. However, EPA officials said that the
Agency had not developed a "grand plan" for defining or implementing
environmental stewardship, so no formal process was in place for including some
programs in Goal 5 while excluding others. The strategic planning staff had
requested program managers to integrate activities to address strategic targets, but
coordinating this planning process between the impacted program offices proved
difficult. One of the stewardship program managers explained that EPA "didn't
spend a year debating definitions of what was or wasn't stewardship", but went
out and started working to encourage stakeholders to participate in these
programs.
EPA planning staff said upper managers made the final decision regarding which
programs would be included in Goal 5 and then asked the program offices to
make their programs fit under the revised goal structure. Program staff also told
us that the change in the strategic architecture had not significantly affected EPA's
In its 2003 Strategic Plan revision, EPA reduced its number of Strategic Goals from 10 to 5.
16
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organizational or management processes. While we recognize that including
these programs was the first time the Agency recognized the importance of
voluntary programs at the strategic target level, good management principles
dictate that a more structured process could lead to increased customer
participation, more effective program implementation, and improved program
results. The Agency needs to determine whether its Goal 5 management
strategies and planning process will lead to these results. A recent assessment of
EPA's voluntary programs management addressed and remedied some of these
concerns.
EPA Working To Improve Voluntary Program Management
In 2003-2004, EPA's Innovation Action Council (IAC) assessed EPA's voluntary
program management processes. The IAC concluded that EPA needed to address
customer needs and improve stakeholder feedback and communication, as well as
improve program coordination to prevent initiative fatigue among participants.
The I AC also determined that enormous variation occurred among EPA's
voluntary programs, along with a lack of consensus from Agency management
regarding these programs' roles and value in EPA's mission. As a result, the IAC
recommended that EPA improve coordination among programs offices, improve
measurement processes, and improve strategic management by incorporating
these programs into the Agency's mission, goals, and objectives.
During its assessment, the IAC conducted a number of informal discussions to
obtain stakeholder opinions in four key areas: (1) value of incentives, (2)
interactions with EPA, (3) how well stakeholders recognized the different
"brands" of Agency voluntary programs, and (4) strategic issues. Participants
included 18 different industrial or professional service companies, 14 EPA
headquarters and Regional offices; five industry associations, and four States.
The IAC also assessed voluntary program design and effectiveness, program
coordination, and measurement. Similar to stakeholders interviewed by the OIG,
the stakeholders that participated in the IAC assessment felt that voluntary
programs were a good way to do business. The IAC stakeholder participants
stated that voluntary programs can:
serve as a showcase for good corporate citizenship,
foster innovations in technology,
create a better communication pathway to EPA,
provide useful technical information, foster networking, and,
contribute to advances in environmental research.
The stakeholders the IAC interviewed also believed that EPA should implement
its voluntary programs more strategically. They indicated that too many
17
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voluntary programs provide soft benefits, are uncoordinated and time intensive, or
are composed of pilots which do not lead to policy changes. These stakeholders
wanted smoother, simpler interactions with fewer overall transactions or
duplication of effort. They wanted to see greater consistency in reporting and
participation requirements, which would enhance the value of"beyond-
compliance" actions. They also indicated that real cost and effort is required to
participate in voluntary programs, so they needed to receive tangible benefits to
justify their participation.
During its voluntary program assessment, EPA also met with several researchers
to get outside perspectives on its voluntary programs. These researchers stated
that if programs are designed and conducted in different ways, the public can
often become confused as to the value or importance of these numerous programs.
The researchers indicated that EPA may not be effectively "signaling" the overall
importance of voluntary programs to the public. EPA concluded that it needed to
overcome challenges regarding their approach to program integration. Often,
multiple programs were pursuing the same customers. This situation created
confusion and "initiative fatigue" for participants, and potentially diluted the
value of Agency recognition and other incentives.
To better manage its voluntary programs, the IAC recommended that EPA
should:
Improve coordination between its voluntary programs, e.g., improve
support services, share information on best practices, and help external
users to access, understand, and participate in EPA voluntary programs.
Enhance the accountability of voluntary programs, e.g., develop better
measures, improve brand management and program design, and develop
more consistent program guidelines.
Use strategic management processes to assure that voluntary programs
target priority environmental needs, and are designed to be analytically
sound, cost effective, and valuable to external participants, e.g.,
incorporating voluntary programs in the Agency's strategic mission, goals,
and objectives.
Many of these recommendations are consistent with good management
principles.7 We believe EPA needs to improve coordination, enhance
accountability, and outline a mission and expectations for how voluntary
programs will assist the Agency in achieving its overall goals and objectives.
Effective leadership and strategic management criteria outlined in the Office of Inspector General's
Assessing Organizational Systems OIG Directive OA-5, December 30, 2004.
18
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To begin implementing ihese recommendations, the Deputy Administrator issued
an April 21,2004, memorandum outlining changes for managing EPA voluntary
programs. This memo included developing a support network for voluntary
program managers, a set of guidelines for program design, brand management,
and measurement, and an Agency-wide notification process for new voluntary
programs. The Office of Policy, Economics, and Innovation was designated as
the lead office for managing this new Agency initiative.
The Deputy Administrator continued to advance this process by issuing a June 28,
2004, Charter for Coordinating and Managing EPA's Voluntary Programs. This
charter formalized developing the voluntary program network, created a voluntary
programs workgroup (composed of senior staff from each Program Office and
Region), and identified the IAC as the body responsible for the oversight of
voluntary program management. This charter also required that annual reports be
issued to the Deputy Administrator so that she/he could determine if any new
policy directions or additional management improvements were needed. The
actions included in this Charter demonstrate initial implementation of the lAC's
recommended management improvements, but EPA has yet to adopt the lAC's
recommendation to incorporate voluntary programs into the Agency's strategic
planning process.
Conclusion
EPA's decision to include stewardship programs into its 2003-2008 Strategic Plan
was an important first step towards acknowledging the importance of voluntary
programs to the Agency's mission, goals, and objectives. The Agency's internal
assessment of managing these programs created efforts to improve program
coordination, gather more stakeholder feedback, and develop program
measurements. The Deputy Administrator began implementing the recommended
changes through rne developing a policy memorandum and a voluntary program
charter. However, EPA still needs to implement the lAC's recommendations to
strategically plan, coordinate, and manage its entire voluntary program effort, and
to develop a process for incorporating voluntary programs into the Agency's
mission and its strategic goals and objectives.
19
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Recommendations
In order to continue improving the management and implementation of EPA's
stewardship and voluntary programs, we recommend that the Acting Assistant
Administrator for Prevention, Pesticides and Toxic Substances and the Acting
Associate Administrator for Policy, Economics and Innovation, address the
following;
3-1 Develop a statement that outlines how voluntary programs are expected to
assist EPA in achieving its overall mission and its stewardship goals and
objectives.
3-2 Develop criteria, guidance, and an action plan for assessing how voluntary
programs will be included in the next revision of the Agency's Strategic
Plan.8
As required by the Government Performance and Results Act (GPRA), each Federal agency must revise its
Strategic Plan every 3 years, beginning in 2000. Therefore, EPA's next strategic plan revision is required to
be conducted in 2006.
20
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10
Chapter 4
Further Evaluation Needed To Effectively Manage
Stewardship and Voluntary Activities
By 2008, EPA expects that its stewardship programs will reduce billions of
pounds of pollution and conserve billions of British Thermal Units (BTUs) of
energy.9 These programs are also expected to help participants save millions of
gallons of water and reduce their operating expenditures by nearly $400 million.
To effectively plan and implement stewardship programs, EPA must incorporate
customer-driven goals into well-defined strategies, and understand how
effectively these programs achieve environmental results.
EPA should also determine how to measure the outcomes of stewardship
activities so it is able to verify that it is achieving its goals. EPA needs to show
that the programs it selects to meet its goal are more effective in achieving
environmental results than other programs it runs. As we discussed in Chapter 2,
the selected stakeholders we interviewed believed that EPA should identify and
strengthen the motivators that encourage people to participate in stewardship
activities, and reduce obstacles to participation. EPA will not be able to achieve
environmental outcomes if it is unable to obtain adequate participation in
environmental stewardship activities. To address this issue, EPA should find out
how to measure the outputs that encourage these behaviors.
EPA also needs to correctly measure the environmental benefits of these
activities. The Agency can begin to address these needs by working to quantify
how voluntary behavior change programs can assist EPA improving
environmental and human health protection. The Agency recognizes that
measuring environmental outcomes from voluntary programs includes its own set
of challenges. Currently, only some voluntary programs require participants to
commit to reporting outcomes from their activities. EPA expects these
participants to provide annual reports with performance information, but each
year some do not turn in reports, leaving the Agency without adequate data to
assess the efficacy of the program.
9 EPA's 2003-2008 Strategic Plan, page 115.
10 Ibid.
21
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The participants have complained that tracking and reporting is a burden to their
companies. This sentiment is a common concern, and leaves EPA with the
following measurement challenges:
Participants must voluntarily agree to supply performance information.
Program implementation differs from participant to participant, so data
collection may not be consistent among participants.
Results vary by participant, making quantifying overall results a
challenge.
EPA cannot yet track some environmental stewardship program outcomes,
though it expects to develop these processes by 2008.
If EPA is unable to overcome these measurement challenges, it will not be able to
determine program outcomes. Further evaluations of EPA's stewardship and
voluntary programs are necessary to assist the Agency in tracking and measuring
these efforts. As a result, the OIG plans to continue evaluating EPA's
stewardship and voluntary programs to determine:
1. What motivates participation in stewardship and voluntary programs, and
what causes voluntary environmental behavior change to occur.
2. The most efficient way to measure the outcomes and impacts of voluntary
programs.
3. Which EPA stewardship and/or voluntary programs are more effective in
encouraging voluntary behavior change and achieving environmental
results.
22
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Appendix A
Program Information for Selected Voluntary Programs
Included in Strategic Goal 5
< FFopgit iwBR*$
Design for the
Environment
Green Chemistry
Green Engineering
Performance Track
Sector Strategies
National Partnership
for Environmental
Priorities
/'' fr$tyRm&Q& J'-
To facilitate the identification,
adoption, and innovation of
clean products, processes,
technologies, and
management systems.
To promote environmentally
benign design of chemical
products and processes.
To design, commercialize, and
use processes and products,
which are feasible and
economical while minimizing
1) generating pollution at the
source and 2) risking human
health and the environment.
To recognize and encourage
top environmental
performance among private
and public facilities, which go
beyond compliance with
regulatory requirements to
achieve environmental
excellence.
To work with priority industry
and service sectors to promote
sector-wide improvement in
environmental performance,
with greater efficiency of
program operations and
reduce regulatory burden.
To encourage, through
recognition, networking, and
case example distribution,
minimizing hazardous and
industrial wastes, particularly
those waste streams
containing one or more of the
30 priority chemicals.
' Pfifrilftimfiiiiift
Partnering with 8 industry sectors.
Include industry, academia,
government, trade organizations,
scientific societies, national labs, and
research centers.
Primary participants are from
academia.
350 industry and non-industry
facilities.
Trade associations, State agencies,
and others. The 12 participating
sectors are Agribusiness, Cement
Manufacturing, Colleges and
Universities, Construction, Forest
Products, Iron and Steel
Manufacturing, Metal Foundries and
Die Casting, Metal Finishing, Paints
and Coatings, Ports, Shipbuilding
and Ship Repair, and
Specialty-Batch Chemical
Manufacturing.
Fourteen members are in the
partnership program including
Dupont. U.S. Steel, and Toyota.
Membership is by individual plant
within the company as specified in
the company's waste minimization
goals application.
yfeorefOpittia*
12 Years
12 Years
5 Years
4 Years
10 Years
1 Year
Source: Information provided by US EPA, Office of Policy, Economics and Innovation
23
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Appendix B
Examples of EPA Voluntary Programs
h- -
Volurrtw Programs Operated by EPA Headmiarters Offices }
Office Air and Radiation (OAR)
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
OAR
Office
AgStar
Best Workplaces for Commuters
Clean School Bus USA
Climate Leaders
Coalbed Methane Outreach Program (CMOP)
Combined Heat and Power Partnership
Diesel Retrofit Program
Energy Star Energy Management
Energy_Star Product Certification
Green Power Partnership
HFC 23 Emission Reduction Program
IAQ "Tools for Schools"
Landfill Methane Outreach Program
Mobile Air Conditioning Climate Protection
Natural Gas Star
PFC Emission Reduction Partnerships
SF-6 Emission Reduction Partnership for Electric Power Systems
SF-6 Emission Reduction Partnership for the Magnesium Industry
Smart Way Transport
The SunWise School Program
Voluntary Aluminum Industrial Partnership
Prevention, Pesticides and Toxic Substances (OPPTS)
:.:-.:.'., .; - : OPPTS1 : :.x;.:. -.'.
.-'I--'--:::'-'-: .<&&&: -iSx:.-':'-. .:
::-':':.;;:'.-:.' : : OPPTS*:'.-'.'-';:-::::'; :-::
OPPTS
OPPTS
OPPTS
OPPTS
OPPTS
OPPTS
OPPTS
OPPTS
Office
pesfcn forfh*:Enyironrnent :,:::.:: : . . . :.vivo:.:, . . .
OojenttrteftWty;-::-:.'-' : :..::-::.;;;-?:.:..-.. :-;--.- * -:.-.-.-.: :: :
Green Enflbeeflrig . . :-. .: -:.::.-::.-.::.-....., /..'X;/:^': .-:;:.-'.,:.-'.... :-:.L
Green Suppliers Network
High Production Volume Challenge
Hospitals for a Healthy Environment
Pesticide Environmental Stewardship Program
Reduced Risk for Conventional Pesticides
Suppliers Partnership
Sustainable Futures
Voluntary Children's Chemical Evaluation Program
of Policy, Economics and Innovation (OPEI)
OPEI
OPE!*
OP£t*
Office
National Award for Smart Growth Achievement
PerfbrtnarK* Track
Sector Strategies
of Research and Development (ORD)
ORD
I Environmental Technology Verification Program
24
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Office of Solid Waste and Emergency Response (OSWER)
OSWER
OSWER
OSWER
OSWER* : : :
OSWER
OSWER
Off ice of Water (OW)
OW
OW
OW
OW
OW
OW
OW
OW
₯ltktic*t«*SlxBxampf*s-:- :' ': ':'.
Source: December 2003 Agency-wide voluntary program survey, US EPA, Office of Policy, Economics and Innovation
Region 1 - Regional Programs
Region 1
Clean Marine Engine Initiative
Region 1
Clean New England Beach Initiative
Region 1
College and University Integrated Strategy
Region 1
Corporate Sponsorship program for Metal Finishes
Region 1
Corporate Wetlands Restoration Partnership (CWRP)
Region 1
Dept. of Public Works Integrated Strategy
Region 1
Urban Environmental Program
[Region 2 - Regional Programs
Region 2
[Lead in Drinking Water in Schools and Non-Residential Buildings, Children's initiative.
Region 2
I New York Harbor Private Ferry Emissions Reductions Program
[Region 3 - Regional Programs
Region 3
Businesses for the Bay (B4B)
Region 3
Green Communities
Region 3
Lead Free Drinking Water in Schools and Day Care
[Region 5 - Regional Programs
Region 5
Binational Toxics Strategy
Region 5
DOD/State/EPA P2 Partnerships
Region 5
Greater Chicago Pollution Prevention Alliance
Region 5
Natural Landscaping Workgroup
Region 5
PCB Phasedown Programs
Region 5
Voluntary Chlor-alkali Industry Mercury Program
[Region 6 - Regional Programs
Region 6
Gulf of Mexico Program
Region 6
Healthy Environments and Living Places for Kids (HELP for Kids)
Region 6
Integrated Pest Management in Schools with Texas
[Region 9 - Regional Programs
Region 9
R9 Heathy Schools Initiative
Region 9
Voluntary Mercury Air Emission Reduction Program with Nevada Gold Mines
uroe: December 2003 Agency-wide voluntary program survey, US EPA, Office of Policy. Economics and Innovation
25
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Appendix C
List of Selected Stakeholders We Interviewed
Organization
League of Women Voters, Texas Pollution Prevention Advisory Committee
Sierra Club Lone Star Chapter
International City/County Management Association (ICMA)
National Association of Counties (NACo)
Northeast Waste Management Officials Association (NEWMOA)
Alliance for Environmental Innovation
San Francisco State University Business School
California Council for Economic and Environmental Balance
Lodi-Woodbridge Winegrape Commission
Sustainable Conservation
California Environmental Dialogue
Texas Instruments Corporation, Texas Pollution Prevention Advisory Committee
Fort Worth-Dallas Small Business Advisory Committee
Texas Association of Business
California Association of Winegrape Growers
Hewlett Packard Corporation
Small Business and Environmental Assistance Office, Texas Commission on
Environmental Quality
Pollution Prevention and EMS Section, Texas Commission on Environmental Quality
Small Business/Local Government Assistance Program, Texas Commission on
Environmental Quality
Clean Texas Program, Texas Commission on Environmental Quality
Border Programs Office, Texas Commission on Environmental Quality
Massachusetts Department of Environmental Protection (MADEP)
Massachusetts Executive Office of Environmental Affairs
Office of Susta inability Programs, California EPA
Department of Pesticide Regulation, California EPA
California EMS Implementation Group
City of San Francisco Environment Office
Organization Type
Non-Profit / Community
Non-profit / Community
Non-Profit / Community
Non-Proffi / Community
Non-Profit / Community
Non-Profit / Community
Non-Profit / Community
Non-Profit / Community
Non-Profit / Community
Non-Profit / Community
Non-Profit / Community
Industry
Industry Association
Industry Association
Industry Association
Industry
State/Local Government
State/Local Government
State/Local Government
State/Local Government
State/Local Government
State/Local Government
State/Local Government
State/Local Government
State/Local Government
State/Local Government
State/Local Government
26
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US EPA, Office of Prevention, Pesticides and Toxic Substances
US EPA, Office of the Chief Financial Officer
US EPA, Office of Policy, Economics, and Innovation
US EPA, Region 6, Dallas, Texas.
US EPA, Office of Tribes
US EPA, Region 1 , Boston, Massachusetts
US EPA, Region 9, San Francisco, California
vtf:*:-fr*:W:-:-:w:':-x-:-x*:-:*:^
Federal Government
Federal Government
Federal Government
Federal Government
Federal Government
Federal Government
Federal Government
27
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Appendix D
Agency Comments to the Draft Report and OIG Evaluation
MEMORANDUM
SUBJECT: Review of Draft Evaluation Report: "Ongoing Management Improvements and
Further Evaluation Vital to EPA Stewardship and Voluntary Programs,"
(Assignment No. 2003-0001451)
FROM: Stephanie Daigle /s/
Acting Associate Administrator for Policy, Economics and Innovation
TO: Kwai Chan
Assistant Inspector General for Program Evaluation
Thank you for the opportunity to review your draft report, "Ongoing Management
Improvements and Further Evaluation Vital to EPA Stewardship and Voluntary Programs,"
(Assignment No. 2003-0001451). I am responding on behalf of the agency and specifically for
the three parties to whom you addressed your transmittal memo of January 21,2005: Deputy
(now Acting) Administrator Stephen Johnson, Acting Assistant Administrator Susan Hazen and
(then) Associate Administrator Jessica Furey.
In your report you reviewed some of EPA's recent efforts to encourage environmental
stewardship, examining our goals and our management of voluntary programs, as well as some
state efforts. You had several general recommendations for how EPA might improve in this area.
We understand that this report is the first of what might be several reports on the topic of
environmental stewardship, as you continue your work in the months ahead.
We are pleased to say that we generally agree with the findings and recommendations in
this draft report. We think that you have picked a topic that is timely and that your evaluation
can help us as we develop new approaches for carrying out EPA's mission. We are also pleased
that you have included some representative state efforts in your evaluation. We have only a
modest number of specific comments on aspects of your report, and we have attached them to
this memo.
Of particular interest to you in this regard and as we have discussed with your staff, we
are currently beginning a new effort at the direction of Acting Administrator Johnson to
determine how we can best encourage environmental stewardship. We accept your report as
helpful input to this effort. Our Innovation Action Council (IAC) will be discussing this topic at
28
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its February 23-24 meeting. We have invited your staff to attend this meeting and look forward
to such comments on your report as your IAC representative (Rick Linthurst) would like to
make.
To allow this discussion of your report to take place, we are sending you this expedited
response today in order to accept your staffs offer to finalize the report before February 23. We
trust that our favorable response and the limited number of specific comments will make this
possible.
More importantly, we look forward to working cooperatively with you and your staff as
we both endeavor to improve how the agency encourages the best environmental stewardship
possible. Please do not hesitate to contact me, the other addressees of your memo and/or our
respective staffs if we can help you in this process.
29
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Appendix E
Distribution
EPA Headquarters
Office of the Administrator
Agency Followup Official
Agency Followup Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Acting Assistant Administrator for Prevention, Pesticides and Toxic Substances
Acting Associate Administrator for Policy, Economics, and Innovation
Audit Follow-up Coordinator, Prevention, Pesticides and Toxic Substances
Audit Follow-up Coordinator, Office of Policy, Economics, and Innovation
Office of Inspector General
Inspector General
Assistant Inspector General for Program Evaluation
Assistant Inspector General for Audit
Assistant Inspector General for Human Capital
Assistant Inspector General for Planning, Analysis, and Results
Assistant Inspector General for Congressional and Public Liaison
Counsel
Science Advisor
Product Line Directors
Editor
Human Resource-Center Managers
30
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