Ill Aberdeen Road
Matawan, NJ 07747
January 31, 2003
Ms. Linda Combs
Chief Financial Officer
U. S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC20460
Dear Ms. Combs:
On behalf of the National Advisory Council for Environmental Policy and Technology
(NACEPT), I am pleased to forward comments and recommendations regarding the Agency's draft 2003-
2008 Strategic Plan Architecture. The recommendations were developed by the NACEPT Compliance
Assistance Advisory Committee and fully endorsed by the Council.
NACEPT appreciates both the importance of and the complexity in developing a Strategic Plan
for EPA. Key highlights of the recommendations are presented below, with more detailed comments
discussed in the enclosure. Our comments offer advice on ways the Agency can integrate compliance
assistance into its Strategic Plan and to work in partnership with the regulated community and the public,
in pursuit of the Agency's goals. Three key recommendations for your consideration are outlined below:
Q Resources for compliance assistance might be better allocated if assistance is more fully
integrated into each goal and objective in the Strategic Plan Architecture, and in related resource
allocations. The resources required for achieving EPA's goals are not yet identified, available
resources almost certainly will not be sufficient to fully achieve the goals, and the Strategic Plan
Architecture may not fully support the most efficient use of resources.
a EPA must rely upon and leverage the resources found in partnerships with others at the federal,
state, tribal and local levels, to achieve its goals in the most effective and efficient manner. EPA
must always remain mindful of the degree to which achievement of its goals is dependent upon
the action of others. The role of all stakeholder communities is particularly important in a time of
limited resources.
Q As EPA's Strategic Plan fully matures, the Agency will continue to face new challenges in
protecting our nation's environment. EPA must remain both vigilant and flexible; ever scanning
the horizon to identify emerging environmental challenges, and swiftly committing itself to
address the challenges it identifies.
NACEPT appreciates this opportunity to offer these recommendations and looks forward to
assisting the Agency as the Strategic Plan evolves.
Enclosure
Sincerely,
Dorothy Bowers, Chair
National Advisory Council for
Environmental Policy and Technology
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NATIONAL ADVISORY COUNCIL
FOR ENVIRONMENTAL POLICY AND TECHNOLOGY
Comments Regarding
U.S. Environmental Protection Agency's
Draft 2003 Strategic Architecture
January 31, 2003
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EXECUTIVE SUMMARY
The National Advisory Council for Environmental Policy and Technology
(NACEPT) appreciates the opportunity to provide comments on EPA's draft
Strategic Architecture. Comments are organized with a "Background and
Overview" followed by comments that address each of the goals. The comments
are focused on recommendations for compliance assistance (CA) as it relates to
EPA's Strategic Architecture, as well as comments of how the Architecture may
impact or limit the ability to use CA in order to achieve its goals and objectives
most effectively. The Compliance Assistance Advisory Committee (CAAC), a
subcommittee under the auspices of NACEPT, prepared these comments in the
belief that they can also assist EPA in developing the more detailed Strategic
Plan. The comments for Goal 5 are the most extensive since CA is not
addressed in most of the other Goals and Objectives. As general comments for
the entire Strategic Architecture the CAAC recommends the following:
• Compliance assistance should be an integral part of the EPA's
management strategy and part and parcel to all of the agency's future
efforts set forth in its Strategic Plan. More resources should be dedicated
to compliance assistance, but not at the expense of enforcement; the best
way to do this in the face of resource constraints is for EPA to become
more of a wholesaler of environmental information, empowering and
leveraging others (states, tribes local governments, and other community-
based organizations, etc) to implement compliance assistance programs.
• The Strategic Architecture appears to be based upon existing programs
and offices and on EPA's budgeting process. This structure is not
conducive to a comprehensive and clear vision of where EPA wants to be
in 5 years, or for strategically planning to achieve the desired outcomes.
As currently constructed, the Architecture perpetuates EPA's structural
barriers to integrated and multi-media approaches and continues a stove
piped perspective of how environmental protection should be achieved.
EPA should address how they will provide necessary opportunities to
develop multi-media strategies that utilize the balanced and
complementary interplay of enforcement, monitoring, incentives,
innovations, and compliance assistance to meet their goals and objectives
and how their resource allocations will support these approaches.
• It is imperative that EPA recognize the diversity of sources that can
contribute to stress on the environment, and the importance of information
and assistance to effect changes in their environmental performance. In
order to achieve its goals and objectives, EPA will need to address not
only traditional point sources, but also non-point, sources of pollution; not
only must large oil refineries and waste management facilities be
engaged, but smaller area sources and waste generators, facilities with
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stormwater runoff, other businesses and even communities and
individuals must also be part of the approach.
• EPA should work with other federal, state, and, local agencies to ensure
that compliance assistance is provided for their regulations when
compliance with these regulations impacts EPA's ability to achieve its
environmental goals and objectives. For instance, state and local
environmental regulations and Department of Transportation hazardous
materials requirements.
• For each of the five goals, EPA needs to identify the problems, issues, or
challenges related to that specific goal in order to place them in
perspective; Why is it a goal?; What is needed to address the goal?; and
How does the Agency provide the solution? Each goal and the
corresponding objectives should be correlated to a range of estimated
costs and a realistic schedule for achievement with a process for ranking
the importance of the issue so that priority spending achieves the greatest
environmental result.
• The Strategic Architecture should explain what financial resources are
needed to achieve these goals and where the financial resources will
derive. The identification of resources is critically important due to the
country's current economic climate and the rapidly diminishing resources
for domestic spending in the Federal budget. Without identifying the
necessary financial resources and where these resources will come from,
EPA's Strategic Plan will not be successful.
• NACEPT has continued to urge EPA to focus on the NACEPT report The
Environmental Future: Emerging Challenges and Opportunities for EPA.
The Architecture should incorporate such trends, for example, the
emerging opportunity to reduce mobile source air pollution through the
development of a clean automobile engine over the next few years with
cleaner fuels being used during the transition to non-polluting engines.
• The lack of specificity in the proposed strategic targets, and "to be
determined" indices of performance, hindered our ability to comment on
EPA's proposed strategic targets.
BACKGROUND AND OVERVIEW
In July 1999, EPA's Office of the Administrator released the report of the EPA
Innovations Task Force, Aiming for Excellence: Actions to Encourage
Stewardship and Accelerate Environmental Progress. This report marked the
culmination of a series of dialogues with affected stakeholders - representatives
from business and communities, state and local government, tribal
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representatives, and regional and headquarters EPA staff - to derive insights
about specific actions that could be taken "to address environmental problems
that have yet to be solved through the current system."
While the Task Force noted in the report that a wide range of comments and
suggested approaches were made in these discussions, it concluded that two
uniform themes had emerged:
• EPA needs to do more to help organizations comply with the law.
• EPA needs to encourage those who are willing and able to do more.
The Task Force further noted in the report, "We believe a system that promotes
stewardship, in addition to compliance with environmental requirements, has the
greatest potential for advancing environmental management capabilities and
solving environmental problems."
In previous recommendations to EPA1, the CAAC recommended that the
Agency's commitment to CA be reflected in all aspects of the Agency's strategic
planning, from its Mission on down, stating:
"The goals identified by each Program Office should reflect the agency's commitment to
compliance assistance. The objectives relative to each Program Office's goals should
explicitly identify the measurable outcomes that the Program Office intends to achieve
with respect to its compliance assistance activities "
The draft Strategic Plan architecture proposes a consolidation of Agency aims
into five broad goal statements - four of which are generally programmatic or
media specific. The goals architecture seems to be constructed around EPA's
existing organizational structure, which may not support more effective
approaches for environmental protection. The CAAC is concerned that the
Strategic Plan will not embody a coherent and comprehensive vision of where
the agency intends to be in five years (2008). It is concerned that the
architecture of the Plan as currently contemplated may unintentionally lock
Agency activities into a framework for accounting and resource commitment that
is unlinked to the Agency's vision. Finally, the CAAC is concerned that the Plan is
not adequately focused to build upon the findings, recommendations and body of
thought yielded from current and past endeavors such as the EPA Innovations
Task Force and the CAAC.
To be successful, EPA will need to adopt a broad, holistic approach to
environmental assistance to persuade the regulated community and the public to
improve their performance by complying with environmental regulations and
practicing environmental stewardship. Through indirect leadership activities such
1 Maximizing Compliance Assistance, National Advisory Council for Environmental
Policy and Technology, Compliance Assistance Advisory Committee, August 13, 2001
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as compliance assistance, collection and dissemination of information on
pollution prevention, and sponsorship of environmental stewardship programs,
the agency and its partners will be most successful in engaging and motivating
regulated entities and the public to plan and implement actions that support the
EPA's goals. In addition, the Agency must educate the regulated community and
the public as to the impact their actions have on the environment. Education will
enable the regulated community and the public to understand why it is important
to initiate stewardship activities, be it in the workplace or in the home.
Strategic Goals and Compliance Assistance Integration.
The EPA Draft Strategic Plan Architecture isolates compliance assistance under
Goal Five rather than placing it as a significant component under each of the
other four Agency goals. We are concerned that, with this separation, compliance
assistance will not be properly and effectively integrated into Agency
commitments and practices. The CAAC recommendations to the Administrator
have not been effectively incorporated into the Strategic Plan and this may result
in impeded integration of compliance assistance and, in turn, unintended
outcomes of traditional and less efficient and effective enforcement measures
rather than higher aims of environmental performance.
As a related matter, the CAAC is also concerned that this media-specific
orientation can impede the development of holistic, cross-media approaches,
ultimately resulting in stove piping of approaches and processes, including the
prevention of proper integration of compliance assistance into agency-wide
planning and programming.
Goals and Measures as Realistic and Achievable Aims
Unlike strategic planning for the private sector and some other public sector
entities, EPA's attainment of many of the goals, objectives and sub-objectives in
the Strategic Plan is dependent on behavioral changes within the regulated and
unregulated communities, and not just within EPA itself. EPA's Strategic Plan
architecture does not yet address the activities that EPA intends to undertake on
its own, and the activities that it must demand of the regulated and unregulated
communities, to achieve these goals, objectives and sub-objectives. Even more
importantly, the Architecture addresses neither the costs to be borne by the
regulated and unregulated communities in pursuit of EPA's goals nor the
procedure to be used in selecting the specific geographic locations to be
improved.
Resource Requirements
The attainment of the goals and objectives EPA identifies will require efficient use
of limited resources and cooperative efforts. It is not clear how EPA will allocate
resources to achieve these goals. In particular, the CAAC is concerned that
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there are not enough resources at the state and local level to work with EPA on
adequately implementing these goals. Furthermore, state and local priorities and
resource allocation issues will affect the degree to which EPA, states, localities,
and tribes can effectively collaborate on the implementation of these plans.
Measures that Promote Understanding of the Regulated Community
EPA's ability to achieve sound economic analysis, efficient regulations, sensible
enforcement and effective compliance assistance depends, to some extent, on
the abilities of its staff to understand the regulated community. EPA can take
positive steps to enhance staff understanding of the regulated community -
including both large and small entities. While the CAAC is sensitive to staffing
and resource constraints, it also believes that EPA staff who write and interpret
regulations, plan and conduct enforcement initiatives and are responsible for
compliance assistance could better accomplish Agency objectives by becoming
more familiar with industry operations and regulatory problems that confront
business - including both large and small regulated entities.
GOAL1: CLEAN AIR
The CAAC applauds EPA's effort to establish measurable goals for clean air. It
believes that the accomplishment of these goals will not be an effort undertaken
solely by EPA but rather will be addressed in partnership with a wide array of
stakeholders. These include state, local and tribal regulators, the current
regulated community, networks of compliance assistance providers, the current
unregulated community and the general public. In addition, success will entail
the use of a wide variety of tools: compliance assistance, pollution prevention,
education, communication, and stakeholder involvement.
It is essential that these elements be specifically identified and made integral
parts of the various objectives and sub-objectives. It may well be that these
issues will be addressed in the full plan but we are concerned at the lack of
reference to them in this Architecture. EPA should make a definitive statement
that pollution prevention, energy efficiency, technical and compliance assistance
and stakeholder involvement are essential elements to the achievement of the
objectives of Goal 1.
Specific sub-objectives should be drafted to indicate how the EPA will involve
these various constituencies and tools as well as how it will measure their
effectiveness. One of the most important elements in CA is developing common
understanding of the goals, rules and mechanisms of environmental regulation.
In developing the strategic objectives, then, it is important that EPA specifically
define terms and avoid ambiguity. An example is found in Objective 1: the use
of terms such as "unhealthy" and "air toxics" seems to assume agreement on
meaning across stakeholder groups. In reality, there is a divergence of opinion
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on these issues. If EPA's progress on these strategies is to be fairly measured,
there must be a less ambiguous statement of what is being measured.
GOAL 2: CLEAN AND SAFE WATER
The CAAC concurs with EPA's focusing its water goals on broad outcomes such
as access to quality water supplies and basic sanitation, increasing the
percentage of aquaculture conducted in quality environments, and increasing the
percentage of waters suitable for recreational use. We also concur with EPA that
holistically assessing watersheds can be a more effective approach to achieving
the Agency's water goals than focusing on individual point source dischargers in
isolation. We also agree that EPA's research agenda with regard to improving
water science is appropriate, and urge the Agency to pursue improving water
science as aggressively as practicable, to provide the best possible tools for
watershed management. However, the objectives and sub-objectives under this
goal do not plan for or measure CA activities related to this goal.
GOAL 3: PRESERVE AND RESTORE THE LAND
Goal 3 proposes to reduce and control risks posed by releases of harmful
substances and proposes to promote waste diversion, recycling and innovative
waste management practices. The CAAC recommends that the goal includes
promotion of compliance with materials handling and waste management
requirements in addition to the promotion of innovative practices and that the
Agency utilize CA in this promotion. Materials and waste management practices
are fundamental to release prevention, pose far less risk, and are less costly
financially and environmentally than release response and remediation. Since
pollution prevention is at the top of EPA's waste management hierarchy, pollution
prevention should be promoted first, before waste diversion and recycling. We
recommend that EPA strengthen the Goal by changing it to read, "Preserve and
restore the land by preventing, reducing and controlling risks..."
EPA's ability to preserve and restore the land is also dependent upon compliance
with the regulations of other federal, state, and local agencies that address
material handling and transport. These include: the Department of
Transportation (training, hazmat packaging and transport), OSHA, fire
department and building codes (materials handling, containment, emergency
equipment, etc.) EPA should engage these entities in partnership activities
designed to support the delivery of compliance assistance for these requirements
as part of EPA's efforts to reduce and control risks posed by releases of harmful
substances. Integration of CA and prevention approaches in this Goal to
address dangerous and harmful materials handled in our daily commerce can
significantly contribute to reduced risk from releases and improved homeland
security.
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GOAL 4: HEALTHY COMMUNITIES AND ECOSYSTEMS
We applaud the Agency's commitment to integrated and comprehensive
approaches and partnerships referenced in Goal 4. In order to succeed at this
holistic approach to environmental improvement, the Agency must ensure the
accessibility of reliable, high quality environmental information to both the
regulated and unregulated communities, including the general public. To this
end, the CAAC recommends that the Agency incorporates into its strategy the
need to improve access by the regulated and unregulated communities to
compliance assistance related information.
GOAL 5: COMPLIANCE AND ENVIRONMENTAL STEWARDSHIP
General
Goal five is an important recognition that environmental performance can be
improved not just through traditional enforcement methods, but also through
compliance assistance, innovations, partnerships, and voluntary activities. By
making compliance assistance (CA) activities that help regulated entities
understand and comply with regulations, prevent pollution, and improve
environmental performance a fundamental part of EPA's Strategic Plan, the
Agency can help minimize the need for more costly enforcement approaches.
Voluntary programs increase goodwill toward the Agency and environmental
stewardship through the fostering of win-win situations.
While the CAAC appreciates EPA's commitment to pollution prevention and
environmental stewardship, we are concerned that EPA may not consider CA to
be a fundamental strategy in achieving Goals 1 through 4. Surely the ultimate
goal of providing CA is protection of the nation's health and air, water and land
resources. Therefore, it is recommended that CA activities be integrated into the
objectives identified in Goals 1 through 4 and that EPA's provision of CA be
included in the Agency's measurement approach for assessing progress toward
achieving those goals.
The objective of Goal 5 should be an integration of all aspects of the agency's
compliance and environmental stewardship activities into a mutually supportive
system. Critical success factors might include improved environmental
performance in the regulated community, enhanced protection of human health
and the environment, and an increase in the use of environmental management
systems as a result of the agency's actions. The objectives developed to support
this goal should define how the EPA will carry out its commitment to compliance
assistance, pollution prevention, and environmental stewardship. This should
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also include other objectives the agency must carry out to fulfill its regulatory
enforcement and compliance incentives commitments.
Review of the current draft Architecture indicates that EPA's Strategic Plan has
not incorporated the CAAC recommendation that the goals of each program
office should reflect the Agency's commitment to compliance assistance. Failure
to integrate CA into all of the Agency's Goals will likely result in over-reliance on
enforcement instead of the win-win scenarios engendered by a fully integrated
program of CA, voluntary programs, and partnerships. CA can provide a more
economical approach to federal environmental investments with greater
environmental and economic benefits than reliance on facility-by-facility
enforcement driven corrective actions.
To be successful, EPA will need to adopt a broad, holistic approach to
environmental assistance that works to persuade the regulated community and
the public to improve its performance by complying with environmental
regulations and practicing environmental stewardship. Through indirect
leadership activities such as compliance assistance, collection and dissemination
of information on pollution prevention, and sponsorship of environmental
stewardship programs, the Agency and its partners will be most successful in
engaging and motivating regulated entities and the public to plan and implement
supporting actions that support the EPA's goals. In addition, the Agency must
educate the regulated community and the public as to the impact their actions
have on the environment. Education will enable the regulated community and
the public to understand why it is important to initiate stewardship activities, be it
in the workplace or in the home.
A primary intent of Goal 5 as presently drafted is to measure reductions of
pollutants as related to compliance with regulations or as a result of compliance
assistance efforts. Because some regulations do not have a direct relationship
with reducing pollution generation, EPA should be cautious about relying solely
on decreased pollution generation as a measure of regulatory comprehension
and compliance. The outcomes measures selected for each objective should be
consistent with the procedures outlined in EPA's Guide for Measuring
Compliance Assistance Outcomes manual and should measure changes in
awareness and understanding, changes in behavior, and environmental and
human health improvements.
EPA should continue to address the issue of how to balance the allocation of
resources between enforcement and compliance assistance; both types of
activities are needed and must continue. In specific comments provided
elsewhere, the CAAC suggests that more resources be applied to compliance
assistance. We are concerned that the Agency does not appear to have
adequate resources to achieve all of the proposed goals using an effective mix of
CA and enforcement. In particular, there are not enough resources at the state
and local level to work with EPA on adequately implementing these goals.
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Furthermore, state and local priorities and resource allocation issues will affect
the degree to which EPA, states, localities, and tribes can effectively collaborate
on the implementation of these plans.
Lastly, EPA should be cautious about assuming a direct and causal relationship
between the amount of funding for environmental management activities and the
magnitude of pollution reduction.
II. Specific Comments
A. Objective 1
This objective proposes to maximize compliance by achieving an X%
increase in the pounds of pollution reduced through a combination of
compliance activities—assistance, incentives and enforcement. Regulated
entities' comprehension of environmental requirements is a pre-requisite
to all methods of improving compliance. Therefore, the first objective of
compliance assistance should be to enable regulated entities to
understand both the regulations that apply and how to comply with them.
1. Sub-Objective 1.1
The first goal of compliance assistance should be to enable
regulated entities to understand the regulations and how to comply
with them. Additionally, providing entities with an understanding of
why compliance is important is often an effective motivator for
improved compliance. Therefore, the primary strategic objectives
for CA should be to maximize the number of entities receiving CA
and using the information to comply with environmental
requirements. Additional benefits of CA are significant and include
improved environmental management practices and the potential
reduction in pollution generated. These should be secondary
targets for this objective.
An effective CA delivery network needs to encompass a variety of
CA providers and delivery methods. Ideally, EPA's assessment of
the effectiveness of CA should include CA provided by other
agencies and organizations that are included and supported in
EPA's CA network. EPA's CA centers are an important contribution
to CA but they remain a single delivery tool.
2. Sub-Objective 1.2
As currently structured this sub-objective does not measure the
number of facilities conducting environmental audits or the number
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of facilities that are encouraged to perform audits as a result of
EPA's audit policy. Instead it measures the number of facilities
reporting violations under the audit policy. Thus to satisfy this sub-
objective, there must be an increased amount of non-compliance
by facilities performing audits. EPA should assess ways to
measure the increase in number of facilities conducting
environmental audits as a method of environmental stewardship.
3. Sub-Objective 1.3
This sub-objective should be clarified as to the role of enforcement
in achieving the agency's goals in the areas of pollution reductions
and environmental stewardship. It appears to some as though EPA
is suggesting that more enforcement actions are needed in order to
meet the numerical targets established in this sub-objective. If, in
reality, EPA is seeking to focus its enforcement efforts to obtain
more environmental benefit from them, this needs to be stated
more clearly so that CAAC members and the public understand
what the Agency is trying to achieve.
B. Objective 2
EPA should clarify how the value for "X Ibs of pollution" will be related to
human health and environmental risks.
1. Sub-Objective 2.1
EPA's sub-objective references government "at all levels" yet sets
strategic targets that appear to address only Federal facilities. This
sub-objective should also seek to engage EPA in working with
other Federal programs and agencies to involve their programs that
interact with regulated entities in supporting CA objectives. These
programs include but are not limited to SBA, DOT, DOL, USDA,
BLM, NIST, DOE, SEC, etc.
The goals for compliance and environmental performance at
government facilities discussed in this objective are different in
scope and detail from the strategic targets for businesses
discussed in the next subjective. Government facilities can and
should serve as a model to private industry. EPA should establish
goals and objectives for government facilities that are as similar as
possible to those for other regulated entities
2. Sub-Objective 2.2
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The second, third and fourth strategic targets discuss reductions of
various measures reported under the Toxic Release Inventory
(TRI). EPA should clarify its intentions regarding the reductions in
"business-reported wastes," "chemicals reported by business to TRI
as released to the environment," and "hazardous waste generated
by businesses." Under EPA's current TRI reporting, wastes that
are recycled, transferred to waste management facilities and
publicly owned treatment works (POTWs), or simply released to the
environment, are all lumped together. As currently written, it is
unclear exactly what would be measured under the proposed sub-
objective. EPA should focus on increasing the recycling and/or
proper handling of materials, while decreasing materials released to
the environment.
The tenth strategic target discusses a reduction of "X million gallons
of waste pollution." The term "waste pollution" is confusing. From
a pollution prevention perspective, any material not reused in a
process is considered waste, whether or not it contains any
particular pollutants.
The eleventh strategic target proposes to reduce by X tons air
pollution prevented. This target would result in a decrease in air
pollution prevention and an increase in pollution. EPA should
clarify this strategic target.
The twelfth strategic target states that "X" millions of Ibs. of
hazardous chemicals and XX millions of gallons of "hazardous
solvents" will be reduced. It is not clear if the reduction to be
measured will be a reduction in Ibs. manufactured, imported, used,
or disposed of.
3. Sub-Objective 2.3
This sub-objective recognizes the important fact that much of the
pollution in this country comes not from industrial point sources but
through the day to day actions of the public. Purchasing decisions
by consumers have further environmental consequences as these
decisions, in the aggregate, affect businesses environmental and
production decisions.
While education of the public is an admirable strategic target, this
sub-objective is not ambitious enough. As written, the only
measurement of this objective is in terms of activities, not impacts.
The Agency should include measurements of success in raising the
public's awareness, knowledge, understanding, positive perception,
etc. Specific targets for reduction in non-point pollution to the air,
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water, and land should be provided in much the same way that they
were provided for businesses in sub-objectives 2.1 and 2.2.
EPA should also recognize and plan to utilize the synergy that
exists between sub-objectives 2.2 and 2.3 All businesses'
employees are part of the people discussed in this sub-objective.
C. Objectives
1. Sub-Objective 3.1
It is unclear why assistance to small businesses is addressed
separately in this Objective rather than included in Objective 1.
The first strategic target must better define "reaching" and the level
of contact it is meant to suggest. Furthermore, the Agency should
go beyond the mere measure of contact to measure the
environmental impact of the contact. The 50 state and three
territorial SBAPs noted in Sub-Objective 3.1 already reach that
number of small businesses annually. The SBAPs are a subset of
the many providers that exist in the CA network. The CAAC
recommends that EPA collaborate with the broader CA network in
their efforts to support outreach and technical assistance
D. Objective 4
It is recommended that the text for this objective be changed to reflect that
the agency's goal is to work with tribal governments to protect tribal
human health and environment. This objective should explicitly recognize
the authority of the tribal governments and identify tribal governments in
EPA's goal as a collaborating partner
E. Objectives
1. Sub-Objective 5.1
Given the level of funding and mission of the Department of Energy
(DOE) and the EPA, it is recommended that EPA collaborate with
the DOE on research into energy production processes be left to
DOE so that EPA's limited resources can be devoted to important
environmental compliance, assistance, and protection efforts
(second strategic target).
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EPA should ensure that the environmental technology discussed in
the third strategic target includes in-process pollution prevention
technology and not just end-of-pipe technology more commonly
promoted under the term 'environmental technology.1
2. Sub-Objective 5.2
The third strategic target is very important and should be given a
high priority. Many of the issues under deliberation by the CAAC
include how EPA can effectively garner and incorporate feedback
from regional, state, and local CA providers and enforcement
personnel. With this mechanism, the Agency will be able to
effectively evaluate the clarity, enforceability and effectiveness of
the rules and regulations it promulgates. Evaluation of clarity,
enforceability and effectiveness will allow the agency to promulgate
regulations that are clear and as close to self-enforcing as possible.
F. Objective 6
The CAAC supports the EPA's goal of ensuring that decisions rely on
sound economic and policy analysis, consider alternatives, incorporate
statutory and executive priorities, and are supported by a well-managed
and inclusive development process.
1. Sub-Objective 6.1:
The CAAC supports this sub-objective to improve the Agency's
regulatory and non-regulatory decisions through the development
of sound economic analysis. It is recommended that the Agency's
economic analysis recognize and estimate the costs of decision-
making needed for firms to comply with regulations. Identifying
those costs may in some cases lead to recognition of the
importance of CA in reducing the compliance costs of regulated
entities.
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