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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