ENHANCING THE MANAGEMENT CAPACITY
y OF THE
ENVIROWENTAL PROTECTION AGENCY
AN ANALYSIS OF THE EPA
BUDGET PROCESS
NATIONAL ACADEMY FOR PUBLIC ADMINISTRATION
Contract No. 68-01-6778
JANUARY 1984
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TABLE OF CONTENTS
Page
I. INTRODUCTION 1
II. EXECUTIVE SIMMARY 1
III. THE EPA BUDGET PROCESS 9
0 Statutory Framework 9
0 Organizational Framework 11
0 Budget Classification Structure 14
0 Dynamics of the Budget Cycle 18
0 The Budget Formulation Phase 20
0 The Budget Review Phase 48
0 The Budget Execution Phase 65
VI. FINDINGS AND RE COMMENDATIONS 73
Statutory Complexity 75
Strategic Planning 84
Complexity and Detail in the Budget Document 87
Regional Office Participation in the Budget Process 95
EPA Use of Resource Distribution Models 104
Confidentiality of Budget Estimates 109
Flexibility in Budget Execution ^Q&-1>'
EPA Management Accountability Systems -l-H- // ~t
Budgeting for Superfund Administrative Expenses J-frT- / 2 -2.
Budgeting for Research and Development 126
Administrative Information Systems 134
Communication and Training 140
V. APPENDIX 142
A. Budget Process Flow Analysis Chart A-l
B. Individuals Consulted by the NAPA/EPA Budget Process
Study Team B-l
C. Documents Reviewed by the NAPA/EPA Budget Process
Study Team C-l
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I. INTRODUCTION
This is the report of the EPA Budget Process Study conducted by
the National Academy for Public Administration under EPA Contract
No. 68—01—6778. The Environmental Protection Agency commissioned
the Academy in July 1983 to undertake intensive studies of the
Agency’s personnel and budget systems. The purpose of these
studies was to identify strengths and weaknesses in the management
and utilization of EPA’s people and its resources and to
recommend improvements to enable the Agency to administer more
effectively the laws on public health and the national environment.
The Chairman of the National Academy convened a Panel to provide
guidance and direction to the two studies. The members of
this Panel are:
Frank C. Carlucci (Chair). President, Sears World Trade, Inc.
Former Deputy Director, CIA, and Deputy Secretary of Defense, -
Former U.S. Ambassador to Portugal.
Robert V. Fri . President, Energy Transition Corp. Former Head,
U.S. Delegation to the International Atomic Energy Administration;
Deputy Administrator, Energy Research and Development Administration;
and Deputy Administrator and Acting Administrator, EPA.
John V. Gardner . Chairman and founder, Independent Sector. Former
Chairman, Common Cause. Former Secretary, Department of Health,
Education and Welfare.
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Simon Lazarus . Partner, Powell, Goldstein, Frazer & Murphy.
Former Associate Director, White Rouse Domestic Policy Staff,
and Attorney, Arnold & Porter.
Gerald Md(anis . President, Md4anis Associates. Former Senior
Associate, Cresap, McCormick and Paget, and Department of Defense
executive responsible for application of systems analysis
techniques to management problems.
Dale McOmber . Former Assistant Director for Budget Review, Office
of Management and Budget.
Robert E. Merriam . Partner, Alexander Proudfoot Co. Former Chair,
Advisory Commission on Intergovernmental Relations, and Deputy
Assistant to the President.
Ersa H. Poston . Former Vice Chair, Merit Systems Protection Board.
Former President, New York State Civil Service Commission; Member,
International Civil Service Commission.
Vicki Techinkel . Secretary, Florida Department of Environmental
Regulation, and Member of the Energy Research Advisory Board, U.S.
Department of Energy.
William N. Walker . Counsel, Mudge, Rose & Guthrie. Former Deputy
Special Representative for Trade Negotiations, Geneva, and Director,
Presidential Personnel Office.
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In its conduct of the EPA Budget Process Study, the Panel was
assisted by a small staff of analysts:
o Eldon D. Taylor, Staff Director
o George Pilarinos, Senior Research Associate
o Patricia L. Foreman, Research Assistant
The Budget Process Study Team conducted interviews with over a
100 people from the Environmental Protection Agency, at Head-
quarters, in the Regional offices, and the Laboratories, as
well as from other interested groups such as the United States
Congress and the Office of Management and Budget. A list of
persons interviewed is provided in Appendix B. In addition to
the interviews, the Study Team reviewed about 80 documents
such as the Agency’s Budget Submissions, Inspector General
Audit Reports, Agency Task Force Reports, Information System
Studies, and numerous memoranda pertaining to the Fiscal Year
1983 through 1985 budget cycles. A complete list of the
documents pertinent to the Study is provided in Appendix C.
The Academy wishes to express its appreciation to the management
and staff of the Environmental Protection Agency for-their
wholehearted cooperation and assistance in the conduct of this
Study.
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II. E CtTrIVE SU 4ARY
This is the report of the Budget Process Study conducted
for the Environmental Protection Agency by the National
Academy for Public Administration (M PA). The Budget
Process Study Team interviewed over a hundred key
management officials, program analysts, and budget
analysts at EPA Headquarters, in the Regional offices,
and the Laboratories, as well as staff representatives
of the United States Congress and the Office of
Management and Budget. The Study Team also reviewed
various EPA analyses and reports pertaining to the
Agency’s budget process, along with numerous internal
memoranda specifically relating to the Fiscal Year
1983 through 1985 budget cycles.
The Budget Study interviews and document reviews clearly
indicate that the EPA budget process is fundamentally
sound :
o EPA top management finds the process useful for internal
program planning and decision—making.
o Budget estimates are based on careful workload analyses
and specific planned accomplishments.
o Budget formulation is focused at EPA Headquarters,
but serious efforts are made to assure that all levels of
management participate.
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o The EPA budget and accounting structure provides for
the stewardship of funds in accordance with sections of
the authorizing statutes and effective mechanisms are in
place to control budget execution both at Headquarters
and in the field.
o Formal accountability systems are employed to monitor
performance of the Agency in its execution of commitments
made in planning and budget documents.
o Representatives of the Office of Management and Budget
advise that the EPA budget document and supporting data
facilitate Executive Branch review and decision—making.
o Staff representatives of the Appropriations Committees
of the Senate and the House of Representatives report that
the EPA budget submission satisfies their review and over-
sight requirements.
It should also be noted that present EPA leadership has
initiated a broad reexamination of the Agency’s statutes,
policies, and procedures that will have a positive impact
on the Agency’s management systems as improvements are
implemented. Within this framework, the Panel has
identified twelve subject areas where change might further
enhance the system and enable it to contribute more
effectively to the accomplishment of the Agency’s mission.
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STATUTORY CCI4PIIXITY
° The NAPA Panel recommends that the EPA and the Authori-
zing Committees of the Congress work together to enact
legislation that provides consistent language in the
environmental statutes for such common functions as
State assistance, research and development, permitting,
standard—setting, enforcement, and administrative
procedure.
STRATEGIC PLANNING
o The NAPA Panel endorses implementation of the Guidance
and Strategic Planning changes outlined in the Deputy
Administrator’s Memorandum of November 2, 1983. The
Panel also recommends that one or two strategies be
selected annually for analysis of longer term (3—5 year)
trends.
CQ4PLEXITY AND DETAIL IN TEE BUD( T DOCtMENT
o The Panel endorses the Agency’s decision to eliminate
the EPA implementation of Zero—Based Budgeting .
• The Panel recommends that the Agency continue to base
its budget formulation on functional analysis so as to
retain the management benefits that accrue therefrom .
o The Panel recommends that the Agency continue to move
toward fewer program elements in the budget structure ,
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more concise budget narratives, and a somewhat higher
level of aggregration of activities and accomplishments
in the budget pricing analysis.
REGIONAL OFFICE PARTICIPATION IN THE BUDCET PROCESS
o The NAPA Panel recoenda that the budget process
improvements suggested in the Headquarters/Regional
Relationships Task Force Report be implemented .
o The Panel recommends that the Deputy Administrator
serve as the focal point for evaluation of the proposed
balance between Headquarters and Regional funding in
the formulation of initial budget estimates .
o The Panel also recommends that the Agency provide a
conflict resolution mechanism, with the Deputy Admistrator
as the focal point, to moderate disputes that may
arise as part of the Lead Region budget collaboration
process and assure that positive Headquarters—Regional
relationships are not disrupted by the process.
EPA U OF RESOURCE DISTRIBUTION MOIELS
o The Panel recommends the continued use of workload models
for Regional resource allocation, recognizing that, when
used effectively, models can yield substantial related
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benefits such as more realistic budget justifications,
improved staff communication, and enhanced program account-
ability .
o The Panel recommends that the Agency develop a formal policy
on resource models that addresses the question of consistency
in design approach and technical validity of model
construction .
o The Panel recommends that the Agency clearly define the
function of resource model design and modification as a
joint Headquarters/Regional responsibility and that
the policy require the full participation of the
Regions in the process.
CONPIIE NT IALITY OF BUDC T E ST ] MATE S
o The N PA Panel recommends that the Agency open its
budget formulation process to permit the sharing of
estimates between the major programs and the Regions.
FLEXIBILITY IN BUDC T EXECT.TIION
o The NAPA Panel recommends that the Congress provide
the Agency with increased reprograining flexibility
by raising the present $250,000 and $500,000
threshholds to $1,000,000 .
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o The Panel recommends that the Agency conduct a review
of internal control systems to insure that managers
are delegated the maximum flexibility possible.
EPA MANAc MENr ACCOUNT&BILITY SYST 4 S
• The NAPA Panel endorses the Agency’s approach to
program and management accountability and recommends
that the systemic improvements initiated during
the Budget Study be implemented .
o The Panel recommends that the Agency review the
impact of data collection requirements that have
accumulated in recent years to reduce the load and
provide a review mechanism for proposed new
requirements.
BUDGETING FOR SUPERFUND AU4INISTMTIVE EXPEN S
o The NAPA Panel recommends that GIB, EPA, and the
appropriate authorizing committees in Congress
consider a revision to GERCIA which would permit
funding of EPA administrative expenses within the
regular Salaries and Expenses appropriation and
eliminates them from the site cleanup cost recovery
process .
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o As an alternative, the Panel recommends legislation
that would permit funding of EPA administrative
expenses within the S&E appropriation and would
prescribe a statutory formula for recovery of the
administrative expenses on a site—specific basis.
BUD ETING FOR RE ARCH AND 1 VELOR4ENT
o The NAPA Panel recommends the establishment of staff
“ R&D Program Manager” positions in the Headquarters
R&D complement, with responsibility for media—based
planning and budgeting, liaison with National Program
Managers, and operation of R&D management account-
ability systems. Research committees would serve in
an advisory capacity to these Program Managers .
o The Panel recommends that multi—discipline Research
Centers be formed at Cincinnati and at Research Triangle
Park, with the Center Directors reporting to the Assistant
Administrator for R&D. “R&D Program Manager” counterpart
responsibilities should be provided at the Centers .
o The Panel recoends that the Agency seek enablii
legislation for its basic research and inter—
disciplinary research activities .
o The Panel recommends that the Agency work with 048 to
develop a more coherent approach to the presentation
of the R&D program in the budget document .
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AII4INISTRATIVE INPOI 1ATION SYST 4S
• The NAPA Panel recommends that EPA establish an Agency
objective to achieve horizontal integration of administra-
tive ADP systems for grants, contracts, personnel,
payroll budget, and accounting .
o The Panel recommends that EPA establish an Information
Systems Steering Committee composed of representatives
from both line and staff user organizations, to advise
on the development of administrative ADP systems, stress-
ing horizontal compatibility and a view of information
systems as an Agency—wide resource .
o The Panel recommends that the Agency conduct a cross—
systems study of administrative processes to provide a
strong foundation for software design.
CG4MUNICA TION AND TRAINING
o The NAPA Panel recommends that EPA develop a new
budget manual and implement a procedure that assures
the issuance of regular, periodic updates .
° The Panel recommends that a training course be designed
for EPA personnel covering the EPA planning, budgeting,
and accountability processes .
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III. T EPA BUD T PRO ZSS
The Environmental Protection Agency was created on
December 2, 1970, by Presidential Reorganization Plan
No. 3 (Executive Order 35, Fed. Reg. 15263). The
Reorganization Plan consolidated into a single indepen-
dent agency a number of Federal environmental programs
that had been assigned to agencies and offices within
the Department of Interior, the Department of Health,
Education and Welfare, the Department of Agriculture,
and the Atomic Energy Commission.
As is the case with all Federal agencies, the EPA goes
through a budget formulation, review, and execution
process to obtain and control the use of its funds.
To be properly understood, this budget process should
be viewed against a backdrop of the statutes that
authorize and direct the Agency’s activities and the
organizational setting for carrying Out Its mission.
Statutory Framework
In place of an organic act, EPA inherited an array of
governing statutes by virtue of the numerous transfers
of authority from the predecessor organizations.
Following is a list of the major statutes EPA is to
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execute, chronologically ordered by their expiration dates:
Act Expiration Date
o National Environmental Policy Act of 1969 —
0 Noise Control Act of 1973 as Amended by the
Quiet Communities Act of 1978 1981
° Clean Air Act, as Amended 1981
° Federal Insecticide Fungicide & Rodenticide Act 1981
0 Environmental Research, Development and Demon-
stration Authorization Act 1981
° Federal Water Pollution Control Act, as
Amended by the Clean Water Act of 1977 1982
° Marine Protection, Research and Sanctuaries Act 1982
° Safe Drinking Water Act 1982
0 Resource Conservation & Recovery’ Act of 1976 1982
0 Toxic Substances Control Act 1983
o Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (Superfund) 1985
The responsibilities and authorities contained in these statutes
are expressed in considerable detail and, taken as a whole,
constitute a substantial and intricate body of law. Eight
of these statutes reproduced in the Selected Environmental
Law Statutes , 1983, Edition, West Publishing Company, comprise
about 750 pages.
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Congressional oversight of EPA is carried on by 19 committees and
subcommittees in the House of Representatives and 7 in the Senate.
EPA officials are routinely required to testify before these
committees, with the number of separate appearances averaging
about 90 per year. Most of the authorization provisions of the
controlling EPA statutes have expired. Until the Congress
enacts new provisions, interim reauthorizations are being
appended to the annual appropriation acts that provide EPA the
funds to carry on its mission.
ORG&NIZATIONkL FRAMEW0 (
The current organization of the Environmental Protection Agency is
depicted in the following chart:
UI INVIION’.INTAL NOTICTION ACLNCY
AOl. N STRATOR
7 R — — — __________
. I, , •*.. J I ADMINISTRATOR •o..1c..
_____ _____ I I
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k° i i i k -i
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.nc . 9 .n.a.sn j ...t.s
C ______
CS. •• • . I Cl . ... •• I
I I 1 I I I I I
i •,.._. I I .. .. ... r . ..... I I ..... I f ....T1 I IICCS I I I I I I IC I I IICM •
I ‘O I I 1 ‘ I I ‘‘“ I I • I I I ICIA . I I II I I I ••S CI I I I I I 1IA • I • , .I .
. 0 CS.I.
Figure 1. Organization of the Environmental Protection Agency
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As the chart indicates, the functions of the Agency are carried
out by a combination of Headquarters and field organizations. At
the Headquarters level, the media/pollutant programs defined
by the statutes are grouped under four Assistant Administrators
who, functioning as “National Program Managers” (NIMs),
are assigned the responsibility for planning and implementing
their programs in varying degrees of coordination with
their Regional counterparts. All EPA research and development
activities in support of media programs are consolidated
under the leadership of an Assistant Administrator for
Research and Development. Although the R&D organization
includes laboratories located throughout the country, the
laboratories are considered Headquarters components and are
not included within the jurisdiction of the Regional
Administrators.
Regional Administrators report to the Administrator and are
responsible for the execution of the Regional programs of
the Agency. The Regional Administrator represents the
Administrator in contacts and relationships with public
and private groups in the Region and is responsible for
accomplishing the national program objectives established
at EPA Headquarters. Each Regional Office has an Air and
Waste Management Division (or two separate Divisions)
responsible for executing the Region’s Air, Noise, Radiation,
Pesticides, Toxic Substances, and Waste Management Programs;
a Water Management Division, responsible for executing the
Region’s Water Quality programs; and an Environmental
Services Division (with no Headquarters counterpart) that
collects, analyzes and evaluates data on environmental
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quality, including pesticide sampling, in support of Regional
and National monitoring requirements.
EPA programs such as Pesticides and Toxic Substances which
rely heavily on registration or permit activities tend to be
centralized at Headquarters in Washington, D.C. The Water
and Air Programs, on the other hand, require substantial
involvement of State and local governments and rely heavily
on the EPA Regional structure for program implementation.
Whatever the organizational design or mode of operation,
however, the budget formulation process is dominated by the
National Program Managers at Headquarters with varying
degrees of participation by Regional representatives.
Figure 2 shows
Administrator,
Administrators
the organizational relationships between the
the National Program Managers, the Regional
and the Regional media divisions.
ETC.
National
Pr ogr am
Managers
I kd [ niitiitot
Deiuty I
Regions I Regional
(Administrator
ETC.
Divisions
Assistant
Administrator
Air
P I
R
O A B C D
C I
R
A I
M
S
-— I I I
I I
I
‘I
1 A
B
C
DJ
Assistant
Administrator
Vat er
I I
, I
E F C H
I I I P
I I I I
I I P I
I I I
P I I I
: :1:
P I P
I
P
P
I
E
F
C
Hj
1
P
P
Figure 2. Headquarters—Regional Organizational Relationships
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Budget Classification Structure
The EPA enabling statutes address concerns with particular
environmental media or threats: air quality, water quality,
drinking water, solid waste, pesticides, radiation, toxic
substances, etc. As the broadest definition of the activities
of the Agency these media categories represent an important
high level of aggregation for purposes of budget and accounting.
These statutes are divided into sections that provide
authority and direct specific actions to be undertaken in
such program areas as research and development; State assistance;
standards for environmental quality; enforcement; permits and
licenses; direct cleanup; claims processing; and others.
The enabling legislation is supplemented annually by Appropria-
tion Acts that provide funds to carry Out the mission.
These Acts subdivide the total amount approved by Congress
into broad groupings such as Research and Development; Abatement,
Control and Compliance; Construction Grants; Salaries and
Expenses; Superfund; etc. When taken in combination with the
functions described in the enabling statutes, these categories
require complex crosscutting aggregations of data in the budget
and accounting systems. For example, within the media
category Water Quality , the budget structure is divided into
three functions:
o Research and Development
o Abatement and Control
° Enforcement
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Each of these is further subdivided into several broad
classifications called subactivities. For example, the
Abatement and Control subactivities are:
o Water Quality Management
o Effluent Standards and Guidelines
o Grant Assistance Programs
o Water Quality Strategies Implementation
o Water Quality Monitoring and Analysis
0 Municipal Source Control
These subactivities are split further into more specific
“budget elements”. In the case of Municipal Source Control ,
the units are:
o Municipal Waste Treatment Facility Construction
o Waste Treatment Operations and Maintenance
One of these is once again subdivided into two program
elements—one for EPA salaries and expenses (funded
as a separate appropriation), and the other for program-
matic uses such as grants or contracts.
The lowest control level in the EPA program budget
structure is the program element. If a program is funded
from only one source (as is “Waste Treatment Operations
and Maintenance”), the terms “budget element” and “program
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element” are synonymous. If a program is funded from two
sources (as is “Municipal Waste Treatment Facility
Construction”), the term “program element” refers to each
of the two components of that budget element. There are
304 program elements in the FY84 EPA program budget
structure and the data for these elements are “rolled up”
in various combinations as needs dictate. Budget justi-
fications are written at the budget element level, of which
there are 212.
The existence of ten EPA Regional Offices, each with
program execution responsibilities, has an important
impact on the budget and accounting process. For one
thing, each of about 30 program elements that involve
Regional work must be further subdivided into ten
components——one for each Region——adding 300 more control
categories to the structure.
Since the EPA budgets submitted to the President and the
Congress are aggregated at National levels without specific
Regional breakdowns, another byproduct of the Regional
structure is the need to devise techniques to equitably
disaggregate the National program element totals into
allocations for each of the 30 Regional components. In
response to this need, workyear and dollar distribution
mechanisms (“workload models”) have been developed, rang—
ing from simple percentage formulas to complex algorithms
with a number of input parameters.
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Water
Quality
anag ement
Etc.
The cascading nature of the classification structure needed
to reflect all these combinations is depicted in Figure 3.
WATER QUA LITY
Research and
Development
Etc.
Abatement and
Control
Effluent
Standards &
Guidelines
Grant Munici
Assistant Source
Pr rams Control
01
1
Etc.
Etc.
Municipal Waste
Treatment Facility
Construction
E nf 01
cement
Etc.
Water Quality
Strategy
Implementation
Etc.
Waste Treatment
Operations and
Maintenance
Water Quality
Monitoring and
Analysis
Etc.
Figure 3.
Budget Classification Structure Diagram
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Dynamics of the Budget Cycle
At this point, a word about nomenclature may be useful. The budget
process takes place over a 3—year cycle, so at any given time the
Agency may be working on the budgets for three different target years.
In order to keep matters sorted out, the name assigned to a particular
target year changes as the cycle progresses. In the first year, or
formulation phase, of a given cycle, the target year is named the
‘Budget Year.” In the second year, or review phase, of the cycle,
the target year becomes “the Operating Year.” In the final year, or
execution phase, the target year is referred to as “the Current Year.
The following diagram displays the nomenclature and the relationship
between the overlapping phases of the three cycles being addressed in
a given year.
FY1982 ff1983 ff1984 ff1985 ff1986
l982Curr. Yr.
1983—Oper. Yr. l983Curr. Yr.
l984Bud. Yr. 19840per. Yr. l984Curr. Yr.
**]985Bud. Yr. 1985—Oper. Yr. l985Curr. Yr.**
1986Bud. Yr. 1986—Oper. Yr. Etc.
1987Bud. Yr. Etc.
Etc .
Figure 4. Budget Cycle Nomenclature and Relationships
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For the purposes of this process flow analysis, significant
events in the 1985 Target Year cycle (enclosed in asterisks
in the diagram above) have been identified and ordered chrono-
logically. When considering the workload implications
of the budget process, however, it is important not to lose
sight of the fact that the three cycles are underway simul-
taneously. Furthermore, the actual process is not as neat
and tidy as the analysis would indicate. Anticipated events
such as Congressional Hearings and passage of Appropriation
Acts frequently do not occur according to the planned schedule.
Continuing Resolutions, Supplemental Appropriations and other
special factors often are injected into the stream of events,
compressing the time available or adding to the amount of
documentation required from the staff.
It is also important to note that the recent changes in EPA
administration and organization have affected the policies
and procedures associated with the budget process. Perhaps
the most significant budget process change was the decision
to eliminate most of the Zero—Based Budgeting (ZBB) methodology
with its ranking committees and multiple resource levels of
budget preparation. ZBB procedures had imposed an enormous
burden of detail on the system and their elimination was a
major relief to managers at all levels.
Other changes in policy, organization, and process are still
under review at the Agency. For example, a major reorientation
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of the process for issuance of annual Administrator’s Guidance
and Program Guidance and for the Administrator’s Management
Accountability System is underway.
Within such a dynamic situation, it is difficult to describe
the budget process as a static system. To make the flow
analysis as meaningful as possible, the description of signif i—
cant events for months 1 through 12 (January—December 1983)
describes the actual EPA experience in preparation of the
FY85 Budget. Events described for months 13 through 36
(January 1984—December 1985) are based on the forecasts by
EPA staff as to how the FY85 cycle will be completed.
Budget Formulation Phase
(Year 1 — months 1 through 12)
The formulation of the Fiscal Year 1985 Budget began with the
development of a planning document entitled Administrator’s
Guidance whose purpose is to place the formulation process
within a broader policy perspective. The Office of Management
Systems and Evaluation (a4SE) is responsible for drafting
the guidance. Although this paper treats January 1983 as
month number 1 in the budget process, G( actually began
preliminary work in October and November of 1982 to identify
the set of long—term, program—specific objectives to be
included in the Guidance.
Q SE began by convening media workgroups composed of staff
analysts. The output of these workgroups was a list of
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needs with the proposed solutions expressed in terms of
objectives for FY84 and 85. The preliminary documents were
circulated to Headquarters offices, Regional offices, and
selected State organizations for comment, negotiation, and
rewrite. Subsequent versions were moved through successively
higher levels of review, culminating in the publication in
February of the final document containing the Administrator’s
approved Guidance. The Guidance document covers two fiscal
years. Relatively specific guidance is supplied for the
budget that is in the Review Phase i.e., moving through the
Congress and soon to be executed. A more general statement
of goals and objectives is provided for the Budget Year for
which formulation has now begun.
The following excerpt from the February 1983 Administrator’s
Guidance for the FY85 Budget Year reflects the tone and level
of detail found in this document.
“ OFFI OF PESTICIDES AND TOXIC SUBSTANCES
PESTICIDES
o Implement oversight protocols for State enforcement
programs.
o Consider development of registration fees to recover
total registration costs.
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o For pesticide enforcement grants and certification and
training grants explore methods to increase self—
sufficiency in funding.
o Insure adequate resources are available to review data
received in response to the Registration Standards
Program and to update regulatory positions when
necessary.
o Consider encouraging States to utilize a portion of
their enforcement grants to provide environmental
monitoring data to OPP.
o Refine and report on Environmental Results Indicators
to track program progress in meeting environmental
S
objectives.
o Incorporate findings of Regional Environmental
Management Reports into program planning and eval-
uation.•
For the most part, the level of budget formulation activity is
low in March and April. Nevertheless, some National Program
Managers begin preliminary work on their portions of the
budget soon after the issuance of the Administrator’s Guidance.
For example, program staff in the Water Quality program begin
developing workload projections for the Budget Year. They
solicit input for this purpose from their Regional counterparts
to generate workyear projections under various assumptions,
using workload models.
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In April, the Office of the Comptroller (OC) begins its
preliminary efforts by meeting with the Administrator
and Deputy Administrator to discuss program emphases, new
program starts, cutbacks, and specific issues to be
addressed in the budget. OC staff may also meet with -
National Program Manager staff and Regional staff to ex-
change views on program issues and directions and to re-
late recent significant Congressional actions to the
formulation of the FY85 Budget.
An important milestone occurs In May or early June,
when the Office of Comptroller produces the formal Budget
Call Letter to be sent to each Assistant Administrator.
In previous years, this Call letter has contained policy
guidance as well as procedural material. The Call for the
FY85 Budget, however, was exclusively procedural, contain-
ing the budget process schedule, the budget resource targets
to be used In submissions, the names of the Lead Deputy
Regional Administrators (discussed below), sample forms,
formats for ranking the program elements in the submission
and for aggregating data to media level, and the schedule
for accomplishment of a special project to develop an Agency
ADP Plan.
The question of Regional participation in the budget process
has been the subject of much discussion at EPA over the
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years. The challenge has been to assure adequate partici-
pation without the expenditure of excessive resources.
Since most of the major National Programs are represented
in each of the ten Regions, maximum participation would
require ten Regional representatives for each program to
meet and discuss each program issue. Such an arrangement
would be expensive and it would be difficult to produce
a satisfactory product in the compressed time frames
associated with the budget process. These problems could
be alleviated somewhat by the electronic transmission of
draft documents and the use of telephone conference calls
to gain a consensus. Nevertheless, this approach is
rather cumbersome and difficult to carry off effectively
for all programs.
Another alternative would have each Regional Administrator
develop a budget for his or her Region based on the annual
Guidance. The program elements in the ten Regional
budgets would then be combined with those formulated by
Headquarters offices to produce an Agency budget. This
approach was, in fact, tried in the development of the
FY82 Budget and is generally considered to have been a
failure because of the extreme workload and the intense
coordination that was required. Much of the problem may
have been due to the use of the complicated ZBB procedures
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—25—
which, in effect, were multiplied tenfold by this pro-
cess. Whatever the cause, there is little enthusiasm
in either the Regions or the Headquarters for Regional
budget formulation.
Instead, EPA has developed the “Lead Region “ concept
in which a Deputy Regional Administrator (DRA) from one
Region represents the interests of all the Regions with
respect to one of the media. For example for FY85, the
Deputy Regional Administrator for Region IX serves as
the Lead DRA for all programs associated with Air
Quality for all ten Regions. Regional officials are
not completely satisfied with the present system, however.
A Task Force established by the Administrator to review
Headquarters—Regional relationships described the problem
as follows:
“The criticisms most frequently heard of the current
budget development process, from the regional perspect-
ive, are:
o The extent and effectiveness of lead Region ‘partici-
pation’ is too dependent on the whim of the NR4.
Participation ranges from extensive regional
involvement to total exclusion.
The degree of lead DRA, participation varies greatly
depending on a number of factors including time and
staff availability.
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—26—
• Lead Regions are in a ‘reactive’ mode from the very
start of the process; very few NNs involve the
regions in the initial development of the regional
budget request. For the most part, the Regions see
N ’( drafts or initial allocations after the N ( has
virtually finalized his or her decisions. Scarce
regional resources make it difficult for Regions to
react in a short timeframe.
Lead Regions are not in a strong enough position to
have much impact on Headquarters/Regional splits in
allocation of resources because budget guidance for
program development is unclear.
o Some lead Regions involve their fellow Regions early
in the development of the request, others involve
their counterparts too late in the process or not at
all. The process lacks structure. Non—lead Regions
who see the budget requests for the first time in
final form are presented with a ‘f alt accompli’ which
is difficult to change.
• The scrutiny which regional programs receive by
Headquarters offices should be balanced —— Regions
should have an opportunity to examine Headquarters
resource allocations and comment on them.
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—27—
Since the ‘targets’ issued at the start of the process
are at the N ’1 level, there is a tendency to think of
an increase in the regional program as being at ‘the
expense’ of a Headquarters program or vice versa. As
a result, there is a tendency to make changes at the
margin rather than to discuss the merits of resource
specific allocations.
o Regions don’t always know if budget Comments will have
an effect until the final agency budget is prepared.”*
The Task Force made several important recommendations to improve
the situation:
“ Responsibilities of the National Program Manager and Lead
Deputy Regional Administrator Should Be Better Defined.. .
¶ General performance expectations during the initial
stages of the budget development process for both the
NPI4 and lead Region should be clearly defined and re-
gional viewpoints should be formally recognized in the
NR’I budget presentation.
Regional Budget Development Meetings Should Be Held Prior to
Development of the National Program Managers Submission and
Before Finalization of the Administrator’s Budget.. .
¶ Regional budget development meetings should be convened
each spring to provide regional representatives the
*Report of the Task Force on Policy and Management Review of
Headquarters—Regional Relationships, September 1983.
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opportunity to advise National Program 1anagers of region-
al needs, problems and other issues...
I The Deputy Administrator should convene an annual hearing
to provide Regional Administrators the opportunity to
present their views on both media—specific and cross-
cutting budget issues. The hearing should be held following
submission of National Program Manager budget submissions to
the Comptroller, but prior to finalization of the
Administrator’s budget proposal,
The Lead Region Selection Process Should be Broadened.. .
I The Comptroller should lead a broadened process for selection
of lead Regions to work with each National Program Manager.
The expanded process will include active participation of
regional officials, National Program Managers, and the
Associate Administrator for Regional Operations, with final
approval by the Deputy Administrator.
Regional Participation In the Budget Development Process Should
be Expanded.. .
I Participation of senior regional staff in the Eeadquarters
budget process should be instituted within operating procedures
developed by the Comptroller, and discussed with the Associate
Administrator for Regional Operations.”*
*Ibjd
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—29—
These proposed changes have been approved by the Deputy Adminis-
trator for implementation in the FY86 budget cycle.
With the issuance of the FY85 Budget Call Letter, National
Program Managers begin intensive work on their portions of
the budget. For each program, (i.e., “budget element”),
within their jurisdiction, the 0(3 submission contains three
basic sections:
A ‘BUD #1’ form summarizing the workyears and intramural!
extramural funds requested, along with a comparison of these
amounts as approved in the two prior years;
A “BUD D1A” section which provides the narrative justif 1—
cation for the program——its goals and objectives, a
description of current operations and expected accomplish-
ments and an explanation of changes from the prior year’s
budget;
• One or more “BUD #2” forms that depict every activity
the Agency expects to perform under that program in
the budget year. For each activity, a set of performance
measures (“accomplishments”) is defined, and, for each
accomplishment, a particular level of performance (an
output”) is committed to for the number of workyears
requested.
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In combination, the hundreds of BUD #2 forms in the budget
request represent a comprehensive functional analysis that
accounts for 100% of the resources requested by the Agency.
The following excerpt from the FY84 budget submission for one
program illustrates the level of detail contained in these
documents:
DU CODE FAY9A HQ _____ RT X DU TITLE Hazardous Spill and Site Response
RESPONSIBLE OFFICE Office of Solid Waste and Emergency Response
DOLLAR PRICING IS EXTRAMURAL ONLY (CONTRACTS, GRANTS AND LAG DOLLARS ONLY)
FY 1982 FY 1983 FY 1984
ACTIVITIES/ PROJ ACTUALS OPER. PLAN REQUEST
&CCOHPLLSHMENTS OUT- OUT- OUT—
____ $ 1 L Z L S .! L L $ 1 L
l lED1AL 88.2 103.4 127.1
PTeliminary
Lasesseent 3.4 962.8 1,500 9.1 4,277.0 4,000 9.1 4,000
Site Inspections 11.8 4,187.6 1,300 18.2 10,678.4 2,000 t8.2 2,000
Site Investiga— 14.5 6,449.6 400 7.3 3,339.2 200 7.3 200
tion
National Priority
List 7.5 4.0 2.5
Reniedial
Investigation s/
Feasibility
Studies 27.1 14,676.0 36 40.1 32,000.0 40 48.0 49,378.7 55
Remedial Design 5.8 5,135.0 13 7.1 8,200.0 24 17.5 15,264.2 40
Remedial
Implementation 6.8 26,894.0 10 3.1 48,361.4 11 9.5 110,449.2 22
InitIal Remedial
Measure 2.5 11,666.0 12 4.5 7,500.0 15 5.0 11,211.7 20
Enfc*rcenient
Coordination 5.0 5.0 5.0
Figure 5, Sample “BUD #2” Pricing Analysis
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—31—
At this stage, the estimates are at a National level of detail.
That is, the requested Regional resources are shown as a total
and the amounts allocated to each Region are not reflected in
the submission. Nevertheless, again in varying degrees, the
National Program Managers involve the Regions in the process.
For example, in the Office of Water, meetings are held with
Regional staff and Lead DRA’s to refine the workload models
for each program element and to identify priorities and
strategies, which are factored into the budget justification
by the Water Quality National Program Manager.
Budget estimate preparation continues in the May—June time—
frame and the draft submissions of the NR4 staff are distribu-
ted to the Lead DRA for information or for comment, depending
on program office practice. Meetings may be held to obtain
a consensus on a final draft, including the ranking of the
budget elements within the media, to be submitted for approval
by the Assistant Administrator. The approved submission is
forwarded to the Office of the Comptroller in early July for
review and aggregation into an Agency composite.
It should be noted at this point that the Office of Research
and Development CORD) follows a different budget development
pattern because of differences in its mission. First,
although most of its work is performed at laboratories
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—32—
outside of Washington, D.C., ORD is treated as a Headquarters
organization, and the Regional structure typical of the
other programs is not applicable. Second, since the rest of
the Agency programs are clients of ORD, a mechanism is
needed for inventorying the R&D needs of the programs,
prioritizing them, and pricing them out. To accommodate
these unique characteristics, ORD has developed specialized
procedures which are stiimvuarized as follows:
a. Media—oriented research committees composed of
researchers, managers, and program office representatives
have been established to examine the research and development
needs in each program area. (See Figure 6.) In March, the
research committee analyses are consolidated into “mega—
strategies” for each media category (i.e., air, water,
toxics, hazardous waste, etc.) which are reviewed by ORD
Office and Laboratory Directors and submitted to media
program offices for their review and concurrence.
b. In April, the Assistant Administrator for R&D develops
budget year target resource allocations for each strategy
area, based on discussions with the niega—strategy authors
and the Administrator’s Guidance. The mega—strategy authors
and the research committee chairmen then meet and disaggregate
the media—level totals to the individual research committees
within each of the media.
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—33—
PRIMARY
STRATEGY RESEARC. COMMITTEE STRUCTURE CLIENT OFFICE
Ox1DA r >
HAZARDOUS AIR POLLUTANT >
GASES AND PARTICLE >
MOBILE SOURCES >
RADIATIO >
WATER QUALIT >
MUNICIPAL WASTEWATE >
INDUSTRIAL WASTEWATER >
_________ DRINKING WATE >
___________ HAZARDOUS WASTE
___________ SUPERFUN >
________ PESTICIDE >
__________ Toxic
ENERG >
AIR
OAQPS 0
A
N
R
ORP
WATER
(
I <
I <
HAL. WASTE I
I SUPERFUND I
I PESTICID j
I TOXICS I
I ENERGY I <
( MRS
W
OWPO
_____
oI 1
OSW
0
s
W
E
R
OERR
______
uPP
0
P
T,
S
OTS
CROSSCUTTING
Figure .
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—34—
c. In April and early May, the research committees meet
and agree on objectives to be fulfilled within their resource
allocations. These are translated into “Planned Program
Accomplishments” (PPAs) for each resource level and forwarded
to the Assistant Administrator level for aggregation.
d. At the end of May—early June, the Assistant Adminis-
trator for Research and Development holds 2 days of meetings
to afford each research committee chairman an opportunity
to describe his or her request. The overview is followed by a
more detailed discussion during which ORD Office Directors
represent their respective Laboratory Directors.
e. When the final resource decisions are made, ORD staff
prepare the narrative, outputs, workyear estimates, and
pricing in the formats required by the Office of the Comptroller
Budget Call Letter, for submission in early July.
OC staff enter all the data supporting the NW submissions into
the computerized Resource Management Information ( 4IS), a
data base and software system dedicated to support of the
budget process and managed by the Office of the Comptroller.
After the data are entered and edited for accuracy, various
Agency level composite computer compilations are generated.
In addition, DC staff review the justifications and prepare
issue papers for the Administrator and Deputy Administrator
to assist in their review of the budget document.
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—35—
The Administrator and Deputy Administrator conduct budget
hearings in late July. The hearings consume about 4 to 5
days over a 2—week period and include program by program
overviews followed by more specific discussions of the re-
sources requested for each decision unit. These sessions are
attended by Assistant Administrators, Office Directors, and
Lead Deputy Regional Administrators (who are present only
during the examination of their programs).
After the hearings, Office of the Comptroller staff develop
a revised set of funding recommendations, incorporating
decisions made by the Administrator and Deputy Administrator
during the hearings. This draft Agency budget is reviewed
with the Deputy Administrator, program by program, resulting
in a list of changes which OC incorporates in the budget for
review by the Administrator, who may direct further modifica-
tions. All approved changes are incorporated in the budget by
the OC (which process is known as the t4arkup”). Each Assist-
ant Administrator receives the section of the new version of
the Agency budget pertaining to his or her area of responsibili-
ty (the “Passback”).
Assistant Administrators have an opportunity to appeal their
Passbacks to the Administrator and the Deputy Administrator.
For the FY85 Budget, the Appeals were heard in a general
meeting with all Assistant Administrators present, with the
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—36 -
opportunity for separate, individual meetings if desired by
the Assistant Administrators. The Appeal decisions are
incorporated by OC into the Agency budget which is reviewed
by the Administrator and his or her Deputy.
This final Pasaback is distributed to the Assistant Adminis-
trators at the end of August to enable them to complete their
preparation of the narrative and tabular material for the
budget by the first week of September. OC staff review the
narratives, negotiate changes with each program office for
clarity and consistency, and put them in final form. All
changes to the tabular material are entered into the I 4IS for
final edits and production of final tables. The Agency’s
budget submission is delivered to the Office of Management
and Budget on September 15 in both a hardcopy version and a
computer tape version.
4B analysts conduct hearings with EPA officials over a 5— to
6—day period around the first week of October. The hearings
include an overview session with the Assistant Administrator
for Administration and Resources Management and Office of the
Comptroller staff, plus separate hearings with each program—
matic Assistant Administrator and staff, focusing on the
detailed substance of each program. In addition, U4B
analysts have frequent followup discussions with EPA staff
during their review of the submission. Based on these hear-
ings, followup discussions, and review of backup material,
the G1B analysts develop a group of proposed changes
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—37—
to the Agency’s budget (usually reductions), which they
present to the Director of 1B at the end of October.
After submission of the Agency’s budget to B, work con-
tinues on special analyses and exhibits, most of which will
be appended to the budget document when submitted to the
Congress by the President. These analyses are spelled out
in Q1B Circular A—li and include statistical and narrative
information on such topics as ADP and telecommunications
systems plans, research and development activities, civil
rights activities, rental payments to GSA, expenditure pro-
jections, Program and Financing Schedules (P&F Schedules),
consulting services and audio—visual services justifications,
etc. This material is voluminious and much of it is due by
the end of September, although some items such as outlay
projections and the P&F Schedules may be held until October
or November, when the accounting data for the prior fiscal
year become available. The statistical information for
these exhibits requires cross—cuts in different patterns
and aggregations from those used for the main budget document.
In some cases, an initial set of tables must be submitted
in September or early October, an updated set forwarded
late in November after G1B issues the Pasaback, and a
final update when the budget is completed in late December.
In addition to the A—il submission, the Agency is often
requested to submit special documentation, backup material
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—38—
and computer runs. One example is a lengthy computer
report presenting all the budget data by object
classification within each program element. This report
explodes each of the 304 program elements into three to
ten categories such as personnel compensation and benefits,
travel, transportation, rent, ADP contracts, grants, etc.
While the Office of the Comptroller is concentrating on
A—il submissions and related documents, Program Managers
turn their attention to the question of Regional resource
distribution. As mentioned earlier, the EPA budget request
to 1B contains an aggregated total for Regional resources
for each program. The existence of a Regional structure
requires some rational method for deciding precisely how
the workyears and funds should be distributed. Workload
models are the mechanisms used by EPA programs to make these
distributions. The concept of workload models originated
in the early years of EPA when the Regional structure was
new and there was no historical experience factor upon
which to base the allocation of resources. To decide on
the “correct” relative staffing for each Region, the program
offices sought objective criteria. Two basic types of
models evolved from this approach: “relative need” models
and “absolute need” models.
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—39—
Relative—need models use surrogate indicators of program needs
such as “population in the region” and “number of automobiles
in the region” and assign weights to each. When the actual
data are inserted and the computations made, the result is
a percentage which each Region should receive of the 100%
budgeted for Regional resources for that program. Obviously,
the validity of the distributions rests on the extent to
which the indicators actually reflect workload.
Absolute—need models are based on a inventory of the actual
program activities that planners identify as part of each
Region’s mission. The priority of the activities, an
estimate of tke workyear expenditure needed for each unit
of activity, and an estimate of the expected frequency of
occurrence for each activity are developed and factored
into the algorithm. Absolute—need models can be detailed
and complex. In some cases, the number of variables involved
can be so large that computers are used for the calculations.
The product of the models is a specific workyear total for
each Region (as opposed to a percentage). While these
models seem more realistic, being based on actual work
performed, the estimates for workyears—per—activity and
activity frequency are subjective and open to cha11ei e
when the results of model execution are unpopular. On the
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—40—
other hand, some managers find the analysis needed to
identify the spectrum of activities comprising each program
element to be useful for other management purposes. In any
case, most models in use today are absolute—need models.
Operation of the models is not automatic. A “calibration”
stage is added to modify the final results. For example,
absolute—need models quantify total need, which usually far
exceeds the workyears available in the budget. An adjustment
is needed to reduce the results to the actual available.
(Such an adjustment is not required for relative need models
since such models yield percentages rather than absolute
amounts.) Modelers may feel that for various reasons one
region received too much from the normal application of the
model’s algorithm and an adjustment is made. Or, use of the
model may result in too dramatic a shift from one year to
the next. To deal with these problems, modelers may give
weight to the historical distribution of resources, or they
may assign each Region a fixed “core” number of workyears
even if the model produces a lower “need”. Some models
have ceilings or floors added to keep the distributions
within some fixed percentage of change from the previous
year. Sometimes, subjective judgments are made to add or
subtract from a particular Region’s allocation.
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—41—
As this brief discussion of models indicates, they are not
fixed formulas that remain constant from year to year.
Rather, they are modified annually by National Program
Managers to adjust them to changing needs and to maintain
the confidence of Regional officials that each year’s
distribution is indeed fair. Accordingly, at about the
time that cJ1B is reviewing the Agency’s budget, some NR4s
begin their review of the parameters to be included in the
model when the time comes to distribute the resources.
As part of this review, they may request input from their
Regional counterparts as to the workload parameters they
consider appropriate. The extent of involvement of the
Regions in the model development and review process varies
from full participation by Regional workgroups at early
stages, to little participation, if any, depending on the pro-
gram. It might also be noted at this point that EPA does
not employ the resource models to determine workyear allocations
for Headquarters offices. The models are used only for Regional
distributions after the Headquarters/Regional “split” of the
total available resources is decided by the NW.
At about the same time, the Office of Management Systems and
Evaluation (a4SE) once again begins work on the planning
document known as the Administrator’s Guidance, which was
described above in month one of this analysis. The Adminis-
trator’s Guidance covers a 2—year time—frame and provides a
set of key objectives to be achieved by each organization
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—42—
in pursuit of the Agency’s goals. In the earlier description
for month one, FY85 was the later of the 2 years, i.e., the
Budget Year , and the Guidance for that year was relatively
general in nature, primarily an extension of the FY84 Guidance.
Now, with the first year of the cycle coming to a close, FY85
will soon become the Operating Year and the Guidance to be
developed is more detailed and specific. G’(SE analysts
draft a candidate list of 30—40 priority activities by
reference to the previous Guidance, the FY85 Budget justifi-
cation, various issue papers, Regional “Environmental
Management Reports” and other source materials. SE sends
the draft list for comment to Assistant Administrators,
Regional Administrators, representatives of the National
Governors Association (NGA), Executive Branch Organizations
(EBOs), and environmental and industrial groups.
Early in October, the Deputy Administrator reviews the
candidate list of priority activities with Assistant Adminis-
trators and Regional Administrators at a planning conference.
Additional meetings follow with the National Governors Associ-
ation, Executive Branch Organizations, and environmental
and industrial groups. The objective is to gain a consensus
of the participants as to the major environmental threats/
opportunities to be addressed over the next several years and
the specific activities to be given priority. Based on the
views expressed at these meetings, and the written comments
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submitted by Assistant Administrators and Regional Adm.tnis—
trators, Q4SE prepares a final priority list for review by
the Administrator and Deputy Administrator. 1SE begins
drafting the Administrator’s Guidance document based on
the decisions resulting from this review.
In accordance with the new Guidance process currently being
implemented, the draft Administrator’s Guidance is distribu-
ted in November, accompanied by a Call to the NNs to
develop detailed Program Guidance for the same 2—year
period (i.e., Operating Year and Budget Year). For the
Operating Year, the Program Guidance will be required to
address the Administrator’s goals and objectives and the
list of 30—35 priority activities. The Program Guid-
ance will also include a brief strategy paper (3 to 5
pages long) identifying the program’s mission, goals,
and program objectives for both of the target years.
The Administrator’s Guidance and the Program Guidance will
ultimately be combined into one Agency Guidance document to
be issued in February. That Guidance document will also
include a set of performance measures, reflecting the
program goals and priority activities to be included in
accountability systems for the Operating Year. In recent
years, there was no central control over the issuance of
Program Guidance (which covered only the Operating Year).
The NNs issued their directions in varying formats and
levels of detail and in differing time—frames. The new
procedure is designed to strengthen the Agency’s strategic
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—44—
planning and to provide the States a better basis for
planning and program implementation.
A major milestone in November is the issuance by 4B of the
changes in the EPA budget resulting from its review (the
“Passback”). The Passback is sent to the Agency in the
form of hardcopy and a computer tape for input to the 4IS
and consists of an overview section showing the new totals,
along with supporting data by program element. These are
expressed in terms of workyears and dollars requested vs.
the amounts approved by GIB. The (1 1B changes are explained
in footnotes.
The Office of the Comptroller enters the computerized data
into the R IS, analyzes the changes, and provides copies to
the Administrator, Deputy Administrator, and National
Program Managers (who receive only the portions relating to
their programs). An immediate decision (within 24 hours)
is needed from the Administrator on whether to Appeal the
(B passback and, if so, at what funding level the Appeal
should be focused. If it is decided to appeal, OC issues
guidance to the NPMs as to the Administrator’s views. The
N 1s develop their portions of the Appeal document and
submit it to OC for review, editing, consolidation and
submission to the Administrator for approval. The Appeal
must be forwarded to I4B within 5 days after the Passback
is issued.
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At about the same time, OC formally notifies the National
Program Managers to begin reviewing their workload models
in preparation for distributing the budget resources that
will ultimately be approved. Program Offices that have not
previously initiated this review now begin this process,
again with varying degrees of participation by the Regions.
Those NPMs that involve the Regions may convene working
groups of Regional representatives to examine the structure
of the model and develop updated versions that are broadly
acceptable to the Regions. Those NPMs that do not involve
the Regions, carry out the review with their own staffs.
Meanwhile, Q4B is reviewing the Agency’s Appeal and negotia-
ting with EPA officials on points at issue. The result of
this process is a second MB Passback in December, which
can also be appealed. Ultimately, any critical issues that
cannot be resolved may be appealed to the President by the
Administrator. When all issues are decided and a final
Passback is received from Q4B, OC updates the 1141S and
completes all the A—li Exhibits material to reflect the
final data.
The DC also sends a Congressional Budget Justification Call
Letter to the National Program Managers providing the general
policy guidance, the schedule, the format, and the editorial
instructions for production of the budget justification. The
Congressional Budget is produced in a different format from
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—46—
the budget submission to G(B and requires a higher standard
of editorial quality. The National Program Managers
compose their portions of the document (“Justification of
Appropriation Estimates for Committees on Appropriations”),
incorporating the resource data from the final Passback.
Because of the volume of budget justification rewriting and
the short time—frame for completion, NN work on models
takes a lover priority in December and January although
some Headquarters staff or Regional activity may continue.
Similarly, NR4 staff move ahead with development of the
detailed Program Guidance, but this too can be expected to
receive a lover level of attention during the writing of
the Congressional Budget.
In January, the Office of the Comptroller assembles the
Congressional Budget and arranges for printing of 600—650
copies to be distributed to the Authorization and Appropria-
tions Committees when the President submits his Budget to
the Congress. OC also prepares various public documents
such as a “Summary of the Budget” booklet, a press release,
and a special presentation of budget data for the press.
An EPA sponsored press conference is also held, with the
Administrator or other official explaining the major elements
of the proposed budget and responding to questions.
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The data in the President’s Budget are treated as highly
confidential by the Executive Branch until the formal
release. At EPA, recent policy has been to sharply
restrict access within the Agency until the January re-
lease date. For example, Assistant Administrators and
their staffs do not have access to the budget submissions
of other Assistant Administrators. At the Regional level,
Lead Regions usually have access only to the budget data of
programs for which they have lead responsibility.
As the first year of the budget cycle——the formulation
phase——comes to a close, then:
o The Agency has planned and constructed its budget
request;
o The budget request has been reviewed by 1B and a final
passback issued to the Agency;
o EPA staff have compiled the “A—li” material to be incorpora-
ted in the President’s Budget which has been sent to the
Congress; -
o The Agency has produced and distributed the Congressional
Budget justification;
o National Program Managers contemplate the mechanisms for
distribution of program resources to the Regions when the
budget is ultimately approved; and,
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° Q4SE has drafted the Administrator’s Guidance and Nation-
al Program Managers are developing their Program Guidance
to be combined into a single document for publication next
February.
Budget Review Stage
(Year 2 — Months 13 through 21)
The description of activities which unfolds for the months
ahead generally follows two tracks: An external track in
which the budget is defended before the Congress and an
internal track to prepare the Agency for the execution of
the budget in the next fiscal year. To place the internal
activities in perspective, a short introduction may be in
order.
The principal product of internal EPA budget activity in
the Budget Review stage is the Operating Plan , to be completed
before the start of the next fiscal year (now referred to as
the “Operating Year”). The Operating Plan contains the
detailed program element—by—program element targets for
workyears to be expended and dollars to be obligated in the
execution of the budget. These targets are divided into
Headquarters and Regional components and further subdivided
into the object classes for performance (personnel compensa—
tion and benefits; travel; equipment; supplies; etc.)
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The development of the Operating Plan recognizes that the
execution of the budget will begin 15 or 16 months after
budget formulation began. Some of the assumptions that
went into the formulation may no longer be valid. Priorities
may have changed. The Operating Plan development process
takes the numbers that resulted from the budget formulation
phase (i.e., the President’s Budget), reconsiders them in
the light of the changed situation and adjusts the program
- element amounts accordingly, while maintaining the appro-
priate totals requested in the President’e Budget.
When the Congress ultimately passes its version of the
Budget, a final revision of the Operating Plan will be made
to accommodate Congressional action on the President’s request
and the updated plan will be submitted to the 4B and the
Congress for approval. The result is, hopefully, a realistic
plan that can serve as a guide to operation in the Budget
Execution phase.
With the release of the official EPA budget statistics in the
President’s Budget, OC issues a call to the National Program
Managers to apply their workload models to the resource
totals for the 30 or so program elements that involve the
Regions, to disaggregate the totals into specific proposed
allocations for each Region.
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In parallel with this effort, the NPMs and OC begin develop-
ing backup material on program issues and detailed budget
matters in preparation for Congressional Hearings. This
effort includes anticipating questions that might be posed
at the Hearings and preparing responses referenced to the
appropriate pages in the budget document.
In early February, the NP!4s will complete their final
comments on the draft Administrator’s Guidance and their
own Program Guidance. The material is forwarded to ()(SE
f or review, with any unresolved issues referred to the
Deputy Administrator for decision.
Also in February, the Comptroller and program officials
brief the various Authorization Committee staffs on the
significant features of the EPA submission. The Committee
staffs need immediate data because the Congressional Budget
Resolution process requires them to be informed early in
the Congressional budget review cycle. In addition, one
Authorization Committee, the Senate Committee on Environment
and Public Works regularly schedules a hearing on the EPA
budget in February. The Administrator, Deputy Administrator,
and the Assistant Administrators (during review of their
programs) attend, give testimony, and respond to questions,
making use of the backup material supplied by the staff.
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Meanwhile, the National Program Managers apply their workload
models to the workyear totals in the President’s Budget to
produce proposed Regional resource distributions for their
programs. The 30—35 separate models yield 2 workyear
amounts for each program element for each Region: “Permanent
Full Time Equivalents” (PFTE) and “Other than Permanent
Full Time Equivalents” (OPFrE). When added, these comprise
the total resources allocated to the Region for that program
element, i.e., “Total Full Time Equivalents” (TFrE). The
allocated resources are expressed to tenths of a workyear.
An example of a proposed distribution of workyears for one
program element, “Hazardous Spill and Site Response” is
depicted in Figure 7.
FY84 Hazardous Spill and Site Response
REGION
I II
III
IV
V
VI
VII
VIII
IX
X
TOTAL
FY83
PFTE
17.1 32.0
20.0
26.6
31.7
19.9
11.0
7.2
16.7
7.3
189.5
OPF E
TFTE
2.1 3.6
19.2 35.6
2.6
22.6
3.8
30.4
6.0
37.7
3.0
22.9
1.4
12.4
0.9
8.1
2.6
19.3
1.0
8.3
27.0
216.5
FY84
PF E
17.1 32.7
21.2
24.9
32.9
18.2
11.0
8.0
15.0
8.5
189.5
OPF E
TFTE
2.0 4.2
19.1 36.9
3.4
24.6
3.5
28.4
6.8
39.7
2.7
20.9
1.7
12.7
1.1
9.1
2.4
17.4
1.8
10.3
29.6
219.1
Delta
PF E
0.0 +0.7
+1.2
—1.7
+1.2
—1.7
0.0
+.8
—1.7
+1.2
0.0
OPFr:E
TFTE
—.1 +0.6
—.1 +1.3
+0.8
+2.0
—0.3
—2.0
+0.8
+2.0
—0.3
—2.0
+0.3
+0.3
+.2
+1.0
—0.2
—1.9
+0.8
+2.0
+2.6
+2.6
Figure 7. Sample Workyear Distribution Proposal for One Program Element
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The sum of the distributions of PFrE and OPFI’E for each of
the 30 or so program elements administered at the Regional
level represents the total workyears allocated to each
Region for the coming fiscal year, assuming the President’s
Budget is accepted by the Congress. The National Program
Managers submit the proposed distributions to the Office of
the Comptroller where they are consolidated and sent to the
Regions for review. This is the first opportunity the
Regions have had to see the effect of the operation of
the models on their total workforce allocation for the
coming fiscal year.
The Regions examine each component of the distributions,
evaluating for each program whether the proportion of
resources allocated to Headquarters vs. the Regions is
reasonable and whether the relative workyear allocations
between Regions are equitable. If the NR4s involved the
Regions early and extensively in model development, a con-
sensus will usually have been reached previously, with few
remaining unresolved issues. For program element models
that did not involve substantial participation and prior
consensus, significant differences of opinion may still
exist. Accordingly, the review of the proposed resource
distributions is a critical milestone from the Regional
perspective and receives priority attention by Regional
staff.
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At the end of February, the Agency Guidance for the Operating
Year and the next Budget Year is published. This document,
whose purpose is to provide a strong foundation for planning
and program implementation by EPA components and by State
agencies, contains the following sections:
o Administrator’s Guidance : A statement of the Administrator’s
overarching goals, fundamental principles, and short— and long—
term goals.
• Deputy Administrator’s Overview : A statement summarizing
the major program initiatives and directions in the Guidance
document.
• Program Guidance : A statement by each of the four media
program offices of the general goals and specific objectives
for the Operating Year and the Budget Year including a brief
narrative strategy statement.
o Intermedia Priority List : The list of 30—35 priority acti-
vities developed over the previous months, reflecting the
most important objectives to be accomplished.
o Management Accountability System and Program Measures :
An appendix containing each program office’s performance
measures to be tracked quarterly in the Administrator’s
Management Accountability System (MAS) or by the Assistant
Administrator.
Simultaneously with the publication of the Agency’s planning
Guidance, the Office of the Comptroller issues a Call
letter formally initiating the Operating Plan development
process, which is divided into three phases. The initial
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Call letter deals with Phase I, which is focused on Head-
quarters offices. The Phase I effort simply distributes
the Assistant Administrator—level totals in the President’s
Budget to the subordinate Headquarters office levels. For
purposes of budget execution, the Assistant Administrators
are called “Responsible Planning and Implementation Officers”
(RPIOs). The subordinate office directors are “Allowance
Holders” who will receive and control the resources ultimately
approved in the final Operating Plan. (These terms are
discussed in more detail below.) The Assistant Administra-
tors submit these Phase I breakdowns to the Office of the
Comptroller in the first week of March.
Meanwhile, the Regional resource allocation process is
nearing completion. The Office of the Comptroller, serving
as “honest broker,” negotiates with the National Program
Managers and the Regional Administrators to resolve disagree-
ments. In an effort to achieve a Regional consensus, a
vote is taken on each model. If there are any unresolved
issues, the affected Regional Administrator sends an Appeal
memorandum to the Administrator who makes the final decisions
by mid-March.
If events follow a normal course, the House of Representatives
Subcommittee on HUD—Independent Agencies will hold hearings
in March. These are held over a 3—day period with the
Administrator, the Deputy, and the Assistant Administrators
in attendance. The Office of the Comptroller prepares the
Administrator’s statement. Program office and OC staff
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edit the transcripts resulting from the hearings, and pre-
pare responses to questions submitted for the record.
The Senate Subcommittee on HUD—Independent Agencies holds
its hearings after the House, generally in April. These
hearings normally are completed in 1 day, with the Admini—
istrator, Deputy Administrator, and Assistant Administrators
in attendance. Again, the Office of Comptroller prepares
the Administrator’s statement and Program offices and OC
staff edit the hearing transcript and prepare responses to
questions for the record.
With the completion of the Appeal process for the Regional
workyear allocations, the Office of the Comptroller makes
the final adjustments and computes the dollar distribution
targets for salaries and expenses for each program element
for each Region. At this point, the S&E targets are computed
in two broad categories: “Personnel Compensation and Benefits”
(PC&B) and “Expense”. OC makes these computations using recent
obligation data from the financial accounting syètem and
applying various adjustments. For example, the PC&B target
for FY83 was computed as follows:
o Take February actual obligations for PC&B
• Subtract cash awards obligated through February
(cash award policies and their magnitude vary
greatly between Regions.)
° Divide the balance by FTE actually used through February
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o Add $100.00 to each PC&B/FTE rate for future awards
(the Agency average), yielding adjusted PC&B per FTE rate
o Multiply FTE in workload model distribution by PC&B/FrE
rate yielding PC&B target for each program element for
each Region.
The Expense category involves a somewhat more complicated
formula yielding an Expense amount per Fit per Region,
which is then multiplied by the FTE in the model resource
distributions to produce Expense targets per program element
per Region.
OC also issues the NN distributions of contract funds and
State grant funds per program element per Region. The
combination of these extramural, program funds and the
intramural, S funds comprises the total available to each
Region for the coming fiscal year. The totals are identical
to the amounts for these categories included in the President’s
Budget. The Office of the Comptroller supplies these
targets to the Regions in the Phase II Operating Plan Call
Letter, which also includes similar targets for the Headquarters
offices. For Headquarters, the Fit and dollar distributions
for each office are the amounts that were previously furnished
to OC in response to the Phase I Call Letter.
The Phase II Operating Plan is an extremely important document
in the Agency’s budget process. It represents the first
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opportunity for National Program Managers and Regional
Administrators to realign their resources within the broad
totals contained in the President’s Budget. These changes
•are known as “reprogramings” and may include changes
between object classes within program elements as well as
changes between program elements. The objective is to
produce a realistic plan based on the latest information
available. This information includes the specific goals,
objectives, and priorities provided in the Agency’s
Guidance for the Operating Year, as well as lower levels of
detail such as unforeseen needs for equipment, contractual
services, training, etc.
The development of the Phase II Operating Plan submission
by each NR4 and Regional Administrator involves more than
simply rearranging totals, of course. For example, at the
Regions the process normally includes the preparation by
each Division of actual work plans for the Operating Year.
The generalized workyear values produced by resource models
must be translated Into actual positions and the names of
people assigned to them, vacancies for which recruitment
will be initiated, and reassignments that will be needed to
conform to the new distributions. Listings of equipment
that will be required, travel to be undertaken, and a
variety of other detailed Items of information will also be
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identified, reviewed, and consolidated with the personnel
data into realistic, overall organizational plans.
For the Regions, the Phase II data are consolidated locally,
reviewed at Regional Administrator levels and submitted
directly to the Office of the Comptroller. Assistant
Administrators at Headquarters do the same for their organi-
zational components. Each change from the original resource
levels for a program element must be separately justified in
this submission. Multiple changes in object classes within
program elements can be consolidated on a single change
form. All reprogramings must total to zero since the
figures in the President’s Budget are an absolute ceiling.
The Phase II submission also includes a memorandum highlight-
ing major program initiatives, policy or program differences
from the President’s Budget and changes that do not conform
to the targets included in the Call letter.
The Phase II submissions are received by the Office of the
Comptroller in mid-May. The data are edited for accuracy
and the changes are entered in the 1 1IS computer system.
The product is a detailed Agency Operating Plan for the
coming fiscal year. (This plan will also serve as the
baseline for the formulation phase of the next budget cycle.)
In June, the House of Representatives and the Senate may
begin their legislative actions on the EPA Appropriations
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Bill. The House usually completes action in June or July,
followed shortly thereafter by the Senate. The Office of
the Comptroller monitors and analyzes Congressional action
on the Bill to keep the EPA staff informed. CC also provides
additional analyses to Congressional staff when requested.
At about this time, National Program Managers turn their
attention to their program accountability systems that will
track performance when the new fiscal year begins. Program
accountability systems do not attempt to track every commit-
ment made in the budget document, since the budget commitments
are intended to account for 100% of the Agency’s resot ces,
including many tasks that are routine. Accordingly, low
priority budget items are ignored. Other items may be grouped
into larger aggregations.. Still others are represented but
expressed in terms of results and qualitative evaluations
rather than in terms of quantities of things to be done.
Program accountability systems can be very detailed. For
example, the Office of Water examines about 50 separate activi-
ties, with well over 100 quantitative measures and over 200
qualitative questions in the Regional evaluation section of
its accountability system. In order to prepare for the new
fiscal year, NB4s ask the Regions to submit their proposals
for measures to be tracked.
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At a higher level of review, the Agency has put in place the
Administrator’s Management Accountability System (MAS). The
MAS tracks several hundred measures of performance across the
Agency on a quarterly basis. A subset of the MAS accountability
measures is also committed to by each Assistant Administrator,
forming the basis for that official’s performance rating. MAS
performance measures are quantitative in nature or have definite
milestones for products. They may be identical or closely
related to the measures tracked by the program office systems.
The NAS performance measures were originally identif led and
approved as part of the Agency Guidance document issued In
February. In mid—summer, Q SE meets with the NR4s to
negotiate the specific number of outputs or milestone dates
to be committed for each measure in the MAS for the new year.
Meanwhile, if the House of Representatives and the Senate
have completed action on the Appropriations Bill by mid-
summer, a House—Senate Conference is held to resolve the
differences between the two versions and, if possible, pass
the legislation in each chamber before the August recess.
In August, the Office of the Comptroller issues a Call for
the Phase III version of the Operating Plan. This is a
further refinement of the Phase II plan, breaking out the
totals for each program element and object class into a
quarterly distribution. The Call also requests a detailed
contract plan, separately listing each action involving an
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obligation of $100 ,000 or more and summarizing actions
below $100,000, to show the processing schedule by quarter.
These plans are primarily for the use of the Contracts
Management Division in planning their workload for the
coming year. The schedule in the contract plan must be
consistent with the obligation pattern shown in the Operat-
ing Plan. Assistant Administrators (as “RPIOs”) and
Regional Administrators (as “Allowance Holders”) submit
these documents to the Office of the Comptroller in late
August and early September.
The NPMs and Regional Administrators also complete their
work on output measurements for the program—specific account-
ability systems and the Administrator’s Management Account-
ability System by the end of August. Final sets of output
commitments are negotiated for each system.
With the current fiscal year drawing to a close, the Office
of the Comptroller must estimate the unobligated balances
for those appropriations that will not expire on September 30.
These balances will be available for use in the next
fiscal year and must be reported to the Office of Management
and Budget for apportionment back to the Agency. The
estimates are derived by reviewing current unobligated
balances reflected in the Financial Management System (FMS)
and obligations expected to occur in the remainder of the
fiscal year.
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Assuming all Congressional action has been completed, and the
President is satisfied with the legislation, he signs the Bill
into law. The law may contain specific provisions restricting
Agency discretion, i.e., ceilings or floors on particular
programs or objects. The conference reports on the bills
may also contain restrictions, which, while they do not
have the force of law, are usually honored by the Executive
Branch agencies affected.
An example of a statutory restriction is the provision in the
current law that the Agency may not transfer funds out of the
PC&B account of the Salaries and Expenses Appropriation to any
other object class without approval by the House and Senate
Appropriations Committees.
An example of restrictions added in Committee and Conference
Reports is the provision that the Agency must obtain prior
Committee approval of any reprograining actions over a
certain threshhold. This amount is currently $500,000 for
the House and $250,000 for the Senate. From the standpoint
of change request processing, the lower limit is the effective
one since the change cannot be effected pending approval by
both Committees.
The Office of the Comptroller prepares a detailed analysis
of Congressional actions showing the funding approvals at
each legislative stage and the final amounts for each
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program. The analysis also lists each statutory and
Committee restriction applicable to the Agency for future
foil ow—u p.
With the enactment of the Appropriations Act, the Office
of the Comptroller adjusts the Operating Plan amounts to
incorporate the final Congressional action, submits the
Plan to the Office of Management and Budget and requests
apportionment of the funds. GIB acts on the apportionment
request through its review of the adjusted Operating Plan.
As they carry Out this review, Q’IB analysts often request
justifications for any significant changes from the Agency’s
earlier submission (as modified by Congressional action).
U4B may impose additional restrictions on the Agency down
to program element level through this apportionment proces8.
The Phase III Operating Plan is also submitted to the
Congressional Appropriations Committees since the Plan will
differ significantly from the President’s Budget and will
always exceed the reprograming threshholds set by the
Committees. One or both of the Committees may disapprove
particular changes and may add new restrictions on any
element.
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As the fiscal year comes to a close, the Office of the
Comptroller issues an end—of—year closing memo giving the
details of the review process for carryover funds and 4SE
issues the final “approved goals, objectives, commitments,
and TM measures” to be tracked by the Administrator’s Manage-
ment Accountability System.
To summarize the key events in this second year of the budget
cycle:
o The EPA budget, which became the President’s Budget,
was reviewed by the Congress, and ultimately became
law.
o The Administrator issued the Agency’s Guidance for the
Operating Year and the next Budget Year, including the
Administrator’s goals and objectives and detailed
Program Guidance.
° The Agency transformed the Budget into a specific,
detailed Operating Plan taking into account the latest
Guidance document and other new factors.
° The specific output indicators and levels of performance
to be tracked by the program offices and the &dministra—
tor’s Management Accountability System were developed
in a coordinated procedure.
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Budget Execution Phase
(Year 3 — Months 22 thru 36)
The fiscal year of Budget Execution begins on October First.
The appropriations made available by statute are distributed
to agencies by the Office of Management and Budget in
“Apportionments.” cMB’s apportionment of EPA funds is
based on the Operating Plan submitted by the Agency (as
described above). The apportionment authorizes the Agency
to obligate funds within whatever restrictions may be appli-
cable.
At EPA all funds are alloted to a single official, the Comp-
troller, the “Allotment Holder,” who is legally accountable
for assuring that obligations are made in accordance with
statutory requirements and that spending authority is not
exceeded.
This single Agency allotment is subdivided into “Allowances”
which provide authority to specific officials (“Allowance
Holders”) to commit and obligate specific portions of the
Agency’s Operating Plan. The Allowance Holders manage the
allowances and are responsible for staying within FTE
ceilings and fund ceilings. Allowances are issued by
appropriation and are supported by an operating plan detailing
the workyears and dollars available for each program element
and object class by fiscal quarter.
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Within a major organizational component such as a Region,
there will be several allowances. These allowances are
issued to the Allowance Holders through their organizational
chain of command. Within this framework, the Deputy adininia—
trator (for the Administrator’s staff offices), the Assistant
Administrators, and the Regional Administrators are designated
“Responsible Planning and Implementation Officers” (PPIOs)
for their organizational areas. The RPIOa are responsible
for developing and implementing operating plans, controlling
resource ceilings, and reviewing programs. Each RPIO is
also an Allowance Holder.
The flow of obligation authority from the Appropriation Act
to the Allowance Holder may be depicted as follows:
APPROPRIATION ACT
4B APPORTIOM4ENTS
Other __________ _________ Other
Agencies Agencies
EPA
ALLOThENT ROL1 R
I I I I
RPIO RPIO RPIO RPIO
ALLOWANCE ALLOWANCE ALLOW N E ALLOWAN Z
EOL RS HOL RS HOL RS HOL RS
Figure 8. Flow of Obligation Authority
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The allowance data whicb, up to now, have resided in the
Resources Management Information System (WIS) managed by
the Budget component of the Comptroller organization Is
transferred via magnetic tape to the agency’s accounting
system — the Financial Management System (FMS) managed by
the Financial Management Division. As Allowance Holders
begin committing and obligating funds, each transaction is
recorded in the PMS and applied against the specific program
element and object class account code to which it relates.
Salary costs and workyears expended are recorded in the
Department of the Interior Payroll System (“DIPS”) which is
currently processed for EPA by Interior. Plans are now
underway however, to bring the payroll system in—house.
Each EPA employee is assigned a “Fixed Account Number,” i.e.,
the program element to which his or her time and salary are
to be charged. If an employee works on more than one
program, DIPS provides for recording these additional
account numbers on the reverse of the time and attendance
card. This is particularly important for employees who
work on Superfund matters in addition to other program tasks
because Superfund salaries and expenses are included In
that appropriation rather than in the Agency’s Salaries and
Expenses appropriation and must be accounted for separately.
This need to account for Salaries and Expenses at the program
element level complicates the Allowance Holder’s control
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task and requires continual reconciliation of accounts in a
situation characterized by relatively high error rates in
the capture via DIPS of multiple account code charges.
Another factor complicating reconciliation is the fact that
the R4IS and the FMS computer systems have evolved separately
and the coding structures for each are not identical, requiring
crosswalk tables to relate the data in the two systems.
All of these systems problems are currently under review in
the Agency.
As the Current Year of Budget Execution continues, Allowance
Holders find that certain accounts do not have sufficient
resources to cover actual needs and they initiate change
requests to reprogram funds from one account to another in
the Operating Plan. These requests are submitted to the
Office of the Comptroller where they are reviewed for code
validity, arithmetic accuracy, and to determine if the change
exceeds Congressional, a4B, or Agency limitations.
If limitations are not exceeded, the changes are implemented,
i.e., they are entered into the (IS, revised allowances
are issued, and the new allowances are transferred by
computer tape to the FMS. If Congressional or B approval
is required, the reprograming is held in abeyance (any—
where from 1 to 3 months) while OC sends the request with
the necessary justification to the appropriate officials.
If approved, OC moves ahead to process the action.
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By November of the new fiscal year, OC has the final end—of—
year obligation data for the prior year, which is reported
to cI4B. The unobligated balances of multi—year appropriations
(“carryover funds”) are available for use in the current
fiscal year, in addition to the new obligational authority
provided by the recent Appropriations Act. Transactions,
such as contracts, which were in process at the end of the prior
fiscal year, but which were not executed, must now be repro-
cessed with current year funds or the Allowance Holder must
request sufficient carryover funds to cover them. Allowance
Holders may also submit justifications for other uses of
carryover funds to supplement their new obligational authority.
The requests for carryover funds are reviewed by the Office
of the Comptroller and an allocation pattern is recommended
to the Administrator for approval. Approved amounts are
issued in new allowances, incorporated in the I 4IS and
transferred to the accounting system via magnetic tape.
In January, the first of the quarterly accountability
milestones occurs. The National Program Managers collect
all the information needed f or the program—specific account-
ability systems and the Administrator’s Management Account-
ability System. The data are collected from Headquarters
and Regional data systems as well as from State information
sources.
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The MAS data are submitted to the Office of Management and
Systems Evaluation where they are analyzed and published in
a Management Accountability Report. The Deputy Administrator
discusses the output results with the Assistant Administrators,
who explain any significant deviations from prior commitments.
Some Regions produce Regional versions of the MAS report
depicting that Region’s subset of the data. The Regional
Administrators use these reports to review progress on the
programs under their jurisdiction.
The Administrator’s Management Accountability System also
provides for a change request procedure to modify output
commitments because of changed circumstances. These requests
are submitted to Q(SE by the Assistant Administrators and
approved requests are incorporated in the next quarterly
reporting cycle.
The cycle of Allowance Holder comin.ttment/obligation, review
of accounts, submission of change requests, issuance of
revised allowances by OC, and update of R IIS and FMS continues
throughout the fiscal year. In April, the Office of the
Comptroller conducts a mid—year review of the status of accounts.
OC projects workyears to be expended and dollars to be -
obligated through the end of fiscal year for each RPIO program
element. OC sends the data to Assistant Administrators and
Regional Administrators who may accept the projections or
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compute new estimates based on their knowledge of the local
situation. - The potential result of this review is a major
Agency reprograming action to reallocate workyears, funds,
and end—of—year ceilings among programs and organizations.
OC submits the proposed changes to the Administrator for
approval, seeks Congressional approval where necessary,
incorporates approved changes in a new Operating Plan,
enters the changes in the R4IS, issues new allowances, and
transfers the information to the FMS for accounting purposes.
If any reprogram.tngs require Congressional approval, they
are referred to the Committees and are held in abeyance
until Committee approvals are obtained.
In the April-May time—frame, the second quarterly accountability
reporting cycle is completed. In this cycle and in the
fourth quarter, it is planned that the Deputy Administrator
will meet with Regional Administrators as well as Assistant
Administrators to discuss progress on output commitments.
As the fiscal year nears completion in August and September,
the pace of Operating Plan change requests picks up as
Allowance Holders seek to make optimum use of their resources.
The Office of Comptroller-issues an end—of—year closing memo-
randum detailing the dates for final changes to the Operating
Plan and the schedule for closeout activities in the accounting
system. An interim “12th month” reconciliation is performed,
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followed by a final “13th month” closeout, officially
bringing the fiscal year to a conclusion.
In early November, the Office of the Comptroller conducts
an end—of—year analysis of the accounting data to analyze
actual vs. planned obligations for each program element, to
identify the causes of any delays in use of contract funds,
to identify any allowances that may have been exceeded and
so on. OC factors these analyses into the issuance of
carryover funds, into the budget execution for the fiscal
year just beginning, and into the formulation phase of the
next budget cycle.
The followup stage of the FY85 budget cycle is completed
shortly thereafter with the production of the final Manage-
ment Accountability Report and the Deputy Administrator’s
discussion of the output results with the Assistant Adminis-
trators and Regional Administrators. The Office of Manage-
ment Systems and Evaluation will review the operation of
the MAS to identify systemic changes that should be incor-
porated in the next cycle. The experience gained will also
influence the development of Administrator’s Guidance for
the next cycle.
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IV. FINDINGS AND RECOIMENDATIONS
In the pages that follow, the Panel-will address various
issues identified in the Study of the EPA Budget Process,
along with recommendations for improvement. To put these
findings and recommendations in perspective, however, it
needs to be stated at the outset that the Study interviews
and document reviews clearly indicate that the EPA budget
process is fundamentally sound :
o EPA top management finds the process useful for internal
program planning and decision—making.
o Budget estimates are based on careful workload analyses
and specific planned accomplishments.
o Budget formulation is focused at EPA Headquarters,
but serious efforts are made to assure that all levels of
management participate.
o The EPA budget and accounting structure provides for
the stewardship of funds in accordance with sections of
the authorizing statutes and effective mechanisms are in
place to control budget execution both at Headquarters
and in the field.
o Formal accountability systems are employed to monitor
performance of the Agency in its execution of commitments
made in planning and budget documents.
o Representatives of the Office of Management and Budget
advise that the EPA budget document and supporting data
facilitate Executive Branch review and decision—making.
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o Staff representatives of the Appropriations Committees
of the Senate and the House of Representatives report that
the EPA budget submission satisfies their review and oversight
requirements.
‘On the other hand, the Academy study also found a high level
of frustration with the budget process among EPA employees——a
perception that the process impedes effective management
and requires excessive time and effort to administer. To
some extent, these views are simply a reflection of problems
in the Federal budget process that are beyond the ability
of the Agency to redress and beyond the scope of this
Study. These problems are addressed in the recent MAPA
report “Revitalizing Federal Management: managers and their
overburdened systems” and the changes suggested in that report
would materially improve the budget process at EPA.
The negative perceptions are also an understandable reaction
to the recent history of EPA, characterized by major shifts
in leadership, organization, and policy, coupled with
severe workforce retrenchments. As the instrument for much
of this change, the Agency’s planning and budget process
was the focus for much of the associated conflict and
tension. Present EPA management is restoring employee
confidence in the Agency’s management systems. If these
moves prove successful, perceptions related to the budget
process will also be favorably affected.
Some of the negative views expressed by EPA staff represent
a residual dissatisfaction with the EPA implementation of
Zero—Based Budgeting (ZBB). The EPA ZBB process required
massive documentation, multiple iterations, and the
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deliberation of many ranking committees. In the view of
most employees interviewed, in spite of all the extra
effort, the quality of the budget was not improved. EPA
has now discarded the ZBB process and has moved to reduce
the workload burden in the formulation of the budget.
These steps are perceived as important improvements by
most employees.
Finally, it should be noted that present EPA top management
has initiated a broad reexamination of the Agency’s manage-
ment systems. Some studies, such as the review of the
statutory basis for the Agency’s programs, were still
underway as this NAPA Budget Study came to a close. Others
have already led to significant new policies and procedures.
For example, the new strategic planning system, the
expanded participation of management officials in the
planning and budget process, and the improvements in the
Administrator’s Management Accountability System, will
ultimately have a positive impact on the management of the
Agency, as they are implemented.
In summary, then, the EPA budget process is basically sound
and management attention has been. focused on making further
improvements in the system. Within this framework, the Panel
has identif led twelve subject areas where change might further
enhance the system and enable it to contribute more
effectively to the accomplishment of the Agency’s mission.
Statutory Complexity
The Environmental Protection Agency was established as an
Independent Agency in the Executive Branch on December 2,
1970, by Presidential Reorganization Plan No. 3 of 1970.
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The objective was to provide a unified organizational
focus for the environmental programs that had been assigned
to various agencies and offices within the Department of
Interior, the Department of Health, Education and Welfare,
the Department of Agriculture, and the Atomic Energy
Commission. The creation of EPA by Reorganization Plan
rather than by statute left the new Agency without an
organic act providing a unified statement of National
goals for the environment or a comprehensive regulatory
authority with which to systematically and logically execute
its mandate.
In place of an organic act, EPA inherited an array of
governing statutes by virtue of the transfers of authority
fr the predecessor organizations. These statutes and
those enacted after EPA’s creation provide specific
directions addressing singularly defined environmenta1
problems such as water pollution or waste disposal, with
requirements often spelled out in minute detail. The
accumulation of these distinct, narrowly focused statutes
has produced an extensive, overlapping, and inconsistent
body of law, whose complexity is compounded by the mass of
legislative history behind each statute and the subsequent
actions of the courts.
Significant progress has been made toward accomplishing
the major programmatic objectives of some statutes such
as the Clean Air, Clean Water, and Noise Control Acts.
Other laws such as the Toxic Substances Control Act and•
the Comprehensive Environmental Response, Compensation
and Liability Act have Introduced new objectives that
will occupy center stage for years to come. Still another
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generation of narrowly focused legislation is on the
horizon to deal with such more recently defined threats
as acid rain and indoor air pollution. Clearly, then, a
steady state of legislative mandate for EPA has not been
achieved. The substance and focus of environmental law
will continue to change as public awareness and understand-
ing of the problems mature.
Congressional oversight of EPA is carried on by 19 Committees
and Subcommittees in the House of Representatives and 7
in the Senate. EPA officials are routinely required to
testify before these committees, with the number of
separate appearances averaging about 90 per year. Most
of the authorization provisions of the controlling EPA
statutes have expired and new statutes are currently under
consideration. Until the Congress enacts new provisions,
interim reauthorizations are reflected in the annual
appropriation acts that provide EPA the funds to carry on
its mission.
Although the individual statutes governing EPA’s mission
focus on particular media or pollutants and establish
goals and objectives peculiar to each, they employ very
similar remedial techniques such as State assistance,
research and development, permitting, standard setting,
and enforcement. Unfortunately, the similar provisions in
each Act differ substantially in formulas to be applied,
administrative procedures to be used, application require-
ments, legal processes, and so on. These differing
statutory approaches to the same provisions have complicated
the management of the Agency and its relationships with
the States and the other organizations affected by its work.
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EPA has attempted to rationalize these processes and minimize
the overlap, duplication, and inconsistency, within the
boundaries of the statutory provisions, kit has met with
only limited success.
The EPA experience with the State assistance provisions is
a good case study illustrating the general problem. In
1970, EPA began with three types of State assistance
program grants, inherited from its predecessor agencies.
By 1980, new legislation had increased the number of
media—specific, targeted, State assistance categorical
grants to sixteen, defined by various legislative authoriza-
tions. As a consequence, a separate State Grant application
was required for each program in order to accommodate the
different statutory requirements and formulas. Grant
funds received from one program could not be transferred to
another, making it difficult for States to address cross—media
pollution control problems. In 1980, the Senate Subcommittee
on Environmental Pollution held hearings on the “Integrated
Environmental Assistance Act” whose purpose was “to
authorize a flexible environmental program of integrated
financial assistance to States and local governments to
plan, manage and implement abatement and control strategies
in a more efficient and effective manner.” In testimony
before the Subcommittee, Douglas 14. Costle, former EPA
Administrator, characterized the problem of vertically
structured, media—specific grant provisions as follows:
“Our programs must be implemented through
separate, often uncoordinated categorical
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grants. This process makes cross—program
collaboration difficult and trade—off s
almost impossible. This familiar pattern
is constantly reinforced by the numerous,
different and characteristically narrow
requirements of our grants. I believe
one part of our answer must be effective
integration across our environmental
programs. -
The Integrated Environmental Assistance Act would have
permitted State and local governments to aubmit an integrated
plan for two or more categorical programs and to shift up
to 20% of the grant funds from one program to another.
Under this bill, a single grant application and a single
State effort requirement replaced the different matching
funds requirements in the current laws. The expected
results of the bill were better State and local government
plans addressing the interrelationships between the media
and crosscategory problems, with simplified and more
streamlined administration of the programs. The proposed
bill had strong support from EPA, State officials, and
environmental groups but did not move beyond the Hearings
stage.
In an effort to alleviate the problem through administrative
action, the Agency explored a “consolidated grant” approach
under which State or local governments submit a single
application and receive a single consolidated award for
two or more pollution control programs (Out of a list of
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seven candidate programs). Although a single application
is permitted, each program component of the consolidated
grant is separately described, the separate formula and
matching requirements of each program still apply, the pro-
gram components of the consolidated grants must be separa-
tely accounted for and funds may not be reprogrammed from
one program component to another within such grants.
Accordingly, the benefits of the administratively implemented
consolidated grant are minimal and it is clear that the
full potential of the concept cannot be realized without
legislation.
The complexity of the EPA statutory framework is directly
reflected in the budget process. As noted earlier, the
statutes address specific media or pollutant threats. As
the broadest definition of the activities of the Agency,
these media categories represent an important high level
of aggregation for purposes of budget and accounting.
The various sections of the enabling statutes defining
program activities (such as State assistance; permits and
licenses; and enforcement) when taken in combination with
the broad activity groupings defined by the annual appropria-
tions acts (e.g., research and development; abatement,
control and compliance; construction grants; etc.) require
complex crosscutting aggregations of data in thebudg4t
and accounting systems.
The “program element” is the principal building block for
budget formulation and execution. Budget justifications
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are written at the program element level and “rolled up’
in various combinations as needs dictate. There are 304
of these elements in the FY84 EPA program budget structure.
About 30 of these elements pertaining to EPA Regional
activities must be further subdivided into ten components——
one for each Region——adding 300 more control categories to
the structure. For execution purposes, program elements
are further exploded into three to ten object class
categories such as personnel compensation and benefits,
travel, transportation, rent, ADP contracts, grants,
etc., creating thousands of accounting control categories.
One obvious effect of the “pigeonholing” of funds is, of
course, the excessive time and effort expended in recording
and reconciling accounts. The problem is magnified,
however, by Congressional restrictions on transferring
funds from one program element to another, from certain
object classes to others, from Superfund administrative
categories to non—Superfund categories and so on. The
cumulative effect is to tie the hands of managers and
limit their ability to use their resources efficiently.
In summary, then, the complex statutory framework for admin-
istering the EPA mission impedes effective management at
both Federal and State levels. The Panel is in general
agreement that merging these statutes into one simplified
organic act offers an attractive solution but that such a
merger is not a practical choice at this time. Each of
the existing separate statutes contains controversial pro—
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visions, supported and opposed by powerful, polarized
advocacy groups. A proposal to merge these controversial
statutes into one piece of legislation——a step that would
also require major shifts in Congressional Committee
jurisdictions——has no reasonable prospect for success.
In any case, the fundamental problem with the existing array
of statutes is not so much their number, but their completely
uncoordinated and inconsistent administrative requirements
and procedures for similar program functions. The solution
lies in somehow rationalizing these provisions horizontally,
across all the statutes. Accordingly,
o The NAPA Panel recommends that the EPA and the Authori-
zing Committees of the Congress work together to enact
legislation that provides consistent language in the
environmental statutes for such common functions as
State assistance, research and development, permitting,
standard—setting, enforcement, and administrative
procedure .
This recommendation builds on the concept of streamlined and
more flexible cross—media procedures inherent in the
proposed Integrated Environmental Assistance Act, expanding
the idea to encompass all or most of the common administrative
and management functions in the Agency’s statutes. An
important advantage of the proposal is that it leaves the
Congressional Committee overs1 ht structure and the
Agency’s organization unaffected.
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The review of the EPA statutes recently initiated by
Administrator Ruckeishaus is expected to produce the
necessary analytical basis for proposing legislative
changes. If the scope of the Study includes an examina-
tion of the common provisions in the present laws and
the development of standardized substitute language, the
Agency and the Executive Branch wIll be in an excellent
position to help the Congress rationalize the statutes.
Model provisions could be implemented in two ways. They
could be proposed as replacements for the equivalent
provisions as each statute comes up for renewal. Or,
they could be combined for enactment as a separate statute
that would immediately super cede the equivalent provisions
in all the present statutes at the same time. The Panel
recommends the latter approach since it would solve a
serious problem relatively quickly, while the modification
of each statute in Its own time—frame could take years to
complete. A single statute containing the model provisions
can also be viewed as “purifying” the media—specific
statutes by eliminating much of the administrative detail
from those Acts and letting them focus on the substance of
National policy toward the environment. It might also be
observed that a single statute containing the rationalized
administrative and management provisions has a potential
for evolving in time into a streamlined version of an
organic act. Such a statute would spell Out the fundamental
responsibilities and authorities of the Agency, but would
leave the individual media—oriented statutes in place.
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Strategic Planning
Interviews with EPA managers and the review of budget process
documentation Indicate that the Agency has not had a formal,
continuing process f or examining the longer—term strategic
Implications of current program decisions. Agency planning
has been focused on the short—term decisions required for
budget and operating plan preparation.
The annual Administrator’s Guidance issued in February of
each year has provided summary level goals and objectives
for the upcoming operating year but only minimal direction
for budget formulation. The responsibility for detailed
program guidance has been delegated to the National Program
Managers but their guidance has usually been focused solely
on the coming year and has varied greatly in format and
timing. Because Program Guidance for even one year into
the future Is very useful to the States in formulating
their plans, the unpredictable availability of this inf or—
mation on a timely basiG has caused problems in meshing
State and Federal planning.
With annual Program Guidance focused on short—term affects,
the Agency has had no mechanism for identifying and communica-
ting the need for strategic shifts in emphasis in areas such
as Research and Development, State assistance and oversight,
Enforcement and Compliance, etc. The absence of strategic
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planning has made integrated priority setting very difficult
and the net effect has been a process in which short—term
budget goals tend to drive program decision—making rather
than having long—range goals drive the budget decisions.
At about the time that the MAPA/EPA Budget Process Study was
analyzing these planning weaknesses, the Agency was considering
possible changes to improve the situation. The Deputy Adminis-
trator met with members of the MAPA Panel to exchange views on
the subject and to discuss specific actions that might strengthen
the Agency’s planning process. Subsequently, the Agency
adopted a new approach to the annual guidance process,
specifically addressing the weaknesses described above.
The salient features of the new process may be stnntnRrized
as follows:
• A single “Agency Guidance” document issued in February
will replace the present system of Administrator’s Guidance
issued in February and various types of separate Program
Guidance published in subsequent months. EPA Regional
officials and State officials will have an opportunity to
influence the content of the document by receiving early
drafts for comment.
• The Guidance document will cover a 2—year period consist-
ing of the approaching Operating Year and the following
Budget Year, effectively expanding the horizon of Program
Guidance from the present 1—year frame of reference.
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• For the Operating Year, the Program Guidance will be
required to address a specific list of 30—35 priority
activities. This list is developed through discussions
and negotiations between the Deputy Administrator, the
Assistant Administrators, Regional Administrators, and
outside groups.
• The Program Guidance component will also include a brief
narrative strategy paper (3 to 5 pages long) identifying the
program’s mission, goals, and program objectives for both
of the target years.
• The Guidance document will include a set of performance
measures, reflecting the program goals and priority activi-
ties to be included in accountability systems for the Opera-
ting Year.
When implemented, these changes will materially strengthen the
Agency’s planning posture and will also provide a better basis
for planning and program implementation at the State level. On
the other hand, some persons interviewed during the Study sug-
gested that the Agency needs longer term strategic planning——
in a 4— or 5—year time—frame——rather than the 2—year scale
being implemented.
The Panel considered this point and concluded that while
selected programs might benefit from longer-term planning,
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others would not, so that an across—the—board requirement
for 4— or 5—year plans would create an unnecessary paper
processing burden. The Panel also considers that the
Agency needs to develop some experience with the 2—year
planning framework now contemplated before deciding whether
Agency—wide, longer term projections (perhaps to 3 years)
would be beneficial. Accordingly
• The NAPA Panel endorses implementation of the Guidance
and Strategic Planning changes outlined in the Deputy
Administrator’s Memorandum of November 2, 1983. The
Panel also recommends that one or two strategies be
selected annually for analysis of longer term (3—5 year)
trends.
Complexity and Detail in the Budget Document
Specific criticisms of the EPA budget submission to the
Office of Management and Budget are that the documentation
required is overly lengthy and detailed; that the time and
effort expended in preparing the material are burdensome
and excessive; and that the detail in the resulting document
leads to 1B examination at very low levels of Agency
activity which can result in restrictions in Agency f].exi—
bill ty.
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Interviews with EPA employees suggest that many of the
negative perceptions about excessive documentation and
workload are residual reactions to the Agency s implemen-
tation of Zero—Based Budgeting (ZBB) concepts in the late
1970s. The ZBB process required managers to develop lists
of prioritized activities within “decision units” and to
estimate, with documentation, the resources needed for each
unit, at four or more levels of funding (0 to 75% of current
year; 75 to 90%; 90 to 100%; 100 to 110%; etc ,). These
hundreds of organizational and program priorities were
combined into a single Agency listing through a series of
five rankings:
• The Deputy Administrator and Assistant Administrators
ranked all the decision unit levels falling under their
organizational responsibility.
• The Regional Administrators performed two rankings——
individual and collective——to produce a Regional con—
sensus on Regional programs cutting across all the media.
• Special Media Task Groups ranked decision units,
pertinent to each medium, whose programs might cut across
the entire Agency’s organizational structure.
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• Intermedia Ranking, performed by the Comptroller’s
Office, combined all the Media Task Group rankings into a
single draft ranking table.
• An Agency Ranking Committee prepared a final version
of the intermedia ranking for review by the Administrator.
A few persons interviewed in the Study felt that the cross—
media ranking process was a valuable contribution to the
Agency’s formulation process. Most people, however, felt
that EPA implementation of ZBB was too complicated,
that the process did not materially imiSrove the Agency’s
budget submission and that the cost far exceeded any
benefits. The elimination of ZBB was welcomed almost
unanimously and this management decision has been cited
more than any other action as a major improvement in the
budget process at EPA. It is clear that a return to ZBB
would be counterproductive.
As presently configured, the EPA budget prepared for
4B contains documentation for each of 212 programs
in the budget structure. (Note: some programs are
funded from two appropriation sources. For purposes of
budget justification, the two “program elements” in such
cases are combined into one “budget element.” For the
overall EPA budget structure, then, the 304 program
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elements translate to 212 budget elements.) The documenta-
tion consists of three basic forms:
• A “BUD #1” form summarizing the workyears and intra-
mural/extramural funds requested for the program,
along with a comparison of these amounts with those
approved in the two prior years;
• One or more pages of “BUD #lA ” forms containing the
narrative justification for the program——its goals and
objectives, a description of current operations and
expected accomplishments, and an explanation of changes
from the prior year’s budget;
• One or more pages of “BUD #2” pricing analysis forms
that depict every activity the Agency expects to perform
under that program in the budget year. For each activity,
a set of performance measures (“accomplishments”) is
defined, and, for each accomplishment, a particular
level of performance (an “output”) is committed to for
the number of workyears requested.
The Agency has recently been moving in the direction of
simplification of its budget submission. On a macro level,
within the limitations imposed by the statutory framework,
EPA has simplified its budget and accounting structure by
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reducing the number of program elements needed to depict
the Agency’s mission. For example, between FY83 and FY84,
the number of elements has been reduced from 327 to 304,
one effect of which will be to reduce the number of pages
of budget documentation in future submissions.
Within the budget document itself, considerable stress has
been laid on improving the content of the BUD lÀ section
of the budget submission. Shorter, more succinct narra-
tives have been achieved and the gross size of the budget,
in terms of number of pages, has been reduced about 22%
between FY83 and FY85.
The hundreds of pages of BUD 2 forms in the EPA budget,
with their detailed listing of planned activities and
projected accomplishments comprise a large percentage of
the EPA budget documentation. The outputs—per—workyear
committed in the BUD 2 are usually derived from analysis
of actual workload data for the previous year. For new
activities, estimates are developed of the time it will
take to complete a unit of work. The following excerpt
from the FY84 budget submission for one program element
illustrates the level of detail contained in these docu-
ments.
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DU CODE FAY9A HQ _____ RT X DU TITLE Hazardous Spill and Site Response
RESPONSIBLE OFFICE Office of Solid Waste and Emergency Response
DOLLAR PRICING IS EXTRAJIURAL ONLY (CONTRACTS. GRANTS AND tAG DOLLARS ONLY)
FY 1982 FT 1983 FT 1984
ACTIV ITIES/ PROJ ACTUALS OPER. PLAN REQUEST
£ C0MPLISHMENTS OUT— OUT— OUT—
___________________ FTE $ PUT F E $ PUT FTE $ PUT
l. tEDIAL 88.2 103.4 127.1
Prel icni nary
Assessment 3.4 962.8 1,500 9.1 4,277.0 4,000 9.1 4,000
Site Inspections 11.8 4,187.6 1,300 18.2 10,678.4 2,000 18.2 2,000
Site Investiga 14.5 6,449.6 400 7.3 5,339.2 200 7.3 200
tion
National Priority
List 7.5 4.0 2.5
Remedial
Investigatlons/
Feasibility
Studies 27.1 14,676.0 36 40.1 32,000.0 40 48.0 49,378.7 55
Remedial Design 5.8 5,135.0 13 7.1 8,200.0 24 17.5 15,264.2 40
Remedial
ImplementatiOn 6.8 26,894.0 10 3.1 48,361.4 11 9.5 110,449.2 22
Initial Remedial
Measure 2.5 11,666.0 12 4.5 7,500.0 15 5.0 11,217.7 20
Enforcement
Coordination 5.0 5.0 5.0
In combination, these forms represent a comprehensive
functional analysis that accounts for 100% of the Agency’s
resources. The analysis requires substantial effort and
increases the volume of data in the budget. On the other
hand, it yields benefits that may be worth the effort:
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-The BUD 2 forms clearly depict the relationship
between work to be performed and the resources needed to
accomplish the work. The listing of these commitments
in the budget document, juxtaposed with the commitments
made in two prior years constitutes an important budget
accountability mechanism. The fact that program offices
must be prepared to explain any significant deviations
from one year to the next to Agency officials reviewing
the submission, and later to 1B examiners, helps to
promote the development of realistic estimates.
The functional analyses needed to produce the BUD 2
forms require each manager to think about his or her
program and to communicate to others the goals and
expectations for that program beyond the current year.
This communication and longer—term view are management
benefits that transcend the budget process.
Accordingly, although it would be possible to reduce the EPA
budget workload by limiting the document to the pricing out of
workyears and dollars at high levels of program aggregation,
such a change would lose the additional benefits of work
planning and accountability that are now av4lable as a
by—product of the process and that are well worth preserving.
On the other hand, the descriptions of activities and
accomplishments in the BUD 2 forms have sometimes been
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carried to a much finer level of detail than is needed,
causing the budget review to take place at a transactional
level. The ‘guidance” resulting from such review can
overly restrict flexibility in budget execution. Some
programs have moved to reduce the nuniber of separate
activities/ accomplishments listed in the BUD 2 sections of
their submissions by coi btning them into some at larger
groupings. If this effort continues, it will not only
simplify formulation of the budget material, but may move
the Agency and 1B budget review process to a higher, more
meaningful level of program detail.
After weighing these factors, the NAPA Panel’s snmm ry
conclusions are that the principal sources of employee
frustration with EPA budget complexity and detail have been
resolved by the Agency within discretionary limits; that
the benefits of workload analysis as a basis for budget
formulation are worth the time and effort involved; and,
that simplifications currently underway will further improve
the EPA budget document. Accordingly,
o The Panel endorses the Agency’s decision to eliminate
the EPA implementation of Zero—Based Budgetit g .
o The Panel recommends that the Agency continue to base
its budget formulation on functional analysis so as to
retain the management benefits that accrue therefrom .
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° The Panel recommends that the Agency continue to move
toward fewer program elements in the budget structure,
more concise budget narratives, and a somewhat higher
level of aggregration of activities and accomplishments
in the budget pricing analysis.
Regional Office Participation in the Budget Process
The functions of the Environmental Protection Agency are
carried out by a combination of Headquarters and field organ-
izations. At the Headquarters level, -the programs defined in
the enabling statutes are assigned to five Assistant Adminis-
trators who, as “National Program Managers” are responsible
for program planning and implementation.
Agency Regional programs are implemented at ten Regional
Offices managed by Regional Administrators who report to the
Administrator of EPA in a line capacity. Regional Adminis-
trators represent the Administrator in contacts and relation-
ships with public and private groups in the Region and are
responsible for accomplishing the national program object-
ives established at EPA Headquarters.
The budget formulation process is dominated by the National
Program Managers at Headquarters. The NR4s are responsible
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f or bringing together the component parts of a program budget
and for defending their portions of the Agency budget as it
moves through the review cycle. For those parts of the
national programs carried out in the Regions the NPMs are
expected to produce the budget estimates in collaboration
with the Regional offices. The question of what form this
Regional participation in the budget process should take
has been the subject of much discussion at EPA over the
years, and various methods have been employed. The method
currently in use is known as the “Lead Region” concept.
The EPA Task Force on Headquarters/Regional Relationships
described this approach as follows:
“With development of the FY 1983 budget, the Zero—
Based Budgeting process, with its layers of review
and ranking teams, was replaced with a centralized
and shortened process. The nature of the regional
role changed, from participation on a variety of
ranking committees, to the interaction of lead Deputy
Regional Administrators (DRA) with National Program
Managers (NR4s) during the budget formulation process
and in the budget hearings themselves. The lead Region
concept evolved as an efficient, productive method to
represent regional concerns and interests in the new
process.
The National Program Manager is charged with develop-
ing the request for the regional component of his or
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her program in conjunction with the lead Region for
each media. The lead Deputy Regional Administrator is
charged with becoming the media ‘experts’ and with
objectively representing the ten regional program needs
and viewpoints, while at the same time maintaining a
national perspective on the program.
During the summer budget hearings, the lead Region
represents all the regions as the MN presents his or
her budget request before the Administrator and Deputy
Administrator. During the final preparation of the (MB
request and the (MB passback and appeal process, the
regional interests are carried largely by the Comptroller
and the NPMs. The Comptroller’s Office is responsible for
maintaining an information flow to the Regions for each
step of the process.”
There is not complete agreement on the success of the Lead
Region concept as reported by the Headquarters/Regional
Relationship Task Force.
“The criticisms most frequently heard of the current
budget development process, from the regional perapec—
tive, are:
• The extent and effectiveness of lead Region
‘participation’ is too dependent on the whim of the
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NPM. Participation ranges from extensive regional
involvement to total exclusion.
• The degree of lead DR& participation varies greatly
depending on a number of factors including time and
staff availability.
o Lead Regions are in a ‘reactive’ mode from the
very start of the process; very few NNs involve
the regions in the initial development of the
regional budget request. For the moet part, the
Regions see N drafts or initial allocations after
the N 1 has virtually finalized his or her decisions.
Scarce regional resources make it difficult for
Regions to react in a short timeframe.
o Lead Regions are not in a strong enough position to
have much impact on Headquarters/Regional splits in
allocation of resources because budget guidance for
program development is unclear.
• Some lead Regions involve their fellow Regions
early in the development of the request, others
involve their counterparts too late in the
process or not at all. The process lacks
structure. Non—lead Regions who see the
budget requests for the first time in final
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form are presented with a ‘f alt accompli’ which is
difficult to change.
o The scrutiny which regional programs receive by
Read uarters offices should be balanced —— Regions
should have an opportunity to examine Headquarters
resource allocations and comment on them.
o Since the ‘targets’ issued at the start of the process
are at the NRI level, there is a tendency to think of
an increase in the regional program as being at ‘the
expense’ of a Headquarters prggram or vice versa. As
a result, there is a tendency to make changes at the
margin rather than to discuss the merits of resource
specific allocations.
o Regions don’t always know if budget comments will have
an effect until the final agency budget is prepared.”
The Task Force concluded that the lead Region approach should be
preserved, but made several recommendations for Btrengthing the
process. These recommendations and’ associated excerpts from
the report are:
Responsibilities of the National Program Manager and
Lead Deputy Regional Administrator Should be Better
Defined
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As noted earlier, there is little formal guidance
to the NW or lead Regions on how effective regional
involvement is to be achieved. The resulting incon-
sistency could be limited by formalizing internal
budget development procedures.
Specifically, this could be accomplished by the
Deputy Administrator through issuance of schedules,
specification of interim products, and definition of
a detailed process for development of the budget by
the NW. This would define the nature of involvement
by the lead Region and the nature and timing of
involvement of non—lead Regions. The final NW
budget submission would be accompanied by a memoran-
dum from the lead Region expressing the regional
view of issues in the regional as well as Headquarters
portion of the request...
Regional Budget Development Meetings Should Be Held
Prior to Development of the National Program Managers
Submission and Before Finalization of the Administra-
tor’s Budget
An additional technique to promote full involvement
of all Regions would be to schedule meetings of
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regional representatives to discuss, define and
prioritize resource requirements...
The Lead Region Selection Process Should be Broadened
The Assistant Administrator for Administration and
the Comptroller are solely responsible for designating
‘lead Regions.’ Extension of the selection process
to include regional officials, NPM5 and other senior
policy officials could be beneficial...
Regional Participation In the Budget Development
Process Should be Expanded
As a technique to further ensure that regional
concerns are fully considered in the final steps of
the budget development process, senior regional
personnel could be designated to work with the
Comptroller. Several regional people, either
the Deputy Regional Administrator, Associate Regional
Administrator, or Management Division Director would
spend the period immediately prior to and after the
budget hearings participating in the budget process;
identifying and collecting regional issues, preparing
regional presentations and generally insuring that
regional issues are heard. During the 0th Passback
and Appeal process, the same people would return
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to Headquarters to continue their participation.
The additional analytic activity, focused entirely
on regional program issues selected by the Regions
themselves, would ensure that regional concerns
are voiced...”
Another problem, not mentioned in the Task Force report but
identified in interviews with Regional personnel, is the po-
tential for conflict between Deputy Regional Administrators
and National Program Managers during the Lead Region’s
participation in the budget process. Instances were cited
in which feelings ran high and adversely affected the
relationship between the NR4 and the Region long after the
collaboration on the budget had ended. A Lead DR serves
as the single focal point for the expression of the views
of all the Regions. A concern was expressed that a Region
might be penalized because the Lead DR& takes his or her
responsibility seriously enough to provide strong Regional
advocacy on controversial issues. This concern points to a
need for a buffer, or moderating influence, to be available
when the situation warrants, and to assure that Lead Region
collaboration in budget formulation does not impair Headquar-
ters Regional program relationships.
The Lead Region concept is, of course, not the only option
available to the Agency for Regional budget formulation
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and various other approaches have been suggested to the
Budget Study Team. On one end of the scale is the proposal
to have all the Regions collaborate with the NPMs on all
Regional program justifications through circulation of
draft documents and the use of telephone conference calls
to achieve a consensus. At the other end is the idea
that responsibility for budget formulation should be
divided, with National Program Managers preparing the
Headquarters components of the budget and each Regional
Administrator developing a budget for his or her Region to
be consolidated at Headquarters. Several other budget
formulation options fall between these approaches.
While each alternative has one or more strong features,
upon examination, each can be found to pose other compli-
cations or weaknesses. None demonstrates any clear superi-
ority over the method the Agency has adopted after dealing
with this question in various ways over the years. The
majority of persons interviewed, both at Headquarters and
in the field, considered the Lead Region approach to be a
reasonable compromise, offering the best potential for
sound budget formulation, within the constraints of the
Federal budget process.
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In consideration of the above,
o The NAPA Panel recommends that the budget process
improvements suggested in the Headquarters/Regional
Relationships Task Force Report be implemented .
o The Panel recommends that the Deputy Administrator
serve as the focal point for evaluation of the proposed
balance between Headquarters and Regional funding in
the formulation of initial budget estimates .
o The Panel also recommends that the Agency provide a
conflict resolution mechanism, with the Deputy Admistrator
as the focal point, to moderate disputes that may
arise as part of the Lead Region budget collaboration
process and assure that positive Headquarters—Regional
relationships are not disrupted by the process.
EPA Use of Resource Distribution Models
The EPA budget request to 18 contains an aggregated total for
Regional resources for each program. The existence of
a Regional structure requires some rational method for deciding
precisely how the workyears and funds should be distributed.
Workload models are the mechanisms used by EPA programs to
make these distributions and two basic types of models,
“relative need” models and “absolute need” models, are
employed.
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Relative—need models use surrogate indicators of program
needs such as “population in the region” and “number of
automobiles in the region” in a formula that yields a
percentage which each Region should receive of the 100%
budgeted for Regional resources. Absolute—need models are
based on an analysis -of the actual program activities that
planners identify as part of each Region’s mission.
The absolute—need algorithim yields a specific workyear
total for each Region (as opposed to a percentage).
Absolute—need models can be detailed and complex and some
require the use of computers. Most models in use today
are absolute—need models.
Resource distribution models are not fixed formulas that
remain constant from year to year. Rather, they are
modified annually by National Program Managers to adjust
them to changing needs and to maintain the confidence of
Regional officials that each year’s distribution is
indeed fair. As part of this review, the NPt1s may request
input from their Regional counterparts as to the workload
parameters they consider appropriate. The extent of
involvement of the Regions in the model development and
review process varies from full participation by Regional
workgroups at early stages, to little participation, if
any, depending on the program.
Workload models come in for a good deal of discussion at EPA
and many opinions were expressed to the Budget Study Team
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in interviews. The Team identif led several strengths and
weaknesses associated with the workload mode]. process:
Perhaps the greatest strength of absolute—need models
is their potential for uses other than simple resource
distribution, Good absolute—need models are based on a
detailed analysis of the work required to accomplish
program objectives. This analysis produces a common
understanding on the part of all concerned as to the
work that needs to be done in that program. If the
activities in a good workload model correspond to those
in the EPA budget document (as they should), the model
can be used to assure that the resources requested in the
budget are adequate to perform the accomplishments promised
in that document. If these same activities are identical
to or consistent with the measures contained in the
program’s accountability system and the Administrator’s
Management Accountability System the Agency has at its
command an integrated budget formulation, resource distri-
bution, and accountability system for the Region.
Well constructed, well documented, absolute—need models
based on thorough work analysis could be used by EPA
management to perform “what if” simulations during the
budget formulation and review stages. To be possible,
this would require that all models be constructed In
accordance with mandatory, consistent Agency requirements.
No such directive now exists.
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• Because of the complexity and the large annual effort
required to maintain their validity, detailed absolute—need
models based on thorough work analysis are not cost effective
tools if they are used solely for resource distribution.
It’s just too complicated a way to allocate program element
resources that may change by only a few workyears in total
over ten Regions.
• Relative—need models are relatively simple and subject
to less fluctuation in component elements from year to
year. However, they are not useful for budget formulation or
accountability measurement.
The absence of a prescribed Agency methodology for model
construction leaves the design up to individual programs.
As a result, some models are not as well constructed as
others, may be insufficiently documented, and may not be
useful for purposes other than resource allocation. This
situation also causes effort to be wasted in creating new
models when existing well constructed models with analagous
elements could be adapted to serve. The extent of Regional
participation in the design and annual validation process
is also left to individual program preference in the absence
of an Agency policy on models. The Office of Management
and Budget has also expressed concern that the application
of inconsistent model techniques leads to inconsistent
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budget documentation which makes the review process more
difficult.
Whatever the strengths and weaknesses of individual
models, the process of developing them and achieving a
consensus on the elements, weights, priorities, etc.,
represents an important communication medium within
the Agency. Shifts in Agency policy must at some
point be reflected in the models and the discussions
by Headquarters and Regional staffs about the model
are often in fact discussions about policy. Similarly,
as noted earlier, absolute—need models, with their
analysis of activities, inform the staff of the pattern
of work to be expected in a program area.
After weighing these factors:
o The Panel recommends the continued use of workload models
for Regional resource allocation, recognizing that, when
used effectively, models can yield substantial related
benefits such as more realistic budget justifications,
improved staff communication, and enhanced prcgr account-
ability .
• The Panel recommends that the Agency develop a formal policy
on resource models that addresses the question of consistency
in design approach and technical validity of model construct-
ion .
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° The Panel recommends that the Agency clearly define the
function of resource model design and modification as a joint
Headquarters/Regional responsibility and that the policy
require the full participation of the Regions in the process.
Confidentiality of Budget Estimates
Premature release of budget information is a problem for all
Executive Branch Agencies and is dealt with in various ways.
At EPA, the currentAgency policy is to sharply restrict
access to budget data during the formulation and X4B review
phases and prior to release of the President’s Budget in
January. Assistant Administrators and their staffs do
not have access to the budget submissions of other
Assistant Administrators. At the Regional level, Lead
Deputy Regional Administrators receive drafts of Regional
budget data, but only for the program for which they
have lead responsibility. In the absence of formal
guidance on the subject, some Lead DR&e send copies to
DMs in other Regions to give them an opportunity to
comment. Others do not, citing the requirement for
confidentiality.
This policy is apparently a response to a problem of
premature leaks of budget data to advocacy groups in
recent years during which the Agency experienced severe
retrenchment. The policy has apparently succeeded
because leaks have in fact been reduced, although the
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recent upward movement in the EPA budget level, reversing
the reductions of recent years, may account for much of
this improvement.
While tight access controls may help deal with the
problem of leaks, they can also have undesirable side
effects, particularly when organizations have inter-
dependent programs. For example, each media section of
the EPA budget has a subsection on research and develop-
ment that is prepared by the Office of Research and
Development, after consultation with the program offices.
In the FY85 budget submission, changes were made by the
R&D organization in its final review stage. Because
the confidentiality policy prohibits the budget material
of one Assistant Administrator to be shared with the
others prior to the Q4B review, the affected media
program offices have had a difficult time making adjust-
ments to make the rest of their documentation. consistent
with the revised R&D justification.
Regional officials feel that they should have an oppor-
tunity to participate in the review of budget data
affecting all their programs, not just the ones for
which they have lead responsibility. As a minimum,
they suggest the policy be clarified so that the present
inconsistent treatment of draft budget material by Lead
DRAs can be regularized.
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Sharing of budget data at the Assistant Administrator
level would help assure that the justifications are
well coordinated. Clarification of the policy to enable
Lead DRAs to obtain the views of other Regions in preparing
their comments would improve the Regional participation
process. The result could be a higher quality, better
coordinated budget document. The opening of the process,
even to this extent, will increase the risk of leaks.
On the other hand, the people who would receive the
needed information are those who already know a great
deal about the EPA budget and are already a risk factor.
Accordingly,
o The NAPA Panel recommends that the Agency open its
budget formulation process to permit the sharing of
estimates between the major programs and the Regions.
Flexibility in Budget Execution
As the Agency’s budget goes through its review phase in the
Office of Management and Budget and in the Legislative
Branch, modifications are made, adding, deleting, reducing
or expanding programs. In order to assure that the
modifications are implemented in the manner contemplated
by the oversight organizations, policy guidance is given
to the Agency, either as directions ordering particular
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things to be done or as constraints imposed to prevent the
Agency from thwarting the approved objectives. The con-
straints may be in the form of prohibitions (“None of the
funds provided under this Act may be used to...”) or of
provisions requiring the Agency to request approval of
changes.
The 4B directions and constraints are given to the Agency
in the “Q4B Passback,” program element by program element.
The Congressional directions and constraints may be in-
corporated in the language of the authorization and
appropriations acts or they may be cited in the reports
of the committees that acted on the legislation. Although
neither the 4B restrictions nor the Conuñittee report
material have the force of law, for all practical pur-
poses there is little distinction except when the statutory
and non—statutory requirements differ on the same point.
An example of a statutory restriction is the provision in
the current law that prohibits the Agency from transferring
funds from the Personnel, Compensation and Benefits object
classification to any other object classification without
the approval by the House and Senate Appropriations Commit-
tees. Another statutory restriction is a ceiling, limiting
the total funds for travel expenses to the amount requested
in the President’s Budget.
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An example of restrictions added in Committee and Conference
Reports is the provision that the Agency must obtain prior
Committee approval of any reprograming action over a certain
threshhold. This amount is currently $500,000 for the Rouse
and $250,000 for the Senate. Since both Committees must
approve such changes, $250,000 is the effective threshhold.
When the Executive Branch and the Legislative Branch are in
sharp disagreement on policy or if there is a lack of conE 1—
dence in the Agency’s ability or willingness to carry out the
approved policy, the number of directions and constraints
tends to be increased and management flexibility reduced.
Once restrictions are imposed, there is a natural inertia
that tends to keep them in place. Nevertheless, as oversight
confidence improves, the opportunity for restoring manage-
ment flexibility by removing the restrictions is enhanced.
Within EPA, the Office of the Comptroller is the focal
point where all the provisions limiting Agency discretion
are recorded and control mechanisms are implemented to
assure that managers execute the budget in the prescribed
manner. The Comptroller issues the resources to responsible
officials in the form of “allowances” which provide
authority to commit and obligate resources. Allowances
are grouped by appropriation and are supported by an
operating plan detailing the workyears and dollare available
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for each program element, and object class within program
element, by fiscal quarter.
The first Operating Plan is produced before the start of
the new fiscal year in order to realign the resources
requested In the original budget document to take account
of new events and changed requirements. This initial
Operating Plan is provided to 4B and the Appropriations
Subcommittees for approval. It represents the first
reprograining action of the fiscal year and serves as the
baseline for subsequent commitments and obligations.-
For various reasons, during budget execution, managers
determine that certain accounts do not have sufficient
resources to cover actual needs, while other have excess
amounts. In order to reprogram the resources, the Allowance
Holder is required to prepare a change request explaining
the proposed action and to submit the documentation to
the Office of the Comptroller where it is reviewed to
determine if the change will exceed Congressional or 4B
limitations.
If limitations are not exceeded, the Office of the Comptroller
implements the change in the Operating Plan and produces
a revised allowance. If Congressional or fBB approval
is required, the reprograuzing is held in abeyance while
the request is sent to the appropriate officials for
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review, approval or disapproval. If approved, the Office
of the Comptroller moves ahead to process the action and
issue a revised allowance. Change requests requiring
Congressional approval are often collected for submission
at one time to the Appropriations Subcommittees and
several months may be required to obtain approval and
implement the change.
While the changes are pending, the manager may not take
the action that initiated the change. Some managers
indicate that the prospect of undergoing a change review
process discourages them from taking an action they
consider necessary. Or, if the action is considered
essential, the manager may opt to “beat” the system by
charging the cost to another account.
As noted earlier, controls and restrictions are instruments
of policy and serve a necessary function. The question
resolves itself to a matter of degree. The cumulative effect
of various restrictions currently imposed on EPA, and the
detailed account structures into which funds and workyears
must be pigeonholed for control, is to discourage initiative
and impedes effective management. Therefore,
The NAPA Panel recommends that the Congress provide the
Agency with increased reprcgraming flexibility by raising
the present $250,000 and $500,000 threshholds to $1,000,000 .
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EPA management should work with members of Congress and the
Appropriations Committee staffs to achieve this objective.
If the Congress is reluctant to raise the threshhold across
the board, it may be possible to identify particular program
elements of particular interest for application of one
control level, with the higher threshhold for all others.
The Panel recommends that the Agency conduct a review of
internal control systems to insure that managers are delegated
the maximum flexibility possible .
The current control system does not give managers enough
discretion. For example:
The Operating Plan provides for control of a detailed
object class breakdown for each program element when it
is probably necessary to control only Personnel Compensation
and Benefits, Travel, and All Other as a total.
Through operation of the workload models, Regional
workyears for each program element are allocated by a
specific mix of Permanent Full Time Equivalents and
Other Than Permanent Full Time Equivalents, when a
program element allocation by total Full Time Equivalents
would suffice. Regional Administrators could decide on
the particular mix best suited to local needs.
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Reprograming change requests are required for many
transactions where a change notification would suffice.
A request involves delay, while notification permits
immediate action.
Whatever the realities, interviews show that many Agency
managers believe the system does not provide them with the
operating flexibility available to the Agency. This
perception problem could be addressed by involving Agency
managers in a review of the budget execution control system.
EPA Management Accountability Systems
At various stages in an Agency’s planning and budgeting
process, commitments are made regarding the quantity and
quality of work to be performed in the budget year. The
comparisons of actual performance against these commitments
constitute the Agency’s management accountability systems.
At EPA, extremely detailed commitments are made and several
significant performance review mechanisms are in place.
The accountability process actually begins with the policy
guidance that precedes budget formulation. The Administrator’s
Guidance is issued annually, setting forth the goals and
objectives for the following 2 years. In prior years, more
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detailed program guidance, if issued, followed on a different
time scale and usually covered only one year. This year, a
new system is being implemented in which the Administrator’s
Guidance and the Programs’ Guidance will be issued as a single
package covering a 2—year time frame. A forced—ranked set of
30—35 priority activities, that reflect the goals and objec-
tives sought, will be included in the Guidance. These priority
activities will, of course, influence the development of the
budget document and will form the basis for subsequent perfor-
mance measurement in the Administrator’s Management Account—
ability System and in individual performance evaluations.
The workyears and outputs committed in the - BUD—2 ” pricing
analysis forms submittted to Q4B account for 100% of Agency’s
resources, including routine tasks and priority activities.
Generally speaking, the outputs are expressed in terms of
numbers of things to be done (“bean counting”) with little
in -the way of quality measurement. Nor do the outputs reflect
much in the way of environmental results, since they are
oriented more toward things done rather than results achieved.
National Program Managers have established program accounta-
bility systems to fulfill these broader performance measure-
ments.
The program accountability systems do not attempt to track
every commitment contained in the budget. Many budget items
are ignored. Others may be grouped into larger aggregations.
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Still others are represented bit expressed in terms of results
rather than tasks. For example, the budget might list “number
of inspections performed” as an accomplishment. The program
accountability system may represent this activity as “number
of facilities in significant noncompliance.” The program
systems also include qualitative evaluations that must be
addressed such as “How does the Region verify the accuracy of
self—monitoring data?” or “What corrective measures have been
taken?”. The Office of Water Accountability System is one of
the more detailed such program systems at EPA. For example,
the Regional evaluation section of this system examines about
50 separate activities, with well over 100 quantitative
measures, and over 200 qualitative questions.
Program accountability systems are kept in harmony with the
goals and objectives expressed in the annual Administrator’s
Guidance. The new system Which will provide for issuance of
the Program Guidance at the same time as the Administrator’s
Guidance will help assure that the program accountability•
systems focus on the important iBsues. In any case, these
program systems represent a significant mechanism of manage-
ment accountability for stewardship of the Agency.
At a higher level of review, the Agency has put in place an
Administrator’s Management Accountability System (MAS). In
the latest implementation of the NAS, the performance will
clearly relate to the activities in the annual Guidance
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document, including the 30—35 priority activities listed
therein. The MAS will track several hundred output commit-
ments that are negotiated with management officials through-
out the Agency. Efforts are being ‘made to assure that the
set of MAS items to be tracked is identical or closely
consistent with the items tracked in the program systems to
avoid the need for special data collections. Considerable
progress has been made in this direction. A subset of the
HAS accountablity measures is also personally committed to
by each Assistant Administrator and these commitments form
the basis for that official’s annual performance rating.
The MAS closes the loop between the Guidance, the budget
documents prepared as a consequence of that Guidance, and
the execution of the resulting budget. One further MAS
change now being considered is to try to make the activities
listed in the BUD—2 forms as consistent as is practical
with the activities in the Guidance and the corwnitments
tracked in the HAS.
The stmt1n ry conclusion of the Budget Study is that the
combination of Administrator and Program Guidance in a
‘single package, the emphasis on 2 years of guidance, the
identification and negotiation of 30—35 priority activities,
and the coordination of the HAS with the program account-
ability systems are significant improvements that should be
pursued. The Agency’s trend toward aggregating the BUD 2
activity/accomplishment/output elements at higher levels
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and defining them in a manner consistent with the MAS will
further tighten up the process.
A small caveat should be added at this point. The changes
in accountability systems and associated data collection
requirements in recent years have had an impact on reporting
workload. Regional officials in particular feel that
insufficient attention has been paid to eliminating prior
report items when new requirements are added, and that the
cumulative reporting burden has grown excessively. EPA
should consider conducting a thorough reports management
review seeking to reduce this load. To keep the Agency’s
internal data collection process streamlined on a continuing
basis, a Headquarters staff office should be assigned to
serve as a reports control point to critique proposed new
reporting requirements and to assure that obsolete require-
ments are eliminated. Accordingly,
• The NAPA Panel endorses the Agency’s approach to program
and management accountability and recommends that the
systemic improvements initiated during the Budget Study
be implemented .
• The Panel recommends that the Agency review the impact of
data collection requirements that have accumulated in recent
years to reduce the load and provide a review mechanism for
proposed new requirements . -
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Budgeting for Superfund Administrative Expenses
The Comprehensive Environmental Response, Compensation and
Liability Act of 1980 ( ERClA), provides for liability,
compensation, cleanup, and emergency response associated
with hazardous substances released into the environment and
with uncontrolled and abandoned hazardous waste sites. To
pay the cost of removal and remedial actions, RCIA created
a Hazardous Substance Response Trust Fund (the “Superfund”)
of $1.6 billion, to be collected over 5 years by a tax
($1.38 billion) on companies dealing with petroleum and
chemical products and by appropriation of general tax revenue
($220 million).
ERC1A provides for EPA’S administrative expenses to be paid
from the trust fund. To assure that trust fund administrative
monies are not used for other EPA purposes, the Act specifies
that the Superfund be charged only for costs Which are
“reasonably necessary for” and “Incidental to” RCTA imple-
mentation. When site cleanup costs are paid by. the Superfund,
EPA may recover the costs from the responsible parties
through litigation. In such cases, the costs——direct and
Indirect——of cleaning up the specific sites must be accurately
determined.
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In short, while all other EPA administrative expenses
are provided under a single Salaries and Expenses Appropri-
ation, Superfund administrative expenses are provided
frc n the trust fund requiring not only separate accounting,
but charging of such expenses on a site—specific basis.
If all EPA Superfund activities were carried out by
employees, facilities, and equipment dedicated solely
to those purposes it might be possible to account for
administrative expenses in a relatively straightforward
manner.
Unfortunately, the situation is not straightforward.
Most EPA Superfund activities are carried on by
employees normally assigned to other Agency functions,
with shared facilities and equipment. The unique
cost accounting requirements imposed by CERCLA to
keep these expenses sorted out, and the further
requirement to account for the Superfund portion on a
site—specific basis have created a major administrative
burden. The flavor of the problem may be gleaned
from the following excerpts from recent a report of
audit by the EPA Office of Inspector General:
“We found instances where employees’ payroll
costs were charged to Superfund when they were
actually working on other programs. Conversely,
there were many instances where employees’ -
payroll costs were not charged to Superfund but
should have been. In some cases, such mischarg—
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ing was deliberate due to budgetary
considerations, but in others it was due to weak
internal-controls or errors...
Officials who directed that payroll costs not be
charged to Superfund believed that strict compli-
ance with the June 17 guidance posed a potential
conflict with prescribed ‘not to exceed’ full—time
equivalent (FrE) workyear ceilings, for Superfund.
As a result, when these offices reached their
budgeted Superfund FrE ceilings they stopped charg-
ing payroll costs to Superfund and began to absorb
them in the salaries and expense appropriation...
Errors of omission occurred because the time
identified to the RCLA program on employees’
timesheets was not always properly entered on the
tiiuecards nor accurately entered into the accounting
system... In some cases, he employees put invalid
account numbers on their timesheets. In others,
the timekeepers did not know they were supposed to
transfer information from timesheets to the timecard;
transferred incorrect information on the timesheete
to the timecard; or incorrectly entered distribition
information on the timecard...”
The audit report shows similar problems with the charging
of support costs for rent, utilities, telephone services,
and so on. As a result of this report, the Agency is
imposing tighter and more detailed accounting controls
including procedures for charging of Headquarters
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Superfund staff time to specific sites. It is worth
considering whether there are any simpler alternatives
to the present system for funding RCT.A administrative
costs that results in such complicated and expensive
accounting requirements. Therefore:
° The N PA Panel recommends that cMB, EPA, and the
appropriate authorizing committees in Congress
consider a revision to ZRCLA which would permit
funding of EPA administrative expenses within the
regular Salaries and Expenses appropriation and
eliminates them from the site cleanup cost recovery
process .
Under such an arrangement, EPA would estimate, justify,
and defend its ZRCIA administrative expenses as it
does for all other programs. EPA would also account
for these expenses separately, by Superfund program
elements as it does for all other program elements,
but cost recovery under RC1A would be limited to
the recovery of extramural cleanup costs directly
chargeable to the sites involved.
If the policy review of this recommendation produces a
conclusion that cost recovery of administrative expenses
on a site basis is essential, then:
° As an alternative, the Panel recommends legislation
that would permit funding of EPA administrative
expenses within the S&E appropriation and would
prescribe a statutory formula for recovery of the
administrative expenses on a site—specific basis .
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Revised statutory provisions could provide a straight-
forward cost distribution formula to allocate these
administrative costs to each site for purposes of
recovery under litigation. For example, the formula
might allocate overhead costs in the same ratio as
the documented extramural direct costs.
Budgeting for Research and Development
The Office of Research and Development CORD) is
responsible for planning and executing a National
program of research, development, and demonstration
in: a) pollution sources, fate, and health and wel-
fare effects; b) pollution prevention and control
and waste management and utilization technology;
c) environmental sources; and d) monitoring systems.
EPA relies on its research and development program
to anticipate and assess both long—term and short—
term environmental risks; to support National EPA
programs by providing expert consultation and advice on
technical issues (e.g., in setting standards and in
developing risk management strategies); and to respond
to novel or emergency situations in the field (e.g., dioxin
contamination).
While the rest bf the Agency is organized along media lines,
the ORD organization is structured functionally, focusing on
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such areas as environmental monitoring systems, environmental
engineering, environmental processes, and health effects.
Each major R&D function potentially relates to all or most
of the media programs.
Although the ORD mission is ‘consolidated within one organi-
zational component of the Agency, it does not have its own
separate statutory basis. The authorization for R&D is
included within each of the media statutes. Accordingly,
the EPA budget document submitted to ()1B includes a
sEparate R&D justification for each of the media sections.
Given the basic functional design of the R&D organization,
the budget process must carry the burden of determining
media program requirements, pricing them out, and
assigning priorities for both short—term and longer—term
R&D. To accommodate these requirements, ORD has
developed specialized procedures which are siiivmuirized
as follows:
a. Media—oriented research committees of researchers,
managers, and program office representatives examine
the research and development needs in each prngrU
area. The research committee analyses are conII àted
into “tnegastrategies’ for each media category (i.
air, water, toxics, hazardous waste, etc.) which are
reviewed by ORD Office and Laboratory Directors and
submitted to media program offices for their concurrence.
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—128—
b. The Assistant Administrator for R&D develops budget
year target resource allocations for each strategy area,
based on discussions with the mega—strategy authors
and the Administrator’s Guidance. The mega—strategy
authors and the research committee chairmen then meet
and disaggregate the media—level totals to the individual
research committees within each of the media.
c. The research committees meet and agree on
objectives to be fulfilled within their resource
allocations. These are translated into “Planned
Program Accomplishments” (PPAs) for each resource
level and forwarded to the Assistant Administrator
level for aggregation. -
d. The Assistant Administrator for Research and
Development holds two days of meetings to afford each
research committee chairman an opportunity to describe
his/her request. This overview is followed by a more
detailed discussion during which ORD Office Directors
represent their respective Laboratory Directors.
e. When the final resource decisions are made by
the Assistant Administrator, ORD Staff prepare
the narratives, outputs, workyear estimates, and pricing
in the formats required by the Office of the Comptroller.
f. The reviews by EPA management, Q(B, Authorizing
Committees, and Appropriations Committees result in a
variety of changes to the initial program balance
suggested by the research committees. Examples include
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—129—
specific program reductions, additions with funds,
additions without funds, additions with inadequate
funds, etc. As the Congressional review cycle nears
completion, the R&D program must be adjusted to
reconcile these changes in order to prepare an opera-
ting plan. This adjustment is made primarily by the
Headquarters Offices.
g. Upon approval of an operating plan, allowances
are issued to the ORD Offices which in turn allocate
funds to the Laboratories for commitment and obligation.
A general pattern of dissatisfaction with the ORD
budget process emerged from the Budget Study interviews.
This dissatisfaction was expressed by officials at the
R&D Laboratory level, by senior R&D managers, by
National Program Managers and by the Comptroller. ()IB
analysts responsible for EPA oversight also cited the
R&D budget as a major problem. The principal areas
of concern may be swmnarized as follows:
• The organization of Headquarters Offices along
functional lines complicates the day—to—day liaison
and interaction with National Program Managers—
particularly at senior management levels.
• The current Headquarters/Laboratory structure
results in a highly fragmented and inflexible
Laboratory capability. Each Laboratory is directed
toward the relatively narrow discipline mission of
its parent office and is captive to the growth and
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retrenchment fortunes of that narrow mission. This
narrow focus of Laboratories supporting a single
Office is also conducive to detailed oversight or
•m.lcro” management by the Headquarters organization,
with a more detailed accounting control pattern
than is typical of the rest of the EPA organization.
o The Research Committee approach to budget planning
has many of the problems found when committees are
asked to perform line activities. On the one hand,
Laboratory Directors feel that their point of view
is not adequately addressed even though laboratory
scientists serve on the committees. Similarly,
National Program Managers may not agree with the
positions taken by the committees although program
office representatives are included. There is also
a feeling that the committees tend to produce lists
of projects rather than well balanced research
programs and that the process pushes too much of the
decision—making up to the Assistant Administrator
level.
o Because EPA has been unable to consolidate
Laboratories and because staff reductions have been
carried Out through attrition, severe imbalances in
numbers of employees and skill mix have resulted at
the ORD Laboratories. The need to fund these less—
than—optimal Laboratory situations may conflict with
the program priorities recommended by the research
committees. The responsibility for making the
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necessary adjustments in the R&D program rests with
the Assistant Administrator for R&D and the adjustments
may be made late in the budget formulation cycle.
National Program Managers are naturally concerned by
the deletion of “their” projects fran “their” R&D
budget for work they view as lower priority.
o Finally, there is some disatisfaction with the R&D
budget justification itself. Q4B officials complain
that the lengthy R&D justifications, distributed
throughout the budget document, comprise up to one—third
of the length of the EPA submission. Because of their
fragmentation, however, the justifications do not
contribute to an understanding of the overall policy
direction of the R&D program.
En its consideration of these problems, the NAPA Panel
recognized some constraints. First, the Panel concluded
that a recommendation to consolidate or eliminate
Laboratories would not be helpful since previous efforts
along these lines to rationalize the R&D field structure
have not been successful. Secondly, the Panel will
not recommend major structural changes in organization
because the Agency has already drafted such pli â d
can implement them when it concludes that it
beneficial to do so. The R&D organization has experi-
enced considerable disruption in recent years and
needs a period of stability before any significant
overhaul is attempted. Within this framework then:
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—132—
° The MAYA Panel recommends the establishment of staff
“ R&D Program Manager” positions in the Headquarters
R&D complement, with responsibility for media—based
planning and budgeting, liaison with National Program
Managers, and operation of R&D management account-
ability systems. Research committees would serve in
an advisory capacity to these Program Managers .
This approach accommodates the program dimension of the R&D
matrix organization, providing focal points of responsibility
for the development of R&D strategies and program plans along
media lines. The current field structure and line reporting
relationships would be unaffected.
o The Panel recommends that multi—discipline Research
Centers be formed at Cincinnati and at Research Triangle
Park, with the Center Directors reporting to the Assistant
Administrator for R&D. “R&D Progra m Manager” counterpart
responsibilities should be provided at the Centers .
Although the present number and location of R&D Laboratories
may remain unchanged, their management can be improved by
assigning them to two Centers for administration and
oversight. Two large multi—diacipline Research Centers
would permit strong Laboratory advocacy in the budget
process and could provide the “critical mass” of
research capability now missing at the narrowly—focused
Laboratories. The “R&D Program Managers” at the Centers
would serve as a link with their Headquarters counterparts
in support of budget formulation and execution.
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—133—
Important economies in such areas as equipment procurement,
equipment sharing, consolidation of stock rooms, and
supply management can be realized by implementation
of the Research Center concept. (Personnel
management improvements also flow from this
recommendation. These are discussed in the MAPA
Personnel Management Study report.)
o The Panel recommends that the Agency seek enabling
legislation for its basic research and inter-
disciplinary research activities .
Basic research is the work needed to anticipate environmental
risks and to analyze issues cutting across media lines or
issues not tied directly to the current needs of ongoing
programs. However, most of this research is authorized in
prcgranm tic legislation, and so is affected by abort—term
program priorities. Separate legislation authorizing basic
research would deal directly with the problem of stability
and continuity in this program.
• The Panel recommends that the Agency work with OIB to
develop a more coherent approach to the presentation
of the R&D program in the budget document .
Discussions with ()(B officials suggest
willing to assist EPA in improving their R&D justifications,
moving away from the detailed lists of planned accomplishments
that now form the basis for review. The Agency should take
advantage of this offer.
I
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Administrative Information Systems
EPA computerized information systems for budget, accounting,
payroll, personnel, grants, and contracts administration have
evolved separately from one another in a vertical, functional
design with little horizontal coordination. This situation
is a reflection of a larger Agency M W systems management
problem, the nature and scope of which was defined as follows
in the report of an Agency Task Group established to address
the matter:
“Over the past few years, several studies conducted by
consultants and the General Accounting Office concluded
that the Agency is not effectively managing its MW
resources and realizing a fair return on its investment
in ADP systems and equipment. Many of the specific
problems identified in those studies were attributed in -
large measure to three related factors: (1) a highly
decentralized management of ADP activities; (2) ineffect-
ive central guidance and coordination among ADP activities;
and (3) a lack of critical mass of ADP activities and
expertise in many parts of the Agency...
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—135—
ADP related activities represent a very significant
commitment of resources by the Agency... The agency
estimates that it will spend approximately $50 million
for ADP in the 1982 fiscal year for consolidated ADP
functions... The significance of ADP activities also
is reflected by the fact that over 450 unique computer—
based information systems and models are now operated
by the Agency or are being developed...
The anomaly is that there is significant duplication
of services provided, functional expertise and equip-
ment; while at the same time same of these groups are
too small to be able to competently provide a full
range of support services or to maintain a nucleus of
staff experts in the computer technology which is
critical to EPA’s future...”
The impact of the vertical systems design on the Agency’s
administrative support functions is substantial. EPA’s
major administrative systems are maintained at separate
computer facilities with different hardware,
software, different processing concepts, differ ta
definitions f or similar items, inconsistent claiêfftcation
and coding structures, and unsynchronized processing cycles.
The systems are in different stages of development and
enhancement but, in general, they can be characterized as
technologically out—of—date and expensive to maintain.
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—136—
Some program offices have had to develop duplicative satel-
lite systems to track or array information at a level of
detail useful to their management.
Officials interviewed during the EPA Budget Process Study
expressed frustration with their inability to get consistent
data on the same topic from the administrative systems; the
need for crosswalk tables to relate classifications and
codes from one system to another; the need to learn several
protocols for accessing systems on different computers; the
need to learn several different retrieval languages unique
to the software of each system; the cumbersome techniques
required for transferring data from one system to another
(such as mailing magnetic tapes); and the wasted time and
effort lost in reconciling inaccurate reports for systems
with outmoded data entry and editing procedures. There was
also some discussion of the philosophical problem of viewing
systems and databases parochially as “belonging” to a parti-
cular office as opposed to the concept of information
systems being an Agency-wide reso ce.
The Agency has taken some major steps toward correcting the
situation. As a result of the Task Group Study cited
earlier, there has been a consolidation of ADP functions in
the administrative area:
° Most ADP functions, facilities, and ADP staffs
previously controlled by the various administrative
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—137—
functional offices have been transferred to the Office -
of Information Resources Management (011K). Only the
ADP staff reporting to the Office of the Comptroller
has been left with that office rather than being moved
to 011K.
0 Although ADP operations and staffs in Regional Offices
remain under the direction of the Regional Administrators,
system development policies and activities are supervised
by 011K and the Regions will now rely on standard
011K—supported software for most administrative systems.
011K also procures and oversees the management of DP
equipment and contract services by the Regions.
011K has initiated plans to bring administrative systems into
better coordination:
0 EPA’s payroll is currently processed by the Department of
Interior, using its NDIPS system. Work is underway
to transfer the operation of DT.PS to EPA’! Oum computer
facility. A systems development
started to standardize personnel, payroll;c
time and attendance data entry programs, procedures,
and telecommunications processes, using the EPA tele-
communications network.
• One data base management software system has been
selected as the standard for EPA. The goal is to move
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—138—
all administrative systems to this software over the
next few years. If this is accomplished, there will be
much improved horizontal coordination of systems and the
user’s ability to access data will be vastly simplified.
o Various enhancements to the accounting system are under-
way and a pilot project to integrate the budget,
operating plans, and accounting information using
off ice microcomputers is being evaluated.
o During 1982, the Office of the Comptroller arranged
for a requirements analysis and a conceptual design
for a new budget system under contract with Electronic
Data Systems Corporation. The proposed system would
make many needed improvements and would use the
standard D 1S. Implementation was temporarily
suspended when the ADP operations were merged. OI1 1
is now examining the proposed budget system to
determine if the budget formulation needs of program
offices and field installations are adequately
addressed and to decide how the new system can most
effectively be integrated with the other related
administrative systems.
In its efforts to rationalize the administrative ADP systems,
the Agency is not contemplating the design of a single,
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—139—
new, largescale, integrated system that would replace all
systems now in place. Rather, the approach is to modernize
each functional system in its own development cycleand to
achieve as much horizontal integration and compatibility as
possible in the process.
Whatever the design approach, the development effort would
benefit significantly from a oss—systems study of paper
processing to streamline workflow; to eliminate redundant
or otherwise unnecessary work; to design forms that permit
simplified data capture, one time, at the source, to fulfill
the needs of multiple systems; to standardize data definitious,
classifications and codes; and to develop coon edit iteria
assuring cross—system validity of data.
As it moves ahead with its system development work, 01R4
will be attempting to take an Agency—wide information systems
perspective. This can be expected to generate organizational
tensions, because the various systems have historically been
“owned” by the functional organizations, with development
concepts and schedules optimized in a vertical rk.
Management sensitivity and attention to this fi
minimize the potentially negative effects and c..._ ..,. avoid
undesirable compromises away from systems that mesh effec-
tively to meet the full range of Agency management needs.
Accordingly,
• The NAPA Panel recommends that EPA establish an Agency
objective to achieve horizontal integration of administra —
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—140—
tive ADP systems for grants, contracts, personnel, payroll
budget, and accounting .
o The Panel recomniends thatEPA establish an Information
Systems Steering Committee composed of representatives
from both line and staff user organizations, to advise
on the development of administrative ADP systems, stress-
ing horizontal compatibility and a view of information
systems as an Agency—wide resource .
o The Panel recommends that the Agency conduct a cross—
systems study of administrative processes to provide a
strong foundation for software design.
Communication and Training
The planning, budgeting and associated accountability
systems at the Environmental Protection Agency are vital
instruments for the accomplishment of the Agency’s mission.
The operation of these systems requires the collection,
analysis, and integration of masses of data from numerous
sources, the interaction of many organizational units,
and the coordinated effort of hundreds of employees at
Headquarters and at field installations throughout the
country. The budget processes are conducted within the
framework of a complex mission and a dynamic policy
structure.
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—14 1—
To function most effectively, these systems require highly
competent line managers, assisted by well informed and
well—trained program analysts, budget analysts, financial
management analysts and other support staff.
Most of the EPA employees interviewed for the Budget Process
Study have been with the Agency for some years and there-
fore have a good understanding of how the various components
of the system work. Nevertheless, many of these same
employees cited the lack of an up—to—date budget manual as
a handicap. The last published EPA budget manual was
issued in 1980 during the ZBB era and is now largely ob-
solete. There is a need for an official published descrip-
tion of the planning and budget system, routinely updated
to keep the staff consistently and accurately informed.
While a manual is an important aid to an effective budget
process, formal staff training can also play an important
part to inform the responsible employees of the latest system
changes and their purpose, as well as to assure that the
next generation of analysts is developed. AccordilEly,
• The NAPA Panel recommends that EPA develop i. n
budget manual and implement a procedure that assures
the issuance of regular, periodic updates .
• The Panel recommends that a training course be designed
for EPA personnel covering the EPA planning, budgeting,
and accountability processes .
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APPENDIX
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Appendix A
BUIXZT PRO ZSS FLOW ANALYSIS
SIMMARY CIl&Wf
January 1984
-------
BUD(ZT PROCESS FLOW ANALYSIS
Summary Chart
(1) January
• Budget Formulation Phase Under-
way. Target Year referred to
as Budget Year .
• Office of Management Systems
and Evaluation ( 1SE) develops
draft Administrator’s Guidance
after coordination with Head-
quarters and Regional program
staff. Guidance covers 2 years
including general policy
direction for the second,
Budget Year.
(2) February
Administrator’s Guidance issued to
Headquarters and Regions. Contains
key objectives to be attained by
each organization in pursuit of
Agency goals.
(3) March
Some National Program Managers (NPM)
begin preliminary work on budget
with Regional participation in
varying degrees. (E.g., NR4 for Water
requests workload estimates from
Regions out to Budget Year. In 01W,
“mega—strategies” for each media
category are prepared, based on
research committee analyses.)
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A-3
BUD( T PROCESS FLOW ANALYSIS
Summary Chart — (Con’t)
(4) April
Office of Comptroller(OC) meets
with Administrator & Deputy to
discuss program emphases,
new starts, cutbacks, issues for
Budget Year.
OC staff meets with NR4 staff
& Regional staff to discuss
program issues/directions &
to relate current Congressional
actions to budget year.
. NNs begin/continue preliminary
work on budget with Regional
participation in varying degrees.
(E.g.:, Water NR1 enters Regional
workload parameters into computer-
ized workload model to produce
workyear estimates. ORD NR’l
develops target resource
allocations for each mega—
strategy, for disaggregation
at research committee level.).
(5)
OC issues Budget Call Letter
containing guidance, targets,
levels, forms. OC and NFMs
identify/confirm “Lead”
Regions for their media to
be included in Call letter.
Deputy Regional Admin-
istrators represent Lead
Regions.
NPMs begin intensive budget
preparation including work—
year & fund estimates for
each program, with Regional
participation in varying degrees.
(E.g., Water N 4 meets with
Regional staff to update/refine
workload models and to identify
priorities/strategies to be
factored into budget justification.
ORD research committees develop
“planned program accomplishments”
within their research allocation.)
(6) June
NFM staff continue development of
budget submission including ranking
of programs, determining HQ—Regional
“split” of resources, preparing
narratives, etc.
Depending on program, Regions may
critique draft budget and meet
with Headquarters staff to develop
priorities and resource levels.
N 1s review draft budgets, conduct
hearings, decide final priorities,
resolve issues. Approved documents
submitted to OC.
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It—.’
BUDGET PRO(ZSS FLOW ANALYSIS
Summary Chart — (Con’t)
• OC receives NFt4 budget submissions
& enters data into Resources Manage-
ment Information System (WIIS)
managed by OC. Produces numerous
runs——(historical, media, Region-
al, etc.)
• NR1s also supply supplementary
resource data for special
topics by program element
(e.g., ADP information).
OC pulls all data together into
Agency composite. OC analysts
analyze Agdacy composite &
brief Administrator/Deputy in
preparation for hearings.
Administrator/Deputy conduct hear—
logs with Assistant Administrators,
Office Directors, & Regional
Administrators/Deputies.
(8) August
Hearings with Admlnistrator/
Deputy continue.
OC develops recommendations on
resource levels; updates I 1IS;
submits “Passback” to Adminis-
trator for final review/changes;
issues final, approved Pass—
back to N1 1s.
NFMs may Appeal to Administrator!
Deputy on recommended levels.
OC “marks up” final Administrator/
Deputy decisions, updates WIIS
& issues final Passback to NIMs
as basis for Agency submission
to ft1B.
NPMs write their final 1B
budget justifications based
on Pasaback levels.
justifications for
Analysts review &
and return to NPMs for
Final O(B submission——hardcopy &
computer tape——produced & delivered.
OC and program offices develop data
for initial versions of “A—li”
Exhibits to be appended in President’s
Budget resulting from 1B review
Process. Specialized EPA offices
participate (e.g., ADP budget
data). Exhibits delivered to a4B.
OC develops other special data runs
such as “object class by program
element.
Some NRIa begin review of parameters
to be included in workload models.
Request Regional Inputs.
G drafts candidate list of priority
activities to form basis of Admin-
istrator’s Guidance. Draft sent to
Assistant Administrators, Regional
Administrators and external groups.
(7) July
(9) September
OC receives NR4
budget to a4B.
edit narratives
final typing.
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BUD(ET PRO(ZSS LOW ANALYSIS
Summary Chart — (Con’t)
(10) October
• OC and program staff prepare
briefing books for (MB
hearings.
• (MB conducts Agency budget
hearings with each Assistant
Administrator followed by
frequent followup communica-
tion with EPA staff.
(MB staff revises EPA Budge ,
submits for (MB Director’s
approval.
OC continues to develop “A—li”
Exhibit material.
Regions submit workload model
suggestions requested by some NR4s.
Assistant Administrator/
Regional Administrator comments
on candidate list of priorities
submitted to a1 .
Deputy Administrator meets
with Assistant Administrators,
Regional Administrators, National
Governors Association, Executive
Branch Organizations, and
environmental and industry groups
to discuss priority activities,
decide on final set for
Administrative Guidance.
(MSE begins development work on
Administrator’s Guidance for the
Operating Year (plus the next
Budget Year).
(11) November
(MB issues Passback (hardcopy
and computer tape).
OC updates RIIS; analyzes changes;
gives copies to Administrator/
Deputy and NI!1s (for their
programs only) for decisions on
whether and at what level to
Appeal.
OC notifies (MB if Appeal will be
forthcoming; issues Guidance to
NPMs on level at which Administrator
desires to Appeal.
NR1s develop material for
incorporation in Appeal.
OC reviews/edits, obtains Admin-
istrator’s approval and submits
Agency Appeal to GIN——within
5 days of Passback.
OC formally notifies NPMs to begin
review of workload models to be
used later for Regional distri-
bution of budget resources.
G4 distributes draft of
Administrator’s Guidance for
Operating Year (and next Budget
Year). Isaues Call to NR4s to
develop Program Guidance for
Operating Year (and next
Budget Year) to be included
in final document.
(12) December
(MB reviews Appeal.
Negotiations begin with EPA.
(14B issues second Passback which EPA
might also appeal to GIN——
or ultimately to the President.
(MB issues final Passback.
EPA completes A—il Exhibit material
to reflect final (MB budget decisions.
OC updates IMIS with final Passback
and issues Congressional Budget
Justification Call Letter to
Assistant Administrators.
Nl’Ms prepare Congressional Budget
Justification, incorporating
Passback data.
NR(s begin/continue review of work—
load models, refining/updating
parameters in algorithms, with
varying degrees of Regional
participation.
NPt1a begin developing detailed
Program Guidance for Operating
Year and next Budget Year,
including strategy paper.
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li—u
BUD(ZT PRO(ZSS FLOW ANALYSIS
Summary Chart — (Con’t)
(13) January
(14) February
(15) March
• OC assembles Congressional
budget——produces 600—650
copies for distribution to
Authorization & Appropriations
Committees.
• NRIs complete Program Guidance.
Submit to aISE to incorporate
in Agency Guidance with unresolved
issues referred to Deputy
Administrator.
House Appropriations Committee holds
hearings. OC prepares Administrator’s
statement. OC and NFMS edit tran-
scripts and prepare responses to
questions for record.
President’s Budget submitted to
Congress.
• OC prepares “Summary of the
Budget” booklet, press
release, and budget data
presentation to press.
• Administrator or designee
holds press conference.
Budget Review Phase begins.
Target Year is now referred
to as Operating Year .
• OC issues Call to N 4s for proposed
allocation of Regional workyear
totals contained in President’s
Budget.
OC and program officials brief
Authorization Committee staffs.
Congressional Authorization
Committees review Budget sub-
mission for Congressional Budget
Resolution purposes. Senate
Public Works Committee holds
hearing.
NPt4s develop and submit proposed
allocation of Regional resources,
based on models, by program ele-
ment. Compute proposed distribu-
tion of State grant funds, apply-
ing statutory or other formulas.
OC consolidates NR4 resource
allocation submissions. Sends
to Regions for concurrence.
OC negotiates changes to model
distributions with NRIs and Regions.
Regions vote on resource allocations.
Regions send appeal memoranda to
Administrator on unresolved issues.
Administrator makes final decisions
on appeals.
Headquarters offices submit proposed
•Phase I” Operating Plan distribution.
OC produces consolidated “Phase I”
Operating Plan.
• NFMs prepare detailed backup
and briefing material for program
and budget issues for Congressional
Hearings.
OC issues “Phase I” Operating Plan
Call to Headquarters offices to
distribute Assistant Administrator
(“RPIO”) level totals in President’s
Budget to subordinate Headquarters
office (“Allowance Holder”) levels
with no reprograming allowed.
Agency Guidance for Operating Year
and next Budget Year issued. Includes
Administrator’s Guidance and Program
Guidance. Document forms basis for
program pla- i ans’ in”, 1 entation
by EPA anc -
-------
A—7
BUD( T PROCESS FLOW AN<SIS
Summary Chart — (Con’t)
(16) April
Senate Appropriations Committee
holds hearing. OC prepares
Administrator’s Statement. OC
and N1 (s edit transcript and
prepare responses to questions
f or the record.
OC adjusts Regional workyear
distributions based on review/
concurrence/appeal process.
(17)
NPMs and Regions develop/
submit “Phase II ” plans:
memoranda highlighting major
initiatives, policy or program
differences from President’s
Budget and change requests to
reprogram workyears & dollars
between offices, program elements
and object classes.
(18) June
Rouse and Senate begin action on
Appropriation Bill. House often
completes action before mid—summer.
Senate follows. OC monitors and
analyzes Congressional action on
Bill. Provides additional analyses
to Congressional staff on request.
• OC computes Regional dollar
distributions based on final
model distributions and
applies Regional distributions
of contract funds and State
grant allocations.
OC issues Call Letter for
Phase II Operating Plan,
including resource targets,
guidance, forms. (NPMa and
Regions may reprogram
resources in President’s
Budget for first time.)
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A-8
BUDGET PROCESS FLOW ANALYSIS
Summary Chart — (Con’t)
(19) July
• If House & Senate complete
action on Appropriations Bill
by mid—summer, Conference
action to resolve differences
takes place before August
recess.
• N1’Ms request Regional
output commitments to be
measured and tracked for
performance by program
accountability systems.
• Q4SE meets with NFMs to
negotiate performance levels
for several hundred output
measures in Administrator ‘a
Management Accountability
System (MAS) and subset for
NR1 performance ratings.
(Output measures were
identified in Agency
Operating Year Guidance
document.)
(20) August
• OC issues call for “Phase III”
Operating Plan——contract plans
and quarterly distribution of
Phase II Plan.
• Assistant Administrators (as
“RPIOS”) and Regional Admin-
istrators (“Allowance Holders”)
submit quarterly distribution
plans for Phase III.
OC estimates unobligated
balances for carryover to
next fiscal year. Requests
apportionment of these funds
from G,IB.
• Regions and Headquarters submit
recommended outputs to be
committed and tracked by NFM
accountability systems and by
MAS. Final sets negotiated for
each review system.
(21) September
• President signs Bill
(assuming completion
action).
• NFMs submit contract plans for
Phase III.
• OC consolidates Agency Phase III
Operating Plan, adjusts to
incorporate final Congressional
action, aubmits to HB. (Plan
becomes basis for October Allowances
for the new fiscal year).
• OC requests apportionment of funds
from a4B.
. GIB acts on apportionment requests
through review of adjusted Operating
Plan. Often requires justifications
for significant changes. GIB may
issue new restrictions on individual
program elements through apportion-
ment process.
into law
of Congressional
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A-9
BUD(ZT PRO( SS PLOW AN&LYSIS
Summary Chart — (Con’t)
(22) October
• Budget Execution Phase begins.
Target Year is now referred to
as Current Year .
Q4B Apportions funds.
• OC i88ue8 initial advices of
allowance, derived from approved
operating plan, to each Allowance
Holder. Allowances are by
appropriation supported by an
operating plan detailing work—
years and dollars by quarter and
by object class.
• Allowance data provided on
computer tape for input to Financ-
ial Management Information System
(F!4S) managed by Financial
Management Division.
• Allowance Holders begin commi
ting and obligating funds.
Transactions recorded in EMS.
Salary costs and vorkyeara
recorded via Payroll system.
(23) November
Allowance Holders commit/
obligate funds. Transactions
recorded in }MS. Allowance
Holders reconcile FMS data
notifying OC (Finance) of
necessary corrections.
Allowance Holders may submit
change requests to OC for
reprograming of operating plan
allowances. OC (Budget) reviews
f or validity and determines if
they exceed Congressional or HB
limitations. If so, requests
approval before making change.
OC (Budget) updates IS, provides
computer tape for OC (Finance)
input to FMS.
OC reports end—of—year obligations
for prior year’s appropriations
to 04B. Unobligated balances of
multi—year appropriations (“carry-
over funds”) are available for use.
OC identifies portions of unoblig—
ated balanc es previously committed,
reserved, or uncommitted.
(24) December
OC (Budget) iseues revised allow-
ances monthly, reflecting approved
changes requested by Allowance
Holders. Enters into R4IS; provides
computer tape for OC (Finance) input
to FMS.
Allowance Holders commit/obligate
funds. Transactions recorded in
FMS. Allowance folders identify
reprograming needs, submit change
requests to OC. Allowance Holders
reconcile financial reports, submit
corrections to OC (Finance).
Agency offices submit requests for
carryover funds with Justifications.
OC (Budget) reviews carryover requests,
recommends an allocation to the
Administrator, updates I 1IS, and
issues approved requests for carryover
allowances. OC (Finance) inputs to
R1 S.
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A-1O
BUD(ZT PRO(ESS FLOW ANALYSIS
Summary Chart — (Con’t)
(25) Januar3
OC (Budget) reviews change requests,
obtains Congressional or G(B approv-
al if necessary, issues updated
allowances, enters changes into
(IS, provides computer tape to
OC (Finance) for input to RISe
• Allowance Holders commit/obligate
funds. Transactions recorded in
FMS. Allowance Holders identify
reprograming needs, submit
change requests to OC. Allowance
Holders reconcile financial reports,
submit corrections to OC (Finance).
(26) February
OC (Budget) reviews change requests,
obtains Congressional or GIB approv-
al if necessary, issues updated
allowances, enters changes into
WIS, provides computer tape to OC
(Finance) for input to RIS.
Allowance Holders commit/obligate
funds. Transactions recorded in
FMS. Allowance Holders identify
reprograming needs, submit change
requests to OC. Allowance Holders
reconcile financial reports, sub-
mit corrections to OC (Finance).
(27) March
OC (Budget) reviews change requests,
obtains Congressional or (B approv-
al if necessary, issues updated
allowances, enters changes into
1 iIS, provides computer tape to OC
(Finance) for input to FMS.
Allowance Holders commit/obligate
funds. Transactions recorded
in FMS. Allowance Holders identify
reprograming needs, submit change
requests to OC. Allowance Holders
reconcile financial reports, submit
corrections to OC (Finance).
NRIs use various information sys-
tems to collect Headquarters and
Regional data needed to track
outputs for program account-
ability systems and for MAS.
Submit MAS data to G1SE.
J4SE produces first quarterly
Management Accountability
Report.
. NP!1s may submit requests to
change output measurement
commitments inMAS. (N
reviews change requests,
revises plan.
. Administrator/Deputy discuss HAS
output results with Assistant
Administrators.
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A-li
BUD(ET PRO( SS FLOW AN&LYSIS
Summary Chart — (Con’t)
(28) April
OC, Assistant Administrators,
and Regional Administrators
conduct 1id—year Review.”
Project workyeara and dollars
through end of fiscal year
using data for first 6 months
recorded in FMS.
(29)
OC revises operating plan
in IlIIS reflecting repro—
graming resulting from Mid—year
Review. Submits changes exceeding
Congressional limitations for review
by Congressional Appropriations
Committees.
(30) June
Allowance Holders commit/obligate
funds. Transactions recorded
in FMS. Allowance Holders identify
reprograming needs, submit change
requests to OC. Allowance Holders
reconcile financial reports, submit
corrections to OC (Finance).
OC recommends allocations
of workyeara, funds, ceilings to
Administrator.
Allowance Holders commit/obligate
funds. Transactions recorded in
PMS. Allowance Holders identify
reprograming needs, submit change
request to OC. Allowance
Holders reconcile financial
reports, submit corrections to OC
(Finance).
N 1s collect Headquarters and
Regional output data for pro—,
gram accountability systems
and for HAS. Submit data
to a1sE.
O1SE produces second quarterly
Management Accountability Report.
NNs may submit requests to
change output measurement
commitments in HAS. (M
reviews change requests,
revises plan.
Appropriations Committees review
changes and their justifications;
if approved, OC adjusts allowances.
OC (Budget) issues revised operating
plan allowances as approved by Appro-
priations Committees. Provides computer
tape to OC (Finance) for input of data
to FMS.
Allowance Holders commit/obligate
funds. Transactions recorded in
FMS. Allowance Holders reconcile
financial reports, submit corrections
to OC (Finance).
• NFMs conduct H id—year Reviews of
Regional progress against commit-
ments & other measures for program
accountability systems.
Administrator/Deputy discuss HAS output
results with Assistant Administrators
and Regional Administrators.
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A- 12
BUDGET PROCESS FLOW ANALYSIS
Summary Chart — (Con’t)
(31) July
• OC, Assistant Administrators, and
Regional Administrators conduct
third—quarter review, using
FNS reports. Project needs to
end of year. After coordinating
with PIIMs, OC issues new operating
plan allowances reflecting
revised data.
If changes exceed limits, OC
submits for approval by Congress-
ional Appropriations Committees
before issuing revised allowances.
• New allowances are recorded in
1 iIS and PMS.
• Allowance Holders commit/obligate
funds. Transactions recorded
in FMS. Allowance Holders identify
reprograming needs, submit
change requests to OC. Allowance
Holders reconcile financial
reports, submit corrections to OC.
NFMs collect Headquarters and
Regional output data for
program accountability systems
and for HAS. Submit HAS data
to a4SE.
(32) August
Allowance Holders commit/obligate
funds. Transactions recorded
In FMS. Allowance Holders identify
reprograming needs, submit change
requests to OC. Allowance Holders
reconcile financial reports,
submit corrections to OC (Finance).
Administrator/Deputy discuss HAS
output results with Assistant
Administrators.
(33) September
OC (Budget) reviews change requests,
obtains Congressional or €HB appro-
val if necessary, issues updated
allowances, enters changes into
I 4IS, provides computer tape to
OC (Finance) for input to FMS.
Allowance Holders commit/obligate
funds. Transactions recorded In
FHS. Allowance Holders identify
reprograming needs, submit change
requests to OC. Allowance Holders
reconcile financial reports, submit
corrections to OC (Finance).
OC (Budget) reviews and approves
year—end change requests, Issues
final updated allowances, enters
into IIS, provides computer tape
to OC (Finance) for input to F!4S.
OC issues end—of—year closing
memorandum detailing dates for final
operating plan changes and 12th
and 13th month closeout dates
for FMS.
Q4SE produces third quarterly
Management Accountability Report.
NR(s may submit requests to
change output measurement commit-
ments ‘ ‘As. G4SE reviews
change •uests, revises plan.
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A- 13
BUIXZT PROCESS FLOW AN&LYSIS
Summary Chart — (Con’t)
(34) October
OC conducts end—of—year analysis
of F!4S data to determine
actual vs planned obligations,
to identify causes of delays
in use of contract funds,
to identify any allowances
that were exceeded, etc.
Review is factored into issu—
ances of carryover, budget
execution, and budget formula-
tion for next cycle.
(35) November
Administrator/Deputy discuss HAS output
results with Assistant Administrators
and Regional Administrators.
(36) December
G1 reviews operation of HAS to
identify changes to be incorporated
in next cycle and to influence
Administrator’s Guidance for next
cycle.
• N is collect Headquarters
and Regional output
data for program account-
ability systems and
for HAS. Submit HAS data
to
• GI produces end—of—year
Management Accountability
Report.
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B—i
Appendix B
INDIVIDUALS CONSULTED BY TEE NAPA/EPA BUDCIT PROCESS STUDY TEAM
EPA Headquarters Off ices:
Deputy Administrator’s Office
Deputy Administrator — Alvin Aim
Special Assistant to the Deputy Administrator — Ronald Brand
Office of Regional Operations
Associate Administrator — Samuel Schuihof
Office of the Inspector General
Inspector General — John Martin
Deputy Inspector General — Donald Kirkendall
Auditor — Steven McNamara
Office of Administration and Resources Management
Assistant Administrator — Howard Messner
Deputy Assistant Administrator — Seymour Greenatone
Special Assistant — Carol Finch
Management Analyst — John Alter
Office of Administration
Director, Of f ice of Administration — Kirke Harpers
Director, Facilities & Support Services Division — Stormy Friday
Director, Grants Administration Division — Harvey Pippen
Chief, Grants Policy & Procedures Branch — John Gwynn
Office of the Comptroller
Comptroller — Morgan Kinghorn
Deputy Comptroller — John Chamberlin
Chief, Budget Formulation & Control Division — Vincette Goerl
Chief, Budget Planning & Resources Information Systems Branch —
Daiva Balkus
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B—2
Chief, Air, Radiation & Legal Services Branch — Al Pesachowitz
Chief, Superfund/RCRA Branch — Dave Ryan
Office of Information Resources Management
Director, Office of Information & Resources Management — Edward Hanley
Deputy, Office of Information & Resources Management — Willis Greenstreet
Acting Director, Information Systems Division — Jack Sweeney
Office Systems Group — Stephan Schilling
Director, Management Planning and Evaluation Staff — Mary Blakeslee
Management Planning and Evaluation Staff — David Speights
Office of External Affairs
Assistant Administrator — Josephine Cooper
Deputy Assistant Administrator — Dick Sanderson
Management Operations Staff — Don Flattery
General Counsel Director, Legislative Division — Virginia Gibbons
Office of Policy Planning & Evaluation
Assistant Administrator — Milton Russell
Chief, Program Integration Branch — Cheryl Wesserman
Environmental Scientist — Alan Ehrlich
Director, Management Systems Division — Cynthia Kelly
Chief, Accountability Systems Branch — James Vickery
Chief, Policy Evaluation Branch — Thomas Kelly
Chief, Progam Management Staff — John Beecher
Special Assistant to the Assistant Administrator — Ernie Abbott
Office of Air, Noise and Radiation
Director, Office of Program Management Operations — Jack Hidinger
Stationary Source Compliance Division — Richard Duffy
Staff Director, Office of Air and Radiation — John Topping
Office of Pesticides and Toxic Substances
Chief, Economics Analysis Branch — Arnold Aspelin
Program Support Division — Ronald Ware
Senior Budget Analyst — Walter Muelken
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B—3
Office of Research and Development
Assistant Administrator (Designate) — Bernard Goldstein
Acting Assistant Administrator — Courtney Riordan
Director, Office of Research Progains Management — Samuel Rondberg
Director of Research Program Management for Technical Information —
Randy Shobe
Deputy Director, Office of Operations — Alan Neuachatz
Director, Office of Health Research — Roger Corteai
Program Analyst — Clifford Moore
Office of Solid Waste & Emergency ResponBe
Assistant Administrator — Lee H. Thomas
chief, Program Management Branch — Bruce Engelbert
Budget Analyst — Susan Hughes
Senior Budget Officer — Thaddeus Juszczak
Office of Water
Acting Assistant Administrator — Rebecca Hanmer
Senior Budget Officer — Cynthia Dougherty
Director, Office of Program Management and Evaluation — Michael Quigley
EPA Regional Offices :
Region II — New York, New York
Assistant Regional Administrator for Policy & Mana W Herbert Barrack
Deputy Director, Office of Policy & Management —Rat en Callahan
Chief, Financial Management Branch — Ronald Gherardi
Analyst, Financial Management Branch — Robert Genovese
Chief, Planning & Evaluation Branch — Stephen Luftig
Analyst, Planning & Evaluation Branch — Barbara Paatalov
Director, Water Division — William Muazynski
Region III — Philadelphia, Pennsylvania
Regional Administrator — Thomas Eichler
Assistant Regional Administrator for Policy and Management — Alvin Morris
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B—4
Region V — Chicago, Illinois
Regional Administrator — Valdas Adamkus
Director, Planning & Management Division — Robert Springer
Chief, Financial Management Section — Jan Mason
Chief, Financial Management Branch — Richard Walker
Chief, Management Services Branch — Beryl Jacobson
Program Analyst, Planning and Analysis Branch — Vicki Thomas
Budget Analyst, Account & Budgeting Unit — Cyndy Colantoni
Director, Central Regional Laboratory, Environmental Service Division —
Chief, Curtis Ross Municipal Facilities Branch, Water Division (Construction
Grants) — Todd Cayer
Chief, Remedial Program Staff, Great Lakes National Programs
Office — Vacys Saulys
Deputy Director, Environmental Services Division — Thomas Yeates
Deputy Regional Counsel — David Ulirich
Deputy Director, Water Division — Dale Bryson
Director, Air Management Division — David Kee
Region VI — Dallas, Texas
Deputy Regional Administrator — Frances Phillips
Assistant Regional Administrator for Management — John Floeter
Air & Waste Management Division — Allyn Davis
Water Management Division — Myron Knudson
Environmental Services Division — Oscar Ramirez
Budget Officer — Jane Moore
Financial Management Officer — Richard Kenyon
EPA Environmental Research Laboratories :
Cincinnati, Ohio
Director, Industrial Research Laboratory (LERL) — David Stephan
Director, Municipal Environmental Research Laboratory (MERL) — Francis Mayo
Director, Drinking Water Research Division (MERL) — Gordon Robeck
Director, Office of Administration — William Benoit
Deputy Director (?4ERL) — Lou Lefke
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B—5
Program Analyst (MERL) — Robert Bridges
Director, Environmental Monitoring Laboratory — Robert Booth
Director, Center for Environmental Research Information (cERI) —
Cal Lawrence
Office of Management and Budget
Deputy Associate Director for Natural Resoruces — Donald Crabill
thief, Environment Branch — David Gibbons
Budget Examiner - Robert Fairweather
Budget Examiner — Richard Brozen
Congress
Professional Staff Member, Senate Committee on Environment and
Public Works — Ann Vom Eigen
Professional Staff Member, Senate Subcommittee on BUD—Independent
Agencies, Committee on Appropriations — Wallace Berger
Staff Assistant, House Subcommittee on BUD—Independent Agencies;
Committee on Appropriations — Richard Malow and Donald Ryan
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c—i Appendix C
DOCthENTS REVIEWED BY THE NAPA/EPA BUD(ZT PRO SS STUDY TEAM
1. Briefing Documents :
• Overview of the Environmental Protection Agency , prepared for the
National Academy of Public Administration, August 25, 1983
o EPA ’s Budget...Overview, Structure, Process, Issues , June 8, 1983
• FT 1983 Budget Process Volume I, II and III
— FT 1983 Guidance and Process
— FT 1983 Budget Call Letter
— FT 1983 National Program Manager CNN) Submission
— F! 1983 Paseback (Agency)
— FY 1983 Appeals (Agency)
— F! 1983 Budget Submission to 0th (2 volumes)
— A—li Preparation and Submission of Budget Estimates
— Items Prepared in Accordance with A—il
— FT 1983 Passback (0 (B)
— FT 1983 Appeals (0(B)
— Requirements and Format for 1983 Congressional Submission
— FT 1983 Justification of Appropriation Estimates for
Committee on Appropriations (1 volume)
— Press Conference Materials
— Workload Model Call Letter
— “White Paper” on Workload Analysis
— Survey of Workload Analysis Methods
— Summaries of 23 Workload Models
— Sample Workload Model Allocation Procedures
— Workload Models
— Operating Plan Call Letter — Phase I
— Operating Plan Call Letter — Phase II
— Operating Plan Highlight Memo
— Operating Plan Call Letter — Phase III
— Contracts Submission
— Analysis of Congressional Action on FT 1983 Appropriation Bill
— FT 1983 Allowance Letter
• Region Ii Budget Process and Internal Controls , FT 84 Briefing Book
o Region V FY84 Regional Planning Process Guidance , March 8, 1983
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C—2
2. EPA Manuals :
o Organization and Functions Manual , 1982 Edition
o Delegations Manual , Environmental Protection Agency, May 7, 1982
• Planning and Budgeting Manual , April 11, 1980
o Resource Management Information System , EPA Comptroller ‘s
Office, June 1981
o Budget Tracking Module User’s Guide , ORD, March 1982
o Fund Control Manual , July 11, 1975
o Financial Management Manual , August 19, 1976
o Timekeeping Minual , July 27, 1983
3. EPA Reports and Published Documents :
o Administrator’s Guidance Operating Year F! 1984 — Budget Year
FY 1985 , EPA February 1983
0 Water Research Strategy FY 1985 — (Draft Report, March 31, 1983)
° Office of Water Operating Guidance and Accountability System ,
FY 1984, Office of Water, March 1983
0 Administrator’s Management Accountability System FY83 Goals,
Objectives Committments and Measures , November 3, 1982
° EPA Administrator’s Management Accountability System — Third
Quarter FY 1983 Report
° Office of Research and Development Prcgram Planning and Documentation
Guide , EPA August 14, 1983
° Planning in the EPA Regional Offices , Prepared by Planning &
Evaluation Branch, Region I, September 1982
- ° Region V — FY84 Regional Planning Process , March 8, 1983
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C—3
• Environmental Management Report , Region X, March 1983
• Office of Research and Development (ORD) Laboratory/
Project Coimnittee Report , June 11, 1982 — Committee for
the Review of the Organizational and Scientific Capability
of ORD Laboratories
• Policy and Management Review of Headquarters/Regional
Relationships , September 1983
• Final Report of the State/Federal Roles Task Force ,
September 14, 1983
• Streamlining EPA Procurement, Procedures and Processes :
Project Summary of the Procurement Review Task Force — August
1983 EPA
• Recommended Approach for Consolidated Management of the
Agency’s ADP Resources , ADP Consolidation Task Force — Feb. 26,
1982
• Regional Support Services Fund Study Findings , February 17,
1982
o Budget Structure and Codes — FY 1983, FT 1984
o FT 1984 RCM/Superfund Workload Analysis , 28 September 1983
• F! 1984 Analysis of Object Class by Program Element , Report
to Office of Management and Budget
• Analysis of Action on FT 1984Appro priatioi iJ 1 U. Office of
the Comptroller, July 12, 1983
• Region II Accomplishments and Coals , F! 1982 1983
• Region II FT 1984 Operating Plan , 10 June 1983
• Region V — Environmental Services Division Activities
Report , 10/26/83
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C—4
4. Audit Reports :
0 Final Report of EPA’s Portion of the Hazardous Substance Response
Trust Fund as of September 30, 1982 , Office of Inspector General,
March 31, 1983
0 Review of the Office of Research and Development’s Extramural
Research Activities, Audit Report , Office of the Inspector
General, March 31, 1983
o Report to the Administrator Environmental Protection Agency:
EPA’s New Research Controls: Problems Remain . General Accounting
Office, July 14, 1981
0 Promising Changes Improve EPA’s Extramural Research; More
Changes Needed , General Accounting Office, October 28,
1980
0 - Accounting and Reporting of Resources Under EPA’s Formal Plan-
ning and Reporting System, Region IV , Office of the Inspector
General, October 22, 1979
5. Contractor Reports :
0 Cost Allocation Feasibility Study for the Superfund Program ,
September 1983, Allen & Hamilton, Inc.
0 Laboratory Information Resources for Research Program Management ,
April 13, 1983, Urban Systems Research and Engineering, Inc.
0 Integrated Budget Systems Development Functional Requirements ,
December 3, 1982 — Electronic Data Systems Corporation
0 Integrated Budget Systems Development, Data Element Matrices and
Data Base Evaluation , December 3, 1982 — Electronic Data Systems
Corporation
0 Environmental Protection Agency Strategic Planning Review ,
October 6, 1978, Programatics, Incorporated
6. External Publications :
0 Selected Environmental Law Statutes 1983 Edition , St. Paul Minn.
West Publishing Company, 1983
o Revitalizing Federal Management: managers and their overburdened
systems , National Academy of Public Administration, November, 1983
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C—5
7. Correspondence :
° Workplan for Review of EPA Statutory Authority , From: Milton
Russell, Assistant Administrator—Designate for Policy, Planning
and Evaluation; To: Deputy Administrator, November 15, 1983
o Development of Operating Year Guidance for FY 1985 and FT 1986 ,
From Deputy Administrator To Assistant Administrators, Inspector
General, Associate Administrators and Regional Administrators,
o Reorganization , From: Director, Office of Information Resources
Management, To: The Staff, Oct. 27, 1983
• Minutes from Budget & Management Task Force From: Robert Springer,
Region V, October 20, 1983
o Preliminary Working Capital Fund Design Paper . Prom: Roger
Coates to Edward J. Ranley, Director Of ISS, Sept. 23, 1983
o Action Tracking System (ATS) , From: Alvin I. Alm, Deputy
Administrator, To: Assistant Administrators, Inspector
General, Associate Administrators, Deputy Regional Administrators,
Office Directors, September 20, 1983
o Streamling EPA’s Management Structure , From: Alvin L. Aim,
Deputy Administrator, To: Howard M. Messner, Assistant
Administrator for Administration, September 16, 1983
o Streamlining EPA’s Management Structure—Action Memorandum
To: Administrator, September 9, 1983
o ADP Modernization Program for the Environmental Protection Agency ;
From: Edward J. Manley, Director, Office of Management Information
and Support Services; To: Assistant Administrators, Associate
Administrators, Regional Administrators, and Inspector General,
September 9, 1983
o Interim EPA Policy on Mic- ” ictor, Office of
Management Information and -- Assistant Admini-
strators, Regional Administrators and L 1 ry Directors,
September 9, 1983
o Review of EPA Statutory Authority , From: Administrator Ruckelshause,
To: Assistant Administrators, Associate Administrators, Regional
Administrators Inspector General, August 12, 1983
° Deadlines for Submission of FY 1985 Budget Request Material , From:
Samuel T. Rondberg, Director, Office of Research Program Management,
To: ORD Office Directors, Program Operations Directors and
Research Committee Chairmen, Jun. 22, 1983
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