United States
Environmental Protection
Agency
Office of Enforcement &
Compliance Assurance
Washington, DC 20460
December 1995
EPA 300-B-95-006
Strategy for Improving
Environmental Management
Programs at Civilian
Federal Agencies
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This document was prepared by Richard Satterfield in EPA's Office
of Federal Facilities Enforcement. Consulting assistance was
provided by Gilah Langner through SciComm, Inc. For information
on the Civilian Federal Agency Task Force, please contact Richard
Satterfield or the contacts listed in the Appendix to this document.
For additional copies of this document, please contact:
Federal Facilities Enforcement Office
U.S. EPA (2261)
401 M Street SW
Washington, D.C. 20460
Fax: 202-260-9437
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Strategy for Improving
Environmental Management
Programs at Civilian
Federal Agencies
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
NOV 2 I 1995
OFFICE OF
ENFORCEMENT AND
COMPLIANCE ASSURANCE
Dear Colleague,
Federal agencies find themselves in the midst of a variety
of new environmental management responsibilities and reporting
requirements. All of this comes at a time when budgets are
increasingly constrained and resources pared to a minimum. All
the more important, then, is a careful assessment of where the
most urgent needs are, how existing resources can be better
deployed to meet these needs, and how federal agencies and EPA
can work together to achieve higher levels of environmental
The enclosed document, Strategy for Improving Environmental
Management Programs at Civilian Federal Agencies, provides such
an assessment. The document is the product of the Civilian
Federal Agency Task Force, convened in 1992 and 1993 to address
the problems faced by civilian federal agencies (non-DOD, non-
DOE) in meeting their environmental challenges. Membership on
the Task Force includes representatives from the Departments of
Agriculture, Commerce, Health and Human Services, Interior,
Justice, Transportation, Treasury, and Veterans Affairs, the
Central Intelligence Agency, Environmental Protection Agency,
General Services Administration, National Aeronautics and Space
Administration, National Science Foundation, National Security
Agency, U.S. Postal Service, and Tennessee Valley Authority. The
document itself was prepared by EPA's Federal Facilities
Enforcement Office as the chair of the Task Force; it has been
reviewed by all members of the group.
As the strategy notes, despite efforts on the part of some
agencies to redefine their missions to include environmental
stewardship, most civilian federal agencies still lag
considerably behind the environmental performance curve. Six
areas of need are identified in this report as the most
significant areas of deficiency. Recommendations developed by
the Task Force to improve these deficiencies range from the
simple -- providing agency points of contacts with an EPA
Headquarters telephone directory --to the more difficult, such
as developing compatible, automated systems to track compliance
status and maintain environmental documentation. These
recommendations are listed in Chapter 2. Short-term measures are
discussed in Chapter 3, and longer-term efforts are detailed in
quality
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Chapter 4. The Task Force's recommendations address EPA as well
as other federal agencies. Out of 31 recommendations, 21 call
for EPA action.
We are all encouraged by the increasing attention that many-
federal agencies are giving to environmental issues. Civilian
federal agencies represent a tremendous potential for
environmental excellence and a proactive approach to
environmental management. With coordination and effective
exchange of information, the resources and talents of federal
agencies can be marshalled to provide the source of leadership in
environmental management which the President has called on us to
provide. This strategy can help us, individually and as a
federal community, use our resources more efficiently, prioritize
our efforts, and make the goal of federal environmental
leadership a reality.
Barry N. Breen
Director
Federal Facilities Enforcement Office
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TABLE OF CONTENTS
Executive Summary i
I. Introduction 1
A. Background 1
B. CFA Environmental Program Issues 4
C. Goals and Objectives 8
II. Task Force Findings & Recommendations 10
A. Defining Six Areas of Need 10
B. Survey of CFA Environmental Program Needs 11
C. Work Group Findings 12
1. Environmental Management Training 15
2. Information Resources 15
3. Communications 16
D. Task Force Recommendations 18
1. Environmental Management Training 19
2. Information Resources 20
3. Compliance Monitoring 21
4. EPA Assistance on Specific Compliance Issues 21
5. Sufficient Staffing 22
6. Communications 23
HI. Short-Term Strategies 25
A. Enhanced Regional Activities 25
B. Catalogue of Federal Agency Publications 29
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C. Executive Guidance for Civilian Agency Senior Management 29
D. Technical Assistance in Environmental Auditing 30
E. Establishing Informational Networks 32
F. On-Line Access to EPA's FFTS and Other Databases 33
G. Information on Training Opportunities 35
H. Internal Improvements at Civilian Agencies 35
IV. Longer-Term Measures 36
A. Promoting Environmental Management Training 36
B. Developing and Retaining Experienced Environmental Staff 37
C. Satisfying Broad-Based Needs for Information on
Technology and Program Methods 39
1. Coordination Among Partnership Groups 39
2. Improving Automated Information Management Systems 40
3. Creating an EPA Library of Technical Documents 41
4. Establishing a Benchmark Communications Network 41
D. Environmental Challenge Program 43
E. Providing a Forum for CFA Concerns 45
F. Making EPA a More Responsive Partner 47
G. Inspections and Enforcement at CFA Installations 48
V. Measuring Success 54
VI. Conclusion 56
Appendix: CFA Task Force Member list 57
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RELATED DOCUMENTS
Civilian Federal Agency Environmental Program Needs Analysis, Final Report.
November 1993.
CFA Work Group Reports, December 1993.
EPA Region 6 Environmental Program Review Process.
Environmental Program Review Survey Results.
Overview of EQIP Initiative at Region 6; Memorandum of Understanding
Between EPA Region 6 and Tinker Air Force Base
These documents are available from:
Federal Facilities Enforcement Office
U.S. EPA (2261)
401 M Street SW
Washington, DC 20460
Fax: 202-260-9437
These documents can also be accessed electronically on a PC computer through the
FFLEX Bulletin Board System, available on EPA's Enviro$ense Environmental Information
System. Enviro$ense is accessible via modem at 703-908-2092 (modem settings 8, N, 1,
emulation VT-100 or ANSIBBS) and via the Internet (World Wide Web) at:
http://wastenot.inel.gov/enviiosense
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STRATEGY FOR IMPROVING
ENVIRONMENTAL MANAGEMENT PROGRAMS
AT CIVILIAN FEDERAL AGENCIES
Executive Summary
Purpose
This document addresses the environmental needs and potential for
improvement at civilian federal agencies.1 The strategy is the product of the Civilian
Federal Agency Task Force, convened in 1992 and 1993 to address the problems faced
by federal agencies in meeting their environmental challenges. This document was
prepared by EPA's Federal Facilities Enforcement Office (FFEO) as the chair of the Task
Force; it has been reviewed by all members of the group.
Background
Recent legislative and executive actions have placed additional legal
requirements and reporting responsibilities on federal agencies and have focused
attention on their environmental performance. Despite efforts on the part of some
agencies to redefine their missions to include environmental stewardship, most CFAs
are lagging considerably behind the environmental performance curve and may be
responsible for significant cleanup and compliance problems that have not yet received
adequate attention. As one example, EPA has determined that between 400 and 500
contaminated sites are owned or operated by 16 CFAs. These sites vary from major
research laboratories and illegal drug operations seized by the Drug Enforcement
Agency to landfills and mines owned by the Departments of Interior and Agriculture.
CFAs often lack the infrastructure, budget, and technical expertise to effectively
manage environmental problems. Resource limitations may force many agencies into a
reactive -- rather than proactive -- posture on environmental compliance. Nor are CFAs
as closely monitored for compliance by EPA or the states as are the Departments of
Defense and Energy. For example, although 56 percent of the federal facilities that EPA
1 Civilian federal agencies (CFAs) include all federal departments and agencies other than
the Department of Defense and the Department of Energy.
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CFA Strategy
Executive Summary ii
Defense and Energy. For example, although 56 percent of the federal facilities that EPA
tracks in its database are owned or operated by civilian agencies, in FY 1994, only 0.4
percent of all CFA facilities were inspected by EPA (38 out of 8,848).2 Meanwhile, the
percentage of CFA facilities among all federal facilities with RCRA Class I violations
increased from 13 to 24 percent between FY 1993 and FY 1994.
At the heart of the problem is the failure of many smaller federal agencies to
embody environmental compliance in systems that get their employees' attention, such
as management commitment, reward systems, or personnel performance evaluation
criteria. As a result, when hazardous waste contamination or violations of
environmental statutes do occur, these agencies are more likely to produce an
inappropriate response to the problem. This in turn compromises the personal liability
of the agency's employees and the compliance status of the agency and its facilities,
and increases the potential for third party impairment or loss and associated legal
complaints.
Findings
A 1993 survey conducted by the Task Force received responses from 27 CFAs,
confirming these problems:
• Over 80% of the CFAs reported that they have no formal compliance
training program at either the regional or installation level for employees
charged with ensuring agency compliance.
• 77% of the agencies reported that they have no training programs to
foster the implementation of pollution prevention strategies as part of the
agency's mission.
• Only 22% of the agencies reported having a formal award system that
encourages environmental compliance among agency employees.
2 U.S. EPA, The State of Federal Facilities: An Overview of Environmental Compliance at
Federal Facilities, FY 1993-94, November 1995.
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CFA Strategy
Executive Summary iii
• Only 40% of the CFAs have conducted a third-party assessment of the
effectiveness of their agency's environmental management program in
reducing violations and risks.
• 50% of respondents have not identified environmental liabilities from past
operations or are only now in the process of developing a plan to do so.
• 50% of the agencies reported that they do not perform risk evaluations of
environmental cleanup contractors prior to award, or that they did not
know of such evaluations.
• Only one agency reported having an agency-wide system or database to
ensure that proper records (e.g., waste manifests, biennial reports, permit
status, etc.) are maintained and updated.
Goals
As part of the development of a strategy to improve CFA environmental
performance, the Task Force articulated the following overarching goals of this effort:
• Assist CFA environmental compliance and management programs in
evolving to higher levels of performance by providing accelerated access
to resources.
• Improve communications between EPA headquarters, EPA regions, federal
agencies and facilities.
• Give federal agencies that have more experience and expertise (i.e., the
Department of Defense and the Department of Energy) the opportunity to
demonstrate leadership by sharing information and helping other agencies
resolve environmental problems.
• Provide EPA with an opportunity to improve federal agency
environmental management and compliance performance through
technical assistance, compliance assistance, and outreach.
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CFA Strategy
Executive Summary iv
Needs and Recommendations
The Task Force identified six areas of highest need for improving CFA
environmental program management. These are outlined below, together with the
Task Force's major recommendations for short-term and long-term action and, where
applicable, EPA's commitments to actions that respond to the recommendations.
(1) Environmental Management Training
Inadequate training and a shortage of on-board expertise in environmental
management are key impediments to compliance. What training programs do
exist are not well publicized and are frequently inadequate or duplicative across
federal agencies.
Recommendations:
• CFAs should promote joint training opportunities across agencies.
• CFAs should identify and publicize training resources available within
individual agencies. These resources include training programs, listings of
qualified instructors, and training facilities.
• Specific training deficiencies identified in the CFA Needs Analysis Report
should be addressed. These include training relative to regulatory affairs
and policy development, generic environmental management training,
and environmental compliance and contract management.
• Each CFA must find internal support for establishing mature
environmental compliance training programs. Specifically, each agency
must address how to establish formal compliance training systems, keep
employees informed of changing EPA regulations, integrate EPA policies
in agency missions and implementation phases, and use awards and
performance review mechanisms to encourage environmental compliance.
EPA Actions:
• EPA will assist agencies in advertising training opportunities and
resources, and will offer training in environmental auditing as well as
expanded training through its regional offices.
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CFA Strategy
Executive Summary v
• EPA will establish an environmental training opportunities bulletin board
for federal agencies in FY 1995.
(2) Information Resources
Regulatory requirements are voluminous and subject to change. Many CFAs
have difficulty finding timely and reliable sources of information on new and
proposed regulations and on innovative technologies and management
strategies.
EPA Actions: Several initiatives are planned that will enhance CFA access to
environmental information:
• EPA's federal facilities electronic bulletin board (FFLEX) will become part
of a larger EPA bulletin board system called Enviro$ense, that will
provide information at-a-glance on new and proposed regulations,
executive orders, guidance, interagency work groups, funding sources,
and other items of interest to federal agency environmental compliance
officers.
• EPA will compile and publicize listings of federal partnership/work group
activities through the monthly Roundtable and other computerized
network means.
• EPA intends to pursue the development of a Benchmark Communication
Network that will allow federal managers to discuss and exchange
environmental program management information on-line and to
benchmark their programs against the best in the public and private
sectors.
For written publications, EPA has developed a Catalogue of Federal Agency
Environmental Compliance/Management Documents. The Federal Aviation
Administration is developing an Executive's Guide to Environmental Management;
other guidance materials are underway as well. EPA will maintain a library or
repository of technical information specifically for federal agency audiences.
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Executive Summary vi
(3) Compliance Monitoring
Most CFAs lack a centralized data management system that alerts agency
headquarters personnel to changes in facility compliance status, regulatory
violations, and pending enforcement actions.
Recommendations:
• Agencies that are still using manual systems to manage and track
environmental compliance information should begin developing
automated systems compatible with other agencies.
• CFAs need to establish minimum grade levels for environmental positions
and to develop performance standards for environmental personnel to
ensure accountability.
EPA Actions:
• EPA will provide CFAs with on-line access to the new Federal Facility
Tracking System to permit a multi-media view of compliance activities at
federal sites. EPA will also develop a PC-based software program for A-
106 submissions, called FEDPLAN-PC.
• EPA will encourage other federal agencies with more advanced
environmental programs to share information on computer technologies,
innovative approaches, and information management approaches with
CFAs.
• EPA will host demonstrations of software and computer systems
developed by other federal agencies at meetings of both the Federal
Agency Roundtable and the CFA Task Force.
• EPA plans to make better use of FFTS data to increase inspections and
enforcement attention at CFA installations. EPA will also provide
increased compliance assistance to civilian agency environmental
managers and other personnel in FY 1996 and beyond. In addition,
federal agencies will be given access to non-enforcement sensitive data in
EPA's FFTS that they can utilize for their own performance and tracking
purposes.
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CFA Strategy
Executive Summary vii
(4) EPA Assistance on Specific Compliance Issues
Smaller agencies would benefit from tapping EPA's environmental management
expertise to develop internal compliance programs, pollution prevention
strategies, environmental auditing, and other policies.
Recommendations:
• The Task Force should continue to develop a set of generic documents
that provide guidance on complying with environmental regulations, and
examples of how compliance programs can be better managed to reduce
the risk of regulatory excursions and environmental releases.
EPA Actions:
• Each EPA region will be encouraged to conduct at least one multi-media
enforcement inspection at a CFA facility in FY 1996. EPA will also refine
FFTS reports to determine how much of an increase in inspections and
enforcement attention at CFA facilities is needed.
(5) Sufficient Staffing
Most smaller agencies have a limited number of experienced technical staff.
Greater in-house expertise is needed in hazardous material/waste management,
pollution prevention technology, and environmental engineering as well as
actual experience in hazardous waste site remediation.
Recommendations:
• CFAs should encourage designated environmental career paths and the
establishment of needed staff positions to achieve the expertise required
to address environmental issues.
• EPA and CFAs should consider reciprocating rotational assignments,
hiring personnel with CFA/EPA experience, and other mechanisms such
as Intergovernmental Personnel Agreements (IPAs) to foster team
building and cross fertilization of ideas.
EPA Actions:
• EPA will seek opportunities to detail CFA environmental officers into
short-term assignments at EPA.
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CFA Strategy
Executive Summary viii
(6) Communications
Many CFAs encounter a confusing lack of consistency on regulatory
requirements between EPA headquarters and regional offices. A lack of
understanding of each other's organizational structures, budgeting processes,
and current priorities is a problem for both CFAs and EPA.
Recommendations:
• EPA and CFAs should both seek team building and partnering
opportunities on environmental projects of mutual interest.
• CFAs should involve EPA headquarters and regions in internal agency
conferences and meetings to explain to their staffs how EPA is structured
and where assistance can be obtained for addressing issues. CFAs should
also involve EPA headquarters and regions in making presentations to
CFA staff on technical issues.
• EPA should develop standardized guidance on how CFAs can best work
with both EPA headquarters and regional offices.
• EPA should define a clear-cut dispute resolution process to handle
situations where two or more EPA regions interpret the same regulation
in different ways and have different enforcement responses.
EPA Actions:
• EPA will clarify the federal facilities role of EPA's regional offices. EPA
will sponsor a national meeting to facilitate discussions between CFA
headquarter personnel and EPA regional coordinators.
• EPA/FFEO and the regional Federal Facility Coordinators (FFCs) will
work together to develop standardized guidance for federal agency
environmental officers. The guidance will describe roles and
responsibilities of FFCs at EPA regions and headquarters. The guidance
will also offer advice to federal agency personnel on raising
environmental issues to EPA and whether the issue should be raised at
the regional or headquarters level. The guidance will also list key
regional points of contact including media specialists and FFCs.
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Executive Summary ix
EPA will strive to develop a consensus with Task Force members on the most
effective ways to implement these and other recommendations. EPA will offer
continued technical assistance to foster improvement in CFA compliance programs,
building on the success of recent initiatives to establish permanent networks and
databases to promote compliance and environmental excellence at smaller federal
agencies. More broadly, EPA recognizes the unique environmental management
concerns faced by smaller-sized federal agencies and will seek to ensure that these
concerns are reflected in the development of national strategies, enforcement policies,
and outreach initiatives conducted by FFEO.
These efforts represent a first, albeit significant, step in forming lasting
partnerships among federal agencies. Another important collaborative effort will be
the development of the Federal Government Environmental Challenge Program
mandated under Executive Order 12856. The Environmental Challenge Program will
provide a vision to federal agencies to go beyond compliance with the law by
developing state-of-the art environmental management programs and implementing
pollution prevention concepts into all aspects of their operations.
Both management and staff level employees at federal agencies are continually
"on the line" making decisions that affect an agency's compliance status. An
environmental management program that is purely reactive to regulations and
environmental practices will be a serious handicap for a federal agency in the years
ahead. Civilian federal agencies represent a tremendous potential for environmental
excellence and a proactive approach to environmental management. With coordination
and effective exchange of information, the resources and talents of federal agencies can
be marshalled to provide a source of leadership in environmental management.
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1
I. INTRODUCTION
A. Background
The emergence of new laws and executive orders over the last several
years has focused increased attention on the environmental performance of
federal facilities.
Executive Order 12856 requires federal agency compliance with the all
requirements of Emergency Planning and Community Right-to-Know Act of 1986
(SARA Title III). Under Executive Order 12088, federal agencies are required to
comply with applicable federal, state and local environmental statutes and
regulations.1 The 1992 Federal Facility Compliance Act (FFCA) requires federal
facilities to be treated the same as private parties with regard to compliance
with the Resource Conservation and Recovery Act (RCRA). The FFCA also
allows the imposition of stiff fines and penalties for federal facilities found to be
out of compliance by EPA or state inspectors. Recent modifications in federal
and many state criminal enforcement laws and policies are likely to encourage
federal prosecutors to consider whether violations are criminal offenses and to
target officials responsible for environmental crimes.
The task of maintaining environmental compliance is daunting, with over
11,000 pages of codified regulations spanning a full range of multi-media issues.
Congress continues to add amendments to existing laws, such as the 1990 Clean
1 RCRA and the Comprehensive Environmental Response Compensation and Liability Act
(CERCLA) require federal agencies to comply with their procedural provisions including
penalties for violations. Prior to passage of the FFCA, EPA took RCRA enforcement actions
against federal agencies differently than against private parties, negotiating Federal Facility
Compliance Agreements to bring federal facilities into compliance. In passing the 1992 Act,
Congress clarified that administrative order authority has been given directly to the EPA
Administrator. The waiver of sovereign immunity found in RCRA was amended by the 1992
FFCA. Congress further clarified in the Act that federal agencies are "persons" for the purpose
RCRA. Therefore, EPA now has administrative compliance order authority against federal
facilities.
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CFA Strategy
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Air Act Amendments, and over 100 new major regulations are expected from
EPA this year alone. The complexity of the situation is further complicated by
the activities of state legislatures, many of which are producing legislation and
regulations faster than the federal government. Moreover, most environmental
laws are reauthorized every 5-8 years and each new reauthorization represents
new requirements and ultimately new compliance expenditures. With nine
major environmental laws, at least one statute is up for reauthorization every
year.
An environmental management program that is purely reactive to these
manifold requirements is a serious handicap for federal agency personnel and
their managers. As David Osborne and Ted Gaebler noted in their book,
Reinventing Government,
"anticipatory governments do two fundamental things: (1) they use an
ounce of prevention rather than a pound of cure; and (2) they do
everything possible to build foresight into their decision making."
Osborne and Gaebler also observed that "some governments are not only trying
to prevent problems, they are working to anticipate the future and to give
themselves radar, and to prevent problems before they emerge rather than
simply offering services afterward." Many organizations, both corporate and
public, have begun to recognize that to reduce liability and unnecessary costs,
regulatory compliance should become the floor, rather than the ceiling, of
environmental performance.
In all this, the role of the federal agency environmental compliance officer
is crucial. He or she must monitor the agency's compliance with environmental
statutes and regulations and create and oversee effective programs that promote
compliance, protect human health, and preserve the environment. Basic to the
compliance officer's completion of responsibilities are the enabling systems or
infrastructure within an agency that support environmental compliance as
foundation of an effective environmental program. These enabling systems
should cut across all planning, organizing, implementing and measuring
processes within the agency.
To prevent environmental problems from happening, federal agencies are
beginning to redefine their own missions to include environmental stewardship.
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Environmental stewardship is environmental management that goes beyond
compliance and includes more proactive efforts such as pollution prevention,
natural resource conservation, and environmental management programs
deemed "state-of-the-art" by organizations, peers and stakeholders.
Two federal agencies, the Department of Defense (DoD) and the
Department of Energy (DOE) have allocated sizeable funds and created large
internal staff and programs to oversee and ensure compliance. Both DoD and
DOE have created an infrastructure to support environmental compliance
policies by anchoring these functions at relatively high levels (e.g., Assistant
Secretary) within their respective agencies. Within DoD, the Army and Air Force
are designing enhanced environmental programs that go beyond compliance by
emphasizing pollution prevention and other proactive programs such as the
Total Quality Environmental Management (TQEM) concept created by the
Global Environmental Management Institute.
Nevertheless, there is growing public concern that federal agencies other
than DoD and DOE are lagging considerably behind the environmental
performance curve and may be responsible for significant cleanup and
compliance problems that have not yet received adequate attention.
Executive Order 12088 (section 1-3) requires EPA to provide technical
assistance and guidance to federal agencies to assist them in complying with
environmental regulations and statutes. EPA has undertaken a variety of
initiatives in response to this mandate (see box on next page). Despite the value
of these efforts, however, specific assistance to smaller federal agencies has been
lacking. For example, the Federal Agency Environmental Roundtable, because of
its large membership size, cannot offer enough opportunities for detailed
compliance and technical assistance-related dialogues between EPA and other
agency representatives. Representatives from CFAs have also reported that their
own concerns become submerged when they raise issues in conceit with the
larger federal agencies (i.e., DoD and DOE). In addition, databases and
publications that are currently available are often not exclusive or specific to
federal agencies.
This strategy document is intended to address the environmental needs
and potential for improvement at civilian federal agencies. This strategy is the
product of the Civilian Federal Agency Task Force, convened in 1992 and 1993
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CFA Strategy
4
Existing Technical Assistance Initiatives at EPA
EPA established a Federal Agency Environmental Roundtable to provide a forum for
exchanging information on EPA policies and regulations. Fifty federal departments and
agencies participate in the monthly meetings. The Roundtable also provides information on
pollution prevention, guidance for performing environmental audits, pollution control
techniques, as well as successful hazardous waste technologies.
Each EPA Regional Office has appointed a Federal Facility Coordinator (FFQ and held
regional federal facility roundtable sessions and annual workshops in an effort to provide
technical information and assistance to federal facility installation managers.
EPA has also produced a variety of guidance documents on pollution abatement and cleanup.
Some, such as the 1988 EPA guidebook, Federal Facility Compliance Strategy (which is
currently being updated), were produced specifically for federal agencies. EPA has also
produced guidelines for conducting environmental auditing and constructing audit programs
at federal agencies. Other public information tools have been developed as well, including
EPA dockets, clearinghouses, hotlines, and databases available on both printed and computer
media. EPA's Office of Research and Development (ORD) in conjunction with EPA's
Technology Innovation Office have begun development of a bulletin board that will provide
a listing of environmental training opportunities exclusively for federal agency employees.
to address the problems faced by federal agencies in meeting their
environmental challenges. The document was prepared by EPA's Federal
Facilities Enforcement Office (FFEO) as the chair of the Task Force; it has been
reviewed by all members of the group. The findings and recommendations of
the Task Force are outlined in Chapter II, and detailed steps toward
implementing the recommendations in Chapters III and IV. The remainder of
this chapter discusses environmental program issues at civilian federal agencies
and the goals and objectives of the Task Force.
B. CFA Environmental Program Issues
In September 1993, an accompanying report of the National Performance
Review, Reinventing Environmental Management, stated: "the federal government,
which manages about a third of all land in the United States, needs to clarify its
commitment to a clean environment." The report found that environmental
management was divided among numerous federal agencies with inconsistent
mandates and conflicting jurisdictions that follow bureaucratic, rather than
ecological, boundaries. The report concluded that most federal agencies have
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CFA Strategy
5
focused too little time on the concept of ecosystem management and
recommended that federal agencies develop collaborative programs around
common goals.
This strategy responds directly to the need for civilian federal agencies
(CFAs) to develop a more cooperative approach and develop partnership efforts
to solve common problems. The recommendations contained in this document
are a result of a collaborative effort of EPA and federal agencies to establish a
common goal of improving environmental performance.
Several studies have corroborated that civilian federal agencies have not
fully assessed their environmental liabilities nor developed adequate
environmental programs (see box on next page). A recent EPA study found that
16 civilian federal agencies own or operate 400 to 500 contaminated sites.4
These sites vary from major research laboratories and illegal drug operations
seized by the Drug Enforcement Agency to landfills and mines owned by the
Departments of Interior and Agriculture. To address cleanup at these sites,
federal agencies have requested over $1.1 billion for hazardous waste
remediation activities for fiscal years 1991-1995.
CFAs often lack the infrastructure, budget, and technical expertise to
effectively manage environmental problems. Facing resource constraints, agency
employees may be forced to choose between environmental considerations and
accomplishing the agency's mission tasks. Resource limitations may force many
agencies into a reactive -- rather than proactive -- posture on environmental
compliance. In some cases, federal properties owned by one agency are leased
to other federal agencies, leading to interagency disputes regarding
contamination assessment and cleanup responsibility. In addition, many CFAs
are not closely monitored for compliance by EPA or the states.
As a result, when hazardous waste contamination or violations of
environmental statutes do occur, these agencies are more likely to produce an
inappropriate response to the problem. This in turn compromises the personal
liability of the agency's employees and the compliance status of the agency and
its facilities, and increases the potential for third party impairment or loss and
4 U.S. EPA, Market for Innovative Treatment Technologies for Remediation of Hazardous Waste
Sites, September 16, 1992.
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CFA Strategy
6
Documenting CFA Program Limitations
A May 1990 study for the Congressional Budget Office reports that in addition to the
significant cleanup and compliance problems facing DoD and DoE, other federal agencies
have also developed significant environmental liabilities and are also liable for major
environmental compliance problems (CBO, Federal Agency Summaries, May 1990).
In 1991, the National Research Council (NRC) formed a committee to evaluate the hazardous
materials management program of the Bureau of Land Management (BLM) of the Department
of Interior (DOI). The committee published the findings and recommendations of this study
in a 1992 report, "Hazardous Materials on Public Lands," and cited several substantial
inadequacies in BLM's Hazardous Materials Management Program (HMMP). According to
the report, the program "...lacked policy direction and initiative; and has been too reactive
and too driven by a singular focus on liability avoidance." The report found that the HMMP
program effectivenesshas been compromised by a shortage of full time professional staff with
the necessary training and experience to investigate hundreds of potentially contaminated
hazardous waste sites, evaluate the field data, and fully identify its environmental liabilities.
In response to the NRC report, DOI's Office of the Inspector General performed a separate
investigation, concurring with many of the same findings reported in the NRC study and
recommending specific improvements to correct deficiencies. These recommendations were
supported by the U.S. Senate Committee on Governmental Affairs in its September 1993
report, U.S. Department of Interior: Environmental Problems and Issues.
Several other reports have substantiated the inadequacies of CFA compliance programs,
including: U.S. Government Accounting Office, Environmental Protection: Solving NASA's
Current Problems Requires Agencywide Emphasis, April 1991; and Argonne National
Laboratory, Assessment of Department of Commerce Hazardous Waste Compliance Programs,
March 15, 1989.
associated legal complaints. A recently released study by EPA confirms that
CFAs lag significantly behind industry leaders such as Chevron, Xerox, and 3M,
as well as their counterparts in federal defense-related agencies (Departments of
Energy, Army, Navy, and Air Force) (see box on page 7).
At the heart of the problem is the failure of many smaller federal agencies
to embody environmental compliance in systems that get their employees'
attention, such as reward systems or personnel performance evaluation criteria.
Agency employees often do not recognize that it is both acceptable and desirable
to think environmentally in performing their daily tasks.
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Benchmarking Federal Agencies
An EPA study compared the performance of CFAs, the Department of Energy, the Army,
Navy, and Air Force, and three private sector corporations (Chevron, Xerox, and 3M). As
part of the study, a series of detailed "Best in Class" descriptors were established in six key
areas of environmental performance: organizational structure; management commitment;
implementation of programs; information collection, use, and follow-up; internal and external
communications; and personnel management. The overall "Best in Class" benchmark
elements are as follows:
• Organizational Structure: Best in Class organizations have an organizational
structure that gives authority, input, and voice to environmental performance.
• Management Commitment: Best in Class organizations possess and demonstrate a
commitment to environmental excellence at each and every stage of the management
hierarchy, and insist on integration of environmental awareness and concerns into
all relevant business operations.
• Implementation: Best in Gass organizations carry out their daily business operations
in ways that integrate environmental protection into their business conduct.
• Information Collection/Management/Follow-Up: Best in Class organizations
continually monitor environmental performance through the use of formal tracking
and reporting mechanisms. Information acquired through these mechanisms is
evaluated, disseminated, and used to continually improve environmental
performance.
• Internal and External Communication: Best in Class organizations foster and use
formal and informal channels to communicate environmental commitment and
performance information. Employee communications is encouraged to develop
cooperation and commitment, including bringing together employees from different
disciplines.
• Personnel: Best in Class organizations ensure that employees are capable of
developing and implementing environmental initiatives. Employees are hired,
trained, and deployed in ways that ensure that staff understand their environmental
responsibilities and receive the training and support necessary to achieve
environmental excellence.
Source: U.S. EPA, Environmental Management System Benchmark Report: A Review of Federal
Agencies and Selected Private Corporations (EPA 300R-94-009), December 1994.
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Despite the obvious benefits, a decision to evolve environmental
management programs to higher levels of performance is not entirely
straightforward. Federal agencies are under enormous pressure to cut spending
and increase staff-to-management ratios. Even though the payback from
investments in new technologies (e.g., information management system for
compliance tracking) is usually significant, the up-front costs may be difficult to
justify to senior agency management. Management may also not realize that the
costs associated with unexpected emergencies (e.g., spill response, lawsuits) are
invariably greater than judicious investments in preventive measures.
C. Goals and Objectives
The purpose of this strategy is to improve environmental management
performance at CFAs. The success of this strategy will be determined by the
degree to which the following goals are achieved:
• Assist civilian federal agencies in evolving their environmental
compliance and management programs to higher levels of
performance by providing access to resources that will improve
compliance and reduce environmental liabilities.
• Improve communications among EPA headquarters, EPA regions
and federal agencies and their facilities.
• Give federal agencies that have more experience and expertise
(e.g., DoD and DOE) the opportunity to demonstrate leadership by
sharing information and helping other agencies resolve
environmental problems.
• Provide EPA with an opportunity to improve federal agency
environmental management and compliance performance through
technical assistance, compliance assistance, and outreach.
To accomplish these goals, the following objectives were outlined:
• Establish an effective dialogue between EPA and CFAs in order to
gain an understanding of environmental program problem areas
and develop an effective strategy to correct these deficiencies.
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• Evaluate the needs of CFAs.
• Convene the CFA Task Force to build consensus on the direction
and scope of the strategy and to foster a team approach to
accomplishing strategy objectives.
• Form work groups to focus on each area of program management
need and develop short-term and long-term recommendations to
address identified needs.
• Identify resource opportunities both within and outside the federal
community to satisfy critical areas of need.
• Bring federal agencies with critical needs together with agencies
with well developed management and compliance programs to
share information and catalyze improvement.
• Create a comprehensive strategy to serve as an implementing tool
for activating the recommendations of the CFA Task Force.
Implementing this strategy should provide the support CFAs need to
ensure fully compliant and sustainable environmental management programs
through a coordinated and integrated federal partnership. The strategy is
intended to help CFAs move beyond compliance and into environmentally
beneficial areas, many of which do not lend themselves to traditional "command
and control" approaches. These partnerships will assist CFAs in performing their
basic environmental work in a more efficient, less costly manner by balancing
regulatory responsibilities with good government practices and matching
resources to priorities.
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II. TASK FORCE FINDINGS & RECOMMENDATIONS
A. Defining Six Areas of Need
One of the principal reasons for convening the CFA Task Force was to
open a direct channel of communication with civilian agency headquarters
personnel to foster an understanding of environmental management problems.
FFEO also sought to gain an understanding of how EPA, through its technical
assistance and outreach programs, could assist these agencies in improving their
environmental management programs.
FFEO began by developing a baseline survey of CFA environmental
management problems, budget shortfalls, technical needs, and other
environmental issues.
During the first two CFA Task Force meetings held on October 19, 1992,
and January 11, 1993, Task Force members held roundtable discussions on key
issues related to management including impediments to environmental
performance. These discussions resulted in a consensus among Task Force
members on six priority areas where improvements are needed in CFA programs
and structure.
The six areas of need are:
(1) Environmental management training. Inadequate training and a
shortage of on-board expertise in environmental management are
key impediments. What training programs do exist are often
duplicative across federal agencies.
(2) Information resources. Regulatory requirements are voluminous
and subject to change. Many CFAs have difficulty finding timely
and reliable sources of information on new and proposed
regulations and on innovative technologies and management
strategies.
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(3) Compliance monitoring. Most CFAs lack a centralized data
management system that alerts agency headquarters personnel to
changes in facility compliance status, regulatory violations, and
pending enforcement actions.
(4) ERA assistance on specific compliance issues and needs. EPA's
environmental management expertise could be enormously useful
if shared with smaller agencies, for example, in providing guidance
to CFAs on developing internal compliance programs, pollution
prevention strategies, environmental auditing, and policies on
remediating sites not listed on the National Priorities List.
(5) Sufficient staffing to provide adequate technical services and support.
Most smaller agencies have a limited number of experienced
technical staff. Greater in-house expertise is needed in hazardous
material/waste management, pollution prevention technology, and
environmental engineering as well as actual experience in
hazardous waste site remediation.
(6) Communications among EPA offices and regions, and between EPA
and other federal agencies. Most smaller agencies indicated
confusion over regulatory requirements due to a lack of consensus
between federal agencies, EPA headquarters, and EPA regions.
These six issues represent areas where improvements can be
accomplished through technical assistance from EPA or other outside sources.
Other enabling systems - such as improved organizational structures, executive
management commitment to environmental programs, improvements in internal
communications, and strategic planning -- were also identified by Task Force
members as being critical to the success of CFA environmental programs. These
enabling systems are not well established at all agencies and therefore may limit
the improvements to be gained through outside technical assistance.
B. Survey of CFA Environmental Program Needs
In order to learn how CFAs have structured their compliance programs,
and to determine the amount and type of technical assistance needed by these
agencies, EPA developed and distributed an evaluation questionnaire to 28 CFAs
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in January 1993. Twenty-seven federal agencies and departments responded to
the questionnaire. The findings were submitted to the Task Force for review
and comment in June 1993, with the final report, Civilian Federal Agency
Environmental Program Needs Analysis, published in November 1993 and
available from EPA/FFEO.
The questionnaire was divided into two parts. Part 1 was designed to
profile existing environmental management methods and infrastructure at these
agencies. Part 2 sought information on the type of technical assistance needed
most to improve environmental performance. The questionnaires were not
intended to provide an in-depth or comprehensive study, but rather to point
toward particular issues that require attention and to give a sense of the extent
of the problem across all civilian agencies. In general, the results of the survey
corroborate the Task Force members' findings and views on CFA environmental
program needs. At the Task Force's request, respondents were allowed to
maintain their anonymity.
The major results of the survey are summarized on the following pages,
organized by the six areas of need.
C. Work Group Findings
To respond to the areas of need, the Task Force formed three work
groups: (1) training-related issues; (2) information resources and compliance
tracking, and (3) communications between federal agencies and EPA. The
remaining areas of need (obtaining EPA assistance and sufficient staffing) were
deferred to a later date. As a first step, the Task Force suggested using
temporary transfers, interagency agreements, and memoranda of understanding
to obtain technical skills and services in hazardous materials management from
other federal and state government offices. The Task Force also discussed the
benefit of either receiving direct technical assistance from EPA or other federal
agencies on a cost-reimbursable basis.
The three work groups met during 1993 and forwarded their findings and
recommendations to the CFA Task Force in December 1993. Each work group
was chaired by an EPA representative, who solicited volunteers from within the
Task Force. The findings and recommendations of the work groups represent a
consensus view of the CFA Task Force on what has to be done to address the six
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Results of the CFA Environmental Program Needs Survey
1. Environmental Management Training
• Over 80% of the CPAs report that they have no formal compliance training
program at either the regional or installation level for employees charged with
ensuring agency compliance.
• Although most CFAs recognized the need to develop formal training programs to
improve environmental performance, 77% of the agencies reported that they have
no training programs to foster the implementation of pollution prevention
strategies as part of the agency's mission.
• 56% of respondents provide written guidance to instruct and advise installation
employees on environmental requirements.
• Only 22% of the agencies reported having a formal award system that encourages
environmental compliance among agency employees.
2. Information Resources
• 56% of respondents have not formally compared their environmental programs
with the programs of other federal agencies or private organizations to identify
strategies for improvement.
• 50% of respondents have not identified environmental liabilities from past
operations or are only now in the process of developing a plan to do so.
• 22% of the agencies indicate that they do not participate in the OMB A-106
process.
• 50% of the agencies reported that they do not perform risk evaluations of
environmental cleanup contractors prior to award, or that they did not know of
such evaluations.
• Only 40% of the CFAs have conducted a third-party assessment of the
effectiveness of their agency's environmental management program in reducing
violations and risks.
3. Compliance Monitoring
• Only one agency reported having an agency-wide system or database to ensure
that proper records (e.g., waste manifests, biennial reports, permit status, etc.)
are maintained and updated.
• 64% of respondents reported that there is no central inventory -- either electronic
or manual ~ that profiles hazardous waste/hazardous material inventories,
emissions or the compliance status at individual agency installations.
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Results of CFA Environmental Program Needs Survey (cont'd.)
• 40% of survey respondents reported that they do not have an environmental
auditing or tracking system in place to oversee and monitor agency compliance
activities.
4. Improved Communications
• Agencies reported needing a better understanding of EPA's enforcement and
regulatory role in enforcing compliance at federal agencies.
• Respondents indicated a need for more clarification on statutory reporting
requirements for federal facilities (e.g., CERCLA 120 Docket and RCRA 3016).
• Nearly 40% of the agencies reported that they have not analyzed the potential
impact of environmental issues on the future mission of their agency.
• 69% of the agencies reported that they do not have well publicized procedures for
reporting environmental problems, violations or criminal conduct within the
agency without fear of retaliation. Several respondents indicated that only
employees (not contractors) are apprised of reporting procedures.
5. Need for EPA Assistance on Specific Compliance Issues
• 45% of the agencies indicated a critical need for EPA assistance in developing
strategies to oversee and monitor environmental management for their agency.
• Agencies reported a growing need for EPA advice and assistance with on-site
remediation technologies, environmental sampling, and data analysis.
6. Sufficient Staffing
• 50% of agencies surveyed reported that compliance with environmental
requirements is not part of their overall performance standards and evaluations of
facility managers or regional directors who have operational and/or property
management responsibilities.
• Only 56% of respondents felt that their executive management demonstrates
support for environmental compliance programs. Six responses indicate "no" or
"minimal support," with several specifically commenting on a lack of budgetary
commitment and staff for environmental compliance programs.
• Agencies reported an increasing need for technical expertise and staffing to assist
with environmental cleanup efforts, including preparing accurate estimates for
tracking costs of cleanup from mobilization to closure; establishing effective
contractual agreements; and understanding terms and conditions of alternative
contract types.
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primary areas of need. The CFA Task Force as a whole reviewed the work group
reports and forwarded written comments to the work group members for
consideration. The final work group reports are available from EPA.
The work group findings are outlined below.
1. Environmental Management Training
The Training Work Group recognized that several challenges in
developing environmental compliance programs exist across agencies. These
include the following:
• Environmental officers generally have little formal training and
often must complete their responsibilities as part of many other
collateral duties;
• Duplication of training programs appears to exist across agencies,
yet programs and information are not shared across agencies;
• Shrinking resources across agencies leave training programs
vulnerable, and failure to leverage federal training investments
may result in fewer training opportunities.
The Civilian Federal Agency Needs Analysis Draft Report issued in June
1993 provided further support to these findings.
2. Information Resources
The Information Resource Work Group focused on the enabling aspect of
adequate information resources, i.e., defining what constitutes a good
environmental management information system and examining the consequences
of having inadequate information systems in place. The following problem areas
were identified:
• Solutions to environmental compliance problems at federal
agencies have, in many instances in the past, resulted in
duplicating efforts at other agencies (reinventing the wheel).
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• Information about guidance, training, and sources of technical
assistance and expertise available to federal environmental
compliance officers is either unavailable or, at best, disjointed and
inconsistent.
• Federal agencies are usually not staffed with enough
knowledgeable environmental professionals to manage adequate
environmental programs. In addition, many agencies have
reported being understaffed with even minimally trained
personnel. As a result, a significant number of federal agency
personnel at every level lack an awareness of legal responsibilities
or appropriate management controls that support compliance and
reduce liabilities.
• Many agencies are not equipped with automated environmental
databases to ensure proper records are maintained and that
reliable data is available to make informed decisions.
• Many agency compliance officers struggle to receive reliable and
timely notification of pending regulations and other pertinent
information that affects environmental performance (e.g., advanced
notification of pending regulations, changes in policies and
executive orders) and legislative actions.
• Agency officials lack information and training on how to evaluate
the performance of their environmental compliance programs and
the appropriate metrics that are necessary to make these
evaluations.
3. Communications
The Communications Work Group defined a vision of effective
communications as a benchmark for identifying current deficiencies and
impediments to communications between CFAs and EPA. Following are the
major impediments identified by the work group:
• The use of jargon/acronyms specific to individual agencies.
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• A lack of understanding of agencies' organizational structures,
budgeting processes, current requirements and priorities (e.g., lack
of line-item appropriations for environmental compliance
activities).
• Many CFA environmental staff are by necessity generalists. They
may not have the same in-depth knowledge as EPA's subject-matter
specialist employed in the various program offices.
• A lack of understanding of (or desire to understand) technical
issues on the part of some individuals involved in the
communication process.
• A lack of consistency across EPA regions regarding policy positions
and enforcement responses for similar scenarios. (Examples cited
include differences across regions, as well as different states within
the same region, regarding cleanup criteria to be used at
hazardous waste sites, and different regulatory approaches in two
or more EPA regions in the vaulted tank issue of 1991. Other
examples include docket reporting under CERCLA 120 and federal
facility hazardous waste site reporting under RCRA section 3016.)
• A lack of prior planning and agreement on the ultimate purpose of
an activity or action, and whether it is worth pursuing.
• A lack of follow-through to ensure that desired results of
agreements and cooperative relationships were understood and
achieved.
• A lack of internal communications regarding coordination efforts
between CFAs and EPA occurring at different levels within these
agencies, and a lack of clear identification of the expectations
resulting from this coordination.
• Differing expectations on the part of EPA and other federal
agencies on what constitutes sound environmental management.
(For example, EPA's emphasis on "going beyond compliance" can
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lead to frustration and poor communication if a CFA's goals and
budget aim at achieving compliance.)
• A lack of standardized computer operating systems among federal
agencies, thus inhibiting the viability of sharing data and
automated communication. (For example, most federal agencies
use DOS as an operating system; some agencies, such as the U.S.
Coast Guard, have incompatible systems.)
• A lack of understanding on the part of CFAs (and Congress) of the
resources actually needed to adequately manage environmental
programs required by statute or regulation. (As an example,
environmental responsibilities are often assigned as a collateral
duty, and employees are given the job as a short-term, 1-2 year
assignment.)
• Some agencies keep a "low profile" or do not have a good
relationship with outside organizations and regulators regarding
environmental matters.
D. Task Force Recommendations
The following recommendations represent the viewpoint of the Task
Force members on actions that need to be taken by EPA and civilian agencies to
address each area of need and improve environmental performance. As such,
they form the framework for the CFA Strategy and should become key factors in
the short and long-term planning processes of CFAs. These recommendations
also represent key elements of EPA/FFEO's long range planning for providing
effective technical assistance to federal agencies.
The recommendations, grouped by the six areas of need, are also divided
into short-term actions (actions that can be implemented within 18 months to
two years) and longer-term actions (3-5 year timeframe). The recommendations
are listed in order of who should initiate or implement the action: EPA, CFAs, or
a combination of both.
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(1) Environmental Management Training
Short-Term Actions
1. EPA should ensure that the "Clu-In" network currently under
development by the Accelerated Training Subgroup of EPA, DoD,
and DOE incorporate notification of individual agency training
opportunities. (The Clu-In network is an electronic bulletin board
display of all environmental training opportunities available
through EPA, DoD, and DOE.)
2. CFAs should promote joint training opportunities across agencies.
3. CFAs should identify and publicize training resources available
within individual agencies. These resources include training
programs, listings of qualified instructors, and training facilities.
4. Each CFA must find internal support for establishing mature
environmental compliance training programs. Specifically, each
agency must address how to establish formal compliance training
systems, keep employees informed of changing EPA regulations,
integrate EPA policies in agency missions and implementation
phases, and use awards and performance review mechanisms to
encourage environmental compliance.
5. CFAs and EPA must ensure that basic environmental compliance
standards and curricula are developed and shared with
environmental officers across agencies.
Long-Term Actions
6. CFAs and EPA should address specific training deficiencies
identified in the CFA Needs Analysis Report. These include
training relative to regulatory affairs and policy development,
generic environmental management training, and environmental
compliance and contract management.
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7. EPA and CFAs should create or designate training clearinghouses
to share information on training opportunities.
(2) Information Resources
Short-Term Actions
8. EPA should create a federal facilities electronic bulletin board that
provides information at-a-glance on new regulations, executive
orders, new guidance under development for federal agencies,
interagency work groups and other activities on environmental
issues, potential sources of funds for program improvements, and
other items of interest to federal agency environmental compliance
officers.
9. EPA should develop an interagency bibliography listing all federal
documents that provide guidance on environmental management
and compliance.
10. CFAs should continue to seek and take advantage of opportunities
offered by both federal and private organizations to benchmark
information management systems and procedures.
Long-Term Actions
11. EPA should create a clearinghouse or other mechanism for federal
agencies to share information on environmental policies,
procedures, guidance, training, and consulting services/contracts.
Sharing the workload would ease the resource shortage and avoid
duplication of effort.
12. EPA should create a federal agency benchmarking opportunity
database that allows agency environmental personnel to seek out
and identify others who have an interest in comparing
organizational, operational, and strategic approaches to
environmental compliance and management. The database could
consist of both a document repository and a federal agency registry
of persons and issues.
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13. EPA should maintain technical information in a federal agency
library or repository and make it available to requesting agencies.
This would include guidance and literature developed by EPA as
well as other federal agencies. The bibliography developed by the
Task Force should serve as a clearinghouse for these documents
and should be maintained on an electronic bulletin board in order
to be more accessible.
14. Agencies with incompatible computer operating systems should
convert to systems that are more compatible with other agencies to
allow for the sharing of software and information as well as better
communications.
(3) Compliance Monitoring
Short-Term Actions
15. EPA's Federal Facility Enforcement Office should provide CFAs with
on-line access to the new Federal Facility Tracking System. Agency
officials can use the data (pre-screened and sanitized by EPA for
enforcement-sensitive information) to identify facilities and
installations that are out of compliance. CFA officials should notify
EPA of any discrepancies between the database information and
other information. EPA should also consider providing access to
other EPA databases, such as the database used for the A-
106/FEDPLAN process.
Long-Term Actions
16. CFAs that are still using manual systems should develop automated
systems that track facility compliance status and store and retrieve
pertinent environmental documentation.
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(4) EPA Assistance on Specific Compliance Issues
Short-Term Actions
17. The Task Force should continue to develop a set of generic
documents that not only provide guidance on complying with
environmental regulations, but also provide examples of how
environmental compliance programs can be better managed to
reduce the risk of regulatory excursions and environmental
releases.
18. CFAs and EPA should use tools such as Memoranda of Agreements
to record terms and conditions agreed upon to resolve significant
environmental issues. This will avoid confusion and duplication of
effort.
Long-Term Actions
19. EPA regions should consider standardizing some processes (e.g.,
the stages of investigation and cleanup of sites on the Federal
Facilities Docket) to the maximum extent possible.
(5) Sufficient Staffing
Long-Term Actions
20. CFAs should encourage designated environmental career paths and
the establishment of needed staff positions to achieve the expertise
required to address environmental issues. Agencies also need to
establish minimum grade levels for environmental positions.
21. EPA and CFAs should work on ways of apprising Congressional
and White House officials (as well as CFA upper management) of
the resources required by CFAs to manage environmental programs
that ensure compliance with federal, state and local statutes and
regulations. EPA and CFAs should provide these officials with an
assessment of the current level of effort being dedicated to
environmental program management.
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22. EPA and CFAs should encourage rotational assignments, hiring
personnel with CFA/EPA experience, and other mechanisms to
foster team building, cross fertilization of ideas and respect for
other's situations. Intergovernmental Personnel Agreements (IPAs)
should be used to the maximum extent possible.
(6) Communications
Short-Term Actions
23. EPA should provide CFA points of contact with an EPA
Headquarters telephone directory and updates as they are
available.
24. EPA regional Federal Facility Coordinators (or their designees)
should brief their senior management on communications problems
CFAs face in working with EPA, along with solutions to these
problems.
25. CFAs should involve EPA headquarters and regions in internal
agency conferences and meetings to explain to their staffs how EPA
is structured and where assistance can be obtained for addressing
issues (e.g., the FFCs within each region). CFAs should also
involve EPA headquarters and regions in making presentations to
CFA staff on technical issues.
26. CFAs should explore the tools of the Alternate Dispute Resolution
process within their agencies to establish methods for working with
EPA (where these do not already exist) when resolving issues.
27. CFAs and EPA should use the tools of TQM such as facilitators, an
agenda and an established process (e.g., Focus, Analyze, Develop
and Execute) to guide meetings toward trackable, measurable
results, and to identify follow-on actions and accountability.
Meeting participants should have the opportunity to obtain
feedback on results achieved.
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28. EPA and CFAs should seek team building and partnering
opportunities on environmental projects of mutual interest and
goals.
Long-Term Actions
29. EPA should develop standardized guidance on how CFAs can best
work with both EPA Headquarters and EPA Regional Offices. This
guidance can be provided in the form of a brochure that can be
easily updated, reprinted, and distributed in bulk. Key regional
points of contact (FFCs, media specialists, etc.) and phone numbers
should be provided.
30. EPA should define a clear-cut dispute resolution process to handle
situations where two or more EPA regions interpret the same
regulation in different ways and have different enforcement
responses. EPA should arrange separate meetings for the technical,
as opposed to the legal, issues needing resolution.
31. EPA should provide recognition for agencies that are "doing
something right" (proactive approaches, pollution prevention,
innovative technologies) rather than recognizing only violations of
environmental compliance. EPA should report on such
environmental successes (e.g., reduced enforcement actions due to
better environmental practices).
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III. SHORT-TERM STRATEGIES
This section of the strategy discusses in greater detail those
recommendations that can be implemented immediately in order to improve
compliance programs at civilian agencies.
A. Enhanced Regional Activities
(Recommendations #6, 18, 19, 24, 25, 27, 28)
EPA has established Federal Facility Coordinators in each of EPA's ten
regional offices. The regional FFCs are primarily tasked with compliance
oversight and enforcement related duties; however, nearly all coordinators also
sponsor technical assistance and other outreach at federal facilities. The
regional FFCs regularly conduct meetings and conferences similar to the monthly
Federal Agency Roundtable held at EPA headquarters. In addition, each region
conducts annual multi-media technical workshops for federal facilities. These
workshops are coordinated by the regional coordinator with participation by
regional media program offices.
Regional coordinators have expressed interest in the activities of the CFA
Task Force and several have been involved in work group activities. Each EPA
region and regional Federal Facility Coordinator can, and should, determine the
best way of implementing this strategy in that particular region. However, in
order to develop a holistic national response to this strategy and to more
completely address the Task Force recommendations, EPA at both headquarters
and regional offices should seek opportunities to open direct lines of
communication with CFA Task Force members.
National Meeting. To initiate this effort, EPA will sponsor a national
meeting to facilitate discussions between CFA headquarter personnel and EPA
regional coordinators. As a follow-up to the meeting, both CFA representatives
and EPA regional coordinators will be advised to brief their respective executive
management on opportunities to improve communications between CFAs and
EPA and partnership projects of mutual interest.
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Partnering. Beginning in 1995, FFEO is encouraging all EPA Federal
Facility Coordinators to seek more team building and partnering opportunities
between EPA and CFAs on environmental projects of mutual interest. FFEO will
set aside funding for each EPA Region to conduct partnership projects with
CFAs. Partnership projects to be funded may include regional conferences and
workshops, site visits to identify environmental management deficiencies, etc.
Training. EPA regional conferences and workshops should focus on areas
of deficiency most evident in CFA training programs that were identified by the
CFA Training Work Group. These would include regulatory requirements and
the development of effective policies and programs, environmental contract
management, generic training topics related to statutory requirements and
media areas (e.g., RCRA requirements, wastewater management). EPA's
regional training efforts cannot and should not become a substitute for CFA
initiated training programs; however, they can begin to provide the necessary
training to ensure adequate awareness of environmental requirements among
federal agency personnel until smaller federal agencies develop more formal
training programs.
FFEO will also encourage EPA personnel at both EPA headquarters and
regional offices to attend CFA conferences and meetings in order to foster an
understanding of how EPA regions operate and discuss opportunities,
constraints, and priorities. EPA envisions that these new regional activities and
programs will help CFA installations evolve to higher levels of compliance with
environmental laws and work toward achieving programs that are more
proactive in environmental management areas.
The boxes on the accompanying pages highlight samples of successful
CFA partnership projects that have been conducted in several EPA Regions.
The Environmental Program Reviews and EQIP agreements in Region 6
(see box) are one example of how both CFAs and EPA Regions can gain an
understanding of the root causes behind the occurrence of violations at CFA
installations, and provide EPA decision makers at regional offices with data to
influence EPA policies and outreach activities directed toward federal agencies.
In addition, the Environmental Program Reviews and the resulting dialogue
between EPA regional staff and CFA facility management personnel can improve
overall communications and foster mutual understanding of organizational
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Regional Initiatives
Region 6 Program Review. Region 6 personnel have conducted environmental
Program Review visits at several CFA facilities in order to provide direct technical assistance
to CFA facility managers and advise CFA personnel on improving overall environmental
management and performance. The purpose of the environmental Program Review visit is
to assess the overall health of the facility's environmental management program and to
facilitate communication between the facility and EPA. In addition, the Region 6 Federal
Assistance Section Chief chaired the Task Force work group on communications and also
sponsored a pollution prevention training program exclusively for smaller Federal agencies.
Program Review visits are not regulatory enforcement inspections; instead, through
discussions with the facility environmental management and staff, Program Reviews are
designed to improve environmental performanceby troubleshootingproblems, recommending
specific program improvements to reduce violations, and strengthening and formalizing
facility environmental management programs. These recommendations could include
improvements in training, self-inspection and auditing activities, and pollution prevention
measures such as source reduction. Opportunities for economizing resources and improving
management efficiencies can also be identified. An overview of the Region 6 Environmental
Program Review Process is available from FFEO.
Region 6 has provided EPA Headquarters with data that indicate the Program Reviews have
also been highly effective in improving communications between EPA and the participating
Federal facility. The rapport developed between the EPA region and the facility will also lay
the foundation for developing team building and partnering opportunities between EPA
headquarters and headquarter units at Federal agencies.
Region 6 personnel have also initiated the Environmental Quality Improvement Partnership
(EQIP) concept at several Federal installations including Tinker Air Force Base in Oklahoma.
The primary purpose to the EQIP process (formerly known as Comprehensive Environmental
Management Programs or CEMPs) is to provide a structured forum for meaningful dialogue
between federal agencies and the EPA regional office. The forum and resulting dialogue will
then facilitate the creation of a network among EPA and agency management for solving
significant compliance problems and other issues related to environmental management. The
EQIP is designed to involve multiple facilities at the Command (DoD) or Bureau or
Departmental (regional) level. This higher level of involvement further enhances
communication and cooperation between EPA and other federal agencies and allows both
EPA and the Federal agency the ability to analyze trends in multiple facilities. A copy of the
MOU between EPA Region 6 and Tinker Air Force Base in Oklahoma is available from FFEO.
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Regional Initiatives (cont'd.)
Region 2. In a joint partnership with EPA Region 2 and the U.S. Postal Service, a
Pollution Prevention Opportunity Assessment was conducted at the Postal Service General
Mail Facility and Vehicle Mail Facility in Buffalo, NY. EPA arrange for and funded the
assessment, which identified source reduction and recycling opportunities and areas for
additional research. The economic and technical feasibility of selected opportunities and
techniques were investigated and a limited implementation plan was developed.
Region 4. In 1992, EPA Region 4 and NASA agreed to an accelerated cleanup
program for NASA's Stennis Space Center where 34 potentially contaminated sites were
discovered. NASA has prepared a consolidated remediation plan describing a facility- wide
approach to follow-up investigations and remedial actions. Region 4 has agreed to review
remediation plans and reports.
Region 7. In a joint partnership with EPA Region 7 and the U.S. Postal Service,
pollution prevention opportunity assessment workshops were conducted at postal facilities
in Kansas City, KS. EPA headquarters (FFEO) arranged for and funded professional trainers
to conduct a three-day training conference attended by 50 Postal Service employees. The
Postal Service Midwest Area Vice President urged all employees to put into practice the
concepts learned from the training session and authorized a Performance Incentive Award
for employees who develop and implement significant pollution prevention projects at
midwest facilities.
capabilities and limitations. Memoranda of Understanding or Agreements can be
used to commit to writing terms and conditions agreed upon to resolve
significant environmental issues. These arrangements can ensure that the
agreement(s) endure changes in agency personnel and any length of time
required to implement the solution by providing responsible parties a record of
exactly what was agreed upon.
Once agreements are arranged, EPA and CFA participants should hold
periodic meetings to track and measure results in reaching the goals of the
agreement and to identify any additional actions and roles to ensure
accountability. Feedback on the progress of the agreement and the results of
the initiative should be provided to all participants. The use of TQM techniques
should be employed at meetings between EPA and agency representatives to
ensure effective participation and progress.
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B. Catalogue of Federal Agency Publications
(Recommendation #9)
One of the key findings of the CFA Task Force is that the development of
solutions for environmental compliance problems at many civilian agencies often
results in duplication of work already done elsewhere in the federal government.
To avoid this, CFA environmental managers must become more familiar with
environmental programs developed at other federal agencies and with guidance
and resources available.
At the request of the CFA Task Force, EPA/FFEO developed a biblio-
graphy called the Catalogue of Federal Agency Environmental Compliance/
Management Documents. Produced in June 1994, the catalogue contains over
210 federal agency environmental compliance and management documents
published by EPA, the Department of Defense (including documents developed
by the Departments of the Air Force, Navy and Army), the Department of
Energy, the Department of Transportation, the Postal Service, the Department of
Commerce, and the Tennessee Valley Authority.
Most of the documents and guidebooks included in the Catalogue have
been developed and tested by federal agencies that are regulated by EPA. These
materials can be adapted by CFAs that have not yet developed guidance or
strategies of their own.
C. Executive Guidance for Civilian Agency Senior Management
(Recommendation #17')
To achieve the goal of advancing civilian federal agencies' environmental
management programs, the CFA Task Force recognized that furthering the
awareness of environmental requirements among agency executives was also
needed. One way to fulfill this need is to provide agency executives with a
primer which outlines their environmental requirements. Most civilian agencies
have not attempted to develop such a document on their own due to the
personnel time and funding required for the task. Members of the Task Force
agreed that by producing one generic document, civilian agencies could further
the environmental awareness of agency executives, while achieving resource
efficiencies through a multi-agency effort. The development of an Executive's
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Guide to Environmental Management by the Federal Aviation Administration is
intended to meet those needs.
The Executive's Guide to Environmental Management will present the basic
issues of facility environmental compliance and offers brief information
regarding the statutory and regulatory requirements of achieving and
maintaining compliance. Information regarding an executive's environmental
duties, responsibilities, and potential liabilities will be provided as they relate to
issues that impact CFAs' facilities and operations.
The document is not intended to be a desk-top environmental manual for
operations managers. Each agency's environmental and legal staff must
determine if the agency's activities are conducted in a manner consistent with
the environmental statutes, and then convey that information to their
management. This primer will simply facilitate the information process.
The document will be distributed to the CFA Task Force members for
review and comment, with the final guide provided to the agencies as a word
processing file. Individual agencies can then customize the document with
additional information prior to production.
D. Technical Assistance in Environmental Auditing
Although not a formal recommendation of the Task Force, EPA will strive
to provide more focused technical assistance to CFAs in the area of
environmental auditing. EPA has actively promoted environmental auditing at
federal agencies and issued its Environmental Auditing Policy Statement in
1986.3 In addition to defining environmental auditing and encouraging all
regulated entities to audit, the policy contains a separate section (1 III, C) that
explicitly addresses and encourages environmental auditing at federal agencies.
In 1989, EPA published the document Generic Protocol for Environmental Audits
at Federal Facilities and a companion document Environmental Audit Program
Design Guideline for Federal Agencies to provide a starting point for agencies that
did not have an environmental audit program and that were in need of
guidelines to establish a program and performance requirements for
3 Federal Register Notice, July 9, 1986 (51 FR 25004).
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environmental auditors. Periodically EPA has also sponsored training exercises
and provided presentations to federal agencies to further environmental auditing
activities.
The Government Accounting Office (GAO) released a report in April
19956 which found that many CFAs, including some with potentially large
environmental liabilities, have made "limited progress" in developing effective
audit programs. GAO noted that civilian agency managers may have little
incentive to support environmental auditing because their agencies run little risk
of being inspected by EPA or the state. Another obstacle cited by GAO is the
lack of technical expertise among civilian agencies to implement audit programs.
To respond to the problems uncovered, in April 1994, EPA convened an
interagency work group to revise the generic audit protocol document, with the
advice of auditing experts throughout the government. The revised protocol
includes a checklist to evaluate compliance with federal regulations at federal
facilities, as well as a means of assessing the effectiveness of all environmental
management programs at both the installation level and at senior management
and agency headquarters levels. The revised audit protocol manual is available
on diskette and on-line to all federal agencies. EPA is also revising the
companion document on audit program design guidelines.
In October 1993, at the request of the CFA Task Force, DOE's Office of
Environmental Audit conducted environmental management assessment training
for Task Force members. The training program initiated agency environmental
officers to the key characteristics of effective environmental management
systems and the role environmental audits play in maintaining these systems.
Coordinated by both EPA and the Federal Aviation Administration, the training
session also provided an opportunity for environmental managers at civilian
agencies to benchmark their audit programs and techniques with those at the
Department of Energy.
EPA will continue to sponsor and support training activities to promote
the value of performing environmental audits at federal agencies. In March
1995, EPA co-sponsored an environmental auditing seminar and training
6 U.S. GAO, Environmental Auditing: A Useful Tool That Can Improve Environmental
Performance and Reduce Costs, GAO/RCED-95-37, April 1995.
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conference for federal facilities with the Institute for Environmental Auditing.
The agenda focused on the auditing needs of civilian agencies and include
breakout groups on building effective environmental auditing programs. The
conference also provided training on fundamentals of environmental auditing as
well as more advanced training on performing management systems.
E. Establishing Informational Networks
(Recommendations #1, 3, 7, 8, 11)
One of the key areas of concern expressed by member agencies of the
CFA Task Force is the need for better information resources to facilitate
improved coordination between EPA and civilian agencies and to avoid
duplication of effort.
FFLEX and Enviro$en$e. EPA has developed an electronic bulletin board
system called Enviro$en$e, which allows downloading and screen viewing of full
text and abstracted documents. Enviro$en$e includes professional contacts and
services; training and education opportunities; federal facilities information;
summaries and bulletins; a calendar of events; case studies and other
documents; and dialogue and electronic mail utilities. The system is routinely
updated and expanded based upon user interest and input. The FFEO
component of the system is known as the Federal Facility Leadership Exchange,
or FFLEX, which can be accessed through Enviro$en$e.
FFLEX allows EPA to begin addressing the need for better communication
and coordination among federal agencies, and to implement several
recommendations made by the CFA Task Force. As recommended, FFLEX
includes listings of EPA contacts in various program offices and the regions, as
well as environmental contacts at other federal agencies.
The FFLEX system also includes a feature that provides summaries of new
and pending environmental requirements as an early warning mechanism to
help federal agencies forecast new requirements (pending regulations), Federal
Register notices, and Executive Orders. The electronic format allows
environmental officers and staff to directly dial in for information on new
regulations and other requirements in order to anticipate agency planning needs
and resources.
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Another feature of FFLEX is a catalogue index, informing users of
compliance-related reports and publications produced by EPA and other
agencies. The index could ultimately include new EPA initiatives for technical
assistance and outreach, partnership programs, technology demonstrations,
Federal Register notices, and legal settlements and court cases involving federal
agencies. The system allows documents to be scanned in and forwarded to the
requesting agency in electronic format. FFLEX will also contain a benchmark
bulletin board service (see Chapter IV.C for more details).
Training Bulletin Board. EPA will develop an environmental training
opportunities bulletin board for federal agencies in FY 96. EPA will pursue two
alternatives to address this need. One option is to salvage the effort started by
the Accelerated Training Subgroup (ATSG). The ATSG had proposed in 1993 to
develop a training opportunities bulletin board to provide public information
regarding training programs and courses at EPA, DoD, and DOE, via the Clu-In
bulletin board system developed by EPA's Technology Innovation Office.
However, the ATSG has since been discontinued and the status of the bulletin
board is in question. Should the Clu-In option become viable again, EPA will
pursue it. Otherwise, EPA will create a separate training opportunity bulletin
board on FFLEX to publicize training information for CFAs.
F. On-Line Access to EPA's FFTS and Other Databases
(Recommendation #15)
In 1996, FFEO will complete the development of the new Federal Facility
Tracking System (FFTS). The FFTS system is intended to provide a multi-media
view of activities and projects planned within the purview of FFEO. It provides
a method for viewing cross-program, multi-media data from other data systems
maintained by EPA's Office of Water, the Office of Solid Waste and Emergency
Response, the Office of Enforcement and Compliance Assurance, and EPA
Regions.
FFTS is a local area network compatible system that is PC-based and
incorporates many automated features for maintaining a multi-media view of
compliance activities at federal facility sites. FFTS derives data from EPA
headquarters and EPA Regions. These capabilities allow EPA personnel to view a
more complete representation of activities at federal Facility sites. In addition,
FFTS can also extract information from other independent data bases, such as
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the Permit Compliance System from the Office of Water Enforcement and
Compliance, the RCRA Information System (RCRIS), and the CERCLA
Information System (CERCLIS). FFTS allows users to extract information on
enforcement actions, permits/compliance status, violations, inspections, and
other key information on federal facilities.
In FY 96, FFEO plans to provide federal agencies with limited on-line
access to nonsensitive enforcement data contained in FFTS. The data can be
used to facilitate an exchange of information regarding the facilities compliance
status. This would include lists of facilities that have been inspected by EPA and
received enforcement actions. This information will be sent to a designated point
of contact in each federal agency and allow agency personnel to become more
aware of the overall compliance status of facilities under its purview. The
federal agency would then follow up with appropriate internal queries or
investigations to resolve outstanding issues between the EPA region and the
facility. CFA agency personnel would provide EPA with information on actions
taken and list any discrepancies in EPA's data. This exchange will facilitate
better communication and coordination between the federal agency
headquarters and the regional facilities, and also develop dialogue between EPA
and the agency to help resolve outstanding compliance issues.
FFEO has also developed a new PC-based management information
database, called FEDPLAN-PC, that contains all federal agency environmental
project information that supports the budgeting and planning process for
environmental compliance (formerly known as the A-106 process, now called
FEDPLAN). FEDPLAN-PC will be fully implemented during FY 1996. The
database provides a powerful data analysis capability to regional media program
review personnel and regional Federal Facility Coordinators. EPA staff will be
able to perform relational analyses between the project level compliance and
budget information contained in FEDPLAN-PC with inspection and compliance
information contained in the new Federal Facility Tracking System coming on-
line. CFA involvement was vital to the Interagency Advisory Committee that
recommended changes to the A-106 process, and CFAs are expected to maintain
their involvement in and access to FEDPLAN-PC.
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G. Information on Training Opportunities
(Recommendations #2, 5)
The CFA Task Force has recommended the establishment of joint training
opportunities across CFAs in order to economize and reduce duplication. Joint
activities can include cost sharing of contractor training courses, or developing
informal or formal agreements to open training courses up to other federal
government personnel in exchange for reciprocal training opportunities. Civilian
agencies should also exchange empirical information on training resources and
curricula and lists of qualified instructors and facilities. EPA will assist agencies
in advertising training opportunities and resources by developing the training
opportunities bulletin board system as described above. In addition, FFEO
activities such as the Federal Agency Roundtable and CFA Task Force meetings
can help distribute training information and opportunities.
H. Internal Improvements at Civilian Agencies
(Recommendation #4)
The CFA Task Force has also developed recommendations that can be
immediately implemented internally at CFAs independent of EPA leadership.
One such area is the development of more mature and formal environmental
compliance training programs and budgets to assure adequate training of agency
employees tasked with environmental responsibilities. Specifically, executive
management at civilian agencies should ensure the development of formal
compliance training systems and mechanisms to keep employees informed of
changing environmental requirements, oversee the integration of Presidential
executive orders and EPA policies into agency missions, and develop oversight
mechanisms (including awards and performance reviews) to encourage
environmental compliance and performance. In the long term, CFAs need to
devise a strategy that will ensure the development of formal and mature
compliance training systems equal to, and compatible with, "state-of-the-art"
training programs in the public and private sector.
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IV. LONGER-TERM MEASURES
In the 1994 State of Federal Facilities Report, EPA pledged to integrate the
principles of environmental stewardship into enforcement agreements and into
federal agency operating missions. EPA has also pledged to work with states,
federal agencies, and the public to achieve federal environmental leadership.
EPA's Office of Enforcement and Compliance Assurance openly encourages the
building of partnerships between EPA, federal agencies and the public to build a
mutual relationship based on trust and respect for each organization's mission
and responsibilities. If the positive and cooperative relationships established by
EPA and the CFA Task Force are to endure beyond those created during the
Task Force meetings and work group activities, EPA and the CFAs must install a
formalized permanent structure to the Civilian Federal Agency Strategy that
endures beyond the immediate agenda of EPA and the civilian agencies. This
structure would also encourage permanent improvements in environmental
management and compliance performance at smaller federal agencies.
This chapter of the strategy outlines initiatives to be developed over a
longer period of time (3-5 years) to not only improve environmental programs
at CFAs but also to form more permanent cooperative relationships between EPA
and CFAs. Although these initiatives are not as detailed as those described as
immediate actions in the previous chapter, they serve as important guideposts
and visions to keep the overall strategy on track toward improving CFA
environmental management programs.
A. Promoting Environmental Management Training
(Recommendations #5, 6)
Training agency personnel in environmental responsibilities is one of the
most important areas that needs to be addressed by CFAs. The National
Performance Review is encouraging federal agencies to move decision-making
downward in the organization to encourage empowerment. This will allow
federal employees who are closest to the agency's operations and environmental
management concerns to influence the decision-making process. The quality of
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their decisions, however, can be no better than the training and experience the
agency provides through formal training programs, and the duties assigned to
that employee.
It is thus imperative that formal training programs be developed by
federal agency managers. The adequacy of these training programs is directly
dependent on the agency's commitment to compliance and ability to
communicate that commitment to its employees.
In addition to immediate actions to increase opportunities for training at
CFAs and the quality of the training, ongoing processes need to be put in place
to ensure an adequate level of awareness among employees who are assigned
environmental management and compliance responsibilities. For this reason,
EPA will develop informational resources (i.e., clearinghouses, bulletin-board
systems) to help civilian agencies identify training opportunities for their
employees. EPA's FFEO will also continue to encourage DoD and DOE to
demonstrate their leadership by offering and reciprocating training opportunities
with CFAs. FFEO can also act as a communication conduit to the EPA Training
Institute or other federal agency providers to express the needs of smaller
federal agencies for specific types of training as well as more training
opportunities.
In addition, EPA and CFA Task Force members need to track the progress
of various national and international standard setting organizations who are
currently drafting qualifications and standards to address concerns related to
environmental training, staffing and qualifications of environmental professionals
(ISO 14000, Canadian Standards Association, National Sanitation Foundation,
etc.). Once final standards regarding these issues are published, federal
agencies should consider subscribing to these standards in an effort to seek
continuous improvement in environmental performance.
B. Developing and Retaining Experienced Environmental Staff
(Recommendations #20, 22)
To ensure that seasoned experience is reflected in environmental
management decisions, it is also imperative for federal agency executives and
managers to carefully plan the infrastructure of the environmental management
units within a federal agency. To retain experienced personnel, agency
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managers need to create an infrastructure with designated career paths, and
establish the necessary amount of full time equivalents (FTEs) within agency
environmental compliance units. These measures will ensure adequate attention
is given to environmental issues.
Personnel rotations. The CFA Task Force has determined that a greater
understanding needs to be developed between EPA and civilian agencies as to
each other's organization, approach, needs, and problems. To address this issue
the Task Force recommended that EPA and civilian agencies consider
reciprocating rotational assignments, hiring personnel with CFA/EPA experience
and other mechanisms to foster team building, cross fertilization of ideas, and
respect for each party's position and situation. To accomplish this goal, EPA and
the CFA Task Force should seek utilizing Intergovernmental Personnel
agreements (IPAs) to the maximum extent possible.
As a long-term strategy, EPA will seek opportunities to detail CFA
environmental officers into short-term assignments at FFEO or the Office of
Federal Activities. Personnel could be assigned to non-enforcement sensitive
duties such as assisting FFEO personnel in pollution prevention or other
outreach activities. EPA has experienced success in similar arrangement with
DoD personnel who have been detailed to FFEO and various EPA regions and
program offices. EPA has already begun to detail staff from FFEO to perform
short-term assignments at DOI and DoD as direct technical assistance to these
agencies and to foster better communication and understanding between the
agencies.
Minimum grade levels. The Task Force also determined that CFAs need to
establish minimum grade levels for environmental positions and to develop
performance standards for environmental personnel to ensure accountability of
environmental responsibilities. Careful consideration also needs to be paid to
the practice of assigning environmental compliance responsibilities to agency
personnel as a collateral duty or part-time basis. Overburdening staff and
management with too many duties increases the chance of environmental issues
being ignored or under-prioritized. EPA encourages all federal executives to
implement this recommendation within their own agencies.
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C. Satisfying Broad-Based Needs for Information
on Technology and Program Methods
As mentioned earlier in this strategy, CFAs need to become more familiar
with the successes and failures experienced at other federal agencies in order to
move their programs beyond compliance based performance and toward
environmental excellence. As noted, EPA has already begun developing
mechanisms to improve access to information for CFAs, such as the electronic
bulletin board system and the monthly EPA/Federal Agency Environmental
Roundtable.
1. Coordination Among Partnership Groups
(Recommendation #28)
Beyond the immediate informational needs that the electronic BBS will
satisfy, CFA representatives also expressed a need for information on the
activities of the numerous committees, teams, task forces, work groups, etc. at
other federal agencies that address a variety of environmental issues of interest
to federal environmental managers. These groups can be ongoing or short-lived,
and may have limited or open membership. Often, the existence and work of
some partnership groups goes unknown beyond a small circle of people. This
leads to duplication of efforts when each agency attempts to resolve the same
problems, and groups are formed concurrently and consecutively to address the
same issue.
In response to the Task Force's request, EPA will increase efforts to
communicate partnership group activities and progress though the monthly
EPA/Federal Agency Environmental Roundtable and through one of several
electronic bulletin board systems. EPA will also compile a list of partnership
groups active in the federal government, as the information becomes known to
FFEO. The list will contain information regarding a point of contact and a
description of the purpose, goals, and products of each group. EPA will provide
public access to the list through a monthly newsletter or via electronic bulletin
board. EPA will also invite representatives of partnership groups to the Federal
Roundtable meetings to report group activities directly to roundtable
participants.
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As a second phase, EPA will conduct annual partnership meetings either
as a special meeting of FFEO and federal agencies or as a special session of the
Environmental Roundtable. The annual partnership meeting will encompass a
multi-day agenda where partnership groups present panel sessions, workshops,
and open-door sessions.
2. Improving Automated Information Management Systems
(Recommendations #4, 16)
EPA and the CFA Task Force have begun to identify new approaches and
technologies that can improve existing information management systems at
civilian agencies. In September 1993, the CFA Task Force held a special session
at DOE headquarters to demonstrate a DOE database system that enhances
environmental management and compliance tracking. (The document, Improving
Access to Information Resources at Civilian Federal Agencies, is available from
FFEO on request.) The CFA Task Force also observed demonstrations of similar
systems utilized by DoD. The purpose of these demonstrations was to foster
awareness among Task Force members of information management systems
employed by DOE and DoD, exchange ideas and lessons learned on the
successes, limitations and costs of these systems, and explore the potential for
these systems to enhance environmental information management and
compliance tracking capabilities at civilian agencies.
EPA supports the Task Force recommendation that federal agencies that
are still using manual systems to manage and track environmental compliance
information should begin developing automated systems to accomplish this task.
As an immediate method of relief, EPA will provide on-line access to FFEO's
newly developed FFTS. However, this initiative is not a panacea for all
information management needs at CFAs. More long-term solutions that
carefully consider all of the environmental information management needs of an
agency must ultimately be developed. Agencies must also determine the types
of operating systems needed to cross-talk with computers systems at EPA and
other federal agencies. This capability is particularly critical if the agency
desires to become linked to the EPA bulletin board systems, FFTS, and EPA
public databases (eg, Clu-In, PIES, FAME, etc.).
EPA will continue to assist CFAs in identifying solutions to information
management problems. EPA will also encourage other federal agencies with
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more advanced environmental programs to share information on computer
technologies, innovative approaches, and information management approaches
with CFAs. EPA will also host demonstrations of software and computer systems
developed by other federal agencies at meetings of both the Federal Agency
Roundtable and the CFA Task Force.
3. Creating an EPA Library of Technical Documents
(Recommendation #13)
To supplement the CFA catalogue effort, EPA will maintain a technical
library or repository of technical information exclusively written to guide federal
agencies toward compliance and environmental program improvement. These
materials would include guidance documents, technical literature, and brochures
developed by EPA and other contributing federal agencies. EPA will also
attempt to collect information on innovative technologies on pollution
prevention and site remediation and cleanup developed by industry and other
government agencies. The documents in the repository would be made available
electronically to federal agency personnel who wish to consult literature
covering a variety of topics including environmental compliance, environmental
management tools and techniques, site restoration and pollution prevention
technologies.
The catalogue of federal agency publications will list the majority of
these documents. As previously mentioned, the catalogue will be maintained on
the FFLEX bulletin-board system to be more accessible to requesting agencies.
EPA will begin collecting the library materials during the next update of the
federal agency publication catalogue.
4. Establishing a Benchmark Communications Network
(Recommendation #12)
Through the discussions held at CFA Task Force meetings and work group
sessions, many civilian agencies have already become familiar with
environmental program activities at other federal agencies and pursued
opportunities to exchange ideas on technology, compliance program
management, and site cleanup. If federal agencies are to achieve environmental
excellence, such collaboration must continue and strengthen. Federal agency
environmental officers also need to communicate with other environmental
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professionals to solicit ideas and proposals that can be applied toward improving
their own environmental programs.
Recently, the concept of benchmarking has gained widespread recognition
from both government and industry as a tool to improve environmental
management programs, particularly in the area of pollution prevention.
Benchmarking, in the context of this discussion, can be defined as a continuous
process of measuring environmental performance at one organization to the
environmental performance of an organization considered "Best-in-Class" by
customers, peers and stakeholder.
As a long-term strategy, the CFA Task Force has proposed -- and EPA
intends to pursue -- the development of a benchmark communication network
for the federal government that allows federal managers to discuss and
exchange environmental program management information on-line. This kind of
interaction would help agency environmental officers determine whether their
own programs are better or worse than those at other agencies, and by how
much. Improved methods in program management and budgeting, pollution
prevention, cleanup, and program support can be exchanged. Benchmarking can
also provide a fresh source of ideas for improvement as well as critical data
needed to track and gauge progress in implementing environmental program
changes.
Data collected from other agencies would allow environmental officers to
analyze future requirements and to influence planning decisions based on
anticipated requirements. For example, aging infrastructure such as wastewater
treatment plants and other pollution abatement equipment can be more
effectively replaced once future requirements are anticipated and benchmarking
with other peer agencies and organizations provide data to decision makers as to
equipment capabilities and limitations. The Benchmark Communications
Network would also allow environmental managers to survey current program
improvement activities employed by other agencies and determine the costs and
other resources (training, staffing) needed to implement needed changes.
Through benchmarking the agency will also be able to determine impacts on
other mission activities and develop effective transition plans for implementing
changes.
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The Benchmark Communications Network would include a government-
wide registry of agency environmental personnel seeking benchmarking
opportunities as well as a registry of federal personnel responsible for successful
changes, ideas and practices. A document repository will also be available to
provide text or "white-paper" explaining the principles of the concept or change.
EPA will consider various options for funding the development of this network,
including the possibility of seeking contributing funds from interested users.
D. Environmental Challenge Program
(Recommendation #31)
Reaching a level of environmental excellence within the U.S. Government
will only occur if EPA and federal agencies and departments develop and share a
common ethic on environmental protection. This ethic will be embodied in
EPA's Federal Government Environmental Challenge Program that recognizes
and rewards outstanding environmental management performance at federal
agencies and facilities. The Challenge Program is being developed by EPA as
mandated by Executive Order 12856, section 4-405.
The program challenges federal agencies to: (1) agree to a code of
environmental principles emphasizing pollution prevention, sustainable
development and "state of the art" environmental management programs; (2)
submit applications to EPA for individual federal facilities for recognition as
"Model Installations;" and (3) encourage individual federal employees to
demonstrate outstanding leadership in pollution prevention. The program will
recognize those departments, agencies, and federal installations where mission
accomplishment and environmental leadership have become synonymous, and
will spotlight these accomplishments as models for other organizations.
The Environmental Challenge Program has several purposes, including:
• The development of a national, voluntary program to recognize
and reward a long-term commitment to sustainable development
by departments, agencies and federal installations.
• Providing positive incentives to the federal sector to encourage
achievement of the highest possible environmental management
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performance that is ranked as a benchmark by peers, customers
and stakeholder alike.
• Encouraging the federal government to go beyond compliance with
the law by incorporating proactive environmental management
programs such, as pollution prevention, into all aspects of their
operations.
• Ensuring that federal agency participation in these programs is
credible and verifiable by establishing basic standards and public
measures of success.
The Code of Environmental Principles represents the first step in the
Environmental Challenge Program for establishing a framework for establishing
an environmental management standard for federal agencies. The program will
ensure that:
1. Federal agencies and departments install enabling systems that
establish environmental compliance as a basic foundation for an
effective environmental program rather than as a final goal. These
enabling systems should cut across and become embedded in all
planning, organizing, implementing and measuring processes.
2. Federal agencies and departments are provided with a guide for
implementing Total Quality Environmental Management (TQEM)
from the ground-floor up.
3. An assessment tool is developed for federal agencies or
departments that can be used internally or externally to measure
progress toward environmental management excellence as well as
opportunities for improvement.
4. A public recognition process is established for those agencies and
departments of the Federal Government that accept the challenge
to agree to the Code of Environmental Principles.
The CFA Task Force has recommended that EPA develop a mechanism for
recognizing positive environmental management approaches taken by federal
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agencies instead of recognizing only the effects of noncompliant behavior toward
environmental requirements (issuance of violation notices, and enforcement
agreements). The Task Force specifically requested that these positive
relationships be based on environmental successes such as facility-specific
programs and initiatives that have resulted in reduced enforcement actions due
to better environmental practices like pollution prevention and the use of
innovative technologies.
EPA will use the Federal Government Environmental Challenge Program
to seek more proactive and positive relationships between EPA and CFAs. EPA
intends to structure the Environmental Challenge Program in a tiered approach
in order to encourage the participation of CFAs. Chapter V of this document
explains how the Environmental Challenge Program will be used to measure the
success of the CFA Strategy.
E. Providing a Forum for CFA Concerns
By developing this strategy, EPA formally recognizes the unique
environmental management concerns faced by smaller-sized federal agencies.
EPA recognizes that CFAs with smaller numbers of environmental management
staff, inadequate resources, and underdeveloped management programs are
falling further behind in their attempts to comply with environmental
regulations and manage liabilities associated with contaminated sites. FFEO
considers the impacts of these circumstances to its federal facility strategy as
significant.
EPA seeks to ensure that these conditions are reflected in the
development of national strategies, enforcement policies and outreach initiatives
conducted by FFEO. EPA has already begun to preserve the concerns of civilian
agency issues in several recent activities.
• In February 1994, EPA issued the report, The State of Federal
Facilities, and identified several strategic visions for CFAs, including
more support for federal agencies with large land holdings and
natural resource responsibilities, (e.g., DOI, USDA). The report
also recognizes the CFA Task Force as a primary mechanism to
promote environmental excellence in the federal government.
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CFA Strategy
46
• EPA is structuring the Environmental Challenge Program's model
facility component in a tiered approach to give recognition to
federal agency programs that are not yet advanced but that are
striving to improve performance.
• In outreach activities, EPA will fund training and other non-
punitive activities on the part of its regional offices, including
advisory services, forums to improve communication and
dissemination of information, and encouraging more self-regulation
and accountability at federal facilities.
• EPA is committed to funding the development of electronic bulletin
boards to meet the information resources needed by CFAs.
• In revising the generic environmental audit protocol, EPA has
made the document more "user friendly" to assist small federal
agencies in understanding and implementing complex regulations.
The CFA Task Force will become a permanent partnership group and
serve as the primary conduit of communication between EPA and CFAs. EPA
intends to continue periodic, informal meetings of the Task Force after this
strategy is published. The Task Force will meet to discuss progress made by
both CFAs and EPA in implementing the actions called for in this strategy and
continue to identify and attempt to resolve the unique environmental
compliance issues of concern to the smaller federal agencies. It is expected that
Task Force members participating in other partnership groups will communicate
the activities of the Task Force to these groups and vice versa. Thus the CFA
Task Force should serve as a conduit for dispersing information among its
membership and as a vehicle for brainstorming solutions to problems unique to
civilian agencies.
CFA Task Force members are also encouraged to organize special events
or produce issue papers, reports, or other products of interest to the group. EPA
intends to serve as an equal participating member of the ongoing Task Force,
and encourages other members to take the initiative in arranging agendas,
serving as meeting leaders, etc. EPA will volunteer to retain the list of Task
Force members and arrange for room space to facilitate meetings of the Task
Force.
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47
F. Making EPA a More Responsive Partner
(Recommendations #21, 26, 29, 30)
Standardized guidance. In response to the Task Force's recommendations,
EPA/FFEO and the regional Federal Facility Coordinators (FFCs) will work
together to develop standardized guidance for federal agency environmental
officers. The guidance will describe roles and responsibilities of FFCs at EPA
regions and headquarters. The guidance will also offer advice to federal agency
personnel on raising environmental issues to EPA and whether the issue should
be raised at the regional or headquarters level. The guidance will also list key
regional points of contact including media specialists and FFCs.
Streamline policies, dispute resolution. EPA will also identify opportunities
to standardize and streamline enforcement policies and procedures to the
maximum extent possible, and will outline a procedure that federal agencies can
follow to help resolve disputes between two or more EPA regions on regulatory
interpretation and enforcement response.
Budgets. Task Force members also pointed out that misunderstandings
develop between EPA and federal agencies over environmental requirements and
the budget resources needed to meet these requirements. These
misunderstandings are further compounded when differing expectations arise
between EPA and other federal agencies on what programs should be operative
to ensure sound environmental management. EPA's emphasis on "going beyond
compliance" and toward environmental excellence often conflicts with the
approach of an agency that is struggling just to obtain a budget to manage
baseline compliance activities.
Task Force members informed EPA that the budget provided to CFA
environmental officers from agency budget officers often has nothing to do with
the compliance officer's evaluation of budget needs to meet baseline compliance
functions or to go beyond compliance. The actual budget for environmental
management is too often a function of what is left over after other mission
oriented activities and programs are funded.
To address this concern, the Task Force requested EPA's assistance in
working with federal agencies to apprise Congress and White House officials and
other concerned parties (e.g., OMB) of the resource requirements needed to
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CFA Strategy
48
manage environmental programs mandated by statute or regulation. These
resource requirements -- such as funding for training programs or environmental
compliance auditing -- are often considered as "overhead."
EPA has taken an important first step in addressing this set of issues by
proposing the establishment of a "Class 0" priority for funding such overhead
costs under the new Federal Environmental Management Program Planning
(FEDPLAN) guidance. The new program management (PGMT) priority
classification is intended to fund expenses considered by environmental officers
as essential for managing environmental programs. They include personnel and
labor costs of environmental managers and their staffs, travel, per diem,
supplies, computer hardware and software, leases, permits and fees, and other
administrative costs including resources, organization, communication, and
training. In addition, program management projects will be assigned a high
priority for funding when the project is considered essential for developing and
sustaining effective management of the environmental program.
EPA recognizes that more needs to be done to ensure adequate
environmental compliance budgets at federal agencies, and will work with CFAs
and other agency representatives to further this goal. Through CFA Task Force
and other meetings, EPA will help identify additional opportunities to
communicate agency budget needs to a higher levels of visibility and also
identify mechanisms that meet resource requirements with minimum budget
impact (e.g., cost sharing through partnership opportunities).
G. Inspections and Enforcement at CFA Installations
Traditionally, CFAs have been given a low-priority status in EPA's
enforcement activities. However, new information is changing EPA's perspective.
CFA facilities comprise a steadily-rising percentage (currently 49%) of the sites
listed on EPA's Federal Facilities Hazardous Waste Compliance Docket (CERCLA,
Section 120). In addition, of the 2,472 federal facilities included on EPA's E.O.
12856 EPCRA Covered Facilities List, 1,686 or 68 percent are CFA facilities (see
Exhibit 1).
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49
ExkiLit 1
Number and. Percentage of E.O. 12856 Covered Facilities
Similarly, enforcement data from FFEO's Federal Facilities Tracking
System (FFTS) show that in FY 1994, 15,800 federal facilities reported engaging
in some type of activity directly affected by environmental requirements. Of
these facilities, 56 percent (or 8,848) are owned or operated by civilian
agencies. The remaining 44 percent, or 6,952 facilities, are owned or operated
by DoD or DOE.
As Exhibit 2 shows, in FY 1994, EPA and the states performed a total of
783 inspections at DoD and DOE installations and facilities, while only 380
inspections at CFA facilities. An analysis of these inspections is presented in
Table 1. Of the 380 inspections of CFA facilities, 38 were conducted by EPA,
and only 13 of them were followed by enforcement actions. Thus, out of the
universe of 8,848 CFA facilities affected by environmental requirements, only 0.4
percent of total CFA facilities were inspected by EPA in FY 1994 (see Exhibit 3).
The percentage of EPA inspections is significantly lower for CFA facilities than
DoD and DOE facilities: of the 6,952 DoD and DOE facilities, EPA inspected 1.7
percent (123 facilities).
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Exhibit 2
FEDERAL FACILITIES
INSPECTED BY EPA AND STATES,
50
DOD/DOE
Facilities
Total Inspected:
783
CFA
Facilities
Total Inspoctod:
380
Not«i "Other" includes TSCA, EPCRA, FIFRA.
Sourest EPA FFTS, 6/95
The data also suggest that
EPA oversight at CFA facilities is
limited when compared to state
monitoring. EPA provides rela-
tively more oversight of DoD and
DOE facilities. There are a
variety of possible reasons for
this difference, including the size
and complexity of the facilities
involved. In any case, the
absence of sufficient EPA pre-
sence at CFA facilities may be a
contributing factor in the
comparative lack of environ-
mental performance at CFA
facilities.
In its April 1995 report,
the General Accounting Office
recommended that EPA "ensure
that civilian federal agencies
receive a measure of enforcement
attention commensurate with the
environmental risks posed by
their operations."7 This
recommendation responded to
GAO's finding that senior
managers at CFAs have little
incentive to support environ-
mental auditing programs, since
few CFAs are targeted for inspec-
tions by the states or EPA. GAO
added that if EPA is serious
about fostering better
environmental compliance and
U.S. GAO, op. cit., p. 6.
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51
Table 1
EPA and State Inspections & Enforcement Actions, FY 1994
Agency
Number of
Facilities
States
Insp. Enforce.
EPA
Insp. Enforce.
DoD & DOE
6,952
660
(9.4%)
218
123 45
(1.7%)
CFAs
8,848
342
(3.8%)
107
38 13
(0.4%)
TOTAL
15,800
1,002
263
161 120
Exliilrit 3
EPA and State Inspection* at CFA Facilities, FY 1994
Total CFA Facilities
8,848
FY 94
State Impaction!
at CFA. (342) 3.8%
FY 94
EPA Impaction*
at CFA. (38) 0.4%
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52
supportive programs (such as environmental auditing), EPA must ensure that
CFA facilities receive additional inspections by federal and state inspectors.
In response to the analysis of EPA's FFTS data, the GAO
recommendations, and EPA's environmental benchmark report,8 EPA plans to
make better use of FFTS data to determine how much of an increase in
inspections and enforcement attention at CFA installations is in order. In FY
1996, EPA will conduct more detailed analysis of compliance and enforcement
trends to determine the extent to which EPA must increase its enforcement
presence at CFA facilities.
EPA will also provide increased compliance assistance to civilian agency
environmental managers and other personnel in FY 1996 and beyond. In
addition, federal agencies will be given access to non-enforcement sensitive data
in EPA's FFTS that they can utilize for their own performance and tracking
purposes.
Since passage of the Federal Facilities Compliance Act in 1992, EPA has
increased the attention given to federal agencies and their compliance with
environmental laws. In 1993, EPA implemented the Federal Facilities Multi-
Media Enforcement/Compliance Initiative (FMECI) for the purpose of targeting
federal facilities for multi-media inspections under a combination of statutes.
EPA and the states exceeded the minimum number of required multi-media
inspections for FY 1993 by 33 percent. The FY 1993 FMECI initiative resulted in
the completion of 41 multi-media inspections of federal facilities and
installations. Six of the 41 facilities inspected were installations owned and
operated by CFAs; the majority of the remainder were DoD facilities (see Exhibit
4). EPA will evaluate its resource commitment to ensure that adequate
attention is being distributed broadly across all sectors of the federal facility
universe.
8 U.S. EPA, Environmental Management System Benchmark Report: A Review of Federal
Agencies and Selected Private Corporations, op. cit.
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CFA Strategy 53
Exhibit 4
Number of Inspected Facilities by Agency
FY 1993 Federal Facilities Multi-Media Enforcement Initiative
|14
110
10
Number of Facilitws
15
20
Depending on further analysis of compliance data, future targeting for
inspections and enforcement may call for an increased enforcement presence at
CFA facilities and installations in each region. EPA will take this measure to
ensure that the entire universe of federal facilities has been included in EPA's
Federal Facilities Multi-Media Enforcement and Compliance Initiative and to
prevent bias in its enforcement targeting scheme.
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54
V. MEASURING SUCCESS
In the next several years, EPA will be investing significant time and
resources into the CFA Environmental Improvement Strategy. Both EPA and
member agencies of the CFA Task Force need to be accountable for ensuring the
success of the program. That success will depend on the ability of each Task
Force member, including EPA, to implement the actions proposed in this
strategy within their own sphere of influence and as completely as possible.
In the past EPA has relied heavily on traditional measures of success to
determine EPA's influence upon federal agencies to improve compliance
behavior and environmental management programs. These traditional measures
normally included the issuance of violation notices and progress made by
regulated entities on meeting compliance schedules. These kinds of
measurements were, and still are, necessary because EPA is primarily responsible
for ensuring regulatory compliance with environmental statutes and laws.
However, EPA also understands the value of examining root causes of non-
compliance and making more permanent impacts on compliance performance
through technical assistance and outreach. To be successful, EPA's attempts at
providing technical assistance and outreach must demonstrate positive results
federal agency compliance and in the cleanup and restoration of contaminated
sites. Finally, EPA's technical assistance and outreach efforts can be effective
only if regulated entities demonstrate a strong environmental ethic.
To monitor the success of this strategy, EPA must develop metrics other
than a reduction in the numbers and frequency of violation notices and the
number of agreements issued at civilian agencies. Performance measures must
focus on how CFA environmental programs are evolving toward a proactive,
state-of the-art level. State-of-the-art programs are those environmental
management systems deemed by peers as being best-in-class or world-class in
both quality and function. Reaching this level will require each federal agency
to develop and demonstrate top-level commitment to a strong environmental
ethic. EPA and the CFA Task Force should seek agreement on milestones
appropriate for marking accomplishments toward this level. A useful approach
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CFA Strategy
55
for measuring progress is the program evolving matrix provided for in the
Federal Environmental Challenge Program (see Chapter IV.D).
This matrix is important to federal agencies for several reasons. First, in
the spirit of change and improvement, it is important that an agency
demonstrate that it recognizes deficiencies in its environmental management
program as well as the consequences of such deficiencies. Once inadequacies
are recognized, agency staff and management will be able to identify the
improvements necessary to remedy the defects. An implementation plan with
key milestones should be developed to demonstrate that the agency has formed
a vision of its own evolution in environmental management and has developed a
roadmap to keep the agency on track toward reaching its goals.
Second, the program evolving matrix allows federal agencies to track
their progress in improving environmental management programs and in
eliminating inefficiencies (e.g., pollution abatement vs. pollution prevention
measures). Management can than make any necessary adjustments needed to
effect improvements. In the coming years, CFAs should be able to demonstrate
progress from their current position on the matrix to each program improvement
milestone along the path to improved performance and compliance. Once a
decision is reached by the agency on the direction that needs to be taken to
improve the agency's environmental management program, a plan should be
developed, committed to in writing, formally adopted by the agency, and
communicated to the employees and the public.
Data will be collected from both EPA regions and headquarters offices to
provide feedback to CFAs on improvements and accomplishments, as evidenced
through multi-media compliance inspections at facilities and installations. Other
metrics will also be needed to provide a comprehensive evaluation. By
performing program reviews as outlined in Chapter III.A of this strategy, EPA
regions can assist federal environmental managers in evaluating the effectiveness
of their programs. EPA and CFAs should also discuss both the accomplishments
and setbacks to the program improvement process at periodic meetings of the
CFA Task Force or in individual agency meetings between CFA and EPA
personnel. EPA will continue to provide support to agencies in meeting
environmental program improvement milestones and serve as liaison with other
federal agencies, such as OMB, in securing funding and other resources needed
to ensure the success of improving CFA environmental programs.
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56
VI. CONCLUSION
The Federal Government has made significant strides in achieving
environmental compliance and implementing programs to address its own
environmental responsibilities. However, more progress needs to be achieved.
Civilian federal agencies represent a tremendous resource for leadership in
environmental management. With coordination and effective exchange of
information, resources and funds can be leveraged to provide maximum benefits.
One lasting result of the CFA Task Force's work is the realization among
participants that EPA and federal agencies must open and maintain a dialogue in
order to develop and disseminate a common environmental ethic. If federal
agencies are to achieve environmental excellence, collaboration across agencies
is the only approach that offers the chance of success.
Ultimately, both to meet the challenges of increasingly stringent
regulations and to reduce liability, federal agencies and departments must
maintain a proactive stance toward environmental management. Proactive
programs require a continuous process and uncompromising standards of self-
inspection and assessment. Both management and staff level employees at
federal agencies are continually "on the line" making decisions that affect an
agency's compliance status. The result of these decisions determines the type
and extent of environmental liabilities facing management today and in future
years. The quality of these decisions will only be as good as the training and
experience provided to agency personnel, and as the level of commitment on the
part of top-level agency management.
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APPENDIX
CFA TASK FORCE MEMBER LIST
Ms. Carolyn Rowe
Department of Agriculture
Agriculture Research Service
6303 Ivy Lane, Room 640
Greenbelt, MD 20770
Mr. Terry Harwood
Department of Agriculture
Forest Service
Auditors Building, Third Floor Central
201 14th Street SW
Washington, D.C. 20250
Tel: 202-205-1156
Fax: 202-205-0861
George Sunstrom
Office of the Secretary
Department of Agriculture
Engineering Staff, Third Floor
201 14th Street SW
Washington, D.C. 20250
Tel: 202-205-1010
Fax: 202-205-0861
Ken Morin
Bureau of Land Management Service Center
Building 50
Denver, CO 80225-0047
Tel: 303-236-6418
Fax: 303-236-3508
Mr. Lawrence McGinty
Chief, Environmental Health & Safety Div.
Central Intelligence Agency
Washington, D.C. 20505
Tel: 703-482-4533
Fax: 703-356-2503
Mr. Ed Wandelt
Chief, Environmental Compliance Section
U.S. Coast Guard (G-ECV-2B)
2100 2nd Street SW
Washington, D.C. 20593
Tel: 202-267-6144
Fax: 202-267-4219
Mr. Paul Taggart
Attorney Advisor
U.S. Department of Commerce
14th & Constitution Ave. NW Room 3270
Washington, D.C. 20230
Tel: 202-482-4115
Fax: 202-482-3270
Ms. Kathleen Styles
Acting Chief, Finance & Litigation Division
U.S. Department of Commerce
14th & Constitution Ave. NW Room 5889
Washington, D.C. 20230
Tel: 202-482-4732
Fax: 202-482-5858
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Dr. Frank Monteferrante
Senior Environmental Specialist
Economic Development Administration
U.S. Department of Commerce
Herbert C. Hoover Building, Room 7019
Washington, D.C. 20230
Tel: 202-482-4208
Fax: 202-482-0995
Ms. Patricia Weggel
Senior Environmental Engineer
Technical Assistance and Evaluation Branch
Office of Administration and Resource
Management
U.S. Environmental Protection Agency
401 M Street SW (Room 3712)
Washington, D.C. 20460
Tel: 202-260-1653
Fax: 202-260-0215
Ms. Anne Fenn
Federal Facilities Coordinator
U.S. EPA Region 1
JFK Federal Building (PAS-205)
Boston, MA 02203
Tel: 617-565-3927
Fax: 617-565-3346
Mr. Bob Hargrove
Federal Facilities Coordinator
U.S. EPA Region 2
26 Federal Plaza
New York, NY 10278
Tel: 212-264-1892
Fax: 212-264-6693
Mr. Bill Cox
Chief, Federal Facilities Assistance
U.S. EPA Region 6
1445 Ross Ave.
Dallas, TX 75202-2733
Tel: 214-655-2258
Fax: 214-655-7446
Ms. Maryalice Locke
Environmental Specialist AEE-20
Hazardous Materials & Special Projects
Office of Environment and Energy
Federal Aviation Administration
800 Independence Ave. SW
Washington, D.C. 20591
Tel: 202-267-3495
Fax: 202-267-5594
Mr. Tom Harris
Environmental Compliance - Health and
Safety Office
Federal Bureau of Prisons
302 1st Street NW, Room 1027
Washington, D.C.
Tel: 202-307-2887
Fax: 202-514-9308
Dr. Naresh K. Chawla
Chief, Safety Office (HFA-205)
Food and Drug Administration
7500 Standish Place
Rockville, MD 20855
Tel: 301-594-1718
Fax: 301-594-3148
Ms. Karone Peace
Safety and Environmental Division
Environmental Branch (PMS)
General Services Administration
18th and F Streets NW, Room 4340
Washington, D.C. 20450
Tel: 202-501-3518
Fax: 202-501-3257
Mr. Bill Johnson
Chief, Facilities Engineering Branch
Indian Health Services
5600 Fisher's Lane, Room 5A-27
Rockville, MD 20857
Tel: 301-443-1247
Fax: 301-443-5697
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Dr. Jonathan P. Deason
Director, Office of Environmental Affairs
Department of the Interior
1849 C Street NW (MS-2340)
Washington, D.C. 20240
Tel: 202-208-3891
Fax: 202-208-6970
Mr. Bob Wilson
Environmental Protection Specialist
Office of Environmental Affairs
Department of the Interior
1849 C Street NW (MS-2340)
Washington, D.C. 20240
Tel: 202-208-7556
Fax: 202-208-6970
Ms. Mary Hecker
Safety and Environmental Manager
Security and Emergency Planning Staff
U.S. Department of Justice
10th and Constitution Ave. NW, Rm. 1103
Washington, D.C. 20530
Tel: 202-514-2977
Fax: 202-514-4699 or 1778
Mr. Michael Green
Chief,
Facilities Operation and Maintenance Office
NASA (Code JXG)
Washington, D.C. 20546
Tel: 202-358-1097
Fax: 202-358-3866
Mr. I. Sam Higuchi, Jr.
Senior Environmental Compliance Officer
National Oceanic and Atmospheric Admin.
SSMC-2/OA3X1, Room 4434
1325 East West Highway
Silver Spring, MD 20910
Tel: 301-713-0845
Fax: 301-713-0219
Ms. Nancy T. Briscoe
National Oceanic and Atmospheric
Administration (GC/NR)
SSMC-3 Room 15104
1315 East West Highway
Silver Spring, MD 20910
Tel: 301-713-1393
Fax: 301-713-1229
Ms. Joyce Jatko
Office of Polar Programs
National Science Foundation
4201 Wilson Blvd., Room 755
Arlington, VA 22230
Tel: 703-306-1030
Fax: 703-306-0139
Ms. Kathleen Hutson
APS 13, Room AT200
National Security Agency
9800 Savage Road
Fort Meade, MD 20755-6000
Tel: 410-684-7305
Fax: 410-684-7300
Mr. Charles E. Bravo
Manager, Environ. Management Policy
U.S. Postal Service
475 L'Enfant Plaza SW, Room 7431
Washington, D.C. 20260
Tel: 202-268-6188
Fax: 202-268-6016
Mr. Dennis Mynot
Tennessee Valley Authority
400 West Summit Hill Drive
Knoxville, TN 37902-1499
Tel: 615-632-6644
Fax: 615-632-6855
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Ms. Katherine Johnson
Office of the Secretary
U.S. Department of Transportation
400 7th Street SW
Washington, D.C. 20590
Tel: 202-366-0560
Fax: 202-366-3911
Mr. Glenn W. Goulet
Program Manager
Infrastructure and Technology Division
Volpe Natnl. Transportation System Center
U.S. Department of Transportation
Kendall Square
Cambridge, MA 02142
Tel: 617-494-2002
Fax: 617-494-2961
Mr. William McGovern
Chief, Environmental Compliance Division
Department of die Treasury
Treasury Annex
1500 Pennsylvania Ave. NW
Washington, D.C. 20220
Tel: 202-622-0043
Fax: 202-622-1468
Mr. John G. Staudt
Chief,
Hazardous Materials Management Division
U.S. Department of Veterans Affairs
810 Vermont Ave. NW
Washington, D.C. 20420
Tel: 202-233-7197
Fax: 202-233-4812
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