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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
Evaluation Report
EPA Needs a Comprehensive
Research Plan and Policies to
Fulfill its Emerging Climate
Change Role
Report No. 09-P-0089
February 2, 2009
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Report Contributors: Manju Gupta
Jeffrey Harris
Jeffrey S. Hart
Lauretta Joseph
John Patrick
Kalpana Ramakrishnan
Denton Stafford
Abbreviations
BOSC Board of Scientific Counselors
CCSP Climate Change Science Program
CCTP Climate Change Technology Program
EPA U.S. Environmental Protection Agency
FY Fiscal Year
GCRP Global Change Research Program
OAR Office of Air and Radiation
OIG Office of Inspector General
ORD Office of Research and Development
Cover Photos: Picture on left shows a hurricane striking a sea wall (photo courtesy National
Oceanic and Atmospheric Administration). Middle picture shows solar and
wind technologies (photo courtesy California Public Utilities Commission).
Picture on right shows coastal erosion in Pacifica, California (photo courtesy
National Aeronautics and Space Administration).
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
09-P-0089
February 2, 2009
Catalyst for Improving the Environment
Why We Did This Review
We sought to answer the
question: how well do the
policies, procedures, and plans
of the U.S. Environmental
Protection Agency (EPA) help
I ensure that its climate change
research fulfills its role in
climate change?
Background
EPA is 1 of 13 federal
agencies that make up the
U.S. Climate Change Science
Program, which guides federal
research through its strategic
plan. Part of EPA's role is
understanding the regional
consequences of global
change. EPA's Office of
Research and Development
(ORD) handles this function.
EPA's Office of Air and
Radiation conducts activities
related to mitigating
greenhouse gases. ORD
manages EPA's climate
change research function
through its Global Change
Research Program.
For further information,
contact our Office of
Congressional, Public Affairs
and Management at
(202)566-2391.
To view the full report,
click on the following link:
www.epa.qov/oiq/reports/2009/
20090202-09-P-0089.pdf
EPA Needs a Comprehensive Research Plan and
Policies to Fulfill its Emerging Climate Change Role
What We Found
EPA does not have an overall plan to ensure developing consistent, compatible
climate change strategies across the Agency. We surveyed EPA regions and
offices and found they need more information on a variety of climate change
topics. They need technical climate change research and tools as well as other
climate change policy guidance and direction. We learned that, in the absence of
an overall Agency plan, EPA's Office of Water and several regional offices have
independently developed, or are developing, their own individual climate change
strategies and plans. The lack of an overall climate change policy can result in
duplication, inconsistent approaches, and wasted resources among EPA's regions
and offices. EPA has not issued interim guidance to give its major components
consistent direction to ensure that a compatible national policy - when it emerges
- will not result in wasted efforts.
EPA's latest plan for future climate change research does not address the full
range of emerging information needs. Specifically, the projected time of
completion or the scope of some research projects do not match the timing or the
scope of regions' needs. ORD does not have a central repository of its climate
change research for its internal users, nor does it effectively communicate the
results of its climate change research to EPA's internal users. While ORD
collects research requirements from regions and program offices, the selection
criteria for research topics are not transparent to the regions. Finally, ORD does
not have a system to track research requests through completion, or a formal
mechanism to obtain feedback from its users.
What We Recommend
We recommend that the Deputy Administrator direct Assistant and Regional
Administrators on how to plan for climate change challenges in their media
areas/regions until the Agency develops an overall strategy; and establish
guidance for regularly entering their climate change scientific information in the
Science Inventory. We also recommend that the Assistant Administrator for ORD
establish various management controls to ensure EPA fulfills its emerging climate
change role and related information needs. The Agency concurred with our
recommendations.
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z
LU
(S
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
MEMORANDUM
SUBJECT:
FROM:
TO:
February 2, 2009
EPA Needs a Comprehensive Research Plan and Policies to Fulfill its
Emerging Climate Change Role
Report No. 09-P-0089
Wade Najjum
Assistant Inspector General, Office of Program Evaluation
Lisa P. Jackson
Administrator
Lek Kadeli
Acting Assistant Administrator for Research and Development
This is our report on the Climate Change Program evaluation conducted by the Office of
Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA). This report
contains findings that describe the problems the OIG has identified and corrective actions the
OIG recommends. This report represents the opinion of the OIG and does not necessarily
represent the final EPA position. Final determinations on matters in this report will be made by
EPA managers in accordance with established audit resolution procedures.
The estimated cost of this report - calculated by multiplying the project's staff days by the
applicable daily full cost billing rates in effect at the time - is $636,217.
Recommendations 2-1 and 3-1 of this report are addressed to the Deputy Administrator, and
Agency comments were received from the Deputy Administrator. The Deputy Administrator
position is currently vacant. Therefore, we are addressing this report to the Administrator.
Action Required
In accordance with EPA Manual 2750, you are required to provide a written response to this
report within 90 calendar days. You should include a corrective actions plan for agreed upon
actions, including milestone dates. We have no objections to the further release of this report to
the public. This report will be available at http://www.epa.gov/oig.
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If you or your staff has any questions regarding this report, please contact me at 202-566-0827;
or Jeffrey Harris, Director of Cross Media, at 202-566-0831 or harris.jeffrey@epa.gov.
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EPA Needs a Comprehensive Research Plan and 09-P-0089
Policies to Fulfill its Emerging Climate Change Role
Table of Contents
Chapters
1 Introduction 1
Purpose 1
Background 1
Noteworthy Achievements 5
Scope and Methodology 5
2 EPA Regions Have Multiple Climate Change Needs 7
EPA Regions Need Differing Climate Change Information 7
EPA's Office of Water and Most Regional Offices Are Independently
Developing Climate Change Strategies 9
Conclusions 10
Recommendation 10
Agency Comments and OIG Evaluation 10
3 Research Plan Does Not Address All Regions' Climate Change Needs 12
Regions Need Climate Change Information and Tools
Directed at Regional and Local Levels 12
The Timing and Scope of ORD's Planned Projects
Do Not Meet Key Regional Needs 13
EPA Lacks Policies to Meet Internal Climate Change
Information Needs Effectively 15
Conclusions 17
Recommendations 18
Agency Comments and OIG Evaluation 19
Status of Recommendations and Potential Monetary Benefits 20
Appendices
A Agency Response and OIG Evaluation 21
B Agency Preliminary Comments and OIG Evaluation 26
C Distribution 30
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09-P-0089
Chapter 1
Introduction
Purpose
The overall purpose of this evaluation was to answer the question, "How well do
the policies, procedures, and plans (i.e., internal/management controls) of the
U.S. Environmental Protection Agency (EPA) help ensure that its climate change
research fulfills its climate change role and related internal needs?"
To accomplish this objective, we answered the following questions:
(1) What research products or information do EPA's program and regional offices
need to fulfill EPA's climate change role? Do EPA's Office of Research and
Development (ORD) climate change research plans meet the information
needs of EPA's program and regional offices?
(2) Does EPA have policies, procedures, or other internal/management control
mechanisms in place to efficiently and effectively coordinate its climate
change research, and to ensure expertise across the Agency is being used to
fulfill its climate change role?
Background
Since the enactment of the Global Change Research Act of 1990, EPA's research
on climate change - also known as global warming - has been part of a national and
international framework. EPA is 1 of 13 federal agencies that comprise the U.S.
Climate Change Science Program (CCSP). The CCSP was launched in 2002. The
CCSP incorporated both the U.S. Global Change Research Program (GCRP) and
the U.S. Climate Change Research Initiative of 2001. The CCSP Strategic Plan
guides federal research on climate change, and the 13 agencies focus their research
on areas related to their unique missions in a collaborative effort.1 Figure 1.1 on
page 2 shows the relationships between these different organizations.
CCSP's strategic plan defines EPA's role as having a primary focus on
understanding the regional consequences of global change. Within EPA, ORD
performs this role. ORD has the responsibility for assessing the potential impacts
1 CCSP assessment activities, in turn, contribute to the work of the Intergovernmental Panel on Climate Change.
Established by the United Nations and the World Meteorological Organization, the Intergovernmental Panel on
Climate Change assesses scientific, technical, and socio-economic information to better understand climate change, its
potential impacts, and options for adaptation and mitigation.
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09-P-0089
of climate change and evaluating adaptation options.2 The Office of Air and
Radiation (OAR) has responsibility for activities related to mitigating greenhouse
gases. Both ORD and OAR communicate science findings and information about
adaptation options.
Figure 1.1: Relationships between International, National (U.S. Federal), and EPA
Climate Change Programs
International Level
Intergovernmental Panel on Climate Change
U.S. Federal Level
EPA Level
U.S. Global Change
Research Program
1990
^£^
U.S. Climate Change
Science Program
(CCSP) 2002,includes
13 federal agencies
•^
U.S. Climate Change
Research Initiative
2001
^
r
U.S. Climate Change
Technology Program
(CCTP) 2002
EPA ORD Global
Change Research
Program (GCRP)
EPA OAR Climate
Change Division
EPA OAR Climate
Protection
Partnership Division
Source: Office of Inspector General (OIG)
We focused primarily on ORD because it has the central responsibility for EPA
climate change research under the CCSP, and because ORD is the scientific
research arm of EPA. ORD's mission is to:
• perform research and development,
• provide responsive technical support to EPA,
• integrate the work of ORD's scientific partners, and
• provide leadership in addressing emerging environmental issues.
While the primary focus of ORD climate research has been on assessing the potential impacts of climate change
and alternative adaptation options, this is changing given the directives of the Fiscal Year 2008 Appropriations Bill.
ORD also has some responsibility for mitigation. Further, as discussed in Chapter 3, EPA's draft 2008 GCRP multi-
year plan synopsis addresses four different categories of regional mitigation research decisions/concerns: (1) Clean
energy, (2) Renewables/Biofuels (wind & solar), (3) Mitigation models, and (4) Sequestration.
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09-P-0089
ORD manages EPA's climate change research function through its GCRP.3
ORD's GCRP not only assesses the impacts of global change; it also focuses on
the implications of climate change on EPA's ability to satisfy its statutory,
regulatory, and programmatic requirements. EPA also has statutory obligations to
provide scientific information to organizations other than EPA regional and
program offices.
The scope of OAR's interest is similar to the scope of ORD's climate change
work. However, OAR is focusing more on mitigation and the effect of regional
air quality control strategies on climate change, as opposed to the effect of climate
change on regional air quality.
EPA Climate Change Research Funding
Relevant scientific and technical work is coordinated across the Federal
Government by the CCSP and the U.S. Climate Change Technology Program
(CCTP). CCSP received about $1.8 billion in Fiscal Year (FY) 2008, and CCTP
received about $3.9 billion. In contrast, EPA received about $36.6 million in
FY 2008 for Science and Technology funding for climate change. ORD's budget
for GCRP, ranging between about $16 and $20 million annually over the last
3 years, is about 1 percent of the total CCSP budget.
ORD's overall budget for FYs 2001-2008 decreased (using inflation adjusted
dollars) 20 percent from $696 to $548 million, while its GCRP budget declined
36 percent from $28 to $18 million during the same period. GCRP's budget has
been about 3 percent, on average, of ORD's entire budget for the last 6 years as
shown in Figure 1.2.4
3 A 2008 GCRP Multi-Year Plan Synopsis describes EPA's GCRP as stakeholder-oriented, with primary emphasis
on assessing the potential consequences of global change (particularly climate variability and change) on air quality,
water quality, aquatic ecosystems, and human health in the United States.
4 Congress' passed Science and Technology Omnibus FY 2008 spending bill specifically increases the GCRP's
budget and stipulates that the new resources will be used to conduct research in support of the Agency's efforts to
regulate greenhouse gas emissions.
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09-P-0089
Figure 1.2: ORD Global Climate Research Plan Budgets as a Percentage of ORD's
Total Budgets, FYs 2001-2008
= £
to 2 $600
| Q $500
c -a
—
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09-P-0089
began identifying additional needed climate change research, information, and
related products.
Noteworthy Achievements
The Board of Scientific Counselors (BOSC) is a public advisory committee
chartered under the Federal Advisory Committee Act that provides advice,
information, and recommendations about the ORD research program. A BOSC
subcommittee performed a review of ORD's GCRP and published its final report
on March 27, 2006. The review found that within the context of what GCRP had
been asked to do so far, it had done the "right work" and that it had done it "well."
Scope and Methodology
To determine how well EPA's policies, procedures, and plans (i.e.,
internal/management controls) help ensure that its climate change research fulfills
EPA's climate change role and related internal needs, we reviewed documents
relating to:
• ORD's and EPA's responsibilities and policies on climate change,
• EPA's 2006-2011 Strategic Plan,
• GCRP's 2008-2012 Draft Multi-Year Plan,
• BOSC's Mid-Cycle Review of GCRP, and
• legislation regarding climate change.
We also reviewed documents provided by the GCRP National Program Director
and attended several relevant conferences concerning climate change.
We conducted two surveys to identify what research products or information
EPA's program and regional offices need to fulfill EPA's climate change role.
We sent the first survey to regions and program offices to identify the universe of
specific climate change decisions and concerns, and to determine the adequacy of
EPA's climate change policies and procedures.
We sent a second survey to selected ORD managers and staff to obtain
information on ORD's existing and planned climate change research products as
well as EPA's policies. We analyzed responses from the 10 EPA regions, OAR,
and ORD's GCRP. We judgmentally chose five climate change decisions and
products to use as case studies for more detailed follow-up. The five case studies
came from five different EPA regions. We then conducted follow-up interviews
with representatives of the five regions.
To determine whether GCRP's climate change research plans meet the
information needs of EPA's programs and regional offices, we analyzed and
compared GCRP planned research product topics and timeframes to the decisions
and concerns identified by regions. We also reviewed ORD's budgets for the last
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09-P-0089
8 years and compared them to annual ORD and GCRP budgets to identify any
funding trends. Further, we interviewed selected external stakeholders concerned
with climate change or research.
We conducted this review in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the review
to obtain sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions based upon
our objectives. We performed our evaluation between November 2007 and
April 2008.
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09-P-0089
Chapter 2
EPA Regions Have Multiple
Climate Change Needs
EPA does not have an overall plan or other means to ensure the development of
consistent, compatible climate change strategies across EPA or to make the best
use of declining research dollars. EPA regions have multiple climate change
needs, including the need for information on a variety of different climate change
topics. Regions stated that they needed technical climate change research and
tools, as well as other climate change policy guidance and direction. In the
meantime, EPA's Office of Water and regional offices have independently
developed, or are in the process of developing, individual climate change
strategies and plans. The lack of an overall climate change policy can result in
duplication, inconsistent approaches, and wasted resources among EPA's regions
and offices.
EPA Regions Need Differing Climate Change Information
Regional respondents to our survey identified a variety of different, emerging
climate change information needs. They need technical climate change research
or information, as well as related policy guidance and direction.
Regions Need Technical Information
Regions stated they would like technical information on:
• impacts of climate change,
• mitigation or greenhouse gas emissions reduction/energy efficiency
technologies,
• tools to assess the effectiveness of emissions reduction technologies and
climate change policy decisions, and
• adaptation strategies to moderate potential climate-related damage and
preventive measures.
Table 2.1 shows the types of climate change information regions require.
Regions 2 and 8 were in the process of identifying climate change research and
information needs, and did not identify specific needs at the time of our survey.
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09-P-0089
Table 2.1: Regional Climate Change Information Needs
Region
1
3
4
5
6
7
9
10
Impact of
Climate
Change
X
X
X
X
X
X
X
Mitigation
Technologies
X
X
X
X
Effectiveness of
Mitigation Technologies
and Climate Change
Policies
X
X
X
X
X
X
Adaptation
Strategies
X
X
X
Source: OIG
Seven regions stated they require a variety of technical information on the impact
of climate change. For example, they need information on the potential impacts
of temperature and health effects, food supply considerations, and local and
regional impacts. Region 6 stated that it would like information on the impact of
rising water on aquifers and ground water monitoring. Region 7 stated it would
like information on the impacts on agricultural processes. Region 9 stated that it
would like information on the impacts on water bodies and agriculture due to
changing pest pressures and invasive species.
Several regions identified information needs on mitigation technologies. Regions
stated that they would like additional information on alternative energy sources
such as biofuel, solar, and wind technologies. Regions 6 and 9 require
information on carbon sequestration, specifically regarding the feasibility of
sequestration at Superfund sites. They also need information on the safely and
efficacy of geologic carbon sequestration.
Regions stated they require tools to assess the effectiveness of mitigation
technologies along with anticipated climate change policies. For example,
Regions 2 and 6 needed computer models to determine the effectiveness of
mitigation technologies and their impact on policy decisions and planning
processes. Regions 5 and 6 stated that they would like information on the
effectiveness of using bio-fuels, such as corn ethanol, as a method for reducing
greenhouse gases. Regions 1 and 6 would like to develop emissions inventories
to monitor reducing greenhouse gases, and would like to have a common protocol
to quantify the benefits of energy efficiencies.
Regions also stated they would like information on adaptation strategies,
including tools to asses their effectiveness. For example, Region 1 stated that,
"As the likely impacts of climate change become better understood, we have
become more and more interested in science-based tools (e.g., predictive models
of coastal impacts) to assist states and communities in preparing for those impacts
(e.g., predictive models of impacts on coasts)." Region 9 stated that it wanted
information on how to develop alternative approaches to storing surface water for
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09-P-0089
dry seasons. Region 10 listed several adaptation information needs such as
identifying appropriate water infrastructure, and ensuring the integrity of drinking
water systems in case of sea level rise and episodic flooding, both potential
hazards of climate change. Region 10 also stated its tribal communities require
information and adaptation strategies that are consistent with tribal cultural
perspectives.
Regions Need Policy Guidance and Direction
Regions stated in survey responses that they need additional policy guidance and
direction on climate change and related research. They said they need this
information in anticipation of any new climate change legislation. They need the
information not necessarily from ORD, but from other EPA program offices. For
example, Region 1 anticipates needing to provide effective technical guidance to
operators of wastewater treatment plants to ensure the greatest possible energy
efficiency. Region 1 anticipates needing presentations, brochures, and other
outreach material to educate the regulated community and the public about
specific requirements. Region 9 staff need guidance on whether to allow
permitting of new coal-power electricity plants.6 Region 10 needs guidance on air
quality programs and how to align timelines and schedules of implementing these
programs when addressing climate change impacts. Some regional
representatives need guidance on how to assess climate change from a tribal
perspective along with plans to attain and maintain air quality standards.
EPA's Office of Water and Most Regional Offices Are Independently
Developing Climate Change Strategies
EPA's Office of Water and most regional offices are independently developing
their own climate change strategies or plans. Although the Administrator issued a
working paper on energy and climate, as discussed in Chapter 1, EPA does not
have an overall climate change policy. EPA's Office of Water has developed its
own draft climate change strategy, and 7 of 10 EPA regions responded to surveys
that they had or were working on their own climate change plans or strategies.
The Office of Water did not respond to our survey because at the time it was
developing a strategy to deal with the impact of climate change. Office of Water
staff stated that they are in the early stages of understanding how climate change
will affect different water programs. Although the Office of Water has an idea of
how climate will affect water resources based on best professional judgments, the
Office is waiting to receive scientific feedback to better understand the nature of
the problem.
6 Some new power plants had designs to utilize geologic carbon sequestration. However, because the safety and
efficacy of carbon sequestration has not been established, Region 9 cannot determine if it can issue permits to the
power plants.
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09-P-0089
EPA Regions 1, 2, 5, 6, 8, 9, and 10 have either developed draft strategies or are
developing draft climate change action plans or strategies.7 However, climate
change poses a new set of challenges. Region 9, for example, stated that two
major challenges are "deciding what degree to implement the highest priority
activities and how to accomplish the work." In general, the regions are looking
into how they can further reduce greenhouse gas emissions and how to create
strategies to help them adapt to climate change.
Conclusions
EPA regional offices stated they need a variety of research products, technical
information, or tools on climate change impacts, adaptation, and mitigation.
Moreover, regions require policy guidance and direction on how to implement
any new climate change legislation. In the meantime, some program and regional
offices are independently creating separate, individual climate change action plans
and strategies.
An overall EPA strategy for climate change should:
• lead to clear research requirements,
• help the Agency fulfill its climate change role, and
• provide "unity" of action so regions and program offices can proceed with
confidence in establishing their own climate change strategies and plans.
Such a national strategy does not yet exist. The lack of an overall climate change
policy can result in duplication, inconsistent approaches, and wasted resources
among EPA's regions and offices. EPA has not issued interim guidance to give
its major components consistent direction so that a compatible national policy -
when it emerges - will not result in wasted efforts.
Recommendation
We recommend that the Deputy Administrator:
2-1 Direct Assistant and Regional Administrators on how to plan for climate
change challenges in their media areas/regions until the Agency develops an
overall strategy.
Agency Comments and OIG Evaluation
The Agency concurred with our recommendation. Recently, the Agency initiated
a process that will contribute to an Agency approach on climate change.
Additionally, the Agency agreed to provide the OIG with progress updates. To
7 One region did not indicate whether it had developed a strategy or was developing a climate change action plan or
strategy.
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09-P-0089
meet the OIG's requirements, the Agency's approach should also include
milestones for each specified action. The Agency's written response, as well as
our evaluation of Agency comments, is in Appendix A.
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09-P-0089
Chapter 3
Research Plan Does Not Address All Regions'
Climate Change Needs
GCRP's January 2008 draft research plan does not address the full range of
EPA's climate change information needs. Regions need climate change tools and
information to fulfill EPA's regulatory responsibilities. In addition, the timing or
the scope of GCRP's planned research projects do not match the timing or the
scope of regions' needs. Finally, ORD lacks procedures to ensure it meets
internal EPA climate change information needs effectively.
Regions Need Climate Change Information and Tools Directed at
Regional and Local Levels
EPA regions need climate change information and tools directed at regional and
local levels. They need this information and these tools, in part, to fulfill EPA's
regulatory responsibilities related to their programs. Regions' areas of concern
include air quality; projections of sea level rise affecting their regions; and
impacts of episodic flooding on water infrastructure, wetlands, and critical habitat
for endangered species in their local areas.
GCRP completed a national level preliminary assessment of the implications of
climate change for air quality across the United States in September 2007. GCRP
plans to complete a more comprehensive assessment and report on the climate
change impact on national and regional air quality by 2012. However, regions
need information and tools to fulfill EPA's regulatory responsibilities related to
their specific programs and activities, such as approving State Implementation
Plans8 and permits. Regions require tools and models that they can use to assess
the climate change impact on air quality at a more local level. In many cases, air
quality problems are localized, and climate change impacts on air quality vary
from one geographic area to another.
Seven regions (Regions 1, 4, 5, 6, 7, 9, and 10) stated that they require regional or
local scale models to develop adaptation strategies that would work for their
cities, States, and regions. For example, Regions 6, 9, and 10 need research on
sea level rise specific to their geographic region. Their concerns include the
impact of sea level rise on the quality and quantity of drinking water, and on
waste water treatment plants. These regions are also concerned about sea level
rise near Superfund sites in their coastal areas. Regions 6 and 9 need regional
8 State Implementation Plans identify how each State will attain and/or maintain the primary and secondary
National Ambient Air Quality Standards.
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09-P-0089
level analysis on the severity and frequency of drought, and the decrease in
mountain snow pack.
Similarly, regions need geographic-specific predicted impacts in other areas for
resource planning and management. For example, Region 7 needs research on
disaster-related weather events, and the impact of climate change on agricultural
processes in its region. Region 10 needs region-specific climate change impact
information to inform local decision makers on building adaptation infrastructure,
such as additional sea walls or dikes. This infrastructure could be impacted by
increased storm intensity and tidal surges that can cause damage to facilities, as
well as damage due to sea level rise.
The Timing and Scope of ORD's Planned Projects Do Not Meet Key
Regional Needs
Although GCRP's draft 2008-2012 Multi-Year Plan addresses most of the topic
areas identified by regions, the timing and scope of the planned research projects
do not meet key regional needs. We compared research topics and delivery dates
of the planned research topics to the information needs the regions identified in
response to our survey in December 2007. We concluded that the planned
completion dates for many of GCRP's planned research topics do not meet all of
the regions' needs. Regions started developing their climate change strategies and
plans after the EPA Administrator added climate change to his list of priorities for
regions in June 2007. However, the survey responses show that the regions need
information on many climate change topics within the next year or even
immediately.
We asked in our survey for the regions to list five current or future climate
change-related decisions or areas of concerns. The regions listed 57 decisions or
areas of concerns. We then summarized these 57 decisions or concerns into 11
summary categories, and compared them to the draft 2008-2012 Multi-Year Plan,
as shown in Table 3.1.
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Table 3.1: Regional Research Needs versus GCRP's Planned Research Projects
Regional
Decision or
Concern
Category
1. Air quality
impacts
2. Clean energy/
efficiency
3. Water quality/
Quantity/
Wastewater
4. Sea level
changes
5. Ecosystem
services
6. Droughts/
water
variability
7. Adaptation
strategies
8. Renewables/
Biofuels (wind
& solar)
9. Mitigation
models
10. Impact models
11. Sequestration
Regions That
Cited the
Decision or
Concern
9, 10
1,6
1,5,6, 10
6,9
6,9, 10
6,9
4,8
3,5,6,9
4,6
1,3,4,6,9
3,5,6,9
Addressed
in GCRP
Multi-Year
Plan?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Regional Timeline
When Information
Is Needed
Ongoing, 1 to 2
years, immediately
Immediately,
medium term
Ongoing, Jan/2010,
short-term
Short term,
Jan/2010, 3-5 years
2008, June 2011,
within 3-5 years
Jan/2010,3-5
years, 5-10 years
ASAP
Ongoing, ASAP,
presently, Jan/2009
immediately
ASAP
Continuous,
presently, ASAP,
Jan/2012, June
2012, immediately
Presently, ASAP,
long-term, 2-5
years
GCRP
Timeline
Satisfies
Regional
Needs?
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
Cannot
determine
Cannot
determine
Source: OIG analysis of survey responses and GCRP's Draft Multi-Year Plan. The 11 numbered
categories do not represent any priority.
We compared regional research needs and desired timeframes to GCRP's planned
products and their estimated completion dates. We found that GCRP's draft plan
addressed 6 of the 11 summary categories in some manner. As shown above in
Table 3.1, GCRP is planning to provide the type of information requested by the
regions in the first six categories soon enough to meet the regions' needs.
However, GCRP's timeframe for delivery did not match the regions' needs in at
least three categories. In the last two categories above, we could not determine
for certain whether GCRP was planning to provide the type of information
requested by the regions soon enough to meet the regions' needs.
As shown in Table 3.1, GCRP plans to satisfy the regions' air quality impact
needs on time. GRCP is researching climate change air quality impact measures,
and plans other similar projects. The research topics include the impact of climate
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change on U.S. particulate matter concentrations, and the human health impacts
due to global change effects on air quality. GCRP plans projects in these two
topic areas for 2009 and 2011, respectively. The regions stated that they needed
these types of products either immediately, "ongoing," or in 1-2 years. GCRP
plans to satisfy these needs on time.
On the other hand, the regions are also asking for information on bio-fuel, solar,
and wind farm technologies. The regions also need information on the possibility
of widespread environmental damage associated with large-scale increased corn
production for use in ethanol production. Responses from different regions listed
the time they need this information as immediate, "ongoing," and "ASAP."
However, according to the draft Multi-Year Plan, GCRP does not plan to
complete its renewable fuels research until 2011. In the interim, ORD has
established a work group on bio-fuels that includes participants from regions,
OAR, and ORD. ORD representatives stated that regions can obtain interim
results by joining the workgroup.
EPA Lacks Policies to Meet Internal Climate Change Information
Needs Effectively
EPA's policies and procedures do not ensure that it can meet the climate change
research information needs of its program offices and regions. EPA does not have
a repository of climate change research conducted by the other agencies. While
ORD has set up processes for communicating with regions, the processes do not
have the force of policy. As a result, ORD's communication of research results is
not coordinated or consistent. Finally, EPA does not have a policy to ensure that
climate change research is effectively coordinated between ORD, program
offices, and regions.
EPA Does Not Have a Central Repository of Climate Change
Information
EPA does not have a central repository of climate change-related research
information. ORD does not systematically or comprehensively collect climate
change research information and make it available to EPA's internal users. EPA
regions and program offices regularly need and obtain climate change research
information from external sources.
Responses to the survey showed that regions and program offices use a variety of
sources outside of EPA for obtaining climate change research information they
need to carry out their responsibilities. Regions obtain this information through
their own informal networks and contacts. The sources they turn to include other
federal agencies, non-governmental organizations, academic researchers, and
international organizations. Fourteen of 16 respondents stated that they get
climate change research information from other federal agencies. Survey
respondents stated that the information they need to carry out their responsibilities
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may be located at the Department of Energy, the National Oceanic and
Atmospheric Administration, or the Department of Agriculture. However, ORD
does not systematically collect that information and make it available to EPA
users. For example, Region 10 uses regional sea level rise information from the
National Oceanic and Atmospheric Administration because ORD focuses on sea
level rise from a national perspective. Region 5 uses research from the
Department of Agriculture related to land use and bio-fuels. Region 6 gets
emissions research information from the Department of Energy. However, survey
respondents also mentioned informal methods and networks staff use to obtain
information from external sources. The potential for duplication of effort and
inefficiency exists when EPA staff in regions and program offices independently
collect information from external sources.
ORD Does Not Systematically Communicate Research Results
ORD does not systematically communicate all relevant research results to its
users. ORD uses formal and informal mechanisms to share results of its research.
Formal mechanisms include publishing reports in technical journals, reporting to
the CCSP, and publishing information on EPA Websites. GCRP's research
products are also published in CCSP reports and posted on the CCSP Website.
ORD established a Science Inventory with the intent of compiling all ORD
research reports. According to ORD, each EPA office is responsible for adding
its own science activities to the inventory. However, the Science Inventory is not
current because it has not been consistently updated or maintained.
ORD's GCRP recently established a new Web-based climate change-related tool
called the Environmental Science Connector. This tool is accessible to all EPA
users. This Web-based tool contains a variety of GCRP climate change research-
related information. However, it contains only GCRP documents, is still in the
early stages of implementation, and is still being refined. According to ORD,
they also have other systematic methods of communicating the results of their
research, including:
• a new public Website, Science to Achieve Results,
• regularly-scheduled Science to Achieve Results progress review sessions,
• fact sheets, and
• public lectures and presentations.
Nonetheless, EPA survey respondents indicate that these methods are not entirely
effective.
ORD's informal processes to communicate climate change research information
to regions and program offices include workshops, meetings, and weekly
telephone calls with the GCRP National Program Director in which regions and
program offices can participate. However, since these processes are informal,
participation is inconsistent and only partly effective.
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EPA Does Not Have a Policy to Ensure Research is Effectively
Coordinated
ORD routinely included the regional offices when developing its new draft Multi-
Year Plan through Research Coordinating Teams. However, EPA does not have a
formal policy to ensure that climate change research is effectively coordinated
among ORD, program offices, and regions.
ORD's research selection process is not transparent to the regions. The March
2006 BOSC report stated that ORD should have a transparent priority setting
process so stakeholders understand how ORD chooses issues to address.
Transparency is necessary so stakeholders understand how they can participate in
the process. In developing its new draft Multi-Year Plan and research strategy,
ORD coordinated with regions by asking them for their research requirements.
However, regions do not know why some topics were selected and others were
not. In some instances, when a research topic is not chosen, the reason is not
documented or communicated. Survey results and our follow-up interviews with
regional representatives show that the regions did not know how and why topics
were selected or not selected for research.
We also found that ORD does not have a system to track regional research
requirements from the time they are received to the time a decision is made about
whether and how the requirement will be met. ORD also does not track research
requests or products by requestor. However, managers from ORD's Office of
Science Policy told us that a project is underway to establish a database that will
track research needs to completion and to the requestor.
Additionally, ORD does not have a formal, systematic mechanism to obtain
feedback on how well its research products meet users' requirements. The March
2006 BOSC report stated that ORD needed to focus more on ensuring that
information provided to decision makers is valuable, applicable, and
understandable. In response to our discussion draft, ORD indicated that it will
conduct a survey before the next BOSC review.
Conclusions
In 2007, EPA program offices and regions began identifying their research and
information needs to fulfill their responsibilities. However, EPA does not yet
have a comprehensive climate change research plan that matches EPA's evolving
climate change role. ORD's current climate change research products and plans
do not meet users' needs in timeliness or scope. Some changes in policy and
procedures are needed to ensure ORD can meet regions' climate change research
information needs.
When the EPA Administrator added climate change as a regional priority in June
2007, regions began identifying new climate change information needs. Before
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that time, regions generally did not request specific climate change-related
research. To address the new priority, regions need some climate change
information immediately or in the very near future.
Compounding the situation, ORD does not maintain a central repository of
climate change research information from other sources that EPA's internal users
frequently need. Nor does ORD have a formal policy to systematically
communicate climate change research to regions or other interested parties. The
Science Inventory database is not current, and the new Environmental Science
Connector is in the early implementation stage and still being refined. In
addition, ORD's research selection process is not transparent, and ORD does not
yet have a system to track regional research requirements to completed research
products or to requestors. Finally, ORD does not have a formal mechanism to
obtain feedback from regions and program offices on how well its research
products meet users' requirements or information needs. These issues can result
in an ineffective use of resources, which could be avoided through better
management controls. Implementation of our recommendations will also help
make the best use of declining resources.
Recommendations
We recommend that the Deputy Administrator:
3-1 Establish guidance to programs and regional offices for regularly entering
their climate change scientific information in the Science Inventory.
Further, we recommend that the Assistant Administrator for the Office of Research and
Development:
3-2 Ensure that ORD continues to routinely update the Science Inventory to
include the latest information from its laboratories and centers.
3-3 Establish a formal, transparent research requirements determination
process that includes well-defined procedures for identifying a unified set
of priority climate change research needs.
3-4 Establish a formal mechanism to track regional research needs from
research project selection to completion, and to requestor.
3-5 Establish a formal method for coordinating GCRP's research work with
regions and program offices, communicating research results, and
collecting feedback on research products. The feedback requested should
include the accessibility, usability, value, and awareness of updates to the
Science Inventory and the Environmental Science Connector.
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Agency Comments and OIG Evaluation
ORD concurred with our recommendations; however, many of the responses
include prospective actions. The Agency must submit a Corrective Action Plan
including milestones and dates for these proposed actions. The Agency's
complete final written response and OIG evaluation are in Appendix A. EPA's
preliminary memorandum response and OIG comments are in Appendix B.
In response to the first recommendation, EPA agreed that Agency's scientific
results must be readily accessible, and agreed to establish guidance for EPA's
regional and program offices. Similarly, in response to the second
recommendation, ORD agrees to ensure that its labs and centers use the Science
Inventory and the Environmental Science Connector to share their current
research across the Agency. ORD will also evaluate the effectiveness of the
mechanisms for providing current scientific information. In response to the third
and fourth recommendations, ORD plans to formalize and document the process
for selecting and prioritizing research requirements from EPA's program and
regional offices and share it Agency wide. ORD plans to issue a memorandum
document with details on the selection and tracking processes to Deputy Assistant
Administrators, Deputy Regional Administrators, Research Coordinating Teams,
Regional Science Liaisons, and Climate Coordinators in December 2009. In
response to the fifth recommendation, ORD stated that it will document and
formalize the mechanisms ORD uses for communication and collecting feedback
in a fact sheet and share it with stakeholders within the Agency. Additionally,
ORD stated that GCRP plans to issue a survey to assess the timeliness and
usefulness of its research products prior to the next BOSC review in 2010.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
Page
No.
Subject
Status1
Planned
Completion
Action Official Date
POTENTIAL MONETARY
BENEFITS (in SOOOs)
Claimed Agreed To
Amount Amount
2-1 10 Direct Assistant and Regional Administrators on
how to plan for climate change challenges in their
media areas/regions until the Agency develops an
overall strategy.
3-1 18 Establish guidance to programs and regional offices
for regularly entering their climate change scientific
information in the Science Inventory.
3-2 18 Ensure that ORD continues to routinely update the
Science Inventory to include the latest information
from its laboratories and centers.
3-3 18 Establish a formal, transparent research
requirements determination process that includes
well-defined procedures for identifying a unified set
of priority climate change research needs.
3-4 18 Establish a formal mechanism to track regional
research needs from research project selection to
completion, and to requestor.
3-5 18 Establish a formal method for coordinating GCRP's
research work with regions and program offices,
communicating research results, and collecting
feedback on research products. The feedback
requested should include the accessibility,
usability, value, and awareness of updates to the
Science Inventory and the Environmental Science
Connector.
Deputy Administrator
Deputy Administrator
Assistant Administrator,
Office of Research and
Development
Assistant Administrator,
Office of Research and
Development
Assistant Administrator,
Office of Research and
Development
Assistant Administrator,
Office of Research and
Development
0 = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is undecided with resolution efforts in progress
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Appendix A
Agency Response and OIG Evaluation
This Appendix provides the Agency's January 8, 2009, response to our recommendations
followed by OIG evaluation of each response. We provide the Agency's October 21, 2008,
memorandum in Appendix B.
MEMORANDUM
SUBJECT: Final Response to Recommendations in the Office of the Inspector General's
Draft Evaluation Report on Climate Change, Assignment No. 2007-0731
FROM: Marcus Peacock
Deputy Administrator
TO: Wade T. Najjum
Assistant Inspector General for Program Evaluation
Thank you for providing the updates to your recommendations pursuant to staff
discussions at the November 25, 2008 exit conference. We concur with your recommendations
and have begun to take actions to implement them. Please see the Attachment for our revised
responses to your recommendations.
For comments on specific findings in your report, please refer back to my October
memorandum to Jeffrey Harris, OIG Director of Special Studies.
I look forward to reviewing your final report and working with you to enhance EPA's
climate change efforts.
Attachment
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Attachment: Response to OIG Recommendations
Introductory Note: As requested, we are providing our response in the Office of Inspector
General's desired "concurrence/non-concurrence" format in accordance with your memorandum
and the U.S. Environmental Protection Agency's Audit Management Process.9 It is important to
note that EPA is already implementing, or has begun to implement, appropriate actions
consistent with the intent of all of your recommendations. We propose "supplementary actions"
where we believe EPA can further enhance its work in response to OIG's findings.
Recommendation 2-1: "...that the Deputy Administrator...direct AAs and RAs on how to
plan for climate change challenges in media areas/regions until the Agency develops an
overall strategy."
» Concurrence: The Deputy Administrator has initiated a process contributing to an
Agency approach on climate change. The OIG report properly recognizes the importance
of cross-Agency coordination in the development of program policy and information
needs to address the challenge of climate change. Recognizing the importance of a more
comprehensive approach, the Deputy Administrator recently convened EPA's Deputy
Assistant Administrators and Deputy Regional Administrators to follow up on the key
coordination issues identified in the July 2008 Senior Leadership Council meeting.
DAAs and DRAs will develop an Agency approach to this important environmental
challenge. This process is in its initial stages and, as it moves forward, we would be
pleased to provide the OIG with an update on its progress.
OIG Response: Subsequent to our discussion draft, the Deputy Administrator
initiated a process to develop an Agency approach to climate change challenges. OIG
believes that the initial steps taken by the Deputy Administrator with the Deputy
Assistant Administrators and Deputy Regional Administrators are necessary for the
development of a comprehensive Agency strategy on climate change. The OIG
accepts development of an Agency approach by the Deputy Assistant Administrators
and Deputy Regional Administrators as meeting the intent of the recommendation.
This approach should also include milestones for each specified action.
Recommendation 3-1: "...that the Deputy Administrator ...establish guidance to programs
and regional offices for regularly entering their climate change scientific information in the
Science Inventory."
9 httpMntranet. epa.gov/rmpolicy/ads/manuals/2 750_2_t.pdf
"In responding to the draft report, the Action Official can concur with the findings or provide explanations for any
disagreements. The Action Official may comment on the accuracy of findings and conclusions, the appropriateness
of the recommendations, or offer alternative recommendations. Responding to the draft report also offers the
opportunity for the Action Official to provide new documentation or information to the auditors. Generally, the OIG
will include the Action Official's response to the draft report as an appendix to the final report." (8-1)
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» Concurrence: EPA agrees that the results of its scientific research must be readily
accessible. The Deputy Administrator will continue to issue guidance to program and
regional offices, which have the responsibility of entering and maintaining their own
scientific information in the Science Inventory.
OIG Response: The Agency concurred with Recommendation 3-1 and agrees to
issue guidance to program offices and regions, which have the responsibility of
entering and maintaining their own scientific information in the Science Inventory.
Similarly, ORD agreed to evaluate the effectiveness of its mechanisms and to ensure
that its labs and centers provide their most current information. EPA should provide
a Corrective Action Plan with completion dates and details of plans for updating the
Science Inventory, and maintaining the Environmental Science Connector.
Recommendation 3-2: ".. .that the AA/ORD ensures that ORD continue to routinely
update the Science Inventory to include the latest information from its laboratories and
centers."
» Concurrence: The Office of Research and Development provides the Science
Inventory and the Environmental Science Connector as Agency-wide depositories for
EPA's scientific information. ORD will continue to evaluate the effectiveness of these
mechanisms and will continue to ensure that its labs and centers provide their most
current information.
OIG Response: Same as for Recommendation 3-1.
Recommendation 3-3: "...that the AA/ORD establish...a formal, transparent process to
determine research requirements that includes well-defined procedures for identifying a
unified set of priority climate change research needs."
» Concurrence: ORD's Global Change Research Program has an effective process in
place to determine the highest-priority research requirements of EPA programs and
regions and of the Climate Change Science Program. GCRP's prioritization process
includes the Research Coordination Team, Regional Science Liaisons, Climate
Coordinators, weekly cross-Agency conference calls, and other formal and informal
mechanisms.
The GCRP Research Coordination Team consists of representatives from ORD, program
offices, and all regional offices. The RCT facilitates research planning and
communication and prioritizes both individual and collective research needs. RSLs are
regional employees who have a well-defined role to coordinate and communicate with
ORD. In addition to the RSLs, Climate Coordinators in select regions are actively
engaged in prioritizing research activities.
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When determining priorities, GCRP must consider the individual requests of programs
and regions, as well its interagency responsibilities under the Climate Change Science
Program. For example, in Fiscal Years 2007 and 2008, the highest-priority research
activity for ORD's GCRP was the production of two CCSP Synthesis and Assessment
Reports.
» Supplementary action planned: See the "supplementary action" under
Recommendation 3-4, which we believe will further formalize and communicate ORD's
current process.
OIG Response: The Agency concurred; however, we consider this item open,
pending review of the detail in the Corrective Action Plan with completion dates and
details of formal documentation of the selection process. We acknowledge that ORD
uses some informal processes regularly to involve regional offices in obtaining their
research needs. We also acknowledge that ORD has to balance the information needs
of regions and program offices with its inter-agency responsibilities. However, the
regions need to understand how and why certain topics are selected and others are not,
to improve their own planning. Therefore it is important that ORD document and
share its research prioritization process with EPA's internal users.
Recommendation 3-4: "...that the AA/ORD establish...a formal mechanism to track
Regional research needs from research project selection to completion, and to requestor."
» Concurrence: GCRP has mechanisms in place with programs and regions to track
research needs from selection to completion (see response to Recommendation 3-3). To
complement these mechanisms, GCRP maintains current information on its
Environmental Science Connector site and makes this resource available to the entire
Agency. GCRP will continue to focus its resources on the highest-priority research needs
in global change.
» Supplementary action planned: To supplement its ongoing efforts to help partners
in program and regional offices better understand ORD's mechanisms and criteria for
selecting research projects, ORD will provide additional information in a memo to
Deputy Assistant Administrators, Deputy Regional Administrators, Research
Coordination Teams, Regional Science Liaisons, and Climate Coordinators. This memo,
to be sent in December 2009, will formally document the selection process and explain
how the Science Connector tracks projects from selection to completion and
communication.
OIG Response: The Agency concurred. However, we consider this item open,
subject to our review of a Corrective Action Plan with completion dates and details of
the formal documentation of the tracking of projects from selection to completion and
communication, proposed as a supplementary action plan.
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Recommendation 3-5: "...that the AA/OKD establish...a formal method for coordinating
GCRP's research work with Regions and Program Offices, communicating research
results, and collecting feedback on research products. The feedback requested should
include the accessibility, usability, value, and awareness of updates to the Science Inventory
and Environmental Science Connector."
» Concurrence: ORD/GCRP already uses several mechanisms to coordinate,
communicate, and collect feedback. The Environmental Science Connector's "Global
Change Resource Center" and GCRP's new public website10 are two tools used by ORD
to coordinate and communicate its global change research. In addition, GCRP's National
Program Director uses weekly Global Conference Calls to obtain feedback from all
program and regional offices.
» Supplementary action planned: To further formalize its ongoing efforts,
ORD/GCRP will develop an internal fact sheet summarizing the mechanisms that ORD
has already put in place to communicate and coordinate GCRP's work with the programs
and regions. ORD will share this factsheet with stakeholders across the Agency to
improve their awareness of GCRP's resources, and GCRP will update the factsheet as
new mechanisms are developed.
Additionally, ORD has begun to survey EPA stakeholders about the timeliness and
usefulness of its products in order to enhance research planning. GCRP plans to issue
such a survey prior to its next Board of Scientific Counselors review in 2010. The survey
will include a request for feedback on the accessibility, usability, value, and awareness of
updates to the Science Inventory and Environmental Science Connector.
OIG Response: The Agency concurred; however, we consider this recommendation
as an open item, subject to a Corrective Action Plan. We recognize that ORD uses
tools and informal processes to communicate and coordinate its global change
research. However, according to survey responses from both ORD and regional staff,
these are informal practices, and they are ad hoc and inconsistent. The Corrective
Action Plan should include the date and details about the fact sheet ORD plans to send
to EPA's offices, as well as how frequently it plans to update the fact sheets. It should
also include the dates for the planned survey, and the type of staff ORD plans to
survey.
' http://www. epa.gov/ord/npd/globalresearch-intro. htm
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Appendix B
Agency Preliminary Comments and OIG Evaluation
This appendix provides the October 21, 2008, memorandum comments mentioned in the EPA
Deputy Administrator's final response in Appendix A. The October comments have been
superseded by the Agency's January 8, 2009, memorandum and attachment. The following
includes OIG evaluation and the Agency comments.
MEMORANDUM
SUBJECT: OIG Evaluation Report on EPA's Climate Change Research Activities
FROM: Marcus Peacock
Deputy Administrator
TO: Jeffrey Harris
Director, Special Studies, Office of Program Evaluation
Thank you for your draft report on how well the U.S. Environmental Protection Agency's
policies, procedures, and plans help ensure that EPA's Global Change Research Program (GCRP
or Program) fulfills its role in meeting environmental decision-makers' climate change
information needs. The insights and recommendations you provide in the report will help the
Agency continue to improve its efforts to address the challenges posed by climate change. I am
pleased to say that, with your help, we are already implementing a number of your
recommendations.
As an overall point, I think the "At-a-Glance" section and aspects of the report could
more accurately represent the breadth, scope, and effectiveness of EPA's Global Change
Research Program in the Office of Research and Development (ORD). I have provided
clarifications in the discussion below and in the Attachment, and I ask that you revise the "At-a-
Glance" section and the report accordingly.
You correctly note in the report that ORD has responsibility for managing EPA's global
climate change research function through its Global Change Research Program. GCRP is
subjected to regular, external peer reviews by the independent Board of Scientific Counselors
(BOSC). As you acknowledge in your report, the past two BOSC reviews of the GCRP (in 2006
and 2008) affirm that the Program is doing the "right work" and is doing it "well." In addition,
the BOSC made recommendations for improvements in the Program, which have already been
implemented. Your review, combined with the BOSC reviews, will help further strengthen the
effectiveness of the GCRP.
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It is important to emphasize in the report that ORD is responsible for only a subset of the
climate change information developed and used by the Agency. Other EPA program offices
conduct work related to GCRP activities that are coordinated with ORD. For example, the
Office of Water's (OW) new Climate Change Strategy formally integrates ORD and OW
activities to address the implications of climate change for the Agency's statutory, regulatory,
and programmatic requirements under the Clean Water Act and Safe Drinking Water Act.
OIG Response: We reported that ORD is not the only responsible program office regarding
climate change. For example, in the report Introduction we state, "The Office of Air and
Radiation (OAR) has activities related to mitigating greenhouse gases." We also reported that
Office of Water was developing a strategy to address the impact of climate change on its
programs; however, it had not been finalized at the time our field work was completed.
Recognizing the importance of a more comprehensive approach to climate change, I
recently convened EPA's Deputy Assistant Administrators (DAAs) and Deputy Regional
Administrators (DRAs) to follow up on key coordination issues identified at the July 2008 Senior
Leadership Council meeting. The DAAs and DRAs will further develop an Agency-wide
approach to climate change. Ultimately, I anticipate that this effort will lead to the development
of an overall Agency strategy.
An Agency-wide strategy needs to consider EPA's role as part of the broader federal
structure. The respective roles and responsibilities of all federal agencies are clearly defined and
distinguished under the U.S. Climate Change Science Program (CCSP) and U.S. Climate Change
Technology Program (CCTP). These two programs coordinate and integrate climate change
science and technology activities across the entire Federal Government, ensuring that resources
are used efficiently and duplication of effort is avoided. Your report recognizes the respective
roles of the CCSP and CCTP, but it should also acknowledge the importance of aligning an
Agency-wide strategy with these interagency programs.
Considering the climate change information generated by other federal agencies as well
as other EPA program offices, a number of the Office of Inspector General's (OIG) findings
extend beyond the purview of ORD/GCRP. For example, OIG's chart on page 13 compares
regional information needs with GCRP plans. However, GCRP does not have lead responsibility
for a number of the areas listed (e.g. renewable energy, sequestration) and thus others are in a
better position to distribute this information to the regions.
Similarly, OIG's recommendation that ORD develop a central depository for climate
information is beyond the purview of ORD/GCRP. In many cases, EPA program offices and
regions need to look beyond GCRP to other parts of EPA and to interagency repositories to
access some of the information they seek.
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OIG Response: Recommendations 3-1 and 3-2 are directed at making EPA's scientific
information available to EPA's internal users; it does not require collecting information
developed by other federal agencies. During our field work, we found that EPA's Science
Inventory was not current. Internal sharing and maintaining EPA's research information is
necessary in order to avoid duplication of research effort and maximizing available resources.
The Agency states that OAR is in better position to distribute information to the regions on
renewables and sequestration. We note that ORD has included renewable energy and
sequestration as research projects in its strategic plan. ORD and Office of Water were able to
formally integrate activities addressing the implications of climate change. Similarly, ORD
and OAR should coordinate their research and activities related to renewables and
sequestration.
The report should acknowledge that any EPA policies and procedures for meeting the Agency's
information needs must ensure that available resources are directed to their highest-valued uses.
Therefore, ORD/GCRP must consider the requests it receives from EPA's program and regional
offices along with those of multiple other partners (e.g. other agencies), and GCRP must allocate
its resources to meet the highest-priority needs. For example, in Fiscal Years 2007 and 2008, the
highest-priority research activity for GCRP was the production of two CCSP Synthesis and
Assessment Reports.
In contrast with the findings in your report, we believe ORD does have formal
mechanisms in place to prioritize its research activities (see Attachment for additional
information). New processes are already in place for making these mechanisms more transparent
to regional and program offices. At the same time, program and regional offices have the
responsibility to prioritize their research needs and communicate them to ORD. For example,
the regional climate change information needs presented in Table 2.1 of your report are not
prioritized, nor, as mentioned above, does the GCRP have the lead responsibility for a number of
these areas. The Global Change Research Coordination Team provides the venue for such
prioritization, consistent with an appreciation of the GCRP's role in the context of the larger
federal effort.
OIG Response: We acknowledge that ORD has to balance the information needs of regions
and program offices with its inter-agency responsibilities. However, ORD does not have a
"formal" mechanism for research prioritization that assures available resources are directed to
their highest-valued uses. A "formal" mechanism or process would be documented and
shared with the regions. While we noted that ORD uses several informal mechanisms to
collect research needs from regions, participation in calls and workshops is not required by
EPA policy, resulting in inconsistent participation. A formal EPA policy is needed.
According to the Agency response to Recommendation 3-4, ORD plans to send such a
memorandum in December 2009.
It is important also to note that EPA will need a strong research and analytic capability in
the economics, as well as the science, of climate change. Going forward, EPA will need to
analyze the economic effects of any regulations promulgated under the Clean Air Act; to provide
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technical expertise to the Congress as it develops and evaluates various legislative proposals; and
to help inform negotiations of any international accord to reduce greenhouse gas emissions
worldwide. All of these efforts will demand unprecedented economic modeling and analytic
efforts from the Agency. In the regulatory arena, most, if not all of the anticipated climate
change regulations will be economically significant, and therefore will require benefit-cost
analysis per Executive Order 12866. More importantly, analysis will be needed to provide
policy makers with key information about the most cost-effective and fair ways to reduce
greenhouse gases. This is equally true in the international arena: EPA will need to provide the
United States delegation and the world community with economic modeling that credibly
demonstrates the likely impacts of climate change as well as the economic impacts of taking
action under various approaches. Efforts to build these needed economic research capabilities
are already underway, primarily in the Office of Air and Radiation and the Office of Policy,
Economics, and Innovation.
Most importantly, we agree with the spirit of your recommendations and have begun to
implement appropriate actions consistent with their intent. Please see the Attachment for our
responses to each of your specific recommendations.
I look forward to working with you to ensure that the Agency has the necessary policies,
procedures, and plans in place so that the GCRP fulfills its role in the Agency's and Federal
Government's overall efforts to address global climate change. Thanks again for your help on
this effort.
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Appendix C
Distribution
Office of the Administrator
Deputy Administrator
Acting Assistant Administrator for Research and Development
Acting Principal Deputy Assistant Administrator for Air and Radiation
Office of General Counsel
Agency Follow-up Official (the CFO)
Agency Follow-up Coordinator
Acting Associate Administrator for Congressional and Intergovernmental Relations
Acting Associate Administrator for Public Affairs
Audit Follow-up Coordinator, Office of Research and Development
Deputy Inspector General
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