National Advisory Council for
Environmental Policy and Technology
July 14, 2006

Administrator Stephen L. Johnson
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC  20460

Submission ofNACEPT Comments on EPA's Draft 2006-2011 Strategic Plan

Dear Administrator Johnson:

On behalf of the National Advisory Council for Environmental Policy and Technology,
we are pleased to forward to you our comments on EPA's Draft 2006-2011 Strategic
Plan. We hope these comments are helpful to you and EPA as you chart the best course
for EPA to  achieve its mission.

We commend EPA for undertaking a formal strategic planning process that provides
goals and objectives to assess EPA's many activities and initiatives, and that so openly
includes public participation.  With the Agency's continued improvements to the
Strategic Plan, we hope it can become  a worthwhile and critical decision making tool for
the Agency, Congress, and the public by providing complete and meaningful information
about what the Agency intends to accomplish and how it will do so.

Executive Summary

We ask that you consider the following observations, which are more fully discussed in
our attached general and specific comments:

Appropriateness and Feasibility:

Today's world is full of change - changes in direction and velocity. Today, the Agency,
governments, businesses, and individuals are aware of this change and of the potential
consequences - positive and negative.  Issues like nanotechnology and new materials,
population growth and shifts,  fuel use, high tech, and climate change are impacting our
lives and our ecosystems.  The strategies the Agency offers in its Strategic Plan suggest
but do not fully reflect this awareness or chart the needed short- and long-term strategy
for tackling such far-ranging,  future-impacting issues.

.   We commend the Agency for completing most of the objectives, sub-objectives, and
   targets.  However, many strategic targets still include little information about baseline

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   conditions, past progress and future pressures.  For example, many are still stated as
   percentage reductions but omit information about the pounds of pollution reduced or
   numbers of people served.   And  many  are still not supported with any baseline,
   leaving the reader with no ability to assess the target's appropriateness or feasibility.

.  Most of the  draft plan includes calls for modest, incremental  gains in established
   programs.  Those gains seem based on what planners consider the Agency's capacity,
   rather than the scope or complexity of the environmental challenges facing us.  And
   although some targets have been raised, some targets have been scaled back  from
   those the Agency issued in its 2003-2008 Strategic Plan.

.  Does the  removal  from  the plan of  most  strategic targets  for  research  and
   development mean that research now has a lower priority than before?

.  The  plan  also  should include  critical  discussions  of long-range environmental
   challenges and how the Agency will  work with others to develop systems-based
   responses to meet those challenges.

Connectivity:

Despite the Agency's siloed legislative foundation and current operating structure, many
of the environmental challenges facing the Agency may require a much broader systems
approach. Air emissions impact water quality, water discharges impact land  quality, and
so on.   EPA will be able to successfully address these issues in its next 35 years by
connecting  its  resources  and  creativity   across  environmental   issues,  connecting
information with communities and across ecosystems,  and connecting formerly siloed
people, processes, and programs.

.  EPA should better cross-reference the plan's goals, objectives, and targets in the
   different goal sections and note their connections. This could help reduce the
   deleterious impact of the Agency's  many silos and promote more effective and
   efficient solutions (and resource allocation).

.  This document should be linked, through in-text references and electronic
   connections, to EPA's other planning and performance-reporting  documents.  Linking
   this document to EPA's budget, for example, would be a helpful way to communicate
   the Agency's priorities. Also connecting smart growth, watershed planning, flood
   control, post disaster planning, air quality, obesity, asthma into one systems approach
   would show linkages important to view and approach simultaneously.

   And ideally, EPA's strategic plan should be linked to other critical environmental-
   related work led by other federal agencies.

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Partners:

EPA will continue to be the world's leading environmental agency.  Its success to date
has depended on EPA establishing strong standards and working with others so states,
communities, and businesses could achieve those standards. As the environmental issues
become more complex and diverse, EPA's future stewardship success will depend even
more on its ability to connect with many partners.

.   This document should describe much more fully the Agency's relationship with its
    partners and the different players' roles in environmental protection.

    The plan should describe the statutory and practical relationships with other federal
    agencies, tribal governments, and state and local governments, and should identify the
    specific steps EPA  is taking to build the capacity of these partners to accomplish its
    goals, objectives, and targets.

.   While  the plan  does discuss environmental stewardship,  the important role  of
    individuals is not explored.

Formatting

In preparing  our comments on  the  draft Strategic Plan, our  starting point was the
Agency's draft 2006-2011 Strategic Plan Architecture issued in February 2006. The first
document is  our general  comments  - themes and  observations  we noted across the
Strategic Plan's  different sections. The second set of documents contains our specific
comments on each section of the Strategic Plan.  Here we have noted each case where
EPA had made additions, deletions, or changes to the text (comparing the draft Strategic
Plan Architecture to the draft Strategic Plan).  We have embedded our comments in the
annotated document. For the Goal 1 through Goal 5 sections,  our comments adhere to
the following editing conventions:

    •  Text deletions from the Strategic Plan Architecture (SA) objectives and sub-
       objectives are identified by strike-out.
    •  Text additions to the SA objectives and sub-objectives are identified by underline.
    •  Text additions outside the SA objectives and sub-objectives (i.e. Means and
       Strategies sections) are "as is" in the draft document.
    •  NACEPT comments on the original Strategic Plan Architecture are in blue and
       are  captioned "NACEPT SA Comments"
    •  NACEPT comments on the Strategic Plan text are in purple and are captioned
       "NACEPT SP Comments."

In preparing our  comments in this way, our goal was to  show how EPA's strategic
planning process has evolved through the Strategic Plan Architecture and full Strategic
Plan phases, as well as the Agency's responsiveness to our comments. In many cases,
our comments on the draft Strategic Plan reiterate our earlier comments on the Strategic

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Plan Architecture and seek a natural progression toward research and planning that will
help create models for sustainable development, creating a higher quality of life for all.

On behalf of the Council, we appreciate the opportunity to offer these comments.
Sincerely,
John L. Howard, Jr.                      Jennifer Nash
NACEPT Chair                          Working Group Chair
Attachment
cc:     Marcus Peacock, Deputy Administrator
       Charles Ingebretson, Chief of Staff
       Ray Spears, Deputy Chief of Staff
       Lyons Gray, Chief Financial Officer
       Kathy Sedlak O'Brien, Director, Office of Planning, Analysis, and
        Accountability/OCFO
       Rafael DeLeon, Director, Office of Cooperative Environmental
        Management
       Sonia Altieri, NACEPT Designated Federal Officer

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         NATIONAL ADVISORY COUNCIL
FOR ENVIRONMENTAL POLICY AND TECHNOLOGY
  Comments on U.S. Environmental Protection Agency's
            Draft 2006-2011 Strategic Plan
                  July 14, 2006

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                     NACEPT GENERAL COMMENTS
              ON EPA's DRAFT 2006-2011 STRATEGIC PLAN
Comment on the Strategic Architecture (SA):
In its comments on EPA's 2003-2008 Strategic Plan, NACEPT encouraged EPA
to link the Strategic Plan with the Report on the Environment, in both formatting
and timing, to facilitate the establishment of goals and objectives, and to provide
a progress report on the Agency's accomplishments.  In comments on the draft
Strategic Architecture for the Agency's 2006-2010 Strategic Plan, we encouraged
EPA to also enhance the linkages between those two documents, its budget, and
its annual Performance and Accountability Report.  These four documents should
be structured  so that each serves a specific function, yet complements the other
three—the  Strategic  Plan  establishes  goals  and objectives,  and  means  and
strategies for achieving them (inputs), the budget establishes fiscal responsibility,
the annual Performance and Accountability Report details the Agency's activities
and progress towards the stated goals and objectives (outputs and outcomes),
and the Report on the Environment discusses the effects of the Agency's actions
on the environment (impacts).   As these documents are complementary, they
should be consistently organized in a  manner that allows the  reader  to easily
follow an issue  or topic across  all four.  To enhance clarity for  the reader, EPA
should also include a discussion of the relationships between these documents in
the introduction  to each.

Comment on the Strategic Plan  (SP):
Now, as we review the Agency's Strategic Plan 2006-2011, the need to integrate
this document with  the  Agency's other planning and  performance reports  is
strikingly apparent.  This Strategic Plan is not a stand-alone document.   As
written,  many targets are  nearly impossible  to understand because  they  (1)
include little information about baseline conditions, (2) are stated as percentage
reductions but fail to state what those percentages represent in  terms of pounds
of pollution reduced or numbers of people served, and (3) include nothing about
past progress.

An  example  of a strategic target that includes the  elements  we  consider
necessary appears in Goal 3, Sub-objective 3.1.2, "Manage Hazardous Wastes
and Petroleum Products Properly:"

   "By 2011, prevent releases at 500 RCRA hazardous waste management
   facilities by implementing initial approved controls or updated controls. (In
   FY2006, EPA estimates that 820 facilities require these controls; the baseline
   is zero.  The universe of facilities will be reassessed by FY 2009.)

   This target is a particularly helpful. We know the universe of facilities requiring
   controls. The baseline information is meaningful, and there is a promise of a

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   review soon.  In addition, the target appears to be aggressive In light of the
   total number of facilities in the group.

Many targets, however, are not comprehensible.  A few examples, taken from the
draft plan, illustrate our point.

.   Goal 1, Sub-objective 1.1.2 Air Toxics
   "By 2010, continue to reduce toxicity-weighted (for cancer risk) emissions of
   air toxics to a cumulative reduction of 19 percent from the 1993 baseline."

   It is impossible to assess this target without knowing how much progress has
   been achieved in the past 13 years.

.   Goal 2, Sub-objective 2.1.1 Water Safe to Drink
   "By 2011, 86 percent of the  population in Indian country served by community
   water systems will receive  drinking  water that meets all applicable health-
   based drinking water standards  throughout  the  year (2005  baseline:  86
   percent)."

   Both the 2005 baseline and the 2011  target are 86 percent. Is it really the
   Agency's intended goal to make no progress in this area?

.   Goal  3,  Sub-objective 3.1.2 Manage  Hazardous Wastes and Petroleum
   Products Properly
   "Each year through 2011, minimize the number of confirmed releases at LIST
   facilities  to 10,000 or fewer from a universe of  approximately  650,000 LIST
   tanks."

   Is "10,000 or fewer" an aggressive goal or simply a continuation of the current
   situation?  Without information about the  number of releases in past years,
   one does not know.

To address the information deficiencies of these and many other targets included
in the plan,  NACEPT reiterates its recommendation that  EPA  link  its Strategic
Plan—through direct references in the text and electronic connections—with the
Agency's other planning and performance documents. For example, the Agency
should link its discussion about targets for reducing air toxics  to (1) the section of
the Agency's budget that details funding for the Agency's air toxic programs; (2)
the  section  in  EPA's  FY 2005 Performance and Accountability  Report that
discusses progress toward meeting air toxic objectives, (3) the discussion of air
toxics in the Agency's Report on the Environment, and (4) the parts of the 2003-
2008  Strategic Plan that address air toxics.  Without ready  access  to  such
information,  the targets appear to be pulled out of thin air and the lay reader has
no basis upon which to assess either their feasibility or their appropriateness.

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Comment on the SA:
The Strategic Plan Architecture is the "skeleton" for EPA's Strategic Plan and is
structured around five Goals (Clean Air and Global Climate Change, Clean and
Safe  Water,  Land  Preservation and  Restoration, Healthy Communities  and
Ecosystems,  and  Compliance and Environmental Stewardship).   There are
substantial linkages across Goals 1, 2 and 3, and more importantly, the means of
achieving those objectives  are contained in Goals 4 and 5.   In a  number of
instances, objectives and sub-objectives under Goals 4 and 5 address issues
already addressed  under Goals 1, 2  and 3,  but with substantively  different
quantitative targets. We recognize  that this is an artifact of the  process through
which the Strategic Plan Architecture  is assembled, in  which  individual offices
across the Agency submit their own objectives  independent of other offices and
EPA's partners.   However,  this illustrates the  need for thoroughly  coordinated
objectives, priority-setting, and activities across those offices and EPA's partners.

Comment on the SP:
We understand that for a variety reasons it may be necessary to maintain the
plan's current five-goal structure.  EPA could do a better job, however, of cross-
referencing these  goals in  the plan  and  noting their  connections.   How,  for
example, does the objective of preventing pollution discussed  in Goal 5 impact
the goal of reducing waste generation discussed  in  Goal 3?   How does the
objective of providing safe drinking water discussed in Goal 2 impact the drinking
water problems in the Mexican border area discussed in Goal 4? As presented,
each goal section seems to represent the  activities of a separate organization.
We urge the Agency to think critically about how it might work to protect human
health and the  environment systematically.   The proposed plan seems for the
most part to lack a systems approach.

Comment on the SA:
NACEPT again  recommends that EPA incorporate a section in the Strategic Plan
on  the  roles  of  other federal  agencies that  are   crucial  to  successful
implementation  of the  Goals.  These federal partners are key participants in the
evaluation and management of the nation's natural and environmental resources,
including conformance with  the National Environmental  Policy Act. EPA should
also work closely with its federal partners to identify their most environmentally
significant initiatives, with a goal of leveraging cross-Agency activities for the
greatest public benefit (i.e., energy-environment  nexus).

Comment on the SP:
In addition to describing the roles  of federal partners, EPA should address its
relationship with state  and local partners.  In many instances EPA plays a much
more  limited role than what appears in the  draft plan and the main drivers are
state,  local, and tribal governments.   For example, under Sub-objective  3.1.1,
Reduce Waste Generation and Increase Recycling, EPA  has a very limited role

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in  increasing recycling  of municipal waste  from  30.6 percent to 40 percent.
Recycling of municipal waste is handled primarily at the state and local level.
The Agency should more clearly identify its role.  Is its role providing grants and
loans?  Is it working in partnership with state, local, and tribal  governments?
How much of the  increased recycling is due to activities at EPA versus those
undertaken by state, local, and tribal governments?  This is but one example of
an issue NACEPT observes throughout the draft plan.  This document  should
describe more  fully  the Agency's expectations  of  its partners  and how it is
building the capacity of the  broader network it needs to accomplish its goals,
objectives, and targets.

Comment on the SA:
Our  review of  the 2003-2008  Strategic  Plan  revealed that  the means and
strategies outlined by the Agency in  pursuit of the Goals often lacked detail
regarding the roles and responsibilities  of EPA's partners in implementing the
Strategic Plan, as well as the burdens placed on the regulated community.  As
EPA moves  forward  in developing the Strategic  Plan,  its  usefulness  will be
dependent on a number of critical elements for each objective and sub-objective.
From a planning perspective, the  following  elements should be discussed for
each objective.

•  In order to provide a sound basis upon which the subsequent Strategic Plan
   can be based, the Strategic Plan Architecture should include:
      o   Prior  performance relative to  the sub-objective or strategic target (if
          addressed in previous Strategic Plans),
      o   Roles and responsibilities of EPA, its partners and the target audience
         for implementing the objective or  target,
      o  An assessment of the capacities and resources of EPA,  its partners
          and the  target  audience  to  implement the  strategy,  including a
          discussion of capacity gaps and resources needs of all parties,
      o  A strategy to effectively address identified gaps and needs, and
      o   Milestones for measuring progress.

•  Where  measurable  sub-objectives  (targets)  are  indicated,  sub-objectives
   should be expressed in a consistent manner throughout the  Strategic Goal
   Architecture and include the following elements:
      o  The regulatory authority for the objective, sub-objective or target,
      o  Timeframe for achieving the sub-objective,
      o   Performance measure(s) or indicator(s),
      o   Baseline from which progress will be measured,
      o  Target audience for EPA action (e.g., regulated sector, general public)
      o   EPA  partners  (e.g.,   tribes,  states,  local governments) who  will
          participate in the implementation strategy, and
      o   Principal  tools  (e.g.,   grants,  compliance  assistance,  incentives,
          enforcement) that will be employed in the implementation strategy.

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Comment on the SP:
We reiterate the importance of providing complete and meaningful information
about what the Agency intends to accomplish and how it will meet its goals.  To
make this  Strategic Plan  valuable to  EPA  and  reviewers, the Means  and
Strategies should include an assessment of the relative significance of each of
the activities in attaining the objectives and sub-objectives; the current  resource
commitments and capacities of the Agency, states, tribes, local governments, the
regulated community, and  other  stakeholders; the anticipated future  resource
needs and  capacities necessary to attain specific sub-objectives and  strategic
targets;  and the actual commitments of the agencies and other parties.   This
additional information would allow EPA to objectively assess where the most
significant opportunities for enhancing its efforts lie and how best to direct and
prioritize its investments and those of its partners.

Comment on the SA:
A  substantial  number of objectives and sub-objectives  in the Strategic  Plan
Architecture were incomplete, and were therefore not ripe for comment.  Many of
them  included references  to  future consultations  with  stakeholders for  the
development  of  appropriate  metrics.    While  we  recognize  that EPA  has
scheduled release of the full Strategic Plan in May 2006, we recommend that the
Agency  complete as many stakeholder consultations as possible prior  to the
Strategic Plan release, and to  incorporate the outcomes of those consultations
into the forthcoming Strategic Plan.

Comment on the SP:
We commend the Agency for completing  most of the objectives, sub-objectives,
and targets  in  the draft plan. Many, however, are still quite puzzling. Consider,
for example, one of the targets included in Sub-objective 5.2.1, Prevent  Pollution
and  Promote  Environmental Stewardship by Business,  Government,  and  the
Public:  "By 2011, reduce water use by 52 billion gallons  cumulatively  from the
2000  baseline  amount  of 220  million  pounds."    220  million  pounds  is
approximately 26.4 million gallons. It is unclear what this quantity represents as
a baseline.

Comment on the SA:
Recognizing that the Agency  has many responsibilities,  there  needs to be a
process to  incorporate futures into its strategic planning  effort, to understand,
assess  and access emerging technologies that can  facilitate the  Agency's
mission  and avoid environmental surprises.  There are futures activities occurring
throughout   the  Agency, such as nanotechnology  and  water infrastructure
sustainability,  but  these  do not  systematically appear in the Strategic  plan
Architecture.

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Comment on the SP:
What environmental  problems will be most  critical over  the  next several
decades? What policy tools will be most effective in addressing those problems?
What information and analytical  capabilities  will be  required?  What types of
partnerships will EPA need to meet future challenges? These questions were on
our minds when we reviewed EPA's draft Strategic Plan  2006-2011.  The draft
plan calls for modest, incremental gains in established activities.  Those gains
seem based on what planners consider the Agency's capacity rather than their
assessment of the magnitude of the environmental challenges before  us.

We have compared the objectives, sub-objectives, and strategic targets  in the
proposed 2006-2011  Strategic  Plan with those in the 2003-2008 Strategic Plan.
In many cases, the 2006-2011  Plan represents a step forward.  The Agency has
added some  important  new initiatives and  in some cases  targets are more
ambitious than in the past. In other cases,  however, targets represent a step
backwards  from those the Agency adopted in its 2003-2008 Strategic Plan.
Targets for greenhouse gas intensity (1.5.1,  1.5.2) appear to  be  less ambitious
than what EPA adopted three years ago, for example.

If one can  glean any assumed vision  of the future from this document,  it  is  a
future that  looks very much like today.  Largely missing is a discussion of how
world population growth,  sprawl and levels of  consumption, rising demand for
energy,  water and  other resources,  emerging science and  technology,  and
political  and social evolution might affect the environment—  and the  Agency's
programs.  We recommend  that  EPA revisit NACEPT's  2002  Report,  "The
Environmental Future," for a glimpse  of future issues that have  already been
identified as having significant impact  on the Agency's future activities.  More
importantly, we cannot stress strongly enough the importance of futures research
in fully informing EPA's  Strategic Plan. We note that nearly all of the strategic
targets in the  areas of research and development have been eliminated from the
draft Strategic Plan. Are we to assume that research is of lower  priority than in
the past?  By removing  these research targets from the draft document, the
Agency  has taken away the public's ability to  comment on their appropriateness.
While the plan does  include discussion of environmental stewardship, we note
that there is little mention of the role of  individuals.  EPA appears to assume that
regulated entities will contribute  the most to stewardship.   We  question  that
assumption.

Comment on the SA:
Neither  the  Strategic  Plan Architecture  nor the  Strategic Plan  discusses
prioritization of the Agency's various objectives and  sub-objectives.  While we
appreciate  the difficulty of such an endeavor, in the face of  finite funding  and
resources,  it  would be worthwhile  for  EPA  to assess its objectives  and sub-
objectives,  and prioritize its activities  by their greatest value to  the  Agency's
mission  and to the public.

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Comment on the SP:
Linking this document to the Agency's budget, through in-text references and
electronic connections, would be a helpful way to communicate priorities.

Comment on the SA:
Finally,  as with  the  2003-2008  Strategic  Plan,  the  current  Strategic Plan
Architecture reads as if it was prepared by numerous authors.  EPA should
assign  responsibility  for  compiling  and  editing  the draft  Strategic  Plan
Architecture and the Strategic Plan to one office, which could weave all of the
disparate pieces into one cohesive and logically organized document.

Comment on the SP:
We reiterate  the importance  of providing  greater  coherence and logic to the
document.

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NACEPT Specific Comments on EPA's Draft 2006-2011 Strategic Plan


   GOAL 1 - CLEAN AIR AND GLOBAL CLIMATE CHANGE

Protect and improve the air so it is healthy to breathe and risks to human health and the
environment are reduced. Reduce greenhouse gas intensity by enhancing partnerships
with businesses and other sectors.

NACEPT SP Comment
The EPA greenhouse gas emission goal, means, and strategies  could benefit from some background
explanation for how they were developed and how the chosen emission reduction target relates to the
aspirational intensity reduction goal.

   Air quality in the  United States has steadily improved, according to EPA's annual
summary of  air quality trends  since the  1970s.1 This trend toward cleaner air has
occurred even  as our  economy has increased  by 195  percent  in gross  domestic
product, miles traveled by cars and trucks  have increased by 178 percent, and energy
consumption has  increased by 48 percent  (Figure  1).  EPA continues to  look for
progressive solutions to remaining indoor and outdoor air pollution problems, which can
cause breathing difficulties, long-term damage to respiratory and reproductive systems,
cancer, and premature death.

   Air pollution also can affect the environment by reducing visibility; damaging crops,
forests, and buildings; acidifying lakes and  streams; and stimulating the growth of algae
in  estuaries and the build-up, or bioaccumulation,  of toxics  in fish. Bioaccumulation
poses particular risks to Native Americans and others  who subsist on plants, fish, and
game. Certain chemicals emitted into the air diminish the protective ozone  layer in the
upper atmosphere, resulting in overexposure to ultraviolet radiation and increased rates
of skin cancer,  cataracts, and other health and  ecological effects. Rapid development
and urbanization in other countries is creating air pollution that threatens not only those
countries but also the United States, since air pollution can travel great distances and
across international boundaries.  EPA is working with key developing countries to reduce
air pollution, with the goals of reducing the impact of transboundary air pollution on the
United States, improving health in developing countries and in the  United States, and
reducing greenhouse gas emissions.

   EPA is addressing this broad range of ambient air problems strategically by applying
a variety of approaches and appropriate tools. We have found that problems with broad
national  or  global impact—emissions from  power  plants and other large  sources,
pollution  from motor vehicles and fuels, and  stratospheric ozone  depletion—are best
handled  primarily  at the  federal level.  A national  approach allows for the  use  of
traditional regulatory tools when  appropriate, and  enables us to implement innovative,
market-based techniques  such  as emissions trading, banking, averaging, and other
national programs cost-effectively.

   States, tribes, and local agencies can best address the regional  and  local  ambient
air problems that remain after federal measures have been  fully applied.  EPA works
closely with public- and private-sector partners and stakeholders to develop the tools—
such  as monitoring, modeling, and emission inventories—that allow states, tribes, and
Goal One - Public Review Draft

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NACEPT Specific Comments on EPA's Draft 2006-2011 Strategic Plan


localities to address  these more localized  problems.  Many of these tools employ
innovative techniques, such as partnership  programs for retrofitting  diesel engines or
community-based approaches to toxics, which are well-suited to the local nature of
these problems.

   The importance of the indoor environment to human health has been highlighted in
numerous   environmental  risk   reports,   including  the   1997   report   of   the
Presidential/Congressional Commission on  Risk Assessment and Risk Management.
Addressing indoor air quality is uniquely challenging because regulatory solutions are
not  a  viable  option—especially  in  private  residences.  Instead,  EPA  relies on
partnership-based information  and outreach programs, which encourage and promote
voluntary action in homes, schools,  and commercial  buildings. These programs  have
been highly effective  in  achieving  an array of  positive  health  outcomes including:
reduced  lung   cancer  deaths  from  radon;   reduced  emergency  room  visits,
hospitalizations and other adverse health outcomes in people with asthma from reduced
exposure to asthma triggers; and reduced childhood asthma, respiratory ailments, ear
infections from exposure to environmental tobacco smoke.

   Ongoing research continues to identify new air pollution issues, in  areas from indoor
air to radiation.  EPA will work with our local,  state, tribal, and international partners and
stakeholders to achieve results through a suite of innovative approaches and programs
that encourage  cost-effective technologies and practices.

OBJECTIVE 1.1  -  HEALTHIER OUTDOOR AIR.  Through  2011, working  with
partners, protect human  health and the environment by attaining  and maintaining
health-based air quality standards and reducing the risk from toxic air pollutants.

NACEPT SA Comments
Sub-objective  1.1.1 references working with partners.  It is important that roles and responsibilities be
identified, and resources  and capabilities of partners be assessed, to ensure that the  objectives can
reasonably be achieved. This issue applies wherever partners" activities are relied upon to achieve  goals.
objectives and targets.

   Sub-objective 1.1.1.  Ozone and PM2s By 2015, working  with partners, improve air
   quality for ozone and PM2.s  as follows:

       Strategic Targets:

         •  By 2015, reduce  the population-weighted ambient concentration of ozone
            in all monitored counties by 14 percent from the 2003 baseline.

         •  By 2015, reduce  the population-weighted ambient concentration of PM2.s
            in all monitored counties by six percent from the 2003 baseline.

       NACEPT SA Comments
       Strategic targets for ozone and PM2.5 reference percent reductions of 14% and 6% respectively
       from 2003 baselines by 2015 in monitored counties. Does the monitoring network (counties)
Goal One - Public Review Draft

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NACEPT Specific Comments on EPA's Draft 2006-2011 Strategic Plan
       sufficiently cover all  areas where ozone  and PM2.5 have potential impacts?  Are there any
       objectives to identify and add impacted areas to the network? Are goals of approximately 1% and
       '/2% per year ambitious? Previous (2003) Strategic Plan addressed these contaminants in terms of
       population in unhealthy areas whose air had improved to healthy. New targets do not distinguish
       between further progress in already healthy areas vs. needed progress in unhealthy areas.

       Targets need to be consistent with regulations.  The Clean Air Act requires ozone & PM2.5
       attainment, not continual improvement in all monitored counties, as the first two targets in 1.1.1
       propose.

       NACEPT SP Comments
       The NACEPT comments on the Strategic Plan Architecture continue to apply, namely, that it is
       not clear why an emission reduction target is being set for all monitored counties rather than for
       nonattainment areas. If the target relates to visibility and/or eco-systems as well as public health.
       the target needs to so state.

       * — By  2011, improve  air quality across states covered by Clean Air Interstate
          Rulo (CAIR) to lovols whoro 92 of tho  108  areas that  did  not moot tho
          standards for 8-hour ozone  (as  of April 2005) achieve  these health-based
          national standards.

       - — By 2011, improve air quality across states covered by CAIR to levels where
          17 of the  36 areas that did not meet the standards for PM   (as of April  2005)

          achieve these health  based national standards.

       NACEPT SA Comments
       CAIR target for ozone is 85% compliance by 201 1. while CAIR target for  PM2.5 is 47%. Need
       to explain rationale for widely divergent targets.

       NACEPT SP Comments
       It is not clear why the stationary source reduction goals related to implementation of CAIR have
       been eliminated.

       * — By  2011,  reduce  annual SO  emissions  from   electric   power  generation

          sources by -1.3 million tons below 2003 levels across states covered by the
       - — By 2011, reduce annual emissions of nitrogen oxides (NO )  from electric
          power generation sources by 1.7 million tons below 2003 levels across states
          covorod by CAIR.

       NACEPT SA Comments
       CAIR targets for SO2 and NOx are expressed as tons reduced from 2003 baseline.  It would be
       useful to identify the 2003 baseline and what the  percent change  is. as well to  show how
       ambitious these targets are. (See NOx. VOC and PM targets for mobile sources.)
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         •  By 2011, reduce annual emissions of fine particles from mobile sources by
            184,000  134,700 tons from the 2000 level of 515,550 tons (134,700 tons
            reduced through federal emissions standards for new engines and 50,000
            tons reduced  from  existing engines through the  National  Clean Diesel
            Campaign).

         •  By 2011,  reduce annual emissions of nitrogen oxides (NOX) from mobile
            sources by 3^7 4.0 million tons from the 2000 level of 11.8 million tons (3.7
            million tons reduced through federal emissions standards for new engines
            and  0.3  million tons  reduced  through  the  National  Clean  Diesel
            Campaign).

         •  By 2011, through federal emission standards, reduce annual emissions of
            volatile organic compounds from mobile sources by 1.9  million tons from
            the 2000 level of 7.7 million tons.

         •  By 2018, visibility in eastern Class I areas will improve by 15 percent on
            the 20 percent worst visibility days, as compared to visibility on the  20
            percent worst days during the 2000-2004 baseline  period.

      -—By 2011, through the National Clean Diesel Initiative, reduce emissions from
         the approximately 11 million engines in the existing  fleet by 20,000  tons of
         fine particles since the year 2000.

      -—By 2011, through the National Clean Diesel Initiative, reduce emissions from
         the approximately 11 million engines  in the existing  fleet by nearly 300,000
         tons of nitrogen oxides  since the year 2000.

      NACEPT SA Comments
      National Clean Diesel Initiative PM and NOx targets are expressed as cumulative goals for the
      entire period 2000 to 2011.  There are no references to baselines or cumulative reductions
      attained 2000 to  2006.  These  targets would be more meaningful as  annual rather than
      cumulative.

      -—By 2011, the number of tribes with the expertise and capability to implement
         the Clean Air Act in  Indian country (as demonstrated by successful delegation
         of CAA  authority under the Tribal Authority Rule) will  increase from the  2005
         baseline of 30 to at least 50.

      -—By 2011,  air quality  assessments in Indian country,  such as air quality and
         deposition monitoring, emissions inventories, and toxics assessments, will be
         tribally-driven and reflect tribal priorities and needs.  At least three tribes will
         complete assessments each year between 2007 and 2011, and at least two
         new tribes will undertake new assessments each year between 2007 and
         orn ^
         ^_ W I I .
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      •  By 2018, visibility in western  Class I  areas will improve by five percent on the
         20 percent worst visibility days, as  compared to visibility on the 20 percent
         worst days during the 2000-2004 baseline period.

      •  By 2011, with EPA support, 17 additional tribes will have completed air quality
         assessments,  such  as  air  quality  and deposition  monitoring,  emissions
         inventories, and air toxics assessments. (FY 2005 baseline: 53 tribes).

      •  By 2011,  20 additional  tribes  will possess the expertise  and capability to
         implement the Clean Air Act in Indian country (as demonstrated by successful
         completion of an eligibility determination under the Tribal Authority Rule). (FY
         2005 baseline: 30 tribes).

   Sub-objective 1.1.2. Air Toxics.  By 2011, working with partners,  reduce air toxics
   emissions and  implement  area-specific  approaches to reduce the risk  to  public
   health and the environment from toxic air pollutants, as  follows:

      Strategic Targets:

      -—By 2010, reduce the toxicity weighted  risk  for cancer  by 4% from  the  1993
      level of 23%.

      NACEPT SA Comments
      Have we made any progress since 1993?  What  is the level of improvement as of 2004?  How do
      we assess progress, since what we know about the health risks from toxics keeps growing?  Given
      that the science of toxic air pollution is evolving, shouldn't the baseline change as well?

      •  By 2010, continue to reduce toxicity-weighted (for cancer risk) emissions of
         air toxics to a cumulative reduction of 19 percent from the 1993 baseline.

      NACEPT SP Comments
      Does this target relate to all identified toxic air pollutants  or just to those that currently are
      regulated?  In addition, this target should be restated to reflect data presented in the recently
      released National Air Toxic Assessment (NATA).

      -—By 2010,  reduce the toxicity weighted risk for  non cancer  by  1  cumulative
         percent from the 1993 level of 56%.

      NACEPT SA Comments
      What does this target mean? That EPA has set a goal of reducing non-cancer risk from 56% to
      55% over a 17-year period?  That, by 2010. "only" 55% of the population will suffer from "non-
      cancer"?  Should the word "effects" be inserted between "non-cancer" and "by"?  This needs to
      be clarified.

      •  By 2010, continue to reduce toxicity-weighted (for non-cancer risk) emissions
         of air toxics to a cumulative reduction of 55 percent from the 1993 baseline.
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       NACEPT SP Comments
       This target continues to be unclear. In addition, it also should reflect new understandings of risk
       as presented in the recently released NATA.

       •  By 2011, through the Clean Air Mercury Rule, reduce mercury emissions from
          electric generating units by 10  tons from the 2000 level of 48 tons.

       NACEPT SA Comments
       This is a well-written target and should be used as a model for other targets.  It includes the
       "audience" or "impact universe" (electric generating units), what the agency hopes to achieve (10
       ton reduction in mercury emissions'), an appropriate baseline (2000 level of 48 tons), and how the
       objective will be achieved (Clean Air Mercury Rule).

       •  By 2011, through federal standards, reduce  air toxics emissions from mobile
          sources by 1.4 million tons from the 1996 level of 2.7 million tons.

       NACEPT SA Comments
       The 1996 baseline is based on the last time EPA developed a standard.  But why are air toxics
       from mobile sources under a different objective  from other pollution from mobile sources?

       NACEPT SP Comments
       Given the length of time since the adoption of the last Mobile Source Air Toxics (MSAT) rule
       and the Agency's published  implementation results, this target should be updated to reflect more
       recent emissions data.  Basing the target on pre-control emission levels makes it appear that the
       current requirements have had no impact.

   Sub-objective  1.1.3.  Chronically Acidic Water  Bodies.  By 2011, reduce the
   number of chronically-acidic water bodies  in  acid-sensitive  regions by two percent
   from 1984 levels.

   NACEPT SA Comments
   In 27 years we are able to achieve a reduction of only 2%?  Why so modest?  What is the basis for
   this timeframe?

   NACEPT SP Comments
   The  baseline for this target should be restated to  reflect more  recent  monitoring data rather than
   defaulting to pre-control conditions.

   Recently published research from a range of academic and governmental scientists indicates that the
   issue of water-body acidity is much more global than previously presumed, and extends to the oceans
   as well as inland lakes. pH declines of 0.3 pH units over the next century are projected as a result of
   absorption of increasing amounts of CO? from the atmosphere. While CO? absorption may be viewed
   as an environmental benefit with regard to atmospheric CO? concentrations,  the increased acidity of
   the oceans  is expected to significantly impact marine ecosystem health.  EPA should conduct and
   support research towards greater understanding of the impact of atmospheric CO? concentrations on
   freshwater and marine ecosystems, and develop, as appropriate, strategies and objectives to ensure
   water bodies are protected from CO?-related acidity.
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      Strategic Targets:

      •   By 2011,  reduce national annual emissions of sulfur dioxide (802) from utility
          electrical  power generation  sources by approximately 8.45 million tons from
          the 1980 level of 17.4 million tons, through implementation of the Acid Rain
          Program  and Clean  Air Interstate Rule, achieving and maintaining the Acid
          Rain statutory S02 emissions cap of 8.95 million tons.

      NACEPT SA Comments
      Attaining the statutory cap is a desirable target but no information is provided as to where current
      emission levels are today, so  it's impossible to assess its appropriateness.

      NACEPT SP Comments
      This target should be updated to reflect current emission and water quality monitoring data. In
      addition, it should read "through continuation implementation of the Acid Rain Program a»d- as
      well as implementation of the Clean Air Interstate Rule."

      •   By 2011, reduce total annual average sulfur deposition  and mean  ambient
          sulfate concentration by 30 percent from 1990 monitored levels.

      NACEPT SA Comments
      How do we assess this target given the number of water bodies in the US and the fact that they
      vary so significantly in terms of acidity? Why does EPA refer to a "total" annual average? Does
      EPA mean "nationwide" average? How does this target relate to the overall 2% goal?

      •   By 2011, reduce total annual  average nitrogen  deposition and mean total
          ambient nitrate concentration by 15 percent from 1990 monitored levels.

      NACEPT SA Comments
      See previous comment regarding sulfur deposition target.

      NACEPT SP Comments
      EPA should consider adopting a target to reduce acidified water body "hot spots", which would
      provide additional focus on particularly intractable problem areas.

Means and Strategies for Achieving Objective 1.1

   Our strategy for reducing outdoor air pollution combines national,  regional and local
measures, reflecting  different  federal,  state,  tribal, and local government roles. EPA,
states, tribes, local agencies and multi-jurisdictional organizations (MJOs) work  together
to meet  clean air  goals in a cost-effective  manner through  innovative, regulatory,
market-based,  and  partnership approaches and  programs. EPA recognizes that  states
are primarily responsible for  maintaining and improving air quality and meeting  national
ambient  air quality standards  (NAAQS). They develop emission inventories,  operate
and maintain air monitoring networks, perform air quality  modeling, and develop State
Implementation Plans (SIPs) that lay out their control strategies for improving air quality
and meeting the  NAAQS. MJOs play a vital role  in the air  quality management  effort by
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addressing regional issues, collaborating with states on control strategies, and providing
technical assistance in data analyses and air quality modeling.

   EPA assists states,  tribes,  local  agencies,  and MJOs by  providing technical
guidance  and  financial  assistance, and  by  issuing regulations  and implementing
programs  designed to  reduce pollution from the  most widespread  and  significant
sources of air pollution:  mobile sources, such as cars, trucks, buses, and  construction
equipment; and stationary sources, such as power plants, oil refineries, chemical plants,
and dry cleaning operations. Interstate transport of pollutants—a problem no state can
solve on its own—makes a major contribution to air pollution problems in the eastern
United States.  To address this  issue,  EPA requires  control of upwind sources that
contribute  to downwind problems in other states.

   EPA has a trust responsibility to  protect air quality in  Indian country, but tribes may
choose to  request authorization to develop and implement Clean Air Act programs. EPA
and tribes  are working to increase the currently limited information on air quality  on tribal
lands, build tribal capacity to  administer air programs  in Indian country, and establish
EPA and  state mechanisms to work effectively with tribal  governments on  regulatory
development and regional and national policy issues. Once a tribe completes an air
quality assessment  so  that   they  and EPA agree  that  they  have  a  satisfactory
understanding of their base  air quality conditions,  the tribe will either develop an air
quality management program appropriate for their needs,  or EPA will work with  the tribe
to develop options so that it can continue to participate in local,  regional, and  national
policy and regulatory development.

   Over the next several years, EPA will continue to focus on  implementing  the fine
particulate matter (PM2.5) standards and 8-hour ozone  standards, reducing S02 and
NOX (precursor emissions of  both  particulate matter and  ozone) and mercury from
electric-generating units, and implementing EPA's air toxics program using  progressive,
market-oriented methods to improve air quality most cost-effectively. EPA will continue
to work with MJOs to develop  strategies for reducing regional haze and with individual
states to  develop approaches to reduce emissions of PM and ozone precursors.  In
addition, EPA will work  with states  to better integrate ozone and  PM efforts,  such as
through    improved   emission  inventories,   comprehensive  air  quality  modeling
approaches,  controlling  sources of  precursors  common  to  both pollutants, and
coordinated control strategy planning cycles.

   Recognizing  that meaningful  public involvement  produces better environmental
results,  EPA will actively seek the  involvement of communities,  civic organizations,
members  of the  public, and  other stakeholders in designing  programs to  achieve
healthier  outdoor air.  In  addition,  we  continue  to work  closely with the  National
Environmental  Justice  Advisory Council, community-based  organizations,  and other
stakeholders  (e.g.,  state/tribes,  local   government,   academia,   environmental
organizations, and  business  and industry)  to ensure  that environmental  justice  is
integrated into our programs, policies, and activities.
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Improving Air Quality

   To help states meet the outdoor air objective,  EPA will continue to develop federal
programs for mobile and stationary sources aimed at achieving large,  nationwide, cost-
effective reductions in emission of PM and its contributors: 862, NOx, and elemental
and organic carbon; ozone-forming NOx; and volatile organic compounds (VOCs).

   Our strategy for the next few years is to implement the Clean  Air Interstate Rule
(CAIR) that was promulgated on May 12, 2005. CAIR takes what we  have learned
about cap-and-trade programs from the Acid Rain program, and provides states with a
solution to  the problem of power plant pollution that drifts from one  state to another.
CAIR is an important component of EPA's plan to help states in the eastern  United
States meet EPA's health-based air quality standards  (Figure 2). Through CAIR and
other Clean Air  Act (CAA)  programs, 92 of the 108  areas that did not meet  the
standards for 8-hour ozone and 17 of the 36 areas that did not meet the standards for
PM2.5 (both as of April 2005) will achieve these health-based national  standards  by
2011. Using a market-based approach, CAIR is projected to reduce S02 emissions by
4.3 million  tons  (over 70  percent)  and NOX emissions by 1.7 million tons (over 60
percent) from 2003 levels (Figure 3), and will not significantly change national electricity
prices. Power generators will continue to rely on diverse sources of fuel, including  our
abundant domestic coal resources. CAIR provides incentives for power plant operators
to find the  best, fastest,  and most  efficient ways to make the  required emission
reductions.  It is  estimated that air quality improvements from  CAIR with other CAA
programs will generate over $100 billion in health and visibility benefits  per year by 2015
and  substantially reduce  premature  mortality  in the  eastern  United States.  These
programs are also projected to reduce the incidence of chronically  acidic lakes and
streams  through  reductions  in  sulfur  and  nitrogen  deposition.  The  health  and
environmental benefits of these programs will continue to grow each  year with  further
implementation.

   Our strategy  for achieving  cleaner air also will include implementing  a series of
national programs that will dramatically reduce emissions from a wide-range of mobile
sources.  EPA's  Tier 2  Vehicle  and  Gasoline  Sulfur Program, which will be  fully
implemented in 2009, will  make  new  cars,  SUVs,  pickup trucks, and vans 77 to 95
percent cleaner  than 2003 models,  while reducing sulfur levels  in  gasoline  by 90
percent. EPA's  Clean Diesel Truck and Bus  Program will require that, beginning in
2007, all new highway diesel engines be as much as 95 percent cleaner than current
models, while reducing sulfur levels in highway diesel fuel by more  than 97 percent.
EPA's  Clean Air Nonroad Diesel  Rule will cut emission  levels  from construction,
agricultural  and industrial diesel-powered  equipment by more than 90 percent, while
removing 99 percent of the sulfur in nonroad diesel fuel by 2010. As part of this nonroad
effort, more stringent standards for locomotives, large marine diesel  engines, and small
gasoline engines (such as those  used in lawn and  garden equipment) are  also being
developed.  The emission reductions resulting from the clean fuel and vehicle standards
finalized over the past several  years will prevent  more than 24,000 premature  deaths
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and, when fully implemented  in 2030, produce annual net benefits of approximately
$175 billion, compared to $11 billion in costs.

   EPA will continue to address diesel emissions not only through new engine and fuel
standards,  but also through partnership programs aimed at reducing emissions from the
existing inventory of diesel engines currently in use. These programs will greatly reduce
emissions of air toxics and criteria pollutants, and help achieve cost-effective air quality
improvements.  For instance,  EPA  will expand  its efforts  to create voluntary  diesel-
retrofit projects to reduce PM emissions from older,  high-polluting trucks and  buses,
concentrating on areas with sensitive populations, and on raising public awareness of
the problem of children  riding in older,  high-emitting diesel school  buses. EPA will
provide grants for retrofitting and replacing diesel school buses and reducing idling, and
will work with the trucking and railroad industries to adopt pollution control and  energy-
saving technologies.
Environmental Justice: Reducing diesel exhaust in higher impact areas

EPA's National Clean Diesel Campaign (NCDC, in establishing diesel retrofit projects to achieve
PM,  NOX  and  other  emissions reductions,  seeks  to  include  areas  that experience
disproportionate impacts from diesel exhaust as one criterion for distributing grant funds. The
program also targets the reduction of diesel  emissions from school buses to reduce children's
exposure to  particulate  matter and other  pollutants. The program takes  an environmental
stewardship approach by focusing on both partnership efforts to address the existing diesel fleet
in addition to  a regulatory approach  for the new  engines that are subject to more stringent
emissions standards.
   Implementing  provisions of the Energy  Policy Act of 2005 also will be a  major
undertaking for EPA in the FY 2006 to 2011  timeframe. Central to this effort will be the
development and  implementation  of  the  Renewable Fuel Standard (RFS)  program,
which will require that the U.S. gasoline supply contain specific volumes of renewable
fuel each calendar year,  starting with  four billion gallons in 2006 and increasing  to 7.5
billion in 2012. Development and  implementation of the  RFS  program will require  a
substantial investment of resources, including expertise on renewable fuels (production,
distribution,  blending),  vehicle  testing to  assess the impacts  of renewable fuels on
emissions, refinery modeling,  transportation  modeling and life-cycle analysis, energy
security impacts, and economic analyses (including farm/agricultural impacts).

   EPA  also  will  continue to implement  the reformulated  gasoline  program  while
working to address issues associated with the use of oxygenates, such as MTBE and
ethanol.  We also will continue to  help  states  and local agencies  implement  the
transportation  conformity  regulation,  to  ensure  that federally-funded  or  approved
highway and transit activities  are  consistent with  State Implementation Plans (SIPs),
and  will finalize changes  to the  regulation  to  address the revised ozone and  PM
standards. Finally, recognizing that efforts to reduce emissions need to be accompanied
by efforts to reduce the effects of unmanaged growth and development, EPA will work
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with state and local governments, assisting  them in crafting comprehensive strategies
that accommodate  necessary growth and  economic  development while minimizing
adverse effects on air quality and other quality-of-life factors.

Reducing Risks From Toxic Pollutants

   EPA regulates the emissions of 186 toxic air pollutants, including dioxin, asbestos,
toluene, and such metals as cadmium, mercury, chromium, and lead compounds." To
further reduce exposure to air toxics,  EPA developed and  issued federal standards for
major stationary  sources which, when fully  implemented through  state programs, will
reduce toxic  emissions  by  1.7  million tons.  In addition, EPA is  conducting national,
regional,  and  community-based efforts to  reduce multimedia  and cumulative risks.
Characterizing emissions and the risks they pose on national and local scales, such as
in Indian  country, will require significant effort. We  will need to update the science and
to  keep the public  informed  about these  issues. Toxics pollutants are of  particular
interest to the environmental justice community because of the proximity of many low-
income and  minority  communities to sources of toxics  emissions  (e.g.,  industrial
facilities, waste transfer stations, roadways, and bus terminals). To  better address areas
that may suffer disproportionate impacts,  EPA will use tools and indicators,  such as
those developed by EPA's  Office of Environmental  Justice, to identify areas with
potential environmental justice concerns.

   EPA is implementing the  Clean Air Mercury Rule (CAMR), which was promulgated
on May 18, 2005. CAMR is the first-ever federal rule to permanently cap and reduce
mercury  emissions  from coal-fired power  plants. CAMR establishes "standards  of
performance" limiting mercury emissions from new and existing coal-fired  power plants
and creates a market-based cap-and-trade  program that will reduce nationwide utility
emissions of mercury  in two  distinct phases. The first  phase cap is 38  tons and
emissions will be reduced by taking advantage of "co-benefit" reductions, i.e., mercury
reductions  achieved by  reducing  sulfur  dioxide  (S02) and nitrogen oxides  (NOX)
emissions under  CAIR.  In the second  phase, beginning in 2018, coal-fired power plants
will  be subject to a second  cap, which  will reduce  emissions  to 15  tons  with full
implementation. Like CAIR, the CAMR program has stringent emissions monitoring and
reporting requirements  modeled after those  developed and  implemented in the Acid
Rain program. The flexibility of allowance trading creates financial  incentives to look for
new and  low-cost ways to reduce emissions and improve the effectiveness of pollution
control equipment.

   The Clean Air Act  (CAA) also requires EPA to  establish standards to  reduce
emissions of air toxics from motor  vehicles and their fuels.  In March  2006,  EPA
proposed standards to  limit the  benzene content of gasoline  and  to reduce emissions
from  passenger vehicles and portable  gasoline containers. EPA will finalize this rule in
2007 and implement it in subsequent years.

   EPA continues to develop and refine tools, training, handbooks, and  information to
assist our partners in characterizing risks from air toxics, and we will work with them on
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strategies for making  local decisions to  reduce those risks. As EPA implements its
community-based  air  toxics programs,  including Community Action for  a Renewed
Environment (CARE), we will evaluate how program activities affect areas with potential
Environmental Justice  concerns. As areas with potential environmental justice concerns
have  been identified, EPA will work with those communities  so they can  identify  and
address  risk and track progress. Working with our state  and local partners, EPA  has
designed and  implemented  a national  toxics  monitoring  network.  Data from  the
monitoring network and from local assessments allow us to better characterize  risk  and
assess priorities.

Working  with Tribes and Other Partners

   EPA  is committed  to working with tribes on a government-to-government  basis to
develop the infrastructure and skills tribes need to assess, understand, and control air
quality on their lands. We will support tribes in their efforts  to build capacity,  and
encourage the development of programs to  help tribes  participate  in discussions of
national  policy and operations and  in regional  planning and  coordination activities.
Recognizing  that many tribal programs are still  in development, we will  support the
growth of programs to enhance measurable air quality and human health outcomes. We
will continue to encourage tribes to assess1 their air quality and develop the capacity to
address identified concerns. We will continue to support air monitoring in Indian country
and  are  exploring  opportunities  for mercury  and  other  deposition monitoring. In
consultation with tribes, we will establish needed federal regulatory authorities and help
tribes develop and manage their own air  programs in a  manner consistent with EPA
Indian Policy and  tribal traditions and culture. We will support tribal air programs by
providing technical support,  assistance with  data development and  analysis. Where
tribes choose not to develop their own programs, we will implement air quality programs
directly. EPA has developed new rules for new or modified major and minor sources in
Indian country, and will work with tribes to delegate or directly implement these rules in
all of Indian country.

   As we develop and implement clean  air  strategies, we will involve the public in
meaningful  ways  and work  with other  federal agencies to  ensure a  coordinated
approach. Our federal partners include the Department of Agriculture (in the areas of
animal feeding operations, agricultural burning, and controlled  burning), the Department
of Transportation  (for transportation-related  air quality  issues), the Department of
Energy (for electric utilities, electricity  generation, and  energy efficiency issues), and the
Department of Interior (concerning visibility in national  parks and wilderness areas).

   EPA also will work to address sources of air pollutants that lie outside our  borders,
but pose risks to air quality and public health within the United States. The pollutants
1 A tribal air quality assessment is completed when the tribe and Regional Office both agree that the tribe has
completed the appropriate steps to understand any air quality issues and concerns, and their activities have changed
to focus on program development and implementation, if appropriate. Further assessments may be carried out as part
of their ongoing activities, but the focus is no longer on gaining an initial understanding of air quality issues and
activities.
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that are subject to international transport include traditional criteria air pollutants, such
as ozone and fine particles, as well as persistent bioaccumulative toxins (PBTs), such
as mercury, dioxins, and polychlorinated  biphenyls (PCBs).  We will work with the
National Oceanic and Atmospheric Administration, the National Aeronautics and Space
Administration,  and other agencies to improve our capability to detect, track,  and
forecast the effects of these air pollutants from international sources. By engaging with
the international  scientific  community, we hope to improve  our understanding of
international flows and our tools  for  analyzing  and evaluating response  policies.
Working  through bilateral  agreements,   international   partners,  and  multilateral
international organizations (such as the United Nations Environment Program and the
Organization for Economic Cooperation and Development), we will promote  capacity
building, technology transfer, and other strategies to reduce foreign sources of pollution.

   EPA will continue to work with partners  to implement sustainable development
public-private partnerships launched at the World Summit for Sustainable Development
in   2002.  The   goals  of  the  Partnership  for   Clean  Fuels   and  Vehicles
(http://www.unep.org/pcfv) are to achieve  global phase-out of leaded  gasoline and to
work with developing countries and transition economies to reduce sulfur in fuels and to
adopt clean vehicle technologies. The goal of the Partnership for Clean  Indoor Air
(http://www.pciaonline.org) is to reduce the  increased environmental  health risk faced
by more than two billion people who burn  traditional biomass fuels indoors for cooking
and heating.

   EPA also will  help represent the United  States in existing multilateral international
agreements (such as  the  Convention on Long-Range  Transboundary Air Pollution
(http://www.unece.org/env/lrtap) and the Stockholm Convention on Persistent Organic
Pollutants  (http://www.pops.int)  to  control  sources  of  internationally  transported
pollutants and protect U.S.  interests. In North  America, we will work with Canada and
Mexico  within  such  existing agreements as the U.S.-Mexico  La  Paz Agreement
(http://air.utep.edu/bca/iac/agreement.html),  the  U.S.-Canada  Air  Quality Agreement
(http://www.epa.gov/airmarkt/usca/agreement.html), and the North American Agreement
on                           Environmental                           Cooperation
(http://www.naaec.gc.ca/eng/agreement/agreement e.htm),  to control the cross-border
flow  of pollutants. We  will also work with Canada, Mexico, and  key stakeholders to
identify  and explore new approaches to managing  air  quality  along our common
borders.

OBJECTIVE 1.2  - HEALTHIER INDOOR AIR. Through 2012, working with partners,
reduce human health risks by reducing exposure to indoor air contaminants through the
promotion of voluntary actions by the public.

   Sub-objective 1.2.1. Radon. By 2012, the number of future premature lung cancer
   deaths prevented annually through lowered radon exposure will increase to 1,250
   from the 1997 baseline of 285 future premature lung cancer deaths prevented.
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   NACEPT SA Comments
   Given that lung cancer has the highest mortality rate (and number) and arises from a number of
   factors, is epidemiology sufficiently robust to be able to measure this objective? There is no baseline
   as to the number of annual lung cancer deaths to assess how ambitious this objective is.

   NACEPT SP Comments
   In the 10 years since 1997. what progress has EPA achieved toward this target? Such information is
   necessary to determine whether the target is reasonable and achievable.  Further, how would this
   result relate to the total lung cancer rate?

   Sub-objective  1.2.2.  Asthma.  By 2012, the number of people taking all essential
   actions to reduce exposure to  indoor environmental  asthma triggers will increase to
   6.5 million from the 2003 baseline of  3 million. EPA will place special emphasis on
   children and other disproportionately impacted populations.

   NACEPT SA Comments
   This objective relies entirely  on  behavioral changes in  the non-regulated community.   What
   measurable indices will be used to assess the number of respondents?  What mechanisms does the
   Agency contemplate to compel consumer compliance?

   NACEPT SP Comments
   Because of EPA's inability to reliably influence or measure personal behaviors, this target should be
   restated to focus on  program adoption and implementation or on decreasing  the number of indoor
   asthma triggers.

   Sub-objective  1.2.3.   Schools.   By 2012, the number of schools implementing an
   effective indoor air quality management plan will increase to 40,000  from the 2002
   baseline of 25,000.

   NACEPT SA Comments
   Whether this is an ambitious objective depends on the number of schools in the  target universe.

   NACEPT SP Comments
   This target should be restated to focus on schools in areas with the highest incidence of indoor air
   quality problems and childhood asthma to ensure that agency efforts are being targeted toward those
   schools with greatest need.

   Sub-objective  1.2.4.   Environmental Tobacco Smoke.  By 2012,  the percentage
   of children six and under regularly exposed to environmental tobacco smoke in the
   home will  be reduced  to X 8  percent from a 1998 baseline of 20 percent, and the
   disparity of exposure between low-income children  and the general  population will
   be reduced.

   NACEPT SA Comments
   This objective relies entirely  on  behavioral changes in  the non-regulated community.   What
   measurable indices will be used to assess  conformance?  What  mechanisms  does  the Agency
   contemplate to compel consumer conformance?
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   NACEPT SP Comments
   NACEPT continues to have concerns regarding EPA's ability to influence consumer behavior in an
   area not under the agency's regulatory authority.

Means and Strategies for Achieving Objective 1.2

   Air within homes, schools, and workplaces can  be more polluted than outdoor air in
the largest and most industrialized cities.'" And because people typically spend close to
90 percent of their time indoors,IV many may have a greater exposure to indoor pollution
than to outdoor air pollution. Relative risk reports issued by EPA,V the Science Advisory
Board/' and several statesv" rank indoor air pollution among the top four environmental
risks. Moreover, people who may spend the most time indoors, thus exposed to indoor
air pollutants  for long periods of time, are often those who may be most susceptible to
their effects:  the young, the elderly, and  the chronically ill, especially those suffering
from respiratory or cardiovascular disease. Further, underserved populations often face
higher exposures and unique mitigation challenges.

   To address indoor air quality issues, EPA develops and implements innovative, non-
regulatory, outreach and partnership programs that inform and educate the public about
indoor air quality and actions that can  reduce potential risks in homes,  schools, and
workplaces. Through these partnership programs, EPA disseminates information and
works with state, tribal, and local governments;  industry and professional groups; and
the public to promote actions to reduce exposures to possibly harmful levels of indoor
air  pollutants, including radon.  EPA's indoor air quality program places particular
emphasis on reaching children and underserved  populations  who often face greater
risks from indoor air quality problems.

   EPA works in  partnership with a wide array of constituencies such as health care
providers in urban areas who treat children prone to  asthma attacks, including children
disproportionately  impacted  by asthma, school  personnel  who manage   school
environments, county and local environmental health  officials, and housing and building
organizations. EPA's partnership  network  also  engages a  wide array of  other
constituencies who care about and impact indoor air quality and who have the expertise
and credibility that allow  EPA to reach a larger audience than we could on our own. To
support these  partnership  approaches,  we  will  base  our  policy  and technical
recommendations for reducing potential exposure  to indoor contaminants on the most
current science available. We will develop data on  households affected by radon, mold,
and asthma triggers in Indian country, to better measure pervasiveness and to quantify
successful implementation of programs such as Tribal Effective Asthma  Management
and Tools for Schools, as well as the health benefits of those programs.

   In addition to offering targeted assistance and  guidance to urban, low-income, and
minority populations  across the  nation, EPA also will provide tribes with appropriate
tools and assistance to address indoor air  toxics, such as radon, environmental tobacco
smoke, indoor asthma triggers, mold, and other biological and chemical contaminants.
We will work with other federal agencies to provide guidance and assistance on  how to
reduce the exposure levels of these contaminants in all Indian communities.
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   EPA will broaden awareness and increase action by working with national as well as
local community-based organizations to design and implement programs that address
critical indoor air quality problems,  including  radon,  secondhand  smoke,  asthma
triggers, and  mold contamination in homes, child care and school facilities, and other
commercial indoor environments. These same issues have become evident in Indian
country as tribal  governments  develop  a better understanding  of indoor air  quality
issues. EPA  will help tribes develop improved baseline data for indoor air issues  in
Indian country and assist tribes and reservations as they address these critical indoor
air quality  problems. Through the State Indoor Radon Grant Program, EPA will continue
to help states and tribes develop and implement effective  radon assessment and
mitigation  programs and will support innovation and expansion of these programs.

OBJECTIVE  1.3   -   PROTECT  THE OZONE  LAYER.   By 2044 2030, through
worldwide action,  ozone concentrations in the  stratosphere will have stopped declining
and slowly begun  the process of recovery, and overexposure to ultraviolet radiation,
particularly among susceptible subpopulations,  such as  children,  will  be reduced.
Specifically:

NACEPT SP Comments
The timeline for this Objective has been extended from 2011 to 2030 (19 years). What is the rationale for
this significant extension?

   Sub-objective  1.3.1.   Stratospheric Chlorine Concentrations.   By 2011, total
   effective equivalent stratospheric chlorine will have reached its peak, and begun its
   gradual decline to a value less than 3.4 parts per billion of air by volume.

   NACEPT SP Comments
   Does this sub-objective mean that 3.4 ppb will be achieved by 2011 or that the decline will begin by
   2011 and the 3.4 ppb goal will be achieved at some future, unspecified date?

      Strategic Targets:

      •   By  2011, 65 percent of all hydrochlorofluorocarbon (HCFC) production and
          import   will  be  phased   out,   further  accelerating  the  recovery  of the
          stratospheric ozone  layer—with further reduction steps in  2015 and 2020,
          concluding with complete elimination of Class II substances in 2030.

      •   Through 2011, continue the transition away from ozone-depleting compounds
          in a way that reduces overall risks to human health and the environment by
          acting on 100 percent of petitions for substitutes within 90 days of receipt.

   Sub-objective  1.3.2:—SunWise.—By 2011, the number of schools registered with
   the SunWise program will increase to 20,000 from X in year 20XX, thereby reducing
   the risks of overexposure to UV radiation through education of children in grades K-
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   NACEPT SA Comments
   What is the baseline of total schools in the target universe? Since reduced exposure will be achieved
   by behavior change, how will the number of children who actually change behavior be assessed?

Means and Strategies for Achieving Objective 1.3

   Scientific  evidence  amassed  over the  past three  decades  has shown  that
chlorofluorocarbons and hydrochlorofluorocarbons (used as refrigerants, solvents, and
for other purposes),  halons, (fire-extinguishing  agents), methyl bromide (a pesticide),
and other halogenated chemicals used around the world are depleting the stratospheric
ozone layer. As a result, more harmful ultraviolet (UV) radiation is reaching the earth,Vl"
increasing the risk of overexposure to radiation and consequent health effects, including
skin  cancer, cataracts,  and other illnesses.  More than a  million new  cases  of skin
cancer are diagnosed each year,lx one in five Americans is expected  to experience skin
cancer,  and more than half of all Americans develop  cataracts by the time they are 80
years old.x

   As a signatory to the  Montreal Protocol on Substances That Deplete  the Ozone
Layer (Montreal  Protocol),Xl  the United States is obligated to regulate and  enforce its
terms domestically. In accordance with this international treaty and related Clean Air Act
requirements,*' EPA will continue  to implement the domestic  rule-making agenda for
the reduction  and control  of  ozone-depleting  substances (ODS) and  enforce  rules
controlling  their  production,  import,  and emission.  This  implementation  includes
combining  market-based  regulatory  approaches   with  sector-specific   technology
guidelines and  facilitating the development and  commercialization  of alternatives to
hydrochlorofluorocarbons.  We will  strengthen outreach efforts to ensure efficient and
effective compliance,  and continue to identify and promote safer alternatives to curtail
ozone  depletion. We  will work with stakeholders  to advance voluntary  and  other
partnerships that will smooth the transition to ODS  substitutes and provide important co-
benefits  such  as greenhouse gas emission  reduction and energy savings.  To  help
reduce  international  emissions, we  will  assist with  the  transfer  of technology to
developing  countries  and  work with  them to accelerate the phase-out  of ODS. EPA
estimates that in the United States alone between 1990 and 2165, the worldwide phase-
out of ODS will save 6.3 million lives from  fatal  cases of skin cancer, avoid  299 million
cases of nonfatal skin cancers, and avoid 27.5 million cases of cataracts.Xl"

   Because the ozone layer is not expected to recover until the middle of this century at
the earliest,XIV  the public will continue to  be exposed to higher levels of UV radiation
than  existed prior to  the use  and emission of ODS.XV Recognizing this fact and the
public's current  sun-exposure practices,   EPA  will continue education  and outreach
efforts to encourage behavioral changes as the primary means of reducing  UV-related
health risks, particularly for school children and their caregivers. The SunWise program,
which we expect to grow from 200 participating K-8 schools in 2000 to 20,000 by 2011,
will teach thousands of school  children and adults  how to protect themselves from
overexposure to the sun.
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OBJECTIVE 1.4  -   RADIATION. Through 2011, working  with  partners, minimize
unnecessary releases of radiation and  be prepared  to minimize  impacts to human
health and the environment should unwanted releases occur.

   Strategic Targets:

   Sub-objective  1.4.1: — Waste  Isolation Pilot Plant. — Through 2011, EPA will
   annually fulfill  100% of the Department of Energy's  (DOE)  requests for waste
   characterization approvals to ensure  that EPA  requirements  are met for proper
   disposal at tho Waste  Isolation  Pilot  Plant (WIPP). — DOE  projects that tho total
   number of drums disposed will  increase from X drums (X million millicuries)  in 2003
   to X drums (X million millicuries) in 201 1 . The estimated total drums to be deposited
   at the WIPP is 860,000 (2.6 billion millicuries) over the next 35 years.

   NACEPT SA Comments
   This implies that  EPA's goal  is to issue all requested approvals, whether or not the requests are
   complete and comply with regulations. The 100% target should apply only to complete and lawful
   requests.

   Sub-objective  1.4.2: — Emergency  Response. — By 2011,  X%  of EPA's radiation
   assets will meet functional requirements to implement the National Response Plan's
   Nuclear/Radiological Incident Annex and National  Oil  and  Hazardous  Substances
   Pollution Contingency Plan. (2005 baseline:  50%)

   NACEPT SA Comments
   This suggests that some fraction of EPA's radiation assets are "dysfunctional assets" and that it will
   take 5 years to achieve some higher level of functionality. Do the assets have some interim value that
   they can be measured against?

   What is a "radiation asset"? And is this information sensitive?

   Sub-objective  1.4.3:  Homeland  Security/RadNet. — By  2011,  PvadNet,  EPA's
   National Radiation Monitoring System, will have operational monitors in X% of the
   most populous  U.S. cities.  (2005 baseline: X% of the most populous U.S. cities)

   NACEPT SA Comments
   FY05 Performance Report says that EPA expects to provide monitoring coverage to 65 percent of the
   US population by 2009. What's vitally missing here is a discussion of providing protection to the
   public through materials management and response assistance in the event of releases.

   •  By 201 1 , 77 percent of the U.S. land area will be covered by the RadNet ambient
      radiation air monitoring system. (2001 Baseline is  35 percent of the U.S. land
      area).
      By 201 1 , the radiation program will maintain a 90 percent level of readiness of
      radiation  program  personnel  and  assets  to  support  federal  radiological
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      emergency response and recovery operations. (2005 Baseline is 50 percent level
      of readiness).

Means and Strategies for Achieving Objective 1.4

   EPA continues to meet the statutory mandates for managing  radiation waste and
controlling radioactive  emissions and  to fulfill  its responsibilities under Presidential
decision  directives  for radiological emergency preparedness and response. These
responsibilities form the core of our strategy to protect the public and the environment
from unnecessary exposure to radiation. EPA works with states, tribes, and industry to
develop  innovative  training,  public information, and voluntary programs to  minimize
these exposures.

   Mining and processing naturally occurring radioactive materials for use in medicine,
power generation, consumer products, and  industry inevitably generate  emissions and
waste. EPA provides guidance  and training to other  federal and state agencies in
preparing for emergencies at  U.S. nuclear plants,  transportation accidents  involving
shipments of radioactive  materials,  and acts of nuclear terrorism. EPA also  develops
guidance for cleaning up radioactively-contaminated Superfund sites. We  will ensure
that  appropriate methods are  used  to  manage radioactive  releases and  exposures.
These include  health-risk site  assessments;  risk  modeling,  cleanup,  and waste
management activities; voluntary programs to  minimize  exposure to radiation  in
commercial  products  and  industrial   applications;  national  radiation  monitoring;
radiological emergency response; and provision of  federal guidance to our international,
federal, state, and local partners.

   EPA will  continue to provide advice and guidance, as requested, to  help state and
local organizations locate, identify,  and dispose of radioactive sources  that  find their
way  into  non-nuclear facilities,  particularly scrap yards, steel mills, and municipal waste
disposal  facilities. We also will continue to  work with the International Atomic Energy
Agency and other federal agencies to prevent metals and finished products suspected
of having  radioactive contamination  from  entering  the  country.  We  will create
partnerships with states, local agencies, and tribes to locate and secure lost, stolen, or
abandoned  radioactive sources  within  the  United States and to  develop innovative
partnership  programs with state  and local  agencies and  industry to investigate and
promote  pollution prevention and operational practices  and  technologies that reduce
industrial radioactive releases. We will continue  and expand our ongoing efforts to
ensure that  tribes receive assistance in dealing with radon exposures  in their homes
and schools.

   EPA also operates RadNet, formerly known as the Environmental Radiation Ambient
Monitoring System (ERAMS),  the only  national ambient radiation monitoring  program
that  provides information  about the wide-scale  spread of radioactive  material  from
nuclear or radiological incidents. Over the next several years,  EPA will upgrade RadNet
by adding portable  and quickly deployable monitors that can be shipped  to  affected
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areas, by conducting real-time monitoring for contamination in air, and by replacing old
equipment with state-of-the art air samplers.

   One  of  EPA's  major  responsibilities related  to radiation  is  certifying  that  all
radioactive waste shipped by the Department of Energy (DOE) to the Waste Isolation
Pilot Plant (WIPP) is disposed of safely and according to EPA's standards. We inspect
waste generator facilities and  biennially evaluate  DOE's  compliance with applicable
environmental laws and regulations. Every 5 years, EPA will have to recertify that the
WIPP is in compliance with EPA's radioactive waste disposal regulations.

OBJECTIVE 1.5   -  REDUCE GREENHOUSE  GAS INTENSITY. Through EPA's
voluntary climate protection programs,  contribute 80 million metric tons of carbon
equivalent  (MMTCE) annually to the President's 18 percent greenhouse gas (GHG)
intensity  goal by 2012. (An additional 24 MMTCE to result from the sustained growth in
the climate programs are reflected in the Administration's Business-as-Usual projection
for GHG  intensity improvement.)

NACEPT SA Comments
This objective is  difficult to comprehend.  How does the  80 MMTCE contribution compare to the
MMTCE of the 18% greenhouse gas intensity goal?  What is the relationship of the "additional" 24
MMTCE and is it an expected result of EPA activities?

NACEPT SP Comments
NACEPT remains concerned that this Objective, and the associated Means and Strategies, do not
demonstrate the significance of EPA's GHG efforts towards the President's 18 percent GHG intensity
goal. EPA should include information that relates its 80 MMTCE contribution to the overall mass
reduction objective that satisfies the 18% GHG intensity goal.

   Sub-objective  1.5.1.    Buildings  Sector.   Through EPA's ENERGY  STAR®
   program, prevent 26 MMTCE in  the buildings sector in 2012, in addition to the 20
   MMTCE prevented  annually in 2002.

   NACEPT SA Comments
   This and the  following two  sub-objectives are written to  suggest that prevention occurs only in
   discrete events at ten-year intervals. (2002 and 2012).  Was the  intent that the annual prevention
   would increase from a 2002 baseline of 20 MMTCE to 26 MMOTCE in 2012?

   Sub-objective  1.5.2.     Industrial  Sector.   Through  EPA's  industrial  sector
   programs, prevent  64 MMTCE  in 2012, in addition  to the 34 MMTCE prevented
   annually in 2002.

   NACEPT SP Comments
   How does this target take into account the increased energy intensity of EPA-required stationary
   source controls, such as those implemented as a result of global NSR settlement agreements, changes
   toNSPS. etc.?
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   Sub-objective  1.5.3.  Transportation  Sector.   Through  EPA's  transportation
   programs, prevent 13  MMTCE in  2012, in  addition  to the  2  MMTCE prevented
   annually in 2002.

   NACEPT SP Comments
   How does this target take into account the Renewable Fuel Standards included in the Energy Policy
   Act of 2005 and the elimination of the oxygenate requirement in reformulated gasoline? Also, what
   assumption does this target make regarding expected growth in trips and VMT?

Means and Strategies for Achieving Objective 1.5

   In 2002, the President announced a U.S. climate policy to reduce the  GHG intensity
of the U.S. economy by 18 percent over the next decade. EPA's  strategy for helping to
improve GHG intensity is to enhance its  partnerships with a diverse set  of private and
public organizations  through  programs  that deliver multiple benefits  in addition to
reducing  GHG intensity—from cleaner air to lower energy bills. At the  core  of these
efforts are government-industry partnership programs designed to  capitalize on the
opportunities  that consumers, businesses, and  organizations have for making sound
investments in energy efficient  equipment, policies  and  practices, and  transportation
choices.

   EPA manages a  number of  partnership efforts to  improve  information  in the
marketplace and more quickly deploy technology in  the residential, commercial,  and
transportation   sectors    of   the  economy.   The   ENERGY   STAR   partnership
(http://www.enerqvstar.qov/)  has  been successful in cost-effectively avoiding GHG
emissions in  the residential, commercial,  and industrial  sectors. EPA's programs on
methane  and other potent greenhouse gases successfully engage  energy, industrial
and   agricultural  sectors  to  deliver  cost  effective  GHG   emission  reductions
(http://www.epa.qov/nonco2/voluntaryproqrams.html).  In  addition,  the  clean  energy
partnership programs  promote the development and purchases of renewable energy
through the Green  Power Partnership and Combined  Heat and  Power Partnership
(http://epa.gov/cleanenergy/) EPA's goals for these efforts are to cost-effectively return
emissions of methane to  1990  levels  or below by 2012; to cost-effectively  limit
emissions of the more potent GHGs (hydrofluorocarbons,  perfluorocarbons, and sulfur
hexafluoride); and to facilitate the use of clean energy technologies.

   EPA     will      continue     its      SmartWay     Transport     Partnership
(http://www.epa.gov/smartway/)  efforts with the trucking and   railroad  industries to
reduce GHGs through efficiency or energy-saving technologies and to promote cleaner
vehicles and the adoption of pollution  control  and  energy-saving  technologies  that
reduce NOx  and PM emissions.  SmartWay also  addresses  environmental justice
because   rail yards,  truck stops,  border crossings, etc.  are often  located  near
communities  with  environmental  justice  concerns.  EPA's  Best Workplaces  for
Commuters   program   (http://www.commuterchoice.gov/)  also  develops  innovative
solutions   to  commuting  challenges faced by  U.S. employers and employees by
promoting commuter  benefits that  reduce vehicle  trips and  miles traveled. Other
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activities at EPA will further advance fuel-efficient and clean automotive technology,
thus saving energy and reducing GHG emissions.

   We also will continue the Partnerships for Home Energy Efficiency (PHEE)-a joint
effort of the U.S. Department of Energy, EPA, and the U.S. Department of Housing and
Urban Development. One of the main objectives of this partnership is to deliver energy-
efficiency  savings to low income and subsidized  housing.  PHEE will help address
energy shortages and rising natural gas prices and thus will help make housing more
affordable.
   EPA will continue  its efforts to provide state, tribal, and  local governments with
technical,  outreach,  and education services about climate change impacts,  mitigation
and adaptation options, and  related issues  so that they can more  effectively  and
comprehensively address their goals.

   EPA also  promotes international partnerships to reduce  GHGs and  deploy clean
technologies.  Through the Methane to Markets Partnership, EPA will work with partner
countries around the world, as well as the U.S. private sector, to reduce global methane
emissions,  enhance  economic growth,  promote energy security, and  improve the
environment    by    using    cost-effective    methane    recovery    technologies
(http://www.methanetomarkets.org/).  In addition, the United  States has joined with
Australia, China, India, Japan, and South Korea to launch the Asia-Pacific Partnership
on Clean Development and Climate. EPA will support this Partnership to advance the
President's goal of developing and accelerating the deployment of cleaner and more
efficient technologies and practices.

OBJECTIVE  1.6 -  ENHANCE SCIENCE AND RESEARCH. Through 2011,  provide
and apply sound science to support EPA's goal of Clean Air by  conducting leading-edge
research and  developing a better understanding and characterization of human health
and environmental outcomes under Goal 1.

   Sub-objective 1.6.1:  Use Science and Technology to Support Air Programs.
   Through 2011, use the best  available scientific information, monitoring, models,
   methods,  and analyses to support air-program-related guidance, policy decisions,
   and  accountability. Through the Clean Automotive Technology program,  EPA and
   industry partners will demonstrate cost-effective engineering  vehicles using  cost-
   effective ultra clean and fuel efficient automotive technology as follows:

      Strategic Targets:

      •  By  2011, demonstrate that the fuel economy of sport utility  vehicles, urban
         delivery vehicles, refuse trucks, and buses  can be cost-effectively improved
         by 60 percent over the 2001 baseline.

      •  By 2011, demonstrate that the fuel efficiency of automotive gasoline engines
         can be cost-effectively improved by 15 percent over the 2001 baseline.
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      •   By 2011, technologies developed under the Clean Automotive Technology
          program will be in two percent of the new light/medium duty trucks sold.

   NACEPT SA Comments
   This goal seems very timid. If the technology diffusion objective for Clean Automotive Technology
   technologies is only 2% in 2011, how long will it take for this technology to diffuse into a significant
   fraction of the national light/medium  truck fleet?  There is no corresponding objective to move
   technology into the automotive gasoline engines? What about non-road gasoline engines?

   Also, where are we now (2006) in relation to the 2001 baseline?

   NACEPT SP Comments
   On further  review, this goal seems even more timid than NACEPT first thought. If the technology
   diffusion objective for Clean Automotive Technologies is only 2% of new vehicles sold by 2011, then
   98% of new vehicles sold in 2011 will be lacking clean technologies.

   Sub-objective 1.6.2:  Conduct  Air  Pollution Research.  Through 2011,  achieve
   progress   toward  reducing  uncertainty  in  standard   setting  and   air  quality
   management  decisions   through advances in understanding in the air pollution
   sciences  and achieve progress in  assessing source to health linkages by reducing
   uncertainties in these linkages.

   Strategic  Targets:

   -—Progress toward  reducing uncertainty  in the  science that  supports standard
      setting and air quality  management decisions.  Success is defined by an external
      expert review to measure the utility  of the data, tools, and technologies for key
      Agency  decisions (metric  to   be  established  in  consultation  with external
      reviewers; measurement methodology still under development).

   •—Progress in  assessing  the  linkage  between health  impacts and air pollutant
      sources and reducing  the  uncertainties that  impede the  understanding  and
      usefulness of these linkages.—Success is defined by an external expert review
      process to measure the utility of the data, tools, and technologies for key Agency
      decisions  (metric  to  be established in consultation with external  reviewers;
      measurement methodology still under development).

   NACEPT SA Comments
   Many science-related targets make reference to consultation with external reviewers, but do not give a
   timeline  for  completion  of  this  review and for  development  of metrics and  measurement
   methodologies. It would seem that EPA has had adequate time to conduct these reviews since this is
   the third generation Strategic Plan.

Means and Strategies for Achieving Objective 1.6

   EPA's science and research efforts are designed to provide the  best  information
available  to  support  our policies  and  regulations.  First,  we  identify the  research
necessary to develop the quality information  and tools we  need for decision-making,
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standard-setting, and implementation work.  Once these scientific tools are in use, we
can identify data gaps and determine our needs for further research.  Progress toward
research goals is assessed through a suite of metrics that is tailored to measuring the
impacts of the outcomes of the respective research programs. Among the measurable
factors are:   independent expert review panel ratings on the extent to which  clients
utilize EPA research products; composite scores on a client survey designed to gather
data on product utility and perceptions of use;  and the results of bibliometric  and/or
client document analyses demonstrating the actual  use of EPA research products.
These factors are applied to measure success in providing the results identified in the
research program below.

Science to Support Air Programs

   EPA will continue to  use sound science to determine the  relative risks that air
pollution poses to human  health and the environment; identify the best means to detect,
abate, and avoid environmental problems associated with air pollutants; and evaluate
the effectiveness of control  programs  in reducing exposure to harmful levels of air
pollution. The Agency will base its efforts to reduce environmental  risks  on the  best
available  scientific  information  and  will   continue  to   integrate  critical  scientific
assessment with policy,  regulatory, and non-regulatory  activities.  Science  activities
related to air quality fall  into three  broad categories: (1) risk assessment,  (2) program
development and assessment, and  (3) technology development and assessment.

Exposure and Risk Assessment

   EPA conducts exposure and risk assessments  on  both criteria and hazardous air
pollutants to support our air toxics program  and to assist in  estimating the risks
associated with  exposure to criteria pollutants, such as fine particles. Our exposure and
risk assessments integrate monitoring  and  modeling  information to  characterize  the
impacts of sources  of air pollution  within the United States, as well as the impacts of
pollution  coming from outside the United  States.  We  also conduct  radiation-risk
assessments to evaluate  health  risks from radiation exposure; to determine appropriate
levels for cleaning up contaminated sites; and to develop radiation protection and risk
management policy, guidance, and  rules.

Program Development and Assessment

   Using mathematical models, EPA works  with states and tribes to evaluate control
options, control  plans, the impacts  of alternative emission scenarios, and the effect of
federal rules. EPA's Acid  Rain program uses  deposition  models  to evaluate  our
allowance trading program and  to support the National Acid Precipitation Assessment
Program, which coordinates  federal acid deposition  research.  In addition, we use
mathematical models, ambient monitoring information, and other data to determine the
effectiveness of control strategies.
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Technology Development and Assessment

   Developing  and  assessing  innovations  in  environmental  protection  is another
important aspect of EPA's clean air program. Through its Clean Automotive Technology
program, EPA will continue to develop advanced clean and fuel-efficient  automotive
technology. We will  collaborate with  industry partners to transfer  the unique  EPA-
patented,  highly-efficient  hybrid  engine and  power-train  components,  originally
developed  for  passenger  cars, to meet the more demanding  size, performance,
durability, and towing requirements of sport utility and urban delivery vehicles, without
compromising performance, safety,  or reductions in emissions.

   EPA is committed to  common-sense,  cost-effective solutions that result in cleaner
air. To control air toxics reasonably and effectively, EPA will continue to evaluate control
technologies to ensure that they are protective, cost-effective, and commercially viable.

   Effectively using partnerships is a key aspect of our approach to  sound science.
Under a joint  effort  on air quality  forecasting,  for example,  EPA and the  U.S.
Department of Commerce's  National Oceanic and Atmospheric Administration (NOAA)
are combining their expertise in air quality, atmospheric measurements, and modeling
to develop a  consistent,  national numerical air quality model for short-term air quality
forecasts for  ozone and PM. We are contributing our national collection, analysis, and
distribution of ambient air quality (our AIRNow program) and emissions  data; air quality
modeling; and detailed research analysis of air quality impacts on human health. NOAA
brings expertise  in  operational  meteorological modeling, air  quality research, and
product development and  distribution.  In addition  to  partnerships with  other  U.S.
agencies, EPA also works with partners in the international science community to better
understand flows of pollutants into and out of the United States and to assess potential
mitigation strategies.

Research

   The Air Research Program is driven by information needs to set and implement the
National Ambient Air Quality Standards (NAAQS), with additional impetus provided by
the need to  ensure  that EPA,  states, tribes, and  localities are  adequately  reducing
residual risks associated with exposure to  hazardous air pollutants (air toxics).  This
program will produce  measurable benefits in the form of:

   •  reduced uncertainty in the science  that supports standard-setting and air quality
      management decisions; and
   •  reduced  uncertainty  in the linkages between health  impacts and air  pollutant
      sources in order to fully appraise their relevance.

   The Program relies on research conducted at EPA Laboratories, through extramural
grants (including  five   Particulate  Matter  Research Centers),   and by co-funded
partnerships  (e.g. with NIEHS and  HEI). EPA has established two strategic targets  to
achieve our research sub-objective. The means and strategies to achieve these targets
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fall  into the following three  main categories designed  to move the program  toward
achieving the benefits stated above:

      1. Data and tools to support implementation of the NAAQS. Planned research
   will increase the capabilities of EPA, states, and tribes to design effective strategies
   for meeting the NAAQS. This includes new and updated data and new methods and
   models to characterize and estimate source emissions. Enhanced air quality  models
   will  incorporate more accurate  meteorological effects  and increased  ability  to
   forecast air quality changes,  improving the ability to alert the public about episodes
   of adverse air quality. Advances in receptor-based models will more  accurately
   identify which source categories contribute to ambient concentrations, providing the
   basis for  targeted control strategies.  Work  will  also  investigate technologies  to
   address multiple pollutants from  key sources contributing to non-attainment or  air
   toxics problems.

        2. Improving our understanding of the health effects associated with exposure
   to ambient PM. Together with HEI and other research partners EPA is undertaking a
   systematic evaluation of PM attributes that will expand our understanding  of how
   they are related to a  range of health outcomes across a  range of endpoints (e.g.
   pulmonary,   cardiovascular,   immunological,  neurological,   reproductive  and
   developmental).

      3. Research to advance understanding of  the links between sources and effects
advances  the state of air pollution science  to enable health effects to be linked more
strongly to specific source types and PM attributes, the major theme of the 5-year PM
centers program.

Human Capital

   One human capital challenge is the existing  shortage of qualified on-board  staff to
implement new requirements such as the Clean Air Interstate Rule and the  Energy
Policy Act  of 2005. For example,  to implement CAIR, EPA has determined that
additional  staff  is  needed  in   the  areas  of emissions  measurement,  engineering
technology,  environmental  assessment, and computer database  development and
administration. Similarly, the  Energy Policy Act of 2005 requires the development of a
national renewable fuel standard (RFS), followed by the promulgation of regulations to
implement the RFS. Developing these regulations will  require staff with expertise in
renewable fuels,  vehicle testing, refinery modeling,  transportation modeling and life-
cycle analysis, energy security impacts, and economic analyses.

   In other areas, EPA has been able to  recruit and retain top talent with the needed
scientific and technical backgrounds. For example, the EPA National Vehicle and Fuel
Emissions Laboratory and the CAT program have both been able to attract high quality
engineers and  scientists.  Cooperative agreements are in  place with several top
engineering colleges to help with recruiting.
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Performance Measurement

   EPA has made great strides in improving measures of Clean Air and Global Climate
Change achievements  so that  they  focus  on environmental results.   The  annual
performance goals (APGs)  and measures under the Clean Air  and Global Climate
Change programs  are  closely aligned  with the long-term  strategic  targets.    EPA
monitors the progress toward strategic objectives and targets through a series of annual
performance goals. The APGs focus  on environmental  outcomes and action-oriented
outputs achieved by the integrated efforts of EPA, its state and tribal partners, and the
regulated community.  Several APGs, established  in the Agency's Annual  Plan and
Budget  and reported on  in EPA's annual  Performance and Accountability Report,
directly track and measure the strategic  targets. For instance, the APGs for reductions
in the population-weighted ambient concentration of ozone and PM 2.5 programs set
annual targets related to the strategic targets.  As another example,  there are annual
measures that  directly  track  strategic  targets for  the  number of people taking  all
essential actions to reduce  exposure  to indoor environmental asthma and  number of
schools implementing an effective indoor air quality management plan.

   For the  research  sub-objective, EPA will track  annual  progress  toward expected
long-term  results  by  means of  multiple,  objective-based measures of  customer
satisfaction, product impact and quality, and efficiency.

Influence of Environmental Indicators and PART Measures on the Strategic Plan

   EPA has aligned  its  strategic and annual  measures under  Goal  1  with  the
environmental indicators to be included in the forthcoming Report on the Environment.
Environmental  indicators  reflected  in the Strategic Plan  include trends  of national
ambient concentrations and emissions of  criteria air  pollutants (and their  precursors)
such as ozone  and fine particulate matter), mercury  point-source emissions, ambient
levels of stratospheric chlorine (which can deplete  the ozone  layer), and greenhouse
gas emissions.

   EPA has included in this  Strategic Plan all the Clean Air and Global Climate Change
long-term,  outcome-oriented  measures developed  through  the  federal  Program
Assessment Rating Tool  (PART)  assessments as strategic targets.   These  targets
include the population-weighted ambient concentration targets for ozone and PM2.5, and
the toxicity-weighted risk reduction goals for air toxics. Improved strategic targets were
also developed for the radiation program  during  the PART assessment process.

Future Improvements to Performance Measurement

   While considering revisions and improvements for developing this Strategic Plan, the
Agency also examined some of the longer-term opportunities to make improvements in
the expression of our outcome measures for future plans. With respect to Goal  1, EPA
is continuing to work on the development  of long-term measures  that capture the
environmental benefits of  the air and  climate change programs.  One example is the
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Agency's work to directly measure the benefits of  reduced ultraviolet exposure on
human health.

CLOSING THE FEEDBACK LOOP: RESULTS OF PERFORMANCE ASSESSMENTS
AND PROGRAM EVALUATIONS

Ambient Air Quality Program

   In  the PART evaluation of the  Acid Rain program, OMB recommended  that EPA
work to: (1) overcome statutory limitations that set maximum emission reduction targets
and  limit the scope  of  emissions trading  and  program  benefits,  and (2) develop
efficiency measures based on the full cost of the program. The first recommendation is
addressed by promulgation of the Clean Air Interstate Rule, which is projected to reduce
S02 and NOx emissions  beyond Title IV and uses a cap-and-trade approach modeled
after the Acid Rain  program.  EPA is  addressing the second  recommendation by
developing data and methods to support efficiency measures that incorporate industry
as well as EPA costs.

   The  National Academy  of Sciences (NAS) evaluated the nation's air quality
management system™  and  concluded  that  while  emitted  pollutants have been
substantially reduced  over the  past 30 years, further  progress is hindered by scientific
and technical limitations in the current system. To address  some of these issues, EPA
is: (1) developing  air quality-ecosystem  indicators for the  future tracking of trends in
human exposure  and ecological condition,  (2) exploring  opportunities to  co-locate
ambient air monitoring and atmospheric deposition monitoring with long-term ecological
research study sites, and (3)  improving methods for monitoring atmospheric inputs,
such as ambient mercury concentrations and mercury deposition, to ecosystems. EPA
also  is working to develop and  expand the use of high order health and  ecological
indicators, and on characterizing the movement of air pollutants through ecosystems
overtime.

Indoor Air

   In  the indoor air  arena, OMB's PART assessment has led the program to better
quantify the  relationship between funding levels and  results, improve transparency by
making  state radon  grantee  performance data easily accessible to the public, and
improve the program's efficiency  measures to more clearly  demonstrate the cost
effectiveness of the program.

Mobile Source - Clean Air Technology (CAT) Program

   As a result of its 2005 PART evaluation, the CAT program is working to develop two
efficiency measures:  one for comparing the CAT program to  similar efforts at other
agencies,  and another  to  relate  a  technology's  fuel economy improvements  to
greenhouse gas reductions.
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Research

   In 2005, the Board of Scientific Counselors (BOSC), a public advisory committee
chartered under the Federal Advisory Committee Act) evaluated the Particulate Matter
and Ozone Research Program and made specific recommendations for improvements.
xv"  Specifically, the BOSC recommended wording for long-term  measures as well as
recommended  periodic assessment of customer satisfaction.  Recommendations were
incorporated into the 2005 PART evaluation of the  NAAQS Research Program.  EPA
has identified actions  and milestones to meet this need.  The long-term measures are
reflected  in the discussion of measurable benefits for research under the Means and
Strategies section.  These measures will be incorporated in an  upcoming revision of
EPA multi-year plan for air research. The multi-year plan complements the  Strategic
Plan  by  providing a  more  specific  air  research   plan  and  will   address the
recommendations of the BOSC, PART, and NRC reviews.

   A committee of air pollution experts formed under the  National Academy of Sciences
National Research Council (NRC) completed a series of reports in  2004 and made three
specific recommendations concerning the management of scientific research:

   •  EPA should  work toward a higher  level of sustained integration and interaction
      among the scientific disciplines and among the full range  of public and private
      research funding organizations.

   •  Research is needed  to develop stronger tools to compile and synthesize the
      large amounts of new information being developed in this research program.

   •  Sustained  and substantially enhanced  management of this program  by EPA,
      accompanied by a  continuing mechanism for independent  review and oversight
      of  the program, will be the only  way to ensure that this investment  is  being
      soundly  made.

Emerging Issues and External Factors

   The current, fundamental imbalance  between  energy supply  and energy  demand,
and the impacts of that  imbalance throughout the  economy, is debatably the most
significant environmentally-related issue that has emerged since the issuance  of EPA's
2003-2008 Strategic Plan. The convergence of  concerns  around energy supply,
economic  prosperity,  national security, and the environment  present  unprecedented
opportunities for technological innovation  in  the marketplace. EPA will be impacted as
the nation moves forward  to address these key energy challenges:  using energy more
efficiently, increasing domestic energy supplies, modernizing the  energy infrastructure;
and, ensuring that public health and the environment are protected.

   Higher and/or more volatile energy prices will create pressures  affecting air quality
programs  and  goals.  EPA's  role  in  supporting  the  development  of  renewable
transportation fuels such as ethanol will increase, and the Agency will need to ensure
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smooth implementation of renewable fuels programs—including those required under
the Energy Policy Act of 2005. As these trends in energy prices  increase the pace of
turnover of capital stock in the energy sector, there will be greater interest in new and
more efficient technologies—many of which  could  have  a positive impact  on air
quality—and the Agency will need to work with industry to encourage the development
of these technologies in all  sectors (e.g., transportation,  electricity production and end-
use).  For example, demand for domestic coal  resources will likely increase,  and EPA
will need to work with the Department of Energy, coal producers,  and others to ensure
that advanced new coal technologies such as integrated gasification combined cycle (or
coal gasification with carbon capture  and  sequestration,  more  broadly)  that have
extremely low air emissions will continue to develop and that we can encourage their
diffusion throughout the marketplace. Finally, we also will need to continue to look for
opportunities  to streamline energy permitting  so that we can both achieve our clean air
goals, and expeditiously build the energy infrastructure our country needs.

   Another challenge comes  from growing levels of emissions in other countries that
threaten to affect progress within the United States and impact our ability to achieve our
public   health and environmental standards.  The  impacts  of   international  and
intercontinental  transport  are  already  being observed,  and  as  energy   use  and
development  increases rapidly in regions such as Asia, there is the potential for critical
impacts in the United States. Efforts to decrease emissions in developing countries will
not replace the  need to continue to reduce  air pollution  emissions  within the United
States.  Instead,  international efforts are needed to  complement our  local and regional
control efforts, to protect public health and our domestic investments. Thus, to achieve
our own domestic  policy goals,  we will  have  to better understand the  impact  of
emissions sources in other  countries on environmental quality and public health in the
United  States and, when  appropriate, work cooperatively  with other countries  to
decrease these emissions.

   Recent scientific studies indicate that the  stratospheric ozone  layer is likely to  take
longer to heal than previously anticipated.XVI" More people will be exposed to excess UV
radiation over a longer time  period, and the number  of people  impacted by this
exposure will increase. This means that timely, comprehensive action by all nations,
including the  United States, is more important than  ever in order to achieve restoration
of the ozone layer.

   There are a number of external factors that could affect achievement of our strategic
goals. State,  local, and  tribal implementation of air programs is necessary for achieving
many  of the clean  air  performance  targets,  but reduced budgets  and  resource
constraints could impede their ability to carry out environmental programs.  Lawsuits and
court action might require the Agency to adjust schedules and could delay achievement
of critical  milestones.  Achievement of  clean air objectives  can  also  be affected by
economic conditions and development patterns in the United States and the world, and
by choices made for energy and transportation policies.
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    Weather conditions and  meteorological  patterns have very important  effects on air
quality.  For example,  high temperatures and bright sunlight can increase the formation
of ozone. Wind can carry air pollution from one area to another, while conditions of  little
or  no wind  can  cause air pollutants to  remain  in  an area and  build up to  unhealthy
levels. These effects must be considered when developing and implementing  plans  and
strategies to achieve and maintain clean air.

Notes
i.U.S. Environmental Protection Agency. March 2006. Air Emissions Trends - Continued Progress
Through 2005. Available online at http://www.epa.gov/airtrends/2006/econ-emissions.html: EPA Office
of Air and Radiation Web Site. Date of Access: April 26, 2006.

ii.Clean Air Act, Title I, Section 112. Available online at http://www.epa.gov/air/caa/caa 112.txt: EPA
Clean Air Act Web Site. Date of Access: April 26, 2006.

iii.U.S. Environmental Protection Agency. 1987. The Total Exposure Assessment Methodology (TEAM)
Study: Summary and Analysis: Volume I. EPA 600-6-87-002a. Washington, DC: GPO.

iv.U.S. Environmental Protection Agency. 1989. Report to Congress on Indoor Air Quality, Volume II:
Assessment and Control of Indoor Air Pollution. EPA 400-1-89-001C. Washington, DC: GPO.

v.U.S. Environmental Protection Agency. 1987.  Unfinished Business: A Comparative Assessment of
Environmental Problems. EPA 230287025a. Washington, DC: GPO.

vi.U.S. Environmental Protection Agency, Science Advisory Board. 1990. Reducing Risk: Setting
Priorities and Strategies for Environmental Protection. EPA-SAB-EC-90-021. Washington, DC: GPO.

vii.    Florida Center for Public Management. September 1995. Comparing Florida's Environmental
       Risks: Risks to Florida andFloridians. Tallahassee. Available online at
       http://www.pepps.fsu.edu/FCER/final.pdf: Program for Environmental Policy and Planning
       Systems Web Site, Institute of Science and Public Affairs, Florida State University. Date of
       Access: April 26, 2006.

       California Comparative Risk Project. May 1994. Toward the 21st Century: Planning for the
       Protection of California's Environment. Berkeley: California Environmental Protection Agency,
       Office of Environmental Health Hazard Assessment. Available online at
       http://www.oehha.org/multimedia/comprisk.html. Date of Access: April 26, 2006.

viii.United Nations Environment Programme. 2002. Scientific Assessment of Ozone Depletion. Available
online a http://ozone.unep.org/Publications/6v_science%20assess%20panel.asp: UNEP, The Ozone
Secretariat Web  Site. Date of Access: April 26, 2006.

ix.American Cancer Society Inc. 2006. Cancer Facts and Figures: 2006.  No. 500806. Available online at
http://www.cancer.org. Date of Access: April 26, 2006.

x.Prevent Blindness America. 2003. Cataract Fact Sheet, FS32. Available online at
http://www.preventblindness.org/resources/factsheets/CataractsFS32.PDF. Date of Access: April 26,
2006.
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xi.United Nations Environment Programme. The Montreal Protocol on Substances that Deplete the
Ozone Layer, as adjusted Beijing 1999. Nairobi, Kenya. Available online at
http://ozone.unep.org/pdfs/Montreal-Protocol2000.pdf: UNEP, The Ozone Secretariat Web Site. Date of
Access: April 26, 2006.

xii.Clean Air Act, Title VI. Available online at http://www.epa.gov/air/caa/title6.html:  EPA Clean Air Act
Web Site. Date of Access: April 26, 2006.

xiii.U.S. Environmental Protection Agency, Office of Air and Radiation. 1999. The Benefits and Costs of
the Clean Air Act 1990-2010, EPA Report to Congress. EPA-410-R-99-001. Washington, DC: GPO.
Available online at http://www.epa.gov/air/sect812/1990-2010/chapl 130.pdf Date of Access: April 26,
2006.

xiv.United Nations Environment Programme. 2002. Scientific Assessment of Ozone Depletion. Available
online at http://ozone.unep.org/Publications/6v_science%20assess%20panel.asp: UNEP, The Ozone
Secretariat Web Site. Date of Access: April 26, 2006.

xv.UV irradiance has increased since the early 1980s by 6 to 14 percent at more than 10 sites distributed
over mid- and high latitudes of both hemispheres. Information from: United Nations Environment
Programme. 2002. Scientific Assessment of Ozone Depletion. Available online at
http://ozone.unep.org/Publications/6v_science%20assess%20panel.asp: UNEP, The Ozone Secretariat
Web Site. Date of Access: April 26, 2006.

XV1 National Research Council of the National Academies. 2004. Air Quality Management in the United
States.  Available online at: http://fermat.nap.edu/books/0309089328/html. Date of Access: April 26,
2006.

xvu The BOSC report can be found at http://www.epa.gov/osp/bosc/pdf/pm0508rpt.pdf EPA's response
can be  found at http://www.epa.gov/osp/bosc/pdf/pm0602resp.pdf Date of Access: April 26, 2006.

xvm New York Times, December 7, 2005, Scientists Say Recovery of the Ozone Layer may take Longer
Than Expected, Kenneth Chang. Available online at:
http://www.nvtimes.com/2005/12/07/science/07ozone.html?ex=1291611600&en=6e8ca9c8549a6f6b&ei
=5090&partner=rssuserland&emc=rss. Date of Access: April 26, 2006.
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GOAL 2  - CLEAN AND SAFE WATER

Ensure drinking  water is safe.  Restore and maintain oceans, watersheds, and their
aquatic ecosystems to  protect  human health,  support  economic  and  recreational
activities, and provide healthy habitat for fish, plants, and wildlife.

      Since the enactment of the Clean Water and Safe Drinking Water  Acts over 3
decades ago,  government, citizens, and the private  sector have worked together to
make dramatic progress  in improving the quality of surface water and drinking water.

      Thirty years ago,  many of the nation's drinking  water systems provided water to
the tap with very limited treatment.  Drinking water was too often the cause of acute
illnesses linked  to  microbiological contaminants  or  of longer-term  health problems
resulting from exposure to low levels of toxic and other contaminants.  Today, drinking
water systems monitor the quality of the water  they provide and treat water to ensure
compliance with  standards covering a wide range of contaminants.  In addition, efforts
to protect waters that are sources of drinking water are  helping to keep drinking water
safe.

      Thirty years ago, about two-thirds of the surface waters assessed by states were
not attaining basic water quality goals and were considered polluted.1  Some of the
nation's rivers were open sewers posing health risks,  and many water bodies were so
polluted that swimming, fishing, and recreation were impossible.  Today, the number of
polluted waters has been dramatically reduced, and many clean waters are getting even
healthier.  A massive investment of federal,  state, and  local funds has resulted in a new
generation of sewage treatment.  More than 50  industrial  sectors now comply with
nationally consistent discharge regulations.   In addition,  sustained efforts to implement
"best  management practices" have helped  reduce runoff of  pollutants from diffuse, or
"nonpoint," sources.

      Cleaner,   safer water  has renewed recreational,  ecological, and economic
interests in communities across the nation.  The recreation, tourism, and travel industry
is one of the largest employers in the country, and a  significant portion of recreational
spending comes from swimming, boating, sport  fishing, and hunting.2  In addition,  each
year, more than 180 million people visit beaches for recreation.3

      The dramatic restoration of some of the  nation's  most polluted  waters has paid
large  dividends  in  enhanced recreation,  healthier fisheries,  and  stronger  local
economies.   Many  of the nation's best-known water pollution problem areas are
showing the results of years of restoration efforts.  The Cuyahoga River,  which  once
caught fire, is now busy  with boats and harbor businesses.  Oregon's Willamette River
has been  restored  to provide swimming, fishing, and  water  sports.   In  Boston, the
Charles River, once badly polluted,  is increasingly recognized as a place for boating
and related recreation.


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      Despite numerous improvements in the quality of water, serious water pollution
and drinking water problems remain in certain areas.  Population growth continues to
generate higher levels of water pollution and places greater demand on drinking water
systems. Continued progress toward clean waters and  safer drinking water will require
that the country  maintain its commitment to the  core  programs that have  proven so
effective in the past and implement partnership approaches to improve water quality
and protect human health.
OBJECTIVE 2.1:  PROTECT HUMAN HEALTH.  Protect human health by reducing
exposure to contaminants in drinking water (including protecting source waters),  in fish
and shellfish, and in recreational waters.

      Sub-objective 2.1.1: Water Safe  to  Drink.  By 2011,  9§ 91. percent  of the
      population served by community water systems will receive drinking water that
      meets  all applicable health-based  drinking water  standards through effective
      treatment and source water protection.  (2005  Baseline:  8§r£ 89  percent ef-
      population served by community water systems meeting all applicable  health
      based drinking water standards.)

            Strategic Targets:

      »  By 2011, community water systems will provide drinking water that meets all
         applicable  health based drinking  water standards during  97%  of person
         months (i.e.,  all  persons  served  by  community water systems  times  12
         months).  (2005 Baseline: community water systems provide drinking  water
         that  meets  all applicable  health-based  drinking water standards   during
         95.17% of person months.)

      •  By 2011,  9§  90  percent of community water systems will  provide drinking
         water  that meets  all applicable  health-based  drinking water  standards
         throughout the year.   (2005  Baseline: 89r2- 89  percent of community water
         systems  provide  drinking  water  that meets all applicable  health-based
         drinking water standards throughout the year.)

      •  By  2011, 9§  86 percent  of the  population  in  Indian  country  served  by
         community water systems will receive drinking water that meets all applicable
         health-based  drinking  water standards  throughout the year.  (2005 Baseline:
         8§r3 86 percent of population in Indian country  served by community water
         systems  received drinking water  that meets  all applicable  health-based
         drinking water standards throughout the year.)

         NACEPT SP Comments
         Both the 2005 baseline and the 2011  goal are now 86 percent.  Is it really the Agency's
         intended goal to make no progress in this area?

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       •   By 2011, minimized risk to public health through source water protection will
          be achieved for 80 50  percent of community water  systems and for  an
          associated  80 62  percent  of  the  population  served  by community water
          systems (i.e., "minimized risk" achieved by  substantial  implementation,  as
          determined by the state,  of sourcewater protection actions in a source water
          protection  strategy).   (2005  Baseline:  20  percent  of  community  water
          systems; 28r4 28  percent  of  the  population  served  by community water
          systems.)

       NACEPT SA Comments
       How does this risk-based objective relate to the prior targets related to health-based drinking
       water standards?  Is the Agency suggesting that 15% to 17% of community water supplies will
       present public health risks even when they are in fall compliance with health-based drinking
       water standards?

       NACEPT SP Comments
       The revised goals of 50% systems and 62% population are substantial retreats from the original
       goals of 80% systems and 80% population, vet the 2005 baselines were deemed correct. What is
       the justification for the substantial  retreat?

       •   By 2015, in coordination with other federal agencies, reduce by 50 percent
          the number of homes on tribal lands  lacking access to safe drinking water.
          (2003 Baseline:  Indian Health Service data indicate that 12 percent of homes
          on tribal lands lack access to  safe drinking  water [i.e., 38,637 homes lack
          access].)

       NACEPT SA Comments
       Prior target is 95% of population in tribal communities will receive drinking water meeting
       health-based standards by 2011.  This target is 94% percent of homes having access to safe
       drinking water by 2015.  Assuming that homes have constant number of occupants, this target
       appears to retreat from the 2011 target.

       NACEPT SP Comments
       The population target has been revised to state that 86% of population in tribal communities
       currently receives drinking water meeting health-based standards and that the Agency intends to
       make  no additional progress by 2011.  How does this target of 94% of homes having access to
       safe drinking water by 2015  relate to the prior goal of no additional progress from 86% of
       population having access to safe water?

       Sub-objective 2.1.2: Fish and Shellfish Safe to Eat.   By 2011, reduce public
       health risk and allow increased consumption of fish  and shellfish,  as measured
       by the strategic targets described as follows.
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             Strategic Targets:

      •   By 2011, reduce the  percentage  of  women of childbearing age having
          mercury  levels in blood above the level of concern  from 5.7 percent to 4.6
          percent.  (2002 Baseline:  5.7 percent of women of childbearing age have
          mercury blood levels above levels of concern identified by the National Health
          and Nutrition Examination Survey [NHANES].)

      NACEPT SA Comments
      Because geographical population variations, consumer education and choices have substantial
      impacts on consumption of mercury-contaminated fish, changes in the national percentage of
      women with elevated blood mercury levels is not a valid indicator of changes in mercury levels in
      fish and shellfish. A more direct and reliable indicator would be actual fish tissue mercury levels.

      •   By 2011, maintain or improve the  percentage of state-monitored shellfish-
          growing acres that are approved or conditionally approved for use that are
          impacted  by  anthropogenic  sources  that are  approved  or conditionally
          approved for use.  (2003 Baseline: 65 to 85 percent [estimated] of 16.3 million
          acres of state-monitored shellfish-growing acres impacted by anthropogenic
          sources are approved or conditionally approved for use:  EPA estimates that 2
          to 20 percent of the total 1990 baseline of  17,157,000 acres of classified
          estuarine  shellfish waters  impacts are   impacted   by  non-anthropogenic
          sources.)

      NACEPT SA Comments
      Neither a baseline nor measurable targets have been identified.

      NACEPT SP Comments
      The newly provided baseline data indicates that the number of state-monitored shellfish-growing
      acres decreased by 5% between 1990 (17.157.000 acres') and 2003 (16.300.000 acres'). Does this
      reflect a reduction in the usable  shellfish-growing acres  nationwide  or a reduction in state
      monitoring coverage?  What percentage of the usable shellfish-growing  acres  is adequately
      monitored through state monitoring programs and does the Agency have appropriate objectives to
      ensure monitoring coverage? Since as much as 35% of shellfish acres impacted by anthropogenic
      sources were not approved  for use  in 1990. a  strategic target of no improvement  seems
      particularly unambitious.

      Sub-objective  2.1.3: Water  Safe for Swimming.   By 2011, the  number  of
      waterborne disease outbreaks attributable to swimming in or other recreational
      contact with coastal and Great Lakes waters will be maintained at two, measured
      as a 5-year average.  (2005 Baseline:  an annual average of two recreational
      contact waterborne disease outbreaks  reported  per year  by the Centers  for
      Disease Control over the years 1998  to 2002;  adjusted to remove outbreaks
      associated with waters other than coastal and  Great Lakes waters and other than
      natural surface waters [i.e., pools or water parks].)
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            Strategic Target:

•  By 2011, maintain the percentage of days of the  beach season that coastal and
   Great Lakes beaches monitored by state beach safety programs that are open and
   safe for swimming at 96 percent.  (2004 Baseline: beaches open 96 percent of the
   584,150 days of the beach  season  [i.e., beach season  days =  3,574 beaches
   multiplied by variable number of days of beach season at each beach.)

      NACEPT SA Comments
      It is unclear why Sub-objective 2.1.3 is based on one measurable, but the associated strategic
      target is based on a different measurable.  The term "By 2011. implies that the sub-objective and
      target will be achieved in 2011, but not necessarily in the intervening years.

Means and Strategies for Achieving Objective 2.1

Water Safe to Drink

      Safe drinking water is critical to protecting  human health.  More than 280 million
Americans  rely on the safety of tap water provided by water systems that comply with
national drinking water standards.4   EPA's  strategy for ensuring safe drinking water
over the next several years includes six key elements:

•  Developing or revising drinking water standards.
•  Supporting  states, tribes, and water systems  in implementing  programs to improve
   compliance with drinking water standards.
•  Promoting sustainable management of drinking water infrastructure.
•  Preventing  contamination  of surface water and ground water that is  a source of
   drinking water.
•  Strengthening security at drinking water systems.
•  Increasing access to  safe drinking  water on tribal lands.

Drinking Water Standards

      The  Safe Drinking Water Act (SDWA) directs EPA to establish national standards
for contaminants in drinking water provided to consumers by water systems.  Under the
Safe Drinking Water Act, EPA sets national  standards that reduce public health risks
based  on  rigorous  technical and  economic  analysis and sound  science, including
contaminant occurrence data,  health effects  studies,  and  research on treatment
technology efficacy.

      Over the  past   30  years,  EPA  has  established  standards for  some  91
contaminants.  Most recently, the Agency  issued enhanced standards for the microbial
pathogen cryptosporidium and disinfection byproducts (December 2005).  EPA plans to
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establish additional standards that address microbial contaminants for water systems
that use ground water.
      Over the next several years,  EPA will conduct  the  second  6-year National
Primary Drinking Water Rule Review.  Where there is  adequate information, EPA will
determine whether revision of an existing standard is warranted.   Through 2011, EPA
will continue to assess the  need for new  drinking  water standards.   Based  on
recommendations from  the  National Research Council,  the  National Drinking  Water
Advisory Council, and other stakeholders,  the Agency will evaluate health effects data
and risks of exposure to contaminants; gather information on technologies that prevent,
detect, and remove contaminants; and evaluate compliance costs.

Compliance with Drinking Water Standards

      EPA will  work closely with states, tribes, and owners and operators of municipal
water systems  to move  toward  the goal  of 91  percent  of the population  served by
community water systems providing water meeting health-based standards by 2011.
For water systems that meet drinking water standards, EPA will emphasize  actions to
maintain compliance.  EPA  will also emphasize the  need to return water systems to
compliance when they fail to meet standards and prepare water systems to comply with
new regulations, such  as  the recent  rules  for  cryptosporidium  and  disinfection
byproducts.

NACEPT SP Comments
The above paragraph should reflect that the goal  here is that 91 percent of the population served by
community water systems receives water meeting health-based standards, not that the population provides
water.

      EPA and states, 49  of which  have primary enforcement  authority for health-
based  standards under the  Safe Drinking Water Act,  are  partners  in ensuring water
system  compliance.   States carry out an array of activities such as onsite sanitary
surveys of water systems and working with small systems to improve their  technical,
managerial,  and financial capacity.   EPA carries out key actions  to  help improve
compliance rates:

   •  Provide guidance, training, and technical assistance.
   •  Ensure proper certification of water system operators.
   •  Promote  consumer awareness of the safety of drinking water.
   •  Maintain  the rate of system sanitary surveys and onsite reviews.
   •  Cooperate with the Office of Enforcement and Compliance Assurance  to identify
      noncompliance and take appropriate action.

NACEPT SP Comments
The last bullet above implies that OECA is an entity external to the Agency. The bullet should be revised
to indicate that identifying noncompliance and taking appropriate action is a key activity internal to the
Agency, for which it is responsible.

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         Small community water systems are more likely to have difficulty complying with
   drinking water standards.  Many of these systems serve people with low incomes and
   are located in rural areas.  In addition, water systems serving tribal areas, Pacific Island
   Territories,  Alaska Native villages, and  communities along the Mexico border  face
   special challenges in providing safe water.

Improving Tribal Drinking Water System Compliance

      The rate of compliance with drinking water standards by water systems on tribal lands (86 percent
in 2005) lags behind nationwide compliance rates (89 percent in 2005). In addition to their often-small
size and rural locations, tribal water systems face other significant challenges, including limited resources
for source water protection.  EPA is taking key steps to maintain or improve  tribal water system
compliance:

•  Develop quick reference guides that tribes can use to assist in complying with drinking water
   regulations.
•  Promote watershed protection on tribal lands and implementation of source water protection plans.
•  Continue to directly implement the Public Water System Supervision and Underground Injection
   Control programs on tribal lands.
•  Participate in an interagency effort encouraging use of available funds to improve tribal access to safe
   drinking water.
         To  support these  communities,  EPA  will provide  training and assistance
   addressing the use of cost-effective treatment technologies, proper waste disposal, and
   compliance with standards for high-priority contaminants, including arsenic in drinking
   water and microbes,  disinfectants,  and disinfection byproducts.  EPA will also continue
   efforts to partner with states to address the underlying need to strengthen the  technical,
   managerial, and financial capacity of small systems.

         The Safe Drinking Water Information System serves  as the  primary  source  of
   information on  compliance with  all Safe Drinking Water Act requirements.  EPA will
   continue to work to ensure that all applicable drinking water regulatory requirements are
   incorporated into this data system to help states and authorized tribes manage their
   drinking water programs. EPA will also continue to work with states, tribes, and others
   to improve data completeness, accuracy, timeliness, and consistency.

   Sustainable Drinking  Water Infrastructure

         Providing drinking water that  meets public health standards  often  requires an
   investment in the construction or maintenance of infrastructure.   The Drinking Water
   State Revolving Fund (DWSRF) provides water systems with low-interest loans to make
   infrastructure improvements.

         Even with financial assistance from the DWSRF, the Agency's September  2002
   report  on  the   infrastructure "gap"  identifies  a  multi-billion-dollar  gap  in  capital

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infrastructure  financing  over the  next 20 years.5   EPA  will continue  to  provide
infrastructure grants to capitalize state DWSRFs to support needed infrastructure.  EPA
will also work with  states to ensure that DWSRF  funds  are  effectively managed, and
with water  system  owners and operators  to  encourage  them to  adopt sustainable
management systems.

NACEPT SP Comments
EPA has already done substantial work in smart growth strategies that integrate community and economic
development,  and should use this exemplary work to encourage adoption of sustainable management
approaches by water and wastewater utilities.

Further. EPA should look beyond simply encouraging adoption of sustainable management systems and
explore potential incentives that make sustainable management the preferred approach. In response to a
charge from EPA's Office of Water. NACEPT's  Sustainable Water Infrastructure Workgroup will
explore opportunities to create sustainability incentives in the  DWSRF and CWSRF programs and
elsewhere, as part of its research and advice on sustainable watersheds.

Sources of Drinking Water

       There is  growing recognition that protecting the quality  of sources  of drinking
water, including  surface waters  and ground water, can reduce violations  of drinking
water standards. EPA will support protection of drinking water sources through training
and technical assistance to states,  tribes,  and communities that are  taking voluntary
measures to prevent or reduce contamination of source water.   The Agency will foster
coordination of  contamination  prevention strategies across  jurisdictions and  monitor
progress in the  adopting of strategies by water systems.  The Agency will encourage
and collaborate  with  external stakeholders to promote and  enhance source water
protection efforts.

       In a related effort, EPA will protect ground water that is  a source of drinking water
by ensuring safe underground injection of waste materials. EPA will:

    •   Continue working with states  and tribes to educate and  assist underground
       injection control well operators.
    •   Work with industry  and stakeholders to  collect and evaluate data on potential
       ground water contamination from Class  V (shallow) wells, including  agricultural
       and stormwater drainage wells and large-capacity septic systems.
    •   Explore best management  practices for  protecting  underground sources  of
       drinking water.
    •   Work  to   address emerging  underground   injection  issues  including carbon
       sequestration and disposal of drinking water  treatment residuals.

       Finally, EPA will work with states and  tribes to use  Clean Water Act authorities to
prevent contamination  of waters that serve as public water supplies and are at high risk.
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The Agency  will continue  to  actively encourage  other federal  programs  to  focus
protection efforts in source water areas.

NACEPT SP Comments
A critical component of source water protection is minimizing demand on sources through comprehensive
conservation and reuse.   As discussed in the  previous comment. EPA should require adoption of
sustainable management  practices as a condition of the DWSRF Program.  EPA should also require
assessment of indirect and redirect reuse opportunities and adoption of such opportunities wherever
feasible.  Finally, working  with the broader academic research community. EPA should invest in
scientific research and technology development  to make  reuse of secondary and tertiary effluent a
practical reality.

Water Infrastructure Security

       The President has given EPA primary responsibility for facilitating the protection
of the water sector,  including  drinking water  systems. The  Bioterrorism Act  of 2002
required  community  water systems  serving  more  than 3,300  people  to  develop
vulnerability assessments and to certify emergency response plans.

       With the compliance deadlines for  these requirements having passed and most
of this work now complete, the  focus of EPA's  water security program has  shifted from
identification of vulnerabilities to reduction of risks associated with these vulnerabilities.
The program  will provide the tools and  assistance that  the  sector  needs to  prevent,
detect,  respond  to,  and  recover from  intentional  acts  and natural  disasters.   For
example,  EPA will aggressively promote the 14 features of an active and effective water
security  program as  developed by the National  Drinking Water Advisory Council, in
addition to initiating efforts to measure progress within the sector with respect to  risk
reduction.

       EPA will also encourage mutual aid agreements within states and regions. EPA
will continue to  provide  training and exercises to  improve  the preparedness of  the
nation's water utilities.

       EPA also  will undertake two  significant initiatives:  (1) the  Water   Sentinel
program,  which will deploy and  test a contamination warning system;  and (2) the Water
Alliance for Threat Reduction, which will provide direct water security training to drinking
water utilities serving  more than 100,000 people.

       Collectively, these efforts will represent a robust  approach for  addressing  the
threats, vulnerabilities, and consequences facing the water sector.

NACEPT SP Comments
EPA should be  cautious in  describing the functionality of the proposed Water  Sentinel system.   As
currently envisioned, the Water Sentinel is not a contamination warning system, but rather an event
detection system that will alert water utilities after contamination has occurred.  EPA will need to
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substantially enhance its water security research and development effort if it wishes to develop a viable
contamination warning system.

Tribal Access to Safe Drinking Water

       The 2002 World Summit on Sustainable Development in Johannesburg adopted
the goal of reducing the number of people lacking access  to safe drinking water and
basic sanitation by 50 percent by 2015.6

       In  the  United States, EPA will  focus on providing infrastructure in tribal areas,
with the 2015 goal  of  increasing the  percentage of tribal homes with access to safe
drinking water and basic sanitation by 50 percent from 2003 levels by 2015.  EPA  will
contribute to this work through its support for development of drinking water facilities in
Indian country and Alaska Native villages, using set-aside funds from  the drinking water
State Revolving  Funds and Clean Water  State  Revolving  Funds as well  as targeted
grants.

       Other federal agencies, such as the Department of Health and Human Services,
the Department of the Interior, and the Department of Agriculture, also play key roles in
addressing this problem.  EPA is working with these agencies to develop a  coordinated
strategy for improving access to water and sanitation.

       In  addition, Mexico Border infrastructure projects,  and projects to improve water
infrastructure in the  Pacific Islands, described under Goal 4 (Healthy  Communities and
Ecosystems), will also increase access to safe drinking  water and basic sanitation.

NACEPT SP Comments
The objective stated in this Means and Strategies Section is mathematically impossible to achieve, and is
substantially different from the relevant strategic target under Sub-objective 2.1.1; Water Safe to Drink:

       •  By 2015. in coordination with other federal agencies, reduce by 50 percent the number of
          homes on tribal lands lacking access to safe drinking  water.  (2003 Baseline:  Indian Health
          Service data indicate that  12 percent of homes on tribal lands lack access to safe drinking
          water [i.e.. 38.637 homes lack access].)

While Sub-objective 2.1.1 is stated as a 50% reduction in non-attainment (12% to 6%). the sub-objective
was restated in this Means and Strategies Section to be a 50% increase in the percentage of tribal homes
having access to clean water.  Since the current baseline is 88% of tribal homes currently have access to
safe drinking water, the Sub-objective as rewritten here would require  that 132%  of tribal homes have
access to safe water by 2015.

Fish and Shellfish Safe to Eat

       Some toxic contaminants that enter water bodies  can move up the food chain
and build up to levels that make fish unsafe to eat.  States and tribes report they have
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issued fish consumption advisories for some 24 percent of river miles and 35 percent of
lake acres.7

      Shellfish also can accumulate disease-causing microorganisms  and toxic algae.
In 2003, shellfishing was prohibited in 9 percent of the acres that support shellfishing.8
EPA is working with states,  tribes, and other federal agencies to improve water and
sediment quality so all fish and  shellfish are safe to eat and to protect the public from
consuming fish and shellfish that pose unacceptable health risks.

Make More Fish Safe to Eat

      Most fish consumption advisories today are issued because of  unhealthy levels
of mercury in fish.  Although  small amounts of mercury are  discharged to waters, most
mercury in fish originates from combustion sources, such as coal-fired power plants and
incinerators, which release it  into the air. The mercury is then deposited by rainfall onto
land and water, where it is methylated  by bacteria and moves up the aquatic food web
through fish to people.

      EPA is working  to reduce releases of mercury to the  air through controls on
combustion sources.  For example,  EPA expects that by 2011,  federal market-based
and other air regulatory  programs  will reduce electric-generating unit emissions of
mercury by 10 tons from their 2000 level of 48 tons (see Goal 1 of this Strategic Plan).

      Improving water and sediment quality is another key element of the strategy for
making more fish safe to eat.  Implementation of Clean Water Act  programs will improve
water quality  by reducing  discharges from  stormwater systems, combined  sewer
overflows, and concentrated animal feeding  operations,  and by reducing runoff from
nonpoint sources.

      These water quality programs rely  on sound  scientific information concerning
individual  contaminants in fish.   In 2001,  EPA issued a criteria document under the
Clean Water Act identifying maximum acceptable  levels of methylmercury in fish tissue
and will help states and tribes adopt the  criterion into water quality standards.  EPA
expects that states and authorized tribes will begin adopting  the new mercury fish tissue
criterion in 2008.

      EPA's  methodology for calculating "human health criteria" for contaminants found
in surface waters reflects research on the human health effects of contaminants and
their potential in water to be concentrated in the food chain and to pose a greater risk to
people who consume fish.  EPA has partly recalculated the criteria for 83 pollutants and
will  be revising these criteria and  additional criteria more completely over the next
several years.
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       EPA is also working to restore the quality of aquatic sediment in critical water
bodies, with special emphasis on the Great Lakes.  In addition, EPA will use Superfund
program  authorities to restore the quality of sediment.  To reduce the potential for future
sediment contamination, EPA is working to reduce the use of polychlorinated biphenyls
(PCBs),  a  major sediment contaminant, in electrical equipment.  (See Goal 4 of this
Strategic Plan.)

       Another key element of EPA's strategy  for making more fish  safe to  eat  is
expanding  the amount  and type  of  information about  fish safety and  making  this
information available  to the  public.  EPA provides guidance  to  states and tribes on
monitoring  and issuance of fish consumption advisories. A total of 46 states and five
tribes now  follow these  guidelines,  and EPA is working to help all states and additional
tribes assess fish safety.

       A  key  public  information tool  is  the  Internet-based  National  Listing of  Fish
Consumption  Advisories.9   This Web  site  allows  states  and  tribes to  enter their
advisories  and provides the public with information about the location of advisories, the
fish that  are affected, and the number of meals or amount of fish that a  person can
safely eat.

NACEPT SP Comments
EPA lists here a number of activities aimed at making more fish safe to eat by (a) reducing the availability
of toxics for  uptake and concentration in fish, and (b) increasing public awareness offish  safety. While
all of these activities can  reasonably be expected to contribute to reduced consumption of contaminated
fish and reduced human  blood mercury levels, each of the activities is independent of the other, and
should be  expressed as a specific strategic target under Sub-objective 2.1.2: Fish and Shellfish Safe to
Eat, with its own performance measure and baseline.

Make More Shellfish Safe to Eat

       The  safety of shellfish  is managed  through a partnership of the U.S.  Food and
Drug  Administration (FDA), the Interstate Shellfish Sanitation Commission (ISSC), and
coastal states. States monitor shellfishing waters and can restrict harvesting if shellfish
are unsafe.

       Because an effective system for monitoring the condition of shellfishing waters
and limiting  public exposure  to unsafe  shellfish is  in place,  shellfish  harvesting  is
restricted in many acres of otherwise productive shellfishing waters. Restrictions can be
the result  of  poor  water quality due  to anthropogenic activity (e.g.  discharges from
sewage treatment plants), but can also be due to naturally occurring algal blooms or for
administrative reasons.

       EPA is working  through its surface water program to address anthropogenic
sources that result in closures. EPA also continues to work with states, the FDA, the
ISSC, and  the National  Oceanic and Atmospheric Administration (NOAA) to encourage

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them to improve conditions that result in an increase in the percentage of shellfishing
acres open for harvesting.

      The  ISSC,  working  with  states and  federal  agencies, has developed an
information system that uses state monitoring data to pinpoint areas where shellfishing
has been restricted.  This information system, now in operation in 13 of 22 shellfishing
states,  enables EPA and the states to identify possible sources of pollutants restricting
the use of shellfishing  waters.  This information can also be used to strengthen water
pollution control activities, including development of watershed plans, implementation of
National Estuary Program plans,  issuance or reissuance of permits to point sources,
enforcement of existing permits, and implementation of controls over polluted runoff.

NACEPT SP Comments
As discussed above with regard to fish, this section identifies a number of activities intended to address
shellfish safety. Each should be expressed as a specific strategic target under Sub-objective 2.1.2: Fish
and Shellfish Safe to Eat, with its own performance measure and baseline.

Water Safe For Swimming

      Recreational waters, especially  beaches  in coastal areas and the  Great Lakes,
provide outstanding recreational opportunities for many Americans.  Swimming  in some
recreational waters,  however,  can  pose  an increased risk of  illness as a result of
exposure to microbial pathogens.

      Beach closures  to protect the public from harmful levels of pathogens can have
significant economic impacts.  In  some  cases,  these pathogens  can  be traced to
sewage  treatment   plants,  malfunctioning septic  systems,   and   discharges  from
stormwater systems and animal feeding operations.

      EPA is implementing a three-part strategy to protect public health and the quality
of the nation's recreational waters.  The Agency will work to protect recreational water
generally, control combined  sewer  overflows (CSOs),  and  protect public  health by
working with local  beach managers to ensure proper notification of the  conditions at
public beaches along the coasts and Great Lakes.

Protect  Recreational Waters

      The first element of the strategy is broadly focused on all recreational waters.
EPA is  working with states to ensure that state-adopted  criteria  for  pathogens and
bacteria in waters designated for recreational use are current and scientifically sound.
In a related effort,  EPA has developed new analytic methods for monitoring pathogen
levels at beaches and other recreational waters.

      To protect and  restore these  waters, EPA works  with  state,  tribal,  and  local
governments to  implement the  core programs of the Clean Water Act.  For example,

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developing and implementing total maximum daily loads (TMDLs) will generally benefit
recreational waters that are  impaired.  The continuing implementation of the discharge
permit program, urban stormwater controls, and nonpoint pollution control programs will
also reduce pollution to recreational waters.

      Proper management of onsite/ decentralized sewage treatment systems is critical
to control of  pathogens and ensuring  that waters  are safe  for swimming.  EPA will
encourage state, tribal, and local governments to adopt voluntary guidelines for the
sound management of these systems and to use Clean Water Revolving Loan Funds to
finance systems where appropriate.

Control Combined Sewer Overflows

      Full implementation of controls for overflows from CSOs is another key step in
protecting recreational waters. These overflows release untreated sewage containing
high levels of pathogens. CSOs, which  occur in about 770 communities around the
country, can  have a significant  impact  on the  quality of recreational waters.   EPA,
states,  and local governments are making steady progress toward reducing overflows
under the "CSO Policy."10

      Most communities with CSOs have now implemented basic  control  measures
and 48  percent of permittees have adopted schedules for implementing Long  Term
Control  Plans for CSOs. EPA is working to complete the development of Long  Term
Control  Plans by 2011 and is monitoring the progress toward full implementation of the
controls called for in these plans.

Protect Coastal and Great Lakes  Beaches

      The third element of  the strategy to protect and restore recreational waters is
focused on public beaches along coastal  areas and the Great Lakes.   Under the
Beaches Environmental Assessment and Coastal Health (BEACH) Act, EPA provides
grants  to state, tribal, and  local governments for programs  to monitor beach water
quality and notify the public when bacterial contamination poses a risk to swimmers.

      Of the  approximately 6,000 beaches nationwide, states have determined that
some 2,756  are "significant" or  "Tier I" beaches based on expected use and  other
criteria.   EPA expects that  100  percent  of these "significant"  public beaches will be
managed under the BEACH Act  each year. EPA has set a goal that these significant
beaches will be open 96 percent of the days of the beach season.

      Finally, EPA  will continue to expand public  access to Internet-based beach
information on its Web site.  Governments receiving BEACH Act grants will provide
information  on water quality,  beach monitoring and advisory programs, and beach
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closures.   This will  provide  beach-goers with  the  information they  need to  make
informed choices.

NACEPT SP Comments
EPA lists here a number of activities aimed at ensuring swimmable waters. Programs such as the TMDL
Program and the CSP Policy are some of the largest programs in the Agency, particularly in light of the
capital impact on local governments.  In light of this. EPA should explicitly identify each of these
programs under Sub-objective 2.1.3: Water Safe for Swimming, each with its own performance measure
and baseline.

OBJECTIVE 2.2:  PROTECT WATER  QUALITY.  Protect the quality of rivers, lakes,
and streams on a watershed basis and protect coastal and ocean waters.

       Sub-objective 2.2.1: Improve Water Quality on a Watershed Basis. By  2012,
       use both pollution prevention and restoration approaches to protect the quality of
       rivers, lakes, and  streams on a watershed basis, as measured by the strategic
       targets  described below.

       NACEPT SA Comments
       Since approaches  such as "pollution prevention" have specific definitions within EPA's toolbox.
       it is unclear if the identification of these approaches implies the exclusion of other tools, such as
       compliance monitoring, compliance assistance, incentives and enforcement.

            Strategic Targets:

       •   By 2012,  attain water quality  standards for all pollutants and impairments in
          over 3,700  more than 2,250 water bodies identified in 2002 as not attaining
          standards  (cumulative).  Waterbodies where mercury  is among multiple
          pollutants causing  impairment may be  counted  toward this target when all
          pollutants but mercury attain standards, but  must be identified as still needing
          restoration for mercury. (2002 Baseline: 3§r2Q8 37,978 water bodies identified
          by states and tribes as not meeting water quality standards;  1,768 of  these
          waterbodies impaired by pollutants including mercury;  baseline to be updated
          in April 2006. Water bodies where mercury is among multiple  pollutants
          causing impairment may be counted toward this target when all pollutants but
          mercury attain standards, but  must be identified as still needing restoration for
          mercury:  1,703 of the 37,978  impaired  water bodies are impaired by multiple
          pollutants including mercury.)

       •   By 2012,  remove at least 8,500 5,200 of the specific causes of water body
          impairment  identified by states in 2002.  (2002 Baseline: estimate of 57,948
          64,250  specific causes of  water body  impairment  identified by states and
          tribes; baseline to be updated  by April 2006.)
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       NACEPT SP Comments
       It is unclear why the removals target of 8.500 was decreased to 5.200 (38.8% reduction in
       successful removals) even while the  estimated universe of impaired waterbodies increased by
       6.302 (10.9%).

       •  By  2012, improve water  quality conditions in  250 213 impaired  watersheds
          nationwide  using the watershed approach (cumulative).  (2002 Baseline: zero
          watersheds improved of an estimated 40,000/50,000 impaired  watersheds
          with one or more water bodies impaired.   The watershed boundaries for this
          measure are those established at the  "12-digit" scale by the U.S. Geological
          Survey (USGS).  Watersheds at this scale  average between  16 and 36
          square miles in  size. "Improved" means that one  or more of the impairment
          causes identified in 2002 are removed for at least 40 percent of the impaired
          water  bodies or impaired miles/acres; or there is  significant watershed-wide
          improvement, as demonstrated by valid scientific information, in one or more
          water   quality   parameters  or  related   indicators   associated  with  the
          impairments.)

       NACEPT SA Comments
       A previous target identified 35.208 waterbodies as not meeting water quality standards, this target
       places the number at 40.000 to 50.000.   It is uncertain which is correct.  It is unclear what is
       meant by "improved means that one  or more of the impairment causes identified in 2002 are
       removed for at least 40% of the impaired waterbodies or impaired miles/acres."

       NACEPT SP Comments
       A previous  revised  target  is  attainment of water  quality  standards  for all pollutants and
       impairments in 2.250 of 37,978 waterbodies identified as not meeting water quality standards.
       This target is improvement  in. as opposed to attainment of.  water quality standards  in 213
       watersheds out of approximately 40.000 to 50.000.  These targets vary by an order of magnitude.
       EPA  should clarify how  the targets  relate to each other and why the  numeric  targets are so
       divergent. With regard to this target an expected improvement in only 213 watersheds (on the
       order !/2%) over  the next five years implies that addressing the nation's currently impaired
       watersheds will take the next millennium.

       Additionally it is still  unclear what  is  meant  by "improved  means that one  or more of the
       impairment causes identified in 2002 are removed for at least 40% of the impaired waterbodies or
       impaired miles/acres."  If this is a cumulative measure, then success would be achieved when an
       impairment is removed from  16,000 impaired watersheds (40.000 x 40%) or 40% of all impaired
       miles or acres. This is a substantially  greater expectation than the target of 213 watersheds stated
       in the first line of the strategic target. If this success measure is meant to address  the number of
       stream reaches (or miles/acres) within a 12-digit scale watershed, it should be revised to make
       this explicit. In  either  case.  NACEPT  recommends  that success not be measured simply by
       removal of one or more impairments, but by removal of all impairments and the waterbody's
       return to an unimpaired state.

       •  By  2012, the condition of the  nation's wadeable streams does not degrade
          (i.e., there  is no statistically significant increase  in the  percent of streams

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         rated "poor" and no statistically  significant decrease in the streams  rated
         "good").  (2006 Baseline: Wadeable Stream Survey identifies XX 28 percent
         of streams in good condition; XX 25 percent in fair condition; XX 42 percent in
         poor condition.)

      NACEPT SA Comments
      Is this a target to be attained by 2012 or a level to be maintained through 2012?

      NACEPT SP Comments
      With the baseline of only 28% of streams rated "good' and 42% rated "poor." the target of
      maintaining the status quo is unacceptable.

      •  By 2012,  improve water quality in Indian country at not fewer than 10 percent
         of baseline monitoring stations in tribal waters (i.e., show improvement in one
         or  more  of  feuf seven  key  parameters:  dissolved   oxygen,  pH,  water
         temperature,  total  nitrogen, total  phosphorus, pathogen  indicators,  and
         turbidity).  (200^1 Baseline: an estimated 7^13 stations in EPA's STORE! data
         system in Indian Country, or within  1,500 meters of  Indian  Country, that
         monitored for key parameters at  least  once  between  1995	2005.2006
         Baseline: 35 tribes provide water quality data to EPA; number of monitoring
         stations to be determined by August 2006.)

      NACEPT SA Comments
      Ten percent  improvement over a 5-year period implies that it will take 50 years to achieve some
      level of improvement at all 743 monitoring stations. This seems particularly unambitious.

      NACEPT SP Comments
      While NACEPT is pleased to see that the number of water quality indicators has been increased
      from four to seven, defining success as improvement in only one or more of the indicators sets a
      very  low bar.   We remain concerned that a target of 10%  improvement over  5  years is
      unambitious and needs to be revised upwards.

      •  By 2015,  in coordination with other federal partners, reduce by 50 percent the
         number of homes on tribal lands lacking  access to basic sanitation.  (2003
         Baseline: Indian Health Service  data  indicate that  8.4 percent of homes on
         tribal lands lack access to basic sanitation  [i.e., 26,777 homes of an estimated
         319,070 homes lacking access].)

      NACEPT Comments
      This target suggests that sanitation will not be fully provided for the next 20 years, and equates to
      approximately  1.300 homes per year, or approximately 4.500 to 6.000 people per year.  This
      likewise appears unambitious.

      Sub-objective 2.2.2: Improve Coastal  and  Ocean  Water.  By 2011, prevent
      water  pollution  and  protect coastal and ocean systems  to  improve  national
      coastal aquatic ecosystem health by at least 0.2  points on the "good/fair/poor"

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      scale of the National Coastal Condition Report. (2004 Baseline: national rating of
      "fair/poor," or 2.3, where the rating is based on a 4-point system ranging from 1.0
      to 5.0 in  which 1  is  poor and 5 is good  using the National Coastal Condition
      Report  indicators for water and sediment, coastal habitat, benthic index, and fish
      contamination).

      NACEPT Comments
      This objective, in particular, depends on actions taken by state and local governments, but no role
      is identified for the partners.

            Strategic Targets:

      •  By 2011, at least maintain aquatic ecosystem health on the "good/fair/poor"
         scale  of the National  Coastal  Condition Report  in the  Northeast Region.
         (2004  Baseline: Northeast rating of 1.8)

      NACEPT Comments
      This and the  following three strategic targets call for no specific improvement in ecosystem
      health even in regions with fair/poor evaluations.  Most, if not all actions to maintain/achieve
      these targets are taken by state and local entities.  However, there is no reference to  goals.
      objectives and actions of partners.

      •  By 2011, at least maintain aquatic ecosystem health on the "good/fair/poor"
         scale  of the National  Coastal  Condition Report in the Southeast Region.
         (2004  Baseline: Southeast rating of 3.8)

      •  By 2011, at least maintain aquatic ecosystem health on the "good/fair/poor"
         scale  of the National Coastal Condition Report in  the  West Coast Region.
         (2004  Baseline: West Coast rating of 2.0)

      •  By 2011, at least maintain aquatic ecosystem health on the "good/fair/poor"
         scale  of the National Coastal Condition Report in  the  Puerto  Rico Region.
         (2004  Baseline: Puerto Rico rating of 1.7)

      •  By 2011, 95 percent of active  dredged material ocean dumping sites will  have
         achieved environmentally acceptable  conditions (as reflected in each site's
         management plan).  (2005 Baseline: 94 percent)

Means and  Strategies for Achieving Objective 2.2

Improve Water Quality On A Watershed Basis

   To improve water quality on a watershed basis, EPA will focus its work with states,
interstate agencies, tribes, local governments, and others on three  key areas:
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   •  Maintain strong core clean water programs with greater emphasis on watershed
      protection.
   •  Strengthen efforts to identify impaired  waters and restore these waters on  a
      watershed basis.
   •  Invest in water infrastructure and strengthen management practices to improve
      the sustainability of water systems.

Maintain Strong Core Programs

      To build on the progress toward clean water of the past 30 years, EPA will work
with states and tribes to operate four key elements of the Clean Water Act:

   •  Scientifically sound water quality standards.
   •  Effective water monitoring.
   •  Strong programs for control of nonpoint sources of pollution.
   •  Strong discharge permit programs.

Water Quality Criteria and Standards

      State and tribal water quality standards provide the environmental baselines for
water quality programs.  EPA provides scientific information concerning contaminants in
the form of "water quality criteria" and supports state and tribal adoption of water quality
standards that protect water for such uses as  swimming, public water supply, and fish
and wildlife.

      EPA's investment in the science needed to support state water quality standards
is focused on several key areas:

   •  Improving the science relating to nutrient criteria.
   •  Developing the science  for a new generation  of pathogen criteria for ambient
      water.
   •  Determining  how  to  address  PPCPs  (Pharmaceuticals  and  personal care
      products) found in the aquatic environment.
   •  Developing criteria methodology for water body sedimentation.
   •  Developing analytic methods needed to support criteria.

NACEPT SP Comments
NACEPT recognizes that each of these  science areas is worthwhile to support EPA's core water
programs. For each of these areas. EPA should include in this Strategic Plan measurable targets against
which performance can be evaluated.

      In working with states and tribes  to improve standards, EPA will:

   •  Assist states as they move from defining to adopting numeric nutrient criteria.

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   •   Encourage the utilization of use attainability.
   •   Issue  guidance for implementing new water quality  criteria in  state and tribal
       programs.
   •   Work with states to adopt appropriate pathogen criteria for recreational waters.
   •   Expand the number and range of biological criteria.

       Finally, EPA will work with states and tribes to ensure  the effective operation and
administration of the standards program.  For example, all states and authorized tribes
are expected to review  and revise their standards every 3 years if  necessary.    In
addition, EPA must promptly review and approve or disapprove changes to standards.

NACEPT SP Comments
As in  the previous comment NACEPT recognizes that these assistance areas are key to successful
implementation of the core programs at the state level.  For each of these areas, EPA should include in
this Strategic Plan measurable targets against which performance can be evaluated.

Water Quality Monitoring

       Over the next 5 years, EPA will assist states and tribes in significantly improving
information  concerning  the condition of  the  nation's  rivers,  lakes, streams,  and
wetlands. Top priorities for this work are:

   •   Continuing the long-term cooperative EPA/state surveys  of the  condition  of
       waters, with  surveys of lakes and rivers following  the  recent survey of wadeable
       streams.
   •   Implementing  water-monitoring  strategies adopted  by states  and tribes  on
       established schedules.
   •   Expanding use of the Assessment  Database and integrated reporting of water
       quality conditions, including identification of impaired waters.
   •   Expanding use of STORET, the national water quality data warehouse.

       This  monitoring work  will  be coordinated with  assessments of fish  tissue
contamination,  the  condition of water at beaches, the condition of coastal waters, and
the condition of ground water.

NACEPT SP Comments
As in the previous comment. NACEPT recognizes that these water quality areas are key to successful
implementation of the core programs at the state level.  For each of these areas. EPA should include in
this Strategic Plan measurable targets against which performance can be evaluated.

Nonpoint Source Pollution Control

       Nonpoint pollution degrades water quality in many of the water bodies throughout
the country.  State nonpoint control programs under section 319 of the Clean Water Act
are critical to reducing nonpoint pollution.

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      EPA  will  work with states to maintain core programs for reducing nonpoint
pollution through implementation of best management practices,  including education
and  technical assistance.  A critical step in this  effort is for EPA  to forge strategic
partnerships with a broad range of agricultural interests at all levels. EPA will work with
the U.S. Department of Agriculture  (USDA) to ensure that federal  resources, including
grants under  section 319  of the Clean Water Act and funds  available through the
programs managed by USDA, are managed in a coordinated manner.

      As part of this effort, EPA will work with  states on developing  and implementing
watershed-based plans, focused on watersheds with impaired water quality caused by
nonpoint sources. These plans are a mechanism to coordinate monitoring and planning
on a watershed basis and will build a foundation  for effective implementation actions
using federal and other funding.

NACEPT SP Comments
Given the significant impact of non-point source pollution on attainment of water quality objectives.
EPA's and States' investments in managing non-point source pollution will  need to be substantial.
Because of the less exact correlation between investments and outcomes for non-point source pollution
management versus point source  pollution management. EPA should invest  in the  development of
performance metrics for these areas, and include measurable targets in this Strategic Plan.

NPDES Permits

Discharge Permit Program

      The National  Pollutant Discharge Elimination System (NPDES) requires  point
sources discharging to  the nation's waters to have permits for  those  discharges and
requires pretreatment programs to control discharges from  industrial facilities to sewage
treatment plants.

      EPA has five key objectives for the program:

   •  Continue to strengthen management of the permit program.
   •  Advance program innovations including watershed  permitting and water quality
      trading.
   •  Implement wet-weather point source controls.
   •  Maintain effective pretreatment of discharges to sewage treatment plants.
   •  Develop new or revised national regulations addressing key  industrial sources of
      pollution.

      EPA worked  with states over the past several years to develop  a  Permitting for
Environmental Results  Strategy  to  address concerns about the backlog in issuing
permits and  the health of state  NPDES programs.   The Strategy was designed to
assess  program  integrity,  foster efficient permitting  operations,  and  increase  data

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quality, including modernizing the Permits Compliance System.   Over the next several
years,  EPA will monitor the implementation of several hundred  follow-up actions that
resulted from the assessments to assure a strong NPDES program.
 Implementing Core Programs on a Watershed Basis

       EPA and states are working to deliver core Clean Water Act programs on a
 watershed basis. Some examples include:

 •   Nonpoint pollution control projects focused on watersheds needing restoration.
 •   Watershed-scale discharge permits.
 •   Water quality trading.
 •   Watershed scale assessment of infrastructure needs.
 •   Demonstration of watershed scale program integration through targeted watershed
    assistance grants.

       In addition, EPA and states are fostering the collaborative efforts of diverse
 partners to  protect the health of watersheds by building local institutions to provide
 stewardship of water resources on a sustained basis.
      To assist states with improving the operational efficiency of permit programs,
EPA will  continue  to  develop and deploy electronic  tools such  as the  electronic
Discharge Monitoring Report, electronic permitting, and electronic Notices of Intent to
be covered  by a general permit, as well as delivery of a new performance tracking
system called the Integrated Compliance Information System-NPDES.

      EPA will continue to support states in expanding the use of innovative permit
tools to improve water quality on  a watershed scale.  The momentum is building for
watershed-based permitting and pollutant trading and over the next 5 years EPA
expects  to  begin  to see  the  results of  early  efforts. To date,  approximately 98
dischargers  have  carried  out trades  under  NPDES  permits.   As more  permits
incorporate trading options, trading  is expected to increase.

      Wet weather discharges are a significant cause of water  pollution and are a top
priority for the permit program.  State  and local governments have issued permits to
control storm  water from industrial sites,  construction  sites and municipal separate
storm sewers. EPA will work to ensure that these permits are reissued promptly when
they expire  and will monitor the extent to which those entities needing  a permit  are
covered by a permit.

      EPA  is  revising  rules  for  discharges  from  Concentrated  Animal  Feeding
Operations (CAFOs) to reflect court findings.  EPA expects that, after the  revised rules
take effect in 2007, permits will be issued promptly, and CAFOs will begin developing
and implementing nutrient management plans.  Projected pollution reductions from this
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effort include 166 million pounds of nutrients and 2 billion pounds of sediments over 5
years.
 Permit Compliance

       EPA will continue working with states to address and resolve significant noncompliance
 with NPDES permits in a timely manner, including placing emphasis on occurrences of
 significant noncompliance where effluent exceedances may contribute to impaired waters.
 EPA will continue to work with states and sewage treatment plants to improve compliance with
 permit conditions.
       EPA will continue to implement and  strengthen  the pretreatment program by
providing tools to assist states and localities in  their activities.   EPA and  states will
monitor the percentage of significant industrial facilities that have control mechanisms in
place to implement pretreatment requirements prior  to discharging to publicly owned
treatment works.

       Most  industrial  facilities discharging  directly  to  water  bodies or to  sewage
treatment  plants  have  permit  limits  or  pretreatment  controls based  on  national
regulations developed for the class of industrial activity.  Regulations are now in place
for more than 50 industrial classes.

       Over the next 5  years, EPA will  consider new wastewater regulations for airport
deicing and drinking water treatment residuals, and will consider revising regulations for
some chemical manufacturers.  EPA will publish  Effluent Guidelines Plans every other
year that summarize the Agency's findings about the sources, volume, and toxicity of
industrial discharges and the need for new or  revised regulations.

NACEPT SP Comments
The NPDES Program and Effluent Guidelines have been the substance of EPA's success in improving
water quality nationally over the past 30 years.   Enhancing these programs to address emerging
contaminants, water quality, and management issues is critical to  their continued  success.  NACEPT
believes that the key objectives  described in this section are properly focused to enhance  the NPDES
Program and Effluent Guidelines. However, given the  significance of these efforts. EPA needs to develop
performance metrics  and measurable strategic targets for these objectives  and include them in this
Strategic Plan.

Restore Impaired Waters on a Watershed Basis

       EPA is  working  with  states, interstate agencies,  and  tribes  to expand  and
strengthen efforts to restore impaired waters with the goal of restoring,  by 2012, at least
2,250 of the 37,978 waters identified by states as impaired in 2002.
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      Key elements of the strategy to restore impaired waters include:

   •  Improve data relating to the location and nature of impairments.
   •  Organize TMDLs on a water body and a watershed basis.
   •  Maintain aggressive efforts to complete TMDL development.
   •  Expedite implementation of pollution control actions called for in TMDLs and
      other plans, giving special attention to "high priority" discharge permits.
   •  Implement watershed  scale  restoration  in  more than 200  "12-  digit"  scale
      watersheds.

      In a related effort, EPA is working to  restore  and protect large-scale ecosystems
around the country. This work is described in Goal 4 of this Strategic Plan.

      States  identify impaired waters (i.e., waters where one  or  more of the uses
designated  in water quality standards is not  being attained) in  reports to EPA. Over the
next several years, EPA will continue to work with states to coordinate identification of
impaired waters with overall water quality assessments and to improve data concerning
the location of impaired waters and the causes of impairments. As these data improve,
EPA and states will be able to identify watersheds where impaired waters are clustered
together and better understand likely impairment causes and remedies.

      This  improved data will also help states refine schedules for the development of
TMDLs  so  that the TMDLs  needed to restore a  group of  impaired waters  can be
developed in a coordinated manner.  EPA is encouraging states  to develop TMDLs for
these waters  on a  watershed basis  because watershed-based TMDLs  are  less
expensive to  develop and create the opportunity  for coordinated  implementation of
response programs and innovations such as water quality trading and watershed-based
permitting.   Trading  is  a valuable  tool that allows  sources of pollutants to share
responsibility for controlling their discharges  within a watershed and to reduce pollutants
at the lowest cost.

      Understanding  that  restoration   of  impaired   waters  can  often  best  be
accomplished through the coordinated development of TMDLs and implementation of
restoration  actions on  a  watershed scale,  EPA  will work  with states to develop
watershed restoration plans focusing on  small, "12-digit" watersheds defined by USGS.
These plans will demonstrate how to coordinate the planning and implementation of
pollution control actions to accomplish improvements  in  water quality.  EPA will work
with states to initiate a significant number of watershed restoration plans, with the goal
of generating  documented water quality  improvement in more than 200 watersheds by
2012.

      EPA will also continue working with states  to develop TMDLs consistent with
state TMDL development  schedules and court-ordered  deadlines.   States  and  EPA
have made significant progress in the development  and approval of TMDLs and expect

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to maintain the current pace of approximately 3,500 TMDLs completed and approved
per year.

      The significant investment in development of TMDLs since 2000 has resulted in
the cumulative completion of over 19,000 TMDLs across the country.  As more TMDLs
are developed  to support those already  in place,  an increasing  number  of impaired
water bodies and watersheds will be ready for implementation of pollution control and
restoration efforts.
  To Learn More: www.epa.gov/tmdl/
      Meeting the water body restoration goal will require that EPA and states carefully
define and schedule restoration actions resulting from TMDLs. In some cases, a single
permit revision or enforcement  action may bring about restoration.   In  other cases,
water body or watershed scale restoration plans linking point source controls,  nonpoint
source management practices, and financing support will be needed.
  Improving Tribal Water Quality

        EPA has set a goal of improving water quality at monitoring stations on tribal lands, t
  key step in this effort is the development of tribal water quality standards and monitoring
  strategies.

        EPA will also work with tribes to develop nonpoint pollution programs under section
  319, expand and strengthen water permit programs, and develop tribal wetlands programs.

        EPA will assist tribes in developing watershed plans for protecting water quality and
  will involve tribes in the development of TMDLs related to tribal waters.

        Wastewater infrastructure issues on tribal lands will be addressed using funds set-
  aside from Clean Water State Revolving Funds and Alaska Native Village Sanitation Grants.
  Increasing access to basic sanitation and safe drinking water on tribal lands is addressed in
  Section 2.1.1 of this Strategic Plan.
      In support of this effort,  EPA will refine the selection and issuance of "high-
priority"  permits  -  those  expired  permits  that  states determine  have  significant
environmental impacts - to ensure they address factors such as location on impaired
waters,  incorporation of new TMDLs and water  quality standards,  and potential  to
contribute to watershed restoration.  EPA will  continue to ensure that these  critical
permits are  issued  promptly while also maintaining  a  high  level of overall  permit
currency to maintain program integrity.
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NACEPT SP Comments
Here again. EPA has identified a substantial list of activities in which it currently engages, or will engage.
to restore impaired watersheds.  Yet the overall objective is to restore only 2,250 of 37.978 (6%) of
impaired waters by 2012.  In light of the  low outcome expectation over the next 6 years from these
efforts. EPA needs to develop, and include in this Strategic Plan, performance metrics and measurable
targets for each of these activities, as well as  a critical analysis for improving the overall outcome
expectation by at least an order of magnitude, during this Strategic Plan cycle.

Support Sustainable Wastewater Infrastructure

      One of the most critical challenges facing the nation is how to sustain water and
wastewater infrastructure systems. Existing systems are aging, with some components
older than  100 years,  and  a  growing  and  shifting  population  requires  continued
investment for new and  existing infrastructure.  Recognizing the substantial remaining
need for wastewater infrastructure,  EPA expects  to continue  to provide  annual
capitalization to CWSRFs in future years.   This continued federal investment in state
revolving funds, along with  other traditional sources  of financing (including increased
local  revenues) will  result  in  significant  progress  toward  addressing the  nation's
wastewater treatment needs.

      EPA's  Gap  Analysis Report (2002) estimated  that  if  capital spending and
investments in operations and maintenance for wastewater infrastructure remained at
current levels, the  potential gap in  funding between 2000 and 2019 would be about
$270 billion.   In addition, investment in  research  and development has  declined and
many utilities have not focused attention on managing for long-term sustainability.

      The nation must embrace a fundamental change in the way it manages, views,
values, and invests in water infrastructure.  This can only occur if all parties embrace a
collaborative approach focused on finding effective, efficient, and fair solutions. As one
partner in a much  larger  effort, EPA's main  role will be to facilitate the efforts by others
to help ensure sustainable water infrastructure.

      EPA has developed  a Sustainable  Infrastructure organized around four main
themes, or "pillars":

   •  Sustainable Management Practices:  In collaboration with leading utilities and
      associations,   EPA   will   promote   greater   adoption  of  sustainable  utility
      management practices.   EPA  will sign  agreements  with  leading  national
      organizations describing  a number of key steps,  including finalization  of  a
      national strategy in early 2007.

   •  Water  Efficiency:   EPA will  develop  a  voluntary,  partnership program  to
      enhance the market for water-efficient products,  modeled after  the  highly
      successful  ENERGY  STAR  program,  to provide consumers with  information
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      regarding the water use and performance of a variety of water-using equipment
      and products.

   •  Full  Cost Pricing:  EPA will identify the range of approaches used to set rate
      structures  based on full cost pricing, collect "lessons learned"  from  utilities
      implementing those structures, and use that data to provide a range of options on
      full-cost pricing to meet the disparate needs of communities.

   •  A Watershed Approach:  EPA will work with utilities, watershed organizations,
      and  others to provide  tools and  information  that  will facilitate  a watershed
      approach for making key infrastructure decisions.

      EPA  is  developing a  new  Internet-based  Clean Watersheds  Needs  Survey
(CWNS) data system to allow local communities and states to more easily enter and
update information on their pollution prevention  and treatment project needs. In support
of sustainable infrastructure management, the CWNS  data will  be easily accessible for
purposes such as project prioritization and Internet mapping  analyses.

      EPA will also  undertake a major research and  development initiative to identify
unmet water infrastructure needs that can be addressed through innovation.

      Clean Water State Revolving Funds (CWSRFs) are another tool  to help support
sustainable infrastructure management.  CWSRFs provide low-interest loans  to  help
finance wastewater treatment facilities  and other clean water projects.  These projects
are critical to continuing the gains in public health and water  quality of the past 30 years.

      As  of  early 2006, the  federal  government had  invested over $23 billion  in
CWSRFs.11  The  revolving nature of the funds and  substantial  additions from  states
have magnified that investment so that $55 billion has been available for loans.12

      Over the next 5 years, EPA will work with  CWSRFs  to meet  several key
objectives:

   •  Fund projects designed as part  of an  integrated watershed approach, including
      repairing or upgrading onsite treatment systems.
   •  Link projects to environmental results through the use of scientifically sound data.
   •  Maintain the CWSRF's excellent fiduciary condition.

      A portion of CWSRF funding is a set-aside each year  for investment in water
infrastructure  improvements  on tribal  lands,  included  expanding  access to  basic
sanitation.
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NACEPT SP Comments
Given the multi-billion dollar investment in water and wastewater infrastructure and the anticipated need
for the next 20 years. EPA's Sustainable Infrastructure Initiative may be the single, most critical activity
that the Agency is engaged in with regard to achieving Goal 2: Clean and Safe Water.  To ensure that it is
making progress in this initiative. EPA needs to develop, and include in this Strategic Plan and refine in
future plan cycles, performance metrics and measurable targets that demonstrate that (a) the four pillars of
Sustainable Infrastructure and other responsible management approaches, systems and methods are fully
developed, disseminated to. and adopted by. the water and wastewater communities nationwide, and (b)
that future DWSRF and CWSRF disbursements are the best investment choices for the Agency and the
American public.

Additionally. EPA should ensure that the  "cost of sprawl" and other  hidden costs of constructing and
maintaining water and wastewater infrastructure be incorporated into full cost pricing guidance. There is
no mention of the expansive growth patterns and the long industry practice of assessing comparable
connection fees for suburban and ex-urban developments  as for inner city redevelopments. even when
actual capital costs can be 10 times greater. This is especially critical now that the extensive maintenance
and replacement demands of mid-20- century suburban infrastructure have become a reality.

Improve Coastal And Ocean Waters

       Coastal and  ocean waters are environmentally and economically valuable to the
nation.  Assessments of coastal regions of  the  country  through the National Coastal
Condition  Report indicate  that coastal waters are improving overall for a composite
score of 2.0 in 2001  to 2.3 in 2004.   Of the five  major coastal regions (i.e., the four
addressed here  and  the Gulf  of Mexico region addressed in Goal  4 of this Strategic
Plan), four regions showed improvement from 2001  to  2004, with only the Northeast
Coast holding constant at 1.8.  (The Puerto  Rico Region was not assessed in 2001.)

       Key programs focused on and critical to improving coastal waters are:

    •   Assessing coastal conditions
    •   Reducing  vessel discharges
    •   Controlling coastal nonpoint pollution
    •   Managing dredged material
    •   Managing non-indigenous invasive species
    •   Supporting international marine pollution  control

       In addition, coordinating these efforts with those of other federal agencies, states,
tribes, and public and private parties is essential.   Improving coastal waters will depend
on successful implementation of pollution controls in inland watersheds.

       Progress  in  protecting  and  restoring coastal waters is  also  directly tied  to
geographically focused projects, such as the key estuaries addressed  by  the National
Estuary  Program,  as well as  programs  to protect coastal ecosystems including  the
Chesapeake Bay, Gulf of Mexico, Long Island Sound, South Florida ecosystem, Puget


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Sound, and Columbia River Basin.  These programs are described under Goal 4 of this
Strategic Plan.

   NACEPT SP Comments
   Recently published research from a range of academic and governmental scientists indicates that the
   issue of water-body acidity is much more global than previously presumed, and extends to the oceans
   as well as inland lakes. pH declines of 0.3 pH units over the next century are projected as a result of
   absorption of increasing amounts of CO? from the atmosphere.  While CO? absorption may be viewed
   as an environmental benefit with regard to atmospheric CO? concentrations, the increased acidity of
   the oceans is expected to significantly impact marine ecosystem health.  EPA should conduct and
   support research towards greater understanding of the impact of atmospheric CO? concentrations on
   freshwater and marine ecosystems, and develop, as appropriate, strategies and objectives to ensure
   water bodies are protected from CO?-related acidity.

Assess Coastal Conditions

      Progress in meeting the strategic goals for coastal waters will be tracked through
the National Coastal Condition Report, created in 2002 as a cooperative project of EPA,
NOAA,  USDA,  and  the  Department of Interior (DOI).   The  report describes  the
ecological  and environmental condition  of  U.S.  coastal  waters  according to  five  key
indicators.   EPA  and other  federal agencies will  review changing  conditions  and
periodically issue updated assessments of the health of coastal waters.

      In support of this work, EPA is developing indices for measuring the  health  of
coral reefs and  monitoring compliance with environmental  requirements  at ocean
dumping sites.

Reduce Vessel Discharges

      To improve the health of  the nation's ocean and coastal waters, EPA will focus
on addressing discharges of pollution from vessels. Key work includes:

   •  Assessing the need for  and developing discharge  standards for cruise ships
      operating in Alaskan waters.
   •  Cooperating with the Department of Defense to develop discharge standards for
      certain armed forces vessels.
   •  Assessing the effectiveness  of the program to reduce  sewage discharges from
      vessels.

Implement Coastal Nonpoint Source Pollution Programs

      Rapid population growth  in  coastal areas  can result in significant increases  in
pollution  from nonpoint sources. For the past  15 years, EPA and NOAA have been
working with coastal and Great Lakes states to improve and  expand programs to reduce
nonpoint source pollution in the "coastal zone" identified by states.

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      Most states have used federal grant funds to develop coastal nonpoint programs
and EPA and NOAA are working with the remaining states to complete the program by
providing continued support and assistance. These nonpoint control programs, focused
on  the  critical  coastal  zone  areas, play an  important role in accomplishing the
environmental improvements sought for coastal waters.

Manage Dredged Material

      Several  hundred million  cubic yards of sediment are dredged from waterways,
ports,  and  harbors  every year  to maintain  the  nation's navigation  system  for
commercial,  national defense, and recreational purposes.  All of this sediment must be
disposed of  safely.  EPA and  the U.S. Army Corps of  Engineers (the Corps) share
responsibility for regulating how and where the disposal of sediment occurs.

      EPA and the Corps will focus additional resources  on improving disposal of
dredged material, including evaluating disposal  sites, designating and monitoring the
sites, and reviewing and concurring on the disposal permits issued by COE.

      EPA is also working with its state partners and other federal agencies, including
COE, the Fish  and Wildlife Service, and the U.S. Coast Guard, to ensure that dredged
material management plans,  which  include  provisions for the beneficial reuse of
dredged material, are developed and  implemented in major ports and harbors.

      EPA has adopted a goal of having 95 percent of active dredged material ocean
dumping sites  meeting environmentally  acceptable conditions, as reflected in the site
management plan.  EPA will use the  new capability provided by the Ocean Survey
Vessel Bold to monitor compliance  with environmental requirements at these ocean
sites and to conduct other ocean studies.

Manage Invasive Species

      One of the greatest threats to U.S. waters and ecosystems is the uncontrolled
spread of invasive species, such as zebra mussels. Invasive species commonly  enter
U.S. waters through the discharge of ballast water from ships.  Although the majority of
these organisms never become established in a  new ecosystem,  an increasing number
of them are  harming the environment and local  economies and posing  risks to human
health.

      EPA is  assisting the U.S.  Coast Guard  in  its efforts to develop ballast water
discharge standards and is addressing this issue at the international level.
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Support International Marine Pollution Control

       EPA works closely with  the U.S. Coast Guard,  NOAA, and the  Department of
State  to  address  environmental  threats  to  U.S.  waters that  require  international
cooperation.

       Recognizing the effect of international shipping on the quality of the U.S. waters,
EPA is heavily involved in the negotiation of international standards at the International
Maritime Organization. These standards are the principal  mechanism EPA is using to
address invasive aquatic species, tributyltin and other harmful antifoulants, and  marine
debris.  Work is currently underway to develop guidelines under a global treaty (not yet
in force) designed to prevent further introductions of invasive aquatic species through
ballast water.

       EPA is also engaged in  cooperative efforts to reduce other sources of pollution
affecting the Gulf of Mexico, Great  Lakes, Arctic Ocean,  Straits of Florida, and the
Wider Caribbean Basin.

NACEPT SP Comments
Here again, the activities that EPA is engaged in with regard to coastal water and oceans can logically be
expected to contribute to sustaining or improving water quality. Because these activities are disparate and
often involve cooperation with other agencies and state and local partners, assessing their effectiveness is
essential. To this end. EPA should develop specific performance metrics and strategic targets for each of
these activities, and include them in this Strategic Plan.

The significant impact of coastal growth patterns, and the equally significant potential for improvement in
coastal water protection through changes in those patterns, should be addressed.  EPA's  Urban and
Economic Development Division has done laudable  work with NOAA's Sea  Grant Program. US
Department of Transportation, and other partners to create positive models, training  opportunities and
educational programs. EPA should enhance the availability of these  tools to coastal communities and
States.

OBJECTIVE 2.3:  ENHANCE RESEARCH TO SUPPORT CLEAN AND SAFE WATER.
Provide and apply a sound scientific foundation to EPA's goal  of clean and safe water
by  conducting leading-edge research and developing a better understanding  and
characterization  of  the environmental outcomes  under Goal 2. By 2011, conduct
leading-edge,  sound  scientific  research to support the protection  of  human health
through the reduction of human exposure  to contaminants in  drinking water, fish and
shellfish, and recreational waters and to support the protection of aquatic ecosystems—
specifically, the quality of rivers, lakes, and streams, and coastal and ocean waters.
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NACEPT SP Comments
NACEPT is disappointed that EPA elected to delete specific sub-objectives and strategic targets under
this Objective.  While the text following this Objective references the substantial scientific research
activities engaged in by the Agency in support of Goal 2. the decision not to include performance metrics
and strategic targets  in this Strategic Plan makes critical review of the Strategic Plan and assessing
performance against the targets impossible.

In reviewing EPA's 2003 Strategic Plan Architecture and Strategic Plan, and the current Strategic Plan
Architecture. NACEPT repeatedly pointed out that this objective, as written, implies that EPA does not
expect or commit to conducting leading-edge, scientific research until 2011. We again advise the Agency
to reconsider this lack of commitment to leading-edge, scientific research over the next five years.

Sub-objective 2.3.1: Apply the  Best Available Science.—By 2011, apply the best
available science (e.g., tools, technologies, and scientific information) to support Agency
regulations and decision-making for current and future environmental and human health
hazards related  to reducing  exposure  to contaminants  in drinking water, fish  and
shellfish, and recreational waters and  protecting aquatic ecosystems.

NACEPT SA Comments
This and the following sub-objective suggest that EPA will not apply and conduct best  available  and
leading science until 2011. In the interim, what science will be applied? This is identical to comments
made with regard to the 2003 Strategic Plan and Architecture. As expressed, these sub-objectives provide
no measurables by which to assess Agency performance.

Sub-objective 2.3.2: Conduct Leading-Edge Research.—By 2011, conduct leading-
edge,  sound scientific  research to support the protection of human health through  the
reduction of  human exposure to contaminants in drinking water, fish  and  shellfish, and
recreational  waters and to  support the protection of aquatic ecosystems—specifically,
the quality of rivers, lakes and streams, and coastal and ocean waters.

NACEPT SA Comments
This implies that between now and 2011, EPA will conduct "trailing-edge research."

Strategic Targets:

• ORB will  develop data,  tools,  and technologies  that the Agency  uses to  inform
decisions for the 6 year review of drinking water standards and contaminant candidate
listing  decisions.—Success is defined  by an  external expert review process to measure
the utility of  the data,  tools,  and technologies for key Agency decisions  (metric to be
established  in consultation with  external reviewers;  measurement methodology  still
under development).

• ORB will develop approaches and methods that the Agency and other key clients use
to inform  the development and application  of criteria for habitat alteration, nutrients,
suspended and bedded sediments, pathogens and toxic chemicals to achieve targets
for meeting  designated uses for  aquatic systems.—Success is defined by an  external

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expert review process to measure the utility of the data, tools, and technologies for key
Agency decisions  (metric to be established in consultation with  external reviewers;
measurement methodology still under development).

• ORB will develop  tools that  the Agency and other key clients  use to assess and
diagnose the causes and pollutant sources of impairment to achieve targets for meeting
designated uses for aquatic systems.  Success  is defined  by an external expert review
process to measure the utility of the data,  tools,  and technologies for  key Agency
decisions—(metric—to—be—established—m—consultation—with—external—reviewers;
measurement methodology still under development).

• ORB will develop  research  products  and activities that the Agency and  other key
clients use for  the restoration  of impaired  aquatic  systems,  protection of unimpaired
systems  and to forecast the  ecological, economic, and human health benefits  of
alternative  approaches  used to meet designated  aquatic use targets.—Success is
defined by an external expert  review process to measure the utility of the data, tools,
and technologies for  key Agency decisions (metric to be established in consultation with
external reviewers; measurement methodology still under development).

• ORB will develop  approaches, methods, and tools that the Agency and  other key
clients use to assess the exposures and reduce the human health risks from biosolids
contaminants in updating biosolids guidance and regulations.  Success is defined by an
external expert  review process to measure the utility of the  data, tools, and technologies
for  key Agency decisions  (metric to  be  established  in consultation with  external
reviewers; measurement methodology still under development).

NACEPT SA Comments
Many references are made to external research reviews, but there is no discussion of what the basis for the
reviews will be. when such  reviews will occur, nor is there any indication of how the reviews will be
incorporated into the Strategic Plan.  Further, there is no  discussion of what the value/application of the
research efforts is  expected to be. Research, in particular, is an important area where outputs need to be
identified and linked specifically to  outcomes.  For  example, there  is no explicit link of any of the
research goals to increasing access to potable water.

Means and Strategies for Achieving Objective 2.3

EPA conducts  dedicated research programs to support both the drinking water and
water quality program.   Additional research related to  human health and  ecological
issues conducted in  support of the Healthy Communities and Ecosystems Goal of this
Strategic Plan also supports drinking water and clean water programs.

      Progress toward  research goals  is assessed through a suite  of metrics that is
tailored to measuring the impacts of the outcomes of the respective research programs.
Among the measurable factors are:   independent expert  review panel ratings on the
extent to which clients  utilize  EPA research products;  composite scores on  a client

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survey designed to gather data on product utility and perceptions of use; and the results
of bibliometric and/or client document analyses  demonstrating the actual use of EPA
research products.  These factors are applied  to measure success  in providing the
results identified in the research programs that follow.

Drinking Water Research Program

      The Drinking Water Research Program (DWRP) supports the needs of the Office
of Water, regions, states, tribes, municipalities and utilities, producing research products
that DWRP clients use to inform their critical decisions associated with implementing the
Safe Drinking Water Act  (SDWA).   The SDWA Amendments of 1996 direct EPA to
conduct research to strengthen the scientific foundation for standards that  limit public
exposure to  drinking  water contaminants.   This program  will  produce measurable
benefits in  the form of enhanced decisions for  the six-year  review of drinking water
standards and contaminant candidate listing decisions.

      DWRP science and engineering research will be executed by strategic use of the
skills  and facilities  available  in the  Office of  Research  and  Development  (ORD)
laboratories, by expertise at universities through  ORD's STAR Grants program,  and by
cross-agency collaborations such as those  established with  the  Centers for Disease
Control and Prevention, the National Institute for Environmental Health Sciences, and
USGS.

      DWRP  will coordinate its  research  portfolio  with  extramural  organizations
conducting  complimentary  research  including the American  Water Works Association
Research Foundation, the Water Environment  Research Foundation,  and  the Global
Water  Research  Coalition.   The program  will  continue to  emphasize the use and
development of genomic and proteomic-based techniques and methods.

      The  Office of  Water  performs  risk assessments  in  support  of  regulatory
determinations for candidate drinking water  contaminants and other risk management
activities, including perfecting methods to assess  exposure,  conducting heath effects
studies  on  contaminant mode of  action and   dose-response, developing analytical
methods to monitor contaminants, and determining treatment, performance, and cost
parameters.

      Regions, states, tribes,  municipalities  and  utilities often need technical advice to
put new and revised drinking water regulations  into action.   The DWRP will  develop
drinking water treatment strategies,  compliance monitoring  methods, and tools for
source water protection to assist these clients with meeting regulations.

      The Safe Drinking Water Act requires  review of existing regulations on a six-year
cycle.  The DWRP will assist the  Office of Water in these reviews by conducting
research to update the science and engineering  information used  in the rule including,
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for example, studying newly identified modes of toxicity, improving  monitoring methods,
improved  treatment  approaches,  and increasing  understanding of the  impact of
distribution systems on water quality.

Water Quality Research Program

      The Water Quality  Research Program  (WQRP)  provides  timely, leading-edge
water quality research products and information to the Office of Water, EPA regions and
states  for use  in support  of  regulatory and  non-regulatory activities that,  when
implemented, result in environmental and/or human health benefits.  This program will
produce measurable benefits in the form of:

•  stronger criteria for the protection of human health and  ecosystems as related to
   designated uses for aquatic systems;

•  increased use of diagnostics and forecasting techniques for the protection of human
   health and ecosystems  as related to designated uses for aquatic systems; and

•  selection, placement, and management of sustainable watershed technologies to 1)
   restore impaired aquatic systems, 2) protect unimpaired systems, 3) provide human
   health risk and treatment process information on  the beneficial  use of biosolids, and
   4) forecast  the ecologic, economic,  and  human  health benefits  of  alternative
   approaches to attaining water quality standards.

      Research under these goals is intended to lead to the  promulgation of protective
standards; the identification of contaminant contributions to  impaired waters; and the
utilization  of tools  needed  to restore  and  protect the nation's  waters  with  due
consideration  of  point and  nonpoint sources  of  contamination and  including the
treatment and beneficial use of biosolids.  Thus, the research directly contributes to the
Agency's water related environmental outcomes.

      In establishing research priorities, the water  quality research program relies on
the inputs of the Office of Water (Office of Science and Technology; Office of Wetlands,
Oceans, and Watersheds; and  the Office of Wastewater Management). In turn, the
research priorities identified by these clients are inclusive of  the research needs of the
EPA regions and states that  have provided  input to the  development of the EPA
Strategic Plan.

HUMAN CAPITAL

      Over the past  20 years,  EPA has  delegated to state governments much  of its
authority to protect surface water and drinking water. As a result, EPA's role has shifted
from directly implementing water programs to providing guidance and assistance to, and
coordinating financial and  information resources for, partners and stakeholders.  EPA

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continues to be responsible for coordinating national water policy and evaluating water
programs, as well as for direct program implementation  of certain programs for some
states and tribes.

      EPA's changing  role  in  protecting  water  quality  means that the Agency's
workforce must be  increasingly  competent  in areas  such as communication,  policy
development, and management of contracts and assistance agreements in addition to
engineering and life sciences.  The Office of Water has initiated the establishment of a
Workforce  Council that will review the implementation of workforce  initiatives  and will
advise senior managers on priorities for improving quality  of work life.

      EPA's Office of Water is assessing the optimal skill mix needed to fulfill mission-
critical assignments,  as well  as  the  distribution  of tasks among those positions and
expected trends in staff retirements.   The Office of Water has formed a Recruitment
Council, composed of staff and managers,  to plan and  coordinate participation in job
fairs, train employees on the recruitment process, and  improve recruitment information
sharing.  In addition, water program offices have established or are working to establish
ongoing ties to historically black colleges as well as other colleges and universities, in
order to create opportunities for ensuring a diverse workforce into the future.

      Recognizing that today's staff members are tomorrow's leaders,  the National
Water Program has initiated  several long-term efforts to provide training and career
guidance to employees.  The Water  Careers program in the Office of Water provides
employees with a variety of opportunities  for training  and  development  related to
creating Individual Development Plans, mentoring and coaching, and leadership.  About
100 water  program staff members have participated  in this  leadership development
program, instituted in 2002. The Office of Water also provides expert training  in water
program topics to both EPA employees and state water program employees.  Three key
training  programs  are the Drinking  Water  Academy, the Water Quality  Standards
Academy, and the NPDES Permit Writer's Course.

NACEPT SP Comments
NACEPT commends EPA's recognition of the need to nurture and maintain a highly skilled workforce to
successfully carry out its mission under this Strategic Plan. However, as recommended previously. EPA
needs to develop and include performance metrics and measurable  targets for workforce enhancement and
incorporate them into this Strategic Plan.

PERFORMANCE MEASUREMENT

      In Goal 2, most  of the strategic targets  (or measurable objectives and sub-
objectives) are measurable  and reportable on  an  annual basis.    These  annual
performance goals and  measures are established in  the  Agency's Annual Plan and
Budget  and  reportable  results  are  documented in EPA's annual  Performance and
Accountability Report.
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      For the research sub-objective, EPA will track annual progress toward expected
long-term results  by  means  of  multiple,  objective-based  measures of  customer
satisfaction,  product impact and quality, and efficiency.

Influences of Environmental Indicators on the Strategic Plan

      The Agency is working to improve the expression of long-term, outcome-oriented
commitments.  In this Clean  and Safe Water Goal, EPA has developed new strategic
targets  drawing from sources such as program  evaluations and the environmental
indicators that will be included in the forthcoming Report on the Environment (ROE).
The first measure addresses  the  chemical, biological  and physical condition of
wadeable streams. The second measure expresses the mercury blood-levels of women
of child-bearing age, a reflection of the health risk from consuming contaminated fish.
Through the  ROE,  the  Agency  will  routinize  the updating  and  improvement of
scientifically-sound environmental indicators. The latest version of the ROE as well as
information    associated    with    the    new    ROE    can    be    found   at
http://www.epa.gov/indicators/index.htm .

Future Improvements to Performance Measurement

      In addition to the revisions and improvements incorporated when developing this
Strategic Plan, the Agency made a preliminary assessment of longer-term opportunities
for such improvements.   Based  on this  assessment, EPA will work to expand  and
sustain  a scientifically-sound,  statistically-valid  monitoring regimen to characterize the
condition of  the nation's waters, to advance measurement of water quality conditions on
tribal lands and to improve measures related to environmental justice.
  Environmental Justice Measures

        The National Water Program is participating on the Agency-wide effort to develop and
  strengthen measures to ensure that the environmental and public health benefits of programs
  are equitably shared among all citizens.  Within this Clean and Safe Water Goal, EPA has
  developed measures of compliance with drinking water standards by tribal water systems as
  well as access to safe drinking water and basic sanitation on tribal lands.

        In the future, the National Water Program expects to be able to use Agency definitions
  of geographic areas meeting criteria related to "environmental justice" and develop measures of
  progress with respect to drinking water safety and restoration of impaired waters in these areas.
  EPA will strive to deliver program resources so that progress toward clean and safe water in
  these areas is as good or as better than progress reported nationwide.
NACEPT SP Comments
While it is laudable to specifically mention tribal lands and tribal water systems, there should also be
reference to inner-city minority communities that have long suffered the impacts of industrial pollution in
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their drinking  water and recreational water bodies.  There are excellent examples of Brownfields
strategies that work (when funded), and the problem locations can be easily mapped in concert with
minority communities to assess progress.

CLOSING  THE FEEDBACK  LOOP:    PERFORMANCE  ASSESSMENTS  AND
PROGRAM EVALUATIONS

The National Water Program  is committed to affirmative assessment of performance
and adaptive management to strengthen performance and enhance results.  Over the
next 5 years, the  National Water  Program will implement  a  program performance
process including the following key steps:

   •  Define 5-year environmental goals and program strategies in this Strategic Plan.
   •  Define annual increments of progress under program measures.
   •  Assess performance of individual water programs.
   •  Annually summarize all program evaluations in a single assessment report and
      revise and strengthen management practices.

Role of Annual Program Guidance

      The National Water Program publishes annual program guidance that expresses
the goals and objective of the Strategic Plan in annual, operational terms. The  annual
guidance includes annual targets for environmental measures from the Strategic Plan
but also includes measures of  program performance.    The  annual guidance also
includes more detailed directions for program management to reflect  priorities of that
year and the results of performance assessments.   A key function of  the annual
guidance is to strengthen the link between program grants to  states, tribes, and others
to the environmental goals in the Strategic Plan.

      The "targets" described in the annual guidance are developed into more formal
"commitments" in grant workplans as a result of negotiations among regions, states,
and tribes during the spring and summer prior to the start of the fiscal year.   These
annual commitments  define,  in an operational sense, the "strategy" for the National
Water  Program for coming fiscal year.   Selected measures and  commitments  are
included  in  the organizational  assessments  used  to  assess the  performance  of
individual EPA managers.

Assessments of Programs and Regions

      The National Water Program assesses the performance  of individual programs
and EPA regions on a continuing basis.  Some of these assessments  are internal and
others are conducted by outside organizations.
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      Each year, the Office of Water visits three to four EPA regional offices and Great
Water body offices to conduct dialogues on program management and performance.
These visits include assessment of performance in the region against the measures in
the Strategic Plan; regional water issues identified in the Regional Plan;  and the annual
state/tribal  program  commitments.  These   assessments  help  identify  program
innovations or "best practices" developed by the region,  states, tribes, watershed
organizations,  and others, and these practices can  be described in  water program
performance reports and more widely adopted throughout the country.

      In addition to looking at the performance of the National Water  Program at the
national level and  performance in each EPA region, individual water programs are
evaluated periodically by EPA and by outside  organizations such as the EPA Office of
Inspector General, the Government  Accountability Office, the Office of Management
and Budget, and  the National Academy of Sciences.

      For  the  past  several  years,  EPA  has  worked  with  states  to   assess
implementation of  the  NPDES permit  program. This  "Permitting  for Environmental
Results" process included review of core program  authorities, and  identification of
improvements in  program  management needed in each state.  EPA is now working with
states to implement almost 300  specific  follow-up  actions designed  to strengthen
program implementation.

      EPA used program  evaluations developed  over the  past several  years in
formulating this Strategic Plan.  For example,  an evaluation of the  Agency's work with
states and tribes to implement clean water programs on a watershed basis by the EPA
Inspector General resulted in important changes to the measure  of progress related to
watersheds in the Strategic Plan.  The  Inspector General identified  issues  in the
methodology  for the  watershed  measure  in  the  previous  Strategic  Plan and
recommended that EPA both improve the design of the measure  and revise supporting
measures of program activity.

      EPA responded to these recommendations by developing a new measure for the
Strategic Plan related to  watersheds (i.e.  new measure addressing  improvement in
water quality in "12 digit"  watersheds) and expanding and revising watershed  related
program activity measures in the annual National Water Program Guidance.  The new
watershed measure in the Strategic Plan addresses smaller geographic areas than the
measure in the  previous  Strategic  Plan  and is  more flexible  in  that it recognizes
improvement in water quality as well as full restoration of impaired waters.

      Another evaluation  study that  influenced the development of this Strategic Plan
addressed the  implementation of programs  to protect  sources  of  drinking  water.
Responding  to the assessment by  the  Inspector  General,  EPA national program
managers worked with regional managers and states and tribes  to revise and simplify
measures related to source water protection. As a result of this effort, EPA was able to
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define a target for the implementation of source water protection programs by 2011 that
is both ambitious and realistic.

PART Reviews

      Some of the water programs reviewed  under the  Program Assessment and
Rating Tool (PART) include, along with their rating of program effectiveness:

•  Public Water Supply Supervision - Adequate
•  Underground Injection Control  - Adequate
•  Surface Water Protection - Moderately Effective
•  Oceans and Coastal Protection - Adequate

      The EPA Board of Scientific Counselors (BOSC) and the Office of Management
and Budget  (OMB)  evaluated the Drinking Water Research Program in 2005.  The
BOSC found that the program is  relevant and critically important to EPA's  mission in
protecting human health and the environment and is focused on high quality research of
national importance.

      OMB found that the program has developed annual  and  long-term  measures of
performance,  coordinates its  work with  other agencies, employs good  oversight of
competitively awarded grants, and requires  grantees to work toward program goals.
Input from these evaluations was instrumental in revision of long-term drinking water
research plans.

      The Office of Water participates  in development of EPA's Performance and
Accountability Report at the end  of the year and progress on many of the outcome
measures identified in this Strategic Plan is described in this  report.

      In addition, the National Water Program  prepares a performance report at the
mid-point in each fiscal year and the end of each fiscal year based on data  describing
progress under both environmental and program measures.   These water program
annual reports include conclusions and recommended actions to improve  performance
by responding to specific instances of poor performance, disseminating "best  practices,"
and informing the development of future annual guidance and strategic plans. Examples
of performance improvements identified through this  process include the need  to
expand  clean water and drinking  water  program integration, the need to reduce data
reporting lags in the drinking water program,  and the need to expedite reviews of tribal
water quality standards.

      Finally, the Office of Water will maintain  program performance records and, to
the extent possible, use this information to identify trends in program performance.
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EMERGING ISSUES AND EXTERNAL FACTORS

       In the fall of 2005,  the  Office of Water held a national meeting to  identify  and
explore emerging issues of significance to clean and safe water.  EPA will continue to
gather information about these issues described  below, and  use insights gained from
this work in both strategic and operational planning.

NACEPT SP Comments
NACEPT is pleased that EPA is  enhancing its efforts to identify and assess emerging issues that will
impact the water arena in the future. Several NACEPT members participated in the Office of Water's
2005 national meetings on emerging water issues and the Council appreciates the opportunity to work
with the Office of Water on the  Sustainable Infrastructure Initiative. The breadth of the critical emerging
issues identified briefly in this Strategic Plan demonstrate that EPA is beginning to engage in the broad
scanning process that NACEPT recommended in its 2002 report. "The Environmental Future - Emerging
Challenges and Opportunities for EPA."  EPA needs to develop an Agency-wide scanning approach to the
identification and assessment of emerging issues that impact all  facets of the Agency's mission, and
include performance metrics and strategic targets for conducting such assessments in the Strategic Plan.

Decaying Water  Infrastructure:   A significant  percent  of municipal  wastewater
infrastructure,  built in the 1970s and 1980s with EPA funding, is  now reaching the  end
of its design life and will need to  be replaced.   Drinking water distribution systems are
also  failing  at  increasing  rates.    EPA's  commitment  to  advancing  sustainable
infrastructure  using the  "four pillars"  of  sound water infrastructure  management,
discussed previously, is intended to  address this issue.

NACEPT SP Comments
The impact  of the last 60 years of development patterns on our water and wastewater systems,  both
natural systems and built  infrastructure, is a theme that  links many  of the problems  and strategies
discussed under Goal 2, and arguably links with the other Goals.

EPA has performed leading-edge work on researching both the impacts of unfettered  suburban and
exurban growth, as well as best-practice solutions. Much of this knowledge is summarized in a  series of
publications released in the past year: "Using Smart Growth Techniques as Stormwater Best Management
Practices."  "Protecting Water Resources  with Higher-Density Development." and "Parking  Spaces/
Community Places: Finding the Balance Through Smart Growth Solutions." These strategies, which are
largely implemented by harnessing  the power of private development  investment along with better-
coordinated  public investment, could potentially be one of the most effective solutions to many of the
problems outlined under this Goal.

Water Scarcity:  Demand for water for municipal and  other  uses is growing steadily.
Meeting this demand while protecting ecological values of aquatic resources  will be a
significant challenge.

Water Security:  The security  of drinking water and wastewater  systems  is now
recognized as a top priority but much remains to be  done to define  needed security
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practices and  implement these measures across  the  country.    EPA  has made a
significant investment of resources in supporting this work.

Nanotechnology:   The  predicted explosion in the use of  nanotechnology offers the
potential for innovative water treatment methods as well as the risks of harm to aquatic
systems from the release of nano-scale devices and  products.

NACEPT SP Comments
Other federal agencies such as the Department of Energy and the National Science Foundation already
support a broad portfolio of nanotechnology research focused on EPA-relevant issues such as pollution
prevention in energy production and advanced materials for water purification.  EPA  should work to
enhance its coordination with these other agencies and support these innovative research efforts through
cooperative research programs and even funding, as may be appropriate.

Remote Sensing Technology:  The dramatic progress in  miniaturizing sensors  and
gathering environmental  data  from remote  locations  will  open  new avenues to
monitoring the condition of waters.

NACEPT SP Comments
While advances in passive sensing will enhance our understanding of the  environment, active sensing will
enable revolutionary gains in our ability to prevent pollution and to address contaminants already in the
environment.   Researchers are already looking at embedded sensor applications to create  "smart
membranes" that turn on when a target contaminant is present, but otherwise allow flow to pass freely
through.  Switching to a  "just-in-time" capability for  addressing contaminants can  result in broad
operational efficiencies and  greatly enhance infrastructure sustainability.  Here again,  other  federal
agencies such as the Department of Energy and the National Science Foundation already support a broad
portfolio of research in this area. EPA should work to enhance its coordination with these other agencies
and support these innovative research efforts through cooperative research programs and even funding, as
may be appropriate.

Sea Level Rise:  Projected increases in sea levels pose significant risks for the health
and  productivity of coastal waters and threaten habitat, fisheries, and wetlands.

Pharmaceuticals   in  Wastewater:    Increases  in  the  variety and   amount of
pharmaceutical  products  reaching  aquatic systems through  disposal  to  wastewater
systems poses risks to ecological systems and to humans. EPA is expanding efforts to
investigate these issues.

Renewable Energy:   As energy demand increases  and  the  costs  of energy from
conventional sources climbs, demand for renewable energy will grow.  Recent studies
have demonstrated  the  potential for sewage  treatment plants  and  animal feeding
operations to generate significant amounts of renewable energy from treatment process
by-products.

       EPA's strategies for achieving clean  and  safe water depend  on  substantial
contributions and investments by many public and private entities.

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      States are primary partners in implementing both clean water and safe drinking
water programs. Many states, however, are facing budget problems and even deficits.
EPA  recognizes that state  budget shortfalls  are an external  factor that  may  limit
progress toward clean and safe water goals.

      Consistent with the federal government's unique trust responsibility to federally
recognized tribes,  EPA  implements programs in  Indian  country, helps build  tribal
capacity to administer clean and safe water programs, and works with authorized tribes
as co-regulators.  Tribal resource needs are great.  Unlike  states, many tribes are still
developing programs to administer clean and  safe water  programs.   Inadequate
progress in developing these programs will  limit progress toward clean water goals.

      Local governments play a critical role  in implementing clean and safe water
programs.  Municipalities and other local entities have proven to be strong partners with
states and the federal government in the financing of wastewater treatment and drinking
water systems,  and  continued partnership in  financing these systems is essential  to
meeting water goals.

      Despite sometimes-significant resource  limits,  municipalities are also now taking
on additional  responsibilities  for addressing storm water and CSOs.  In the case of the
drinking water  program,  effective  local  management  of drinking  water  systems,
including  protection  of source  waters,  is essential to  maintaining high rates  of
compliance with drinking water standards.  More than 90 percent of the nation's 52,000
community water systems are smaller systems (serving 10,000  or  fewer people) that
often  struggle to  provide safe drinking water.    Continued consultation with local
governments  is  critical to achieving clean and safe water.

      Several key elements  of the National Water Program, including nonpoint source
control,  source water  protection,  and  watershed  management,  require  broad
partnerships among  many federal, state,  and local  agencies and  the private sector.
Over the next several years,  building partnerships with the agricultural community (such
as USDA, state agricultural agencies, and local conservation districts)  is a top priority
for meeting clean water goals.  EPA will also continue to provide water quality data and
technical assistance that can help USDA target its runoff control programs.

      EPA relies  on many  other  agencies to provide  monitoring data to measure
progress toward its goal of clean and safe water.  States lead the effort in water quality
monitoring.  Other  agencies  provide critical information as well, such as USGS, which
maintains  water-monitoring stations throughout the nation, and NOAA, which provides
information on coastal waters.

      EPA also relies on the Corps  to co-administer the Section 404 program  of the
Clean Water Act.   In fact, the Corps acts as the lead federal agency for permitting the
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discharge of dredged or fill material and, as part of its civil works projects,  addressing
dredged material management issues in U.S. waters.

       In addition to the domestic activities that  support the 2002 World Summit goal,
EPA  will  continue  working with the Agency  for  International  Development,  the
Department  of  State,  and other  interested stakeholders to  improve  access to safe
drinking water and sanitation worldwide.

       Finally,  all  of the  EPA's  coastal  and   oceans  activities  are  carried  out in
partnership with other federal agencies and, in  some cases, international, state,  local,
and private entities as well.  EPA relies on its work with the Department of Defense,  the
U.S.   Coast  Guard,  Alaska  and  other states,   and  a  number of cruise ship  and
environmental   and  nongovernmental  organizations  regarding  regulatory  and  non-
regulatory approaches to managing wastewater discharges from vessels.

NACEPT Comments
As discussed in this section. EPA relies heavily on partnerships with a variety of federal, state, tribal.
local and international partners,  on the performance of the regulated community and on the behavior of all
citizens to achieve its goal of clean and safe water. Due to the structure of this Strategic Plan around five
goals, many  of the Agency's activities with regard to these partners are  discussed not under Goal 2, but
under Goals  4 and 5. This segmentation makes understanding  of EPA's  full portfolio of water-related
activities more difficult than it  need be.  and the Agency  should strive to minimize this segmentation in
future Strategic Plans.

Notes
1 .U.S. Environmental Protection Agency. 1998. Clean Water Action Plan: Restoring and Protecting America's
Waters. Washington, DC: Government Printing Office.

2.Travel Industry Association of America. 2002. Tourism Works for America, 11th Edition. Washington, DC:
Travel Industry of America.

3. Pew Oceans Commission. 2002. America's Living Oceans Charting a Course for Sea Change. Arlington, VA:
Pew Oceans Commission.

4.U.S. Environmental Protection Agency, Office of Ground Water and Drinking Water Accessing, Drinking Water
Data in SDWIS/Fed (Safe Drinking Water Information System/Federal Version) Web Site,
http://www.epa.gov/safewater/data/getdata.html.

5.U.S. Environmental Protection Agency. 2002. The Clean Water and Drinking Water Infrastructure Gap
Analysis. Washington, DC: Government Printing Office.

6.United Nations. 2002. Report of the World Summit on Sustainable Development: Johannesburg, South Africa, 26
August - 4 September, 2002. New York, NY:United Nations.
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7.U.S. Environmental Protection Agency, Office of Water, Office of Science and Technology. National Listing of
Fish and Wildlife Advisories. Washington, DC. Available online at http://mapl.epa.gov.  Date of Access: May 1,
2003.

8.U.S. National Oceanic and Atmospheric Administration.  1998. Classified Shellfish Growing Waters. In State of
the Coast Report. Silver Spring, MD: National Oceanic and Atmospheric Administration.

9.U.S. Environmental Protection Agency, Office of Water, Office of Science and Technology. National Listing of
Fish and Wildlife Advisories. Washington, DC. Available online at http://mapl.epa.gov.  Date of Access: May 1,
2003.

10.U.S. Environmental Protection Agency. Tuesday, April 19, 1994. Combined Sewer Overflow (CSO) Control
Policy. Federal Register Vol. 59, No. 75, page 18788.

11 .U.S. Environmental Protection Agency.  June, 2002. CWNIMS National Report.  CWSRFFunds Available for
Projects, Net Sources. Washington, DC: Government Printing Office.

34.U.S. Environmental Protection Agency. June, 2002. CWNIMS National Report. CWSRF Funds Available for
Projects, Net Sources. Washington, DC: Government Printing Office.
12.U.S. Environmental Protection Agency, Office of Ground Water and Drinking Water Accessing, Drinking Water
Data in SDWIS/Fed (Safe Drinking Water Information System/Federal Version) Web Site,
http://www.epa.gov/safewater/data/getdata.html.
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GOAL 3 - LAND PRESERVATION AND RESTORATION

Preserve and restore the land by using innovative waste management practices and
cleaning up contaminated properties to reduce risks posed by releases of harmful
substances.

      Uncontrolled, hazardous and nonhazardous wastes on the land can migrate to
the air, ground water, and surface water, contaminating drinking water supplies, causing
acute illnesses or chronic diseases, and threatening healthy ecosystems in urban, rural,
and  suburban  areas.   Hazardous substances can kill living  organisms  in lakes and
rivers,   destroy  vegetation   in  contaminated  areas,   cause  major   reproductive
complications in wildlife, and otherwise limit the ability of an ecosystem to survive.

      EPA will work to preserve and restore the land using the most effective waste
management and cleanup methods available. We use  a hierarchy of approaches to
protect  the  land:  reducing  waste at its source; recycling waste; managing waste
effectively  by  preventing spills and  releases of toxic  materials;  and,   cleaning up
contaminated properties.  The Agency is especially concerned about threats to our most
sensitive  populations,  such  as  children, the elderly,  and  individuals  with chronic
diseases.

NACEPT SP Comments
Because of the reality that a significant part of EPA's work involves partnerships. NACEPT suggests that
the first sentence of the paragraph above be modified to read:  "EPA will work in partnership with
state, local  and tribal governments and private industry to ..."

      The Resource Conservation and Recovery Act (RCRA)' and the  Comprehensive
Environmental  Response, Compensation,  and Liability Act (CERCLA,  or Superfund)"
provide the legal authority for most of EPA's work toward this goal. The Agency and its
partners use Superfund authority to clean up uncontrolled or abandoned hazardous
waste  sites and return  the  land  to  productive  use.   Under RCRA,  EPA  works in
partnership with states and tribes to address risks associated with leaking underground
storage tanks  (USTs) and with the generation  and management  of  hazardous and
nonhazardous  wastes.   The  EPA  waste  management program  recognizes  tribal
governments as  the primary parties for setting standards, making environmental policy
decisions, and managing programs for reservations, consistent with federal standards
and regulations.  Accordingly, EPA regional offices work directly with tribal governments
as the recognized  independent authorities for reservation affairs and  not as political
subdivisions of states.
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      EPA also uses authorities provided under the Clean Air Act,'" Clean Water Act,lv
and  Oil  Pollution Act of 1990V  to  protect against spills and  releases  of  hazardous
materials.  Controlling the many risks posed  by accidental and intentional releases of
harmful substances presents a significant challenge to protecting the land.  EPA uses
an  approach  that  integrates prevention,  preparedness, and  response activities  to
minimize these  risks.  Spill-prevention activities keep harmful substances from being
released to the  environment.  Improving EPA's readiness to respond to emergencies
through training, development of clear authorities, and provision of proper  equipment
will ensure that we are adequately prepared to minimize contamination and harm to the
environment when spills do occur.

OBJECTIVE 3.1: PRESERVE  LAND.  By 2011, reduce adverse effects to land by
reducing waste  generation, increasing recycling, and  ensuring  proper management of
waste and  petroleum products at facilities in ways that prevent releases.

      Sub-objective 3.1.1: Reduce Waste Generation and Increase Recycling.  By
      2011, reduce materials use through product and process redesign, and increase
      materials and energy recovery from wastes  otherwise requiring disposal.

      NACEPT SP Comments
      While NACEPT agrees that EPA should focus  on materials and energy recovery to minimize the
      quantities of waste requiring disposal. EPA should also focus on materials energy recovery from
      disposal facilities themselves.   There is a growing body of work on the use of bioreactors and
      other technologies for contaminant extraction and energy recovery from existing landfills that can
      lead to enhanced site management and extension of site lifetimes.

      Strategic  Targets:

   •  By 2011,  decrease the total amount of municipal solid waste disposed at landfills
      and  combustion facilities by xx 1_1 million tons from XX (tons) in YYYY (year) the
      amount disposed in 2003  (under determination).

   NACEPT SP Comments
   It is not  clear  as to why a target of 11 million tons was selected, particularly when the baseline
   amount for 2003 is still being determined. What is the reduction goal for 2020?  Does this proposed
   level of reduction put the nation on track to achieve the longer-range goal?

   •  By 2011,  increase recycling of the total  annual municipal solid waste produced to
      40 percent from 30.6 percent in 2003.

   NACEPT SP Comments
   What is the reduction goal for 2020? Does this suggested goal put the nation on track to achieve the
   long-range goal, or should it be much more aggressive?
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   Further, in many instances EPA plays a much more limited role than what appears in this plan often
   in these situations the main drivers are state, local and tribal governments.  That thought is recognized
   in some places,  but goes unsaid in many others.  For example. EPA has a  very limited role in
   increasing recycling of municipal waste from 30.6 percent to 40 percent.  Recycling of municipal
   waste is handled  primarily at the state and local level. The Agency should more clearly identify what
   its role  and strategy is in this area. Is its role providing grants and loans? Is it working in partnership
   with state, local and tribal governments? How much of the increased recycling is expected to be due
   to activities at EPA versus those undertaken by state, local and tribal governments? How realistic are
   the recycling figures?  Recent work with Bucks  County Pennsylvania on developing its 10 year
   municipal solid waste plan showed that it was extremely difficult to obtain reliable figures on the
   amount of municipal waste, especially Construction and Demolition waste, being recycled. Does EPA
   know how reliable its figures are?

   •   By 201 1 , increase reuse and  recycling of construction and demolition debris by
       XX% 6 percent from a baseline of ¥¥% 59 percent in 2003.

   NACEPT SP Comments
   This leads to the same questions  as above.  How does this fit into the long-range goal? Moreover
   there is simply a question of what this target is supposed to mean. Does this really mean a 6%
   increase of the 59% baseline, giving a recycling rate of 62.5% or is it supposed to be  an increase of 6
   percentage points to 65%?

   •   By 201 1 , increase the use of coal combustion ash to 50  percent from XX% 32
       percent in 2001.

   NACEPT SP Comments
   How does this compare with the long-range goals?

   •   By 2011, increase by XX%, from XX% in year YYYY, 81. the  number of tribes
       covered by an adequate and recently-approved integrated waste  management
       plan  that has been approved by an appropriate governing body within the last 5
   NACEPT SP Comments
   Why is the goal an increase of 81? What fraction of the 572 federally recognized tribal governments
   are currently covered? When will all tribes be included?

   •   By 201 1 , reduce the number of open dumps  on Tribal lands by XX%, from XX%
       in year YYYY close, clean up, or upgrade 54 open dumps in Indian country and
       on other tribal lands.

   NACEPT SP Comments
   Why was a target of 54 open dumps selected as the number to close? What is the universe in terms of
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   numbers? Does this complete the process of closing such open dumps?  Is this an aggressive goal?
   Without some comparative numbers, it is not possible to evaluate this.

      Sub-objective  3.1.2:  Manage Hazardous Wastes and Petroleum Products
      Properly. By 2011, reduce releases to the environment by managing hazardous
      wastes and petroleum products properly.
       Strategic Targets:

    •  By 2011, prevent  releases frem at 500  RCRA hazardous waste  management
       facilities by increasing the number of facilities that were brought under approved
       or updated controls from XX (at the end  of FY 2008) to XX implementing initial
       approved controls or updated controls.  (In  FY2006, EPA estimates  that  820
       facilities require these controls: the baseline is zero. The universe of facilities will
       be reassessed by FY 2009.)

   NACEPT SP Comments
   This is a particularly helpful target.   We know from this universe that no such facilities  have
   accomplished this as vet, and there is a promise of a review soon. In addition, the target appears to be
   aggressive in light of the total number of facilities in the group.

   •   By 2011, increase  the percentage  of  LIST  facilities  that  are  in significant
       operational compliance  with  both  release detection  and  release prevention
       requirements by five percent compared to more than the 66 percent in 2006, out
       of a total estimated universe of approximately XXX,XXX 245,000 facilities.

   NACEPT SA Comments
   Five percent over a five-year period equates to one percent per year. At this rate, it will take a
   century to bring the universe of UST facilities into significant operational compliance.

   NACEPT SP Comments
   It is still unclear whether  EPA intends to increase the number of facilities in compliance by 5% to
   69.3% or to increase the percentage of facilities in compliance from 66% to 71%.  If EPA intends the
   latter, it should explicitly state the 71% target.

   •   Each year  through 2011,  minimize the number  of confirmed releases at  UST
       facilities to 10,000  or fewer from a universe of approximately 650,000 UST tanks.

   NACEPT SP Comments
   On  the surface, this seems to be a comforting target however, there  is  no  information  about the
   number of releases in past years.  Is 10.000 or less an aggressive goal or simply a continuation of the
   current situation? Why is there no expectation for reductions of this number each year until 2011
   rather than a flat line?


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Means and Strategies For Achieving Objective 3.1

      EPA's  strategy  for  reducing  waste  generation  and  increasing  recycling,
promoting the development  of tribal integrated waste management plans, and closing,
cleaning up or upgrading open dumps is based  on:  (1) establishing and  expanding
partnerships with businesses, industries,  states, communities, consumers,  tribes and
federal agencies;  (2) stimulating development of infrastructure, new technologies, and
environmentally responsible behaviors by  product manufacturers, users, and disposers
("product stewardship");  and (3) helping  businesses,  government, tribes, institutions,
and consumers by providing education, outreach, training, and technical assistance.  To
implement  this strategy,  EPA will apply  the  talents and  technical expertise of its
workforce to create synergistic relationships with its stakeholders to achieve common
goals.

Working Toward a Vision for 2020

      These updated strategic  goals for  materials management put us on a  path to
achieve our vision for the RCRA program in the year 2020.  In  2002,  in a document
entitled,  "Beyond  RCRA:  Waste and  Materials Management  in the  Year 2020."
(http://www.epa.gov/epaoswer/osw/vision.htm ) we noted the future we envision is one
"...in which materials that were once considered wastes suitable only for landfilling are
now continually reused and recycled, and 'industrial ecology' has become the mantra of
corporate executives across the nation. Landfills are becoming obsolete...".

      While EPA  did not go so far as to  say that we would achieve a full cradle-to-
cradle  industrial system by 2020, we envisioned that "...a future waste reduction
program could achieve more than it would otherwise by setting its aspirations high, and
explicitly focusing  on reducing waste as  much  as possible, even  approaching zero."
Our recycling goals for 2011 would clearly  need to increase dramatically to reach a zero
waste future by 2020.   However, even if our  aspirational goals  prove  to be overly
aggressive, they will have helped push us toward a more sustainable future.

NACEPT SP Comments
It is good to read that the goals  for 2011 are aspirational. however as noted, the text in  the previous
sections does not make that clear.  Further information could make for a much stronger presentation of the
case.

An  effective  Strategic  Plan should  not  be an aspiration  but a  clear  set of goals/objectives/
actions/commitments.  Once these targets are viewed as  aspirational they lose  their value in ensuring
accountability.
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Establishing and Expanding Partnerships

      EPA  will  work  to  establish  and
expand   its  partnerships  with   industry,
states, and  other entities to reduce waste
and to develop  and deliver tools  that can
help  businesses,   manufacturers,   and
consumers.      Nationally     recognized
programs,     such     as     WasteWise
(http://www.epa.gov/epaoswer/non-
hw/reduce/wstewise/htm),   and  our  Coal
Combustion Products  Partnership (C2P2;
http://www.epa.gov/epaoswer/osw/conserve
/c2p2/index.htm),      which       employ
partnerships to encourage waste prevention
and recycling, will serve as models for new
alliances  among   government  agencies,
industries,  and  businesses that capitalize
on voluntary efforts to  reduce waste and
increase recycling.
      EPA will also continue to support its
tribal  partners to  improve  practices  for
managing solid waste on Indian lands. EPA
has direct implementation responsibility for
RCRA hazardous waste and LIST programs
in  Indian country.  Recognizing the unique
challenges  encountered  on  tribal  lands,
EPA will work with tribes on a government-
to-government  basis that affirms its federal
trust  responsibility to  the  572 federally
recognized    tribal    governments    and
acknowledges the importance of conserving
natural resources for cultural uses. Actions
to  upgrade tribal  solid waste management
infrastructure will  continue, including the development of integrated waste management
plans, codes, ordinances, recycling programs, and other alternatives to open dumping.
These efforts will  help to prevent open dumping  in Indian country, further the cleanup of
existing dumps, and reduce the risks that such dumps pose to human health and the
environment.
A Vision of the Future
(from Beyond RCRA: Waste and Materials
Management in the Year 2020)
Generating and managing post-consumer
household wastes have undergone a
transformation.  Concern for environmental
sustainability has become ingrained as a
societal value as individuals have become much
more aware of the environmental consequences
of their consumptive choices.  These changes in
consumer values have prompted shifts in
manufacturing techniques and choices, so that
manufacturing processes are based on
managing resources efficiently, closing the loop
of material flows, and designing for the
environment. Products contain fewer toxic
materials and are designed to last longer.  Much
less—and less toxic—waste is generated during
manufacturing. Manufacturers now take
responsibility for their products throughout the
product life cycle, and product stewardship—
involving all members of the product chain—is a
standard operating procedure.  Household
recycling, as well as advances in packaging,
product design,  and other market-based
measures, has reduced household waste
generation rates to a small fraction of what they
were in the late  twentieth century. Virtually all
organic wastes, construction and demolition
wastes, and other materials formerly managed
as part of the municipal solid waste stream are
now diverted  to  beneficial reuse, dramatically
reducing the amount of landfill space needed.
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      During 2006 - 2011, EPA will initiate a national effort to forge partnerships with
senior managers  from  other  federal  agencies  to  identify and  resolve commonly
acknowledged waste problems in Indian country and other tribal  lands.  This  effort will
build  on  the  work  of  the  National  Interagency Workgroup,  whose  members
cooperatively contribute to fund annually the Solid  Waste Assistance Grant Program for
tribes.

 NACEPT SP Comments
 The means and strategies described here appear to be primarily a continuation or extension of existing
 programs.   That leaves some unanswered questions.  What is the rate of progress for the existing
 activities? Based on the track record will the current level of activities realistically achieve the targeted
 results?  If more needs to be done, what are the plans for that? This issue is not clearly addressed in this
 document. The issue would seem to have particular relevance because this section addresses both tribal
 concerns and progress and inter-agency relationships.

Stimulating Infrastructure Development, Product Stewardship, and New Technologies

      Another key strategy for reducing waste is fostering development of infrastructure
that will make it easier for industry, businesses, and consumers to reduce the  waste
they generate,  acquire and use recycled materials,  and purchase products containing
recycled materials.  EPA will continue  to promote development of new  and expanded
markets  for recycled  materials and new and better recycling technologies.  Within
municipal solid waste, we will focus our efforts on specific commodity streams with the
potential for large increases in recycling with a particular emphasis on  paper,  organics,
containers,  packaging,   and  electronics.    Several  initiatives  already  underway
demonstrate  the potential of such efforts.   EPA has established product stewardship
partnerships  with  manufacturers, retailers,  and governmental  and nongovernmental
organizations to reduce the impacts  that electronics and carpets can have  on the
environment  throughout  their  useful  lives.  Carpets  and  electronics  offered strong
opportunities for  collaboration  because  key  industries and  states  identified  the
environmental benefits associated with waste reduction in these sectors. Through our
new GreenScapes  (http://www.epa.gov/greenscapes/) partnership,  we  are  promoting
major increases in end-markets for compost while also working to teach homeowners
how to save  time, money, and natural  resources  by reducing and  recycling their yard
wastes.
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       We will also work to increase recycling at important tribal  venues.   Significant
potential exists for waste reduction,  increased recycling of beverage containers, and
composting of organics (both yard and food wastes) at large public venues such  as
tribally-owned and operated  casinos, shopping  centers,  and amphitheaters  where
concerts and  other large events are held. Such "Recycling on the Govl" projects at these
venues have  the  potential to result in more recyclable and compostable materials being
diverted from landfills, contributing to the national recycling goal.  Such projects will also
create opportunities for partnerships and relationship building among  EPA, tribes, and
local governments.

NACEPT SP Comments
It is very difficult to attempt to correlate the proposed level of targeted results with the possible level of
accomplishment that might be expected to happen from the Means and Strategies proposed. Here, again.
for the most part, the proposal seems to be to continue what is already underway. While there is nothing
inherently wrong with that, the case could be made stronger if there was some information about the track
record of the initiatives over the last couple of years.  Are there already plans in place to enhance  the
efforts? Why would we expect more to be accomplished than has already been accomplished? Will some
new effort or increased attention be required in order to achieve the results targeted?

Further, regulatory flexibility is likely to be necessary to achieve increased materials and energy recovery
because current regulations mandate that certain materials be handled as wastes.  An essential ingredient
in promoting development of new and expanded markets for recycled materials is  using increased
regulatory flexibility to "de-waste" certain materials based on new science that demonstrates that re-use is
safe and disposal is unnecessary.

       To  increase recycling  of  industrial byproduct materials, we  will concentrate  on
three large-quantity material  streams: coal combustion products,  foundry  sands, and
construction  and demolition  debris.  EPA  is engaging  with  the  construction and
demolition  industries  to  identify ways to increase the recycling  of construction and
demolition     debris.           Through     the     Green     Highways     Initiative
(http://www.greenhighways.org/),  EPA collaborates  with  governments  at  all  levels,
businesses, and  industries to achieve the following  goals:  promote  use of industrial
materials in the transportation infrastructure;  promote  reduction, reuse, and  recycling of
municipal solid waste; and educate our partners about options for "green procurement."

NACEPT SP Comments
This proposed Means and Strategy appears to be logical, however, considering industrial turnaround time
and time probably necessary to get standards and approval procedures modified, it does not seem realistic
that these activities alone will be able to achieve the levels of the targeted changes. That leads to  the
question of what other initiatives does EPA plan or propose in order to achieve the projected level of
results?  If EPA believes that the stated initiatives will be able to deliver the results, then a stronger case
could be made by providing some additional details.
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       EPA will also promote development of new and better recycling technologies and
will explore ways  to  obtain energy  or  products from waste.  For  example, through
bioreactor technology, which provides accelerated stabilization of municipal solid waste,
the collection  of landfill gases containing methane offers promise as  a future source of
energy. The Agency will  continue  to support initiatives  that revamp technologies to
reduce or eliminate the use of virgin  materials, recover energy  to produce power, and
improve waste management.

NACEPT SP Comments
While energy use reduction and alternative energy sources are important goals, they do not appear to be
part of the targeted plan for this section. If the  intent of this paragraph is to present some ideas about
expanding markets for recyclable materials that would be a positive statement, however, some discussion
about how this relates to achieving the targets for 2011 would be helpful.  As presented, this initiative
would seem to show most impact in terms of increased recycling rates after 2011.
Providing Education, Outreach,  Training, and Technical Assistance

      As  a result  of the  Agency's continuing  outreach activities  with  non-profit
organizations,  major retailers,  electronics  manufacturers, and  other industries,  more
products  and  venues  are  displaying  conservation,  waste  prevention, and recycling
messages.  These educational  messages increase awareness of the issues associated
with waste disposal  and  encourage consumers,  young  people,  and  underserved
communities to make smarter, more responsible environmental choices.

      Collaborating with industries and with government agencies at all levels, EPA will
continue to foster the increased recycling of industrial byproducts that would otherwise
require  disposal.  Outreach, training,  and assistance efforts will focus on construction
and demolition debris and coal  combustion products to attain our numerical goals.  Our
Coal  Combustion Products  Partnership  will serve  as a primary  outreach vehicle to
encourage  the use of  coal   combustion  products.    EPA's  Construction  Initiative
(http://www.epa.gov/epaoswer/osw/conserve/priorities/bene-use.htm)    will    foster
recycling  of industrial materials, including construction and  demolition debris, in major
transportation  and building construction  projects.  We will continue working with  the
foundry industry to encourage recycling of spent  foundry sands and to develop a
numerical goal to quantify these efforts.

NACEPT SP Comments
These are admirable initiatives. However, it is not clear that efforts involving coal combustion products.
demolition  wastes, and spent foundry sands will achieve the targeted changes in total recycling and
landfill avoidance. This non-clarity is compounded by the statement above "to develop a numerical goal
to quantify these efforts". If it is not known whether these efforts will achieve the hoped-for results, what
else is planned on the part of EPA to achieve them?  This section on Means and Strategies should include
some discussion of what else is planned.

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      The Agency and its partners will design activities that encourage students and
teachers to start innovative  recycling programs and will  develop unique tools and
projects which promote waste reduction, recycling,  and neighborhood revitalization in
Hispanic and African-American communities and on Indian lands.  The EPA supports
the development of  tribal waste  management programs  by funding training on and
publishing resource documents for tribal employees  for the development of tribal waste
management plans, community education and  outreach, and other cleanup activities to
mitigate the results of improper waste disposal.

NACEPT SP Comments
A great deal is projected in terms of results and accomplishments from the efforts involving partnership
and collaboration with tribes. While the comments in the paragraph above regarding education, training.
and references are positive, they appear  on the surface to fall short of what is needed to accomplish the
anticipated results. The case can be strengthened by an explanation as to why this effort is expected to be
successful, or of other initiatives to be undertaken in order to reach the targeted numbers.

Establishing and Expanding International Initiatives

       "Global Environment" is a  core priority in the Agency's Action Plan.  Recycling
(e.g.,  paper,  plastics, electronics) and waste management are  becoming increasingly
global  enterprises, and EPA  waste  management  programs will continue to devise
efficient  and rational  solutions,  working  on  voluntary and regulatory  initiatives  in
conjunction  with  partner countries  and international  agencies, to protect  the  global
environment.

      EPA actively promotes the safe handling  of waste imports and exports through
participation  in the Commission  for  Environmental Cooperation's Hazardous Waste
Task  Force  in   implementing environmentally sound  management  principles  for
hazardous waste among North American Free Trade Agreement countries.  This work
will lead to significantly improved tracking of transboundary hazardous waste shipments
and  result   in  improved  compliance,  enhanced  border  security,  and  reduced
administrative burden and costs to both the private sector and government agencies in
both the  U.S. and abroad.  EPA also  is partnering with Mexico to implement the U.S.-
Mexico   Border   2012   Plan   (http://www.epa.gov/usmexicoborder/intro.htm),   which
includes  reduction of land contamination through the Waste Policy Forum. EPA and
Mexican authorities are working together in this forum to clean up and prevent tire piles
and remediate contaminated sites along the border (2.1 million tires have been cleaned
up through April 2006).
      EPA is engaged with the Working Group on Waste Prevention and Recycling of
the Organization for  Economic Cooperation and Development  (OECD)  in efforts  to
minimize waste  generation, remove barriers to recycling,  and streamline exports and


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imports of hazardous waste recyclables.v"  EPA has a leading role in a global public-
private  partnership under the Basel  Convention  to  enhance the design,  collection,
reuse, and recycling of mobile phones.  EPA is participating in negotiations expected to
continue until 2009, under the auspices of the International Maritime Organization's
environmental committee,  to develop a  new international convention for the safe and
environmentally sound dismantling and recycling of ships.

NACEPT SP Comments
The international initiatives are important, but it is not clear (in fact it is very unclear) about how they
relate as means and strategies to the strategic targets that are presented in this plan.  The entire plan could
be strengthened if that were  done because there are some questions about whether the entire array of
means and strategies presented will really be sufficient to achieve the targeted results. Moreover, making
a connection between the proposed strategic targets and the internationally-related activities  would
strengthen the rationale to continue and elevate  the  level of attention and resources that these activities
receive.

Managing Hazardous Wastes And Petroleum Products

       Recognizing that some  hazardous wastes cannot yet be completely eliminated or
recycled, the RCRA program reduces the  risks  of exposure to hazardous  wastes by
maintaining a "cradle-to-grave" approach to waste management.

Preventing Hazardous Releases from RCRA Facilities

       EPA's strategy for addressing hazardous wastes that must be treated, stored or
disposed is  based on achieving greater efficiencies at  waste management facilities
through more focused  permitting processes and  improving permitting conditions where
appropriate.  We will work with our state,  tribal, and local government partners to ensure
that hazardous waste  management facilities  have approved controls in  place and
continue to strive for safe waste management.

      Through the end of FY 2008,  EPA will continue to  work with authorized states—
specifically, those with a large number of facilities lacking initial approved controls—to
achieve the goal  of having 95 percent of approximately 2,460 facilities  with permits or
other approved controls.  We  want to  resolve any  issues that might be preventing key
categories of these facilities from obtaining permits or putting other approved controls in
place and transfer successful strategies from other states. At the same time,  we  will
update  controls for preventing releases  at 150 facilities.   By  2009, we  will finalize  the
universe of facilities that  still  require initial approved controls and  those that  need
updated permits (currently estimated to  be 820), and use that number as the universe
for determining future accomplishments.
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NACEPT SP Comments
As indicated previously, this section clearly relates the proposed strategic targets with the means and
strategies that will be used, including sufficient information to allow a reader some perspective on how
the proposed activities relate to the  strategic targets, as well as some perspective about whether the
anticipated level and type of effort will be sufficient to achieve the projected result.

Preventing Releases from Underground Storage Tank Systems

      EPA recognizes that the  size and diversity of the regulated community puts state
authorities  in the best position to  regulate USTs and to set priorities.  RCRA Subtitle  I
allows state  LIST  programs  approved  by EPA to  operate  in  lieu of the federal
program/'" Even states that have not received formal state program approval from EPA
are in most cases the primary implementing agencies-with the  exception of  Indian
country-and are receiving annual grants from EPA.

       The Underground  Storage Compliance Actlx (or USTCA) of the Energy  Policy
Act requires  major  changes  to  federal  and  state LIST programs  and focuses on
preventing  releases to keep our nation's land and water safe.  Among other things,  it
expands eligible uses of the Leaking Underground Storage Tank  (LUST) Trust  Fund,
extends the LUST  Trust  Fund tax through 2011,  and includes  provisions regarding
inspections, operator training, delivery prohibition, secondary containment and financial
responsibility, and cleanup of releases that contain oxygenated fuel additives. Some of
these  provisions  require  implementation  by   August  2006;  others  will  require
implementation in subsequent years.  To implement the new law,  EPA and states will
work closely with tribes, other federal agencies, tank owners and operators, and other
stakeholders to bring about the mandated changes affecting UST facilities.

      In any given year,  it is possible that factors such as greater field presence and
discovery of older  releases during site closures will increase the number of confirmed
releases reported, potentially exceeding the Agency's annual strategic targets.  Despite
such  apparent  increases in releases, human health  and the environment are  being
better protected than if the releases  went undetected or unreported.  While the vast
majority  of the  approximately 650,000 active  USTs have the  regulatorily-required
equipment, significant work remains to ensure that UST owners  and operators maintain
and operate their systems properly/  EPA will also continue to support state programs,
strengthen  partnerships  among  stakeholders,  and  provide  technical  assistance,
compliance assistance,  and training  to  promote  and  enforce compliance by UST
facilities. The Agency and states will use innovative compliance  approaches, along with
outreach and education tools, to bring more tanks  into compliance.

NACEPT SP Comments
While  this section  about UST and LUST does provide very useful information  about the status and
changes in the program, it is not very clear about how the initiatives and planned actions relate to the

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proposed strategic targets. Further explanation about that would strengthen the case.

OBJECTIVE 3.2:  RESTORE LAND.  By 2011, control the risks to  human health and
the environment by mitigating the impact of accidental  or intentional releases and by
cleaning up and restoring contaminated sites or properties to appropriate levels.

       Sub-objective 3.2.1: Prepare for and Respond to Accidental and Intentional
       Releases.   By  2011, reduce and  control the risks posed  by  accidental  and
       intentional releases of harmful substances by improving our nation's capability to
       prevent, prepare for, and respond  more effectively to these emergencies.

       Strategic Targets:

       •   By 2011, achieve and maintain at least  95 percent of maximum  score on
          readiness evaluation criteria in  each region.

       NACEPT SP Comments
       What is the rationale for selecting a 95% readiness score for each region?  Does this simply
       continue the readiness level achieved in  the past, or is this an improvement?  Some information
       about the historical context of this target would be helpful.

       •   Between 2006 and 2011,  complete 975 Superfund-lead hazardous substance
          removal actions.  In FY2005, 175 of these actions were completed.

       NACEPT SA Comments
       No baseline specified. Is this a significant target?

       NACEPT SP Comments
       Still no baseline is specified.  While the target represents a greater than five-fold  increase in
       activity, the overall significance of this increased activity can only be assessed by comparison to
       the total universe of Superfund sites.

       •   Between  2006  and 2011, oversee and  complete  650  voluntary removal
          actions.  In FY2005, 137 of these actions were completed.

       NACEPT SA Comments
       No baseline specified. Is this a significant target?

       NACEPT SP Comments
       Still no baseline is specified.  While the target represents a greater than four-fold  increase in
       activity, the overall significance of this increased activity can only be assessed by comparison to
       the total universe of potential clean-up sites.

       •   By 2011, reduce by 25 percent the gallons of oil spilled by  facilities subject to

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          Facility Response Plan regulations relative to the 601,000 gallons of oil spilled
          in 2003.

       NACEPT SP Comments
       This target also has no baseline. What is the expected level of oil spill by 2020? Does this 2011
       target get the nation far enough to the goal?  Should it be higher? What fraction of facilities
       experiencing spills are subject to Facility Response plan regulations?  Do spills at non-covered
       facilities represent a significant impact on the environment?

       •  By  2011, increase the compliance rate to 90  percent of all facilities subject to
          Facility Response Plan regulations from 50 percent in 2004.

       NACEPT SA Comments
       Does the relevant statute allow EPA to establish targets less than full compliance by the regulated
       community?

       NACEPT SP Comments
       NACEPT continues to be concerned that the relevant statute does not allow EPA to establish a
       target of less than full compliance by the  regulated community. The Means and Strategies for
       this sub-objective does not identify the statutory authority under which EPA may exempt 10% of
       facilities from this requirement, or the criteria under which EPA would identify facilities eligible
       for exemption.

       Sub-objective 3.2.2:  Clean Up and Revitalize Contaminated Land.  By 2011,
       control the risks to human health and the environment at contaminated properties
       or sites through cleanup, stabilization, or other action,  and make land available
       for reuse.

       NACEPT SA Comments
       Restoration  of brownfields sites  is essential to this objective, vet brownfields sites are  not
       mentioned.   The contribution  of brownfields restoration activities under sub-objective 4.2.3
       should be included here.

       The strategic targets below all have different universe sizes. What is the origin of these varying
       universe sizes?

       Are these current Superfund sites, or do they reflect current sites that could become Superfund
       sites if state or local governments don't take action?

       Strategic Targets:

       •  By  2011,  make  final  assessment  decisions  at  40,390 40,455  of 44,700
          potentially hazardous waste sites submitted to EPA for remedial evaluations
          to help resolve community concerns on whether these sites require long-term


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          cleanup to protect public health and the environment, or if they can be cleared
          of Superfund liability and to help determine if they can be cleared  for possible
          redevelopment.

       NACEPT SA Comments
       No baseline specified. Are all of the sites on the current Superfund list or are these potential new
       sites not vet evaluated?

       NACEPT SP Comments
       The revisions in the language helps address some of the  questions raised in the previous
       comment. However, some additional issues are raised.  A Figure of 40.455 seems to be very
       precise for a target such as this without  some further information. Does this represent the sites
       known to be easy to resolve?  Does it represent a target on a time-lined way to achieve complete
       resolution?  More information would strengthen this target.

       •   By 2011,  control all  identified unacceptable human  exposures from site
          contamination to  health-based levels,  or below,  for current  land and/or
          groundwater use conditions at 84 percent (1,294) of 1,543 Superfund human
          exposure sites (as of FY 2005). This baseline includes 172 Superfund federal
          facility sites.  By 2011,  increase  the percentage  of  high priority NCAPS
          (National Corrective Action Prioritization System)-ranked RCRA facilities with
          human exposures to toxins controlled to XX% from XX% in 20YY.  By 2020,
          control all  identified unacceptable human exposures from site contamination
          to health based levels, or below, for current land and/or  groundwater use
          conditions at 95% of all facilities requiring RCRA Corrective Action 95 percent
          (universe of all facilities that need  RCRA Corrective  Action-including  high-
          ranked facilities-to be finalized by the end of 2007).

       NACEPT SA Comments
       There is no prioritization of sites with highest human impact potential.  A remote site has less
       impact potential than an urban site.

       NACEPT SP Comments
       The revision does provide additional information that clarifies some of the issues raised in the
       previous  comment above. However, the concern about prioritization of sites for attention still
       remains.  While it is a commendable target to reduce unacceptable exposures to health-based
       levels, it does seem that first attention should be given to the sites with the highest human impact
       potential. Is it intended within the  plan  to achieve this target? Explicit language  to clarify this
       would strengthen the target.

       Further, although objective 3.2 talks about controlling risks to human health and the environment
       by cleaning up to "appropriate levels." in the bullet above there is no mention of "risk-based"
       cleanup levels.  The bullet is directed only at achieving "health-based levels."  Why can't the
       Agency apply risk-based cleanup levels  in achieving this  goal in appropriate locations? One
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      problem with Superfund is that it often compels sites to be cleaned up to unrealistic cleanup
      levels, e.g.. achieving MCLs in groundwater when everyone on or around the site is already
      served by public water.

      •   By  2011,  control  the  migration  of  contaminated  groundwater  through
          engineered  remedies or natural processes at 74 percent  (1,016)  of  1,381
          Superfund groundwater sites (as of FY2005).  This baseline includes 166
          Superfund federal facility sites.  By 2011, increase the percentage of h4§k
          priority RCRA Corrective Action facilities with toxic releases to groundwater
          controlled to XX% from  XX% in 20YY.—By 2020,  control the migration of
          contaminated—groundwater—through—engineered—remedies—GF—natural
          processes at 95% of all facilities requiring RCRA Corrective Action migration
          of  contaminated  groundwater under control  to 50 percent  of  all facilities
          requiring RCRA Corrective Action  (universe  to be  finalized by the end of
          2007).

      NACEPT SA Comments
      There is no indication of priority or importance of sites to be controlled. For example, are they
      large or small sites? What is the potential exposure represented?

      NACEPT SP Comments
      Because the current (baseline) percentages of Superfund and RCRA Corrective Action sites under
      control is not specified, it is not possible to determine whether 74% and 505. respectively,  are
      meaningful targets. Moreover, the issue of prioritization of those sites with the highest impact is
      still unresolved.

      •   By 2011, reduce the backlog of LUST cleanups that do not meet state risk-
          based standards for human exposure and groundwater migration from 27%
          26  percent  down  to 20%  21  percent,    aed  For  Superfund,  complete
          construction  of remedies   at approximately  76  percent  (1,171)  of  1,547
          Superfund sites (as  of FY2005).   This  baseline includes 172  Superfund
          federal facility  sites.  (Note:  construction completion is a milestone  which
          indicates that  all  significant construction activity has been  completed, even
          though additional  remediation may be  needed for  all  cleanup goals  to  be
          met.)

      NACEPT SA Comments
      It is unclear what is meant by backlog as a percentage of some  unidentified number.  Is  the
      percent backlog related to the 1.547 Superfund sites or some other universe?

      NACEPT SP Comments
      It is still unclear what is meant by backlog of LUST cleanups.  Some additional information about
      the nature and compiler of this list would be helpful. Even more helpful for both the LUST and
      Superfund  targets would be a discussion of the plan for the timing of getting these lists to zero.

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       That leads to some question about how aggressive these target numbers are? What is the date for
       the end-game, and do these target numbers place the program where it needs to be by 2011 ?

       •—By 2020, complete construction of final romodios at 95% of all facilities requiring
          RCRA Corrective Action (universe to be finalized by end of 2007).

       -—By 2011, ensure that 90% of tho 115 Suporfund Federal facility sites on tho NPL that
          require 5 year reviews remain protective of human health and tho environment  or
          actions are underway to ensure such protectiveness.

       NACEPT SA Comments
       If 115 Federal facilities require 5-year reviews, then the Federal government should be committed
       to 100 percent compliance.

       NACEPT SP Comments
       We note that this target has been removed. We would expect however that the goal, even if it is
       not in the plan, would not be forgotten.

       -—By 2011, doloto 8% (105) of 1,239 final NPL sites  (as of FY 2005) that require no
          further response activities to protect human health or tho onvironmont.  This basolino
          includes 158 Superfund Federal facility sites.

       NACEPT SA Comments
       It is unclear what the objective is here.  If the objective is to clean up 105 sites to the "no further
       response" level,  this should be made clear.  This does not seem like an aggressive enough goal.
       and implies that it will take more than a century to address all  1.239 current NPL sites.

       NACEPT SP Comments
       We note that this target has been removed.

       •   By  2011,  ensure  that  XX percent (xx number)  of XX  final  and  deleted
          construction   complete  NPL  sites  are  ready  for  reuse  (i.e.,  EPA  has
          determined that all cleanup goals have been met for media that may affect
          current and  reasonably anticipated future land uses and that controls are  in
          place so there are no unacceptable risks to human health). (NOTE: In order
          to develop realistic targets for this measure, EPA is developing the baseline
          of the final and deleted construction complete NPL sites that currently meet
          these criteria.)

       NACEPT SP Comments
       It is not clear why this should be a strategic target.  It implies that some deleted construction
       complete NPL sites are not ready for reuse.  It begs the question of how sites could be deleted if
       they were not ready for reuse. Is there some other problem involved that is not stated? It is even
       more problematic because no numbers are presented at this stage.  Is it a big problem?  How


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       fixable is it?

       Sub-objective 3.2.3:  Maximize Potentially Responsible Party Participation
       at Superfund Sites.   Through  2011,  conserve  Superfund trust fund  federal
       resources by  ensuring that  potentially  responsible  parties  conduct or pay for
       Superfund cleanups whenever possible.

       Strategic Targets:

       •  Each  year through 2011,  reach  a settlement or take  an enforcement action
          before the  start of a remedial action at 95 percent of Superfund  sites having
          viable, liable responsible parties other than the federal government.

       NACEPT SA Comments
       This target should also include and encourage voluntary clean-up  actions by responsible parties
       prior to settlement or enforcement action.

       NACEPT SP Comments
       The clear reading of this target suggests that essentially everything will be accomplished in the
       first two years of this initiative. Is that what is intended? The writing says that in year one, work
       will be begun at 95% of all sites having an identifiable responsible party.  Then in the second year
       95% of the remaining 5% will be initiated.  That is 4.75% of the  original number, leaving only
       0.25% for work in the remaining years.  If this is what is meant, it  is a laudable goal, however to
       achieve this much in the first year would have to mean either that the universe to work with is
       very small, or that much preliminary effort is in place to achieve  so much in one year. In any
       event this needs clarification.

       Further, the Agency needs to understand why settlements  aren't taking place  now to the level
       desired.  In the means and strategies portion of this section of the plan there is no discussion
       about promoting flexibility in selecting remedies at Superfund sites.  PRPs might  be more likely
       to settle with EPA if the Agency was more willing to  select alternative remedial technologies.
       such as bioremediation versus traditional pumping and treating remedies, where such alternatives
       are appropriate.  Also, the Agency could consider the use and promotion  of alternative dispute
       resolution mechanisms and mediation in the settlement process.  The court system  is increasingly
       encouraging the use of alternative dispute resolution and mediation, and the Agency may want to
       consider including a mention of increasing the use of ADR and mediation as a part of the means
       to achieve this goal.

       •  Each  year through  2011,  address   all  unaddressed  costs  in Statute  of
          Limitations cases for Superfund  sites with unaddressed total past Superfund
          costs equal to or greater than $200,000.

       NACEPT SA Comments
       While this is a good objective for cases over $200.000. does this imply writing off cases less than
       $200.000?  What does this mean in terms of lost recovery of public expenditures related to these

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      sites? Is write-off of less than $200.000 sites authorized under the statute?

      NACEPT SP Comments
      NACEPT  remains  concerned that writing off cases involving unaddressed costs less than
      $200.000 is not authorized by statute and may impose a significant burden on the public.

      Further, experience suggests that EPA often addresses these situations simply by signing tolling
      agreements with the PRPs. which does nothing to encourage settlements and merely postpones
      decisions.  Is this objective expected to be met by entering tolling agreements or is it targeted at
      actually recovering reimbursement of EPA's expenses?

Means and Strategies for Achieving  Objective 3.2

      EPA leads the federal government's effort to reduce the risks posed  by releases
of harmful substances and by contaminated land, and return land to beneficial  use.  The
most  effective  approach  to  controlling  these   risks  incorporates  developing  and
implementing prevention  measures, improving response capabilities,  maximizing the
effectiveness of response and cleanup  actions, and promoting  a vision of protective,
sustainable, and productive uses of formerly contaminated properties.

      EPA works with organizations at every level of government and the private sector
to maximize its ability to control risks from accidental and intentional releases of harmful
substances,   contaminated lands,  and  hazardous  waste  sites.  Human  health  and
environmental protection  is  the  responsibility  of all affected  individuals,  and   it  is
important  to  engage  communities, organizations,  businesses,  and governments  in
collaborative  efforts toward returning  lands to  beneficial  use.   In this way, we can
increase public  understanding of environmental  issues,  help  ensure the  long-term
sustainability  of our cleanup efforts, and become environmental stewards for land that is
returned to beneficial use.

PREPAREDNESS AND RESPONSE

      EPA plays  a major role in reducing the  risks that accidental  and intentional
releases of harmful substances and oil pose to human health and the environment.
Under the National Response System  (MRS),  EPA evaluates and responds  to
thousands of releases annually.   The MRS is a multi-agency preparedness  and
response  mechanism  that  includes  the  following key  components:   the  National
Response Center;  the National  Response  Team  (NRT),  composed of 16 federal
agencies;  13 Regional Response Teams;  and federal on-scene coordinators (OSCs).
These organizations and  entities work  with  state and local officials  to develop and
maintain contingency plans that enable the nation to respond effectively to hazardous
substance and oil emergencies. When an incident occurs, these  groups coordinate with
the OSC-in-charge to  ensure that all necessary resources, such as  personnel and


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equipment, are available and that containment, cleanup, and disposal activities proceed
quickly,  efficiently, and effectively.  EPA's primary role in the MRS is to serve as the
federal OSC for spills and releases in the inland zone.

Preparing for Emergencies

      Preparedness on  a  national  level  is  essential  to  ensure  that  emergency
responders are able to deal with multiple, large-scale emergencies, including those that
may involve chemicals, oil, biological agents, or weapons of mass destruction. Over the
next several years, EPA will continue to enhance its core emergency response program
to respond quickly and effectively to chemical, oil, biological,  and radiological releases,
and  large-scale national  emergencies.   Our efforts  will focus on  continuation  of
specialized training on the Incident Command System, development of additional health
and  safety  materials and participation in  exercises  with  federal,  state  and  local
government agencies,  including  the  Regional  Response  Teams,  and  response
readiness across multiple regions.

      In addition to enhancing our readiness capabilities, EPA will  work to improve
coordination and  communication mechanisms.   For example, as  part of the National
Incident Coordination  Team,  EPA will  continue to  improve  its   mechanisms for
coordinating  responses   to  national  emergencies.     Under  the  Continuity  of
Operations/Continuity of Government program, we will upgrade and test plans, facilities,
training, and equipment to ensure that essential  government business  can continue
during  a catastrophic emergency.  Our NRT capabilities will also expand to ensure
coordination  with  the  Department   of  Homeland  Security,   Federal  Emergency
Management Agency (FEMA),  Federal Bureau of Investigation  (FBI),  other federal
agencies, and state and local governments during large-scale responses.

Responding to Hazardous Substance Releases and Oil Spills

      Each year, EPA personnel assess, respond to, mitigate, and clean  up thousands
of releases—whether accidental, deliberate, or  naturally  occurring.   These incidents
range from small  spills at chemical or oil facilities to larger accidental releases in train
and highway accidents, and from natural disasters such as hurricanes Katrina and Rita,
and earthquakes to national emergencies such as terrorist events.

      EPA will  work to improve its capability to respond effectively to  incidents that
involve harmful  chemical, oil, biological, and radiological substances.  The Agency will
improve its  response readiness levels, review response  data provided  in  the "after-
action" reports following  the response to a  release, and examine  "lessons  learned"
reports to identify which activities work and which need to be improved.  Over the next 2
years,  EPA will  work to expand  the  current core emergency response program  to
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include prevention and preparedness,  thereby covering  all aspects  of  emergency
management.  The removal response measures have been revised from  start of the
action to completion of the cleanup to better reflect the accomplishment of the outcome.

Preventing and Preparing for Oil Spills

      An important component of EPA's land strategy is preventing oil spills and being
prepared for spills that do  occur so that the oil does not reach our nation's  waters.
Under the  Oil Pollution Act,xl the Agency requires certain facilities (defined in 40 CFR
112.2) to develop Facility Response Plans and to practice implementing the plans by
conducting drills and exercises to be prepared in the event of a spill. Compliance with
these requirements reduces the number of oil  spills that  reach navigable  waters and
prevents detrimental effects on human health and the environment should a spill occur.
Over the next 5  years, EPA will work to ensure at  least  90 percent compliance with
these regulations by industry.  Compliance at the end of FY 2005 was 77  percent.

NACEPT SP Comments
This section appears to be clearly related to one of the strategic targets.  It is not clear, however, precisely
what will be done by EPA to lead to this level of compliance.  Is this to be enforcement action.
compliance assistance, education, training, or something else? This  seems to be a particular complex
target because while EPA can commit to doing many things, compliance will depend on response by the
regulated community. How does EPA propose to assure the necessary response to achieve the target?
Again, it is unclear whether EPA has statutory authority to set a target of less than full compliance by the
regulated community.
Cleaning Up And Revitalizing Contaminated Sites

      The primary goal of EPA's cleanup programs is to
protect  America's  citizens from the  risks  posed  by
contaminated  land;  restore the nation's  contaminated
land; and enable America's communities to safely return
these properties to beneficial  economic, ecological, and
societal uses.   In  implementing its  cleanup programs,
EPA will ensure that all people are treated fairly,  given
equal opportunity to  participate meaningfully in making
the cleanup decisions about these contaminated lands,
and  that  no  one  portion  of the population  bears a
disproportionate health burden.

      EPA continues to foster a One Cleanup Program,
which  is a long  term initiative designed  to  encourage
programs at all levels of government to work together to
ensure that appropriate cleanup tools are used; that  resources, activities,  and results
                        "Revitalization"

                The term "revitalization" in its
                broadest sense means to impart
                new life, energy, or activity to
                something. In the context of
                contaminated or potentially
                contaminated properties,
                revitalization refers to actions
                taken to promote protective,
                productive, and sustainable use,
                continued use,  or reuse of
                property. These revitalization
                actions can help to impart new life
                to properties, resulting in
                enhancements to America's
                communities and ecosystems.
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are coordinated with  partners  and stakeholders and communicated  to  the public
effectively;  and that cleanups are protective and contribute to community revitalization,
including areas with environmental justice concerns. While the approach reflects EPA's
efforts to coordinate  across  all of its cleanup  programs, the  Agency  maintains  the
flexibility needed to accommodate differences  in program authorities and approaches.

Common Elements of Environmental Cleanups

      Common elements  of EPA's  cleanup  programs  include  initial assessment,
stabilization (when  needed),  site  investigation, selection  of  appropriate  remedies,
implementation and  completion of remedies, and promoting protective uses/reuses.
EPA performs these activities in cooperation  with partners who share authority for the
sites,  and works with federal, state, tribal, and local government partners  to identify
facilities and sites requiring attention and to  implement these elements.

Assessing Sites

      All cleanup programs assess preliminary site information to determine whether or
not contaminated sites or facilities pose a significant risk  to human health and  the
environment and require  cleanup actions.   Site assessments  can also assist in  the
determination  of whether or  not  sites  can  be cleared for possible redevelopment.
Attainment of final site assessment decisions  is a strategic target for EPA's Superfund
program.
Stabilizing Sites

      "Stabilization"  refers  to  the   initial
actions  taken to  control actual or  potential
exposure, based  on current land and water
use.  Where  necessary, these actions are
taken  immediately  to  protect  populations
located  within a  reasonable distance from
the site from existing or imminent exposure
to harmful contaminants.

      EPA's   Superfund   and    RCRA
Corrective   Action   programs  use   two
environmental indicators—controlling human
exposures   and   controlling   groundwater
migration—to  help   communicate  to  the
public progress that  is being  made toward
protecting    human    health    and    the
environment  due to stabilization and  other
         Controlling Human Exposures and
              Groundwater Migration

     Controlling unacceptable human exposures
     to contamination and preventing the
     continued spread of contaminated
     groundwater are key indicators of cleanup
     progress. When EPA determines that human
     exposure is under control at a site, it means
     that there is no exposure to contaminants at
     unsafe levels under current site conditions.

     When a determination is made that
     groundwater migration is under control at a
     site, it means that contamination levels fall
     within the levels specified as safe by EPA, or
     if they do not, that the contaminated
     groundwater is not continuing to spread
     above unacceptable levels or negatively
     affecting surface water into which
     groundwater may be flowing.
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cleanup activities.
Investigating Sites and Selecting Site Remedies

      EPA and its partners conduct detailed environmental investigations to identify the
type and extent of contamination, as well as actual or potential exposures to humans
and environmental receptors.  The data collected from these activities are used to make
critical determinations  regarding  risks  to human  health and the environment  and
eventual remedy selections. To better address areas  that may suffer  disproportionate
impacts, EPA will  encourage the broader use of improved sample collection techniques,
analytical (e.g., on-site chemical analysis)  tools and indicators.  Approaches will include
those previously developed by EPA's Office of Environmental Justice to identify areas
with potential environmental justice concerns.

      Remedies  are selected based on many criteria, including  the environmental
media of  concern (e.g.,  soil,  air,  groundwater,  etc.),  cleanup objectives based on
protection associated with reasonably expected  uses  of  the site  (e.g., industrial,
commercial, residential, ecological,  recreational), compliance with applicable laws,
implementation  issues, and  acceptability to  state and tribal  governments  and the
affected communities.  Cost  and efficiency of the overall cleanup process are  also
important. When  remedies involve leaving contamination in place, EPA will continue to
ensure that such remedies include institutional controls like notices  and easements
designed  to  prevent  inappropriate  uses of  the land  or  water  and/or associated
unacceptable exposures.

Completing the Site Cleanup

      Implementing remedies and completing the site  cleanup involve  constructing
remedy components that  are  designed to  provide long-term protection  and  include
performing any remaining cleanup actions  that do not  require physical  construction
(e.g.,  monitoring).  Completing construction of all remedies at a site or facility is an
important  milestone and is a  strategic target for several of  EPA's cleanup programs.
The RCRA program has developed a long-term goal  of  implementing and completing
construction of final remedies at  95 percent of all facilities that need RCRA corrective
action by 2020 [Beyond RCRA (http://www.epa.qov/epaoswer/osw/vision.htm)1,  and we
will be developing interim annual targets to achieve this goal in 2008.

      During remedy construction and following construction  completion, the Superfund
program conducts reviews every 5 years to ensure that the remedy is functioning as
intended and that it remains protective.  With the large number of sites moving  into the
post-construction  completion stage,  EPA will  implement a  strategy to manage post-
construction         completion         activities          (PCC         Strategy,
http://www.epa.gov/superfund/action/postconstruction/)  over  the next  5  years.   The
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purpose  of this strategy is to ensure the long-term effectiveness of response actions in
protecting human health and the environment at a site.  The PCC Strategy  sets the
following five goals:  (1) ensure that remedies remain protective and cost effective;  (2)
ensure that required  institutional controls are  implemented and effective; (3) ensure
adequate financing and capability to conduct  PCC activities; (4) support appropriate
reuse of  site while assuring remedy reliability; and (5) improve site records management
to ensure remedy reliability.

      A  key milestone for all cleanup programs is the point at which all cleanup goals
for a particular remedy or an entire site/facility are achieved.   Depending  on  the site-
specific goals, this can mean that no contamination is left above levels of concern and
that the  land  has no restrictions to its use,  based on  environmental  contamination.
When contamination is left in place,  cleanup goals are based  on restricted uses of the
property.  In these situations, long-term protectiveness is contingent on the continued
operation and maintenance of appropriate institutional and, if necessary,  engineering
controls such as monitoring.  For the Superfund program, sites can be deleted  from the
National  Priorities List after all remedies at a site have met their cleanup goals.

Promoting Protective Uses/Reuses of Previously Contaminated Land

      EPA's  cleanup programs  have  set a national  goal  of  returning  formerly
contaminated  sites to  long-term, sustainable, and productive use.  This  goal creates
greater impetus for selecting and implementing remedies that, in addition to providing
clear environmental and human health outcomes, also support reasonably anticipated
future land use options and provide greater economic and social benefits.

      Revitalization (http://www.epa.gov/oswer/landrevitalization/) is fostered in several
ways: (1) developing policies and systems  for the safe long-term  use of remediated
land;  (2) identifying and  removing unintended  barriers that hinder a  community's
beneficial reuse of contaminated properties;  (3) working with the private marketplace to
make formerly contaminated properties commercially attractive;  and (4) developing
revitalization measures and indicators for all EPA cleanup programs.

NACEPT SP Comments
NACEPT  suggests that the Agency should add to the 4 ways identified for revitalization the  following:
"(5) providing grants, loans and other financial assistance to state, local, and tribal governments and local
economic  and redevelopment authorities for brownfield assessment and remediation." EPA  has made
brownfield redevelopement a pillar of its efforts to reuse land and that should be recognized here.

Maximizing Potentially Responsible Party Participation at Superfund Sites

      Enforcement authorities play a critical  role in all Agency cleanup programs.
However, they have an additional and unique role under the Superfund program.  They

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are used to leverage  private party resources to conduct  a majority of the cleanup
actions and to reimburse the federal government for the federally financed cleanups.
EPA will continue to pursue  the following two strategies for limiting the use of federal
funds.

"Enforcement First"

       Under  the  Superfund program's  "Enforcement  First"   strategy,  EPA takes
enforcement actions at sites  where viable, liable potentially  responsible parties (PRPs)
exist, so that the PRPs either pay for or perform the cleanup at the site.  This strategy
allows EPA to focus limited federal resources on sites where PRPs either do not exist or
they lack the funds  or  capabilities needed to conduct the cleanup.  In order to ensure
that these parties are able to meet their cleanup obligations, EPA developed a national
strategy  to  assess  companies'  compliance   with  federal  financial  assurance
requirements  and will implement it over the next several years.  EPA will continue to
leverage  private party dollars so that federal money  is used  only  when  absolutely
necessary to clean up hazardous waste sites.

Recovering Costs

       Cost recovery is  another  way to leverage private party resources through
enforcement.  Under Superfund, EPA has the authority to compel private parties to pay
back  federal   money  spent  to  conduct  cleanup  activities.  [(42 USC 9601-9675,
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA),
Sec. 107.)]  EPA will continue its efforts to address 100  percent of the unaddressed past
costs for Statute of  Limitations cases at sites with unaddressed total past Superfund
costs equal to or greater than $200,000 and to report the value of costs recovered.

NACEPT SP Comments
This section provides much interesting detail about the way that EPA carries out the CERCLA  and
RCRA-related site clean up processes.  However, the section does not seem to link clearly with the
strategic targets, particularly in specific means and strategies to accomplish  the very specific numerical
targets. This raises a number of questions related to why these targets exist at all if the plan is to simply
continue to carry out the current practices. If the targets represent specific issues or needs that have been
identified, some readers might conclude that they exist because  of shortcomings in existing practices.
The fact that no new initiatives or needed enhancements are discussed leaves doubt about the possible
success of achieving the targets.  Again, it is unclear whether EPA has statutory authority to write off
recovery of costs in cases less than  $200.000.

Further, one reason why it is difficult for the Agency to recover 100 percent of its costs is that past
inefficiency in the Superfund remedy selection process has resulted in waste, which leads to bickering and
inaction over the past costs. NACEPT suggests that the Agency have a sub-goal that  states that it will use
its Superfund dollars efficiently and that it will evaluate the cost-effectiveness and performance of its
contractors in achieving that goal.  PRPs would be more likely to reimburse the agency willingly for its

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expenditures if they could see that the Agency and its contractors were not wasting money, over studying
sites, for example.  There is some discussion of cost-effectiveness under Goal 3. That point needs to be
emphasized more. Again, the Agency should look inward at its contracting practices to help achieve cost-
effective remedies in order to achieve 100 percent reimbursement of those expenses. That is especially
important now when there is no new tax money being put into the Superfund accounts and work is all
funded out of the general budget.  It's not enough to say you are going to get 100% reimbursement.  The
Agency needs to maximize the efficient use of its limited Superfund dollars in all aspects.

OBJECTIVE 3.3:  ENHANCE  SCIENCE AND RESEARCH.  Through 2011, provide
and apply  sound science for protecting and restoring land by conducting leading-edge
research, which through collaboration, leads to preferred environmental outcomes.

       Sub-objective   3.3.1:    Provide  Science  to   Preserve   Resources  and
       Remediate  Land.    Through  2011,  provide  sound science  and  constantly
       integrate  partner inputs for smarter technical solutions and protection strategies
       that enhance  our ability to remediate contaminated land  for beneficial  use,
       conserve resources and materials management, and preserve land quality.

       Strategic Targets:

       •   Through 2011, lead the incorporation of sound science as determined by peer
          review into guidance and decisions on  land preservation,  remediation, and
          response.

       NACEPT Comments
       What does this target mean, who determines that the science  is sound, and how will this be
       measured?

       NACEPT SP Comments
       We continue to have the same comment. Of particular continuing concern is the issue of how  this
       target will be measured? How can quantification of incorporation of sound science be achieved?
       In practical terms, the answer to that question would seem to benefit directly the entire research
       and development enterprise of EPA.

       •   Through 2011, facilitate the deployment of new technological approaches at
          sites,  develop state-of-science-reports,  and provide training  on  emerging
          applied science issues.

       NACEPT SP Comments
       What performance metrics will EPA use to assess the success and effectiveness of this effort?

    Sub-objective 3.3.2:   Conduct Research to  Preserve Resources and Support
    Land  Remediation Activities.    Through  2011,  conduct  sound,  leading-edge
    scientific research to provide a foundation for preserving  resources, supporting land

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    quality,  and remediating contaminated land.   Research will  result in  documented
    methods,  models,  assessments, and risk  management  options for  program and
    regional offices, facilitating their accurate evaluation of effects on human health and
    the  environment,  understanding of  exposure pathways,  and  implementation  of
    effective  risk-management   options.  Communicate  Disseminate  the  research
    affecting Indian country in partnership with the tribes.

    NACEPT SA Comments
    The last sentence referencing Indian country seems to be disconnected from the sub-objective.

    NACEPT SP Comments
    The last sentence continues to seem disconnected from this sub-objective. Has EPA identified some
    unique issue related to resource presentation and/or land preservation on tribal lands that requires
    unique knowledge transfer mechanisms?  Conversely, is this sentence intended to limit knowledge
    transfer only to tribes?

Means and Strategies For Achieving Objective 3.3

Science to Preserve and Remediate Land

       EPA will continue  to  improve its capability to assess environmental  conditions
and determine the  relative risks  that contaminated land  poses to health  and  the
environment.   The Agency  will ensure that the environmental data it collects  are of
known, documented, and acceptable quality by implementing  necessary field and  lab
procedures,  practices, and  controls.    We   will  continue  integrating  technological
advances  to enhance our site  investigation capabilities,  implement  cost-effective
remedies,  and improve  the operation and maintenance of  existing remedies.   In
addition, we will continue to coordinate with other agencies to identify and communicate
program research priorities.

NACEPT SP Comments
NACEPT suggests that the agency clarify whether the paragraph above is addressing its capabilities under
just Superfund and RCRA or under all of its programs. Again, in this paragraph the Agency uses the
words "implement cost-effective remedies".  There is very little in the body  of the plan, however,  that
identifies the means for implementing those cost  effective  remedies.   For example, there is some
discussion about using sound science and cutting edge research. How is that expected to percolate down
to the people in the regional  offices selecting the remedies?  The  only way it can do so is through
continuing training and education of the staff on the results of the research and the use of new  and
alternative remedial technologies.  EPA needs to deal with the disconnect between its research efforts and
the people implementing the day-to-day activities of the Agency. NACEPT suggests some mention here
in the strategic  plan of a process of (1) research. (2) education and training, and  (3)  implementation.
Perhaps part of that can go in the Human Capital section. Currently that section talks about readiness. It
should also address training and education of regional office staff.
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      Multimedia risk assessment methodologies for solid waste are built upon prior
collaborative work within the Agency to  develop the Multimedia, Multipathway,  and
Multi-receptor Risk Assessment (3MRA) modeling system  in support of the Hazardous
Waste Identification Rule (HWIR).  3MRA development will focus on addressing key
recommendations by the Science Advisory Board  and will address uncertainty analysis,
sensitivity analysis, and parameter estimation in model-supported, risk-based  decision
making.  Resource conservation research will be conducted to provide a preliminary risk
screening for electronics  waste  based  on  current  understanding of  hazardous
constituents. At the same time,  additional work will be conducted to better understand
the hazardous constituents and how they might pose  risks during various recycling
operations, disposal, or component reuse.

      The 3MRA model will also evaluate relative risks on a national  basis of various
waste disposal options for use in  regulatory decision-making. In addition to modeling,
material  evaluation by speciation and  leach testing is  needed  to understand  what
hazardous constituents might be released in various disposal and use  scenarios.  EPA
has  targeted  specific materials  for volume  reduction  to  minimize generation of
hazardous waste and other materials for beneficial  use to  demonstrate one facet of
resource conservation. Research is planned to support these efforts with case studies.

      While the emphasis  on  cradle-to-cradle materials management has increased,
we realize that significant volumes of municipal,  commercial, and industrial waste will
continue to be produced for the foreseeable future. Materials  management research will
evaluate  landfill  caps, improving  containment technologies.  Ongoing  research  on
operation of  landfills as bioreactors will continue. The research is addressing operation
and  monitoring parameters, as well as  evaluating  risks such  as  increased fugitive
emissions. Results to  date have been incorporated in training and technology transfer
materials used by state permitting officials.

Research to  Clean Up and Revitalize Contaminated Land

      EPA's  land research program supports our objective of  reducing or controlling
potential risks to human health and the environment at contaminated waste  sites by
providing the science to accelerate scientifically defensible and cost-effective decisions
for cleanup at complex  sites,  in accordance  with the Comprehensive Environmental
Response, Compensation, and Liabilities Act (CERCLA).   This program will  produce
measurable benefits in the form of:

   •  better management of material streams, conserve  resources and  appropriately
      manage waste;  and
   •  more   effective   mitigation,  management  and   long-term   stewardship  of


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      contaminated sites.
        Research will focus on  contaminated sediments, ground water contamination,
site characterization, and technical support to specific sites.  Reducing uncertainties in
the assessment  of contaminated sediments and developing and evaluating remedial
options will be the focus of this research theme.  Research activities on sediments will
develop  the  framework  for   modeling  remedial  alternatives  and  an  improved
understanding of causal relationships  between sediment contamination and chemical
residues/exposure to aquatic organisms. The Agency is  investigating several  alternative
sediment  remedies with the potential to  be more cost-effective than conventional
dredging or capping remedies.   An emphasis is  being  placed  on  bioremediation of
organics, electrochemical degradation, and conventional and reactive landfill caps.  In
coordination with the U.S.  Army Corps  of  Engineers,  and in  association with  the
Strategic  Environmental  Research  and  Development  Program (SERDP),  we  will
complete a number of research  projects to evaluate the field performance of dredging
and capping, to improve understanding of the best management practices.

      EPA's ground water research will continue to develop applications for  permeable
reactive  barriers  and  address fate  and  transport  and treatment  methods  for
contaminants.   Ground  water  remediation of inorganic plumes and  ground water-
surface water assessment strategies will be stressed. Research on dense nonaqueous
phase  liquids  (DNAPL)  source  remediation  is focused  on three critical issues:   1)
Demonstration, evaluation and  optimization  of  DNAPL  remediation technologies;  2)
Assessment  and  prediction  of the   benefits  of  partial DNAPL depletion  and  3)
Development and assessment of integrated  DNAPL source remediation approaches.
Our  technical support centers  will  continue to provide site-specific  assistance on
technical issues.

      Research  in support  of EPA's  leaking underground storage tanks program  will
provide  fate  and transport  studies  and  the  effectiveness of remedial alternatives.
Emergency response activities  for  oil spills  are supported  by research on fate and
transport and risk management strategies for petroleum and non-petroleum oil spills.

      Progress toward research goals is assessed through a suite of metrics that is
tailored  to measuring the impacts of the respective research  programs.  Among  the
measurable factors are:  independent expert review panel  ratings on the extent to which
clients utilize  EPA research  products;  composite scores on a client survey designed to
gather  data on product  utility and perceptions of use;  and the results of bibliometric
and/or  client  document analyses demonstrating  the  actual  use of  EPA research
products.  These  factors are applied  to  measure success in providing the  results
identified in the research program.

NACEPT SP Comments
This section provides a detailed account of aspects of the current EPA R and D program. However, it is

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not clear in this means and strategy section exactly how this discussion relates to the strategic targets.  It
would be extremely helpful to point out the specific type of activities that will advance progress to the
planned targets in order to allow determination of whether metrics of progress can be developed, and
equally important,  whether sufficient resources have been made available to accomplish the planned
results.

HUMAN  CAPITAL

       EPA's emergency  prevention,  preparedness,  response,  and  cleanup  staff are
vital to the work of this Goal. The Agency will continue to enhance the interdisciplinary
skills of technical personnel  in the field, ensuring their readiness and protecting  their
health and safety when they are responding to  releases  of dangerous  materials and
cleaning  up contaminated lands. This  will  be accomplished through annual on-scene
coordinator readiness  training conferences, continuation of specialized training on the
Incident Command System, development of additional health and safety  materials, and
participation  in  exercises  with  federal,   state, and  local  government  agencies.
Additionally,  acquisition  and   maintenance of appropriate  response  equipment,
experience  with daily cleanup  operations, and pre-deployment of responders for
national  special  security events will contribute to the enhancement  of workforce skill
levels.

NACEPT SP Comments
Knowing the forecasted Human Capital issues related to potential retirement of a significant proportion of
EPA personnel in the next few years, it would be helpful to have some discussion of how that might
impact achievement of the goals  of this  section.   In addition, some commentary about the plans to
overcome any potential negative impact would be helpful, as well.

PERFORMANCE MEASUREMENT

      As a first step  in developing measures for revitalization  described below, the
Superfund  program has set a target for a "site ready for reuse" measure to demonstrate
cleanup progress. This measure tracks  NPL sites as follows:  where construction of the
remedy  is complete;  where cleanup  goals  in  the  Record  of  Decision have been
achieved  such  that there are  no unacceptable risks associated  with  current and
reasonably anticipated future uses; and where all institutional controls required in the
Record of Decision have been implemented.

       In this Goal, all of  the strategic targets will be directly measured on an  annual
basis as annual performance goals and measures  in the Agency's  Annual Plan and
Budget.  At the  end of each year, EPA's  Performance and  Accountability Report will
address whether the annual commitments were met.   In this way, progress toward the
longer-term commitments  will be measured annually over the 2006-2011 time horizons.
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      For the research sub-objective, EPA will track annual progress toward expected
long-term results  by  means  of  multiple,  objective-based  measures  of  customer
satisfaction,  product impact and quality, and efficiency.

NACEPT SP Comments
Some further discussion of how these efforts in performance measurement relate to the strategic targets in
this plan  would be helpful.   Perhaps even more helpful  would be discussion about longer-term
performance measurement. When are these issues all expected to be reduced to no further problems, or at
least a small number of newly identified locations? Do  the strategic targets put the Agency and the
Nation on a meaningful timescale to achieve the desired results?

Influences of Environmental Indicators and PART Measures on the Strategic Plan

       Goal 3 currently contains one metric relating to waste generation as a strategic
target that also appears in EPA's forthcoming 2007  Report on the Environment (ROE).
Long-term outcome  measures for the Agency's   cleanup programs  also  serve as
environmental indicators  in that report. While we  recognize  the importance of these
indicators, EPA also recognizes their limitations  with  respect  to  capturing broader
descriptions of the state of contaminated land in the United States.  The latest version of
the   ROE    and    information    associated    with   it   can   be   found   at
http://www.epa.gov/indicators/index.htm.

      Most  of the strategic targets for the waste management, underground storage
tank, and Superfund programs are based on the long-term, outcome-oriented measures
developed by  EPA for use  in OMB's  Program Assessment and  Rating  Tool (PART)
assessment.

      As a  result  of the  self-evaluation conducted during the FY  2005 OMB PART
process,  the Superfund  program: (1) enhanced a key outcome measure to better
communicate progress towards long-term  human health; (2) added a new measure to
reflect the lasting impacts of land cleanup and restoration; improved our processes for
reporting on annual  and long-term performance  data to ensure  accountability;  (3)
implemented a new program review process and  undertook its first benchmarking study
to seek  improved  performance, effectiveness and  efficiencies,  and protection.   The
OMB PART  for the Oil Removal Program led to the  development of new measures and
related targets as well as  a  commitment to develop  a second long-term  outcome
measure and at least one annual outcome measure.

NACEPT SP Comments
The information  in this section seems to be related to some  of the earlier NACEPT comments about
prioritization in terms of which sites get first attention, particularly with relevance to human health issues.
This entire portion of the Plan would  be  strengthened with some additional elaboration of these
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comments, particularly with regard to how they affect prioritization and the role of human health risk
considerations.

Future Improvements to Performance Measurement

       In support of  EPA's  national goal  of returning formerly contaminated  sites to
sustainable and productive use, the Agency is developing new revitalization measures
for all  cleanup  programs.  These measures will  capture the total number and acres of
sites for which  EPA  has some level of accountability, the number of sites and acres
EPA has determined to be ready for reuse (or protective  of exiting uses), and whether
and how the sites are being used (e.g., industrial, commercial, residential, etc.).

 NACEPT SP Comments
 NACEPT suggests that the Agency should apply the same indicators to sites where EPA has provided
 brownfield assessment  and/or remediation grants to measure the success of  that effort to  reuse
 contaminated land.  It is not enough to measure  the performance just  at Superfund  and RCRA sites.
 because those are just a small fraction of the total sites.

       As the Agency  puts the recording,  updating,  reviewing, and improvement of
scientifically-sound environmental indicators on a routine footing through the Report on
the Environment, we expect increasing opportunities to benefit from these indicators in
future  strategic plans.  This will enable the Agency to increasingly articulate all of our
significant long-term objectives in terms of measurable improvements  in the condition of
land.

NACEPT SP Comments
The previous paragraph contains some very reassuring ideas.  However, it would be good to expand them
a bit by directly referring to how these ideas are connecting to the establishment of the strategic targets in
this plan.

       When  considering revisions  and improvements for developing this Strategic Plan
we  also  conducted a preliminary assessment of longer-term opportunities to  improve
our articulation  of strategic, outcome-oriented commitments for future Plans.  Under this
Goal,  we identified  four  priorities for  developing improved measures:   extent of
contaminated land;  extent  of  land restored to  potential use; extent of previously
contaminated land in productive use; and, the impacts of waste-management efforts on
human and environmental  condition.

CLOSING   THE  FEEDBACK   LOOP:        RESULTS  OF   PERFORMANCE
ASSESSMENTS AND  PROGRAM EVALUATIONS

       In undertaking the  PART process,  the Superfund  Program made the following
policy  and process  changes:  a commitment to develop stronger strategic  planning


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procedures  to  ensure continuous  improvement  in the  program,  including  regular
procedures  that  will  track  and  document key  decisions  and  work  products;  a
commitment to  evaluate the data quality of key data sources used by the program to
improve the accuracy  and reliability  of performance information; and a commitment to
develop a forum for sharing and implementing best practices among regional offices
that will improve the program's overall performance  and efficiency.

      The  EPA Science  Advisory Board  (SAB) conducted an advisory  review of the
Contaminated Sites and RCRA Multi-Year Plans in July 2004.  The following quote  is
from the SAB letter to the Administrator on the findings of the panel:  "In general, the
Panel  finds that the   Contaminated  Sites  and  RCRA   Multi-Year  Plans  are
programmatically and  scientifically  sound.  We   note  in  particular the  remarkable
coordination of  the program's  research with that of the relevant program offices and
other institutions and are encouraged by the judicious use of leveraging opportunities to
significantly stretch limited resources to meet more  of the Agency's needs."  Changes  in
the research program  in response to the  SAB recommendations were: combining the
two multi-year plans into one document, reducing the number of long term goals to two,
and clearer linkage of research activities to program activities in objectives 3.1  and 3.2.

      The  SAB also  reviewed the  Multimedia, Multipathway, and Multireceptor Risk
Assessment (3MRA) modeling  system and delivered a report documenting the findings
of that review  in  November 2004.   EPA is addressing  their recommendations to
maintain  the value, utility,  and credibility of 3MRA.   These  include the continued
development of the 3MRA modeling  system validation protocols,  modeling  system
evaluation,  and  additional uncertainty analysis.

NACEPT SP Comments
We note the reported SAB comments about the close alignment of EPA research efforts with program
activities. Reading of this document seems not to provide details of that close alignment (as indicated
previously). We suggest that this opportunity be revisited in this document.
EMERGING ISSUES AND EXTERNAL FACTORS

      There  are a  number  of  emerging  technologies  with  potentially important
implications for waste management strategies and programs.   One that  could  have
significant  implications for  energy supply is  Waste to Energy (WTE) where waste
materials that are unlikely to  be recycled  have potential as feedstocks for  energy
production. As a  small but growing source of energy  being  monitored by EPA, they
could also replace other sources of energy that are in short supply. With rising energy
costs, WTE may continue to grow as a technology with future energy-saving potential.

      Additionally, significant  research  is  being carried  out  on the  application of

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nanotechnologies to the remediation of hazardous waste sites.  The benefits from the
use  of  nanomaterials  for  remediation  could  include  more  rapid  or cost-effective
cleanups relative to current conventional approaches.  More information on this topic
can be found in the external peer review draft of EPA's White Paper on Nanotechnology
http://www.epa.gov/osa/nanotech.htm.

      Since the  Superfund program was intended to provide permanent solutions at
sites to the maximum  extent  practicable,  complications  arise when  new scientific
information suggests that the cleanup decisions have been based  upon now outdated
risk assessments.  Nevertheless, the program  will incorporate new emerging science
into  our decision making as appropriate and consistent  with the intent  to provide
permanent solutions.

      EPA's ability to respond  as  the federal  On Scene Coordinator  for releases of
harmful  substances in the  inland  zone is affected by several  external factors.  The
National Response system  ensures that EPA will respond when necessary, but relies
heavily on the ability of responsible parties and  state,  local, and tribal agencies to
respond to most emergencies.  The need  for  EPA to respond  is a  function of the
quantity and severity of spills that occur, as well  as the capacity of state,  local, and tribal
agencies to address spills.

      EPA's ability  to   respond   to  homeland  security  incidents  is  affected  by
circumstances surrounding  each event.   For  instance,  if travel or communication is
severely impeded, EPA's response may be delayed and its efficiency reduced.  In the
case of a  single  large-scale incident, our removal activity resources will most likely be
concentrated on  that response,  thus reducing our ability to address other emergency
releases.    In severe  cases,   EPA's  current  emergency  response  workforce and
resources  may not be sufficient to address a many simultaneous large-scale incidents.

      A number of external factors could substantially affect the Agency's ability to
achieve  its  objectives for cleanup and prevention.  These factors  include Agency
reliance on  private-party response  and state and tribal partnerships,  development of
new environmental technologies, work by other federal agencies, and statutory barriers.
State programs are primarily responsible for implementing the RCRA Hazardous Waste
and LIST programs. Our ability to achieve the goals for these programs depends on the
strength and funding levels of state  programs.  Similarly,  our  success in  meeting
compliance standards depends  on extensive training and a strong state presence.  To
increase LIST compliance, EPA will build upon  its commitment to provide  states and
tribes with technical support and  training.

      Achievement of our waste reduction and recycling objectives will depend on the
participation of federal agencies, states, tribes,  local governments, industries, and the
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general  public, in partnerships  that  aim to  reduce  waste  generation and increase
recycling.   EPA  provides national leadership in the areas of waste  reduction  and
recycling to facilitate public and  private partnerships that can provide the impetus for
government, businesses,  and citizens to join in the campaign to reduce the  amount of
waste generated and ultimately sent for disposal.  However,  both domestic and foreign
economic stresses can adversely affect markets for recovered materials.

       Similarly, EPA relies on  its partnerships with  other federal agencies and  tribal
governments to ensure that open dumps in Indian country are upgraded,  cleaned-up, or
closed  and that tribes  have access to information  on  modern  waste management
planning.   Achieving EPA  tribal  waste management objectives  will depend  on  the
successful participation by federal agencies and tribes.

NACEPT SP Comments
This is a particularly interesting section of the plan. We agree that many factors,  such as those listed, may
affect the ability of EPA to achieve the projected strategic results. However, that should be one major
objective of the plan.  If the federal planning exercise, of which this is a part, has been entered into with
the  expectation  that over a  five-year period agreed  upon results can be achieved, then the  entire
government, particularly including the  executive and legislative branches, must also agree that the
resources and level of cooperation necessary to achieve the agreed upon results will  also be provided.
With that in mind, some further elaboration of a few of the paragraphs above with regard to resources and
collaborative activities would be very helpful in advancing the necessary discussions and debates.
NOTES

i.42 U.S. Code 6901-6992k

ii.42 U.S. Code 9601-9675

iii.42 U.S.  Code 7401-767Iq

iv.33 U.S.  Code 1251-1387

v.33 U.S. Code 2701-2761

6 U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response.
Resource Conservation Challenge/ Recycling on the Go web site:
http://www.epa.gov/osw/conserve/onthego/

™ (Core Performance Elements of the Guidelines for Environmentally Sound Management of Wastes,
April 24, 2003, Environment Policy Committee, OECD)

8..42 U.S.  Code 6901-6992k

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1X Title XV, Subtitle B of the Energy Policy Act of 2005 (Public Law 109-58) amends RCRA Subtitle I.

10.Memorandum from Cliff Rothenstein, Director, EPA Office of Underground Storage Tanks to
Underground Storage Tank Division Directors in EPA regions 1-10. December 15, 2005. FY
2005 End-of-Year Activity Report.

11.33 U.S. Code 2701-2761

NACEPT SP Comments
A general comment  is that the current  version  of Section 5  on Compliance and Environmental
Stewardship contains some specific goals relating to pollution prevention and reuse of materials that seem
to exist independently of the strategic targets here in Section 3. Perhaps at this stage of the preparation of
the Plan there has not been time or opportunity to achieve necessary coordination. However, we strongly
urge that such coordination  take place.  From one perspective we urge this because some stronger and
more reaching targets might emerge. From another, it will make the plan appear as a unified, overall -
EPA plan, rather than a collection of plans each from different components of the Agency.
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GOAL 4 - HEALTHY COMMUNITIES AND ECOSYSTEMS

Protect,  sustain,  and  restore the  health  of communities,  and  ecosystems  using
integrated and comprehensive systems approaches and multidisdpUnary partnerships.

   Communities and ecosystems are extremely complex systems of enormous variety.
To protect, sustain,  or  restore the health of communities and ecosystems,  EPA  brings
together a variety  of  programs, tools, approaches,  and  resources; creates  strong
partnerships with  federal, state, tribal, and local government agencies; and enlists the
support of many stakeholders.
                       4.1 Chemical and Pesticide Risks
                       4.2 Communities
                       4.3 Ecosystems
                       4.4 Science and Research

NACEPT SP Comments
As presently ordered, the  Objectives  and Sub-objectives could  give the reader the impression that
identification and mitigation of chemical and pesticide risks are the primary focus of the Agency's
activities under this goal.  NACEPT recommends that EPA emphasize the importance of a systems
approach to healthy communities and ecosystems through greater discussion of the systems approach, or
by reorganizing the section as follows:
      4.1.   Communities and Ecosystems
      4.2.   Science and Research
      4.3.   Chemical and Pesticide Risks

   EPA  manages environmental  risks  to  watersheds,  communities, homes,  and
workplaces to protect human health and the environmental integrity of ecosystems.  The
Agency employs a mix of regulatory programs and partnership approaches to achieve
results in ways that  are efficient,  innovative, and sustainable.   Ideally,  EPA  can
implement a strategy of preventing pollution at the source; however, where programs to
prevent  pollution  or   ecosystem  damage  are not  viable,   EPA  promotes  waste
minimization, avoidance  of impact on  habitat,  safe disposal,  and  remediation.   In
managing risk,  EPA directs its efforts toward the greatest threats in our communities,
homes, and workplaces, including threats to sensitive populations, such as children, the
elderly, and Native Americans, and to communities with potential disproportionately high
and adverse environmental and/or public health effects.

   A key component of protecting the health of people, communities, and ecosystems
is  identifying,  assessing, and reducing the  risks presented  by the thousands of
chemicals on which our society  and economy have come to depend.  Chemical  and
biological pesticides help meet national and global  demands for food, provide effective
pest control for homes,  schools, gardens, highways,  utility lines, hospitals, drinking
water  treatment facilities,  and  control  animal vectors  of disease.   Industrial  and
commercial chemicals are in products throughout our homes and workplaces.
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   Building a community's capability to make decisions that affect the environment is at
the heart of EPA's community-centered work.   EPA's efforts to share information and
build  community  capacity offer the tools communities  need to consider the many
aspects of planned  development  or  redevelopment.   EPA encourages community
development by providing funds to  inventory,  assess,  and clean up the hundreds of
thousands  of properties that have  been  abandoned or unused due to previous
industrial,  commercial, or other use.   In the U.S.-Mexico border,  addressing  local
pollution and infrastructure are  priorities for Mexico and the  United States under the
Border 2012 Agreement.  Ensuring safe drinking water for all Americans is another
important  priority.  Addressing  these  challenges  requires combining  innovative and
community-based approaches with national guidelines and inter-agency coordination to
achieve results.

   Some  populations, such  as children, the elderly, and  Native Americans  face
significant and unique health threats from a range of environmental exposures.  Pound
for pound, children breathe more air, drink more water,  and eat more food than adults,
and their behavior patterns may increase their exposure to potential toxics.  Because
their systems are still developing, children may be more  vulnerable to environmental
risks,  including air pollution  that may exacerbate asthma, lead-based paint in  older
homes, microbes in drinking water that may be resistant  to treatment, and persistent
chemicals that  may cause cancer or induce reproductive or  developmental changes.
Even  older  Americans in good health may be  at  increased risk  from  exposure to
environmental pollutants.  As people age, their bodies are less able to detoxify and
eliminate toxins. Native Americans represent another segment of the population with a
different risk profile.   Their traditional  sources for food and ways of life may  lead to
higher levels of exposure to certain toxics. EPA continues its focus  on  these sensitive
populations  by  increasing the Agency's understanding  of  these issues,  building
infrastructure and capacity, and providing information and tools needed to assess and
prevent adverse impacts.

   The key to sustaining and enhancing both domestic  and international environmental
progress  is the collaborative efforts of  national, tribal, state, and  local governments, of
international  organizations,  the private  sector,  and  concerned citizens.   Working
collaboratively with other government agencies, EPA cooperates with other nations and
international organizations to identify, develop,  and implement policy options to address
environmental problems  of  mutual  concern.   By assisting  developing  countries in
managing their natural resources  and  protecting  the  health of their citizens,  EPA
leverages financial and human resources to the greater environmental good.  EPA also
works to  include environmental protection provisions  and commitments to enforce
environmental laws and  regulations effectively in all  international  trade agreements
negotiated by the United States.

   EPA's ecosystem  protection programs encompass a wide range of approaches that
address specific at-risk regional areas and larger categories of threatened systems,
such as estuaries and wetlands. Locally generated pollution, combined with pollution
carried by  rivers  and streams and  through air deposition, can accumulate in these
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ecosystems and degrade them over time.  Large water bodies, such  as the  Gulf of
Mexico, the Great Lakes, and the Chesapeake Bay, have been  exposed to substantial
pollution over many years. Coastal estuaries and wetlands are also vulnerable.  As the
populations in coastal  regions  grow,  the challenges to preserve and  protect these
important  ecosystems  increase.  Working  with  stakeholders,  EPA has  established
special programs to protect and restore these unique resources.

   Science guides EPA's identification and treatment of emerging issues and advances
our understanding of long-standing human health and environmental challenges. EPA's
research  is  typically  crosscutting,  multidisciplinary,  and  at  the cutting  edge  of
environmental science;  reflects the dynamic nature of science; and brings scientific rigor
to the characterization of uncertainty and risk. The Agency's research provides decision
makers with a more complete picture of the potential risks and benefits of alternative
approaches to  environmental protection.   EPA's  research program  includes "core
research"  that builds the scientific  knowledge base in human health and ecology, in
addition to informing environmental decision making.  To further our ability to measure,
assess, and describe environmental conditions,  EPA's research is vital for advancing
programs  like the National Land Cover Database and the Environmental Monitoring and
Assessment Program, as well as EPA's Report on the Environment.^  EPA's research
also informs  stewardship approaches and sustainability  solutions that  can prevent
pollution by building environmental protection into both national economic and individual
consumer decisions.

OBJECTIVE 4.1:  CHEMICAL AND PESTICIDE  RISKS. By 2011. prevent and reduce
pesticide and industrial  chemical risks to humans, communities, and  ecosystems.

   Sub-objective 4.1.1:  Reduce  Chemical Risks.  Through  By  2011, prevent and
   reduce chemical risks to humans, communities, and ecosystems.

   NACEPT SP Comments
   The Strategic Targets outlined in this Sub-objective lack the specificity required to determine how
   performance will be measured to achieve the stated outcomes. As such. EPA's specific role/strategy
   to address each of the outcomes is unclear.

      Strategic Targets:

      •   By 2011, eliminate  or effectively manage risks associated with 100 percent of
          High Production Volume (HPV) chemicals for which unreasonable risks have
          been identified through EPA risk assessments.2

      NACEPT SA Comments
      How will this be measured  and assessed?

      •  Through 2011, ensure that new chemicals introduced into commerce do not
          pose unreasonable risks to workers, consumers, or the environment.3
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      NACEPT SA Comments
      How will this be measured and assessed?

      •  By 2011, achieve a 30.6% 3J. percent cumulative reduction of chronic human
         health risk from environmental releases of industrial chemicals in commerce
         since 2001.4

      NACEPT SA Comments
      How will this be measured and assessed?

      •  By 2010, eliminate childhood lead poisoning cases as a public health concern
         by reducing to zero the number of cases of children (aged 1-5 years) with
         elevated blood lead levels (>10ug/dl).5

      NACEPT SA Comments
      This objective relies solely on consumer behavior.  What strategies/tools will EPA rely on to
      achieve this objective?

      •  By 2010, reduce to 28 percent the percent difference in the geometric mean
         blood lead level in low-income children 1-5 years old as compared to the
         geometric mean for non-low income children 1-5 years old.6

      NACEPT SP Comments
      In light of the prior strategic target of eliminating childhood lead poisoning as a public health
      concern by reducing to zero the number of cases of children with elevated blood levels, this target
      seems irrelevant.

      •  By 2011, through work with international partners, eliminate the use of lead in
         gasoline in the remaining  35 countries that  still use lead  as an additive,
         affecting over 700  million people.    (Baseline:  As of January  2006,  35
         countries still need to phase lead out of gasoline.  Information source: United
         Nations  Environment  Program and the  Partnership for Clean Fuels  and
         Vehicles  maintain a global  database on fuel  quality,  which is  updated
         periodically.7)

      •  By 2011,  through  work with international partners, over 3 billion people will
         have access to low-sulfur fuel in 10 countries, including China,  India,  Mexico
         and  Brazil. (Baseline: As of January 2006, none of the developing countries
         has  access to low-sulfur fuel,  according to the United Nations Environment
         Program and the Partnership for Clean Fuels and Vehicles.)

   Sub objoctivo 4.1.2: Protect Human Health from Posticido Risk. Through 2011,
   protect human health by  ensuring that pesticides continue to be safe and available
   when used in accordance with the  label.
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   Strategic Targetsf-

   • By 2011,  protect  human health  by reducing the  percentage  of  the general
   population with detectable levels of currently registered pesticides in their bodies by
   a cumulative total of XX%. (Metric under development for inclusion in the full text
   Hroft ^
   U I Ul L. J

   • By 2011, reduce the occurrence of pesticide related illnesses and incidents in the
   pesticide  occupational community  by  XX%  (agricultural workers  and  pesticide
   applicators).  (Metric under development for inclusion in the full text draft.)

   • Through 2011, improve protection by working with other nations to facilitate guicker
   market entry, availability,  and use of lower risk pesticides  through worksharing with
   NAFTA and OECD on a cumulative XX number of reduced risk pesticides.  (Metric
   under development for inclusion in the full text draft.)

   Sub-objective 4.1.2: Reduce Chemical Risks at Facilities and in Communities.
   By 2011,  protect human  health, communities, and the environment from chemical
   releases through facility risk-reduction efforts and  building  community preparedness
   and response capabilities.

   NACEPT SP Comments
   This sub-objective was previously numbered 4.1.5  in the Strategic Plan Architecture.  Relocating
   entire sub-objectives in a document as complex as the Strategic Plan frustrates the review process.

   The strategic targets outlined in this section seem not to be very ambitious.  Is there a reason for this?
   The information included in the target that calls for a 10% percent reduction from the 2007 baseline
   does  not explain the basis of the 2007 baseline.  What's included in the baseline?  How will
   performance be measured?

      Strategic Targets:

      -—By 2011, reduce by XX pounds inventories of hazardous chemicals at Risk
         Management Plan facilities.

      NACEPT SA Comments
      Is this a regulatory goal of the RMP program?

      •  By 2011, continue  to maintain the Risk Management Plan  (RMP) prevention
         program and further reduce by 5 percent  the number of accidents and the
         conseguences of those  accidents (including  evacuation,  injuries,  fatalities,
         and property damage) at RMP facilities. (The  baseline is an annual average
         of 340 accidents, based on RMP program data through 2003.)

      NACEPT SA Comments
      This is highly dependent on factors external to the Agency and outside the regulatory jurisdiction
      of the Agency. How will EPA accomplish this?
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      •   By 2011,  reduce  by 5  percent the  consequences  of  accidents  at RMP
          facilities,  as  measured by  injuries, fatalities,  and  property  damage. (The
          baseline is an  annual average of  358 injuries,  13 fatalities,  $143,487,189
          property damage at RMP from 1995-2003.)

      •   By 2011, vulnerability zones surrounding RMP facilities  will be reduced by
          XX% 5_percent from the 2004  baseline, which will result  in the protection of
          XX reduction of risk for over 4 million people  in the community. (The 2004
          baseline is 33,504 miles of total cumulative radius of all vulnerability zones).

      NACEPT SP Comments
      Given the broad variability in population  density in communities across the country, it is unclear
      how EPA could determine that 4 million people live in 5% of the vulnerability zones and how
      EPA has or will select target vulnerability zones to achieve this strategic target.

      •   By 2011, improve by XX% 1Q percent from the 2007 baseline the capabilities
          of Local Emergency Planning Committees (LEPCs) to prevent,  prepare for,
          and respond to chemical emergencies (as  measured by a survey  of those
          LEPCs), thereby reducing  the  risk to  communities from the potentially
          devastating effects of chemical accidents, as measured by a survey of those
          LEPCs.

      NACEPT SA Comments
      This target references a future baseline. This target is dependent entirely on actions by state and
      local entities and the regulated community and outside the regulatory jurisdiction of the Agency.

      NACEPT SP Comments
      This target continues to reference a. future, undefined baseline.

   Sub-objective 4.1.3: Protect Human Health from Pesticide Risk.  Through 2011,
   protect human  health by ensuring  that  implementing our statutes and  taking
   regulatory actions  to ensure pesticides continue to be safe and available when used
   in accordance with the label.

   NACEPT SP Comments
   This sub-objective appeared in the Strategic Architecture as sub-objective 4.1.2.

   EPA  should consider adding a specific Strategic Target that integrates  environmental stewardship
   strategies to reduce pesticide risk.

      Strategic Targets:

      •   By 2011, protect  human health by reducing the  percentage of the general
          population with detectable levels of currently registered  pesticides in their
          bodies by a cumulative total of  XX%. (Metric under development for  inclusion
          in the  full text draft.) reduce the  concentration of pesticides detected  in the
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         general population by 50 percent.  Baselines  are determined from 1990-1992
         Centers  for  Disease  Control-National  Health and Nutrition  Examination
         Survey (NHANES) data.g

      •  Through 2011, reduce the occurrence of  pesticide  related illnesses and
         incidents  in  the  pesticide occupational community by XX%  (agricultural
         workers and  pesticide applicators).—(Metric under development  for inclusion
         in the  full text draft.) protect those occupationally exposed to pesticides  by
         improving upon or maintaining a rate of 3.5 incidents per 100,000 potential
         risk events.  Baseline: There were 1385 occupational pesticide incidents in
         2003 out of 39,850,000 potential pesticide risk events/year.2

      -—Through 2011,  improve protection by working with other nations to facilitate
         quicker market entry, availability, and use of  lower risk pesticides through
         worksharing with NAFTA and OECD  on  a cumulative XX number of reduced
         risk pesticides.  (Metric under development for inclusion in the full text draft.)

      •  By 2011,  improve the health of those who work in  or around pesticides  by
         reaching a 50 percent targeted reduction in moderate to severe  incidents for
         six acutely toxic  agricultural pesticides with the  highest incident  rate:
         chlorpyrifos, diazinon, malathion, pyrethrins,  2,4-dichlorophenoxy acetic acid
         (2,4-D), and  carbofuran.   Baselines will be  determined from the  Poison
         Control  Center  (PCC)  Toxics  Exposure  Surveillance   System  (TESS)
         database for 1999-2003.^

   Sub-objective 4.1.4:  Protect the Environment from Pesticide  Risk.  Through
   2011, protect the environment by ensuring that  implementing our statutes and taking
   regulatory actions to ensure pesticides continue to be  safe and available when used
   in accordance with the label.

   NACEPT SP Comments
   This sub-objective appeared as sub-objective 4.1.3 in  the  Strategic Architecture.

   Is there a reason why a specific number is not called  out in the strategy  that aims to reduce the
   number of agriculture watersheds sampled by the USGS NAWAQA program?

      Strategic Targets:

   •  By 2011, establish the baseline and reduce by a cumulative XX% the contribution
      of pesticides  to environmental  impairments.  (Metric  under  development for
      inclusion  in the  full  text draft.)  reduce the percentage of urban watersheds
      sampled  by the US Geological  Survey's National Water Quality  Assessment
      (USGS NAWQA) program that exceed the National Pesticide  Program aguatic
      life benchmarks for three key pesticides  of concern (diazinon,  chlorpyrifos,
      malathion).  The 1992  - 2001 baselines as a percentage of urban watersheds
      sampled  that exceeded benchmarks are Diazinon: 40 percent:  Chlorpyrifos:  37
      percent: and Malathion: 30 percent.—
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   •—By 2011, working with states  and tribes,  identify XX pesticides of concern to
      water quality, use available tools to manage the risk, and effect a positive change
      in environmental conditions.—(Metric under development for inclusion in the full
      text draft.)

   -—By 2011, protect endangered and threatened species from pesticide exposure by
      reducing the exposure levels by a cumulative XX%. (Metric under development
      for inclusion in the full text draft.)

   •  By 2011, reduce the number of agricultural watersheds  sampled by the USGS
      NAWQA program that exceed  EPA aquatic life benchmarks for 2 key pesticides
      (azinphos-methyl  and  chlorpyrifos).  Based  on  1992-2001  data,  18  percent
      percent of agricultural  watersheds sampled exceeded benchmarks for Azinphos-
      methyl and Chlorpyrifos.

   •  By 2011, cumulative percentage of Section 3 actions (registrations of new active
      ingredients and re-registration  of existing pesticides) taken by EPA which have
      fully addressed Endangered Species Act obligations, will reach 60 percent.

   Sub-objective 4.1.5: Realize the Benefits from Pesticide Use.  Through 2011,
   ensure the public health and economic  benefits of pesticide  availability and use are
   achieved.

   NACEPT SP Comments
   This sub-objective appeared as sub-objective 4.1.4 in the Strategic Architecture.

      Strategic Targets:

      •  By 2011, ensure the public health and economic benefits of pest control are
         achieved by avoiding XXX (cumulative) amount of crop loss through ensuring
         effective pesticides are available to address emergency pest  infestations.
         (Metric under development for inclusion  in the full text draft.)  avoid  $1.5
         billion of crop loss  by  ensuring that effective pesticides are available to
         address emergency pest infestations.

      •  By 2011,  decrease structural damage  and vector borne disease  by a
         cumulative XX%. (Metric under development for inclusion in the full text draft.)
         annually avoid $900M in termite structural damage by ensuring that safe and
         effective pesticides  are  registered/re-registered and available for termite
         treatment.

Means and Strategies For Achieving Objective 4.1

   In cooperation with  our state and tribal partners and with the support of industry,
environmental groups, and other stakeholders, EPA will use environmental stewardship
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strategies  to  reduce  significantly  chemical  and  pesticide  risks  to  individuals,
communities, and ecosystems.

NACEPT SP Comments
This section is an example of where the environmental stewardship strategies should be integrated in the
Objective. Sub-objectives, and Strategic Target. This would provide the specific targets, program criteria.
approaches and timelines.

Reducing Risks From Chemicals

   EPA's strategy to prevent and reduce risks posed by chemicals and microorganisms
consists of two primary approaches: (1) preventing the introduction into U.S. commerce
of chemicals and organisms that pose unreasonable risks; and (2) effectively screening
the stock  of chemicals already in commerce for potential risk.  EPA develops and
implements action plans to reduce the  use of and exposure to chemicals demonstrated
to harm humans and  the environment.  EPA works with states and tribes, other federal
agencies,  the private sector,  and  international entities and  increasingly  employs
stewardship strategies to protect public health and the environment from chemical risks.

   The primary  mechanism for  preventing the introduction  into U.S.   commerce of
chemicals and organisms that pose unreasonable risks is the Toxic Substances Control
Act's (TSCA's) requirement that EPA review all new industrial chemicals  and organisms
prior to their production or  import and be  notified of significant new uses for certain
chemicals that have already been reviewed.12  Under TSCA, EPA screens, assesses,
and reduces risks posed by the 66,600 chemicals that were in use prior to the TSCA's
enactment in 1977.   Thousands of these chemicals  still are in  use today,  and nearly
3,000 of them are High Production Volume (HPV) chemicals, produced or imported  into
the United States in quantities  exceeding  1 million pounds  per  year.  Under the HPV
Challenge Program,  more  than 400 companies and  100  consortia  have voluntarily
provided critical  hazard screening data on almost 1,400 HPV chemicals that EPA is
making publicly available through a comprehensive searchable database.13  EPA also
participates  in  the Organization for Economic Co-operation  and Development (OECD)
Screening Information Data Set program,14 the international equivalent of  the HPV
Challenge Program.  EPA uses these data to screen chemicals for potential hazards
and risks, and to set priorities for further assessments and actions to eliminate or
manage unreasonable risk.

   EPA's New Chemical Program prevents the introduction of chemicals  and organisms
into economic production that  might pose  unreasonable  risk.  EPA's premanufacture
notice  (PMN)  reviews typically assess 1,300  to 1,500 new chemicals  or organisms
every year,  a rate expected to  continue through 2011.   Under the New Chemical
Program, EPA has developed  a number of advanced screening tools to estimate the
fate, concentrations,  and potential health  and  environmental  hazards of chemicals
released to  the  environment.15  These  advanced  tools are also critical  to another
component  of this approach—EPA's  work to  encourage  development of  safer or
"greener" new  chemicals at  the earliest stages  of product, process, and service design.
The Sustainable  Futures  initiative16  provides  chemical manufacturers with the same
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screening  tools EPA uses to evaluate potential risks to workers and the public and
possible impacts  to the environment.   EPA  expects to  increase the New Chemical
Program's efficiency as more  companies voluntarily  pre-screen their chemicals and
reduce the number of problematic new chemical notices submitted to EPA. EPA's tools
and models  continue to undergo rigorous external peer review and are updated and
expanded  as needed, based on review recommendations.

Addressing Lead And Other High-Risk Chemicals

   EPA targets  risk-reduction  efforts at specific chemicals  and addresses essential
environmental  justice concerns.  Foremost among these is  the federal  government's
commitment to eliminate the  incidence of childhood lead poisoning.  Since the 1990s,
EPA has focused on reducing children's  exposure to lead in paint and dust through a
regulatory framework, federal interagency collaboration, and  education of parents and
the medical  community about prevention.  Because of these efforts, children's blood
lead levels in the United States have declined dramatically, and the federal government
anticipates that it will achieve  its goal of eliminating the incidence of childhood  lead
poisoning  in 2010.  In working  towards that goal, EPA is developing a comprehensive
program to address lead hazards created by renovation, repair, and painting activities in
homes with  lead-based paint.   Continued  vigilance is  required to ensure that no
resurgence in childhood lead poisoning occurs after 2010. The Agency is also working
to eliminate the disparity in blood lead levels between low income and non-low income
target populations, and to address  other environmental justice  concerns.  EPA will
accomplish this by targeting program resources towards this  country's most vulnerable
populations.

   Particulate  matter (PM) from vehicles is a growing  public health problem in many
countries,  particularly in urban  areas in the developing world.  Reducing sulfur in fuel
will significantly decrease emissions of particulate matter from vehicles.  Over the next 5
years, through the public-private global Partnership for Clean Fuels and Vehicles,  EPA
will reduce emissions from vehicles in key countries by eliminating lead from gasoline
worldwide  and reducing  sulfur from gasoline and  diesel  fuels.   The  Partnership,
launched by EPA at the World  Summit on Sustainable Development in Johannesburg,
South Africa (WSSD), includes representatives from the oil and automobile industries,
non-governmental organizations, governments, and international organizations such as
the United Nations Environmental Program.17  The Partnership also leverages expertise
from other U.S.  government agencies to provide technical  assistance on projects  in
several parts of the world, including expertise from the U.S. Agency for International
Development, the U.S. Department of State, and the Centers for Disease Control.

   EPA is also evaluating and  implementing risk management actions on chemicals of
emerging  concern.   Perfluorooctanoic acid  (PFOA), a persistent chemical causing
systemic and developmental  toxicity in animal studies, has been found in human blood
and has  a half-life in  humans measured  in  years.18   EPA invited the eight major
companies with operations in the United States that generate or use PFOA in  their
products  to  participate in a global environmental stewardship  program to reduce
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emissions  and product  content  levels of  PFOA,  PFOA  precursors,  and related
chemicals.   All eight  of  the companies committed  to reduce  facility emissions and
product content of PFOA  and related chemicals by 95 percent no later than 2010, and
to work toward eliminating emissions and product content of these chemicals by  2015.
Companies will report their  progress  for both their U.S.  and  global  operations.   In
addition,  the United  States shares  with  Germany the  lead  on preparing a draft
international PFOA  assessment for the Organization for  Economic Cooperation and
Development.   EPA  will seek  to expand the stewardship  program  into a truly
international effort through cooperative activities with foreign governments.

   Mercury is a domestic and global pollutant and potent neurotoxin that places adults,
children,  and developing fetuses  at risk for a variety of health  problems,  including
developmental delays.   The U.S. has been a  catalyst  for increasing  international
collaboration, building countries'  capacities,  and promoting data sharing  to  better
characterize and reduce  global mercury use and releases.  EPA expects to achieve
measurable reduction  in the chlor-alkali sector, commercial and manufactured products
sector, and the sectors for artisanal and small scale gold mining and coal combustion,
together responsible for up to 80 percent of global anthropogenic mercury emissions.
This reduction will be accomplished through demonstration projects in key countries,
training, public awareness programs, and information sharing.

   EPA employs a multimedia,  cross-Agency strategy to focus  on  other high-risk
chemicals and classes of chemicals.  For example, we are working  to prevent new
persistent,  bioaccumulative,  toxic (PBT) chemicals  from  entering commerce and  to
reduce the risks associated with PBTs that are currently in use or have been used in the
past, including mercury and polychlorinated biphenyls (PCBs).  EPA ensures  that PCB
waste is properly  stored  and disposed, and that PCB-contaminated sites are correctly
cleaned up by advising the regulated  community on PCB  remediation, reviewing and
acting  on PCB disposal applications,  and overseeing PCB  permitted storage and
disposal facilities.  EPA supports the  U.S.  Navy, the Department of Transportation's
Maritime Administration (MARAD), and other federal agencies that dispose of obsolete
ships containing PCBs. In addition, the Agency works with the  Department of Defense
to approve the incineration of  PCBs in nerve agent rockets and the safe disposal  of
PCB wastes outside of the United States.

   Tribal environmental and  public health issues are continuing EPA priorities for the
chemical program.  EPA focuses on the needs  of tribal  communities by addressing
chemical risks using risk  assessment methods that take into account the different risk
profiles of some tribal lifestyles by building infrastructure  and  capacity, by  providing
information and  tools to assess  and  prevent  adverse  impacts  on  these  sensitive
populations, and  by implementing lead, asbestos,  and  PCB  programs  within tribal
communities.
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Reducing Risks From Accidental Chemical Releases From Facilities

   To  reduce or eliminate risks associated  with  accidental  chemical  releases from
facilities, EPA must first identify and understand the potential  risks.  Since 2003, EPA
completed approximately 1,800 audits of Risk Management Plan  (RMP) facilities and
processed over 12,000 RMPs.  During 2007, EPA will review and analyze data collected
in  1999 and 2004 under the Agency's  Risk  Management  Plan (RMP) program.19
Through 2011,  EPA  will  continue analyzing  RMP and the Emergency Planning and
Community Right-to-Know (CRRTK) data 20 to identify geographic  locations and facility
types with the greatest potential for chemical accidents and releases areas, and identify
where  susceptible and  sensitive populations may be at higher  risk from  chemical
releases.  EPA will use this information to develop voluntary initiatives and activities
aimed at high-risk facilities and geographic areas.

   In the event of a chemical emergency, protecting first responders and  other on-site
personnel  is critical. EPA's federal,  state, and local partners accomplish the majority of
this work.   EPA  provides emergency personnel with  information they need to take
necessary precautions  and  treat individuals who  may be on the  scene.  EPA,  in
collaboration with other federal, private, and academic organizations,  is increasing the
pace for developing Acute Exposure Guideline Levels (AEGLs), i.e., limits for short-term
exposures representing three tiers of health effect endpoints (i.e., discomfort, disability,
and  death)   for  five different exposure  durations.21    States, communities,  fire
departments, health agencies, and local governments use the information provided by
EPA in their  local emergency response planning and mitigation efforts to understand
how these chemical  risks could affect them, how to reduce  those risks,  and how  to
address and mitigate risks should a chemical release occur.

Reducing Exposure To Pesticides

   The mission of EPA's  Pesticide  Program  is  to  protect  human health and the
environment by ensuring that pesticides are safe and available.22 Pesticides protect our
food supply from a range of pests including fungi, insects, weeds, and microorganisms.
They reduce  risks of vector-borne diseases, sanitize hospital  equipment, and disinfect
household items and surfaces.  Consequently,  people may be exposed to pesticides
from the foods that they eat,  in and around homes and parks,  and in  occupational
settings.  Because many pesticides are potentially hazardous,  EPA serves  an important
role by screening new  pesticides before they reach the market,  and as  an effective
steward of pesticides already on the market.

   EPA's statutory authority to regulate pesticides derives from three  primary statutes:
the Federal  Insecticide,  Fungicide,  and  Rodenticide Act (FIFRA), the  Federal Food,
Drug, and Cosmetic Act (FFDCA), and the  Food  Quality Act of 1996  (FQPA) that
amended  both  FIFRA  and FFDCA.   Under these laws,  EPA has  responsibility for
protecting  consumers, pesticide users, or workers who may be exposed to pesticides,
and  children and  other  sensitive  populations,  and for protecting the  ecosystems,
including   non-target  plants  and  species,  with  a  special  emphasis  on  EPA's
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responsibilities under the Endangered Species Act.  EPA is also required to balance the
risks  and  benefits of  a pesticide's use when  making  regulatory decisions  and
establishing tolerances or maximum allowable pesticide residues on food and feed, and
to consider cumulative and aggregate risks and greater protections for children.  EPA
seeks to maximize the potential  for pesticide use to  positively affect quality of life,
control vector-borne disease,  and ensure  availability and  affordability of agricultural
goods.

      EPA's Pesticide Registration Program serves to screen pesticide products before
their entry into  the market.23   EPA reviews significant  data  prior to  registering  a
pesticide and, when needed,  implements use restrictions and  directions  that ensure
when a  pesticide is used according to label directions it will not  result in  unreasonable
risk. This pre-market review includes consideration of human health and environmental
concerns and the pesticide's potential benefits.  Under the Reregistration Program, EPA
reviews  existing  registrations  to  ensure they meet current scientific standards  and
concerns identified  after the original registration.24   A provision  under FQPA replaced
the FIFRA requirement for  reregistration with a  requirement for periodic  review  of
pesticide  registrations  to   ensure existing   registrations  meet  the  most  current
standards.25 The Agency uses data on the concentrations of pesticides detected in the
general  public,  collected by the  Center for Disease Control in a bi-annual National
Health and Nutrition Examination  Survey (NHANES), to assess  EPA's effectiveness  in
protecting human health from pesticides.26

   EPA began promoting the registration of reduced risk pesticides in 1995.  EPA gives
priority in its registration program for pesticides that have low impact on human health,
low  toxicity to  non-target  organisms  (birds,  fish, and  plants),  low  potential for
groundwater contamination,  lower use rates,  low pest  resistance  potential, and those
that  are compatible  with Integrated  Pest Management.27  Several  countries  and
international organizations have instituted programs to facilitate registration of reduced
risk pesticides.   EPA will maintain its leadership role and work with the international
scientific community and individual OECD member countries to ensure the registration
of twelve  new reduced  risk  pesticides and to establish related tolerances (maximum
residue  limits) in Organization for Economic Cooperation and  Development (OECD)
countries. As a greater amount of food is imported from other countries, international
use of reduced risk pesticides contributes to reduced risks for Americans.

   The  regulation of  pesticides  also  requires a strong field  program to  ensure  that
decisions  made during  the  licensing  and re-licensing  processes  are  implemented  in
pesticide use.   Working closely with states, tribes, and other federal agencies, EPA's
pesticide field program  addresses worker  safety,  certification,  and training for more
hazardous pesticides,  as well as protection  of  endangered  species.   In agriculture
alone, an estimated 1.8 million workers  could be exposed to pesticides, and there are
millions  of individuals involved in  occupations  that  use pesticides,  such as lawn care,
healthcare, food preparation, and landscape maintenance.28  In addition to promoting
and  licensing  safer products, EPA reduces  the  number and severity  of pesticide
exposure incidents through regulations under the Worker Protection Standard, pesticide
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applicator certification  and  training,  risk assessment and risk  management,  and
effective communication and outreach.  Close cooperative relationships between EPA,
states, tribes, and other regulatory partners allows information on local pesticide use
patterns,  geological  conditions,  location  of  endangered  species, and tribal  cultural
practices to inform the risk assessment process and to  guide  EPA to practical and
effective decisions.

Reducing Risks To Ecosystems

   Pesticides can have negative effects on water resources, soil, and wildlife. While a
significant portion of  the risk assessments conducted for  new and existing pesticides
relate to  human health, EPA  also conducts ecological risk assessments to address
potential  impacts to plants, animals, and  ecosystems.   Under  FIFRA, EPA must
determine that a pesticide is not likely to harm the environment in the same way that it
must  determine  potential risk  for  human  health.  EPA  may impose risk  mitigation
measures such  as  use restrictions, denial of uses, or  requirements to monitor
environmental conditions such as effects on water sources.

   Reductions in the  concentrations of pesticides in water sources are a major indicator
of the efficacy of EPA's risk assessment, management, mitigation, and  communication
activities.   To reduce  potential  environmental impact of four pesticides of concern
(diazinon,  chlorpyrifos,  malathion, and azinphos-methyl), EPA will use sampling data
from urban and  agricultural watersheds collected under the U.S. Geological Survey
(USGS) National  Water Quality Assessment (NAWQA) program.29  For each  of the
pesticides, EPA will monitor the impacts of previous regulatory decisions and consider
additional action necessary  to  achieve greater environmental improvements.   EPA will
work with USGS to develop sampling  plans, and intermediate (2008-2010) goals will be
refined when the USGS plan is  finalized in late FY 2007.  In addition to currently tracked
insecticides,  EPA will  request that  USGS  add additional insecticides  to  sampling
protocols   and   establish  baselines  for  newer   products   that  are   replacing
organophosphates such as synthetic pyrethroids.

   Under the Endangered Species Act (ESA), EPA is required to ensure that pesticide
regulatory decisions will not  adversely modify critical habitat or jeopardize the continued
existence of listed species.  With approximately 600 active ingredients in over 19,000
products—each which may have multiple uses—and approximately 1,200 listed species
each with diverse habits and habitat requirements, this is a great challenge.  EPA is
working with the U.S  Fish and Wildlife Service and National Marine Fisheries Service to
establish  an effective process  for EPA to carry out its ESA obligations.  Together, we
are developing "counterpart regulations" that provide EPA  authority to make certain
determinations  without  further  consultation.  Realizing  that former  licensing  and
registration processes did not fully examine endangered species impacts,  EPA has
made assessing risks to endangered species a priority and is revising its  processes to
make endangered species considerations a routine part of Agency reviews.30  EPA is
training staff  to ensure they are able to make  determinations under the counterpart
regulations.  EPA, states, and tribes also make vital contributions by providing valid and
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relevant information on local pesticide use and practices, and recommendations on the
feasibility of potential mitigation methods.

Realizing Economic Benefits Of Pesticides

   Controlling the production and income losses from pests is important for agricultural
production  systems where pest  damage can  be  an  economic detriment.   U.S.
agricultural producers have relied on registered pesticides for decades to produce an
abundant and safe food supply and to avoid economic losses from pests.  One of the
primary benefits of EPA's  licensing and  re-licensing programs is  access to  effective
pesticides that eliminate or limit losses.   FIFRA also authorizes conditional use of a
pesticide for a geographically specific emergency.  Historically, the crop  loss avoided
through the timely review of emergency exemption requests is estimated at $1.5 billion
per year.  EPA  continues to  support  these benefits to  American  agriculture  and
American consumers by carefully reviewing all requests for emergency exemptions in a
timely manner.

   Due to the availability of effective termiticides,  it  is estimated that $900 million of
termite damage is avoided each  year. Although some effective termiticides  have been
removed from the market because of safety concerns, EPA works with industry to help
register safe alternatives to maintain a high level of protection with safe products  that
meet or exceed all current safety standards.

OBJECTIVE 4.2:  COMMUNITIES. Sustain, clean up, and restore communities and the
ecological systems that support them.

   Sub-objective 4.2.1: Sustain Community Health.  By 2011, reduce the air, water,
   and  land  impacts  of new growth and development through  use of smart growth
   strategies  in §0 30  communities by 2011  (2006 as a  baseline) by working with
   communities to  adopt  growth strategies that perform better for the environment,
   economy,   and  the  community.  (Metric under development),  that  will  achieve
   significant  measurable  environmental  and/or  public  health improvements.   The
   baseline will be established in 2006.

   NACEPT SA Comments
   What is the baseline of communities by which this target is measured? 50 communities over 5 years
   seems an extremely small number.  How will this be accomplished, how will it be coordinated with
   other agencies, and how will target communities be selected?

   NACEPT SP Comments
   NACEPT previously commented that 50 communities over  5 years seemed an extremely small
   number. The revised target of 30 communities over 5 years is an even less impressive goal. What is
   the basis of the 2006 baseline?  Is there a public process for development of the 2006 baseline? The
   targets lack sufficient detail to determine program effectiveness.

   Sub-objective   4.2.2:  Restore   Community  Health  through  Collaborative
   Problem-Solving.  Make significant environmental improvements in  communities
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   with  potential disproportionately  high and adverse  environmental  and/or public
   health effects ("areas with potential environmental justice concerns") and foster the
   ability  of  communities   to  address  local  environmental  concerns  with  other
   stakeholders through collaborative problem solving.31

       Strategic Targets:

       •   By 2011, an additional 30 communities in areas with potential environmental
          justice  concerns will achieve  significant measurable  environmental  and/ or
          public  health improvement through  collaborative  problem-solving strategies.
          (Baseline:  In 2006, 30 communities used with potential environmental justice
          concerns are in the process of using collaborative problem-solving strategies
          to  improve  their in efforts to  achieve  environmental and/ or public health
          improvement.  Community-specific baselines will be developed by 2008 for
          assessing improvement.)

       NACEPT SA Comments
       What is the baseline of communities in need of collaborative problem-solving? Is this an ongoing
       training program in which communities come and go or is the program capacity expected to
       double bv 2011?

       What is the specific deliverable here - training, technical assistance?  Does this means  EPA will
       be involved in a total of 60 communities  or 30 different communities?

       NACEPT SP Comments
       It  is not possible to assess what fraction of communities that could potentially  benefit from
       collaborative problem-solving will be served by this program without knowing the baseline. How
       will the 30 communities be selected?  Since 30 communities will enter the program in  2006 and
       the 2011 target is also 30 communities, is it  logical to assume that the program will not be
       available to additional communities during the life of this Strategic Plan?

       •   By 2011, as compared to the general  population, significantly decrease the
          amount of  pollution that may  disproportionately affect  the environmental
          health  of communities with  potential environmental justice concerns.   This
          reduction will include, as appropriate,  pollutant sources  associated with the
          following national  environmental justice priorities: asthma, air toxics, lead,
          contaminated   fish  and   shellfish,   drinking   water:   brownfields,   and
          contaminated sites.

       NACEPT SA Comments
       How will this be measured?
       See healthy community standards from the American Institute  of Architects (AIA) Livable
       Communities Initiative.

       What does this mean and how will it be  achieved?  Will EPA develop programs over and above
       the expected regulatory programs: or that go beyond regulatory requirements?
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   Sub-objective  4.2.3:  Assess  and  Clean Up Brownfields.   Working with state,
   tribal,  and local partners, promote the assessment, cleanup, and sustainable reuse
   of brownfields properties.

   NACEPT SA Comments
   What specific actions is EPA planning to take?

   NACEPT SP Comments
   Has EPA considered offering land use and mortgage rate incentives in order to level the playing field
   against sprawl and cheap, available agricultural lands?

   Brownfields activities are  essential to Goal 3:  Land  Preservation and Restoration, and should be
   discussed under Goal 3 objectives and sub-objectives as well as here.

   A specific target timeline should be established by  EPA to develop a methodology to better integrate
   environmental justice consideration into EPA-funded brownfield projects.

   What constitutes an "assessment?" Is EPA counting assessment activities conducted by its partners.
   or just those by EPA?

       Strategic Targets:

       •  By  2011, conduct environmental assessments at XXXX 13,900 properties.
          (FY 2005 baseline is 7,900.)

       NACEPT SP Comments
       It is not clear whether this strategic target is 13.900 assessments over the life of this Strategic Plan
       or a cumulative total of 13.900 assessments by 2011 (6.000 assessments of the life of this Plan).
       The baseline against which this target should be assessed should be the number of properties in
       need of assessment rather than the number of assessments performed.

       •  By  2011,  make XXXX  1,125 acres  (cumulative) of brownfields  ready for
          reuse.  (Baseline will be established in FY 2006.)

       NACEPT SP Comments
       It is unclear whether this strategic target is 1.125 cumulative acres over the life of this Strategic
       Plan or a cumulative total of 1.125 acres since program inception. The  target should be clarified.
       Also, the baseline against which this target should be assessed is the total acreage in need  of
       cleanup for development.

       1.125 acres of brownfields seems like a small number.

       •  By  2011,  leverage XXXX $12.9 billion (cumulative) in assessment, cleanup,
          and redevelopment funding at  brownfields properties  (FY 2005 baseline  is
   Sub-objective 4.2.4:  Sustain  and  Restore the United States -  Mexico Border
   Environmental  Health.   By 2012,  sustain and restore the environmental health


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   along  the United States-Mexico border and enhance collaboration with communities
   through implementation  of the  "Border 2012®  plan  including improving water
   infrastructure and providing improved water quality conditions and working toward a
   binational policy on land cleanup,  reuse, and revitalization of abandoned sites based
   on the strategic targets described  below.

      Strategic Targets:

   •  By 2012,  achieve a  majority  of  currently exceeded water  quality standards in
      impaired reaches or segments of significant shared and trans-boundary  surface
      waters.  (2002 Baseline: 42 water quality  impairments/sources were identified for
      19 reaches or 24 segments  of significant shared and  trans-boundary  surface
      waters.)

   NACEPT SA Comments
   This target is quite confusing.  Is the objective to reduce the total number of impairments by more
   than half, even if no individual reach actually becomes unimpaired?

   How is success measured here?  Would elimination of 22 problems/exceedences be considered
   success even if no individual reach actually attained all applicable water  quality standards?  This
   target needs to be clarified.

   NACEPT SP Comments
   The minor revisions to this strategic target make it no less confusing than before. How is success
   measured here? Would elimination of  22 problems/exceedences be considered success even if no
   individual reach actually attained all applicable water quality standards?  This target needs to be
   clarified.

   •  By 2012,  provide safe drinking water to 25  percent of homes  in the Mexican
      border area that  lacked access to safe drinking water  in 2003.  (2003 Baseline:
      98,515 homes lacked access to safe drinking water.)33

   NACEPT SA Comments
   Since this and the next target are substantially lower than the water-related targets under Goal 2 both
   generally and with respect to tribal  lands, is this, in effect, setting up an environmental justice nexus
   in the border area? Why is this different here as opposed to under Goal 2?

   NACEPT SP Comments
   NACEPT has strong concerns that EPA  apparently has not considered our comments regarding these
   two strategic targets when they appeared in the Strategic Architecture and that the Agency plans to set
   up an environmental justice nexus in the border area.  Further, these targets do not appear to address
   new housing (both permanent and makeshift) that is likely to be constructed in the border  region in
   the immediate and long-term future.

   •  By 2012, provide adequate wastewater sanitation to 25 percent of homes in  the
      Mexican border area that lacked access to wastewater sanitation in 2003. (2003
      Baseline:  690,723 homes  lacked access to wastewater sanitation.)34
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   •  By 2012,  cleanup five waste sites (two abandoned waste tires sites  and three
      abandoned hazardous waste sites) in the  United States-Mexico border region,
      thereby reducing the threat of infectious diseases and acute respiratory illnesses
      from tire fires and the threat of acute heavy metals poisoning and  long term
      central nervous damage, potentially adversely affecting approximately  1.7 million
      local residents.

   NACEPT SA Comments
   While this is a very specific target, how does it relate to the universe of the potential sites and impacts
   in the entire border region? Are there plans to transfer the lessons learned here to other sites?

   NACEPT SP Comments
   It remains impossible to assess whether cleanup of five sites in the border region constitutes 100% or
   .001% of the universe of sites in need of attention. What is the baseline of sites in the border region
   and why have five specific sites been selected?

   Sub-objective 4.2.5: Sustain and Restore Pacific Island Territories.  By  2011,
   sustain and restore the environmental health of the U.S. Pacific Island Territories of
   American  Samoa, Guam, and the  Commonwealth of the Northern Mariana Islands
   (CNMI).

      Strategic Targets:

   •  By  2011, 95  percent of the  population  in each  of the U.S. Pacific Island
      Territories served by  community drinking  water systems will receive drinking
      water that meets all applicable health-based drinking water standards throughout
      the year.  (2005 Baseline: 95 percent of the population in American Samoa, 10
      percent in CNMI, and 80 percent of Guam  served by community water systems
      received drinking  water that meets  all applicable health-based drinking  water
      standards throughout the year).

   •  By 2011, the sewage treatment plants in the  U.S. Pacific Island Territories will
      comply 90 percent of the time with permit limits for biochemical oxygen demand
      (BOD) and total suspended solids (TSS). (2005  Baseline: the sewage treatment
      plants in the Pacific Island Territories complied 59 percent of the time with the
      BOD and TSS permit limits).

   NACEPT SP Comments
   NACEPT questions  whether EPA has statutory authority to establish a target less  than 100%
   compliance with applicable permit limits.

   •  By 2011, beaches in  each of the U.S.  Pacific Island Territories monitored  under
      the Beach Safety Program will be open and  safe for swimming 96 percent of
      days  of  the beach season. (2005 Baseline: beaches were open  and  safe
      64percent of the 365-day beach season in American Samoa, 97 percent in  CNMI
      and 76 percent in Guam).
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   Sub-objective  4.2.6: Reduce Persistent Organic Pollutants (POPs) Exposure.
   By 2011,  reduce the mean  maternal serum blood levels of POPs contaminants in
   indigenous populations in the Arctic.35

   NACEPT SA Comments
   How will these targets be achieved?  Specific programs need to be identified, along with the
   measurements that will link them to the projected outcomes.

   NACEPT SP Comments
   This sub-objective appeared as sub-objective 4.2.5 in the Strategic Architecture.

   Does EPA have similar strategic targets for other citizens located in the Arctic and for citizens in
   other states and territories of the United States? How do the Artie targets compare to non-Arctic
   targets?

      Strategic Targets:

   •  By 2011, reduce mean maternal blood levels of polychlorinated biphenyls (PCBs)
      (measured as Aroclor 1260) in indigenous populations in  the Arctic to 5.6 ug/l.

   NACEPT Comments
   How will this and the following objective be accomplished?"  How is this directly correlated to the
   environment?

   •  By 2011,  reduce mean  maternal blood levels  of  chlordane (measured  as the
      metabolites  oxychlordane and trans-nonachlor) in indigenous populations in the
      Arctic to 1.1  ug/l.

Means And Strategies For Achieving Objective 4.2

   Communities are the places where we live and work, supported and enriched by
natural ecosystems  and their valuable  assets.  EPA  is committed to  sustaining and
restoring community health and the ecological systems that support it.   EPA's work in
communities  across the United States is  critical to ensure clean and safe water for
drinking,  swimming, and fishing, healthy air, and safe management of waste and its by-
products.  Much of EPA's community work also addresses environmental justice and
tribal concerns and advances stewardship and sustainability.   EPA's national  media-
specific programs  carry out important aspects of work  in communities;  however,  to
effectively address the  great range of conditions among communities  requires cross-
media  coordination  and innovative  strategies.   As  we expand  our  knowledge  of
environmental conditions, stressors,  and  solutions, community-based strategies  for
environmental protection will become more common and widely implemented.  Thus,
developing and implementing  effective  community-based  strategies  are  the great
challenge and promise of environmental protection in the coming century.

Sustaining Healthy Communities
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   Achieving  healthy communities and ecosystems requires protecting and sustaining
natural resources that are at risk.  EPA uses four approaches to facilitate community-
based protection of local natural resources.

   •  Inform  local decision-making. EPA continues to improve methods for information
      exchange and  for  giving  communities  greater  access  to environmental
      information.

   •  Build local capacity.  EPA develops  and  distributes tools that integrate media-
      specific information, supports multimedia planning, and develops training for local
      agencies and community groups on  how to use environmental assessment and
      planning data and how to work collaboratively and cooperatively with a range of
      stakeholders.  EPA also identifies and provides opportunities for greater public
      participation  in environmental decision making.

   •  Provide  technical  and  financial  assistance  directly  to  communities.  This
      assistance  helps  neighborhood  groups  adopt   integrated  comprehensive
      approaches  to environmental problems in  their  neighborhoods,  coordinate
      environmental  management,  and  promote strategic partnerships with EPA.  For
      example, EPA's Community Action for a Renewed Environment (CARE) program
      provides competitive  grants directly to communities to create local collaborative
      partnerships to reduce  releases and minimize exposure  to  toxic pollutants.
      Through programs like CARE, by 2011, EPA expects more than 100 community
      partnerships will use  meaningful public involvement to address disproportionate
      environmental  impacts and/or prioritized risks through comprehensive, integrated
      planning,  and  environmental management  and partnership  programs.  These
      communities will provide quantitative  data on human, public, or community health
      to EPA.   Through  continuing efforts  to  negotiate  international free trade
      agreements, our assistance to communities  also extends to specific international
      trading partners.  In this  context,  EPA conducts environmental  reviews  and
      provides  technical assistance to  promote ecologically compatible  development
      abroad.

   •  Ensure that  national policies and programs support  rather than hinder, the
      comprehensive, and  integrated management  of  local resources.  EPA also
      reviews new policies  and regulations to ensure  that federal programs are more
      compatible with local  efforts  and   that they  promote overall environmental
      improvement. EPA continues to collaborate with  other federal agencies to create
      incentives for and remove barriers to smart growth and integrated environmental
      management.

Restoring Healthy Communities: Environmental Justice

   EPA maintains  an ongoing commitment to ensure  environmental justice for all
people,  regardless of race,  color,  national origin,  or  income  in  accordance with
Executive Order 12898, "Federal Actions to Address Environmental Justice in Minority
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Populations and  Low-Income Populations."   In recognizing that minority and/or low-
income communities frequently may be  exposed  disproportionately to environmental
hazards  and  risks,  EPA  works to  protect these and  other  affected  communities.
Ensuring  environmental justice  means  not  only  protecting human health and the
environment for everyone, but also ensuring that all people are treated fairly and are
given the opportunity to participate meaningfully in the development, implementation,
and enforcement of environmental laws, regulations, and policies.

   To achieve the goals of environmental justice, EPA is establishing, as appropriate,
measurable  environmental justice  commitments  for  eight  national  environmental
priorities and  other  critical areas of focus.   Priority areas  include: reducing asthma
attacks;  reducing exposure  to  air  toxics;  increasing  compliance with regulations;
reducing incidence of elevated  blood lead levels;  ensuring that fish and  shellfish are
safe  to eat; ensuring that water  is safe to drink; revitalization  of brownfields and
contaminated  sites; and, using collaborative problem-solving to  address environmental
and/or public health  concerns. EPA is also increasing the integration of environmental
justice considerations in all aspects of its mission  through staff training and improved
access to guidance documents, online tools, and other resources; the dissemination of
information  about successful strategies;  and  enhancing the  ability of  staff to  work
effectively with community-based organizations and other stakeholders. EPA promotes
collaborative problem-solving  strategies by providing capacity-building through grants
and cooperative agreements,  online tools, training, and technical assistance. EPA also
coordinates stakeholders  to  help  leverage resources  and to address  multi-media,
cumulative risk, and/or other community concerns.  In addition, the Agency uses dispute
resolution, facilitation, listening sessions, and other consensus building techniques and
convenes multi-stakeholder groups  to  address  environmental and/or  public health
issues. These efforts help communities  and other stakeholders develop partnerships
that produce practical solutions to local human health and environmental issues.

NACEPT SP Comments
To achieve the goals of environmental justice. EPA should further define its strategy for addressing the
mission and goals outlined in the draft Strategic Plan.  The agency should consider the development of an
interagency environmental justice strategy.  This strategy would provide a roadmap. with specific targets.
program elements, and timelines for achieving EPA's already-established environmental justice mission
and goals. The  California Environmental Protection Agency (CALEPA) has developed a strategy for
addressing environmental justice at the state level.  EPA should review California's strategy as reference
for a  more  detailed national  strategy.  The documents  can be  found  on  CALEPA  EJ  website:
www.calepa.ca.gov/EnvJustice/

Assessing And Cleaning Up Brownfields

   Brownfields are real properties whose expansion, redevelopment, or reuse may be
complicated by the presence or potential presence of a hazardous substance, pollutant,
or contaminant.  Cleaning up and  reinvesting in  these properties  increases local tax
bases,  facilitates job  growth,  utilizes  existing  infrastructure,  takes  development
pressures off  undeveloped land, and improves and protects the environment.  EPA's
Brownfields Program works in cooperation with communities, states, tribes, and various
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other stakeholder groups, and provides funding  and technical assistance to address
both  public health and environmental concerns and  to advance a  community's
revitalization vision.

   EPA offers competitive grants for brownfields assessment, cleanup, job training, and
revolving loan fund grants.  EPA has awarded 780 of these grants since the enactment
of the Brownfields Law.  Assessing brownfields helps communities understand the risks
these properties pose and provides the information needed to undertake cleanup and
reuse.  Nearly  one third of the properties that  communities assess do not require
environmental cleanup.  EPA's cleanup  grants provide  funding  for environmental
cleanup activities of many properties that are contaminated.  EPA's revolving loan fund
grants capitalize a revolving loan fund to carry out cleanup activities at brownfield sites.
In addition, EPA's brownfields job training  grants fund eligible governmental and non-
profit organizations  for recruitment, training,  and job placement in  the environmental
field for residents affected by brownfields, helping to ensure that the economic benefits
derived from brownfield reuse remain in the affected community.

   Competitive grant ranking criteria include community need, sustainability, community
involvement, preservation of greenspace, and  reduction of threats to human health and
the  environment.  The  "Brownfields Law" also requires EPA to consider "the  extent to
which the  grant would address or facilitate the identification and reduction of threats to
the   health or welfare  of  minority or  low-income  communities,  or other  sensitive
populations,"   further  emphasizing the  brownfields  program's   commitment   to
environmental  justice   and  addressing  community  concerns  in the   reuse   of
brownfields.36    The program  is  developing  a  methodology to  better  assess  the
relationship   between   EPA-funded  brownfields  projects   and  sensitive,  socio-
economically  disadvantaged communities.  This  information will allow the program to
evaluate the assistance provided to date and to develop strategies that better integrate
environmental justice considerations.

   EPA provides funds  to state and tribal  governments  to  establish  and  enhance
response programs that oversee the majority of brownfields assessments and cleanup.
These programs may provide technical oversight and assistance to property owners;
create inventories of brownfields sites;  develop policies, regulations,  and ordinances;
and  conduct site assessment and cleanup of brownfields sites.  EPA funding is often
critical to the operation of these response  programs,  especially for tribal governments
for whom funding might not otherwise be available.

   EPA also  provides  outreach and technical assistance to stakeholders confronting
and  revitalizing  brownfields.   EPA performs targeted  brownfields  assessments  at
individual sites where stakeholders are seeking federal assistance to identify the extent
of contamination.  Through the Brownfields  and Land Revitalization Technology Support
Center,37  EPA helps streamline  site investigations and the cleanup  process, identify
technology options, evaluate contractor capabilities and recommendations, and explain
complex technologies   to  communities.    EPA  provides  technical  tools  to help
stakeholders complete  brownfields  transactions, such as Triad38  and SMARTe.39  The
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Triad approach to site assessment improves environmental decision  making through
systematic  planning,   dynamic   work   strategies,   and  real-time   measurement
technologies.  SMARTe is a tool that communities can  use to assess both market and
non-market  costs  and benefits of redevelopment options, clarify private and  public
financing  options,  and  evaluate  and  communicate  environmental  risks.    EPA
cosponsors  a  national brownfields conference with educational sessions, workshops,
and roundtables where the brownfields reuse community shares ideas, lessons learned,
and best practices.

   The Brownfields Program is conducting a program review of the operations at EPA
headquarters and at the Agency's 10 regional offices. The review will compile feedback
on program  objectives and  operations, ensure  accountability of internal  and external
stakeholders,  evaluate decision-making  processes,  and identify and  share best
practices. The review, which is aimed at enhancing the overall quality of the program,
will be completed in FY 2008.

NACEPT SP Comments
While it is critical that EPA continue  to provide funding  for brownfields assessment, cleanup, job
training, and revolving loan fund grants, the agency should review eligibility criteria of its grant and loan
programs to ensure that they do not impose any disincentives to potential applicants. Additionally, the
grants should further weight the cumulative and overall needs faced by applicants and streamline grant
award and reporting processes.

Reducing Transboundary Threats Along The United States-Mexico Border

   In an increasingly interconnected world, domestic environmental quality and  public
health often  require action along borders and in other parts of the world. Since 1970, the
United States-Mexico border region has experienced rapid population  growth. Today,
there are approximately 13 million  inhabitants in the border  region,  nearly equally
divided between  Mexico  and the United States.  The U.S.-Mexico Border 2012
Program,  a  joint effort between the governments of the  United  States  and Mexico,
works with  the 10 border states  and border communities  to  reduce transboundary
threats to improve the region's environmental and ecosystem health.40

   As part of EPA's  continuing  commitment to environmental  justice, the Agency  is
working with some disadvantaged border communities to improve water quality in both
the United States and Mexico.  For decades, raw sewage has flowed unabated through
and from  border cities, posing a significant public health and environmental threat to
both U.S. and Mexican communities.  Inadequate water and sewage treatment  cause
border  residents to suffer  disproportionately from hepatitis A  and other waterborne
diseases. To reduce health risks  to residents,  EPA assists communities in the U.S.-
Mexico border region to  increase the number of homes with access  to safe drinking
water and basic sanitation.  As this infrastructure comes on line, discharges of raw
sewage will  be reduced and surface water quality will improve.  Restoration of surface
water quality on 24 impaired shared and trans-boundary waters is an EPA priority.
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   EPA will also  focus on the environmental and human health  risks posed by land
contamination from abandoned tires and hazardous waste.  Piles of waste tires pose a
risk to health  and  the  environment because they serve as  breeding grounds for
mosquitoes and  are  prone to fires, which are difficult to extinguish.  Addressing the
challenge of contaminated hazardous waste sites will also minimize the threat of acute
heavy metal poisoning and long-term central nervous system damage to local residents.
 To Learn More:
 www. epa. gov/owm/mab/mexican/
Restoring Island Communities

   The U.S. island territories of American Samoa, the Commonwealth of the Northern
Mariana Islands (CNMI), and Guam face severe environmental infrastructure problems,
leaving residents more at risk from environmental problems than many of their mainland
counterparts. In some cases, island residents are not able to turn on their faucets and
get clean,  safe  water.   Similarly, these  islands are frequently  plagued  with  poor
wastewater conveyance and treatment  systems that contaminate drinking water wells
and surface waters, posing an  immediate  danger to residents.  Island beaches  have
important recreational, economic,  and cultural significance.  Beaches provide a year-
round draw for tourists and residents alike and also allow local fisherman to continue
traditional practices. Currently, pollution from many different sources results in frequent
and widespread island beach advisories.

   EPA uses a combination of tools to improve conditions in the islands.  The Agency
targets infrastructure and non-point source grants at the greatest deficiencies.   With
aggressive enforcement and technical assistance,  EPA works to improve the capacity of
island utilities to protect public health and safeguard  the environment.   In  close
cooperation  with  island and  federal  partners,  EPA continues to work toward the
development of a  Territories  Bond Bank.   The Bond Bank will provide islands with
access to more affordable financing, greatly enhancing their ability to fund critical capital
improvement projects.

Protecting Arctic Indigenous Communities

   Long-range and transboundary atmospheric transport and deposition of persistent
organic  pollutants (POPs) are a continuing threat to human health and ecosystems.
These pollutants can travel great  distances from  their sources, remain intact for long
periods, enter the ecosystem, and bioaccumulate through the food chain. Consequently,
POPs are a continuing threat to human  health and the ecosystems in North America,
especially the Arctic.  Arctic indigenous populations, including those  in Alaska,  have
higher  exposures  to POPs  than other  populations due  to their  traditional  food
consumption.  Reducing international  sources of POPs can  lead to reductions of their
levels in the Arctic environment, including animal food sources. The United States is a
strong supporter of the Stockholm Convention on Persistent Organic Pollutants, a global
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treaty to reduce POPs that EPA helps implement.
                                                41
   The Arctic Monitoring  and  Assessment Program, that documents exposure  of
indigenous populations to toxics in remote areas, indicates the primary sources of POPs
are from  international, long-range transport, and that some of the largest sources  of
pollutants to the Arctic include Russia and China.42  EPA works with Russia and other
Arctic Council members toward reducing these pollutants, including efforts to collect and
safely  store  obsolete  pesticide stockpiles.   Based on EPA-led Arctic Council projects,
EPA estimates that about 24,000 tons of POPs pesticides will be removed from unsafe
storage and  destroyed by 200843 and about 12,000 tons of PCB oil will be destroyed by
2009.44  EPA also works with partners to raise awareness about persistent pollutants,
build capacity to prevent pollution, and share beneficial technologies to protect  arctic
indigenous communities.

OBJECTIVE 4.3:  RESTORE  AND  PROTECT CRITICAL  ECOSYSTEMS.  Protect,
sustain, and  restore the  health of critical natural habitats and ecosystems.

NACEPT SA Comments
By establishing "critical  ecosystems" and ecosystem-specific  sub-objectives, is the  Agency devaluing
non-listed ecosystems?  Will this have an  impact on priority setting and resource allocation  during
implementation of the Strategic Plan?

NACEPT SP Comments
This is an area  where Goals 3 and 4 can be linked by connecting the sustainable principles of community.
economy, and  ecology.   The rebuilding of disaster areas  is an opportunity to  "get it right"  in the
rebuilding effort.

Recently published research from a range of academic and governmental scientists indicates that the issue
of water-body acidity is much more global than previously presumed, and extends to the oceans as well as
inland lakes. pH declines of 0.3 pH units over the next century are projected as a result of absorption of
increasing amounts of CO? from the atmosphere.  While  CO?  absorption may  be viewed as  an
environmental benefit with regard to atmospheric CO? concentrations, the increased acidity of the oceans
is expected to significantly impact marine ecosystem health. EPA should conduct and support research
towards greater understanding of the impact of atmospheric CO? concentrations on freshwater and marine
ecosystems, and develop, as appropriate, strategies and objectives to ensure water bodies are protected
from Correlated acidity.
             Critical Ecosystems
                •  Wetlands
                •  Estuaries
                •  Great Lakes
                •  Chesapeake Bay
                •  Gulf of Mexico
                •  Long Island Sound
                •  South Florida Ecosystem
                •  Puget Sound Basin
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   Sub-objective 4.3.1: Increase Wetlands.  By 2011, working with partners, achieve
   a net increase in wetlands acres with additional focus on  assessment of wetland
   condition as determined by the Strategic targets described below.

       Strategic Targets:

•  By  2011, working with partners, achieve a net increase of 100,000 acres of wetlands
   per year  with  additional focus  on   biological  and functional  measures  and
   assessment of wetland condition.  (2003 Baseline: annual net wetland gain/loss to be
   determined in  Spring  of 2006 based on  new Fish and Wildlife  Service Report 2004
   Baseline: 32,000 acres annual net wetland gain based on new U.S. Fish and Wildlife
   Service  (USFWS)  National Wetlands Inventory Status and Trends  Report, 1998-
   2004.)

•  By  2011, in partnership with the U.S. Army Corps of Engineers (the Corps),  states,
   and tribes, achieve "no net loss" of wetlands each year under the Clean Water Act
   Section 404 regulatory program, beginning in 2007.  (Baseline: new  baseline to be
   determined in 2008)

NACEPT SA Comments
How do these two targets fit together? Is the second target a sub-set of the first target?
How are these two targets coordinated so that the net increase of the first target is achieved if the net
outcome of Section 404 activities is zero?

   Sub-objective 4.3.2:   Facilitate the Ecosystem-Scale Restoration of Estuaries
   of National Significance Designated under the National Estuary  Program.   By
   2011, working with partners,  protect or restore  an additional (i.e.,  measuring from
   2007 forward) 250,000 acres of habitat within the study areas  for the 28 estuaries
   that are part  of the National  Estuary Program.   (2005 Baseline: 510,910 449,242
   acres of habitat protected or restored; cumulative from 2001 2002.)

   NACEPT SA Comments
   Protection and restoration are separate processes/programs. Although providing program flexibility is
   desirable, are the two being tracked separately to make certain both goals are being met?

   NACEPT SP Comments
   When compared to the 2002 through 2005 cumulative baseline of 449.242 acres, this strategic target
   is a 42% reduction in the annual restoration rate (62.500 acres versus 149.747 acres'). What is EPA's
   reason behind this substantial reduction in expected program performance?
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   Sub-objective 4.3.3:  Improve the Health of the Great Lakes. By 2011, prevent
   water pollution and protect aquatic systems so that the overall  ecosystem health of
   the Great Lakes is at least 23 points on a 40-point scale.  (2005 Baseline: Great
   Lakes rating of 21.5 on the 40-point scale where the rating uses select Great Lakes
   State of the Lakes Ecosystem indicators based on a 1 to  5  rating system for each
   indicator, where 1 is poor and 5 is good.45)

   NACEPT SA Comments
   How is this sub-objective coordinated with activities under Goal 2 and Goal 57

      Strategic Targets:

   •  Through 2011, maintain or improve an  average annual 5  percent decline for the
      long-term trend  in  average concentrations  of PCBs  in  whole  lake  trout and
      walleye samples.  (Baseline: exponential decay of Great Lake dataset  beginning
      with 1990 decline from 1990 levels.—)

   NACEPT SA Comments
   This is and the following target are confusing and should be reworded to state that the average
   concentrations should decline by 5% or greater per year.

   •  Through 2011, maintain or improve an  average 7 percent annual decline for the
      long-term trend in average concentrations  of toxic chemicals (PCBs) in the air in
      the Great Lakes basin.  (Baseline: Exponential decrease of average concentrations
      using  IADN data  through  2000.  Decline from  1992 levels  measured through
      Integrated Atmospheric Deposition Network (IADN) data.—)

   •  By 2010, restore and  delist a cumulative total of at least 40 8 Areas of Concern
      within the Great Lakes basin (2005 Baseline: 0 areas of concern de-listed as of
      2005 of the 31 total areas of concern.)

   •  By 2011,  remediate a cumulative total  of  7 million cubic  yards of contaminated
      sediment in  the  Great  Lakes.    (2005  Baseline:  3.7 million  cubic  yards  of
      contaminated sediments from the Great Lakes  have been remediated from 1997
      through 2004 of the 75 million yards estimated to need remediation.)

   NACEPT SP Comments
   By inserting the phrase "a cumulative total of," the target for the life of this Strategic Plan
   has been reduced 47% from 7 million cubic yards to 3.3 million cubic yards, or an average
   annual remediation of 660,000 cubic yards. Based on the estimated 75 million  cubic yard
   baseline requiring remediation, this effort will take more than a century to complete.

   Sub-objective 4.3.4: Improve The Health of the Chesapeake Bay Ecosystem.
   By 2011,  prevent water  pollution and protect aquatic systems so that the overall
   aquatic system health  of the Chesapeake Bay is  improved as measured by  the
   strategic targets described below.
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      Strategic Targets:

   •  By 2011, achieve 45 percent (83,250 acres) of the submerged aquatic vegetation
      goal for the Bay will be achieved long-term restoration goal of 185,000 acres of
      submerged aguatic vegetation.  (2005 Baseline: 39 percent (72,935 acres) of
      submerged  aguatic  vegetation goal  achieved;  the ultimate  goal is 100%
      achievement of the 185,000 acre goal for submerged aguatic vegetation.)

   •  By  2011, 63% of dissolved oxygen goal  will  be achieved achieve  40  percent
      (29.92 cubic km) of the long-term  restoration goal of 100 percent attainment of
      the dissolved oxygen  water guality standards in all tidal waters of the Bay. (2005
      Baseline: 57% of dissolved oxygen goal  achieved; the ultimate goal is 100%
      attainment of the dissolved  oxygen water  quality standards in all tidal waters of
      the Bay. 34 percent (25.40 cubic km) of dissolved oxygen goal achieved.)

   •  By  2011, achieve 59 percent (95.88 million pounds) of the long-term  goal to
      reduce annual nitrogen loads 162 million pounds from 1985  levels.

   •  By  2011, achieve 74 percent (10.63 million pounds) of the long-term  goal to
      reduce annual phosphorus loads 14.3 million pounds from 1985 levels.

   •  By 2011, achieve 74  percent (1.25 million tons) of the long-term  goal to reduce
      annual land-based sediment loads  1.68 million tons from 1985 levels.

   Sub-objective 4.3.5: Improve the Health of the Gulf of  Mexico.   By 2011,  the
   overall health of coastal waters  of the Gulf of Mexico will be improved from 2.4 to 2.6
   on the  good/fair/poor scale of the  National Coastal Condition  Report.   (2004
   Baseline: Gulf Coast rating of fair or 2.4 where  the rating is based on a 4-point
   system where 1  is poor and 5 is good.)

      Strategic Targets:

   •  By 2011, restore water and  habitat quality to meet water quality standards in 71
      impaired segments (cumulative) in 13 priority  coastal areas (i.e., 20 percent of
      the 354 impaired segments  identified  in 13  priority  coastal areas).   (2005
      Baseline: 28 segments restored)

   •  By  2011, restore, enhance, or protect 20,000 acres of important coastal and
      marine habitats.  (2005 baseline: 16,000 acres  restored, enhanced, or protected;
      Gulf of Mexico coastal wetland habitats include 3,769,370 acres.)

   •  By 2015, reduce releases of nutrients throughout the Mississippi  River Basin to
      reduce the size of the hypoxic zone in the  Gulf of Mexico to less than 5,000 km2,
      as measured by the 5-year  running average of the size of  the zone.  (Baseline:
      1996-2000 running average  size =  14,128 km2.)
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   Sub-objective 4.3.6: Restore and Protect Long Island Sound.  By 2011, working
   through the Long Island Sound Study Management Conference partnership, prevent
   water pollution,  improve water quality, protect  aquatic systems,  and restore  the
   habitat of Long Island Sound.

   NACEPT SA Comments
   This sub-objective should be numbered 4.3.6.

      Strategic Targets:

   •  By 2011 2014, reduce point source  nitrogen discharges to Long Island Sound by
      10,892 tons 58.5 percent as measured by the Long Island Sound Nitrogen Total
      Maximum Daily  Load. (Annual reduction target:  1,556 tons/year 8,303 Ibs/day.
      200^1 Baseline: 28,100 tons/year.  TMDL baseline:  212,899 Ibs/dav: 2014 target:
      88,353 Ibs/dav.)

   •  By 2011, reduce the size of hypoxic area in Long Island Sound (i.e., the average
      maximum July-September <3mg/l DO) by 25 percent; reduce average duration of
      maximum hypoxic event by 25 percent.  (2005 baseline derived from  19-year
      averages as of December 2005.  Size: 203 sq/mi. Duration: 58 days.)

   •  By 2011, restore or  protect an additional 300 acres of coastal habitat, including
      tidal wetlands, dunes, riparian buffers, and freshwater wetlands from the 2005
      baseline.  (2005 baseline: 562 acres  restored and  150 acres protected acres
      restored are reported to the NEP.)

   •  By 2011,  reopen  an additional  50  miles  of  river and  stream corridor to
      anadromous fish passage from the  2005 baseline through removal of dams and
      barriers or installation of by-pass structures such as fishways.   (2005 baseline:
      81 miles.)

   Sub-objective 4.3.7: Restore and Protect the South Florida Ecosystem.  Protect
   and maintain the South Florida Ecosystem, including the Everglades and coral reef
   ecosystems, as measured by the strategic targets described below.

   NACEPT SA Comments
   This sub-objective should be numbered 4.3.7.

   NACEPT SP Comments
   The strategic targets listed below for the  South Florida Ecosystem do not present a goal of restoration.
   but merely a goal of maintaining the status quo (no deterioration from baselines). However, the
   various baselines are not sufficiently described to determine whether the ecosystem is currently in
   excellent health or impaired. If the ecosystem is impaired, then EPA should establish more ambitious
   strategic targets for improvement and restoration.

      Strategic Targets:
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   •  Annually, beginning in 2008, work with the U. S. Army Corps of Engineers and
      other partners to achieve "no net loss® of wetlands in South  Florida  under
      Section 404 of the Clean Water Act. (2005 baseline to be determined in 2006.)

   •  By  2012,  working with all stakeholders (federal,  state,  regional,  and  local),
      achieve "no net loss® of stony coral cover (mean  percent stony coral cover) in
      the Florida Keys National Marine Sanctuary (FKNMS) and in the coastal waters
      of Dade,  Broward,  and  Palm  Beach  Counties,  Florida.    (Baseline  to  be
      determined using information collected and analyzed in FY 2005 by the long-term
      coral reef monitoring projects.)

   •  By 2011, maintain the overall health and functionality of  sea grass beds in the
      FKNMS each year beginning in 2008, as measured by the long-term sea grass
      monitoring project that addresses composition and abundance, productivity, and
      nutrient availability.  (Baseline index of sea grass health to be determined using
      information collected and analyzed in FY 2005.)

   •  By 2011, maintain the overall water quality of the near shore and coastal waters
      of the FKNMS each  year, beginning in 2008.   (Baseline concentrations  for
      inorganic nitrogen [nitrate,  nitrite,  and ammonium], soluble reactive phosphorus,
      water clarity [turbidity and  light attenuation], and chlorophyll a to be determined
      using information  collected and analyzed in  FY 2005  as measured by the long-
      term water quality monitoring project.)

   •  By 2011,  maintain the water quality of  the Everglades ecosystem each  year,
      beginning  in  2008,  as measured through  water quality monitoring  of total
      phosphorus. (Baseline is 1995 water quality.)

   Sub-objective 4.3.8:  Restore  and Protect the Puget  Sound Basin.   By 2011,
   improve  water  quality, air quality,  and minimize the  adverse impacts of  rapid
   development  in the  Puget Sound Basin as  measured by  the  strategic  targets
   described below.

   NACEPT SA Comments
   This sub-objective should be numbered 4.3.8.

      Strategic Targets:

   •  By 2011,  improve water quality  and lift harvest  restrictions  in 1,000 acres of
      shellfish bed growing areas impacted by degraded or declining  water quality.
      (Baseline:  As of January 2006, approximately 30,000 shellfish bed  growing areas
      had harvest restrictions due to water quality impairments in Puget Sound.)

   •  By 2011, remediate 100 acres of prioritized contaminated sediments 200 acres of
      prioritized  contaminated sediments are remediated.  (Baseline: as of January
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      2006, approximately 5,000 acres of remaining contaminated sediments required
      some level of remediation.)

   •  By 2011,  festefe 3,500 acres of tidally- and seasonally-influenced  estuarine
      wetlands are restored. (2005 Baseline: xxx acres restored as of January 2006
      total  intertidal and near shore habitat acres identified in the 2006 Puget Sound
      Near Shore Restoration Site Inventory Database.)

   •  By 2011,  through coordinated diesel emission mitigation efforts, reduce total
      diesel emissions in the Puget Sound airshed  by 8 percent through  coordinated
      diesel emission mitigation efforts.  (2006 Baseline xxx tons of diesel emissions to
      the Puget Sound airshed will be determined in 2006.)

   Sub-objective 4.3.9: Restore and Protect the Columbia River Basin.  By 2011,
   prevent  water pollution,  and improve  and protect water quality and  protect and
          ecosystems in the Columbia River Basin ecosystems so that to reduce risks
   to human health and the environment can be reduced as measured by the strategic
   targets described below.

   NACEPT Comments
   This sub-objective should be numbered 4.3.9.

      Strategic Targets:

   - — By 2011, about 5,000 acres of farmland have best management practices, no-till
      agriculture and/or precision agriculture actions in place resulting in XX% sediment
      reduction by 2011.  (2004 Baseline: YY.OOO acres of agricultural land which have
      implemented sediment reduction  actions. — This information will  be collected by
      working with State and local agricultural partners.)

   - — By 2011, reduce toxic chemicals (PCBs, dioxins, furans, arsenic, mercury, and all
      forms of DDT and breakdown products) in fish tissue in 50% of the geographic
      areas of the Columbia River and tributaries where fish were sampled and shown
      to be contaminated in the EPA 2002 Fish Contaminant Survey. — (Baseline: Data
      on fish sampling from the EPA 2002 Fish Contaminant Survey.)
   •  By 2011, protect, enhance or restore 13,000 acres of wetland habitat and 3,000
      acres of upland habitat.  (Baseline: 1999 Lower Columbia River Comprehensive
      Conservation Management Plan.—)

   •  By 2011, clean up about 400 acres (5%) 150 acres of known highly contaminated
      sediments.   (Baseline: XX acres [Approximately 8,000  acres] of 400 acres of
      known highly contaminated sediments in the main-stem  of the Columbia River
      and Lower Willamette River as of 2006.)
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   •  By  2011,  demonstrate  a  10  percent  reduction  in  mean concentration  of
      contaminants of concern found  in water and fish tissue.  (Chemical-specific
      baseline  will be available  in  2006 from  the  following  sources:  Pesticide
      Stewardship Partnership (PSP) Studies for Oregon as of 2006—; Total Maximum
      Daily  Load (TMDL) studies for Washington—: 2002 EPA Columbia River Basin
      Fish Contaminant Survey—;  Lower  Columbia River Estuary Partnership 2006
      Monitoring   Study—;   and   Washington  Ecology's  March  2005   Report:
      Concentrations of 303(d) Listed Pesticides, PCBs, PAHs, Measured with Passive
      Samplers Deployed in the Lower Columbia River.—)

Means and Strategies For Achieving Objective 4.3

   EPA works  to protect,  sustain,  and restore  the health  of natural  habitats and
ecosystems  by  identifying  and evaluating problem  areas,  developing  tools, and
improving  community  capacity to address  problems.  Our activities target wetlands,
estuaries,  and high-priority areas such as the Great Lakes, Chesapeake Bay,  Gulf of
Mexico, Long Island Sound, South Florida ecosystem, Puget Sound  Basin,  and the
Columbia  River.  Place-based ecosystem protection efforts focus  attention on critical
watersheds  to  develop and  implement water quality  control  practices and other
ecosystem management tools that can be transferred  to other place-based efforts
nationwide.

Increasing Wetlands

   Since the 1700's, the United States has lost more than 115 million acres of wetlands
to development, agriculture, and other uses.54  Today,  the nation  may  be entering  a
period of annual net gain of wetlands acres for some wetland classes.  When wetlands
function properly, they can  provide water  quality protection,  fish and wildlife habitat,
natural floodwater storage, and reduction in the erosive potential of surface water. Still,
many wetlands in  the United States are in less than pristine condition and  many created
wetlands,  while beneficial, fail to replace the diverse plant and animal communities of
wetlands lost.  Excessive sedimentation, nutrient over-enrichment,  pesticides,  invasive
species, habitat loss, and fragmentation are degrading wetlands.55

   The 2006 National  Wetlands Inventory Status and Trends Report shows the overall
gains in wetland acres exceeded overall losses from 1998 through 2004.  However, this
gain is primarily attributable to an increase in unvegetated freshwater  ponds, some of
which (such  as aquaculture ponds) may not function  as wetlands and others which have
varying  functional value.  The report also  notes that freshwater vegetated  wetlands
declined by  0.5 percent, a  smaller rate of loss than in preceding years,  and estuarine
vegetated  wetlands declined by 0.7  percent, an  increased rate of loss from  the
preceding  years. The Status and Trends Report, however, does not assess the quality
or condition  of wetlands.  EPA will work with the  U.S.  Fish and Wildlife Service and
other federal agencies to refine the methodology used in preparing future reports to
more effectively assess the status and trends of both the quantity and  quality  of the
nation's wetlands.
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    EPA cooperates with federal partners, state and tribal governments,  and others to
achieve the President's goal, set in 2004, to  restore,  improve, and protect 3 million
acres of wetlands  by 2009.   Progress under the President's  Initiative  is reported
annually starting in 2005,  in  "Conserving America's  Wetlands:  Implementing the
President's Goal."   EPA also works with the U.S. Army Corps of Engineers (the Corps)
in several key areas to ensure "no net loss" of wetlands under Section 404 of the Clean
Water Act.  A key area of cooperation is the application  of the 404(b)(1) guidelines that
require that discharges of dredged  or fill material into waters of the United States  be
avoided and minimized to the extent practicable, and that unavoidable impacts be fully
compensated.  EPA and the Corps are  cooperatively developing a consistent  set of
science-based standards for all types of compensatory mitigation56 or mitigation that
compensates for wetland destruction.  EPA also works with the Corps to  enhance data
collection and tracking of Section 404 permitted projects and associated compensatory
mitigation and provides this information to federal,  state, and  tribal partners and the
public.

   EPA leads federal  agency implementation of the  2002 National Wetlands Mitigation
Action  Plan,  which  includes 17 action  items to improve the effectiveness  of wetland
mitigation and restoration.57  EPA  continues to enhance its wetlands monitoring  by
building state and tribal capacity to measure wetland function  and condition.  Broad-
based, integrated monitoring and assessment programs improves wetlands decision-
making,  helps  target  restoration   activities,  and  facilitates our  ability to  address
significant stressors.  EPA provides technical and  financial support through wetland
program development grants to build state and tribal wetland programs in the areas of
regulation,  monitoring, restoration, water quality standards, mitigation compliance, and
partnership-building.  Other programs, such as the Five Star Restoration  Challenge
Grant Program,58 regional  geographic initiatives  (RGI),59 targeted  watershed grants
(TWG),60  and  nonpoint  source  grants,61  provide  funding,  technical  support, and
information to help communities build strong partnerships to implement riparian, coastal,
and wetland restoration projects.  EPA also is fully integrating wetlands protection into
other clean water and other Agency programs, such as Brownfields.
 To Learn More:
 www.epa.gov/owow/wetlands/
Restoring Estuaries

   Estuaries  are  among the  most  biologically  productive ecosystems  on  earth,
providing numerous ecological, economic, cultural, and aesthetic benefits and services.
They  are also among the most threatened ecosystems, largely as a result of rapidly
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increasing  growth and  development.62   Estuaries  tend to accumulate  sediments,
nutrients, and other pollutants from adjacent and upstream land-based sources.  This
can have  a profound effect on water quality, habitats, living  resources, and  human
health.  In addition, overuse of natural resources and conflicts among recreational and
commercial users have resulted in a host of problems.

   EPA's  National  Estuary Program (NEP)  provides  inclusive,  community-based
planning and action  in 28 nationally significant estuaries selected by Congress and the
states' governors.  EPA supports and monitors the continuing efforts of all 28  NEP
estuaries to implement approved comprehensive conservation and management plans,
which identify over 2,000 priority actions needed to protect the estuaries and  restore
estuarine resources.  In addition, EPA supports broad priorities identified by the NEPs,
including: developing approaches to identify and rank priority habitats; providing tools to
integrate local and regional plans for  growth with stormwater management; supporting
development of total maximum  daily loads (TMDLs) for coastal waters; developing and
implementing nutrient  management strategies, including development of nutrient water
quality criteria;  addressing problems  of invasive  species; and,  reducing wet weather
runoff from urban and agricultural areas.
     ESTUARIES IN THE NATIONAL ESTUARY PROGRAM
     Albemarle-Pamlico Sounds, NC
     Barataria-Terrebonne, LA
     Barnegat Bay, NJ
     Buzzards Bay, MA
     Casco Bay, ME
     Charlotte Harbor, FL.
     Coastal Bend Bays and Estuaries, TX.
     Lower Columbia River, OR/WA
     Delaware Estuary, DE/NJ
     Delaware Inland Bays, DE
     Galveston Bay, TX
     Indian River Lagoon, FL
     Long Island Sound,  NY/CT
     Maryland Coastal Bays, MD
  Massachusetts Bay, MA
  Mobile Bay, AL
  Morro Bay, CA
  Narragansett Bay, Rl
  New Hampshire Estuaries, NH
  New York/New Jersey Harbor, NY/NJ
  Peconic Bay, NY
  Puget Sound, WA
  San Francisco Bay, CA.
  San Juan Bay,  PR
  Santa Monica Bay, CA
  Sarasota Bay, FL
  Tampa Bay,  FL
  Tillamook Bay, OR
     To Learn More:  www.epa.gov/owow/estuaries
    The health of the nation's estuarine ecosystems also depends on the maintenance
of high-quality habitat.   Diminished and degraded  habitats are less able to support
healthy  populations of wildlife and  marine  organisms and perform the  economic and
ecological functions on which coastal populations  depend for  their livelihood.   EPA
facilitates the ecosystem-wide protection and restoration of natural areas in cooperation
with other federal  resource agencies  through interagency partnerships, such  as the
Estuary Habitat Restoration Council and Coastal America.

Great Lakes
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   The Great Lakes are the largest system of surface freshwater on earth, containing
20 percent of the world's surface freshwater and about 84 percent of North America's
surface freshwater.  The watershed includes 2 nations, 8 American states,  a Canadian
province, more than 40 tribes, and more than one-tenth of the U.S. population.

   While certain persistent toxic substances (PTS) have been reduced significantly in
the Great Lakes Basin Ecosystem over the past 30 years,  they continue to be present at
levels that pose threats  to  human and  wildlife  health,  warrant fish consumption
advisories in all five lakes, and disrupt a way of life for many in the basin.  The Great
Lakes Legacy Act targets additional resources to  clean up contaminated sediments, one
of the significant sources of PTS.  The Great Lakes Regional Collaboration  Strategy
uses the concepts of the Great  Lakes Binational Toxics Strategy63 as its starting point
for reduction and elimination of PTS.  The Great Lakes Binational Toxics Strategy is a
groundbreaking international toxics reduction effort that applies voluntary and regulatory
tools focused on pollution prevention to a targeted set of substances, including mercury,
PCBs, dioxins/furans,  and certain  canceled pesticides.  Both the Legacy Act and the
Great Lakes Binational Toxics Strategy support  work EPA is doing with the states  to
promote delisting of all Areas of Concern by 2025.

   In a 2004 Executive Order, the  President established two major Great Lakes efforts:
A "Great Lakes Interagency Task Force"64 and a Great Lakes "Regional Collaboration
of National Significance"  (GLRC).65   The  Task Force  brings together ten  Cabinet
secretaries and federal  agency heads to coordinate restoration of the Great Lakes,
focusing  on outcomes  like cleaner  water and  sustainable  fisheries, and targeting
measurable results. More than 1,500 people representing federal, state, local and tribal
governments; nongovernmental entities; and private citizens participated on eight issue-
specific  GLRC teams to develop  a GLRC  Strategy,  completed in 2005.66   Strategy
Teams focused on aquatic invasive species, habitat/species, coastal health, sediments,
nonpoint  sources,  toxic  pollutants,  indicators and information,  and  sustainable
development, and  recommended many actions  to  take  over the next 5 years.   The
federal government committed to implement 48 near-term activities that address issues
in all 8 of the priority areas identified in the Strategy, as illustrated below:

   •  Implement the Great Lakes  Legacy Act to remediate contaminated sediments in
      Great Lakes Areas of Concern.
   •  Establish  a communication network among  federal  agencies to coordinate
      responses to newly identified aquatic invasive species, primarily in response  to
      requests for assistance from state or local authorities.
   •  Develop a system to track and report on the GLRC wetlands goal  to enhance
      and protect 200,000 acres of wetlands in the Great  Lakes basin.
   •  Develop a standardized sanitary survey form for  state and local governments
      use.
   •  Improve policy  guidance on managing  peak flows at  sanitary sewer plants  to
      reduce overflows.
   •  Conduct surveillance for emerging chemicals of concern.
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   •  Work with the U.S. Army Corps of Engineers to expedite the processing and
      review of permits for projects to restore wetlands and other aquatic habitat in the
      Great Lakes Basin.
 To Learn More:
  www.epa.gov/greatlakes/
Chesapeake Bay

   EPA's Chesapeake Bay work is based on a unique regional partnership formed to
direct and conduct  restoration of the  Bay and its tidal tributaries.   Partners include
Maryland, Virginia, Pennsylvania, Delaware, New York, and West Virginia; the District of
Columbia; the Chesapeake Bay Commission,  a tri-state  legislative body; EPA,  which
represents  the  federal  government;  and  participating  citizen  advisory  groups.
Chesapeake 2000,  a  comprehensive and far-reaching agreement, guides restoration
and protection efforts through 2010, and focuses on improving water quality as the most
critical element in the  overall protection and restoration of the bay and its tributaries.67
The challenge for EPA and its partners is to reduce pollution and restore aquatic habitat
to the extent  that  the Bay's waters can  be  removed from the Clean Water Act's
"impaired waters" list.

   EPA and its partners work to improve two  key measures of bay water quality: the
restoration of  submerged  aquatic vegetation (SAV)  and the attainment of dissolved
oxygen (DO) standards in the Bay's tidal waters. The  Chesapeake Bay Program's long-
term goal for SAV restoration in the Bay is 185,000 acres and the long-term goal for DO
restoration in the Bay  is 100 percent attainment of standards in all tidal waters  of the
Bay.  To achieve these long-term goals, Bay watershed  models estimate that annual
nitrogen loadings must be reduced by 162 million pounds, phosphorus reduced by 14.3
million pounds, and  sediment reduced by 1.68 million tons per year from  1985 levels.68
As of 2005, 39 percent (72,935 acres) of the SAV and 34% (25.40 cubic km) of the DO
long-term  restoration  goal  was  achieved, and 41%  (67.42 million  pounds)  of the
nitrogen, 58 percent (8.39  million pounds) of the phosphorus,  and 54  percent (0.91
million tons) of the sediment long-term reduction goal was achieved.69

   As of 2005, 61 percent (30.41 million pounds) of the nitrogen and 80 percent (4.93
million pounds) of the  phosphorus long-term reduction goals were achieved.  The 2011
targets are 88 percent (43.91 million Ibs) of the nitrogen  and 91  percent  (5.61 million
pound) of the  phosphorus  reduction goals for wastewater dischargers.  The long-term
goals  for  nutrient   reduction  from  significant wastewater  dischargers  in  the Bay
watershed are to achieve  a 50 million  pound  per year reduction in nitrogen and  a  6
million pound  per year reduction in phosphorus loads from 1985 levels.  The current
pace  of nutrient and  sediment load  reductions is  not  sufficient and  needs  to be
accelerated to restore  water quality by the Chesapeake 2000 goal of 2010. EPA and its
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partners  will  review  progress  each year and make adjustments to increase  annual
targets if appropriate.

   EPA works with other Bay Program partners to make the most cost-effective use of
available regulatory,  incentive,  and voluntary tools and to find new  economies  and
innovations to  pick  up the pace dramatically.   A  key strategy  to  reduce nutrient
discharges is the  implementation of  advanced wastewater treatment.  Another  key
strategy to reduce nitrogen, phosphorus, and sediment loadings is  the restoration  and
protection of  riparian forests that prevent sediment and nutrient  pollution from entering
waterways from the land. The  long-term goal  for forest buffer planting in the watershed
is 10,000 miles.  As  of FY 2005,  3,791 miles had been planted, achieving 38% of the
goal.  The 2011 target for forest buffer  planting is 8,400 miles or 84% goal achievement.
Implementing agricultural best management practices to reduce nutrients and sediment
is also key to  achieving Bay goals, and requires close cooperation with U.S. Department
of Agriculture. Water quality restoration complements other critical initiatives to protect
and  restore  critical  Bay watershed  habitat and  improve  fisheries  management,
undertaken by partner federal agencies, such as the National Oceanic and Atmospheric
Administration, U.S. Department of the Interior, U.S. Department of Agriculture, and the
U.S. Army Corps of Engineers,  and  by Maryland, Virginia,  Pennsylvania,  Delaware,
New York, and West  Virginia.
 To Learn More:
 www.epa.gov/region3/chesapeake/
Gulf of Mexico

   The Gulf of Mexico's estuaries and near coastal waters support critical fisheries and
wildlife habitats that significantly contribute to the national and  Gulf state economies.
The sustainability of the Gulfs marine  resources is under  increasing pressure from
population  growth, land development, coastal  and commercial  activities.  Hurricanes
Katrina and Rita wrought widespread environmental harm in 2005.

   The EPA Gulf of Mexico Program70 assists the Gulf states and stakeholders develop
a regional, ecosystem-based framework for restoring and  protecting  the Gulf.   EPA
supports a collaborative,  multi-organizational  partnership  with  business,  industry,
agriculture, state and  local government, citizens,  environmental organizations, fishery
interests, and federal agencies.  In addition, the five Gulf states formed a Gulf of Mexico
Alliance71   to  increase  regional  collaboration  to enhance the  environmental  and
economic health of the  Gulf of Mexico.   Thirteen federal agencies have organized a
regional partnership72 to provide support  to the Gulf of Mexico Alliance.

   In  2006, the Gulf of Mexico Alliance73 developed the  Governors'  Action  Plan for
Healthy and Resilient Coasts74 that identifies five key priority coastal and ocean issues
that are regionally significant and  can be effectively addressed through cooperation at
the local, state, and federal levels: (1) water quality for  healthy beaches and  shellfish
beds;  (2) wetland and  coastal  conservation  and  restoration;  (3)  identification  and
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characterization of  gulf habitats for management decision making; (4) reductions  in
nutrient  loadings;  and, (4) strategic environmental  education across  the  five-state
region.

   Although  nutrients, such as nitrogen and  phosphorus, are essential  for healthy
marine and freshwater environments,  an overabundance  can  trigger  excessive algal
growth.   In the  near-shore Gulf of Mexico, excessive algal growth results in a decrease
in  dissolved oxygen in the bottom water, and a corresponding  loss of aquatic habitat.
This "hypoxic zone" is the largest area of hypoxia in U.S. waters that is associated with
human activities.
                       REDUCING THE GULF HYPOXIC ZONE

 To reduce the size of the hypoxic zone in the Gulf of Mexico, EPA supports:
    •   State-based implementation of nutrient-focused hypoxia reduction measures through
        multi-year budget strategies;
    •   Collaborative monitoring and assessment framework to measure and calibrate the
        performance of nitrogen reduction efforts;
    •   Updating of information on flow, nutrient concentrations, and loadings at the mouths
        of each major sub-basin in partnership with USGS and sub-basin committees;
    •   Modeling of the hypoxic zone;
    •   Cooperative implementation of industry-led nonpoint source nutrient reduction
        strategies through effective sub-basin team partnerships; and
    •   Science and management re-assessment of the nutrient load reductions achieved
        and the response of the hypoxic zone; water quality throughout the Basin; and
        economic and social effects of Gulf of Mexico hypoxia.
   Causes of the Gulf of Mexico hypoxic zone include: excessive nutrients delivered to
Gulf waters from the Mississippi-Atchafalaya River drainage basin; physical changes,
such  as channelization,  loss of  natural wetlands  and riparian buffers, and wetland
conversions throughout the basin; and stratification in the waters of the northern Gulf
caused by the  interaction of fresh river water and the saltwater of the Gulf.  EPA is
working with other partners on a national hypoxia task force to carry out key actions
outlined in the Action Plan for Reducing,  Mitigating,  and Controlling Hypoxia in the
Northern Gulf of Mexico, with the goal of reducing the size  of the hypoxic  zone from
about 14,000 square km to less than 5,000 square km by 2015.75
 To Learn More:
 www.epa.gov/gmpo/
Long Island Sound

   EPA works  in partnership with the  States of New York and Connecticut and other
federal, state,  and local  Long  Island  Sound  Management Conference  partners to
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implement a comprehensive conservation and management plan (CCMP) to restore the
Sound.  Since levels of dissolved oxygen are critical to  the health of aquatic life and
viable public use of the Sound, the CCMP focuses on controlling nitrogen discharges to
meet applicable water quality standards.  EPA and state  partners are implementing an
agreement  to control the maximum  daily load of nitrogen entering the Sound.   The
agreement  provides for a 58.5 percent reduction in nitrogen loads to the Sound over a
15-year period ending in 2014.  This bi-state nitrogen reduction agreement uses flexible
and innovative approaches, notably Abubble® management zones and exchange ratios
that allow sewage treatment plant operators to Atrade®  nitrogen  reduction obligations
with each other.  This approach will allow the plant operators to save an estimated $800
million  by allocating reductions to those plants  where  they  can  be achieved  most
economically while meeting water quality improvement goals.

   EPA and the Management  Conference  partners are also  working  to  restore
degraded habitats;  reopen rivers and streams to anadromous fish passage; improve
riparian buffers; restore submerged aquatic vegetation in key embayments; reduce the
impact of toxic  substances, pathogens,  and floatable  debris on the  ecology;  and
promote  environmental education,  management, and  stewardship throughout the
watershed.   The bi-state  Long  Island Sound 2003 Agreement  and  its successor
documents  guide and measure the  implementation of progress  in concert with core
Clean  Water  Act   programs  to  manage  nonpoint  sources  of  pollution,  protect
watersheds, regulate point sources of pollution, and address nitrogen deposition from
the airshed.
 To Learn More:
 www.epa.gov/region01/eco/lis/
South Florida Ecosystem

   The natural resources of the South Florida ecosystem include 3 national parks, more
than 10 national wildlife refuges, a national preserve, and a national marine sanctuary.
The South Florida ecosystem is the principal nursery area for the largest commercial
and sport fisheries in Florida, home of the largest wilderness area east of Mississippi
River, the location of the only living coral barrier reef adjacent to the United States, the
most significant breeding ground for wading birds in North America, a major producer of
sugarcane, home to two Native American nations, and a major tourist region.

   Rapidly expanding human population is a threat to the  ecosystem's health. The
South Florida region is home to about 8 million  people;  and is more populous than 39
individual states.  Over 2 million more people are expected to  settle in the area over the
next 10 to 20 years.  Fifty percent of the region's wetlands have been lost to suburban
and  agricultural  development  and  the  altered hydrology   and  water  management
throughout the region have had a major impact on the ecosystem.
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   To address the issues surrounding the south Florida ecosystem, EPA is working in
partnership with several local, regional, state, and federal agencies.  The  goal is to
ensure  the  long-term  sustainability  of the  region's varied  natural  resources  while
providing for the coexistence of  extensive agricultural operations and  a continually
expanding  human population.  EPA's South  Florida geographic initiative  (SFGI) is
designed  to  protect  and   restore  communities  and  ecosystems  impacted   by
environmental problems. Under the SFGI, EPA works with stakeholders to develop and
implement community-based  approaches to  mitigate diffuse  sources of  pollution and
cumulative risk.

   EPA leads  special projects  and planning activities  in  the  South Florida  area,
including the Everglades and the Florida Keys coral reef ecosystem.  SFGI staff  are
involved in  activities  related to the Section 404  wetlands  protection program,  the
comprehensive Everglades Restoration Program  (CERP), the water quality  protection
program for the  Florida Keys National  Marine Sanctuary,  the Southeast  Florida  Coral
Reef Initiative as directed by the U.S. Coral Reef Task Force,  the Brownfields program,
and other waste  division programs.  EPA continues to implement the South Florida
Assessment Project, an ecosystem assessment of the Everglades.
 To Learn More:
 http://www.epa.gov/region4/water/southflorida/
Puget Sound

   EPA works closely with other federal, state, tribal, and local agencies through Puget
Sound action partnerships to help protect this ecosystem and associated wide-ranging
human  health  issues. The Puget  Sound  contains  the  Pacific  Northwest's largest
population and commerce center, including a major transboundary estuary and airshed,
a vital system of international ports and multi-modal transportation networks, and a
concentration of national  defense installations.  The Puget Sound  includes roughly 20
major rivers and 2,500 miles of sheltered inland waters that provide habitat to 26 kinds
of marine mammals, 200 species offish, and 100 species of sea birds. This ecosystem
has commercial salmon landings that average 19.2 million pounds a year, and includes
578,000 average annual sport fishing trips for salmon and steelhead.

   Protecting and restoring water quality in shellfish growing  areas is a high priority.
While  the  Puget  Sound currently  leads  U.S.   waterways  in shellfish production,
averaging over $100 million in  annual sales, 30,000 acres of shellfish beds have been
closed to harvest since 1980.   These  closures affect both  local economies  and also
cultural and subsistence  uses  of these traditional  resources.  Excess nutrients create
"hypoxic  zones" that  further impair shellfish and  finfish populations and require the
reduction of nutrient loadings into the Sound.
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   Recent monitoring assessments  indicate that marine species in the Puget Sound
have high levels of toxic contamination.  Almost 5,700 acres of submerged lands (about
9 square miles) are currently classified as contaminated with toxics.  Another 24,000
acres are classified as at least partially contaminated with toxics. In addition to these
legacy contamination  problems, additional pollutants  are released.  Approximately 1
million pounds of toxics are released into the water and 5 million pounds into the air
each  year,  with many pollutants finding their way into  Puget  Sound.  An  important
element of the strategy for protecting Puget Sound is to maintain the rate of progress in
addressing contaminated estuary bottom sediments, while at the same time developing
more  effective source control strategies to reduce the release of additional toxics into
the environment.

   Over half of the shallow water habitats in Puget Sound have  been lost, with higher
loss  rates in  key urban estuaries.   Intertidal  salt marsh habitat has declined by 75
percent since  the 1800s.  In  addition, development has modified one-third of  Puget
Sound's shoreline, and the population is expected to  increase by 1.4 million over the
next 20 years.  State and local governments are working to update the Puget Sound
comprehensive conservation  and management  plan  (CCMP) and to  conduct   both
growth management and species recovery planning.
 To Learn More:
 www.epa.gov/pugetsound
Columbia River Basin

      At 1,214 miles  in length, boasting a 260,000 square mile drainage basin, the
Columbia River spans  portions of Oregon, Washington, Idaho, Wyoming, Nevada, Utah,
Montana, and a substantial portion of British Columbia.   The Columbia River Basin  is
comprised of ecosystems  that are home to  a  diverse array of biologically significant
plants  and animals.   The  Basin  is also a  dynamic economic  engine driving many
industries vital to  the Pacific Northwest,  including sport  and commercial fisheries,
agriculture, transportation,  recreation, and,  with 55 hydropower dams, electrical power
generation.

   Columbia  River salmon and steelhead runs—once the largest on earth—are now a
fraction of their original size.  EPA studies and state monitoring programs have found
significant levels  of toxins in fish and the waters they inhabit,  including dichloro-
diphenyl-trichloroethane (DDT), PCBs, and dieldrin.76  EPA and its partners adopted a
three-dimensional approach to the problem  of toxins in the  Columbia River system,
emphasizing  remediation,  prevention, and  protection efforts.   Oregon,  Washington,
Idaho,   Columbia  Basin  tribal  governments,  the  Lower Columbia  River Estuary
Partnership, local governments, citizen groups, industry, and other federal  agencies are
actively engaged in  efforts to  remove contaminated sediments, bring  back native
anadromous fish, restore water quality,  and  preserve, protect, and restore  habitat, as
illustrated below:
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   •  Working locally with agriculture producers  to reduce pesticide use through the
      Pesticide Stewardship Partnership.
   •  Providing an anonymous opportunity to collect banned toxics and pesticides.
   •  Implementing  total  maximum  daily  loads  through  sediment  reductions and
      riparian restoration.
   •  Cleaning up the Portland Harbor Superfund site and PCB contamination in the
      Columbia River at Bradford Island.
   •  Restoring wetlands and habitats at Mirror Lake and Ridgefield through the Lower
      Columbia River Estuary Partnership with Targeted Watershed Program funding.

   EPA, state and tribal partners, and the Lower Columbia River Estuary Partnership
have launched a Columbia River toxics strategy to identify and clean up contaminated
sediments, restore critical wetlands, and reduce toxics in water, land, and fish.77 Under
this strategy,  EPA, states,  and tribes are systematically expanding key  actions in the
Columbia River Basin based on available resources, such as fish, water,  and sediment
monitoring;  pesticide  stewardship  partnerships;  targeted pesticide/toxic  collections;
precision agriculture;  and related activities. The National Estuary Program also plays a
key role in addressing toxics and restoration of critical wetlands in the Lower Columbia
River estuary.  Key actions and milestones to demonstrate a reduction of toxins in fish
and/or water by 2011  include:

   •  Identifying contaminants of concern.
   •  Identifying other databases that can serve as baseline data.
   •  Establishing new monitoring efforts to fill data gaps for understanding toxics in
      water, fish,  and sediment.
   •  Identifying and  implementing best management  actions and other measures to
      prevent or reduce the presence of the contaminants of concern in the Columbia
      River.
 To Learn More:
 www.epa.gov/RegionlO/
OBJECTIVE 4.4:   ENHANCE SCIENCE AND RESEARCH. Through 2011, provide a
sound scientific foundation for EPA's goal of protecting, sustaining, and restoring the
health of people, communities, and ecosystems by conducting leading edge research
and developing a better understanding and characterization of environmental outcomes
under Goal  A.  Through 2011,  identify and synthesize the  best available scientific
information, models,  methods,  and analyses to support Agency guidance and  policy
decisions  related  to the health  of  people,  communities, and  ecosystems.    Focus
research on pesticides and chemical toxicology; global change: and  comprehensive,
cross-cutting studies of human, community, and ecosystem  health.
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Sub-objective 4.4.1: Apply the Best Available Science. Through 2011, identify and
synthesize the best available scientific information, models, methods and analyses to
support Agency guidance  and policy  decisions  related to the  health  of  people,
communities, and ecosystems.

Sub-objective 4.4.2: Conduct Relevant Research.
Through  2011, conduct research that  contributes to the overall health  of  people,
communities, and ecosystems.  Focus research on pesticides and chemical toxicology;
global  change;  and comprehensive,  cross-cutting studies of human, community, and
ecosystem health.

Strategic Targets  Human Health Research:

• Risk  assessors and risk managers use ORD's methods, models and data to use
mechanistic  (mode  of action)  information to  reduce  uncertainty  in risk assessment
(metric  to  be  established   in  consultation with  external reviewers;—measurement
methodology still under development).

• Risk assessors  and  risk managers  use  ORD's  methods,  models  and data  to
characterize and provide adequate protection for susceptible subpopulations; and to
characterize aggregate and cumulative risk in order to manage risk of humans exposed
to multiple environmental  stressors  (metric  to be established  in  consultation  with
external reviewers;  measurement methodology  still under development).

• Risk  assessors and risk managers use ORD's methods and models to evaluate the
effectiveness of public health outcomes (metric to be  established in consultation with
external reviewers;  measurement methodology  still under development).

Strategic Targets  Ecological Research^-

• States and tribes use a common monitoring  design and appropriate indicators to
determine the status and trends  of ecological resources and  the  effectiveness  of
national programs  and  policies.—Success is defined by an external  expert review
process to measure the utility of the data, tools, and technologies for key Agency
decisions—(metric—te—be—established—ifl—consultation—with—external—reviewers;
measurement methodology still  under development).

• States, tribes and  relevant EPA offices have improved their ability to determine causes
of ecological degradation,  and to  forecast the ecological impacts of various  actions
through the application of recently developed (within the previous 5 years) ORB causal
diagnostic tools and methods, resulting in positive environmental outcomes.  Success is
defined by an  external expert review process to measure the  utility of the data, tools,
and technologies for key Agency decisions (metric to be established in consultation with
external reviewers;  measurement methodology  still under development).
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• States, tribes and  relevant EPA offices have improved  their  ability to  protect and
restore ecological condition and services through the application  of recently developed
(within the previous 5  years)  ORB  environmental  restoration tools and  methods,
resulting in positive environmental outcomes. Success is defined by an external expert
review process to measure the utility of the data, tools, and technologies for key Agency
decisions—(metric—te—be—established—ifl—consultation—with—external—reviewers;
measurement methodology still under development).

Strategic Targets - Global Climate Change Research:

• State,  regional,  and national decision makers  and decision makers  in EPA regional
and program  offices  will  use scientific information  about the place based impacts of
global change to protect the people, the economy,  and  the environment of the United
States by adapting to global change. Success is defined by an external expert review
process to measure  the utility  of the data, tools,  and technologies  for  key Agency
decisions—(metric—te—be—established—ifl—consultation—with—external—reviewers;
measurement methodology still under development).

• Air quality managers and decision makers in EPA regional and program offices will
use scientific information and models from EPA's research and assessment program to
evaluate and  implement adaptation policies that protect  air  quality from the impacts of
global change. Success is defined by an external expert  review process to measure the
utility  of the  data, tools, and technologies for  key Agency decisions (metric to be
established in consultation with external  reviewers;  measurement methodology still
under development).

• ORB will develop scientific information  and decision tools that the  Agency uses to
inform  decisions  for the protection of  human health, water  quality,  and  aquatic
ecosystems by adapting to global change.—Success  is  defined  by an external expert
review process to measure the utility of the data, tools, and technologies for key Agency
decisions—(metric—te—be—established—ifl—consultation—with—external—reviewers;
measurement methodology still under development).

Strategic Targets - Endocrine Disruptors Research:

-—Reduction—ifl—uncertainty—regarding—the—effects,—exposure,—assessment,—afl4
management  of endocrine disrupters so that EPA has a sound scientific foundation for
environmental decision-making.—Success  is defined by  an  external expert review
process to measure  the utility  of the data, tools,  and technologies  for  key Agency
decisions—(metric—to—be—established—ifl—consultation—with—external—reviewers;
measurement methodology still under development).

• Determination of the extent of the impact of endocrine  disrupters on humans, wildlife,
and the  environment  to better inform the federal and scientific communities.  Success is
defined  by  an external expert review process to measure the utility of the data, tools,
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and technologies for key Agency decisions (metric to be established in consultation with
external reviewers; measurement methodology still under development).

• OPPTS uses endocrine disrupter screening and testing assays developed by ORB to
create validated methods that evaluate the potential for chemicals to cause endocrine-
mediated  effects  in order to reduce  or  prevent risks  to  humans and wildlife from
exposure to endocrine disrupting chemicals (EDCs).  Success is defined by an external
expert review process to measure the utility of the data, tools, and technologies for key
Agency decisions  (metric  to  be established in  consultation with external  reviewers;
measurement methodology still under development).

Strategic Targets   Human  Health Risk Assessment Research:

-—Integrated—Risk—Information—System—(IRIS)—aed—other  priority health—hazard
assessments:—Agency, state and local risk  assessors  use the state-of-the-science
health hazard assessment  information provided on priority substances in their decisions
and  actions to protect human health  from risks posed  by environmental  pollutants.
Success is defined by an  external expert review process to measure the utility of the
data,  tools, and  technologies for key  Agency decisions (metric to be established in
consultation—with—external—reviewers;—measurement—methodology—stiU—under
development).

• State-of-the-science risk assessment models, methods, and guidance: EPA programs,
states and other  risk assessors use  the risk assessment  models,  methods,   and
guidance  provided to enhance, through the incorporation  of contemporary scientific
advances,  the quality and objectivity  of their assessments  and decision making on
environmental health risks.  Success is defined by an external expert review process to
measure the utility of the data, tools,  and technologies for key Agency decisions (metric
to  be established in consultation with  external reviewers; measurement methodology
still under  development).

• Air Quality Criteria Documents: As mandated  in the  Clean Air Act, the ambient air
criteria pollutants are reviewed and AQCDs revised to reflect the best available scientific
information on identifiable  effects on public health and the environment from exposure
to  the pollutant, and this information  is used by the EPA Office of Air and Radiation in
their review and promulgation of the  National Ambient Air Quality Standards  (NAAQSs)
to  protect  public  health with an adequate  margin of safety.—Success is defined by an
external expert review process to measure the utility of the data, tools, and technologies
for key Agency  decisions (metric  to  be established  in  consultation  with  external
reviewers; measurement methodology still under development).

 Strategic Targets - Computational Toxicology Research:

• Risk assessors will use improved methods and tools to better understand and describe
the linkages of the source to outcome  paradigm.—Success is defined by an external
expert review process to measure the utility of the data, tools, and technologies for key
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Agency decisions  (metric to  be established in consultation with  external reviewers;
measurement methodology still under development).

• Regulators  and risk assessors will use advanced  hazard characterization tools to
prioritize and  screen chemicals for  toxicological evaluation.—Success is defined by an
external expert review process to measure the utility of the data, tools, and technologies
for  key Agency decisions (metric to  be established  in  consultation with  external
reviewers; measurement methodology still under development).

• Assessors and regulators will use new and improved methods and  models based on
the latest  science  for enhanced  dose-response  assessment  and quantitative risk
assessment.  Success is  defined by an external expert review process  to measure the
utility  of the  data, tools,  and technologies for key Agency decisions (metric to be
established in consultation with external  reviewers;  measurement  methodology still
under development).

Strategic Targets - Mercury Research:

• ORB will advance  the  research to reduce and prevent release of mercury into the
environment.  Success is defined by an external expert review process  to measure the
utility  of the  data, tools,  and technologies for key Agency decisions (metric to be
established in consultation with external  reviewers;  measurement  methodology still
under development).

• ORB will conduct  research to understand the transport and  fate of mercury from
release to  the receptor  and  its effects  on the receptor.—Success  is defined  by an
external expert review process to measure the utility of the data, tools, and technologies
for  key Agency decisions (metric to  be established  in  consultation with  external
reviewers; measurement methodology still under development).

Strategic Targets   Homeland Security Research:

• ORB will  provide tools  including  new  or refined  advisory  levels  for various
contaminants of concern,  improved  risk assessment methods and communication tools,
and support  to emergency  and follow up responders,  enabling rapid evaluation of
chemical, biological,  and  radiological risks associated with a terrorist threat or attack.
Success is defined by an external  expert review  process to measure the utility of the
data,  tools, and technologies for key  Agency  decisions (metric to be  established in
consultation—with—external—reviewers;—measurement—methodology—sttU—under
development).

• ORB will develop data,  methods, and technologies that the Agency uses to  inform
decisions by water utilities and their support organizations, public health officials, and
the emergency and  follow-up response  community to  identify  vulnerabilities,  detect
contamination, warn  the  public, and respond effectively in  the event  of a biological,
chemical, or radiological attack on any of the nation's water infrastructure.  Success is
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defined by an external expert review process to measure the utility of the data, tools,
and technologies for key Agency decisions (metric to be established in consultation with
external reviewers; measurement methodology still under development).

• ORB will provide tools, protocols and methods to the emergency and follow-up
response community,  elected  and appointed  officials,  and  the general  public for
locating,  collecting, and analyzing environmental samples; protecting decontamination
personnel,  the general public,  and the  environment;  and  the  decontamination and
disposal  of materials in the event of a biological, chemical, or radiological attack inside
and outside of buildings.—Success is defined by an external expert review process to
measure the utility of the data, tools, and technologies for key Agency decisions (metric
to be established in consultation with external  reviewers; measurement methodology
still under development).

Strategic Targets - Safe Pesticides and Products:

• OPPTS uses the results of ORD's research as the scientific foundation for prioritization
of testing requirements and enhanced interpretation of exposure, hazard identification
and  dose-response  information.—Success is defined by an external expert review
process  to  measure the  utility  of  the data, tools, and technologies for  key  Agency
decisions—(metric—to—be—established—in—consultation—with—external—reviewers;
measurement methodology still under development).

• OPPTS uses the results of ORD's research as the scientific foundation for probabilistic
risk assessments to protect natural  populations of birds, fish and other wildlife. Success
is defined by an external expert review process to measure the utility of the data, tools,
and technologies for key Agency decisions (metric to be established in consultation with
external reviewers; measurement methodology still under development).

• OPPTS uses the results of ORD's research as the scientific foundation for preventing
or reducing risks to human environments within communities, homes, workplaces, and
evaluating novel or newly discovered environmental hazards.—Success  is defined by an
external expert review process to measure the utility of the data, tools, and technologies
for key  Agency  decisions  (metric to  be  established  in consultation with  external
reviewers; measurement methodology still under development).

NACEPT SP Comments
We are disappointed that EPA deleted the list of strategic targets under this Objective.  While we
recognize that establishing specific  targets and  performance metrics for scientific research is more
difficult than for regulatory activities. NACEPT believes that the exercise is extremely useful both for
identifying the specific activities that EPA will perform  and for allocating precious resources to those
activities that will produce the greatest  return on investment.  We recommend that EPA  consider
reinstating the strategic targets under this Objective and move forward with their full development in
consultation with the larger scientific community.

Means and Strategies For Achieving Objective 4.4
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NACEPT SP Comments
This Means and Strategies  Section describes a variety  of EPA  research activities with regard to
communities and ecosystems. However, these activities are no longer linked to strategic targets under
Objective  4.4. since the strategic targets have been deleted.  Therefore, it is no longer possible to
comment on the efficacy of these various activities with regard to their associated targets in the Strategic
Plan.

   Since research must be ahead of  the curve, significant lead  times are typically
necessary  to  conduct  the  research  required  to  support  program implementation.
Consequently, research is  required to  be forward-looking.  Areas in which  the EPA
Office of  Research and Development (ORD) will devote particular attention in the years
ahead  include development of computational toxicology, bioinformatics and related
technology,  environmental  and human health monitoring and indicator development
(including the incorporation of an emerging  Global Earth Observation  System  of
Systems  (GEOSS)), and the improved utility of research results through incorporation of
uncertainty analysis.

   Research arising out of the human health research program led to the establishment
of the  computational toxicology program  in 2003, exemplifying  the value of applying
cutting-edge scientific innovations in order to protect the  environment better and more
efficiently. This research harnesses computational biology to assess the risk chemicals
pose to  human  health  and the environment  and has  enabled EPA  to screen  the
hundreds of thousands of commercially available chemicals for toxicity.  Another new
dimension  is the  nascent nanotechnology  research  program  launched in 2005;  it
focuses on  decision support and the safe use  of nanomaterials in commercial and
environmental applications.

      Progress toward  research goals is assessed through a suite of metrics that is
tailored to measuring the  impacts  of the respective research programs.  Among  the
measurable factors are:  independent expert review panel ratings on the extent to which
clients  utilize EPA research products; composite scores on a client survey designed to
gather  data  on product  utility and  perceptions of use; and  the  results  of bibliometric
and/or  client document  analyses  demonstrating the actual  use of EPA  research
products.   These factors  are applied  to  measure  success in providing the  results
identified in the research programs that follow.

HUMAN HEALTH RESEARCH

   The Human Health Research Plan (HHRP) provides risk assessors/managers with a
greater capacity  to  reduce reliance on  default assumptions in  human health risk
assessment.  The HHRP assesses uncertainties  in risk assessment articulated across
several legislative acts  (i.e., FQPA, SDWA, CAA) and  addresses research priorities
articulated by  multiple Program Offices (i.e.,  OPPTS, OPP, OW,  OAR, OCHP), risk
assessors  (i.e.,  IRIS,  NAAQS)  and  regional offices.    This  program  will produce
measurable benefits in the form of:

   •  reduced  uncertainty in  risk assessment  using ORD's  mechanistic  (mode  of


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      action) information;
   •  reduced  uncertainty  in  risk  assessment  via  the  use of  ORD's products
      characterizing and  protecting  susceptible subpopulations,  and characterizing
      aggregate and cumulative risk from multiple environmental stressors; and
   •  tools to evaluate the effectiveness of public health outcomes.

   Research to develop approaches for the prioritization and screening of chemicals
utilizes  emerging genomic and  proteomic methods to  study potential  sites where
toxicants could affect biological systems. This information is used with other methods to
determine how  tissue levels  in  those biological  systems cause  adverse effects.
Emerging  technologies  and models  are  then  used  to  identify  potential  biological
indicators  that can  be used to screen or  prioritize chemicals based on  the study of
several classes of environmental agents.

   Methods  and models developed over a period of 3-4 years to study single chemicals
and  pathways of exposure will then  be used during  the next 2-3  years to identify
bioindicators of exposure to evaluate  multiple chemical/multiple exposures. This work
addresses concerns  related to  environmental justice and accountability related to
assessment  of regulatory decision-making.

   Methods,  models,  and data from the work described above are applied during the
next 2-3 years  to the problem of understanding the basis for differential response to
chemicals as a function of life stage.  A  portion of this  work focuses on assessing
differential exposure and response in children, while another portion  focuses on  older
populations.  Additional work emphasizes the potential long-term health effects following
developmental  exposure  to  environmental  agents.     Fundamental  research  on
environmental influences  on neurodevelopment,  asthma,  and disease  is obtained
through extramural sources jointly funded by EPA and NIEHS.  Other lines of research
will contribute to developing principles to evaluate the effectiveness of risk management
decisions at  the local and regional  level. This work is accomplished  in collaboration with
CDC and other federal agencies, as well as with the regions.

ECOLOGICAL RESEARCH

   The ecosystems research program will produce measurable benefits in the form of:

    •   more  states and tribes  using  a common monitoring design and appropriate
       indicators to determine  the status and trends of ecological resources and the
       effectiveness of national programs and policies;
    •   all  states, tribes and relevant  EPA  offices having improved ability to diagnose
       causes of, and forecast, the ecological impacts of various actions using EPA
       research tools and  methods,  resulting  in measurable  positive environmental
       outcomes; and
    •   states, tribes and relevant EPA offices have improved their ability to protect and
       restore  ecological  condition  and  services  using  EPA research  tools  and
       methods, resulting in measurable positive environmental outcomes.
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  Analytical tools derived from ecological structure and function relationships will help
to evaluate land development and  urban sprawl.    New  research on  measures,
especially measures of ecosystem services at  different scales, will  improve  EPA's
understanding of the impact of stressors on natural systems, and how to most efficiently
control and reduce harmful affects.  Improved understanding of services provided by
ecosystems and ecological health will illuminate conditions affecting place-based health.
Research in this area requires greater coordination between environmental and human
health  research and  public health, as well as a stronger role for  local partnerships.
Better  understanding of ecological condition indicators and ecosystem  services will
improve  EPA's ability to  provide assessment  tools to place-based decision makers.
This research program assesses uncertainties in  ecological risk assessment articulated
in several legislative acts  (i.e., CWA,  CAA, TSCA, FIFRA,  CERCLA, RCRA) and  is
relevant to the research priorities of multiple Program Offices (i.e., OW, OAR, OPPTS,
OPP, OEI) and regional offices.

GLOBAL CLIMATE CHANGE RESEARCH

   The Global Change Research Program has its primary emphasis on assessing the
potential  consequences of global change  on air quality, water quality, ecosystems, and
human health in  the United States. This  program will  produce measurable benefits  in
the form of:
   •  increased  use of scientific information about the place-based impacts of global
      change;
   •  increased  use of scientific information and models to evaluate and implement
      adaptation policies that protect air quality from the impacts of global change; and
   •  greater ability for EPA programs that protect human health,  water quality,  and
      aquatic ecosystems to accommodate the  need  for adaptation caused by global
      change.

   The program  employs a  place-based framework  to  provide  the  means for
integration.  The Program uses study results to investigate adaptation options to improve
society's  ability to effectively respond to the risks  and opportunities presented by global
change.

   This work is consistent with and closely coordinated with the 2003 Strategic Plan  of
the  U.S. Climate Change Science Program (CCSP), addressing two of its five principal
goals,  namely to: understand the  sensitivity and adaptability of different  natural  and
managed ecosystems  and human systems to  climate and  related global  changes
(CCSP Goal 4) and; explore  the uses  and identify the limits  of evolving knowledge  to
manage risks and opportunities related to  climate  variability and change (CCSP Goal 5).

   EPA's Global Program, along with the entire  CCSP, is placing markedly increased
emphasis on  the goal of improving decision-making and  adaptive management.
"Decision support" reflects the broad  purpose of making scientific knowledge more
readily available and more useful to decision makers, with the ultimate goal of improving
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environmental and societal outcomes.  To accomplish this, the Program is developing a
dynamic "decision inventory" to  identify different classes of climate-sensitive decisions
in  different regions of the country, and to evaluate the returns from providing  better
scientific information to inform those decisions.

ENDOCRINE DISRUPTORS SCIENCE AND RESEARCH

      Over the last several  years, concern has grown about exposure to endocrine-
disrupting, or hormonally active,  chemicals.   Evidence suggests  that exposure to
chemicals that mimic hormones (endocrine disrupters, or EDCs)  may cause  adverse
health effects in wildlife and may affect human health as well. OPPTS, other Program
Offices,  and the Regions apply research products to  help reduce  uncertainty  in our
knowledge of endocrine  disrupters,  determine chemicals'  potential  for  endocrine
disruption, and identify  the  nature  of adverse effects.   This  program will  produce
measurable benefits in the form of:
   •  reduced  uncertainty  regarding  the  effects,  exposure,   assessment,   and
      management of endocrine disrupters;
   •  determination of the extent of the impact of endocrine disrupters  on humans,
      wildlife, and the environment; and
   •  greater use of endocrine disrupter screening and testing assays developed from
      Agency research.

   The Agency needs valid tests to assess new chemicals' and pesticides' potential for
endocrine disruption.  The validation of screens and tests necessary before large-scale
reviews  can  take  place will be completed;  and  the Endocrine  Disrupter Methods
Validation Advisory Committee (EDMVAC) will continue to provide EPA with scientific
and technical advice.  We are working to minimize the use of animals for these tests.

   Research  to understand the effects of endocrine disrupters has shifted from animal
exposure testing to computational  toxicological research.  This is a relatively new field
and the extent to which  it will  yield fruitful results is not fully known.  Consequently,
endocrine disrupter research will reflect the degree of success achieved in the field of
computational toxicology. Progress  in the ability to sequence the  human genome has
led to a rapid development  of  laboratory methods to  assess gene expression on  a
genome-wide basis,  and contributing to the  tools available for  endocrine disrupter
research.  Continued expansion of this field may also facilitate research into the effects
of  endocrine disrupters.

HUMAN HEALTH RISK ASSESSMENT RESEARCH

   The  Human  Health  Risk Assessment (RA) program serves the programs  and
regions throughout EPA by incorporating and integrating the use of  scientific information
as a foundation for regulatory decision-making. This program will produce measurable
benefits in the form of:
   •  state-of-the-science health hazard assessment information  provided  on priority
      substances in Agency, state and local risk assessors' decisions;
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   •  the incorporation of contemporary scientific advances into their assessments,
      enhancing their quality and objectivity; and
   •  AQCDs for ambient air pollutants (as mandated  in the Clean Air Act) are revised
      to reflect the best available scientific information on identifiable effects on public
      health and the environment from exposure to the pollutant, and this information is
      incorporated in the review  and  promulgation of the  National Ambient Air Quality
      Standards (NAAQSs).
   The  Integrated Risk Information System  (IRIS) and Air  Quality Criteria Document
(AQCD) assessments,  and other assessments,  are directly responsive  to  program
needs and are primary considerations in Agency actions to protect human health and
the environment.  Recognizing their importance, the strategic objective of the RA
program  is to increase the  output of these products while enhancing their quality
through  incorporating the latest advances in risk assessment science.  These  activities
are coordinated  across EPA research and  program offices through formal means
including the IRIS consensus review and Risk Assessment Forum processes.

COMPUTATIONAL TOXICOLOGY RESEARCH

   Computational toxicology  is the integration of modern computing  and information
technologies with molecular biology and chemistry to improve the prioritization of data
requirements and risk assessment of chemicals. This program will produce measurable
benefits in the form of:
      •   increased use of improved methods and tools to link sources to outcomes;
      •   increased  use of advanced  hazard characterization tools to prioritize  and
         screen chemicals for toxicological evaluation; and
      •   increased use of the latest science for enhanced dose-response  assessment
         and quantitative risk assessment.

   The  methods,  models,  and data generated by  the Agency's National Center for
Computational Toxicology (NCCT) will respond to the need for better, faster,  cheaper
approaches  to testing  chemicals and  emerging  technologies  such  as  bio-  and
nanotechnology.   Associated  research  will  address the  need to assess  cumulative
impacts  on humans  from  multiple exposures,  as well as  facilitating  approaches to
identify  and  characterize diseases in people resulting from changing environmental
factors and other factors, such as other disease states and pharmacological exposure.
The research includes both intramural and extramural resources.  . With  these tools,
scientists can  produce a more-detailed understanding of the hazards and risks of a
much larger number of chemicals.  ToxCast, a forecasting tool, will provide a number of
EPA program  offices with the ability to prioritize,  screen,  and assess the  potential
hazards of chemicals  in far more rapid and time relevant manner than current methods.

   Two  important research products moving  into more common use  that enable this
scanning to be done efficiently and at greatly reduced expense are customized DNA
arrays and  tools for  modeling  and virtual prototyping.   EPA has taken  a leadership
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position in  this new field of environmental protection, and will apply new  capabilities
from this research to other research applications in the coming years.

MERCURY RESEARCH

   The Agency's Mercury Research Program will produce measurable benefits in the
form of:
   •  reduced release of mercury into the environment; and
   •  better  understanding of   the  transport and  fate of mercury from  release to
      adverse effects.

   The program is focusing on several key uncertainties, specifically: (1) how much
methyl  mercury in  fish  consumed by  the  U.S. population  is  contributed by  U.S.
emissions relative to other sources of mercury; (2) how much  mercury emissions  from
coal-fired  utility  boilers  and  other combustion  systems  can  be  reduced;  (3)  the
magnitude  of contributions of mercury releases from non-combustion sources; (4) the
risks associated with methyl mercury exposure to wildlife species and other significant
ecological receptors; (5) critical  changes in human health associated with exposure to
environmental sources of mercury in the most susceptible human sub-population; and
(6) the most effective means for informing susceptible populations of the health risks.

   In order to evaluate the effectiveness of the new Clean Air Mercury Rule (CAMR),
research work focuses on efforts to increase the accuracy, precision, and effectiveness
of continuous emission monitors. This work is coordinated across several programs and
globally, e.g., with the UNEP Fate and Transport Partnership.

   Another high priority for the Mercury Program  will be to provide information to EPA,
states, and utilities on alternative control technologies.  Research is also  required to
focus on identifying potential mercury deposition "hot spots" that may already exist, and
may occur  in the future with market trading of mercury emissions.

HOMELAND SECURITY RESEARCH

   Threat  and  consequence  assessment  (TCA)  research  focuses  on  the  rapid
evaluation of chemical, biological, and radiological risks associated with a terrorist threat
or attack. This program will produce measurable benefits in the form of:
      •  faster  evaluations of chemical, biological,  and radiological risks associated
         with a terrorist threat or attack;
      •  better-protected national water infrastructure, by way of research  products to
         identify vulnerabilities,  detect contamination, warn the public,  and respond
         effectively in the event of a biological, chemical, or radiological attack; and
      •  better  emergency and follow-up  response, by way of research products for
         locating,  collecting,   and  analyzing  environmental   samples;   protecting
         decontamination personnel, the general public, and the environment; and the
         decontamination and disposal of materials  inside and outside of contaminated
         buildings.
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      Researchers   are   developing   and  refining  advisory   levels  for   various
contaminants of concern, improving risk assessment methods and communication tools,
and providing support to  emergency and follow-up responders.  Research results are
provided (in cooperation with the Office of Solid Waste and Emergency Response and
other federal agencies) to the emergency and remedial response community,  elected
and appointed officials, and the general public to help them be more informed should an
intentional attack occur in the United States.

   Water infrastructure protection (WIP) research focuses on  the protection and safety
of the  nation's water supply,  treatment  operations, and drinking water distribution
systems, and to  a lesser  degree, on wastewater collection, treatment operations, and
treated water discharge.   Research results are  provided (in cooperation with EPA's
Office of Water) to water utilities and their support organizations,  public health officials,
and the  emergency and  follow-up response community.   Work  also  involves the
laboratory and field testing and evaluation of technologies to detect, contain, treat, and
recover from intentional attacks on drinking water and wastewater facilities.

   Decontamination and consequence management (DCM) research focuses on  rapid
and cost-effective remediation  and restoration of buildings and  broad outdoor areas.
Research results are provided (in  cooperation with  EPA's Office of Solid Waste and
Emergency  Response and other federal  agencies) to the emergency and  follow-up
response community, elected and appointed officials, and the general public. Work also
involves  the  laboratory  and  field  testing  and  evaluation  of  technologies  to
decontaminate and dispose of materials and areas affected by intentional attacks.

SAFE PESTICIDES AND PRODUCTS RESEARCH

   The   Safe Pesticides/Safe  Products  (SP2)  Research  Program  will   produce
measurable benefits in the form of:
  •  new predictive tools  for prioritization and enhanced  interpretation  of exposure,
    hazard identification and dose-response information;
  •  the  scientific foundation for  probabilistic risk  assessment methods to  protect
    natural populations of birds, fish and other wildlife;
  •  the scientific foundation for guidance to reduce risks of human environments within
    communities, homes, workplaces;  and
  •  strategic scientific information  and advice concerning novel or newly discovered
    hazards.

   Among the research underway or planned is the development and application of the
latest molecular and computational  approaches to produce the next series of chemical
prioritization  tools and toxicity  testing  approaches.   Research  in this subject  is
increasingly linked to advances in computational  toxicological  research.  This is a
relatively new field and the extent to which it will yield fruitful results is not fully known.
Progress in the ability to sequence  the human genome has led to a rapid  development
of laboratory methods to assess  gene  expression on a  genome-wide basis,  and
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contributing to the tools available for SP2 research.

   The  scientific foundation  for conducting probabilistic risk assessments for wildlife
populations  is  advanced  by developing  methods for extrapolation  among wildlife
species and exposure  scenarios  of  concern (e.g.,  endangered  species focus).
Research  will also work to  improve the evaluation  of potential ecological effects of
biotechnology products,  the development of  risk  management approaches;  and
development of methods to  assess for the  potential  allergenicity  of  genetically
engineered plants.
HUMAN CAPITAL

      The foundation for achieving  the goal of healthy communities and ecosystems
begins  with  an EPA workforce  that  has a well-balanced  combination  of skills,
experience,  and expertise.  The  skilled occupations needed to carry  out  the work
inherent in  this goal range from toxicologists with expertise in chemical testing,
registration and  monitoring,  biologists to evaluate the exposure impact of  chemical
releases on wetlands, specialized chemical  engineers to reduce hazardous risk at
chemical facilities, and modelers  to evaluate risks of chemicals to  populations and
fragile  ecosystems.   EPA  also  identified a gap  in  the number  of economists,
epidemiologists,  human exposure modelers, and hydrologists needed to fill mission-
critical scientist/researcher positions.

PERFORMANCE MEASUREMENT

   Many  strategic  targets  to protect,  sustain,  or  restore the  health  of people,
communities, and ecosystems are directly measured on  an  annual basis as annual
performance  goals and measures in the Agency's Annual Plan and  Budget.  Other
strategic targets rely on measures or  indicators  of changes in the environment or human
health, such as habitat and water quality conditions, and blood lead levels.  Collection
and  analyses of these data are often expensive  and time-consuming.  In addition,
changes in  environmental and  health  conditions that  result from  EPA programs
frequently take  several years to observe  and measure.   It  is therefore  not always
practicable or useful to  collect these data every year.   Consequently, while these
environmental and health outcome measures and data are excellent indicators of EPA's
long-term performance, the Agency also uses other shorter-term measures and data to
manage programs.

Influences of Environmental Indicators and PART Measures on the Strategic Plan

   EPA has incorporated one new strategic target that embodies metrics presented as
environmental indicators in the forthcoming Report  on the Environment,78  involving
human  body-burden  of pesticides.  EPA has also incorporated all of the  long-term,
outcome-oriented measures  currently  used in twelve PART  evaluations of various
pesticides, toxics, brownfields, geographic and research programs as strategic targets
in this Strategic Plan.
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Future Improvements to Performance Measurement

   As the  Agency  puts  the  recording,  updating,  reviewing,  and improvement of
scientifically-sound environmental indicators  on a routine footing through the Report on
the Environment, we expect increasing opportunities to incorporate this information into
future strategic plans.  This will enable the Agency to increasingly articulate all of our
significant long-term objectives in terms of measurable improvements in the condition of
land.

   When considering revisions and improvements for developing this Strategic Plan, we
also  conducted  a preliminary assessment of longer-term opportunities  to improve our
articulation of strategic,  outcome-oriented commitments for future Plans. Collaborative
research plans  for the pesticides  and  toxics programs  focus  on program-support
research to produce new and better representation of the dimensions and magnitudes
of risks  to human health and ecosystems from toxic substances  and pesticides.   The
Agency  also identified development of a Chesapeake Bay Water Quality Index for more
comprehensive representation of the Bay's aquatic health as a priority.

CLOSING THE FEEDBACK LOOP: RESULTS OF PERFORMANCE ASSESSMENTS
AND PROGRAM EVALUATIONS

NACEPT SP Comments
Has EPA  looked into the Sustainable Design Assessment Team criteria from the AIA?

   The programs that support the Agency's healthy communities and ecosystems goals
are assessed using three key approaches:

   •   Internal EPA program evaluations,  including those by the EPA Inspector General
      and by the EPA Board of Scientific Counselors.
   •   Office  of Management and  Budget  Program Assessment and  Rating  Tool
      (PART) reviews.
   •   External assessments by organizations such  as the Government Accountability
      Office and the National Academy of Sciences.

Internal  Program Evaluations

   Internal program  evaluations are conducted by both  individual program offices, by
the EPA Inspector General,  and by the EPA Board of Scientific Counselors (BOSC).
The  BOSC  Human Health Subcommittee   evaluated  the Agency's  Human  Health
Research Program's four long-term goals  related to the use of information in  risk
assessment,  aggregate and cumulative  risk, susceptible  subpopulations, and public
health outcomes.   As a  result of BOSC recommendations,  the program increased
communication  and  collaboration  between  research areas,  developed specific  peer
review goals,  and articulated a decision-making process.  The BOSC's recommendation
informed the  Human Health Research program's long term goals and the means  and
strategies to them.
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   Program  offices  also  develop  program-specific  evaluations.   For example, in  a
cooperative effort between regional and headquarters office, the Brownfields Program  is
reviewing the operations of the ten regional offices  and the headquarters office. The
review  will  compile  feedback  on  program  objectives  and  operations,  assure
accountability of internal and external stakeholders, enhancing the overall quality of the
program, evaluate decision making processes, and identify exchanging best  practices.
The review will be completed in FY 2008.

   The EPA Inspector General has conducted extensive program reviews of programs
supporting the healthy communities and ecosystems goal  over the past  several years.
Examples of this work include:

   •  Assessment of the integration of environmental justice  into EPA operations,
      including recommendations for reaffirming the commitment to  environmental
      justice and strengthening planning efforts.
   •  Review   of   EPA  implementation   of  the  Food   Safety  Act,  including
      recommendations for changes to consideration of subpopulations, responding to
      petitions, and increasing consistency of public  participation.
   •  Assessments of the implementation  of the Brownfields  program,  including
      resource management  and improvements  to grant  application  and selection
      processes.

Program Assessment Rating Tool (PART)

   EPA works closely with the Office of Management to assess the effectiveness of key
environmental  programs  using  the  Program Assessment Rating  Tool  (PART).
Programs are  rated  as "effective,"  moderately effective," "adequate," and "ineffective".
Many of the programs supporting Goal 4 have been assessed under the PART process.
Summaries  of  all  completed  PART  studies   are  available   in  the  Internet  at
www.whitehouse.gov/omb/expectmore/ and examples  of several  of the  programs
evaluated through PART process, and the program  rating, are provided below:

   •  New Chemicals Program - moderately effective.
   •  Existing Chemicals Program - adequate.
   •  Pesticide Registration - adequate.
   •  Brownfields Revitilization - adequate.
   •  U.S. Mexico Border Water Infrastructure - adequate.
   •  The Ecological  Research Program   -  Ineffective  (The program  is conducting
      follow-up actions to address this issue).
   •  Human Health Research - adequate.
   •  Endocrine Disrupting Chemicals Research - adequate.

External Evaluations

   EPA participates with outside organizations, such as the Government Accountability
Office (GAO) and the National Academy of Sciences, in the evaluation of program
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effectiveness   and  development   of   recommendations  for  improved  program
management and policies. The GAO has conducted numerous evaluations of programs
supporting the healthy communities and ecosystems goal; a complete list is available at
http://www. gao.gov/docsearch/repandtest. htm I.  Some examples include:

   •  Chemical Regulation: Options Exist to Improve EPA's Ability to Assess Health
      Risks and Manage its Chemical Review Process (June 2005).
   •  Brownfield Redevelopment: Stakeholders Cite Additional Measures that Could
      Complement EPA's Efforts to Clean up and Redevelop Properties (April, 2005).
   •  Wetlands:  Corps  of Engineers  Needs to Better Supports its Decisions for Not
      Asserting Jurisdiction (September 2005).
   •  Great Lakes: Organizational  Leadership and Restoration Goals  Need to be
      Better Defined for Monitoring Restoration  Progress (September 2004).
   •  Chesapeake Bay:  Improved Strategies Are Needed top Better  Assess, Report,
      and Manage Restoration Progress (October 2005).
   •  Columbia River Basin: A Multi-layered Collections of Directives and Plans Guides
      Federal fish and Wildlife Activities (June 2004).

   The National Academy of Sciences develops reports  and recommendations  on a
range of environmental issues, including issues related to the Healthy Communities and
Ecosystems Goal.  For example, in 2006, NAS released a report titled Rebuilding the
Unity of Health and the Environment in Rural America.  In 2004, NAS released a report
titled "Valuing  Ecosystem Services: Toward  Better Environmental  Decision-making."
Additionally, the Agency's Risk Assessment Forum has also convened  external reviews
to evaluate programs when appropriate.  The Endocrine Disrupting Chemical Research
program was evaluated in this manner.

   The ORD Board of Scientific Counselors (BOSC) has initiated a cycle of review for
the  ORD  research programs.  An average of three programs will be evaluated annually
for  relevance,  utility, and value to EPA.   The  BOSC has  reviewed  and made
recommendations  for improvements to three of the  Goal 4 research plans between
2005 and 2006.

   •  Human Health
   •  Ecosystems
   •  Global Climate Change
   •  Endocrine Disrupting Chemicals

EXTERNAL FACTORS AND EMERGING ISSUES

   Promoting safe and healthy communities requires up-to-date knowledge of the  rapid
technology change in today's economy.  The growing importance of some technologies,
in particular, nano- and biotechnologies, will require foresight to craft skillful and flexible
responses.  In addition,  rapid growth  and  technological change has  the  potential  to
impact human health and the environment.  In the energy sector, EPA is committed to
additional  consideration of how best to  address both potential positive and negative
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implications of these rapid technology changes.

   Nanoscale materials represent an emerging challenge to the EPA's new chemicals
program.  These materials are chemical substances containing structures on the scale
of approximately 1  to 100 nanometers, or 1  to 100 billionths of a meter.  Because of their
small size,  they may have different molecular properties than chemical substances on a
larger scale and may present unique issues with respect to health and environmental
risks.  Some nanotechnology products  already are commercialized; the first public
inventory      of       these      products       can      be       viewed      at
http://www.nanotechproiect.org/inventories.       EPA   is  currently   reviewing  the
premanufacture  notices for several  new chemical  substances  in the nanoscale  size
range.

   EPA's nascent nanotechnology research program  is focusing  on decision support
and   guiding  the  safe  use  of  nanomaterials in commercial  and environmental
applications. Between 2007 and 2011, EPA research will address four broad areas:

   •  Development  of risk assessment approaches  to evaluate nanomaterials.
   •  Assessment of risks to human health and  ecosystems, particularly nanomaterials
      used in intentionally dispersive applications.
   •  Life  cycle assessments of nanomaterial  impacts throughout product  lifecycles
      and  life cycle approaches to inform the use of nanotechnology in ways  that
      prevent pollution and allow more sustainable use of resources.
   •  Identification and development of research technologies that use nanomaterials
      to detect,  monitor, and remediate environmental releases of traditional  pollutants
      as well as nanoparticles.

NACEPT SP Comments
While EPA certainly should address the environmental implications of nanomaterials and nanotechnology
in commercial applications, the  Agency should also  enhance  its understanding and  support of
nanotechnologies that focus on addressing environmental problems in revolutionary ways. Other federal
agencies such as the Department of Energy and the National Science Foundation already support a broad
portfolio of nanotechnology research focused on EPA-relevant issues such as pollution prevention in
energy production and advanced materials for water purification.  EPA should work to  enhance its
coordination  with these other agencies and support these innovative research efforts through  cooperative
research programs and even funding, as may be appropriate.

   Another part of the Agency's  response  to  nanotechnology  is a new, environmental
stewardship  program  that will  complement the   Toxic  Substances Control Act's
regulatory tools.  The program will gather existing data and information assembled from
manufacturers and processors of new nanoscale materials or materials currently in U.S.
commerce.   This  partnership with the chemical industry  and  other stakeholders will
inform risk assessment  and risk reduction activities. EPA will  use this information and
strategic testing to  determine  whether  commercial  activities  involving  nanoscale
materials present potential risks and respond with appropriate efforts to protect human
health and the environment.  EPA may also be able to provide tools to companies that
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will help them anticipate environmental risks and direct their investments toward safer
products and production procedures.

   With  so many new technologies and the continual development of new chemicals,
EPA works to respond with the best technology available.  EPA is anticipating the use of
DMA micro-arrays in  environmental chemical testing.  DMA  micro-arrays are a type of
technology that profiles the genomes of plant and animal species and uses sequences
like probes to recognize substances.  The Agency recognizes that these technologies
have the potential to change and enhance  chemical testing in multiple environmental
areas.   EPA's research is  making significant progress in the use of DMA micro-arrays
(gene  chips) and related developments,  particularly in  computational toxicology.  As
these technologies develop, the Agency will examine their potential  applications and
relevance to protecting the environment and human health.

   Another  emerging technology,  distributed  sensor networks,  has the  potential  to
enhance EPA's  environmental monitoring.   It is possible  to  envision  a network  of
physical, chemical, and biological sensors that will feed into a central environmental
data management and  analysis  system, such  as EPA's  Global  Earth Observation
System of Systems (GEOSS).  Distributed sensor networks can increase the frequency
and speed of data collection and transmission,  improve the quality of data, enhance
data integration,  and  facilitate  access  to and sharing  of data.    Other potential
implications include the opportunity to provide better environmental health information
that  allows  us to measure  progress  at  multiple temporal  and spatial  scales.  This
technology could increase the frequency of EPA's Report  on the  Environment and
advance our foresight capabilities.  Distributed sensor networks could enhance multi-
media, interdisciplinary  and cross-program collaboration at EPA, and provide data that
accurately portrays environmental conditions on a real-time basis.

NACEPT SP Comments
EPA's brief assessment of distributed sensor technologies does not begin to address the real value of
sensors for environmental protection. While advances in passive sensing will enhance our understanding
of the environment, active sensing will enable revolutionary gains in our ability to prevent pollution and
to address contaminants already in the environment. Researchers are already looking at embedded sensor
applications to create "smart membranes" that turn on when a target contaminant is present, but otherwise
allow flow to pass freely through. Switching to a "just-in-time" capability for addressing contaminants
can result in broad operational efficiencies and greatly enhance infrastructure sustainabilitv. Here again.
other federal agencies such  as the Department of Energy and the National  Science Foundation already
support a broad portfolio of research in this area.  EPA should work to enhance its coordination with these
other agencies and support these innovative research efforts through cooperative research programs and
even funding, as may be appropriate.

   Renewable energy and fuel sources such as biofuels could have many implications
for EPA.  The potential environmental impacts of new renewable and non-renewable
forms of energy production, and  the distribution and storage infrastructure will need to
be examined.  Biofuel  production has the  potential to affect  human health and the
environment  through  pesticide  use  and  habitat  loss.    The  potential  multi-media
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emissions generated from the use and production of biofuels production also will need
to be characterized.

    Global change, habitat loss and destruction due to sprawl and exploitation of natural
resources,  invasive  species,  nonpoint  source  pollution,  and  the  accumulation and
interaction of  these  effects present emerging  ecological  challenges for the  Agency.
EPA's ability to achieve its strategic objectives depends on  many factors over which the
Agency  has  little  or no influence.    Partnerships,  international collaboration,  global
harmonization, industry,  economic  influences (including increased trade  and foreign
investment), industrial  accidents,  natural disasters, litigation, and new legislation have
significant influence on the Agency's ability to achieve its goals.  Changes in the focus,
new level of effort, or status of any of these components  could play a critical role  in the
success of the Agency's programs.
  To Learn More:
  http://www.epa.gov/ocfo/futures/perspectives.htm
1 For additional information on EPA's National Land Cover Database, see: http://www.epa.gov/nerlesd 1/land-sciA
http://www.mrlc.govA and http://edcsnsl7.cr.usgs.gov/glcc/: on the Environmental Monitoring and Assessment
Program, http://www.epa.gov/emap/ and on EPA's Report on the Environment,
http://www.epa.gov/indicators/index.htm (accessed 15 May 2006).

2 Baseline: EPA screening of data obtained through the HPV Challenge Program is commencing in 2006; actions to
obtain additional information needed to assess risks will commence subsequently as chemicals are identified as
priority concerns through the screening process. Measurement Mechanism: EPA risk management action tracking
tools, including RAPIDS (not publicly available) and HPVIS. See U.S. Environmental Protection Agency High
Production Volume Information System (HPVIS) internet site: http://epa.gov/hpvis/. Washington, DC: Office of
Prevention, Pesticides & Toxic Substances (accessed 19 May 2006). Once HPV challenge chemicals have been
through the EPA multi-tier risk assessments process, any found to present unreasonable risks under the Toxics
Substance Control Act is tracked for action, such as Significant New Use Rules (SNURs) that bind all manufacturers
and processors to  terms and conditions that prevent unreasonable risks, other regulatory action, guidance, referral to
other Agency statutes, etc.

3 Baseline: 100 percent in FY 2004 and FY 2005. Measurement Mechanism: Number of TSCA 8(e) Chemical
Hazard Notifications associated with Pre-manufacture notice (PMN)-reviewed chemicals verified to identify the
occurrence of unreasonable risks.  Starting in FY 2005, the EPA expanded its assessment of incoming TSCA 8(e)
reports, required to be submitted whenever companies learn of "substantial risks", to determine whether EPA
properly identified those potential hazards/risks in previously reviewed PMNs. The results of this new assessment
process enables the program to identify potential flaws in its PMN review protocols and act quickly to make
associated improvements.

4 Baseline: 2001 starting point is 0. Actual cumulative reduction reported from 2001 - 2003 is 6.6% (5.7% for 2001
- 2002; 0.9% for 2002 - 2003. Target assumes annual 3.0% reductions for remaining years through 2011.
Measurement Mechanism: EPA's Risk Screening Environmental Indicators (RSEI) model. See: U.S. Environmental
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Protection Agency Risk-Screening Environmental Indicators (RSEI) internet site: http://www.epa.gov/opptintr/rsei/.
Washington, DC: Office of Prevention, Pesticides & Toxic Substances (accessed 19 May 2006).

5 Baseline: 310,000 cases in 1999-2002. Data source: Centers for Disease Control and Prevention. 2005. Blood Lead
Levels -United States, 1999-2002, MMWR:54, pages 513-516. Available on the internet:
www.cdc.gov/mmwr/PDF/wk/mm5420.pdf (accessed 19 May 2006).

6 Baseline: 37.0% in 1991-1994. Data source: Centers for Disease Control and Prevention, 1994 Update: Blood Lead
Levels-United States, 1991-1994, MMWR,43(30): 545-548:
www.cdc.gov/mmwr/preview/mmwrhtml/00032080.htm (accessed May 22, 2006).98

7 See United Nations, Partnership for Clean Fuels and Vehicles internet site:
http://webapps01.un.org/dsd/partnerships/public/partnerships/178.html#top. Division for Sustainable Development
(accessed 19 May 2006).

8 This Strategic Target is based on the levels of several key pesticides found in people as measured by the  Center for
Disease Control's bi-annual (1990 - 1992) National Health and Nutrition Examination Survey (NHANES).  Center
for Disease Control had collected these data for sufficient time to establish a meaningful baseline. The target
provides an indicator of the body burden in the general population resulting from pesticide exposure. See
http://www.cdc.gov/nchs/nhanes.htm.

9 The term "risk events" is based on the assumption that every pesticide application has the potential to create a
pesticide incident with adverse health effects. The number of pesticide applications was derived by taking the
universe of occupationally exposed individuals and estimating the number of pesticide applications per individual
peryear. Data sources: EPA's annual count of certified applicators; U.S. Department of Labor, Findings from the
National Agricultural Workers Survey (NAWS) 2001 - 2002. A Demographic and Employment Profile of United
States Farm Workers, Research Report No. 9. March 2005, Office of the Assistant Secretary for Policy, Office of
Programmatic Policy: Washington, DC: http://www.doleta.gov/agworker/naws.cfm. and; American Association of
Poison Control Centers' Toxic Exposure Surveillance System: http://www.aapcc.org/poisonl.htm (accessed 10 May
2006).

10 American Association of Poison Control Centers' Toxic Exposure Surveillance System:
http://www.aapcc.org/poisonl.htm (accessed  10 May 2006).

11 USGS National Water-Quality Assessment (NAWQA) program, as reported inUSGS's 2006 report, Pesticides in
the Nation's Streams and Ground Water.

12
   Toxic Substances Control Act Section 5: Manufacturing and Processing Notices, Public Law 94-469, October 11,
1976.

13 U.S. Environmental Protection Agency, High Production Volume Information System (HPVIS) internet site:
http://www.epa.gov/hpvis/index.html. Washington, DC: Office of Prevention, Pesticides & Toxic Substances
(updated 17 April 2006; accessed 30 May 2006).

14 See Organisation for Economic Co-operation and Development, Co-operation on the Investigation of Existing
Chemicals, Description of OECD Work on Investigation of High Production Volume Chemicals internet site:
http://www.oecd.0rg/document/21/0.2340.en  2649 34379  1939669  1 1  1 l.OO.html. and Global HPV Portal and
existing databases internet site:
http://www.oecd.Org/document/9/0.2340.en 2649 34379 35211849  1 1  1 l.OO.html. Also see United Nations
Environmental Program, Chemical Screening Information Data Set (SIDS) for High Volume Chemicals internet
site: http://www.chem.unep.ch/irptc/sids/OECDSIDS/sidspub.html (accessed 30 May 2006).

15 Advanced tools developed under the NCP include QSAR - Quantitative Structure Activity Relationships.  There is
no defined base  data set required before PMN, and the TSCA does not require prior testing of new chemicals.
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Consequently, less than half of the PMNs submitted include toxicological data. In these cases, EPA scientists assess
the chemical's structural similarity to chemicals for which data are available - called structure-activity relationship
(SAR)- to help predict toxicity. A useful discussion of SAR is found in an OECO monograph, US EPA/EC Joint
Project on the Evaluation of (Quantitative) Structure Activity Relationships, Environment Monograph No. 88,
Organisation for Economic Co-Operation and Development, Paris, 1994, available on the internet at
http://www.epa.gov/opptintr/newchems/pubs/ene4147.pdf (accessed 19 May 2006).

The Ecological Structure Activity Relationships (ECO SAR) is a personal computer software program used to
estimate the aquatic toxicity of chemicals.  The program predicts the toxicity of industrial chemicals to aquatic
organisms such as fish, invertebrates and algae using (Q)SARs. ECOSAR estimates a chemical's acute (short-term)
toxicity and, when available, chronic (long-term or delayed) toxicity. ECOSAR is available on the internet at US
Environmental Protection Agency, Pollution Prevention (P2) Framework, Hazard Models internet site:
http://www.epa.gov/oppt/p2frameworydocs/hazard.htnrfSub2. Washington, DC: Office of Pollution Prevention and
Toxics (accessed 19 May 2006).

 Office of Pollution Prevention and Toxics, Sustainable Futures. 67 Federal Register 76282. December 11, 2002,
Washington, DC: U.S. Environmental Protection Agency:
http://www.epa.gov/oppt/newchems/pubs/sustainablefutures.htm (accessed 5 May 2006).

17 See Partnership for Clean Fuels and Vehicles internet site: www.unep.org/PCFV. Nairobi, Kenya: United Nations
Environmental Program (updated 25 April 2005, accessed 18 May 2006).

18 For relevant studies, see citations in U.S. Environmental Protection Agency (2005). Draft risk assessment of the
potential human health effects associated with exposure to perfluorooctanoic acid and its salts.  Washington, DC,
Office of Pollution Prevention and Tocixs, Risk Assessment Division. Available at:
http://www.epa.gov/opptintr/pfoa/pfoarisk.pdf (accessed 17 May 2006).

19 See Office of Emergency Management RMP Program Overview internet site:
http://vosemite.epa.gov/oswer/ceppoweb.nsf/content/RMPoverview.htm. Washington, DC: U.S. Environmental
Protection Agency (updated 11 October 2002; accessed 25 May 2006).

20 See Office of Emergency Management EPCRA Overview internet site:
http://vosemite.epa.gov/oswer/ceppoweb.nsf/content/epcraOverview.htm. Washington, DC: U.S. Environmental
Protection Agency (accessed 17 May 17, 2006).

21 See Acute Exposure Guideline Levels (AEGLs) Program internet site: http://www.epa.gov/opptintr/aegl/.
Washington, DC: U.S. Environmental Protection Agency (updated 3 March 2006, accessed 25  May 2006).
22 See Office of Pesticide Programs, Pesticides internet site: http://www.epa.gov/pesticides/. Washington, DC: U.S.
Environmental Protection Agency (accessed 17 May 17, 2006).

23 See U.S. Environmental Protection Agency, Pesticides: Topical  & Chemical Fact Sheets, Pesticide Registration
Program internet site: http://www.epa.gov/pesticides/factsheets/registration.htm (updated 2 may 2006; accessed 19
May 2006).

24 See U.S. Environmental Protection Agency, Pesticide Tolerance Reassessment & Reregistration internet site:
www.epa.gov/pesticides/reregistration (updated and accessed 24 May 2006).

25Federal Insecticide, Fungicide, and Rodenticide Act, as amended. January 23, 2004. Section 3(g), Registration
Review (7 U.S.C. 136a). Available at www.epa.gov/opp00001/regulating/fifra.pdf (accessed 24 may 2006).

26  Department of Health and Human Services. 2005. 3rd National Report on Human Exposure to Environmental
(NCEH Pub. No. 05-0570Chemicals). Atlanta, Georgia: Centers for Disease Control and Prevention.  Available at:
http://www.cdc.gov/exposurereport/ (accessed 24 May 2006)
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27 See U.S. Environmental Protection Agency, Pesticides: Health and Safety, Reducing Pesticide Risk internet site:
http://www.epa.gov/pesticides/health/reducing.htm (accessed 10 May 2006).

28 U.S. Department of Labor, Findings from the National Agricultural Workers Survey (NAWS) 2001 - 2002. A
Demographic and Employment Profile of United States Farm Workers, Research Report No. 9. March 2005, Office
of the Assistant Secretary for Policy, Office of Programmatic Policy: Washington, DC:
http://www.doleta.gov/agworker/naws.cfm (accessed 10 May 2006).

29 See U.S. Geological Survey, National Water Quality Assessment Program internet site:
http://water.usgs.gov/nawqa/ (accessed 19 May  2006).

30 U.S. Fish and Wildlife Service and National Oceanic  and Atmospheric Administration 2004. Joint Counterpart
Endangered Species Act Section 7 Consultation Regulations, 50 CFR Part 402. Available on the internet:
http://endangered.fws.gov/consultations/pesticides/Final Rule.pdf (accessed 19 May 2006).

31 The term "significant" is used in a manner analogous to its use under the National Environmental Policy Act,
involving considerations of both "context" and "intensity." See 40 CFR 1508.27. Under this definition, "...in the
[context] of a site-specific action, significance would usually depend upon the affects in the locale....  Both short-
and long-term effects are relevant." With respect to intensity, issues such as the magnitude of the impact (positive
and negative) will be considered.

32 Source for data is Assessment Cleanup and Redevelopment Exchange System (ACRES).

33 Census estimate of homes lacking access minus homes provided with access between 2000 and 2003.

34 2000 Census estimate of homes lacking access to adequate wastewater sanitation minus homes provided with
access between 2000 and 2003.

35 Baseline for both strategic targets: The 2006 calculated baseline mean maternal serum level for PCBs was 6.28
ug/1 and for total  chlordane was 1.26 ug/1. This initial baseline was calculated based on Arctic Monitoring and
Assessment Program data (AMAP, 2003),that includes human health data points from indigenous maternal
populations across the Arctic, including Alaska, Canada, Norway, and the Russian Federation.  Measurement
Mechanism:  Assessment of data from AMAP, an existing international scientific working group, which advises
governments of the eight Arctic countries on issues related to pollution in the Arctic.  AMAP data is presented in
periodic scientifically-based assessments (available at www.amap.no ), which are a result of cooperative efforts
involving a large number of scientists and other stakeholders, who follow agreed quality assurance and control
protocols consistent with such practices common in the  United States.

36 Small Business Liability Relief and Brownfields Revitalization Act (Public Law 107-118 (H.R. 2869), 115 stat.
2356). Available on the Internet at" http://www.epa.gov/swerosps/bf/sbrrbra.htnrfstatus (accessed 11 May 2006).

37See Brownfields and Land Revitalization Technology  Support Center internet site:
http://www.brownfieldstsc.org/. U.S. Environmental Protection Agency Office of Superfund Remediation and
Technology Innovation), U.S. Army Corps of Engineers, and Argonne National Laboratory (updated and accessed
18 May 2006).

38 See Triad Resource Center internet site: http://www.triadcentral.org/ (accessed  18 May 2006). Triad is an
innovative approach to decision-making for hazardous waste site characterization and remediation. The Triad
approach proactively exploits new characterization and  treatment tools. The Triad Resource Center provides the
information hazardous waste site managers and  cleanup practitioners need to implement the Triad effectively. The
U.S. Environmental Protection Agency, U.S. Army Corps of Engineers, U.S. Army, U.S. Navy, Argonne National
Laboratory, State of New Jersey Department of Environmental Protection, and the Interstate Technology Regulatory
Council support Triad.
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39 See SMARTe (Sustainable Management Approaches and Revitalization Tools) internet site:
http://www.smarte.org/smarte/home/index.xml (accessed 17 May 2006).  SMARTe, is an open-source, web-based,
decision support system for developing and evaluating future reuse scenarios for potentially contaminated land.
SMARTe contains guidance and analysis tools for all aspects of the revitalization process including planning,
environmental, economic, and social concerns. The US Environmental Protection Agency Office of Research and
Development and Office of Brownfields Cleanup and Redevelopment, the German Federal Ministry of Education
and Research, and the Interstate Technology Regulatory Council support its development.

  'U.S. Environmental Protection Agency, U.S.-Mexico Border Program, Border 2012 Program Web Site:
http://www.epa.gov/usmexicoborder/ (accessed 9 May 2006)

41 Stockholm Convention on Persistent Organic Pollutants. Signed by USA on May 23, 2001. Entered into force on
17 May 2004. See http://www.pops.int/  See also http://www.epa.gov/oppfeadl/international/pops.htm
42Arctic Monitoring and Assessment Programm, 2003. AMAP Assessment 2002: Human Health in the Arctic.
Arctic Monitoring and Assessment Programme (AMAP), Oslo, Norway.
(http://www.amap.no/Assessment/ScientificBackground.htm).

43 See Arctic Council, www.arctic-council.org under "Activities" (ACAP/Obsolete Pesticides Project) (accessed 17
May 2006).

44 See Arctic Council, www.arctic-council.org under "Activities" (ACAP/PCB Project) (accessed 17 May 2006).

45 Data for the index components are tracked internally by USEPA's Great Lakes National Program Office and
reported through the State of the Lakes Ecosystem Conference (SOLEC) process. The document, "State of the
Great Lakes 2005 -A Technical Report," presents detailed indicator reports prepared by primary authors, including
listings of data sources.

46 See U.S. Environmental Protection Agency, Great Lakes Monitoring, Contaminants in Top Predator Fish internet
site: http://www.epa.gov/glnpo/glindicators/fishtoxics/topfishb.html (accessed 17 May 2006).

47 Data will be available at U.S. Environmental Protection Agency, Great Lake Monitoring, Atmospheric Deposition
of Toxic Pollutants internet site: http://www.epa.gov/glnpo/glindicators/air/airb.html (accessed 17 May 2006).

48 Lower Columbia River Estuary Program. June 1999. Comprehensive Conservation and Management Plan.
Portland, OR: Estuary Partnership Office. Available on Lower Columbia River Estuary Partnership internet site:
http://www.lcrep.org/mgmt complete_plan.htm (accessed 18 May 2006).

49 Hood River Watershed, DEQ 2006, Mill Creek Watershed, DEQ 2006, Walla Walla Watershed, DEQ 2006
(pending), Pudding River Watershed, DEQ 2006 (pending), and Clackamas River, Watershed DEQ 2006 (pending).
These reports which are found in hard copy will be put on the EPA Columbia River website (as a part of the baseline
information) which is currently under development.

50 Water Cleanup Plans (TMDLs) by Watershed/Ecology Region,
http://www.ecv.wa.gov/programs/wq/tmdl/watershed/index.html  (updated April 2005);Yakima River Pesticide
TMDL, Okanogan River DDT and PCB TMDL, Wenatchee River, Mission Creek, and Lake Chelan PCB and
Pesticide TMDL, Walla Walla Pesticide and PCB TMDL, and Palouse River Pesticide and PCB TMDL.

51 U.S. Environmental Protection Agency (2002). Columbia River Basin Fish Contaminant Survey: 1996-1998 (EPA,
910-R-02-006). Seattle, Washington, USEPA Region 10, Risk Evaluation Unit.
    http://vosemite.epa.gov/R10/OEA.NSF/af6d4571f3e2bl698825650f0071180a/c3a9164ed269353788256c09005
d36b7?OpenDocument (accessed 17 May 2006).
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52 Fixed Station and Seasonal Monitoring Of Conventional and Toxic Contaminants on the Lower Columbia River
Estuary Partnership (LCREP) Internet site: http://www.lcrep.org/eco water qual.htm#fixed (accessed 17 May
2006).

53 Johnson, A. and D. Norton (March 2005). Concentrations of 303(d) Listed Pesticides, PCBs, and PAHs Measured
with Passive Samplers Deployed in the Lower Columbia River, Ecology Publication No. 05-03-006. Olympia WA.,
Washington State Department of Ecology. Available on the Internet: http://www.ecv.wa.gov/pubs/0503006.pdf
(accessed 17 May 2006).

54Dahl, T.E. 1990. Wetlands Losses in the United States, 1780s to 1980s. Washington, DC: U.S. Department of the
Interior, U.S. Fish and Wildlife Service. Available on the Internet: :
www.npwrc.usgs.gov/resource/othrdata/wetloss/wetloss.htm (accessed 17 May 2006).

  Dahl, T.E. 2006. Status and Trends of Wetlands in the Conterminous United States, 1998 to2004. Washington,
DC: U.S. Department of the Interior, U.S. Fish and Wildlife Service.
56
57
  Compensatory Mitigation Rulemaking web page: http://www.epa.gov/wetlandsmitigation (accessed 9 May 2006)
  U.S. Environmental Protection Agency, Army Corps of Engineers, and Departments of Agriculture, Commerce,
Interior, and Transportation. December 24, 2002. National Wetlands Mitigation Action Plan. Available on the
internet: http://www.mitigationactionplan.gov/index.html (updated 6 September 2005; accessed 30 May 2006).

58 See U.S. Environmental Protection Agency, Five Star Restoration Program internet site:
http://www.epa.gov/owow/wetlands/restore/5star/. Washington, DC: Office Wetlands, Oceans, and Watersheds
(updated 1 May 2006, accessed 30 May 2006).

59 See U.S. Environmental Protection Agency, Regional Geographic Initiatives internet site:
http://www.epa.gov/regional/rgi.htm. Washington DC: Office of Regional Operations (updated 25 April 2006,
accessed 30 May 2006).

60 See U.S. Environmental Protection Agency, Targeted Watershed Grants Program internet site:
http://www.epa.gov/owow/watershed/initiative/. Washington, DC: Office Wetlands, Oceans, and Watersheds
(updated and accessed 30 May 2006).


61 See U.S. Environmental Protection Agency, Polluted Runoff (Nonpoint Source Pollution), Clean Water Act
Section 319 internet site: http://www.epa.gov/OWOW/NPS/cwact.html. Washington,  DC: Office Wetlands, Oceans,
and Watersheds (updated 22 February 2006, accessed 30 May 2006).

  Beach, Dana. 2002. Coastal Sprawl: The Effects of Urban Design on Aquatic Ecosystems in the United States.
Arlington, VA: Pew Oceans Commission. Available online at:
http://www.pewtrusts.org/ideas/ideas item. cfm? content item id=1023&content  type id=8 (accessed 9 May 2006)

63 See U.S. Environmental Protection Agency, Great Lakes Pollution Prevention and Toxics Reduction, Great Lakes
Binational Toxics Strategy internet site: http://www.epa.gov/glnpo/bns/index.html (accessed 19 May 2006).

64 See U.S. Environmental Protection Agency, Great Lakes, Regional Collaboration: Interagency  Task Force internet
sites: http://www.epa.gov/grtlakes/collaboration/taskforce/index.html (accessed 18 May 2006).

65 See U.S. Environmental Protection Agency, Great Lakes, Regional Collaboration: Making the Great Lakes
Greater internet site: http://www.epa.gov/grtlakes/collaboration/index.html (accessed  18 May 2006). See also:
Bush, George W. May 18, 2004. Executive Order: Establishment of great lakes interagency task force and
promotion of a regional collaboration of national significance for the Great Lakes..  Washington, DC. Available on
the internet at: http://www.epa.gov/grtlakes/collaboration/taskforce/eo.html (accessed 18 May 2006).
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66 See Great Lakes Regional Collaboration internet site: http://www.glrc.us/ (updated 7 July 2005; accessed 17 May
2006). See also Great Lakes Regional Collaboration Strategy to Restore and Protect the Great Lakes, December
2005, Chicago, IL, Great Lakes Regional Collaboration. Available on the internet at:
http://www.glrc.us/strategv.html (accessed 17 May 2006).

  U.S. Environmental Protection Agency, Chesapeake Bay Program. June 2000.  Chesapeake 2000 Agreement.
Annapolis, Maryland. Available online at: http://chesapeakebav.net/pubs/chesapeake2000agreement.pdf (accessed
9 May 2006)

68 See Koroncai, R., et al. December 2003. Setting and Allocating the Chesapeake Bay Basin Nutrient and Sediment
Loads: The Collaborative Process, Technical Tools, and Innovative Approaches. Annapolis, Maryland: U.S.
Environmental Protection Agency, Region III, Chesapeake Bay Program Office:
http://www.chesapeakebav.net/caploads.htm (accessed 30 May 2006).

69 To view data on submerged aquatic vegetation, see: http://www.chesapeakebav.net/pubs/statustrends/88-data-
2002.xls: dissolved oxygen: http://www.chesapeakebav.net/pubs/statustrends/204-data-2005.xls: on nitrogen,
phosphorus and sediment reductions, see http://www.chesapeakebav.net/pubs/statustrends/186-data-2003.xls. For
additional information on data and methods for submerged aquatic vegetation, see:
http://www.chesapeakebav.net/pubs/2006reports/Indicator Survey  SAV.doc; for dissolved oxygen:
http://www.chesapeakebav.net/pubs/2006reports/Indicator Survey  Dissolved OxygenRevised031406.doc; and for
nitrogen, phosphorus, and sediment reductions:
http://www.chesapeakebav.net/pubs/2006reports/IndicatorSurvev Reducing Pollution 032406.doc (accessed 30
May 2006).

70 See U.S. Environmental Protection Agency, Gulf of Mexico Program internet site: http://www.epa.gov/gmpo
(accessed 17 May 2006).

71 See The Gulf of Mexico Alliance internet site http://www.gulfofmexicoalliance.org (accessed 17 May 2006).

72 See Federal Workgroup, the U.S. Ocean Action Plan's Gulf of Mexico Regional Partnership internet site:
http://www2.nos.noaa.gov/gomex (accessed 17 May 2006).

73 See The Gulf of Mexico Alliance internet site:  http://www.dep.state.fl.us/guh7. Tallahassee, Florida: Florida
Department of Environmental Protection (accessed 30 May 2006).

74 Gulf of Mexico Alliance.  2006. Governors' Action Plan for Healthy and Resilient Coasts March: 2006-March
2009. Available on the internet: http://www.dep.state.fl.us/gulf/files/files/GurfActionPlan Final.pdf (accessed 17
May 2006).

75 Mississippi River/Gulf of Mexico Watershed Nutrient Task Force. 2001. Action Plan for Reducing, Mitigating,
and Controlling Hypoxia in the Northern Gulf of Mexico. Washington, DC.available on the internet at:
http://www.epa.gov/msbasin/taskforce/pdf/actionplan.pdf. See also Mississippi River Basin and Gulf of Mexico
Hypoxia Hypoxia Task Force internet site: http://www.epa.gov/msbasin/taskforce/index.htm (accessed 17 May
2006)

76 See U.S. Environmental Protection Agency (2002).  Columbia River Basin Fish Contaminant Survey: 1996-1998
(EPA, 910-R-02-006). Seattle, Washington, USEPA Region 10, Risk Evaluation Unit. Available on the internet:
    http://vosemite.epa.gov/R10/OEA.NSF/af6d4571f3e2bl698825650f0071180a/c3a9164ed269353788256c09005
d36b7?OpenDocument (accessed 17 May 2006); Fixed Station and Seasonal Monitoring Of Conventional and Toxic
Contaminants on the Lower Columbia River Estuary Partnership (LCREP) Internet site:
http://www.lcrep.org/eco water qual.htm#fixed (accessed 17 May 2006); and Johnson, A. and D. Norton (March
2005). Concentrations of 303(d) Listed Pesticides, PCBs, and PAHs Measured with Passive Samplers Deployed in
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the Lower Columbia River, Ecology Publication No. 05-03-006. Olympia WA., Washington State Department of
Ecology. Available on the Internet: http://www.ecv.wa.gov/pubs/0503006.pdf (accessed 17 May 2006).

77 The Columbia River Toxics Strategy is a commitment by EPA, Oregon, Washington, and Idaho, in coordination
with Columbia Basin tribes, to reduce toxics in water and in fish that people eat.

78 See U.S. Environmental Protection Agency, EPA Report on the Environment internet site:
http://www.epa.gov/indicators/index.htm (accessed 19 May 2006).
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GOAL 5 - Compliance and Environmental Stewardship

Improve environmental performance through ensuring compliance with  environmental
requirements by enforcing environmental statutes, preventing pollution, and promoting
environmental stewardship.  Protect human health and the environment by encouraging
innovation and providing incentives for governments, businesses, and the public that
promote environmental stewardship and long-term sustainable outcomes.

	Under this  goal, EPA will work to ensure that government,  business, and the
public meet federal environmental requirements and will empower and assist them to do
more.    EPA  programs  designed  to  ensure  compliance  (through  assistance,
enforcement, and  other tools)  with federal environmental laws and regulations, to
increase voluntary and self-directed actions to minimize or eliminate pollution before it is
generated (pollution prevention), and to promote environmental stewardship behavior all
contribute to the  achievement of this goal.   The Agency also promotes  greater
compliance by other countries such as key international trading partners with their own
domestic and international environmental commitments,  since greater compliance will
lead to lower levels of pollution that can cross borders and impact the United States.

	EPA  uses  the term  "environmental  stewardship"  to  describe  behavior that
includes  but  also  exceeds  the  requisite  compliance  with   existing  regulatory
reguirements.   Stewards of the environment  recycle wastes  to the greatest  extent
possible,  minimize or eliminate pollution at its sources, and use energy  and natural
resources efficiently to reduce impacts on the environment. Under this  goal,  EPA will
strive to use science and research more strategically and effectively to inform Agency
policy decisions and  to guide  compliance, pollution prevention, and  environmental
stewardship efforts.  In order for EPA to meet its domestic environmental challenges,
the Agency will work with  key international stakeholders through complementary and
coordinated actions to promote and increase environmental stewardship globally.

OBJECTIVE  5.1:     ACHIEVE   ENVIRONMENTAL   PROTECTION  THROUGH
IMPROVED COMPLIANCE.  By 2011, maximize compliance to protect  human  health
and the environment through enforcement and other compliance assurance activities by
achieving a 5 percent increase in the pounds of pollution reduced, treated, or eliminated
by regulated entities, including those in  Indian  country.   (Baseline to be determined  in
2006)

Note to Reviewers:—OECA will be developing statistically-valid compliance rates for key
populations  associated with the national priorities  of EPA's enforcement and compliance
program.—In  addition, as part of a larger review of its performance  measures, OECA will be
consulting with a broad array of co-regulators, compliance programs, and academic experts to
learn more about statistically-valid compliance rate  methodologies that might be appropriate to
apply to EPA's enforcement and compliance program.  We would appreciate your comments on
this matter as you review the draft architecture.
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NACEPT SA Comments
Why 5%?  How many pounds does this represent? What is the difference between a pound of pollution
reduced and a pound eliminated? What is achieved by "treating" pollution, and shouldn't this objective
place priority on elimination over treatment?  What types of compliance assurance activities are  covered
in this  objective?  The word "by" is confusing: does the 5% increase in pounds of pollution reduced.
treated, or eliminated lead to improved compliance, or does improved compliance lead to  the 5%
improvement?  If we assume  EPA means the latter, the objective might be  reworded as follows: "By
2011. achieve a 5% reduction in the pounds of pollution released by regulated entities through compliance
assurance activities such as..."

NACEPT SP Comments
This  section of the draft Strategic Plan would be more meaningful if it referenced information about the
level of environmental  quality improvement  EPA attributed to compliance activities in previous years.
EPA's  Fiscal  Year 2004 Annual Report, for  example, anticipated that civil enforcement  actions  in
FY2004 would "reduce, properly treat, or eliminate an estimated 1 billion pounds of pollutants from
release into the environment"  (p. 106). With the benefit of that information  it is possible to place this
strategic objective into context.   A 5% increase  would  amount to an additional 50 million  pounds  of
pollution reduced, treated, or eliminated.  While  this information is helpful,  it raises further questions:
How significant is that improvement compared  to releases from regulated  industries overall?  How
effective is this objective compared to others  in this goal section? What level of risk reduction does the
agency anticipate will result?

It would be helpful to include a footnote explaining what EPA means by the phrase "reduced, treated,  or
eliminated."  These terms are  not self-explanatory, especially when combined since they refer  to quite
different actions.

We welcome the emphasis in this section upon improving compliance "in Indian country" and in  areas  of
environmental injustice. We wonder, however, why environmental justice is mentioned in sub-objectives
5.1.1, 5.1.2. and 5.1.3. but not in this overarching objective.

       Sub-objective   5.1.1:   Compliance   Assistance.      By   2011,   prevent
       noncompliance  or  reduce environmental risks, with an emphasis  on achieving
       results  in  areas with potential environmental justice  concerns,  through  EPA
       compliance assistance by maintaining or improving on the  following  percentages
       for direct  assistance provided  to  regulated  entities,  including those  in  Indian
       country:  85  percent  of  the regulated entities improve their  understanding  of
       environmental  requirements;  50  percent  of  the  regulated  entities  improve
       environmental  management practices; and 12  percent of the  regulated entities
       reduce, treat, or eliminate pollution.  (Baseline to be determined in 2006)

       NACEPT SA Comments
       This sub-objective is particularly difficult to understand. In the first phrase, the word "or" should
       be changed to "and." The sub-objective should state BOTH the number of regulated entities that
       will improve their practices as well  as the percentages. The sub-objective is ambiguous with
       respect to whether performance improvement is a goal - it states that the  agency will "maintain"
       or "improve." Shouldn't improvement be expected?  What is the basis for the percentage goals.
       and why is  only  12%  of the regulated population  expected to "reduce, treat, or eliminate
       pollution"?  Will EPA target specific sectors, or does it expect to achieve  improvements across
       the board?
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       NACEPT SP Comments
       This sub-objective includes too many clauses.  As written, it could be virtually meaningless to the
       lav reader.

       By inserting the phrase, "for direct assistance provided to regulated entities, including those in
       Indian county." does EPA intend to ignore compliance assistance delivered by other providers.
       such as states, local governments, non-governmental organizations and academia?  While this
       plan might suggest otherwise, in recent years EPA has properly assumed the role of wholesaler to
       a large and  expanding  community  of compliance assistance providers,  and  EPA's direct
       assistance is minor in comparison to the efforts of this larger compliance assistance  community.

       How will EPA know whether it is achieving these goals? Does it assume that any facility that
       receives information on compliance increases its understanding? If this is the case, it would be
       better  to  say  that EPA  seeks to increase  or maintain the number  of facilities  receiving
       information. It would be useful to know the number of facilities, in addition to percentages.  Can
       we use the information provided in sub-objective 5.1.3 to conclude that 45% of regulated entities
       are improving environmental management practices now?  By what measure?

       EPA now considers sharing information about environmental management practices and pollution
       elimination as means to improve compliance. That is commendable!

       Sub-objective  5.1.2:  Compliance Incentives.  By 2011, identify  and correct
       noncompliance and reduce environmental risks, with an emphasis on achieving
       results  in  areas with  potential  environmental  justice  concerns,  through a 5
       percentage point increase in the number of facilities that  use  EPA incentive
       policies  to conduct environmental audits or other actions  that  reduce,  treat, or
       eliminate pollution  or  improve environmental  management  practices  at  their
       facilities, including those in Indian  country.  (Baseline to be determined in  2006)

       NACEPT SA Comments
       The number of facilities that currently access incentive policies should be provided.  Each sub-
       objective should include the absolute number of regulated  entities affected as well as percentages.
       Shouldn't the objective be to increase the number of facilities that conduct environmental audits.
       prevent pollution,  and improve environmental management practices, whether or not they utilize
       EPA incentive policies?   In other  words, we question whether the use of incentives policies
       should be an objective at all.

       NACEPT SP Comments
       Information  presented  in  EPA's Fiscal Year 2004  Annual  Report (p.  Ill) suggests that the
       number of facilities that utilize EPA incentives policies varies from year to year.  1754 facilities
       utilized the policy in FY2001.  1467 in FY2002. 848 in FY2003. and 969 in FY2004.  Over this
       four-year  period,  the number  of facilities  utilizing  EPA incentives decreased by some 44%.
       Given  that variability, is a 5  percentage  point increase realistic? Please see  our comment above
       with respect to the Strategic Architecture.  The  number of facilities that utilize compliance
       incentives is a  measure of neither EPA's  performance  nor the performance of the  regulated
       community.

       Sub-objective  5.1.3:  Monitoring and Enforcement. By 2011, identify,  correct,
       and deter  noncompliance and reduce environmental  risks,  with an emphasis on
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       achieving results in areas with potential environmental justice concerns, through
       monitoring and enforcement of regulated  entities' compliance,  including those in
       Indian  country, by achieving:   a 5 percent  increase in the  number of facilities
       taking complying actions1  during EPA inspections and evaluations after potential
       deficiencies have been identified; a 5 percentage point increase in the percent of
       enforcement actions requiring that pollutants be reduced, treated, or eliminated;
       and  a 5 percentage  point  increase in  the percent of enforcement  actions
       requiring improvement of environmental management practices.  (Baseline to be
       determined in 2006)

       NACEPT SA Comments
       Each  sub-objective should include the absolute number of regulated entities affected as well as
       percentages.  What does it mean to take "complying actions during EPA inspections?" What
       would such complying actions entail?

       We find it difficult to comment on this sub-objective without baseline information.  This sub-
       objective appears to address three distinct environmental improvement strategies:  complying
       actions during an inspection; reducing, treating,  or eliminating pollution; and improvement in
       environmental management practices. Are  we to assume that each of these strategies carries
       equal weight for the agency, since EPA is striving to increase the use of each by 5 percentage
       points over the next 5 years?  While the first measurable is based  on action by the regulated
       community (increase in the number of facilities  decisively  responding to non-compliance
       identified during EPA inspections, albeit only 5%). the second and third measurables relate only
       to behavior change  within EPA by inclusion of particular tools in EPA enforcement actions
       (inputs) and not to behavior change (actions) in the regulated community (outcomes). Since the
       vast majority of enforcement actions  are  initiated at the state  and local levels through
       enforcement program delegation, are these measurables applicable to  state and local enforcement
       actions as well, or limited only to actions initiated by EPA?

       An example would be helpful here.

       NACEPT SP Comments
       Please see comments on Strategic Architecture, above. The new footnote explaining what EPA
       means by "taking complying actions during EPA inspections" is helpful.

Means and Strategies for Achieving Objective 5.1

       EPA works cooperatively with state,  tribal,  and local agencies to secure and
maintain compliance with the nation's environmental laws and regulations.   To reduce
noncompliance and the environmental risks that  can result,  EPA and  its  partners
provide compliance assistance to promote understanding of environmental regulations;
offer  incentives  that encourage facilities  voluntarily to identify, disclose,  and correct
violations; monitor compliance through inspections,  evaluations, and investigations; and
conduct civil  and criminal enforcement actions  to correct violations and  deter future
noncompliance.

       EPA will continue working with state, tribal, and local environmental compliance
assurance programs to ensure  that regulated entities are in compliance.  Specifically,
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EPA will (1) work with states and tribes to ensure a consistent level of effort in state and
tribal  enforcement and compliance assurance programs;  (2) expand the role  of  its
partners in identifying national priorities for the federal enforcement and compliance
assurance programs; (3) better integrate strategic planning efforts at the state,  tribal,
regional, and national levels; (4) share information about patterns of noncompliance or
emerging  risks which need  to be addressed; (5) explore development of  common
performance  measures for  state and tribal enforcement  and compliance assurance
programs; and, (6) continue to ensure  compliance in Indian country, including improving
data collection and  reporting, and building compliance assurance  and enforcement
capacity of tribes.  EPA also will work with some of these  same partners, and federal
entities such as the U.S.  Departments of State, Justice and Interior, to encourage and,
as  appropriate, support  efforts  by other  countries to develop and ensure greater
compliance with their own domestic  environmental programs.  The four elements of
EPA's  compliance  assurance  program—assistance,  incentives,  monitoring,  and
enforcement—are described in more detail below.

NACEPT SP Comments
The above paragraph should include a discussion of means and strategies for addressing environmental
justice.

Regarding point (2) above, how will the agency expand the role of partners in identifying priorities?  Can
EPA say anything here about what its priorities will be?
Regarding point (4). with whom will the agency share information?  Will the agency increase the public's
access to information about noncompliance and emerging risks?

Compliance Assistance

       To   assist  regulated  entities  in  complying  with  environmental  laws  and
regulations, EPA will continue to provide direct assistance to regulated entities through
activities such  as training, workshops, on-site visits, and telephone contacts.  Our  14
virtual                Compliance                Assistance                Centers
(http://www.epa.gov/compliance/assistance/centers/index.html)      directly     provide
assistance and access to resources  such as pollution  prevention information for  the
regulated  community.  EPA also provides  indirect assistance to regulated entities  by
developing tailored compliance assistance  tools and making them  readily available to
the regulated  community through  its  websites, free publications,  and distributions of
materials  through trade associations and other  groups.   The  Agency's  National
Environmental  Compliance  Assistance  Clearinghouse  provides a forum for sharing
information on  best practices, outcome measurement, and  new compliance assistance
materials  among  federal,   state,  tribal,  and  local  governments,  academia,  trade
associations,  and other organizations  that provide compliance assistance to regulated
entities. When providing compliance assistance, EPA also encourages the promotion of
environmental stewardship behavior by establishing partnership programs designed to
minimize or eliminate pollution prior to  its generation.

       The Agency  is developing compliance  assistance activities and measures
through the Environmental  Assistance Network in order  to  improve  environmental
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performance on a sector-specific  basis such as in  the  health care and construction
sectors.   The  Network  brings  together  Agency  offices to collaborate  and identify
opportunities for  building common  metrics and  measurement approaches  for  a
particular sector that will address  environmental assistance, pollution prevention, and
environmental stewardship.

NACEPT SP Comments
Are we to assume that the environmental problems of the health care and construction sectors represent
agency priorities?  Can EPA say more  in this document about the problems it considers "ripe"  for
addressing through the strategies of compliance and stewardship?

The above paragraph should include a discussion  of means and strategies for addressing environmental
justice.

Compliance Incentives

      Compliance incentive  policies  help foster an environmental stewardship ethic
within the regulated community by offering an  incentive to address  environmental issues
proactively.  EPA offers several incentives to encourage  regulated entities, private and
governmental, to assess their overall compliance with environmental requirements and
voluntarily disclose, promptly correct, and prevent the recurrence  of non-compliance
problems.  The Agency will continue to make  the Audit Policy (Self-Policing Policy) and
other compliance incentives available to  the regulated community, including reduced
penalties for violations  and extended time  for  correction.  EPA also encourages owners
of multiple facilities to enter into  corporate-wide auditing  agreements  because such
agreements offer the opportunity for these regulated entities to review their operations
more comprehensively while providing  certainty  about their  environmental liability.
Corporate-wide  auditing  agreements,   particularly  those  following   mergers  and
acquisitions,  offer the  potential  for  significant  environmental  benefits  because
environmental compliance issues are addressed simultaneously across the company.

      EPA will continue to work with  stakeholders to improve opportunities for entities
to self-disclose  and correct violations.  The Small  Business Compliance Policy has
recently been modified to encourage greater participation  by small businesses, allowing
businesses with fewer  than 100 employees to benefit from a reduction in penalties  for
federal violations they  discover,  disclose,  and correct.  As  part of outreach supporting
the Small Business Compliance Policy, EPA  will work with small  business compliance
assistance  providers  to  develop  tools   small  businesses can  use  to  understand
applicable environmental requirements and take advantage of the flexibility offered  by
the policy.  EPA also will continue to encourage states to adopt, and communities to
use, the policy.
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Compliance Monitoring and Enforcement

      Federal environmental regulations establish a baseline for consistent compliance
levels nationwide.   States and tribes  that have been delegated  responsibilities for
specific programs  may  make  these  baseline standards  more stringent and  enforce
against  the  more  stringent  standards.  EPA  uses strategic targeting  to conduct
monitoring  and  enforcement  activities—inspections, evaluations,  civil and criminal
investigations, administrative actions,  and civil  and criminal judicial enforcement—to
identify  the most egregious violators and return them to compliance  as  quickly as
possible.  EPA's goal is to address the most significant risks to human health and the
environment and to address disproportionate  burdens on certain populations.   EPA's
national enforcement and compliance assurance program  will continue to focus on two
major components:  (1)  a  limited number of national priorities that focus on  significant
environmental risks and  patterns of noncompliance; and, (2) core program activities that
implement  the requirements  of all environmental  laws  and  programs.  Through a
collaborative process with  states and tribes, EPA analyzes data and trends  to identify
areas appropriate for priority attention.

OBJECTIVE   5.2:  IMPROVE  ENVIRONMENTAL  PERFORMANCE  THROUGH
POLLUTION   PREVENTION  AND  THE ADOPTION OF  OTHER STEWARDSHIP
PRACTICES THAT LEAD  TO SUSTAINABLE OUTCOMES.  By 2011, enhance public
health and environmental protection and increase conservation  of natural resources by
promoting pollution prevention and the adoption of other stewardship practices by
companies, communities, governmental organizations, and individuals.

NACEPT SP Comments
We question whether including the objective of stewardship in this goal section is appropriate. Wouldn't
stewardship fit more appropriately in  Goal 4? The means and strategies to foster stewardship would seem
to be quite different from those the Agency might use to foster compliance.

EPA has issued a charge to NACEPT to  explore opportunities for enhancing environmental stewardship
and cooperative conservation approaches, and NACEPT expects to provide additional comments to the
Agency based on its research.

The plan mentions promoting the adoption of stewardship practices among  individuals, but none of the
sub-objectives or strategic targets mention individuals. How will the Agency engage individuals?

   Sub-objective   5.2.1:   Prevent   Pollution  and   Promote  Environmental
   Stewardship  by  Business.  Government  and the  Public.  By  2011,  reduce
   pollution, conserve natural resources, and improve other environmental stewardship
   practices through implementation of EPA's pollution prevention  programs.

      Strategic Targets:

      •  By 2011, reduce 4Qr£ 7.3 billion pounds of hazardous materials cumulatively
         from the 2005  2000 baseline amount of 44 million pounds.
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      NACEPT SA Comments
      Who is to do this, and through what means? What is the baseline, and what percentage reduction
      does the target represent?  [Same comment applies to 6 bulleted points below.1

      NACEPT SP Comments
      It is unclear why this target decreased 30% from 10.5 billion pounds to 7.3 billion pounds. What
      does the baseline amount of 44 million pounds represent? It would seem to be extremely low for
      the 2000 total hazardous waste generated. It is unclear how the reduction can be greater than the
      baseline (by more than two orders of magnitude).  If the baseline  is the hypothetical reduced
      amount in 2000. how does this relate to the total quantity of hazardous waste generated in that
      same year?  It is also unclear what "reduce cumulatively"  means in the present context.  The
      cumulative time frame is not specified. [Same comments apply to 4 bulleted points below.1

      • —By 2011, reduce 1.5 billion  pounds of non  hazardous materials cumulatively
         from the 2005 baseline.

      -—By 2011,  reduce,  conserve or offset  4 million  megawatts of  energy use
         cumulatively from the 2005 baseline.

      NACEPT SP Comments
      It is unclear why the non-hazardous materials and electricity reduction targets proposed in the
      Strategic Plan Architecture have been deleted in this Strategic plan.  They should be re-instated.
      and a target  for reducing greenhouse gases should be added.

      •   By 2011, reduce, conserve, or offset 1 quadrillion 774.0 trillion British Thermal
          Units (BTUs) cumulatively from the 2QQ§ 2002 baseline amount of 0 BTUs.

      •   By 2011, reduce water use  by ?3 52.0 billion  gallons cumulatively from  the
         2000 baseline amount of 220 million pounds.

      NACEPT SP Comments
      220 million pounds of water is approximately 26.4 million gallons.  It is unclear what this
      quantity represents as a baseline.

      •   By 2011,  save $1.1  billion through pollution prevention improvements in
         business, institutional,  and governmental costs cumulatively from the 2005
         2002 baseline amount of $0.0.

      •   By 2011, achieve a XXX pound (10% of baseline) overall reduction of priority
         chemicals in waste using 200^1 as a baseline year reduce 4 million pounds of
         priority chemicals from waste streams as measured  by National Partnership
         for   Environmental    Priorities    (NPEP)   contributions,    Supplemental
          Environmental  Projects (SEPs), and other tools used by  EPA to achieve
         priority chemical reductions.
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      NACEPT SP Comments
      It is difficult to assess the significance of these targets, but they appear to be quite modest.  Take
      for example the water use goal which states that business, government, and the public will reduce
      52 billion gallons of water cumulatively from the 2000 baseline of 220 million pounds.  (We will
      ignore for the moment our question about the meaning of the 220 million pound baseline.)  As a
      point of comparison, consider the water reduction goal  for Performance Track  facilities noted
      below of 5.1  billion  gallons of water  annually, or  25.5  billion gallons over  five years.
      Approximately 400 facilities participate in the Performance Track program, just .0005% of the
      780.000  manufacturing  facilities that EPA is attempting  to engage in its Sector Strategies
      Program (see below). If we expect 400 facilities to reduce 25.5 billion gallons of water, shouldn't
      we expect some 780.000 facilities to reduce more than 52 billion gallons, roughly  double that
      amount?

Sub-objective  5.2.2:  Promote  Improved  Environmental Performance  through
Business and Community Innovation.  Through 2011, achieve measurably improved
environmental  performance to achieve  sustainable  outcomes through sector-based
approaches, performance-based programs, and assistance to small business.

      Strategic Targets:

      •   By fiscal year 2011, the reported  results  of Performance Track member
         facilities  collectively  will achieve  show the  following  normalized  annual
          reductions:  XXX 5.1  billion  gallons  in water  use;  XXX  13,000 tons  of
          hazardous  materials  use; XXX Metric  Tons  230,000 megatons  of carbon
          dioxide equivalent (MTC02E MTCOE) of greenhouse gases; XXX 300 tons of
         toxic discharges to water; and XXX 5,500 tons of combined  NOx, SOx, VOC,
          and   PM   emissions.     (Performance Track  member   facilities  make
          commitments to, and report yearly progress on, performance improvements in
          up to four environmental areas.  In FY 2005, Performance Track  members
          achieved normalized annual reductions of 3,387,333,545 3.4 billion  gallons in
         water  use;  8,794 tons  of  hazardous  materials use;  151,129  MTC02E  of
          greenhouse gases; 186  tons  of toxic  discharges to water;  and  3,188 3,533
         tons of combined NOx, SOx, VOC, and PM emissions.)

      NACEPT SA Comments
      While it is difficult to comment on Performance Track targets since they are not given, how  do
      the reductions noted  for the previous year compare to reductions of facilities  that do not
      participate in the program?  How do they compare to water use, hazardous material use, and
      discharges of greenhouse gases, toxics, and NOx and SOx from industry generally? Are  these
      significant or inconsequential reductions?

      NACEPT SP Comments
      Thank you  for  including the numerical  targets.   Many  facilities  that do not participate  in
      Performance Track are also reducing their environmental  footprints.  Are Performance Track
      facilities going beyond the norm,  or is EPA taking credit for improvements that facilities would
      have made anyway, even in the absence of the program?
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      •   By 2011, the participating manufacturing  and service  sectors in the Sector
          Strategies Program  will achieve  an  aggregate  10  percent  reduction  in
          environmental releases to air, water,  and land, working from a 2004 baseline
          and normalized  to  reflect  economic growth.  (Baseline  and normalization
          factors to be developed in 2006.)

Sub-Objective 5.2.3: Promote Environmental Policy Innovation. By Through 2011,
achieve measurably improved environmental  results, promote stewardship behavior,
and  advance sustainable  outcomes  by testing, evaluating,  and applying alternative
approaches to environmental  protection in states, companies, and  communities. This
work also will seek to  improve the organizational  cost effectiveness and  efficiency  for
regulatory agencies as well as regulated entities.

      Strategic Target:

      •   By 2011, innovation projects under the State Innovation Grant Program and
          other piloting mechanisms will achieve, on average, a 7.5 percent or greater
          improvement in  environmental results (such as  reductions  in air  or water
          discharges, improvements in ambient water or air quality, or improvements in
          compliance  rates),  aed/ or a  5 percent or greater  improvement in cost
          effectiveness and efficiency.  (Note:  Baselines  will  be developed based  on
          2001 2005 innovation program activities. Each  project's achievement will  be
          measured by  the   results   established  in  selected  grantee  proposals.
          Baselines for ambient  conditions  or  pollutant  discharges  or  costs  of
          compliance  will  be developed at  the  beginning of  each  project, and
          improvements for each project will be measured  after  full implementation of
          the innovative practice.)

      NACEPT Comments
      Why 7.5%? This is a very specific target. 7.5%  compared to  what? "Traditional" environmental
      regulation? How will this be measured?

      NACEPT SP Comments
      Thank you for including information about how EPA will measure results.  In addition to  the
      "before-after" comparisons  noted, it would be  helpful to undertake matched case  studies of
      facilities that do and do not participate in innovative programs.  EPA could measure each
      project's achievement by comparing ambient  conditions, pollutant discharges,  and costs of
      compliance among facilities that participate in innovative programs  with the same set of
      conditions, discharges, and costs for similar facilities that do  not participate. Such matched case
      studies may be the most appropriate method for evaluating program effectiveness.

Means and Strategies for Achieving Objective 5.2

      EPA is committed to developing and promoting innovative strategies that achieve
better environmental results, reduce costs, and  promote environmental stewardship.  In
collaboration with  its state  and tribal partners, the Agency will continue  to  focus  its
efforts on innovations  that will assist small businesses and communities in improving
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both their environmental and economic performance.  EPA relies on partnerships to
achieve pollution prevention goals under  the  Pollution Prevention Act of 1990  that
encourages  prevention and source reduction as the preferred method of preventing
pollutants from release to the environment.  In addition, EPA and key stakeholders and
partners will work to enhance international awareness and use of pollution prevention
measures and environmental stewardship approaches, in particular by focusing on key
trading partner countries that also represent  major  emitters of critical transboundary
pollutants.

NACEPT SP Comment
This section should describe how EPA intends to engage individuals in stewardship.

      EPA's Innovations Strategy relies on continued outreach to  states, tribes,  and
businesses to help identify innovative approaches that merit testing,  evaluation,  and
implementation.  To provide leadership  on the cutting edge of environmental policy,
EPA works  continually to identify, test,  and  implement innovative strategies  that are
effective  and efficient. Some  innovations  relate to  policies and programs,  such as
permitting or the regulation of small sources. Other innovations  change the  way the
Agency does business. For example, EPA utilizes Agency staff expertise in working with
state, community,  and business leaders to strengthen  partnerships  that  encourage
greater reliance  on collaboration and meaningful public involvement.   EPA advances
innovation through  a  combination  of  policy analysis, piloting, grants,  assessments,
information-sharing, and  regulatory or policy development.  To  identify and test new
approaches,  the Agency partners extensively  with states, tribes, businesses,  and
others.  To bring  innovations to full-scale implementation, EPA initiates regulatory
change  such as more flexible permitting approaches, or promotes adoption of new
strategies by states.

Improving Environmental Performance

      EPA will advance environmental protection through innovative and collaborative
approaches  with  business  and governmental entities  that  produce  measurable
environmental results.  For example, EPA's National Environmental Performance Track
Program  is  a public-private partnership that  encourages  continuous environmental
improvement through the use of environmental management systems,  local community
involvement, and measurable environmental results.  The objectives of the Performance
Track program are to motivate high-performing facilities  to measurably reduce their
environmental footprint beyond legal requirements and to change the way government
regulates these facilities.   Performance Track members make commitments among 38
different environmental performance categories.  Facilities are urged to  target their most
significant aspects, yielding  environmental  accomplishments in their most important
areas.  Facilities also  leverage their commitments to  influence improved environmental
performance  up  and  down their supply chain.  Performance Track establishes new
relationships  between government  and business  which  is  based  on  recognition,
mentoring, sharing knowledge, incentives (including  lower inspection priorities), and a
sustained pattern of superior performance.
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NACEPT SP Comments
The goals of Performance Track are laudable, but how significant are its impacts?  For example, what
percentage of eligible facilities participate? Our understanding is that the size of this program is relatively
small and that its growth has been modest. Can we rely on Performance Track to achieve the agency's
stewardship objectives?

      EPA  will  continue to promote improved  environmental performance  by  high-
impact sectors of the U.S. economy with the Sector Strategies Program. At present, the
program works with 12 major manufacturing and service sectors, representing 780,000
facilities and over 20  percent  of  manufacturing gross domestic product (GDP) and
environmental releases.   Although the  program's overall activities  are  intended  to
promote  environmental stewardship  while  minimizing regulatory  burden,  individual
sector projects address EPA's  specific air, water,  land, and ecosystem objectives as
well.  The program also supports  the Administrator's goal to  "accelerate  the pace  of
environmental protection"  by  addressing  the 'driver &  barrier'  factors  that  affect
environmental management decisions throughout each sector.  In addition to  fostering
collaboration and  innovation,  the  program maintains an  emphasis  on  results and
accountability by tracking  sector-wide  trends in  pollutant emissions  and  resource
conservation in  the Sector Strategies Performance Report, which  is  available to the
public at www.epa.gov/sectors/performance.html.

NACEPT SP Comments
The above  paragraph includes useful contextual information about the  percentage of  manufacturing
facilities the Sector Strategies Program is reaching. It would be helpful to include similar information for
the Performance Track program.

      EPA will continue to promote the widespread use of environmental management
systems (EMS) both domestically and  internationally.  EMSs provide  organizations of all
types with  a structured  system  and  approach  for managing environmental and
regulatory responsibilities to improve overall environmental  performance,  including
areas not subject to regulation  such as product design, resource conservation, energy
efficiency, and other sustainable practices.  Through various partnership programs and
its  EMS  website,  the Agency provides  information and  technical  assistance for
organizations implementing EMSs.  EPA will also fund research on the effectiveness  of
EMSs in the private and public sector.   Leading by  example, EPA has implemented
EMSs at  34 of  its  own facilities to improve environmental management  and reduce
environmental impact.

      EPA  also remains committed  to  identifying  and testing new approaches  to
improving environmental performance by partnering  with  states, tribes, and industry
through the  State Innovation Grant Program.  EPA will use this grant  program to fund
projects that promote innovative approaches to  permitting and other  approaches that
improve corporate environmental performance. One example of an innovative program
receiving  State  Innovation  Grants is  the Environmental Results Program (ERP), an
approach  first developed by the State  of Massachusetts to  regulate small sources such
as drycleaners and  printers more cost-effectively.  By requiring each business  owner to
certify annually compliance with all applicable requirements, providing for random state
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inspections to provide a statistically reliable picture of performance across the industry,
and requiring businesses to submit a plan for returning to compliance if a violation if
found,  the  ERP  results  in  significant performance improvements in  sectors that
previously had been largely overlooked. Moreover, the resources needed to monitor an
entire sector are very small compared to  traditional means.   State  Innovation  Grants
have been instrumental in expanding the use of this policy innovation. Between  15 and
20  states  are  now  using or  exploring  the  use  of  ERP  to  effectively address
environmental concerns related  to small businesses  including sectors such as auto
body shops, auto salvage  yards, small hazardous waste generators, and gas stations.
In another project supported  by  this grant program, Arizona  developed an automated
permit  application system that  reduced  the  number of permit  writers devoted  to
stormwater permitting statewide from 34 to two, allowing a reallocation of resources to
compliance assistance in higher priority areas.

      EPA  measures and tracks results for the State  Innovation Grant program  by
requiring grantees to include performance  measures in  project  planning, to  report
regularly on implementation  of  their  projects,  and  to  file a  final  report on  results
achieved. Additionally, by 2011,  EPA  is planning to conduct an evaluation of the State
Innovation Grant Program.

NACEPT SP Comments
The performance measures noted above will be helpful, however the best way to assess the effectiveness
of State Innovation Grants might be to compare the performance of participants with that of similar non-
participants.

Cost Saving Technologies  that Prevent Pollution

      EPA's Green Chemistry Program2 supports  research  and fosters development
and  implementation  of innovative  chemical technologies to  prevent  pollution  in  a
scientifically sound, cost-effective manner.  The Green Suppliers Network is a national
EPA program that works with the Department of Commerce's Manufacturing Extension
Program and state technical  assistance programs  to improve the environmental and
economic performance  of manufacturing  suppliers  by providing critical  information
necessary to inform  corporate  decision  making on cost saving  opportunities and
technologies that eliminate waste  and increase energy efficiency.  The Presidential
Green  Chemistry Challenge Award program recognizes superior  achievement  in the
design of chemical products and encourages chemical designers to prevent pollution,
conserve water, and reduce energy use in  achieving measurable results.  The program
has been at the forefront of the  global  Green Chemistry  movement,  and through
voluntary  partnerships  with  academia, industry,  and  other  government  agencies,
supports fundamental research  in  environmentally benign chemistry and  provides a
variety of educational and international activities.

      EPA's Design for the Environment3 (DfE) Industry Partnership Program promotes
integration of cleaner,  cheaper, and smarter pollution prevention solutions  into everyday
business practices.   DfE encourages  the  adoption of less polluting  practices through
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technology assessments and  outreach that  includes a comprehensive comparison of
cost, performance, and hazards of baseline and alternative technologies.  The program
will continue to work with industry sectors to measure results in reducing risks to human
health  and the environment,  improve  performance,  and save costs associated  with
existing and alternative pollution prevention technologies or processes.

Waste  Minimization

      To  reduce  priority chemicals in  wastes going to landfills, EPA focuses on key
waste streams and waste  generators through a  variety of mechanisms,  including the
National  Partnership  for  Environmental Priorities (NPEP),  a part of  the Agency's
Resource  Conservation Challenge  (RCC).   Through  this program,  EPA encourages
state and  local governments, manufacturers, and other nongovernmental organizations
to form partnerships to reduce the generation of waste containing any of the 31 priority
chemicals.  Companies that become NPEP partners are publicly recognized for  their
contribution  to the national reduction goal.   As of April 2006, NPEP has enrolled 84
partners, which together have committed to achieve reductions of over 6 million pounds
of priority chemical reductions.

      EPA will advance environmental protection and protection of children's  health
through innovative and   collaborative approaches  with  government  entities  and
businesses that produce measurable environmental results.  EPA's Schools Chemical
Cleanout Campaign aims to decrease the number of injuries and K -12 school days lost
due to  poor chemical  management and chemical spills, which is likely to improve the
learning environment in K-12 schools across the nation. EPA will continue to work with
other federal agencies, and their state,  tribal  and  local equivalents to facilitate chemical
cleanout  and  prevention  of  future chemical management  problems  by providing
technical assistance and grant funding.

Preventing Environmental Impacts through NEPA  Review

      The Agency will prevent significant environmental  impacts associated with large
federal projects subject to National Environmental Policy Act (NEPA) review4. Section
309 of  the Clean Air Act requires EPA  to review and make public its comments on the
environmental  impacts of other federal agencies.  EPA performs this role in consultation
with the White House  Council on Environmental  Quality.  EPA also provides technical
assistance to other federal agencies on developing environmental impact statements;
assists  them  in   developing  projects to   avoid  environmental   impacts; supports
streamlined  environmental  review  processes;  participates in rotational assignment
programs; participates  in interagency work groups; and, provides training and guidance.
EPA's  own activities that are  subject to NEPA requirements  include wastewater and
drinking water treatment plant construction  and facilities constructed under other  EPA
grants and EPA-issued new-source water discharge permits.
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Pollution Prevention Work with Tribal Partners

      Tribal environmental and public health issues remain a priority as part of EPA's
efforts to apply environmental justice principles in its programs.  EPA will focus on the
expansion  of  green technologies on tribal lands,  especially for  tribal  communities'
buildings that were constructed decades ago.  Currently, EPA is working with the  U.S.
Department of Housing and Urban Development (HUD) to provide information about
green building training for tribes,  incorporate green building guidance into tribal housing
grants, post green building materials on appropriate websites, and  implement advisory
group recommendations.

NACEPT SP Comments
We suggest that EPA include a paragraph here on evaluating innovative programs to identify and promote
the most promising innovations.

OBJECTIVE 5.3: BUILD TRIBAL CAPACITY TO IMPROVE HUMAN HEALTH AND
THE  ENVIRONMENT  IN  INDIAN COUNTRY.     Protect  human  health  and  the
environment  on   tribal  lands  by assisting  federally-recognized  tribes  to:  build
environmental management capacity; assess environmental  conditions and measure
results; and implement environmental programs in Indian country.

NACEPT SP Comments
This objective should include fostering stewardship in "Indian country."

      Strategic Targets:

      •  By 2011, increase the  percent of  tribes with  an environmental program to 67
         percent.5 (FY 2005 Baseline: 54 percent of 572 tribes.)

      NACEPT SA Comments
      Would any "environmental program" satisfy this requirement?  Shouldn't  the agency specify
      minimal requirements?

      NACEPT SP Comments
      The explanatory footnote is helpful.

      •  By 2011, increase the percent of tribes implementing federal environmental
         programs in Indian country to 9 percent. (FY 2005 Baseline:  5 percent of 572
         tribes.)

      NACEPT SA Comments
      This  should be compared to the previous target.  If only 5% of tribes implement any federal
      environmental programs, then 49% of tribes  have environmental programs that are not equivalent
      to  federal programs.  A goal of increasing  the number of federal programs to 9% seems  quite
      conservative.
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      •  By  2011,   increase  the  percent  of  tribes  conducting  EPA-approved
         environmental monitoring and assessment activities in Indian country to 26
         percent. (FY 2005 Baseline: 20 percent of 572 tribes.)

Means and Strategies for Achieving Objective 5.3

      Under  federal   environmental  statutes,  the  Agency has  responsibility  for
protecting human health and the environment in  Indian country.  EPA has worked to
establish the internal  infrastructure and organize its activities in  order to meet this
responsibility.

      Since adopting  the  EPA Indian Policy in 1984 (which has been reaffirmed by
each  succeeding Administration), EPA has  worked with  tribes  on a  government-to-
government  basis that affirms  the federal trust responsibility between  EPA and  each
federally recognized  tribe.   EPA's American Indian  Environmental Office leads  the
Agency-wide effort to ensure environmental protection in Indian country.  In 2006, there
are 572 federally-recognized tribes as well as intertribal consortia6 in 9 EPA Regions.
The  land base  in  Indian  Country totals  over  70  million  acres and varies  from
reservations of less than 10 acres to those of more than 14 million acres.

      EPA's  strategy  for achieving its objectives in  Indian  country has three major
components.  First,  the Agency will continue to distribute Indian General Assistance
Program (GAP) capacity-building grants with  the goal  of establishing an environmental
presence in all 572 federally recognized tribes in  the United States.  GAP grants help
cover the costs of  planning,  developing,  and establishing  environmental protection
programs and creating  this environmental  presence for a tribe. In 2005, EPA provided
$62 million in GAP resources  which  allowed  480 tribes and  intertribal consortia to
develop an integrated environmental program.

      Second,  EPA will develop the information technology infrastructure needed to
measure environmental conditions in Indian country and  related lands and measure  the
environmental results that  accrue from the implementation of environmental programs
on those lands.   The Agency will provide the data and information necessary for tribes
and EPA to meet environmental priorities.  The Tribal Program Enterprise Architecture
(TPEA)  complements   the General  Assistance  Program  (GAP)  with  an information
technology infrastructure that organizes environmental data on a tribal basis. The TPEA
provides a clear, up-to-date picture of environmental conditions in Indian country on a
local level. These data can assist tribes in identifying priorities for assuming regulatory
and program management responsibility, primarily through the "Treatment in a manner
similar to a  State" (TAS)  process  available  under several environmental statutes or
through development of a tribal program under tribal law, without seeking EPA approval.
We will  continue to establish direct links with  other federal  agencies  (including the U.S.
Geological Survey, Bureau of  Reclamation,  and  Indian Health Service) to create an
integrated, comprehensive, multi-agency Tribal Enterprise Architecture.  This interactive
system will allow tribes  and EPA regional offices to supply information on environmental
conditions that supplements data collected by EPA's national tribal  systems.  As data
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gaps are identified, EPA will work with our tribal partners to obtain data that will assist
environmental managers to more accurately address high risks within Indian Country.

      Third,  EPA's American Indian Environmental  Office will  continue to coordinate
closely  with  Agency  programs  to  guide  and  track the  timely  and  appropriate
implementation of those programs directly on  Indian lands.   In its continuing outreach to
tribes,  EPA  has developed  specific tribal  strategies  in  water,  air,  land,  pollution
prevention and toxics, and enforcement and compliance.   Consultation, collaboration,
and direct partnerships with tribes remain a priority for the Agency and are integral to
EPA's strategic planning. The Tribal Caucus, which has provided input to the Agency on
tribal issues for several years, will serve as the focal  point for work under this objective
and will help  facilitate continued development of EPA-tribal partnerships. The Agency
will also engage other  EPA-sponsored tribal  groups, such  as the Tribal Committee of
the Forum on State and Tribal Toxics Action, the Tribal Pesticides Program  Council, the
Tribal Science Council,  the National Tribal Air Association, and the Tribal Water Council
(under development).

NACEPT SP Comment
This section should describe how EPA will foster stewardship in tribal lands.

OBJECTIVE  5.4:  ENHANCE  SOCIETY'S  CAPACITY  FOR  SUSTAIN ABILITY
THROUGH SCIENCE  AND  RESEARCH.   Conduct  leading-edge,  sound scientific
research  on  pollution  prevention,  new  technology  development,  socioeconomic,
sustainable systems,  and decision-making tools.  By 2011, the products of this research
will be independently recognized  as providing critical  and key evidence in informing
Agency polices and decisions and solving problems for the Agency and its partners and
stakeholders.  (Also—see—Research,—under  Cross  Agency   and—Support Program
Evaluations in Appendix of this Strategic Plan.)

NACEPT Comments
Can EPA provide any guidance about the level of priority it will place on these different research areas?
Since outcomes are  difficult to measure in this area, some information about outputs would be helpful.
For example, how many RFPs does EPA expect to issue for each sub-objective?

      Sub-objective 5.4.1:  Strengthening  Science.  The research and  educational
      community, the regulated community and decision and policy makers use ORB
      Agency research products and services to enhance the scientific and technology
      base and  catalyze innovation  of alternative processes,  tools,  technologies and
      systems for advanced environmental  protection; implement more  efficient and
      sustainable  practices, materials  and  technologies   in  improved environmental
      performance;  implement  improved  and  scientifically  sound  management
      decisions and policies and practices for sustainable resource management.

      Sub-objective 5.4.2: Conducting Research.   Through  2011, conduct leading-
      edge,  sound  scientific  research  on  pollution  prevention,  new   technology
      development, socioeconomic,  sustainable systems,  and  decision-making  tools.
      The products of  this research will provide critical and key evidence  in informing


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      Agency polices and decisions affecting the Agency programs in Goal 5, as well
      EPA partners and stakeholders.

Strategic Targets - Sustainability and Pollution Prevention:

      »  The research and educational  community apply ORB research  results,
         products and  services to enhance the scientific and technology base and
         catalyze innovation of alternative processes, tools, technologies and systems
         for advanced environmental  protection.—Success is defined by an external
         expert  review  process to  measure  the  utility  of  the data, tools,—an4
         technologies  for  key Agency  decisions—(metric  to   be  established  in
         consultation with external reviewers; measurement methodology still under
         development).

NACEPT Comments
What is the timetable  for developing these metrics and measurement methodologies?

      -—The regulated community applies ORB research products and services to
         implement—more—efficient—and—sustainable—practices,—materials—an4
         technologies in improved environmental performance.  Success is defined by
         an external expert review process to measure the utility of the data, tools, and
         technologies  for  key Agency  decisions—(metric  to   be  established  in
         consultation with external reviewers; measurement methodology still under
         development).

      •—Decision and policy makers  use ORB  products  and  services to implement
         improved  and scientifically sound management decisions and policies and
         practices for sustainable resource management.—Success is defined by  an
         external expert review process to measure  the utility  of the data, tools, and
         technologies  for  key Agency  decisions—(metric  to   be  established  in
         consultation with external reviewers; measurement methodology still under
         development).

Strategic Targets  Economics and Decision Sciences:

      »  Through  2011—identify  and—reduce  uncertainties  and—potential—biases
         associated with  benefit transfer  methods, and provide  these  methods and
         estimated values  from original  studies for ecological   and  human  health
         benefits analysis  for  use—in—Regulatory—Impact  Analyses  and  similar
         documents by  EPA's program offices,  states,  regions, and  other  bodies.
         Success is defined by an external expert review process to measure the utility
         of the data,  tools, and methods for  key Agency decisions  (metric to  be
         established—m—consultation—wtib—external—reviewers;—measurement
         methodology still under development).
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      ••  Through  2011 make progress in  improving the understanding of decision-
         making with respect to compliance behavior and environmental performance
         in response to interventions, including government enforcement, information
         disclosure, voluntary initiatives, and similar programs, to support the design of
         policies using these interventions.—Success is defined by an external expert
         review process to measure the utility of the data, tools, and methods for key
         Agency decisions  (metric to be  established in  consultation  with  external
         reviewers; measurement methodology still under development).

      »  Through  2011 make  progress in identifying regulated entities' responses to
         market mechanisms  and incentives and  investigating how  market-based
         programs can be designed to improve environmental  quality  at the lowest
         cost,  to  support the  design  of  policies  using  market  mechanisms  and
         incentives for environmental management. Success is defined by an external
         expert review process to  measure the utility of the data, tools, and methods
         for key Agency decisions (metric  to be  established in consultation  with
         external reviewers; measurement methodology still under development).

      NACEPT SP Comments
      Why  has EPA  eliminated all of the strategic targets in this section? Are we to assume that this
      objective is of lower priority than in the past?

Means and Strategies for Achieving Objective 5.4

      Progress toward research goals  is assessed through a suite of metrics that is
tailored to measuring the impacts of the outcomes of the respective research programs.
Among the measurable factors  are:  independent expert review panel ratings on the
extent to which clients utilize EPA research  products;  composite  scores on a client
survey designed to gather data on product utility and perceptions of use; and the results
of bibliometric and/or client document analyses  demonstrating the actual use of EPA
research products.  These factors are applied to measure success in  providing the
results identified in  the research programs that follow.

Science and Technology for Sustainability

      Through  intramural and extramural resources, the Science and Technology for
Sustainability (STS) research program aims to develop models, tools, and technologies
that will give decision makers more options and enable them to make decisions  that
lead to sustainable outcomes. The concept of stewardship recognizes that our nation's
natural resources are the common property of all parts of society.  Effective stewards of
the environment will work to enhance environmental protection and achieve sustainable
outcomes. This program will produce measurable benefits in the form of:

   •  an enhanced scientific and technology base to catalyze innovation for advanced
      environmental protection;
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   •  more efficient  and sustainable  practices,  materials,  and  technologies  with
      improved environmental performance; and

   •  improved  and  scientifically sound  management decisions  and  policies  and
      practices for sustainable resource management.

      More fundamental research to enhance basic sustainability knowledge  and
catalyze environmental stewardship includes Life Cycle Assessment and Material Flow
Analysis  methodological development; theoretical  modeling of sustainable systems;
development  of new  science-based  sustainability  metrics and indicators;  and the
People, Prosperity, and the Planet Student Design Competition program.

      The  regulated community receives  support as they seek to implement more
efficient, sustainable, and protective practices, materials, and technologies that result in
improved environmental stewardship, using the underlying methodologies described
above. Additional research, often with industrial partners, is focused on new industrial
methods, alternative chemicals and industrial practices, including decision support tools
for bench chemists to evaluate  the environmental  dimensions  of new chemicals  and
production  pathways.  The Environmental Technology Verification (ETV)  Program has
been  expanded  to  include a sustainability-focused  effort,  the  Environmentally
Sustainable Technologies  Evaluation  Program.  Quality-controlled  test protocols are
being developed to help verify the capabilities of new technologies.

      A  Sustainable Environmental Systems research program was established  that
draws on economics, ecology, law, and engineering in seeking systems-based solutions
to regional environmental problems.  Two new applied and  educational  extramural
programs have been introduced-the People, Prosperity, and the Planet Student Design
Competition for Sustainability, and the Collaborative Science and Technology Network
for Sustainability.

Economics and Decision Sciences

      The  Economics and  Decision Sciences (EDS)  program  within ORD is an
extramural  program,  based  primarily  on needs  identified  in  the Environmental
Economics Research Strategy (EERS).  EDS research helps identify innovative, cost-
effective  policy  approaches  to address  environmental  challenges and  provides
necessary methods and data for economics analysis of policy effectiveness, leading  to
better decision-making. The EDS program  is coordinated closely with economists doing
related work  in ORD  and with  our research  partners in  EPA's National  Center for
Environmental Economics, who conduct  most  of the Agency's  internal  economics
research.  Because of the breadth of  the need for better economic analyses, the EDS
program  has clients in  virtually every  EPA headquarters office,  as well as many
Regions.    Other  federal,  state, and local government officials,  as well  as private
organizations, also use the results of EDS research.

This program will produce measurable benefits in the form of:


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   •  reduced  uncertainties  and  potential  biases  associated  with  benefit transfer
      methods with estimated values from original studies for ecological and human
      health benefits analysis;

   •  improved understanding of decision-making with respect to compliance behavior
      and  environmental  performance  in  response  to  interventions,   including
      government enforcement, information disclosure, voluntary initiatives, and similar
      programs; and

   •  identification  of regulated   entities'  responses  to  market  mechanisms  and
      incentives,  and  investigation of how market-based programs can be designed to
      improve environmental  quality at the lowest cost.

      The  EERS envisions a dual strategy for achieving improved benefit valuation—
development of benefit transfer methods and development of original benefit estimates
followed by switching to original valuation estimates.

      With its emphasis on analyzing and developing programs to change the behavior
of individuals and organizations, this research will inform EPA's stewardship  initiatives,
identifying the most  effective means of providing  information that  leads to desired
changes in  behavior.

      Research will  also  focus on the use of trading programs for new pollutants,
media, and geographical areas.   This  research area will include investigation  of the
environmental justice  implications of trading programs because of the concern about
"hotspots" in trading programs.

HUMAN CAPITAL

      EPA relies on a core set of competencies to assist the regulated community in
complying with  environmental laws and  regulations;  a comprehensive knowledge of
applicable  requirements;  sector-specific information about  business and   industrial
processes;  an understanding  of best practices;  and,  an  ability to assess  a specific
situation and readily determine how best to advise those regulated entities seeking help
and guidance.  The Agency is also seeking to enhance the abilities of its personnel to
interact and assist those it regulates.  For example,  the Agency expects to focus its
efforts on attracting applicants who are also skilled facilitators and communicators and
on  encouraging  rotational opportunities at the state and  local  levels for current
employees   to  broaden  their  perspectives  and  thereby  enhance  collaborative
relationships between Agency staff and the regulated community. The changing and
increasingly complex array of environmental challenges presents a rich opportunity for
our work with state partners and others in the regulated community to address problems
of both a local and regional nature.  We recognize that a broad spectrum of  regulatory
and stewardship  approaches will  be necessary.  A highly-skilled, well-informed  EPA
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workforce with a  large  capacity for collaborative,  results-oriented  work and the
organizational systems to support it will be the key to our future success.

      EPA employees engaged in developing or  implementing compliance incentives
also possess a body of core competencies that helps them  in fashioning incentives or
guiding  the  regulated community in proactively addressing environmental problems.
EPA attorney/advisors, engineers,  and environmental protection specialists,  among
others,  all  contribute  in reviewing  submitted materials,  assessing  compliance,  and
crafting  the Agency's response, including fines or penalties.  EPA personnel involved in
compliance  monitoring  and  enforcement  similarly  have  their own  core  set of
competencies  as  they endeavor to carry  out  their respective  responsibilities which
include  inspections, civil and criminal investigations,  and administrative and  judicial
enforcement.

PERFORMANCE MEASUREMENT

      The compliance program established annual performance goals and measures to
facilitate tracking  progress  toward  the compliance objective.  For each compliance
program sub-objective, there is a matching annual performance goal,  which in turn, is
supported by a set of performance  measures.  This parallel structure enables annual
progress toward Strategic Plan goals to be easily tracked.

Influence of PART Measures on the Strategic Plan

      EPA's strategy for maximizing protection of human health  and  the environment
through  improved compliance focuses on compliance assurance activities that will  lead
to reductions  of  pollutants  entering  the  environment,  pollutants  being treated, or
pollutants eliminated from  the  environment.  EPA's compliance objective tracks the
pounds  of pollution  estimated to be reduced, treated, or eliminated,  which is also a
performance measure  included  in the Program  Assessment  Rating Tool (PART)
assessment for the compliance program. The four major compliance assurance tools -
assistance, incentives, monitoring, and enforcement - are used in  an integrated fashion
to address  noncompliance  problems and  contribute to the  achievement  of their
respective compliance sub-objectives  and the compliance objective. In addition, EPA
has  incorporated the PART long-term, outcome-oriented measures for the Agency's
tribal General Assistance Program (GAP) grants into the Strategic Plan.

Future Improvements to Performance Measurement

      EPA is working to supplement  the pollutant reduction outcome measure for its
compliance  program with  information that characterizes  the hazard  and potential
exposure of the public to the pollutants.  The compliance program is using air pollution
models  to estimate  the human  health benefits of reductions in  air pollutants.   As a
result, in FY 2005, the compliance assurance program reported that the ten biggest air
pollution cases produced annual human  health benefits valued at over $4.6 billion
dollars,  due to annual  pollutant  reductions of  more than 620 million pounds.   The
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compliance program continues to work with the air program to further expand the types
of information on human health benefits that can be reported for air pollution cases, and
is exploring opportunities to report similar information for cases involving other media.

      In order to more accurately characterize the state of compliance for particular
sectors and regulations, the compliance program began  piloting the use of statistically-
valid compliance rates in 2000.  Though development of pilot rates has proven to be
resource intensive, the program is continuing to work to  identify more efficient ways to
develop  statistically-valid compliance  rates so their  use can  be expanded.   While
continuing to explore  opportunities to expand the use of statistically-valid compliance
rates generally, the program  is focusing on developing  compliance rates for national
priority areas.

      EPA's  compliance  program is  also working to  develop  a set of  nationally
consistent environmental justice indicators (i.e., health, environmental, compliance, and
demographics)  to  identify   and  place  an  emphasis  on  activities  in  potential
disproportionately and adversely affected areas  ("areas with potential environmental
justice  concerns").  This effort is designed to  better protect all communities, including
minority and/or low-income communities.  It will help the Agency report on the impact
that the  compliance  program has had in areas  with potential environmental justice
concerns and on the minority and/or low-income populations  living in these areas.
Experience gained from use of these  indicators will  be used  to  develop specific
environmental justice measures, and to  develop  environmental  justice targets for
compliance assurance activities.

      EPA is committed to continual assessment of performance, and the development
of the  most meaningful performance measures.   The  pollution prevention  programs
have collaborated with states and tribes in developing improved performance  measures.
Through the PART process, the pollution prevention programs continue their extensive
review of performance measures to make them more outcome oriented.

CLOSING THE FEEDBACK LOOP: RESULTS OF PERFORMANCE ASSESSMENTS
AND PROGRAM EVALUATIONS

      EPA met its original priority chemical reduction goal in 2003 (2 years earlier than
anticipated) and has continued to achieve additional reductions while re-setting the goal
for the 2006-2011 Strategic Plan.  The successes of the  early years of the program are
not proving easily  sustainable,  as the  "low hanging   fruit"  of  waste  minimization
opportunities appears to have been reaped.  Future reductions will be more difficult and
require a revised targeting approach.  EPA is working with states to develop a sector
targeting approach that will allow for more direct technology transfer between facilities
involved in similar industrial processes.

      The  Harvard  Regulatory  Policy  Program evaluated  several aspects of the
Performance Track program  including the differences among facilities applying for the
program, the characteristics of facilities motivating them to apply, and the differences in
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environmental performance between members and non-members.  The evaluation has
reinforced the  importance  of  EPA recognition as  an incentive  for environmental
improvements.  The Performance  Track program  will  take  steps  toward  increasing
recognition and branding associated with the program.  It has also led the Agency to
refocus  recruiting efforts at the corporate level  while identifying firms that are taking
positions of environmental  leadership.  The study also stressed the importance of low
transaction costs as a way of encouraging participation in innovative programs.  The
study has confirmed, based on several indicators of environmental performance, that
EPA has  been successful in identifying the better-performing firms in the selection
process for Performance Track.

      The Enforcement  and  Compliance   program   has  undergone  three  PART
assessments since FY 2003:  civil enforcement (2003), criminal  enforcement (2004),
and pesticides grants (2005). The nature and scope of the recommendations made by
OMB as a result of each PART assessment  have been focused on  individual  program
areas and have been limited to certain  aspects of OECA's program  management. For
example, OECA continues to work to improve and refine outcome  measurement and to
strategically expand the use of statistically-valid compliance rates.  These activities are
directly related to PART follow-up actions.

Emerging Issues and External Factors

      The rapid technology change of  today's economy presents  unique opportunities
and challenges. By 2011, significant scientific advances can be expected in the areas of
nanotechnology, genomic research, computational toxicology, computer sciences, and
the cognitive and  behavioral sciences.  The  development and application of emerging
nanotechnologies, biotechnologies, and sensor technologies could  significantly enhance
EPA's ability to protect human health and the environment.  Progress in these frontier
areas will also directly affect future direction of EPA's research  programs.   EPA's
Science and Technology for the Sustainability framework emphasizes these research
areas  to support  a  forward-looking,  integrated,  and  preventive  approach  to
environmental protection.

      Advances in measurement  technology could have significant impacts  on EPA
programs. As  more sensitive technology to detect and  measure emissions  is  installed
in facilities, emissions reporting could become more accurate and  emission rates could
be found to be either higher or lower than previously reported

      Distributed  sensor  network technologies,  remote sensing, and  hyper  spectral
imaging are developing rapidly and have the potential to support compliance monitoring
by increasing the frequency and speed of data  collection  and transmission, improving
data quality,  enabling  data integration,  and facilitating data  access and data  sharing.
Sensors could  facilitate the acquisition and  use of empirical data and  facilitate the
tracking and analysis of the flow of materials and elements throughout the industrial
cycle.
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       Emerging applications of nanotechnology could present new  opportunities for
pollution       prevention       and        environmental        stewardship        (see
http://www.epa.gov/osa/nanotech.htm).  Nanotechnology applications have potential for
reductions in energy  demand,  development  of cleaner energy and  improvements in
manufacturing process efficiency leading to reduced material use and waste generation.
Pollution  prevention  programs can  provide  a  forum  for industry  and  academia  to
exchange  information  on   the  environmental   effects   and   benefits   of  innovative
nanomaterials, and enable more environmentally responsible  manufacturing  processes
and product design.  A growing  number of institutional players  are picking up the call for
policymakers to study  nanotechnology and develop policy responses.
       At  the  same  time,  these emerging  technologies  may  present  novel  risks.
Anticipating these  risks and  developing  tools for their identification will be important as
these technologies are developed and enter the marketplace.
1 Complying actions are actions taken by a facility to address deficiencies, which are potential violations, identified
during on-site inspections and evaluations. Examples of a complying action include correcting record keeping
deficiencies, requesting a permit application, improving pollutant identification (labeling, manifesting, etc.),
improving management practices (storage, training, etc.) or reducing pollution through use reduction, industrial
process change, or emissions or discharge change.

2 U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics. Green Chemistry Web Site,
http://www.epa.gov/greenchemistry. Washington, DC. Accessed September 9, 2006.

3 U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics. Design for the Environment
Web Site: http://www.epa.gov/dfe.  Washington, DC. Accessed September 9,  2006.

4 U.S. Environmental Protection Agency, Office of Enfocement and Compliance Assurance. National
Environmental Policy Act Web Site: http://www.epa.gov/compliance/basics/nepa.htmlfeequirement. Washington,
DC. Accessed September 9, 2006.

 A tribe is counted as having an environmental program for the purposes of this measure if the tribal government
has taken at least one of the following actions, in combination with having "an organizational structure which
includes EPA-funded environmental office or coordinator that has been staffed in the most recent year":

A)     Complete a Tier III TEA, as evidenced by a document signed by the tribal government and EPA.
B)     Establish environmental laws, codes, regulations, ordinances, resolutions, policies, or other compulsory
       environmental compliance program, as evidenced by a document signed by the tribal government.
C)     Complete solid and/or hazardous waste implementation activities.
D)     Complete an inter-governmental environmental agreement (e.g. state-tribe MO A, federal-tribe MO A, etc).

EPA is seeking comment on other areas that would be considered evidence of the implementation of an
environmental program. Proposed additional actions may include:

E)     Approve a tribal environmental plan which includes an assessment of the reservation environment,
       establishes a plan of action to address environmental concerns, and sets goals for public health and
       environmental outcomes. This plan must be approved by the tribal government;
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F)     Tribal environmental programs funded entirely by tribal governments, for which EPA provided
       substantial technical assistance to the tribe in program development.
6 Intertribal consortia are groups of federally -recognized Tribes that meet the criteria for EPA purposes, that join to
work together.
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