JNACEPT
            Shaping the Nation's Environmental Policy
           National Advisory Council for


       Environmental Policy and Technology
             NACEPT's Comments on




EPA's Draft 2009-2014 Strategic Plan Change Document
                December 30, 2008

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Table of Contents


I. Introduction	2

II. Overarching Questions	2

Question 1: Are the identified target areas the right ones?	2

Question 2: Are the proposed strategies and measure sufficient?	5

Question 3: Is the Change Document sufficiently integrated with other EPA planning initiatives
and documents?	8


III. Answers to Specific OCFO Questions	9


Appendices	12

Appendix I:  Specific NACEPT Comments on Proposed 2009-2014 Strategic Measurement
Framework	12

Appendix II: Review Questions from EPA's Office of the Chief Financial Officer	78

Appendix III: Examples of Regulatory Innovation	80

Appendix IV: NACEPT Strategic Plan Workgroup Members	82

Appendix V: Public Comments	83

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I.  Introduction

The Office of the Chief Financial Officer (OCFO) asked NACEPT to review the 2009-2014
Strategic Plan Change Document and provide feedback and suggestions related to the proposed
changes and long-term measures. In addition, several specific questions were asked about four
of the Agency's goals. The request from EPA is located in Appendix 2 of this NACEPT advice
letter. NACEPT established a workgroup to address the details of this Agency request and the
entire Council has taken the opportunity to review and approve this response.

This advice letter has five components. NACEPT organized consideration of the overarching
questions into three sections—Are the identified target areas the right ones?, Are the proposed
strategies and measures sufficient?, Is the Change Document sufficiently integrated with other
EPA planning initiatives and documents?  The first three components of this NACEPT advice
letter provide responses to these questions.  The fourth component provides answers to the
Specific Follow-up Area questions NACEPT was asked to consider. The fifth component
(Appendix I) provides comments and suggestions for modifying some of the proposed
performance measures to make them better understood and more clearly related to the targeted
areas and goals of the Agency. In addition, Appendix III offers more details about examples of
possible regulatory innovation initiatives.
II. Overarching Questions

Question 1: EPA has identified nine targeted areas....Are these areas the right ones?

EPA is now facing a once-in-a-generation opportunity to refocus and take bold steps. NACEPT
urges that this opportunity be embraced in the Strategic Plan Change Document and the 2009-
2014 EPA Strategic Plan.  In this context, we support OCFO's approach of targeting a limited
number of important areas for special attention. All should be united by the need for EPA to
operate with a new paradigm of sustainability, and should be measured by success in achieving
sustainability-related goals.

We recommend that these areas be chosen based on several criteria:

    •   Areas that urgently require attention,
    •   Areas that pose the largest problems that need to be solved,
    •   Areas where significant changes in strategy are critical,
    •   Areas where new approaches to performance management are needed, and
    •   Areas where EPA can make the most significant improvements.

By  applying all of these criteria, Climate Change stands out as the preeminent issue for focused
attention. The targeted areas OCFO has identified in the Change Document include the two key

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aspects of the climate challenge:  reducing greenhouse gas emissions and mitigating the impacts
of climate change.  NACEPT strongly endorses OCFO's identification of these areas for priority
attention and recommends that they be singled out for special emphasis in the 2009-2014 EPA
Strategic Plan. It would be inappropriate today to treat Climate Change as having a similar level
of importance as other targeted areas such as Import Safety.

It is urgent and essential that EPA step forward to take a major role among federal agencies in
addressing Climate Change.  The urgency and complexity of the issue are unprecedented in the
environmental field.  The Strategic Plan should define a federal leadership and coordinating role
for EPA. It should highlight the importance of internal cross-media coordination, regulatory
innovation and international cooperation for responding to the climate challenge. It should
contribute to the debates about alternative regulatory approaches by providing scientifically and
technically credible information to those making legislative decisions. It should anticipate how
EPA can support these new regulatory GHG strategies and identify programs across the Agency
that need to be coordinated around this new priority.

To reinforce the urgency of the climate challenge, we recommend that EPA redo the Strategic
Plan in one year to be more fully in keeping with the new Administration's priorities regarding
Climate Change  and other environmental issues.

While we believe that climate deserves to be singled out as uniquely important, we favor
OCFO's approach of identifying several other priority areas. Whether or not the particular areas
OCFO has identified are the best areas is difficult to assess, but we  believe they are reasonable
choices. We do recommend, however, that in the Strategic Plan itself a fuller rationale for these
particular choices be set out.  We also urge that that two other potential topics be considered for
designation as targeted areas:

   1. Water Resource Sustainability. NACEPT's reports on Sustainable Water Infrastructure
      make the case that this topic is sufficiently important to merit a separate delineation. It is
      an area where EPA currently lags and could make significant improvements. At a
      minimum, EPA will likely be called upon to significantly increase its funding of both the
      Drinking Water and Clean Water State Revolving Fund programs under an economic
      stimulus package and should use the opportunity to aggressively promote and provide
      incentives for sustainable infrastructure projects. Moving water, whether for drinking,
      municipal, industrial or agriculture supply or for water treatment, expends energy, often a
      significant percentage. This provides one more major reason for using full natural
      (green) infrastructure approaches on a watershed/ landscape scale as part of water
      Sustainability.

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   2.  Support for Technology Development and Commercialization.  The technology
       initiatives discussed in NACEPT's subcommittee reports on environmental technology
       and venture capital financing for bringing new technologies to the marketplace also merit
       inclusion considering the large role such initiatives could play in fostering an
       environmental revolution in technology.

Adding these two topics leads to the following set of targeted areas:

       •   Climate Change
              o  Reductions in GHG emissions
              o  Impacts of Global Climate Change
       •   Water Resource Sustainability
       •   Sustainable Agriculture
       •   Contaminants
       •   Import Safety
       •   Enforcement/Compliance Measurement Approach
       •   Improving Program Implementation in Indian Country
       •   Research Strategic Directions and Targets
       •   Support for Technology Development and Commercialization
       •   Environmental Indicators, Monitoring, and Related Information

Final decisions about targeted areas should be made in the context of the criteria set out above
and the emerging priorities of the incoming administration.

We appreciate the approach taken in the Change Document to identifying indicators of progress
within the priority areas, but we do not believe the continuation of the five goal approach will be
the best way to track progress over time, primarily because many of the targeted areas will
require cross-media efforts and the current five-goal approach largely highlight single media
initiatives.  Nevertheless, there is rationale for keeping the approach in this time of transition and
letting the incoming administration establish its own goals.

The Change Document does indicate that working with such indicator-based initiatives will
necessitate cross-program activities resulting in outcomes under more than one goal. However,
it does not speak strongly enough to perhaps the most important challenge facing the agency, that
further major steps of environmental progress require a new level of collaborative problem
solving. Many of the challenges ahead for the EPA and for the nation's environment are multi-
media or not even directly connected to the Agency's traditional environmental media
approaches. In order to address them successfully,  EPA must achieve better integration and
active collaboration between its programs and improve its ability to work in partnership with

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other federal agencies and with states, tribes and other external stakeholders to understand the
problems and to develop and implement solutions.

During the planning, therefore, it will be important to devise a cross-program tracking system to
be able to report on progress on larger cross-program activities.  In fact, success in demonstrating
progress toward larger environmental goals (e.g. reduction of GHG emissions) involving actions
by two or more program offices could be one of the more valuable procedural outcomes of this
entire planning and implementation process.
Question 2: Are the strategies and measures EPA has identified sufficient for addressing the
areas EPA has targeted for change?
A.  Strategies

By and large we notice a positive shift towards strategies that approach environmental issues on
a more thorough, sustainability-oriented basis. We note, for example, a greater emphasis on
smart growth policies, sustainable materials management, green site remediation practices, and
sustainable agriculture. Several strategies appear to emphasize collaboration with external
partners, for example EPA's proposed effort to promote "green infrastructure."  Recognizing that
EPA cannot achieve environmental quality working on its own, NACEPT called for
collaborative  approaches in its report, Everyone's Business: Working toward Sustainability
through Environmental Stewardship and Collaboration.

We recommend that the Strategic Plan emphasize innovative regulatory strategies more strongly.
For example,  the issues related to global impacts of Climate Change can be expected to require
new views about the content and pace of change of regulatory approaches that must be
coordinated with other agencies, states,  and tribes.  Implementation of new energy-related
technology on a timely basis will require continued coordination of technology development and
regulatory responses with other federal agencies including the Department of Energy. Other
examples of regulatory innovation that could help EPA move more quickly to achieve the
expectations of this Strategic Plan include changes in permitting and inspection patterns in the
National Pollutant Discharge Elimination System (NPDES) program in order to improve the
effectiveness  of the program. Similarly, adoption of the Environmental Results Program that
EPA has helped develop in several states could help reduce the need for some enforcement
resources while achieving improved compliance. A move by EPA toward differential oversight
of states and tribes depending on the level of environmental performance would be expected to
achieve more beneficial environmental results without requiring additional resources. These
examples of environmental innovation are described in more detail in Appendix III.

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With regard to the Agency's newly revised pollution prevention program strategy, we hope that
pollution prevention will once again become a front-line initiative within the Agency. While
there may still be debate about whether the exact areas of the current initiative are the most
critical, the importance of pollution prevention should be strongly emphasized.

We find that many of the strategies EPA is proposing lack boldness and urgency. With respect
to boldness, the strategies to reduce greenhouse gases, in particular, seem to be placeholders for
much more dramatic action. Preparing for, preventing, and mitigating the impacts of Climate
Change demand more than just the same strategies (voluntary programs). We recommend that
EPA take steps now to plan for a regulatory greenhouse gas reduction program by identifying
programs across the agency that need to be coordinated around this new priority and reinstated
national debate (e.g. review of scientific capabilities, assessment of regulatory and compliance
options, preparedness to respond to congressional requests as well as programs aimed at
adaptation to flooding, droughts, sea level rise, higher intensity storms, disrupted weather
patterns,  changes in species distribution,  and other expected consequences of rapidly changing
global temperatures).

With respect to urgency, the section on Impacts of Global Climate  Change indicates that a report
will be available on such impacts at the national level in 2012, some four years away. We
recommend that some initial assessment should be a priority. In the area of contaminants,
waiting until 2010 or 2011 for rulemaking regarding underground injection of carbon dioxide is
not acceptable if EPA considers this approach to be very important for controlling the release of
greenhouse gases. Again, we recommend that accelerating this strategy should be a priority.

While EPA is working to address issues of Import Safety, a companion program of some type
addressing issues of Export Safety and Compliance would be very  useful in the area of
encouraging technology development.  The manufacturing, material content, and take-back
regulations of the EU and other jurisdictions present barriers for technology development for
many US manufacturers.  Assistance by EPA and other federal agencies such as the Department
of Commerce in addressing these concerns could be helpful from both an environmental
protection perspective and with regard to economic development.

Apparently missing from the Draft Plan is a strategy to address environmental challenges posed
by the current state of the economy.  We recommend that EPA consider approaches that will
allow it to make continued progress toward its goals in the likelihood that it does not receive all
the resources it needs. One such adaptive strategy EPA might consider is differential oversight
of delegated state programs. While current credit problems and bonding challenges are
hopefully temporary, if prolonged they may threaten the availability of funding for
municipalities and the private  sector utilities to continue the maintenance and upgrade of water
infrastructure.  We recommend that EPA address that possibility in the Strategic Plan.

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B. Measurement framework

It is time for EPA to revisit the question of appropriate sustainability measures.  This would
require, as a theoretical example, that hypoxia not be the only goal in looking at setting nutrient
limits in TMDLs, but that the balance of the food web, including native phytoplankton, be the
goal.  Another example would be that life-cycle assessments of energy alternatives be performed
to establish carbon reduction goals, rather than set goals based on a superficial measurement that
may, in fact, lead to unintended consequences.

We find the side-by-side comparison of the 2006-2011 and 2009-2014 strategic management
framework very helpful.  However, many strategic measures are still very difficult to interpret.
Echoing our comments on the 2006-2011  Strategic Plan, we recommended that each strategic
measure include the following: (1) a baseline of environmental quality when EPA initiated a
given program, (2) current condition, (3) how much further environmental quality must improve
to achieve EPA goals, (4) what increment of progress EPA hopes to achieve over the next five
years, stated as both a percentage improvement as well as what that percentage represents in
pounds of pollution reduced or numbers of people served, and (5) some indication of how that
increment will be accomplished. The proposed plan seems to have lost sight of such a common
sense approach. We recommend that OCFO step back and try to consider the plan from an
outsider's perspective. All measures should be stated in terms the public can understand and
should compare the proposed measure to the overall goal.

We note that EPA is proposing to eliminate several strategic measures: for construction and
demolition materials recycling, Local Emergency Planning Committee activity, and two of three
risk management planning measures.  EPA proposes to limit its measure for municipal solid
waste recycling to its own activities. While we recognize that finding ways to measure the
effectiveness of these programs and activities poses challenges, we cannot support eliminating a
measure from the strategic plan for that reason alone. We recommend that EPA should first
determine whether these activities are desirable on their merits.

Consistent with our comments regarding strategies, we find that many sub-objectives and
strategic measures are lacking in ambition. For example, the strategic measure for sub-objective
1.3.3 "Reduce Exposure to Excess UV Radiation," includes the target date of 2165 for a
reduction of skin cancers by 50 percent. That is roughly seven generations.  Are there  no actions
that EPA might consider or encourage to achieve that target in a shorter period? According to
the plan EPA has proposed, goals of safe drinking water and attainment of water quality
standards will not be fully achieved until the 22nd century.  We call for bolder action.

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Question 3: Is the Change Document Sufficiently Integrated with EPA's Other Planning
Activities and Documents?

The Change Document does discuss relationships with other EPA planning activities with a
particular emphasis on the Report on the Environment (ROE) as a key component of the process
of determination of new areas of focus for the Agency. NACEPT agrees that connections with
the conditions and challenges raised in the ROE process are valid approaches to setting priorities
for the Agency. However,  in a larger sense, this question is difficult to answer, because the
relationships between the goals and the measurement framework to the objectives and to other
EPA planning initiatives including the budget are unclear.

All of the goals and components of the measurement framework may be important—clearly each
is important to some component of EPA.  However, it is not possible in this document to
determine the relationship of each goal and each measurement factor to the overall plan and
particularly to the critical targeted areas. These relationships should be more clearly stated in the
writing of the plan. For example, the Strategic  Plan will have an important role in setting budget
priorities and should be closely related to the Agency's future Performance and Accountability
Reports (PAR).

It appears unlikely that all components of the performance measurement framework will have
equal standing in budget discussions or in the overall Agency performance assessment.  The
Strategic Plan would be more helpful with some discussion about the priorities that have been
established or will be established among the performance measures. Specifically, the ability to
recognize which performance measures are related to the Report on the Environment findings
and which measures are important components  of PART would clarify many questions. Such
information would  assist a reader in understanding what EPA considers to be the most critical
activities and tasks for this  planning period and could also lead to productive discourse about
necessary resources and participation by other federal  agencies and the private sector.

A number of topical areas such as agriculture, fertilizer use, and sea surface temperatures that are
mentioned in the Introduction of the Change Document as problems do not seem to appear in the
performance measures section of the document. This appears to reflect a lack of connection
between some of the issues identified as emerging from the Report on the Environment and the
details of the planned activities of the Agency.  More discussion of this apparent  disconnect
would help readers of the Strategic Plan to understand how EPA anticipates addressing these
important issues. Alternatively, the appearance of performance measures for these issues would
complete the process.

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III. Answers to Specific OFCO Questions

Goal 1: Clean Air and Global Climate Change

Organizations for possible collaboration with EPA research program to leverage local
government efforts in identifying and developing global climate change strategies include:

      Western States Governors Association
      National Tribal Environmental Council
      National Congress of American Indians
      National Association of Counties
      International Council for Environmental and Local Initiatives
      United States Conference of Mayors


Goal 2: Clean and Safe Water

EPA is requesting a replacement shellfish measure:

NACEPT suggests that EPA measure the percentage of shellfish beds that are monitored as well
as the percentage that are closed  to harvesting due to pollution. Through their experience with
305(b) reporting, states may have helpful experience to inform EPA's development of this
measure.

Another approach could be to report the total area of known, safe shellfish beds versus the total
area of known, closed shellfish beds.

Response to request for suggestions and reactions related to improving the suite of water quality
measures:

      NACEPT was not able to provide a meaningful response to this request in the time
      available.
Goal 4: Healthy Communities and Ecosystems

Organizations for collaboration with EPA's research program to leverage local government
efforts in identifying and developing global climate change strategies include:
       Western States Governors Association
       National Tribal Environmental Council
       National Congress of American Indians
       National Association of Counties

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       International Council for Environmental and Local Initiatives
       United States Conference of Mayors

Organizations for providing feedback on partnerships for developing ecological science
indicators that have been useful to local government decision-makers:

       Western States Governors Association
       National Tribal Environmental Council
       National Congress of American Indians
       National Association of Counties
       International Council for Environmental and Local Initiatives
       United States Conference of Mayors


Goal 5: Compliance and Environmental Stewardship

EPA's enforcement program is moving to a new problem-based performance measurement
structure and is interested in feedback on this approach overall.

NACEPT acknowledges that effective strategies for measuring compliance and enforcement are
difficult to develop and implement. While NACEPT appreciates EPA's effort to move away
from activity-based measures (e.g. "How many facilities did EPA inspect?") and instead focus
on environmental outcomes (e.g. "Is the air and water getting cleaner?"), the outcomes that the
Office of Enforcement and Compliance Assurance (OECA) has proposed lack context and
relevance. Measures that the public might better understand include:

   •   What percent of all regulated facilities are in compliance (compliance rate)? If the goal is
       100%, where are we now relative to that goal and what are the major problems
       preventing us from achieving it? NACEPT acknowledges that such an approach is
       complicated, for example the concept of "total regulated facilities" likely would be at best
       an estimate.  Further, what would "in compliance" be based upon? This may not be
       workable or meaningful goal if a minor record-keeping offense can potentially equal a
       major toxic release. This would not be a desirable or meaningful result in
       communicating progress to the public. One strategy OECA might consider as a model
       for addressing these concerns is the National Pretreatment Program in the Office of
       Water.

   •   With respect to the number of pounds of pollutants reduced, a denominator is needed so
       as to answer the question, "Pounds reduced compared to what?"  To know if the number
       is meaningful, EPA would need to back it up by an analysis such as:

          o  To meet water quality standards, x pounds of pollutant y needs to be reduced. We
             can reach this goal in z years if, every year, q percent is reduced.
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Reactions and ideas regarding the suggested EPA approach of defining "environmentally
significant" pollutants as nutrients, pathogens, mercury, other metals, sediment/turbidity, toxic
organics, pH, temperature, and salinity.
While NACEPT agrees that focusing attention upon significant pollutants may be helpful and
that using the 303(d) list of impairments makes a great deal of sense, this focus should not come
at the expense of addressing the problem of "non-significant" pollutants. Both should be
discussed. NACEPT urges EPA to make explicit its rationale for limiting its reporting to
pollutants of "significance" rather than all pollutants.  Making significance distinctions is not
without problems, and showing significant pollutants only might raise suspicions that other
problems are not important, or are being masked.
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          APPENDIX I: SPECIFIC NACEPT COMMENTS ON PROPOSED 2009-2014
          STRATEGIC MEASUREMENT FRAMEWORK
Goal 1: Clean Air and Global Climate C
Current (2006-2011) Strategic Plan

Objective
Sub-objective
Strategic Target
"hange
Prooosed (2009-2014) Strategic Plan

Objective
Sub-objective
Strategic Measure
                      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.
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.
1.1 Healthier Outdoor Air: Through 2014, 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.
   1.1.1 Ozone and PM2.5: By 2015, working with
   partners, improve air quality for ozone and
   PM2.5.
   1.1.1 Reduce Criteria Pollutants and Regional Haze
      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 ozone in all monitored counties by 14

     percent from the 2003 baseline, compared to the eight

     percent cumulative reduction expected by 2008.
      By 2015, reduce the population-weighted
      ambient concentration of PM2.5 in all
      monitored counties by 6 percent from the 2003
      baseline.
     By 2015, reduce the population-weighted ambient

     concentration of PM2.5 in all monitored counties by
     percent from the 2003 baseline, compared to the 4
     percent cumulative reduction expected by 2008.
      By 2011, reduce emissions of fine particles
      from mobile sources by 134,700 tons from the
      2000 level of 510,550 tons.
     By 2014, reduce emissions of fine particles from
     mobile
     sources by 51,000 tons from a 2009 baseline level of
     417,000 tons.
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  By 2011, reduce emissions of nitrogen oxides
  (NO ) from mobile sources by 3.7 million tons
  from the 2000 level of 11.8 million tons.
By 2014, reduce emissions of nitrogen oxides (NO )
from

mobile sources by 2.1 million tons from a 2009
baseline level

of 9.3 million tons.
  By 2011, reduce emissions of volatile organic
  compounds from mobile sources by 1.9 million
  tons from the 2000 level of 7.7 million tons.
By 2014, reduce emissions of volatile organic
compounds

from mobile sources by 1.1 million tons from a 2009
baseline level of 5.9 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 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 2018, visibility in western Class I areas will
  improve by 5 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 2018, visibility in western Class I areas will
improve by 5 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, 30 additional
  tribes (6 per year) will have completed air
  quality emission inventories. (FY 2005
  baseline: 28 tribal emission inventories.)
By 2014, with EPA support, 47 additional tribal air
quality emission inventories will be completed. (FY
2007 baseline: 37 tribal emission inventories.)
Comment: What is the baseline number of total tribes in the customer universe? If it is very small, then
this could represent significant progress. If it is very large, the progress could be insignificant to
meaningless.
  By 2011, 18 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: 8 tribes.)
By 2014, with EPA support, 12 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
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                                                   Rule).

                                                   (FY 2007 baseline: 10 tribes.)
Comment: What is the baseline number of total tribes in the customer universe? If it is very small, then
this could represent significant progress. If it is very large, the progress could be insignificant to
meaningless.	
1.1.2 Air Toxics: By 2011, reduce the risk to
public health and the environment from toxic air
pollutants by working with partners to reduce air
toxics emissions and implement area-specific
approaches.
1.1.2 Reduce Air Toxics
  By 2010, reduce toxi city-weighted (for cancer
  risk) emissions of air toxics to a cumulative
  reduction of 19 percent from the 1993 non-
  weighted baseline of 7.24 million tons.
  By 2014, reduce toxicity-weighted (for cancer risk)
  emissions

  of air toxics to a cumulative reduction of 34 percent
  from the 1993 non-weighted baseline of 7.24 million
  tons, maintaining

  the 34 percent cumulative reduction expected by 2006.
   Comment:  This sub-objective states that the desired reduction of 34 percent from the 1993 baseline
   was achieved in 2006.  Is it really the EPA's position that no further progress can be made in this
   regard, and that the program is in static "maintenance mode?"
  By 2010, reduce toxicity-weighted (for non-
  cancer risk) emissions of air toxics to a
  cumulative reduction of 55 percent from the
  1993 non-weighted baseline of 7.24 million
  tons.
  By 2014, reduce toxicity-weighted (for non-cancer
  risk) emissions of air toxics to a cumulative reduction
  of 59 percent from the 1993 non-weighted baseline of
  7.24 million tons,  compared to the 58 percent
  cumulative reduction expected by 2006.
Comment: This sub-objective states that a 58 percent reduction was achieved between 1993 and 2006
(average annual reduction of 4.5 percent), yet the anticipated further reduction through 2014 will be an
additional 1 percent (average annual reduction of 0.125 percent).  What is the logical basis for the
dramatic change in expectation?
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1.1.3 Chronically Acidic Water Bodies: By
2011, due to progress in reducing acid deposition,
the number of chronically-acidic water bodies in
acid-sensitive regions of the northern and eastern
United States should be maintained at or below
the 2001 baseline of approximately 500 lakes and
5,000 kilometers of stream-length in the
population covered by the Temporally Integrated
Monitoring of Ecosystems/Long-Term
Monitoring Survey. The long-term target is a 30
percent reduction in the number of chronically-
acidic water bodies in acid-sensitive regions by
2030.
1.1.3 Reduce the Adverse Effects of Acid Deposition
                                                    By 2014, due to progress in reducing acid deposition,
                                                    the
                                                    number of chronically-acidic water bodies in acid-
                                                    sensitive regions of the northern and eastern United
                                                    States should be maintained at or below the 2001
                                                    baseline of approximately
                                                    500 lakes  and 5,000 kilometers of stream-length in the
                                                    population covered by the Temporally Integrated
                                                    Monitoring
                                                    of Ecosystems/Long-Term Monitoring Survey. The
                                                    long-term target is a 30 percent reduction in the
                                                    number of chronically-acidic water bodies in acid-
                                                    sensitive regions by 2030.	
Comment: This sub-objective states the 2014 goal is to achieve the 2001 baseline, and the 2030 goal is a 30
percent reduction in impacted water bodies, but does not identify the baseline from which the long-term
target is set.
  By 2011, reduce national annual emissions of
  sulfur dioxide (SO ) from utility electrical
  power generation sources by approximately
  8.45 million tons from the 1980 level of 17.4
  million tons, achieving and maintaining the
  Acid Rain statutory SO2 emissions cap of 8.95
  million tons.
  Through 2015, maintain the national annual emissions
  of

  sulfur dioxide (SO ) from utility electric power
  generation sources at a level below 8.95 million
  annual tons, compared to the 1980 level of 17.4
  million tons per year.
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      By 2011, reduce total annual average sulfur
      deposition and mean ambient sulfate
      concentration by 30 percent from 1990
      monitored levels of up to 25 kilograms per
      hectare for total sulfur deposition and 6.4
      micrograms per cubic meter for mean ambient
      sulfate concentration.
     By 2014, reduce total annual average sulfur deposition
     by 20 percent from 2001 monitored levels of up to 15
     kilograms per hectare for total sulfur deposition.
      By 2011, reduce total annual average nitrogen
      deposition and mean total ambient nitrate
      concentration by 15 percent from 1990
      monitored levels of up to 11 kilograms per
      hectare for total nitrogen deposition and 4.0
      micrograms per cubic meter for mean total
      ambient  nitrate concentration.
     By 2014, reduce total annual average nitrogen
     deposition by 30 percent from 2001 monitored levels
     of up to 5 kilograms per hectare for total nitrogen
     deposition.
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.
1.2 Healthier Indoor Air: Through 2014, working with
partners, reduce human health risks by reducing exposure to
indoor air contaminants through the promotion of voluntary
actions by the public.
   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.	
   1.2.1 Reduce Exposure to Radon
                                                       By 2014, the number of future premature lung cancer
                                                       deaths prevented annually through lowered radon
                                                       exposure will

                                                       increase to 1,250 from the 2006 baseline of 644 future

                                                       premature lung cancer deaths prevented.
   Comment:  This sub-objective delays attainment of the 1,250 deaths prevented level for two full years.
   EPA should identify the cause for this delay.  EPA should also identify the number of future premature
   cancer deaths projected to result from radon exposure (full target universe) to determine the impact of
   Agency activities on the overall number of projected premature deaths.	
   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
   1.2.2 Reduce Exposure to Asthma Triggers
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   populations.
                                                       By 2014, 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.
   Comment:  This sub-objective delays attainment of the 6.5 million actions level for two full years. EPA
   should identify the cause for this delay.  The Agency should also identify the size of the full action
   universe needed to fully eliminate indoor asthma triggers. Is 6.5 million the entire universe, a substantial
   majority or just a small portion of the necessary actions?	
   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.
   1.2.3 Reduce Exposure to Indoor Air Contaminants in
   Schools
                                                       By 2014, the number of schools implementing an
                                                       effective

                                                       indoor air quality management plan will increase to
                                                       48,000

                                                       from the 2002 baseline of 25,000.
   Comment:  EPA should identify the total universe of schools that might be required (or at least expected)
   to implement an indoor air quality management plan. Is 48,000 the entire universe, a substantial majority
   or just a small portion of the regulated universe?
1.3 Protect the Ozone Layer: 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.
1.3 Protect the Ozone Layer: Through 2014, continue
efforts to restore the earth's stratospheric ozone layer and
protect the public from the harmful effects of UV radiation.
                                                    1.3.1 Heal the Ozone Layer
                                                       By 2014, 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. (1980
                                                     17

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                                                      baseline

                                                      = 1.8ppb.)
   Comment: What is the expected peak total effective equivalent stratospheric chlorine level expected in
   2014? Over what timeline will a reduction to 3.4 parts per billion be attained? What actions related to
   this projected reduction will EPA measure and hold itself accountable for? Is there scientific justification
   for a final reduction target that is twice the 1980 baseline level?	
                                                     1.3.2 Reduce Emissions of Ozone-Depleting
                                                     Substances
      By 2015, reduce U.S. consumption of Class II
      ozone-depleting substances to less than 1,520
      tons per year of ozone depleting potential from
      the 2003 baseline of 9,900 tons per year.
     By 2015, reduce U.S. consumption of Class II ozone-

     depleting substances to less than 1,520 tons per year
     of ozone depleting potential from the 2009 baseline
     of 9,900 tons per year.
                                                     1.3.3 Reduce Exposure to Excess UV Radiation
      By 2165, reduce the incidence of melanoma
      skin cancer to 14 new skin cancer cases avoided
      per 100,000 people from the 1990 baseline of
      13.8 cases  avoided per 100,000 people.
     By 2165, reduce the incidence of melanoma skin
     cancer to 14 new skin cancer cases per 100,000
     people from the 2005 baseline of 21.5 cases per
     100,000 people.
   Comment: The target date for an effective 50 percent reduction in skin cancers is 156 years out (roughly
   7 generations). Are there no actions that EPA might consider or encourage to achieve this target in a
   shorter time period?
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.
1.4 Radiation: Through 2014, working with partners,
minimize unnecessary releases of radiation and be
prepared to minimize impacts to human health and the
environment should unwanted releases occur.
                                                     1.4.1 Monitor the Environment for Radiation
      By 2011, 77 percent of the U.S. land area will
      be covered by the RadNet ambient radiation air
      monitoring system. (2001 baseline is 35percent
      of the U.S. land area.)
     By 2014, 51 percent of the U.S. population will be in
     proximity to an ambient radiation monitoring system
     that provides scientifically sound data for assessing
     public
     exposure resulting from radiological emergencies.
     (2001 baseline is 22 percent of U.S. population.)
      Comment:  The baselines and targets reported in the 2011 sub-objective and the 2014 sub-objective
      appear to suggest that the RadNet is actually being deployed more for protecting land than people. By
      2001, 22 percent of the population lived on the first 35 percent of land area in which the RadNet was
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      deployed.  EPA projects that land coverage will reach 77 percent by 2011 and population coverage will
      reach 51 percent by 2014, leaving the remaining 49 percent of the population (on the remaining 23
      percent land area) unmonitored. The 2014 coverage target could be substantially bettered if the
      RadNet were deployed where the people are.	
                                                    1.4.2 Prepare for and Respond to Radiological
                                                    Emergencies
      By 2011, the radiation program will maintain a
      90 percent level of readiness of radiation
      program personnel and assets to support federal
      radiological emergency response and recovery
      operations. (2005 baseline is a 50 percent level
      of readiness.)
     By 2014, the radiation program will maintain a 90
     percent

     level of readiness of radiation program personnel and
     assets

     to support federal radiological emergency response
     and

     recovery operations. (2007 baseline is an 83 percent
     level of readiness.)	
      Comments:  EPA is reporting a 33 percent increase in personnel and asset readiness between 2005 and
      2007, but now planning it will take 5 additional years to achieve the next 7 percent improvement in
      readiness. The Agency should justify both the reasons for the steep drop-off in increased readiness and
      the 2-year delay in achieving the 90 percent readiness level.  Given the critical nature of radiological
      emergencies, when might 100 percent readiness be achieved?
1.5 Reduce Greenhouse Gas Intensity: By 2012, 160
million metric tons of carbon equivalent (MMTCE) of
emissions will be reduced through EPA's voluntary
climate protection programs.
1.5 Reduce Greenhouse Gas Emissions: Through 2014,
continue to reduce greenhouse gas emissions through
voluntary climate protection programs that accelerate the
adoption of cost-effective greenhouse gas reducing
technologies and practices.
       1.5.1 Buildings Sector: By 2012, 46 MMTCE
       will be reduced in the buildings sector
       (compared to the 2002 level.)	
   1.5.1 Reduce Greenhouse Gas Emissions
                                                       By 2014, 53 MMTCE will be reduced in the
                                                       buildings sector (compared to 31 MMTCE reduced in
                                                       2006) through EPA's voluntary climate protection
                                                       programs.
       1.5.2 Industrial Sector: By 2012, 99 MMTCE
       will be reduced in the industry sector
       (compared to the 2002 level).
     By 2014, 112 MMTCE will be reduced in the
     industry sector (compared to 69 MMTCE reduced in
     2006) through EPA's voluntary climate protection
     programs.
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       1.5.3 Transportation Sector: By 2012, 15
       MMTCE will be reduced in the transportation
       sector (compared to the 2002 level).
     By 2014, 20 MMTCE will be reduced in the
     transportation sector (compared to 0.6 MMTCE
     reduced in 2006) through EPA's voluntary climate
     protection  programs.
       Comment:  For the three sub-objectives listed above (1.5.1 through 1.5.3), EPA needs to identify the
       total greenhouse gas emissions from all sectors/activities, to demonstrate the significance of the target
       reductions.
1.6 Enhance Science and Research: Through 2012,
provide 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.
1.6 Enhance Science and Research: Through 2012,
provide 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.
                                                     1.6.1 Clean Air Research
                                                       By 2013, achieve a rating of "meets expectations" or
                                                       higher in independent expert review assessment of
                                                       the utility of EPA research for protecting the air and
                                                       reducing risks to human health.
Goal 2: Clean and Safe Water
Current (2006-2011) Strategic Plan

Objective
Sub-objective
Strategic Target
Prooosed (2009-2014) Strategic Plan

Objective
Sub-objective
Strategic Measure
                                   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.
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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.
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.
  2.1.1 Water Safe To Drink: By 2011, 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: 89
  percent.)
  2.1.1 Water Safe To Drink
                                                By 2014, 93 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:
                                                89 percent.)
    By 2011, 90 percent of community water
    systems will provide drinking water that
    meets all applicable health-based
    drinking water standards through
    approaches including effective treatment
    and source water protection. (2005
    baseline: 89 percent.)
    By 2014, 90 percent of community water
    systems will provide drinking water that
    meets all applicable health-based
    drinking water standards through
    approaches including effective treatment
    and source water protection. (2005
    baseline: 89 percent.)
    Comment:  EPA should justify why it is delaying attainment of the 90 percent target
    for 3 addition years. Assuming the now-projected performance gain of 1 percent
                                                             ml
    over 9 years, this goal will not be fully achieved until the 22  century.
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By 2011, community water systems will
provide drinking water that meets all
applicable health-based drinking water
standards during 96 percent of person
months (i.e., all persons served by
community water systems times  12
months). (2005 baseline: 95.2 percent.)
By 2014, community water systems will
provide drinking water that meets all
applicable health-based drinking water
standards during 97 percent of person
months (i.e., all persons served by
community water systems times  12
months). (2005 baseline: 95.2 percent.)
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. (2005
baseline: 86 percent.)
By 2014, 88 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. (2005 baseline:
86 percent.)
Comment: As discussed in previous NACEPT comments, EPA continues to project
lower attainment rates in Indian Country versus community water systems generally
(88 percent vs. 93 percent). EPA should justify why it continues to establish lower
systems expectations in Indian Country and whether improved direct assistance
efforts can eliminate this differential.
By 2011, minimize risk to public health
through source water protection for 50
percent of community water systems and
for the associated 62 percent of the
population served by community water
systems (i.e., "minimized risk" achieved
by substantial implementation, as
determined by the state, of actions in a
source water protection strategy). (2005
baseline: 20 percent of community water
systems; 28 percent of population.)
By 2014, minimize risk to public health
through source water protection for 50
percent of community water systems and
for the associated 62 percent of the
population served by community water
systems (i.e., "minimized risk" achieved
by substantial implementation, as
determined by the state, of actions in a
source water protection strategy). (2005
baseline: 20 percent of community water
systems; 28 percent of population.)
Comment: EPA should justify the 3-year delay in attaining this sub-objective.
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  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 (38,637 homes lack access).)
  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 (38,637 homes lack access).) (FY
  07 end-of-year result is 36,575 homes;
  11.5 percent of homes on tribal lands
  lacking access to safe drinking water.)
2.1.2 Fish and Shellfish Safe to Eat: By
2011, reduce public health risk and allow
increased consumption offish and shellfish,
as measured by the following strategic
targets
2.1.2 Fish and Shellfish Safe to Eat
  By 2011, reduce the percentage of
  women of childbearing age having
  mercury levels in blood above the level
  of concern 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).)
  By 2014, reduce the percentage of
  women of childbearing age having
  mercury levels in blood above the level
  of concern 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).)
  By 2011, maintain or improve the
  percentage of state-monitored shellfish-
  growing acres impacted by
  anthropogenic sources that are approved
  or conditionally approved for use. (2003
  baseline: 65 to 85percent of 16.3 million
  acres of state-monitored shellfish-
  growing acres estimated to be impacted
  by anthropogenic sources are approved
  or conditionally approved for use.)
  Exploring replacement measure
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2.1.3 Water Safe for Swimming: By
2011, improve the quality of recreational
waters as measured by the following
strategic targets:
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 five-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 (pools
  and water parks).)
  By 2014, 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 five-
  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 (pools and water parks).)
  By 2011, maintain the percentage of days
  of the beach season that coastal and
  Great Lakes beaches monitored by state
  beach safety programs are open and safe
  for swimming at 96 percent. (2005
  baseline: beaches open 96 percent of the
  743,036 days of the beach season (beach
  season days are equal to 4,025 beaches
  multiplied by variable number of days of
  beach season at each beach).)
  By 2014, maintain the percentage of days
  of the beach season that coastal and Great
  Lakes beaches monitored by state beach
  safety programs are open and safe for
  swimming at 96 percent. (2007 baseline:
  beaches open 95 percent of the 679,589
  days of the beach season (beach season
  days are equal to 3,647 beaches
  multiplied by variable number of days of
  beach season at each beach).)
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2.2 Protect Water Quality: Protect the
quality of rivers, lakes, and streams on a
watershed basis and protect coastal and ocean
waters.
2.2 Protect Water Quality: Protect the
quality of rivers, lakes, and streams on a
watershed basis and protect coastal and ocean
waters.
  2.2.1 Improve Water Quality on a
  Watershed Basis: By 2012, use pollution
  prevention and restoration approaches to
  protect the quality of rivers, lakes, and
  streams on a watershed basis.
  2.2.1 Improve Water Quality on a
  Watershed Basis
    By 2012, attain water quality standards
    for all pollutants and impairments in
    more than 2,250 water bodies identified
    in 2002 as not attaining standards
    (cumulative). (2002 baseline: 39,798
    water bodies identified by states and
    tribes as not meeting water quality
    standards. 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 impaired water bodies are
    impaired by multiple pollutants including
    mercury, and 6,501 are impaired by
    mercury alone.)
    By 2014, attain water quality standards
    for all pollutants and impairments in
    more than 2,360 water bodies identified
    in 2002 as not attaining standards
    (cumulative). (2002 baseline: 39,798
    water bodies identified by states and
    tribes as not meeting water quality
    standards. 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 impaired water bodies are impaired
    by multiple pollutants including mercury,
    and 6,501 are impaired by mercury alone.
    2008 baseline TBD.)
    Comment:  EPA's target of attaining water quality standards in 2,360 water bodies
    by 2014 is far less than 10 percent of the 2002 baseline 39,798 water bodies in non-
    attainment.  At the projected rate, full attainment will not occur until well into the
    22nd century.
    By 2012, remove at least 5,600 of the
    specific causes of water body
    impairments identified by states in 2002
    (cumulative). (2002 baseline: estimate of
    By 2014, remove at least 5,920 of the
    specific causes of water body
    impairments identified by states in 2002
    (cumulative). (2002 baseline: estimate of
                                         25

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69,677 specific causes of water body
impairments identified by states.)
69,677 specific causes of water body
impairments identified by states. 2008
baseline TBD.)
Comment: EPA's target of removing 5,920 specific causes from a universe of 69,677
causes (2002 baseline) is less than 10 percent over a 12-year period. At the projected
rate, full attainment will not occur until well into the 22nd century.  Additionally,
since this sub-objective addresses specific causes, EPA should be able to bring
enforcement action against these sources in far less time, with greater results.
By 2012, improve water quality
conditions in 250 impaired watersheds
nationwide using the watershed approach
(cumulative). (2002 baseline: zero
watersheds improved of an estimated
4,800 impaired watersheds of focus
having 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 22 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 associated with the
impairments.)
By 2014, improve water quality
conditions in 300 impaired watersheds
nationwide using the watershed approach
(cumulative). (2002 baseline: zero
watersheds improved of an estimated
4,800 impaired watersheds of focus
having 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 22 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
water shed-wide improvement, as
demonstrated by valid scientific
information, in one or more water quality

parameters associated with the
impairments. 2008 baseline TBD.)
Comment: EPA's success measure of "one or more" improvements is problematic
here. Success should be declared when all impairments are eliminated and the
watershed is impairment free, not when just one or more impairments are
addressed, but the watershed remains impaired.
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Through 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 rated "poor" and no statistically
significant decrease in streams rated
"good"). (2006 baseline: Wadeable
Stream Survey identifies 28 percent of
streams in good condition; 25  percent in
fair condition; 42 percent in poor
condition.)
Through 2014, ensure that the condition
of the Nation's wadeable streams does
not degrade (i.e., there is no statistically
significant increase in the percent of
streams rated "poor" and no statistically
significant decrease in streams rated
"good"). (2006 baseline for streams: 28
percent in good condition; 25 percent in
fair condition; 42 percent in poor
condition. States/EPA will establish
baseline conditions for lakes and rivers in
2010 and 2012 respectively.)
Comment: The target of "no degradation" would be acceptable if all (or nearly all)
wadeable streams were in in "good" condition. However, a target of "no
degradation" when 25 percent of streams are in "fair" condition and 42 percent of
streams are in "poor" condition is not protective of public health.
By 2012, improve water quality in Indian
country at not fewer than 50 baseline
monitoring stations in tribal waters
(cumulative) (i.e., show improvement in
one or more of seven key parameters:
dissolved oxygen, pH, water
temperature, total nitrogen, total
phosphorus, pathogen indicators, and
turbidity). (2006 baseline: 185
monitoring stations on tribal waters
located where water quality has been
depressed and activities are underway or
planned to improve water quality, out of
an estimated 1,661 stations operated by
tribes.)
By 2014, improve water quality in Indian
country at 75 or more baseline
monitoring stations in tribal waters
(cumulative) (i.e., show improvement in
one or more of seven key parameters:
dissolved oxygen, pH, water temperature,
total nitrogen, total phosphorus, pathogen
indicators, and turbidity). (2006 baseline:
185 monitoring stations on tribal waters
located where water quality has been
depressed and activities are underway or
planned to improve water quality, out of
an estimated 1,661 stations operated by
tribes.)
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  By 2015, in coordination with other
  federal partners, reduce by 50 percent the
  number of homes on tribal lands lacking
  access to basic sanitation (cumulative).
  (2003 baseline: Indian Health Service
  data indicate that  8.4 percent of homes
  on tribal lands lack access to basic
  sanitation (26,777 homes of an estimated
  319,070 homes).)
  By 2015, in coordination with other
  federal partners, reduce by 50 percent the
  number of homes on tribal lands lacking
  access to basic sanitation (cumulative).
  (2003 baseline: Indian Health Service
  data indicate that  8.4 percent of homes on
  tribal lands lack access to basic sanitation
  (26,777 homes of an estimated 319,070
  homes).)
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" 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.)	
2.2.2 Improve Coastal and Ocean Water
                                              By 2014, prevent water pollution and
                                              protect coastal and ocean systems to at
                                              least maintain national coastal aquatic
                                              ecosystem health on the "good/fair/poor"
                                              scale of the National Coastal Condition
                                              Report. (2009 baseline: national rating of
                                              "fair" or 2.8 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.)
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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.)
By 2014, at least maintain aquatic
ecosystem health on the "good/fair/poor"
scale of the National Coastal Condition
Report in the Northeast Region. (2009
baseline: Northeast rating of 2.4.)
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 2014, at least maintain aquatic
ecosystem health on the "good/fair/poor"
scale of the National Coastal Condition
Report in the Southeast Region. (2009
baseline: Southeast rating of 3.6.)
Comment:  The Southeast rating declined from 3.8 to 3.6 between 2004 and 2009.  Is
it really EPA's objective to maintain the declined state of ecosystem health?
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 2014, at least maintain aquatic
ecosystem health on the "good/fair/poor"
scale of the National Coastal Condition
Report in the West Coast Region. (2009
baseline: West Coast rating of 2.4.)
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 2014, at least maintain aquatic
ecosystem health on the "good/fair/poor"
scale of the National Coastal Condition
Report in the Puerto Rico Region. (2009
baseline: Puerto Rico rating of 1.7.)
                                            By 2014, at least maintain aquatic
                                            ecosystem health on the "good/fair/poor"
                                            scale of the National Coastal Condition
                                            Report in the Hawaii Region. (2009
                                            baseline: Hawaii rating of 4.5.)	
                                            By 2014, at least maintain aquatic
                                            ecosystem health on the "good/fair/poor"
                                            scale of the National Coastal Condition
                                            Report in the South Central Alaska
                                            Region  (2009 baseline: South Central
                                            Alaska rating of 5.0.)
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    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 and measured through
    onsite monitoring programs). (2005
    baseline: 94 percent.)
    By 2014, 95 percent of active dredged
    material ocean dumping sites will have
    achieved environmentally acceptable
    conditions (as reflected in each site's
    management plan and measured through
    onsite monitoring programs). (2005
    baseline: 94 percent.)
2.3 Enhance Science and 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.
2.3 Enhance Science and Research: By
2014, 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.
Comment: The objective indicates that EPA has delayed by 3 years any expectation to
conduct leading-edge, sound scientific research. This implies that the Agency is free to
conduct trailing-edge, unsound research in the interim.	
                                              2.3.1 Drinking Water Research
                                                By 2013, achieve a rating of "meets
                                                expectations" or higher in independent
                                                expert review assessment of the utility of
                                                EPA research for reducing human
                                                exposure to contaminants in drinking
                                                water and protecting human health.	
                                              2.3.2 Water Quality Research
                                                By 2014, achieve a rating of "meets
                                                expectations" or higher in independent
                                                expert review assessment of the utility of
                                                EPA research for protecting aquatic
                                                ecosystems and reducing human
                                                exposure to contaminants in recreational
                                                waters.
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Goal 3: Land Preservation and Restoration
Current (2006-2011) Strategic Plan

Objective
Sub-objective
Strategic Target
Prooosed (2009-2014) Strategic Plan

Objective
Sub-objective
Strategic Measure
              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.
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.
3.1 Preserve Land: By 2014, 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.
  3.1.1 Reduce Waste Generation and
  Increase Recycling: By 2011, reduce
  materials use through product and process
  design, and increase materials and energy
  recovery from wastes otherwise requiring
  disposal.
  3.1.1 Waste Generation and Recycling
    By 2011, increase reuse and recycling of
    construction and demolition debris by 6
    percent from a baseline of 59 percent in
    2003.
    Comment: This sub-objective has been eliminated due to a reported lack of
    annually-available data. However, it appears that data was available in the baseline
    year (2003). Therefore, data likely continues to be collected, but may not be readily
    available. EPA should further investigate opportunities to access this data (or a
    suitable surrogate) before deleting this sub-objective.
                                               By 2014, increase the amount of
                                               municipal solid waste reduced, reused,
                                               or recycled by 130 billion pounds.
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  Comment: EPA should identify baseline data to qualify whether this target is
  meaningful.
  By 2011, increase the use of coal
  combustion ash to 50 percent from 32
  percent in 2001.
  By 2014, increase the use of coal
  combustion ash to 56 percent from 40
  percent in 2007.
  By 2011, increase by 118 the number of
  tribes covered by an integrated waste
  management plan compared to FY 2006.
  By 2014, increase by 118 the number of
  tribes covered by an integrated waste
  management plan compared to FY 2008.
  Comment: EPA should identify the universe of tribes. What is the FY 2008 baseline
  to which the 2014 target is being compared?
  By 2011, close, clean up, or upgrade 138
  open dumps in Indian country and on
  other tribal lands compared to FY 2006.
  By 2014, close, clean up, or upgrade 138
  open dumps in Indian country and on
  other tribal lands compared to FY 2008.
  Comment: EPA should identify the universe of open dumps in Indian country.
  What is the FY 2008 baseline to which the 2014 target is being compared?
3.1.2 Manage Hazardous Waste and
Petroleum Products Properly: By 2011,
reduce releases to the environment by
managing hazardous wastes and petroleum
products properly.
3.1.2 Hazardous Waste and Petroleum
Products
  By 2011, prevent releases at 500 RCRA
  hazardous waste management facilities
  by implementing initial approved
  controls or updated controls. (The
  universe of facilities will be reassessed in
  FY 2009. However, we currently
  estimate that there will be about 820
  facilities that will require these controls.
  The goal of 500 represents about 60
  percent of the universe of 820 facilities.)
  By 2014, issue XX initial approved
  controls or updated controls.
  Comment: While the universe of facilities is being reassessed in 2009, EPA should
  give some deference to the current estimate of 820 facilities, and should specify some
  expected level of activity/progress for public review purposes.
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    By 2011, increase the percentage of UST
    facilities that are in significant
    operational compliance with both release
    and detection and release prevention
    requirements to 71 percent from 66
    percent in 2006 (an increase of 5 percent)
    out of a total estimated universe of
    approximately 245,000 facilities.
    Each year through 2014, increase the
    percentage of UST facilities that are in
    significant operational compliance
    (SOC) with both release detection and
    release prevention requirements by  0.5
    percent over the previous year's target.
    This means an increase of facilities  in
    SOC from 65 percent in 2009 to 67.5
    percent in 2014.
    Comment: The 2014 target of 67.5 percent SOC is a substantive retreat from the
    2011 target of 71 percent.  EPA should provide justification for the decreased
    expectation.
    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.
    Each year through 2014, minimize the
    number of confirmed releases at UST
    facilities to 9,000 or fewer.
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.
3.2 Restore Land: By 2014, 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.
  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.
  3.2.1 Chemical Release Preparedness
  and Response
    By 2011, achieve and maintain at least
    95 percent of the maximum score on
    readiness evaluation criteria in each
    region.
    By 2014, achieve and maintain at least
    75 percent of the maximum score on the
    Core National Approach to Response
    (NAR) evaluation criteria.
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Comment: The 2014 target of 75 percent of maximum score on the NAR criteria is a
substantial retreat from the 2011 target of 95 percent of maximum score on
readiness criteria. Are the two criteria so substantially different that EPA's previous
progress did not meet the NAR criteria?
By 2011, complete an additional 975
"Superfund-lead" hazardous substance
removal actions. (In FY 2005, 175 of
these actions were completed.)
By 2014, complete an additional 850
"Superfund-lead" hazardous substance
removal actions.
Comment: EPA should identify the backlog of Superfund-lead removal actions to
demonstrate the significance of the target.
By 2011, oversee and complete 650
voluntary removal actions. (In FY 2005,
137 of these actions were completed.)
By 2014, oversee and complete an
additional 850 potential responsible
party (PRP) removal actions, which
include voluntary, administrative orders
on consent (AOC), and unilateral
administrative order (UAO) actions.
Comment: EPA should identify the backlog of PRP removal actions to demonstrate
the significance of the target.
By 2011, reduce by 25 percent the
gallons of oil spilled by facilities subject
to Facility Response Plan regulations
relative to the 601,000 gallons of oil
spilled in 2003.
By 2014, 60 percent of all SPCC
facilities found to be non-compliant
between FY 2010-2014 will be brought
into compliance.
Comment: In delegated programs such as the National Pretreatment Program,
sustained 40 percent non-compliance is considered an indicator of unacceptable
program management.  EPA should hold itself to the same program management
criteria as its delegates.
By 2011, inspect (and ensure compliance
at) 90 percent of the estimated 4,200
facilities subject to Facility Response
Plan regulations, up from 50 percent in
2004.
By 2014, 60 percent of all FRP facilities
found to be non-compliant between FY
2010-2014 will be brought into
compliance.
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  Comment: In delegated programs such as the National Pretreatment Program,
  sustained 40 percent non-compliance is considered an indicator of unacceptable
  program management.  EPA should hold itself to the same program management
  criteria as its delegates.
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.
3.2.2 Contaminated Land
  By 2011, make final assessment
  decisions at 40,491 of 44,700 potentially
  hazardous waste sites evaluated by EPA
  to help resolve community concerns on
  whether these sites require long-term
  cleanup to protect public health and the
  environment and to help determine if
  they can be cleared for possible
  redevelopment. (By the end of FY 2005,
  a total of 38,770 final site assessment
  decisions had been made.)
  By 2014, make final assessment
  decisions at XX of XX potentially
  hazardous waste sites evaluated by EPA
  to help resolve community concerns on
  whether these sites require long-term
  cleanup to protect public health and the
  environment and to help determine if
  they can be cleared for possible
  redevelopment.
  By 2011, control all identified
  unacceptable human exposures from site
  contamination for current land and/or
  groundwater use conditions at
  approximately 85 percent (1,316) of
  1,543 Superfund human exposure sites.
  (The universe of 1,543 is the number of
  NPL sites with potential human exposure
  pathways as of FY 2005 and includes 172
  Superfund federal facility sites. Baseline:
  by the end of FY 2006, approximately 82
  percent (1,266) of sites had human
  exposures under control.)
  By 2014, control all identified
  unacceptable human exposures from site
  contamination for current land and/or
  groundwater use conditions at
  approximately XX percent (XX) of XX
  Superfund human exposure sites. (The
  universe of XX is the number of National
  Priority List (NPL) human exposure  sites
  as of the end of FY 2008.)
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By 2011, increase to 95 percent the high
National Corrective Action Prioritization
System (NCAPS)-ranked RCRA
facilities with human exposures to toxins
controlled. (The universe of all facilities
that need RCRA Corrective Action will
be final by the end of FY 2007 and will
include high, medium, and low ranked
facilities.)
By 2014, increase to XX percent the
number of Resource Conservation and
Recovery Act (RCRA) facilities with
human exposures to toxins controlled.
(At the end of FY 2008, potential human
exposures to toxins were controlled at
XX percent (XXX) of all 3,746 facilities
needing corrective action.)
By 2011, control the migration of
contaminated groundwater through
engineered remedies, natural processes,
or other appropriate actions at 74 percent
(1,017) of 1,381 Superfund groundwater
sites. (The universe of 1,381 sites is the
number of NPL sites with groundwater
contamination as of FY 2005 and
includes 166 Superfund federal facility
sites. Baseline: by the end of FY 2005, 68
percent (937) of sites had groundwater
migration under control.)
By 2014, control the migration of
contaminated groundwater through
engineered remedies, natural processes,
or other appropriate actions at XX
percent (XX of XX Superfund
groundwater sites. (The universe of XX
sites is the number of NPL sites with
groundwater contamination as of the end
of FY 2008.)
By 2011, increase to 80 percent the high
NCAPS-ranked RCRA facilities with
migration of groundwater under control.
(The universe of all facilities that need
RCRA corrective action will be final by
the end of FY 2007 and will include high,
medium, and low ranked facilities.)
By 2014, increase to XX percent the
number of Resource Conservation and
Recovery Act (RCRA) facilities with
migration of contaminated groundwater
under control. (At the end of FY 2008,
the migration of contaminated
groundwater was controlled at XX
percent (XXX) of all 3,746 facilities
needing corrective action.)
By 2011, complete construction of
remedies at approximately 76 percent
(1,171) of 1,547 Superfund sites. (The
universe of 1,547 sites is the total number
of sites on the NPL as of FY 2005 and
includes 172 Superfund federal facilities.
Baseline: by the end of FY 2005, 62
percent or 966 sites had completed
By 2014, complete construction of
remedies at more than XX percent (XX)
of XX Superfund sites. (The universe of
XX sites is the total number of sites on
the NPL as of the end of FY 2008.)
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construction.)
By 2011, increase to 22 percent the
RCRA facilities with final remedies
constructed. (The universe of all facilities
that need RCRA corrective action will be
final by the end of FY 2007 and will
include high, medium,  and low ranked
facilities.)
By 2014, increase to XX percent the
number of RCRA facilities with final
remedies constructed. (At the end of FY
2008, all  cleanup remedies had been
constructed at XX percent (XXX) of all
3,746 facilities needing corrective
action.)
By 2011, reduce the backlog of LUST
cleanups (confirmed releases that have
yet to be cleaned up) that do not meet
state risk-based standards for human
exposure and groundwater migration
from 26 percent to 21 percent.
Each year through 2014, reduce the
backlog of LUST cleanups (confirmed
releases that have yet to be cleaned up)
that do not meet state risk-based
standards for human exposure and
groundwater migration by 1 percent.
This means a decrease from 23 percent in
2007 to 16 percent in 2014.
By 2011, ensure that 36 percent (345) of
966 final and deleted construction
complete NPL sites are ready for reuse
site-wide. (As of July 2006, 20 percent
(195) of the 966 final and deleted
construction complete NPL sites,
including 14 Superfund federal facility
sites, met EPA's definition for ready for
reuse site-wide.)
By 2014, ensure that XX percent (XX) of
XX final and deleted construction
complete NPL sites are ready for
anticipated use site-wide. (The site-wide
universe of XX is the number of final
and deleted NPL sites, excluding sites
with groundwater contamination only, as
of the end of FY 2008.)
Comment: Since EPA has now gone through several iterations of its Strategic Plan,
the Agency's offices have had much more than sufficient time to plan for the 2014
Strategic Plan. The omission of numeric performance targets this late in the game
could be interpreted as symptomatic of a lack of respect for the planning process, or
at minimum, the public input component represented by this document.
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  3.2.3 Maximize Potentially Responsible
  Party Participation at Superfund Sites:
  Through 2011, conserve federal resources
  by ensuring that potentially responsible
  parties conduct or pay for Superfund
  cleanups whenever possible.
  3.2.3 Potentially Responsible Party
  Participation at Superfund Sites
    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.
    Each year through 2014, 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.
    Each year through 2011, address all
    unaddressed costs in statute of limitations
    cases for sites with unaddressed total past
    Superfund costs equal to or greater than
    $200,000.
    Each year through 2014, address all
    unaddressed costs in statute of
    limitations cases for sites with
    unaddressed total past Superfund costs
    equal to or greater than $200,000.
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.
3.3 Enhance Science and Research: Provide
and apply sound science for protecting and
restoring land by conducting leading-edge
research, which, through collaboration, leads
to preferred environmental outcomes.
                                               3.3.1 Land Protection Research
                                                 By 2014, achieve a rating of "meets
                                                 expectations" or higher in independent
                                                 expert review assessment of the utility of
                                                 EPA research for protecting and
                                                 restoring land.
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Goal 4: Healthy Communities and Ecosystems
Current (2006-2011) Strategic Plan

Objective
Sub-objective
Strategic Target
ProDOsed (2009-2014) Strategic Plan

Objective
Sub-objective
Strategic Measure
              GOAL 4: HEALTHY COMMUNITIES AND ECOSYSTEMS

  Protect, sustain, or restore the health of people, communities, and ecosystems using
  integrated and comprehensive approaches and partnerships.
  4.1 Chemical and Pesticide Risks: By
  2011, prevent and reduce pesticide and
  industrial chemical risks to humans,
  communities, and ecosystems.
4.1 Chemical and Pesticide Risks: By 2014,
prevent and reduce pesticide and industrial
chemical risks to humans, communities, and
ecosystems.
    4.1.1 Reduce Chemical Risks: By
    2011, prevent and reduce chemical risks
    to humans, communities, and
    ecosystems.
  4.1.1 Reduce Chemical Risks
      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. (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.)
    By 2014, initiate risk management actions as
    needed to effectively manage risk for ChAMP
    chemicals identified as high priority
    chemicals of special concern.  (Baseline is
    zero risk management actions through 2008.)
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Comment: EPA should identify the universe of potential risk management actions to
demonstrate the extent to which reported actions reach the regulated community.
                                       By 2014, achieve a 50 per cent cumulative
                                       reduction of chronic human health risk from
                                       environmental releases of High Production
                                       Volume chemicals in commerce since 1998.
                                       (Baseline: cumulative reduction reported
                                       from 1998-2006 is 3 3 per cent.)
Through 2011, ensure that new
chemicals introduced into commerce
do not pose unreasonable risks to
workers, consumers, or the
environment. (The FY 2004 and FY
2005 baseline is 100 percent.)
Through 2014, ensure that new chemicals
introduced into commerce do not pose
unreasonable risks to workers, consumers, or
the environment. (Baseline through 2007 is
100 percent.)
By 2011, achieve a 26 percent
cumulative reduction of chronic
human health risk from
environmental releases of industrial
chemicals in commerce since 2001.
(Baseline: cumulative reduction
reported from 2002-2003 is 6.6
percent.)
By 2014, achieve a 55 percent cumulative
reduction of chronic human health risk from
environmental releases of industrial
chemicals in commerce since 2001.
(Baseline: cumulative reduction reported
from 2002-2006 is 33 percent.)
                                       By 2014, reduce global demand for mercury
                                       by 25 percent by working with international
                                       partners to initiate successful mercury policy
                                       initiatives and reduction activities affecting
                                       at least five countries. (Pilots are deemed
                                       successful when they have completed all
                                       parts of the pilot program and have begun to
                                       reduce mercury.)
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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). (The 1999-2002
baseline is 310,000 cases.)
By 2014, maintain elimination of childhood
lead poisoning as a public health concern by
not allowing the percent of children (aged 1-
5 years) with elevated blood lead levels
(>10ug/dl) to rise above 0.01 percent.
(Baseline: pending availability of NHANES
data, baseline could extend through 2006.
Information should be available through
2004. -1.5 percent of children with elevated
blood lead levels. 300 thousand  out of a
universe of 20 million children.)
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. (The
1991-1994 baseline is 37 percent.)
By 2014, reduce to 25 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. (The 1999-
2002/4 baseline is 30 percent.)
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 more
than 700 million people. (Baseline:
as of January 2006, 35 countries had
not phased lead out of gasoline.)
By 2014, through work with international
partners, eliminate the use of lead in gasoline
in the remaining 16 countries that still use
lead as an additive, affecting more than 700
million people. (Baseline: as of July 2008, 16
countries had not phased lead out of
gasoline.)
By 2011, through work with
international partners, more than 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.)
By 2014, through work with international
partners, more than 3 billion people will have
access to low-sulfur fuel in 75 countries.
(Baseline: as of July 8, 2008, 43 countries
had introduced low-sulfur.)
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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.
                                      4.1.2 Reduce Chemical Risks at Facilities
                                      and in Communities
                                          By 2014, conduct 2,400 inspections and
                                          audits at RMP facilities. (Baseline: in FY
                                          2007, 750 RMP inspections were conducted.)
By 2011, continue to maintain the
Risk Management Plan (RMP)
prevention program and further
reduce by 5 percent the number of
accidents at RMP facilities. (The
baseline is an annual average of 340
accidents, based on RMP program
data through 2003.)
  Comment: EPA should identify the universe of RMP facilities to demonstrate the
  significance of the target activity level in relation to the regulated community.
  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, and $143.5
  million in property damage at RMP
  from 1995-2003.)
  By 2011, vulnerability zones
  surrounding RMP facilities will be
  reduced by 5 percent from the 2004
  baseline, which will result in the
  reduction of risk for over 4 million
  people in the community. (The 2004
                        2
  baseline is 1,086,428 mi of
  cumulative area of RMP
  vulnerability zones.)
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  By 2011, improve by 10 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.
Comment: EPA should not delete the four performance-based targets under sub-
objective 4.1.2 as these remain valid indicators of chemical risk reduction and
enhanced public protection.
4.1.3 Protect Human Health from
Pesticide Risk: Through 2011, protect
human health by implementing our
statutes and taking regulatory actions to
ensure pesticides continue to be safe
and available when used in accordance
with the label.
4.1.3 Protect Human Health from Pesticide
Risk
  By 2011, reduce the concentration of
  pesticides detected in the general
  population by 50 percent. (Baselines
  are determined from 1999-2002
  Centers for Disease Control-National
  Health and Nutrition Examination
  Survey (NHANES) data.)
  By 2014, reduce the concentration of
  pesticides detected in the general population
  by XX percent. (Baselines are determined
  from 1999-2002 Centers for Disease Control-
  National Health and Nutrition Examination
  Survey (NHANES) data. According to
  NHANES data for FY 1999-2002 the
  concentration of pesticides residues detected
  in blood samples from the general population
  are:

  Dimethylphosphaste = 0.41 ug/L

  Dimethylthiophosphate = 1.06 ug/L

  Dimethyldithiophosphate = 0.07 ug/L

  Diethylphosphate = 0.78 ug/L

  Diethylthiophosphate = 0.5 ug/L
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                                         Diethyldthiophosogate = 0.07 ug/L

                                         3,5,6-Trichloro-2pyridnol =1.9 ug/L.)
Through 2011, 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 1,385 occupational pesticide
incidents in 2003 out of 39,850,000
potential pesticide  risk events/year.)
By 2014, 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 1,388 incidents out of 39,850,000
potential risk events for those occupationally
exposed to pesticides in FY 2003.)
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.)
By 2014, improve the health of those who
work in or around pesticides by reaching a
XX 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. The rates for
moderate to severe incidents for exposure to
agricultural pesticides with the highest
incident rates base on FY 1999 -2003 data
were: chlorpyrifos, 67 incidents; diazinon, 51
incidents;  malathion, 36 incidents;
pyrethrins, 29 incidents; 2, 4-D, 27;
carbofuran, 24.)
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                                          By 2014, complete 100 percent Tier 1
                                          screening to determine whether any of the
                                          first group of pesticide chemicals have the
                                          potential to interact with estrogen, androgen,
                                          or thyroid hormone systems; complete
                                          validation of Tier 2 tests, which are designed
                                          to assess whether substances cause
                                          endocrine effects and provide data to support
                                          hazard identification and risk assessment;
                                          and based on review of Tier 1 screening
                                          results, initiate Tier 2 testing for pesticide
                                          chemicals, as appropriate. (Baseline: one of
                                          five Tier 2 tests were validated in FY 2008.)
4.1.4 Protect the Environment from
Pesticide Risk: Through 2011, protect
the environment by implementing our
statutes and taking regulatory actions to
ensure pesticides continue to be safe
and available when used in accordance
with the label.
4.1.4 Protect the Environment from Pesticide
Risk
  By 2011, reduce the percentage of
  urban watersheds that exceed the
  National Pesticide Program aquatic
  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.)
  By 2014, reduce the percentage of urban
  watersheds that exceed the National Pesticide
  Program aquatic 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.)
  By 2011, reduce the percentage that
  exceeds EPA aquatic life benchmarks
  for two key pesticides (azinphos-
  methyl and chlorpyrifos). (Based on
  1992-2001 data, 18 percent of
  agricultural watersheds sampled
  exceeded benchmarks for azinphos-
  By 2014, reduce the percentage that exceed
  EPA aquatic life benchmarks for two key
  pesticides (azinphos-methyl and
  chlorpyrifos). (Baseline: based on FY 1992-
  2001 data, 18 percent of agricultural
  watersheds exceeded aquatic life benchmarks
  for azinphos-methyl and 18 percent of
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    methyl and chlorpyrifos.)
    agricultural watersheds exceeded aquatic life
    benchmarks for chlorpyrifos.)
    Comment:  EPA needs to specify the percentage targets in the above two measures to
    demonstrate their significance.
  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.
  4.1.5 Realize the Benefits from Pesticide Use
    By 2011, annually continue to avoid
    $1.5 billion in crop loss by ensuring
    that safe and effective pesticides are
    available to address emergency pest
    infestations.
    By 2014, annually continue to avoid $1.5
    billion in crop loss by ensuring that safe and
    effective pesticides are available to address
    emergency pest infestations. (According to
    EPA and USDA data for the years FY 2000-
    2005, emergency exemptions issued by EPA
    resulted in $1.5 billion in avoided crop loss.)
    By 2011, annually continue to avoid
    $900M in termite structural damage
    by ensuring that safe and effective
    pesticides are registered/re-registered
    and available for termite treatment.
    By 2014, annually continue to avoid $900M
    in termite structural damage by ensuring that
    safe and effective pesticides are
    registered/re-registered and available for
    termite treatment. (Baseline: based on U.S.
    Census housing data, industry data, and
    academic studies on damage valuation, EPA
    calculates that in FY 2003 there were $900
    million in annual savings from structural
    damage avoided due to availability of
    registered termiticides.)
4.2 Communities: Sustain, cleanup, and
restore communities and the ecological
systems that support them.
4.2 Communities: Sustain, clean up, and restore
communities and the ecological systems that
support them.
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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 30 communities
that will achieve significant measurable
environmental and/or public health
improvements. (Baselines for criteria
air pollutants, land consumption, and
storm water run-off prior to EPA
assistance will be established for each
community.)
4.2.1 Sustain Community Health
                                          By 2014, reduce the air, water, and land
                                          impacts of new growth and development
                                          through the use of smart growth strategies in
                                          XX communities (plus selected states, local
                                          governments, and standard-setting
                                          organizations) that will achieve significant
                                          measurable environmental and/or public
                                          health improvements. (Baselines for criteria
                                          air pollutants, land consumption, and storm
                                          water run-off prior to EPA assistance will be
                                          established for each community.)
4.2.2 Restore Community Health
through Collaborative Problem-
Solving: By 2011, 30 communities with
potential environmental justice
concerns will achieve significant
measurable environmental or public
health improvement through
collaborative problem-solving
strategies. (Baseline: in 2006, 20
communities with potential
environmental justice concerns are in
the process of using collaborative
problem-solving strategies in efforts to
achieve environmental or public health
improvement. Community-specific
baselines will be developed by 2008 for
4.2.2 Restore Community Health through
Collaborative Problem-Solving
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assessing improvement.)
                                          By 2014, 45 communities with potential
                                          environmental justice concerns will achieve
                                          significant measurable environmental or
                                          public health improvement through
                                          collaborative problem-solving strategies.
                                          (Baseline: in 2006, 30 communities with
                                          potential environmental justice concerns are
                                          in the process of using collaborative
                                          problem-solving strategies in efforts to
                                          achieve environmental or public health
                                          improvement. Community-specific baselines
                                          will be developed by 2008 for assessing
                                          improvement.)
  Comment: EPA needs to identify the universe of communities with potential
  environmental concerns to demonstrate the significance of this target.

  Also, the 2006 baseline value is different in the 2011 and 2014 sub-objectives.  This
  discrepancy needs to be resolved.
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.
4.2.3 Assess and Clean Up Brownfields
  By 2011, conduct environmental
  assessments at 13,900 (cumulative)
  properties. (As of the end of FY
  2005, EPA assessed 7,900
  properties.)
  By 2014, conduct environmental assessments
  at 18,800 (cumulative) properties. (Baseline:
  as of the end of FY 2007, EPA assessed
  11,800 properties.)
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  By 2011, make an additional 1,125
  acres of brownfields ready for reuse
  from the 2006 baseline. (The 2006
  baseline will be available in 2007.)
  By 2014, make an additional 11,700 acres of
  brownfields ready for reuse from the 2007
  baseline. (Baseline: as of the end of FY 2007,
  EPA made 4,700 acres ready for reuse.)
  By 2011, leverage $12.9 billion
  (cumulative) in assessment, cleanup,
  and redevelopment funding at
  brownfields properties (FY 2005
  baseline is $7.5 billion.)
  By 2014, leverage $17.7 billion (cumulative)
  in assessment, cleanup, and redevelopment
  funding at brownfields properties. (Baseline:
  as of the end of FY 2007, EPA leveraged
  $11.4 billion.)
4.2.4 Sustain and Restore the United
States - Mexico Border
Environmental Health: By 2012,
sustain and restore the environmental
health along the United  States-Mexico
border through implementation of the
"Border 2012" plan.
4.2.4 Sustain and Restore the United States -
Mexico Border Environmental Health
  By 2012, achieve a majority of
  currently exceeded water quality
  standards in impaired trans-
  boundary segments of surface
  waters. (2002 baseline: 17 currently
  exceeded water quality standards
  were identified for 10 transboundary
  segments of U.S. surface waters.)
  A new measure is being developed and
  planned to align with the Fall PART update.
  Proposed measure will better focus on
  environmental outcomes and may assess
  biological oxygen demand (BOD) or another
  parameter as a measure for improved water
  quality (e.g., pounds of pollutant removed).
  (Baseline: TBD.)
  By 2012, provide safe drinking water
  to 25 percent of homes in the U.S.-
  Mexico border area that lacked
  access to safe drinking water in 2003.
  (2003 baseline: 98,515 homes lacked
  access to safe drinking water.)
  By 2014, provide safe drinking water to 50
  percent of homes in the U.S.-Mexico border
  area that lacked access to safe drinking water
  in 2003. (2003 baseline: 98,515 homes
  lacked access to safe drinking water.)
  By 2012, provide adequate
  wastewater sanitation to 25 percent
  of homes in the U.S.-Mexico border
  area that lacked access to wastewater
  sanitation in 2003. (2003 baseline:
  690,723 homes lacked access to
  By 2014, provide adequate wastewater
  sanitation to 50 percent of homes in the U.S.-
  Mexico border area that lacked access to
  wastewater sanitation in 2003. (2003
  baseline: 690,723 homes lacked access to
  wastewater sanitation.)
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  waste water sanitation.)
  By 2012, clean up five waste sites
  (two abandoned waste tires sites and
  three abandoned hazardous waste
  sites) in the U.S.-Mexico border
  region.
  By 2012, clean up five waste sites (two
  abandoned waste tires sites and three
  abandoned hazardous waste sites) in the
  U.S.-Mexico border region.
  Comment: EPA should identify the universe of waste sites in the U.S. - Mexico
  border region to demonstrate the significance of this target.
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).
4.2.5 Sustain and Restore Pacific Island
Territories
  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 the
  Commonwealth of the Northern
  Mariana Islands, 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 2014, 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 is available
  24 hours per day and meets all applicable
  health-based drinking water standards
  throughout the year. (2005 baseline: 95
  percent of the population in American
  Samoa, 10 percent in the Commonwealth of
  the Northern Mariana Islands, 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.)
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  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.)
  By 2014, 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.)
  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 64 percent of the 365-day
  beach season in American Samoa, 97
  percent in the Commonwealth of the
  Northern Mariana Islands, and 76
  percent in Guam.)
  By 2014, 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 64 percent of the 365-day beach
  season in American Samoa, 97 percent in the
  Commonwealth of the Northern Mariana
  Islands, and 76 percent in Guam.)
4.2.6 Reduce Persistent Organic
Pollutants (POPs) Exposure: By
2011, reduce the mean maternal serum
blood levels of persistent organic
pollutant (POP) contaminants in
indigenous populations in the Arctic.
4.2.6 Reduce Persistent Organic Pollutants
(POPs) Exposure
  By 2011, reduce mean maternal
  blood levels of poly chlorinated
  biphenyls (PCBs) (measured as
  Aroclor 1260) in indigenous
  populations in the Arctic to 5.6 |ig/l.
  (The 2006 calculated baseline mean
  maternal serum level for PCBs was
  6.3 ug/1.)
  By 2014, reduce mean maternal blood levels
  of poly chlorinated biphenyls (PCBs)
  (measured as Aroclor 1260) in indigenous
  populations in the Arctic to 5.1 |ig/l. (The
  2006 calculated baseline mean maternal
  serum level for PCBs was 6.3 ug/1.)
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    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/1.
    (The 2006 calculated baseline mean
    matenal serum level for total
    chlordane was 1.3 ug/1.)
    By 2014, reduce mean maternal blood levels
    of chlordane (measured as the metabolites
    oxychlordane and trans-nonachlor) in
    indigenous populations in the Arctic to 1.0
    Ug/1. (The 2006 calculated baseline mean
    maternal serum level for total chlordane was
    1.3 ug/1.)
4.3 Restore and Protect Critical
Ecosystems: Protect, sustain, and restore
the health of critical natural habitats and
ecosystems.
4.3 Restore and Protect Critical Ecosystems:
Protect, sustain, and restore the health of critical
natural habitats and ecosystems.
  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.
  4.3.1 Increase Wetlands
    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. (2004 baseline:
    32,000 acres annual net wetland
    gain.)
    By 2014, 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. (2004 baseline: 32,000
    acres annual net wetland gain.)
    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.)
    By 2014, in partnership with the U.S. Army
    Corps of Engineers (the Corps), state, 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.) (Proposed change in calculating
    measurement of "no net loss " of wetlands
    from  "wetlandacreage" to "wetland
    acreage and stream miles. " "No net loss"
    also would be expressed as a ratio of gains
    to losses.)
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4.3.2 Facilitate the Ecosystem-Scale
Restoration of Estuaries of National
Significance: 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: 449,242 acres of
habitat protected or restored;
cumulative from 2002.)
4.3.2 Increase Habitat Protected or Restored
in Estuaries of National Significance
                                           By 2014, working with partners, protect or
                                           restore an additional (i.e., measuring from
                                           2010 forward) 500,000 acres of habitat
                                           within the study areas for the 28 estuaries
                                           that are part of the National Estuary Program.
                                           (2008 baseline: XXXX acres of habitat
                                           protected or restored; cumulative from 2002.
                                           Baseline will be updated with 2008 data.)
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.)
4.3.3 Improve the Health of the Great Lakes
                                           By 2014, prevent water pollution and protect
                                           aquatic systems so that the overall ecosystem
                                           health of the Great Lakes is at least 23.5
                                           points on a 40-point scale. (2009 Baseline:
                                           Great Lakes rating of 22.5 (expected) on the
                                           40-point scale where the rating uses select
                                           Great Lakes State of the Lakes Ecosystem
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                                        indicators based on a 1 to 5 rating system for
                                        each indicator, where 1 is poor and 5 is
                                        good.)
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.  (1990
baseline: concentration levels at
stations  in Lakes Superior [0.45
ppm], Michigan [2.72 ppm], Huron
[1.5 ppm], Erie [1.35 ppm] and
Ontario  [2.18 ppm].)
Through 2014, maintain or improve an
average annual 5 percent decline for the
short-term trend (year 2000 and on) in
average concentrations of PCBs in whole
lake trout and walleye samples. (2000
baseline: concentration levels at stations in
Lakes Superior [0.71  ppm], Michigan [1.5
ppm], Huron [.78 ppm], Erie [1.2 ppm] and
Ontario [1.2 ppm].)
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. (1992 baseline: concentration
levels for U.S. stations: Lake
Superior [110 pg/m3], Lake
Michigan  [289 pg/m3], and Lake
Erie [431 pg/m3].)
Through 2014, 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. (1992 baseline: concentration
levels for U.S. stations: Lake Superior [110
pg/m3], Lake Michigan [289 pg/m3], and
Lake Erie [431 pg/m3].)
By 2010, restore and delist a
cumulative total of at least 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 2014, restore and delist a cumulative total
of at least 7 Areas of Concern within the
Great Lakes basin (2008 Baseline: one area
of concern de-listed of the 31 previously
identified areas of concern.)
By 2011, remediate a cumulative
total of 7 million cubic yards of
contaminated sediment in the Great
Lakes. (2005 Baseline: of the 75
million yards estimated to need
remediation, 3.7 million yards of
By 2014, remediate a cumulative total of 8
million cubic yards of contaminated
sediment in the Great Lakes. (2009 Baseline:
Of the 46.5 million cubic yards once
estimated to need remediation in the Great
Lakes, EPA expects to report in 2009 that 5.5
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  contaminated sediments from the
  Great Lakes have been remediated
  from 1997 through 2004.)
  million cubic yards of contaminated
  sediments are expected to have been
  remediated from 1997 through 2008.)
                                          By 2014, remove 46 beneficial use
                                          impairments within areas of concern within
                                          the Great Lakes. (2008 Baseline: llBUIs
                                          removed from Areas of Concern.)
  Comment: EPA should identify the universe of beneficial use impairments to
  demonstrate the significance of this target.
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.
4.3.4 Improve the Health of the Chesapeake
Bay Ecosystem
  By 2011, achieve 45 percent (83,250
  acres) of the 185,000 acres of
  submerged aquatic vegetation
  necessary to achieve Chesapeake Bay
  water quality standards. (2005
  baseline: 39  percent (72,935 acres) of
  submerged aquatic vegetation
  necessary to achieve Chesapeake Bay
  water quality standards.)
  By 2014, achieve 45 percent (83,250 acres)
  of the 185,000 acres of submerged aquatic
  vegetation necessary to achieve Chesapeake
  Bay water quality standards. (2008 baseline:
  35 percent (64,912 acres) of submerged
  aquatic vegetation necessary to achieve
  Chesapeake Bay water quality standards.)
  By 2011, achieve 40 percent (29.92
  cubic km) of the long-term
  restoration goal of 100 percent
  attainment of the dissolved oxygen
  water quality standards in all tidal
  waters of the Bay. (2005 baseline: 34
  percent (25.40 cubic km) of
  dissolved oxygen goal achieved.)
  By 2014, achieve 40 percent (29.92 cubic
  km) of the long-term restoration goal of 100
  percent attainment of the dissolved oxygen
  water quality standards in all tidal waters of
  the Bay. (2008 baseline: 12 percent (8.98
  cubic km) of dissolved oxygen goal
  achieved.)
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By 2011, achieve 59 percent (95.88
million pounds) of the
implementation goal for nitrogen
reduction practices necessary to
achieve Chesapeake Bay water
quality standards, expressed as
nitrogen reduction in relation to
achieving a 162.5 million pound
reduction from 1985 levels (based on
long-term average hydrology
simulations). (2005 baseline: 41
percent of nitrogen goal achieved.)
By 2014, achieve 60 percent (97.43 million
pounds) of the implementation goal for
nitrogen reduction practices necessary to
achieve Chesapeake Bay water quality
standards, expressed as nitrogen reduction in
relation to achieving a 162.5 million pound
reduction from 1985 levels (based on long-
term average hydrology simulations). (2008
baseline: 47 percent of nitrogen goal
achieved.)
By 2011, achieve 74 percent (10.63
million pounds) of the
implementation goal for phosphorus
reduction in practices necessary to
achieve Chesapeake Bay water
quality standards, expressed as
phosphorus reduction in relation to
achieving a 14.36 million pound
reduction from 1985 levels (based on
long-term average hydrology
simulations). (2005 baseline: 58
percent of phosphorus goal
achieved.)
By 2014, achieve 74 percent (10.62 million
pounds) of the implementation goal for
phosphorus reduction practices necessary to
achieve Chesapeake Bay water quality
standards, expressed as phosphorus reduction
in relation to achieving a 14.36 million
pound reduction from  1985 levels (based on
long-term average hydrology simulations).
(2008 baseline: 62 percent of phosphorus
goal achieved.)
By 2011, achieve 74 percent (1.25
million tons) of the implementation
goal for sediment reduction practices
necessary to achieve Chesapeake Bay
water quality standards, expressed as
sediment reduction in relation to
achieving a 1.69  million ton
reduction from 1985 levels (based on
long-term average hydrology
simulations). (2005 baseline: 54
percent of sediment goal achieved.)
By 2014, achieve 83 percent (1.4 million
tons) of the implementation goal for
sediment reduction practices necessary to
achieve Chesapeake Bay water quality
standards, expressed as sediment reduction in
relation to achieving a 1.69 million ton
reduction from 1985 levels (based on long-
term average hydrology simulations). (2008
baseline: 64 percent of sediment goal
achieved.)
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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 is based on a scale where 1 is poor
and 5 is good.)
4.3.5 Improve the Health of the Gulf of
Mexico
                                           By 2014, 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 is
                                           based on a scale where 1 is poor and 5 is
                                           good.)
  By 2011, restore water and habitat
  quality to meet water quality
  standards in 162 impaired segments
  (cumulative) in 13 priority coastal
  areas (2002 baseline: 812 impaired
  segments identified in Section 303(d)
  listings.)
  By 2014, restore water and habitat quality to
  meet water quality standards in 160 impaired
  segments (cumulative) in 13 priority coastal
  areas. (2006 baseline:  0 segments restored.
  Baseline was reset to 0 in FY 2006 and
  measure is cumulative from FY 2007.)
  By 2011, restore, enhance, or protect
  a cumulative 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 2014, restore, enhance, or protect a
  cumulative 32,600 acres of important coastal
  and marine habitats. (2007 baseline: 18,660
  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
                     2
  to less than 5,000 km , as measured
  by the 5-year running average of the
  size of the zone. (Baseline: 2002-
  By 2015, reduce releases of nutrients
  throughout the Mississippi River Basin to
  reduce the size of the hypoxic zone in the
                                    2
  Gulf of Mexico to less than 5,000 km , as
  measured by the 5-year running average of
  the size of the zone. (Baseline: 2003-2007
                                 2
  running average size = 14,644 km .)
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  2006 running average size = 14,944
  km2.)
4.3.6 Restore and Protect Long
Island Sound: By 2011, prevent water
pollution, improve water quality,
protect aquatic systems, and restore the
habitat of Long Island Sound by
working through the Long Island Sound
Management Study Conference
partnership.
4.3.6 Restore and Protect Long Island Sound
  By 2014, reduce point source
  nitrogen discharges to Long Island
  Sound by 58.5 percent as measured
  by the Long Island Sound Nitrogen
  Total Maximum Daily Load.
  (TMDL). (TMDL 2000 baseline:
  213,151 Ibs/day; 2014 target: 85,238
  Ibs/day.)
  By 2014, reduce point source nitrogen
  discharges to Long Island Sound by 58.3
  percent as measured by the Long Island
  Sound Nitrogen Total Maximum Daily Load.
  (TMDL). (TMDL 2000 baseline: 59,146
  trade equalized (TE) Ibs/day; 2014 target:
  24,646 TE Ibs/day.)
  By 2011, reduce the size of hypoxic
  area in Long Island Sound (defined
  as the area in which 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 2014, reduce by 25 percent the size of the
  hypoxic area in Long Island Sound (i.e.,
  defined as the area in which the average
  maximum July-September dissolved oxygen
  level is <3mg/l in bottom waters 
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  protected.)
  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 cumulative baseline: 81 miles
  reopened.)
  By 2014, reopen 150 miles of river and
  stream corridor to anadromous fish passage
  in Long Island Sound watershed through
  removal of dams and barriers or installation
  of by-pass structures such as fishways. (2009
  baseline: 0 miles.)
4.3.7 Restore and Protect the South
Florida Ecosystem: Protect and
maintain the South Florida Ecosystem,
including the Everglades and coral reef
ecosystems.
4.3.7 Restore and Protect the South Florida
Ecosystem
  By 2011, 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 Bade, Broward, and Palm Beach
  Counties, Florida, working with all
  stakeholders (federal, state, regional,
  and local). (2005 baseline: Mean
  percent stony coral cover 6.7 percent
  in FKNMS and 5.9 percent in
  southeast Florida.)
  Through 2014, maintain "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 Bade, Broward, and Palm Beach
  Counties, Florida, working with all
  stakeholders (federal, state,  and local). (2005
  baseline: mean percent stony coral cover 6.8
  percent in FKNMS and 5.9 percent in
  southeast Florida.)
  Through 2011, beginning in 2008,
  annually maintain the overall health
  and functionality of sea grass beds in
  the FKNMS as measured by the
  long-term sea grass monitoring
  project that addresses composition
  and abundance, productivity, and
  nutrient availability. (The 2005
  baseline index of sea grass health
  Through 2014, annually maintain the overall
  health and functionality of sea grass beds in
  the FKNMS as measured by the long-term
  sea grass monitoring project that addresses
  composition and abundance, productivity,
  and nutrient availability. (2005 baseline:
  Elemental Indicator (El) - 8.3; Species
  Composition Index (SCI) -0.48.)
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will be available in December 2006.)
Through 2011, beginning in 2008,
annually maintain the overall water
quality of the near shore and coastal
waters for the FKNMS (2005
baseline: for reef sites, chlorophyll
less than or equal to 0.2 ug/1 and
vertical  attenuation coefficient for
downward irradiance (kd, i.e., light
attenuation) less than or equal to 0.13
per meter; for all sites in FKNMS,
dissolved inorganic nitrogen less than
or equal to 0.75 micromolar and total
phosphorus less than or equal to 0.2
micromolar.)
Through 2014, annually maintain the overall
water quality of the near shore and coastal
waters for the FKNMS. (2005 baseline: for
reef sites, chlorophyll less than or equal to
0.2 ug/1 (43 sites) and vertical attenuation
coefficient for downward irradiance (kd
measures light attenuation) less than or equal
to 0.13 per meter (23 sites); for all sites in
FKNMS, dissolved inorganic nitrogen less
than or equal to 0.75 micromolar (54 sites)
and total phosphorus less than or equal to 0.2
micromolar (63 sites).)
Through 2011, beginning in 2008,
improve the water quality of the
Everglades ecosystem as measured
by total phosphorus, including
meeting the 10 parts per billion (ppb)
total phosphorus criterion throughout
the Everglades Protection Area
marsh and the effluent limits to be
established for discharges from storm
water treatment areas. (2005
baseline: average annual geometric
mean phosphorus concentrations
were 5 ppb in the Everglades
National Park, 10 ppb in Water
Conservation 3 A, 13  ppb in the
Loxahatchee National Wildlife
Refuge, and 18 ppb in Water
Conservation Area 2A; annual
average flow-weighted total
phosphorus discharges from storm
Through 2016, improve the water quality of
the Everglades ecosystem as measured by
Total Phosphorus (TP), including meeting
the 10 parts per billion (ppb) TP criterion
throughout the Everglades Protection Area
marsh and the effluent limits to be
established for discharges from storm water
treatment areas. (2005 baseline:  average
annual geometric mean phosphorus
concentrations were 5 ppb in the Everglades
National Park, 10 ppb in Water Conservation
3 A, 13 ppb in the Loxahatchee National
Wildlife Refuge, and 18 ppb in Water
Conservation Area 2A; annual average flow-
weighted TP discharges from stormwater
treatment areas ranged from 13 ppb for area
3/4 and 98 ppb for area 1W.)
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  water treatment areas ranged from 13
  ppb for area 3/4 and 98 ppb for area
  1W.)
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.
4.3.8 Restore and Protect the Puget Sound
Basin
  By 2011, improve water quality and
  enable the lifting of 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 2014, improve water quality and enable
  the lifting of harvest restrictions in 1,600
  acres of shellfish bed growing areas impacted
  by degraded or declining water quality in the
  Puget Sound. (2007 baseline: 322 acres of
  shellfish beds with harvest restrictions in
  2006 had their restrictions lifted.)
  By 2011, remediate 200 acres of
  prioritized contaminated sediments.
  (Baseline: as of January 2006,
  approximately 5,000 acres of
  remaining contaminated sediments
  required some level of remediation.)
  By 2014, remediate 200 acres of prioritized
  contaminated sediments in the Puget Sound.
  (2008 baseline: zero acres remediated
  relative to the 2008 universe of
  approximately 500 acres of remaining
  contaminated sediments in EPA
  superfund/RCRA sites.)
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  By 2011, restore 3,500 acres of
  tidally- and seasonally-influenced
  estuarine wetlands. (Baseline: a total
  of approximately 45,000 acres of
  intertidal and near shore habitat were
  identified by state, tribal, and local
  groups as potential restoration sites
  in the 2006 Puget Sound Near Shore
  Restoration Site Inventory Database.)
  By 2014, restore 9,500 acres of tidally- and
  seasonally-influenced estuarine wetlands in
  the Puget Sound. (2007 baseline: 4,152 acres
  had been restored or protected starting in FY
  2006 and FY 2007.)
  By 2011, reduce total diesel
  emissions in the Puget Sound airshed
  by 8 percent through coordinated
  diesel emission mitigation efforts.
  (Baseline will be available in
  December 2006.)
  By 2014, reduce total diesel emissions in the
  Puget Sound airshed by 12 percent through
  coordinated diesel emission mitigation
  efforts. (Baseline: 2005-2006 Washington
  State Emissions Inventory for the counties
  within the Puget Sound basin.)
4.3.9 Restore and Protect the
Columbia River Basin: By 2011,
prevent water pollution, and improve
and protect water quality and
ecosystems in the Columbia River
Basin to reduce risks to human health
and the environment.
4.3.9 Restore and Protect the Columbia
River Basin
  By 2011, protect, enhance or restore
  13,000 acres of wetland habitat and
  3,000 acres of upland habitat in the
  Lower Columbia River watershed.
  (2005 baseline: 96,770 acres of
  wetland and upland habitat available
  for protection, enhancement, or
  restoration.)
  By 2014, protect, enhance or restore 19,000
  acres of wetland and upland habitat in the
  Lower Columbia River watershed. (2005
  baseline: 0 acres of wetland and upland
  habitat, with 96,770 acres available for
  protection, enhancement, or restoration.)
  By 2011, clean up 150 acres of
  known highly contaminated
  sediments. (Baseline: 400 acres of
  known highly contaminated
  sediments in the main stem of the
  Columbia River and Lower
  Willamette River as of 2006.)
  By 2014, clean up 85 acres of known highly
  contaminated sediments in the Columbia
  River basin. (2006 baseline: 0 acres, with
  400 acres of known highly contaminated
  sediment.)
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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.)
    By 2014, demonstrate a 10 percent reduction
    in mean concentration of certain
    contaminants of concern found in water and
    fish tissue in the Columbia River basin.
    (Chemical-specific baseline will be available
    at end FY 2009.)
4.4 Enhance Science and Research:
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.
4.4 Enhance Science and Research: 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.
                                          4.4.1 Human Health Research
                                            By 2012, achieve a rating of "meets
                                            expectations" or higher in independent
                                            expert review assessment of the utility of
                                            EPA research for assessing human health
                                            risk and protecting human health.
                                          4.4.2 Ecosystem Research
                                            By 2014, achieve a rating of "meets
                                            expectations" or higher in independent
                                            expert review assessment of the utility of
                                            EPA research for protecting and restoring
                                            ecosystems.
                                          4.4.3 Human Health Risk Assessment
                                          Research
                                            By 2011, achieve a rating of "meets
                                            expectations" or higher in independent
                                            expert review assessment of the utility of
                                            EPA health hazard information.
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  4.4.4 Global Climate Change Research
    By 2013, achieve a rating of "meets
    expectations" or higher in independent
    expert review assessment of the utility of
    EPA research for assessing the consequences
    of global change on air quality, water
    quality, ecosystems, and human health.
  4.4.5 Endocrine Disrupting Chemicals
  Research
    By 2012, achieve a rating of "meets
    expectations" or higher in independent
    expert review assessment of the utility of
    EPA research for decision-making related to
    effects, exposure, assessment, and
    management of endocrine disruptors.
  4.4.6 Safe Pesticides and Products Research
    By 2011, achieve a rating of "meets
    expectations" or higher in independent
    expert review assessment of the utility of
    EPA research for decision-making related to
    pesticides and toxics.
  4.4.7Homeland Security Research
    By 2012, achieve a rating of "meets
    expectations" or higher in independent
    expert review assessment of the utility of
    EPA research for protecting the public,
    emergency responders, and the environment
    in the event of chemical, biological, or
    radiological attack.
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Goal 5:  Compliance and Environmental Stewardship
Current (2006-2011) Strategic Plan

Objective
Sub-objective
Strategic Target
ProDOsed (2009-2014) Strategic Plan

Objective
Sub-objective
Strategic Measure
          GOAL 5: COMPLIANCE AND ENVIRONMENTAL STEWARDSHIP

  Protect human heath and the environment through ensuring compliance with
  environmental requirements by enforcing environmental statutes, preventing pollution,
  and promoting environmental stewardship. Encourage innovation and provide incentives
  for governments, tribes, businesses, and the public that promote environmental
  stewardship and long-term sustainable outcomes.

  Comment:  The interactions between EPA and the regulated communities are  reported
  under Goal 5. Pursuant to implementation provisions of the major  environmental
  statutes, compliance, assistance and enforcement activities can be delegated to the states,
  and in the case of the National Pretreatment Program, to individual municipalities.
  Thus, the vast majority of regulated entities do not interact directly with EPA, but with
  their state or local regulatory agencies. Because EPA has traditionally reported and
  measure only its direct activities in these areas, EPA should: (i) clarify if data reported
  for the Goal 5 objectives and sub-objectives will be universal or limited to direct EPA
  efforts, and (ii) identify the universe of activities undertaken by delegated state and local
  regulatory partners to demonstrate the significance of its own efforts. Finally, EPA
  should report on its activities undertaken in support of delegated state and local
  regulatory partners.
  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:
  3-year rolling average FYs 2003-2005:
  900,000,000 pounds.)
5.1 Achieve Environmental Protection
through Improved Compliance: Address
environmental problems, promote compliance
and deter violations, by achieving goals for
national priorities and programs including those
with potential environmental justice concerns
and those in Indian country.
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5.1.1 Compliance Assistance: By 2011,
prevent noncompliance or reduce
environmental risks, with an emphasis on
achieving results in all areas including
those 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: 50
percent of the regulated entities receiving
direct assistance improve environmental
management practices; and  12 percent of
the regulated entities receiving direct
assistance reduce, treat, or eliminate
pollution. (Baselines are determined each
year based on prior year results.)
5.1.1 Address Environmental Problems from
Air Pollution
                                             By 2014, reduce, treat, or eliminate XXX
                                             estimated pounds of air pollutants. Note:
                                             When reporting out the results for the
                                             pounds of pollutants estimated to be
                                             reduced, treated or eliminated measure,
                                             EPA will break out the "environmentally
                                             significant" pollutants for air. For this
                                             measure, OECA is defining
                                             "environmentally significant" as criteria
                                             air pollutants and air toxics.  (Baseline
                                             TBD.)
                                             By 2014, achieve an investment of$XXin
                                             pollution control equipment or practices
                                             for air. (Baseline TBD.)
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                                             By 2014, increase the percentage of EPA
                                             activities resulting in implementation of
                                             improved environmental practices for air.
                                             Note: EPA is exploring a range of
                                             activities to be included in this measure 's
                                             environmental results. Possible activities
                                             include cases, incentive initiatives,
                                             compliance assistance, and compliance
                                             monitoring. (Baseline  TBD.)
5.1.2 Compliance Incentives: By 2011,
identify and correct noncompliance and
reduce environmental risks, with an
emphasis on achieving results in all areas
including those with potential
environmental justice concerns.  Use of
compliance incentives will result in 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 practices at their  facilities,
including those in Indian country.
(Baseline: 3-year rolling average FYs
2003-2005: 940 facilities.)
5.1.2 Address Environmental Problems from
Water Pollution
                                             By 2014, reduce, treat, or eliminate XXX
                                             estimated pounds of water pollutants.
                                             (Baseline TBD.) Note: when reporting
                                             results for the pounds of pollutants
                                             estimated to be reduced, treated, or
                                             eliminated measure, EPA  will break out
                                             the "environmentally significant" water
                                             pollutants  that affect the top 5 to 10 causes
                                             of impairment to waters. For this measure,
                                             these "environmentally significant"
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                                            pollutants are nutrients (with related
                                             environmental effects), pathogens,
                                             mercury, other metals, sediment/turbidity,
                                             toxic organics, pH, temperature, and
                                             salinity.
                                             By 2014, achieve an investment of$XXin
                                             pollution control equipment or practices
                                             for water. (Baseline TBD.)
                                             By 2014, increase by Xpercent EPA
                                             activities resulting in implementation of
                                             improved environmental practices for
                                             water. Note: EPA is exploring a range of
                                             activities to be included in this measure 's
                                             environmental results. Possible activities
                                             include cases, incentive initiatives,
                                             compliance assistance, and compliance
                                             monitoring. (Baseline TBD.)
5.1.3 Monitoring and Enforcement: By
2011, identify, correct, and deter
noncompliance and reduce environmental
risks, with an emphasis on achieving
results in all areas including those 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 actions during
EPA inspections and evaluations after
deficiencies have been identified
(baseline to be determined based on FY
2006 results); a 5 percentage point
increase in  the percent of enforcement
actions requiring that pollutants be
5.1.3 Address Environmental Problems from
Waste, Toxics, and Pesticides Pollution
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reduced, treated, or eliminated (FY 2005
baseline: 28.8 percent); and a 5
percentage point increase in the percent of
enforcement actions requiring
improvement of environmental
management practices (FY 2005 baseline:
72.5 percent).
                                             By 2014, reduce, treat, or eliminate XXX
                                             estimated pounds of waste, toxics, and
                                             pesticides pollutants. Note: EPA is
                                             analyzing methods for reporting out
                                             "environmentally significant" pollutants
                                             for the pounds of pollutants estimated to be
                                             reduced, treated, or eliminated measure
                                             but has not yet selected the methodology.
                                             EPA is currently exploring a toxicity
                                             equivalent approach to this measure.
                                             (Baseline TBD.)
                                             By 2014, achieve an investment of$XXin
                                             pollution control equipment, practices, and
                                             future response actions for waste, toxics,
                                             and pesticides. (Baseline TBD.)
                                             By 2014, increase the percentage of EPA
                                             activities resulting in implementation of
                                             improved waste, toxics, and pesticide
                                             practices. Note: EPA is exploring a range
                                             of activities to be included in this
                                             measure 's environmental results. Possible
                                             activities include cases, incentive
                                             initiatives, compliance assistance, and
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compliance monitoring. (Baseline TBD.)
5.1.4 Criminal Enforcement
By 2014, increase the severity of the crimes
investigated (as measured by the percent of
open high impact cases). (Baseline TBD.)
Comment: This sub-objective is unclear.  Does EPA mean to suggest that increasing
the percentage of high impact cases left unresolved would be deemed an
improvement of some sort? Perhaps better targets/measures might be: (i) an X
increase in the percentage of investigations involving high impact activities, and (ii) a
X decrease in the percentage of unresolved high impact cases.
                                        By 2014, there will be an annual
                                        recidivism rate of Xpercent. (Baseline
                                        TBD.)	
                                        By 2014, Xpercent of closed cases will
                                        have a criminal enforcement consequence
                                        (indictment, conviction, fine, or penalty).
                                        (Baseline TBD.)
                                        By 2014, Xpercent of charged cases will
                                        have an individual that was charged.
                                        (Baseline TBD.)
Comment: This sub-objective is unclear.  Perhaps a better target measure might be
an X increase in the percentage of cases in which an individual(s) was charged as
well the corporation. Otherwise the simplest way to demonstrate improvement with
regard to this measure would be to focus on cases involving individuals while
ignoring cases involving corporations.
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5.2 Improve Environmental Performance
through Pollution Prevention and Other
Stewardship Practices: 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.
5.2 Improve Environmental Performance
through Pollution Prevention and Other
Stewardship Practices: By 2014, 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.
  5.2.1 Prevent Pollution and Promote
  Environmental Stewardship: By 2011,
  reduce pollution, conserve natural
  resources, and improve other
  environmental stewardship practices
  while reducing costs through
  implementation of EPA's pollution
  prevention programs.
  5.2.1 Prevent Pollution and Promote
  Environmental Stewardship
    By 2011, reduce 4.5 billion pounds of
    hazardous materials cumulatively
    compared to the 2000 baseline of 44
    million pounds reduced.
    By 2014, reduce 6.5 billion pounds of
    hazardous materials cumulatively
    compared to the 2007 baseline of 2.5
    billion pounds.
    Comment: The measured activity "hazardous materials reduction" is not well-
    defined. EPA should identify the universe of hazardous materials produced annually
    to demonstrate the significance of this target.
                                             By 2014, pollution prevention program
                                             participants will reduce xx million pounds
                                             of Chemical Assessment and Management
                                             Program (ChAMP) high priority chemicals
                                             of special concern cumulatively compared
                                             to the 2007 baseline ofxx million pounds
                                             reduced.
                                             By 2014, reduce xx million pounds of
                                             ChAMP high priority chemicals of special
                                             concern across all participating Agency
                                             programs.
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  By 2011, reduce, conserve, or offset
  31.5 trillion British Thermal Units
  (BTUs) cumulatively compared to the
  2002 baseline amount of 0 BTUs
  reduced, conserved, or offset.
  By 2014, reduce, conserve, or offset 10
  million metric tons of carbon equivalent
  (MMTCE) compared to the 2008 baseline
  amount of 2.5 MMTCE reduced,
  conserved, or offset.
  By 2011, reduce water use by 19
  billion gallons cumulatively compared
  to the 2000 baseline amount of 220
  million gallons reduced.
  By 2014, reduce water use by 50 billion
  gallons cumulatively compared to the 2007
  baseline amount of 11 billion gallons
  reduced.
  By 2011, save $791.9 million through
  pollution prevention improvements in
  business, institutional, and
  governmental costs cumulatively
  compared to the 2002 baseline of $0.0
  saved.
  By 2014, save $2.0 billion through
  pollution prevention improvements in
  business, institutional, and government
  costs cumulatively compared to the 2007
  baseline of $300 million dollars saved.
  By 2011, 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.
  By 2014, reduce 4 million pounds of
  priority chemicals as measured by the
  National Partnership for Environmental
  Priorities program, Supplemental
  Environmental Projects, and contributions
  from other tools used by EPA to achieve
  chemical reductions throughout the
  lifecycle of products.
5.2.2 Promote Improved
Environmental Performance through
Business and Community Innovation:
Promote Improved Environmental
Performance Through Business and
Community Innovation. Through 2011,
improve environmental performance with
sustainable outcomes through sector-
based approaches, performance-based
programs, and assistance to small
business.
5.2.2 Business and Community Innovation
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By FY 2011, the reported results of
Performance Track member facilities
collectively will show the following
normalized annual reductions: 5.1
billion gallons in water use; 13,000
tons of hazardous materials use;
230,000 megatons of carbon dioxide
equivalent (MTCOE) of greenhouse
gases; 300 tons of toxic discharges to
water; and 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 3.4
billion gallons in water use; 8,794 tons
of hazardous materials use; 151,129
MTCO2E of greenhouse  gases;  186
tons of toxic discharges to water; and
3,533 tons of combined NOx, SOx,
VOC, and PM emissions.)
By FY 2014, the reported results of
Performance Track member facilities
collectively will show the following
normalized cumulative reductions: XX
billion gallons in water use; XX tons of
hazardous materials use; XX megatons of
carbon dioxide equivalent (MTCO2E) of
greenhouse gases; XX tons of toxic
discharges to water; and XX tons of
combined NOx, SOx, VOC, and PM
emissions. (Performance Track member
facilities set goals and report yearly
progress on, performance improvements in
up to four environmental areas. In FY
2007, Performance Track members
achieved normalized cumulative reductions
of 18.6 billion gallons in water use; 89,200
tons of hazardous materials use; 1.2
million MTCO2E of greenhouse gases;
3,900 tons of toxic discharges to water; and
57,700 tons of combined NOx, SOx, VOC,
and PM emissions.)
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
by December 2006.)
By 2014, the participating manufacturing
and service sectors in the Sector Strategies
Program will achieve an aggregate XX
percent reduction in environmental releases
to air, water, and land, working from a
2004 baseline and normalized to reflect
economic growth.
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5.2.3 Promote Environmental Policy
Innovation: 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.
By 2011, innovation projects under the
State Innovation Grant Program and other
piloting mechanisms will achieve, on
average, an 8 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), or a 5 percent or
greater improvement in cost effectiveness
and efficiency. (Each project's
achievement will be measured by the
goals established in the grantee's
proposal. 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.)
5.2.3 Promote Environmental Policy
Innovation
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                                              By 2014, innovation projects under the
                                              State Innovation Grant Program and other
                                              piloting mechanisms will achieve, on
                                              average, an 8 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), or a 5 percent or greater
                                              improvement in cost effectiveness and
                                              efficiency. (Each project's achievement
                                              will be measured by the goals established
                                              in the grantee's proposal. 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.)
5.3 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.
5.3 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.
                                            5.3.1 Improve Human Health and the
                                            Environment in Indian Country
    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.)
    By 2014, increase the percent of tribes
    implementing federal regulatory
    environmental programs in Indian country
    by X percent. (FY 2008 baseline: 6 percent
    of 572 tribes.)
    By 2011, increase the percent of tribes
    conducting EPA-approved
    environmental monitoring and
    assessment activities in Indian country
    By 2014, increase the percent of tribes
    conducting EPA-approved environmental
    monitoring and assessment activities in
    Indian country by X percent. (FY 2008
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      to 26 percent. (FY 2005 baseline: 20
      percent of 572 tribes.)
    baseline: 21 percent of 572 tribes.)
      By 2011, increase the percent of tribes
      with an environmental program to 67
      percent. (FY 2005 baseline: 54 percent
      of 572 tribes.)
    By 2014, increase the percent of tribes with
    an environmental program by X percent.
    (FY 2008 baseline: 57 percent of 572
    tribes.)
      Comment: What is the difference between the first and third sub-objectives listed
      above, and why is the progress for these significantly different?

      The 2005 - 2008 baseline changes reported for the three sub-objectives above
      indicated progress of 1 percent, 1 percent and 3 percent respectively, over three
      years. At these rates of progress, it will take well into the 22nd century to achieve 100
      percent.	
  5.4 Enhance Society's Capacity for
  Sustainability Through Science and
  Research: Conduct leading-edge, sound
  scientific research on pollution prevention,
  new technology development,
  socioeconomics, 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.
5.4 Enhance Society's Capacity for
Sustainability Through Science and
Research: Conduct leading-edge, sound
scientific research on pollution prevention, new
technology development, and sustainable
systems. The products of this research will
provide critical and key evidence in informing
Agency polices and decisions and solving
complex multimedia problems for the Agency
and its partners and stakeholders.
                                              5.4.1 Science and Technology for
                                              Sustainability
                                                By 2011, achieve a rating of "meets
                                                expectations" or higher in independent
                                                expert review assessment of the utility of
                                                EPA research for preventing pollution,
                                                promoting environmental stewardship, and
                                                encouraging innovation.	
http://www.epa.gOv/greenpowerhttp://www.epa.gov/chphttp://www.epa.gov/owow/estuaries
/cre.htmlhttp://www.epa.gov/chemrtk/hpvis/aboutrbd.htmhttp://www.epa.gov/champhttp:/
/www.epa.gov/champ/pubs/champbriefing050808.pdfhttp://es.epa.gov/ncer/nanohttp://epa.
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gov/oppt/nano/stewardship.htmhttp://www.oecd.org/department/0,3355http://www.epa.gov
/grtlakes/collaboration/strategy.htmlhttp://www.epa.gov/region09/water/watershed/index.h
tmlhttp://www.epa.gov/champ
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Appendix II

                      2009-2014 Strategic Plan Change Document

                        Questions for Advisory Group Feedback



Overarching Questions:
The 2009-2014 Strategic Plan update is focusing on a small number of targeted areas where EPA
believes it can make the most significant improvements in strategies and performance
measurement that will advance the Agency's mission of protecting human health and the
environment.
       Do the proposed changes in Agency strategies and long-term strategic measures
       accomplish this?
       Within the targeted areas, are there any additional new or significantly different strategies
       that EPA should consider to improve environmental and human health outcomes?
       Are there other areas that you believe should be targeted?
Specific Follow-Up Areas
Goal 1:
       Relating to "Impacts of Global Climate Change," second bullet, on page 7 of the
       Strategic Plan Change Document, EPA is interested in feedback on organizations for
       collaboration with EPA's research program to leverage local government efforts in
       identifying and developing global climate change adaptation strategies.
Goal 2:
   •   Because the anticipated data are not available for measuring the shellfish acres impacted
       by anthropogenic sources that are approved for use, EPA is requesting input on a
       replacement shellfish measure (under Sub-objective 2.1.2).
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   •   As discussed on page 10 of the Change Document, EPA is pursuing some pilot efforts to
       improve the suite of water quality measures under Sub-objective 2.2.1.   EPA is
       interested in suggestions and reactions related to efforts to improve the  suite of water
       quality measures.
Goal 4:
       Similar to Goal 1, relating to "Impacts of Global Climate Change" on page 12 of the
       Change Document, EPA is interested in feedback on organizations for collaboration with
       EPA's research program to leverage local government efforts in identifying and
       developing global climate change adaptation strategies.
       Related to "Research Strategic Directions and Targets" on page 15, EPA is interested in
       feedback on any partnerships for developing ecological science indicators that have been
       useful to local government decision-makers.
Goal 5:
EPA's enforcement program is moving to a new problem-based performance measurement
structure in Goal 5 (Objective 5.1). While the Agency is interested in feedback on the new
approach overall, we are particularly seeking input on two areas:
       When EPA reports the results for the measure on pounds of water pollutants estimated to
       be reduced, treated or eliminated (Sub-objective 5.1.2), EPA will break out the
       "environmentally significant" water pollutants that affect the top 5 to 10 causes of Clean
       Water Act Section 303(d) listed impairment to waters. EPA currently plans to define
       "environmentally significant" pollutants as nutrients (with related environmental effects),
       pathogens, mercury, other metals, sediment/turbidity, toxic organics, pH, temperature,
       and salinity. We would like your reaction and ideas regarding this approach.
       EPA is investigating methods for reporting out "environmentally significant" waste,
       toxics, and pesticides pollutants for the measure on pounds of pollutants estimated to be
       reduced, treated or eliminated (Sub-objective 5.1.3), but has not yet selected the
       methodology. EPA is currently exploring a toxicity equivalent approach to this measure.
       Based on your experience, can you provide suggestions?
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Appendix III

Examples of Regulatory Innovation


A. NPDES program

The NPDES program has been identified over the years as one in need of an upgrade. In the
early 1990's EPA formed a Permit Improvement Team (PIT), which identified NPDES
streamlining as a high priority. In conjunction with streamlining, the group discussed ways in
which delegated states could be given more flexibility to improve the effectiveness of the
program, for example:

          •  Issuing watershed permits for all NPDES dischargers in a watershed;

          •  Allowing watershed-based trading;

          •  Focusing more resources on non-compliance issues and high-priority watersheds;

          •  Allowing permit renewals to be synchronized so all permits are reviewed
             simultaneously in a given watershed.

More recently, the State of Colorado has suggested that major NPDES discharges be inspected
less frequently in return for more frequent inspection of "minor" NPDES discharges, of which
there are many more compared to "majors" and, arguably, are significantly under-regulated.

Although there are arguments that legislation is needed to make changes to the NPDES program,
counter-arguments can be made that much can be done by regulation and policy while others,
such as allowing 10 year renewals rather than  5 year renewals, might require a change to the
Clean Water Act.

B.  Environmental Results Program

Eighteen states participate in the Environmental Results Program (ERP) Consortium, a group of
states that are embracing the Massachusetts-born alternative to traditional regulation. The ERP
program typically captures a large number of small, under-regulated facilities such as dry
cleaners, printers, photo-processors, and gas stations that collectively have a significant
environmental footprint. The program consists of the following steps:

The state:

   •   conducts an inventory of all facilities,
   •   develops a baseline  compliance rate with existing regulations (in some cases, facilities
       are operating, illegally, outside the regulatory system), and,
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   •   based on the initial inventory and compliance evaluation,
   •   rolls out a comprehensive technical assistance program to inform the facilities how to get
       into compliance and stay in compliance.

The facilities must then certify that they are in compliance or identify where they need to get into
compliance and commit to doing so. This is done annually through a self-certification on-line
system.

The state then conducts random, numerically statistically significant inspections to assess overall
compliance and takes enforcement action where necessary for non-compliant facilities or those
that fail to certify.

This system takes less time and has proven to be more effective than traditional command-and-
control regulation. The states would not have the resources to conduct the thousands of
inspections needed at all of these small facilities. The ERP program shifts some of the burden to
the facilities themselves, and provides more robust assessment tools for the state agency to
ensure improved compliance from the sector.

Although EPA has funded ERP development in the states, it has not embraced this tool for its
own regulatory programs. There is an opportunity to mainstream ERP within EPA core programs
in the new Administration.

C. Differential  Oversight

States with delegated federal programs have suggested that EPA use more discretion in
determining the level of state oversight needed. It is wasteful and duplicative to have sound,
effective, and in some cases, state run programs that are more protective than EPA's, burdened
by intervention with little value added by EPA.

EPA might be better served to evaluate state and tribal programs, and shift oversight resources to
states and tribes that are under-performing, and undertake other activities to augment regulatory
programs in those jurisdictions that need less oversight.
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Appendix IV

NACEPT Strategic Plan Workgroup
Members

NACEPT Members

Mr. Joel Bol stein
Partner
Environmental Law Practice Group
Fox Rothschild LLP

Mr. Clayton Matt
Department Head
National Resource Department
Confederated Salish and Kootenai Tribes

Ms. Jennifer Nash
Workgroup Co-Chair
Director of Policy and Programs
Product Stewardship Institute, Inc.

Ms. Arleen O'Donnell
Board of Directors
Massachusetts Environmental Trust

Mr. Robert Olson
Senior Fellow
Institute for Alternative Futures
Ms. Victoria Tschinkel
Executive Committee Member
1000 Friends of Florida

Dr. Dan Watts
Workgroup Co-Chair
Research Professor
New Jersey Institute of Technology

Supplemental Member

Mr. Richard Sustich
Industrial and Governmental Development
Manager
Center of Advanced Materials for
Purification of Water with Systems
University of Illinois at Urbana-Champaign

NACEPT Chair

Mr. John Howard
Partner
Vinson & Elkins, LLP

NACEPTDFO

Ms. Sonia Altieri
NACEPT Designated Federal Officer
Office of Cooperative Environmental
Management (OCEM)
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Appendix V

Public Comments



 From:         ChickenLady86@aol.com

 To:           Sonia Altieri/DC/USEPA/US@EPA

 Date:         12/09/2008 05:39 PM

 Subject:       Environmental Research
The five EPA goals are Clean Air and Global Climate Change, Clean and Safe Water, Land Preservation
and Restoration, Healthy Communities and Ecosystems, and Compliance and Environmental
Stewardship.

The Science Channel had a show about researching various ways of producing needed resources from
waste. Methane from manure and landfills. Waste (sewage) water recycling into drinking water.  Growing
plants in places normally not used.  These units were all independent of one another. This independence
was not financially economical.

Why not combine all under one roof or as one facility?  From various forms of waste to methane, and
clean water, which feeds growing plant greenhouses with water and fertilizer.  These facilities could be
built near cities using the city's waste.

With so many of big companies reducing staff, a facility like this would turn our world around.
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                              NACEPT
                              Shaping the Nation's Environmental Policy
                             National Advisory Council for
                         Environmental Policy and Technology
December 30, 2008
The Honorable Stephen L. Johnson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Re: NACEPT's Comments on EPA's Draft 2009-2014 Strategic Plan Change Document

Dear Administrator Johnson,

On behalf of the National Advisory Council for Environmental Policy and Technology, I am
pleased to forward you our comments  on EPA's Draft 2009-2014 Strategic Plan Change
Document. The Strategic Plan is among the Agency's most important documents; it articulates
where the Agency will direct its resources over the coming half-decade and the progress it seeks
to achieve. We commend EPA for undertaking  a formal strategic planning process that targets
its highest priorities. By stating priority areas up front and including strategic measures from the
previous plan alongside proposed new measures, this  draft offers greater opportunities for
meaningful public input than ever before.

Our advice letter answers three questions: (1) Are the targeted areas that EPA has identified the
right ones?   (2)  Are the  proposed  strategies and measures sufficient?  (3)  Is the Change
Document appropriately integrated with the other EPA planning initiatives and documents?  In
addition, it includes answers to several questions  OCFO has posed, as well as detailed comments
on specific performance measures and examples  of possible regulatory innovation initiatives we
encourage EPA to consider. We would like to draw your attention to the following main points.

Are the targeted areas that EPA  has  identified the right ones?  EPA now faces a once-in-a-
generation opportunity to refocus  and  take bold  steps.  This document represents only a  partial
response to that opportunity.  The areas it has targeted are appropriate, but should be integrated
within an overarching  sustainability  framework.  Climate  change should be elevated  as the
preeminent environmental  concern, and  EPA  should take the lead  among federal  agencies
working to address this problem.   Some other important issues are  missing, including water
resources sustainability  and support  for  technology  development  and  commercialization.
Perhaps most important, the  proposed plan should speak more directly to the need for more
collaborative  problem solving, both within the  Agency across media offices and with other
federal, state, and tribal entities, in order to achieve environmental progress.

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Are the proposed strategies and measures sufficient? In terms of strategies, we notice a positive
shift towards more thorough, sustainability-orientated approaches to environmental  problems.
Still, we would like to see bolder strategies that reflect the urgency of today's environmental
problems.  We recommend a stronger emphasis on innovative regulatory strategies  and more
attention to coordination among regulatory agencies, states, and tribes. We urge that pollution
prevention will once again become an agency priority.

In terms  of the proposed measurement framework,  we  call  on the Agency  to consider
sustainability measures.  While difficult to conceptualize and implement, sustainability is the
ultimate  measure of EPA's success.  Many strategic  measures  are lacking in ambition and
evidence  a disturbing  willingness to delay achievement of environmental  quality  goals for
decades - in some cases, until the next century.

Is the Change  Document appropriately integrated with  other EPA  planning initiatives?
NACEPT has for some  time  urged  EPA  to  link its  strategic plan with its  other planning
documents, particularly its Report on the Environment,  proposed  budget, and Performance and
Accountability Reports.  Such integration would help readers understand the Agency's priorities
more clearly. While the proposed plan references the Report on the Environment, it does not tell
us which measures will be subject to the Program Assessment Rating Tool (PART) review or the
level of resources allocated to different initiatives. We would welcome that explanation.

We look forward to the opportunity to discuss our comments with you and to further engagement
to strengthen the proposed plan.

                                         Sincerely,
                                        John L. Howard, Jr.
                                        Chair
cc:     Jennifer Nash, Working Group Co-Chair
       Dan Watts, Working Group Co-Chair
       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 & Accountability/OCFO
       Rafael DeLeon, Director, Office of Cooperative Environmental Management
       Sonia Altieri, NACEPT Designated Federal Officer

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