U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Catalyst for Impro ving the En vironment
Evaluation Report
Regional Public Liaison Program
Needs Greater Focus on Results
and Customer Awareness
Report No. 09-P-0176
June 24, 2009
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Report Contributors: Bram Hass
Larry Dare
Eric Lewis
Abbreviations
EPA U.S. Environmental Protection Agency
FTE Full-Time Equivalent
OIG Office of Inspector General
OSWER Office of Solid Waste and Emergency Response
RPL Regional Public Liaison (formerly Regional Superfund Ombudsman)
RSO Regional Superfund Ombudsman
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
09-P-0176
June 24, 2009
Catalyst for Improving the Environment
Why We Did This Review
The Office of Inspector
General (OIG) evaluated the
actions taken by the U.S.
Environmental Protection
Agency's (EPA's) Office of
Solid Waste and Emergency
Response (OSWER) to
implement its Regional Public
Liaison (RPL) program.
We also reviewed program
changes resulting from a 2003
OIG report.
Background
Responding to the 2003 OIG
report, EPA in 2004 revised its
Superfund Regional
I Ombudsman program,
renamed staff RPLs, and
established national program
(guidance. The RPLs help the
public and regulated
community by (1) providing
information and facilitating
informal contact with EPA
staff, (2) helping resolve
problems, and (3) making
recommendations for
improvement to Agency
senior management.
For further information,
contact our Office of
Congressional, Public Affairs
and Management at
(202)566-2391.
To view the full report,
click on the following link:
www.epa.qov/oiq/reports/2009/
20090624-09-P-0176.pdf
Regional Public Liaison Program Needs Greater
Focus on Results and Customer Awareness
What We Found
OSWER's RPL program does not sufficiently focus on or measure specific
outputs and outcomes and is not consistently implemented across offices. RPLs
report results in varied formats, and OSWER does not consolidate program results
into a comprehensive report. As a result, RPLs reported annual results that could
not be readily consolidated to show what RPLs had achieved. The program does
not sufficiently focus on results because it lacks clear program logic. Developing
a logic model would help define outputs and outcomes and encourage a results-
oriented approach to program implementation. A more consistent and
comprehensive approach would also raise stakeholder awareness of the RPL
program.
Despite limited resources, RPLs have assisted many stakeholders since the
program was revised in 2004. New guidance more clearly described program
expectations and sought to provide more consistent program implementation
across regional offices.
What We Recommend
We recommend that OSWER use a logic model approach to revise the RPL
program to help focus on outputs and outcomes and ensure stakeholders are aware
of the RPL resource. Also, OSWER should revise the 2004 RPL guidance to
reflect program revisions and build in minimum requirements for stakeholder
awareness activities, including a national RPL Website.
OSWER concurred and described planned corrective actions to address all of our
recommendations. OSWER stated it has requested assistance from OSWER's
Center for Program Analysis to conduct a logic model assessment starting during
the RPLs' National Meeting, June 16-18, 2009. OSWER's response explains that
this assessment will lead to revised guidance that will include minimum
requirements for stakeholder awareness activities.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
June 24, 2009
MEMORANDUM
SUBJECT:
FROM:
TO:
Regional Public Liaison Program Needs Greater Focus
on Results and Customer Awareness
Report No. 09-P-0 176
Wade T. Najjum
Assistant Inspector General
Office of Program Evaluation
Mathy Stanislaus
Assistant Administrator
Office of Solid Waste and Emergency Response
This is our final report on the subject review conducted by the Office of Inspector General (OIG) of
the U.S. Environmental Protection Agency (EPA). This report contains findings that describe
concerns the OIG has identified and corrective actions the OIG recommends. This report represents
the opinion of the OIG and does not necessarily represent the final EPA position. Final
determinations on matters in this report will be made by EPA managers in accordance with
established resolution procedures.
The estimated cost of this report - calculated by multiplying the project's staff days by the applicable
daily full cost billing rates in effect at the time - is $355,483.
Action Required
We believe the written response you provided to the draft report meets the requirements of EPA
Manual 2750 for a written response within 90 days of the date of this report. We request that you
inform us as you complete each corrective action so we may update our tracking system. We have
no objections to the further release of this report to the public. This report will be available at
http ://www. epa. gov/oig.
If you or your staff have any questions regarding this report, please contact Eric Lewis at
202-566-2664 or lewis.eric@epa.gov, or Larry Dare at 202-566-2138 or dare.larry@epa.gov.
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Regional Public Liaison Program Needs 09-P-0176
Greater Focus on Results and Customer Awareness
Table of Contents
Chapters
1 Introduction 1
Purpose 1
Background 1
Noteworthy Achievements 2
Scope and Methodology 3
2 Focusing on Results Would Provide Greater Program
Consistency and Facilitate Measuring Results 4
RPL Program Needs Greater Focus on Outputs and Outcomes 4
OSWER Should Analyze Program Logic to Focus on Results 6
Regional Resources Devoted to RPL Program Varied Greatly 6
Performance Agreements Should Include RPL Role 7
Consistent Implementation Would Improve Stakeholder Awareness 7
Conclusions 9
Recommendations 9
Agency Response and OIG Comment 10
Status of Recommendations and Potential Monetary Benefits 11
Appendices
A Agency Response to Draft Report 12
B Distribution 15
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09-P-0176
Chapter 1
Introduction
Purpose
The Office of Inspector General (OIG) reviewed the U.S. Environmental
Protection Agency's (EPA's) Regional Public Liaison (RPL) program within the
Office of Solid Waste and Emergency Response (OSWER) to answer the
following questions:
• Is the RPL program being implemented consistently across offices?
• How does EPA measure the results (outputs and outcomes) of this
program, including its impact on the involved communities and the
environmental problems they face?
We also looked at whether the program implemented recommendations made in
our March 13, 2003, report, EPA Regional Super fund Ombudsmen Program
Needs Structure (2003-S-00004).
Background
EPA created Regional Superfund Ombudsman (RSO) positions in each regional
office as part of the Superfund Administrative Reforms effort in 1996. The RSOs
facilitate resolution of stakeholder concerns and provide a forum so States and
communities can be more informed and involved in clean-up decisions. Prior to
this reform, stakeholders raised concerns with regional personnel but had no
formal mechanism to have their issues elevated. When EPA appointed the 10
RSOs in June 1996, it issued a press release saying:
The establishment of an ombudsman position in each EPA region
will help resolve Superfund issues that fall through the cracks in
the current system. Through these ombudsmen, who will work
closely with the EPA headquarters ombudsman, the public will
have access to an EPA employee who will be able to cut through
red tape to investigate complaints and arrange meetings with
appropriate staff to try to resolve problems. The ombudsmen will
have the authority to cut across bureaucratic lines to get answers
and resolve problems quickly.
In our March 2003 report, we noted that EPA does not have a management
system in place to ensure its RSOs are accountable for fulfilling their
responsibilities. The RSO program was generally a collateral duty within the
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Superfund program. As a result, there was a perceived lack of independence and
impartiality. Further, a lack of guidance had caused uncertainty over the RSO
program. The report pointed out that changing the title of the RSOs would allow
them to continue to provide a valuable service by informally resolving issues at a
local level, and would alleviate the perception that they should meet the American
Bar Association's core characteristics of impartiality and independence. Also, to
ensure consistent performance and results, we recommended that OSWER
provide guidance describing the roles and responsibilities of the position.
Responding to our report recommendations, OSWER issued guidance in March
2004, OSWER Guidance for the Regional Public Liaisons (OSWER 9200.0-48).
The guidance changed the "Regional Superfund Ombudsman" title to "Regional
Public Liaison," and allowed regions, at their discretion, to broaden the former
RSOs' scope beyond Superfund to include programs that OSWER administers
under nine other Acts. It described the purpose of the RPLs as "... to provide
information and assistance to the public in resolving issues and concerns raised
about the programs administered by OSWER." The guidance explains that the
RPL may be called on to serve in a number of capacities:
• Provide information and facilitate informal contact with EPA staff.
• Help resolve problems.
• Make recommendations to Agency senior management aimed at
improving OSWER programs.
The RPL program provides stakeholders the opportunity to be involved in
OSWER programs and serves as an important internal control to reduce the risk
that stakeholders' concerns will go unanswered. In issuing the guidance,
OSWER's Deputy Assistant Administrator's cover memo stated that".. .the RPLs
have been a useful resource for people outside the Agency who have needed
assistance or had concerns about the program. They have helped numerous
individuals and defused many potentially difficult situations." He pointed out that
the purpose of the guidance was to strengthen the effectiveness of the RPLs by
establishing a clear and consistent set of operating principles and procedures. He
viewed the guidance as a sound framework for RPL activities that still allowed
each region to implement a program that was consistent with its own needs and
organization.
Noteworthy Achievements
RPLs have assisted many stakeholders since the program was revised in 2004.
New guidance more clearly described program expectations and sought to provide
more consistent program implementation across regional offices. The name of the
program was changed from Ombudsman to Regional Public Liaison to more
accurately reflect the nature of the program.
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Scope and Methodology
We reviewed OSWER's RPL program from January 2008 through May 2009 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the evaluation to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our evaluation objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions based on
our evaluation objectives. We limited our review of management controls and
compliance to those directly relating to the issues identified. Office of
Management and Budget Circular A-123 notes that internal controls are a means
of managing the risk associated with federal programs and operations.
We analyzed the current RPL guidance and identified documentation and
guidance from predecessor programs. We obtained annual reports, resource
estimates, job descriptions, performance agreements, meeting minutes, and other
information about how RPLs carried out their duties. We conducted searches of
EPA's national and regional Websites to determine whether stakeholders could
readily find the RPLs, whether RPL names were up to date, and whether RPLs
were listed on Superfund site descriptions. We communicated with eight current
and five former RPLs. We also visited Region 2 to obtain an understanding of
how an extensive RPL effort operated.
As previously noted, we reviewed a March 2003 OIG report to determine whether
our recommendations in that prior report had been implemented. We also
reviewed Government Accountability Office reports and testimony.
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Chapter 2
Focusing on Results Would Provide Greater Program
Consistency and Facilitate Measuring Results
OSWER's RPL program does not sufficiently focus on or measure specific
outputs and outcomes and is not consistently implemented across offices.
Although RPLs are dedicated to helping their customers, the current design and
implementation limit the program's potential to effectively serve the public and
measure results. RPL guidance describes three primary roles: helping members
of the public gain access to information, helping resolve problems, and initiating
positive institutional change to prevent similar problems in the future. However,
because regional offices implement the program differently, offices report results
that are not comparable and do not provide a clear picture of the program's
overall accomplishments. A more consistent and comprehensive approach would
also raise stakeholder awareness of the RPL program.
RPL Program Needs Greater Focus on Outputs and Outcomes
The 2004 RPL guidance does not define outputs or outcomes for RPLs to track as
they carry out their responsibilities. As a result, RPLs reported annual results that
could not be readily consolidated to show what RPLs had achieved. Without a
clear link between program objectives and expected outputs and outcomes, the
program will have little chance of achieving its intended results.
EPA's Office of Policy, Economics, and Innovation defines outputs and outcomes
as follows:
• Outputs: A measure of products and services provided as a direct result
of program activities.
• Outcomes: Accomplishments of program goals and objectives.
The RPL guidance states that each RPL should provide an annual report to his/her
Regional Administrator with a copy to the Assistant Administrator for OSWER
describing numbers and types of issues that the RPL addressed. It goes on to note
that the annual report could be used to make process and organizational
recommendations and address publicly issues of concern, but does not require a
consolidated report.
Based on this requirement, RPLs should be reporting outputs ("numbers.. .of
issues and concerns... addressed"). Categorizing them by "types of issues and
concerns" is left up to the RPLs. Because each RPL categorizes reporting outputs
differently and there was no shared format, RPL reports we reviewed were not
consistent. For example:
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• One RPL provided several breakouts, including information requests
versus assistance requests, and categorization by EPA program area as
well as the source of the request.
• One RPL showed number of contacts received, number that were site-
related, and number referred.
• One RPL with only a few cases described them and noted whether they
were open or closed at the end of the fiscal year.
• One RPL reported no major cases but referred 15-20 calls to other
divisions.
None of the RPLs summarized activities by the three roles of the RPL (providing
information, cutting red tape, and initiating institutional change). Unless the
RPLs use comparable categories when tracking and reporting on inquiries and
cases, it will be difficult to summarize overall RPL program results.
While the reporting requirement does not require RPLs to track outcomes, we
believe it would be beneficial. We found two outcome categories in sections
where the guidance discussed other subjects: (1) "resolving problems," and
(2) "members of the public.. .gain access to information.. .that will help them
participate more fully in established Agency processes." Program outcomes also
could be described in terms of the RPLs' three key roles. Outputs and outcomes
should be integrated into an overall program design for tracking and reporting.
Although EPA reported it had measures for the earlier RSO program, one RPL
told us that no common output or outcome measures were ever provided to the
regions. None are currently being used. These measures are listed in the
Government Accountability Office's May 2000 report on Superfund
Administrative Reforms.1 One measure was the number of cases for which EPA
conducted investigations and mediations. Another was whether the public's
perceptions of EPA's decisions improved.
To capture and assess outputs and outcomes, RPLs must collect and report
comparable data regarding program accomplishments. They instead use different
methods to track cases and collect different data about program accomplishments.
For example, one RPL uses a spreadsheet to log cases while others use less formal
methods. Annual reports also capture results differently; some RPLs simply
summarize the results of each case they handled during the year, while others
produce relatively detailed reports. Further, not all RPLs sent annual reports each
year. Without comparable data and reporting, the RPL program cannot conduct the
kind of analysis necessary to evaluate results, identify areas for improvement in the
RPL program, or encourage institutional reform in OSWER-related programs.
1 SUPERFUND: Extent to Which Most Reforms Have Improved the Program Is Unknown, May 2000, GAO/RCED-
00-118.
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The RPL program coordinator does not produce a consolidated annual report that
would show the RPL program's accomplishments. National guidance requires each
RPL to submit a report annually but does not require a consolidated report.
Nonetheless, we believe a national report would be beneficial.
OSWER Should Analyze Program Logic to Focus on Results
Given its limited resources, we believe the RPL program would benefit by using a
logic model. We analyzed OSWER's 2004 guidance for RPLs to determine if a
logic model could be constructed from its description of the program. The guidance
did not provide all the elements needed for a usable logic model. If the RPL
program design was based on a logic model, then it would focus more specifically
on defining outputs and outcomes and thus more clearly on program results.
EPA training materials explain that a logic model is a diagram and text that
describes/illustrates the logical (causal) relationships among program elements
and the problem to be solved, thus defining measurements of success. Logic
models help managers answer key questions and understand and check
assumptions on how the program is supposed to work. These models can support
program improvement and evaluation, helping to answer such questions as:
• What am I doing, with whom, and to whom/what?
• How well am I doing it?
• Is anybody (anything) better off in either the short or long term?
• What role, if any, did my program play in the results?
• What role, if any, did factors unrelated to the program play in the results?
• Were there any unintended outcomes, and if so, why?
EPA and many other organizations use logic models to better define the
relationship of resources; customers; outputs; and short-, medium-, and long-term
results (or outcomes). This technique enables one to determine whether the
program is set up to succeed and facilitates program evaluation. The EPA Office of
Policy, Economics, and Innovation's logic model training stresses that meaningful
measuring of program performance requires a clear understanding of what a
program does and the results it is intended to accomplish. EPA and the Office of
Management and Budget endorse and make use of the logic model approach.
Regional Resources Devoted to RPL Program Varied Greatly
Resources used by the various regions for the RPL program varied greatly, and
one benefit of using a logic model approach is that it could help OSWER and the
regional offices assess the adequacy of resources.
According to estimates provided by the RPLs and the program coordinator, the
entire RPL program used about 2.5 FTEs in 2008. Implementing the RPL
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program is a collateral duty for most RPLs. One RPL (Region 2) estimated his
region's effort at 1.9 FTEs. He and two assistants handle several hundred
inquiries per year among other duties. Their inquiries come from the region's
main Web inquiry system, a Superfund hotline, direct contacts from stakeholders,
and referrals from EPA staff. Another RPL reported spending about 35 percent of
his time on RPL matters. RPL estimates for other regions ranged from 1 percent
to 10 percent of one FTE. We believe that spending such a small amount of time
may not allow RPLs to carry out the full extent of their duties. Further, two
regional offices do not have anyone designated as RPL. Several RPLs and other
regional staff attributed the limited RPL resources devoted to cases in their
regions to excellent community relations.
Performance Agreements Should Include RPL Role
The 2004 RPL guidance states that RPL duties should be included in the
individual's annual performance agreement:
... The RPL is accountable for the successful performance of
his/her official duties, as defined in his/her position description
and more specifically delineated in his/her annual performance
agreement.
We found that two of the eight current RPL performance agreements did not
mention their RPL roles. Four RPLs had general statements related to their RPL
duties. Two had more specific wording related to their RPL role. None referred to
the 2004 OSWER guidance. We found no common wording or description of
duties among those we reviewed. A common understanding and written description
of RPL duties in performance agreements would help ensure that the regions
implemented the RPL program more consistently and achieved program outputs
and outcomes.
Consistent Implementation Would Improve Stakeholder Awareness
A more consistent and comprehensive approach would raise stakeholder
awareness of the RPL program. EPA should ensure that stakeholders who may
need RPLs are aware of their existence and can reach them easily. Currently, the
guidance does not address awareness efforts. Based on information provided by
RPLs and our checks of regional Websites, we found that EPA's efforts to inform
stakeholders about the RPL program are inconsistent. For example, 4 of 10
regional Websites did not mention the program. Stakeholders may learn of the
RPL program from the RPL directly (at public meetings, for example), from other
EPA staff, or from EPA documents and Internet sites.
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RPL Guidance Does Not Address Stakeholder Awareness
The 2004 RPL guidance does not advise RPLs on ensuring that stakeholders
know the RPLs exist. The guidance states that "If community members believe
that the official Agency procedures have failed to adequately address their
concerns, they may ask the RPL to help them get information or assistance from
within the system." It does not describe how RPLs inform stakeholders outside
EPA of their availability.
When the RPLs' predecessor RSO program started in 1996, implementation plans
prepared by several regional offices described methods for publicizing the
existence of that program. For example, Region 2's 1996 Implementation Plan
stated that".. .The degree to which the public is made aware of the ... Program
and its availability and accessibility will determine the effectiveness of the
Program. Therefore, it is imperative that EPA's stakeholders become aware of
the program's availability, capability and limitations." The plan listed various
activities including creating a toll free telephone number, distributing fliers at
certain Superfund sites describing the program, and providing handout materials
to elected officials and the public. The plan also suggested coordinating with a
wide range of other regional EPA staff and State agencies; developing an RSO
Web page; and meeting with citizens, community members, and special interest
groups. Implementation plans for Regions 7 and 10 listed similar activities.
A handbook for an even earlier ombudsman program stated that the program's
effectiveness depended to a large extent on public awareness, noting that"... Any
system for handling complaints is of no use unless the public can actually get into
the system when the need arises." It specified certain actions, such as: developing
program fliers and brochures, providing a Federal Register notice, contacting
congressional representatives, listing the ombudsman separately in telephone
directories, and including a description of the program in employee orientation.
Various Techniques Used by Regions to Raise Awareness
Raising awareness of the RPL program varies among regions, and some
techniques could be easily implemented. Some RPLs have taken specific steps to
ensure stakeholders are aware of their program. Others appear to take a passive
approach, only reacting to inquiries if and when they receive them. Although
RPL staff discussed a draft early in the program, they have never produced a
national brochure.
Some RPLs told us that they have attended public meetings to explain their role
and share their contact information. One RPL noted that he developed a brochure
and handed it out at public meetings. He also mailed a notification about his
availability to all Potentially Responsible Parties associated with the sites in his
region and to the local jurisdictions where the sites are located. Further, he
reported joining EPA colleagues on site visits.
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Greater Visibility on Websites Could Help
Some regional Websites lack any apparent mention of the RPL. EPA's Websites
are one key avenue for reaching people and organizations that might benefit from
RPL assistance. EPA Policy 2191.0 emphasizes the importance of the Internet by
stating, "The EPA Web site is a fundamental part of every Agency program; taken
together, these pages are the foundation of the Agency's environmental outreach
and communication program." We found no reference to the RPL on four
regional Websites. Also, when we checked regional Superfund site fact sheets
listed on regional Websites, we found that only two regions included RPL contact
information with the site. On one site we found that the RPL was included in the
body of the site description document; in the other, the RPL was mentioned in a
side banner next to the site description. Because EPA considers Websites such an
important part of its awareness and communication efforts, the RPLs should be
prominently displayed on each Website and with site descriptions.
The list of RPLs on EPA's national Website was last updated in 2003 and is
currently outdated. That list follows a description of the program's origin in the
1996 Superfund Administrative Reforms. However, we recently found that
EPA's community involvement Websites now include a link to a Regional Public
Liaison site that is under development. Program managers and RPLs have
discussed plans to develop an RPL Website, prepare a brochure, and add an
article about the RPLs to the community involvement program's Web page.
These steps should be undertaken only after the program has defined its program
logic and intended outputs and outcomes.
Conclusions
The RPL program provides an important link between concerned stakeholders and
an EPA liaison who can provide assistance. It should provide OSWER an internal
control to reduce the risk that significant stakeholders' concerns go unaddressed.
However, the program currently has design and operational deficiencies that hinder
its chances of success. These deficiencies can be addressed by defining the
program logic and performance measures (outputs and outcomes), better use of
performance agreements, and improving stakeholder awareness of RPLs.
Recommendations
We recommend that the Assistant Administrator for Solid Waste and Emergency
Response:
2-1 Develop an RPL program logic model to:
• identify outputs and outcomes,
• assess resource needs, and
• revise the program's design to help RPLs achieve the desired
outputs and outcomes.
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2-2 Adopt common data reporting elements across all regional offices and
collect, summarize, and report comparable data.
2-3 Report results annually in a consolidated, national report.
2-4 Develop and use a common performance agreement element for all RPLs.
The element should refer to the national RPL program guidance when
defining the RPL role and expected outputs and outcomes.
2-5 Make stakeholders aware of the RPL program by sharing contact
information through regional staff, site descriptions, and a national
Website linked to each regional RPL Website.
2-6 Revise the 2004 RPL guidance as necessary to reflect revisions in the
program and build in minimum requirements for stakeholder awareness
activities.
Agency Response and OIG Comment
OSWER concurred and described planned corrective actions to address all of our
recommendations. OSWER stated is has obtained contractor support to develop a
national RPL Website and has requested assistance from OSWER's Center for
Program Analysis to conduct a logic model assessment starting during the RPLs'
National Meeting, June 16-18, 2009. The week after the meeting, OSWER told
us that it started work on the logic model during the national meeting and will get
contractor support to help complete it. OSWER's response to our draft report said
that the assessment will lead to common data reporting elements, revised
guidance that will include minimum requirements for stakeholder awareness
activities, and a common RPL performance agreement element. After adopting
common data reporting elements, the RPL program will begin submitting
consolidated national reports. We believe these actions will address our
recommendations and we will close out the recommendations as those actions are
completed.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
POTENTIAL MONETARY
BENEFITS (in $OOOs)
Claimed Agreed To
Amount Amount
2-1 9 Develop an RPL program logic model to (1) identify
outputs and outcomes, (2) assess resource needs,
and (3) revise the program's design to help RPLs
achieve the desired outputs and outcomes.
2-2 10 Adopt common data reporting elements across all
regional offices and collect, summarize, and report
comparable data.
2-3 10 Report results annually in a consolidated, national
report.
2-4 10 Develop and use a common performance
agreement element for all RPLs. The element
should refer to the national RPL program guidance
when defining the RPL role and expected outputs
and outcomes.
2-5 10 Make stakeholders aware of the RPL program by
sharing contact information through regional staff,
site descriptions, and a national Website linked to
each regional RPL Website.
2-6 10 Revise the 2004 RPL guidance as necessary to
reflect revisions in the program and build in
minimum requirements for stakeholder awareness
activities.
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
09/30/2009
03/31/2010
03/31/2011
10/01/2010
09/30/2009
10/01/2010
0 = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is undecided with resolution efforts in progress
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Appendix A
Agency Response to Draft Report
June 10, 2009
MEMORANDUM
SUBJECT: Response to Draft Public Liaison Report: "Regional Public Liaison Program Needs
Greater Focus on Results and Customer Awareness" (Project No. OCPL-FY08-003)
FROM: Barry N. Breen/s/
Deputy Assistant Administrator
TO: Eric Lewis, Director, Special Reviews
Office of Program Evaluation
PURPOSE
The purpose of this memorandum is to provide a written response to the findings of the
Draft Evaluation Report: "Regional Public Liaison Program Needs Greater Focus on Results
and Customer Awareness" (Project No. OCPL-FY08-0003). My staff has reviewed the draft
report and agrees with the conclusions presented in the draft report. Below you will find the
corrective actions we have initiated or planned for each recommendation.
RECOMMENDATIONS AND OSWER RESPONSE
Recommendation 2-1
Develop a Regional Public Liaison (RPL) program logic model to (1) identify outputs and
outcomes; (2) assess resource needs, and (3) revise the program's design to help RPLs achieve
the desired outputs and outcomes.
OSWER Response: The RPL program has initiated discussions with staff in the Office of Solid
Waste and Emergency Response, Center for Program Analysis, to conduct a logic model
assessment. The logic model assessment will be conducted during the Regional Public Liaison
National Meeting, June 16-18, 2009. The RPL program expects to complete the logic model
assessment by September 30, 2009.
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Recommendation 2-2
Adopt common data reporting elements across all regional offices and collect, summarize, and
report comparable data.
OSWER Response: The RPL program will adopt common data reporting elements across all
regional offices once the logic model assessment is complete. Initial discussions on this
recommendation will be conducted during the Regional Public Liaison National Meeting, June
16-18, 2009. The RPL program expects to implement common data reporting elements across
all regional offices by March 31, 2010.
Recommendation 2-3
Report results annually in a consolidated national report.
OSWER Response: The RPL program will report results in a consolidated national report after
common data reporting elements have been adopted across all regional offices. The RPL
program expects to submit the first consolidated national report by March 31, 2011. This report
will include information from calendar year 2010.
Recommendation 2-4
Develop and use a common performance agreement element for all RPLs. The element should
refer to the national RPL program guidance when defining the RPL role and expected outputs
and outcomes.
OSWER Response: The RPL program will develop and use a common performance agreement
element for all RPLs. Initial discussions on this recommendation will be conducted during the
Regional Public Liaison National Meeting, June 16-18, 2009. The development of a final
common element for performance agreements is dependent on the completion of the logic model
assessment. The RPL program expects to implement a common performance element by
October 1, 2010.
Recommendation 2-5
Make stakeholders aware of the RPL program by sharing contact information through regional
staff, site descriptions, and a national website linked to each regional RPL website.
OSWER Response: The RPL program will develop a national website linked to each regional
RPL website. The RPL program has obtained contractor support to develop a national website.
A draft version of the national website will be available for review and comment during the RPL
National Meeting, June 16-18, 2009. The RPL program expects to publish the final website by
September 30, 2009.
Recommendation 2-6
Revise the 2004 RPL guidance as necessary to reflect revisions in the program and build in
minimum requirements for stakeholder awareness activities.
OSWER Response: The RPL program will revise the 2004 RPL guidance to reflect revisions in
the program ascertained from the logic model assessment and build in minimum requirements
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for stakeholder awareness activities. The RPL program expects to implement the revised
guidance by October 1, 2010.
CONCLUSIONS
If you have any questions about these comments, please contact Karen L. Martin at
703-603-9925, or martin.karenl@epa.gov.
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Appendix B
Distribution
Office of the Administrator
Assistant Administrator, Office of Solid Waste and Emergency Response
Acting Regional Administrators, Regions 1-10
Principal Deputy Assistant Administrator, Office of Solid Waste and Emergency Response
Director, Office of Superfund Remediation and Technology Innovation
Acting Director, Office of Regional Operations
Acting General Counsel
Acting Associate Administrator for Congressional and Intergovernmental Relations
Acting Associate Administrator for Public Affairs
Agency Follow-up Official (the CFO)
Agency Follow-up Coordinator
Audit Follow-up Coordinator, Office of Solid Waste and Emergency Response
Audit Follow-up Coordinators, Regions 1-10
Public Affairs Officers, Regions 1-10
Acting Inspector General
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