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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
EPA Met or Exceeded Most
Internal Climate Change Goals,
But Data Quality and Records
Management Procedures
Need Improvement
Report No. 14-P-0325	July 29, 2014

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This is one of the U.S. Environmental Protection Agency Office of Inspector General's
products associated with climate change. For details on our other reports on climate
change, go to http://www.epa.gov/oig/climatechange.
Report Contributors:
Rudolph M. Brevard
Hilda Canes Garduno
Leon Carter
Christine El-Zoghbi
Michael Goode
Bram Hass
Eric Jackson
Doug LaTessa
Eric Lewis
Nyquana Manning
Nicole Pilate
Teresa Richardson
Brooke Shull
Mary Anne Strasser
Abbreviations
EPA	U.S. Environmental Protection Agency
FY	fiscal year
GHG	greenhouse gas
OARM	Office of Administration and Resources Management
OIG	Office of Inspector General
OMB	Office of Management and Budget
SSPP	Strategic Sustainability Performance Plan
Cover photo: Green roof, wind turbines and solar panels at the EPA's Atlantic Ecology
Division Laboratory in Narragansett, Rhode Island. (EPA photo)
Hotline

To report fraud, waste or abuse, contact us
through one of the following methods:
email:
OIG Hotline@.epa.qov
phone:
1-888-546-8740
fax:
1-202-566-2599
online:
http://www.epa.qov/oiq/hotline.htm
write:
EPA Inspector General Hotline

1200 Pennsylvania Avenue, NW

Mailcode 2431T

Washington, DC 20460
Suggestions for Audits or Evaluations
To make suggestions for audits or evaluations,
contact us through one of the following methods:
email:	OIG WEBCOMMENTS@epa.gov
phone:	1-202-566-2391
fax:	1-202-566-2599
online:	http://www.epa.g0v/0ig/c0ntact.html#Full Info
write: EPA Inspector General
1200 Pennsylvania Avenue, NW
Mailcode 241OT
Washington, DC 20460

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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
14-P-0325
July 29, 2014
Why We Did This Review
The congressional Bicameral
Task Force on Climate Change
requested that we assess
U.S. Environmental Protection
Agency (EPA) implementation
of policies that address climate
change at EPA facilities to
ensure the EPA was meeting
requirements.
To address this request, we
evaluated the EPA's
implementation of requirements
under Executive Order 13514,
"Federal Leadership in
Environmental, Energy, and
Economic Performance." To
meet the requirements of the
order, the EPA developed a
2012 Strategic Sustainability
Performance Plan that
identified its progress in
meeting internal agency goals
related to greenhouse gas
emissions, among others.
We also reviewed the EPA's
implementation of EPA Office
of Inspector General (OIG)
recommendations made in
2011 to adjust its greenhouse
gas reductions goal based on
funding and project status.
This report addresses the
following EPA goals or
cross-agency strategies:
•	Addressing climate change
and improving air quality.
•	Working toward a
sustainable future.
For further information,
contact our public affairs office
at (202) 566-2391.
The full report is at:
www.epa.qov/oiq/reports/2014/
20140729-14-P-0325.pdf
EPA Met or Exceeded Most Internal Climate
Change Goals, But Data Quality and Records
Management Procedures Need Improvement
Most Climate Change Goals Met
Improving data quality and
records management
procedures can support
confidence in the reliability
of EPA's progress reports
on its climate change goals.
The EPA adhered to most climate change
requirements for federal agencies. With a few
exceptions, the EPA provided documentation to
support its reported 2012 accomplishments. The
EPA exceeded its climate change goals and
requirements related to water use, greenhouse
gas emissions and renewable energy. The EPA was one of only three agencies
out of 25 reporting that received a green scorecard on the OMB sustainability
scorecard for fiscal year (FY) 2013 and has achieved a green scorecard the last
3 years. In addition, the EPA voluntarily tracks and reports data for its leased
buildings that are 50,000 square feet or larger. In response to the
recommendation from the 2011 OIG report, the EPA incorporated a review of its
greenhouse gas reduction goals as part of its annual Strategic Sustainability
Performance Plan submission, and it agreed to make adjustments to the overall
reduction goal as needed. Since the agency is on track to meet its 2020
greenhouse gas reduction goals and it has developed a process to revise the
goals, we believe this prior OIG recommendation has been addressed.
Areas Where Improvements Are Needed
We identified several internal control weaknesses in the EPA's data quality
assurance procedures and adherence to its Records Management Policy that
need to be addressed. The agency relies heavily on a contractor to collect water
and energy data used in the 2012 Strategic Sustainability Performance Plan and
also relies on the contractor to perform its own quality assurance review of data
presented in the plan, which, due to EPA inattention, could increase the
likelihood that inaccurate data gets overlooked. Further, we identified data errors
in the plan. The agency also lacks sufficient internal controls for electronic
stewardship and data center accomplishments reported in the plan. Additionally,
we identified areas where the EPA was not in full compliance with the agency's
Records Management Policy. Specifically, EPA accomplishment data reported in
the 2012 Strategic Sustainability Performance Plan related to fleet management,
waste diversion and acquisitions have not been appropriately maintained and
documented.
Recommendations and Planned Agency Corrective Actions
We recommend that the agency establish procedures to conduct a quality
assurance review of Strategic Sustainability Performance Plan data provided by
the contractor and EPA program offices. We also recommend that the agency
develop and implement procedures for maintaining and securing records
associated with production of the annual Strategic Sustainability Performance
Plan in accordance with the EPA's Records Management Policy. The agency
agreed with our recommendations and provided a corrective action plan.

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£ MM ro	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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*L PRO"*4-	THE INSPECTOR GENERAL
July 29, 2014
MEMORANDUM
SUBJECT: EPA Met or Exceeded Most Internal Climate Change Goals,
But Data Quality and Records Management Procedures Need Improvement
Report No. 14-P-0325
FROM: Arthur A. Elkins Jr. /AM*f ^
TO:	Craig Hooks, Assistant Administrator
Office of Administration and Resources Management
This is our 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 the problems
the OIG has identified and corrective actions the OIG recommends. This report represents the opinion of
the OIG and does not necessarily represent the final EPA position. Final determinations on matters in
this report will be made by EPA managers in accordance with established audit resolution procedures.
The EPA office having primary jurisdiction over the issues evaluated is the Office of Acquisition
Management within the Office of Administration and Resources Management.
Action Required
In accordance with EPA Manual 2750, your office provided acceptable and complete planned corrective
actions in response to OIG recommendations. All recommendations are resolved and no final response
to this report is required. We will post this report to our website at http://www.epa.gov/oig.

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EPA Met or Exceeded Most Internal Climate Change Goals, But Data
Quality and Records Management Procedures Need Improvement
14-P-0325
Table of C
Why We Did This Review		1
What the Executive Order Says		1
EPA Met Most of Its 2012 Planned Climate Change Goals		3
Goal 1: GHG Reduction and Inventory Requirements for Management		4
Goal 2: Buildings and Energy Use		5
Goal 3: Fleet Management		7
Goal 4: Water Use		7
Goal 5: Pollution Prevention and Waste Reduction		8
Goal 6: Acquisition		8
Goal 7: Electronics and Data Centers		8
Goal 8: Agency Innovation		9
Areas Where Improvements Are Needed		9
EPA Relies on Contractor to Verify SSPP Data		10
Improved Controls Needed for Electronic Acquisitions Database		10
Improved Controls Needed to Verify Data Center Performance Metrics		10
Improved Record Keeping Procedures Can Ensure Data Accuracy		11
Recommendations		11
Agency Response to Draft Report and OIG Evaluation		12
Status of Recommendations and Potential Monetary Benefits		13
Appendices
A Scope and Methodology		14
B Agency Response to Draft Report and OIG Comments		15
C Distribution		24

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Why We Did This Review
The congressional Bicameral Task Force on
Climate Change requested that the U.S.
Environmental Protection Agency's (EPA's)
Office of Inspector General (OIG) assess the
agency's implementation of policies that address
climate change. The task force sent similar
requests to nearly 70 Inspectors General
throughout the federal government. To address
this request, the EPA OIG evaluated the EPA's
implementation of Executive Order 13514,
"Federal Leadership in Environmental, Energy,
and Economic Performance," as documented in
the EPA's 2012 Strategic Sustainability
Performance Plan (SSPP). Executive Order
13514 (referred to in this report as the Executive
Order) establishes an integrated strategy toward
sustainability in the federal government and
makes reduction of greenhouse gas (GHG)
emissions a priority for all federal agencies.
Our objectives were to:
(1)	Conduct a follow-up review on the EPA's implementation of the OIG's
recommendation to "make adjustments to the GHG emission reductions
and/or reduction goals based on actual funding and status of projects, and
revise the EPA's overall reduction goal if needed during the annual update
of the Strategic Sustainability Performance Plan." This recommendation
was made, and agreed to by the EPA, in the OIG's April 2011 Report No.
11 -P-0209, EPA's Plan to Reduce Agency Greenhouse Gas Emissions
Is on Track to Meet Executive Order 13514 Requirements.
(2)	Assess the extent to which the agency is meeting its 2012 SSPP
objectives.
What the Executive Order Says
To promote energy security and protect the health of our environment, President
Obama signed Executive Order 13514 on October 5, 2009. The Executive Order
requires all federal agencies to meet specific goals related to the reduction of
GHG emissions, conservation of water resources, local planning, fleet
management, energy efficiency, electronics stewardship, pollution prevention and
the advancement of sustainable acquisitions. The Executive Order requires
SEFA==—
U.S. Environmental Protection Agency
Strategic Sustainability Performance Plan
FY 2010-FY 2020
June 29,2012
	


22


1

Figure 1: EPA's 2012 SSPP report
is at: http://www.epa.gov/oaintrnt/
documents/sspp2012 508.pdf
(Source: EPA website)
14-P-0325
1

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agencies to develop targets for GHG emissions reductions based on the "scope" of
emissions sources, as described below and illustrated in figure 2.
•	Scope 1 emissions are direct GHG emissions from sources owned or
controlled by the EPA. This includes emissions from fossil fuels burned
onsite, from EPA-owned or -leased vehicles, and other direct sources.
•	Scope 2 emissions include indirect emissions resulting from the
generation of EPA-purchased electricity, heat or steam power.
•	Scope 3 emissions include indirect emissions from sources not owned or
directly controlled by the EPA but related to its activities, such as
employee business travel, local commuting and waste disposal.
Figure 2: Sources of Scope 1, 2 and 3 GHG emissions. (Source: EPA websitej
Requirements for Management of Climate Change Goal
Accomplishment Data
We identified three requirements that apply to the EPA's management of its
climate change goal data.
First, federal agencies are required to describe how they will achieve the
environmental, economic and energy goals mandated by the Executive Order in
an SSPP. The SSPP must be updated annually and submitted to the White House
Council on Environmental Quality and the Office of Management and Budget
(OMB). In the SSPP, the EPA must identify specific agency goals and milestones,
as well as activities, plans and procedures relevant to the agency's implementation
of the order. In addition, all federal agencies must establish and report a GHG
inventory to the OMB. The EPA's Assistant Administrator for the Office of
Administration and Resources Management (OARM) is the Senior Sustainability
Officer responsible for ensuring implementation of the Executive Order at the
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EPA. To ensure compliance with the order, the EPA has informed its senior
managers—including Assistant Administrators, Regional Administrators and
Laboratory Directors—of their responsibilities in implementing the Executive
Order requirements.
Second, the EPA has other general requirements and responsibilities related to
internal controls that apply to its SSPP reporting data. OMB Circular A-123,
"Management's Responsibility for Internal Control," dated December 2004,
defines internal control responsibilities in federal agencies. It states that
management is responsible for establishing and maintaining internal control to
achieve the objectives of effective and efficient operations, reliable financial
reporting, and compliance with applicable laws and regulations. For example,
good internal controls include appropriate documentation and access to that
documentation. OMB Circular A-123 also states that periodic reviews,
reconciliations or comparisons of data should be included as part of the regular
assigned duties of federal agency personnel, and periodic assessments should be
integrated as part of management's continuous monitoring of internal control.
Third, the agency has internal records management requirements. The EPA's
Records Management Manual outlines requirements and responsibilities related to
maintaining, securing, disposing and transferring of agency records. EPA offices
must capture records to:
•	Maintain adequate and proper documentation and evidence of agency
activities for the time required to meet all program, audit and historical
need.
•	Maximize the usefulness of the records while active and allow for
interoperability and sharing of records across programs and information
systems.
•	Allow for timely access and retrieval.
•	Safeguard records from loss, misuse, and unauthorized access to or
modification of information.
•	Facilitate the identification and preservation of permanent records.
EPA Met Most of Its 2012 Planned Climate Change Goals
Overall, we found that the EPA met or exceeded most federal sustainability
requirements under the Executive Order, as reported in the 2012 SSPP. With a
few exceptions noted later, the EPA provided documentation to support its
reported SSPP accomplishments. The EPA has guidance for the collection and
verification of data on GHG emissions and energy and water use, and the
guidance is updated annually and includes data quality assurance procedures.
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The OMB uses a scorecard process to measure the federal government's
sustainability performance. The scorecard employs a simple evaluation system:
green for success; yellow for mixed results; and red for unsatisfactory. Through
the OMB scorecard process, agencies are assessed on several sustainability areas,
including: energy intensity, water intensity, fleet petroleum use, GHG pollution,
green building practices and renewable energy use. The EPA was one of only
three agencies out of 25 reporting that received a green scorecard on the OMB
sustainability scorecard for fiscal year (FY) 2013. The EPA has achieved a green
scorecard the last 3 years. Our analysis of the EPA's 2012 SSPP accomplishments
for each goal is summarized below.
Goal 1: GHG Reduction and Inventory Requirements for Management
We confirmed that the EPA is on track to meet its
goals related to GHG emissions.1 The EPA's FY 2020
goal for Scope 1 and 2 GHG emission reductions is
25 percent from its FY 2008 baseline. For Scope 3
emissions, the EPA's goal is an 8 percent reduction
from its FY 2008 baseline. We verified that the EPA
had records and data to demonstrate that it reduced its
Scope 1 and 2 emissions by a combined 57 percent
and its Scope 3 emissions by 10 percent in FY 2011.
As stated in the SSPP, the EPA achieved these
reductions through energy efficiency projects at its
facilities, improved fleet management practices and
green power purchases. The EPA's renewable energy purchases enabled the
agency to reduce its reported GHG emissions under current guidance from the
White House Council on Environmental Quality.
In addition, the EPA tracked and
reported GHG emissions data for both
required and non-required facilities.
Although agencies are not required to
report GHG emissions for facilities
that are leased, the EPA collects
facility GHG data for its leased
buildings that are 50,000 square feet
or larger on a quarterly basis and
voluntarily reports these emissions.
To verify GHG emissions data, which
include data on the agency's energy
and water use, renewable energy
purchases, and commuter and business
travel emissions, we reviewed
1 GHG emissions are measured in metric tons of carbon dioxide equivalent.
Videoconference equipment is used
by the EPA to reduce business travel
emissions. (Source: EPA website)
Roof-top solar panels supply "green" electricity to the EPA's National Health
and Environmental Effects Research Laboratory in Corvallis, Oregon.
(Source: EPA website)
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spreadsheets compiled by the EPA's contractor. We also reviewed original data
from utility bills and renewable energy contracts for a sample of EPA facilities.
In response to the recommendation from our FY 2011 report, the agency
incorporated a review of its GHG reduction goals as part of its annual SSPP
submission, and it agreed to make adjustments to the overall reduction goal based
on the previous year's progress and available funding. Since the agency is on
track to meet its 2020 GHG reduction goals, and it has developed a process to
revise the goals if needed, we beli eve this recommendation has been addressed.
Goal 2: Buildings and Energy Use
We confirmed through data and document
reviews the agency's reported achievements
in meeting its goals for energy intensity,
high performance sustainable buildings,
Energy Savings Performance Contracts and
regional/local planning initiatives.
Energy Use. The EPA is required to reduce
its energy intensity by 3 percent annually.2
EPA data shows that the agency achieved its
FY 2011 energy intensity reduction goal of
18 percent. The agency achieved energy
savings by initiating and completing several
major capital improvement projects to
improve energy efficiency at its facilities in
FY 2011. The agency also derived
0.68 percent of its energy use from onsite
renewable resources, such as wind, solar and
r _
Solar lighting lines the roadways at the EPA's
Research Triangle Park facility in North
Carolina. According to the EPA, this is the
longest stretch of solar-luminated roadway in
the United States. Solar lighting is part of the
agency's green power efforts. (Source: EPA
website)
geothermal power.3 In addition, the agency
was required to complete energy assessments at 75 percent of high-energy use
facilities by FY 2011. We determined, based on data collected by the EPA's
contractor, that the agency exceeded the 75 percent target and completed more
than the required number of assessments (78 percent).
2	Energy intensity is energy use (measured in British thermal units) per gross square foot.
3	The EPA has onsite renewable resources at 12 facilities, located in: Athens. Georgia; Chelmsford, Massachusetts;
Narragansett, Rhode Island; Edison, New Jersey; Montgomery, Alabama: Research Triangle Park, North Carolina
(Main Office. National Computer Center and Childcare Center); Ada, Oklahoma; Golden, Colorado; Manchester,
Washington; and Corvallis, Oregon.
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Advanced electric meter and boiler at the EPA's laboratory in Manchester, Washington. The EPA is
required to install advanced metering equipment to capture energy consumption at its facilities to the
maximum extent practicable. The EPA also initiated a project at its Manchester lab to retrofit fuel oil-fired
boilers with natural gas to reduce GHG emissions and save on fuel costs. (EPA photos)
High Performance Sustainable
Buildings. We confirmed that EPA
documentation supports its 2012 SSPP
accomplishments related to sustainable
building management. For example, we
verified documentation demonstrating
the EPA's claims that 7.8 percent of the
agency's buildings measuring greater
than 5,000 square feet met the Guiding
Principles for Federal Leadership in
High Performance and Sustainable
Buildings in FY 2011. We also
confirmed through records review that
45 construction projects and lease
actions went through the EPA's
GreenCheck process, which applies
sustainability requirements to projects
requiring funding in excess of $85,000.
Energy Savings Performance Contracts. The Energy Savings Performance
Contracts initiative required federal agencies to enter into a minimum of
$2 billion in performance-based contracts to improve federal building energy
efficiency by December 2013. We confirmed that the EPA identified two potential
Energy Savings Performance Contracts, totaling $9 million. The agency plans to
pursue other proposed contracts to determine whether they are economically
feasible and advantageous.
Regional/Local Planning. The agency's accomplishments in regional and local
planning include participation in the Partnership for Sustainable Communities,
and cooperation with other federal agencies to publish information resources
about sustainable strategies for locating federal facilities.
The EPA Region 8 building's green roof in Denver, Colorado, is
an example of sustainable building practices used by the agency.
The roof helps to regulate building temperature, reduce
stormwater runoff and absorb carbon dioxide.
(Source: EPA website)
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Goal 3: Fleet Management
We confirmed the EPA's accomplishments
related to fleet management and fossil fuel
reductions by reviewing agency fleet data in
the Federal Automotive Statistical Tool
database. The agency is required to reduce
its petroleum consumption by 30 percent by
FY 2020 from its FY 2005 baseline. The
EPA's fleet data show that it reduced
petroleum consumption by approximately
33 percent in FY 2011 from its 2005
baseline. This reduction more than doubled
the EPA's interim petroleum reduction target
of 12 percent for FY 2011.
As reported in the SSPP, the EPA did not
reach its requirement to increase alternative fuel4 consumption by 10 percent
annually. The agency's FY 2011 alternative fuel consumption was approximately
32 percent less than its target of 79,000 gasoline gallon equivalents. Additionally,
EPA fleet data support that the agency exceeded its Energy Policy Act
requirement to ensure that at least 75 percent of vehicle acquisitions were
alternative fuel vehicles, excluding law enforcement and emergency response
vehicles. The agency also eliminated 42 vehicles from its fleet in FY 2011.
Goal 4: Water Use
The EPA is required to improve its water use
efficiency and management by reducing
potable water consumption intensity3 by
2 percent annually through FY 2020 relative
to its FY 2007 baseline (i.e., 26 percent). We
reviewed agency water use data to confirm
that the EPA reduced its potable water use
intensity by more than 15 percent in FY 2011
from its FY 2007 baseline. The agency also is
required to reduce its non-potable water
consumption for industrial, landscaping and
agricultural uses by 2 percent annually through FY 2020 compared to its FY 2010
baseline (i.e., 20 percent). Agency data support that the EPA reduced its non-
potable water use by 58 percent in FY 2011 from the prior year. The EPA
achieved this through water conservation and storm water management projects.
Photo of plug-in hybrid vehicle. The EPA
acquired 153 alternative fuel vehicles to reduce
its petroleum consumption and increase its
alternative fuel consumption in FY 2011.
(Source: www.fueleconomv.gov)
Water cistern used to collect and store
rainwater for landscaping at childcare center
at the EPA's Research Triangle Park facility
in North Carolina. (Source: EPA website)
4	Alternative fuels are non-petroleum fuels. They include gaseous fuels such as hydrogen and natural gas, alcohols
such as ethanol. vegetable and waste-derived oils, and electricity.
5	Water use intensity is measured in gallons per gross square foot per year.
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Goal 5: Pollution Prevention and Waste Reduction
We confirmed that the EPA has documentation to support its accomplishments on
pollution prevention and waste reduction as reported in the SSPP. The Executive
Order requires the EPA to minimize the generation of waste and pollutants
through source reduction, and divert6 at least 50 percent of non-hazardous solid
waste and 50 percent of construction and
demolition waste by the end of FY 2015.
EPA data show that it achieved a waste
diversion rate of 59 percent for
solid waste, as well as construction and
demolition waste, in FY 2011. We also
reviewed EPA documentation to confirm
that the agency is reducing waste through
prevention assessment projects and other
prevention efforts such as the
agencywide "Think Beyond the Bin"
program.
Goal 6: Acquisition
We were able to verify documentation for most of the EPA's accomplishments
related to acquisition. The EPA Acquisition System has been fully implemented
agencywide and contains data fields for recording environmental attributes, such
as the energy or water efficiency of a product or service, or whether a product
contains recycled content. We also verified through document and data review
that the EPA implemented initiatives to improve acquisition planning, market
research and procurement data collection. However, we could not confirm the
agency's assertion that it met or exceeded the Executive Order requirement to
procure 95 percent of new contracts with green attributes for 3 consecutive years
(2009, 2010 and 2011). Specifically, the methodology used to calculate the
percentage of new contract actions with green attributes was not documented
properly and could not be replicated.
Goal 7: Electronics and Data Centers
We were able to confirm through document and data review, software assessments
and a site visit to the EPA's National Computer Center that the agency achieved
many of its reported SSPP accomplishments related to electronic stewardship and
data centers. The agency deployed software that is capable of establishing power-
management settings for computers and monitors to 100 percent of all eligible
EPA computers and monitors. Also, we verified that the EPA's personal computer
standard details numerous "green" requirements in accordance with the Executive
6 Waste diversion is the prevention and reduction of generated waste through source reduction, recycling, reuse or
composting.
THINK
REDUCING WASTE
AT EPA FACILITIES
The Think Beyond the Bin campaign, launched in
FY 2011, encourages facilities to strengthen their
waste diversion efforts through source reduction,
recycling, reuse and composting. (Source: EPA
Intranet website)
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Order. We also reviewed the EPA's claim that "virtualization7 is extensively used
to support database hosting" at the EPA's data centers. Virtualization enables
multiple operating systems to be located and independently operated from one
physical server instead of the "one server one operating system" platform
previously used. The EPA's implementation of virtualization helps the agency
become more energy efficient by restructuring processes associated with server
operations. The consolidation of physical servers can save energy, translating to
savings of up to 80 percent in data center energy costs while reducing
infrastructure and capital costs. In this area we found that the EPA's National
Computer Center has made significant strides in virtualizing its database hosting
infrastructure. As of 2012, the
National Computer Center had
virtualized 71 percent of its hosted
databases. However, as of 2012,
all EPA data centers had only
virtualized 38 percent of their
hosting infrastructure. We also
found that the EPA lacks internal
controls to validate its electronic
stewardship data.
Goal 8: Agency Innovation
The 2012 SSPP described future activities that the EPA would undertake, but it
did not report the EPA's specific FY 2011 accomplishments for providing agency
innovation and governmentwide support for meeting the Executive Order goals.
Areas Where Improvements Are Needed
We identified several instances where the EPA lacked sufficient internal controls
for gathering and reporting data in the 2012 SSPP. We found that the agency:
•	Lacked procedures to ensure that accurate data was reported and generated
by its contractor.
•	Did not have adequate procedures for verifying data accuracy in the
Federal Electronic Challenge database, which the EPA relies on for
reporting its electronic stewardship goals.
•	Does not have sufficient internal controls to verify performance metrics
for the EPA's data centers.
•	Lacked procedures for data collection, storage and manipulation measures
(i.e., record keeping) for several metrics reported in the 2012 SSPP.
EPA policy requires that ail of its retired electronic products
are reused, donated, sold or recycled using environmentally
sound management practices (Source: EPA website)
7 According to the EPA's Office of Environmental Information "virtualization" is a "method of partitioning one or
more physical servers into multiple virtual machines.''
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EPA Relies on Contractor to Verify SSPP Data
A majority of the data reported in the 2012 SSPP related to GHG reduction,
energy use and water use was managed by an EPA contractor. However,
sufficient internal controls were not in place to verify the data collected and
generated by the contractor. The EPA only seeks to verify the data if it sees an
issue or problem with the data during a "visual check." According to an EPA
official, first-line facility managers check the data. While there is additional data
quality review at headquarters, the OIG does not believe these data quality review
processes are adequate. The EPA relies heavily on its contractor not only to
collect the data used in the SSPP but to conduct "self-supervised" quality
assurance reviews.
Lack of sufficient internal controls resulted in the inclusion of undefined data in
the SSPP. Specifically, because mileage data for privately owned vehicle usage
are available on an annual basis only, the contractor did not have corresponding
quarterly data for privately owned vehicles. The contractor had to use substitute
privately owned vehicle data to calculate total EPA business travel GHG
emissions for the second quarter of FY 2011 through the first quarter of FY 2012.
The EPA deferred to the contractor to explain the substitute data. However, the
contractor's response did not explain how the substitute data was developed. The
EPA's lack of sufficient internal controls may increase the risk that inaccurate
data is reported or accomplishments could be over- or understated in the SSPP.
Improved Controls Needed for Electronic Acquisitions Database
The agency did not implement an internal control process that ensures accuracy of
Federal Electronic Challenge acquisitions. The Federal Electronic Challenge
database is used to report data related to electronic stewardship goals. Some EPA
locations that report data to the Federal Electronic Challenge database may
provide supplemental documentation to validate the data, but this is not
mandatory. A draft Standard Operating Procedure has been developed, but it has
not been finalized and distributed to other EPA reporting locations.
Improved Controls Needed to Verify Data Center Performance Metrics
The EPA does not have sufficient internal controls to verify performance metrics
for its data centers. As a result, we found that some accomplishments reported in
the SSPP applied only to the EPA's National Computer Center in Research
Triangle Park, North Carolina, rather than to the EPA as a whole. Without
procedures in place to assure accurate data collection, management and reporting,
the EPA cannot affirm that the goal related to data centers is being accomplished
as reported.
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Improved Record Keeping Procedures Can Ensure Data Accuracy
We found that the EPA lacked procedures for data collection, storage and
manipulation measures (i.e., record keeping) for several metrics reported in the
2012 SSPP. The EPA did not maintain proper documentation on historical vehicle
data, facility waste diversion records and compliance records for acquisitions.
As outlined in the EPA Records Management Manual, EPA staff are required to
maintain adequate and proper documentation and evidence of agency activities.
Inadequate record keeping can mean decisions could appear unsupported and
undocumented, and work completed may need to be repeated, which creates
inefficiency. Specifically, we found the following:
•	Goal 3 Fleet Management database. Due to system limitations, the
EPA's fleet database is incapable of generating or saving historical data on
the number of fleet vehicles used for emergency response and law
enforcement. The EPA's emergency and law enforcement vehicles are
exempt from federal alternative fuel vehicle acquisition requirements.
•	Goal 5 Waste Diversion. Waste diversion data reported in the 2012 SSPP
was derived from a questionnaire distributed to EPA facilities and entered
into a tracking sheet, but the system used to track the information holds
75 percent rather than 100 percent of the agency's locations.
•	Goal 6 Acquisition. OARM's Office of Acquisition Management was not
able to reproduce the same results on the numbers of new EPA contracts
with green attributes, as they were originally reported in the 2012 SSPP.
Staff could not explain how the data were collected and analyzed because
key personnel retired.
Recommendations
We recommend that the Assistant Administrator for Administration and
Resources Management:
1.	Establish procedures for OARM personnel to conduct a quality assurance
review of SSPP data provided by the contractor and EPA program offices.
2.	Develop and implement procedures for maintaining and securing records
associated with production of annual SSPP data, in accordance with the
EPA's Records Management Policy. Specifically, assure that:
a. Fleet data reported in the SSPP are documented and accessible,
and can be reproduced using either the current fleet database or by
maintaining copies of historical data reports.
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b.	SSPP waste diversion data are documented for all facilities that can
provide it, and specify in future SSPP reports whether the waste
diversion rates are estimates or only represent specific facilities.
c.	Findings and results associated with the acquisitions information in
the SSPP report can be reproduced, including records of the data
and methodology used. These records should be properly
maintained, and should be accessible for the time period required
by the EPA's Records Management Policy.
Agency Response to Draft Report and OIG Evaluation
We received comments on the draft report from the OARM and the Office of
Environmental Information (appendix B). The agency's response included some
technical comments, which were incorporated into the final report as appropriate.
The agency agreed with all recommendations and provided a corrective action
plan, as well as estimated completion dates for each corrective action. The plan
provided steps the agency will take to address the recommendations, including
many actions already in the planning stages. We agree with the EPA's proposed
actions and consider recommendations 1 and 2 resolved. The full OIG evaluation
of the agency response is also in appendix B
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
No.
Subject
Status1
Action Official
Planned
Completion
Date
Claimed
Amount
Ag reed-To
Amount
Establish procedures for OARM personnel to
conduct a quality assurance review of SSPP data
provided by the contractor and EPA program
offices.
Develop and implement procedures for maintaining
and securing records associated with production of
annual SSPP data in accordance with the EPA's
Records Management Policy. Specifically, assure
that:
a.	Fleet data reported in the SSPP are
documented and accessible, and can be
reproduced using either the current fleet
database or by maintaining copies of
historical data reports.
b.	SSPP waste diversion data are documented
for all facilities that can provide it, and specify
in future SSPP reports whether the waste
diversion rates are estimates or only
represent specific facilities.
c.	Findings and results associated with the
acquisitions information in the SSPP report
can be reproduced, including records of the
data and methodology used. These records
should be properly maintained, and should
be accessible for the time period required by
the EPA's Records Management Policy.
Assistant Administrator for
Administration and
Resources Management
Assistant Administrator for
Administration and
Resources Management
10/31/14
12/31/14
10/31/14
10/31/14
0 = Recommendation is open with agreed-to corrective actions pending.
C = Recommendation is closed with all agreed-to actions completed.
U = Recommendation is unresolved with resolution efforts in progress.
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Appendix A
Scope and Methodology
We conducted our work from April 2013 to February 2014. We conducted this performance
audit in accordance with generally accepted government auditing standards. Those standards
require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and conclusions based on our
audit objectives.
We used the 2012 SSPP objectives as the benchmark for assessing how well the agency met its
goals under Executive Order 13514. We identified requirements for record keeping and internal
controls.
For each SSPP goal area, we assessed the EPA's documentation of data origination and
collection methodology. We conducted interviews of both agency and contractor personnel who
had direct knowledge of the data collection, management and storage specifics associated with
the 2012 SSPP. For our review of the EPA's electronics and data centers, we conducted an onsite
inspection of the National Computer Center data center at the EPA's facility in Research
Triangle Park, North Carolina. We also reviewed utility bills, spreadsheets and guidance
documents to verify that the EPA had documentation of the original source for all data in the
2012 SSPP.
To follow up on our recommendation from the April 2011 EPA OIG report, EPA's Plan to
Reduce Agency Greenhouse Gas Emissions Is on Track to Meet Executive Order 13514
Requirements, we reviewed the completed corrective actions taken by the agency and the
progress made by the agency in meeting its GHG reduction requirements.
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Appendix B
Agency Response to Draft Report and OIG Comments
STa%
g	'r0 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
g	f	WASHINGTON, D.C. 20460
VIV *
PR0^°
APR 16 2014	office of
ADMINISTRATION
AND RESOURCES
MEMORANDUM	management
SUBJECT: Response to OIG Draft Report Regarding Internal Climate Change Goals,
OPE-FY13-0014
FROM: Craig E. Hooks, Assistant Administrator
TO:	Carolyn Copper, Assistant Inspector General
Office of Program Evaluation
Thank you for the opportunity to review your draft report, "EPA Met or Exceeded Most Internal
Climate Change Goals, but Data Quality and Record Management Procedures Need
Improvement" Project Number OPE-FY13-0014, dated March 5, 2014. It is important that the
Office of Inspector General recognizes that the EPA met or exceeded most federal sustainability
requirements under the Executive Order and provided most documentation to support its reported
FY 2012 accomplishments. The Office of Administration and Resources Management, in
partnership with other EPA offices and regions, provides environmental and sustainable
leadership with the federal government. The EPA was one of only three agencies out of 25
reporting that received a green scorecard on the Office of Management and Budget sustainability
scorecard for FY 2013. The EPA has achieved a green scorecard the last three years.
OARM offers comments as attachment to this memo. If you have any questions regarding our
response, please contact me at (202) 564-4600 or Yvette Jackson, deputy director, Facilities
Management and Services Division, at (202) 564-2030.
Attachments (2)
cc: Renee Wynn
Nanci Gelb
Renee Page
John Showman
John Bashista
David Updike
Yvette Jackson
Eric Lewis
Asfara Moghis
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Attachment 1
OARM and OEI Response to OIG Draft Report Regarding Internal Climate
Change Goals Project No. OPE-FY13-0014 March 5, 2014
Response to the Recommendations:
1) Establish procedures for OARM personnel to conduct a quality assurance review o/SSPP
data provided by the contractor and EPA program offices.
OARM response:
•	OARM will update existing standard operating procedures to include federal staff
sampling of data collected by the contractor to help ensure the accuracy of energy and
water data. Expected completion: October 31, 2014
•	OARM will examine the contractor's compliance with the SOP for data quality
control/quality assurance. Expected completion: October 31, 2014
•	The EPA will provide more transparency and disclosure regarding its waste diversion
data in the June 2014 SSPP and subsequent reports. Expected completion: October
31, 2014
•	OARM finalize a draft electronics stewardship SOP to emphasize the internal control
processes necessary for ensuring accuracy of the EPEAT data reported to the OMB.
Expected completion: October 31, 2014 (While the new SOP has not been finalized
or distributed, a memorandum summarizing the new reporting process was distributed
in November 2013 to the EPA reporting locations.)
OIG Comment 1: We agree with the EPA's proposed actions. Recommendation 1 is resolved.
2) Develop and implement procedures for maintaining and securing records associated with
production of annual SSPP data in accordance with the EPA's Records Management Policy.
Specifically, assure that:
a. Fleet data reported in the SSPP are documented and accessible, and can be reproduced
using either the current fleet database or by maintaining copies of historical data reports.
OARM response:
•	OARM will implement changes to the Automotive Statistical Tool database that
holds fleet management data. Expected completion: December 31, 2014
These changes will include:
•	An update to the Vehicle Exemption field of the Master Record that will timestamp
every change. The data will include the user, date and time of change, and what the
exemption type was changed to.
•	All the necessary back-end code necessary to create and report out on a "point-in-
time" query snapshot of the fleet.
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•	A simple front-end tool where users can enter a specific date and AST would return a
full data spreadsheet of what the fleet looked like on that date.
•	OARM will also keep copies of historical data reports regarding fleet vehicles.
OIG Comment 2: We agree with the EPA's proposed actions. Recommendation 2a is resolved.
b.	SSPP waste diversion data are documentedfor all facilities that can provide it, and
specify in future SSPP reports whether the waste diversion rates are estimates or only
represent specific facilities.
OARM response:
•	OARM will report the percent of facilities reporting waste diversion data in the June
2014 and subsequent SSPPs. Expected completion: October 31, 2014
OIG Comment 3: OARM provided a revised response on May 9, 2014:
OARM will report waste diversion data in a more detailed and transparent
manner. At a minimum, OARM will include in its report: a list of major facilities,
whether or not an individual facility on that list reported waste diversion data, the
waste diversion data reported by that individual facility, and a discussion of the
methodology used to calculate the agency waste diversion rate derived from the
individual facility data. OARM will include this in the SSPP due in June 2014
and in subsequent SSPPs. Expected completion: October 31, 2014.
We agree with the EPA's revised response and the proposed actions. Recommendation 2b is
resolved.
c.	Findings and results associated with the acquisitions information in the SSPP report can
be reproduced, including records of the data and methodology used. These records
should be properly maintained, and should be accessible for the time period required by
the EPA's Records Management Policy.
OARM response:
•	OARM will develop procedures to ensure that records used for any future SSPP will
be properly maintained and accessible for the required time period specified by the
agency's records management policy. Expected completion: October 31, 2014.
•	OARM is in the process of finalizing a SOP for data extraction and explicit
methodology used to determine the agency's compliance with the goals specified in
Executive Order 13514, Federal Leadership in Environmental, Energy, and Economic
Performance. Expected completion: October 31, 2014
OIG Comment 4: We agree with the EPA's proposed actions. Recommendation 2c is resolved.
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Response to Findings and Factual Accuracy:
At A Glance
. . . the agency relies heavily on a contractor to collect the data used in the 2012 Strategic
Sustainability Performance Plan . . .
OARM response: As demonstrated during the course of this review, OARM collects and reviews
environmental performance data from many sources, including contractors and EPA
organizations.
OIG Comment 5: The audit team verified water and GHG data from databases generated,
collected and maintained by the contractor (i.e., the FY 2011 and FY 2008 Comprehensive
Inventory Master spreadsheets and the Annual Energy and Water Yearbook). In our meeting
with the contractor, they explained how they collect data for these areas and enter them into the
databases. The OIG modified the report as follows:
The agency relies heavily on a contractor to collect water and energy data used in
the 2012 Strategic Sustainability Performance Plan....
Goal 6: Acquisition page 8
However, we coirfd not confirm the agency's assertion that it met or exceeded the Executive
Order requirement to procure 95 percent of new contracts with green attributes for 3
consecutive years.
OARM response: We request clarification regarding the exact 3 consecutive years that could not
be confirmed in the statement.
OIG Comment 6: The years that could not be confirmed were FYs 2009, 2010 and 2011. The
OIG modified the report as follows:
However, we could not confirm the agency's assertion that it met or exceeded the
Executive Order requirement to procure 95 percent of new contracts with green
attributes for 3 consecutive years (2009, 2010 and 2011).
Goal 7: Electronics and Data Centers pages 8-9
We could not validate the EPA 's claim that "virtualization is extensively used to support
database hosting" at the EPA 's data centers ... we found that the agency's claims about
virtualization applied to only one of its data center facilities.
OEI response: OEI does not agree with the report findings regarding data center virtualization
accuracy. The responses provided in summary and detail demonstrated substantial virtualization
across both NCC and non-NCC data centers. The EPA provided evidence of extensive and
growing virtualization across the agency, including evidence of 192 Oracle databases hosted on
virtual platforms within the NCC representing well over 90% of NCC Oracle databases. The
EPA also provided evidence of over 120 applications and application platforms hosted on virtual
servers.
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OEI believes virtualization is already extensively used to support database hosting, and the EPA
currently is expanding virtualization to support the Web and application server tiers. The EPA's
Federal Data Center Consolidation Initiative 2011 data shown below indicate that the EPA was
26% virtualized overall and 41% virtualized within the NCC; data for 2012 indicate growth such
that the agency was 38% virtualized overall and 71% virtualized within the NCC. The agency
continues to be aggressively virtualizing NCC hosted applications and platforms, which are
mostly database and Web application platforms.
Year: 2011
Total
Operating
Systems
Total Physical
Percent
Physical
Percent
Virtualized
All EPA
2,906
2,165
75.40%
25.50%
NCC Only
747
441
59.04%
40.96%

Year: 2012
Total
Operating
Systems
Total Physical
Percent
Physical
Percent
Virtualized
All EPA
3,377
2,094
62.01%
37.99%
NCC Only
2,074
597
28.78%
71.22%
OIG Comment 7: The OIG concurs that the agency's National Computer Center has made
significant strides in virtualizing its database hosting infrastructure. However, as of 2012, the
agency's data centers had only virtualized 38 percent of their hosting infrastructure.
The OIG modified the report as follows (beginning with sentence 4 after Goal 7: Electronics
and Data Centers), to reflect the National Computer Center's progress in the area of database
hosting virtualization:
We also reviewed the EPA's claim that "virtualization is extensively used to
support database hosting" at the EPA's data centers. Virtualization enables
multiple operating systems to be located and independently operated from one
physical server instead of the "one server one operating system" platform
previously used. The EPA's implementation of virtualization helps the agency
become more energy efficient by restructuring processes associated with server
operations. The consolidation of physical servers can save energy, translating to
savings of up to 80 percent in data center energy costs while reducing
infrastructure and capital costs. In this area we found that the EPA's National
Computer Center has made significant strides in virtualizing its database hosting
infrastructure. As of 2012, the National Computer Center had virtualized
71 percent of its hosted databases. However, as of 2012, all EPA data centers had
only virtualized 38 percent of their hosting infrastructure. We also found that the
EPA lacks internal controls to validate its electronics stewardship data.
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Areas Where Improvements Are Needed
EPA Relies on Contractor to Verify SSPP Data page 10
A majority of the data reported in the 2012 SSPP related to GHG reduction, water use and local
planning was managed by an EPA contractor. However, sufficient internal controls were not in
place to verify the data generated and collected by the contractor. The EPA only seeks to verify
the data if it sees an issue or problem with the data during a "visual check. "
OARM response: Utility bills are sent to the contractor for use in preparing the SSPP data. The
EPA has begun to conduct a sampling review of bills compared to the generated report to verify
accuracy, and a future metering system will also permit an easier consolidation and verification
of the data.
The EPA believes that the "visual check" is an effective control mechanism. The EPA reports
energy use quarterly, in multiple digital metrics and graphic forms. This includes, but is not
limited to, current quarter vs. previous year's quarter performance, rolling four-quarter
performance data over a 3 year period, and most recent four quarters vs. previous fiscal year.
These reports are on an individual lab basis and are distributed to HQ facilities staff, HQ
environmental management systems staff, and every reporting facility as they are issued.
OARM disagrees that a contractor manages the majority of information regarding "local
planning." Information about activities related to "local planning" is collected from many
sources and no contractor has been tasked with collecting "local planning" participation
information specifically, nor reports out on this data.
OIG Comment 8: Since "local planning" includes the partnership of other agencies such as the
U.S. Department of Transportation and the U.S. Department of Housing and Urban
Development, the OIG took local planning out of this statement as we recognize this data is
collected from a variety of sources (i.e., the contractor and EPA). However, the OIG continues
to believe there is a lack of sufficient internal controls. Based on information provided to the
audit team, the reporting requirements set by the contractor included the collection of data and
performing their own quality assurance check. Specifically, according to the contractor
"the agency sometimes checks data for special projects, for example the Cincinnati Andrew W.
Breidenbach Environmental Research Center had special projects they were interested in
looking at in more detail. They do not routinely or frequently ask for utility bills. There is no
formal process." The contractor also stated that the agency "does do a bit of a spot check. They
pay more attention to special projects." Based on the exit conference between the EPA and the
OIG, the OIG modified the report to include the following statement (under the section
EPA Relies on Contractor to Verify SSPP Data):
According to an EPA official, first-line facility managers check the data. While
there is additional data quality review at headquarters, the OIG does not believe
these data quality review processes are adequate.
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EPA Relies on Contractor to Verify SSPP Data page 10
Lack of sufficient internal controls resulted in the inclusion of erroneous data in the SSPP.
Specifically, the contractor did not correctly report business travel emissions reductions for FY
2011.
OARM response: We have re-verified reported SSPP emissions data for business travel but
found no error in the data provided in the plan. In support of this determination, we have
attached material from our files supporting the statement made in the SSPP executive summary
regarding reductions in business travel related emissions (See Business Travel Emissions
attachment). We believe the data provided to the OIG was annual data that is used to meet
regular reporting requirements, and that the business emissions travel data contained in the
executive summary was a "special" one-time pull of data (May 2012) to highlight progress and
the environmental benefits of the video conference initiative started in FY10. The data taken
from the "special" one-time data pull would not match the regular reporting data provided on a
fiscal year basis.
OIG Comment 9: There is no explanation in the SSPP executive summary that would alert the
reader to the fact that the business emissions travel data contained in the executive summary was
a "special" one-time pull of data. Nor is the reader alerted to the fact that the data taken from the
special one-time data pull would not match the regular reporting data provided on a fiscal year
basis. In fact, any reference or explanation of what a special one-time pull of data is, and its
impact on the reported SSPP emissions data, is absent from the SSPP. The OIG modified the
report as follows:
Lack of sufficient internal controls resulted in the inclusion of undefined data in
the SSPP. Specifically, because mileage data for privately owned vehicle usage
are available on an annual basis only, the contractor did not have corresponding
quarterly data for privately owned vehicles. The contractor had to use substitute
privately owned vehicle data to calculate total EPA business travel GHG
emissions for the second quarter of FY 2011 through the first quarter of FY 2012.
The EPA deferred to the contractor to explain the substitute data. However, the
contractor's response did not explain how the substitute data was developed.
EPA's lack of sufficient internal controls may increase the risk that inaccurate
data is reported or accomplishments could be over- or understated in the SSPP.
Improved Controls Needed for Electronic Acquisitions Database page 10
The agency did not implement an internal control process that ensures accuracy of Federal
Electronic Challenge acquisitions.
OARM response: For fiscal years 2009 through 2012, the EPA used the Federal Electronics
Challenge reporting structure to collect and synthesize agencywide electronics stewardship data
needed to report to the Office of Management and Budget on the agency's sustainability goals. In
FY 2012, the FEC announced the end of the awards and data collection program. Beginning
with FY13 data collection, OARM and OEI agreed on a revised reporting structure and process
(using legacy FEC contacts) to collect and summarize information on the agency's acquisition of
electronics, specifically the EPA's Electronic Product Environmental Assessment Tool®
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registered product purchases. The new process leverages OARM's annual environmental
stewardship reporting process with data accuracy and quality reviews performed at the local site,
as well as at the centralized/consolidated level. In addition to the new process, the OARM and
the OEI have collaborated on improving the process further and investigating options for
improving data and internal quality controls for electronics stewardship.
OIG Comment 10: The OIG acknowledges that the agency is taking proactive steps in this area
and concurs with these efforts.
Improved Controls Needed to Verify Data Center Performance Metrics page 10
The EPA does not have sufficient internal controls to verify performance metrics for its data
centers. As a result, we found that some accomplishments reported in the SSPP applied only to
the EPA's National Computer Center in Research Triangle Park, North Carolina, rather than to
the EPA as a whole.
OARM response: NCC is the EPA's primary application hosting data center and does dominate
the analysis due to the large concentration (over 60%) of EPA operating systems and
applications hosted there. However, performance metrics are aggregated for the agency and the
NCC achievements are accurately included in the aggregate which represents the agency's
accomplishments.
OIG Comment 11: The OIG agrees that the National Computer Center is the agency's primary
database hosting location and has made significant strides in virtualizing its database hosting
infrastructure at the National Computer Center. However, as of 2012, all agency data centers
were only 38 percent virtualized. This distinction was not made in Goal 7 of the SSPP, thereby
over-representing the agency's accomplishments in the area of virtualization. Additionally, our
review in this area found that the EPA did not have controls in place to verify that performance
data provided was accurate and represented the posture of the entire agency. As a result, the OIG
found that sufficient internal controls over data verification were not in place.
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Exhibit 2
Annual Rate of GHG Scope 3 Emissions Air and Ground Business
Travel	4Q FY10 1QFY11 2Q FY11 3QFY11 4Q FY 11 1Q FY 12
Current and 3 Previous Quarters Business
Travel Air and Rental Car Emissions	»»»»»» 19,561 18,963 18,995 17,554 15,809 13,987 MTC02E
Emissions Data by Quarter

FY 2010
FY 2011
FY 2012
1st Qtr
2nd Qtr
3rd Qtr
4th Qtr
1st Qtr
2nd Qtr
3rd Qtr
4th Qtr
1st Qtr
GHG Emissions
from Air Travel
(MTC02e)
4,087
3,669
4,518
4,102
3,579
3,727
3,332
2,660
2,067
GHG Emissions
from Car
Rentals
(MTC02e)
779
712
900
794
689
686
646
490
379
Total
(MTC02e)
4,866
4,381
5,418
4,896
4,268
4,413
3,978
3,150
2,446
Current and


previous 3
MTC02

quarters
equivalents

4th Q FY 2010
19,561
This metric always gives us 12 months of travel data to compare
1st Q Fy 2011
18,963
This eliminates any regular/seasonal swings in travel by always including
2nd QFy 2011
18,995
four quarters of business air and ground travel.
3rd Q Fy 2011
17,554

4th Q FY 2011
15,809

1st Q FY 2012
13,987
72%
28% reduction
Data is derived from GSA Travel Trax program that pulls in every agencies travel data from the various travel management systems (i.e. gov trip) and
converts them to Metric Tons of C02 Equivalents emitted. It is used by all/most federal agencies in calcing their Scope 3 Business Air and Travel
emissions
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Appendix C
Distribution
Office of the Administrator
Assistant Administrator for Administration and Resources Management
Assistant Administrator for Environmental Information and Chief Information Officer
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Principal Deputy Assistant Administrator, Office of Administration and Resources Management
Director, Office of Acquisition Management, Office of Administration and
Resources Management
Director, Office of Administration, Office of Administration and Resources Management
Director, Office of Policy and Resource Management, Office of Administration and
Resources Management
Deputy Director, Office of Acquisition Management, Office of Administration and
Resources Management
Deputy Director, Office of Policy and Resource Management, Office of Administration and
Resources Management
Director, Headquarters Procurement Operations Division, Office of Acquisition Management,
Office of Administration and Resources Management
Audit Follow-Up Coordinator, Office of Administration and Resources Management
Audit Follow-Up Coordinator, Office of Acquisition Management, Office of Administration and
Resources Management
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