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OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
Report
Studies Addressing EPA's
Organizational Structure
Report No. 2006-P-00029
August 16, 2006

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Report Contributors:
Eric Lewis
Dwayne Crawford
Bettye Bell-Daniel
Bram Hass
Rae Donaldson
Abbreviations
EPA	U.S. Environmental Protection Agency
GAO	Government Accountability Office
GPRA	Government Performance and Results Act
NAPA	National Academy of Public Administration
NPR	National Performance Review
OIG	Office of Inspector General
RPPI	Reason Public Policy Institute

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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
2006-P-00029
August 16, 2006
Catalyst for Improving the Environment
Why We Did This Review
Based on the interest of the Senate
Committee on Environment and
Public Works, we initiated a project
to research studies, articles,
publications, and reports that
address the U.S. Environmental
Protection Agency's (EPA's)
organizational structure. This
project is a collection of
information, not an audit, and the
information provided is strictly the
viewpoint of the authors of the
studies and not those of the Office
of Inspector General (OIG).
Background
EPA was established in 1970 to
merge key anti-pollution programs
into an environmental protection
administration as a new
independent agency of the
Executive Branch. EPA was
initially intended to be organized
around its major functions, such as
research, monitoring, and
enforcement. However, EPA was
organized along media lines, such
as air, land, and water.
Consequently, some scholars and
practitioners have called for major
reform of the Agency's fragmented
media program structure and
environmental statutes.
For further information, contact our
Office of Congressional and Public
Liaison at (202) 566-2391.
To view the full report,
click on the following link:
www.epa.aov/oia/reports/2006/
20060816-2006-P-00029.pdf
Studies Addressing EPA's Organizational Structure
What the Studies Found
The 13 studies, articles, publications, and reports we reviewed identified issues
with cross-media management, regional offices, reliable information, and
reliable science. We included reliable information and reliable science because
some authors stated that changes to EPA's organizational structure were
necessary to improve these areas.
•	Cross-Media Management. Seven studies stated that EPA might be
missing an opportunity to be more effective because EPA bases its
organizational structure on disparate environmental laws that do not
consider that problems with the various media are interrelated.
•	Regional Offices. Two studies stated that EPA's regional offices do not
adequately consider the geographic connectivity of environmental issues
that cross EPA's identified regions. Thus, the regions may not adequately
address their environmental problems.
•	Reliable Information. Ten studies stated that EPA does not always have
reliable data to support its positions on the state of the environment or to
measure effectively the success of its programs in improving the
environment.
•	Reliable Science. Two studies stated that EPA does not always utilize
reliable science to support its rules and regulations. Consequently, the
authors believe that EPA may pass regulations that may not fully address
environmental problems.
What the Studies Recommended
The authors of 9 of the 13 studies made the following recommendations:
•	EPA should seek congressional assistance in drafting a single cross-media
environmental statute, and should change its organizational structure to
address environmental issues from a cross-media approach.
•	EPA should develop a regional management system that addresses cross-
media issues over the affected regions.
•	Congress should form and fund an independent bureau of environmental
information or statistics (an addition external to EPA) to assess the state of
the environment and the success of EPA media programs.
•	EPA should evaluate its current policies governing the use of science and
consider the appointment of a science "czar" (an addition to the EPA
organizational structure) to improve the credibility of its science.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
August 16, 2006
MEMORANDUM
SUBJECT: Studies Addressing EPA's Organizational Structure
Report No. 2006-P-00029
TO:
Marcus A. Peacock
Deputy Administrator
This is the Office of Inspector General (OIG) of the U.S. Environmental Protection
Agency (EPA) final report, Studies Addressing EPA's Organizational Structure. We conducted
the assignment based on the interest of the Senate Committee on Environment and Public Works
to research studies, articles, publications, and reports that address EPA's organizational structure.
This project is a collection of information, not an audit, and the information provided is strictly
the viewpoint of the authors of the studies and not those of the OIG. The OIG does not make
any recommendations in this report.
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 $279,683.
Action Required
We provided a copy of the draft report for comment on July 11, 2006, at which time we
offered to meet and discuss the report and to consider any comments you may have had
regarding its content. Subsequently, your office informed us they had no comments and a
meeting was not necessary. Therefore, we are issuing our final report without change, and will
be closing this report upon issuance.
You may contact me at (202) 566-2212 or roderick.bill@epa.gov. or Melissa Heist at
(202) 566-0899 or heist.melissa@epa.gov. if you have any questions concerning this report.
Sincerely,
—BiirXTRoderi ck
Acting Inspector General

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Studies Addressing EPA's Organizational Structure
Table of C
Chapters
1	Introduction 	 1
Purpose		1
Background		1
Scope and Methodology		4
2	Summary of Studies on EPA's Organizational Structure		6
EPA Accomplishments		6
Cross-Media Management		7
Regional Offices		10
Reliable Information		11
Reliable Science		13
Status of Recommendations and Potential Monetary Benefits		15
Appendices
A Key Points from Studies, Reports, Articles, and Other Publications		16
A1 - National Academy of Public Administration Reports		17
A2 - National Resources Journal Article		22
A3 - Environmental Politics Article		23
A4 - Reason Public Policy Institute Report		24
A5 - Environmental Protection Agency National Performance Review		26
A6 - Government Accountability Office Reports and Testimonies		28
A7 - Resources for the Future Testimony		31
B Breakout of Issue Categories by Report		32
C EPA's Initial Organizational Chart (as of December 4, 1970)		33
D EPA's Organizational Chart (as of April 30, 1971)		34
E EPA's Current Organizational Chart (as of June 2006)		35
F Distribution		36

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Chapter 1
Introduction
Purpose
Based on the interest of the Senate Committee on Environment and Public Works,
the Office of Inspector General (OIG) initiated this project to research studies,
articles, publications, and reports that have addressed the U.S. Environmental
Protection Agency's (EPA's) organizational structure and provided suggestions to
improve performance. This project represents a collection of information, not an
audit. An audit would require us to substantiate the information. The objective of
the project was to summarize the studies' pertinent findings in an informational
document that provides perspectives on what has been problematic and what EPA
may need to change regarding its organizational structure. These studies can
challenge EPA to ask important questions about its future, such as:
•	Would a functional organizational structure (like that of the Departments
of Defense and Health and Human Services) be more effective over the
long-term than the current hybrid structure that includes both functional
and media program offices?
•	Should EPA evaluate the effectiveness of its current regional structure?
•	Should EPA or Congress develop new and/or independent offices to insure
the Agency uses reliable information and reliable science?
Background
President Richard M. Nixon established EPA under Reorganization Plan No. 3 on
July 9, 1970, based on an earlier recommendation by the President's Advisory
Council on Executive Organization, also know as the Ash Council. The Ash
Council recommended merging key anti-pollution programs into an
environmental protection administration as a new independent agency of the
Executive Branch. Under the Plan, the Department of the Interior; Department of
Agriculture; Department of Health, Education and Welfare; Atomic Energy
Commission; Federal Radiation Council; and Council on Environmental Quality
transferred environmental duties to EPA. The environmental programs from
these agencies were established as separate offices under EPA (see Figure 1
below).
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Figure 1. Functions Transferred to EPA from Other Agencies
Department of the Interior
•	Pesticide Research
•	Federal Water Quality Administration
Department of Agriculture
• Pesticide Registration
Department of Health,
Education and Welfare
•	National Air Pollution Administration
•	Bureau of Water Hygiene
•	Bureau of Solid Waste Management
•	Bureau of Radiological Health
•	Pesticide Tolerances and Research
Executive Office of the
President
•	Federal Radiation Control
•	Environmental Radiation Standards
of the Atomic Energy Commission
•	Environmental Systems Studies of
the Council on Environmental Quality
Plan Development
The Ash Council recommended organizing EPA according to functional
categories (e.g., monitoring, research, standard-setting, enforcement, assistance)
rather than along media lines (e.g., air, water, land). This recommended
organizational approach was intended to recognize the interrelated nature of
pollution problems, acknowledge that pollutants cut across media lines, encourage
balanced budget and priority decisions between component functions, and permit
more effective evaluations of total program performance.
Plan Alterations
The head of the Ash Council's environmental protection group, who also served
as the White House EPA Task Force Director on transitional issues, chose not to
submit the recommended Ash Council organizational proposal to EPA's first
Administrator for fear that massive changes proposed in the plan would create
friction and chaos. The Task Force Director concluded that although a functional
organization was the appropriate long-term goal for the Agency, only incremental
change was reasonable and feasible in the short-term. Therefore, the Task Force
Director proposed the following three-stage approach for organizational change:
(1)	Initially, the merger would leave intact each of the media program areas
that formed EPA (water quality, air pollution control, pesticides, radiation,
and solid waste management).
(2)	In a second phase, the Agency would add new functional divisions that
would put greater distance between the Administrator and the three
Assistant Administrators' offices (Office of Planning and Development,
Office for Standards and Compliance, and Office for Research and
Monitoring).
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(3) Finally, the Agency would work towards a completely functional
organization. EPA would abolish the media program offices in favor of
the functional units recommended by the Ash Council. However, this
would occur after the Agency had proven that it could manage the
environmental interests of the country.
Plan Implementation
On December 4, 1970, EPA's first Administrator formally organized the Agency
under EPA Order 1110.2. At the start of his tenure, the Administrator set up a
system in which five commissioners administered discrete EPA media programs
for water, air, pesticides, radiation, and solid waste (see Appendix C);
corresponding to the Task Force Director's proposed first stage. The
Administrator's purpose was to continue with important existing activities, and
create what the Council considered to be a more effective organization later.
In April 1971, the Administrator drew up a second organizational plan with a
structure (see Appendix D) that corresponded to the second stage envisioned by
the Task Force Director. The one exception was the inclusion of a Media
Programs office, which was meant to establish formal communication between
the air and water media programs. The Administrator hoped that the interaction
among previously separate elements would generate new ideas. The
Administrator also established ten regional offices, covering the entire nation, to
work with State and local officials and private organizations to insure maximum
participation in environmental programs. The regional boundaries conformed to
those already specified for five other major Federal agencies.
Although the Administrator carried out the first two stages of the Task Force
Director's three-stage plan, he did not push the Agency to stage three and a
completed functional theme. Therefore, the media program offices remained.
The Administrator did not organize EPA functionally because he felt that the
structure was not as important as the personnel. He believed that the success of
an organization depended upon getting key people to make it work. In addition,
the Administrator believed that the inherited programs (from other agencies) had
to maintain continuity to avoid congressional criticism.
Current Organizational Structure
EPA's current organizational structure includes an Office of the Administrator, 12
headquarters offices, and 10 regional offices (see Appendix E). The
Administrator provides overall supervision of the Agency and is responsible
directly to the President of the United States. The 12 headquarters offices include
the following media and functional offices:
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Table 1. Media and Functional Offices
Media Offices
Functional Offices
Air and Radiation
Administration and Resources Management
Prevention, Pesticides, and Toxic Substances
Chief Financial Officer
Solid Waste and Emergency Response
Enforcement and Compliance Assurance
Water
Environmental Information

General Counsel

Inspector General

International Affairs

Research and Development
Each EPA regional office is responsible for the execution of the Agency's
programs within its States.
The Office of the Administrator is developing a regional priorities framework that
will allow the Agency to track progress on delivering results tailored to selected
areas of the country. The priorities will be similar environmental or health issues
that contiguous areas of the country are likely to be actively addressing. The
concept will identify the top priority environmental issues that are of significant
common interest to one or more of four separate regions of the country (referred
to as Northeast, Great South, Midwest, and Great American West priorities).
Under this concept, the Agency hopes to identify a limited number of quantifiable
metrics with baselines and targets that can be tracked regularly and show
progress.
Scope and Methodology
From December 2005 through February 2006, we reviewed 13 documents that
included detailed analysis of the Agency's organizational structure. This report is
a summary of the perspectives provided in the studies, reports, articles, and other
publications. These articles and studies were issued between 1988 and 2005 by
the National Academy of Public Administration (NAPA), Government
Accountability Office (GAO), academia, environmental and public policy groups,
and EPA. In addition to the perspectives provided in the body of this report,
additional content from each of these documents is provided in Appendix A.
Appendix B identifies the categories of organizational structure issues that are
addressed in each study.
Some of the older studies do not consider how more recent organizational
changes, such as the addition of the Office of the Chief Financial Officer and the
Office of Environmental Information in 1997 and 1999, respectively, affect
EPA's organizational structure and performance. The studies also do not consider
EPA initiatives, such as the Deputy Administrator's regional priorities project.
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The OIG did not validate any of the information obtained, nor did the OIG
conduct its own analysis of EPA's organizational structure as a part of this
assignment. The work performed does not constitute an audit conducted in
accordance with generally accepted government auditing standards. For example,
we did not assess compliance with applicable requirements of laws and
regulations or applicable internal controls as a part of this review.
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Chapter 2
Summary of Studies on EPA's Organizational Structure
The authors of 13 studies, articles, publications, and reports we reviewed stated
that EPA could improve its ability to accomplish its mission through changes to
its organizational structure. EPA's current organizational structure is a hybrid
structure that incorporates elements of both functional and media-focused offices.
Although this was not the structure the Ash Council initially recommended, the
Agency has made significant accomplishments in improving the environment.
However, the authors of the studies identified issues with EPA's organizational
structure, which we grouped as follows:
•	Cross-Media Management: EPA is a "stove-pipe" organization
reflecting legislation that focuses on media programs such as air, land,
water, and various individual pollutants.
•	Regional Offices: EPA does not have an effective strategy for managing
environmental issues across EPA regions.
•	Reliable Information: EPA cannot tie improvements in the environment
to its programs because it lacks reliable information.
•	Reliable Science: EPA does not always utilize reliable science when
making decisions on environmental regulations.
EPA Accomplishments
While discussing concerns with EPA's organizational structure, the authors noted
the following examples of significant achievements of the Agency.
In its 1995 report on EPA, Setting Priorities, Getting Results: A New Direction
for EPA, NAPA stated:
•	"In the past two decades, the United States has made extraordinary
progress in reducing pollution from the biggest and most obvious
sources."
•	"... EPA has greatly enhanced the quality of life in America. The nation
decided in the 1970s to take a united stand against pollution. Those who
can remember when rivers stank and when air pollution episodes killed
people, appreciate how much the agency and the nation have
accomplished. Children now swim in rivers their parents were taught to
avoid; many cities now have much cleaner air. And recently, the nation
has taken steps with international partners that will eventually repair
humanity's damage to the layer of stratospheric ozone that protects all life
on earth."
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In its 2000 report, Environment.gov: Transforming Environmental Protection for
the 21st Century, NAPA stated:
"Authorized by the Clean Air Act, the Clean Water Act, and other statutes, the
agency has forced large-scale polluters to reduce their air and water emissions
and manage their hazardous wastes. Strong national programs have required
firms to use particular pollution-control technologies, and required states to
achieve specific levels of air quality. Those programs have matured: most are
now implemented by state environmental agencies acting with varying
degrees of oversight by EPA's 10 regional offices."
Cross-Media Management
The authors of seven studies stated a need for a cross-media approach to
environmental protection. While EPA has taken some steps to address cross-
media issues, the Agency has never fully met the Ash Council's call for a cross-
media approach. The authors contend that EPA's media-focused offices and
programs have produced a management structure that deals poorly with complex,
multi-layered environmental problems.
EPA Steps to Address Cross-Media Issues
In its 1997 report, Resolving the Paradox of Environmental Protection, NAPA
stated that EPA had taken some action to address fragmentation and cross-media
issues. For instance, the study stated that the Administrator ".. .initiated three
significant reorganizations, each of which is intended to create constant pressure
for change and each of which creates new structures with cross-media, cross-
program, or cross-statute responsibilities."
NAPA's 2000 report commented on EPA's Region 1 cross-media reorganization.
NAPA reported the Region 1 Administrator consolidated the air, water, and waste
offices into an Office of Ecosystem Protection. Half of this office's staff were
devoted to separate multimedia offices for each State and teams to work with
State and local entities to improve 17 "special places" in the region. The Region 1
Administrator combined compliance, pollution prevention, and enforcement into
an Office of Environmental Stewardship, which increased regional efforts to
prevent pollution and motivate entities to increase compliance and use of less-
polluting technologies.
Media Program Focus Hinders Effectiveness
In its December 1993 internal National Performance Review (NPR), Creating a
U.S. Environmental Protection Agency that Works Better and Costs Less -
Phase 7, EPA reported:
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•	"The teams found organizational and 'traditional mindset' barriers that
have negatively impacted EPA's ability to address multi-media or
ecosystem types of problems and to institutionalize pollution prevention."
•	"Media-specific approaches create duplication among media program
offices."
•	"The need to tackle more complex issues through prevention and control,
in a more 'holistic' fashion, appears to require a new organizational
approach."
•	"As EPA strives to solve more complex issues, its current structure works
to inhibit or impede success."
•	"The EPA also needs to address the barriers which are created by multiple
pieces of enabling legislation."
•	"Program offices within EPA are divided by media-specific statutes that
sometimes erect seemingly insurmountable barriers to cross-media
initiatives."
•	"Today, environmental issues are more complex than ever before; and
environmental protection strategies must cut across all environmental
media and all routes of exposure. Rarely is it sufficient to deal with
environmental media individually. Rather, the quality of science across all
program offices that exercise statutory authority over specific media
should reflect a consistent, holistic approach to protecting and enhancing
both ecosystems and human health and, at the same time, should ensure
adequate environmental resources to meet future needs."
The Reason Public Policy Institute (RPPI) stated in its 2001 report, Managing for
Results at the U.S. Environmental Protection Agency, that EPA's current
fragmented media program structure gives rise to inconsistencies and conflicts in
environmental protection efforts, causes too much confusion, and prevents
effective collaboration for results.
The authors of the article, "Organizational Dilemmas of the US EPA: Why
Structure Matters for Environmental Protection," reported in the February 2005
edition of Environmental Politics that:
•	EPA is bound by its institutional history, its political design, and its
organizational structure, due mainly to the lack of a congressional
mandate when it was created.
•	"The Agency's fatal structural flaw - its programs and offices - are so
narrowly tailored, so content specific that they cannot effectively or
efficiently handle pollutants that cross multiple environmental media; or,
state and international boundaries. The results of this structure, which is
largely based on the lack of a single organic act... is that program
implementation takes more time than allotted or is not done at all." A
cross-media mandate at its inception could have integrated all of the
environmental statutes delegated to EPA, allowing it to pursue a clear and
precise agenda with formal authority.
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The authors of the article, "Reforming EPA's Organizational Structure-
Establishing an Adaptable Agency Through Eco-Regions," reported in the Winter
2002 edition of the National Resources Journal that:
•	The geographical disparity of environmental problems and ecosystem
features makes it difficult for EPA headquarters and/or regional offices to
establish a single set of priorities.
•	EPA must be organized in a manner that allows the Agency to continually
evaluate policies and regulations.
In the three NAPA reports, the authors stated:
•	"EPA's organizational structure has always been a serious handicap to
effective management.... EPA's media-specific program offices, as well
as the statutes they implement, encourage narrow thinking about
problems, and inhibit the processes of comparing risks, setting priorities,
and considering ways to integrate the programs' activities." (1995 Report)
•	The fragmented nature of EPA's statutes makes environmental protection
difficult, is inefficient, adds cost to protection, and discourages innovation.
(1997 Report)
•	"Congress and the executive branch have organized EPA, as well as other
executive agencies, in ways that result in narrow—and sometimes
ineffective—attacks on environmental and economic problems." The
National Environmental Performance Partnership agreements between
EPA and States are meant to focus on outcomes and tend to be cross-
media in nature; however, the Agency is organized along media lines.
(2000 Report)
Study Recommendations
In six of the seven studies, the authors recommended or suggested that EPA
change its organizational structure or seek congressional assistance in drafting a
single cross-media environmental statute. This would allow EPA to address
environmental issues from a cross-media approach.
For example, EPA proposed two options in its 1993 NPR report:
•	Reorganize by function, geographic area, specific ecosystem problem, or
industry; and
•	Establish an infrastructure that enables the Agency to quickly organize
cross-media teams to work on specific issues related to ecosystems,
geographic locations, or pollution prevention initiatives.
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In its three reports, NAPA made the following recommendations:
•	"Drawing on a study of the effects of the reorganizations in states and
EPA regions, EPA should draft a reorganization plan that would integrate
EPA's media programs into multimedia organizations with discrete
functional responsibilities." (1997 Report) This duplicated a 1995 report
recommendation.
•	"Develop and implement a strategy for addressing the outdated
organizational structure of the agency, starting with the reorganization of
the regional offices. If necessary, EPA should seek statutory changes to
allow reorganization that would end the fragmentation of the agency into
separate media offices." (2000 Report)
In its 2001 report, RPPI recommended that Congress begin a bipartisan process to
comprehensively upgrade and update the nation's environmental protection
statutes, and that EPA assess its internal program structures to examine ways to
better integrate environmental protection efforts across media.
The authors of the Environmental Politics article suggested the establishment of a
unified congressional mandate, integrating all of the environmental statutes
delegated to EPA.
Regional Offices
Two of the studies we reviewed expressed concerns with the existing regional
structure's ability to deal effectively with cross-regional problems.
In its 2001 report, RPPI indicated that the differences among the EPA regional
offices, as well as the change-resistant culture in some regions, have presented
management challenges. RPPI indicated the need for better coordination between
EPA regions, headquarters enforcements offices, and media program offices.
RPPI believed all three issue conflicting program directives and guidance
documents that need to be better coordinated.
In the 2002 National Resources Journal article, the authors stated the Agency's
efforts to carry out its mandate and achieve its mission are hampered by the
geographic disparity of environmental problems. In the authors' opinion, EPA's
operational context dictates the need for an organizational structure that is
adaptable and structured around eco-regions. The authors described an eco-
region as a geographic area whose overlapping characteristics define its
boundaries, an area that rarely follows traditional political boundaries.
Study Recommendations
The authors of the 2002 National Resources Journal article stated that
reorganization by eco-regions would give EPA new tools to make better decisions
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for both its own future and the environment's. The authors concluded that
adopting the eco-region concept as the basis for a new jurisdictional unit could
help the Agency move towards a more adaptable structure, finally providing
institutional momentum for integrated policymaking. More specifically, the
authors suggested that restructuring the Agency by eco-regions could:
•	Help the Agency overcome the difficulties of fragmentation through
integrated ecosystem management,
•	Facilitate better collection and organization of ecological information to
evaluate a program's effectiveness and track emerging environmental
problems,
•	Promote learning by adapting information and communication for the
various ecological and scientific contexts in which EPA operates,
•	Help the Agency prioritize its activities and funding decisions, and
•	Make flexible enforcement programs more feasible by providing a
jurisdiction roughly bounded for the dispersion of many common
pollutants.
Reliable Information
The authors of 10 studies indicated concerns over the reliability and adequacy of
EPA's information and the Agency's ability to fairly assess the state of the
environment. While the reliable information issue is not directly caused by the
organizational structure, the authors stated that an organizational change in this
area could help resolve the issue. The authors believed:
•	EPA does not have the data to support its positions on the state of the
environment or to measure the success of its programs,
•	EPA has been slow to correct problems in the data systems that generate
environmental information, and
•	EPA has few common measures to track the state of the environment.
Consequently, the authors indicated, this has led States to develop different
performance measurements and use different methodologies to collect data.
Although EPA has taken important steps to improve the environmental
information it uses to set priorities and measure progress, the authors believed the
Agency must further improve its environmental information.
For example, GAO reported:
•	EPA's information systems have incomplete and untimely data. If EPA
implements changes aimed at long-term improvement, it can achieve its
goal of having timely and complete data in its systems. (1988 Report)
•	Although EPA's regulatory programs depend heavily on scientific
information about the health and environmental effects of chemicals and
pollutants, these data often do not exist. Data that EPA has available are
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often inadequate and poorly managed. EPA is also missing the
information necessary to judge the success of its programs. While EPA
has developed some measures of environmental outcomes, the Agency has
generally relied on activity-based indicators, such as numbers of permits
or enforcement actions taken, to track its progress. (1993 Report)
•	Obtaining and managing environmental information has been a long
standing challenge for EPA. Without a comprehensive picture of
environmental conditions, EPA has difficulty setting risk-based priorities
for its programs, evaluating performance progress and environmental
results, and reporting on its accomplishments as required by the
Government Performance and Results Act (GPRA). EPA has not had the
information it needs on environmental conditions and changes over time to
identify problem areas that are emerging and need additional regulatory
action. (2001Report)
•	EPA needs better environmental and scientific information to manage
risks and measure results. While EPA has collected a vast amount of
scientific and environmental data, much of it is not complete and accurate
enough to credibly assess risks and establish corresponding risk reduction
strategies. Likewise, EPA has not been successful in identifying,
developing, and reaching agreement with its stakeholders on a
comprehensive set of measures to link EPA's activities to changes in
human health and the environment. This is primarily because of
inadequacies in its scientific and environmental data. (2002 Report)
•	EPA has taken important steps to improve the environmental information
it uses to set priorities and measure progress. However, EPA must work
further to improve its environmental information, fill significant gaps, and
incorporate better scientific understanding into its performance measures.
(2003)
NAPA stated:
•	"The agency lacks effective means to ensure that the data used to measure
progress towards environmental goals are reliable." (1995 Report)
•	"EPA lacks a comprehensive, credible system to measure environmental
conditions and trends. Such a system will be necessary to make
performance-based management work." (1997 Report)
•	"It is clear, however, that the OEI is inadequate as presently constituted. It
is too weak, too narrowly focused, too focused on access to data instead of
on the existence and quality of data, too closely linked to political
leadership, as well as being insufficiently funded and staffed." (2000
Report)
Further, RPPI stated in its 2001 report that EPA:
•	Lacks adequate environmental performance measures,
•	Has not addressed critical data shortcomings, and
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•	Has not sufficiently mapped the strategic linkages between its programs
and ultimate improvements in the nation's environment.
Study Recommendations
Authors of five of the studies (three by NAPA, one by GAO, and one by RPPI)
suggested that Congress establish an independent bureau of environmental
information or statistics to assess the state of the environment and the success of
EPA programs. In addition, Paul R. Portney, President of Resources for the
Future, indicated he was in favor of the creation of a "Bureau of Environmental
Statistics" in his June 2003 testimony on legislation to elevate EPA to cabinet
status. He felt the bureau would provide the following benefits:
•	Improve the quality of the nation's environmental data,
•	Provide better information on environmental conditions and trends,
•	Elevate the quality of policy debates about which environmental programs
are working and which are not, and
•	Improve our ability to compare the benefits and costs of both current and
prospective environmental programs.
Reliable Science
The authors of two studies contended that EPA does not always utilize reliable
science to support its rules and regulations, and that an organizational change
could help improve the credibility of EPA's science. The studies indicated that
EPA's science program is impacted by numerous congressional mandates and has
become affected by politics. The Agency, they said, has a basic conflict between
being a regulatory agency and having a role in deciding how science is utilized.
In its 1993 NPR report, EPA stated the Agency's ability to conduct an "effective
and coherent quality-science program" is impacted by numerous congressional
mandates and highly departmentalized appropriations. The NPR defines quality
science as having the following characteristics:
•	Clear identification and prioritization of the most important scientific
questions to be addressed;
•	Identification and use of the most appropriate and powerful experimental
and analytical designs;
•	Employment of state-of-the-art experimental techniques;
•	Accurate measurements;
•	Validation and independent review processes; and
•	Recruitment, retention, and reward of high-quality scientific personnel.
The Agency also reported that ineffective communications between its policy-
makers and scientific staff had tarnished its scientific reputation. The Agency
reported that its severely limited ability to support and nurture its scientific staff
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has contributed to the perception that EPA's decision-making is not always rooted
in sound science.
In its 2001 report, RPPI observed the significant challenges surrounding the
development and use of environmental science. Some RPPI participants felt that
the issue of sound science would never be effectively resolved; that ultimately
politics determines which policies are developed and implemented. RPPI felt that
the development and analysis of environmental science is too great a challenge for
EPA to address as long as it plays the role of regulator and that Congress should
remove science from Agency jurisdiction.
Study Recommendations.
Despite the sentiments expressed in the report on the independent development of
scientific data, RPPI made recommendations to EPA to improve EPA's scientific
credibility. Specifically, RPPI recommended the Agency evaluate its current
policies governing the use of science and seek Congressional approval to consider
the appointment of a science "czar" or chief scientist. RPPI stated the "czar" or
chief scientist should have "considerable authority early in the agency decision-
making process to set a tone right from the outset that science is the underlying
basis for the decision making."
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec. Page
No. No.
Subject
Status1
Action Official
Planned
Completion	Claimed Agreed To
Date	Amount Amount
This project is a collection of information, not an audit, and the information provided is strictly the
viewpoint of the authors of the studies and not that of the OIG. The OIG does not make any
recommendations in this report.
1 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
Key Points from Studies, Reports, Articles, and Other
Publications
In addition to the findings and recommendations on EPA's organizational structure that are
included in the body of this report, the following appendices provide statements, concerns, and
recommendations from each of the 13 studies we reviewed.
A1 - National Academy of Public Administration Reports
A2 - National Resources Journal Article
A3 - Environmental Politics Article
A4 - Reason Public Policy Institute Report
A5 - Environmental Protection Agency National
A6 - Government Accountability Office Reports
A7 - Resources for the Future Testimony
Performance Review
and Testimonies
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Appendix A1
National Academy of Public Administration Reports
Setting Priorities, Getting Results: A New Direction for EPA. 1995.
Statements
•	"In the past two decades the United States has made extraordinary progress in
reducing pollution from the biggest and most obvious sources."
•	".. EPA has greatly enhanced the quality of life in America. The nation decided in
the 1970s to take a united stand against pollution. Those who can remember when
rivers stank and when air pollution episodes killed people, appreciate how much the
agency and the nation have accomplished. Children now swim in rivers their parents
were taught to avoid; many cities now have much cleaner air. And recently, the
nation has taken steps with international partners that will eventually repair
humanity's damage to the layer of stratospheric ozone that protects all life on earth."
Concerns
•	"EPA's organizational structure has always been a serious handicap to effective
management... EPA's media-specific program offices, as well as the statutes they
implement, encourage narrow thinking about problems, and inhibit the processes of
comparing risks, setting priorities, and considering ways to integrate the programs'
activities. The media programs have resisted attempts to develop effective
management systems that could coordinate their activities... competition for
resources has further divisive effects."
•	"Reorganization would make sense only as one element in a broader strategy of (1)
establishing a clearer sense of common purpose; (2) melding the environmental
statutes into a more coherent whole; (3) developing an Agency-wide commitment to
set priorities; and (4) improving management systems."
Recommendations
•	"The administrator should also initiate actions to reorganize EPA headquarters, in
consultation with Congress, unions, and stakeholder groups. Within the next 18
months, EPA should propose a reorganization plan, including any necessary
legislation, to consolidate EPA's administrative structures and integrate EPA's media
programs into multi-media organizations with discrete functional responsibilities."
As an example of what a reorganized headquarters might look like, the report
proposed having an administrator and a deputy administrator, who would be the chief
operating officer, both supported by a small analytical and clerical staff. "The rest of
the agency would be structured around seven offices, each of which would focus on
one aspect of integrated environmental management:
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-	"Building scientific understanding of environmental risks,"
-	"Setting standards and writing regulations,"
-	"Ensuring compliance with national standards,"
-	"Developing partnerships,"
-	"Developing the authoritative base of information about environmental
conditions,"
-	"Planning and managing," and
-	"Investigating and auditing."
•	NAPA stated "EPA should rebuild its central monitoring, evaluation and information
management capabilities" by:
-	Reestablishing "a formal accountability system," managed by a small staff;
-	Establishing "a program evaluation function for the Agency as a whole;"
-	Creating a legislatively independent "bureau of environmental statistics within the
agency"; and as a first step, "immediately establish a full-time statistical
management group to develop comprehensive plans for a bureau of environmental
statistics as well as to begin to consolidate and integrate appropriate agency
programs and activities"; and
-	"Implement performance measures" — the Chief Operating Officer should lead
EPA's Government Performance Results Act (GPRA) implementation by
working with the Agency's senior leaders to "assure that the performance
measures developed under GPRA relate directly to EPA's mission, goals and
objectives."
Resolving the Paradox of Environmental Protection: An Agenda for Congress, EPA, & the
States. 1997.
Statements
"In the last two years, Congress, [EPA], and state and local governments have made
progress in their efforts to improve the nation's environmental protection system. Much
of the progress... however, has occurred at the margins of EPA's programs and will
remain of only marginal importance unless EPA and Congress make an explicit effort to
learn from federal and state environmental initiatives and then change core operations
and policies accordingly."
Concerns
•	"The fragmented patchwork of EPA's statutes... makes it harder to protect the
environment. Statutes and regulations which focus on one form of pollution in one
media—air, water, or land—typically fail to recognize the interactions among different
pollutants and the movement of pollutants from one medium to another."
•	This "fragmentation is inefficient... differences among statutes and regulatory
regimes make it more costly for EPA and states to manage their programs and for
businesses and communities to figure out how best to comply." The statutes'
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complexity, inconsistencies, and hard-to-understand required procedures limit
creative, constructive thinking that might lead to innovative, more cost-effective
environmental protection.
•	"EPA lacks a comprehensive, credible system to measure environmental conditions
and trends. Such a system will be necessary to make performance-based management
work... Data describing environmental conditions is incomplete, and too often
unreliable."
Recommendations
•	"EPA should build an authoritative national system for monitoring environmental
conditions. EPA should reconstitute its Center for Environmental Information and
Statistics outside the Office of Policy, Planning, and Evaluation.. .or work with
Congress to establish an independent bureau of environmental statistics."
•	"EPA and the states should build the capacity to evaluate the effectiveness of their
environmental programs."
•	"Drawing on a study of the effects of the reorganizations in states and EPA regions,
EPA should draft a reorganization plan that would integrate EPA's media programs
into multimedia organizations with discrete functional responsibilities."
Environment.gov: Transforming Environmental Protection for the 21st Century. 2000.
Statements
"Authorized by the Clean Air Act, the Clean Water Act, and other statutes, the agency
has forced large-scale polluters to reduce their air and water emissions and manage their
hazardous wastes. Strong national programs have required firms to use particular
pollution-control technologies, and required states to achieve specific levels of air
quality. Those programs have matured: most are now implemented by state
environmental agencies acting with varying degrees of oversight by EPA's 10 regional
offices."
Concerns
•	"Congress and the executive branch have organized EPA, as well as other executive
agencies, in ways that result in narrow—and sometimes ineffective—attacks on
environmental and economic problems. EPA's division into offices and programs
focusing exclusively on air pollution, water pollution, and hazardous wastes, for
example, has produced a management structure that deals poorly with complex,
multilayered environmental and economic problems."
•	"EPA's successful innovations and management reforms have been those it could
carry out within a single national program office. Most efforts to innovate across
programs have failed... The agency's efforts to coordinate its national program
offices through Project XL, [NEPPS or GPRA priority setting], the Common Sense
Initiative or ecosystem protection... have demonstrated that EPA's media-based
organizations remain fundamentally unable to work together."
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•	"EPA is not organized well to foster or respond to increasingly complex arrangements
among public and private institutions, or the changing capacities of states. That EPA
cannot currently collaborate effectively with [other federal agencies] hobbles the
nation's ability to manage the environmental aspects of large-scale issues such as
global trade, production agriculture, or climate change. EPA cannot adequately
address those problems by itself."
•	".. EPA and the states do not gather adequate data about environmental conditions...
virtually all of the Agency's data systems—except for its national network of air-
quality monitoring—were developed to track the regulatory process. EPA gathers a
great deal of information about permits, enforcement, and emissions, but relatively
little about ambient conditions."
•	"EPA's Office of Environmental Information lacks the authority it needs to achieve
its mission." The office lacks "the authority to reshape and integrate the Agency's
media-based data systems."
•	"Neither EPA nor its state counterparts have transformed their core programs to use
new tools to address effectively or efficiently some of the most serious environmental
problems facing America. Innovation at EPA and the states is still of marginal
significance. There is no system to identify and sustain the most productive
innovations."
Recommendations
•	"The EPA administrator should give a senior agency manager who is accountable
directly to the administrator responsibility for NEPPS, other EPA-state relationships,
and the management of EPA's system of regional offices."
•	"Regions should be held accountable for improvements in environmental
performance, including effective performance by states under NEPPS, addressing
high-priority regional environmental issues, and contributing to the achievement of
national environmental goals."
•	"Regional administrators should have the necessary tools to assure effective
performance: regular meetings and communication with the administrator and deputy
administrator; substantial regional budgetary authority; sufficient and capable staff;
and authority to make decisions about state performance plans, proposals for waivers,
and approval of innovative state programs."
•	EPA should "create an independent capacity for assessment."
•	EPA should "foster a management culture of prompt decision-making and action."
•	"Revamp EPA's planning and budgeting systems to move the agency towards
strategic, performance-based management consistent with the intent of... [GPRA],
eliminating those practices that reinforce fragmented programs and relationships."
•	"Develop and implement a strategy for addressing the outdated organizational
structure of the agency, starting with the reorganization of the regional offices. If
necessary, EPA should seek statutory changes to allow reorganization that would end
the fragmentation of the agency into separate media offices."
•	"The administrator should work with Congress to create an independent, well-funded
bureau of environmental information. In the meantime, the administrator should
strengthen the existing Office of Environmental Information by leading efforts to
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integrate and rationalize the data systems of the media programs, and to develop other
objective data of high quality. In addition, the administrator should strongly support
the office's efforts to work with the states to create a cooperative federal-state data
system based on uniform definitions and comparable scientific methods."
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Appendix A2
National Resources Journal Article
Weiland, Paul S. and Robert 0. Vos. "Reforming EPA's Organizational Structure: Establishing
an Adaptable Agency Through Eco-Regions." Natural Resources Journal. 2002.
Concerns
•	The geographical disparity of environmental problems and ecosystem features makes
it difficult for EPA headquarters and/or regional offices to establish a single set of
priorities.
•	EPA must be organized in a manner that allows the Agency to continually evaluate
policies and regulations and adjust them in response to scientific advances.
Recommendations
Reorganization by eco-region would:
•	Make EPA less programmatic and more adaptable to address the dynamic challenges
it faces now and in the future.
•	Make EPA a more adaptable organization to overcome fragmentation, collect and
analyze information, learn from mistakes using principles of adaptive management,
improve priority setting, adopt a flexible approach to enforcement, and enhance
public participation.
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Appendix A3
Environmental Politics Article
Arnold, Richard and Andrew B. Whitford. "Organizational Dilemmas of the US EPA: Why
Structure Matters for Environmental Protection." Environmental Politics. Vol. 14, No. 1, 118-
123, 2005.
Concerns
•	EPA is "hamstrung" by its institutional history, its political design, and its
organizational structure, due mainly to the lack of a congressional mandate when it
was created.
•	"Internally, managerial resources are divided horizontally between overlapping media
offices, and vertically between the national EPA offices, the regional EPA offices and
state/tribal governments."
•	"The Agency's fatal structural flaw - its programs and offices - are so narrowly
tailored, so content specific that they cannot effectively or efficiently handle
pollutants that cross multiple environmental media; or, state and international
boundaries. The results of this structure, which is largely based on the lack of a single
organic act... is that program implementation takes more time than allotted or is not
done at all."
Recommendations
•	Congress should establish a mandate that would integrate all of the environmental
statutes delegated to EPA, allowing the Agency to pursue a clear and precise agenda
with formal authority. This would end administrative ambiguities in the allocation of
resources, allow goals to be prioritized, and grant the Agency specific status in
interagency cooperation.
•	In order to address the interactions of a cross-media mandate, the program media
offices of Air and Radiation; Prevention, Pesticides, and Toxic Substances; Water;
and Solid Waste and Emergency Response would have to be joined. Similarly, in
order to address administrative feasibility, reposition the Offices of Finance, General
Counsel, Inspector General, and Enforcement to give them oversight authority over
an Interactive Pollutant Office; but below the Administrator, merge planning and
policy with the compliance, legal, and budgetary requirements that accompany
enhanced legislative authority.
•	Elevate EPA to Cabinet-level status. Currently, the U.S. is the only modernized
country without an environmental policy agency in a cabinet-level role. A
congressional mandate could raise EPA from being a Federal agency to being a
department at the Cabinet level, which would enhance the Agency's authority in
shaping the national and international environmental agenda, political feasibility of its
policy, and counterbalancing competing political interest.
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Appendix A4
Reason Public Policy Institute Report
In coordination with the National Academy of Public Administration, Progressive Policy
Institute, Urban Institute, Green Mountain Institute for Environmental Democracy, National
Environmental Policy Institute, and the U.S. Chamber of Commerce. Report to the 43rd
President and 107th Congress: Managing For Results at the U.S. Environmental Protection
Agency. 2001.
Concerns
•	"Effective management and optimal performance of many EPA programs is
hampered by outdated statutes and a lack of 'legal room' needed for innovation."
•	"EPA has not done a sufficient job in addressing the long-standing challenges posed
by its internal 'silo-based' program structure. Instead, the current fragmented
program structure gives rise to inconsistencies and conflicts in environmental
protection efforts, causes too much confusion, and prevents effective collaboration for
results."
•	"Differences among the EPA regional offices, as well as change-resistant culture in
some regions, have presented management challenges at the EPA."
•	EPA faces significant challenges in managing the development and analysis of
environmental science, as well as using science to inform its decision-making.
Further, there is the perception that the development and analysis of environmental
science is too great a challenge for EPA to address as long as it plays the role of
regulator and that science should be removed from the jurisdiction of the Agency
entirely.
Recommendations
•	Examine organizational restructuring of EPA; consider strategies to promote cross-
media review and coordination as well as re-integration of enforcement back into
each program area.
•	Begin a bipartisan process to comprehensively upgrade and update the nation's
environmental protection statutes (possibly by naming a bipartisan commission to
develop model legislation). Even in the absence of comprehensive statutory
revisions, the EPA should look for ways to create "legal space" within existing
statutes to promote innovation and results.
•	Immediately begin a process to identify truly outcome-oriented performance
measurements to track environmental improvements and improve and standardize
environmental data systems in partnership with the States and localities.
•	Consider the creation of an independent Bureau of Environmental Information and
Statistics, "patterned after the Bureau of Labor or Health Statistics."
•	"Improve the credibility of EPA science; evaluate the current policies governing the
use of science at EPA and consider the appointment of a science czar."
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"The Administrator is going to have to make some critical decisions about the
place of science in the agency and specifically pick up on recommendations that
have been made over several years now, that there be a science advisor—that the
science presence in the agency be elevated substantially into a position of
authority there. I think that the opportunity there lies early on in an
Administration to set that tone and to start building on the credibility of EPA
science because that is ultimately the foundation for everything that the agency is
going to be doing from there on."
"I would suggest to the administrator that he or she ask Congress for the authority
to appoint a chief scientist and follow the model that is used for naming a director
for the US Geological Survey. It should be an appointment that transcends
Administrators, as recommended by the National Academy of Sciences. EPA
should have a chief scientist with considerable authority early in the agency
decision-making processes to set a tone right from the outset that science is the
underlying basis for the decision making."
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Appendix A5
Environmental Protection Agency National
Performance Review
Creating A U.S. Environmental Protection Agency that Works Better and Costs Less - Phase 1.
1993.
Concerns
•	"The teams found organizational and 'traditional mindset' barriers that have
negatively impacted EPA's ability to address multi-media or ecosystem types of
problems and to institutionalize pollution prevention."
•	"Media-specific approaches create duplication among program offices."
•	"The need to tackle more complex issues through prevention and control, in a more
'holistic' fashion, appears to require a new organizational approach."
•	"As EPA strives to solve more complex issues, its current structure works to inhibit
or impede success."
•	"The EPA also needs to address the barriers which are created by multiple pieces of
enabling legislation."
•	"EPA's ability to conduct an effective and coherent quality-science program is
impacted by numerous congressional mandates and highly departmentalized
appropriations."
•	"Research and development is not driven by a holistic, long-term, strategic plan."
•	Critical research has been cut back or eliminated as the Office of Research and
Development is forced to respond to new policy mandates without a commensurate
increase in funds and staff.
•	The Agency's severely limited ability to support and nurture its scientific staff has
contributed to the perception that EPA's decision-making is not always rooted in
sound science.
•	"Program offices within EPA are divided by media-specific statutes that sometimes
erect seemingly insurmountable barriers to cross-media initiatives."
•	"Today, environmental issues are more complex than ever before; and environmental
protection strategies must cut across all environmental media and all routes of
exposure. Rarely is it sufficient to deal with environmental media individually.
Rather, the quality of science across all program offices that exercise statutory
authority over specific media should reflect a consistent, holistic approach to
protecting and enhancing both ecosystems and human health and, at the same time,
should ensure adequate environmental resources to meet future needs."
Recommendations
•	EPA could be organized by function, geographic area, specific ecosystem problems,
or industry.
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•	EPA should establish an infrastructure to enable cross-media teams to be organized
quickly in order to work on specific issues related to ecosystems, geographic
locations, or pollution prevention initiatives.
•	The Agency needs to resolve the sensitive issues related to the responsibility,
accountability, and financing of multi-media work groups.
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Appendix A6
Government Accountability Office
Reports and Testimonies
Protecting Human Health and the Environment through Improved Management. RCED-88-101.
1988.
Concerns
•	EPA is challenged by the long-term nature of the solutions to its efforts and differing
legislative requirements. Institutional barriers have constrained EPA's management
of its information resources.
•	EPA's information systems have incomplete and untimely data. EPA has several
efforts in process to upgrade the quality of information it uses. GAO said that if EPA
implements changes aimed at long-term improvement, it can achieve its goal of
having timely and complete data in its systems. Two sets of action will make this
possible. First, EPA should develop an information resources management
organizational framework that will establish high-level management authority for
directing and implementing information resources management activities. The
second action is for EPA to use more effective mission-based planning and budgeting
for its information activities.
Corrective Actions and Recommendations
EPA has begun initiatives intended to increase its management and operational
effectiveness. These include obtaining better financial, management, and programmatic
information.
Management Issues Facing the Environmental Protection Agency. T-RCED-93 -26. 1993.
Concerns
This GAO testimony listed the following challenges that EPA faced in 1993:
•	Accomplishing multiple mandates with limited resources;
•	Developing necessary scientific and monitoring information;
•	Strengthening global environmental protection efforts; and
•	Although EPA's regulatory programs depend heavily on scientific information about
the health and environmental effects of chemicals and pollutants, these data often do
not exist. Data that EPA has available are often inadequate and poorly managed.
EPA is also missing the information necessary to judge the success of its programs.
While EPA has developed some measures of environmental outcomes, the agency has
generally relied on activity-based indicators, such as numbers of permits or
enforcement actions taken, to track its progress.
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Recommendations
•	GAO suggested that a more integrated approach to environmental management might
help EPA accomplish its multiple mandates.
•	To achieve an integrated approach, GAO suggested considering alternative
organizational structures, such as organization by function or organization by
pollution sectors.
Major Management Challenges and Program Risks: Environmental Protection Agency.
GAO-01-257. 2001.
Concerns
•	EPA has made slow progress in developing and implementing a comprehensive
information management strategy.
•	EPA has fundamental disagreements with States over their respective roles, the
priorities among State environmental programs, and the appropriate extent of Federal
oversight.
•	Obtaining and managing environmental information has been a long standing
challenge for EPA. Without a comprehensive picture of environmental conditions,
EPA has difficulty setting risk-based priorities for its programs, evaluating
performance progress and environmental results, and reporting on its
accomplishments as required by the Government Performance and Results Act
(GPRA). EPA has not had the information it needs on environmental conditions and
changes over time to identify problem areas that are emerging and need additional
regulatory action.
Environmental Protection: Observations on Elevating the Environmental Protection Agency to
Cabinet Status. GAO-02-552T. 2002.
Concerns
•	Major management challenges at EPA are related to human capital, the quality of
environmental information used by EPA, and streamlining environmental
requirements through use of innovative approaches.
•	The following factors should be considered in determining EPA's appropriate
organizational structure:
-	The significance of problems to be addressed,
-	The extent and level of interaction and coordination necessary with other Federal
departments, and
-	The need for international cooperation in formulating long-term policies.
•	EPA needs better environmental and scientific information to manage risks and
measure results. While EPA has collected a vast amount of scientific and
environmental data, much of it is not complete and accurate enough to credibly assess
risks and establish corresponding risk reduction strategies. Likewise, primarily
because of inadequacies in its scientific and environmental data, EPA
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has not been successful in identifying, developing, and reaching agreement with its
stakeholders on a comprehensive set of measures to link EPA's activities to changes
in human health and the environment.
Recommendations
GAO supported the creation of a Bureau of Environmental Statistics that would collect,
compile, analyze, and publish a comprehensive set of environmental quality and related
measures of public health. This Bureau could also obtain data collected by other Federal
agencies but not currently integrated with EPA's data.
Major Management Challenges and Program Risks: Environmental Protection Agency.
GAO-03-112. 2003.
Concerns
EPA has made progress toward resolving performance and management challenges that
GAO previously identified in its 2001 performance and accountability report. However,
EPA should continue to:
•	Improve environmental information,
•	Strengthen human capital management,
•	Make regulatory innovation successful,
•	Improve grants planning and management, and
•	Strengthen controls over financial reporting.
EPA has taken important steps to improve the environmental information it uses to set
priorities and measure progress. For example, EPA has started to determine the overall
status of the nation's environment. EPA has also begun to improve the compatibility and
security of its data systems. However, EPA must work further to improve its
environmental information, fill significant gaps, and incorporate better scientific
understanding into its performance measures.
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Appendix A7
Resources for the Future Testimony
Paul R. Portney, President of Resources for the Future (a nonprofit and nonpartisan organization
that conducts independent research on environmental, energy, and natural resource issues), gave
testimony before the House Committee on Government Reform on June 6, 2003. His testimony
was his personal views on legislation to elevate EPA to cabinet status.
Concerns
Mr. Portney indicated that he was in favor of the creation of a "Bureau of Environmental
Statistics." He felt the bureau would provide the following benefits:
•	Improve the quality of the nation's environmental data,
•	Provide better information on environmental conditions and trends,
•	Elevate the quality of policy debates about which environmental programs are
working and which are not, and
•	Improve our ability to compare the benefits and costs of both current and prospective
environmental programs.
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Appendix B
Breakout of Issue Categories by Report
Report Title
Cross-Media
Management
Regional
Offices
Reliable
Information
Reliable
Science
N APA Setting Priorities, Getting Pesults.
(1995)
X

X

NAPA Resolving the Paradox of
Environmental Protection. (1997)
X

X

NAPA Environment.gov: Transforming
Environmental Protection for the 21st
Century. (2000)
X

X

National Resources Journal "Reforming
EPA's Organizational Structure: Establishing
an adaptable Agency through Eco-Regions."
(2002)
X
X


Environmental Politics "Organizational
Dilemmas of the US EPA: Why Structure
Matters For Environmental Protection."
(2005)
X



Reason Public Policy Institute
Report to the 43rd President and 107th
Congress: Managing for Results at EPA.
(2001)
X
X
X
X
EPA National Performance Review
Creating A U.S. Environmental Protection
Agency that Works Better and Costs Less -
Phase 1. (1993)
X


X
GAO Protecting Human Health and the
Environment Through Improved Management,
(1988)


X

GAO Management Issues Facing the
Environmental Protection Agency. (1993)


X

GAO Major Management Challenges and
Program Risks: Environmental Protection
Agency. (2001)


X

GAO Environmental Protection:
Observations on Elevating the Environmental
Protection Agency to Cabinet Status. (2002)


X

GAO Major Management Challenges and
Program Risks: Environmental Protection
Agency. (2003)


X

Resources for the Future President
Testimony before the House Committee on
Government Reform. (2003)


X

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Appendix C
EPA's Initial Organizational Chart
(as of December 4,1970)
Approved: [signed] William D. Ruckelshaus
Date: December 4,1970
Commissioner
Pesticides Office
Assistant Administrator
for
Planning and Management
Commissioner
Water Quality Office
Commissioner
Solid Wastes Office
ADMINISTRATOR
Assistant Administrator
for
Research and Monitoring
Assistant Administrator
(for Standards and Enforcement)
and General Counsel
Commissioner
Air Pollution Control Office
Commissioner
Radiation Office
Regional Offices at the EPA
10 Regional Administrators
Director, Public Affairs
Director, Legislative Liaison
Director, International Affairs
Director, Equal Opportunity
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EPA's Organizational Chart
(as of April 30, 1971)
Appendix D
Office of
Congressional Affairs
Office of
Equal Opportunity
Office of
International Affairs
Office of
Public Affairs
Assistant Administrator
Assistant Administrator
Assistant Administrator
Assistant Administrator
Assistant Administrator
Planning and
Management
Enforcement and
General Council
Research and
Monitoring
Media Programs
Categorical Programs
Office of
Enforcement
Office of
Administration
Office of
Planning and
Evaluation
Office of
Audit
Region 1
Boston
Region 2
New York
Region 3
Philadelphia
Region 4
Atlanta
Region 5
Chicago
Region 6
Dallas
Region 7
Kansas City
Region E
Denver
Region 3
San Francisco
Region 10
Seattle
Office of
Air Programs
Office of
General Council
Office of
Pesticides Programs
Office of
Radiation Programs
Office of
Water
Programs
Office of
Resource
Management
Deputy
Administrator
Office of
Solid Waste
Management
Programs
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Appendix E
EPA's Current Organizational Chart
(as of June 2006)
Region A
Atlanta
Region 9
San Francisco
Region 5
Chicago
Region 2
New York
Region 10
Seattle
Region 1
Boston
Region £
Denver
Region 6
Dallas
Region 7
Kansas City
Region 3
Philadelphia
Chief Financial Officer
Administrator
Deputy Administrator
As s i stant Ad m i n i strato r
for
Water
As s i stant Ad m i n i strato r
for Environmental
Information
Inspector General
Assist Administrator for
Prevention, Pesticides
and Toxic Substances
As s i stant Ad m i n i strato r
for Enforcement and
Compliance Assurance
Assistant Administrator
nternational Affairs
General Counse
Assistant Administrator
for Solid Waste and
Emergency Response
As s i stant Ad m i n i strato r
for Air and Radiation
As s i stant Ad m i n i strato r
for Research and
Development
Assistant Administrator
for Administration and
Resources Management
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Appendix F
Distribution
Office of the Administrator
Assistant Administrators
Agency Followup Official (the CFO)
Agency Followup Coordinator
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Director, Office of Regional Operations
General Counsel
Acting Inspector General
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