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s	U.S. Environmental Protection Agency	2007-B-00002
%	\ Office of Inspector General	July 24,2007
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%; At a Glance
Why We Did This Review
We conducted this review at
the request of the Office of
Management and Budget. We
were asked to assess (1) the
accuracy and reliability of the
U.S. Environmental Protection
Agency's (EPA's) Office of
Enforcement and Compliance
Assurance (OECA) pollution
reduction projections for
enforcement actions and
settlements, and (2) whether the
reported projected pollution
reductions were achieved.
Background
OECA's enforcement actions
can result in facilities agreeing
to install pollution controls or
take other measures to reduce
pollutant emissions or
discharges. In accordance with
the Government Performance
and Results Act, OECA
annually reports on the amount
of pollutants expected to be
reduced, treated, or eliminated
as a result of these actions.
OECA only reports 1 year's
worth of estimated pollutant
reductions, though reductions
may occur for years into the
future. The reductions are
reported in the fiscal year that
an enforcement case is
concluded, not necessarily the
year in which the projected
reductions will be fully
realized.
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.qov/oiq/reports/2007/
20070724-2007-B-00002.pdf
Catalyst for Improving the Environment
Assessment of EPA's Projected Pollutant Reductions
Resulting from Enforcement Actions and Settlements
What We Learned
The accuracy and reliability of EPA's projected pollutant reductions for Fiscal
Years 2003-2006 were dependent on the specific program in which the
enforcement action took place. For example, more reliable data were available to
project reductions from oil spill and power plant cases than other Clean Water Act
(CWA) and Clean Air Act (CAA) cases, respectively. EPA has improved its
internal control process for ensuring more accurate pollutant reduction estimates
from concluded enforcement cases. The accuracy of estimated reductions from
CWA enforcement actions has likely improved as a result of these internal control
changes. However, we noted some inconsistencies in the calculation of projected
CAA emission reductions. For example, three of the six power plant cases we
reviewed did not include estimates for particulate matter reductions, thereby
underreporting reductions. Also, different methodologies were used to estimate
post-compliance emissions from power plant cases. Further, three of the six
regions we surveyed did not independently review the basis for the projected
reductions for some CAA cases as called for by OECA's guidance.
EPA's annual projected reductions were heavily influenced by a few large cases.
Less than 1 percent of the CWA cases accounted for 52 percent of the projected
pollutant reductions from concluded CWA enforcement actions. Similarly, a few
large power plant cases resulted in a marked increase in total estimated CAA-
related reductions for Fiscal Years 2004-2005. For example, two power plant
cases accounted for over 600 million pounds in reductions, about 78 percent of
the Fiscal Year 2004 total.
Facilities were on target to meet the projected reductions for the CAA cases we
reviewed. However, it will take years to complete all corrective actions in these
cases. Consequently, we could not determine whether they had achieved their
total projected reductions. Projected reductions have already been achieved for at
least one CWA case, and other CWA cases were making progress toward meeting
their projected reductions. EPA's 2006 Annual Report used terms such as
"achieved," "reduced," and "actual" to describe emission reductions for that year
even though the reductions were often only projected amounts, since it can take
years for reductions to occur. OECA agreed to use more precise wording in
future reports.
We presented the results of our review to OECA on May 23, 2007. We clarified
parts of our presentation based on OECA's feedback. OECA generally agreed
with our findings and stated that it would address the issues disclosed. We make
no recommendations in this report.

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