Office of Inspector General
U.S. Environmental Protection Agency
At a Glance
22-E-0008
November 17, 2021
Why We Did This Evaluation
We conducted this evaluation to:
•	Assess the impacts of the
coronavirus pandemic on the
number and type of
compliance-monitoring
activities taken by state and
local agencies at facilities
that emit air pollution.
•	Determine what guidance the
U.S. Environmental
Protection Agency provided
to state and local agencies to
target or prioritize
compliance-monitoring
activities at facilities and how
agencies conducted those
tasks during the pandemic.
The EPA's Clean Air Act
Stationary Source Compliance
Monitoring Strategy recommends
the frequency and type of
activities to be conducted by
delegated state and local
agencies, which then report
those activities to the EPA. We
relied on those reported activities
for our findings and
recommendations.
This evaluation supports an EPA
mission-related effort:
•	Improving air quality.
This evaluation addresses these
top EPA management challenges:
•	Overseeing states implementing
EPA programs.
•	Maintaining operations during
pandemic responses.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
Total National Reported Clean Air Act
Compliance-Monitoring Activities Decreased
Slightly During Coronavirus Pandemic, but
State Activities Varied Widely
What We Found
The coronavirus pandemic marginally impacted
the total number of nationwide compliance-
monitoring activities at facilities that emit air
pollution. However, activities varied widely
among states and territories, with reported
changes in activities at high-emitting sources in
fiscal year 2020 ranging from an 88-percent
decline to a 234-percent increase. Substantially
lower levels of compliance monitoring limit the
deterrent effect that consistent monitoring can
have on facilities' noncompliance and increase
the risk that noncompliance could go undetected
Compliance-monitoring
activities are important to
ensure that facilities
comply with applicable
Clean Air Act
requirements and air
regulations to protect
human health and the
environment and deter
violations that result in
excess emissions.
at facilities.
State and local agencies shifted some types of compliance-monitoring activities
from on-site to off-site. This shift is in accordance with guidance the EPA issued
in July 2020, which provided some flexibility to state and local agencies to count
off-site compliance-monitoring activities toward the Clean Air Act Stationary
Source Compliance Monitoring Strategy, or CAA CMS, commitments for full
compliance evaluations. The EPA, however, has not yet assessed the impact of
this flexibility on the use of off-site full-compliance evaluations to ensure that
evaluations are consistent with the CAA CMS. In addition, while the EPA
convened a workgroup to explore using remote video to conduct off-site
partial-compliance evaluations, the Agency has not yet determined the
conditions under which remote video is technically, legally, and
programmatically feasible and has not finalized its draft standard operating
procedures.
While the EPA did not issue pandemic-specific guidance on how state and local
agencies should prioritize facilities for compliance monitoring, the three state
and local agencies we reviewed told us that they prioritized activities at the
largest emitters of air pollution to meet their commitments under the CAA CMS.
Recommendations and Planned Agency Corrective Actions
We recommend that the EPA address the needs of agencies that had
significant declines in compliance-monitoring activities. We also recommend
internal controls to strengthen the EPA's oversight of off-site
compliance-monitoring activities. The EPA provided acceptable corrective
actions and planned completion dates for our six recommendations. All
recommendations are resolved with corrective actions pending.

-------