
Using GPRA to Improve Environmental Quality and the Effectiveness of EPA - Background Briefing Organ
by Guest Blogger, 7/11/2002
Prepared by: Shelley H. Metzenbaum
978-371-3099
smetzenbaum@aics.net
The Opportunity
The Government Performance and Results Act of 1993 (GPRA) offers an unprecedented opportunity to improve environmental quality, both by shaping EPA's overall priorities and by providing more useful information to the agency and the public. Yet despite the potentially enormous payoff, those outside EPA -- Congress, environmental organizations, and the public -- have largely ignored the new law. If this disinterest continues, GPRA could easily regress into a trivial, bureaucratic paper exercise. But it should be much more.
The law, which applies to all federal agencies, contains three main components. First, EPA must consult with "potentially affected" or "interested" parties in developing a three-year strategic plan. Second, EPA must establish an annual performance plan that quantitatively measures the agency's results. And third -- and perhaps most important because of the opportunity it represents to improve environmental data available to the public -- EPA must report on its results relative to the performance plan at the end of each year (the first such report is due by March 31, 2000).
EPA completed its very first strategic plan in September 1997 and released its second performance plan in February 1999. These plans are more informative than what was previously available on a routine basis (primarily budget documents), but they are still of limited value both to those inside and outside the agency. For instance, EPA does not seek to measure or report performance by geographic area, pollution source, watershed, or demographic group affected. Instead, goals and measures are expressed in the most general terms, and too often in terms of outputs (measuring the activities that are performed to achieve a goal) rather than outcomes (measuring actual improvement in the environment).
Ideally, in setting its goals and measures, EPA should look at GPRA as a management tool that has three main functions:
- First, it should focus the agency's work. The GPRA process should be used to determine and describe the focus of the agency's activities, delineating for both agency staff and the public the (1) areas on which EPA will focus its attention and available funds, and (2) the areas that will receive less or no attention. The fact is that such decisions occur every day in the individual offices of EPA in an ad hoc, unarticulated form. A more structured and transparent prioritization would allow citizens and their representatives to comment on the various trade-offs the EPA makes.
- Second, as mandated by GPRA, it should articulate "how the goals and objectives are to be achieved." If done well, this would allow the public to review, assess, and debate the likely effectiveness of EPA's approach to a problem.
- Third, it should allow for comparison across EPA's organizational units. This would promote cross-agency learning and make it easier to identify weak programs within EPA. Moreover, it would stimulate a healthy competition among organizational units to deliver better environmental quality. For example, reporting on the performance of EPA's regional offices for a few priority environmental indicators would introduce the constructive tension of comparison with public scrutiny.
- First, there is a lack of clarity within EPA about "where the buck stops" (other than at the door of the Administrator or Deputy Administrator who already have too much on their to-do lists). This lack of clarity has long confounded efforts to address problems and pursue strategies that need attention across or beyond EPA's media programs. GPRA should be used to clarify how individual organizational units will contribute to overall agency goals.
- Second, it is difficult to identify and address weak programs within EPA. Even when staff in a division of a headquarters program office knows which regional programs or program designs are weak, they seldom "run it up the management chain" (to their Assistant Administrator) to share the information with the Regional or Deputy Regional Administrators who can fix the problem. The EPA culture does not encourage this sort of communication. More likely, if a headquarters office is aware of a problem, it would share the performance information only with the regional program director, who may, in fact, be a contributor to the problem. EPA should use GPRA to build a more transparent performance information and communication system that identifies management problems and motivates the agency to fix them.
- Third, cross-agency learning is not sufficiently supported within EPA. Today, when one region or office tests a better way to deliver some aspect of environmental protection, it is very hard for others to find out about the test and whether it merits replication. It is even more difficult to find out about a regional experiment that did not work, although sharing that lesson would also help the whole agency deliver better environmental protection. GPRA should form the structural foundation for a more effective management system that enables EPA to learn and share information about program effectiveness.
- Goals - are they the right ones? EPA has adopted ten goals and eight guiding principles. Has it got the goals right? Some of the goals (clean air; clean and safe water; reducing risk in communities, homes, workplaces, and ecosystems; reducing global and cross-border risks; restoration of contaminated sites) are clear environmental outcome goals over which EPA has primary jurisdiction. Others (safe food) deal with issues over which EPA shares jurisdiction. EPA's other goals describe how the agency is going to do its work (preventing pollution, better waste management, emergency response, expansion of right-to-know, sound science, credible deterrence, greater compliance, and effective management.) Should more of EPA's goals be environmental outcome goals? What about the principles? Should these be integrated into the goals or kept separate? Some of the principles describe what the agency will do (reduce health and environmental risk). Some address how it will do its work (emphasize pollution prevention, strengthen partnerships, maximize public participation and community right-to-know, emphasize comprehensive regional and community-based solutions, choose common-sense, cost-effective solutions). Some identify programmatic priorities (emphasize children's health, place emphasis on Indian Country). Do you agree with the goals and principles as articulated in EPA's strategic plan? Has EPA got too many goals? How can the agency manage eighteen goals and principles, without knowing which ones take priority over the others or support the others? Should it have fewer goals so that it can manage strategically? Should EPA's objectives be primarily environmental outcomes or should they also include programmatic outcomes such as effective management? Should it try to integrate its goals across programs, so that, for example, reducing risk becomes a single goal rather than two goals - one addressing domestic concerns and one addressing international concerns? When EPA shares jurisdiction with another agency, do you want to know more about how the other agencies are going to address the goal?
- Measures - do you understand them? Are they useful? For each goal, EPA has identified objectives, including the indicators it will use to measure its performance relative to the objectives and targets levels of performance to be achieved by certain dates. Do you find the measures EPA has selected to be useful or would you prefer other measures, even if EPA has to invest additional resources to develop and collect those measures and therefore may need to make programmatic or reporting reductions elsewhere? For example, would you rather know the number of pesticides registered, the volume and toxicity of applied pesticides, or the level of pesticide-related illnesses and fatalities? Would you rather know how many states run lead-abatement training and accreditation programs or how many children have lead poisoning in each state? What other information do you need to allow you to interpret the performance measures EPA reports? Do you want to see national performance indicators compared to the performance of other developed countries? Which, if any of these performance measures, will you be able to use? How will the measures be most useful? Would the measures be more useful if they were broken down geographically, by Congressional district, by region, by state, by watershed, by airshed? If you had the information disaggregated at these different levels, would it affect the way you used it? Would it be more useful if the information were broken down by specific demographic categories, such as male and females; children and adults; and by ethnic group. If you had to choose among these "break-downs," which would be most useful to you? Do you feel that the milestones EPA has set should be more aggressive? Should they be more realistic?
- How EPA will accomplish its goals - do EPA's proposed approaches for improving environmental performance make sense? In its Strategic Plan, EPA provides some detail about how it hopes to accomplish its objectives. For example, in the pollution prevention area, EPA's identifies several interim milestones for its pollution prevention program to achieve by 2005. These include: (1) each Executive Branch department having an effective program for purchasing environmentally preferable products, and (2) sixty percent of manufacturing facilities having adopted voluntary environmental management systems, including environmental accounting and materials management practices. Do you want to know more about how EPA plans to accomplish these goals? Would you like the EPA Performance Plan to make it easier to link the discussion of resources and strategies to the milestones?
- Data quality - what do you want to know about data quality? Each objective in EPA's Performance Plan describes how EPA verifies and validates its performance measures. This narrative does not, however, describe the quality of EPA's data. Do you want EPA to assess the accuracy of its data quality for each of its objectives and report on that publicly in its GPRA plans and reports?
- Unit of accountability - should the Performance Plan identify who in EPA is accountable for achieving specific objectives? As noted above, one of EPA's management weaknesses is a lack of clarity about who is responsible for what. Do you think it would be valuable to you or to the agency if the plan identified which organizational units were responsible for what outcomes?
- Organization - would it make it more useful to you or other public organizations if the information in the Strategic and Performance Plans were organized and presented differently? The way the current strategic and performance plan is organized and presented primarily reflects the organizational structure of EPA's headquarters offices. Would you find it useful to have the information organized geographically or functionally instead of the way it is currently presented? Alternatively, would you prefer that EPA conduct special analyses that organize, analyze, and present information? This has been done for years with the Budget of the United States in a set of appendices called "Special Analyses of the Budget" (currently, "Analytical Perspectives"). These looked across organizational units to describe budgetary resources that addressed specific needs or functions, such as the federal government's financial credit activities.
It was suggested above that geographic organization of the information would prove far more useful to the public, because they could more easily relate the information EPA reports to their local situation. It might also link more closely to EPA's management structure, so that the responsibilities of regional offices and the commitments made by the states would be more obvious not only to those outside the agency but to those inside it as well. Would you like to see the information organized and presented by:
- EPA regional offices,
- states,
- Congressional district.
- watershed or airshed?
- (a) Do you prefer objectives that have longer term (e.g. 2010) timetables, or those that are shorter term (e.g. 2003)?
- (b) How much specificity do you want in the goals and performance plan? For example, in its performance plan for FY2000, EPA says it will increase the percentage of the population served by community drinking water systems that meet all health-based standards in effect in 1994 from 89% in 1999 (up from 83% in 1994) to 91% in 2000. Do you want the plan to indicate which communities are expected to move beyond the threshold, or at least are candidates for improvement (that is, they are currently fail to meet 1994 standards)?
- (c) What information do you want EPA to provide you to help you do your work better?
- All Americans are protected from significant risks to human health and the environment where they live, learn, and work.
- National efforts to reduce environmental risk are based on the best available scientific information.
- Federal laws protecting human health and the environment are enforced fairly and effectively.
- Environmental protection is an integral consideration in U.S. policies concerning natural resources, human health, economic growth, energy, transportation, agriculture, industry, and international trade, and these factors are similarly considered in establishing environmental policy.
- All parts of society - communities, individuals, business, state and local governments, tribal governments - have access to accurate information sufficient to effectively participate in managing human health and environmental risks.
- Environmental protection contributes to making our communities and ecosystems diverse, sustainable, and economically productive.
- The United States plays a leadership role in working with other nations to protect the global environment.
- (a) By 2010, improve air quality for Americans living in areas that do not meet NAAQS for ozone and particulate matter.
- (b) By 2010, reduce air toxics emissions by 75 percent from 1993 levels to significantly reduce the risk to Americans of cancer and other serious adverse health effects caused by airborne toxics.
- (c) By 2005, improve air quality for Americans living in areas that do not meet the NAAQS standards for carbon monoxide, sulfur dioxide, lead, and nitrogen dioxide.
- (d) By 2010, ambient sulfates and total sulfur deposition will be reduced by 20-40 percent from 1980 levels due to reduced sulfur dioxide emissions from utilities and industrial sources. By 2000, ambient nitrates and total nitrogen depositions will be reduced by 5-10 percent from 1980 levels due to reduced emissions of nitrogen oxides from utilities and mobile sources.
- (a) By 2003, reduce the age-adjusted death rate for selected respiratory diseases in the United States from the 1996 rate of 20.9 per 100,000 to 18.8 per 100,000.
- (b) By 2005, reduce the estimated annual damage to property (from soiling) and crops caused by air pollution by $6 billion (1990 dollars) from the estimated damage caused by air pollution in 1970.
- (c) By 2003, none of the Nation's National Parks and Wilderness areas will have deteriorating visibility (down from approximately 5.5 percent in 1997) and 80 percent of such areas will have improving visibility (a slight increase from 78 percent in 1997).
- (a) By 2005, protect human health so that 95 percent of the population served by community water systems will receive water that meets drinking water standards, consumption of contaminated fish and shellfish will be reduced, and exposure to microbial and other forms of contamination in waters used for recreation will be reduced.
- (b) Conserve and enhance the ecological health of the nation's (state, interstate, and tribal) waters and aquatic ecosystems - rivers and streams, lakes, wetlands, estuaries, coastal areas, oceans, and groundwater - so that 75 percent of waters will support healthy aquatic communities by 2005.
- (c) By 2005, pollutant discharges from key point sources and nonpoint source runoff will be reduced by at least 20 percent from 1992 levels. Air deposition of key pollutants impacting water bodies will be reduced.
- (a) From 2003 through 2005, reduce the number of waterborne-disease outbreaks to 2 a year. The average number of outbreaks for the years 1991 through 1996 was approximately 14 a year.
- (b) From 2001 through 2005, there will be no deaths associated with water provided by public drinking water systems. Over a six-year period beginning in 1991, 58 people died from water-borne disease.
- (c) By 2005, no more than 8 percent of the nation's water bodies will be of poor quality. In 1992 and 1994 approximately 10 percent of surveyed waters were of poor quality.
- (d) By 2005, at least 70 percent of the nation's water bodies will be of good quality. In 1992 and 1994 approximately 63 percent of surveyed waters were of good quality.
- (e) By 2000 and 2005, there will be approximately 103.5 million acres of wetlands (estuarine and palustrine) and 106 million acres of wetlands respectively in the conterminous United States. As of 1995 there were approximately 101 million acres of wetlands in the United States.
