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Performance and Accountability Series:

January 2003:

Major Management Challenges and Program Risks:

Environmental Protection Agency:


A Glance at the Agency Covered in This Report:

The Environmental Protection Agency has the critical and complex 

mission of protecting human health and safeguarding the environment. It 

works collaboratively with the states, local governments, tribes, and 

others on a variety of efforts, including ensuring that 

* the air in every American community will be safe and healthy to 


* all Americans will have drinking water that is clean and safe to 


* America’s rivers, lakes, wetlands, aquifers, and coastal and ocean 

waters will be protected;

* the foods Americans eat will be free from unsafe pesticide residues;

* America’s wastes will be stored, treated, and disposed of in ways 

that prevent harm to people and the natural environment; and

* the United States will lead other nations in reducing significant 

risks from climate change, stratospheric ozone depletion, and other 

hazards of international concern.

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This Series:

This report is part of a special GAO series, first issued in 1999 

and updated in 2001, entitled the Performance and Accountability 

Series: Major Management Challenges and Program Risks. The 2003 

Performance and Accountability Series contains separate reports 

covering each cabinet department, most major independent agencies, 

and the U.S. Postal Service. The series also includes a 

governmentwide perspective on transforming the way the government 

does business in order to meet 21st century challenges and address 

long-term fiscal needs. The companion 2003 High-Risk Series: An 

Update identifies areas at high risk due to either their greater 

vulnerabilities to waste, fraud, abuse, and mismanagement or major 

challenges associated with their economy, efficiency, or 

effectiveness. A list of all of the reports in this series is 

included at the end of this report.

GAO Highlights:

Highlights of GAO-03-112, a report to Congress included as part of 

GAO’s Performance and Accountability Series.

Why GAO Did This Report:

In its 2001 performance and accountability report on the 

Environmental Protection Agency (EPA), GAO identified important 

challenges facing the agency in improving environmental information, 

developing a comprehensive human capital approach, and strengthening 

working relationships with the states.  The information GAO presents in 

this report is intended to help to sustain congressional attention and 

an agency focus on continuing to make progress in addressing these 

challenges—and others that have arisen since 2001—and ultimately 

overcoming them.  This report is part of a special series of 25 reports 

on governmentwide and agency-specific issues.

What GAO Found:

The Environmental Protection Agency has made progress toward resolving 

the specific performance and management challenges that GAO previously 

identified.  However, each of these challenges requires more work and 

vigilance to be overcome.  In addition, the agency must face emerging 

challenges in managing grant resources to better achieve environmental 

results and in correcting weaknesses in controls over its financial 


* Improving environmental information. EPA has taken important steps to 

improve the environmental information it uses to set priorities and 

measure progress.  For example, EPA has embarked on a major effort to 

determine the overall status of the nation’s environment.  EPA has also 

taken steps to improve the compatibility and security of its data 

systems.  However, EPA must work to further improve its environmental 

information, fill significant data gaps, and incorporate better 

scientific understanding into its performance measures.

* Strengthening human capital management. EPA has conducted a study of 

its workforce and issued a human capital strategy.  However, the agency 

still must determine the number of employees it needs to accomplish its 

mission, the technical skills required, and how best to allocate 

employees among EPA’s strategic goals and geographic locations.  

Similarly, EPA needs to fully prepare for the loss of leadership, 

institutional knowledge, and scientific expertise that will likely 

result from upcoming retirements.

* Making regulatory innovation successful. EPA has invested 

time and resources in a variety of initiatives to encourage more 

effective and cost-efficient environmental protection.  However, these 

initiatives have yielded limited results.  Our work shows that current 

environmental statutes significantly impede regulatory innovation.  If 

the statutory obstacles to innovation are not addressed, EPA’s future 

regulatory initiatives may not fare better than past ones. 

* Improving grants planning and management. EPA annually spends over 

half its budget on grants.  However, the agency has often not focused 

its planning and performance measurement for grants on achieving 

environmental results.  In addition, EPA must address persistent 

problems in its management and oversight of grants.

* Strengthening controls over financial reporting. EPA’s Inspector 

General issued an unqualified opinion on EPA’s consolidated financial 

statements for fiscal year 2001.  However, the Inspector General 

identified several internal control weaknesses that EPA needs to 

address to improve its ability to process, summarize, and report 

financial data.

What Remains to Be Done:

GAO believes that EPA should:

* Ensure that recent steps to improve environmental information receive 

sustained top management support.

* Implement a systematic and comprehensive human capital approach.

* Articulate a clear and specific endorsement of legislation that would 

address statutory obstacles to the agency’s regulatory reinvention 


* Strengthen its grants planning and management to better achieve 

environmental results.

* Improve its internal controls over financial reporting.


Transmittal Letter:

Major Performance and Accountability Challenges:

GAO Contacts:

Related GAO Products:

Performance and Accountability and High-Risk Series:

This is a work of the U.S. Government and is not subject to copyright 

protection in the United States. It may be reproduced and distributed 

in its entirety without further permission from GAO. It may contain 

copyrighted graphics, images or other materials. Permission from the 

copyright holder may be necessary should you wish to reproduce 

copyrighted materials separately from GAO’s product.

January 2003:

The President of the Senate and the

Speaker of the House of Representatives:

This report addresses the major management challenges and program risks 

facing the Environmental Protection Agency (EPA) as it works to carry 

out its complex mission of protecting human health and safeguarding the 

environment. The report discusses the actions that EPA has taken and 

that are under way to address the challenges GAO identified in its 

Performance and Accountability Series 2 years ago. The report also 

summarizes the challenges that remain, new ones that have emerged, and 

further actions that GAO believes are needed.

This analysis should help the new Congress and the administration carry 

out their responsibilities and improve government for the benefit of 

the American people. For additional information about this report, 

please contact Robert A. Robinson, Managing Director, Natural Resources 

and Environment, at (202) 512-3841 or at

Signed by David M. Walker:

David M. Walker

Comptroller General

  of the United States:

[End of section]

Major Performance and Accountability Challenges:

In January 2001 we reported that EPA faced three performance and 

accountability challenges in fulfilling its mission of protecting 

human health and the environment. First, EPA needed to improve its 

environmental and performance information management to set priorities 

and measure results. Without a comprehensive picture of environmental 

conditions, EPA faces difficulty in setting risk-based priorities for 

its programs, evaluating performance progress and environmental 

results, and reporting on its accomplishments. Second, EPA needed to 

place greater emphasis on developing a comprehensive human capital 

program. Without such a program, EPA faces difficulty in aligning human 

capital investments with strategic goals and objectives, and 

determining the number of employees, the skills, and the deployment of 

its workforce needed to accomplish its mission. Finally, we reported 

that the nation’s complex future environmental challenges require EPA 

and its stakeholders to adopt fundamentally different regulatory 

approaches that are more flexible and less administratively burdensome.

During the past 2 years, EPA has continued its traditional efforts to 

protect the nation’s air, land, water, and human health, while 

undertaking new roles and responsibilities, such as mitigating the 

environmental effects of the tragic events of 2001. EPA played a major 

role in responding to the attacks at the World Trade Center, assisting 

in debris removal, air and water quality monitoring, worker protection, 

dust cleanup, and criminal investigation. Similarly, EPA worked with 

the Federal Bureau of Investigation and the Department of Defense at 

the Pentagon crash site to monitor air and drinking water quality and 

to collect forensic evidence for criminal investigation. EPA also 

provided personnel, equipment, and contractors to help assess or clean 

up anthrax contamination at the U.S. Postal Service, the Capitol Hill 

complex, and other government sites. Despite its 

increased responsibilities, EPA has, to its credit, also undertaken 

some major initiatives to improve the overall management of the agency 

and its resources.

These management initiatives have helped EPA make progress in 

addressing the management challenges we identified in our 2001 report. 

For example, in an effort to improve the quality of the information 

used to set priorities and measure results, EPA plans to issue the 

first-ever State of the Environment Report in early 2003, which will 

summarize available information on the condition of the nation’s 

environment and identify the remaining information needed to complete 

the picture. In addressing its human capital challenges, EPA has begun 

to develop a workforce assessment system that will identify the 

technical skills and number and type of positions required, inventory 

the skills of the current workforce, examine attrition rates, and 

forecast the number of new hires required. Finally, in an effort to 

adopt regulatory approaches that are more flexible and less 

administratively burdensome, EPA has invested considerable time and 

resources in a variety of initiatives to encourage more effective and 

cost-efficient ways of protecting the environment. However, for each of 

the management challenges we identified in 2001, more work remains to 

be done. In addition, we have identified two other challenges that EPA 

needs to address. Specifically, EPA needs to strengthen its grants 

management and improve internal controls over its financial management 

reporting. In sum, the major management challenges that EPA faces are 

as follows:

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EPA Needs to Ensure That Recent Steps to Improve Environmental 

Information Receive Sustained Top Management Support:

Information is critical to EPA’s mission of protecting the environment 

and public health. Information from scientific research, from the 

monitoring of air and water quality and other environmental parameters, 

and from epidemiological and other studies of the links between 

environmental pollutants and human health effects is needed to inform 

EPA’s policies and to assess the effectiveness of the agency’s policies 

and programs in achieving desired results. While the quality of 

environmental information and the scientific understanding of how 

environmental factors can affect ecological conditions and human health 

have improved since EPA’s inception, the pace of progress has sometimes 

been slow. Furthermore, significant gaps in environmental information 

and scientific knowledge remain. EPA has taken a number of recent 

actions to implement recommendations that we and others have made to 

enhance the quality and usefulness of the environmental information 

that it and its partners generate. These actions include adopting an 

information strategic plan that envisions managing information as a 

strategic resource, developing data standards to facilitate efficient 

reporting, aggregating and integrating environmental data, measures to 

improve information security, and initiatives to develop a 

comprehensive set of environmental indicators and use them to provide 

the public with a baseline report on the current state of 

the environment.

To ensure that these and related actions continue and achieve the 

desired results, EPA management needs to develop annual or multiyear 

action plans to translate the “vision” embodied in the strategic 

information plan into specific actions that will advance the 

achievement of the plan’s goals. Action plans would, among other 

things, establish target dates for completing specific actions and 

identifying the resources required to meet these milestones. Action 

plans could help ensure that the strategic plan becomes and remains a 

living document that informs agency decision making; guides investments 

in information infrastructure, technology, and human capital; and 

evolves over time to reflect progress, changing circumstances, and new 

imperatives. Sustained progress in enhancing the agency’s information 

management will require a long-term commitment of management attention, 

including appropriate follow-through and resource support.

Significant Gaps Remain in Environmental Data and Science:

The results of scientific research, and the information and knowledge 

gained from monitoring the environment and public health, are essential 

foundations for developing; assessing; and refining environmental 

policy, including developing measures to gauge the effectiveness of 

that policy in producing the desired outcomes. While EPA, the states, 

and other environmental partners carry out a considerable amount of 

research and collect extensive information on environmental parameters, 

significant gaps and weaknesses remain in the knowledge and 

understanding of environmental stressors and pollutants and their 

effects on ecological condition and human health. Information obtained 

from environmental monitoring is often fragmentary and of varying 

quality, information on human exposures to toxic pollutants is limited, 

and the ecological and public health effects of many environmental 

contaminants are still not well understood. As we have reported in the 

past, such gaps in the data and in scientific understanding hamper 

EPA’s efforts to (1) perform critical human exposure and risk 

assessments, (2) use risk as a basis for setting program priorities, 

(3) obtain a comprehensive understanding of environmental conditions 

and changes over time, and (4) assess the agency’s effectiveness in 

carrying out its mission of protecting the environment and 

human health.

Information on the health risk posed by exposures to toxic chemicals is 

critical to EPA’s policy decision making. However, the information 

needed to credibly assess these risks often does not exist. In a May 

2000 report on the lack of data regarding human exposures to toxic 

chemicals in the environment, we reported that exposure data were 

limited because the data were being collected nationwide for only a 

small percentage of the nearly 1,500 potentially harmful chemicals we 

reviewed.[Footnote 1] For the nearly 500 chemicals that EPA identified 

as most in need of testing under the Toxic Substances Control Act, only 

2 percent were being tested for human exposure. We recommended that the 

Secretary of Health and Human Services and the EPA Administrator 

develop a coordinated federal strategy for the monitoring and reporting 

of human exposures to potentially toxic chemicals.

Progress in this area has been slow, however, and the benefits of 

initiatives currently in the discussion or planning stages are likely 

to be years away from realization. For example, EPA’s Office of 

Research and Development is moving to establish a program addressing 

environmental public health outcomes as part of its Human Health 

Research Strategy. This Office recently held a workshop involving 

several public health agencies to help in developing a research 

framework that would be complementary to other agencies’ efforts and 

define opportunities for collaboration. Also, according to officials of 

EPA’s Office of Environmental Information, that Office worked with the 

Centers for Disease Control and Prevention in 2002 on a potential 

cross-agency initiative to develop and link environmental and human 

health information resources, specifically the Centers’ National 

Environmental Public Health Tracking Program network and EPA’s National 

Environmental Information Exchange Network. The proposed linkage holds 

the potential to enhance information technology tools to foster the 

analysis and dissemination of information obtained to a variety 

of audiences.

Important data gaps also remain in EPA’s Integrated Risk Information 

System, a database containing information on human health effects that 

may result from exposure to chemicals in the environment. Specifically, 

the database contains no basic data on the toxicity of about two-thirds 

of the known hazardous air pollutants and only limited information on 

the ecological effects of environmental pollutants. Likewise, there are 

significant data gaps and weaknesses in EPA’s National Water Quality 

Inventory, the primary report on the condition of the nation’s waters. 

The gaps result from the fact that only a small percentage of U.S. 

waters is assessed for quality and only a limited number of assessments 

are based on current, site-specific monitoring information.[Footnote 

2] Incomplete water quality data make it difficult for EPA to 

accurately describe the condition of the nation’s waters and report on 

the progress being made toward achieving established water quality 

goals. The data gaps and weaknesses are also problematic because agency 

officials rely on state-reported data in the inventory when making 

program management decisions, including determining how certain Clean 

Water Act funds will be allocated among the states.

EPA’s research on the use of biological indicators for environmental 

assessments demonstrates the importance and value of research. 

Because site-specific water quality monitoring is complex, difficult, 

and expensive, for many contaminants (including sediment, toxic 

chemicals, pathogens, and invasive species) that are potentially of 

concern, it is doubtful that many states, territories, and tribes will 

ever be able or willing to devote sufficient resources to monitor their 

streams and other water bodies adequately and on a regular basis. 

Recognizing this, EPA has conducted research on alternative 

methodologies for estimating the environmental conditions of streams, 

estuaries, and other water bodies. EPA’s Environmental Monitoring and 

Assessment Program (EMAP) has conducted studies that have established 

that the use of biological indicators that integrate chemistry, 

habitat, pathogens, and other stressors over time lead to less 

expensive approaches to monitoring the environmental conditions in 

streams and other water bodies. According to EPA, as of May 2002, 

20 states had adopted a methodology based on EMAP to determine the 

environmental condition of steams and estuaries on a regional scale. In 

addition, the agency reports that it has several initiatives under way 

for the greater application of this approach to coastal areas and 

streams in arid areas of the West and for assessing the nation’s great 


In November 2001, at the direction of its Administrator, EPA embarked 

on a major effort that holds the promise of providing, for the first 

time ever, an overall picture--albeit less than perfect and complete--

of the nation’s current environmental conditions and trends and, 

equally important, of highlighting data gaps and indicating the 

research and information collection efforts needed to fill those gaps. 

The Administrator directed EPA’s Office of Environmental Information 

and Office of Research and Development to lead an agencywide initiative 

to develop a set of indicators of environmental quality and use these 

indicators as a basis for drafting the State of the Environment Report 

to be issued in early 2003. The report is intended to serve as the 

basis for initiating a broad public discussion about the environment 

and environmental protection. As currently envisioned, it will 

(1) describe current environmental conditions and trends using existing 

data and indicators developed by EPA and others, (2) identify data gaps 

and research needs, (3) discuss challenges that government and 

other environmental partners face in filling those gaps and needs, and 

(4) be accompanied by extensive technical information and support. The 

report is to encompass five environmental theme areas: human health, 

ecological condition, clean air, pure water, and better protected land. 

Under human health, for example, the report will explore trends in 

diseases, human exposure to environmental pollutants, and diseases 

thought to be related to environmental pollution.

EPA views the draft State of the Environment Report as the starting 

point of a public dialogue on environmental protection issues and an 

important step toward a more comprehensive approach to identifying 

priorities, focusing resources on areas of greatest concern, and 

managing its work to achieve measurable results. If successful in its 

aims, this multiyear undertaking could make a substantial contribution 

not only to identifying and filling research and data gaps but also to 

measuring progress within an overall framework of ecological and human 

health, assisting EPA’s strategic-planning efforts, and facilitating a 

transition to performance-based management driven by environmental 

goals. To be successful, however, particularly in identifying and 

filling research and data gaps, this effort will require sustained 

cooperation and coordination on the part of EPA, other federal and 

state partners, academic institutions, and others. It will also require 

adequate and dependable financing, something that many people--

including advocates of strong environmental science in the Congress--

may argue has been absent until now.

EPA Has Made Progress in Overcoming Data System Weaknesses That Limit 

the Usefulness of Environmental Data, but More Needs to Be Done:

We reported in January 2001 that EPA’s data management system is 

outmoded in numerous respects, including having separately designed, 

media-specific databases that are generally not technically 

compatible.[Footnote 3] This incompatibility is a legacy of the 

historical “stove-pipe,” or single media, orientation of EPA’s programs 

and has served as a barrier to the efficient reporting, aggregation, 

and integration of data to present comprehensive information on 

pollutants, industrial sectors, localities, and environmental 

conditions and trends. Despite this historical legacy, however, EPA has 

recognized the importance of integrated environmental information and 

the need to make its databases compatible with one another and with 

those of its state and tribal partners. For example, since our January 

2001 report, the agency has made notable progress in implementing an 

initiative to standardize basic data element definitions and formats to 

permit the information contained in EPA and state and tribal databases 

to be combined to present a more comprehensive picture of environmental 

conditions and results. Agency officials also view data standardization 

as a way to reduce the reporting burden for states and industry by 

allowing more integrated data reporting and facilitating electronic 

reporting via the Internet.

Implementing a recommendation that we made in a September 1999 report, 

that the agency coordinate its data standardization efforts with the 

states, federal agencies, and other organizations, EPA and its state 

and tribal partners created the Environmental Data Standards Council to 

work cooperatively to develop consensus-based data standards.[Footnote 

4] To date, EPA and its partners on the Council have adopted and begun 

to implement seven final data standards that will foster consistently 

defined and formatted data elements and sets of data values and 

facilitate public access to more meaningful data. The data standards 

that have been finalized are:

* the date,

* the latitude/longitude,

* biological taxonomy,[Footnote 5]

* chemical identification,

* facility identification,

* permitting, and:

* the Standard Industrial Classification/North American Industrial 

Classification System.

As an example of the function and value of such data standards, the 

“chemical identification” standard provides a consistent way to 

identify and represent chemical substances across the agency. It 

provides EPA with a unique, unambiguous, common name for each chemical 

substance and chemical grouping in which the agency has an interest, 

and provides a way to reference data about chemical substances across 

EPA systems and to search for chemical entries in these systems. By the 

same token, the “facility identification” data standard provides, for 

the first time, a unique facility identification number for any 

facility subject to EPA’s regulatory authority, regardless of the media 

program(s) involved. Achieving consensus even on such a seemingly 

simple and straightforward matter was by no means an easy task. EPA 

officials told us that it was necessary to overcome broad resistance 

stemming from concerns about “big brotherism.”:

In addition to these final standards, a number of new standards are 

currently under development or envisioned by the Council and EPA action 

teams. These standards include:

* contact,

* enforcement/compliance,

* tribal identifiers,

* reporting water quality results for chemical and microbiological 


* geospatial referencing,

* the electronic reporting of environmental laboratory results,

* federal facilities identifiers, and:

* the National Pollutant Discharge Elimination System (NPDES).

The NPDES will pick up where the final permitting standard leaves off, 

by standardizing data elements related to water pollutant discharge 


Other EPA initiatives related to the effort to integrate data within 

and across agency programs and with partners and stakeholders include 

the cross-agency Information Integration Program, which is intended to 

foster the development of an information integration strategy to 

identify tools and approaches that can be used across the agency and by 

states and tribes to support improved decision making and increase 

efficiency. This program culminated in (1) the creation of the Model 

for Information Integration, which provides a framework for EPA’s 

integration efforts and establishes a vision for its target information 

architecture; (2) the development of a system of registries that serve 

as repositories for commonly used data element definitions and 

information about data (metadata); [Footnote 6] and (3) an 

Environmental Information Management System, developed by EPA’s Office 

of Research and Development, which provides descriptive information 

about various data sets; databases; documents; models; and multimedia 

projects, enabling users to identify and use the data that best meet 

their needs.

While the measures taken to date represent noteworthy progress 

toward the goal of environmental data compatibility and integration, 

EPA still has some distance to travel and important challenges to 

overcome. For the most part, the agency has focused on the 

compatibility of its data with those of state and tribal agencies 

rather than with the data of other federal agencies and nongovernmental 

organizations that share an interest in environmental protection. 

Improved collaboration between federal agencies is essential because 

(1) individual agencies have different capacities and skills that are 

complementary and lend themselves to fruitful collaboration and 

(2) separate attempts have fallen short of supporting the large efforts 

that are needed to produce high-quality, comprehensive data on 

environmental conditions and trends. In this regard, EPA’s Science 

Advisory Board, created to provide the agency with expert and impartial 

external scientific advice, recommended that EPA do more to link its 

databases with external sources. For example, the Board noted that 

“answering many health-related questions frequently requires linking 

environmental data with census, cancer, birth registry, or other data 

systems (such as water distribution maps) to determine whether there is 

a relationship between the environmental measures and health.”:

Although EPA officials do not dispute the value of linking the agency’s 

databases with those of other federal agencies and nongovernmental 

organizations, they note that efforts have been limited by resource 

constraints and a lack of statutory authority to require other agencies 

to collect and report data using formats compatible with those used by 

EPA. Acknowledging that EPA may have unduly focused on state and tribal 

partners, to the exclusion of federal agencies and others when 

composing the Environmental Data Standards Council, officials of the 

Office of Environmental Information pointed out that one of the reasons 

for publishing proposed data standards in the Federal Register for 

public comment, before making them final, is to solicit the 

participation and input of other interested and knowledgeable parties, 

including other federal agencies. They noted that another federal 

agency, the Department of the Interior’s U.S. Geological Survey (USGS), 

in conjunction with the National Water Quality Monitoring Council, was 

instrumental in proposing and initiating the development of the 

standard for Reporting Water Quality Results for Chemical and 

Microbiological Analytes. In addition, USGS has taken the lead in 

developing a geospatial data standard, an e-government initiative that 

is highly relevant to EPA and on which EPA is collaborating.

Data Limitations Still Hinder Development of Results Measures, but 

Groundwork Is Being Laid for More Effective Performance Measurement:

Well before passage of the Government Performance and Results Act of 

1993 (Results Act), a number of internal and external studies, 

including our August 1988 general management review of EPA,[Footnote 7] 

called on the agency to manage for measurable environmental results as 

a way to improve its performance and accountability. As we and others 

noted, developing effective measures of the environmental results of 

EPA’s policies and program activities would help the agency’s managers 

in assessing the extent to which the agency contributes to 

environmental improvements and in setting priorities, planning, and 

budgeting. The effective measurement of environmental results would 

also serve to make the agency more accountable to the Congress and the 

public for its performance.

The Results Act, for the first time, formally required EPA and other 

federal agencies to prepare performance plans containing annual 

performance goals and measures to help them move toward managing for 

results. Performance goals and measures were to be used to assess an 

agency’s progress toward achieving the results expected from its major 

functions. Performance goals established under the act’s requirements 

constitute target levels of performance expressed as tangible, 

measurable objectives against which actual achievement can be compared. 

Performance measures constitute the “yardsticks” to assess success in 

meeting performance goals.

Notwithstanding EPA’s timely actions to implement the Results Act’s 

procedural requirements, the agency’s progress in moving toward 

measuring the actual results of its activities has been slow. To a 

large extent, EPA’s performance goals and their associated performance 

measures continue to be expressed as outputs--environmental 

standards established, permits issued, enforcement actions taken--

rather than as end outcomes, measures that directly show how EPA’s work 

led to improvements in environmental conditions or public health. For 

example, as shown in table 1, for fiscal year 1999, 86 percent of EPA’s 

278 performance measures consisted of output measures, while only 

14 percent consisted of outcome measures. Three years later, in fiscal 

year 2002, 71 percent of the agency’s 365 performance measures 

consisted of output measures, while the percentage of outcome measures 

had moderately increased to 29 percent. For fiscal year 2003, under way 

since October 1, 2002, EPA has a total of 284 performance measures of 

which 60 percent are output measures and the remaining 40 percent, 

outcome measures.

Close examination, however, shows that only a portion of EPA’s fiscal 

year 1999, fiscal year 2002, and fiscal year 2003 outcome measures 

actually measured end outcomes, the environmental results of its 

programs and activities (7 percent of fiscal year 1999 performance 

measures, 22 percent of fiscal year 2002 performance measures, and 

27 percent of fiscal year 2003 performance measures).[Footnote 8] The 

remaining EPA outcome measures for these 3 fiscal years are more 

properly classified as measures of intermediate outcomes rather than 

end outcomes. Intermediate outcomes indicate progress or presumed 

contributions toward achieving end outcomes. They are used when end 

outcomes are not immediately clear, easily delivered, or quickly 

achieved. For example, inducing local jurisdictions to adopt higher 

water quality standards is an intermediate outcome contributing, 

presumably, to the end outcome of safe drinking water.

Table 1: Classification of EPA’s Performance Measures:

Fiscal year: 1999; Outputs: 86% (240 of 278); Intermediate outcomes: 7% 

(18 of 278); End outcomes: 7% (20 of 278); Total outcomes: 14% (38 of 


Fiscal year: 2002; Outputs: 71% (260 of 365); Intermediate outcomes: 7% 

(26 of 365); End outcomes: 22% (79 of 365); Total outcomes: 29% (105 of 


Fiscal year: 2003; Outputs: 60% (170 of 284); Intermediate outcomes: 

13% (38 of 284); End outcomes: 27% (76 of 284); Total outcomes: 40% 

(114 of 284).

[End of table]

Source: EPA.

Note: GAO’s analysis of EPA’s data.

The relatively low percentage of end outcome measures in EPA’s 

collection of performance metrics is largely a reflection of the fact 

that data and scientific knowledge essential to permit end outcome 

measurement are often lacking, as well as the fact that there is often 

a significant time lag between actions taken to protect and improve the 

environment and demonstrable effects. In addition, other factors, such 

as the level of economic activity, can have confounding effects, 

obscuring the role played by EPA programs in environmental change. The 

data/knowledge problem is one that EPA is attempting to address through 

its ongoing indicators initiative and anticipated State of the 

Environment Report. While these efforts are expected to identify 

important data gaps and point to the research needed to improve the 

scientific understanding of the environment, it may be years before 

such gaps are filled and research yields dividends of knowledge and 

scientific understanding sufficient to allow for a more reliable 

measurement of the environmental results of EPA’s program activities. 

Hence, the measurement of the environmental results of EPA’s programs 

and managing for improved performance are likely to continue to pose a 

significant challenge for the agency for some time to come.

In addition to the environmental indicators and State of the 

Environment Report initiatives, the agency has undertaken another 

related initiative that has a similar potential over the longer term to 

enhance its ability to measure and manage for environmental outcomes. 

Known as “Managing for Improved Results,” this project was launched in 

the summer of 2001 by EPA’s Deputy Administrator, who charged the 

Office of the Chief Financial Officer with the task of examining a mix 

of near-and long-term reforms to improve the agency’s ability to manage 

for results. In response to this charge, a steering group of senior 

headquarters and regional staff, reporting to the Deputy Administrator, 

was assembled to (1) examine EPA’s management practices, including 

priority setting, planning, budgeting, and performance tracking/

reporting, and (2) explore options both for significant and far-

reaching reforms as well as smaller-scale improvements. Among the more 

far-reaching recommendations that the steering group has made is the 

recommendation that the agency develop a new strategic-planning 

architecture with a new goal structure focused on a reduced number of 

environmentally focused goals, as few as 5 in number (compared with the 

current 10 strategic goals). With respect to performance measurement, 

the steering group recommended that EPA’s program offices develop 

better performance measures as part of the strategic plan’s goal 

revision process. Actions envisioned as part of this recommendation 

include (1) program offices responsible for each strategic objective 

developing multiyear plans to improve the quality and 

outcome-orientation of associated annual performance goals and annual 

performance measures, (2) national program managers and lead regions 

collaborating to improve measures, (3) goal teams ensuring that data of 

adequate quality will be available, (4) the Office of the Chief 

Financial Officer’s expansion of its consultation and technical support 

to the rest of the agency, and (5) using State of the Environment 

Report indicators to guide the development of the next improved 

generation of outcome-based performance goals and measures.

All of these initiatives aimed at improving EPA’s ability to manage for 

environmental results are, essentially, long-term in nature. They will 

require a long-term commitment of management attention, follow-through, 

and support--including the dedication of appropriate and sufficient 

resources--for their potential to be fully realized. A number of 

similar initiatives in the past have been short-lived and disappointing 

in terms of lasting contributions to improved performance management. 

Just as the forthcoming State of the Environment Report is intended to 

foster an ongoing dialogue between the agency and its partners, 

including the broader public, both the Environmental Indicators 

Initiative and the Managing for Results Initiative represent just the 

beginnings of long-term undertakings. These initiatives’ ultimate 

payoff will depend on how fully EPA’s organization and management 

support them and the extent to which needs identified--for more and 

better data; for scientific research; for a restatement of strategic 

goals; and for a refinement of performance goals, objectives, and 

measures--are addressed in a determined, systematic, and sustained 

fashion over a period of years. Even the task of revising the agency’s 

strategic goal structure and reducing the number of goals to a few 

specifically focused on environmental dimensions will not be an easy 

matter on which to achieve consensus and, once agreed upon, to 

implement. As one senior EPA official pointed out, this is particularly 

true when, as in EPA’s case, budgeting is tied to the agency’s 

goal structure.

Significant Progress Made in Enhancing EPA’s Information Security:

The security of EPA’s information is critical to its mission of 

protecting human health and the environment, a fact underscored by the 

events of September 11, 2001, and their aftermath. Much of the 

sensitive information contained in EPA’s databases regarding 

environmental infrastructure, such as municipal drinking water systems 

and the location of stores of toxic chemicals, could be expected to 

hold great interest for would-be terrorists and others with criminal 

intent. In a review of EPA’s information security program issued in 

July 2000, we found serious and pervasive problems that “essentially 

rendered [the program] ineffective.”[Footnote 9] Our report 

characterized the agency’s security practices at the time as weak and 

largely a paper exercise that did little to mitigate risks to the 

agency’s data and systems. We recommended that EPA take a number of 

steps to improve security program management and planning, enhance 

computer incident management, and strengthen access controls associated 

with its major computer operating systems and agencywide network.

Since the issuance of our report, EPA and the agency’s Office of 

Inspector General reported that the agency has made substantial 

improvements to its information security program. The agency has 

improved its risk assessment and planning processes, implemented major 

new technical and procedural controls, issued new policies, initiated a 

regular process of testing and evaluation, and devoted significant 

attention and resources to improving the technical information 

infrastructure and building the management framework for an effective 

security program, as documented by EPA’s Office of Inspector General in 

September 2002 and by an August 2002 GAO follow-up on the status of 

agency efforts to implement the recommendations in our July 2000 

report. Under the leadership of the Office of Environmental Information 

(OEI), the agency has been taking steps to ensure appropriate public 

access to the information in EPA’s computer systems, while protecting 

the confidentiality and integrity of its information. According to EPA 

and the agency’s Office of Inspector General, specific actions taken to 

improve information security and to address problems that we, the 

Inspector General, and others have cited, include the following:

* Developing the Information Security Action Plan to guide EPA’s 

revised security program and respond to the findings and 

recommendations of our July 2000 report.

* Establishing the Technical Information Security Staff, within OEI, to 

review EPA’s security accomplishments, manage the agency’s security 

efforts, and evaluate needs for future security governance.

* Designating program and regional Information Security Officers, 

who are responsible for coordinating security activities, providing 

guidance, reviewing security practices, and informing colleagues of 

their information security responsibilities.

* Defining, in consultation with EPA’s state and tribal partners, 

levels of security that must be met for the exchange of information 

across the National Environmental Information Exchange Network. These 

levels range from Level 1 (public information, available to all users 

without authentication) to Level 4 (information requiring the highest 

levels of proof of the integrity and origin of data, along with 

confidentiality and third-party verification).

In an August 2002 follow-up on the status of EPA’s efforts to address 

our July 2000 report’s recommendations, we concluded that although 

some work remained to be completed to address the problems cited in 

the report, EPA had made sufficient progress to justify closing out the 

recommendations. However, notwithstanding the progress EPA has made in 

this area, EPA’s Inspector General continues to identify EPA’s security 

program management as a management challenge (albeit of a lower order 

than in years past). As the Inspector General has noted, the dynamic 

nature of security threats will require continued attention and 

vigilance on the part of EPA management. The agency, moreover, will 

need to strive to build and maintain a strong centralized security 

program with an oversight process that identifies and adequately 

addresses vulnerabilities and to ensure that information resources and 

environmental data are secure. Given the agency’s decentralized 

organizational structure, it is essential for the success of EPA’s 

information security program that OEI exercise a strong leadership and 

monitoring role. A major continuing challenge will be to provide the 

public with access to a wide range of environmental information, while 

also protecting against the use of this information in ways that could 

harm the environment or public health and safety.

EPA’s Recently Completed Information Strategy Needs to Be Implemented 

Systematically and Revised Periodically in Light of Progress and 

Changing Circumstances:

In a September 1999 report, we recommended that EPA develop a 

comprehensive information management strategy that would (1) establish 

milestones and identify the resources needed to fill key data gaps; 

(2) identify and develop necessary data standards; and (3) coordinate 

its data standardization efforts with other federal agencies, the 

states, and other entities.[Footnote 10] In our January 2001 report on 

EPA’s major management challenges and program risks, we reported that, 

beyond agreeing with our 1999 recommendation, EPA had made limited 

progress in developing a comprehensive information management strategy 

to ensure the completeness, compatibility, and accuracy 

of data.[Footnote 11]

In July 2002, EPA issued its “Strategic Information Plan: A Framework 

for the Future,” which largely responds to our 1999 recommendation. The 

plan, developed by EPA’s Office of Environmental Information, under the 

direction of the Chief Information Officer, sets a new vision for EPA’s 

information management, which is to provide government and citizens 

with fast, relevant, and integrated information about environmental and 

public health conditions, trends, and potential threats. The plan 

envisions establishing a system that advances the creation, management, 

and use of information as a strategic resource at EPA and stresses the 

need to streamline and strengthen the agency’s information management 

infrastructure to improve the effectiveness and efficiency of its 

operations and programs. The plan sets six specific information 

management goals for the agency: (1) improve the use of environmental 

information, (2) collect appropriate data, (3) strengthen EPA’s 

information infrastructure, (4) enhance access to information, 

(5) adopt an agencywide approach to using information to make 

management decisions, and (6) invest in human capital for 

information management.

EPA’s Information Plan provides a much needed long-term strategic 

vision for the information management function. It charts the course 

the agency will need to pursue in coming years, in consultation and 

collaboration with its state and tribal partners and other key 

stakeholders, to design and implement systems and services that are 

aimed at streamlining data collection, making the Internet the method 

of choice for reporting and exchanging information, and making more 

effective use of the information it collects.

As previously noted, a number of initiatives are already under way 

within the agency to implement aspects of the goals laid out in the 

strategic plan, including data quality improvement, the development and 

implementation of data standards, and building networks for data 

exchange. Missing in EPA’s strategic information plan, however, are 

indications of priorities, milestones, and estimated resource 

requirements that could drive forward movement and provide a more 

detailed road map for goal implementation. We recommended such an 

“action plan” in our September 1999 report and continue to believe that 

an annual or multiyear action plan is needed to translate the “vision” 

embodied in the strategic plan into specific actions that will advance 

goal achievement. An action plan would lay out in some detail and 

specificity the discrete goal-related measures that will be taken 

during the planning period. It would also establish target dates for 

the completion of action and identify resources required to meet these 

milestones. Action plans, we believe, could ensure that EPA’s strategic 

plan becomes and remains a living document that informs agency 

decision making; guides investments in information infrastructure, 

technology, and human capital; and evolves over time to reflect 

achievements, changed circumstances, and new imperatives.

EPA Needs to Implement a Systematic and Comprehensive Human Capital 


High-performing organizations in the private and public sectors have 

long understood the relationship between effective “people management” 

and organizational success. An organization’s people--its human 

capital--are its most critical asset in managing for results. EPA, like 

many other federal agencies, has historically given insufficient 

attention to strategically managing its human capital. As a result, EPA 

faces critical agencywide human capital challenges that, if not 

addressed, will limit its ability to achieve its mission. Specifically, 

the agency has yet to determine the number of employees it needs to 

accomplish its mission objectives, the technical skills required, and 

how to best allocate employees among EPA’s strategic goals and 

geographic locations. Furthermore, with a substantial portion of its 

workforce nearing retirement age, it is imperative that EPA fully 

prepare for the resulting loss of leadership, institutional knowledge, 

and scientific expertise.

To its credit, EPA has taken some steps in recent years to improve its 

human capital management. The agency has conducted a workforce study 

that identifies some of the general skills and abilities that EPA 

employees need. Furthermore, the agency has developed a human capital 

strategy that identifies EPA’s vision for its people, its core values, 

and its major human capital goals. However, EPA is far from being able 

to implement a systematic and comprehensive human capital approach that 

will enable the efficient and effective achievement of its mission 

objectives. Specifically, EPA needs to (1) develop a system for 

determining the number of employees and skills required to meet its 

mission objectives and allocating staff according to identified mission 

needs and (2) recruit, train, and develop employees to ensure that EPA 

will have the leadership, institutional knowledge, and scientific 

expertise needed to accomplish its mission, both now and in the future.

EPA Needs to Assess Workforce Requirements and Allocate Staff to 

Accomplish Mission Objectives:

High-performing organizations identify their current and future human 

capital needs, including the appropriate number of employees, the key 

skills required for mission accomplishment, and the appropriate 

deployment of staff across the organization. They then identify and 

address any human capital gaps or surpluses. However, EPA, like many 

other federal agencies, has yet to determine its current or future 

human capital needs for accomplishing its mission or to fully inventory 

the skills in the current EPA workforce. EPA’s 1999 workforce study 

identified general skills needed by EPA employees (such as effective 

communication and collaboration) but did not identify the scientific or 

technical skills critical to EPA’s mission. Nor did the study address 

the number of staff or the skills EPA needs agencywide and by 

geographic location. In response to a 2001 Office of Management and 

Budget (OMB) request, EPA, along with other federal agencies, prepared 

a workforce analysis that included information on the number of its 

supervisors and managers, their grade level, their location, and the 

number of people they oversee, and an evaluation of the skills of the 

workforce. However, because EPA has not yet comprehensively assessed 

its workforce, EPA’s human resource managers told us that the analysis 

that it submitted to OMB is only a starting point for a systematic 

workforce analysis.

Without reliable and valid workforce information, EPA cannot ensure 

that it is hiring the right number and type of people or allocating 

existing staff resources to effectively meet current or future mission 

needs. During the past 12 years, when the size of the civilian federal 

workforce was reduced significantly, EPA increased its workforce from 

15,277 in fiscal year 1990 to 17,802 in fiscal year 2002. In doing so, 

EPA hired thousands of employees without systematically considering the 

workforce impact of the changes in environmental laws and regulations, 

the technological advances, or the expansion in state environmental 

staff that occurred during the 1990s. Similarly, EPA has yet to factor 

these workforce changes into its allocation of existing staff resources 

to its headquarters and regional offices to meet its strategic goals. 

Furthermore, if EPA should need to downsize, as other federal agencies 

have done, it would not have the information needed to ensure that 

staff reductions could be absorbed with minimal impacts on mission 

objectives. For example, the Congress denied EPA’s proposal to downsize 

its enforcement staff in order to shift resources to state enforcement 

grants because EPA had no workforce information to demonstrate that 

staff reductions would not jeopardize environmental enforcement.

In July 2001, we recommended that EPA develop a system for workforce 

allocation and deployment that is explicitly linked to the agency’s 

strategic-planning efforts and is based on the systematic efforts of 

each major program office to accurately identify the size of the 

workforce, the deployment of staff geographically and organizationally, 

and the skills needed to support EPA’s strategic goals.[Footnote 12] 

EPA has begun to develop a system, known as the “national strategic 

workforce planning system,” that may substantially implement this 

recommendation. The system is to be used by EPA regions and in 

headquarters offices to assess workforce needs. According to EPA, the 

system will, among other things, identify the technical skills and the 

number and type of positions required, inventory the skills of the 

current workforce, examine attrition rates, and forecast the number of 

new hires required. EPA issued a methodology for the workforce-planning 

system in September 2002 and has begun implementing the system in 

several headquarters offices and in the Chicago, Kansas City, and 

Seattle regional offices. EPA expects agencywide implementation of the 

workforce-planning system to be under way by late 2003.

Although EPA’s proposed workforce-planning system appears promising, it 

is too early to determine how it will affect EPA’s ability to 

systematically allocate staff. As EPA’s Deputy Assistant Administrator, 

Office of Administration and Resources Management, acknowledged, EPA 

has made progress in workforce planning, but the most difficult 

challenges remain--such as using workforce data to make difficult 

staffing decisions. For example, EPA’s workforce planning will need to 

take into account the agency’s extensive use of grants to states and 

awards to contractors to perform EPA’s work. The agency estimates that 

its contracted work alone would require an additional 11,000 to 15,000 

employees if contractors were not used. Thus, EPA must plan for a 

workforce that is adept at both delivering services directly and 

managing the cost and quality of services delivered by third parties on 

the government’s behalf. In addition, EPA must work diligently and 

effectively to gain support for its workforce-planning efforts within 

both the executive and legislative branches.

Moreover, EPA’s workforce-planning system, along with the agency’s 

other human capital efforts, will need to incorporate the implications 

of major management initiatives. Specifically, EPA has undertaken a 

comprehensive effort to assess the state of the environment, identify 

priorities for environmental and human health improvements, and focus 

its resources on achieving results in the areas of greatest concern. 

EPA is currently working to integrate its “state of the environment” 

effort into its agencywide strategic plan. According to EPA officials, 

the revised strategic plan will largely determine EPA’s workforce 

needs, and workforce allocation will be tied to the relative priority 

assigned to strategic goals. Once the strategic plan is finalized 

(expected in late 2003), EPA will then need to determine its impact on 

the agency’s human capital resources and systems.

EPA Needs to Ensure Continuity of Leadership and Mission-Critical 


To ensure a continuing ability to accomplish their mission objectives, 

federal agencies need to aggressively pursue comprehensive succession 

planning and executive development to address the loss of leadership 

and institutional knowledge that will result from Senior Executive 

Service (SES) retirements. At EPA, 162 senior executives, or 

60 percent, will become eligible for retirement in the next 5 years. As 

shown in figure 1, potential retirements may create particularly severe 

leadership shortages in some EPA units and regions, such as region 7 

(Kansas City) and region 10 (Seattle), where about 86 percent of the 

executives will become eligible to retire over the next 5 years.

Figure 1: Percentage of Total SES Staff Eligible to Retire by 2008, by 

EPA Unit/Region:

[See PDF for image]

[End of figure]

Note: GAO’s analysis of EPA’s data.

We reported in July 2001 that EPA did not have succession planning in 

place to ensure continuity in the agency’s leadership and to prepare 

for the management losses that would likely occur, as many executives 

become eligible for retirement.[Footnote 13] We recommended that EPA 

work toward designing succession plans to maintain leadership 

continuity that are based on (1) a review of current and emerging 

leadership needs and (2) identifying sources of executive talent within 

and outside EPA. In response, EPA reinstated a development program for 

SES candidates, which is expected to prepare 51 candidates for 

leadership positions. According to EPA, a number of these candidates 

may be ready in the summer of 2003 for Office of Personnel Management 

certification as senior executives. In addition, EPA has implemented a 

management training program for new and current mid-level supervisors. 

However, it remains to be seen how successful these programs will be in 

developing the executive resources that the agency needs. EPA 

implemented the management development programs before assessing how 

revising its strategic objectives would affect its current and emergent 

leadership needs. Therefore, EPA may need to modify these programs once 

its strategic plan is finalized.

EPA also faces challenges in sustaining adequate scientific expertise 

to carry out its mission. EPA acknowledges that its efforts to protect 

human health and the environment must be based on the best available 

science. However, EPA’s scientific performance has been criticized many 

times in reports by the National Research Council, EPA’s Science 

Advisory Board, and GAO, among other organizations, and in countless 

complaints and lawsuits from stakeholders. In the National Research 

Council’s opinion, the concerns about EPA’s scientific performance are 

related to the agency’s ability to attract and retain first-rate 

scientific talent, given intense job market competition from the 

private sector and academic institutions. EPA’s challenge to maintain 

adequate scientific expertise could intensify in the coming years, as 

many agency scientists become eligible for retirement. As shown in 

figure 2, a significant portion of EPA’s key scientific and technical 

staff--environmental protection specialists, biological scientists, 

ecologists, toxicologists, environmental engineers, physical 

scientists, and health physicists--will become eligible for retirement 

by the end of 2008.

Figure 2: Percentage of EPA Staff in Key Scientific/Technical 

Occupations Eligible for Retirement by 2008:

[See PDF for image]

[End of figure]

Note: GAO’s analysis of EPA’s data.

EPA can fill the gaps in scientific expertise that may arise from these 

retirements through targeted recruitment efforts to hire “outside” 

expertise and by training current staff to develop the needed 

expertise. To improve its ability to recruit highly qualified 

scientists, EPA is considering the use of special hiring authority 

modeled on a National Institutes of Health program to select and retain 

senior scientists. Under this special authority, EPA would establish 

competitive, limited-term (although renewable) appointments for 

research scientists and engineers. The agency believes that the special 

authority would increase EPA’s flexibility to respond to emerging 

environmental problems, establish a performance-based career path for 

scientists, and reward scientific staff working on high-priority 

environmental research. While such special authority might hold 

promise, EPA officials acknowledge that the initiative is still in the 

developmental stage. Therefore, it is too early to say how well the 

proposed personnel authority would help EPA select and retain highly 

qualified scientists. In addition to recruiting outside scientific 

talent, EPA also needs to help current employees upgrade their 

scientific expertise through internal or external training 

opportunities. Thus far, however, EPA’s strategy for developing its 

workforce has aimed to enhance general competencies, such as 

communication and collaboration, rather than specific mission-critical 

scientific or technical skills.

EPA and State Efforts to Implement Innovative Regulatory Approaches May 

Need Legislative Support:

For some time now, EPA has been counting on its efforts to “reinvent” 

environmental regulation to improve the efficiency and effectiveness 

with which the agency and the states carry out their environmental 

responsibilities. A key agency assumption has been that considerable 

innovation can take place within the existing statutory environmental 

framework. However, our work shows that limited progress in regulatory 

innovation has been made to date, and that statutory constraints have 

served as a major barrier. Although EPA has recently made vague 

references to the impetus that statutory revisions could provide to 

regulatory innovation, the agency needs to more clearly state the 

legislative changes it would endorse to overcome constraints 

to innovation.

EPA Has Tried a Variety of Initiatives to “Reinvent” Environmental 


Under the existing federal approach to environmental protection, EPA, 

pursuant to statutes such as the Clean Air Act and Clean Water Act, 

prescribes regulations with which states, localities, and private 

companies must comply. But this approach has often been criticized in 

recent years for being costly, inflexible, and ineffective in 

addressing some of the nation’s most pressing environmental problems. 

For example, the National Academy of Public Administration recently 

reported that although traditional regulatory approaches manage to keep 

most forms of industrial pollution in check, they are too narrow in 

scope to affect many other more difficult problems and sources of 

pollution or environmental degradation, such as diffuse sources of 

water pollution caused by urban and agricultural runoff. Moreover, even 

where existing approaches have succeeded in curtailing pollution from 

major industrial sources, they have often been costly and have provided 

regulated entities with little incentive to reduce pollution below 

mandatory compliance levels.

EPA responded to such concerns during the 1990s with a variety of 

initiatives intended to encourage innovative regulatory strategies that 

could streamline environmental requirements while encouraging more 

effective means of protecting the environment. Among the agency’s 

“flagship” programs was Project XL, which encouraged individual 

regulated facilities to propose projects that EPA would test to 

determine whether alternative approaches could achieve compliance at 

lower cost and produce greater environmental benefits. In addition to 

pursuing a number of other “high-priority actions” and a number of 

“other significant actions” to encourage innovation, EPA stressed that 

the agency’s overall support for the reinvention effort was part of an 

effort to transform the agency’s culture to encourage staff to think 

about and embrace innovative approaches to environmental regulation.

EPA’s “reinvention” efforts of the 1990s encountered a number of 

problems both within and outside the agency. These problems illustrated 

issues that needed to be resolved in order for environmental regulation 

to truly be “reinvented.” Specific examples follow:

* Key stakeholders in the reinvention process expressed concern over 

the large number of complex and demanding initiatives under way--as 

well as confusion over the underlying purpose of some of the agency’s 

major initiatives.

* EPA had difficulty in achieving “buy-in” among the agency’s rank and 

file, who were accustomed to the long-standing regulatory structure.

* EPA had difficulty in achieving agreement among external stakeholders 

(including federal and state regulators and representatives of industry 

and environmental organizations) in a number of its reinvention 

efforts, particularly when stakeholders perceived that unanimous 

agreement was required before progress could be made.

* EPA had a mixed record in evaluating the success of many of its 

initiatives and was therefore unable to provide convincing evidence 

to external stakeholders of the merits of pursuing an alternative 

regulatory strategy.

Of perhaps greatest significance, much of the regulated community--

whose participation is crucial for reinvention to succeed--expressed 

strong reservations about the prospects for reinvention within the 

current statutory framework. In fact, a study by Resources for the 

Future concluded that “industry participants in reinvention programs 

generally steer the programs to peripheral matters because their 

counsels general caution them against taking any action that might 

result in litigation.”[Footnote 14] Similarly, several of our studies 

found that states’ experimentation with pollutant trading and other 

innovative environmental strategies was often constrained by the 

statutory framework.[Footnote 15]

Recent GAO Findings Confirm Limitations on Ability to Innovate under 

Current Statutory Framework:

In January 2002, we issued a report that cast doubt on EPA’s ability to 

achieve significant innovation in the absence of legislative 

changes.[Footnote 16] The report contained detailed analyses of 20 

initiatives that 15 states cited as being among the key initiatives 

they had pursued. Specifically, we asked state environmental officials 

to rank, in order, the most serious obstacles that had impeded progress 

in pursuing these initiatives successfully. Among the most serious 

impediments identified were federal regulations governing the 

implementation of specific programs (ranked first or second in 12 of 

the 20 cases).[Footnote 17] EPA has long maintained that it could 

address these kinds of impediments through informal mechanisms and 

administrative actions. However, our report countered this claim, 

noting that EPA’s ability to inject flexibility into its regulatory 

programs was limited without clear statutory authorization. 

Specifically, we concluded that current legislation does not contain 

explicit language authorizing the use of innovative environmental 

approaches in lieu of specific regulatory requirements, and the absence 

of this “safe legal harbor” for EPA has been a significant obstacle to 

states and others in their efforts to test innovative proposals. The 

absence of this “safe harbor” has also tended to reinforce the cultural 

resistance to innovation that EPA is seeking to change.

EPA’s key initiatives have achieved varied success, further 

underscoring questions about how well EPA’s reinvention efforts will 

fare without some kind of legislative support. For example, through the 

end of 2000, the agency had invested considerable time and resources in 

pursuing innovations under Project XL. The Administrator had set and 

achieved the goal of signing agreements for at least 50 XL projects by 

the end of that year. However, no new projects have been initiated, and 

EPA reinvention officials indicated recently that the program is now 

changing focus dramatically. Ongoing projects will continue, but any 

new projects will need to meet a more selective test of being “bigger, 

bolder, and more strategic.” EPA officials cited Massachusetts’ 

Environmental Results Program as an example of a project meeting this 

test because the underlying concepts apply broadly to a number of 

facilities, as opposed to the single-facility focus of many past 

XL projects.

EPA has recently taken steps to make its innovation efforts more 

systematic and organized. In April 2002, the Administrator released a 

new innovation strategy to help the agency strengthen innovation 

partnerships with states, focus innovation on priority issues, 

diversify environmental approaches, and foster a more innovative EPA 

culture.[Footnote 18] To support the implementation of the strategy, 

EPA has launched a pilot grant program to fund state innovations that 

address the environmental priorities identified in the strategy. EPA 

also plans to form the National Center for Environmental Innovation to 

support implementation of its strategy, provide leadership on 

environmental innovation, and manage key innovation programs. To help 

assess the results of its efforts, EPA staff are tracking innovations 

and reporting on them quarterly to agency management.

EPA’s latest approach to bolstering environmental innovation is 

understandable, given the fundamental barriers to broader regulatory 

experimentation posed by the current statutory framework. However, 

unless these statutory barriers are addressed more directly, it remains 

to be seen whether EPA’s recent efforts to promote innovation will fare 

much better than its past efforts. EPA’s innovation strategy hints at 

some kind of statutory encouragement of regulatory innovation, noting 

that the agency plans to “engage in dialogue with parties that are 

interested in applying the flexibility and multimedia dimensions of 

these and other innovation programs more broadly through new 

legislative authority.” Such cryptic endorsement of legislative change 

appears to be a small step in the right direction, but alone, it will 

do little to encourage states and the regulated community to 

participate actively in innovative projects. Nor will it provide 

tangible assurances for the environmental community and other interest 

groups that such projects can proceed without damaging the environment. 

EPA needs to exert leadership in this area by articulating a clearer 

and more specific endorsement of legislation that would more directly 

address the root cause of the problems that have, for so many years, 

impeded its regulatory reinvention efforts.

EPA Needs to Improve Its Grants Management to Better Achieve Its 

Mission Objectives:

Effective grants management is essential for any federal agency that 

uses grants as a vehicle to commit taxpayer money toward achieving 

public purposes. Effective grants management is of particular 

importance for EPA because it typically spends about half of its annual 

budget on grants. In fiscal year 2002, EPA expended about $4 billion of 

its $7.8 billion budget[Footnote 19] on grants, which it distributed to 

over 3,300 recipients, including state and local governments, tribes, 

universities, and nonprofit organizations. EPA awards grants to support 

its ongoing programs--such as hazardous waste cleanup and wastewater 

treatment--as well as to fund discretionary short-term projects--such 

as training and outreach. The wide diversity of grant recipients and 

wide range of activities that EPA grants support present the agency 

with a formidable challenge to ensure that all awarded grants are used 

to achieve the agency’s overall mission of protecting human health and 

the environment.

For many years, our reports and numerous other internal and external 

agency management studies have called for EPA to manage its resources 

to achieve environmental results. With such a high percentage of its 

resources devoted to grants, the agency’s ability to manage for results 

largely depends on how well it manages its grants. However, in many 

cases, EPA has not managed its grants so that they are effectively used 

to achieve environmental results. EPA’s project grants have often been 

awarded without a clear plan for how the project will help achieve 

EPA’s mission or produce tangible environmental benefits. Furthermore, 

after years of improvement initiatives, EPA still struggles to 

efficiently and effectively administer its grant process to ensure that 

available resources deliver the maximum effect.

EPA Needs to Better Plan and Measure Grant Results:

To help federal agencies more effectively use their resources to 

achieve results, the Government Performance and Results Act of 1993 

requires federal agencies to prepare strategic plans and goals and to 

devise measures to gauge progress toward these stated objectives. Since 

submitting its first strategic plan to the Congress in 1997, EPA has 

continued to refine its plans, goals, and performance measures to help 

it focus agency resources on environmental results. However, EPA’s 

planning and performance measurement for project grants has often been 

disconnected from EPA’s efforts to manage for an improved environment, 

as shown below:

* EPA selects project grants before considering how the projects would 

contribute to achieving the agency’s strategic goals. In 2001, we 

reported that EPA program officials treated EPA’s strategic goals and 

objectives not as a tool to guide the selection of project grants, but 

rather as a clerical tool for categorizing grants after the funds were 

already awarded.[Footnote 20] By assessing the relevance of these 

grants to EPA’s strategic plan after the selection process, EPA cannot 

ensure that it is selecting the projects that will best help the agency 

accomplish its mission.

* EPA often does not require grantees to submit work plans to explain 

how a project would achieve measurable environmental results. In 2002, 

EPA’s Inspector General reported that EPA approved grantee work plans 

without determining the projects’ long-term human health and 

environmental outcomes.[Footnote 21] Instead, EPA funded grants on the 

basis of work plans that focused on short-term, procedural results, 

such as meetings or conferences.

* EPA often does not measure what results are being achieved with 

grants. We reported in September 2000 that EPA did not have criteria 

to measure the effectiveness of its Science to Achieve Results grant 

program.[Footnote 22] Instead, EPA’s management of the program focused 

on the procedures and processes of awarding grants. As a result, EPA 

was uncertain about what the program was achieving. Similarly, the EPA 

Inspector General reported in 2002 that, in many cases, EPA had not 

measured whether the grants it had awarded were achieving meaningful 

environmental benefits.[Footnote 23] In fact, for almost half of the 

42 grants reviewed, EPA did not even attempt to measure the projects’ 

outcomes. In some cases, the Inspector General concluded that what the 

grant funding had accomplished was unknown or unclear.

EPA has acknowledged that its planning and performance measurement for 

grants need to better focus on environmental results, and has promised 

to take corrective action. EPA has recently announced that it will 

upgrade its training for project officers and managers to emphasize the 

importance of planning grants to achieve environmental results. EPA has 

also announced that it will issue guidance to help ensure that all 

grant work plans include a discussion of how grantees plan to measure 

and report on environmental progress. However, the agency has also 

expressed reservations about the extent to which grant projects can be 

planned to achieve environmental results. The Assistant Administrator 

for EPA’s Office of Administration and Resources Management stated that 

the Paperwork Reduction Act and OMB regulations may affect EPA’s 

ability to request that recipients collect information to measure the 

results of EPA-funded activities. The Assistant Administrator also 

stated that the limitations that currently exist in environmental 

outcome measurement could affect the agency’s ability to measure the 

results of funded projects.

Planning for grants to achieve environmental results--and measuring 

those results--is a difficult challenge, especially for projects such 

as outreach or training. However, in view of the fact that EPA spends 

about half of its budget on grants, it is imperative that EPA 

wholeheartedly accept this challenge. Certain EPA-funded projects have 

already demonstrated that outcome-based grant planning and measurement 

are possible. For example, in seeking funding for outreach to local 

building code officials about indoor air quality issues, a nonprofit 

organization designed a grant project to deliver tangible environmental 

results. That is, the project measured results in terms of actions that 

affect human health--in this case, the construction of homes that 

resist the release of radon into the indoor air. Regarding the 

Assistant Administrator’s concerns about the state of environmental 

outcome measurement, it should be noted that EPA’s Office of 

Environmental Information and Office of Research and Development are 

currently collaborating on developing a new generation of outcome-based 

goals and measures using environmental indicators to help improve 

performance measurement. As EPA improves its planning and measuring of 

environmental results, it is important that the agency fully integrate 

these improvements into its grants planning and performance management.

EPA Needs to Better Administer Grant Resources to Maximize Results:

Along with improved planning and performance measurement for grants, 

EPA also needs to improve its stewardship of grant funding to maximize 

the impact of available resources. The effective management and 

oversight of grants helps ensure that the agency funds the best 

projects at the least cost, that grant money is properly used to 

accomplish the intended results, and that funded projects are completed 

in a timely manner. Historically, EPA has experienced various problems 

in grants management and oversight, and these problems have persisted 

in recent years, as shown below:

* EPA has not ensured that it obtains the best price through 

competition for project grants. EPA’s Inspector General reported in 

2001 that EPA officials gave grants to the same recipients year after 

year without competition or selected certain grantees without 

competition on the basis of the undocumented belief that the grantee 

was “uniquely qualified.”[Footnote 24] In 2002, the Inspector General 

reported that grant recipients, in turn, awarded contracts for EPA-

funded work without determining the reasonableness of the contractor’s 

price, instead selecting contractors on the basis of familiarity or in 

some cases awarding contracts to their own subsidiaries 

without competition.[Footnote 25]

* EPA has not provided effective oversight to ensure that grant funds 

are used only for allowable purposes. In 2001, we reported that EPA’s 

oversight of nonprofit grantees was not sufficiently rigorous to 

uncover expenditures for unallowable costs.[Footnote 26] Specifically, 

we found that EPA conducted oversight reviews of only 4 percent of its 

nonprofit grantees and that these reviews were not designed to identify 

unallowable costs.

* EPA has sometimes not ensured that its grantees have proper financial 

and internal controls in place to ensure that federal funds are 

properly used. For example, the EPA Inspector General found that one 

grantee could not adequately account for over half of its $300,000 in 

EPA grant funding. Another grantee submitted multiple financial status 

reports showing conflicting ending balances for its grant funding.

* EPA has often not ensured that grant projects are completed in a 

timely manner. In September 2000, we reported that EPA had not tracked 

its Science to Achieve Results research grants to ensure their on-time 

completion.[Footnote 27] We found that 144 of the nearly 200 grantees 

reviewed had missed their deadline for submitting final reports, even 

after extensions had been granted.

* EPA does not have an automated data system that it can rely upon to 

provide consistent and accurate information to support grants 

management. EPA’s system does not generate reports needed to 

effectively monitor grants, and individual grantees do not always have 

unique identifiers in the system but may appear under multiple names or 

identification numbers.

EPA has recently taken various actions intended to improve its 

management and oversight of the grants it awards, such as (1) issuing 

an order to require competition in the award of many grants and to 

require detailed justifications for noncompetitive awards; 

(2) conducting training sessions about competitive procurement 

requirements for grant recipients and EPA personnel; (3) revising 

agency policy to require EPA staff to conduct more on-site reviews of 

grant recipients and to check for unallowable costs in grantee 

spending; (4) developing a new data system to better track funding 

amounts, project milestones, and agency oversight activities; and 

(5) developing a long-term strategic plan for grants management that is 

intended to improve accountability, coordination, and resource 

management for EPA grants.

Although these actions appear promising, EPA has a long history of 

undertaking initiatives to improve grants administration, and, despite 

years of corrective actions, problems persist. The EPA Inspector 

General recently concluded that some agency actions to address grant 

weaknesses have not been effective, and in May 2002 recommended that 

EPA designate grants management as a material weakness under the 

Federal Managers’ Financial Integrity Act. OMB also recommended that 

EPA identify grants management as a material weakness. OMB believes 

that a strong grants competition policy, along with improved 

prioritization, oversight, and enforcement procedures, is needed to 

improve EPA’s grants management and will ultimately lead to better 

environmental outcomes.

Notwithstanding the Inspector General’s and OMB’s recommendations, in 

November 2002, the Administrator concurred with the recommendations 

of EPA senior managers not to declare the agency’s grants management to 

be a material weakness under the Integrity Act. The agency justified 

its decision on the basis of the policies it had recently issued to 

improve competition in awarding grants and to strengthen the agency’s 

monitoring of grant recipients. EPA does, however, consider grants 

management to be an “agency level” weakness under the Integrity Act--a 

weakness that does not merit the attention of the President or Congress 

but is significant enough to require regular reporting to the 

Administrator. While EPA’s classification of grants management under 

the Integrity Act may be the subject of debate, it is clear that 

improving grants management must be a top priority for the agency. With 

about half of EPA’s budget devoted to grants, the agency’s ability to 

efficiently and effectively accomplish its mission largely depends on 

how well it manages its grant resources.

EPA Needs to Improve Internal Controls over Its Financial Reporting:

EPA’s Inspector General issued an unqualified opinion on EPA’s 

consolidated financial statements for the fiscal year ended 2001. 

However, when it considered internal controls over financial reporting, 

the Inspector General identified three reportable conditions that could 

adversely affect the agency’s ability to process, summarize, and report 

financial statement data. Additionally, in its assessment of compliance 

with laws and regulations that relate to financial statement reporting, 

the Inspector General identified two instances of noncompliance, only 

one of which was substantial. While noteworthy, neither instance of 

noncompliance would result in material misstatements to the audited 

financial statements.

EPA had three reportable conditions in fiscal year 2001. The first was 

its failure to implement Statement of Federal Financial Accounting 

Standard (SFFAS) No. 10, Accounting for Internal Use Software, until 

the end of fiscal year 2001, even though the standard was applicable 

for the entire fiscal year. SFFAS No. 10 requires the capitalization of 

the full cost (direct and indirect) of internal use software whether it 

is commercial off-the-shelf, contractor developed, or internally 

developed. In addition, some of the supporting documentation used to 

identify capitalized software cost was insufficient to determine 

whether such costs exceeded the capitalization threshold. Because EPA 

issued guidance at the end of fiscal year 2001 for capitalizing 

internally developed software, the Inspector General did not believe a 

recommendation was warranted.

The second reportable condition concerned the interagency agreement 

invoice (IAG) approval process. EPA project officers did not fulfill 

oversight duties related to reviewing and approving interagency 

agreement invoices. The Inspector General has continued to find 

instances where program offices did not receive support for IAG 

invoices paid, did not promptly approve payable IAG invoices, or did 

not identify the proper account to be charged. EPA agreed with the 

Inspector General’s findings and, according to the agency’s management, 

EPA has implemented an automated project officer approval system that 

addresses this finding.

The third reportable condition dealt with automated application 

processing controls for EPA’s Integrated Financial Management System 

(IFMS). The lack of system documentation made it impossible to assess 

the adequacy of the automated internal control structure as it related 

to automated input, processing, and output controls for the IFMS 

system. The Inspector General found that EPA has taken tangible steps 

to replace the IFMS with the Financial Replacement System (FinRS) 

project. However, the Inspector General will not be able to 

sufficiently assess the adequacy of the automated internal control 

structure until the new system is in place.

The Inspector General’s tests of compliance with the Federal Financial 

Management Improvement Act of 1996 disclosed an instance where EPA’s 

financial management systems did not substantially comply with SFFAS 

No. 4, Managerial Cost Accounting Concepts and Standards for the 

Federal Government. Specifically, EPA did not comply with the 

requirements to provide cost per output to management in a timely 

fashion. In addition, under EPA’s current cost-accounting structure, 

when costs by output are produced, such costs are not described in 

sufficient detail to be useful to managers. EPA took exception to these 

Inspector General findings, stating that the agency believes it is in 

compliance with the managerial cost accounting standard. According to 

EPA’s management, cost-per-output information is provided to program 

managers on a regular basis. The resolution of this issue will likely 

be the topic of future discussions between EPA management and the 

Inspector General.

EPA was noncompliant with appropriation law when making disbursements 

for grants funded with more than one appropriation. Specifically, 

disbursements for these grants were made using the oldest available 

funding (appropriation) first, which might or might not have been the 

appropriation that benefited from the work performed. Consequently, EPA 

was not in compliance with title 31, U.S. Code, section 1301, which 

requires EPA to match disbursements to the benefiting appropriation. In 

fiscal year 2001, EPA adopted new procedures for allocating costs on 

such grants for new awards. Therefore, it is anticipated that the 

problem will be corrected as the remaining obligated balances are 


Although the Inspector General has identified several internal control 

weaknesses, it appears that corrective actions are well under way. The 

successful completion of these efforts to correct identified reportable 

conditions and compliance issues will assist EPA in providing its 

managers and the Congress with more timely and reliable financial 


[End of section]

GAO Contacts:

Subjects covered in this report: Improving environmental information

; Strengthening EPA’s human capital management

; Making regulatory innovation successful

; Improving EPA’s grants planning and management; Contact person: John 

B. Stephenson, Director; Natural Resources and Environment; (202) 512-


Subjects covered in this report: Maintaining EPA’s information 

security; Contact person: Robert F. Dacey, Director; Information 

Technology; (202) 512-3317;

Subjects covered in this report: Accounting for EPA’s financial 

resources; Contact person: McCoy Williams, Director; Financial 

Management and Assurance; (202) 512-6906;

[End of table]

[End of section]

Related GAO Products:

Performance and Accountability Series:

Major Management Challenges and Program Risks: A Governmentwide 

Perspective (GAO-01-241, January 2001).

Major Management Challenges and Program Risks: Environmental Protection 

Agency (GAO-01-257, January 2001).

High-Risk Series: An Update (GAO-01-263, January 2001).

Environmental and Performance Management Information:

Managing for Results: Agency Progress in Linking Performance Plans with 

Budgets and Financial Statements (GAO-02-236, Jan. 4, 2002).

Environmental Information: EPA Needs Better Information to Manage Risks 

and Measure Results (GAO-01-97T, Oct. 3, 2000).

Toxic Chemicals: Long-Term Coordinated Strategy Needed to Measure 

Exposures in Humans (GAO/HEHS-00-80, May 2, 2000).

Managing for Results: EPA Faces Challenges in Developing 

Results-Oriented Performance Goals and Measures (GAO/RCED-00-77, 

Apr. 28, 2000).

Water Quality: Key EPA and State Decisions Limited by Inconsistent and 

Incomplete Data (GAO/RCED-00-54, Mar. 15, 2000).

Environmental Information: EPA Is Taking Steps to Improve Information 

Management, but Challenges Remain (GAO/RCED-99-261, Sept. 17, 1999).

Information Technology and Security:

Computer Security: Progress Made, but Critical Federal Operations and 

Assets Remain at Risk (GAO-03-303T, Nov. 19, 2002).

Critical Infrastructure Protection: Significant Challenges Need to Be 

Addressed (GAO-02-961T, July 24, 2002).

Information Technology: Enterprise Architecture Use across the Federal 

Government Can Be Improved (GAO-02-6, Feb. 19, 2002).

Computer Security: Improvements Needed to Reduce Risk to Critical 

Federal Operations and Assets (GAO-02-231T, Nov. 9, 2001).

Information Security: Fundamental Weaknesses Place EPA Data and 

Operations at Risk (GAO/AIMD-00-215, July 6, 2000).

Human Capital:

A Model of Strategic Human Capital Management (GAO-02-373SP, Mar. 15, 


Human Capital: Attracting and Retaining a High Quality Information 

Technology Workforce (GAO-02-113T, Oct. 4, 2001).

Human Capital: Implementing an Effective Workforce Strategy Would Help 

EPA to Achieve Its Strategic Goals (GAO-01-812, July 31, 2001).

Innovative Regulatory Approaches:

Environmental Protection: Overcoming Obstacles to Innovative State 

Regulatory Programs (GAO-02-268, Jan. 31, 2002).

Environmental Protection: Challenges Facing EPA’s Efforts to 

Reinvent Environmental Regulation (GAO/RCED-97-155, July 2, 1997).

Environmental Protection: Status of EPA’s Initiatives to Create a New 

Partnership with States (GAO/T-RCED-96-87, Feb. 29, 1996).

EPA Grants Management:

Environmental Protection: Grants Awarded for Continuing Environmental 

Programs and Projects (GAO-01-860R, June 29, 2001).

Environmental Protection: EPA’s Oversight of Nonprofit Grantees’ Costs 

Is Limited (GAO-01-366, Apr. 6, 2001).

Environmental Protection: Information on EPA Project Grants and Use of 

Waiver Authority (GAO-01-359, Mar. 9, 2001).

Environmental Research: STAR Grants Focus on Agency Priorities, 

but Management Enhancements Are Possible (GAO/RCED-00-170, 

Sept. 11, 2000).

Environmental Protection: Grants for International Activities and Smart 

Growth (GAO/RCED-00-145R, May 31, 2000).

EPA Financial Management:

Debt Collection Improvement Act of 1996: Major Data Sources Inadequate 

for Implementing the Debtor Bar Provision (GAO-02-462, Mar. 29, 2002).

Debt Collection Improvement Act of 1996: Status of Selected Agencies’ 

Implementation of Administrative Wage Garnishment (GAO-02-313, 

Feb. 28, 2002).

Inspectors General: Information on Resources and Selected 

Accomplishments of 18 Inspectors General (AIMD-00-149R, Apr. 14, 2000).

[End of section]

Performance and Accountability and High-Risk Series:

Major Management Challenges and Program Risks: A Governmentwide 

Perspective. GAO-03-95.

Major Management Challenges and Program Risks: Department of 

Agriculture. GAO-03-96.

Major Management Challenges and Program Risks: Department of Commerce. 


Major Management Challenges and Program Risks: Department of Defense. 


Major Management Challenges and Program Risks: Department of Education. 


Major Management Challenges and Program Risks: Department of Energy. 


Major Management Challenges and Program Risks: Department of Health and 

Human Services. GAO-03-101.

Major Management Challenges and Program Risks: Department of Homeland 

Security. GAO-03-102.

Major Management Challenges and Program Risks: Department of Housing 

and Urban Development. GAO-03-103.

Major Management Challenges and Program Risks: Department of the 

Interior. GAO-03-104.

Major Management Challenges and Program Risks: Department of Justice. 


Major Management Challenges and Program Risks: Department of Labor. 


Major Management Challenges and Program Risks: Department of State. 


Major Management Challenges and Program Risks: Department of 

Transportation. GAO-03-108.

Major Management Challenges and Program Risks: Department of the 

Treasury. GAO-03-109.

Major Management Challenges and Program Risks: Department of Veterans 

Affairs. GAO-03-110.

Major Management Challenges and Program Risks: U.S. Agency for 

International Development. GAO-03-111.

Major Management Challenges and Program Risks: Environmental Protection 

Agency. GAO-03-112.

Major Management Challenges and Program Risks: Federal Emergency 

Management Agency. GAO-03-113.

Major Management Challenges and Program Risks: National Aeronautics and 

Space Administration. GAO-03-114.

Major Management Challenges and Program Risks: Office of Personnel 

Management. GAO-03-115.

Major Management Challenges and Program Risks: Small Business 

Administration. GAO-03-116.

Major Management Challenges and Program Risks: Social Security 

Administration. GAO-03-117.

Major Management Challenges and Program Risks: U.S. Postal Service. 


High-Risk Series: An Update. GAO-03-119.

High-Risk Series: Strategic Human Capital Management. GAO-03-120.

High-Risk Series: Protecting Information Systems Supporting the Federal 

Government and the Nation’s Critical Infrastructures. GAO-03-121.

High-Risk Series: Federal Real Property. GAO-03-122.


[1] See U.S. General Accounting Office, Toxic Chemicals: Long-Term 

Coordinated Strategy Needed to Measure Exposures in Humans, GAO/

HEHS-00-80 (Washington, D.C.: May 2, 2000).

[2] Pursuant to section 305(b) of the Clean Water Act, states report 

biennially to EPA on the quality of their waters. EPA summarizes this 

information in a biennial report, the National Water Quality Inventory. 

The most recent such report is the report for 2000. For that report, 

states assessed only 19 percent of the nation’s river and stream miles; 

43 percent of its total acres of lakes, ponds, and reservoirs; 36 

percent of its square miles of estuaries; and 6 percent of its ocean 

shoreline miles. Furthermore, as we reported in March 2000, on the 

basis of our survey of 50 states and the District of Columbia, only 3 

states indicated that they had the majority of the data needed to 

identify and assess nonpoint sources of pollution, generally considered 

to be the greatest contributor to water quality impairment at present.

[3] See U.S. General Accounting Office, Major Management Challenges and 

Program Risks: Environmental Protection Agency, GAO-01-257 

(Washington, D.C.: January 2001).

[4] See U.S. General Accounting Office, Environmental Information: EPA 

Is Taking Steps to Improve Information Management, but Challenges 

Remain, GAO/RCED-99-261 (Washington, D.C.: Sept. 17, 1999).

[5] This standard refers to the classification of biological organisms 

in established categories, such as kingdom, phylum, class, order, 

family, genus, species, and subspecies.

[6] One such registry, the Environmental Data Registry, contains 

descriptive information about data managed by the agency, with special 

emphasis on data elements used by EPA’s national systems. The registry 

is a single comprehensive source of information about the definition, 

origin, source, and location of environmental data and is the primary 

tool used by EPA for implementing data standards.

[7] See U.S. General Accounting Office, Environmental Protection 

Agency: Protecting Human Health and the Environment through Improved 

Management, GAO/RCED-88-101 (Washington, D.C.: Aug. 16, 1988).

[8] Examples of end outcomes would include ensuring that drinking water 

is safe or maintaining healthy air with respect to levels of pollutants 

such as carbon monoxide, sulfur dioxide, nitrogen dioxide, and lead.

[9] See U.S. General Accounting Office, Information Security: 

Fundamental Weaknesses Place EPA Data and Operations at Risk, GAO/

AIMD-00-215 (Washington, D.C.: July 6, 2000).

[10] See GAO/RCED-99-261.

[11] See GAO-01-257.

[12] See U.S. General Accounting Office, Human Capital: Implementing an 

Effective Workforce Strategy Would Help EPA to Achieve Its Strategic 

Goals, GAO-01-812 (Washington, D.C.: July 31, 2001).

[13] See GAO-01-812.

[14] See Resources for the Future, Industry Incentives for 

Environmental Improvement: Evaluation of U.S. Federal Initiatives 

(Washington, D.C.: September 1996).

[15] See U.S. General Accounting Office, Environmental Protection: 

Status of EPA’s Initiatives to Create a New Partnership with States, 

GAO/T-RCED-96-87 (Washington, D.C.: Feb. 29, 1996). Also, see U.S. 

General Accounting Office, Environmental Protection: Challenges Facing 

EPA’s Efforts to Reinvent Environmental Regulation, GAO/RCED-97-155 

(Washington, D.C.: July 2, 1997).

[16] See U.S. General Accounting Office, Environmental Protection: 

Overcoming Obstacles to Innovative State Regulatory Programs, 

GAO-02-268 (Washington, D.C.: Jan. 31, 2002).

[17] States also cited as a significant obstacle a cultural resistance 

among many in EPA toward alternative approaches--a resistance that, 

they maintained, often manifested itself in a lengthy and costly EPA 

review of their proposals. But this cultural resistance was often tied 

to the regulations themselves--participants were often concerned that 

strict application of the regulations was needed to reduce the risk of 

lawsuits filed by private interest groups.

[18] See Environmental Protection Agency, Innovating for Better 

Environmental Results (April 2002).

[19] The fiscal year 2002 budget amount does not include unobligated 

balances from previous budget authority.

[20] See U.S. General Accounting Office, Environmental Protection: 

Information on EPA Project Grants and Use of Waiver Authority, 

GAO-01-359 (Washington, D.C.: Mar. 9, 2001).

[21] See EPA Inspector General, Surveys, Studies, Investigations, and 

Special Purpose Grants, Report No. 2002-P-00005 (Mar. 21, 2002).

[22] See U.S. General Accounting Office, Environmental Research: STAR 

Grants Focus on Agency Priorities, but Management Enhancements Are 

Possible, GAO-RCED-00-170 (Washington, D.C. Sept. 11, 2000).

[23] See footnote 21.

[24] See EPA’s Competitive Practices for Assistance Awards, Report No. 

2001-P-00008 (May 21, 2001).

[25] See Environmental Protection Agency, Procurement Made by 

Assistance Agreement Recipients Should Be Competitive, Report No. 2002-

P-00009 (Mar. 28, 2002).

[26] See U.S. General Accounting Office, Environmental Protection: 

EPA’s Oversight of Nonprofit Grantees’ Costs Is Limited, GAO-01-366 

(Washington, D.C.: Apr. 6, 2001).

[27] See footnote 22.

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