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United States Government Accountability Office:


Before the Subcommittee on Energy and the Environment, Committee on 
Science, Space, and Technology, House of Representatives: 

For Release on Delivery: 
Expected at 2:00 p.m. EST:
Thursday, November 17, 2011: 

Environmental Protection Agency: 

Actions Needed to Improve Planning, Coordination, and Leadership of 
EPA Laboratories: 

Statement of David C. Trimble:
Natural Resources and Environment: 


Chairman Harris, Ranking Member Miller, and Members of the 

I am pleased to be here today to discuss the research and development 
activities of the Environmental Protection Agency (EPA) and the 
findings of our recent report on the agency's laboratory enterprise. 
[Footnote 1] EPA was established in 1970 to consolidate a variety of 
federal research, monitoring, standard-setting, and enforcement 
activities into one agency for ensuring the joint protection of 
environmental quality and human health.[Footnote 2] Scientific 
research, knowledge, and technical information are fundamental to 
EPA's mission and inform its standard-setting, regulatory, compliance, 
and enforcement functions. The agency's scientific performance is 
particularly important as complex environmental issues emerge and 
evolve, and controversy continues to surround many of the agency's 
areas of responsibility. Unlike other primarily science-focused 
federal agencies, such as the National Institutes of Health or the 
National Science Foundation, EPA's scientific research, technical 
support, and analytical services underpin the policies and regulations 
the agency implements. Therefore, the agency operates its own 
laboratory enterprise. This enterprise is made up of 37 laboratories 
that are housed in about 170 buildings and facilities located in 30 
cities across the nation. Specifically, EPA's Office of Research and 
Development (ORD) operates 18 laboratories with primary responsibility 
for research and development. Four of EPA's five national program 
offices[Footnote 3] operate nine laboratories with primary 
responsibility for supporting regulatory implementation, compliance, 
enforcement, and emergency response. Each of EPA's 10 regional offices 
operates a laboratory with responsibilities for a variety of applied 
sciences; analytical services; technical support to federal, state, 
and local laboratories; monitoring; compliance and enforcement; and 
emergency response. 

Over the past 20 years, independent evaluations by the National 
Research Council and others have addressed planning, coordination, or 
leadership issues associated with EPA's science activities.[Footnote 
4] The scope of these evaluations varied, but collectively they 
recognized the need for EPA to improve long-term planning, priority 
setting, and coordination of laboratory activities; establish 
leadership for agencywide scientific oversight and decision making; 
and better manage the laboratories' workforce and infrastructure. When 
it was established in 1970, EPA inherited 42 laboratories from 
programs in various federal departments. According to EPA's historian, 
EPA closed or consolidated some laboratories it inherited and created 
additional laboratories to support its mission. Nevertheless, EPA's 
historian reported that the location of most of EPA's present 
laboratories is largely the same as the location of its original 
laboratories in part because of political objections to closing 
facilities and conflicting organizational philosophies, such as 
operating centralized laboratories for efficiency versus operating 
decentralized laboratories for flexibility and responsiveness. Other 
federal agencies face similar challenges with excess and underused 
property. Because of these challenges, GAO has designated federal real 
property as an area of high risk.[Footnote 5] 

This statement summarizes the findings of our report issued in July of 
this year that examines the extent to which EPA (1) has addressed the 
findings of independent evaluations performed by the National Research 
Council and others regarding long-term planning, coordination, and 
leadership issues; (2) uses an agencywide, coordinated approach for 
managing its laboratory physical infrastructure; and (3) uses a 
comprehensive planning process to manage its laboratory workforce. In 
preparing this testimony, we relied on the work supporting our July 
report. In conducting that work, we reviewed agency documents and 
independent evaluations, visited EPA laboratories, interviewed agency 
officials, and examined agency databases; our recent report contains a 
detailed description of our scope and methodology. All of the work for 
our July report was performed in accordance with generally accepted 
government auditing standards. 

EPA Has Not Fully Addressed Findings of Evaluations on Long-standing 
Planning, Coordination, or Leadership Issues: 

EPA has taken some actions but has not fully addressed the findings 
and recommendations of five independent evaluations over the past 20 
years regarding long-standing planning, coordination, and leadership 
issues that hamper the quality, effectiveness, and efficiency of its 
science activities, including its laboratory operations. 

First, EPA has yet to fully address planning and coordination issues 
identified by a 1992 independent, expert panel evaluation that 
recommended that EPA develop and implement an overarching issue-based 
planning process that integrates and coordinates scientific efforts 
throughout the agency, including the important work of its 37 
laboratories.[Footnote 6] That evaluation found that EPA's science was 
of uneven quality and that the agency lacked a coherent science agenda 
and operational plan to guide scientific efforts throughout the 
agency. Because EPA did not implement the evaluation's recommendation, 
EPA's programs, regional officials, and ORD continue to independently 
plan and coordinate the activities of their respective laboratories 
based on their own offices' priorities and needs. 

Second, EPA has also not fully addressed recommendations from a 1994 
independent evaluation by the MITRE Corporation to consolidate and 
realign its laboratory facilities and workforce[Footnote 7]--even 
though this evaluation found that the geographic separation of 
laboratories hampered their efficiency and technical operations and 
that consolidation and realignment could improve planning and 
coordination issues that have hampered its science and technical 
community for decades. In its evaluation, MITRE recommended that EPA 
(1) realign and consolidate the ORD laboratories; (2) consolidate 
program laboratories in the Office of Prevention, Pesticides, and 
Toxic Substances[Footnote 8] and the two laboratories under the Office 
of Radiation and Indoor Air; and (3) through consolidation, reduce the 
number of regional office laboratories to a few laboratories with a 
national service focus. In response to the MITRE study, an agencywide 
steering committee formed by EPA to consider restructuring and 
consolidation options issued a report to the Administrator in July 
1994.[Footnote 9] The steering committee report stated that combining 
ORD laboratories at a single location could improve teamwork and raise 
productivity but concluded that, for the near term, ORD should be 
functionally reorganized but not physically consolidated. Regarding 
program office laboratory consolidations, the Office of Radiation and 
Indoor Air did not physically consolidate its laboratories but did 
administratively and physically consolidate its Las Vegas laboratory 
with ORD's Las Vegas radiation laboratory, and the Office of 
Prevention, Pesticides, and Toxic Substances colocated three of four 
laboratories with the region 3 laboratory. As for the regional 
laboratories, the steering committee's report endorsed the current 
decentralized regional model but did not provide a justification for 
its position. 

Third, EPA has not fully addressed recommendations from the 
independent evaluations regarding leadership of its research and 
laboratory operations.[Footnote 10] More specifically, EPA has not 
appointed a top science official with responsibility and authority for 
all the research, science, and technical functions of the agency--even 
though one study found that the lack of a top science official was a 
formula for weak scientific performance in the agency and poor 
scientific credibility outside the agency. Instead, EPA's efforts to 
establish leadership over its laboratory enterprise have relied on 
advisory positions and councils to achieve consensus and voluntary 
cooperation of ORD and the agency's program and regional offices. 
Because of the limited success of EPA's advisory positions and 
councils and in the absence of a central science policy authority, the 
National Research Council in 2000 recommended that EPA request 
authority from Congress to create a new position of deputy 
administrator for science and technology, with managerial authority to 
coordinate and oversee all the agency's scientific and technical 
activities. To date, EPA has not requested authority to create a new 
position of deputy administrator for science and technology and 
continues to operate its laboratories under the direction of 15 
different senior officials using 15 different organizational and 
management structures. As a result, EPA has a limited ability to know 
if scientific activities are being unintentionally duplicated among 
the laboratories or if opportunities exist to collaborate and share 
scientific expertise, equipment, and facilities across EPA's 
organizational boundaries. 

EPA Has Not Taken an Agencywide, Coordinated Approach to Manage Its 
Laboratory Physical Infrastructure: 

On the basis of our analysis of EPA's facility master planning 
process, we found that EPA manages its laboratory facilities on a site-
by-site basis and does not evaluate each site in the context of all 
the agency's real property holdings--as recommended by the National 
Research Council report in 2004.[Footnote 11] EPA's facility master 
plans are intended to be the basis for justifying its building and 
facilities spending, which was $29.9 million in fiscal year 2010, and 
allocating those funds to specific repair and improvement projects. 
Master plans should contain, among other things, information on 
mission capabilities, use of space, and condition of individual 
laboratory sites. In addition, we found that most facility master 
plans were out of date. EPA's real property asset management plan 
states that facility master plans are supposed to be updated every 5 
years to reflect changes in facility condition and mission, but we 
found that 11 of 20 master plans were out of date and 2 of 20 had not 
been created yet.[Footnote 12] 

Because EPA makes capital improvement decisions on a site-by-site 
basis using master plans that are often outdated, it cannot be assured 
it is allocating its funds most appropriately. According to officials 
responsible for allocating capital improvement resources, they try to 
spread these funds across the agency's offices and regions equitably 
but capital improvement funds have not kept pace with requests. The 
pressure and need to effectively share and allocate limited resources 
among EPA's many laboratories were also noted in a 1994 National 
Academy of Public Administration report on EPA's laboratory 
infrastructure, which found that EPA has "too many labs in too many 
locations often without sufficient resources to sustain a coherent 
stable program."[Footnote 13] 

In addition, because decisions regarding laboratory facilities are 
made independently of one another, opportunities to improve operating 
efficiencies can be lost. Specifically, we found cases where 
laboratories that were previously colocated moved into separate space 
without considering the potential benefits of remaining colocated. In 
one case, we found that the relocation increased some operating costs 
because the laboratories then had two facility managers and two 
security contracts and associated personnel because of different 
requirements for the leased facility. In another case, when two 
laboratories that were previously colocated moved into separate new 
leased laboratories several miles apart, agency officials said that 
they did not know to what extent this move may have resulted in 
increased operating cost. 

EPA also does not have sufficiently complete and reliable data to make 
informed decisions for managing its facilities. Since 2003, when GAO 
first designated federal real property management as an area of high 
risk, agencies have come under increasing pressure to manage their 
real property assets more effectively.[Footnote 14] In February 2004, 
the President issued an executive order directing agencies to, among 
other things, improve the operational and financial management of 
their real property inventory.[Footnote 15] The order established a 
Federal Real Property Council within the Office of Management and 
Budget (OMB), which has developed guiding principles for real property 
asset management. In response to a June 2010 presidential memorandum 
directing agencies to accelerate efforts to identify and eliminate 
excess properties,[Footnote 16] in July 2010 EPA reported to the OMB 
that it does not anticipate the disposal of any of its owned 
laboratories and major assets in the near future because these assets 
are fully used and considered critical for EPA's mission.[Footnote 17] 
EPA stated that decisions regarding facility disposal are made using 
the Federal Real Property Council's guidance but we found that EPA 
does not have the information needed to effectively implement this 
guidance. Specifically, EPA does not have accurate, reliable 
information regarding (1) the need for facilities, (2) property usage, 
(3) facility condition, and (4) facility operating efficiency--thereby 
undermining the credibility of any decisions based on this approach. 

* First, EPA does not maintain accurate data to determine if there is 
an agency need for laboratory facilities because many facility master 
plans are often out of date. According to EPA's asset management plan, 
the master plans are tools that communicate the link between mission 
priorities and facilities. However, without up-to-date master plans, 
EPA does not have accurate data to determine if laboratory facilities 
are needed for its mission. 

* Second, the agency does not have accurate data on space needs and 
usage because many facility master plans containing space utilization 
analyses are out of date. EPA also does not use public and commercial 
space usage benchmarks--as recommended by the Federal Real Property 
Council--to calculate usage rates for its laboratories. Instead, EPA 
measures laboratory usage on the basis of interviews with local 
laboratory officials. According to EPA officials, they do not use 
benchmarks because the work of the laboratories varies. In 2008, 
however, an EPA contractor created a laboratory benchmark based on 
those used by comparable facilities at the Centers for Disease Control 
and Prevention, the National Institutes of Health, the Department of 
Energy, and several research universities to evaluate space at two ORD 
laboratories in North Carolina. Consequently, we believe that 
objective benchmarks can be developed for EPA's unique laboratory 
requirements. In addition, the contractor's analysis concluded that 
EPA could save $1.68 million in annual leasing and $800,000 in annual 
energy costs through consolidation of the two ORD laboratories. Agency 
officials told us they hope to consolidate the laboratories in fiscal 
year 2012 if funds are available. 

* Third, the agency does not have accurate data for assessing 
facilities' condition because condition assessments contained in 
facility master plans are often outdated. The data may also be 
unreliable because data entered by local facility managers are not 
verified, according to agency officials. Such verification could 
involve edit checks or controls to help ensure the data are entered 

* Fourth, EPA does not have reliable operating cost data for its 
laboratory enterprise, because the agency's financial management 
system does not track operating costs in sufficient detail to break 
out information for individual laboratories or for the laboratory 
enterprise as a whole. Reliable operating cost data are important in 
determining whether a laboratory facility is operating efficiently, a 
determination that should inform both capital investment and property 
disposal decisions. 

EPA Does Not Use a Comprehensive Workforce Planning Process for Its 

EPA does not use a comprehensive planning process for managing its 
laboratories' workforce. For example, we found that not all of the 
regional and program offices with laboratories prepared workforce 
plans as part of an agencywide planning effort in 2007, and for those 
that did, most did not specifically address their laboratories' 
workforce. In fact, some regional management and human resource 
officials we spoke with were unaware of the requirement to submit 
workforce plans to the Office of Human Resources. Some of these 
managers told us the program and regional workforce plans were a 
paperwork exercise, irrelevant to the way the workforce is actually 
managed. Managers in program and regional offices said that workforce 
planning for their respective laboratories is fundamentally driven by 
the annual budgets of program and regional offices and ceilings for 
full-time equivalents (FTE).[Footnote 18] 

In addition, none of the program and regional workforce plans we 
reviewed described any effort to work across organizational boundaries 
to integrate or coordinate their workforce with the workforces of 
other EPA laboratories. For example, although two regional workforce 
plans discussed potential vulnerability if highly skilled laboratory 
personnel retired, neither plan explored options for sharing resources 
across regional boundaries to address potential skill gaps. According 
to EPA's Regional Laboratory System 2009 Annual Report, many of the 
regional laboratories provide the same or similar core analytical 
capabilities--including a full range of routine and specialized 
chemical and biological testing of air, water, soil, sediment, tissue, 
and hazardous waste. Nonetheless, in these workforce plans, each 
region independently determines and attempts to address its individual 
workforce needs. As a result, by not exploring options for sharing 
resources among the ORD, program, and regional boundaries to address 
potential skill gaps, EPA may be missing opportunities to fill 
critical occupation needs through resource sharing. 

Moreover, EPA does not have basic demographic information on the 
number of federal and contract employees currently working in its 37 
laboratories. Specifically, EPA does not routinely compile the 
information needed to know how many scientific and technical employees 
it has working in its laboratories, where they are located, what 
functions they perform, or what specialized skills they may have. In 
addition, the agency does not have a workload analysis for the 
laboratories to help determine the optimal numbers and distribution of 
staff throughout the enterprise. We believe that such information is 
essential for EPA to prepare a comprehensive laboratory workforce plan 
to achieve the agency's mission with limited resources. Because EPA's 
laboratory workforce is managed separately by 15 independent senior 
officials, information about that workforce is tracked separately and 
is not readily available or routinely compiled or evaluated. Instead, 
EPA has relied on ad hoc calls for information to compile such data. 

In response to our prior reports on EPA's workforce strategy[Footnote 
19] and the work of the EPA Inspector General, EPA hired a contractor 
in 2009, in part to conduct a study to provide information about the 
agency's overall workload, including staffing levels and workload 
shifts for six major functions, including scientific research. In its 
budget justification for fiscal year 2012, however, the agency 
reported to Congress that a survey of the existing workload 
information provided by the contractor will not immediately provide 
information sufficient to determine whether changes are needed in 
workforce levels. As of October 2011, EPA had not released the results 
of this study, and we therefore cannot comment on whether its content 
has implications for the laboratories. The agency asked its National 
Advisory Council for Environmental Policy and Technology to help 
address scientific and technical competencies as it develops a new 
agencywide workforce plan. However, the new plan is not complete, and 
therefore it is too early to tell whether the council's 
recommendations will have implications for the laboratories. 

Finally, in our July 2011 report on EPA's laboratory enterprise we 
recommended, among other things, that EPA develop a coordinated 
planning process for its scientific activities and appoint a top-level 
official with authority over all the laboratories, improve physical 
and real property planning decisions, and develop a workforce planning 
process for all laboratories that reflects current and future needs of 
laboratory facilities. In written comments on the report, EPA 
generally agreed with our findings and recommendations. 

Chairman Harris, Ranking Member Miller, this concludes my prepared 
statement. I would be happy to respond to any questions that you or 
other members of the subcommittee may have at this time. 

GAO Contact and Staff Acknowledgments: 

For further information on this statement, please contact David 
Trimble at (202) 512-3841 or Contact points for our 
Congressional Relations and Public Affairs offices may be found on the 
last page of this statement. Other staff that made key contributions 
to this testimony include Diane LoFaro, Assistant Director; Jamie 
Meuwissen; Angela Miles; and Dan Semick. 

[End of section] 


[1] GAO, Environmental Protection Agency: To Better Fulfill Its 
Mission, EPA Needs a More Coordinated Approach to Managing Its 
Laboratories, [hyperlink,] 
(Washington, D.C.: July 25, 2011). 

[2] Reorganization Plan No. 3 of 1970, 35 Fed. Reg. 15623 (Dec. 2, 
1970) (5 U.S.C. Appendix 1). 

[3] The national program offices with laboratories are the Office of 
Air and Radiation, the Office of Enforcement and Compliance Assurance, 
the Office of Chemical Safety and Pollution Prevention, and the Office 
of Solid Waste and Emergency Response. 

[4] The National Research Council is the principal operating agency of 
both the National Academy of Sciences and the National Academy of 

[5] High-Risk Series: An Update, [hyperlink,] (Washington, D.C.: February 

[6] Environmental Protection Agency, Safeguarding the Future: Credible 
Science, Credible Decisions, The Report of the Expert Panel on the 
Role of Science at EPA, EPA/600/9-91/050 (Washington, D.C.: March 

[7] MITRE Corporation, Center for Environment, Resources, and Space, 
Assessment of the Scientific and Technical Laboratories and Facilities 
of the U.S. Environmental Protection Agency (McLean, Va., May 1994). 

[8] Now known as the Office of Chemical Safety and Pollution 

[9] Environmental Protection Agency, Research, Development, and 
Technical Services at EPA: A New Beginning, Report to the 
Administrator, EPA/600/R-94/122 (Washington, D.C.: July 1994). 

[10] National Research Council, Interim Report of the Committee on 
Research and Peer Review in EPA (Washington, D.C., National Academies 
Press, 1995); Environmental Protection Agency, Office of Inspector 
General, Regional Laboratories (Washington, D.C., Aug. 20, 1997); and 
National Research Council, Strengthening Science at the U.S. 
Environmental Protection Agency: Research-Management and Peer Review 
Practices (Washington, D.C., National Academies Press, 2000). 

[11] National Research Council, Investments in Federal Facilities: 
Asset Management Strategies for the 21st Century (Washington, D.C., 
National Academies Press, 2004). 

[12] Master plans are created for owned properties only. We found 
there were no master plans for two laboratory properties located in 
Research Triangle Park, N.C., and Fort Meade, Md. We also found that 9 
of the 11 outdated master plans were over 10 years old. 

[13] National Academy of Public Administration, A Review, Evaluation, 
and Critique of a Study of EPA Laboratories by the MITRE Corporation 
and Additional Commentary on EPA Science and Technology Programs 
(Washington, D.C., May 1994), 10. 

[14] High-Risk Series: An Update, [hyperlink,] (Washington, D.C.: February 

[15] Federal Real Property Asset Management, Exec. Order No. 13327, 69 
Fed. Reg. 5897 (Feb. 4, 2004). 

[16] Presidential Memorandum, Disposing of Unneeded Federal Real 
Estate, 75 Fed. Reg. 33987 (June 16, 2010). 

[17] Environmental Protection Agency, Real Property Cost Savings and 
Innovation Plan (Washington, D.C., July 23, 2010. 

[18] An FTE consists of one or more employed individuals who 
collectively complete 2,080 work hours in a given year. Therefore, one 
full-time employee or two half-time employees equal one FTE. 

[19] GAO, Human Capital: Implementing an Effective Workforce Strategy 
Would Help EPA to Achieve Its Strategic Goals, [hyperlink,] (Washington, D.C.: July 31, 
2001); Human Capital: Key Principles for Effective Strategic Workforce 
Planning, [hyperlink,] 
(Washington, D.C.: Dec. 11, 2003); Clean Water Act: Improved Resource 
Planning Would Help EPA Better Respond to Changing Needs and Fiscal 
Constraints, [hyperlink,] 
(Washington, D.C.: July 22, 2005); EPA's Execution of Its Fiscal Year 
2007 New Budget Authority for the Enforcement and Compliance Assurance 
Program in the Regional Offices, [hyperlink,] (Washington, D.C.: Sept. 26, 
2008); Environmental Protection Agency: Major Management Challenges, 
[hyperlink,] (Washington, D.C.: 
Mar. 4, 2009). 

[End of section] 

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