Regulatory Reinvention:

EPA's Common Sense Initiative Needs an Improved Operating Framework and Progress Measures

RCED-97-164: Published: Jul 18, 1997. Publicly Released: Jul 18, 1997.

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Pursuant to a congressional request, GAO examined the progress of the Environmental Protection Agency's (EPA) Common Sense Initiative toward its goal of finding "cleaner, cheaper, smarter" ways of reducing or preventing pollution and the methods EPA uses to measure progress.

GAO noted that: (1) in the almost 3 years the Initiative has been under way, it has produced three formal recommendations to EPA, none of which has suggested the types of changes in the existing approach to environmental management that EPA expected; (2) although stakeholders have begun to work collaboratively on environmental solutions, progress toward the Initiative's goal has been limited by several factors, such as the length of time needed to collect and analyze data, the difficulties stakeholders have had in reaching consensus on the approaches needed to address large, complex issues or policies, and variations in stakeholders' commitments of time and understanding of the technical aspects of environmental issues; (3) in addition, the Common Sense Initiative Council and its subcommittees and workgroups have spent considerable time discussing how they would carry out their work and developing their own operating standards; (4) an improved operating framework that better defined the Initiative's goal and expected results and included the specific guidance on how the Initiative would accomplish its work would enable the Council and its industrial sector subcommittees and workgroups to concentrate more of their effort on substantive issues; (5) EPA gauges the progress of the Initiative primarily on the basis of accomplishments associated with its various processes or activities, such as stakeholder meetings, and not on the basis of its results; (6) although such process-oriented information is important, it does not measure the agency's progress in meeting the Initiative's goal, consistent with the Government Performance and Results Act's intent; (7) as a result, EPA cannot determine the extent to which the Initiative may cost-effectively reduce or prevent pollution or ascertain whether such improvements are due to changes in the agency's approach to environmental management; (8) in addition, the Initiative's projects typically do not establish or provide for performance measures to gauge the extent to which they are decreasing pollution and/or reducing costs; (9) GAO found that 11 of the 15 ongoing projects it reviewed did not provide for measuring results; and (10) without such measures, it is difficult to assess progress or demonstrate whether a project's expected outcome has occurred.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: EPA proposed two areas for Common Sense Initiative Council involvement, including addressing broader issues common to the sector subcommittees, and providing strategic guidance to the sectors and advice to EPA on the sector-based approach. The Council accepted this approach as the framework for its future work and interaction with the subcommittees. EPA provided guidance to the Council on the key elements of a sector approach to environmental protection that established a framework for each subcommittee to follow. The guidance recommended that the subcommittees work through three stages, including strategic planning, development and implementation of a comprehensive work plan, and preparation of recommendations. This guidance also provided information that clarified EPA's expectations with respect to achieving cleaner, cheaper, smarter environmental management approaches. As of May 1998, the Council and each of its subcommittees had prepared work plans following the guidance provided.

    Recommendation: To permit the Initiative's subcommittees and workgroups to devote more of their attention to substantive issues, the Administrator, EPA, should provide an improved operating framework that more clearly defines the Initiative's "cleaner, cheaper, smarter" environmental protection goal--including its expected results.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Implemented

    Comments: In response to this recommendation, EPA provided the Initiative with a framework for developing work plans that specify not only how the Council, its subcommittees, and work groups will accomplish their work, but also how the Initiative's goal is interpreted and applied to individual projects. In addition, EPA developed a draft entitled, "Consensus Decision-Making Principles and Applications in the EPA Common Sense Initiative." This paper clarified the principles of decisionmaking by consensus, how they apply in the context of the Initiative, and how Initiative activities could proceed in the absence of consensus. This document was unanimously adopted by the Council.

    Recommendation: To permit the Initiative's subcommittees and workgroups to devote more of their attention to substantive issues, the Administrator, EPA, should provide an improved operating framework that specifies how the Common Sense Initiative Council and its subcommittees and workgroups will accomplish their work, clarifying issues such as how and when consensus will be achieved, how the Initiative's goal should be interpreted and applied to individual projects, and to what extent representatives of all stakeholders groups should be included in activities at each level of the Initiative, including projects and workgroups.

    Agency Affected: Environmental Protection Agency

  3. Status: Closed - Implemented

    Comments: Consistent with EPA guidance, the Council and its industry-based subcommittees developed performance measures in conjunction with their work plans. These measures identify the Initiative's contributions in the areas of developing and implementing a sector-based regulatory framework, encouraging pollution prevention, record keeping and reporting, compliance and enforcement, permitting, facilitating the development of environmental technology, involving communities, and emerging environmental issues. Measurement of performance will be based on the Initiative's recommendations to the agency, and the agency will be accountable for implementing the Council's recommendations. The Council plans followup to determine whether the agency has acted on its recommendations and will conduct evaluations to determine their effects. These performance measures are also being incorporated into the EPA's strategic goals.

    Recommendation: To provide a basis for evaluating the progress of the Initiative in cost-effectively reducing or preventing pollution, the Administrator, EPA, should require the development of results-oriented performance measures for assessing the extent to which the Common Sense Initiative Council's and subcommittees' actions have produced real, measurable environmental improvements at less cost to industry and the public.

    Agency Affected: Environmental Protection Agency


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