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EPA Met or Exceeded Most 

Internal Climate Change Goals,

But Data Quality and Records 

Management Procedures

Need Improvement

Report No. 14-P-0325 July 29, 2014

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL
This is one of the U.S. Environmental Protection Agency Office of Inspector General’s 

products associated with climate change. For details on our other reports on climate 

change, go to http://www.epa.gov/oig/climatechange.

Report Contributors: Rudolph M. Brevard 

Hilda Canes Garduño

Leon Carter

Christine El-Zoghbi

Michael Goode 

Bram Hass 

Eric Jackson

Doug LaTessa

Eric Lewis

Nyquana Manning

Nicole Pilate

Teresa Richardson

Brooke Shull

Mary Anne Strasser

Abbreviations

EPA U.S. Environmental Protection Agency

FY fiscal year

GHG greenhouse gas

OARM Office of Administration and Resources Management

OIG Office of Inspector General

OMB Office of Management and Budget

SSPP Strategic Sustainability Performance Plan

Cover photo: Green roof, wind turbines and solar panels at the EPA’s Atlantic Ecology 

Division Laboratory in Narragansett, Rhode Island. (EPA photo) 

Hotline Suggestions for Audits or Evaluations

To report fraud, waste or abuse, contact us 

through one of the following methods:

To make suggestions for audits or evaluations, 

contact us through one of the following methods:

email:

phone:

fax:

online:

write:

OIG_Hotline@epa.gov

1-888-546-8740

1-202-566-2599

http://www.epa.gov/oig/hotline.htm

EPA Inspector General Hotline 

1200 Pennsylvania Avenue, NW

Mailcode 2431T

Washington, DC 20460

email:

phone:

fax:

online:

write:

OIG_WEBCOMMENTS@epa.gov

1-202-566-2391

1-202-566-2599

http://www.epa.gov/oig/contact.html#Full_Info

EPA Inspector General 

1200 Pennsylvania Avenue, NW

Mailcode 2410T

Washington, DC 20460
 

 14-P-0325

July 29, 2014

Why We Did This Review

The congressional Bicameral 

Task Force on Climate Change

requested that we assess 

U.S. Environmental Protection 

Agency (EPA) implementation 

of policies that address climate 

change at EPA facilities to 

ensure the EPA was meeting 

requirements.

To address this request, we 

evaluated the EPA’s

implementation of requirements 

under Executive Order 13514, 

“Federal Leadership in 

Environmental, Energy, and 

Economic Performance.” To 

meet the requirements of the

order, the EPA developed a 

2012 Strategic Sustainability 

Performance Plan that 

identified its progress in 

meeting internal agency goals 

related to greenhouse gas 

emissions, among others. 

We also reviewed the EPA’s 

implementation of EPA Office 

of Inspector General (OIG)

recommendations made in 

2011 to adjust its greenhouse 

gas reductions goal based on 

funding and project status.

This report addresses the 

following EPA goals or 

cross-agency strategies:

 Addressing climate change 

and improving air quality.

 Working toward a 

sustainable future.

For further information, 

contact our public affairs office 

at (202) 566-2391.

The full report is at:

www.epa.gov/oig/reports/2014/ 

20140729-14-P-0325.pdf

EPA Met or Exceeded Most Internal Climate 

Change Goals, But Data Quality and Records 

Management Procedures Need Improvement

Most Climate Change Goals Met 

The EPA adhered to most climate change 

requirements for federal agencies. With a few 

exceptions, the EPA provided documentation to 

support its reported 2012 accomplishments. The

EPA exceeded its climate change goals and 

requirements related to water use, greenhouse 

gas emissions and renewable energy. The EPA was one of only three agencies 

out of 25 reporting that received a green scorecard on the OMB sustainability

scorecard for fiscal year (FY) 2013 and has achieved a green scorecard the last 

3 years. In addition, the EPA voluntarily tracks and reports data for its leased 

buildings that are 50,000 square feet or larger. In response to the 

recommendation from the 2011 OIG report, the EPA incorporated a review of its 

greenhouse gas reduction goals as part of its annual Strategic Sustainability 

Performance Plan submission, and it agreed to make adjustments to the overall 

reduction goal as needed. Since the agency is on track to meet its 2020 

greenhouse gas reduction goals and it has developed a process to revise the 

goals, we believe this prior OIG recommendation has been addressed.

 Areas Where Improvements Are Needed

We identified several internal control weaknesses in the EPA’s data quality 

assurance procedures and adherence to its Records Management Policy that

need to be addressed. The agency relies heavily on a contractor to collect water 

and energy data used in the 2012 Strategic Sustainability Performance Plan and 

also relies on the contractor to perform its own quality assurance review of data 

presented in the plan, which, due to EPA inattention, could increase the

likelihood that inaccurate data gets overlooked. Further, we identified data errors 

in the plan. The agency also lacks sufficient internal controls for electronic 

stewardship and data center accomplishments reported in the plan. Additionally, 

we identified areas where the EPA was not in full compliance with the agency’s 

Records Management Policy. Specifically, EPA accomplishment data reported in 

the 2012 Strategic Sustainability Performance Plan related to fleet management, 

waste diversion and acquisitions have not been appropriately maintained and 

documented. 

 Recommendations and Planned Agency Corrective Actions

We recommend that the agency establish procedures to conduct a quality 

assurance review of Strategic Sustainability Performance Plan data provided by 

the contractor and EPA program offices. We also recommend that the agency

develop and implement procedures for maintaining and securing records 

associated with production of the annual Strategic Sustainability Performance 

Plan in accordance with the EPA’s Records Management Policy. The agency 

agreed with our recommendations and provided a corrective action plan.

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

Improving data quality and 

records management 

procedures can support 

confidence in the reliability 

of EPA's progress reports 

on its climate change goals.
July 29, 2014

MEMORANDUM

SUBJECT: EPA Met or Exceeded Most Internal Climate Change Goals, 

But Data Quality and Records Management Procedures Need Improvement

Report No. 14-P-0325

FROM: Arthur A. Elkins Jr.

TO: Craig Hooks, Assistant Administrator

Office of Administration and Resources Management

This is our report on the subject review conducted by the Office of Inspector General (OIG) of the 

U.S. Environmental Protection Agency (EPA). This report contains findings that describe the problems 

the OIG has identified and corrective actions the OIG recommends. This report represents the opinion of 

the OIG and does not necessarily represent the final EPA position. Final determinations on matters in 

this report will be made by EPA managers in accordance with established audit resolution procedures.

The EPA office having primary jurisdiction over the issues evaluated is the Office of Acquisition 

Management within the Office of Administration and Resources Management.

Action Required

In accordance with EPA Manual 2750, your office provided acceptable and complete planned corrective 

actions in response to OIG recommendations. All recommendations are resolved and no final response 

to this report is required. We will post this report to our website at http://www.epa.gov/oig. 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

THE INSPECTOR GENERAL
EPA Met or Exceeded Most Internal Climate Change Goals, But Data 14-P-0325

Quality and Records Management Procedures Need Improvement

Table of Contents

Why We Did This Review.......................................................................................... 1

What the Executive Order Says................................................................................ 1

EPA Met Most of Its 2012 Planned Climate Change Goals..................................... 3

Goal 1: GHG Reduction and Inventory Requirements for Management.............. 4

Goal 2: Buildings and Energy Use ...................................................................... 5

Goal 3: Fleet Management ................................................................................. 7

Goal 4: Water Use.............................................................................................. 7

Goal 5: Pollution Prevention and Waste Reduction............................................. 8

Goal 6: Acquisition.............................................................................................. 8

Goal 7: Electronics and Data Centers................................................................. 8

Goal 8: Agency Innovation.................................................................................. 9

Areas Where Improvements Are Needed ................................................................ 9

EPA Relies on Contractor to Verify SSPP Data .................................................. 10

Improved Controls Needed for Electronic Acquisitions Database ....................... 10

Improved Controls Needed to Verify Data Center Performance Metrics ............. 10

Improved Record Keeping Procedures Can Ensure Data Accuracy.................... 11

Recommendations .................................................................................................... 11

Agency Response to Draft Report and OIG Evaluation.......................................... 12

Status of Recommendations and Potential Monetary Benefits ............................. 13

Appendices

A Scope and Methodology .................................................................................. 14

B Agency Response to Draft Report and OIG Comments................................. 15

C Distribution ....................................................................................................... 24
14-P-0325 1

Why We Did This Review

The congressional Bicameral Task Force on 

Climate Change requested that the U.S. 

Environmental Protection Agency’s (EPA’s) 

Office of Inspector General (OIG) assess the 

agency’s implementation of policies that address 

climate change. The task force sent similar 

requests to nearly 70 Inspectors General 

throughout the federal government. To address 

this request, the EPA OIG evaluated the EPA’s

implementation of Executive Order 13514, 

“Federal Leadership in Environmental, Energy, 

and Economic Performance,” as documented in 

the EPA’s 2012 Strategic Sustainability 

Performance Plan (SSPP). Executive Order 

13514 (referred to in this report as the Executive 

Order) establishes an integrated strategy toward 

sustainability in the federal government and 

makes reduction of greenhouse gas (GHG) 

emissions a priority for all federal agencies. 

Our objectives were to:

(1) Conduct a follow-up review on the EPA’s implementation of the OIG’s 

recommendation to “make adjustments to the GHG emission reductions 

and/or reduction goals based on actual funding and status of projects, and 

revise the EPA’s overall reduction goal if needed during the annual update 

of the Strategic Sustainability Performance Plan.” This recommendation 

was made, and agreed to by the EPA, in the OIG’s April 2011 Report No. 

11-P-0209, EPA’s Plan to Reduce Agency Greenhouse Gas Emissions 

Is on Track to Meet Executive Order 13514 Requirements.

(2) Assess the extent to which the agency is meeting its 2012 SSPP 

objectives. 

What the Executive Order Says

To promote energy security and protect the health of our environment, President 

Obama signed Executive Order 13514 on October 5, 2009. The Executive Order

requires all federal agencies to meet specific goals related to the reduction of 

GHG emissions, conservation of water resources, local planning, fleet 

management, energy efficiency, electronics stewardship, pollution prevention and 

the advancement of sustainable acquisitions. The Executive Order requires 

Figure 1: EPA’s 2012 SSPP report 

is at: http://www.epa.gov/oaintrnt/

documents/sspp2012_508.pdf 

(Source: EPA website)
14-P-0325 2

agencies to develop targets for GHG emissions reductions based on the “scope” of 

emissions sources, as described below and illustrated in figure 2.

 Scope 1 emissions are direct GHG emissions from sources owned or 

controlled by the EPA. This includes emissions from fossil fuels burned 

onsite, from EPA-owned or -leased vehicles, and other direct sources.

 Scope 2 emissions include indirect emissions resulting from the 

generation of EPA-purchased electricity, heat or steam power. 

 Scope 3 emissions include indirect emissions from sources not owned or 

directly controlled by the EPA but related to its activities, such as 

employee business travel, local commuting and waste disposal. 

Requirements for Management of Climate Change Goal

Accomplishment Data

We identified three requirements that apply to the EPA’s management of its 

climate change goal data. 

First, federal agencies are required to describe how they will achieve the 

environmental, economic and energy goals mandated by the Executive Order in 

an SSPP. The SSPP must be updated annually and submitted to the White House 

Council on Environmental Quality and the Office of Management and Budget 

(OMB). In the SSPP, the EPA must identify specific agency goals and milestones, 

as well as activities, plans and procedures relevant to the agency’s implementation 

of the order. In addition, all federal agencies must establish and report a GHG

inventory to the OMB. The EPA’s Assistant Administrator for the Office of 

Administration and Resources Management (OARM) is the Senior Sustainability 

Officer responsible for ensuring implementation of the Executive Order at the 

Figure 2: Sources of Scope 1, 2 and 3 GHG emissions. (Source: EPA website)
14-P-0325 3

EPA. To ensure compliance with the order, the EPA has informed its senior 

managers—including Assistant Administrators, Regional Administrators and 

Laboratory Directors—of their responsibilities in implementing the Executive 

Order requirements.

Second, the EPA has other general requirements and responsibilities related to 

internal controls that apply to its SSPP reporting data. OMB Circular A-123, 

“Management’s Responsibility for Internal Control,” dated December 2004, 

defines internal control responsibilities in federal agencies. It states that 

management is responsible for establishing and maintaining internal control to 

achieve the objectives of effective and efficient operations, reliable financial 

reporting, and compliance with applicable laws and regulations. For example,

good internal controls include appropriate documentation and access to that 

documentation. OMB Circular A-123 also states that periodic reviews, 

reconciliations or comparisons of data should be included as part of the regular 

assigned duties of federal agency personnel, and periodic assessments should be 

integrated as part of management’s continuous monitoring of internal control.

Third, the agency has internal records management requirements. The EPA’s 

Records Management Manual outlines requirements and responsibilities related to 

maintaining, securing, disposing and transferring of agency records. EPA offices 

must capture records to:

 Maintain adequate and proper documentation and evidence of agency 

activities for the time required to meet all program, audit and historical 

need.

 Maximize the usefulness of the records while active and allow for 

interoperability and sharing of records across programs and information 

systems.

 Allow for timely access and retrieval.

 Safeguard records from loss, misuse, and unauthorized access to or 

modification of information.

 Facilitate the identification and preservation of permanent records.

EPA Met Most of Its 2012 Planned Climate Change Goals

Overall, we found that the EPA met or exceeded most federal sustainability 

requirements under the Executive Order, as reported in the 2012 SSPP. With a 

few exceptions noted later, the EPA provided documentation to support its 

reported SSPP accomplishments. The EPA has guidance for the collection and 

verification of data on GHG emissions and energy and water use, and the

guidance is updated annually and includes data quality assurance procedures. 
14-P-0325 4

The OMB uses a scorecard process to measure the federal government’s 

sustainability performance. The scorecard employs a simple evaluation system: 

green for success; yellow for mixed results; and red for unsatisfactory. Through 

the OMB scorecard process, agencies are assessed on several sustainability areas, 

including: energy intensity, water intensity, fleet petroleum use, GHG pollution,

green building practices and renewable energy use. The EPA was one of only 

three agencies out of 25 reporting that received a green scorecard on the OMB 

sustainability scorecard for fiscal year (FY) 2013. The EPA has achieved a green 

scorecard the last 3 years. Our analysis of the EPA’s 2012 SSPP accomplishments 

for each goal is summarized below. 

Goal 1: GHG Reduction and Inventory Requirements for Management 

We confirmed that the EPA is on track to meet its 

goals related to GHG emissions.

1 The EPA’s FY 2020 

goal for Scope 1 and 2 GHG emission reductions is 

25 percent from its FY 2008 baseline. For Scope 3 

emissions, the EPA’s goal is an 8 percent reduction 

from its FY 2008 baseline. We verified that the EPA 

had records and data to demonstrate that it reduced its 

Scope 1 and 2 emissions by a combined 57 percent 

and its Scope 3 emissions by 10 percent in FY 2011. 

As stated in the SSPP, the EPA achieved these 

reductions through energy efficiency projects at its 

facilities, improved fleet management practices and 

green power purchases. The EPA’s renewable energy purchases enabled the 

agency to reduce its reported GHG emissions under current guidance from the 

White House Council on Environmental Quality. 

In addition, the EPA tracked and 

reported GHG emissions data for both 

required and non-required facilities. 

Although agencies are not required to 

report GHG emissions for facilities 

that are leased, the EPA collects 

facility GHG data for its leased 

buildings that are 50,000 square feet 

or larger on a quarterly basis and 

voluntarily reports these emissions. 

To verify GHG emissions data, which 

include data on the agency’s energy 

and water use, renewable energy 

purchases, and commuter and business 

travel emissions, we reviewed 

 

1 GHG emissions are measured in metric tons of carbon dioxide equivalent.

Videoconference equipment is used 

by the EPA to reduce business travel 

emissions. (Source: EPA website)

Roof-top solar panels supply “green” electricity to the EPA’s National Health 

and Environmental Effects Research Laboratory in Corvallis, Oregon. 

(Source: EPA website)
14-P-0325 5

spreadsheets compiled by the EPA’s contractor. We also reviewed original data 

from utility bills and renewable energy contracts for a sample of EPA facilities.

In response to the recommendation from our FY 2011 report, the agency 

incorporated a review of its GHG reduction goals as part of its annual SSPP 

submission, and it agreed to make adjustments to the overall reduction goal based 

on the previous year’s progress and available funding. Since the agency is on 

track to meet its 2020 GHG reduction goals, and it has developed a process to 

revise the goals if needed, we believe this recommendation has been addressed. 

Goal 2: Buildings and Energy Use

We confirmed through data and document 

reviews the agency’s reported achievements 

in meeting its goals for energy intensity, 

high performance sustainable buildings, 

Energy Savings Performance Contracts and 

regional/local planning initiatives.

Energy Use. The EPA is required to reduce 

its energy intensity by 3 percent annually.

2

EPA data shows that the agency achieved its 

FY 2011 energy intensity reduction goal of 

18 percent. The agency achieved energy

savings by initiating and completing several 

major capital improvement projects to 

improve energy efficiency at its facilities in 

FY 2011. The agency also derived 

0.68 percent of its energy use from onsite 

renewable resources, such as wind, solar and 

geothermal power.3In addition, the agency 

was required to complete energy assessments at 75 percent of high-energy use 

facilities by FY 2011. We determined, based on data collected by the EPA’s 

contractor, that the agency exceeded the 75 percent target and completed more 

than the required number of assessments (78 percent).

 

2 Energy intensity is energy use (measured in British thermal units) per gross square foot.

3 The EPA has onsite renewable resources at 12 facilities, located in: Athens, Georgia; Chelmsford, Massachusetts;

Narragansett, Rhode Island; Edison, New Jersey; Montgomery, Alabama; Research Triangle Park, North Carolina 

(Main Office, National Computer Center and Childcare Center); Ada, Oklahoma; Golden, Colorado; Manchester, 

Washington; and Corvallis, Oregon.

Solar lighting lines the roadways at the EPA’s 

Research Triangle Park facility in North 

Carolina. According to the EPA, this is the 

longest stretch of solar-luminated roadway in 

the United States. Solar lighting is part of the 

agency’s green power efforts. (Source: EPA 

website)
14-P-0325 6

Advanced electric meter and boiler at the EPA’s laboratory in Manchester, Washington. The EPA is 

required to install advanced metering equipment to capture energy consumption at its facilities to the 

maximum extent practicable. The EPA also initiated a project at its Manchester lab to retrofit fuel oil-fired 

boilers with natural gas to reduce GHG emissions and save on fuel costs. (EPA photos)

High Performance Sustainable 

Buildings. We confirmed that EPA 

documentation supports its 2012 SSPP 

accomplishments related to sustainable 

building management. For example, we 

verified documentation demonstrating

the EPA’s claims that 7.8 percent of the 

agency’s buildings measuring greater 

than 5,000 square feet met the Guiding 

Principles for Federal Leadership in 

High Performance and Sustainable

Buildings in FY 2011. We also 

confirmed through records review that 

45 construction projects and lease 

actions went through the EPA’s 

GreenCheck process, which applies 

sustainability requirements to projects 

requiring funding in excess of $85,000. 

Energy Savings Performance Contracts. The Energy Savings Performance 

Contracts initiative required federal agencies to enter into a minimum of 

$2 billion in performance-based contracts to improve federal building energy 

efficiency by December 2013. We confirmed that the EPA identified two potential 

Energy Savings Performance Contracts, totaling $9 million. The agency plans to 

pursue other proposed contracts to determine whether they are economically 

feasible and advantageous.

Regional/Local Planning. The agency’s accomplishments in regional and local 

planning include participation in the Partnership for Sustainable Communities, 

and cooperation with other federal agencies to publish information resources 

about sustainable strategies for locating federal facilities.

The EPA Region 8 building’s green roof in Denver, Colorado, is 

an example of sustainable building practices used by the agency. 

The roof helps to regulate building temperature, reduce 

stormwater runoff and absorb carbon dioxide.

(Source: EPA website)
14-P-0325 7

Goal 3: Fleet Management

We confirmed the EPA’s accomplishments 

related to fleet management and fossil fuel 

reductions by reviewing agency fleet data in 

the Federal Automotive Statistical Tool 

database. The agency is required to reduce 

its petroleum consumption by 30 percent by 

FY 2020 from its FY 2005 baseline. The 

EPA’s fleet data show that it reduced

petroleum consumption by approximately 

33 percent in FY 2011 from its 2005 

baseline. This reduction more than doubled 

the EPA’s interim petroleum reduction target

of 12 percent for FY 2011. 

As reported in the SSPP, the EPA did not 

reach its requirement to increase alternative fuel4consumption by 10 percent 

annually. The agency’s FY 2011 alternative fuel consumption was approximately 

32 percent less than its target of 79,000 gasoline gallon equivalents. Additionally, 

EPA fleet data support that the agency exceeded its Energy Policy Act 

requirement to ensure that at least 75 percent of vehicle acquisitions were 

alternative fuel vehicles, excluding law enforcement and emergency response 

vehicles. The agency also eliminated 42 vehicles from its fleet in FY 2011. 

Goal 4: Water Use

The EPA is required to improve its water use 

efficiency and management by reducing 

potable water consumption intensity5by 

2 percent annually through FY 2020 relative 

to its FY 2007 baseline (i.e., 26 percent). We 

reviewed agency water use data to confirm 

that the EPA reduced its potable water use 

intensity by more than 15 percent in FY 2011 

from its FY 2007 baseline. The agency also is 

required to reduce its non-potable water 

consumption for industrial, landscaping and 

agricultural uses by 2 percent annually through FY 2020 compared to its FY 2010 

baseline (i.e., 20 percent). Agency data support that the EPA reduced its nonpotable water use by 58 percent in FY 2011 from the prior year. The EPA 

achieved this through water conservation and storm water management projects.

 

4 Alternative fuels are non-petroleum fuels. They include gaseous fuels such as hydrogen and natural gas, alcohols 

such as ethanol, vegetable and waste-derived oils, and electricity.

5 Water use intensity is measured in gallons per gross square foot per year.

Water cistern used to collect and store 

rainwater for landscaping at childcare center 

at the EPA’s Research Triangle Park facility 

in North Carolina. (Source: EPA website)

Photo of plug-in hybrid vehicle. The EPA 

acquired 153 alternative fuel vehicles to reduce 

its petroleum consumption and increase its 

alternative fuel consumption in FY 2011.

(Source: www.fueleconomy.gov)
14-P-0325 8

Goal 5: Pollution Prevention and Waste Reduction 

We confirmed that the EPA has documentation to support its accomplishments on

pollution prevention and waste reduction as reported in the SSPP. The Executive 

Order requires the EPA to minimize the generation of waste and pollutants 

through source reduction, and divert6at least 50 percent of non-hazardous solid 

waste and 50 percent of construction and 

demolition waste by the end of FY 2015. 

EPA data show that it achieved a waste 

diversion rate of 59 percent for 

solid waste, as well as construction and 

demolition waste, in FY 2011. We also 

reviewed EPA documentation to confirm

that the agency is reducing waste through 

prevention assessment projects and other 

prevention efforts such as the 

agencywide “Think Beyond the Bin”

program.

Goal 6: Acquisition

We were able to verify documentation for most of the EPA’s accomplishments

related to acquisition. The EPA Acquisition System has been fully implemented 

agencywide and contains data fields for recording environmental attributes, such 

as the energy or water efficiency of a product or service, or whether a product 

contains recycled content. We also verified through document and data review

that the EPA implemented initiatives to improve acquisition planning, market 

research and procurement data collection. However, we could not confirm the 

agency’s assertion that it met or exceeded the Executive Order requirement to 

procure 95 percent of new contracts with green attributes for 3 consecutive years

(2009, 2010 and 2011). Specifically, the methodology used to calculate the 

percentage of new contract actions with green attributes was not documented 

properly and could not be replicated.

Goal 7: Electronics and Data Centers

We were able to confirm through document and data review, software assessments 

and a site visit to the EPA’s National Computer Center that the agency achieved

many of its reported SSPP accomplishments related to electronic stewardship and 

data centers. The agency deployed software that is capable of establishing powermanagement settings for computers and monitors to 100 percent of all eligible 

EPA computers and monitors. Also, we verified that the EPA’s personal computer 

standard details numerous “green” requirements in accordance with the Executive 

 

6 Waste diversion is the prevention and reduction of generated waste through source reduction, recycling, reuse or 

composting.

The Think Beyond the Bin campaign, launched in 

FY 2011, encourages facilities to strengthen their 

waste diversion efforts through source reduction, 

recycling, reuse and composting. (Source: EPA 

Intranet website)
14-P-0325 9

Order. We also reviewed the EPA’s claim that “virtualization7is extensively used 

to support database hosting” at the EPA’s data centers. Virtualization enables 

multiple operating systems to be located and independently operated from one 

physical server instead of the “one server one operating system” platform 

previously used. The EPA’s implementation of virtualization helps the agency 

become more energy efficient by restructuring processes associated with server 

operations. The consolidation of physical servers can save energy, translating to 

savings of up to 80 percent in data center energy costs while reducing

infrastructure and capital costs. In this area we found that the EPA’s National 

Computer Center has made significant strides in virtualizing its database hosting 

infrastructure. As of 2012, the 

National Computer Center had 

virtualized 71 percent of its hosted 

databases. However, as of 2012,

all EPA data centers had only 

virtualized 38 percent of their

hosting infrastructure. We also 

found that the EPA lacks internal 

controls to validate its electronic 

stewardship data.

Goal 8: Agency Innovation

The 2012 SSPP described future activities that the EPA would undertake, but it 

did not report the EPA’s specific FY 2011 accomplishments for providing agency 

innovation and governmentwide support for meeting the Executive Order goals. 

 

Areas Where Improvements Are Needed

We identified several instances where the EPA lacked sufficient internal controls 

for gathering and reporting data in the 2012 SSPP. We found that the agency: 

 Lacked procedures to ensure that accurate data was reported and generated 

by its contractor.

 Did not have adequate procedures for verifying data accuracy in the 

Federal Electronic Challenge database, which the EPA relies on for 

reporting its electronic stewardship goals.

 Does not have sufficient internal controls to verify performance metrics 

for the EPA’s data centers.

 Lacked procedures for data collection, storage and manipulation measures 

(i.e., record keeping) for several metrics reported in the 2012 SSPP.

 

7 According to the EPA’s Office of Environmental Information, “virtualization” is a “method of partitioning one or 

more physical servers into multiple virtual machines.”

EPA policy requires that all of its retired electronic products 

are reused, donated, sold or recycled using environmentally 

sound management practices (Source: EPA website)
14-P-0325 10

EPA Relies on Contractor to Verify SSPP Data

A majority of the data reported in the 2012 SSPP related to GHG reduction, 

energy use and water use was managed by an EPA contractor. However, 

sufficient internal controls were not in place to verify the data collected and 

generated by the contractor. The EPA only seeks to verify the data if it sees an 

issue or problem with the data during a “visual check.” According to an EPA 

official, first-line facility managers check the data. While there is additional data 

quality review at headquarters, the OIG does not believe these data quality review 

processes are adequate. The EPA relies heavily on its contractor not only to 

collect the data used in the SSPP but to conduct “self-supervised” quality 

assurance reviews. 

Lack of sufficient internal controls resulted in the inclusion of undefined data in 

the SSPP. Specifically, because mileage data for privately owned vehicle usage 

are available on an annual basis only, the contractor did not have corresponding 

quarterly data for privately owned vehicles. The contractor had to use substitute 

privately owned vehicle data to calculate total EPA business travel GHG 

emissions for the second quarter of FY 2011 through the first quarter of FY 2012. 

The EPA deferred to the contractor to explain the substitute data. However, the 

contractor’s response did not explain how the substitute data was developed. The 

EPA’s lack of sufficient internal controls may increase the risk that inaccurate 

data is reported or accomplishments could be over- or understated in the SSPP.

Improved Controls Needed for Electronic Acquisitions Database

The agency did not implement an internal control process that ensures accuracy of 

Federal Electronic Challenge acquisitions. The Federal Electronic Challenge 

database is used to report data related to electronic stewardship goals. Some EPA 

locations that report data to the Federal Electronic Challenge database may 

provide supplemental documentation to validate the data, but this is not 

mandatory. A draft Standard Operating Procedure has been developed, but it has 

not been finalized and distributed to other EPA reporting locations. 

Improved Controls Needed to Verify Data Center Performance Metrics

The EPA does not have sufficient internal controls to verify performance metrics 

for its data centers. As a result, we found that some accomplishments reported in 

the SSPP applied only to the EPA’s National Computer Center in Research 

Triangle Park, North Carolina, rather than to the EPA as a whole. Without 

procedures in place to assure accurate data collection, management and reporting, 

the EPA cannot affirm that the goal related to data centers is being accomplished 

as reported.
14-P-0325 11

Improved Record Keeping Procedures Can Ensure Data Accuracy

We found that the EPA lacked procedures for data collection, storage and 

manipulation measures (i.e., record keeping) for several metrics reported in the 

2012 SSPP. The EPA did not maintain proper documentation on historical vehicle 

data, facility waste diversion records and compliance records for acquisitions. 

As outlined in the EPA Records Management Manual, EPA staff are required to

maintain adequate and proper documentation and evidence of agency activities. 

Inadequate record keeping can mean decisions could appear unsupported and 

undocumented, and work completed may need to be repeated, which creates 

inefficiency. Specifically, we found the following:

 Goal 3 Fleet Management database. Due to system limitations, the 

EPA’s fleet database is incapable of generating or saving historical data on 

the number of fleet vehicles used for emergency response and law 

enforcement. The EPA’s emergency and law enforcement vehicles are 

exempt from federal alternative fuel vehicle acquisition requirements. 

 Goal 5 Waste Diversion. Waste diversion data reported in the 2012 SSPP 

was derived from a questionnaire distributed to EPA facilities and entered 

into a tracking sheet, but the system used to track the information holds 

75 percent rather than 100 percent of the agency’s locations.

 Goal 6 Acquisition. OARM’s Office of Acquisition Management was not 

able to reproduce the same results on the numbers of new EPA contracts 

with green attributes, as they were originally reported in the 2012 SSPP. 

Staff could not explain how the data were collected and analyzed because 

key personnel retired.

Recommendations

We recommend that the Assistant Administrator for Administration and 

Resources Management:

1. Establish procedures for OARM personnel to conduct a quality assurance 

review of SSPP data provided by the contractor and EPA program offices.

2. Develop and implement procedures for maintaining and securing records 

associated with production of annual SSPP data, in accordance with the 

EPA’s Records Management Policy. Specifically, assure that:

a. Fleet data reported in the SSPP are documented and accessible, 

and can be reproduced using either the current fleet database or by 

maintaining copies of historical data reports.
14-P-0325 12

b. SSPP waste diversion data are documented for all facilities that can 

provide it, and specify in future SSPP reports whether the waste 

diversion rates are estimates or only represent specific facilities.

c. Findings and results associated with the acquisitions information in 

the SSPP report can be reproduced, including records of the data 

and methodology used. These records should be properly 

maintained, and should be accessible for the time period required 

by the EPA’s Records Management Policy.

Agency Response to Draft Report and OIG Evaluation

We received comments on the draft report from the OARM and the Office of 

Environmental Information (appendix B). The agency’s response included some 

technical comments, which were incorporated into the final report as appropriate. 

The agency agreed with all recommendations and provided a corrective action 

plan, as well as estimated completion dates for each corrective action. The plan 

provided steps the agency will take to address the recommendations, including 

many actions already in the planning stages. We agree with the EPA’s proposed 

actions and consider recommendations 1 and 2 resolved. The full OIG evaluation

of the agency response is also in appendix B
14-P-0325 13

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 11 Establish procedures for OARM personnel to 

conduct a quality assurance review of SSPP data 

provided by the contractor and EPA program 

offices.

O Assistant Administrator for 

Administration and 

Resources Management 

10/31/14

2 11 Develop and implement procedures for maintaining 

and securing records associated with production of 

annual SSPP data in accordance with the EPA’s 

Records Management Policy. Specifically, assure 

that:

a. Fleet data reported in the SSPP are 

documented and accessible, and can be 

reproduced using either the current fleet 

database or by maintaining copies of 

historical data reports.

b. SSPP waste diversion data are documented 

for all facilities that can provide it, and specify 

in future SSPP reports whether the waste 

diversion rates are estimates or only 

represent specific facilities.

c. Findings and results associated with the 

acquisitions information in the SSPP report 

can be reproduced, including records of the 

data and methodology used. These records 

should be properly maintained, and should 

be accessible for the time period required by 

the EPA’s Records Management Policy. 

O

O

O

Assistant Administrator for 

Administration and 

Resources Management

12/31/14

10/31/14

10/31/14

1 O = Recommendation is open with agreed-to corrective actions pending.

C = Recommendation is closed with all agreed-to actions completed.

U = Recommendation is unresolved with resolution efforts in progress.
14-P-0325 14

Appendix A

Scope and Methodology

We conducted our work from April 2013 to February 2014. We conducted this performance 

audit in accordance with generally accepted government auditing standards. Those standards 

require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a 

reasonable basis for our findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and conclusions based on our 

audit objectives.

We used the 2012 SSPP objectives as the benchmark for assessing how well the agency met its 

goals under Executive Order 13514. We identified requirements for record keeping and internal 

controls.

For each SSPP goal area, we assessed the EPA’s documentation of data origination and 

collection methodology. We conducted interviews of both agency and contractor personnel who 

had direct knowledge of the data collection, management and storage specifics associated with 

the 2012 SSPP. For our review of the EPA’s electronics and data centers, we conducted an onsite 

inspection of the National Computer Center data center at the EPA’s facility in Research 

Triangle Park, North Carolina. We also reviewed utility bills, spreadsheets and guidance 

documents to verify that the EPA had documentation of the original source for all data in the 

2012 SSPP.

To follow up on our recommendation from the April 2011 EPA OIG report, EPA’s Plan to 

Reduce Agency Greenhouse Gas Emissions Is on Track to Meet Executive Order 13514 

Requirements, we reviewed the completed corrective actions taken by the agency and the 

progress made by the agency in meeting its GHG reduction requirements.
14-P-0325 15

Appendix B 

Agency Response to Draft Report and OIG Comments

APR 16 2014

MEMORANDUM

SUBJECT: Response to OIG Draft Report Regarding Internal Climate Change Goals, 

OPE-FY13-0014

FROM: Craig E. Hooks, Assistant Administrator 

TO: Carolyn Copper, Assistant Inspector General 

Office of Program Evaluation 

Thank you for the opportunity to review your draft report, “EPA Met or Exceeded Most Internal 

Climate Change Goals, but Data Quality and Record Management Procedures Need 

Improvement” Project Number OPE-FY13-0014, dated March 5, 2014. It is important that the 

Office of Inspector General recognizes that the EPA met or exceeded most federal sustainability 

requirements under the Executive Order and provided most documentation to support its reported 

FY 2012 accomplishments. The Office of Administration and Resources Management, in 

partnership with other EPA offices and regions, provides environmental and sustainable 

leadership with the federal government. The EPA was one of only three agencies out of 25 

reporting that received a green scorecard on the Office of Management and Budget sustainability 

scorecard for FY 2013. The EPA has achieved a green scorecard the last three years.

OARM offers comments as attachment to this memo. If you have any questions regarding our 

response, please contact me at (202) 564-4600 or Yvette Jackson, deputy director, Facilities 

Management and Services Division, at (202) 564-2030.

Attachments (2)

cc: Renee Wynn 

Nanci Gelb

Renee Page

John Showman

John Bashista

David Updike

Yvette Jackson

Eric Lewis

Asfara Moghis

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF

ADMINISTRATION

AND RESOURCES

MANAGEMENT
14-P-0325 16

Attachment 1

OARM and OEI Response to OIG Draft Report Regarding Internal Climate 

Change Goals Project No. OPE-FY13-0014 March 5, 2014

Response to the Recommendations:

1) Establish procedures for OARM personnel to conduct a quality assurance review of SSPP 

data provided by the contractor and EPA program offices.

OARM response: 

 OARM will update existing standard operating procedures to include federal staff 

sampling of data collected by the contractor to help ensure the accuracy of energy and 

water data. Expected completion: October 31, 2014

 OARM will examine the contractor’s compliance with the SOP for data quality 

control/quality assurance. Expected completion: October 31, 2014

 The EPA will provide more transparency and disclosure regarding its waste diversion 

data in the June 2014 SSPP and subsequent reports. Expected completion: October 

31, 2014

 OARM finalize a draft electronics stewardship SOP to emphasize the internal control 

processes necessary for ensuring accuracy of the EPEAT data reported to the OMB. 

Expected completion: October 31, 2014 (While the new SOP has not been finalized 

or distributed, a memorandum summarizing the new reporting process was distributed 

in November 2013 to the EPA reporting locations.) 

OIG Comment 1: We agree with the EPA’s proposed actions. Recommendation 1 is resolved.

2) Develop and implement procedures for maintaining and securing records associated with 

production of annual SSPP data in accordance with the EPA’s Records Management Policy. 

Specifically, assure that:

a. Fleet data reported in the SSPP are documented and accessible, and can be reproduced 

using either the current fleet database or by maintaining copies of historical data reports.

OARM response:

 OARM will implement changes to the Automotive Statistical Tool database that 

holds fleet management data. Expected completion: December 31, 2014

These changes will include:

 An update to the Vehicle Exemption field of the Master Record that will timestamp 

every change. The data will include the user, date and time of change, and what the 

exemption type was changed to.

 All the necessary back-end code necessary to create and report out on a “point-intime” query snapshot of the fleet.
14-P-0325 17

 A simple front-end tool where users can enter a specific date and AST would return a 

full data spreadsheet of what the fleet looked like on that date.

 OARM will also keep copies of historical data reports regarding fleet vehicles.

OIG Comment 2: We agree with the EPA’s proposed actions. Recommendation 2a is resolved.

b. SSPP waste diversion data are documented for all facilities that can provide it, and 

specify in future SSPP reports whether the waste diversion rates are estimates or only 

represent specific facilities.

OARM response: 

 OARM will report the percent of facilities reporting waste diversion data in the June 

2014 and subsequent SSPPs. Expected completion: October 31, 2014

OIG Comment 3: OARM provided a revised response on May 9, 2014:

OARM will report waste diversion data in a more detailed and transparent 

manner. At a minimum, OARM will include in its report: a list of major facilities, 

whether or not an individual facility on that list reported waste diversion data, the 

waste diversion data reported by that individual facility, and a discussion of the 

methodology used to calculate the agency waste diversion rate derived from the 

individual facility data. OARM will include this in the SSPP due in June 2014 

and in subsequent SSPPs. Expected completion: October 31, 2014.

We agree with the EPA’s revised response and the proposed actions. Recommendation 2b is 

resolved.

c. Findings and results associated with the acquisitions information in the SSPP report can 

be reproduced, including records of the data and methodology used. These records 

should be properly maintained, and should be accessible for the time period required by 

the EPA’s Records Management Policy.

OARM response: 

 OARM will develop procedures to ensure that records used for any future SSPP will 

be properly maintained and accessible for the required time period specified by the 

agency’s records management policy. Expected completion: October 31, 2014.

 OARM is in the process of finalizing a SOP for data extraction and explicit 

methodology used to determine the agency’s compliance with the goals specified in 

Executive Order 13514, Federal Leadership in Environmental, Energy, and Economic 

Performance. Expected completion: October 31, 2014

OIG Comment 4: We agree with the EPA’s proposed actions. Recommendation 2c is resolved.
14-P-0325 18

Response to Findings and Factual Accuracy:

At A Glance

. . . the agency relies heavily on a contractor to collect the data used in the 2012 Strategic 

Sustainability Performance Plan . . . 

OARM response: As demonstrated during the course of this review, OARM collects and reviews 

environmental performance data from many sources, including contractors and EPA 

organizations.

OIG Comment 5: The audit team verified water and GHG data from databases generated, 

collected and maintained by the contractor (i.e., the FY 2011 and FY 2008 Comprehensive 

Inventory Master spreadsheets and the Annual Energy and Water Yearbook). In our meeting 

with the contractor, they explained how they collect data for these areas and enter them into the 

databases. The OIG modified the report as follows:

The agency relies heavily on a contractor to collect water and energy data used in 

the 2012 Strategic Sustainability Performance Plan....

Goal 6: Acquisition page 8

However, we could not confirm the agency’s assertion that it met or exceeded the Executive 

Order requirement to procure 95 percent of new contracts with green attributes for 3 

consecutive years. 

OARM response: We request clarification regarding the exact 3 consecutive years that could not 

be confirmed in the statement.

OIG Comment 6: The years that could not be confirmed were FYs 2009, 2010 and 2011. The 

OIG modified the report as follows:

However, we could not confirm the agency’s assertion that it met or exceeded the 

Executive Order requirement to procure 95 percent of new contracts with green 

attributes for 3 consecutive years (2009, 2010 and 2011).

Goal 7: Electronics and Data Centers pages 8-9

We could not validate the EPA’s claim that “virtualization is extensively used to support 

database hosting” at the EPA’s data centers . . . we found that the agency’s claims about 

virtualization applied to only one of its data center facilities. 

OEI response: OEI does not agree with the report findings regarding data center virtualization 

accuracy. The responses provided in summary and detail demonstrated substantial virtualization

across both NCC and non-NCC data centers. The EPA provided evidence of extensive and 

growing virtualization across the agency, including evidence of 192 Oracle databases hosted on 

virtual platforms within the NCC representing well over 90% of NCC Oracle databases. The 

EPA also provided evidence of over 120 applications and application platforms hosted on virtual 

servers.
14-P-0325 19

OEI believes virtualization is already extensively used to support database hosting, and the EPA 

currently is expanding virtualization to support the Web and application server tiers. The EPA’s 

Federal Data Center Consolidation Initiative 2011 data shown below indicate that the EPA was 

26% virtualized overall and 41% virtualized within the NCC; data for 2012 indicate growth such 

that the agency was 38% virtualized overall and 71% virtualized within the NCC. The agency 

continues to be aggressively virtualizing NCC hosted applications and platforms, which are 

mostly database and Web application platforms.

Year: 2011 Total 

Operating 

Systems

Total Physical Percent 

Physical

Percent 

Virtualized

All EPA 2,906 2,165 75.40% 25.50%

NCC Only 747 441 59.04% 40.96%

Year: 2012 Total 

Operating 

Systems

Total Physical Percent 

Physical

Percent 

Virtualized

All EPA 3,377 2,094 62.01% 37.99%

NCC Only 2,074 597 28.78% 71.22%

OIG Comment 7: The OIG concurs that the agency’s National Computer Center has made 

significant strides in virtualizing its database hosting infrastructure. However, as of 2012, the 

agency’s data centers had only virtualized 38 percent of their hosting infrastructure. 

The OIG modified the report as follows (beginning with sentence 4 after Goal 7: Electronics 

and Data Centers), to reflect the National Computer Center’s progress in the area of database 

hosting virtualization:

We also reviewed the EPA’s claim that “virtualization is extensively used to 

support database hosting” at the EPA’s data centers. Virtualization enables 

multiple operating systems to be located and independently operated from one 

physical server instead of the “one server one operating system” platform 

previously used. The EPA’s implementation of virtualization helps the agency 

become more energy efficient by restructuring processes associated with server 

operations. The consolidation of physical servers can save energy, translating to 

savings of up to 80 percent in data center energy costs while reducing 

infrastructure and capital costs. In this area we found that the EPA’s National 

Computer Center has made significant strides in virtualizing its database hosting 

infrastructure. As of 2012, the National Computer Center had virtualized 

71 percent of its hosted databases. However, as of 2012, all EPA data centers had 

only virtualized 38 percent of their hosting infrastructure. We also found that the 

EPA lacks internal controls to validate its electronics stewardship data.
14-P-0325 20

Areas Where Improvements Are Needed

EPA Relies on Contractor to Verify SSPP Data page 10

A majority of the data reported in the 2012 SSPP related to GHG reduction, water use and local 

planning was managed by an EPA contractor. However, sufficient internal controls were not in 

place to verify the data generated and collected by the contractor. The EPA only seeks to verify 

the data if it sees an issue or problem with the data during a “visual check.” 

OARM response: Utility bills are sent to the contractor for use in preparing the SSPP data. The 

EPA has begun to conduct a sampling review of bills compared to the generated report to verify 

accuracy, and a future metering system will also permit an easier consolidation and verification 

of the data. 

The EPA believes that the “visual check” is an effective control mechanism. The EPA reports 

energy use quarterly, in multiple digital metrics and graphic forms. This includes, but is not 

limited to, current quarter vs. previous year’s quarter performance, rolling four-quarter 

performance data over a 3 year period, and most recent four quarters vs. previous fiscal year. 

These reports are on an individual lab basis and are distributed to HQ facilities staff, HQ 

environmental management systems staff, and every reporting facility as they are issued. 

OARM disagrees that a contractor manages the majority of information regarding “local 

planning.” Information about activities related to “local planning” is collected from many 

sources and no contractor has been tasked with collecting “local planning” participation 

information specifically, nor reports out on this data. 

OIG Comment 8: Since “local planning” includes the partnership of other agencies such as the 

U.S. Department of Transportation and the U.S. Department of Housing and Urban 

Development, the OIG took local planning out of this statement as we recognize this data is 

collected from a variety of sources (i.e., the contractor and EPA). However, the OIG continues 

to believe there is a lack of sufficient internal controls. Based on information provided to the 

audit team, the reporting requirements set by the contractor included the collection of data and 

performing their own quality assurance check. Specifically, according to the contractor 

“the agency sometimes checks data for special projects, for example the Cincinnati Andrew W. 

Breidenbach Environmental Research Center had special projects they were interested in 

looking at in more detail. They do not routinely or frequently ask for utility bills. There is no 

formal process.” The contractor also stated that the agency “does do a bit of a spot check. They 

pay more attention to special projects.” Based on the exit conference between the EPA and the 

OIG, the OIG modified the report to include the following statement (under the section 

EPA Relies on Contractor to Verify SSPP Data):

According to an EPA official, first-line facility managers check the data. While 

there is additional data quality review at headquarters, the OIG does not believe 

these data quality review processes are adequate. 
14-P-0325 21

EPA Relies on Contractor to Verify SSPP Data page 10

Lack of sufficient internal controls resulted in the inclusion of erroneous data in the SSPP. 

Specifically, the contractor did not correctly report business travel emissions reductions for FY 

2011. 

OARM response: We have re-verified reported SSPP emissions data for business travel but 

found no error in the data provided in the plan. In support of this determination, we have 

attached material from our files supporting the statement made in the SSPP executive summary 

regarding reductions in business travel related emissions (See Business Travel Emissions 

attachment). We believe the data provided to the OIG was annual data that is used to meet 

regular reporting requirements, and that the business emissions travel data contained in the 

executive summary was a “special” one-time pull of data (May 2012) to highlight progress and 

the environmental benefits of the video conference initiative started in FY10. The data taken 

from the “special” one-time data pull would not match the regular reporting data provided on a 

fiscal year basis. 

OIG Comment 9: There is no explanation in the SSPP executive summary that would alert the 

reader to the fact that the business emissions travel data contained in the executive summary was 

a “special” one-time pull of data. Nor is the reader alerted to the fact that the data taken from the 

special one-time data pull would not match the regular reporting data provided on a fiscal year 

basis. In fact, any reference or explanation of what a special one-time pull of data is, and its 

impact on the reported SSPP emissions data, is absent from the SSPP. The OIG modified the 

report as follows:

Lack of sufficient internal controls resulted in the inclusion of undefined data in 

the SSPP. Specifically, because mileage data for privately owned vehicle usage 

are available on an annual basis only, the contractor did not have corresponding 

quarterly data for privately owned vehicles. The contractor had to use substitute 

privately owned vehicle data to calculate total EPA business travel GHG 

emissions for the second quarter of FY 2011 through the first quarter of FY 2012. 

The EPA deferred to the contractor to explain the substitute data. However, the 

contractor’s response did not explain how the substitute data was developed.

EPA’s lack of sufficient internal controls may increase the risk that inaccurate 

data is reported or accomplishments could be over- or understated in the SSPP.

Improved Controls Needed for Electronic Acquisitions Database page 10

The agency did not implement an internal control process that ensures accuracy of Federal 

Electronic Challenge acquisitions.

OARM response: For fiscal years 2009 through 2012, the EPA used the Federal Electronics 

Challenge reporting structure to collect and synthesize agencywide electronics stewardship data 

needed to report to the Office of Management and Budget on the agency’s sustainability goals. In 

FY 2012, the FEC announced the end of the awards and data collection program. Beginning 

with FY13 data collection, OARM and OEI agreed on a revised reporting structure and process 

(using legacy FEC contacts) to collect and summarize information on the agency’s acquisition of 

electronics, specifically the EPA’s Electronic Product Environmental Assessment Tool® 
14-P-0325 22

registered product purchases. The new process leverages OARM’s annual environmental 

stewardship reporting process with data accuracy and quality reviews performed at the local site, 

as well as at the centralized/consolidated level. In addition to the new process, the OARM and 

the OEI have collaborated on improving the process further and investigating options for 

improving data and internal quality controls for electronics stewardship. 

OIG Comment 10: The OIG acknowledges that the agency is taking proactive steps in this area 

and concurs with these efforts. 

Improved Controls Needed to Verify Data Center Performance Metrics page 10

The EPA does not have sufficient internal controls to verify performance metrics for its data 

centers. As a result, we found that some accomplishments reported in the SSPP applied only to 

the EPA’s National Computer Center in Research Triangle Park, North Carolina, rather than to 

the EPA as a whole. 

OARM response: NCC is the EPA’s primary application hosting data center and does dominate 

the analysis due to the large concentration (over 60%) of EPA operating systems and 

applications hosted there. However, performance metrics are aggregated for the agency and the 

NCC achievements are accurately included in the aggregate which represents the agency’s 

accomplishments.

OIG Comment 11: The OIG agrees that the National Computer Center is the agency’s primary 

database hosting location and has made significant strides in virtualizing its database hosting 

infrastructure at the National Computer Center. However, as of 2012, all agency data centers 

were only 38 percent virtualized. This distinction was not made in Goal 7 of the SSPP, thereby 

over-representing the agency’s accomplishments in the area of virtualization. Additionally, our 

review in this area found that the EPA did not have controls in place to verify that performance 

data provided was accurate and represented the posture of the entire agency. As a result, the OIG 

found that sufficient internal controls over data verification were not in place. 
14-P-0325 23

Exhibit 2

Annual Rate of GHG Scope 3 Emissions Air and Ground Business 

Travel 4Q FY10 1Q FY11 2Q FY11 3Q FY11 4Q FY 11 1Q FY 12

Current and 3 Previous Quarters Business 

Travel Air and Rental Car Emissions >>>>>>>>>>>> 19,561 18,963 18,995 17,554 15,809 13,987 MTCO2E

Emissions Data by Quarter

FY 2010 FY 2011 FY 2012

1st Qtr 2nd Qtr 3rd Qtr 4th Qtr 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr 1st Qtr

GHG Emissions 

from Air Travel 

(MTCO2e)

4,087 3,669 4,518 4,102 3,579 3,727 3,332 2,660 2,067

GHG Emissions 

from Car 

Rentals 

(MTCO2e)

779 712 900 794 689 686 646 490 379

Total 

(MTCO2e) 4,866 4,381 5,418 4,896 4,268 4,413 3,978 3,150 2,446

Current and 

previous 3 

quarters

MTCO2 

equivalents

4th Q FY 2010 19,561 This metric always gives us 12 months of travel data to compare

1st Q Fy 2011 18,963 This eliminates any regular/seasonal swings in travel by always including

2nd Q Fy 2011 18,995 four quarters of business air and ground travel.

3rd Q Fy 2011 17,554

4th Q FY 2011 15,809

1st Q FY 2012 13,987 72%

28% reduction 

Data is derived from GSA Travel Trax program that pulls in every agencies travel data from the various travel management systems (i.e. gov trip) and

converts them to Metric Tons of CO2 Equivalents emitted. It is used by all/most federal agencies in calcing their Scope 3 Business Air and Travel 

emissions
14-P-0325 24

Appendix C

Distribution

Office of the Administrator 

Assistant Administrator for Administration and Resources Management 

Assistant Administrator for Environmental Information and Chief Information Officer

Agency Follow-Up Official (the CFO) 

Agency Follow-Up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for External Affairs and Environmental Education 

Principal Deputy Assistant Administrator, Office of Administration and Resources Management 

Director, Office of Acquisition Management, Office of Administration and 

Resources Management 

Director, Office of Administration, Office of Administration and Resources Management 

Director, Office of Policy and Resource Management, Office of Administration and 

Resources Management 

Deputy Director, Office of Acquisition Management, Office of Administration and 

Resources Management 

Deputy Director, Office of Policy and Resource Management, Office of Administration and 

Resources Management 

Director, Headquarters Procurement Operations Division, Office of Acquisition Management, 

Office of Administration and Resources Management 

Audit Follow-Up Coordinator, Office of Administration and Resources Management 

Audit Follow-Up Coordinator, Office of Acquisition Management, Office of Administration and 

Resources Management