a

GAO

United States Government Accountability Office

Report to Congressional Requesters

July 2005 CLEAN WATER ACT

Improved Resource 

Planning Would Help 

EPA Better Respond 

to Changing Needs 

and Fiscal Constraints

GAO-05-721
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-721.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact John B. 

Stephenson at (202) 512-3841 or 

stephensonj@gao.gov. 

Highlights of GAO-05-721, a report to

congressional requesters 

July 2005

CLEAN WATER ACT

Improved Resource Planning Would Help 

EPA Better Respond to Changing Needs 

and Fiscal Constraints 

EPA’s process for budgeting and allocating resources is largely based on 

historical precedent and does not fully consider the changing nature or 

distribution of the workload either for specific environmental laws or the 

broader goals and objectives in the agency’s strategic plan. With prior year’s 

allocations as the baseline, year-to-year changes are marginal. EPA’s 

program offices and regions also have some flexibility to realign resources 

based on actual workload. Overall, the impact of these changes is minor, 

according to EPA. Because the nature and distribution of the act’s workload 

has changed as the scope of regulated activities has grown, with EPA gaining 

new responsibilities and shifting others to the states, more than marginal 

changes may be appropriate. EPA does not conduct the periodic “bottomup” assessments of the work that needs to be done, the distribution of the 

workload, or the resources needed to respond more effectively to changing 

needs and constrained resources. 

EPA has developed initiatives that could improve its ability to plan its 

resources more strategically, including efforts that focus on workforce 

planning. These efforts are promising but could be more effective if two 

agencywide initiatives were better coordinated and employee skill surveys 

were designed to identify gaps in needed skills. Beyond these initiatives, 

EPA faces larger challenges in adopting a more systematic process for 

budgeting and resource allocation, particularly in obtaining reliable data on 

key workload indicators. According to EPA officials, data on many of the 

factors that affect workload—and thus, drive resource needs—are not 

comprehensive or reliable. One of the biggest challenges will be assessing 

which of the workload indicators represent the most significant factors in 

determining resource needs. While this assessment presents a challenge, it 

would help EPA set priorities for improving data quality. 

States Authorized to Issue Clean Water Act Permits 

Year

Number of states 

Source: EPA.

0

10

20

30

40

50

General permits

Pretreatment program

Federal facilities

Overall permit

program

1972 1977 1982 1987 1992 1997 2002

Federal and state fiscal constraints 

may jeopardize past and future 

accomplishments resulting from 

the Clean Water Act (the act). In 

this environment, it is important to 

manage available resources as 

efficiently as possible and to 

identify future human capital 

needs, including the size of the 

workforce and its deployment 

across the organization. GAO was 

asked to determine (1) the extent 

to which the Environmental 

Protection Agency’s (EPA) process 

for budgeting and allocating 

resources considers the nature and 

distribution of its Clean Water Act 

workload and (2) the actions EPA 

is taking to improve resource 

planning and the challenges the 

agency faces in doing so. 

What GAO Recommends

Among other things, GAO 

recommends that EPA identify the 

key workload indicators that drive 

resource needs, ensure that 

relevant data are complete and 

reliable, and use the results to 

inform its budgeting and resource 

allocation. In commenting on a 

draft of this report, EPA expressed 

general agreement with much of 

the report and two of the 

recommendations. EPA did voice 

concern that a bottom-up workload 

assessment contrasts with its 

approach, which links budgeting 

and resource allocation to 

performance goals and results. 

GAO continues to believe that 

assessing workload and how it 

drives resource needs is fully 

compatible with EPA’s approach. 
Page i GAO-05-721 Clean Water Act Resources

Contents

Letter 1

Results in Brief 3

Background 5

EPA’s Process for Budgeting and Allocating Resources Does Not 

Fully Consider the Current Workload in Terms of Strategic Goals 

or Specific Laws 8

EPA Has Made Some Progress in Improving Its Resource Planning, 

but Challenges Remain 12

EPA Has Not Developed a Detailed Estimate of the Cost to 

Implement the Clean Water Act, As Required 22

Conclusions 23

Recommendations for Executive Action 23

Agency Comments and Our Evaluations 24

Appendixes

Appendix I: Scope and Methodology 26

Appendix II: Information on Resources Allocated to EPA Regional Offices 

and States for Controlling Point and Nonpoint Source 

Pollution 28

Appendix III: Information on Selected Workload Indicators Related to 

Controlling Point and Nonpoint Source Pollution 35

Appendix IV: Comments from the Environmental Protection Agency 41

Appendix V: GAO Contact and Staff Acknowledgments 43

Tables Table 1: Increasing Workload Associated with Selected Clean 

Water Act Responsibilities Related to Controlling Point 

and Nonpoint Source Pollution Since 1972 6

Table 2: Strategic Plan Goals That Encompass Clean Water Act 

Responsibilities Related to Controlling Point and Nonpoint 

Source Pollution 11

Figures Figure 1: States Authorized to Assume Key Permitting 

Responsibilities, 1972 to 2004 8

Figure 2: Allocation of Funding by the Office of Water under the 

Surface Water Protection Program Project, by EPA 

Region, in Fiscal Years 2004 and 2005 29
Contents

Page ii GAO-05-721 Clean Water Act Resources

Figure 3: Allocation of Staff Years by the Office of Water under the 

Surface Water Protection Program Project, by EPA 

Region, in Fiscal Years 2004 and 2005 30

Figure 4: Estimated Staff Years from the Office of Enforcement and 

Compliance Assurance, by EPA Region, Dedicated to 

Controlling Point Sources under the Clean Water Act 

during Fiscal Years 2004 and 2005 31

Figure 5: Allotments to States for Section 106 Grants, by EPA 

Region, for Fiscal Years 1999 to 2005 33

Figure 6: Allotments to States for Section 319 Grants, by EPA 

Region, for Fiscal Years 1999 to 2005 34

Figure 7: Number of States in Each EPA Region That Are 

Authorized to Issue Individual Permits and the Number of 

States Not Authorized 35

Figure 8: Number of Major and Minor Facilities, by EPA Region 36

Figure 9: Total River and Stream Miles, by EPA Region 37

Figure 10: Total Lake Acres, by EPA Region 38

Figure 11: Percent Change in Population, by EPA Region, 

1990-2004 39

Figure 12: Change in Relative Share of U.S. Population, by EPA 

Region, 1990-2004 40

Abbreviation

EPA Environmental Protection Agency

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Page 1 GAO-05-721 Clean Water Act Resources

United States Government Accountability Office

Washington, D.C. 20548

A

July 22, 2005 Letr

The Honorable James L. Oberstar 

Ranking Democratic Member

Committee on Transportation and Infrastructure

House of Representatives

The Honorable Jerry F. Costello

House of Representatives

The Honorable John F. Tierney

House of Representatives

For over 50 years, the Federal Water Pollution Control Act, commonly 

referred to as the Clean Water Act, has played a critical role in reducing 

water pollution and improving the health of the nation’s waterways.1

 

However, federal and state fiscal constraints may jeopardize these 

accomplishments and make it increasingly difficult to achieve further 

progress in addressing new and existing sources of pollution. In this 

environment, it is important to manage available resources as efficiently as 

possible. The Environmental Protection Agency (EPA), as the federal 

agency primarily responsible for administering the Clean Water Act, plays a 

key role in determining what must be done to meet the act’s requirements, 

identifying the skills needed to accomplish the work, and deploying 

resources to the appropriate entities.

In addition to fiscal constraints, other forces, such as demographic trends 

and technological advances, are challenging government agencies to 

change the way they do business by setting priorities and managing their 

resources to achieve better performance more efficiently. In this context, 

leading private sector organizations have found that ensuring that the right 

people with the right skills are in the right place is critical to achieving 

performance goals. Relatedly, in September 2000, GAO recommended that 

federal agencies develop an explicit workforce planning strategy to identify 

their current and future human capital needs, including the size of the 

workforce; its deployment across the organization; and the knowledge,

1

For consistency, we refer to the statute as the Clean Water Act throughout the report.
Page 2 GAO-05-721 Clean Water Act Resources

skills, and abilities needed for the agency to meet its goals and objectives.2 

GAO further recommended that such a strategy should be explicitly linked 

to the agencies’ mission and strategic and program planning efforts. 

For EPA specifically, both GAO and the National Academy of Public 

Administration have recommended that EPA use data on workload 

requirements and skill needs to better manage resources for its 

environmental programs. For example, in July 2001, GAO recommended 

that EPA collect information on the size of its workforce, the deployment 

of staff geographically and organizationally, and the skills needed to 

support its strategic goals.3

 GAO concluded that a workforce strategy could 

be particularly useful during a time of fiscal constraint because such a 

strategy allows the agency to tailor reductions in a manner that would 

minimize potential adverse impacts on EPA’s programs. 

To carry out its responsibilities under the Clean Water Act, EPA relies on its 

Office of Water, Office of Enforcement and Compliance Assurance, and 10 

regional offices, as well as states’ water pollution control agencies. With a 

number of key amendments beginning in 1972, the scope of the act has 

increased significantly, along with the workload associated with 

implementing and enforcing its requirements. Major changes included, for 

example, controls over pollution from sewer overflows, storm water, and 

animal waste at concentrated feeding operations. At the same time, EPA 

has authorized states to take on more responsibilities, shifting the agency’s 

workload from direct implementation to oversight. Changes in the nature, 

extent, and distribution of the Clean Water Act workload can affect the 

resources needed to carry out the act. In this regard, section 516(b)(1) of 

the act requires, among other things, that EPA provide the Congress with a 

detailed estimate of these costs every 2 years.4

You asked us to determine the (1) extent to which EPA’s process for 

budgeting and allocating resources considers the nature and distribution of 

its Clean Water Act workload and (2) actions EPA is taking to improve 

2

GAO, Human Capital: A Self-Assessment Checklist for Agency Leaders, GAO/OCG-00-14G

(Washington, D.C.: Sept. 1, 2000). 

3

GAO, Human Capital: Implementing an Effective Workforce Strategy Would Help EPA to 

Achieve Its Strategic Goals, GAO-01-812 (Washington, D.C.: July 31, 2001). See also National 

Academy of Public Administration, Setting Priorities, Getting Results: A New Direction for 

EPA (Washington, D.C.: April 1995).

4

33 U.S.C. §1375(b)(1).
Page 3 GAO-05-721 Clean Water Act Resources

resource planning and the challenges it faces in doing so. In addition, we 

determined what effort EPA has made to develop the detailed estimate of 

the cost of carrying out the provisions of the Clean Water Act, as required 

by the act. As agreed with your offices, we focused on EPA and state 

resources associated with implementing and enforcing the major programs 

under the Clean Water Act. Also as agreed, for the purposes of this review, 

we defined EPA’s Clean Water Act workload to include activities associated 

with controls over pollution from specific facilities (called the National 

Pollutant Discharge Elimination System program) and diffuse sources, 

such as agricultural runoff. We also included related activities, such as 

setting water quality criteria and standards, for both specific pollutants and 

individual water bodies; monitoring water quality; and establishing 

requirements for the disposal of sewage sludge. We excluded (1) financial 

assistance for local infrastructure under the Clean Water State Revolving 

Fund; (2) activities for which the primary federal responsibility lay outside 

EPA, such as issuing permits for dredged and fill material, managed by the 

U.S. Army Corps of Engineers; and (3) location-specific programs, such as 

those focused on the Great Lakes, Chesapeake Bay, and designated sites 

under the National Estuary Program. (App. I contains a detailed description 

of our methodology.)

We performed our work between August 2004 and July 2005 in accordance 

with generally accepted government auditing standards.

Results in Brief EPA’s process for budgeting and allocating resources does not fully 

consider the agency’s current workload, either for specific statutory 

requirements, such as those included in the Clean Water Act, or for the 

broader goals and objectives in the agency’s strategic plan. Instead, EPA 

makes incremental adjustments and relies primarily on historical 

precedent. With prior years’ allocations as the baseline, year-to-year 

changes are marginal and occur in response to (1) direction from the Office 

of Management and Budget and the Congress, (2) spending caps imposed 

by EPA’s Office of the Chief Financial Officer, and (3) priorities negotiated 

by senior agency managers. In addition, EPA’s program offices and regions 

have some flexibility to realign resources based on their actual workload, 

but the overall impact of these changes is also minor, according to agency 

officials. Changes at the margin may not be sufficient because both the 

nature and distribution of the Clean Water Act workload have changed as 

the scope of activities regulated under the act has increased and EPA has 

taken on new responsibilities while shifting others to the states. For 

example, controls over pollution from storm water and animal waste at 
Page 4 GAO-05-721 Clean Water Act Resources

concentrated feeding operations have increased the number of regulated 

entities by hundreds of thousands and required more resources in some 

regions of the country. EPA may be unable to respond effectively to 

changing needs and constrained resources because it does not have a 

system in place to conduct periodic “bottom-up” assessments of the work 

that needs to be done, the distribution of the workload, or the staff and 

other resource needs. 

EPA has made progress in improving resource planning, but challenges 

hinder comprehensive reform. Effective resource planning involves 

identifying the tasks that must be accomplished to achieve an 

organization’s objectives, determining the type and level of resources 

needed to carry out the work, and developing a strategy to obtain the 

needed resources. Workforce planning is a key component of any 

successful resource management strategy. While EPA’s initiatives related to 

workforce planning address, to varying degrees, some of its human capital 

management problems, the agency’s efforts could be more effective. For 

example, both the Office of Enforcement and Compliance Assurance and 

the Office of Human Resources surveyed current employees to determine 

the types of skills they possess without first identifying the specific skills 

most needed to accomplish the agency’s mission. As a result, these surveys 

may not necessarily capture the information EPA needs to 

comprehensively determine the skills gap. Although the Office of Human 

Resources subsequently identified priority occupations, needed 

competencies, and skill gaps for the agency as a whole, EPA officials 

acknowledge that this was a high level effort that was not linked to a 

detailed analysis of workload and did not provide specific information on 

the type and deployment of workforce needs. Other efforts by EPA show 

promise in providing useful information, but they are still in the early 

stages. As EPA moves forward with efforts to improve resource planning, it 

faces larger challenges in adopting a more systematic process for 

budgeting and resource allocation: obtaining reliable data on key workload 

indicators, such as the quantity and quality of water in particular areas, and 

overcoming internal resistance. Specifically, according to EPA officials, 

data on many of the factors that affect workload—and thus, drive resource 

needs—are not comprehensive or reliable. In addition, EPA staff may be 

reluctant to adopt a more systematic, data-driven approach to resource 

allocation, because of unsatisfactory experiences with using workload 

models in the 1980s. 

At least in the last few years, EPA has not developed and submitted to the 

Congress the detailed estimate of the cost of carrying out the provisions of 
Page 5 GAO-05-721 Clean Water Act Resources

the Clean Water Act, as required by section 516(b)(1) of the act. According 

to EPA, the agency had been operating under the assumption that the 

requirement had expired. Upon further investigation, EPA acknowledged 

that the requirement was subsequently reinstated. While silent on reports 

required in earlier years, EPA said that the agency had been remiss in not 

producing reports due in 2003 and 2005. Regardless, EPA currently lacks 

the information needed to develop the estimate. For example, in addition to 

problems with the completeness and reliability of the workload data 

needed to support sound cost estimates, EPA’s budget and cost accounting 

systems cannot isolate the resources allocated to Clean Water Act 

enforcement activities. To the extent that EPA improves its resource 

planning and allocation process, and develops the data required to support 

such a process, the agency would also have the information it needs to 

estimate the cost of carrying out the provisions of the Clean Water Act.

We are making recommendations to, among other things, improve EPA’s 

process for budgeting and allocating resources and help EPA comply with 

its reporting requirement under section 516(b)(1).

In commenting on a draft of this report, EPA agreed with our 

recommendation to comply with its reporting requirement and recognized 

that workforce planning strategies we recommended can be effective tools 

for identifying and addressing future performance needs and has already 

begun some of these efforts. However, EPA expressed concern that a 

bottom-up assessment of workload, as we recommended, contrasts with 

the approach it advocates, which links budgeting and resource allocation 

to performance goals and results. While we acknowledge EPA’s concern, 

we believe that assessing the underlying workload and how it drives 

resource needs organizationally and geographically is critical to sound 

workforce planning and can be fully compatible with EPA’s overall 

approach.

Background Through the National Pollutant Discharge Elimination System program, the 

Clean Water Act established the basic structure for regulating discharges of 

pollutants into the waters of the United States, including rivers, lakes, and 

streams. Under this program, EPA and EPA-authorized states issue and 

enforce permits to regulate pollution from specific entities, including, for 

example, industrial dischargers and municipal wastewater treatment 

facilities, known as “point sources.” In support of the permitting program, 

EPA and the states perform a number of important activities, such as 

monitoring water quality and setting limits on the amounts of specific 
Page 6 GAO-05-721 Clean Water Act Resources

pollutants that can be discharged into water bodies. The act also requires 

states to implement management programs for controlling pollution from 

diffuse or “nonpoint” sources, such as agricultural runoff.

To carry out its responsibilities for controlling point and nonpoint source 

pollution, EPA relies on the Office of Water, the Office of Enforcement and 

Compliance Assurance, and 10 regional offices, as well as states’ water 

pollution control agencies. As table 1 shows, since the Clean Water Act was 

amended in 1972, the scope of EPA and state responsibilities and the 

associated workload, has increased significantly.

Table 1: Increasing Workload Associated with Selected Clean Water Act Responsibilities Related to Controlling Point and 

Nonpoint Source Pollution Since 1972

Year

Changes in scope of Clean Water Act-related 

activities

Estimated workload for EPA and states (as of June 

2005)

1972-1973 Clean Water Act, as amended (1972), establishes the 

National Pollutant Discharge Elimination System 

program; EPA issues implementing regulations (1973). 

The amendments also required EPA to oversee total 

maximum daily load calculations by the states.a

• 15,033 municipal wastewater treatment facilities 

(municipal facilities) covered by individual permits

• 30,504 industrial facilities, 785 federal facilities, and 

1,974 other facilities covered by individual permits

• 52,304 facilities covered by general permits

1977-1978 Clean Water Act, as amended (1977), requires publicly 

owned treatment works serving industrial users to 

implement pretreatment programs; EPA issues 

implementing regulations (1978).b

• 1,500 municipal facilities with approved pretreatment 

programs, collectively covering 30,000 industrial facilities

1987 Clean Water Act amended. Among other things, the 

amendments require states to implement nonpoint source 

pollution control programs, establish a framework for 

regulating storm water discharges, and require EPA to 

issue regulations on managing sewage sludge. 

• Includes controls over urban and agricultural runoff, for 

example; workload in different regions of the United 

States varies depending on pollution sources.

1990 EPA issues regulations implementing Phase I of storm 

water permitting program.c 

• 1,000 municipal separate storm sewer systemsd

• 100,000 industrial facilities

• Construction projects larger than 5 acres

1993 EPA issues use and disposal regulations for 

biosolids/sludge.e

• All domestic wastewater treatment facilities

1994 EPA issues policy on combined sewer overflows.f • 748 communities and cities with combined sewer 

systems

1996 States begin establishing total maximum daily loads. • Of nearly 55,000 water quality impairments identified, 

more than 14,000 total maximum daily load requirements 

have been issued with EPA approval.

1999 EPA issues regulations implementing Phase II of storm 

water permitting program.c

• 5,000 municipal separate storm sewer systems

• 80,000 industrial facilities

• Construction projects larger than 1 acre
Page 7 GAO-05-721 Clean Water Act Resources

Source: GAO analysis of EPA data and pertinent legal and regulatory requirements.

Note: We are reporting estimated workload, as of June 2005, because data were not available to 

determine the workload at the time regulatory changes occurred. 

a

A total maximum daily load is a calculation of the amount of a specific pollutant that a specific body of 

water can receive and still meet water quality standards. 

b

Under the pretreatment program, some industrial facilities are required to pretreat their wastewater 

before discharging into sewer systems to remove pollutants that may pass through or interfere with the 

treatment processes at municipal wastewater treatment facilities. 

c

Storm water regulated under the Clean Water Act is defined as runoff from point sources, such as 

industrial facilities, during rain or snow events. In Phase I, EPA regulated storm water discharges from 

larger municipal separate storm sewer systems, and from industrial facilities, including larger 

construction projects. In Phase II, EPA began regulating storm water discharges from smaller 

municipal storm sewers and smaller construction projects.

d

A municipal separate storm sewer system is a system designed for collecting and conveying storm 

water only and is not part of a publicly owned treatment works.

e

Biosolid/sludge is any residue removed during the treatment of municipal wastewater or domestic 

sewage, which can be recycled under certain conditions stipulated by an EPA or state permit.

f

A combined sewer system collects domestic and industrial sewage and rainwater runoff in one system 

of pipes. During periods of heavy rainfall or snowmelt, these systems may overflow, discharging 

untreated sewage into the nation’s waters.

g

A concentrated animal feeding operation is a facility in which animal waste can potentially enter water 

bodies as a result of breaks in waste storage structures or other accidents. 

h

A sanitary sewer system is a wastewater collection system designed to collect and convey only 

domestic sewage from homes and industrial and commercial wastewater. In such systems, storm 

water is conveyed through a municipal separate storm sewer system. As with combined sewer 

systems, however, these systems can overflow and discharge sewage directly into water bodies when 

collection system capacity is exceeded due to wet weather.

Even as the overall workload has increased as a result of these changes, the 

states have been playing a greater role in carrying out required tasks. As 

shown in figure 1, since 1972, EPA has authorized 45 states to perform at 

least some of the permitting activities associated with controlling pollution 

from wastewater treatment and industrial facilities. As EPA authorizes 

states to take on more responsibilities, the agency’s workload shifts from 

direct implementation to oversight.

2003 EPA substantially revises regulations implementing 

permitting requirements for concentrated animal feeding 

operations.g

• 18,000 operations; still in the process of identifying 

dischargers

Ongoing EPA is developing regulations on sanitary sewer 

overflows.h

• 20,428 municipal facilities and satellite collection systems

(Continued From Previous Page)

Year

Changes in scope of Clean Water Act-related 

activities

Estimated workload for EPA and states (as of June 

2005)
Page 8 GAO-05-721 Clean Water Act Resources

Figure 1: States Authorized to Assume Key Permitting Responsibilities, 1972 to 

2004

Note: For certain types of facilities, EPA and the states issue a general permit to cover all facilities with 

stated characteristics.

EPA’s Process for 

Budgeting and 

Allocating Resources 

Does Not Fully 

Consider the Current 

Workload in Terms of 

Strategic Goals or 

Specific Laws

EPA budgets and allocates resources incrementally, largely based on 

historical precedents, and thus its process does not reflect a bottom-up 

review of the nature or distribution of the current workload—either for 

specific environmental laws or the broader goals and objectives in the 

agency’s strategic plan. These historical precedents are drawn from 

workload models EPA had developed in the 1980s, but the distribution of 

EPA’s workload has changed over time as EPA has taken on new 

responsibilities under the Clean Water Act and other laws and the states 

gradually assumed a greater role in the day-to-day implementation of key 

aspects of this workload. Other factors, such as the introduction of new 

technologies and shifts in regional population, have also affected the 

amount, type, and distribution of EPA’s resource needs. 

Year

Number of states 

Source: EPA.

0

10

20

30

40

50

General permits

Pretreatment program

Federal facilities

Overall permit program

1972 1974 1976 1978 1980 1982 1984 1986 1988 1990 1992 1994 1996 1998 2000 2002 2004
Page 9 GAO-05-721 Clean Water Act Resources

Nonetheless, in developing the amounts of its budget request and 

subsequent resource allocations, EPA officials use prior years’ allocations 

as a baseline and make adjustments to reflect (1) direction from the Office 

of Management and Budget and the Congress and (2) spending caps 

imposed by EPA’s Chief Financial Officer, such as ceilings on staff years 

and payroll. For example, guidance from the Office of Management and 

Budget sets overall parameters for the agency’s budget—generally a given 

percentage of the previous year’s budget. Once EPA receives its 

appropriation from the Congress, the agency’s operating plan—which is 

also based on historical precedent—guides the allocation of funding and 

staff years to the organizational units.

While acknowledging that their budgeting and resource allocation is not 

based on a bottom-up review, EPA officials said that the process is linked 

to the agency’s strategic goals and objectives. They told us that the annual 

budgeting and resource allocation process reflects changes in program and 

budget priorities, as determined by senior EPA managers, across the 

agency and within specific program offices. In particular, officials from 

both the Office of Water and Office of Enforcement and Compliance 

Assurance told us that they make strategic decisions in developing the 

agency’s budget—within and across agency goals and objectives—to 

reflect shifting priorities. For example, for fiscal year 2005, EPA asked for 

an additional $22 million for grants to state water pollution control 

agencies, including $17 million to address a need for more water quality 

monitoring. However, EPA officials acknowledged that shifts in funding 

and staff years, as a result of changing priorities, are generally marginal and 

that increases in priority areas are usually offset by decreases in areas of 

lower priority. 

Within the existing system,5

 EPA and state officials have some flexibility to 

realign resources based on actual workload but have not taken full 

advantage of such opportunities.6

 For example:

5

Realigning appropriated resources is subject to statutory language (e.g., earmarks or 

restrictions in appropriations acts) and reprogramming guidelines, which specify how an 

agency might shift funds from one object to another within an appropriations account.

6

While opportunities for more closely linking resources and workload exist, as discussed 

later in this report, some of the data on key workload indicators are not complete or 

reliable. 
Page 10 GAO-05-721 Clean Water Act Resources

• During each budget cycle, EPA’s regional offices have an opportunity to 

influence how the program offices allocate any increases or decreases 

in resources, as reflected in the agency’s operating plan. While, in 

theory, such changes could be directed to the regions based on their 

relative need, regional officials report that most changes are allocated 

based on historical precedent.

• Under section 106 of the Clean Water Act,7

 EPA must distribute grants to 

state water pollution control agencies based on the extent of the 

pollution problem in the respective states. In 1997 and 1998, an EPAstate work group developed a weighted distribution formula that 

considers various workload indicators, such as a state’s surface water 

area, groundwater use, water quality impairment, point and nonpoint 

pollution sources, and population of urbanized areas. The formula, 

currently in regulations, includes a funding “floor,” which stipulates that 

states must receive at least as much as they received in fiscal year 2000, 

unless funding goes down, with an annual adjustment for inflation and 

the current year’s appropriation.8

 Consequently, as EPA regional 

officials pointed out, the allocations do not fully reflect relative 

workloads.

• In 1995, EPA and the states established the National Environmental 

Performance Partnership System, which gave states greater flexibility to 

direct resources to their most pressing environmental problems by 

combining funds from multiple grants. In practice, however, officials in 

EPA’s regional offices and a state environmental organization report 

limited use of the funding flexibility. According to EPA officials, states 

have only used the program to move marginal amounts of money to 

target cross-cutting initiatives or other similar programs. 

In terms of overall structure, EPA has organized its budget requests and 

allocated resources around its strategic plan, rather than specific 

environmental laws or programs.9

 The strategic plan lays out broad agency 

goals and objectives, some of which encompass Clean Water Act 

7

33 U.S.C. §1256.

8

40 C.F.R. §35.162.

9

EPA restructured its fiscal year 2006 budget in response to congressional direction so that 

it is organized by appropriations account and program project. Information on strategic 

goals and objectives is provided as a supplement.
Page 11 GAO-05-721 Clean Water Act Resources

responsibilities for controlling point and nonpoint source pollution. EPA’s 

current strategic plan includes these activities primarily under two goals: 

Clean and Safe Water (Goal 2) and Compliance and Environmental 

Stewardship (Goal 5). As table 2 indicates, however, the objectives and 

subobjectives within each goal can include activities under multiple 

environmental laws. Within the agency’s goal for Clean and Safe Water, for 

example, objectives for protecting water quality, protecting human health, 

and enhancing science and research address requirements under the Safe 

Drinking Water Act and other laws, in addition to those under the Clean 

Water Act. 

Table 2: Strategic Plan Goals That Encompass Clean Water Act Responsibilities Related to Controlling Point and Nonpoint 

Source Pollution

Source: EPA.

Note: Italicized text indicates objectives and subobjectives related to controlling point and nonpoint 

source pollution. Some activities under Goal 4, Healthy Communities and Ecosystems, which includes 

location-specific programs authorized under the Clean Water Act, such as those focused on the Great 

Lakes and Chesapeake Bay, also involve controlling point and nonpoint sources of pollution.

According to officials from EPA’s Office of the Chief Financial Officer, 

Office of Enforcement and Compliance Assurance, and Office of Water, 

isolating the amount of resources dedicated to specific Clean Water Act 

programs and activities would be extremely difficult. The officials said that 

the budgeting and allocation structure aligns resources with goals and 

Goal 2: Clean and Safe Water Goal 5: Compliance and Environmental Stewardship

Objective 2.1: Protect Human Health

• Subobjective 2.1.1: Water Safe to Drink

• Subobjective 2.1.2: Fish and Shellfish Safe to Eat

• Subobjective 2.1.3: Water Safe for Swimming

Objective 2.2: Protect Water Quality

• Subobjective 2.2.1: Improve Water Quality on a Watershed 

Basis

• Subobjective 2.2.2: Improve Coastal and Ocean Waters

Objective 2.3: Enhance Science and Research

• Subobjective 2.3.1: Apply the Best Available Science

• Subobjective 2.3.2: Conduct Leading-Edge Research

Objective 5.1: Improve Compliance

• Subobjective 5.1.1: Compliance Assistance

• Subobjective 5.1.2: Compliance Incentives

• Subobjective 5.1.3: Monitoring and Enforcement

Objective 5.2: Improve Environmental Performance Through 

Pollution Prevention and Innovation

• Subobjective 5.2.1: Prevent Pollution and Promote Environmental 

Stewardship by Government and the Public

• Subobjective 5.2.2: Prevent Pollution and Promote Environmental 

Stewardship by Business

• Subobjective 5.2.3: Business and Community Innovation

• Subobjective 5.2.4: Environmental Policy Innovation

Objective 5.3: Build Tribal Capacity

Objective 5.4: Enhance Science and Research

• Subobjective 5.4.1: Strengthening Science

• Subobjective 5.4.2: Conducting Research
Page 12 GAO-05-721 Clean Water Act Resources

objectives that encompass multiple laws and programs and is not intended 

to provide statute-specific or program-specific breakdowns. The Office of 

Enforcement and Compliance Assurance, in particular, organizes its budget 

into program projects, such as compliance monitoring and civil 

enforcement, that cut across all environmental media. 

Recognizing these difficulties, we asked budget officials within the Office 

of Enforcement and Compliance Assurance and Office of Water to estimate 

the funding and staff years allocated to EPA’s regional offices for 

controlling point and nonpoint source pollution under the Clean Water Act 

and to provide the amounts allotted to the states under two grant programs 

that support such activities at the state level. (See app. II for this 

information.) 

EPA Has Made Some 

Progress in Improving 

Its Resource Planning, 

but Challenges Remain

To plan their resources most effectively, organizations must determine 

what they need to accomplish their work and develop a plan to meet those 

needs by obtaining staff and other resources. EPA has developed several 

initiatives that could improve the agency’s ability to plan its resources more 

strategically, including some efforts that focus on workforce planning and 

others that could provide key information needed to support a data-driven 

approach to budgeting and allocating resources. Beyond these initiatives, 

however, EPA faces larger challenges in adopting a more systematic 

process for budgeting and resource allocation: obtaining reliable data on 

key workload indicators and overcoming internal resistance to adopting 

such a process. 

Effective Resource Planning 

Involves Identifying Staff 

and Other Resources 

Needed to Meet 

Performance Goals and 

Fulfill the Organization’s 

Mission 

At its most basic level, effective resource planning involves identifying the 

specific activities and tasks that must be accomplished to achieve an 

organization’s objectives, determining the type and level of resources 

needed to carry out the work, and developing a strategy to obtain the 

needed resources. Realistically, because organizations rarely have access 

to unconstrained budgets, managers typically have to set priorities so that 

the most important tasks can be accomplished within available resources. 

Particularly in an environment of limited resources, the data that inform 

resource planning are useful in helping decision makers determine how 

best to absorb budget cuts. Because an organization’s employees often 

account for a significant share of its resources, workforce planning is a key 

component of any successful resource management strategy.
Page 13 GAO-05-721 Clean Water Act Resources

Studies by GAO and others have shown that successful organizations use 

strategic workforce planning to identify and fill the gaps between their 

current and future workforce needs in meeting organizational goals and 

fulfilling their overall mission. Strategic workforce planning encompasses a 

broad array of initiatives to attract, retain, develop, and motivate a topquality workforce with the skills needed to meet performance goals. In 

2003, for example, we reported that successful organizations have used 

strategic workforce planning as a tool to both identify current needs and 

anticipate and prepare for upcoming human capital issues, such as an aging 

workforce or changes in mission-critical skills, that could jeopardize the 

accomplishment of goals.10 More recently, we found that leading 

organizations go beyond a succession planning approach that focuses on 

simply replacing individuals and, instead, engage in broad, integrated 

efforts that focus on strengthening both current and future organizational 

capacity. 

Our 2003 report said that an analysis of gaps in an organization’s workforce 

should identify how many employees have the skills and competencies 

needed to meet program goals and the number that are likely to remain 

with the agency over time, given expected losses due to retirement and 

other attrition. Similarly, the report found that a forward-looking analysis 

should identify the specific skills and competencies that will be needed to 

meet future goals. We concluded that workforce gap analyses can be useful 

in justifying budget requests by showing the link between the program 

goals and the staff resources needed to accomplish them. 

In July 2001, we reported specifically on EPA and the extent to which the 

agency was using key management practices associated with successful 

human capital strategies, including strategic workforce planning.11 We also 

examined how EPA’s Office of Enforcement and Compliance Assurance 

deployed resources across the 10 regional offices to ensure consistent 

enforcement of federal environmental requirements. Among other things, 

we recommended that EPA 

• develop a system for workforce allocation and deployment that is 

explicitly linked to the agency’s strategic and program planning efforts 

10GAO, Human Capital: Key Principles for Effective Strategic Workforce Planning, GAO04-39 (Washington, D.C.: Dec. 11, 2003). 

11GAO-01-812. 25, 26.
Page 14 GAO-05-721 Clean Water Act Resources

and that is based on systematic efforts of each major program office to 

accurately identify the size of its workforce, the deployment of staff 

geographically and organizationally, and the skills needed to support its 

strategic goals;

• design succession plans to maintain a sustained commitment and 

continuity of leadership within the agency; and

• target recruitment and hiring practices to fill the agency’s short- and 

long-term human capital needs and, specifically, to fill gaps identified 

through EPA’s workforce planning system and implement training with 

an explicit link to needed competencies.

Our recommendations to EPA’s Office of Enforcement and Compliance 

Assurance expanded on some of the same themes. For example, we 

recommended that the office develop a systematic method for deploying 

resources to address the agency’s enforcement workload, taking into 

account the workforce planning information needed to analyze the 

workload. According to our report, such information should include the 

level of resources currently being allocated to specific enforcement 

activities; the factors that determine the enforcement workload in each 

region; and the specific skills needed to address each region’s workload, 

along with the number of employees who possess such skills.

EPA Has Several Efforts 

Under Way to Improve 

Resource Planning

EPA has initiated several efforts that could improve the agency’s ability to 

strategically plan its workforce and other resources. While some of these 

efforts are not directly related to workforce planning, they could give the 

agency some of the information needed to support a systematic, datadriven method for budgeting and allocating resources. 

Three initiatives within EPA focus specifically on workforce planning, 

including one by the Office of Enforcement and Compliance Assurance, 

which focused on civil enforcement activities and was completed in 2003, 

and two agencywide efforts that are still in the early stages of development. 

The agencywide efforts are being managed by EPA’s Office of Human 

Resources and the Office of the Chief Financial Officer. These three 

initiatives are as follows: 

• Workforce Deployment Review for civil enforcement activities. In 

response to our July 2001 report, the Office of Enforcement and 

Compliance Assurance surveyed about 2,600 headquarters and regional 
Page 15 GAO-05-721 Clean Water Act Resources

employees engaged in civil enforcement activities to identify existing 

workforce skills and specific areas of programmatic expertise.12 EPA’s 

report on the survey, issued in October 2003, recommended, among 

other things, expanding the survey to include all of the office’s 

employees, periodically updating the information, and aligning training 

with national priorities.13 In addition, the report recognized that 

circumstances have changed since the 1980s, when EPA last used the 

workload models to establish a baseline. The report concluded that 

enforcement officials should reexamine the existing practice of 

adjusting staff levels based on historical precedent.

• Strategic workforce planning process. In response to guidance from the 

Office of Management and Budget, EPA’s Office of Human Resources is 

currently working on a strategic workforce planning process to help 

EPA identify and address skill needs agencywide. Human Resource 

officials believe that EPA should be using detailed workforce plans to 

drive its budget requests and make informed decisions about how to 

make the best use of the resources it receives. The new planning 

process includes (1) analyzing the skills needed to achieve agency goals 

now and in the future, (2) assessing the skills possessed by the current 

workforce, (3) identifying any current or future gaps in critical skills, 

and (4) developing strategies to fill such gaps. During 2003, the Office of 

Human Resources piloted a computer-based tool designed to capture 

information on the skills possessed by EPA staff but abandoned the 

effort in response to complaints that the tool was overly complicated 

and did not provide helpful information. In 2004, the office’s workforce 

planning team reviewed the agency’s strategic plan and other relevant 

studies and interviewed key stakeholders inside and outside EPA to 

develop a strategic picture of the agency’s future work and workforce 

requirements. The team corroborated its findings with senior EPA 

executives, who provided their views on the work that the agency will 

be doing in the future and described the workforce in terms of the 

priority, mission-critical competencies, and occupations needed to 

12The skills assessment represents one element of the information needed to support a 

systematic method for deploying enforcement resources to address the agency’s workload. 

We also recommended that the office develop other information, such as the level of 

resources currently being allocated to specific enforcement activities and the factors that 

determine the enforcement workload in each region. However, enforcement officials 

indicated that internal time constraints limited their ability to address these issues. 

13EPA, The Workforce Deployment Review, Executive Steering Committee Report

(Washington, D.C.: October 2003).
Page 16 GAO-05-721 Clean Water Act Resources

support the work. As a result of this effort, EPA identified 18 priority 

occupations, 12 technical competencies, and 12 cross-occupational 

competencies that are essential for the agency to accomplish its future 

mission. In addition, based on projected retirements and other attrition, 

EPA identified potential gaps in critical areas. Currently, the office is 

examining any ongoing resource planning efforts by EPA regional and 

program offices before moving ahead with its own planning process. 

• Options for an agency approach to workforce assessment. EPA’s Office 

of the Chief Financial Officer formed a work group in the fall of 2004 to 

improve the agency’s tools for making decisions on distributing staffing 

resources. The work group is currently exploring options for how 

frequently to measure workload: doing a comprehensive assessment of 

all programs every 3 to 5 years or applying a screening tool to identify 

certain high-priority program areas for annual assessment. 

Although EPA’s workforce planning initiatives address, to varying degrees, 

some of the recommended practices for managing human capital, its 

efforts could be more effective. For example, both the Office of 

Enforcement and Compliance Assurance and the Office of Human 

Resources attempted to determine the types of skills they possess without 

first identifying the skills most needed to accomplish the agency’s mission. 

As a result, these surveys may not necessarily capture the information EPA 

needs to comprehensively determine the skills gap. Although the Office of 

Human Resources followed up its skills survey by identifying priority 

occupations, needed competencies, and skill gaps for the agency as a 

whole, EPA characterized the effort as an assessment at the “20,000 foot” 

level. Human Resource officials acknowledged that the effort was not 

linked to a detailed analysis of workload and did not provide information 

on region- or program-specific workforce needs. To guide the office’s 

development of ground-level analyses, during the spring of 2005, the office 

surveyed program and regional offices to determine the nature of any 

localized workforce planning. In addition, although officials involved in the 

two agencywide initiatives (sponsored by the Office of Human Resources 

and the Office of the Chief Financial Officer) were aware of the parallel 

efforts, we found little evidence that the two offices were coordinating with 

each other to avoid duplication or the adoption of conflicting strategies. 

Both these efforts are still in the early stages; coordinating now would 

allow the agency to ensure that it is making the best use of its resources.

Two other initiatives within the Office of Water, while not directly related to 

resource planning, could provide relevant and useful information for a 
Page 17 GAO-05-721 Clean Water Act Resources

data-driven approach to budgeting and allocating resources. For example, 

beginning in December 1998, EPA and the states collaborated on a state 

resource analysis for water quality management to develop an estimate of 

the resources that states need to fully implement the Clean Water Act. The 

primary focus of the project was identifying the gap between states’ needs 

and available resources. To develop the estimates of the gap, EPA and the 

states created a detailed model of activities associated with implementing 

the Clean Water Act, the average time it takes to complete such activities, 

and the costs of performing them.14 The National Academy of Public 

Administration subsequently reviewed the model and determined that the 

underlying methodology was sound.15 In fact, the academy recommended 

that EPA and the states refine the model to support data-driven grant 

allocation decisions. According to EPA and representatives of state 

environmental organizations, however, the agency has not implemented the 

recommendation because of resource constraints and reluctance on the 

part of some states.

Another initiative by the Office of Water, called the Permitting for 

Environmental Results Strategy, also has potential to provide useful 

information for more effective resource planning. This effort began in 2003, 

prompted by circumstances that were making it increasingly difficult for 

EPA and the states to meet their responsibilities under the Clean Water Act. 

According to EPA, not only had the scope and complexity of the act 

expanded over time, but the states were facing an increasing number of 

lawsuits and petitions to withdraw their authorization to administer some 

Clean Water Act programs. As part of its effort to identify and resolve 

performance problems in individual states, EPA and the states have been 

developing profiles containing detailed data on the responsibilities, 

resources, and workload demands of each state and region—information

14According to the project’s interim report, issued in April 2002, the total estimated needs for 

states to fully implement the Clean Water Act ranged from $1.54 billion to $1.68 billion 

annually. Based on current spending levels, the report estimated an annual resource gap 

ranging from $735 million to $960 million.

15National Academy of Public Administration, Understanding What States Need to Protect 

Water Quality (Washington, D.C.: December 2002).
Page 18 GAO-05-721 Clean Water Act Resources

that could be useful in any comprehensive and systematic resource 

planning method.16

Challenges to Adopting a 

More Systematic Process 

for Allocating Resources 

Include Obtaining Reliable 

Workload Data and 

Overcoming Internal 

Resistance

Perhaps the most significant obstacle to developing a systematic, datadriven approach to resource allocation is ensuring that needed data on 

EPA’s workload are complete and reliable. While our particular interest was 

Clean Water Act activities for controlling point and nonpoint source 

pollution, evidence suggests that EPA would encounter similar reliability 

concerns if a systematic resource allocation process were to be organized 

around strategic goals and objectives, thus encompassing other program 

areas.17 Without comprehensive and reliable data on workload, EPA cannot 

accurately identify where agency resources, such as staff with particular 

skills, are most needed.

According to EPA officials, some of the key workload factors related to 

controlling point and nonpoint source pollution include the number of 

point source dischargers, the number of wet weather dischargers, and the 

quantity and quality of water in particular areas.18 However, for some of this 

information, the relevant databases, such as the Permit Compliance 

System, which contains information on discharging facilities, and the 

National Water Quality Inventory, which contains information on water 

quality, have been subject to criticism from several sources, including GAO. 

For example: 

• Discrepancies between Permit Compliance System and state data. In 

2001, the Environmental Council of the States reported that of 42 states 

surveyed, more than 80 percent found “significant and pervasive data 

discrepancies” between data tracked by state authorities and data 

contained in the Permit Compliance System. Even among states that 

reported using EPA’s database as their primary information system, 75 

16Among other things, the profiles contain information on a wide range of activities that 

comprise state and regional workload, including monitoring water quality, permitting, 

inspecting permitted facilities, and taking enforcement actions. In collecting data for these 

profiles, the Office of Water also worked with states to resolve data quality problems.

17See, for example, GAO, Environmental Information: EPA Needs Better Information to 

Manage Risks and Measure Results, GAO-01-97T (Washington, D.C.: Oct. 3, 2000).

18EPA uses the term wet weather discharges to include sewer overflows, concentrated 

animal feeding operations, and storm water from municipal separate storm sewer systems 

and from industrial facilities. 
Page 19 GAO-05-721 Clean Water Act Resources

percent found errors in the data. Another problem is that the last system 

modernization effort was in 1982; as a result, the database does not 

contain information on more recently regulated entities, such as storm 

water dischargers and concentrated animal feeding operations. The 

database also lacks complete information on the point source 

dischargers it does track, particularly smaller facilities and states’ 

enforcement actions. Although at one time EPA linked states’ grant 

funding to the submission of facility data to the database, the agency 

discontinued the policy. In addition, EPA does not require complete 

information on minor facilities.19 

• Lack of historical data in Permit Compliance System. EPA’s Permit 

Compliance System database does not provide sufficient information to 

evaluate trends in key workload indicators because the system 

overwrites older information whenever program officials enter new data 

on a facility. Thus, for example, EPA cannot generate trend data on the 

number of permits issued or renewed over a specified time period. After 

related criticism from EPA’s Inspector General, Office of Water officials 

told us that, in 1999, they began pulling data from the system at regular 

intervals to provide data on trends in the agency’s permitting backlog 

and the number of regulated facilities. At the same time, however, EPA 

began to clean up its inventory, eliminating data on facilities that were 

no longer in existence. Although the cleanup was necessary, it also 

affected the agency’s ability to develop reliable trend data. For these and 

other reasons, EPA identified the Permit Compliance System as an 

agency weakness beginning in 1999. 

• Data limitations in the National Water Quality Inventory. Data on the 

quality of the nation’s waters, which EPA compiles and presents in the 

National Water Quality Inventory, are also subject to important 

limitations.20 While the majority of states contributed data describing 

rivers and lakes, data on other types of water bodies were less 

comprehensive. For example, only nine states provided information on 

19EPA classifies facilities (including municipal wastewater treatment plants and industrial 

and federal facilities) as major or minor, depending on the risk to the environment posed by 

the pollutants being discharged from the facility; the volume of pollutants being discharged; 

and, in the case of municipal wastewater treatment facilities, the size of the population 

being served. 

20The most recent year for which the full National Water Quality Inventory is available is 

2000. EPA has posted water quality information from the 2002 inventory for approximately 

30 states on its Web site but has not yet issued the full inventory.
Page 20 GAO-05-721 Clean Water Act Resources

the status of their wetlands. In addition, states are only able to assess a 

portion of their waters every 2 years. For example, according to the 2000 

report, states assessed 19 percent of the nation’s total river and stream 

miles and 43 percent of the total lake, pond, and reservoir acres. 

Furthermore, states do not report data consistently. In 2002, GAO found 

that variations in the approaches that states use to assess water quality 

causes inconsistencies in the listing of impaired waters.21 These 

inconsistencies also limit the ability to compare data from year to year. 

While acknowledging that some data are missing from the Permit 

Compliance System, EPA officials told us that since 2001, they have worked 

with the states and regional offices to clean up the data and believe that 

their efforts have improved data quality. The officials also said that the 

system will be modernized into the Integrated Compliance Information 

System, which will be phased in beginning in 2006. According to 

information provided by EPA, the modernization effort will identify the 

data elements to be entered and maintained by the states and regions and 

will include additional data entry for minor facilities and special regulatory 

program areas, such as concentrated animal feeding operations, combined 

sewer overflows, and storm water. Regarding the National Water Quality 

Inventory, the Office of Water recently began advocating the use of 

standardized, probability-based, statistical surveys of state waters so that 

water quality information would be comparable both among states and 

from year to year. 

We did not attempt to compile an exhaustive list of all factors that 

potentially affect EPA and state workload. Although the state water quality 

management resource analysis compiled a comprehensive list of activities 

performed in support of the Clean Water Act to serve as a basis for 

estimating the state resource needs, there is no similar analysis of 

workload indicators for EPA headquarters or regional offices. In addition 

to the factors discussed above, EPA officials and representatives of state 

environmental organizations identified other factors that directly or 

indirectly affect workload and thus could provide some indication of 

resource needs. Some factors were mentioned consistently by all or most 

of the officials we interviewed and other factors were cited less frequently. 

One of the challenges to improving data quality will be determining which 

of the workload indicators represent the most significant drivers of 

21GAO, Water Quality: Inconsistent State Approaches Complicate Nation’s Efforts to 

Identify Its Most Polluted Waters, GAO-02-186 (Washington, D.C.: Jan. 11, 2002).
Page 21 GAO-05-721 Clean Water Act Resources

resource needs. Making this determination, however, would also help EPA 

prioritize efforts to improve data quality.

More complete data are available on some of the workload factors 

identified by EPA and representatives of state environmental organizations, 

including the number of states authorized to implement aspects of the 

permitting program, the number of major and minor facilities, water 

quantity, and population. While these data may not be adequate in all 

respects, we believe the data are sufficiently reliable to illustrate potential 

differences in the regional distribution of workload. Appendix III contains 

a series of figures displaying selected workload indicators. 

Even with better workload data, EPA would find it difficult to implement a 

systematic, data-driven approach to resource allocation without staff 

support for such a process. Support may not be easily forthcoming. 

According to EPA officials in several offices and regions, staff are reluctant 

to accept a data-driven approach because of their experience in using 

workload models during the 1980s. At that time, each major program office 

used a model to allocate resources to the agency’s regional offices. When 

the models were initially developed, agency officials believed they were 

useful because EPA’s programs were rapidly expanding as the Congress 

passed new environmental laws. Over time, however, the expansion of 

EPA’s responsibilities leveled off, and its impact on the relative workload of 

regions was not as significant. The change in the rate of the workload 

expansion, combined with increasingly constrained federal resources 

during the late 1980s, meant that the workload models were only being 

used to allocate changes at the margins. The agency stopped using the 

models in the early 1990s because, according to officials, staff spent an 

unreasonable amount of time negotiating relatively minor changes in 

regional resources. 

Officials at EPA headquarters and regional offices cited some of the same 

concerns when we asked about applying a more systematic approach to 

budgeting and allocating resources today. Officials in several offices 

maintained that such an approach would not be useful for the agency, in 

part because EPA would not obtain increased resources as a result. 

Because all programs have insufficient resources, officials explained, it 

would not necessarily be helpful to analyze where these resource gaps 

were largest. Some regional officials were more supportive of the use of 

workforce planning, particularly where officials believed the region was 

receiving fewer resources than it deserved relative to other regions. 

Regional officials also believed that this type of analysis would help them 
Page 22 GAO-05-721 Clean Water Act Resources

manage the resources they get and could provide information that could 

stave off additional funding cuts or reduce how frequently headquarters 

officials implement new requirements for the regions.

EPA Has Not 

Developed a Detailed 

Estimate of the Cost to 

Implement the Clean 

Water Act, As Required

Section 516(b)(1)(A) of the Clean Water Act requires EPA, in cooperation 

with the states, to make a detailed estimate of the cost of carrying out the 

provisions of the act.22 Such estimates must be reported to the Congress 

every 2 years. In response to our inquiries, EPA issued a letter on May 2, 

2005, stating that the agency has been operating under the assumption that 

the requirement had expired as of December 1999. However, the letter 

acknowledged that the reporting requirement may have been reinstated. 

After studying the issue further, EPA issued a follow-up letter on May 16, 

2005, which confirmed that the requirement had been reinstated and that 

the agency had been remiss in not producing reports due in 2003 and 

2005.23 EPA’s letter was silent regarding the reports due in 1999 and prior 

years.

Even if EPA had been aware of the reporting requirement, it currently lacks 

the information needed to develop an estimate of the cost of carrying out 

the Clean Water Act. First, the process EPA uses to budget and allocate 

resources is built around available resources rather than an unconstrained 

budget. Second, EPA’s budget structure and cost accounting systems do not 

provide specific detail on how EPA staff spend their time in carrying out 

Clean Water Act enforcement responsibilities within the Office of 

Enforcement and Compliance Assurance, where the budget is organized 

around activities that cut across all environmental media. Finally, as 

already described, EPA lacks complete and reliable data on key aspects of 

its Clean Water Act workload, making it difficult to develop sound cost 

estimates. Having better information on specific workload activities would 

not only help improve EPA’s process for budgeting and allocating resources 

within its current budget structure, but it would also help EPA develop the 

cost estimates needed to comply with section 516(b)(1)(A).

2233 U.S.C. § 1375(b)(1)(A). 

23The reporting requirement was eliminated by section 3003(a) of the Federal Reports 

Elimination and Sunset Act of 1995, which took effect on December 21, 1999. Section 

302(a)(10) of the Great Lakes and Lake Champlain Act of 2002 reinstated the requirement as 

of November 27, 2002. No report was required in 2001.
Page 23 GAO-05-721 Clean Water Act Resources

Conclusions Because EPA does not have a system in place to conduct periodic bottomup assessments of the work that needs to be done, the distribution of the 

workload, or staff and other resource needs, the agency may be unable to 

respond effectively to changing needs and constrained resources. Despite 

some flexibility in budgeting and allocating resources, EPA cannot 

determine whether the amount and distribution of its resources are 

appropriate to effectively carry out its strategic goals and objectives or 

meet its responsibilities under the Clean Water Act and other 

environmental laws. Moreover, EPA does not have the information it needs 

to tailor reductions in staff or other resources in a manner that minimizes 

potential adverse impacts on its environmental programs. 

Having complete and reliable data on the activities and tasks that must be 

accomplished—and how that work is distributed organizationally and 

geographically—will help EPA budget and allocate resources more 

effectively. In addition, such data will inform the agency’s workforce 

planning efforts and help ensure that the right people with the right skills 

are where they need to be to get the work done.

EPA is obligated to meet its reporting responsibilities under section 

516(b)(1) of the Clean Water Act. Periodic bottom-up assessments of the 

workload and related resource needs would give EPA the tools it needs to 

develop this detailed estimate, as required. 

Recommendations for 

Executive Action

We recommend that the Administrator, EPA, identify the key workload 

indicators that drive resource needs, ensure that relevant data are 

complete and reliable, and use the results to inform the agency’s budgeting 

and resource allocation. 

Furthermore, to ensure that EPA is making the best use of resources 

dedicated to strategic workforce planning, we also recommend that EPA 

coordinate ongoing planning efforts across the agency to avoid duplication. 

EPA’s workforce planning efforts should build on what the agency has 

accomplished thus far in identifying priority occupations, needed 

competencies, and skill gaps for the agency as a whole. As a next step, 

consistent with our 2001 recommendations, EPA should focus its efforts on 

a ground level assessment and identify (1) the agency’s workload and skill 

needs; (2) the skills and deployment of existing staff, geographically and 

organizationally; and (3) strategies to fill identified gaps.
Page 24 GAO-05-721 Clean Water Act Resources

Finally, we recommend that EPA meet its reporting responsibilities under 

section 516(b)(1) of the Clean Water Act or seek appropriate relief from the 

Congress.

Agency Comments and 

Our Evaluations

We provided a draft of this report to EPA for review and comment. EPA 

agreed with our recommendation regarding its reporting responsibilities 

under section 516(b)(1) of the Clean Water Act and plans to respond 

according to the requirements of the law. While not addressing our 

recommendation on eliminating potential duplication of effort, EPA 

acknowledged that the workforce planning strategies we recommended 

can be effective tools for identifying and addressing future performance 

needs and stated that it has already initiated several of these efforts. EPA 

also noted that our report raises important issues affecting the distribution 

of constrained resources. However, the agency noted that its resource 

allocation decisions are based on performance and results and expressed 

concern that a bottom-up assessment of the underlying workload 

contrasted with its approach. We do not take issue with the use of 

performance and results in developing budgets and allocating resources, 

although, based on our review, EPA’s budget and resource allocations were 

based primarily on historical precedent and, hence, year-to-year changes 

were marginal. Moreover, we believe our recommendation is fully 

compatible with an approach that links budgeting and resource allocation 

to performance goals and results. In our view, the agency’s performance 

goals should be informed by an assessment of the underlying workload—

and how the tasks that must be accomplished drive resource needs 

organizationally and geographically. Finally, EPA officials also provided a 

number of technical comments and clarifications, which we incorporated 

as appropriate. EPA’s comments are in appendix IV.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to appropriate congressional 

committees; the Administrator, EPA; and the Director of the Office of 

Management and Budget. We also will make copies available to others 

upon request. In addition, the report will be available at no charge on the 

GAO Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me 

at (202) 512-3841 or stephensonj@gao.gov. Contact points for our Offices of 
Page 25 GAO-05-721 Clean Water Act Resources

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix V.

John B. Stephenson

Director, Natural Resources

and Environment
Page 26 GAO-05-721 Clean Water Act Resources

Appendix I

Scope and Methodology ApApenednxidexiIs

We defined the scope of our review to include Clean Water Act programs 

for controlling pollution from point and nonpoint sources and related 

activities, such as setting water quality criteria and standards, for both 

specific pollutants and individual water bodies; monitoring water quality; 

and establishing requirements for the disposal of sewage sludge. We 

excluded (1) financial assistance for local infrastructure under the Clean 

Water State Revolving Fund; (2) activities for which the primary federal 

responsibility lay outside the Environmental Protection Agency (EPA), 

such as issuing permits for dredged and fill material, managed by the U.S. 

Army Corps of Engineers; and (3) location-specific programs, such as those 

focused on the Great Lakes, Chesapeake Bay, and designated sites under 

the National Estuary Program. We performed our work at EPA’s Office of 

Congressional and Intergovernmental Relations; Office of the Chief 

Financial Officer; Office of Enforcement and Compliance Assurance; Office 

of General Counsel; Office of Human Resources; and Office of Water in 

EPA’s Washington, D.C., headquarters. We also obtained information from 

four EPA regional offices located in Atlanta, Ga.; Boston, Mass.; 

Philadelphia, Pa.; and San Francisco, Calif. Our criteria for selecting these 

offices included differences in how the offices are organized to implement 

the Clean Water Act, differences in the factors that drive their workload, 

and geographic distribution.

For information on EPA’s process for budgeting and allocating resources, 

we interviewed officials from the Office of the Chief Financial Officer and 

other EPA offices with responsibility for Clean Water Act programs to 

control pollution from point and nonpoint sources, including the Office of 

Congressional and Intergovernmental Relations, Office of Enforcement 

and Compliance Assurance, and Office of Water. Among other things, we 

reviewed relevant portions of EPA’s strategic plan, budget data, and 

operating plan. We also obtained (1) estimates of the funding and staff 

years allocated to EPA’s regional offices and (2) allotments to the states 

under two relevant grant programs. While these data may not be adequate 

in all respects, we determined that they were sufficiently reliable to 

illustrate differences in the relative share of resources across EPA’s 

regional offices. In the four EPA regional offices selected for review, we 

discussed the budgeting and allocation process with cognizant officials. 

For information on EPA’s efforts to improve resource planning, we 

interviewed officials from EPA’s Office of the Chief Financial Officer, Office 

of Enforcement and Compliance Assurance, Office of Human Resources, 

and Office of Water, as well as the Association of State and Interstate Water 

Pollution Control Administrators, the Environmental Council of States, and 
Appendix I

Scope and Methodology

Page 27 GAO-05-721 Clean Water Act Resources

the National Academy of Public Administration to identify such efforts and 

obtain relevant documents on their status and results. Officials from these 

entities and the four EPA regional offices selected for review also provided 

information on the challenges EPA faces in taking actions to improve 

resource planning. In particular, we researched sources of data for the 

workload factors identified by EPA officials and state environmental 

officials as among the key drivers of resource needs. For some factors, 

such as number of authorized states in EPA regions, states for which EPA 

has direct implementation responsibilities, population, and population 

growth, we determined that the data were sufficiently reliable for our 

purposes. Regarding other factors, such as number of facilities and water 

quality, we found the data to be incomplete or unreliable for certain states 

or regions, for certain years, or for certain types of facilities or water 

bodies. As a result, we were unable to analyze these data for workload 

trends or geographic distribution.1

 We found them sufficiently reliable to 

provide illustrative examples. To identify key elements of strategic 

workforce planning, we reviewed reports from GAO, EPA’s Office of 

Inspector General, and the National Academy of Public Administration. 

For information on EPA efforts to develop the detailed cost estimate 

required under section 516(b)(1)(A) of the Clean Water Act, we interviewed 

officials from EPA’s Office of the Chief Financial Officer, Office of General 

Counsel, and Office of Water. 

We conducted our work from August 2004 through July 2005 in accordance 

with generally accepted government auditing standards.

1

See pages 19-21 for additional information on our efforts to assess data reliability for 

certain workload indicators.
Page 28 GAO-05-721 Clean Water Act Resources

Appendix II

Information on Resources Allocated to EPA 

Regional Offices and States for Controlling 

Point and Nonpoint Source Pollution ApendxiI

Across the Environmental Protection Agency (EPA), the program offices 

track the funds and staff years dedicated to the goals and objectives laid 

out in the agency’s strategic plan, down to a level of detail known as 

program projects. The plan’s objectives generally contain multiple program 

projects and the reverse may also be true: an individual program project 

can contribute funds or staff years to multiple agency objectives. For 

example, within the Office of Water, most of the resources applicable to 

controlling point and nonpoint source pollution under the Clean Water Act 

are included under the program project called Surface Water Protection 

and the projects for categorical grants on Pollution Control (Section 106) 

and Nonpoint Source (Section 319). However, the Surface Water Protection 

program project contains resources for a broader range of activities than 

those included within our scope. At the same time, some of the resources 

that are relevant to controlling point and nonpoint source pollution are 

included in program projects that contain resources for other Clean Water 

Act and Safe Drinking Water Act-related activities.

We asked Office of Water officials to provide a regional breakdown of the 

funding contained in the Surface Water Protection program project (see fig. 

2).1

 Fiscal years 2004 and 2005 are the only years for which consistent data 

are available because the program project for Surface Water Protection 

was created in 2004.

1

EPA’s regional offices are located in the following cities: Boston, Mass. (I); New York, N.Y. 

(II); Philadelphia, Pa. (III); Atlanta, Ga. (IV); Chicago, Ill. (V); Dallas, Tex. (VI); Kansas City, 

Mo. (VII); Denver, Colo. (VIII); San Francisco, Calif. (IX); and Seattle, Wash. (X).
Appendix II

Information on Resources Allocated to EPA 

Regional Offices and States for Controlling 

Point and Nonpoint Source Pollution

Page 29 GAO-05-721 Clean Water Act Resources

Figure 2: Allocation of Funding by the Office of Water under the Surface Water 

Protection Program Project, by EPA Region, in Fiscal Years 2004 and 2005 

Region

Dollars (in millions)

Source: EPA.

0

2

4

6

8

10

12

2005

2004

1 2 3 4 5 6 7 8 9 10
Appendix II

Information on Resources Allocated to EPA 

Regional Offices and States for Controlling 

Point and Nonpoint Source Pollution

Page 30 GAO-05-721 Clean Water Act Resources

Figure 3 provides a similar breakdown in terms of regional staff years. 

Figure 3: Allocation of Staff Years by the Office of Water under the Surface Water 

Protection Program Project, by EPA Region, in Fiscal Years 2004 and 2005

Within the Office of Enforcement and Compliance Assurance, it is difficult 

to isolate resources dedicated specifically to implementing the Clean Water 

Act or other environmental statutes because the office organizes its budget 

by program projects, such as compliance monitoring and civil enforcement, 

that cut across all environmental media. Beginning in fiscal year 2000, 

however, the office’s budget officials asked the regional offices to provide a 

“best guess estimate” of the number of staff years devoted to particular 

program areas, including activities related to controlling point sources 

under the Clean Water Act. (See fig. 4.) The budget officials indicated that 

this exercise likely does not capture all relevant staff years and said that 

they did not verify the regional estimates. Fiscal years 2004 and 2005 were 

the only years for which complete data were available.

Region

Dollars (in millions)

Source: EPA.

0

2

4

6

8

10

12

2005

2004

1 2 3 4 5 6 7 8 9 10
Appendix II

Information on Resources Allocated to EPA 

Regional Offices and States for Controlling 

Point and Nonpoint Source Pollution

Page 31 GAO-05-721 Clean Water Act Resources

Figure 4: Estimated Staff Years from the Office of Enforcement and Compliance 

Assurance, by EPA Region, Dedicated to Controlling Point Sources under the Clean 

Water Act during Fiscal Years 2004 and 2005

The Office of Enforcement and Compliance Assurance does not develop 

similar estimates for the amount of funding allocated to the regional 

offices. Although budget officials suggested that we could estimate 

regional spending based on the average cost of a staff year, regional 

officials said such an approach might be misleading because the cost of 

staff years varies from year to year and region to region.

Region

Staff years

Source: EPA.

8%

10%

29%

28%

0

10

20

30

40

50

2005

2004

1 2 3 4 5 6 7 8 9 10
Appendix II

Information on Resources Allocated to EPA 

Regional Offices and States for Controlling 

Point and Nonpoint Source Pollution

Page 32 GAO-05-721 Clean Water Act Resources

The states receive annual allotments from the Office of Water under two 

major grant programs. Grants under section 106 of the Clean Water Act 

provide funds for water quality monitoring, regulating point source 

dischargers, and related activities. Grants under section 319(h) of the act 

fund the implementation of state programs for controlling pollution from 

nonpoint sources, such as agricultural runoff.2

 Figures 5 and 6 show 

allotments to the states, by region, under the program projects for Pollution 

Control (Section 106) and Nonpoint Source (Section 319).

2

33 U.S.C. §1329(h). 
Appendix II

Information on Resources Allocated to EPA 

Regional Offices and States for Controlling 

Point and Nonpoint Source Pollution

Page 33 GAO-05-721 Clean Water Act Resources

Figure 5: Allotments to States for Section 106 Grants, by EPA Region, for Fiscal Years 1999 to 2005

Region

Dollars (in millions)

0

5

10

15

20

25

30

35

1999

2000

2001

2002

2003

2004

2005

1 2 3 4 5 6 7 8 9 10

Source: EPA.
Appendix II

Information on Resources Allocated to EPA 

Regional Offices and States for Controlling 

Point and Nonpoint Source Pollution

Page 34 GAO-05-721 Clean Water Act Resources

Figure 6: Allotments to States for Section 319 Grants, by EPA Region, for Fiscal Years 1999 to 2005

Region

Dollars (in millions)

1999

2000

2001

2002

2003

2004

2005

0

5

10

15

20

25

30

35

40

45

1 2 3 4 5 6 7 8 9 10

Source: EPA.
Page 35 GAO-05-721 Clean Water Act Resources

Appendix III

Information on Selected Workload Indicators 

Related to Controlling Point and Nonpoint 

Source Pollution ApendxiI

This appendix contains information on selected workload indicators for 

which the underlying data are sufficiently reliable to illustrate potential 

differences in the regional distribution of workload. 

Figure 7 shows the number of states in each Environmental Protection 

Agency (EPA) region that are authorized to issue individual permits under 

the Clean Water Act and the number of states for which EPA retains direct 

implementation responsibility. The number of authorized states in a given 

region affects workload in several ways, including the number of staff 

devoted to oversight. When states are not authorized, regional officials 

have greater responsibilities, such as writing permits for regulated entities.

Figure 7: Number of States in Each EPA Region That Are Authorized to Issue 

Individual Permits and the Number of States Not Authorized

Note: Puerto Rico, which is unauthorized, and the U.S. Virgin Islands, which is authorized, are 

included in the count of states for region 2. The District of Columbia, which is unauthorized, is included 

in the count of states for region 3. American Samoa, Guam, and the Northern Mariana Islands, all of 

which are unauthorized, are included in the count of states for region 9. Tribal lands are not included 

for any region. 

Region

Number of states

Source: EPA.

0

1

2

3

4

5

6

7

8

States not authorized

States authorized

1 2 3 4 5 6 7 8 9 10
Appendix III

Information on Selected Workload Indicators 

Related to Controlling Point and Nonpoint 

Source Pollution

Page 36 GAO-05-721 Clean Water Act Resources

Figure 8 shows the regional distribution of major and minor facilities, 

including both municipal and industrial dischargers. Although these data 

are from EPA’s Permit Compliance System, for which concerns about data 

reliability are significant, EPA officials believe that the information on the 

number of facilities is adequate. 

Figure 8: Number of Major and Minor Facilities, by EPA Region

One of the key workload indicators cited by EPA and representatives of 

state environmental organizations was the quantity of surface waters that 

must be assessed and monitored to obtain a complete picture of water 

quality. These assessments may, in turn, trigger other resource-intensive 

activities, such as establishing total maximum daily loads. Figures 9 and 10 

portray the miles of rivers and streams and the acres of lakes in each EPA 

region, according to the 2002 update of the National Hydrography Dataset, 

which was first compiled by the U.S. Geological Survey in 1992.

Region

Number of facilities

Source: EPA.

0

5,000

10,000

15,000

20,000

25,000

Number of minor facilities with general permits

Number of major facilities

1 2 3 4 5 6 7 8 9 10
Appendix III

Information on Selected Workload Indicators 

Related to Controlling Point and Nonpoint 

Source Pollution

Page 37 GAO-05-721 Clean Water Act Resources

Figure 9: Total River and Stream Miles, by EPA Region

Note: Region 10 does not include data on miles of rivers and streams in Alaska.

Region

Miles (in thousands)

Source: EPA.

0

100

200

300

400

500

600

700

1 2 3 4 5 6 7 8 9 10
Appendix III

Information on Selected Workload Indicators 

Related to Controlling Point and Nonpoint 

Source Pollution

Page 38 GAO-05-721 Clean Water Act Resources

Figure 10: Total Lake Acres, by EPA Region

Note: Region 10 does not include data on acres of lakes in Alaska.

The National Hydrography Dataset does not contain detailed information 

on wetlands. The most recent information on wetlands was compiled in 

1997 by the U.S. Fish and Wildlife Service. However, the information is no 

longer considered accurate because, for example, the Fish and Wildlife 

Service estimates that the United States loses 58,500 acres of wetlands 

annually.

EPA identified population and population growth as indirect indicators of 

workload, which are not necessarily linked to resource needs. For 

example, while a large population may indicate that the region has a large 

number of municipal wastewater treatment facilities, the population may 

be concentrated in a few large cities with centralized facilities, resulting in 

fewer individual facilities than otherwise expected. Similarly, growth in 

population might indicate that EPA and state staff will need to regulate 

more construction sites. However, the work required of environmental 

officials could vary depending on the number and size of these sites in each 

region. Figure 11 shows the census population estimates for the EPA 

regions for 1990 and 2004, along with the percentage increase in each 

Region

Acres (in millions)

Source: EPA.

0

1

2

3

4

5

6

7

1 2 3 4 5 6 7 8 9 10
Appendix III

Information on Selected Workload Indicators 

Related to Controlling Point and Nonpoint 

Source Pollution

Page 39 GAO-05-721 Clean Water Act Resources

region.1 We used 1990 as the starting point for this comparison because it 

was shortly after EPA abandoned the use of workload models in the late 

1980s. 

Figure 11: Percent Change in Population, by EPA Region, 1990-2004

Note: The District of Columbia is included in the population count for region 3.

Figure 12 presents a slightly different picture of the same population data. 

It shows the change in the relative share of the U.S. population in each 

region between 1990 and 2004.

1

The 2004 census data are based on state estimates from 2004.

Region

Population (in millions)

Source: Census.

8%

9% 10%

26%

10%

25%

27%

10%

29%

28%

0

10

20

30

40

50

60

2004

1990

1 2 3 4 5 6 7 8 9 10
Appendix III

Information on Selected Workload Indicators 

Related to Controlling Point and Nonpoint 

Source Pollution

Page 40 GAO-05-721 Clean Water Act Resources

Figure 12: Change in Relative Share of U.S. Population, by EPA Region, 1990-2004

Note: The District of Columbia is included in the population count for region 3.

Region

Percentage of U.S. population

Source: Census.

0

5

10

15

20

2004

1990

1 2 3 4 5 6 7 8 9 10
Page 41 GAO-05-721 Clean Water Act Resources

Appendix IV

Comments from the Environmental 

Protection Agency ApendxiIV
Appendix IV

Comments from the Environmental 

Protection Agency

Page 42 GAO-05-721 Clean Water Act Resources
Page 43 GAO-05-721 Clean Water Act Resources

Appendix V

GAO Contact and Staff Acknowledgments ApendxiV

GAO Contact John B. Stephenson (202) 512-3841

Staff 

Acknowledgments

In addition to the individual named above, Christine Bonham, Stephen 

Cleary, Ellen Crocker, Elizabeth Curda, Denise Fantone, Julian Klazkin, 

Krista Loose, Naved Qureshi, Lisa Shames, Carol Herrnstadt Shulman, 

Gregory Wilmoth, and Melissa Wolf made key contributions to this report.

(360511)
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