AUDIT REPORT IG-03-013 

Report Recipients: 

H/Assistant Administrator 

 for Procurement 

J/Assistant Administrator 

 for Management Systems

NASA NONCOMPLIANCE WITH WASTE 

REDUCTION REQUIREMENTS 

May 30, 2003 

cc: 

JM/Director, Management 

 Assessment Division 

NASA Center Directors 

 National Aeronautics and 

Space Administration

OFFICE OF INSPECTOR GENERAL 

Released by: ___[original signed by] __

David M. Cushing, Assistant Inspector General for Auditing 
NASA Office of Inspector General 

IG-03-013 May 30, 2003 

 A-01-011-00 

NASA Noncompliance With Waste Reduction Requirements 

We performed this audit to determine whether NASA effectively complied with the 

requirements of Executive Order (EO) 13101, “Greening the Government Through Waste 

Prevention, Recycling and Federal Acquisition,” September 14, 1998, and the Resource 

Conservation and Recovery Act (RCRA). One of the Federal government’s goals for 

protecting the environment is to lead waste reduction efforts by using recycled and 

environmentally preferable products. EO 13101 and Section 6002 of RCRA require 

agencies to meet this goal by implementing affirmative procurement programs to increase 

the use of recycled and environmentally preferable products. Details regarding the audit 

objectives, background, scope, and methodology are in Appendix C. 

We found that NASA’s affirmative procurement program needs improvements. 

• Centers were not obtaining waivers to justify purchases of certain nonrecycled 

products because Center personnel were not aware that a waiver was required and 

because a waiver process did not exist at one Center. 

• The Federal Acquisition Regulation (FAR) clauses related to waste reduction and 

using products containing recovered materials were not included in applicable 

support services contracts because the contracting officers had not received 

adequate training or guidance on the FAR requirements. 

• The Agency Environmental Executive (AEE) needs to be at a higher level to meet 

EO requirements. 

NASA Should Justify Purchases of Certain Products Without Recycled Content 

NASA’s affirmative procurement program is not fully compliant with EO 13101 and 

RCRA. The Environmental Protection Agency (EPA) has designated 56 products that 

agencies are to purchase with recycled content whenever feasible. These products 

include building insulation, carpet, cement, concrete, latex paint, printer ribbons, toner 

cartridges, printing paper, and engine coolants. EPA-designated products are general 

product categories that may or may not contain recycled content, depending upon the 

manufacturer, supplier, or other factors. For example, printing paper is available from 

many sources, some of which provide paper produced from only new materials. Other 

sources provide paper manufactured with recycled materials. Therefore, even though a 

product is EPA-designated, it may not contain the required recycled content. 

NASA Procedures and Guidelines (NPG) 8830.1, “Affirmative Procurement for 

Environmentally Preferable Products,” February 1999, requires that when NASA 

purchases EPA-designated products, the items must contain recycled content unless the 

purchaser obtains a written waiver. Under the waiver process, a procurement request 
2

originator must furnish a request for a waiver to his or her Center environmental 

manager, or a designee, for approval before the purchase of a product without the 

required recycled content. A waiver may be obtained if the products with recycled 

content are not available competitively within a reasonable time frame, do not meet 

appropriate performance standards, or are available only at an unreasonable price. 

For FYs 2000 and 2001, NASA purchased about $16.2 million of EPA-designated 

products. About $5.9 million (36.4 percent) of this total was for product purchases that 

required a waiver (that is, the products did not have the required recycled content). 

However, no waivers were prepared for any of the purchases included in the 2-year 

period even though the NASA Centers, except for the Johnson Space Center, had a 

waiver process. NASA purchases that were not supported by waivers increased from 30 

percent in FY 2000 to 42 percent in FY 2001 (see Appendix E). 

The NASA AEE stated that contracting officers were not aware of affirmative 

procurement program requirements because of a lack training on the requirements. This 

official also believed that the lack of emphasis on compliance at the Center level may 

have contributed to an ineffective program. Center officials also acknowledged that the 

lack of training and emphasis contributed to an ineffective program. 

Required FAR Clauses Not Included in NASA Contracts 

Contracting officers can obligate contractors to comply with EO and RCRA requirements 

by incorporating certain FAR clauses in NASA contracts. The FAR requires that certain 

clauses directing contractors to reduce waste and to use products containing recovered 

materials be included in contracts that provide for or support the operation of NASAowned facilities. From August 1, 2000, through October 30, 2001, NASA awarded 60 

such contracts valued at more than $1.0 billion. Most of those contracts should have 

included, but did not include the applicable FAR clauses: 

• 50 (83.3 percent) of the 60 contracts did not include FAR clause 52.223-10, 

which requires contractors to establish waste reduction programs, and 

• 55 (91.7 percent) contracts omitted FAR clauses 52.223-4 and 52.223-9, which 

require contractors to certify that they will use at least the amount of recovered 

materials required by the applicable contract specifications and to estimate the 

percentage of recovered materials used during the performance of the contract. 

(see Appendix F). 

Contracting officers play a vital role in ensuring that NASA and its contractors fully 

achieve the benefits associated with reducing waste and buying recycled products. 

NASA officials at both Headquarters and the Centers attributed the lack of inclusion of 

the clauses by the contracting officers to a lack of training and to a lack of emphasis on 

compliance with the requirements of the EO, RCRA, and the FAR. In addition, NASA 

Procurement Management Surveys, which are used to monitor the effectiveness of 
3

internal controls over Center procurement processes, did not identify that contracting 

officers had not included the applicable FAR clauses in contracts and, therefore, were not 

useful in ensuring that the requirements were met. 

Agency Environmental Executive Position Is Not at the Level Required 

The EO requires that the NASA Administrator establish the NASA AEE position at the 

Assistant Administrator level to help ensure that EO objectives are given appropriate 

visibility and management attention throughout the Agency. The NASA Administrator 

initially designated the Associate Administrator for Management Systems and Facilities 

(now known as the Assistant Administrator for Management Systems) to be the NASA 

AEE. However, NASA’s Assistant Administrator for Management Systems 

subsequently designated the Director of the Environmental Management Division as the 

AEE for NASA and assigned tasks supporting many AEE responsibilities to the Principal 

Center for Recycling and Affirmative Procurement, which is located at the Kennedy 

Space Center. According to the Assistant Administrator and Environmental Management 

Division officials, confusion over the appropriateness of delegating AEE responsibilities 

to lower organization levels may have existed, because a prior EO and NPG 8830.1 

permitted delegation to a lower-level organization. 

Delegating the AEE position to a lower-level organization reduced the effectiveness of 

the AEE position. The Center environmental managers we interviewed believed they did 

not have enough influence to ensure that program and procurement personnel complied 

with the EO, RCRA, and FAR requirements and that program direction was needed from 

a level higher than the Environmental Management Division at Headquarters or the 

Principal Center. The Centers’ noncompliance with EO and RCRA requirements for 

purchasing products containing recycled content and the award of contracts without the 

required FAR clauses indicate that the AEE is not at a high enough level to ensure 

appropriate management attention is given to the affirmative procurement program. 

Recommendations for Corrective Action 

We recommended that the Assistant Administrator for Management Systems, in 

coordination with the Assistant Administrator for Procurement, emphasize the 

affirmative procurement requirements in NPG 8830.1 and provide training on EO and 

RCRA requirements for applicable personnel. We also recommended that the Director, 

Johnson Space Center, direct the appropriate officials to implement a waiver process for 

EPA-designated products in accordance with NPG 8830.1. 

In addition, we recommended that the Assistant Administrator for Procurement provide 

training for contracting officers on affirmative procurement requirements and include a 

review for affirmative procurement clauses in Procurement Management Surveys. 

Further, we recommended that the Assistant Administrator for Management Systems 

revise NPG 8830.1 to address the requirements of the EO and immediately assume the 

role of the AEE. 
4

Management’s Response and our Evaluation of the Response 

NASA concurred with the report recommendations and has initiated corrective actions. 

We consider management’s comments (see Appendix H) to be responsive to the 

recommendations. Details related to disposition of the recommendations are in 

Appendices A and G. 

Appendices 

Among the appendices, note that Appendix B includes background on applicable laws 

and regulations; Appendix C describes objectives, scope, and methodology; and 

Appendix D includes a summary of prior audits on affirmative procurement. In addition, 

Appendix E summarizes NASA purchases of EPA-designated products, and Appendix F 

identifies contracts that should include FAR requirements. Appendix I shows the report 

distribution. 
5

List of Appendixes 

Appendix A – Status of Recommendations 

Appendix B - Background 

Appendix C – Objectives, Scope, and Methodology 

Appendix D – Prior Audit Coverage 

Appendix E – NASA Purchases of EPA-Designated Products 

Appendix F – Contracts That Should Include FAR Requirements 

Appendix G – Recommendations, Management’s Response, and Evaluation 

of Management’s Response 

Appendix H – Management’s Response 

Appendix I – Report Distribution 

Acronyms 

AEE Agency Environmental Executive 

EO Executive Order 

EPA Environmental Protection Agency 

FAR Federal Acquisition Regulation 

FY Fiscal Year 

NPG NASA Procedures and Guidelines 

RCRA Resource Conservation and Recovery Act 
6

Appendix A. Status of Recommendations 

Recommendation No. Resolved Unresolved Open/ECD* Closed 

1 X 7/31/03 

2 X 5/31/04 

3 X 9/30/03 

4 X 5/31/04 

5 X 7/31/03 

6 X 5/31/04 

7 X 6/30/03 

*Estimated completion date. 
7

Appendix B. Background 

RCRA Requirements. Section 6002 of the RCRA, dated October 21, 1976, required the 

Administrator of the EPA to develop and publish guidelines for solid waste management that are 

to be followed by the Government and the private sector. The RCRA required each procuring 

agency needing these designated products to procure products composed of the highest 

percentage of recovered materials practicable consistent with maintaining satisfactory contract 

competition. The RCRA further specified that procuring agencies did not have to purchase 

products meeting guidelines if such products: 

(A) Are not reasonably available within a reasonable period of time; 

(B) Fail to meet the performance standards set forth in the applicable specifications 

or fail to meet the reasonable performance standards of the procuring agencies; 

or 

(C) Are only available at an unreasonable price. 

Executive Orders 12873 and 13101. As a follow-on to the RCRA requirements, EO 12873, 

“Federal Acquisition, Recycling, and Waste Prevention,” issued October 20, 1993, and its 

replacement EO 13101, “Greening the Government through Waste Prevention, Recycling, and 

Federal Acquisition,” issued September 14, 1998, served to improve the Federal Government’s 

use of recycled products and environmentally preferable products and services. The EOs 

required NASA to designate an AEE to assure NASA's compliance with the requirements. The 

RCRA required NASA to establish affirmative procurement programs for all EPA-designated 

guideline products purchased by the Agency above the threshold of $10,000. Both EOs required 

100 percent of NASA’s purchases of the EPA-designated guideline products to meet or exceed 

the guidelines unless NASA’s procurement request originators provided written justifications 

that the products were not available competitively within reasonable time frames, did not meet 

appropriate performance standards, or were available only at unreasonable prices. In addition, 

the EO’s required the AEE to track agency purchases of guideline products and to report the 

purchases to the Federal Environmental Executive. The Federal Environmental Executive is 

designated by the President and is located within the EPA. 

FAR Clause Requirements. These clauses require contractors to comply with EO and RCRA 

requirements concerning recovered materials and waste reduction. 

• FAR Clause 52.223-10, "Waste Reduction Program." This clause requires 

contractors to establish programs to promote cost-effective waste reduction in all 

operations and facilities covered by Government contracts. FAR Subpart 23.7, 

“Contracting for Environmentally Preferable and Energy-Efficient Products and 

Services,” requires this clause to be incorporated into all solicitations and contracts 

for contractor operation of Government-owned or -leased facilities and all 

solicitations and contracts for support services at Government-owned or -operated 

facilities. 
8

Appendix B

• FAR Clause 52.223-4, "Recovered Material Certification." This clause requires 

contractors to certify that the percentage of recovered materials to be used in 

performing their contracts will be at least the amounts required by the applicable 

contract specifications. FAR Subpart 23.4, “Use of Recovered Materials,” requires 

this clause to be inserted in solicitations that are for, or specify the use of, recovered 

materials. 

• FAR Clause 52.223-9, "Estimate of Percentage of Recovered Material Content 

for EPA-Designated Products." This clause requires contractors to estimate the 

percentages of recovered materials content for the EPA-designated products used in 

contract performance upon completion of the contracts, including, if applicable, the 

percentages of postconsumer material content. FAR Subpart 23.4 requires this clause 

to be included in solicitations and contracts exceeding $100,000 that include FAR 

Clause 52.223-4. 

These FAR clauses are limited in scope, and contractors are required to comply only if the 

specific clauses are included in their contracts. 

NASA Implementing Guidelines. NASA issued NPG 8830.1, “Affirmative Procurement for 

Environmentally Preferable Products,” in February 1999 to establish standard procedures for 

procuring environmentally preferable goods and services to the maximum extent possible 

consistent with requirements in EO 13101, FAR Part 23, and NASA policy and directives. The 

NPG, signed by the former Administrator, specifies that the Associate Administrator for the 

Office of Management Systems and Facilities (now the Assistant Administrator for Management 

Systems) was to function as the AEE for NASA. The NPG also provides that the AEE position 

could be delegated to lower management levels within the Agency. 

Further, the NPG assigns various responsibilities to the Centers: implementing a Center 

awareness program to promote affirmative procurement; advising procurement request initiators 

on acquisition strategies for environmentally preferable products and services; ensuring that 

Center procurements comply with the EO unless a waiver is approved; and reporting these 

purchases to the Principal Center. 

In addition, the NPG established a waiver process to document the approval to purchase products 

that do not meet EPA guidelines. The NPG requires the procurement request originator to obtain 

an approved request for a waiver before the purchase of a product that does not meet EPA 

requirements for recovered materials. The procurement request originator must furnish the 

approved waiver to the contracting officer for acquisition of the product and for documentation 

for the contract files. The NPG states that waivers are permitted only for products that cannot be 

acquired competitively within a reasonable time, or meet appropriate performance standards, or 

at a reasonable price. 
9

Appendix C. Objectives, Scope, and Methodology

Objectives

The overall audit objective was to determine whether NASA adequately complied with 

EO 13101, “Greening the Government Through Waste Prevention, Recycling, and Federal 

Acquisition.” Specifically, we evaluated NASA’s compliance with EO 13101 and efforts to 

incorporate the FAR clauses related to EO and RCRA requirements into applicable contracts. 

Our original objectives also included evaluating waste reduction initiatives implemented in 

response to the EO. We found that NASA implemented waste reduction initiatives to 

significantly reduce the amount of waste NASA generates for landfills and to save costs. 

However, the extent of savings will occur over the long term and cannot be fully evaluated at 

this time. We also evaluated NASA’s actions to identify and assess opportunities for 

consolidating waste reduction activities with other collocated Federal agencies and offices. 

NASA Centers have implemented several initiatives with other Federal agencies that may 

provide environmental benefits. NASA may have additional opportunities to consolidate waste 

reduction activities with other Federal agencies, but taking advantage of these opportunities will 

require the cooperation of the other agencies. 

Scope and Methodology 

We reviewed applicable NASA and Federal regulations and policies. We visited NASA 

Headquarters to identify actions taken by the Office of Management Systems, the Environmental 

Management Division, and the Office of Procurement to comply with the requirements of EO 

13101. Additionally, we evaluated the following at Kennedy Space Center (Kennedy), Marshall 

Space Flight Center (Marshall), and Wallops Flight Facility (Wallops): 

• Compliance with the requirements of EO 13101; Section 6002 of RCRA; and 

NPG 8830.1, “Affirmative Procurement Plan for Environmentally Preferable Products.” 

• NASA’s efforts to incorporate the FAR clauses related to EO and RCRA requirements 

into applicable contracts. 

Based on our work at Kennedy, Marshall, and Wallops, we developed questionnaires for the 

remaining Centers and requested information to determine whether the Centers complied with 

EO 13101 and Section 6002 of RCRA, how they implemented the affirmative procurement 

program, and whether appropriate clauses had been included in NASA contracts. Additionally, 

we interviewed the Deputy Chief, Office of the Federal Environmental Executive, to gain insight 

into the intent of the EO and RCRA. 

We used computer-processed reports from NASA Headquarters and Kennedy to determine the 

volume of purchases of EPA-designated products. We selectively tested the data by comparing 

it to Center-provided data to determine its reliability and concluded that the data was reliable. 
10

Appendix C

Management Controls Reviewed 

We reviewed the management controls relative to the implementation of EO 13101 and Section 

6002 of RCRA. Specifically, we reviewed documentation related to the delegation of the NASA 

AEE and taskings to the Principal Center. We also reviewed the process and controls over 

purchasing EPA-designated items and the inclusion of the FAR clauses in applicable contracts. 

We concluded that NASA’s affirmative procurement program needs to be strengthened as 

described in this report. 

Audit Field Work 

We conducted field work from February 2001 through August 2002 at NASA Headquarters, 

Kennedy, Marshall, and Wallops. We performed the audit in accordance with generally 

accepted government auditing standards. 
11

Appendix D. Prior Audit Coverage 

In June 2001, the General Accounting Office issued a report entitled, "Federal Procurement, 

Better Guidance and Monitoring Needed to Assess Purchases of Environmentally Friendly 

Products." The General Accounting Office found it could not determine the extent to which the 

large procuring agencies, including NASA, were procuring EPA-designated products because 

the agencies lacked reliable and complete data on contractor purchases of these products. The 

agencies did not have adequate systems to track purchases of EPA-designated products by their 

contractors. NASA concurred with the draft report and endorsed the General Accounting 

Office’s recommendations for executive action. 

The NASA Office of Inspector General issued Report IG-99-051, "Audit of Environmental 

Aspects of External Tank Contract NAS8-36200," September 24, 1999. The audit found that the 

external tank contract had not been modified to incorporate the Federal waste reduction program 

as set forth under the FAR, and as a result, adverse environmental effects may not have been 

minimized and potential recycling benefits could not be realized. 

The NASA Office of Inspector General also issued Report IG-98-017, “Kennedy Space Center’s 

Recycling Efforts,” June 12, 1998. The audit found that Kennedy did not collect and report 

accurate recycling data, which did not allow for reasonable measurements of program 

accomplishments. In addition, Kennedy had no collection procedures to retain proceeds from its 

recycling program, which resulted in $141,431 in revenue not being available to Kennedy for 

funding additional recycling projects. 
Appendix E. NASA Purchases of EPA-Designated Products 

 Fiscal Year 2000 Fiscal Year 2001 

Facility 

Total 

Amount 

Purchased 

Amount 

Requiring 

Waiver 

Percentage 

Requiring 

Waiver 

Total 

Amount 

Purchased 

Amount 

Requiring 

Waiver 

Percentage 

Requiring 

Waiver 

Total 

Amount 

Purchased 

R

Ames Research  Center 

$396,355 $94,045 23.7 $281,960 $196,811 69.8 $678,315 

Dryden Flight  Research Center 

73,048 59,316 81.2 25,028 15,870 63.4 98,076 

Glenn Research  Center 

516,775 195,575 37.8 719,759 672,364 93.4 1,236,534 

Goddard Space  Flight Center 

1,436,165 729,689 50.8 960,564 288,190 30.0 2,396,729 

Headquarters 116,104 6,399 5.5 18,985 14,939 78.7 135,089 Jet Propulsion  Laboratory 

1,171,821 341,996 29.2 1,372,763 448,781 32.7 2,544,584 

Johnson Space  Center 

1,151,005 222,697 19.3 709,080 343,375 48.4 1,860,085 

Kennedy Space  Center 

1,583,435 477,996 30.2 1,922,076 453,145 23.6 3,505,511 

Langley Research  Center 

272,652 32,904 12.1 573,771 215,001 37.5 846,423 

Marshall Space  Flight Center 

917,178 28,409 3.1 785,259 479,181 61.0 1,702,437 

Michoud Assembly  Facility 

241,004 151,322 62.8 170,334 83,315 48.9 411,338 

Stennis Space  Center 

189,185 96,882 51.2 293,425 139,419 47.5 482,610 

White Sands Test  Facility 

169,889 38,182 22.5 143,456 27,820 19.4 313,345 

Total $8,234,616 $2,475,412 30.1 $7,976,460 $3,378,211 42.4 $16,211,076 $

Source: Center/Facility reports of EPA-designated products to NASA’s Agency Environmental Executive. Note: Goddard Space Flight Center also includes Wallops Flight Facility data. 

12 
Appendix F. Contracts That Should Include FAR Requirements 

(Awarded from August 2000 through 2001) 

Center

Number of 

Contracts 

Awarded

Total Value of 

Contracts

Number of 

Contracts that 

Did Not Have 

FAR Clause 

52.223-10

Value of Contracts 

without FAR 

Clause 52.223-10

Number of 

Contracts that 

Did Not Have 

FAR Clauses 

52.223-4 and 

52.223-9

Ames Research  Center 5 $23,015,062 5 $23,015,062 5 Dryden Flight  Research Center 1 23,333,127 0 0 0 Glenn Research  Center 4 186,988,619 4 186,988,619 4 Goddard Space  Flight Center 20 227,849,774 18 94,945,946 19 Johnson Space  Center 18 137,563,734 15 121,734,007 18 Kennedy Space  Center 1 1,985,563 0 0 1 Langley Research  Center 3 426,300,000 2 423,800,000 2 Marshall Space  Flight Center 4 151,742,729 2 136,181,087 2 Stennis Space  Center 4 15,590,553 4 15,590,553 4 Totals 60 $1,194,369,161 50 $1,002,255,274 55 

Source: Center/Facility Data on Contracts 

 Note: Goddard Space Flight Center also includes Wallops Flight Facility data. 

13 
14

Appendix G. Recommendations, Management’s Response, and 

Evaluation of Management’s Response 

The Assistant Administrator for Management Systems, in coordination with the 

Assistant Administrator for Procurement, should: 

1. Emphasize to Center environmental managers and contracting officers 

the affirmative procurement requirements in NPG 8830.1, and reaffirm NASA’s 

commitment to the program. 

Management’s Response. Concur. The Assistant Administrator for Management 

Systems and Assistant Administrator for Procurement will distribute a memorandum 

regarding NASA's commitment to affirmative procurement requirements to the 

environmental managers and contracting officers. 

2. Provide training on EO and RCRA requirements for all applicable 

environmental, procurement, and applicable program office officials. 

Management’s Response. Concur. NASA will design, develop, and deploy training on 

affirmative procurement, including guidance on the EO, RCRA, and/or FAR 

requirements, as appropriate to the job function. 

Evaluation of Management’s Responses. Management’s planned actions to 

recommendations 1 and 2 are responsive. The recommendations are resolved but will 

remain undispositioned and open until the agreed-to corrective actions are completed. 

3. The Director, Johnson Space Center, should direct the appropriate officials to 

implement a waiver process for EPA-designated products in accordance with 

NPG 8830.1. 

Management’s Response. Concur. The Johnson Space Center is developing a waiver 

process, based on an evaluation of Center procurement processes. Johnson is also 

looking at waiver processes developed at other Centers for best practices. 

Evaluation of Management’s Response. Management’s planned actions are 

responsive. The recommendation is resolved but will remain undispositioned and open 

until the agreed-to corrective action is completed. 

The Assistant Administrator for Procurement should: 

4. Provide training for contracting officers on affirmative procurement 

requirements and the use of related FAR clauses. 

Management’s Response. Concur. NASA will review existing mandatory training for 

contracting officers to evaluate its coverage of affirmative procurement requirements and 
15

Appendix G

related FAR clauses. On the basis of that review, NASA will work to assure contracting 

officer training is adequate, possibly augmenting standard Governmentwide training 

required for certification. 

5. Direct staff performing Procurement Management Surveys to determine 

whether contracting officers included the required FAR clauses in contracts that 

provide for or support the operation of NASA-owned facilities. 

Management’s Response. Concur. The Assistant Administrator for Procurement will 

review and revise as necessary guidance for Procurement Management Surveys to assure 

the required FAR clauses are included in contracts that provide for or support the 

operation of NASA-owned facilities. 

Evaluation of Management’s Responses. Management’s planned actions to 

recommendations 4 and 5 are responsive. The recommendations are resolved but will 

remain undispositioned and open until the agreed-to corrective actions are completed. 

The Assistant Administrator for Management Systems should: 

6. Revise NPG 8830.1 to reflect the EO 13101 requirement that the AEE 

position be established at no lower than the Assistant Administrator level and that 

the position cannot be delegated to a lower level.

Management’s Response. Concur. NASA will include the requirement as a part of the 

scheduled revision of NPG 8830.1. 

7. Immediately assume the role of the AEE to comply with the requirements 

of EO 13101. 

Management’s Response. Concur. NASA will establish the Assistant Administrator for 

Management Systems as the Agency Environmental Executive, and the Director of 

Environmental Management as the Alternate Agency Environmental Executive. NASA 

will distribute a letter to Office of the Federal Environmental Executive to formalize this 

agreement. 

Evaluation of Management’s Responses. Management’s planned actions to 

recommendations 6 and 7 are responsive. The recommendations are resolved but will 

remain undispositioned and open until the agreed-to corrective actions are completed. 
16

Appendix H. Management’s Response 
17

Appendix H
18

Appendix H
19

Appendix I. Report Distribution 

National Aeronautics and Space Administration (NASA) Headquarters 

A/Administrator 

AA/Chief of Staff 

ADI/Associate Deputy Administrator for Institutions and Asset Management 

ADT/Associate Deputy Administrator for Technical Programs 

B/Deputy Chief Financial Officer for Financial Management 

B/Deputy Chief Financial Officer for Resources (Comptroller) 

BF/Director, Financial Management Division 

G/General Counsel 

H/Assistant Administrator for Procurement 

HK/Director, Contract Management Division 

HS/Director, Program Operations Division 

J/Assistant Administrator for Management Systems 

JM/Director, Management Assessment Division 

L/Assistant Administrator for Legislative Affairs 

NASA Centers 

ARC/D/Director, Ames Research Center 

DFRC/X/Director, Dryden Flight Research Center 

GRC/0100/Director, John H. Glenn Research Center at Lewis Field 

GSFC/100/Director, Goddard Space Flight Center 

JSC/AA/Director, Lyndon B. Johnson Space Center 

KSC/AA/Director, John F. Kennedy Space Center 

LaRC/106/Acting Director, Langley Research Center 

MSFC/DA01/Director, George C. Marshall Space Flight Center 

SSC/AA00/Director, John C. Stennis Space Center 

KSC/CC/Chief Counsel, John F. Kennedy Space Center 

Non-NASA Federal Organizations and Individuals 

Assistant to the President for Science and Technology Policy 

Deputy Associate Director, Energy and Science Division, Office of Management and 

 Budget 

Branch Chief, Science and Space Programs Branch, Energy and Science Division, Office 

 of Management and Budget 

Managing Director, Acquisition and Sourcing Management Team, General Accounting 

 Office 

Managing Director, Natural Resources and Environment, General Accounting Office 
20

Appendix I 

Non-NASA Federal Organizations and Individuals (Cont.)

Senior Professional Staff Member, Senate Subcommittee on Science, Technology, and 

 Space 

Chairman and Ranking Minority Member – Congressional Committees and 

Subcommittees 

Senate Committee on Appropriations 

Senate Subcommittee on VA, HUD, and Independent Agencies 

Senate Committee on Commerce, Science, and Transportation 

Senate Subcommittee on Science, Technology, and Space 

Senate Committee on Environment and Public Works 

Senate Subcommittee on Environment and Hazardous Materials 

Senate Committee on Governmental Affairs 

House Committee on Appropriations 

House Subcommittee on VA, HUD, and Independent Agencies 

House Committee on Government Reform 

House Subcommittee on Government Efficiency and Financial Management 

House Subcommittee on Technology, Information Policy, Intergovernmental Relations, 

 and the Census 

House Committee on Science 

House Subcommittee on Space and Aeronautics 

Congressional Member 

Honorable Pete Sessions, U.S. House of Representatives 
NASA Assistant Inspector General for Auditing 

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