GAO United States

General Accounting Office

Washington, D.C. 20548

Resources, Community, and

Economic Development Division

B-277552 

July 30, 1997

The Honorable Richard K. Armey

Majority Leader

House of Representatives

The Honorable John Kasich

Chairman

Committee on the Budget

House of Representatives

The Honorable Dan Burton

Chairman

Committee on Government Reform

 and Oversight

House of Representatives

The Honorable Bob Livingston

Chairman

Committee on Appropriations

House of Representatives

Subject: Results Act: Observations on EPA’s Draft Strategic Plan

On June 12, 1997, you asked us to review the draft strategic plans

submitted by the cabinet departments and selected major agencies for

consultation with the Congress as required by the Government

Performance and Results Act of 1993 (the Results Act). This letter is our

response to that request concerning the Environmental Protection Agency

(EPA).

Objectives, Scope,

and Methodology

Specifically, you asked us to review EPA’s draft plan and (1) assess whether

it fulfills the requirements of the Results Act and to provide our views on

its overall quality; (2) assess whether it reflects EPA’s key statutory

authorities; (3) assess whether it reflects interagency coordination for

crosscutting programs, activities, or functions that are similar or

complementary to other federal agencies; (4) assess whether it addresses

management problems we have previously identified; and (5) assess

whether EPA’s data and information systems are adequate for providing

reliable information for measuring results.

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We reviewed the draft strategic plan that EPA provided congressional

committees with on July 1, 1997. Our overall assessment of the draft plan

was generally based on our knowledge of EPA’s operations and programs,

our prior reviews of the agency, and other existing information available at

the time of our assessment. The criteria that we used to determine

whether the draft strategic plan complied with the requirements of the

Results Act were the provisions of the Results Act itself, supplemented by

the Office of Management and Budget’s (OMB) guidance on developing the

plans (OMB Circular A-11, Part 2).

To make judgments about the overall quality of the draft plan, we used our

May 1997 guidance for congressional review of the plans

(GAO/GGD-10.1.16) as a tool. To determine whether the draft plan contained

information on interagency coordination and addressed the management

problems that we previously identified, we relied on our general

knowledge of EPA’s operations and programs and the results of our prior

reports. In determining whether the draft strategic plan reflected EPA’s

major statutory responsibilities, we reviewed applicable legislation,

including laws cited in EPA’s draft plan and, as you requested, coordinated

our review with the Congressional Research Service. To determine

whether EPA had adequate systems in place to provide reliable information

on performance, we relied on the results of our previous reports and those

of EPA’s Office of the Inspector General. We also discussed the draft plan

with officials of EPA’s Office of Planning, Analysis, and Accountability,

which is responsible for preparing the plan. Our work was performed

during July 1997. We obtained comments from EPA on a draft of this report,

which are summarized at the end of this letter.

It is important to recognize that EPA’s final plan is not due to the Congress

and OMB until September 1997. Furthermore, the Results Act anticipated

that it may take several planning cycles to perfect the process and that the

final plan would be continually refined as future planning cycles occur.

Thus, our findings reflect a snapshot status of the draft strategic plan at

this time. We recognize that developing a strategic plan is a dynamic

process and that EPA is continuing to revise the draft with input from OMB,

congressional staff, and other stakeholders.

Background EPA was formed in 1970 by executive reorganization from various

components of other agencies to better marshal and coordinate federal

pollution control efforts. The agency does not have a single, unified statute

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to enumerate an overarching mission and purpose. Instead, EPA is

responsible for implementing about a dozen major statutes.

Although its activities have expanded to include various international and

nonregulatory approaches to controlling pollution, EPA is, above all, a

regulatory agency, responsible for setting and enforcing the environmental

standards called for in the various statutes. It also conducts environmental

research; assists state and local governments, private groups, individuals,

and educational institutions combatting environmental pollution; and

assists in developing and recommending to the President new policies for

environmental protection. EPA has a significantly greater effect on the

national economy than its annual budget of about $7 billion would suggest.

For example, the nation spent over $120 billion in 1994—the year of the

latest available data—on controlling and regulating pollution.1

EPA relies heavily on the states to implement its programs. Major

environmental laws—such as the Safe Drinking Water Act and the Clean

Water Act—assign to EPA the key functions involved in the delivery of

environmental programs but allow states to assume these responsibilities.

Today, operational responsibilities for most of EPA’s major programs lie

with the states and, for the most part, EPA now depends on the states to

implement the full range of environmental responsibilities associated with

these programs. Even when responsibilities have not been formally

delegated, states often play a major role in day-to-day program activities.

EPA has previously prepared strategic plans, the most recent of which was

issued in July 1994, about a year after the Results Act became law. The

current draft plan builds on the 1994 plan but is the first being developed

in response to the Results Act. The current draft plan is also the first

strategic plan being developed under EPA’s new planning, budgeting, and

accountability organization. In response to April 1995 recommendations

by the National Academy of Public Administration (NAPA), EPA is in the

process of improving and integrating its planning, budgeting, and

accountability processes. In January 1997, the EPA Administrator approved

the staffing and organizational structure for a new office—the Office of

Planning, Analysis, and Accountability within the Office of the Chief

Financial Officer—to design and implement a new system. The current

draft strategic plan is being prepared by the Office of Planning, Analysis,

and Accountability as the first component of the new planning, budgeting,

and accountability system.

1

Survey of Current Business (Vol. 70, No. 9, Sept. 1996), Bureau of Economic Analysis, Department of

Commerce.

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The Results Act requires that agencies’ strategic plans contain the

following six critical components: (1) a comprehensive mission statement;

(2) agencywide long-term goals and objectives for all major functions and

operations; (3) approaches (or strategies) and the various resources

needed to achieve the goals and objectives; (4) the relationship between

the long-term goals and objectives and the annual performance goals;

(5) an identification of key factors, external to the agency and beyond its

control, that could significantly affect the achievement of the strategic

goals; and (6) a description of program evaluations used to establish or

revise strategic goals and a schedule for future program evaluations.

Results in Brief EPA’s draft strategic plan does not yet contain all the elements required by

the Results Act. While EPA has made progress toward developing a

strategic plan for carrying out the agency’s missions and meeting the

requirements of the Results Act, it still has some work to do before it

completes its final plan by September 30, 1997. The draft plan provides a

mission statement, general goals and objectives, approaches and

strategies, and an identification of key external factors. It communicates

the agency’s planned activities, and its goals and objectives are generally

results oriented and measurable. However, the draft plan does not include

two of the elements required by the Results Act: (1) the relationship

between the goals and objectives and the annual performance goals and

(2) program evaluations used to develop the plan and a schedule for future

evaluations.

On the basis of our review of relevant legislation, we believe that the

activities defined in EPA’s draft plan are supported by legislation and that

the draft plan reflects EPA’s major legislative requirements. We also believe

that the linkages that EPA provides between goals, objectives and

strategies, and “potential” statutory authorities help the reader to

understand the plan. However, it would be more helpful if EPA identified

which of the laws actually support each goal.

EPA’s draft plan does not discuss interagency coordination for crosscutting

programs, activities, or functions that are similar to those of other federal

agencies. It is important that the plan do so because EPA and other

agencies carry out a number of mission-related activities that are

crosscutting or similar. For example, to meet the purposes of its plan, EPA

must work closely with agencies responsible for cleaning up hazardous

waste sites at federal facilities, address global warming and other

international environmental concerns, and ensure a food supply that is

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safe from harmful chemicals. EPA is currently taking steps to coordinate its

plan with other agencies, such as the Department of Energy and the

National Aeronautics and Space Administration, to address crosscutting

programs and activities. As EPA identifies such programs and activities, its

strategic plan would be improved through a discussion of the steps that

the agency will take to ensure proper coordination.

EPA’s draft strategic plan recognizes major management challenges that we

have previously identified and discusses the agency’s plans to act on them.

The draft plan, however, provides limited details on how these

long-standing problems will be resolved. These challenges include setting

priorities, making effective use of nonregulatory approaches to

supplement traditional “command and control” regulations, improving

working relationships with the states, and ensuring the quality and

completeness of the scientific research on which the agency bases its

decisions.

EPA is currently developing an agencywide information system to track

performance and report on results. However, this system will depend on

data from various other systems and sources that currently do not provide

the reliable information that EPA needs for measuring results. Many gaps

exist in these data, and the needed data are often difficult to compile

because different collection methods have been used to obtain them.

Likewise, effort is still needed to identify, develop, and reach agreement

on a comprehensive set of performance measures for the agency.

Particularly needed are additional environmental measures or indicators

to link EPA’s activities to changes in health and environmental conditions.

Because the type and amount of data needed for environmental measures

can be costly, EPA has to find the right balance of environmental and

activity measures. In a June 1997 report, we recommended that EPA, in

consultation with key stakeholders, establish benchmarks for the

information system and use them to monitor the agency’s progress toward

obtaining the data it needs to accurately assess its progress in managing

environmental protection programs.2 EPA also needs to improve its

financial data by correcting internal control weaknesses that have been

identified by the agency’s Office of the Inspector General. EPA’s final plan

should address such weaknesses and set clear expectations for correcting

them and achieving an unqualified opinion on the agency’s financial

statements.

2

Managing for Results: EPA’s Efforts to Implement Needed Management Systems and Processes

(GAO/RCED-97-156, June 18, 1997).

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EPA’s Draft Strategic

Plan Does Not Yet

Contain All the

Elements Required by

the Results Act

EPA’s draft strategic plan does not contain all six of the Results Act’s key

requirements, and certain aspects of those included could be improved.

Nevertheless, the draft plan shows progress overall toward meeting the

purposes of the act.

EPA’s Draft Strategic Plan

Lacks Key Elements

Required by the Results

Act

EPA’s draft plan contains four of the six elements required by the Results

Act: (1) a mission statement, (2) general goals and objectives,

(3) approaches or strategies to achieve the goals and objectives, and (4) an

identification of key external factors. However, the draft plan does not

describe either the (1) relationship between the general goals and

objectives and the annual performance goals or (2) program evaluations

used in developing the plan and a schedule for future evaluations.

Although the draft plan contains a section on program evaluation, the

discussion focuses on the role of evaluation in assessing future results and

provides general criteria for deciding which evaluations to perform in the

future. For the four elements that were included, we noted that the draft

plan did not contain all the details suggested by OMB Circular A-11 and/or

other improvements could be made to improve the plan’s usefulness.

Observations on the

Overall Quality of EPA’s

Draft Plan

EPA has made progress in producing a draft strategic plan in accordance

with the purposes of the Results Act. Two elements are missing and those

that are included could be made more useful. However, the draft plan, in

total, provides a good indication of EPA’s planned direction and major

efforts to achieve its mission. The goals and objectives of the draft plan

are, to a great extent, outcome-oriented, and its objectives are largely

measurable. The objectives—along with the sections on planned

accomplishments, strategies, and results expected—provide a basis for

holding EPA accountable for achieving results. The draft plan also provides

several additional sections that are not required by the Results Act or

suggested in OMB Circular A-11 but which are helpful to understanding EPA’

s operations and activities. For example, the plan includes a chapter that

discusses how EPA generally considers benefit and cost information in its

work and the significant costs and benefits associated with the goals and

objectives presented in the plan. According to EPA officials, this chapter

was specifically included in EPA’s draft plan at the request of the Congress.

While the plan’s goals and objectives are generally well defined, the large

number of goals and objectives may make it difficult for the Congress,

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other stakeholders, and possibly agency managers to discern EPA’s

priorities—that is, what will be most important to the agency over the next

several years. The draft plan has 10 goals and 45 associated objectives. In

addition, the plan contains 14 strategic principles that are similar to goals.

These principles include emphasizing children’s health; choosing common

sense, cost-effective solutions to environmental problems; and

strengthening partnerships with states and others.

Although the draft plan points out the important role of other federal

agencies and states in carrying out EPA’s programs, the plan could more

clearly describe (1) the contribution that these entities are expected to

make in meeting the agency’s goals and objectives and (2) the effect of

their performance on the plan’s success. Our specific observations on the

six elements required by the Results Act are discussed in the following

sections.

Mission Statement According to OMB Circular A-11, the mission statement should briefly

define the basic purpose of the agency, with particular focus on its core

programs and activities. In its draft plan, EPA provides an overarching

statement that its mission is “to protect public health and to safeguard the

natural environment—air, water, and land—upon which life depends.” EPA

also identifies several purposes of the agency, including ensuring that all

Americans are protected from significant risks to public health and the

environment where they live, learn, and work; basing national

environmental efforts on the best available scientific information; and

ensuring that federal laws protecting public health and the environment

are enforced fairly and effectively.

The draft plan’s overarching mission statement is general but concisely

states what EPA is broadly charged with doing under its statutes. This

statement, along with the purpose statements, are comprehensive in that

they cover the agency’s major statutes, programs, and activities. The

mission statement is also results oriented and clearly specifies the public

need that the mission is to fulfill.

Although having a concise and straightforward mission statement is

important, EPA can better distinguish its responsibilities from those of

other agencies and recognize the important role of the states in carrying

out federal environmental programs. Other agencies also have major

responsibilities for parts of EPA’s mission, for example, the Department of

Health and Human Services protects human health, the Department of

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Labor’s Occupational Health and Safety Administration regulates health

risks in the workplace, and the Departments of Agriculture and the

Interior protect the environment. State and local governments also have

health and environmental programs.

Goals and Objectives OMB Circular A-11 states that strategic plans should set out an agency’s

long-term programmatic, policy, and management goals, outlining planned

accomplishments and the schedule for their implementation. According to

Circular A-11, the general goals and objectives should elaborate on how

the agency is to carry out its mission and very often will be expressed as

outcomes. Circular A-11 also states that general goals and objectives

should be stated in a manner that allows a future assessment of whether

they are being achieved.

EPA has listed 10 goals for the agency, most of which have multiple

objectives. EPA officials told us that the strategic plan’s goals and

objectives are largely derived from those developed by EPA’s National

Environmental Goals Project.3

The plan is generally developed along the same lines as EPA’s statutory

requirements and organizational structure. For example, individual goals

address clean air, clean water, waste management and cleanup,

international responsibilities, and internal management functions. (See

encl. I for a listing of EPA’s draft goals.)

The goals are generally results-oriented and measurable. For example,

EPA’s goal for clean air states, in part, that the “air in every American

community will be safe and healthy to breathe, as determined by the latest,

best scientific evidence.” However, EPA’s goals for “effective management”

and “sound science, improved understanding of environmental risk, and

greater innovation to address environmental problems” do not clearly

define the expected results, and it is unclear how EPA would assess

progress toward achieving these goals.

Although the objectives are generally results oriented and measurable, in

some cases, obtaining the data needed to measure progress toward the

objectives will present a challenge for EPA. For example, one of EPA’s clean

and safe water objectives states that watersheds will be restored and

protected so that 80 percent of the nation’s surface waters will support

3

EPA began the National Environmental Goals Project in 1992 to establish, with input from the public

and other government agencies, a set of long-range national environmental goals with realistic and

measurable milestones for 2005. EPA officials anticipate that the final report will be issued in 1998.

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healthy aquatic communities by 2005. However, according to EPA’s most

recent National Water Quality Inventory Report, the states have assessed

only 42 percent of their lake, pond, and reservoir acres; 17 percent of their

river and stream miles; and 9 percent of the nation’s ocean shoreline. In

addition, EPA reported inconsistencies in the assessments and in the

assessment methodologies themselves.

In some instances, objectives are dependent upon actions to be taken by

other federal agencies or other entities that are not under EPA’s control.

For example, in order to fully achieve EPA’s goal for “better waste

management and restoration of abandoned waste sites,” EPA must depend

on federal agencies such as the Departments of Energy and Defense,

which have cleanup responsibility for federal facilities under their

jurisdiction. Likewise, as of December 1996, EPA authorized 32 states to

implement the cleanup requirements of the Resource Conservation and

Recovery Act of 1976, as amended, and EPA’s data suggests that about

70 percent of the cost of cleaning up Superfund sites is the responsibility

of the private sector. Although EPA must rely on other federal agencies,

states, and the private sector to clean up previously polluted sites, the

draft plan does not explain how EPA is going to coordinate this effort.

Approaches to Achieving

Strategic Goals and

Objectives

Under the Results Act, the strategic plan must describe the operational

processes, staff skills, and technologies, as well as the human, capital,

information, and other resources, needed to meet the goals and objectives

of the plan. Additionally, according to OMB Circular A-11, strategies should

outline how the agency will communicate strategic goals throughout the

organization and hold managers and staff accountable for achieving these

goals.

In its draft plan, EPA provides a chapter on approaches organized by its

strategic or general goals. For each goal, the plan generally has sections on

the importance of the goal, objectives, what will be accomplished,

strategies for how it will be accomplished, results expected, and

performance measures. Together, these sections provide considerable

detail on EPA’s planned actions for achieving each of the goals. The

sections, along with the plan’s chapter on assessing results, which

describes the agency’s accountability process, communicate how

managers and staff will be held accountable for achieving the draft plan’s

goals.

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Neither the chapter on approaches nor other parts of the plan describe the

staffing skills and resources needed to achieve the goals, as required by

the Results Act. Instead, the approaches chapter recognizes that achieving

the goals will take substantial human, capital, and technological resources.

This chapter also states that the agency has developed a set of

shorter-term objectives that (1) define how the agency will spend its

resources and (2) provide a guide for assessing whether the goals are

being reached. However, these shorter-term

objectives—subobjectives—are generally not included in the plan.

According to EPA officials, the annual performance plans required by the

Results Act will provide more details on staffing and resource needs.

The chapter on approaches could also be improved by better linking the

strategies to the specific objectives under each goal. While the strategies

presented fit under the broad goals, the objectives state more specifically

what results EPA is trying to achieve during the time frame covered by the

strategic plan, and it is not always clear how a particular strategy relates to

one or more of these objectives. For example, EPA’s safe food goal is that

the “foods Americans eat will be free from unsafe pesticide residue.”

Within this goal, EPA has the following two objectives:

• By 2005, the risk from the agricultural use of pesticides will be reduced by

50 percent from 1995 levels.

• By 2005, the use on food of current pesticides that do not meet the new

statutory standard of “reasonable certainty of no harm” will be

substantially eliminated.

Under the strategies section, the draft plan primarily discusses the

agency’s current pesticide program without indicating what will be done

differently to, for example, achieve the 50-percent reduction in risk from

the agricultural use of pesticides.

Relationship Between

Long-Term Goals and

Objectives and Annual

Performance Goals

Under the Results Act, the strategic plan must describe how the agency’s

annual performance goals are related to the general goals and objectives in

the strategic plan. A performance goal is the target level of performance

expressed as a tangible, measurable objective against which actual

achievement is to be compared. According to OMB Circular A-11, the

strategic plan should outline the (1) type, nature, and scope of the

performance goals to be included in an annual performance plan; (2) the

relationship between the performance goals and the general goals and

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objectives; and (3) the relevance and use of performance goals in helping

determine the achievement of general goals and objectives.

EPA’s draft plan discusses, in a general way, the relevance and use of

performance goals to help determine the achievement of general goals and

objectives. However, it does not identify the annual performance goals and

discuss their relationship to particular general goals and associated

objectives.

Office of Planning, Analysis, and Accountability officials agreed that the

draft strategic plan does not describe the relationship between long-term

goals and objectives and annual performance goals, as called for by the

Results Act and OMB Circular A-11. They said, however, that they believe

that the relationship will be clear once the annual performance plan is

available. According to the officials, annual performance goals are being

developed for each of the strategic goals and objectives, making the

linkage clear. The officials further said that EPA’s new planning, budgeting,

and accountability system calls for the preparation of multiyear plans as a

bridge between the plans. Because of time constraints, the strategic and

annual performance plans are being developed concurrently this planning

cycle, and the multiyear plan will probably be prepared next year,

according to the officials. The officials stated that language discussing the

relationship of the annual performance goals to the strategic goals and

objectives will be added to the September 1997 version of the strategic

plan.

Key External Factors OMB Circular A-11 points out that agencies’ achievement of their goals and

objectives can be influenced by certain external factors that exist, occur,

or change over the time period covered by their plans. Circular A-11 notes

that these factors can be economic, demographic, social, or environmental

and states that the strategic plan should briefly describe each external

factor, indicate its link with a particular goal(s), and describe how the

achievement of the goal could be affected by the factor.

EPA’s draft plan identifies as a key external factor the agency’s heavy

reliance on partnerships to protect the environment and human health.

The draft plan notes that, although the agency has some influence, it does

not control the actions of the state, local, and tribal governments that

implement federal environmental programs; other federal agencies with

significant environmental responsibilities; or other countries and

international organizations with which the United States shares

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environmental goals. The draft plan also notes that much of the success of

the agency’s programs depends on the voluntary cooperation of the

private sector and the general public. In addition, the draft plan identifies

significant external factors, such as (1) the development of new

environmental technology that works better and costs less and (2) natural

processes that affect the condition of ecosystems.

Some further discussion of the importance of the states, tribes, industry,

and the public to EPA’s success is provided in the draft plan’s introductory

chapter and, for the states, also in the chapter on assessing results.

However, the plan does not link the external factors to particular goals or

describe how the achievement of the goals could be affected by the

factors. In our view, the draft plan would also benefit from further

discussion, in the section on key external factors, to identify the

(1) significant environmental responsibilities of other federal agencies that

affect EPA’s success, (2) types of technological developments that have

previously affected the agency’s programs or are currently under

development, and (3) natural processes that affect the environmental

condition of ecosystems. For example, success in cleaning up waste sites

largely depends upon the actions of other federal agencies, such as the

Departments of Defense and Energy; meeting new air quality standards

depends upon the introduction of new technologies; and saving

watersheds depends upon the actions of federal, state, and local

organizations to protect natural environmental systems.

Program Evaluation Under the Results Act, the strategic plan is to describe program

evaluations that were used in preparing the plan and include a schedule

for future evaluations. OMB Circular A-11 calls for this schedule to outline

the general scope and methodology for the evaluations, the key issues to

be addressed, and the time when such evaluations are to occur. In EPA’s

draft plan, however, this section—contained in the chapter on assessing

results—generally describes how program evaluations will be used in the

future and the general criteria for selecting programs to evaluate. The

section does not describe program evaluations done by the agency or

others, such as its Inspector General or us, which were to be used to

establish strategic goals or a schedule for future evaluations.

Office of Planning, Analysis, and Accountability officials told us that,

although not described in the plan, program evaluations and other studies,

including those done by EPA’s Office of the Inspector General and us, were

used in developing the draft plan. According to the officials, the agency’s

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program offices were aware of the evaluations and studies when

developing their goals, objectives, and strategies and took the findings into

consideration. As discussed earlier, the officials also said that the draft

plan’s strategic goals and objectives are largely derived from those

developed by EPA’s National Environmental Goals Project, and these

evaluations would have been identified and taken into account during the

almost 5 years since the project began. The officials further noted that

program evaluations will be an important part of the accountability

component of EPA’s new planning, budgeting, and accountability system,

but the component is under development. According to the officials, a

section on how program evaluations contributed to establishing the

agency’s goals is being drafted and will be included in the September 1997

version of the strategic plan.

Legislative Authorities

Are Reflected in Plan

On the basis of our review of relevant legislation, we believe that (1) the

activities defined in EPA’s plan are supported by legislation and (2) the plan

reflects EPA’s major legislative requirements. In addition, although not

required by the Results Act, EPA has provided a list of statutory authorities

for each goal and related objectives and strategies that potentially could

be used in carrying out the planned actions. We believe that including

these linkages in EPA’s plan should facilitate a better understanding of the

diversity and complexity of the agency’s overall mission and goals and

objectives. We note, however, that EPA’s draft plan lists these laws as

“potential” authorities. To be fully useful, EPA will need to identify, in the

final plan, which of these laws actually support each goal.

In commenting on a draft of this report, Office of Planning, Analysis, and

Accountability officials told us that they intend to revise the draft plan to

include actual, rather than potential, statutory authorities. They also said

that these authorities would be tied to the individual objectives, rather

than to the broader goals.

Crosscutting Program

Activities Are Not

Addressed, but

Coordination Efforts

Are Under Way

EPA’s draft plan makes broad references to the need for coordination with

federal agencies (and other stakeholders) to accomplish the agency’s

mission, but it does not explicitly address the relationship of EPA’s

activities to federal agencies with crosscutting or similar activities. Neither

does it provide evidence that EPA has coordinated the plan’s development

with them. However, the plan does identify “strengthening partnerships

with stakeholders”—including other federal agencies—as a strategic

principle that will be used to guide senior management in making

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decisions about the agency’s priorities, activities, and ways in which the

plan’s goals and objectives may best be reached. The plan also recognizes

that voluntary partnerships with stakeholders are a key external

factor—to a large extent beyond EPA’s control—that could significantly

affect the agency’s ability to achieve its mission. While EPA has some

influence over the actions taken by other federal agencies with significant

environmental responsibilities (as well as some influence over state, tribal,

and local governments), it does not control their actions. Hence, the

agency acknowledges that effective partnerships with federal agencies and

other stakeholders are essential to successfully implementing the plan’s

goals and objectives.

To address this coordination issue, EPA officials responsible for the plan’s

development told us that the agency has taken a number of steps to

include stakeholders in developing and refining the plan.4

 For example, a

wide range of stakeholders’ views—including those of other federal

agencies—were incorporated into EPA’s Environmental Goals for America,5

 which served as the framework for developing the agency’s strategic plan.

In addition, while EPA did not formally involve all federal agencies with

similar activities in preparing its plan, the agency’s program offices

informally solicited input from some federal agencies in developing their

respective goals and objectives for inclusion in the plan. In addition,

according to one of these officials, EPA’s Office of Research and

Development prepared its own strategic plan last year through the

involvement of a number of stakeholders. This plan incorporated

recommendations made by the agency’s Science Advisory Board, the

National Research Council, and NAPA, among others, and was used as the

basis for developing science-related goals and objectives for the EPA-wide

strategic plan.

To further refine the plan and determine areas of potential overlap

between EPA and federal agencies with related responsibilities, EPA

identified 16 federal agencies with crosscutting or similar functions and

sent each of them a draft outline of the strategic plan in May 1997 and the

4

The stakeholders include states, regions, environmental and other public interest groups, business

associations, individual corporations, and local governments, among others. However, EPA’s efforts to

coordinate with other federal agencies were limited primarily by the time frames they were working

under to complete the plan.

5

Environmental Goals for America: With Milestones for 2005, EPA (Dec. 1996).

Page 14 GAO/RCED-97-209R EPA’s Draft Strategic Plan
B-277552 

full draft in early July 1997 for their review and comment.6 In addition, EPA

is reviewing these agencies’ draft plans to identify areas of potential

duplication that warrant further coordination. One official involved in the

development of EPA’s plan told us that because strategic plans are written

at such a broad level, it can be difficult to use them as a tool for identifying

areas of duplication—this level of detail is often found at the project level.

As a result, EPA may need a couple of years to fully coordinate its activities

with those of other federal agencies. According to EPA officials responsible

for developing the strategic plan, the September 1997 version will address

comments made by federal agencies and other stakeholders on the July

draft circulated for review and discuss EPA’s past and ongoing efforts to

coordinate the plan with these stakeholders.

Our past work has found that EPA—as the central federal agency

responsible for safeguarding the environment—carries out a number of

mission-related activities that are crosscutting or similar to those of other

federal agencies. These activities include the following:

• One of EPA’s most visible relationships with other federal agencies involves

the cleanup of hazardous waste (Superfund) sites at federal facilities.7

 The

process for cleaning up these sites consists of many steps involving both

the responsible federal agencies and EPA. Our 1996 review of risk

evaluations for federal facilities8

 found that as of February 1996, EPA had

designated 154 facilities as high priorities for cleanup,9

 including facilities

operated by the Departments of Agriculture (2), Defense (127), Energy

(20), the Interior (2), and Transportation (1). Our work also found that

interagency comparisons of risk posed by these sites are difficult because

agencies have independently developed different risk-ranking and

priority-setting approaches. While EPA’s draft strategic plan includes a goal

6

In late July 1997, a copy of EPA’s draft strategic plan was also sent to the National Science

Foundation for review and comment. EPA is reviewing the Foundation’s draft plan, according to Office

of Planning, Analysis, and Accountability officials. The officials said that the draft plan was not sent

earlier because of an oversight, but EPA will have time to incorporate the comments before the plan is

finalized.

7

Numerous federal facilities have been contaminated with a wide range of substances, including highly

radioactive waste and toxic chemicals, and require cleanup. The Superfund program, established

under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as

amended, governs cleanups of hazardous waste sites, including those located on federal property.

8

Federal Facilities: Consistent Relative Risk Evaluations Needed for Prioritizing Cleanups

(GAO/RCED-96-150, June 7, 1996).

9

As of April 1995, federal agencies had placed 2,070 facilities on the federal facility docket, EPA’s

listing of the facilities awaiting evaluation for possible cleanup. In addition, EPA had placed 154

federal facilities on the National Priorities List as of February 1996. EPA uses the list as an aid in

determining which sites warrant further investigation to assess public health and environmental risks

and which sites merit cleanup.

Page 15 GAO/RCED-97-209R EPA’s Draft Strategic Plan
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and related objectives that pertain to the cleanup of hazardous waste sites,

it does not specifically address the issue of interagency coordination in

achieving “better waste management and restoration of abandoned waste

sites.”

• EPA shares responsibilities with other agencies for collecting and managing

the data needed to perform environmental assessments. For example, data

on ecosystem management are collected independently by various

agencies for different purposes. Often, these data are noncompatible and

insufficient for decision-making. Data for health assessments are equally

widespread among federal entities. For example, EPA must coordinate such

data with the Department of Labor, the National Institute for Occupational

Safety and Health, the National Institute of Environmental Health

Sciences, the National Science Foundation, and the National Cancer

Institute, among other agencies. While the plan recognizes the need for

stakeholders’ general involvement, it does not address the interagency

coordination of data needed for health and environmental assessments.

Neither does it assume or assign responsibility for collecting, managing,

and making the data available to others.

• EPA, as the nation’s chief technical and regulatory agency for

environmental matters, also plays a major role in international

environmental programs and activities—including efforts to address global

environmental concerns, such as climate change, stratospheric ozone

depletion, marine and coastal pollution, and loss of biological diversity.

Our recent work on international environmental agreements10 noted that

EPA shares responsibility for implementing international environmental

agreements with several federal agencies, including (1) the Department of

State, (2) the U.S. Agency for International Development, (3) the

Department of Energy, and (4) the Department of Commerce (primarily,

the National Oceanic and Atmospheric Administration). However, EPA’s

goal and related objectives on the reduction of global and cross-border

environmental risks make only passing references to the need to

cooperate with other federal agencies and other stakeholders in

implementing this goal.

• EPA also shares responsibility with other federal agencies for ensuring a

safe food supply for the American public and has therefore included food

safety as one of the plan’s goals. In particular, the agency will strive to

keep foods free of pesticides and protect the public from threats posed by

tainted foods. While this goal makes a general reference to involving

stakeholders in developing performance measures, there is no discussion

of the related roles played by the U.S. Department of Agriculture, the Food

10International Environment: U.S. Funding of Environmental Programs and Activities

(GAO/RCED-96-234, Sept. 30, 1996).

Page 16 GAO/RCED-97-209R EPA’s Draft Strategic Plan
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and Drug Administration, and the Centers for Disease Control, among

others, in supporting EPA’s efforts to accomplish this goal.

As noted above, EPA is taking steps to coordinate its plan with other

federal agencies to address the issue of crosscutting or similar functions.

However, because overlapping and fragmented programs can waste scarce

resources, confuse and frustrate programs’ customers, and limit the

overall effectiveness of the federal effort, it is important that the plan

directly address this issue. As EPA identifies areas where its functions are

similar to and/or duplicate those of other federal agencies, its strategic

plan would benefit from explicitly identifying these functions or activities

and detailing the steps that EPA will take to ensure proper coordination

with these agencies and the elimination of unnecessary duplication.

Providing this type of information would help assure the Congress that

crosscutting functions or activities shared by EPA and other federal

agencies are sufficiently distinct and are making effective use of scarce

federal resources.

EPA officials told us that language will be added to the plan to acknowledge

the critical role that other federal agencies play in the successful

achievement of EPA’s mission and that, to the extent possible, the plan will

identify specific federal agencies with a prominent role in attaining the

objectives listed in the plan. According to the officials, the September 1997

version of the plan will also have an appendix summarizing, by goal, the

crosscutting issues shared by EPA and other federal agencies. The officials

said that this information will serve as the basis for coordinating the

development of performance measures, resolving potential areas of

conflict, and improving the management of current and future crosscutting

initiatives.

EPA’s Strategic Plan

Addresses Major

Management

Challenges

In various reports and testimonies over the years, we have identified

several major management challenges for EPA. These involve (1) setting

priorities, (2) making effective use of nonregulatory approaches to

supplement traditional command-and-control regulations, (3) working

better with the states, (4) ensuring the quality and completeness of the

scientific research on which the agency makes its decisions, and (5) better

managing the Superfund program. NAPA also identified these challenges in

its April 1995 report on EPA’s performance in managing environmental

protection.11 EPA has been working to improve in these areas, and its draft

11Setting Priorities, Getting Results: A New Direction for EPA, National Academy of Public

Administration (Apr. 1995).

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strategic plan recognizes these problems and discusses plans for

additional efforts to address them. However, the draft plan would benefit

by being more specific about actions that are planned.

The draft plan is also vague with respect to how EPA intends to implement

information technology management reforms called for in the Paperwork

Reduction Act of 1995 and the Clinger-Cohen Act of 1996, which direct

agencies to integrate information technology investments with the

agency’s overall strategic planning process. In addition, EPA’s draft plan

does not address other important emerging information technology issues

involving the need for computer systems to be changed to accommodate

dates beyond 1999—the “year 2000 problem”—and information security.

Setting the Agency’s

Priorities

We have reported that EPA needs to make two principal improvements in

the way it sets its priorities for planning and budgeting purposes.12 First,

priorities could better reflect risks to human health and the environment.

For example, we noted in our 1991 report that EPA’s Science Advisory

Board, which advises the Administrator on scientific matters, found that

funding priorities were more closely aligned with public opinion about

health and environmental risks than with scientific assessment. In its 1995

report, NAPA concluded that to set better priorities, EPA will need to do a

better job of comparing risks and risk reduction strategies across

environmental programs or problem areas. Second, we have found that

EPA’s priority-setting process has often yielded too many priority items,

that is, priorities that are too encompassing without being ranked as to

their importance. Similarly in its 1995 report, NAPA said that EPA’s 1994

strategic plan appears to include almost everything of interest in the

agency.

As noted in its draft strategic plan, EPA is working to improve and integrate

its planning, budgeting, and accountability processes. As we reported in

June 1997, EPA’s new processes are principally being put in place in

response to NAPA’s concerns.13 When fully implemented, the improvements

12Environmental Protection: Current Environmental Challenges Require New Approaches

(GAO/T-RCED-95-190, May 17, 1995), Management Issues Facing the Environmental Protection Agency

(GAO/T-RCED-93-26, Mar. 29, 1993), Environmental Protection: Meeting Public Expectations With

Limited Resources (GAO/RCED-91-97, June 18, 1991), and Environmental Protection Agency:

Protecting Human Health and the Environment Through Improved Management (GAO/RCED-88-101,

Aug. 16, 1988).

13Managing for Results: EPA’s Efforts to Implement Needed Management Systems and Processes

(GAO/RCED-97-156, June 18, 1997).

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should help the agency to better define its priorities, including making

better use of available information on risk.

The draft strategic plan also addresses the need for better risk

information. For example, in discussing the eighth goal of EPA’s draft

strategic plan—“Sound Science, Improved Understanding of

Environmental Risks, and Greater Innovation to Address Environmental

Problems”—the draft plan states, among other things, that science enables

the agency to identify the most important sources of risk to public health

and the environment, and by doing so, informs priority-setting, ensures

credibility for policies, and guides the deployment of resources. According

to the draft plan, the planned efforts under this goal will provide EPA with

greater certainty in assessing and comparing environmental risks on the

basis of access to critical information and tested methodologies through

high quality-peer review.

Although not specifically mentioned in the draft plan, a project is being

carried out by the Science Advisory Board to rank the relative risks of

environmental problems and develop methodologies that EPA can use to

rank risks in the future. A draft report on the results of this study, which is

called the Integrated Risk Project, is to be provided to other scientists and

experts for peer review in August 1997. According to EPA officials, strategic

planning is an iterative process and the plan will be updated, as

appropriate, to reflect the final results of this and other studies or factors.

Using Nonregulatory

Approaches to Pollution

Control

The traditional approach to pollution control—which requires polluters to

adhere to certain performance or technology standards—has helped

control pollution from large, stationary sources, such as factories and

power plants.14 However, a number of environmental problems remain

that the traditional approaches cannot resolve or that could be resolved

more efficiently and effectively through other methods. These problems

include pollution from some small, diffuse sources and pollution that

crosses from one environmental medium—air, water, or land—to another.

The selective use of market incentives to supplement traditional

regulatory approaches, efforts to prevent pollution, and other

nonregulatory approaches may be less costly to the economy, as well as

more effective in controlling or preventing pollution.

14Environmental Protection: Meeting Public Expectations With Limited Resources (GAO/RCED-91-97,

June 18, 1991).

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The fourth goal of EPA’s draft strategic plan focuses on preventing

pollution. The draft plan states that because traditional regulatory

programs can be costly, EPA is looking at alternative approaches that may

be used to augment basic programs. Rather than traditional “end of the

pipeline” controls, preventing pollution at the source will be EPA’s strategy

of first choice, according to the plan. Some of the goal’s associated

objectives involve the use of certain nonregulatory approaches, such as

the introduction of safer chemicals into the marketplace, and one of the

objectives is for EPA to improve pollution prevention strategies, tools, and

approaches. In addition, the discussion of strategies under some of the

other goals includes nonregulatory approaches. Finally, one of the plan’s

strategic principles is for managers to emphasize the prevention of

pollution in setting priorities and making key decisions.

The draft plan mentions the use of emissions allowance trading, another

potentially effective nontraditional approach, in the introductory chapter

but does not relate additional efforts to a particular goal or objective.

Under emissions-trading programs, pollution sources that reduce their

emissions below the required levels can sell their extra allowances to

other sources of pollution to help them meet their requirements. These

programs can be a less costly means to reduce pollution than traditional

regulatory approaches. For example, we recently reported that EPA’s acid

rain program, which includes the trading of emissions allowances, has

been successful thus far in reducing sulfur dioxide emissions while

reducing compliance costs.15 We noted, however, that EPA has had limited

success in expanding the emissions trading of other pollutants covered

under the Clean Air Act. Several important issues, such as developing and

implementing reliable emissions monitoring and reporting systems,

determining penalties for noncompliance, and allocating emissions

reductions among participants, must be addressed in adopting any

emissions-trading program. As a consequence, it will take time for EPA and

the states to resolve these issues. Although the draft plan refers to EPA’s

using a range of strategic approaches to promote clean air and upgrading

and improving air-monitoring networks, these details were too general to

determine whether the draft plan intends to address these issues.

Working Better With the

States

While EPA is ultimately responsible for overseeing the delivery of national

environmental programs, the states are primarily responsible for

day-to-day implementation. Despite the importance of a good EPA/state

15Air Pollution: Overview and Issues on Emissions Allowance Trading Programs (GAO/T-RCED-97-183,

July 9, 1997).

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relationship, we have reported that difficulties have characterized the

relationship over the years.16 Resource limitations are a major cause of

these problems. Federal funding has not kept pace with new requirements,

and the states have been unable to make up the difference. This resource

shortage has been exacerbated because EPA has sometimes required states

to apply scarce resources to national priorities at the expense of some of

their own environmental concerns. Also affecting the EPA/state

relationship have been states’ concerns that EPA (1) is inconsistent in its

oversight across regions, (2) sometimes micromanages state programs,

(3) does not provide sufficient technical support for increasingly complex

program requirements, and (4) often does not adequately consult states

before making key decisions affecting them.

In EPA’s draft plan, strengthening partnerships is one of the agency’s

strategic principles. According to the plan, EPA will enhance its partnership

with federal, tribal, state, and local agencies; the Congress; private

industry; public interest groups; and citizens to identify environmental

goals and work together to achieve them. Additionally, the introductory

chapter describes the states’ important role and EPA’s May 1995 agreement

with state environmental leaders to establish the National Environmental

Performance Partnership System. Under the new system’s performance

partnerships, EPA and the states are to determine together what work will

be carried out annually and how it will be accomplished. According to the

plan, performance partnerships are helping to shape a fundamentally

different relationship between EPA and the states. Furthermore, the

chapter on assessing results discusses working with state environmental

commissioners to draft core performance measures to provide a common

basis for tracking progress and establishing commitments between the

states and EPA.

The draft plan, however, does not contain any specific objectives or

measures—such as increasing the number of states participating in the

National Environmental Performance Partnership System—to provide a

basis for measuring EPA’s progress. Currently, about half of the states have

signed performance partnership agreements with EPA.

Ensuring the Quality and

Completeness of Scientific

Research

EPA uses peer review to enhance the quality, credibility, and acceptability

of scientific and technical work products, which may ultimately form the

basis of regulations and other key decisions by the agency. In

16EPA and the States: Environmental Challenges Require a Better Working Relationship

(GAO/RCED-95-64, Apr. 3, 1995) and Environmental Protection: Status of EPA’s Initiatives to Create a

New Partnership With States (GAO/T-RCED-96-87, Feb. 29, 1996).

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January 1993, EPA issued a policy statement calling for peer review of the

major scientific and technical work products used to support the agency’s

rule making and other decisions. (In accordance with scientific custom

and/or statutory mandates, several offices within EPA have been using peer

review for many years.) The Congress, we, and others later raised

concerns that the policy was not being consistently implemented

throughout EPA. In 1994, the policy was revised to expand and improve the

use of peer review throughout the agency. However, in a September 1996

report and March 1997 testimony, we found that, despite some recent

progress, peer review continued to be implemented unevenly.17 In some

cases, the policy was followed properly, but in others, key aspects of the

policy were not followed or peer review was not conducted at all.

In its draft strategic plan, one of EPA’s strategic principles is to apply

sound, peer-reviewed science. According to this principle, EPA will

promote the development, peer review, and application of sound science

to meet the agency’s current program requirements and to guide future

directions. In addition, more defensible environmental decisions through

high-quality peer review is listed under the “Results Expected” section of

the goal on sound science. Although the draft plan does not establish

compliance with EPA’s peer review policy as an objective, one of the

performance measures under the goal is the endorsement of research

results by peer review and other impartial, outside reviews.

Managing the Superfund

Program

EPA’s Superfund program began in 1980 as a relatively short-term project to

clean up abandoned hazardous waste sites whose number, at that time,

was thought to be limited. Since then, thousands of sites have been

discovered—many of which are owned by the federal government—and

cleaning them up has proved to be more complicated and costly than

anticipated. Recent estimates show that cleaning up these sites could

amount to over $300 billion in federal costs and many billions more in

private expenditures.

Under the Superfund law, EPA can compel the private parties responsible

for hazardous waste sites to clean them up or it can conduct the cleanup

and demand reimbursement of its costs from the responsible parties.

Private parties perform about 75 percent of cleanups. To pay for EPA’s

cleanups, the agency has drawn on a legislatively established trust fund,

primarily financed by a tax on crude oil and certain chemicals and by an

17Peer Review: EPA’s Implementation Remains Uneven (GAO/RCED-96-236, Sept. 24, 1996) and Peer

Review: EPA’s Implementation Remains Uneven (GAO/T-RCED-97-95, Mar. 11, 1997).

Page 22 GAO/RCED-97-209R EPA’s Draft Strategic Plan
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environmental tax on corporations. Federal agencies generally use their

annual appropriations to finance cleanups of the facilities under their

jurisdiction.

The magnitude of the nation’s hazardous waste problem calls for the

efficient use of available funds to protect the environment and the public.

We have reported in the past, however, that (1) EPA and other federal

agencies have not consistently allocated their cleanup resources to reduce

the most significant threats to human health and the environment;

(2) although EPA is responsible for pursuing reimbursement when it funds

a cleanup, it has recovered from responsible parties only a fraction of the

moneys that it has spent; and (3) while about half of the Superfund

program’s budget annually goes to contractors, EPA has had long-standing

problems controlling contractors’ costs. In a 1997 report on the Superfund

program’s management, we noted that EPA and other federal agencies have

taken steps toward addressing these problems, but further action is

needed in each area.18 For example, in the area of contract management,

we reported that EPA needs to improve the quality of its independent cost

estimates and use them more effectively to determine the scope and size

of its contractors’ work budgets.

EPA’s draft strategic plan addresses some of these problems in general

terms. Two of the strategies under its better waste management goal are to

(1) maximize potentially responsible parties’ participation in conducting

or funding response actions while promoting fairness in the enforcement

process and (2) manage the use of contract dollars to improve

performance and reduce cost. The draft plan also states under the

effective management goal that EPA will enhance its contract management

information systems.

Managing Information

Resources

The Paperwork Reduction Act of 1995 and the Clinger-Cohen Act of 1996

direct agencies to implement a framework of modern technology

management on the basis of practices followed by leading private and

public organizations that have successfully used technology to improve

performance and help meet strategic goals. Under these laws, agencies are

to better relate their technology plans and information technology use to

their programs’ missions and goals. EPA’s draft plan notes that the agency

plans to integrate information technology investments with its overall

strategic-planning process and implement best practices identified by us

18High-Risk Series: Superfund Program Management (GAO/HR-95-12, Feb. 1995) and High-Risk Series:

Superfund Program Management (GAO/HR-97-14, Feb. 1997).

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for information resources management. However, the draft plan does not

clearly describe how these strategies will be carried out and how results

will be measured.

Furthermore, EPA, like many other agencies, will face the emerging

management challenges of implementing modern technology and resolving

the need for computer systems to be changed to accommodate dates

beyond 1999—the “year 2000 problem.” Yet, EPA’s draft plan does not

discuss how the agency intends to address the “year 2000 problem” as well

as any significant information security weaknesses—two issues that we

have identified as high risk across the government.19

EPA’s draft plan also highlights the need for enhancing information systems

to improve the quality and timeliness of management information and for

integrating information technology investments with the agency’s overall

strategic-planning process. However, strategies and measures for doing so

are not specifically addressed in the draft plan. In commenting on a draft

of this report, EPA officials said that the September 1997 version of the plan

will address these information management challenges.

EPA Faces Challenges

to Provide Reliable

Information on

Achievement of

Strategic Goals

In its draft strategic plan, EPA points out that its new planning, budgeting,

analysis, and accountability process will enable it to better manage for

results. However, the agency does not currently have the reliable

information it needs to measure results. The accountability component of

the new system is being designed to allow EPA to obtain the information

necessary to evaluate and report its progress toward its goals and

objectives. Nonetheless, as we reported in June 1997, EPA faces substantial

challenges to obtain the scientific and environmental information needed

to fully support its new system, including determining progress toward

meeting key environmental indicators. Furthermore, various problems in

EPA’s financial data and internal control systems could hinder EPA’s ability

to accurately measure cost information supporting its goals and

objectives.

Scientific and

Environmental Data

Although EPA has collected much scientific and environmental

information, many gaps exist, and the data are often difficult to compile

because different data collection methods have been used. Although EPA

has tried to improve the quality of its data, these data are often unreliable,

and the agency’s disparate information systems are not integrated. These

19GAO High Risk Series (GAO/HR-97-20, Feb. 1997).

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shortcomings have been raised in various external and internal reports on

EPA, including the Vice President’s report on reinventing government.20

Likewise, much effort is still needed to identify, develop, and reach

agreement on a comprehensive set of environmental measures to link

EPA’s activities to changes in health and environmental conditions.

Currently, EPA has to rely mainly on activity measures, such as the number

of permits issued or inspections made, to measure its performance or

success. In its April 1995 report, NAPA identified the lack of high-quality

data on environmental conditions as a particularly important problem for

EPA.

In our June 1997 report, we pointed out that EPA has been trying since the

1970s to revise its management systems to better manage for results. We

observed that the agency will likely need several years to develop and fully

implement an integrated planning, budgeting, and accountability system.

Even with this much time, the agency will have difficulty obtaining the

scientific and environmental data and developing and reaching agreement

on the appropriate environmental measures of its programs’ and its own

performance called for by the new system. Given the complexity of these

efforts and the time required to complete them, we recommended that the

EPA Administrator, in consultation with key stakeholders, establish

expectations or benchmarks for how the new system is to operate when

fully implemented and use them to monitor the agency’s progress in

implementing the system. EPA agreed with our recommendation and the

need to identify some measures of success for implementing the new

planning, budgeting, and accountability system—that is, some way for the

agency to know whether it is progressing toward the type of system

intended.

In its draft strategic plan, EPA also recognizes that meeting its objectives

will depend upon developing and using common indicators and measures

with the states to track progress and establish commitments between the

states and EPA. The plan briefly discusses the agency’s efforts to work with

the environmental commissioners of states to draft “core performance

measures,” which EPA expects will eventually be part of most state/EPA

work plans and related agreements. While EPA and the states have various

efforts under way to develop and use environmental measures and

indicators, as stated in our June report on EPA’s efforts to manage for

results, these efforts, while valuable, have been disparate. For example, at

a conference convened by EPA in September 1996 to better coordinate

20Reinventing Environmental Regulation, National Performance Review (Mar. 16, 1995).

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these efforts, state and EPA regional representatives said that

(1) clarification is needed on EPA’s and the states’ direction in developing

indicators; (2) some qualities of a good indicator are not well understood;

and (3) in some cases, determining whether the best indicators have been

chosen will take many years. Thus, it appears that it will be some time

before EPA is able to develop and use a set of environmental indicators that

accurately and comprehensively reflect the impact of its programs or their

results.

Financial Data EPA’s Office of the Inspector General’s (OIG) opinion on the agency’s

consolidated financial statements for fiscal year 1996 was, in part,

qualified because data supporting amounts accrued for grantees’ unbilled

expenses could not be confirmed and estimates for unbilled Superfund

oversight costs were not sufficiently accurate. The OIG’s audit identified

these same issues as resulting in internal control weaknesses that were

deemed to be material weaknesses. Additionally, the OIG report cited a

number of other reportable conditions in their evaluation of internal

control. These reportable conditions included internal control weaknesses

in areas, such as accounts receivable, property, and documentation of the

agency’s Integrated Financial Management System. While the strategic

plan addresses a material weakness in the area of grant closeouts, it does

not address the above issues that directly relate to the reliability of data

supporting fiscal performance.

EPA officials told us that the September 1997 version of the strategic plan

will contain more information on financial management. According to the

officials, at a minimum, a performance measure for financial management

will be added to the plan under the effective management goal.

Agency Comments We provided EPA with copies of a draft of this report for review and

comment. We met with EPA officials, including the Acting Deputy Director

of the Office of Planning, Analysis, and Accountability and the Director of

the Office’s Planning Staff. The EPA officials said that the report is a fair

and objective assessment of the July 1, 1997, draft strategic plan that we

reviewed. The officials also said that they are continuing to revise the draft

plan, will add the two missing elements required by the Results Act, and

will incorporate the other improvements noted in this report. The officials

also suggested clarifications or technical changes that we have

incorporated, as appropriate.

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We are sending copies of this report to the Minority Leader of the House of

Representatives; Ranking Minority Members of your Committees; the

Chairmen and Ranking Minority Members of other Committees that have

jurisdiction over EPA’s activities; the Administrator, EPA; and the Director,

Office of Management and Budget. We will send copies to others on

request.

Please call me at (202) 512-6111 if you or your staff have any questions

about this report.

Peter F. Guerrero

Director, Environmental

 Protection Issues

Enclosure

Page 27 GAO/RCED-97-209R EPA’s Draft Strategic Plan
EPA’s Draft Goals

1. Clean Air. The air in every American community will be safe and healthy

to breathe, as determined by the latest, best scientific evidence. In

particular, children, the elderly, and people with respiratory ailments will

be protected from health risks of breathing polluted air. Strategies to

reduce air pollution will also restore life in damaged forests and polluted

waters.

2. Clean and Safe Water. All Americans will know that their drinking water

is clean and safe. Effective protection of America’s rivers, lakes, wetlands,

aquifers, and coastal and ocean waters will sustain fish, plants, and

wildlife, as well as recreational, subsistence, and economic activities.

Watersheds and their aquatic ecosystems will be restored and protected to

improve public health, enhance water quality, reduce flooding and provide

habitat for wildlife.

3. Safe Food. The foods Americans eat will be free from unsafe pesticide

residues. Children especially will be protected from the health threats

posed by tainted food because they are among the most vulnerable groups

in our society.

4. Preventing Pollution and Reducing Risk in Communities, Homes,

Workplaces andEcosystems. Pollution prevention strategies, risk

management, and remediation strategies aimed at cost-effectively

eliminating, reducing, or minimizing emissions and contamination will

result in cleaner and safer environments in which Americans can live,

work, and enjoy. EPA will safeguard ecosystems and promote the health of

natural communities that are integral to the quality of life in this nation.

5. Better Waste Management and Restoration of Abandoned Waste Sites.

America’s wastes will be stored, treated, and disposed of in ways that

prevent harm to people and to the natural environment. EPA will work to

clean up previously polluted sites and restore them to uses appropriate for

surrounding communities.

6. Reduction of Global and Cross-Border Environmental Risks. The United

States will lead other nations in successful, multilateral efforts to reduce

significant risks to human health and ecosystems from climate change,

stratospheric ozone depletion, and other hazards of international concern.

7. Expansion of Americans’ Right to Know About Their Environment. Easy

access to a wealth of information about the state of their local

environment will expand citizen involvement and give people tools to

Page 28 GAO/RCED-97-209R EPA’s Draft Strategic Plan
EPA’s Draft Goals

protect their families and their communities as they see fit. Increased

information exchange between scientists, public health officials,

businesses, citizens, and all levels of government will foster greater

knowledge about the environment and what can be done to protect it.

8. Sound Science, Improved Understanding of Environmental Risk, and

Greater Innovation to Address Environmental Problems. EPA will develop

and apply the best available science for addressing current and future

environmental hazards, as well as new approaches toward improving

environmental protection.

9. A Credible Deterrent to Pollution and Greater Compliance With the Law.

EPA will ensure compliance with laws intended to protect public health and

the environment.

10. Effective Management. EPA will establish a management infrastructure

that will set and implement the highest-quality standards for effective

internal management and fiscal responsibility.

(160402) Page 29 GAO/RCED-97-209R EPA’s Draft Strategic Plan
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