U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

 Evaluation Report 

EPA Needs a Comprehensive 

Research Plan and Policies to 

Fulfill its Emerging Climate 

Change Role 

 Report No. 09-P-0089 

 February 2, 2009 
Report Contributors:	 Manju Gupta 

 Jeffrey Harris 

Jeffrey S. Hart 

Lauretta Joseph 

John Patrick 

Kalpana Ramakrishnan 

Denton Stafford 

 

Abbreviations 

BOSC Board of Scientific Counselors 

CCSP Climate Change Science Program 

CCTP Climate Change Technology Program 

EPA U.S. Environmental Protection Agency 

FY Fiscal Year 

GCRP Global Change Research Program 

OAR Office of Air and Radiation 

OIG Office of Inspector General 

ORD Office of Research and Development 

Cover Photos: Picture on left shows a hurricane striking a sea wall (photo courtesy National 

Oceanic and Atmospheric Administration). Middle picture shows solar and 

wind technologies (photo courtesy California Public Utilities Commission). 

Picture on right shows coastal erosion in Pacifica, California (photo courtesy 

National Aeronautics and Space Administration). 
 

U.S. Environmental Protection Agency 09-P-0089 

February 2, 2009 Office of Inspector General 

At a Glance
 

Catalyst for Improving the Environment 

Why We Did This Review 

We sought to answer the 

question: how well do the 

policies, procedures, and plans 

of the U.S. Environmental 

Protection Agency (EPA) help 

ensure that its climate change 

research fulfills its role in 

climate change? 

Background 

EPA is 1 of 13 federal 

agencies that make up the 

U.S. Climate Change Science 

Program, which guides federal 

research through its strategic 

plan. Part of EPA’s role is 

understanding the regional 

consequences of global 

change. EPA’s Office of 

Research and Development 

(ORD) handles this function. 

EPA’s Office of Air and 

Radiation conducts activities 

related to mitigating 

greenhouse gases. ORD 

manages EPA’s climate 

change research function 

through its Global Change 

Research Program. 

For further information, 

contact our Office of 

Congressional, Public Affairs 

and Management at 

(202) 566-2391. 

To view the full report, 

click on the following link: 

www.epa.gov/oig/reports/2009/ 

20090202-09-P-0089.pdf 

EPA Needs a Comprehensive Research Plan and 

Policies to Fulfill its Emerging Climate Change Role

 What We Found 

EPA does not have an overall plan to ensure developing consistent, compatible 

climate change strategies across the Agency. We surveyed EPA regions and 

offices and found they need more information on a variety of climate change 

topics. They need technical climate change research and tools as well as other 

climate change policy guidance and direction. We learned that, in the absence of 

an overall Agency plan, EPA’s Office of Water and several regional offices have 

independently developed, or are developing, their own individual climate change 

strategies and plans. The lack of an overall climate change policy can result in 

duplication, inconsistent approaches, and wasted resources among EPA’s regions 

and offices. EPA has not issued interim guidance to give its major components 

consistent direction to ensure that a compatible national policy – when it emerges 

– will not result in wasted efforts. 

EPA’s latest plan for future climate change research does not address the full 

range of emerging information needs. Specifically, the projected time of 

completion or the scope of some research projects do not match the timing or the 

scope of regions’ needs. ORD does not have a central repository of its climate 

change research for its internal users, nor does it effectively communicate the 

results of its climate change research to EPA’s internal users. While ORD 

collects research requirements from regions and program offices, the selection 

criteria for research topics are not transparent to the regions. Finally, ORD does 

not have a system to track research requests through completion, or a formal 

mechanism to obtain feedback from its users. 

What We Recommend 

We recommend that the Deputy Administrator direct Assistant and Regional 

Administrators on how to plan for climate change challenges in their media 

areas/regions until the Agency develops an overall strategy; and establish 

guidance for regularly entering their climate change scientific information in the 

Science Inventory. We also recommend that the Assistant Administrator for ORD 

establish various management controls to ensure EPA fulfills its emerging climate 

change role and related information needs. The Agency concurred with our 

recommendations. 
 

 

 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

February 2, 2009 

MEMORANDUM 

SUBJECT:	 EPA Needs a Comprehensive Research Plan and Policies to Fulfill its 

Emerging Climate Change Role

 Report No. 09-P-0089 

FROM:	 Wade Najjum 

 Assistant Inspector General, Office of Program Evaluation 

TO: Lisa P. Jackson 

 Administrator 

Lek Kadeli 

Acting Assistant Administrator for Research and Development 

This is our report on the Climate Change Program evaluation conducted by the Office of 

Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA). This report 

contains findings that describe the problems the OIG has identified and corrective actions the 

OIG recommends. This report represents the opinion of the OIG and does not necessarily 

represent the final EPA position. Final determinations on matters in this report will be made by 

EPA managers in accordance with established audit resolution procedures. 

The estimated cost of this report – calculated by multiplying the project’s staff days by the 

applicable daily full cost billing rates in effect at the time – is $636,217. 

Recommendations 2-1 and 3-1 of this report are addressed to the Deputy Administrator, and 

Agency comments were received from the Deputy Administrator. The Deputy Administrator 

position is currently vacant. Therefore, we are addressing this report to the Administrator. 

Action Required 

In accordance with EPA Manual 2750, you are required to provide a written response to this 

report within 90 calendar days. You should include a corrective actions plan for agreed upon 

actions, including milestone dates. We have no objections to the further release of this report to 

the public. This report will be available at http://www.epa.gov/oig. 
If you or your staff has any questions regarding this report, please contact me at 202-566-0827; 

or Jeffrey Harris, Director of Cross Media, at 202-566-0831 or harris.jeffrey@epa.gov. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

EPA Needs a Comprehensive Research Plan and 09-P-0089 

Policies to Fulfill its Emerging Climate Change Role 

Table of Contents 

Chapters 

1 Introduction ........................................................................................................... 1 

Purpose .......................................................................................................... 1 

Background .................................................................................................... 1 

 Noteworthy Achievements.............................................................................. 5 

Scope and Methodology................................................................................. 5
 

2 EPA Regions Have Multiple Climate Change Needs.......................................... 7 

EPA Regions Need Differing Climate Change Information ............................ 7
 

EPA’s Office of Water and Most Regional Offices Are Independently 

 Developing Climate Change Strategies .................................................... 9 

Conclusions.................................................................................................... 10 

Recommendation .......................................................................................... 10 

Agency Comments and OIG Evaluation......................................................... 10 

3 Research Plan Does Not Address All Regions’ Climate Change Needs.......... 12 

Regions Need Climate Change Information and Tools 

 Directed at Regional and Local Levels...................................................... 12 

The Timing and Scope of ORD’s Planned Projects 

EPA Lacks Policies to Meet Internal Climate Change 

 Do Not Meet Key Regional Needs............................................................. 13 

Information Needs Effectively.................................................................... 15 

Conclusions.................................................................................................... 17 

Recommendations ........................................................................................ 18 

Agency Comments and OIG Evaluation......................................................... 19 

Status of Recommendations and Potential Monetary Benefits................................. 20 

Appendices

 A Agency Response and OIG Evaluation ............................................................. 21 

B Agency Preliminary Comments and OIG Evaluation ....................................... 26 

C Distribution .......................................................................................................... 30 
 

 

 

09-P-0089 

Chapter 1

Introduction 

Purpose 

The overall purpose of this evaluation was to answer the question, “How well do 

the policies, procedures, and plans (i.e., internal/management controls) of the 

U.S. Environmental Protection Agency (EPA) help ensure that its climate change 

research fulfills its climate change role and related internal needs?” 

To accomplish this objective, we answered the following questions: 

(1) What research products or information do EPA's program and regional offices 

need to fulfill EPA’s climate change role? Do EPA’s Office of Research and 

Development (ORD) climate change research plans meet the information 

needs of EPA’s program and regional offices? 

(2) Does EPA have policies, procedures, or other internal/management control 

mechanisms in place to efficiently and effectively coordinate its climate 

change research, and to ensure expertise across the Agency is being used to 

fulfill its climate change role? 

Background 

Since the enactment of the Global Change Research Act of 1990, EPA’s research 

on climate change – also known as global warming – has been part of a national and 

international framework. EPA is 1 of 13 federal agencies that comprise the U.S. 

Climate Change Science Program (CCSP). The CCSP was launched in 2002. The 

CCSP incorporated both the U.S. Global Change Research Program (GCRP) and 

the U.S. Climate Change Research Initiative of 2001. The CCSP Strategic Plan 

guides federal research on climate change, and the 13 agencies focus their research 

on areas related to their unique missions in a collaborative effort.1 Figure 1.1 on 

page 2 shows the relationships between these different organizations. 

CCSP’s strategic plan defines EPA’s role as having a primary focus on 

understanding the regional consequences of global change. Within EPA, ORD 

performs this role. ORD has the responsibility for assessing the potential impacts 

1

 CCSP assessment activities, in turn, contribute to the work of the Intergovernmental Panel on Climate Change. 

Established by the United Nations and the World Meteorological Organization, the Intergovernmental Panel on 

Climate Change assesses scientific, technical, and socio-economic information to better understand climate change, its 

potential impacts, and options for adaptation and mitigation. 

1 
 

Figure 1.1: Relationships between International, National (U.S. Federal), and EPA 

Climate Change Programs 

International Level Intergovernmental Panel on Climate Change 

U.S. Global Change U.S. Climate Change 

U.S. Federal Level Research Program Research Initiative 

1990 2001 

U.S. Climate Change U.S. Climate Change Science Program Technology Program (CCSP) 2002,includes (CCTP) 2002 13 federal agencies 

EPA ORD Global EPA OAR Climate EPA OAR Climate EPA Level Change Research Protection Change Division Program (GCRP) Partnership Division 

 Source: Office of Inspector General (OIG) 

We focused primarily on ORD because it has the central responsibility for EPA 

climate change research under the CCSP, and because ORD is the scientific 

research arm of EPA. ORD’s mission is to: 

• perform research and development, 

• provide responsive technical support to EPA, 

• integrate the work of ORD's scientific partners, and 

• provide leadership in addressing emerging environmental issues. 

 

09-P-0089 

of climate change and evaluating adaptation options.2 The Office of Air and 

Radiation (OAR) has responsibility for activities related to mitigating greenhouse 

gases. Both ORD and OAR communicate science findings and information about 

adaptation options. 

2 While the primary focus of ORD climate research has been on assessing the potential impacts of climate change 

and alternative adaptation options, this is changing given the directives of the Fiscal Year 2008 Appropriations Bill. 

ORD also has some responsibility for mitigation. Further, as discussed in Chapter 3, EPA’s draft 2008 GCRP multiyear plan synopsis addresses four different categories of regional mitigation research decisions/concerns: (1) Clean 

energy, (2) Renewables/Biofuels (wind & solar), (3) Mitigation models, and (4) Sequestration. 

2 
 

3

 A 2008 GCRP Multi-Year Plan Synopsis describes EPA’s GCRP as stakeholder-oriented, with primary emphasis 

on assessing the potential consequences of global change (particularly climate variability and change) on air quality, 

water quality, aquatic ecosystems, and human health in the United States. 4

 Congress’ passed Science and Technology Omnibus FY 2008 spending bill specifically increases the GCRP’s 

budget and stipulates that the new resources will be used to conduct research in support of the Agency’s efforts to
 

regulate greenhouse gas emissions.
 

3 

09-P-0089 

ORD manages EPA’s climate change research function through its GCRP.3  

ORD’s GCRP not only assesses the impacts of global change; it also focuses on 

the implications of climate change on EPA’s ability to satisfy its statutory, 

regulatory, and programmatic requirements. EPA also has statutory obligations to 

provide scientific information to organizations other than EPA regional and 

program offices. 

The scope of OAR’s interest is similar to the scope of ORD's climate change 

work. However, OAR is focusing more on mitigation and the effect of regional 

air quality control strategies on climate change, as opposed to the effect of climate 

change on regional air quality. 

EPA Climate Change Research Funding 

Relevant scientific and technical work is coordinated across the Federal 

Government by the CCSP and the U.S. Climate Change Technology Program 

(CCTP). CCSP received about $1.8 billion in Fiscal Year (FY) 2008, and CCTP 

received about $3.9 billion. In contrast, EPA received about $36.6 million in 

FY 2008 for Science and Technology funding for climate change. ORD's budget 

for GCRP, ranging between about $16 and $20 million annually over the last 

3 years, is about 1 percent of the total CCSP budget. 

ORD’s overall budget for FYs 2001-2008 decreased (using inflation adjusted 

dollars) 20 percent from $696 to $548 million, while its GCRP budget declined 

36 percent from $28 to $18 million during the same period. GCRP’s budget has 

been about 3 percent, on average, of ORD’s entire budget for the last 6 years as 

shown in Figure 1.2.4 
 

 

09-P-0089 

Figure 1.2: ORD Global Climate Research Plan Budgets as a Percentage of ORD’s 

Total Budgets, FYs 2001-2008 Millions in 2008 Inflation

Adjusted Dollars ($)

$900 

$800 

$700 

$600 

$500 

$400 

$300 

$200 

$100 

$0 

$696 $707 $683 

$745 $736 

$577 $548 $634 

$28 $25 $22 $24 $22 $20 $18$17

4.0% 3.5% 3.0% 3.3% 3.2% 3.2% 2.9% 3.3% 

ORD Total 

GCRP 

GCRP/Total (%) 

2001 2002 2003 2004 2005 2006 2007 2008 

Fiscal Years 

Source: OIG 

EPA’s Evolving Climate Change Role 

The evolving mission for EPA includes a larger role in researching alternative 

strategies to mitigate climate change. In the January 2007 State of the Union 

Address, President Bush stated: 

America is on the verge of technological breakthroughs that will 

enable us to live our lives less dependent on oil. And these 

technologies will help us be better stewards of the environment, 

and they will help us to confront the serious challenge of global 

climate change. 

Soon after the President emphasized that climate change was a “serious 

challenge,” in April 2007, the Supreme Court held that “... the Clean Air Act 

authorizes EPA to regulate emissions from new motor vehicles on the basis of 

their climate change impacts....” 5 The Court decision contributed to shifting 

EPA’s role from focusing not only on assessing impacts of and adaptation to 

climate change, but also on mitigation measures. 

Shortly thereafter, on June 11, 2007, EPA issued a Working Paper, EPA 

Administrator’s Priorities: Clean Energy and Climate, “...to help accelerate 

environmental protection, reduce greenhouse gases, and strengthen energy 

security.” Subsequently, EPA programs and regions (and their respective States) 

5

 Massachusetts et al. v. EPA (Case No. 05-1120). 

4 
09-P-0089 

began identifying additional needed climate change research, information, and 

related products. 

Noteworthy Achievements 

The Board of Scientific Counselors (BOSC) is a public advisory committee 

chartered under the Federal Advisory Committee Act that provides advice, 

information, and recommendations about the ORD research program. A BOSC 

subcommittee performed a review of ORD’s GCRP and published its final report 

on March 27, 2006. The review found that within the context of what GCRP had 

been asked to do so far, it had done the “right work” and that it had done it “well.” 

Scope and Methodology 

To determine how well EPA’s policies, procedures, and plans (i.e., 

internal/management controls) help ensure that its climate change research fulfills 

EPA’s climate change role and related internal needs, we reviewed documents 

relating to: 

• ORD’s and EPA’s responsibilities and policies on climate change, 

• EPA’s 2006-2011 Strategic Plan, 

• GCRP’s 2008-2012 Draft Multi-Year Plan, 

• BOSC’s Mid-Cycle Review of GCRP, and 

• legislation regarding climate change. 

We also reviewed documents provided by the GCRP National Program Director 

and attended several relevant conferences concerning climate change. 

We conducted two surveys to identify what research products or information 

EPA's program and regional offices need to fulfill EPA’s climate change role. 

We sent the first survey to regions and program offices to identify the universe of 

specific climate change decisions and concerns, and to determine the adequacy of 

EPA’s climate change policies and procedures. 

We sent a second survey to selected ORD managers and staff to obtain 

information on ORD’s existing and planned climate change research products as 

well as EPA’s policies. We analyzed responses from the 10 EPA regions, OAR, 

and ORD’s GCRP. We judgmentally chose five climate change decisions and 

products to use as case studies for more detailed follow-up. The five case studies 

came from five different EPA regions. We then conducted follow-up interviews 

with representatives of the five regions. 

To determine whether GCRP’s climate change research plans meet the 

information needs of EPA’s programs and regional offices, we analyzed and 

compared GCRP planned research product topics and timeframes to the decisions 

and concerns identified by regions. We also reviewed ORD’s budgets for the last 

5 
09-P-0089 

8 years and compared them to annual ORD and GCRP budgets to identify any 

funding trends. Further, we interviewed selected external stakeholders concerned 

with climate change or research. 

We conducted this review in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the review 

to obtain sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based upon 

our objectives. We performed our evaluation between November 2007 and 

April 2008. 

6 
09-P-0089 

Chapter 2

EPA Regions Have Multiple 

Climate Change Needs 

EPA does not have an overall plan or other means to ensure the development of 

consistent, compatible climate change strategies across EPA or to make the best 

use of declining research dollars. EPA regions have multiple climate change 

needs, including the need for information on a variety of different climate change 

topics. Regions stated that they needed technical climate change research and 

tools, as well as other climate change policy guidance and direction. In the 

meantime, EPA’s Office of Water and regional offices have independently 

developed, or are in the process of developing, individual climate change 

strategies and plans. The lack of an overall climate change policy can result in 

duplication, inconsistent approaches, and wasted resources among EPA’s regions 

and offices. 

EPA Regions Need Differing Climate Change Information 

Regional respondents to our survey identified a variety of different, emerging 

climate change information needs. They need technical climate change research 

or information, as well as related policy guidance and direction. 

Regions Need Technical Information 

Regions stated they would like technical information on: 

•	 impacts of climate change, 

•	 mitigation or greenhouse gas emissions reduction/energy efficiency 

technologies, 

•	 tools to assess the effectiveness of emissions reduction technologies and 

climate change policy decisions, and 

•	 adaptation strategies to moderate potential climate-related damage and 

preventive measures. 

Table 2.1 shows the types of climate change information regions require. 

Regions 2 and 8 were in the process of identifying climate change research and 

information needs, and did not identify specific needs at the time of our survey. 

7 
 

 

 

09-P-0089 

Table 2.1: Regional Climate Change Information Needs 

Region 

Impact of 

Climate 

Change 

Mitigation 

Technologies 

Effectiveness of 

Mitigation Technologies 

and Climate Change 

Policies 

Adaptation 

Strategies 

1 x x x 

3 x x 

4 x x x 

5 x 

6 x x x 

7 x 

9 x x x x 

10 x x x 

Source: OIG 

Seven regions stated they require a variety of technical information on the impact 

of climate change. For example, they need information on the potential impacts 

of temperature and health effects, food supply considerations, and local and 

regional impacts. Region 6 stated that it would like information on the impact of 

rising water on aquifers and ground water monitoring. Region 7 stated it would 

like information on the impacts on agricultural processes. Region 9 stated that it 

would like information on the impacts on water bodies and agriculture due to 

changing pest pressures and invasive species. 

Several regions identified information needs on mitigation technologies. Regions 

stated that they would like additional information on alternative energy sources 

such as biofuel, solar, and wind technologies. Regions 6 and 9 require 

information on carbon sequestration, specifically regarding the feasibility of 

sequestration at Superfund sites. They also need information on the safety and 

efficacy of geologic carbon sequestration. 

Regions stated they require tools to assess the effectiveness of mitigation 

technologies along with anticipated climate change policies. For example, 

Regions 2 and 6 needed computer models to determine the effectiveness of 

mitigation technologies and their impact on policy decisions and planning 

processes. Regions 5 and 6 stated that they would like information on the 

effectiveness of using bio-fuels, such as corn ethanol, as a method for reducing 

greenhouse gases. Regions 1 and 6 would like to develop emissions inventories 

to monitor reducing greenhouse gases, and would like to have a common protocol 

to quantify the benefits of energy efficiencies. 

Regions also stated they would like information on adaptation strategies, 

including tools to asses their effectiveness. For example, Region 1 stated that, 

“As the likely impacts of climate change become better understood, we have 

become more and more interested in science-based tools (e.g., predictive models 

of coastal impacts) to assist states and communities in preparing for those impacts 

(e.g., predictive models of impacts on coasts).” Region 9 stated that it wanted 

information on how to develop alternative approaches to storing surface water for 

8 
 

 

09-P-0089 

dry seasons. Region 10 listed several adaptation information needs such as 

identifying appropriate water infrastructure, and ensuring the integrity of drinking 

water systems in case of sea level rise and episodic flooding, both potential 

hazards of climate change. Region 10 also stated its tribal communities require 

information and adaptation strategies that are consistent with tribal cultural 

perspectives. 

Regions Need Policy Guidance and Direction 

Regions stated in survey responses that they need additional policy guidance and 

direction on climate change and related research. They said they need this 

information in anticipation of any new climate change legislation. They need the 

information not necessarily from ORD, but from other EPA program offices. For 

example, Region 1 anticipates needing to provide effective technical guidance to 

operators of wastewater treatment plants to ensure the greatest possible energy 

efficiency. Region 1 anticipates needing presentations, brochures, and other 

outreach material to educate the regulated community and the public about 

specific requirements. Region 9 staff need guidance on whether to allow 

permitting of new coal-power electricity plants.6 Region 10 needs guidance on air 

quality programs and how to align timelines and schedules of implementing these 

programs when addressing climate change impacts. Some regional 

representatives need guidance on how to assess climate change from a tribal 

perspective along with plans to attain and maintain air quality standards. 

EPA’s Office of Water and Most Regional Offices Are Independently 

Developing Climate Change Strategies 

EPA’s Office of Water and most regional offices are independently developing 

their own climate change strategies or plans. Although the Administrator issued a 

working paper on energy and climate, as discussed in Chapter 1, EPA does not 

have an overall climate change policy. EPA’s Office of Water has developed its 

own draft climate change strategy, and 7 of 10 EPA regions responded to surveys 

that they had or were working on their own climate change plans or strategies. 

The Office of Water did not respond to our survey because at the time it was 

developing a strategy to deal with the impact of climate change. Office of Water 

staff stated that they are in the early stages of understanding how climate change 

will affect different water programs. Although the Office of Water has an idea of 

how climate will affect water resources based on best professional judgments, the 

Office is waiting to receive scientific feedback to better understand the nature of 

the problem. 

6

 Some new power plants had designs to utilize geologic carbon sequestration. However, because the safety and 

efficacy of carbon sequestration has not been established, Region 9 cannot determine if it can issue permits to the 

power plants. 

9 
 

 

09-P-0089 

EPA Regions 1, 2, 5, 6, 8, 9, and 10 have either developed draft strategies or are 

developing draft climate change action plans or strategies.7

 However, climate 

change poses a new set of challenges. Region 9, for example, stated that two 

major challenges are “deciding what degree to implement the highest priority 

activities and how to accomplish the work.” In general, the regions are looking 

into how they can further reduce greenhouse gas emissions and how to create 

strategies to help them adapt to climate change. 

Conclusions 

EPA regional offices stated they need a variety of research products, technical 

information, or tools on climate change impacts, adaptation, and mitigation. 

Moreover, regions require policy guidance and direction on how to implement 

any new climate change legislation. In the meantime, some program and regional 

offices are independently creating separate, individual climate change action plans 

and strategies. 

An overall EPA strategy for climate change should: 

•	 lead to clear research requirements, 

•	 help the Agency fulfill its climate change role, and 

•	 provide “unity” of action so regions and program offices can proceed with 

confidence in establishing their own climate change strategies and plans. 

Such a national strategy does not yet exist. The lack of an overall climate change 

policy can result in duplication, inconsistent approaches, and wasted resources 

among EPA’s regions and offices. EPA has not issued interim guidance to give 

its major components consistent direction so that a compatible national policy – 

when it emerges – will not result in wasted efforts. 

Recommendation 

We recommend that the Deputy Administrator: 

2-1	 Direct Assistant and Regional Administrators on how to plan for climate 

change challenges in their media areas/regions until the Agency develops an 

overall strategy. 

Agency Comments and OIG Evaluation 

The Agency concurred with our recommendation. Recently, the Agency initiated 

a process that will contribute to an Agency approach on climate change. 

Additionally, the Agency agreed to provide the OIG with progress updates. To 

7

 One region did not indicate whether it had developed a strategy or was developing a climate change action plan or 

strategy. 

10 
09-P-0089 

meet the OIG’s requirements, the Agency’s approach should also include 

milestones for each specified action. The Agency’s written response, as well as 

our evaluation of Agency comments, is in Appendix A. 

11 
 

09-P-0089 

Chapter 3

Research Plan Does Not Address All Regions’ 

Climate Change Needs 

GCRP’s January 2008 draft research plan does not address the full range of 

EPA’s climate change information needs. Regions need climate change tools and 

information to fulfill EPA’s regulatory responsibilities. In addition, the timing or 

the scope of GCRP’s planned research projects do not match the timing or the 

scope of regions’ needs. Finally, ORD lacks procedures to ensure it meets 

internal EPA climate change information needs effectively. 

Regions Need Climate Change Information and Tools Directed at 

Regional and Local Levels 

EPA regions need climate change information and tools directed at regional and 

local levels. They need this information and these tools, in part, to fulfill EPA’s 

regulatory responsibilities related to their programs. Regions’ areas of concern 

include air quality; projections of sea level rise affecting their regions; and 

impacts of episodic flooding on water infrastructure, wetlands, and critical habitat 

for endangered species in their local areas. 

GCRP completed a national level preliminary assessment of the implications of 

climate change for air quality across the United States in September 2007. GCRP 

plans to complete a more comprehensive assessment and report on the climate 

change impact on national and regional air quality by 2012. However, regions 

need information and tools to fulfill EPA’s regulatory responsibilities related to 

their specific programs and activities, such as approving State Implementation 

Plans8

 and permits. Regions require tools and models that they can use to assess 

the climate change impact on air quality at a more local level. In many cases, air 

quality problems are localized, and climate change impacts on air quality vary 

from one geographic area to another. 

Seven regions (Regions 1, 4, 5, 6, 7, 9, and 10) stated that they require regional or 

local scale models to develop adaptation strategies that would work for their 

cities, States, and regions. For example, Regions 6, 9, and 10 need research on 

sea level rise specific to their geographic region. Their concerns include the 

impact of sea level rise on the quality and quantity of drinking water, and on 

waste water treatment plants. These regions are also concerned about sea level 

rise near Superfund sites in their coastal areas. Regions 6 and 9 need regional 

8

 State Implementation Plans identify how each State will attain and/or maintain the primary and secondary 

National Ambient Air Quality Standards. 

12 
 

09-P-0089 

level analysis on the severity and frequency of drought, and the decrease in 

mountain snow pack. 

Similarly, regions need geographic-specific predicted impacts in other areas for 

resource planning and management. For example, Region 7 needs research on 

disaster-related weather events, and the impact of climate change on agricultural 

processes in its region. Region 10 needs region-specific climate change impact 

information to inform local decision makers on building adaptation infrastructure, 

such as additional sea walls or dikes. This infrastructure could be impacted by 

increased storm intensity and tidal surges that can cause damage to facilities, as 

well as damage due to sea level rise. 

The Timing and Scope of ORD’s Planned Projects Do Not Meet Key 

Regional Needs 

Although GCRP’s draft 2008-2012 Multi-Year Plan addresses most of the topic 

areas identified by regions, the timing and scope of the planned research projects 

do not meet key regional needs. We compared research topics and delivery dates 

of the planned research topics to the information needs the regions identified in 

response to our survey in December 2007. We concluded that the planned 

completion dates for many of GCRP's planned research topics do not meet all of 

the regions’ needs. Regions started developing their climate change strategies and 

plans after the EPA Administrator added climate change to his list of priorities for 

regions in June 2007. However, the survey responses show that the regions need 

information on many climate change topics within the next year or even 

immediately. 

We asked in our survey for the regions to list five current or future climate 

change-related decisions or areas of concerns. The regions listed 57 decisions or 

areas of concerns. We then summarized these 57 decisions or concerns into 11 

summary categories, and compared them to the draft 2008-2012 Multi-Year Plan, 

as shown in Table 3.1. 

13 
 

 

 

 

09-P-0089 

Table 3.1: Regional Research Needs versus GCRP’s Planned Research Projects 

Regional 

Decision or 

Concern 

Category 

Regions That 

Cited the 

Decision or 

Concern 

Addressed 

in GCRP 

Multi-Year 

Plan? 

Regional Timeline 

When Information 

Is Needed 

GCRP 

Timeline 

Satisfies 

Regional 

Needs? 

1. Air quality 

impacts 

9, 10 Yes Ongoing, 1 to 2 

years, immediately 

Yes 

2. Clean energy/ 

 efficiency 

1, 6 Yes Immediately, 

medium term 

Yes 

3. Water quality/ 

Quantity/ 

 Wastewater 

1, 5, 6, 10 Yes Ongoing, Jan/2010, 

short-term 

Yes 

4. Sea level 

changes 

6, 9 Yes Short term, 

Jan/2010, 3-5 years 

Yes 

5. Ecosystem 

services 

6, 9, 10 Yes 2008, June 2011, 

within 3-5 years 

Yes 

6. Droughts/ 

water 

variability 

6, 9 Yes Jan/2010, 3-5 

years, 5-10 years 

Yes 

7. Adaptation 

strategies 

4, 8 Yes ASAP No 

8. Renewables/ 

Biofuels (wind 

& solar) 

3, 5, 6, 9 Yes Ongoing, ASAP, 

presently, Jan/2009 

immediately 

No 

9. Mitigation 

models 

4, 6 Yes ASAP No 

10. Impact models 1, 3, 4, 6, 9 Yes Continuous, 

presently, ASAP, 

Jan/2012, June 

2012, immediately 

Cannot 

determine 

11. Sequestration 3, 5, 6, 9 Yes Presently, ASAP, 

long-term, 2-5 

years 

Cannot 

determine 

Source: OIG analysis of survey responses and GCRP’s Draft Multi-Year Plan. The 11 numbered 

categories do not represent any priority. 

We compared regional research needs and desired timeframes to GCRP’s planned 

products and their estimated completion dates. We found that GCRP’s draft plan 

addressed 6 of the 11 summary categories in some manner. As shown above in 

Table 3.1, GCRP is planning to provide the type of information requested by the 

regions in the first six categories soon enough to meet the regions’ needs. 

However, GCRP’s timeframe for delivery did not match the regions’ needs in at 

least three categories. In the last two categories above, we could not determine 

for certain whether GCRP was planning to provide the type of information 

requested by the regions soon enough to meet the regions’ needs. 

As shown in Table 3.1, GCRP plans to satisfy the regions’ air quality impact 

needs on time. GRCP is researching climate change air quality impact measures, 

and plans other similar projects. The research topics include the impact of climate 

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change on U.S. particulate matter concentrations, and the human health impacts 

due to global change effects on air quality. GCRP plans projects in these two 

topic areas for 2009 and 2011, respectively. The regions stated that they needed 

these types of products either immediately, “ongoing,” or in 1-2 years. GCRP 

plans to satisfy these needs on time. 

On the other hand, the regions are also asking for information on bio-fuel, solar, 

and wind farm technologies. The regions also need information on the possibility 

of widespread environmental damage associated with large-scale increased corn 

production for use in ethanol production. Responses from different regions listed 

the time they need this information as immediate, “ongoing,” and “ASAP.” 

However, according to the draft Multi-Year Plan, GCRP does not plan to 

complete its renewable fuels research until 2011. In the interim, ORD has 

established a work group on bio-fuels that includes participants from regions, 

OAR, and ORD. ORD representatives stated that regions can obtain interim 

results by joining the workgroup. 

EPA Lacks Policies to Meet Internal Climate Change Information 

Needs Effectively 

EPA’s policies and procedures do not ensure that it can meet the climate change 

research information needs of its program offices and regions. EPA does not have 

a repository of climate change research conducted by the other agencies. While 

ORD has set up processes for communicating with regions, the processes do not 

have the force of policy. As a result, ORD’s communication of research results is 

not coordinated or consistent. Finally, EPA does not have a policy to ensure that 

climate change research is effectively coordinated between ORD, program 

offices, and regions. 

EPA Does Not Have a Central Repository of Climate Change 

Information 

EPA does not have a central repository of climate change-related research 

information. ORD does not systematically or comprehensively collect climate 

change research information and make it available to EPA’s internal users. EPA 

regions and program offices regularly need and obtain climate change research 

information from external sources. 

Responses to the survey showed that regions and program offices use a variety of 

sources outside of EPA for obtaining climate change research information they 

need to carry out their responsibilities. Regions obtain this information through 

their own informal networks and contacts. The sources they turn to include other 

federal agencies, non-governmental organizations, academic researchers, and 

international organizations. Fourteen of 16 respondents stated that they get 

climate change research information from other federal agencies. Survey 

respondents stated that the information they need to carry out their responsibilities 

15 
09-P-0089 

may be located at the Department of Energy, the National Oceanic and 

Atmospheric Administration, or the Department of Agriculture. However, ORD 

does not systematically collect that information and make it available to EPA 

users. For example, Region 10 uses regional sea level rise information from the 

National Oceanic and Atmospheric Administration because ORD focuses on sea 

level rise from a national perspective. Region 5 uses research from the 

Department of Agriculture related to land use and bio-fuels. Region 6 gets 

emissions research information from the Department of Energy. However, survey 

respondents also mentioned informal methods and networks staff use to obtain 

information from external sources. The potential for duplication of effort and 

inefficiency exists when EPA staff in regions and program offices independently 

collect information from external sources. 

ORD Does Not Systematically Communicate Research Results 

ORD does not systematically communicate all relevant research results to its 

users. ORD uses formal and informal mechanisms to share results of its research. 

Formal mechanisms include publishing reports in technical journals, reporting to 

the CCSP, and publishing information on EPA Websites. GCRP’s research 

products are also published in CCSP reports and posted on the CCSP Website. 

ORD established a Science Inventory with the intent of compiling all ORD 

research reports. According to ORD, each EPA office is responsible for adding 

its own science activities to the inventory. However, the Science Inventory is not 

current because it has not been consistently updated or maintained. 

ORD’s GCRP recently established a new Web-based climate change-related tool 

called the Environmental Science Connector. This tool is accessible to all EPA 

users. This Web-based tool contains a variety of GCRP climate change researchrelated information. However, it contains only GCRP documents, is still in the 

early stages of implementation, and is still being refined. According to ORD, 

they also have other systematic methods of communicating the results of their 

research, including: 

• a new public Website, Science to Achieve Results, 

• regularly-scheduled Science to Achieve Results progress review sessions, 

• fact sheets, and 

• public lectures and presentations. 

Nonetheless, EPA survey respondents indicate that these methods are not entirely 

effective. 

ORD’s informal processes to communicate climate change research information 

to regions and program offices include workshops, meetings, and weekly 

telephone calls with the GCRP National Program Director in which regions and 

program offices can participate. However, since these processes are informal, 

participation is inconsistent and only partly effective. 

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EPA Does Not Have a Policy to Ensure Research is Effectively 

Coordinated 

ORD routinely included the regional offices when developing its new draft MultiYear Plan through Research Coordinating Teams. However, EPA does not have a 

formal policy to ensure that climate change research is effectively coordinated 

among ORD, program offices, and regions. 

ORD’s research selection process is not transparent to the regions. The March 

2006 BOSC report stated that ORD should have a transparent priority setting 

process so stakeholders understand how ORD chooses issues to address. 

Transparency is necessary so stakeholders understand how they can participate in 

the process. In developing its new draft Multi-Year Plan and research strategy, 

ORD coordinated with regions by asking them for their research requirements. 

However, regions do not know why some topics were selected and others were 

not. In some instances, when a research topic is not chosen, the reason is not 

documented or communicated. Survey results and our follow-up interviews with 

regional representatives show that the regions did not know how and why topics 

were selected or not selected for research. 

We also found that ORD does not have a system to track regional research 

requirements from the time they are received to the time a decision is made about 

whether and how the requirement will be met. ORD also does not track research 

requests or products by requestor. However, managers from ORD’s Office of 

Science Policy told us that a project is underway to establish a database that will 

track research needs to completion and to the requestor. 

Additionally, ORD does not have a formal, systematic mechanism to obtain 

feedback on how well its research products meet users’ requirements. The March 

2006 BOSC report stated that ORD needed to focus more on ensuring that 

information provided to decision makers is valuable, applicable, and 

understandable. In response to our discussion draft, ORD indicated that it will 

conduct a survey before the next BOSC review. 

Conclusions 

In 2007, EPA program offices and regions began identifying their research and 

information needs to fulfill their responsibilities. However, EPA does not yet 

have a comprehensive climate change research plan that matches EPA’s evolving 

climate change role. ORD’s current climate change research products and plans 

do not meet users’ needs in timeliness or scope. Some changes in policy and 

procedures are needed to ensure ORD can meet regions’ climate change research 

information needs. 

When the EPA Administrator added climate change as a regional priority in June 

2007, regions began identifying new climate change information needs. Before 

17 
 

09-P-0089 

that time, regions generally did not request specific climate change-related 

research. To address the new priority, regions need some climate change 

information immediately or in the very near future. 

Compounding the situation, ORD does not maintain a central repository of 

climate change research information from other sources that EPA’s internal users 

frequently need. Nor does ORD have a formal policy to systematically 

communicate climate change research to regions or other interested parties. The 

Science Inventory database is not current, and the new Environmental Science 

Connector is in the early implementation stage and still being refined. In 

addition, ORD’s research selection process is not transparent, and ORD does not 

yet have a system to track regional research requirements to completed research 

products or to requestors. Finally, ORD does not have a formal mechanism to 

obtain feedback from regions and program offices on how well its research 

products meet users’ requirements or information needs. These issues can result 

in an ineffective use of resources, which could be avoided through better 

management controls. Implementation of our recommendations will also help 

make the best use of declining resources. 

Recommendations 

We recommend that the Deputy Administrator: 

3-1 Establish guidance to programs and regional offices for regularly entering 

their climate change scientific information in the Science Inventory. 

Further, we recommend that the Assistant Administrator for the Office of Research and 

Development: 

3-2 Ensure that ORD continues to routinely update the Science Inventory to 

include the latest information from its laboratories and centers. 

3-3 Establish a formal, transparent research requirements determination 

process that includes well-defined procedures for identifying a unified set 

of priority climate change research needs. 

3-4 Establish a formal mechanism to track regional research needs from 

research project selection to completion, and to requestor. 

3-5 Establish a formal method for coordinating GCRP’s research work with 

regions and program offices, communicating research results, and 

collecting feedback on research products. The feedback requested should 

include the accessibility, usability, value, and awareness of updates to the 

Science Inventory and the Environmental Science Connector. 

18 
 

 

09-P-0089 

Agency Comments and OIG Evaluation 

ORD concurred with our recommendations; however, many of the responses 

include prospective actions. The Agency must submit a Corrective Action Plan 

including milestones and dates for these proposed actions. The Agency’s 

complete final written response and OIG evaluation are in Appendix A. EPA’s 

preliminary memorandum response and OIG comments are in Appendix B. 

In response to the first recommendation, EPA agreed that Agency’s scientific 

results must be readily accessible, and agreed to establish guidance for EPA’s 

regional and program offices. Similarly, in response to the second 

recommendation, ORD agrees to ensure that its labs and centers use the Science 

Inventory and the Environmental Science Connector to share their current 

research across the Agency. ORD will also evaluate the effectiveness of the 

mechanisms for providing current scientific information. In response to the third 

and fourth recommendations, ORD plans to formalize and document the process 

for selecting and prioritizing research requirements from EPA’s program and 

regional offices and share it Agency wide. ORD plans to issue a memorandum 

document with details on the selection and tracking processes to Deputy Assistant 

Administrators, Deputy Regional Administrators, Research Coordinating Teams, 

Regional Science Liaisons, and Climate Coordinators in December 2009. In 

response to the fifth recommendation, ORD stated that it will document and 

formalize the mechanisms ORD uses for communication and collecting feedback 

in a fact sheet and share it with stakeholders within the Agency. Additionally, 

ORD stated that GCRP plans to issue a survey to assess the timeliness and 

usefulness of its research products prior to the next BOSC review in 2010. 

19 
 

 

 

 

 

 

 

 

 

 

 

09-P-0089 

Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

2-1 

3-1 

3-2 

3-3 

3-4 

3-5 

10 

18 

18 

18 

18 

18 

Direct Assistant and Regional Administrators on 

how to plan for climate change challenges in their 

media areas/regions until the Agency develops an 

overall strategy. 

Establish guidance to programs and regional offices 

for regularly entering their climate change scientific 

information in the Science Inventory. 

Ensure that ORD continues to routinely update the 

Science Inventory to include the latest information 

from its laboratories and centers. 

Establish a formal, transparent research 

requirements determination process that includes 

well-defined procedures for identifying a unified set 

of priority climate change research needs. 

Establish a formal mechanism to track regional 

research needs from research project selection to 

completion, and to requestor. 

Establish a formal method for coordinating GCRP’s 

research work with regions and program offices, 

communicating research results, and collecting 

feedback on research products. The feedback 

requested should include the accessibility, 

usability, value, and awareness of updates to the 

Science Inventory and the Environmental Science 

Connector. 

O 

O 

O 

O 

O 

O 

Deputy Administrator 

Deputy Administrator 

Assistant Administrator, 

Office of Research and 

Development 

Assistant Administrator, 

Office of Research and 

Development 

Assistant Administrator, 

Office of Research and 

Development 

Assistant Administrator, 

Office of Research and 

Development 

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

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is undecided with resolution efforts in progress 

20
 
 

 

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Appendix A 

Agency Response and OIG Evaluation 

This Appendix provides the Agency’s January 8, 2009, response to our recommendations 

followed by OIG evaluation of each response. We provide the Agency’s October 21, 2008, 

memorandum in Appendix B. 

MEMORANDUM
 

SUBJECT: Final Response to Recommendations in the Office of the Inspector General’s 

Draft Evaluation Report on Climate Change, Assignment No. 2007-0731 

FROM: Marcus Peacock 

 Deputy Administrator 

TO: Wade T. Najjum 

Assistant Inspector General for Program Evaluation 

Thank you for providing the updates to your recommendations pursuant to staff 

discussions at the November 25, 2008 exit conference. We concur with your recommendations 

and have begun to take actions to implement them. Please see the Attachment for our revised 

responses to your recommendations. 

For comments on specific findings in your report, please refer back to my October 

memorandum to Jeffrey Harris, OIG Director of Special Studies. 

I look forward to reviewing your final report and working with you to enhance EPA’s 

climate change efforts. 

Attachment 

21
 
 

 

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Attachment: Response to OIG Recommendations 

Introductory Note: As requested, we are providing our response in the Office of Inspector 

General’s desired “concurrence/non-concurrence” format in accordance with your memorandum 

and the U.S. Environmental Protection Agency’s Audit Management Process.9

 It is important to 

note that EPA is already implementing, or has begun to implement, appropriate actions 

consistent with the intent of all of your recommendations. We propose “supplementary actions” 

where we believe EPA can further enhance its work in response to OIG’s findings. 

Recommendation 2-1: “...that the Deputy Administrator...direct AAs and RAs on how to 

plan for climate change challenges in media areas/regions until the Agency develops an 

overall strategy.” 

>> Concurrence: The Deputy Administrator has initiated a process contributing to an 

Agency approach on climate change. The OIG report properly recognizes the importance 

of cross-Agency coordination in the development of program policy and information 

needs to address the challenge of climate change. Recognizing the importance of a more 

comprehensive approach, the Deputy Administrator recently convened EPA’s Deputy 

Assistant Administrators and Deputy Regional Administrators to follow up on the key 

coordination issues identified in the July 2008 Senior Leadership Council meeting. 

DAAs and DRAs will develop an Agency approach to this important environmental 

challenge. This process is in its initial stages and, as it moves forward, we would be 

pleased to provide the OIG with an update on its progress. 

OIG Response: Subsequent to our discussion draft, the Deputy Administrator 

initiated a process to develop an Agency approach to climate change challenges. OIG 

believes that the initial steps taken by the Deputy Administrator with the Deputy 

Assistant Administrators and Deputy Regional Administrators are necessary for the 

development of a comprehensive Agency strategy on climate change. The OIG 

accepts development of an Agency approach by the Deputy Assistant Administrators 

and Deputy Regional Administrators as meeting the intent of the recommendation. 

This approach should also include milestones for each specified action. 

Recommendation 3-1: “...that the Deputy Administrator ...establish guidance to programs 

and regional offices for regularly entering their climate change scientific information in the 

Science Inventory.” 

9 http://intranet.epa.gov/rmpolicy/ads/manuals/2750_2_t.pdf 

“In responding to the draft report, the Action Official can concur with the findings or provide explanations for any 

disagreements. The Action Official may comment on the accuracy of findings and conclusions, the appropriateness 

of the recommendations, or offer alternative recommendations. Responding to the draft report also offers the 

opportunity for the Action Official to provide new documentation or information to the auditors. Generally, the OIG 

will include the Action Official’s response to the draft report as an appendix to the final report.” (8-1) 

22
 
 

09-P-0089 

>> Concurrence: EPA agrees that the results of its scientific research must be readily 

accessible. The Deputy Administrator will continue to issue guidance to program and 

regional offices, which have the responsibility of entering and maintaining their own 

scientific information in the Science Inventory. 

OIG Response: The Agency concurred with Recommendation 3-1 and agrees to 

issue guidance to program offices and regions, which have the responsibility of 

entering and maintaining their own scientific information in the Science Inventory. 

Similarly, ORD agreed to evaluate the effectiveness of its mechanisms and to ensure 

that its labs and centers provide their most current information. EPA should provide 

a Corrective Action Plan with completion dates and details of plans for updating the 

Science Inventory, and maintaining the Environmental Science Connector. 

Recommendation 3-2: “...that the AA/ORD ensures that ORD continue to routinely 

update the Science Inventory to include the latest information from its laboratories and 

centers.” 

>> Concurrence: The Office of Research and Development provides the Science 

Inventory and the Environmental Science Connector as Agency-wide depositories for 

EPA’s scientific information. ORD will continue to evaluate the effectiveness of these 

mechanisms and will continue to ensure that its labs and centers provide their most 

current information. 

OIG Response: Same as for Recommendation 3-1. 

Recommendation 3-3: “...that the AA/ORD establish...a formal, transparent process to 

determine research requirements that includes well-defined procedures for identifying a 

unified set of priority climate change research needs.” 

>> Concurrence: ORD’s Global Change Research Program has an effective process in 

place to determine the highest-priority research requirements of EPA programs and 

regions and of the Climate Change Science Program. GCRP’s prioritization process 

includes the Research Coordination Team, Regional Science Liaisons, Climate 

Coordinators, weekly cross-Agency conference calls, and other formal and informal 

mechanisms. 

The GCRP Research Coordination Team consists of representatives from ORD, program 

offices, and all regional offices. The RCT facilitates research planning and 

communication and prioritizes both individual and collective research needs. RSLs are 

regional employees who have a well-defined role to coordinate and communicate with 

ORD. In addition to the RSLs, Climate Coordinators in select regions are actively 

engaged in prioritizing research activities. 

23
 
09-P-0089 

When determining priorities, GCRP must consider the individual requests of programs 

and regions, as well its interagency responsibilities under the Climate Change Science 

Program. For example, in Fiscal Years 2007 and 2008, the highest-priority research 

activity for ORD’s GCRP was the production of two CCSP Synthesis and Assessment 

Reports. 

>> Supplementary action planned: See the “supplementary action” under 

Recommendation 3-4, which we believe will further formalize and communicate ORD’s 

current process. 

OIG Response: The Agency concurred; however, we consider this item open, 

pending review of the detail in the Corrective Action Plan with completion dates and 

details of formal documentation of the selection process. We acknowledge that ORD 

uses some informal processes regularly to involve regional offices in obtaining their 

research needs. We also acknowledge that ORD has to balance the information needs 

of regions and program offices with its inter-agency responsibilities. However, the 

regions need to understand how and why certain topics are selected and others are not, 

to improve their own planning. Therefore it is important that ORD document and 

share its research prioritization process with EPA’s internal users. 

Recommendation 3-4: “...that the AA/ORD establish...a formal mechanism to track 

Regional research needs from research project selection to completion, and to requestor.” 

>> Concurrence: GCRP has mechanisms in place with programs and regions to track 

research needs from selection to completion (see response to Recommendation 3-3). To 

complement these mechanisms, GCRP maintains current information on its 

Environmental Science Connector site and makes this resource available to the entire 

Agency. GCRP will continue to focus its resources on the highest-priority research needs 

in global change. 

>> Supplementary action planned: To supplement its ongoing efforts to help partners 

in program and regional offices better understand ORD’s mechanisms and criteria for 

selecting research projects, ORD will provide additional information in a memo to 

Deputy Assistant Administrators, Deputy Regional Administrators, Research 

Coordination Teams, Regional Science Liaisons, and Climate Coordinators. This memo, 

to be sent in December 2009, will formally document the selection process and explain 

how the Science Connector tracks projects from selection to completion and 

communication. 

OIG Response: The Agency concurred. However, we consider this item open, 

subject to our review of a Corrective Action Plan with completion dates and details of 

the formal documentation of the tracking of projects from selection to completion and 

communication, proposed as a supplementary action plan. 

24
 
 

09-P-0089 

Recommendation 3-5: “...that the AA/ORD establish...a formal method for coordinating 

GCRP’s research work with Regions and Program Offices, communicating research 

results, and collecting feedback on research products. The feedback requested should 

include the accessibility, usability, value, and awareness of updates to the Science Inventory 

and Environmental Science Connector.” 

>> Concurrence: ORD/GCRP already uses several mechanisms to coordinate, 

communicate, and collect feedback. The Environmental Science Connector’s “Global 

Change Resource Center” and GCRP’s new public website10 are two tools used by ORD 

to coordinate and communicate its global change research. In addition, GCRP’s National 

Program Director uses weekly Global Conference Calls to obtain feedback from all 

program and regional offices. 

>> Supplementary action planned: To further formalize its ongoing efforts, 

ORD/GCRP will develop an internal fact sheet summarizing the mechanisms that ORD 

has already put in place to communicate and coordinate GCRP’s work with the programs 

and regions. ORD will share this factsheet with stakeholders across the Agency to 

improve their awareness of GCRP’s resources, and GCRP will update the factsheet as 

new mechanisms are developed. 

Additionally, ORD has begun to survey EPA stakeholders about the timeliness and 

usefulness of its products in order to enhance research planning. GCRP plans to issue 

such a survey prior to its next Board of Scientific Counselors review in 2010. The survey 

will include a request for feedback on the accessibility, usability, value, and awareness of 

updates to the Science Inventory and Environmental Science Connector. 

OIG Response: The Agency concurred; however, we consider this recommendation 

as an open item, subject to a Corrective Action Plan. We recognize that ORD uses 

tools and informal processes to communicate and coordinate its global change 

research. However, according to survey responses from both ORD and regional staff, 

these are informal practices, and they are ad hoc and inconsistent. The Corrective 

Action Plan should include the date and details about the fact sheet ORD plans to send 

to EPA’s offices, as well as how frequently it plans to update the fact sheets. It should 

also include the dates for the planned survey, and the type of staff ORD plans to 

survey. 

10 http://www.epa.gov/ord/npd/globalresearch-intro.htm 

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Appendix B 

Agency Preliminary Comments and OIG Evaluation 

This appendix provides the October 21, 2008, memorandum comments mentioned in the EPA 

Deputy Administrator’s final response in Appendix A. The October comments have been 

superseded by the Agency’s January 8, 2009, memorandum and attachment. The following 

includes OIG evaluation and the Agency comments. 

MEMORANDUM
 

SUBJECT: OIG Evaluation Report on EPA’s Climate Change Research Activities 

FROM: Marcus Peacock 

 Deputy Administrator 

TO: Jeffrey Harris 

 Director, Special Studies, Office of Program Evaluation 

Thank you for your draft report on how well the U.S. Environmental Protection Agency’s 

policies, procedures, and plans help ensure that EPA’s Global Change Research Program (GCRP 

or Program) fulfills its role in meeting environmental decision-makers’ climate change 

information needs. The insights and recommendations you provide in the report will help the 

Agency continue to improve its efforts to address the challenges posed by climate change. I am 

pleased to say that, with your help, we are already implementing a number of your 

recommendations. 

As an overall point, I think the “At-a-Glance” section and aspects of the report could 

more accurately represent the breadth, scope, and effectiveness of EPA’s Global Change 

Research Program in the Office of Research and Development (ORD). I have provided 

clarifications in the discussion below and in the Attachment, and I ask that you revise the “At-aGlance” section and the report accordingly. 

You correctly note in the report that ORD has responsibility for managing EPA’s global 

climate change research function through its Global Change Research Program. GCRP is 

subjected to regular, external peer reviews by the independent Board of Scientific Counselors 

(BOSC). As you acknowledge in your report, the past two BOSC reviews of the GCRP (in 2006 

and 2008) affirm that the Program is doing the “right work” and is doing it “well.” In addition, 

the BOSC made recommendations for improvements in the Program, which have already been 

implemented. Your review, combined with the BOSC reviews, will help further strengthen the 

effectiveness of the GCRP. 

26
 
09-P-0089 

It is important to emphasize in the report that ORD is responsible for only a subset of the 

climate change information developed and used by the Agency. Other EPA program offices 

conduct work related to GCRP activities that are coordinated with ORD. For example, the 

Office of Water’s (OW) new Climate Change Strategy formally integrates ORD and OW 

activities to address the implications of climate change for the Agency’s statutory, regulatory, 

and programmatic requirements under the Clean Water Act and Safe Drinking Water Act. 

OIG Response: We reported that ORD is not the only responsible program office regarding 

climate change. For example, in the report Introduction we state, “The Office of Air and 

Radiation (OAR) has activities related to mitigating greenhouse gases.” We also reported that 

Office of Water was developing a strategy to address the impact of climate change on its 

programs; however, it had not been finalized at the time our field work was completed. 

Recognizing the importance of a more comprehensive approach to climate change, I 

recently convened EPA’s Deputy Assistant Administrators (DAAs) and Deputy Regional 

Administrators (DRAs) to follow up on key coordination issues identified at the July 2008 Senior 

Leadership Council meeting. The DAAs and DRAs will further develop an Agency-wide 

approach to climate change. Ultimately, I anticipate that this effort will lead to the development 

of an overall Agency strategy. 

An Agency-wide strategy needs to consider EPA’s role as part of the broader federal 

structure. The respective roles and responsibilities of all federal agencies are clearly defined and 

distinguished under the U.S. Climate Change Science Program (CCSP) and U.S. Climate Change 

Technology Program (CCTP). These two programs coordinate and integrate climate change 

science and technology activities across the entire Federal Government, ensuring that resources 

are used efficiently and duplication of effort is avoided. Your report recognizes the respective 

roles of the CCSP and CCTP, but it should also acknowledge the importance of aligning an 

Agency-wide strategy with these interagency programs. 

Considering the climate change information generated by other federal agencies as well 

as other EPA program offices, a number of the Office of Inspector General’s (OIG) findings 

extend beyond the purview of ORD/GCRP. For example, OIG’s chart on page 13 compares 

regional information needs with GCRP plans. However, GCRP does not have lead responsibility 

for a number of the areas listed (e.g. renewable energy, sequestration) and thus others are in a 

better position to distribute this information to the regions. 

Similarly, OIG’s recommendation that ORD develop a central depository for climate 

information is beyond the purview of ORD/GCRP. In many cases, EPA program offices and 

regions need to look beyond GCRP to other parts of EPA and to interagency repositories to 

access some of the information they seek. 

27
 
 

 

09-P-0089 

OIG Response: Recommendations 3-1 and 3-2 are directed at making EPA’s scientific 

information available to EPA’s internal users; it does not require collecting information 

developed by other federal agencies. During our field work, we found that EPA’s Science 

Inventory was not current. Internal sharing and maintaining EPA’s research information is 

necessary in order to avoid duplication of research effort and maximizing available resources. 

The Agency states that OAR is in better position to distribute information to the regions on 

renewables and sequestration. We note that ORD has included renewable energy and 

sequestration as research projects in its strategic plan. ORD and Office of Water were able to 

formally integrate activities addressing the implications of climate change. Similarly, ORD 

and OAR should coordinate their research and activities related to renewables and 

sequestration. 

The report should acknowledge that any EPA policies and procedures for meeting the Agency’s 

information needs must ensure that available resources are directed to their highest-valued uses. 

Therefore, ORD/GCRP must consider the requests it receives from EPA’s program and regional 

offices along with those of multiple other partners (e.g. other agencies), and GCRP must allocate 

its resources to meet the highest-priority needs. For example, in Fiscal Years 2007 and 2008, the 

highest-priority research activity for GCRP was the production of two CCSP Synthesis and 

Assessment Reports. 

In contrast with the findings in your report, we believe ORD does have formal 

mechanisms in place to prioritize its research activities (see Attachment for additional 

information). New processes are already in place for making these mechanisms more transparent 

to regional and program offices. At the same time, program and regional offices have the 

responsibility to prioritize their research needs and communicate them to ORD. For example, 

the regional climate change information needs presented in Table 2.1 of your report are not 

prioritized, nor, as mentioned above, does the GCRP have the lead responsibility for a number of 

these areas. The Global Change Research Coordination Team provides the venue for such 

prioritization, consistent with an appreciation of the GCRP’s role in the context of the larger 

federal effort. 

OIG Response: We acknowledge that ORD has to balance the information needs of regions 

and program offices with its inter-agency responsibilities. However, ORD does not have a 

“formal” mechanism for research prioritization that assures available resources are directed to 

their highest-valued uses. A “formal” mechanism or process would be documented and 

shared with the regions. While we noted that ORD uses several informal mechanisms to 

collect research needs from regions, participation in calls and workshops is not required by 

EPA policy, resulting in inconsistent participation. A formal EPA policy is needed. 

According to the Agency response to Recommendation 3-4, ORD plans to send such a 

memorandum in December 2009. 

It is important also to note that EPA will need a strong research and analytic capability in 

the economics, as well as the science, of climate change. Going forward, EPA will need to 

analyze the economic effects of any regulations promulgated under the Clean Air Act; to provide 

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technical expertise to the Congress as it develops and evaluates various legislative proposals; and 

to help inform negotiations of any international accord to reduce greenhouse gas emissions 

worldwide. All of these efforts will demand unprecedented economic modeling and analytic 

efforts from the Agency. In the regulatory arena, most, if not all of the anticipated climate 

change regulations will be economically significant, and therefore will require benefit-cost 

analysis per Executive Order 12866. More importantly, analysis will be needed to provide 

policy makers with key information about the most cost-effective and fair ways to reduce 

greenhouse gases. This is equally true in the international arena: EPA will need to provide the 

United States delegation and the world community with economic modeling that credibly 

demonstrates the likely impacts of climate change as well as the economic impacts of taking 

action under various approaches. Efforts to build these needed economic research capabilities 

are already underway, primarily in the Office of Air and Radiation and the Office of Policy, 

Economics, and Innovation. 

Most importantly, we agree with the spirit of your recommendations and have begun to 

implement appropriate actions consistent with their intent. Please see the Attachment for our 

responses to each of your specific recommendations. 

I look forward to working with you to ensure that the Agency has the necessary policies, 

procedures, and plans in place so that the GCRP fulfills its role in the Agency’s and Federal 

Government’s overall efforts to address global climate change. Thanks again for your help on 

this effort. 

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Appendix C 

Distribution 

Office of the Administrator 

Deputy Administrator 

Acting Assistant Administrator for Research and Development 

Acting Principal Deputy Assistant Administrator for Air and Radiation 

Office of General Counsel 

Agency Follow-up Official (the CFO) 

Agency Follow-up Coordinator 

Acting Associate Administrator for Congressional and Intergovernmental Relations 

Acting Associate Administrator for Public Affairs 

Audit Follow-up Coordinator, Office of Research and Development 

Deputy Inspector General 

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