Office of Inspector General 

 Audit Report

The Effectiveness and Efficiency

of EPA’s Air Program

Report No. E1KAE4-05-0246-8100057

February 27, 1998
Inspector General Division

 Conducting the Audit: Northern Audit Division

 Chicago, IL

Inspector General Divisions

 Contributing to the Issue Area: Headquarters Audit Division

 Washington, DC

Eastern Audit Division

 Boston, MA

 New York, NY

Mid-Atlantic Audit Division

 Philadelphia, PA

Southern Audit Division

 Research Triangle Park, NC

Central Audit Division

 Dallas, TX

Western Audit Division

 San Francisco, CA

Office of Internal Audits

 Washington, DC

Engineering & Science Staff

 Washington, DC

Program Offices Involved: Office of Air and Radiation

Office of Research and Development 

Office of Communications, 

Education, and Public Affairs
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, DC 20460

 February 27, 1998

OFFICE OF 

THE INSPECTOR GENERAL

MEMORANDUM

SUBJECT: The Effectiveness and Efficiency of EPA’s Air Program,

Report No. E1KAE4-05-0246-8100057

FROM: Michael Simmons /s/

Deputy Assistant Inspector General

 for Internal Audits

TO: Richard D. Wilson

Acting Assistant Administrator

 for Air and Radiation

Henry L. Longest II

Acting Assistant Administrator

 for Research and Development

Loretta M. Ucelli

Associate Administrator

 for Communications, Education, and Public Affairs

Attached is a copy of our report entitled “The Effectiveness and Efficiency of EPA’s Air

Program,” Report No. E1KAE4-05-0246-8100057. This report provides important findings and

recommendations that should significantly improve the efficiency of the Air Program and its

relations with other offices. The final report incorporates the comments each of your offices

provided on position papers we previously issued.

We appreciate your staffs’ efforts in working with us to develop this report. We

particularly want to thank the Office of Air and Radiation management and staff for their

cooperation and the high level of attention they gave to our work in the Air Program over the past

several years. Without that cooperation and attention, we could not have produced this report. 
Action Required

In accordance with EPA Order 2750, we have designated the Acting Assistant

Administrator for Air and Radiation as the action official for this report. As the action official, 

he is required to provide us with a written response within 90 days of the date of this report. The

response should incorporate actions from the Offices of Research and Development, and

Communications, Education, and Public Affairs. The response should also address all

recommendations. For corrective actions planned but not completed by the response date, please

describe the actions that are ongoing and provide a timetable for completion. This information will

assist us in deciding whether to close this report.

We have no objections to the release of this report to the public. Should your staff have any

questions, please contact Kimberly O’Lone, Audit Manager, at 312-886-3186 or Janice 

Miller, Team Leader, at 312-886-3084.

Attachment
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EXECUTIVE SUMMARY

INTRODUCTION Since 1993, the Office of Inspector General (OIG) has been

conducting a coordinated body of audit work in the U.S.

Environmental Protection Agency’s (EPA) Air Program, that led to

this overall report. We began this effort with a general survey in

1993 and issued a strategic plan in May 1994. We have issued

reports on air grants, toxics, enforcement, state implementation

plans, emission factors, and voluntary programs. This report

culminates our efforts, pulling together overall issues from OIG and

U.S. General Accounting Office work. 

The Office of Air and Radiation (OAR) is responsible for carrying

out EPA’s Air Program. Its mission is to protect and enhance the

quality of the nation’s air resources and protect human health and

the environment from airborne pollutants and radiation. OAR

carries out this mission by implementing the Clean Air Act, as

amended in 1990 (Act), and the 1993 Climate Change Action Plan. 

OAR also develops programs to reduce risk from indoor air

pollution and radiation. This report primarily focuses on OAR’s

activities under the Act. 

OBJECTIVE

The objective of this audit was to determine whether the Air

Program was working effectively and efficiently to make the

nation’s air cleaner. 

This report is separated into three parts based on the above

objective. Part 1 is the introduction, providing background

information on the Air Program and our audit work. Part 2

discusses whether the Air Program has been effective. Part 3

summarizes our conclusions on whether the Air Program has been

efficient. 
The Effectiveness and Efficiency

of EPA’s Air Program

1We did not independently verify information relating to emissions or the health effects of emissions. 

Instead, we relied on EPA or other published sources for information in this part of our report.

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RESULTS IN BRIEF

OAR data show that the Air Program has been effective in cleaning

the air and reducing the potential for depleting the ozone layer.1

We also concluded that, while the Air Program has generally

operated efficiently, it could also be more efficient. 

The Air Program Has Between 1987 and 1996, U.S. emissions of all criteria pollutants

Been Effective in declined. Much of this reduction was due to emission controls

Reducing Emissions placed on motor vehicles and utilities. OAR estimates that, without

the emission reductions, there would have been more health

problems, such as heart disease and respiratory illnesses. Also,

because of OAR’s Acid Rain Program, the damage to lakes and

forests has been reduced. 

Emissions of ozone depleting chemicals have decreased, through

the phase out of the production of certain chemicals, such as

chlorofluorocarbons (CFCs). Without the phase out of CFCs, OAR

predicts that the depletion of the stratospheric ozone layer would

increase, accompanied by an increase in skin cancer.

The Air Program Could The Air Program has generally operated efficiently. Several prior

Be More Efficient audit reports found that OAR had good management practices and

good internal controls over operations reviewed. OAR officials,

however, could increase their program efficiency in several ways. 

For instance, Air Program officials could improve their relations

with other parties that OAR needs to carry out its mission. These

parties include the Office of Research and Development (ORD), the

Office of Communications, Education, and Public Affairs

(OCEPA), and outside stakeholders, such as states. OAR officials

could also direct more attention to several ongoing activities to

improve their efficiency. These issues are summarized in the

following paragraphs.
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 OAR and ORD Needed One way the Air Program could be more efficient is if its research

 to Ensure That Air and monitoring needs were adequately met. To do this, officials

 Research and Monitoring from OAR and ORD agreed they needed to work together. 

 Needs Were Met Although the officials generally worked well together and agreed

on most of their activities, some areas of disagreement existed. The

disagreements mainly focused on how ORD used its budget for air

activities. ORD has not established a consistent process for making

Agency-wide research planning and budgeting decisions. Both

offices agreed, however, that the fiscal year 1999 process was an

improvement over prior years. The two offices also did not have a

method for resolving disagreements or sharing decisions with all

managers and staff in both offices. Disagreements between the two

offices have resulted in impaired working relationships. If the

offices do not work well together to resolve disagreements, they

may not be making decisions to use their joint resources in the most

efficient ways. 

 OAR and OCEPA The Air Program could also be more efficient if it worked with

 Needed to Work OCEPA to raise public awareness about air pollution. The public

 Together to Raise is important to the success of OAR programs. Officials from the

 Public Awareness two offices agreed they have not communicated or coordinated

sufficiently with each other in the past. As a result, OAR did not

always use its resources efficiently. Recently, officials in both

offices have taken steps to improve their working relationship. 

They must continue working together to resolve past differences.

 OAR Needed to Give A third way the Air Program could be more efficient is if OAR

 Stakeholders was more responsive to stakeholders, such as EPA regional offices,

 Sufficient Feedback states, and industry and environmental groups, in implementing the

Act. OAR frequently consulted stakeholders for ideas; however,

some stakeholder relationships could have benefitted from more

feedback from OAR. Stakeholders may have perceived a lack of

feedback because (1) they may not have had a clear understanding

of how the stakeholder process worked and entered the partnership

with high expectations, (2) there was not always a formal

mechanism to provide feedback, and (3) the process for working

with stakeholders was lengthy. As a result, some stakeholders were

reluctant to work with OAR again. OAR cannot efficiently carry

out the Act without the cooperation and help of its stakeholders.
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 OAR Needed to Finally, the Air Program needs to devote attention to several

 Give Attention to ongoing activities to improve efficiency. These activities have

 Several Activities been discussed in prior audit reports and include: leading the state

implementation plan process, developing and improving emission

factors, and issuing air toxic standards. OAR has not considered

these activities high priorities, compared with other program areas. 

This resulted in delays and limited funding. Consequently, these

activities have operated inefficiently and may not be achieving their

desired results. For example, state plans to achieve emission

reductions could be delayed. The plans may also be incorrect if the

state’s estimates of emissions from major sources are based on

inaccurate emission factors. Also, industry deadlines for installing

controls over emissions of air toxics will be delayed if OAR is late

in issuing standards. 

RECOMMENDATIONS

We recommend that the Acting Assistant Administrator for Air and

Radiation:

1. Along with the Acting Assistant Administrator for Research

and Development continue the improvements made in the

fiscal year 1999 research planning process. 

2. Work with the Associate Administrator for

Communications, Education, and Public Affairs to establish

procedures to ensure that the offices work up-front with

each other when developing projects to raise public

awareness of air pollution. 

3. Establish a process to ensure that feedback is provided to all

stakeholders when OAR has not addressed their concerns,

or has not used the input. 

Additional and expanded recommendations are included at the end

of each chapter, beginning in Part 3.
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AGENCY COMMENTS 

AND OIG EVALUATION The Acting Assistant Administrators for OAR and ORD and the

Associate Administrator for OCEPA concurred with our

recommendations. They need to provide specific corrective actions

and milestone dates for implementing the recommendations. See

appendices 1, 2, and 3 for the OAR, ORD, and OCEPA responses.
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Table of Contents

EXECUTIVE SUMMARY ............................................... i

ABBREVIATIONS ..................................................... ix

PART 1: INTRODUCTION .............................................. 1

INTRODUCTION ............................................................. 2

Purpose ............................................................. 2

Background .......................................................... 2

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

PART 2: WAS THE AIR PROGRAM WORKING EFFECTIVELY TO

MAKE THE NATION’S AIR CLEANER? ................................ 7

THE AIR PROGRAM HAS BEEN EFFECTIVE IN REDUCING EMISSIONS ...................... 8

Criteria Pollutants ..................................................... 8

Stratospheric Ozone Depletion ........................................... 10

Conclusion .......................................................... 11

PART 3: WAS THE AIR PROGRAM WORKING EFFICIENTLY TO

MAKE THE NATION’S AIR CLEANER? ............................... 12

THE AIR PROGRAM COULD BE MORE EFFICIENT ................................... 13

 CHAPTERS

1 OAR AND ORD NEEDED TO ENSURE THAT AIR RESEARCH AND MONITORING

NEEDS WERE MET .................................................... 14

Background ................................................... 14

OAR and ORD Generally Worked Well Together ....................... 15

Some Disagreements Existed ...................................... 16

Causes of Disagreements ......................................... 17

Disagreements Impaired Relations and Efficiency ....................... 17

Conclusion .................................................... 18

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

Agency Comments and OIG Evaluation .............................. 19
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2 OAR AND OCEPA NEEDED TO WORK TOGETHER TO

RAISE PUBLIC AWARENESS .............................................. 20

Background ................................................... 20

Changing Working Relationship for OAR and OCEPA ................... 20

OAR and OCEPA Did Not Always Work Well Together ................. 21

Relationship Impacted Efficiency ................................... 21

Conclusion .................................................... 23

Recommendations .............................................. 23

Agency Comments and OIG Evaluation .............................. 23

3 OAR NEEDED TO GIVE STAKEHOLDERS SUFFICIENT FEEDBACK .................. 24

Background ................................................... 24

OAR Asked for Input From Stakeholders ............................. 26

OAR Did Not Always Give Feedback ................................ 26

Stakeholders Perceived Lack of Feedback ............................ 27

Stakeholders Hesitant to Work With OAR ............................ 28

Conclusion .................................................... 29

Recommendations .............................................. 29

Agency Comments and OIG Evaluation .............................. 30

4 OAR NEEDED TO GIVE ATTENTION TO SEVERAL ACTIVITIES ..................... 31

Background ................................................... 31

SIP Processing Needed to be Improved .............................. 33

Emission Factors Needed to be Developed and Improved ................. 34

Timely Air Toxic Standards Needed ................................. 35

Conclusion .................................................... 37

Recommendations from Prior Audit Reports ........................... 38

EXHIBITS

1 EPA OIG AND GAO REPORTS ......................................... 40

2 SCOPE, METHODOLOGY, AND PRIOR AUDIT COVERAGE ................ 42

3 ISSUES NEEDING FURTHER STUDY ................................... 45

APPENDICES

1 OFFICE OF AIR AND RADIATION RESPONSE ........................... 47
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2 OFFICE OF RESEARCH AND DEVELOPMENT RESPONSE ................. 49

3 OFFICE OF COMMUNICATIONS, EDUCATION, AND

PUBLIC AFFAIRS RESPONSE ......................................... 51

4 DISTRIBUTION ..................................................... 53
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Abbreviations

Act Clean Air Act, as amended in 1990

CCAP Climate Change Action Plan

CFC Chlorofluorocarbon

EPA Environmental Protection Agency

GAO U.S. General Accounting Office

MACT Maximum Achievable Control Technology

NOAA National Oceanic and Atmospheric Administration

OAR Office of Air and Radiation

OCEPA Office of Communications, Education, and Public Affairs

OIG Office of Inspector General

OMB Office of Management and Budget

OMS Office of Mobile Sources

ORD Office of Research and Development

SIP State Implementation Plan

Subcommittee Clean Air Act Advisory Committee subcommittee for Ozone, Particulate Matter,

and Regional Haze Implementation Programs

UV Ultraviolet
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PART 1

Introduction
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PART 1

Introduction

PURPOSE Since 1993, the Office of Inspector General (OIG) has been

conducting a coordinated body of audit work in the U.S.

Environmental Protection Agency’s (EPA) Air Program. We began

this effort with a general survey in 1993 and issued a strategic plan

in May 1994. We have issued reports on air grants, toxics,

enforcement, state implementation plans, emission factors, and

voluntary programs. This report culminates our efforts, pulling

together overall issues from OIG and U.S. General Accounting

Office (GAO) work. See exhibit 1.

The objective of this audit was to determine whether the Air

Program was working effectively and efficiently to make the

nation’s air cleaner. 

BACKGROUND

The Office of Air and Radiation (OAR) is responsible for carrying

out EPA’s Air Program. OAR’s mission is to protect and enhance

the quality of the nation’s air resources and protect human health

and the environment from airborne pollutants and radiation. OAR

carries out this mission by implementing the Clean Air Act, as

amended in 1990 (Act), and the 1993 Climate Change Action Plan. 

OAR also develops and implements programs to reduce risk from

indoor air pollution and radiation. 

OAR is headquartered in Washington, D.C., and is comprised of

four main program offices, as shown in figure 1. 
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Report No. 8100057

Figure 1: Office of Air and Radiation

Organization Chart

Mobile Sources

(Washington, DC 

and Ann Arbor, MI)

Radiation and 

Indoor Air

(Research Triangle 

Park, NC)

Air Quality 

Planning and Standards

Atmospheric Programs

(Washington, DC) (Washington, DC, with 

labs in Las Vegas, NV 

and Montgomery, AL)

OAR Responsibilities OAR has defined four areas of fundamental responsibility:

implementing the Act; carrying out the Climate Change Action Plan

(CCAP); reducing risks from radon and other indoor air pollutants;

and protecting health and the environment from radiation. Figure 2

shows OAR’s fiscal 1996 resources (excluding grants), as allocated

among these responsibilities.

Figure 2: OAR FY 1996 Resources

(in Millions)

Act

$175.4

CCAP

$69.3

Indoor Air

$18.1

Radiation

$13.9

Other

$8.4

OAR spent the bulk of its resources on responsibilities associated

with implementing the Act. For instance, in fiscal 1996, OAR spent

about $175 million on its own programs to:

C set health-based national ambient air quality standards for

specific pollutants, and help state, local, and tribal

governments develop and implement programs to prevent

and control those pollutants;
The Effectiveness and Efficiency

of EPA’s Air Program

2

The Montreal Protocol is an international agreement on ozone-depleting substances. The agreement was

originally signed in 1987, and was substantially amended in 1990 and 1992.

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C develop standards to control the release of air toxics, which

are pollutants that are known or suspected to cause cancer

or other serious health effects;

C set standards to reduce emissions from motor vehicles

through tailpipe standards, evaporative emissions controls,

on-board vapor recovery systems, and cleaner fuels;

C operate the Acid Rain program, a market-based program to

reduce sulfur dioxide and nitrogen oxide emissions from

utilities; and

C oversee U.S. efforts to stop stratospheric ozone depletion

by regulating the production, use, and disposal of ozonedepleting substances, and implementing U.S. responsibilities

under the revised Montreal Protocol.2

Another OAR fundamental responsibility is to implement provisions

of the CCAP. OAR’s role is to develop and implement programs to

stimulate and transform the markets for technologies that reduce

emissions for carbon dioxide, methane, and other compounds that

contribute to global warming. OAR allocated over $69 million

from its fiscal 1996 budget to implement the climate change

programs. 

A third area of fundamental responsibility is aimed at reducing the

public health risks from radon and other indoor pollutants. OAR

spent almost $18 million on its indoor environments programs. 

These activities are authorized by the Indoor Radon Abatement Act

and the Superfund Amendments and Reauthorization Act. 

OAR’s remaining fundamental responsibility is to protect the public

health and the environment from radiation exposure, upon which it

spent about $14 million. Because our work focused on the Air

Program, we did not evaluate any of OAR’s radiation programs. 
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These special reviews were more limited in scope than an audit and were conducted in accordance with

OIG Manual Chapter 150.

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State Responsibilities State and local agencies are responsible for carrying out many of

the Act’s provisions. The Act had states take the lead in carrying

out its provisions, because pollution control problems often require

special understanding of local industries, geography, housing

patterns, and other factors. While the law requires OAR to set

limits on how much of a pollutant can be in the air anywhere in the

U.S., it also allows individual states to establish stronger pollution

controls. States are not, however, allowed to have weaker

pollution controls than those set for the whole country. 

OAR provides funding to state and local agencies to assist in their

programs. In Section 105 of the Act, OAR is authorized to provide

grants to state and local agencies. These grants are designed to

help the agencies establish and operate air pollution control

programs. In fiscal 1996, OAR allocated just over $163 million to

these grants. OAR also provided $6.6 million to state and local

agencies for indoor environments programs. 

SCOPE AND

METHODOLOGY We performed our audit in accordance with the U.S. GAO’s

Government Auditing Standards, as issued by the Comptroller

General of the United States (1994 Revision). 

As part of this audit, we relied on reports OIG and GAO auditors

prepared. A complete listing of audit reports is included in exhibit

1. The reports we used for this audit were also performed in

accordance with the Government Auditing Standards with the

following exceptions:

OIG Special Reviews3

EPA’s Air State Implementation Plan Program

 Consolidated Report

EPA’s Development of its Proposed Open Market 

 Trading Rule
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These surveys did not identify potential issues warranting additional audit work. As such, reports were

not issued to the Air Program. They were performed in accordance with Government Auditing Standards, with the

exception of the reporting requirement.

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OIG Surveys4

Region 3 Title V State Operating Permit Program

Acid Rain Allowance Trading Program 

The standards the OIG and GAO followed gave us reasonable

assurance of the quality and accuracy of the information. We relied

on the information in the reports to reach conclusions on how the

Air Program was managed and cited examples from the prior

reports in this report. 

For our audit objectives, we performed a limited assessment of

internal controls, which included reviewing OAR’s Assurance

Letters for fiscal years 1994, 1995, and 1996. The 1994 report

identified inaccurate data in the state implementation plan tracking

system as an Agency level weakness, but this weakness was shown

as corrected in 1995. We did not detect any material internal

control weaknesses during this audit. However, we continue to

believe that the emission factor program is a material weakness, as

identified in our September 30, 1996 report, Emission Factor

Development, EPA OIG Report No. 6100318. We discuss this

issue further in chapter 4. 

See exhibit 2 for scope and methodology details, as well as prior

audit coverage. See exhibit 3 for issues needing further study.
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PART 2

Was the Air Program Working 

Effectively to Make 

the Nation’s Air Cleaner?
The Effectiveness and Efficiency

of EPA’s Air Program

5We did not independently verify information relating to emissions or the health effects of emissions. 

Instead, we relied on EPA or other published sources for information in this part of our report.

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PART 2

The Air Program Has Been Effective

In Reducing Emissions

Office of Air and Radiation (OAR) data show that the Air Program

has been effective in cleaning the air and reducing the potential for

depleting the ozone layer.5 Between 1987 and 1996, U.S.

emissions of all criteria pollutants declined. Much of this reduction

was due to emission controls placed on motor vehicles and utilities. 

OAR estimates that, without the emission reductions, there would

have been more health problems, such as heart disease and

respiratory illnesses. Also, because of OAR’s Acid Rain Program,

the damage to lakes and forests has been reduced. 

Emissions of ozone depleting chemicals have decreased, through

the phase out of the production of certain chemicals, such as

chlorofluorocarbons (CFCs). Without the phase out of CFCs, OAR

predicts that the depletion of the stratospheric ozone layer would

increase, accompanied by an increase in skin cancer. 

CRITERIA

POLLUTANTS

Background The Clean Air Act of 1970 required EPA to identify air pollutants

that it anticipated endangered public health. EPA identified six

“criteria” pollutants, for which it has promulgated the National

Ambient Air Quality Standards. These pollutants are: (1) lead, (2)

carbon monoxide, (3) sulfur dioxide, (4) particulate matter, (5)

ground-level ozone, and (6) nitrogen dioxide. The standards

specify acceptable air pollution concentrations for a geographic

area. The Clean Air Act, as amended in 1990 (Act), classified as

non-attainment areas those places that exceeded the standards and

established deadlines for states to achieve them.
The Effectiveness and Efficiency

of EPA’s Air Program

6National Air Quality and Emissions Trends Report, 1996, EPA-454/R-97-013, January 1998.

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Emissions Have According to the most current OAR data, the concentrations of all

Gone Down six criteria pollutants have gone down, as shown in table 1.6

Table 1:

Criteria Pollutants

Pollutant

Air quality

concentrations

% decrease

1987 - 1996

Lead 75%

Carbon Monoxide 37% 

Sulfur Dioxide 37% 

Particulate Matter

(1988 - 1996 data) 25%

Ozone/Volatile 

Organic Compounds

15%

Nitrogen Dioxide 10%

These reductions have occurred in a time of growth. Since the Act

was passed in 1970, the U.S. economy, population, and on-road

miles driven have all increased. These factors are all traditional

causes of air quality problems. 

OAR also reported that some emissions have been reduced ahead of

schedule. Sulfur dioxide emissions, which form one of the

components of acid rain, were reduced from the 1980 level of

almost 11 million tons to just over 5 million tons in 1995. This was

39% below the 1995 allowable emissions level of 8.7 million tons

the Act required. 
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The Montreal Protocol is an international agreement on ozone-depleting substances. The agreement was

originally signed in 1987, and was substantially amended in 1990 and 1992.

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The Act Has In the National Air Quality and Emissions Trends Reports from

Led to the 1995 and 1996, OAR attributed the reductions of criteria pollutants

Reductions to steps taken under the Act. OAR concluded that changes in

gasoline (oxygenated fuels and unleaded and reformulated gasoline)

and other motor vehicle controls resulted in decreases in carbon

monoxide, lead, and ground-level ozone. Utilities using new

control technologies, such as scrubbers, and switching to low sulfur

fuels, affected sulfur dioxide and nitrogen dioxide emissions. 

Finally, a decrease in residential wood burning resulted in reduced

particulate matter emissions.

Reductions Help According to OAR, the emission reductions achieved may help

People and the improve public health and the environment. Exposure to

Environment carbon monoxide, particulate matter, lead, and sulfur dioxide can

result in serious health threats to people with heart disease. 

Nitrogen dioxide, ground-level ozone, particulate matter, and sulfur

dioxide can also cause or aggravate respiratory illnesses. Exposure

to lead may also result in neurological impairments, such as mental

retardation and behavioral disorders. 

A study prepared for the U.S. Geological Survey found that rainfall

in the Eastern half of the country was 10 to 25% less acidic because

of OAR’s Acid Rain Program. As a result, lakes and streams

affected by acid rain will be able to recover, restoring fish and other

life. Forests will also be restored and visibility will improve. 

STRATOSPHERIC 

OZONE DEPLETION 

Background Under the Act and the 1987 Montreal Protocol, OAR was required

to write regulations to phase-out the production and sale of CFCs

and several other chemicals.7 These chemicals may be causing the

destruction of the stratospheric ozone layer. 
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Emissions Have Emissions of ozone depleting chemicals have gone down. For

Gone Down example, scientists from the Department of Commerce’s National

Oceanic and Atmospheric Administration (NOAA) reported that, in

1995, the total amount of ozone-destroying chemicals in the lower

atmosphere declined for the first time. 

Production Bans Production bans under the Act led to decreases in ozone depleting

Have Led to Reductions chemicals. NOAA scientists concluded that the decline in ozone

destroying chemicals in the atmosphere occurred because many

nations have limited the production of those chemicals. In July

1992, OAR issued its final rule that limited the production and

consumption of these chemicals. OAR issued allowances or

permits for producing and importing the chemicals. Most major

ozone depleting substances were phased out by December 1995. A

remaining chemical, methyl bromide, may be produced and

consumed through the year 2000, when it will also be phased out. 

Reductions Will Halting the depletion of the stratospheric ozone layer will reduce

Help People and harmful effects of exposure to the sun, such as skin cancer. Ozone

the Environment depletion allows more ultraviolet (UV)-b radiation to reach the

Earth's surface. According to OAR, increased UV-b radiation

causes human skin cancers, cataracts, and impairs human immune

systems. Increased UV-b radiation also reduces crop yields and

threatens plant and animal life.

CONCLUSION

OAR data show that the Air Program has been effective in cleaning

the air and reducing the potential for depleting the ozone layer.
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PART 3

Was the Air Program Working 

Efficiently to Make 

the Nation’s Air Cleaner?
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PART 3

The Air Program Could Be More Efficient

The Air Program has generally operated efficiently. Several prior

audit reports found that the Air Program had good management

practices and good internal controls over operations reviewed. For

instance:

C The voluntary programs for Radon and ENERGY STAR®

used good management practices and developed ways to

estimate their environmental results. 

C The Green Lights program had adequate program

operations and internal controls, and it had direct and

specific plans for addressing program barriers. 

C EPA regions (1) had adequate procedures in place for

obtaining, reviewing, and approving state implementation

plans (SIPs), (2) established a good working relationship

with Headquarters and states, and (3) worked up-front with

states to get SIPs submitted on time. 

C The Office of Air and Radiation’s (OAR) Acid Rain

Division developed procedures and effectively implemented

the Acid Rain Permits Program, Allowance Tracking

System, and Continuous Emissions Monitoring System. 

While the Air Program has been efficient in many ways, it can still

improve its efficiency. For instance, Air Program officials could

improve their relations with other parties that OAR needs to carry

out its mission. These parties include the Office of Research and

Development, the Office of Communications, Education, and Public

Affairs, and outside stakeholders, such as states. OAR could also

be more efficient if it directed more attention to several ongoing

activities. The following chapters discuss in detail how the Air

Program could work more efficiently to make the nation’s air

cleaner. 
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PART 3

CHAPTER 1

OAR and ORD Needed to Ensure That

Air Research and Monitoring Needs Were Met

One way the Air Program could be more efficient is if its research

and monitoring needs were adequately met. To do this, officials

from the Offices of Air and Radiation (OAR) and Research and

Development (ORD) agreed they needed to work together. 

Although the officials generally worked well together and agreed

on most of their activities, some areas of disagreement existed. The

disagreements mainly focused on how ORD used its budget for air

activities. ORD had not established a consistent process for making

Agency-wide research planning and budgeting decisions. Both

offices agreed, however, that the fiscal year 1999 process was an

improvement over prior years. The two offices also did not have a

method for resolving disagreements or sharing decisions with all

managers and staff in both offices. Disagreements between the two

offices have resulted in impaired working relationships. If the

offices do not work well together to resolve disagreements, they

may not be making decisions to use their joint resources in the most

efficient ways. 

BACKGROUND

OAR has many research and monitoring needs to support its air

programs. Air Program officials perform some of this research and

monitoring, while outside organizations, such as ORD, other

government agencies, or contractors, also perform some. ORD’s

activities include a range of functions: technical support, such as

monitoring to detect air pollution trends; long-term research to find

new ways to prevent and control air pollution; risk assessments for

new standards and other pollutants; developing measurement and

reference methods; research on the health and ecological effects of

air pollutants; and working on Air Program reports, such as the

Mercury Report to Congress.
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In fiscal year 1997, ORD allocated just over 20% of its Enacted

Operating Plan budget to Air Program activities. ORD used $91.4

million of its $439.4 million budget for air-related research and

technical support activities. As shown in figure 3, of the $91.4

million, about three quarters was for research activities and one

quarter was for technical support. 

 

Research

Technical Support

76%

24%

Figure 3: ORD's Air-Related Resources

FY 1997

The past several years have been a period of change for ORD and

the Agency’s research, development, and technical support planning

process. In July 1994, an Agency-wide Steering Committee issued

a report to the Administrator, Research, Development, and

Technical Services at EPA: A New Beginning. To implement the

report’s recommendations, in 1996, ORD issued a Strategic Plan

after obtaining input from both within and outside the Agency. The

plan identified priorities, as well as areas for disinvestment. ORD

also established a new planning process based on priorities

identified by the program and regional offices and risk-based

decision-making. 

OAR AND ORD

GENERALLY WORKED OAR and ORD generally worked well together and agreed on most

WELL TOGETHER of their activities, such as their coordination on the newly revised

ambient air standards for ozone and particulate matter. While the

two offices have an overall positive working relationship, officials

from both offices agreed that their working relationships could
The Effectiveness and Efficiency

of EPA’s Air Program

8One example of a distinction between routine and research-oriented monitoring involved the Agency’s

ultraviolet-b radiation monitoring network. Although ORD had considered transferring responsibility for the

network to the Air Program, ORD instead decided to maintain the network, because calibration and operation of

the current state-of-the-art monitors were very technical and, as such, did not constitute routine monitoring.

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improve if they better resolved disagreements. They need to build

upon this relationship to address the issues cited in this chapter.

SOME 

DISAGREEMENTS Some areas of disagreement existed between the two offices. The

EXISTED disagreements mainly focused on (1) how ORD used what it

described as its limited resources, and (2) which of the two offices

would perform needed monitoring activities. For instance, ORD

officials decided that, with declining resources, their office could

not continue performing both research activities and all monitoring

activities. Therefore, consistent with its 1996/1997 Strategic Plan,

ORD chose to disinvest in “routine” monitoring activities, while

maintaining the more technical or research-oriented monitoring

networks.8 Air Program officials disagreed with ORD’s decision to

phase out some air monitoring activities. 

The two offices also disagreed about which office should perform

the monitoring activities. ORD officials believed that, as the

monitoring activities evolved from being research in nature to more

routine, the Air Program should take over the activities. This

transition would allow ORD’s limited resources to be devoted to

research. However, OAR expected ORD to continue its traditional

role in providing monitoring support and believed much of the

monitoring in question was not “routine.” Air Program officials

stated that they did not have enough time to adequately reallocate

their resources to handle the monitoring when ORD presented them

with a disinvestment plan. OAR also believed that, if monitoring

functions were to be transferred, they should be accompanied by

the associated resources.
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CAUSES OF

DISAGREEMENTS The disagreements between the two offices occurred for several

reasons. For instance:

C OAR was concerned that ORD had not established a

consistent process for making planning and budgeting

decisions that provided clear opportunities for input by

stakeholder offices, such as OAR. Although an Air

Program official said the just-completed planning process

for fiscal year 1999 was better than it had been in prior

years, he did not think it was well-defined. Other Air

Program managers also were not sure how, or even if, they

had input to ORD’s decisions. 

C ORD expressed concern that OAR had not always set

priorities for its research and monitoring needs, or indicated

what activities ORD could eliminate if sufficient funding

was not available to meet all of the needs. According to

ORD, program offices need to convey and prioritize their

research, development, and technical support needs, so

ORD can put the needs in context with those of other

offices.

C Neither office had a mechanism in place for resolving

disagreements over the decisions they made. They also did

not have a way of sharing decisions affecting air research

and monitoring between the two offices and among the

managers and staff within each office. 

C The two offices had not agreed on the definition of routine

monitoring and which office should perform such

monitoring.

DISAGREEMENTS

IMPAIRED RELATIONS Disagreements between the two offices impaired working

AND EFFICIENCY relationships and efficiency. Air Program managers were very

frustrated with ORD, because they were not always aware of, or

did not understand, ORD’s decisions on air research and
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monitoring activities. ORD officials, in turn, were frustrated with

Air Program officials, because they requested many research and

monitoring projects, without establishing priorities, especially

across the different OAR offices. 

If the two offices do not work well together, they may not be

making decisions to use their joint resources in the most efficient

ways. For example, because OAR did not clearly identify its top

priorities, ORD officials could not always make informed decisions

about which Air Program research and monitoring activities were

the most important. If ORD chose not to perform some activities

OAR considered critical, then Air Program officials would need to

find other resources to fund those activities. If the two offices

worked together to establish their joint priorities, then they could

conduct the most important activities, while less important activities

could wait until resources were available.

CONCLUSION

If OAR and ORD worked together to resolve their disagreements

over how air research and monitoring resources should be spent,

and what activities each office should do, they could improve the

efficiency of their joint efforts.

RECOMMENDATIONS 

We recommend that the Acting Assistant Administrator for Air and

Radiation and the Acting Assistant Administrator for Research and

Development work together to:

1-1. Continue the improvements made in the fiscal year 1999

research planning process including making sure that in

future processes:

a. ORD provides a consistent process for making

planning and budgeting decisions, which identifies

opportunities for input from the program offices and

regions at key decision points.
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b. OAR identifies up-front its cross-office priorities,

and both offices agree on the lower priority activities

that will be eliminated if resources are limited.

c. each office informs its managers and staff at each

critical stage of the planning and budgeting process.

d. both offices commit to resolve differences on shortterm or time-critical issues expeditiously, seeking

higher resolution of disagreements only as a last

resort and doing so together.

1-2. Use the Agency’s Environmental Monitoring Management

Council as a forum for addressing multi-office technical

support issues, such as defining routine monitoring and

which offices should perform it. 

AGENCY COMMENTS 

AND OIG EVALUATION Following our briefing on the results of our fieldwork, OAR and

ORD officials concurred that they needed to work together to

resolve their disagreements. In a conference call on September 3,

1997, officials from the two offices proposed several actions they

could take to resolve these concerns. These actions are included in

the recommendations. 

Both Acting Assistant Administrators for OAR and ORD concurred

with our findings and recommendations. They need to provide

specific corrective actions and milestone dates for implementing the

recommendations.
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PART 3

CHAPTER 2

OAR and OCEPA Needed to

Work Together to Raise Public Awareness

A second way the Air Program could be more efficient is to work

with the Office of Communications, Education, and Public Affairs

(OCEPA) to raise public awareness about air pollution. The public

is important to the success of Office of Air and Radiation (OAR)

programs. Officials from the two offices agreed they have not

communicated or coordinated sufficiently with each other in the

past. As a result, OAR did not always use its resources efficiently. 

Recently, officials in both offices have taken steps to improve their

working relationship. They must continue working together to

resolve past differences. 

BACKGROUND

EPA’s program offices individually develop education and

marketing materials, but are to coordinate them through OCEPA. 

For example, OCEPA reviews, approves, and distributes education

and marketing materials that the Air Program develops. 

Education and awareness are pivotal for OAR’s voluntary

programs, such as those to reduce radon exposure, greenhouse

gases, and energy consumption. OAR’s Office of Mobile Sources

sees public education as a key to convincing people to reduce

future automobile emissions and accept other alternatives to

driving. The Organization for Economic Cooperation and

Development agrees, and recommended in 1996 that the U.S.

strengthen education to increase public understanding about the

effects of air pollution caused by vehicle use.

CHANGING WORKING

RELATIONSHIP FOR Recently, OAR and OCEPA officials have agreed they needed to

OAR AND OCEPA improve their working relationship and have begun taking steps to

do so. OCEPA has had a change in management, and plans to

reorganize soon. Anticipation of the reorganization and other
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changes have helped OCEPA officials streamline their efforts,

allowing them to concentrate on areas where they will have the

most impact. OAR officials reported that OCEPA staff members

are now more responsive and helpful. Officials from both offices

also meet together frequently. Communication is more open and

constructive, fostering a cooperative relationship, instead of an

adversarial one. 

OAR AND OCEPA

DID NOT ALWAYS Conflicts between OAR and OCEPA caused tension and resulted

WORK WELL in staff members not working well together. The two offices had

TOGETHER not always coordinated on projects to raise public awareness of air

pollution. For instance, OCEPA officials said that OAR should

involve OCEPA early in educational and outreach projects. 

Because Air Program officials did not always do this, OCEPA did

not review the products until they were completed. OCEPA then

questioned the effectiveness or cost of some products. OAR

officials thought OCEPA needlessly delayed the projects with

extensive questions and did not always add value to the projects. 

RELATIONSHIP

IMPACTED The lack of communication and coordination between OAR and

EFFICIENCY OCEPA resulted in OAR not always using its resources in the most

efficient way. Staff in both offices were frustrated and had

difficulty working together. Officials felt they were working

against each other, not together to accomplish OAR’s mission. 

Among other instances, tension was created when:

C OCEPA was not involved with OAR’s development of a

refrigerator-style magnet for the ENERGY STAR program. 

(See figure 4 for a representation of the magnet.) OAR

created the magnet for contractors to give to the public,

providing information about types of equipment that have

met the ENERGY STAR energy efficiency criteria. OCEPA

officials were disturbed because (1) they thought OAR

should have consulted them about information to include on

the magnet, and (2) the magnet was printed without

OCEPA’s approval. An OCEPA official stated that the

magnet was difficult to read and did not contain useful
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information, such as a phone number. OAR officials stated

that it was not clear that OCEPA was supposed to review

magnets before they were released.

 

Figure 4: OAR Energy Star Magnet

C The two offices could not arrange to work together on a

fast-track project with the American Lung Association. The

American Lung Association and OAR planned to enter a

cooperative agreement to develop a public service

announcement about ground-level ozone. To complete the

announcement in time for ozone season, the project needed

to proceed quickly. OCEPA officials, however, could not

accommodate OAR’s request for a fast-track review. 

OCEPA’s workload would not allow it to look at the

announcement until after the ozone season, in September. 

OAR officials were frustrated that OCEPA officials could

not make time to review the project, even though it was

important to them. OAR eventually did not finalize the

planned cooperative agreement with the American Lung

Association because the project could not be completed

timely. 

By not working together, the two programs were not operating as

efficiently as possible.
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CONCLUSION

Recognizing that they needed to improve their communication and

coordination, OAR and OCEPA officials have taken steps to begin

improving their working relationship. Working together, OCEPA

and OAR can inform the public about air pollution causes, effects,

and remedies, in common sense ways.

RECOMMENDATIONS

We recommend that the Acting Assistant Administrator for Air and

Radiation work with the Associate Administrator for

Communications, Education, and Public Affairs to: 

2-1. Ensure that product review requirements are followed. 

2-2. Establish procedures to ensure that the offices work upfront with each other when developing projects to raise

public awareness of air pollution. 

We also recommend that the Associate Administrator for

Communications, Education, and Public Affairs:

2-3. Establish concise product review procedures that serve as a

clear and simple guide to the product review process.

AGENCY COMMENTS 

AND OIG EVALUATION Following our briefing on the results of our fieldwork, OAR and

OCEPA officials agreed they needed to improve their coordination

and communication. In August 1997, officials from the two offices

committed to work together. Several of their proposed actions are

included in the recommendations. 

Both the Acting Assistant Administrator for OAR and the

Associate Administrator for OCEPA concurred with our

recommendations. OCEPA provided corrective actions, but needs

to provide a milestone date for recommendation 2-2. OAR needs

to provide specific corrective actions and milestone dates.
The Effectiveness and Efficiency

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9OAR Stakeholders Page, September 1997.

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PART 3

CHAPTER 3

OAR Needed to Give 

Stakeholders Sufficient Feedback

A third way the Air Program could be more efficient is if the Office

of Air and Radiation (OAR) was more responsive to stakeholders,

such as EPA regional offices, states, industry, and environmental

groups, in implementing the Clean Air Act, as amended in 1990

(Act). OAR frequently consulted stakeholders for ideas; however,

some stakeholder relationships could have benefitted from more

feedback from OAR. Stakeholders may have perceived a lack of

feedback because (1) they may not have had a clear understanding

of how the stakeholder process worked and entered the partnership

with high expectations, (2) there was not always a formal

mechanism to provide feedback, and (3) the process for working

with stakeholders was lengthy. As a result, some stakeholders were

reluctant to work with OAR again. OAR cannot efficiently carry

out the Act without the cooperation and help of its stakeholders.

BACKGROUND

OAR officials recognize that working with stakeholders is critical to

the success of their programs. According to OAR, "by working

together as stakeholders with common goals, federal, state and

local agencies can help each other in attaining and preserving

clean air in the United States."9

OAR does not have the mandate or the resources to carry out the

Act itself. Instead, the Act encouraged OAR to consult

stakeholders and made state and local entities, with EPA oversight,

largely responsible for implementation. With that responsibility,

Federal funds have also gone to state and local entities. For

example, as shown in figure 5, of OAR's fiscal year 1996 resources,
The Effectiveness and Efficiency

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10These grants are referred to as Section 105 grants, based on the Act section in which they are

authorized. 

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37% went to state and local entities as grants to establish and

operate air pollution control programs.10 

 Figure 5: OAR Air Grants to State 

and Local Entities

1993 1994 1995 1996

0

100

200

300

400

500

Air Grants

OAR Resources

$421.1 $411.6

$448.2 $441.1

$175.8 $174.8 $179.6 $163.3

42% 42% 40% 37%

State and local entities also contribute their own resources toward

cleaning the air. In September 1995, the State and Territorial Air

Pollution Program Administrators/Association of Local Air

Pollution Control Officials reported that Section 105 grant funding

accounted for between 4 and 65% of overall air program funding

for selected state and local entities. 

Table 2: OAR Air Grants As a Percentage

of Overall Air Program Funding

Number Sampled High Low Average

14 States 65% 8% 29%

11 Locals 32% 4% 19%

OAR and its stakeholders share a common goal, working to make

the nation's air cleaner. Together, OAR and its stakeholders can

achieve more than if they worked independently. 
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OAR ASKED FOR 

INPUT FROM OAR often turned to stakeholders for input. According to OAR

STAKEHOLDERS officials, one of their most important stakeholders is the Clean Air

Act Advisory Committee, which they were required to establish

under the Act. The committee provides advice to OAR on policy

and technical issues associated with implementation of the Act. 

Committee members include a variety of people representing: 

states, local entities, tribes, public interest groups, environmental

groups, industry and trade groups, consultants, academia, and

Federal Government agencies. 

OAR also involved stakeholders in a wide variety of projects. For

example, the Office of Mobile Sources (OMS) worked with

automobile manufacturers on proposed regulations and to develop

new technology. OMS had also established partnerships with other

governmental agencies, such as the Department of Energy and the

Department of Transportation. OAR worked with 37 states

through the Ozone Transport and Assessment Group to develop

solutions for ozone transport. OAR also solicited input from the

regions on planning and priority setting. 

OAR DID NOT ALWAYS

GIVE FEEDBACK Some stakeholders, however, did not believe they received

sufficient feedback from OAR. Several stakeholders told us that

OAR frequently asked them to provide input, but did not tell them

of the results. For example, members of the Clean Air Act

Advisory Committee subcommittee for Ozone, Particulate Matter,

and Regional Haze Implementation Programs (subcommittee) said

EPA did not keep them informed of progress on the implementation

plan for the new ozone and particulate matter standards. OAR

received subcommittee recommendations on how to implement the

new standards and later, without further consultation or input from

the subcommittee, released a broad outline describing how it

planned to implement the new standards. The subcommittee

members were initially disappointed with OAR's outline, and that

they were "never briefed on the strategy." 
The Effectiveness and Efficiency

of EPA’s Air Program

11Environmental Protection: Challenges Facing EPA’s Efforts to Reinvent Environmental Regulation,

GAO/RCED-97-155, July 2, 1997.

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STAKEHOLDERS

PERCEIVED LACK Stakeholders may have perceived a lack of feedback from OAR

OF FEEDBACK because (1) they may not have had a clear understanding of how the

stakeholder process worked and entered the partnership with high

expectations, (2) there was not always a formal mechanism to

provide feedback, and (3) the process for working with

stakeholders was lengthy. 

First, OAR and its stakeholders may have entered the stakeholder

relationship with different expectations, when stakeholders did not

clearly understand the process. A U.S. General Accounting Office

report found that stakeholders often worked with EPA expecting to

reach a consensus.11 However, from OAR officials' perspective,

when they ask for input from stakeholders, especially on a proposed

rule, consensus could not always be achieved. In one example, the

State of Washington and OAR worked together on the Maximum

Achievable Control Technology (MACT) standard for aluminum

mills. A state official said that she learned OAR's expectation of the

state role in the MACT development was different from the state's

initial expectation. In this case, state officials were disappointed

that OAR did not use all of their input when developing the final

standard. While OAR officials considered the state comments, they

could not reflect all of the comments in the final rule, because they

were not technically feasible. Because of their varied expectations,

state staff were frustrated.

Second, stakeholders provide input to OAR and some may expect

to be kept informed of the status. When a stakeholder provides

formal comments to EPA on proposed rules, a mechanism is in

place to address the comments, by either including them in the final

rule or at least responding to the comments, if changes are not

made to the rule. However, there is no such formal mechanism to

provide feedback to stakeholders at other stages of the rulemaking

process.
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Finally, participating with OAR as a stakeholder is a very lengthy

process. If stakeholders want to ensure their comments are

included in the final rule, they must submit formal comments

throughout the rulemaking process. This process can take up to

two years. OAR often asks stakeholders to provide input when

developing a proposed rule. For example, OAR consults the Clean

Air Act Advisory Committee or the appropriate subcommittee to

get stakeholder input prior to developing a proposal. OAR then

writes the proposed rule and submits it to the Office of

Management and Budget (OMB). OMB can take up to 90 days to

review a proposed rule, and sometimes does not take any action

during the first 60 days. At this time, OMB usually works only

with OAR on the proposed rule. This results in a long waiting

period where stakeholders are left out and do not know what is

going on with the rule.

STAKEHOLDERS

HESITANT TO WORK OAR cannot efficiently implement the Act without the

WITH OAR cooperation and help of its stakeholders. Stakeholder expectations

are often higher than what OAR can or intends to meet. These high

expectations can create misunderstandings and hurt OAR's

stakeholder relationships. Relationships that lack sufficient

feedback can leave stakeholders feeling misguided and hesitant to

work with OAR again. For example:

C Clean Air Act Advisory Committee subcommittee members

were upset at not being briefed on OAR's final

implementation plan for the new ozone and particulate

matter standards. Several subcommittee members initially

thought "EPA must either redefine the group's role in the

process or disband it entirely." The members were left

wondering why EPA officials asked for input if they did not

intend to use it. The members also wanted EPA to refine

the group's mission, to better direct resources to areas

where EPA would be receptive to suggestions. 

C A state air director said he saw his staff's work on the

MACT standard for aluminum mills as being of limited

value. His staff is currently working on other MACT
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standards with OAR, but with a lower amount of effort than

was spent on the aluminum mill MACT. He also has a

lower expectation of results and of what the state's input

can accomplish. 

Poor stakeholder relationships result in OAR potentially alienating a

vital resource. If stakeholders enter a partnership with high

expectations, they will likely be disappointed when those

expectations are not met. Stakeholders that do not feel their input

was addressed in a final regulation are more likely to challenge the

regulation through lawsuits. 

CONCLUSION

OAR officials need to see working with stakeholders as a process

that involves much more than just accepting input. OAR and the

stakeholders need to have a clear understanding of their relationship

up-front. OAR also needs to provide stakeholders with sufficient

feedback, especially when unable to incorporate the stakeholders'

suggestions. Informal feedback is crucial when there is no formal

mechanism available. Assuring solid relationships with stakeholders

is vital to efficiently achieving the common goal of cleaning the

nation's air. 

RECOMMENDATIONS

We recommend that the Acting Assistant Administrator for Air and

Radiation:

3-1. Develop a process to work with stakeholders up-front to

define expectations of the results or outcome of the

stakeholder relationship.

3-2. Require OAR officials to explain to stakeholders the

process for proposing a regulation, including: OMB

involvement, that comments at some stages will not

formally be addressed, and that it can be a lengthy process. 

3-3. Establish a process to ensure that feedback is provided to all

stakeholders when OAR has not addressed their concerns,

or has not used the input.
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AGENCY COMMENTS 

AND OIG EVALUATION The Acting Assistant Administrator for OAR concurred with our

findings and recommendations. He needs to provide specific

corrective actions and milestone dates for implementing the

recommendations.
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PART 3

CHAPTER 4

OAR Needed to Give Attention

to Several Activities

The fourth way in which the Air Program could be more efficient is

to devote attention to several ongoing activities. These activities

have been discussed in prior audit reports and include: leading the

state implementation plan (SIP) process, developing and improving

emission factors, and issuing air toxic standards. The Office of Air

and Radiation (OAR) has not considered these activities high

priorities, compared with other program areas. This resulted in

delays and limited funding. Consequently, these activities have

operated inefficiently and may not be achieving their desired results. 

For example, state plans to achieve emission reductions could be

delayed. The plans may also be incorrect if the state’s estimates of

emissions from major sources are based on inaccurate emission

factors. Also, industry deadlines for installing controls over

emissions of air toxics will be delayed if OAR is late in issuing

standards. 

BACKGROUND

SIPs, emission factors, and air toxic standards are vital to achieving

some of OAR’s fundamental responsibilities, as they have defined

them. For example, to meet its responsibility of helping state, local,

and tribal governments develop and implement programs to achieve

the air quality standards, OAR must assure that approved SIPs are

in place and emission factors are reliable. To meet its responsibility

to develop standards to control the release of air toxics, OAR must

assure that it has a current, practical plan to develop the standards.

SIPs SIPs are the major mechanisms used to attain air quality standards. 

A SIP is a plan made up of the regulations a state will use to clean

up polluted air. The Clean Air Act, as amended in 1990, (Act)

established deadlines for states to submit the plans to EPA for

review and action. States develop a separate plan for each standard

or air pollutant of concern, such as: ozone, carbon monoxide, and

particulate matter. 
The Effectiveness and Efficiency

of EPA’s Air Program

12A source category is a group of facilities that generally employ similar manufacturing processes or

produce similar products.

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Emission Factors Emission factors are sometimes used to estimate emissions from

major sources of air pollution. They are primarily used when more

reliable emissions data, such as monitoring data from continuous

emission monitors or stack tests, are not available for a source. 

EPA and states use these emission estimates in many parts of their

air pollution control programs, including: (1) preparation of

emission inventories used in air quality models to develop and

evaluate pollution control strategies, (2) permitting and fee

programs, and (3) emission trading programs.

Air Toxics Air toxic standards, called Maximum Achievable Control

Technology standards, establish pollution controls for all sources

that emit significant amounts of toxic substances into the air. 

Potential sources of air toxics include printers, dry cleaners, and oil

and natural gas producers. The standards require all major sources

to install control equipment or change manufacturing processes to

reduce toxic emissions to levels at least as stringent as those already

achieved by the best-performing facilities in a source category.12

The Act established deadlines for OAR to issue air toxic standards,

requiring OAR to regulate certain percentages of source categories

by November of 1994, 1997, and 2000, as shown in table 3.

Table 3: Air Toxic Standards

Due

(Shown Cumulatively)

Year Due

Percentage of

Standards Due

1994 25%

1997 50%

2000 100%

SIP PROCESSING

NEEDED TO BE While regional offices had several good management practices
The Effectiveness and Efficiency

of EPA’s Air Program

13EPA’s Air State Implementation Plan Program Consolidated Report, EPA OIG Report No. 6400100,

September 30, 1996.

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IMPROVED in the SIP program, OAR could improve parts of the program on a

national basis. For instance, OAR and states had not always met

Act deadlines for submitting and processing SIPs. Late OAR

guidance was the greatest single cause for states submitting their

SIPs late.13 State legislatures often have to pass SIPs into law. 

Because this can be a lengthy process, some states need a long lead

time to develop and put their SIPS in place. 

Another major cause of late SIPs was OAR delays in bringing

policy issues to closure. Both our review and an OAR SIP

Improvement workgroup found that some issues were left

unresolved for a long time. For example, OAR needed to resolve

national issues before regions could process some SIPs. In several

instances, Region 2 officials delayed processing state SIPs because

they identified a national issue that needed to be resolved. They

had to wait for a decision from an OAR workgroup before

processing the SIPs. The OAR SIP Improvement workgroup cited

low priority with management as a root cause of this delay.

While states have already submitted many of the original SIPs

required under the Act, they will be required to submit new SIPs to

meet the ambient air quality standards for ozone and particulate

matter that were revised in 1997. As states begin to design

programs to achieve these new standards, they will again need

OAR’s guidance and prompt policy decisions to develop their SIPs

efficiently. The longer it takes to get SIPs processed and in place,

the longer it will take to achieve cleaner air. 
The Effectiveness and Efficiency

of EPA’s Air Program

14Emission Factor Development, EPA OIG Report No. 6100318, September 30, 1996.

34

Report No. 8100057

EMISSION FACTORS

NEEDED TO BE Emission factor development had not met users’ demands for new

DEVELOPED and revised emission factors.14 Emission factors were unavailable

AND IMPROVED for many sources of air pollution, and those that were available

were often unreliable. Moreover, OAR had not met the Act’s

requirements to develop emission factors for all sources of ozone

precursors. State and industry officials had to use the unreliable

factors to estimate emissions. In cases where no factors were

available, users were forced to rely on “best engineering

judgement,” or an educated guess. 

OAR cited resource limitations as causing problems with emission

factors. Developing or revising emission factors can be expensive

and can take several years to complete. For example, one revision

cost OAR about $1 million in contract funds and took over five

years to complete. An OAR official said that recent budget cuts

significantly hindered OAR’s efforts to revise and develop high

quality emission factors. Resources for emission factors decreased

from $5.8 million in contract dollars and 17.6 full time equivalents

(FTEs) in fiscal year 1992 to $1.4 million and 8.8 FTEs in fiscal

year 1996. This is shown in figure 6.

 

17.6

15.4

13.9

12.6

8.8

5.8

3.2 2.9 2.7

1.4

1992 1993 1994 1995 1996

0

5

10

15

20

FTEs

Contract Dollars (in Millions)

Figure 6: Emission Factor Funding

FY 1992 through FY 1996
The Effectiveness and Efficiency

of EPA’s Air Program

15Development of Maximum Achievable Control Technology Standards, EPA OIG Report No. 6100140,

March 19, 1996.

35

Report No. 8100057

Without reliable emission factors, OAR and the states who use

them cannot be sure that their: (1) air pollution control strategies

target the right industries or products, (2) permitting programs

include all required sources and establish proper emission limits,

and (3) emission trading programs are effective in reducing air

pollution. If these programs are not effective, the nation’s air

quality could be adversely affected and people could be subjected to

the health hazards associated with excessive exposure to air

pollutants.

TIMELY AIR TOXIC 

STANDARDS NEEDED OAR has been behind schedule for promulgating air toxic

standards. As shown in figure 7, OAR missed its statutory

deadlines for most of the 21 air toxic standards due in 1992 and

1994. OAR also missed more than 85% of its 26 statutory

deadlines for 1997. 

2

19

26

2

13

23

1992 1994 1997

5

10

15

20

25

30

 Standards Due

 Deadlines Missed

Figure 7: Air Toxic

Standard Deadlines

Although the Agency was behind schedule for promulgating air

toxic standards, in 1995, OAR officials actively sought and put to

use many initiatives to speed and improve the process. An Office

of Inspector General (OIG) review of various OAR initiatives

revealed that many had already proven effective at speeding up the

process and others had merit.15 However, to meet the deadlines set
The Effectiveness and Efficiency

of EPA’s Air Program

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Report No. 8100057

by Congress for future standards (58 are due in November 2000),

OAR must continue and even accelerate the issuance of regulations.

U.S. General Accounting Office (GAO) reports have identified

limited funding as a reason the Air Toxics Program has had limited

success. In 1991, OAR officials stated that they planned to have

larger budgets for the program in future years. However, those

plans never materialized. For instance, GAO reported that OAR’s

1994 budget was reduced by $32 million. The Air Toxic Standards

Program faced a significant reduction to its funding request, when it

was reduced by 51 percent. See figure 8.

 

$14.5

$7.1

Requested Funded

0

5

10

15

51%

Figure 8: Air Toxic Funding

FY 1994

If OAR does not issue the remaining air toxic standards timely, it

will (1) allow industry additional time to operate without using the

best methods available to reduce the air toxics it emits and (2) face

challenges to the standards. 

Issuing standards late allows industry more time before it has to

change its methods to reduce emissions. Industry does not have to

change its processes until an air toxic standard becomes effective. 

If OAR does not issue an air toxic standard within 18 months of its

statutory due date, states are then required to set emission limits for

sources through the state operating permit. State officials are

supposed to determine, on a case-by-case basis, what limit they

think would apply, had a standard been timely issued. If OAR later

issues a different or more stringent air toxic standard, the new
The Effectiveness and Efficiency

of EPA’s Air Program

16Information on EPA’s Air and Radiation Program’s Budget, 1990-95, GAO/RCED-96-201R, July 1,

1996.

37

Report No. 8100057

standard does not apply to the permitted source until the next

permit renewal. The Act allows up to eight years for this to occur.

Because of problems with the air toxic standard program, OAR

may be vulnerable to lawsuits. For instance, environmental

organizations may sue OAR to force it to issue standards that are

already late. These groups and the regulated industry may also sue

OAR, because budget problems may impact the quality of the

newer standards. For example, in a December 1994 memorandum,

an OAR official stated that the fiscal year 1995 budget level would

have a significant impact on the Office’s ability to meet its

requirements. He said this was especially true for developing and

issuing the 1997 and 2000 standards.16 In an attempt to meet as

many deadlines as possible, OAR reduced the amount of data

collected and analyzed in developing the standards. However,

OAR officials expressed concern that the quality of the newer air

toxic standards may suffer.

CONCLUSION

Because OAR had not considered its ongoing activities of:

C leading the SIP process, 

C developing and improving emission factors, and 

C issuing air toxic standards

as high priorities, the activities had not operated as efficiently as

possible, experiencing delays and limited funding. If these activities

continue to be low priorities, it is likely that the problems identified

in this chapter will also continue. SIPS will still be delayed and will

be based on unreliable emission factors. Industry deadlines for

installing air toxic controls will also be delayed. As a result, OAR

and state air programs may not be as efficient or effective as they

could be, resulting in continued air pollution. 
The Effectiveness and Efficiency

of EPA’s Air Program

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Report No. 8100057

RECOMMENDATIONS

FROM PRIOR AUDIT Prior audit reports included recommendations to address the

REPORTS concerns discussed in this chapter. For instance, in our 1996 report

on SIPs, we recommended that the OAR Assistant Administrator: 

(1) place priority on implementing the SIP workgroup’s

recommendations for developing guidance and bringing

policy issues to closure; 

(2) place priority on promptly resolving national SIP issues,

including those that impact guidance documents; and

(3) establish realistic deadlines for future SIPs that allow EPA

time to develop useful guidance.

In her April 1997 response to that report, the Assistant

Administrator agreed with the recommendations and provided steps

for implementing them. She also stated that OAR had emphasized

up-front planning for the new ozone and particulate matter SIPs to

ensure that the SIP revisions were submitted in a timely manner. 

She identified several actions that she believed would substantially

ease the SIP development effort and result in SIPs being submitted

more timely and being fully approvable. These actions, when fully

implemented, should address our concerns with late guidance and

unresolved national issues. As a result, we are not making

additional recommendations in this area.

In the prior OIG audit of emission factors, we recommended that

OAR declare the program as a material weakness, until adequate

resources were obtained to assure satisfactory progress. OAR

submitted its emission factor strategy to the EPA Senior Leadership

Council and the OIG on November 25, 1997. The strategy

provided some actions for correcting the program weaknesses. For

instance, beginning in fiscal year 1998, OAR will focus its efforts

on upgrading and developing factors for air toxics and the revised

particulate matter standard, as well as those for non-road mobile

sources. We accepted that these actions, when fully implemented,

will address our concerns with emission factor development. 

However, we still believe that the program should be declared a
The Effectiveness and Efficiency

of EPA’s Air Program

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Report No. 8100057

material weakness, until OAR implements the corrective actions. 

We do not have any additional recommendations in this area.

GAO recommended, in 1991, that OAR revise its air toxics strategy

to include all actions, activities, and tasks mandated or reasonably

believed to be necessary to carry out the objectives of the Act. As

of October 1997, this had not been completed. We believe OAR

should still update the air toxics strategy for issuing the remaining

air toxic standards. 
The Effectiveness and Efficiency

of EPA’s Air Program

40

Report No. 8100057

Exhibit 1

Page 1 of 2

EPA OIG and GAO Reports

EPA OIG Reports Included in the Scope of this Report

Report Name, 

Issuing Office

Report

Date

Report

Number

Survey of EPA Green Lights Program, 

Headquarters Audit Division

01/17/95 5700002

Regional Management of CAA Section 105 Air Grant Program,

Southern Audit Division

09/29/95 5100510

Acid Rain Allowance Trading Program,

Eastern Audit Division

12/12/95 (1)

Region 3 Title V State Operating Permit Program,

Mid-Atlantic Audit Division

02/06/96 (1)

Development of Maximum Achievable Control Technology

Standards,

Headquarters Audit Division

03/19/96 6100140

EPA’s Development of its Proposed Open Market Trading Rule,

Eastern Audit Division

03/28/96 6400046

Emission Factor Development,

Southern Audit Division

09/30/96 6100318

EPA’s Air State Implementation Plan Program Consolidated

Report,

Northern Audit Division

09/30/96 6400100

Risk Reduction Through Voluntary Programs,

Northern Audit Division

03/19/97 7100130

(1) No report number was assigned, because it was an internal survey report.
The Effectiveness and Efficiency

of EPA’s Air Program

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Report No. 8100057

Exhibit 1

Page 2 of 2

GAO Reports Included in the Scope of this Report

Report Name Date Number

Air Pollution: EPA’s Strategy and Resources May Be

Inadequate to Control Air Toxics

06/26/91 GAO/RCED-91-143

Indoor Air Pollution: Federal Efforts Are Not Effectively

Addressing a Growing Problem

10/15/91 GAO/RCED-92-8

Asbestos Removal and Disposal: EPA Needs to Improve

Compliance with its Regulations

02/25/92 GAO/RCED-92-83

Air Pollution: Unresolved Issues May Hamper Success of

EPA’s Proposed Emissions Program

09/25/92 GAO/RCED-92-288

Air Pollution: Actions to Promote Radon Testing 12/24/92 GAO/RCED-93-20

Air Pollution: Difficulties in Implementing a National Air

Permit Program

02/23/93 GAO/RCED-93-59

Air Pollution: EPA’s Progress in Determining the Costs and

Benefits of Clean Air Legislation

02/11/94 GAO/RCED-94-20

Air Pollution: Reductions in EPA’s 1994 Air Quality

Program’s Budget

11/29/94 GAO/RCED-95-31BR

Air Pollution: Allowance Trading Offers an Opportunity to

Reduce Emissions at Less Cost

12/16/94 GAO/RCED-95-30

Air Pollution: EPA Data Gathering Efforts Would Have

Imposed a Burden on States

08/07/95 GAO/AIMD-95-160

Information on EPA’s Air and Radiation Program’s Budget,

1990-95

07/01/96 GAO/RCED-96-201R

Global Warming: Difficulties Assessing Countries’ Progress

Stabilizing Emissions of Greenhouse Gases

09/04/96 GAO/RCED-96-188

Peer Review: EPA’s Implementation Remains Uneven 09/24/96 GAO/RCED-96-236

Environmental Protection: Challenges Facing EPA’s Efforts

to Reinvent Environmental Regulation

07/02/97 GAO/RCED-97-155
The Effectiveness and Efficiency

of EPA’s Air Program

17We originally planned to include air enforcement in this report. Because OAR is no longer responsible

for enforcement, it was not included in this report. Instead, the OIG issued a report (7100306) on air enforcement

to the Office of Enforcement and Compliance Assurance on 09/30/97. The OIG also issued reports on validation

of air enforcement data in the states of Pennsylvania, Arkansas, Maryland, and Massachusetts. 

18We refocused this audit from indoor air to an audit of Air Voluntary Programs. 

42

Report No. 8100057

Exhibit 2

Page 1 of 3

Scope, Methodology, and Prior Audit Coverage

SCOPE We began this work with a general survey of the Air Program in

November 1993. In May 1994, we developed a strategic plan for

the air area. The plan identified ten reviews needed for a

comprehensive program evaluation. The suggested reviews and the

work completed are shown in table 4. 

Table 4: Audits Included in the Air Strategic Plan

Planned Audits Work Completed

Title V Permits Survey without report 

Green Programs Survey with report

Section 105 Grants Audit report

State Implementation Plans Special review report

Enforcement17 Audit reports

Acid Rain Emissions Trading Survey without report 

Non-Acid Rain Emissions

Trading

Special review report

Air Toxics Audit report

Indoor Air18 Audit report

Emission Inventories/Factors Audit report

Exhibit 2
The Effectiveness and Efficiency

of EPA’s Air Program

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Report No. 8100057

Page 2 of 3

After completing the individual assignments, in October 1996, we

began fieldwork to prepare this report on the Air Program’s

effectiveness and efficiency. We issued fully-developed position

papers to OAR, ORD, and OCEPA on November 4, 1997. We

held meetings with each office in December to obtain comments on

the position papers. Because we had agreement on the

recommendations included in the position papers, we did not issue a

draft report, and instead obtained formal written responses on the

position papers. Those responses are included as appendices 1, 2,

and 3.

Following is the methodology we used to answer our objective for

this report.

METHODOLOGY

The first part of our objective was to determine if the Air

Program was operating effectively to make the nation’s air cleaner. 

To accomplish this objective, we obtained and reviewed EPA,

international, and other government reports. We did not perform

direct tests of the data contained in these reports, because it was

not practical to do so. As a result, we cannot be certain of the

data’s validity and reliability.

The second part of our objective was to determine if the Air

Program was operating efficiently to make the nation’s air cleaner.

To accomplish this objective, we:

C reviewed prior OIG and GAO audit reports, issued since

November 1990, to identify common concerns. 

C discussed these concerns with Air Program management

and reviewed relevant documents they provided to

determine why the similar concerns existed and whether

they were indicators of program-wide problems. 
The Effectiveness and Efficiency

of EPA’s Air Program

44

Report No. 8100057

Exhibit 2

Page 3 of 3

C interviewed officials from regional and state air programs,

and environmental groups, to obtain their opinions on the

efficiency of the national Air Program. 

C interviewed officials from other EPA program offices that

OAR works with, including the Offices of Research and

Development; Communications, Education, and Public

Affairs; and Enforcement and Compliance Assurance. We

also reviewed documents they provided, to evaluate how

well the offices worked together to achieve the Air

Program’s goals. 

PRIOR AUDIT 

COVERAGE The OIG and GAO have performed many audits on various

activities of the Air Program, as shown in exhibit 1. We relied on

these audit reports for general information in preparing this report. 

We also highlighted four of these audits as containing issues

needing attention, as discussed in chapter 4. Those reports are:

1. EPA’s Air State Implementation Plan Program

Consolidated Report, 09/30/96, Report No. 6400100.

2. Emission Factor Development, 09/30/96, Report No.

6100318.

3. Development of Maximum Achievable Control Technology

Standards, 03/19/96, Report No. 6100140.

4. EPA’s Strategy and Resources May Be Inadequate to

Control Air Toxics, 06/26/91, Report No. GAO/RCED-91-

143.

For specific details on the findings and recommendations in these

reports, see chapter 4.
The Effectiveness and Efficiency

of EPA’s Air Program

45

Report No. 8100057

Exhibit 3

Page 1 of 2

Issues Needing Further Study

During our work in the Air Program, we identified several areas

that may need future study. A brief summary of those areas

follows.

Acid Rain 

Emissions Trading When we performed a survey of this program in 1995, the program

was not yet fully operational. We may want to perform additional

work on the results of the “True-Opt” reconciliation process, where

actual utility emissions are reconciled to the allowances held. This

reconciliation began in January 1996. We may also want to review

the status of states receiving approval of their acid rain permit

programs, which were due in July 1996. 

Non-Acid Rain 

Emissions Trading We performed our work on this program in 1996, but EPA had not

established its final open market trading rule, so no trades had been

completed. Since the time of our review, EPA decided not to issue

a rule, but instead issued guidance. We may want to perform

additional work once some trades have been completed under this

guidance to evaluate the internal controls over the process.

Monitoring Data This is an area we may want to consider looking at, because it is

critical to how EPA evaluates the results of its air pollution

programs.

Achieving Attainment We may want to determine whether non-attainment areas are

achieving attainment on schedule. For instance, moderate carbon

monoxide and ozone non-attainment areas were supposed to meet

the standards by December 1995 and November 1996, respectively. 

If these areas have not met the standards, we should evaluate

whether the states have fully implemented their state

implementation plans and whether the implementation has resulted

in anticipated reductions in pollution. Furthermore, we should
The Effectiveness and Efficiency

of EPA’s Air Program

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Report No. 8100057

Exhibit 3

Page 2 of 2

look at what actions EPA took when areas did not meet the

standards timely.

Title V Permits After states have had time to implement the Title V state operating

permit program, we should consider reviewing it. We performed a

survey in 1996, but the program was not fully operational at that

time. Potential audit issues include (1) EPA and state review of

companies that changed from major sources to synthetic minor

sources, thus avoiding the need for a Title V permit, and (2) how

EPA and states have addressed companies who admitted they had

been out of compliance on their permit applications.
The Effectiveness and Efficiency

of EPA’s Air Program

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Report No. 8100057

Appendix 1

Page 1 of 2

Office of Air and Radiation Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

FEB 12 1998

 OFFICE OF 

 AIR AND RADIATION

MEMORANDUM

SUBJECT: OAR’s Comments on the Air Theme Report - “The Effectiveness and Efficiency

of EPA’s Air Program” OIG Report E1KAE4-05-0246-xxxxxx

FROM: Richard D. Wilson

Acting Assistant Administrator 

 for Air and Radiation (6101)

TO: Michael D. Simmons

Deputy Assistant Inspector General

 for Internal Audits (2421)

Thank you for the opportunity to comment on the Office of the Inspector General’s Air

Theme Report - “The Effectiveness and Efficiency of EPA’s Air Program” (OIG Report

E1KAE4-05-0246-xxxxxx). We have reviewed the OIG’s position papers and concur with the

findings and recommendations.

I am pleased that OAR and ORD have made great strides in identifying research priorities

with their respective programs in the current budget cycle. We will continue to work with ORD

to strengthen OAR’s presence and results with the research community. Similarly it is

encouraging that OAR and OCEPA’s roles have been clarified and we are proceeding with a

better working relationship between our offices.

As you can see, even after half a decade with this Air Theme Audit, there remains much

work to be done. So I ask not only for the OIG’s continued cooperation but also for OCEPA and

ORD to work with OAR to develop plans for implementing the report’s recommendations under

the subsequent ninety day review. Please have your offices continue to coordinate any responses

through Pete Cosier (260-7755) of my staff. Thank you. I believe with everyone’s cooperation

we will soon be able to complete this theme audit effort.

cc: Henry L. Longest II (8101)

Loretta M. Ucelli (1701)

Kevin Teichman (8104R)

Arnold Bloom (8102R)

Ernest Ragland (2421)

Anthony Carrollo, Director OIG, Northern Audit Division

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)

Note: The original response was signed by Richard D. Wilson.
The Effectiveness and Efficiency

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Appendix 1

Page 2 of 2

Kimberly O’Lone, OIG, Northern Audit Division

Janice Miller, OIG, Northern Audit Division

Rob Brenner (6103)

Margo Oge (6401)

John Seitz (MD-10)

Paul Stolpman, (6201J)

Larry Weinstock, (661J)

Jerry Kurtzweg (6102)

Steve Page (6101)

Carl Mazza (6101)

Kevin Teichman (8104R)

Omayra Salgado (6102)

Pete Cosier (6102)

Arnold Bloom (8102R)
The Effectiveness and Efficiency

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Report No. 8100057

Appendix 2

Page 1 of 2

Office of Research and Development Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

FEB -4 1998

 OFFICE OF 

 RESEARCH AND DEVELOPMENT

MEMORANDUM

SUBJECT: Response to OIG Position Papers - “The Effectiveness and Efficiency of

EPA’s Air Program”

FROM: Henry L. Longest II 

Acting Assistant Administrator 

 for Research and Development (8101)

TO: Michael Simmons

Deputy Assistant Inspector General 

 for Internal Audit (2421) 

Purpose

The purpose of this memorandum is to convey ORD’s response to the Office of

Inspector General's Position Papers - “The Effectiveness and Efficiency of EPA’s Air

Program,” issued to us in final form on February 3, 1998.

Discussion

We have reviewed the OIG position papers and concur with the findings and

recommendations pertaining to ORD. We are pleased to note that ORD has already

taken certain steps, as part of its FY 2000 planning process, to implement the OIG’s

recommendations. Specifically, last month, ORD met with OAR to discuss OAR’s

strategic priorities for ORD research and technical support. We will continue to

work with OAR to forge our corrective action plan to the OIG’s report

recommendations. We understand that this corrective action plan must be

submitted to the OIG within 90 days from the issuance of the final audit report.

We appreciate the opportunity to work with the OIG and OAR representatives

in developing and reviewing various iterations of these position papers. We believe

this process was insightful and important. We particularly appreciate the extensive

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)

Note: The original response was signed by Joseph K . Alexander for Henry L. Longest II.
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Report No. 8100057

Appendix 2

Page 2 of 2

2

and outstanding efforts of the OIG Northern Audit Division Team Leader in working

with us on this important assignment. 

Once again, thank you for your responsiveness to our suggestions on this

effort. Should your staff have any questions or require further information, they

may contact Arnold Bloom at (202) 564-6687.

cc: Richard Wilson (6101)

Carl Mazza (6101)

Pete Cosier (6102)

Joseph Alexander (8101R)

Thomas Clark (8101R)

Kevin Teichman (8104R)

Peter Durant (8102R)

Lek Kadeli (8102R)

Colleen Lentini (8102R)

Arnold Bloom (8102R)

Ernest Ragland (2421)

Janice Miller (OIG/OA/NAD) 
The Effectiveness and Efficiency

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Appendix 3

Page 1 of 2

Office of Communications, Education, 

and Public Affairs Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

 OFFICE OF 

 COMMUNICATIONS, EDUCATION AND

DEC 16 1997 PUBLIC AFFAIRS

MEMORANDUM

SUBJECT: OCEPA Comments for the Air Theme Report

FROM: Loretta M. Ucelli

Associate Administrator

TO: Michael Simmons

Deputy Assistant Inspector General

 For Internal Audits (2421)

We have reviewed and discussed your position papers from the Air Theme audit.

OCEPA is in agreement with the recommendations that effect our office ( Part 2, Chapter 2). 

We met with your staff and suggested a few minor revisions, which Janice Miller

assures me are being made to the position papers.

Recommendations and proposed actions:

2-1. Carry out and work within the planned OCEPA reorganization to ensure that

 product review requirements are followed and discourage OAR officials from

 bypassing the product review requirements.

OCEPA’s proposed reorganization plan is being reviewed in the Office of the Administrator.

We anticipate sign-off before the first of the year and clearance by the Agency by the end of

January. An integral part of the reorganization is the placement of the product review system

within the new Office of Communication. We believe that the program offices will benefit from

a new approach to planning and approving the Agency’s information products. OCEPA also

intends to conduct a two day work shop, in mid-to-late February, with representatives from the

program offices and outside stakeholders to assist the Agency in defining and producing the

types of information products that will be useful to various audiences and the general public.

2-2. Establish procedures to ensure that the offices work up-front with each other

 when developing projects to raise public awareness of air pollution.

OCEPA intends to update all communications planning procedures to ensure that initial contact

 

Note: The original response was signed by Diane H. Esanu for Loretta M. Ucelli.
The Effectiveness and Efficiency

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Report No. 8100057

Appendix 3

Page 2 of 2

between ourselves and any program office begins early and is a collaborative effort that will lead

to increased public awareness. 

2-3. Establish concise product review procedures that serve as a clear and simple

 guide to the product review process for program offices.

An additional benefit of the February product review workshop will be discussions that will lead

to new guidelines (procedures) that program offices will reference when planning to develop

information products. We anticipate that written guidelines, after program input and review,

should be finalized by May, 1998.

If you or your staff have other questions or need additional information, please contact

Diane Esanu, Acting Deputy Associate Administrator at (202) 260-2190.

 
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Appendix 4

Page 1 of 1

Distribution

Headquarters

Assistant Administrator for Air and Radiation (6101)

Assistant Administrator for Research and Development (8101R)

Associate Administrator for Communications, Education, and Public Affairs (1701)

Agency Followup Official (2710)

 Attn: Chief Financial Officer, OCFO

Agency Followup Coordinator (2724)

Audit Followup Coordinator, Office of Air and Radiation (6102)

Audit Followup Coordinator, Office of Research and Development (8102R)

Audit Followup Coordinator, Office of Communications, Education, and Public Affairs (1104)

Associate Administrator for Congressional and Legislative Affairs (1301)

Headquarters Library (3401)

Office of Inspector General

Inspector General (2410)

Regional Offices

Regional Administrators

Regional Air Directors

Regional Audit Followup Coordinators

Regional Directors of Public Affairs

Regional Libraries

All State Directors