United States General Accounting Office

GAO Resources, Community, and Economic

Development Division

September 1995 Environmental Protection

Issue Area Plan

Fiscal Years 1995-97

GAO/IAP-95-23

Foreword

As the investigative arm of Congress and the nation’s auditor, the General

Accounting Office is charged with following the federal dollar wherever it

goes. Reflecting stringent standards of objectivity and independence, GAO’s

audits, evaluations, and investigations promote a more efficient and

cost-effective government; expose fraud, waste, abuse, and

mismanagement in federal programs; help Congress target budget

reductions; assess financial information management; and alert Congress

to developing trends that may have significant fiscal or budgetary

consequences. In fulfilling its responsibilities, GAO performs extensive

research and uses hundreds of databases or creates its own to compile and

analyze information.

To focus GAO’s resources on the most important issues facing Congress,

each of GAO’s 35 issue areas develops a strategic plan that describes its key

issues and their significance, how those issues influence audit objectives

and the focus of its work, and the planned major job starts. Each issue

area relies heavily on input from congressional committees, agency

officials, and subject-matter experts in developing its strategic plan.

With annual environmental compliance costs reaching $115 billion, federal

facility cleanup costs projected at $1 trillion, and environmental issues

permeating almost every facet of our lives, interest in environmental

protection programs remains at the forefront of the public and

congressional agenda. In light of these huge costs, GAO’s evaluations in this

issue area generally focus on increasing the cost-effectiveness of

environmental programs. By doing so, scarce public and private resources

can be best used to protect human health and the environment. The

principal issues in the environmental protection area are

• the generation and management of hazardous and solid waste;

• air quality measures required by the 1990 Clean Air Act Amendments;

• regulations for pesticides and other toxic substances;

• surface water, groundwater, and drinking water protection;

• the Environmental Protection Agency’s (EPA) organization, management,

and budget; and

• hazardous waste cleanups at federal facilities.

In the following pages, we describe our key planned work on these

nationally significant issues. Because events may significantly affect this

plan, our planning process calls for updating this plan and responding

quickly to emerging issues. If you have any questions or suggestions about

Page 1 GAO/IAP-95-23
Foreword

this plan, please call me at (202) 512-6111 or Larry Dyckman, Associate

Director, at (202) 512-3645.

Peter F. Guerrero

Director

Environmental Protection Issues

Page 2 GAO/IAP-95-23
Contents

Foreword 1

Table I: Key Issues 4

Table II: Planned

Major Work

8

Page 3 GAO/IAP-95-23
Table 1: Key Issues

Issue Significance

Hazardous and solid waste: Is the

government managing hazardous

and solid waste programs

cost-effectively?

Although EPA acknowledges that it is far more cost-effective to minimize the generation of waste

rather than treat and dispose it, Resource Conservation and Recovery Act (RCRA) regulations

are primarily directed at treatment and disposal. Further, these regulations do not necessarily

address those wastes that present the greatest risk to human health and the environment.

Finally, the Superfund program is a high priority for reform legislation. Specific concerns center

around the public and private sectors’ liability, the role of risk in decision-making, and the

appropriate responsibility of states in cleanup efforts.

Air quality: Is the government

adopting cost-effective air quality

control measures?

With annual implementation costs exceeding $25 billion for clean air rules already issued and

more rules mandated for fiscal years 1995 to 1997, many current and projected regulations are

likely to be scrutinized to help ensure that the most cost-effective approaches to controlling air

pollution are used, including alternatives to traditional approaches, such as emissions trading,

pollution prevention, and increased regulatory flexibility.

Pesticides and toxic substances:

Is the federal government

appropriately protecting the public

from pesticides and other toxic

substances?

The process for regulating pesticides and other toxic substances has become costly, slow, and

of questionable benefit. While some believe the programs are overly protective, others believe

they do not adequately protect infants, children, and/or workers. Because of the general

dissatisfaction with these programs and the increased attention paid to regulatory costs and

benefits, totally new approaches will likely be considered as pesticide and toxic statutes are

reauthorized.

Water quality: Is the government

cost-effectively protecting surface

water, groundwater, and drinking

water?

Significant progress has been made in cleaning up the nation’s surface water and drinking water

supplies. However, the costs of complying with current and projected requirements (estimated at

over $4 billion annually for cities alone) have led to water programs being labeled as “unfunded

mandates.” As the two major water quality statutes go through reauthorization, attention will be

focused on whether compliance costs bring commensurate benefits.

Management and budget: Do EPA’s

management and budget systems

effectively target its resources and

expend them for their intended

purposes?

Alternatives to traditional regulatory approaches are increasingly being pursued to help meet

environmental objectives more cost-effectively. However, EPA’s organization and management

systems, for the most part, continue to reflect traditional regulatory approaches. In addition,

although EPA needs to target and use its resources effectively, the agency has long been

hindered by problems in its contracting, financial, and management control systems. Similarly,

the United States needs assurances that funds it dedicates to implementing international

environmental agreements are spent in a cost-effective manner. 

Page 4 GAO/IAP-95-23
Table 1: Key Issues

Objectives Focus of work

•Provide Congress with information to aid in

its reauthorizing RCRA and Superfund and

in allocating funds to these programs.

•Recommend ways to improve the design

and management of waste programs so

they are more cost-efficient, reduce waste,

increase recycling and reuse, and promote

safer waste management.

•Appropriateness of regulations’ coverage and definitions of wastes 

•Opportunities for government and industry to reduce waste generation, increase

recycling, and reduce risks associated with waste management

•Opportunities to streamline and improve the cost-effectiveness of RCRA

•Federal budget implications of completing cleanups

•Appropriateness of federal and state responsibilities for cleanups

•Role of risk in determining cleanup goals and priorities

•Financial impacts on parties responsible for cleaning up sites

•Provide Congress with information to aid in

its planned oversight of control measures

adopted under the Clean Air Act

Amendments of 1990.

•Assess states’ progress in implementing

the Clean Air Act Amendments of 1990.

•Adequacy of EPA’s cost-benefit and regulatory impact analyses used to support

selected clean air rules

•Progress made in adopting flexible regulatory approaches provided under the 1990 act

•The pace of EPA’s implementation of the Clean Air Act Amendments of 1990, the

problems associated with the approaches chosen, and the opportunities to achieve

program goals more cost-effectively

•Provide Congress with information to aid in

its reauthorizing legislation on pesticides

and toxic substances.

•Identify alternative approaches to control

pesticides and toxic substances.

•Progress in protecting the public from the adverse effects of pesticides and toxic

chemicals

•Adequacy of EPA’s chemical exposure data collection and analysis efforts

•Opportunities to reduce risks more cost-effectively by setting better testing and

regulatory priorities

•Identify ways to reduce the public and

private sectors’ cost of complying with water

quality requirements.

•Provide Congress with information and

options to assess in reauthorizing the Clean

Water and Safe Drinking Water acts.

•Barriers to the use of existing regulatory flexibility to reduce compliance costs

•Legislative and regulatory options to achieve water quality goals more cost-effectively

•Identify ways EPA could improve the use of

alternatives to traditional regulatory

approaches.

•Assess how EPA uses tools, such as risk

analysis and cost-benefit analysis, to

provide adequate protection to human

health and the environment at an affordable

cost.

•Assess the adequacy of EPA’s budget

requests, procedures, and practices.

•Determine if EPA’s controls are adequate

to guard against fraud, waste, and abuse.

•Examine how U.S. funds are spent to

support U.S. international environmental

obligations. 

•EPA, state, and industry experiments with integrated environmental management as a

way to reduce compliance costs

•EPA’s process for estimating costs and benefits of environmental regulations

•EPA’s budget and financial management practices 

•EPA’ s progress in implementing the Chief Financial Officers Act, the Government

Performance and Results Act, and the Federal Managers’ Financial Integrity Act

•Funds that are being spent to support U.S. obligations under international

environmental treaties

Page 5 GAO/IAP-95-23
Table 1: Key Issues

Issues Significance

Federal facilities: Is the cleanup of

federally owned hazardous waste

sites well-managed and

cost-effective?

With costs of up to $1 trillion, the cleanup of hazardous waste sites at federal facilities is

expected to be the largest public works project the government has ever undertaken. Although

federal agencies have already spent tens of billions of dollars, cleanup progress has been slow

and virtually none of the sites have been fully remediated. Budget pressures are now making it

impossible for the program to meet its original expectations and are forcing a reassessment of

how it should be organized and run.

Page 6 GAO/IAP-95-23
Table 1: Key Issues

Objectives Focus of work

•Provide Congress with information to help

in its budget decisions affecting efforts to

clean up federal facilities. This information

includes ways to improve the cleanup

process through better (1) priority setting,

(2) contract management, and (3)

development and use of cost-saving

technologies.

•Advise the Office of Management and

Budget and EPA on ways to better

coordinate cleanup efforts across agency

lines.

•Priority setting based on risk

•Efficiency and cost-effectiveness of the cleanup process

•Federal contracting for hazardous waste cleanup services

•Research and development for new cost-saving technologies

•Roles and responsibilities of agencies for various cleanup functions

Page 7 GAO/IAP-95-23
Table II: Planned Major Work

Issue Planned major job starts

Hazardous and solid waste •Review hazardous waste regulations to determine if they address waste that present the greatest risk

to human health and the environment.

•Assess the opportunities for government and industry to reduce waste, increase recycling, and reduce

risks related to waste management.

•Review federal and state responsibilities in the Superfund program.

•Review the role of risk in allocating cleanup resources.

•Assess the potential financial impact of proposed changes to the Superfund liability system.

Air quality •Conduct mandated studies on costs and benefits of the Clean Air Act Amendments.

•Assess EPA’s progress in developing rules that promote regulatory flexibility, including market-based

approaches.

•Review states’ implementation of Clean Air Act provisions.

Pesticides and toxic

substances

•Assess progress made in protecting infants, children, workers, and other highly exposed individuals

from the adverse effects of harmful chemicals.

•Evaluate federal efforts to obtain and analyze toxic chemical exposure data. 

•Assess cost-effectiveness of alternative approaches to controlling toxic substances.

Water quality •Assess the flexibility EPA has provided to the states in implementing the Safe Drinking Water Act.

•Evaluate state implementation of and capacity to run Clean Water Act programs.

•Evaluate alternative methods to reduce the costs of protecting water quality.

Management and budget •Review EPA, state, and industry experiences with integrated environmental management.

•Assess EPA’s process for estimating costs and benefits of environmental regulations.

•Review EPA’s budget to identify potential savings.

•Evaluate EPA’s progress in implementing the Chief Financial Officers Act, the Government

Performance Act, and the Federal Managers’ Financial Integrity Act.

•Review progress made in implementing environmental requirements of the North American Free Trade

Agreement (NAFTA).

Federal facilities •Assess cost-effectiveness of priority setting, program procedures, and cleanup strategies.

•Evaluate federal agencies’ contracting to clean up hazardous waste.

•Review effectiveness and coordination of agency research and development programs for cleanup

technology.

•Assess and compare federal and private sector management of site cleanup programs.

Page 8 GAO/IAP-95-23
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