U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Special Report 

 National Environmental Policy 

 and Quadrennial Review Needed 

 Report No. 10-P-0140 

 June 8, 2010
 
Report Contributors: Patrick Gilbride 

Erin Barnes-Weaver 

Alicia Mariscal 

Abbreviations 

CEQ Council on Environmental Quality 

EPA U.S. Environmental Protection Agency 

FY Fiscal Year 

NAPA National Academy of Public Administration 

NEPA National Environmental Policy Act 

OIG Office of Inspector General 

OPEI Office of Policy, Economics, and Innovation 

Cover Photos: Diverse settings that may be affected by a national environmental policy. 

(EPA photos) 
 

U.S. Environmental Protection Agency 10-P-0140 

June 8, 2010 Office of Inspector General 

At a Glance 

Catalyst for Improving the Environment 

Why We Did This Review 

This report updates our Fiscal 

Year 2009 management 

challenge on how the U.S. 

Environmental Protection 

Agency (EPA) uses threat and 

risk information in 

decisionmaking. We 

researched the need for a 

national environmental policy 

to leverage resources for 

environmental protection 

across government and 

stakeholder groups. 

Background 

Congress passed the National 

Environmental Policy Act and 

created EPA in 1970 to carry 

out national policy. EPA’s 

success in protecting the 

environment depends on the 

efforts of other federal 

agencies and States. In some 

cases, EPA partners with other 

entities to accomplish 

environmental goals and, in 

other cases, stakeholders have 

more authority than EPA over 

activities that impact 

environmental quality. 

For further information, 

contact our Office of 

Congressional, Public Affairs 

and Management at 

(202) 566-2391. 

To view the full report, 

click on the following link: 

www.epa.gov/oig/reports/2010/ 

20100608-10-P-0140.pdf. 

National Environmental Policy and 

Quadrennial Review Needed

 What We Found 

The environmental protection structure created by the National Environmental 

Policy Act 40 years ago has not resulted in a comprehensive approach. In 

addition, new, complex environmental problems such as global climate change, 

regional water scarcity, and long-range transport of pollutants in air or water 

require more concerted, coordinated efforts. 

EPA shares responsibility for environmental protection with States and 25 federal 

agencies, resulting in a fragmented approach to environmental protection. For 

example, EPA and the U.S. Department of Energy both issued ENERGY STAR 

criteria documents for the same products, which could cause confusion in the 

marketplace. 

EPA lacks authority over many activities that impact the nation’s environment. 

For example, housing financed, controlled, underwritten, or owned by four other 

federal government entities represents a significant number of homes that could be 

built radon resistant. The U.S. Department of Agriculture could use its extensive 

field experience with local farming communities to further contribute to EPA’s 

Chesapeake Bay clean-up efforts. 

Past and current Agency efforts, such as the Proposed Environmental Goals for 

America with Milestones for 2005 (1995), did not set national policy or clearly 

align the environmental protection efforts of all federal and State stakeholders. 

The National Strategy for Homeland Security and the U.S. Department of 

Homeland Security Quadrennial Homeland Security Review are an example of a 

nationwide framework to solve a large, complex problem. Australia and Japan 

offer international examples of how to incorporate a national policy approach into 

environmental protection legislation and activities. 

EPA should work with Congress and the Administration to examine ways to 

leverage resources expended to various, insular environmental protection efforts. 

The Administration should propose to Congress that it create expert panels to 

consider formulating a national environmental policy and subsequent quadrennial 

review. Congress could also consider passing legislation recommended by these 

panels to harmonize various efforts and, where appropriate, to maintain existing 

requirements in environmental statutes. These efforts could help address the 

Administrator’s priority to expand the conversation on environmentalism and 

build strong State and tribal partnerships. 
 

 

 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

June 8, 2010 

MEMORANDUM 

SUBJECT:	 National Environmental Policy and Quadrennial Review Needed

 Report No. 10-P-0140 

FROM:	 Bill A. Roderick 

 Acting Inspector General 

TO:	 Lisa P. Jackson 

Administrator 

This is our report on the subject research conducted by the Office of Inspector General of the 

U.S. Environmental Protection Agency (EPA). While we commend EPA for its many successes, 

this special report contains observations related to your priorities to expand the conversation on 

environmentalism and build strong State and tribal partnerships. Specifically, this report 

suggests that EPA work with Congress and the Administration to create expert panels that 

consider formulating a national environmental policy and quadrennial review. This report 

represents our opinion and not necessarily the final EPA position. EPA managers will make 

final determinations on matters in this report in accordance with established audit resolution 

procedures. 

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

applicable daily full cost billing rates in effect at the time – is $205,000. 

Action Required 

Though comments are not necessary, if you decide to provide us with an action plan in response 

to the observations in this report, please do so within 90 calendar days. We have no objections to 

the further release of this report to the public. This report will be available at 

http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact me at (202) 566-0847 

or roderick.bill@epa.gov; or Patrick Gilbride, Director for Audit, Risk and Program Performance 

Issues, at (303) 312-6969 or gilbride.patrick@epa.gov. 
 

 

 

 

 

 

National Environmental Policy and 10-P-0140 

Quadrennial Review Needed 

Table of Contents 

Chapters 

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

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

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

 Scope and Methodology.............................................................................. 6 

2 National Environmental Policy Needed............................................................ 7 

 New Environmental Challenges .................................................................. 7 

 Fragmented Efforts...................................................................................... 8 

Past EPA Efforts Did Not Include Setting National Policy ........................... 10 

The Need to Coordinate Across Different Levels of Government ............... 12 

Others Have Utilized National Policy Approaches....................................... 18 

Challenges to Implementing a National Policy ............................................ 22 

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

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

Status of Recommendations and Potential Monetary Benefits.............................. 25 

Appendices 

A EPA Organizational Phases .............................................................................. 26 

B References.......................................................................................................... 28 

C Agency Response to Draft Report.................................................................... 31 

D Distribution ......................................................................................................... 35 
 

 

 

10-P-0140 

Chapter 1

Introduction 

Purpose 

The Reports Consolidation Act of 2000 requires that the Office of Inspector 

General (OIG) annually identify Agency management challenges. On April 28, 

2009, we issued a memorandum listing Fiscal Year (FY) 2009 management 

challenges for the U.S. Environmental Protection Agency (EPA).1 One challenge 

urged EPA to apply threat and risk assessment methodologies in Agency priority 

setting and decisionmaking. In August 2009, we met with EPA officials to 

discuss updating the threat and risk assessments challenge for FY 2010. Based on 

that discussion, we reviewed and revised the FY 2009 challenge and conducted 

additional research on the need for a national environmental policy and a 

quadrennial review. 

Background 

National Environmental Policy Act 

Four decades ago, Congress passed the National Environmental Policy Act 

(NEPA):2 

To declare a national policy which will encourage productive and 

enjoyable harmony between man and his environment; to promote efforts 

which will prevent or eliminate damage to the environment and biosphere 

and stimulate the health and welfare of man; to enrich the understanding 

of the ecological systems and natural resources important to the Nation; 

and to establish a Council on Environmental Quality. 

The Act declared the “continuing policy of the Federal Government, in 

cooperation with State and local governments, and other concerned public and 

private organizations, to use all practicable means and measures . . . to create and 

maintain conditions under which man and nature can exist in productive 

harmony.” The Act further required federal agencies to develop environmental 

impact statements for major federal actions significantly affecting the quality of 

the human environment. The Act “makes available to States, counties, 

municipalities, institutions, and individuals, advice and information useful in 

restoring, maintaining, and enhancing the quality of the environment.” The Act 

created in the Executive Office of the President a Council on Environmental 

1

 The memorandum is at http://www.epa.gov/oig/reports/2009/FiscalYear2009MgmtChallenges.pdf. 2

 The President signed NEPA into law on January 1, 1970. 

1 
 

 

 

 

 

 

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Quality (CEQ), charged with formulating and recommending national policies to 

promote improved environmental quality. 

EPA from 1970 to 1990 

The President’s Advisory Council on Executive Organization, chaired by Roy L. 

Ash (the Ash Council),3

 addressed how to implement NEPA’s vision. Before 

EPA was created in 1970, more than a dozen federal agencies had environmental 

responsibilities, resulting in the lack of an organized, concerted focus to address 

pollution and degradation caused by prior years of neglect. The Ash Council 

recognized that setting and enforcing environmental standards must be performed 

outside the affected agencies. Although reluctant to establish another government 

agency, President Nixon accepted the Ash Council proposal and outlined the 

structure of a new administrative agency that would carry out national 

environmental policy. 

Reorganization Plan No. 3 of 1970 created EPA and transferred to it programs 

housed in 15 units of several existing federal departments and independent 

agencies. EPA assumed programs related to air quality, water quality, solid 

waste, pesticides, and radiation formerly based at the U.S. Department of Health, 

Education, and Welfare; U.S. Department of the Interior; Atomic Energy 

Commission; U.S. Department of Agriculture; and Federal Radiation Council.4 

The creation of EPA consolidated separate federal efforts and served as the first 

step in addressing national environmental policy. 

William Ruckelshaus, EPA’s first Administrator, designed the organizational 

structure of the Agency in three phases with the ultimate goal of organizing along 

functional lines.5 Phase 1 created five program offices along the environmental 

media lines of water, air, pesticides, radiation, and solid waste. By April 1971, 

phase 2 consolidated these offices into two new entities led by assistant 

administrators. The Office of Media Programs incorporated the water and air 

programs. The Office of Categorical Programs subsumed the pesticides, 

radiation, and solid waste management offices. At the time, 10 regional offices 

mirrored the organization of EPA Headquarters. The Agency never implemented 

the third phase, which would have eliminated the media-oriented program offices 

3

 Appointed on April 5, 1969, the Ash Council undertook “a thorough review of the organization of the Executive 

Branch of Government” and included federal organization for environmental protection as one of its target areas. 4

 The initial functions transferred to EPA 40 years ago no longer exist at other departments, but, as we describe 

elsewhere in this report, other federal agencies currently do coordinate with EPA on certain activities. 5

 Among the several different possible organizational approaches, Ruckelshaus considered the ideas of Alain 

Enthoven, a Defense Department organization analyst. Enthoven suggested a mission-based approach that would 

have been a radical departure from traditional, media-oriented pollution control. Enthoven believed that by 

structuring EPA around functional objectives such as criteria setting, research and development, and enforcement, 

the Agency could best achieve its mission with centralized efficiency. Douglas Costle, who worked with the Ash 

Council and was EPA Administrator from 1977 to 1981, recognized the merits of Enthoven’s approach but also 

understood that existing statutes imposed complex restrictions to integration and centralization. Ruckelshaus drew 

heavily on Costle’s advice and settled on a tripartite reorganization strategy designed to make EPA more efficient by 

consolidating and streamlining functions. 

2 
 

 

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and restructured EPA along completely functional, mission-based lines, such as 

criteria setting and enforcement. (See Appendix A for flowcharts of EPA’s 

different organizational phases.) Ruckelshaus did not implement the third phase 

because the changes required to implement a purely mission-based approach 

would have impeded the quick and effective performance of the Agency’s broad 

public mandate. 

The Ash Council rejected the idea of organizing EPA along media lines due to 

concerns that program offices would consider environmental problems as 

individual, self-contained issues rather than in the integrated manner in which 

they occur (for example, thinking of land pollution as separate or isolated from 

water pollution, instead of considering pollution as having an affect on both land 

and water). Instead, the Ash Council believed that EPA should be designed 

around its major functions – monitoring, research, standards-setting, enforcement, 

and assistance. 

Dennis C. Williams, author of The Guardian: EPA’s Formative Years, 1970-

1973, explains that due to the “heat of the pollution enforcement battle, neither 

Ruckelshaus nor his successors had the time, resources, or even the inclination to 

restructure the agency along completely functional lines.” As the years passed 

and new environmental legislation or changing national priorities modified the 

Agency’s focus, EPA’s organizational structure continued to evolve, but never 

beyond the confines of phase 2. Williams pointed out that, in hindsight, never 

implementing the third phase “doomed the Agency to periodically rehashing the 

unsolvable” mission-based versus media-specific “organizational question in its 

efforts to accomplish its broad mission effectively and efficiently.” 

A 2002 National Academy of Public Administration (NAPA) case study on the 

Ash Council noted that establishing EPA proved difficult because its 

Administrator had no clear authority, or an ‘organic’ act, with which to integrate 

various statutorily separate programs. When environmental issues first engaged 

the public interest, the national approach was geared toward remediating specific, 

identified problems. When the public perceived an environmental or public 

health threat as posing a serious risk, widespread concern led to the passage of 

legislation designed to reduce the threat. In EPA’s first decade, Congress passed 

the following legislation: 

•	 Clean Air Act – 1970 

•	 Federal Water Pollution Control Act (Clean Water Act) – 1972 

•	 Endangered Species Act – 1973 

•	 Safe Drinking Water Act – 1974 

•	 Resource Conservation and Recovery Act – 1976 

•	 Toxic Substances Control Act – 1976 

•	 Comprehensive Environmental Response, Compensation, and Liability 

Act – 1980 

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In his book The New Environmental Regulation, Daniel J. Fiorino noted, “In the 

space of just over ten years, Congress had enacted a comprehensive, if 

fragmented, statutory framework for pollution control.” He also noted: 

The accomplishments of 1970-1981 make it one of the more productive 

decades for any single area of domestic policy in recent U.S. history. 

Within this period the United States built the legal and institutional 

infrastructure for environmental regulation. It enacted a formidable array 

of laws, established a national regulatory agency, created a 

comprehensive system of regulation, and put major sectors of U.S. 

industry to the task of reducing and cleaning up pollution. 

However, Fiorino also noted that while “environmental legislation flowed from 

Congress in a steady stream,” each statute dealt with a small piece of the overall 

picture. The United States lacked an approach that addressed environmental 

problems comprehensively. 

Ruckelshaus returned as EPA Administrator in 1983 and sparked a decade of 

innovative efforts. Ruckelshaus and his successors sought to not just innovate 

within the terms of “old” regulation, but to plant the seeds of innovative 

approaches in four areas: 

1.	 Defining the environmental problem as more than just pollution control. 

2.	 Expanding the use of consensus-based processes, such as regulatory 

negotiation. 

3.	 Developing new policy tools to complement regulation. 

4.	 Working to integrate across environmental media and policy sectors, such 

as agriculture and energy. 

EPA from 1990 to Present 

By the 1990s, the pollution prevention movement was in full bloom and EPA 

began examining ways to integrate analyses and strategies by contaminant (such as 

lead), geographic area or affected resource (such as groundwater), and industry 

(such as auto manufacturing). Protecting the environment was no longer seen as a 

narrow matter of instituting technical controls on pollution or reconciling tradeoffs 

among economic and environmental goals; it was viewed as a fundamental aspect 

of social, human, and economic development. 

Despite this awareness, environmental regulation changed only at the margins from 

1993 to 2001. Notable proposals for second-generation environmental legislation 

that would have authorized the Agency to try innovative approaches were not 

enacted. As a result, separate laws for each environmental medium continue to 

define EPA’s responsibilities, and EPA’s internal design, with separate offices for 

each medium, reflects this fragmentation. EPA has created some cross-media 

functional offices, including the Office of Enforcement and Compliance Assurance 

4 
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and Office of Research and Development (see Appendix A for EPA’s current 

structure). Regional offices are not organized alike and do not necessarily mirror 

Headquarters mostly media-structured organization. 

Since its creation, EPA has established and enforced environmental standards 

through its part functional, part media-specific organizational structure. In 1997, 

NAPA reported in Resolving the Paradox of Environmental Protection: An 

Agenda for Congress, EPA & the States that EPA has suffered since its inception 

from its structure and conflicting goals: 

EPA’s authorizing statutes have encouraged the Agency and its partners 

to manage complex problems as if they were neatly partitioned into 

discrete air, water, and waste-management problems. There is no 

statutory definition of a general mission for the Agency and no established 

criteria to set priorities that cut across statutory lines. EPA also lacks 

formal mechanisms to enable it to choose among different statutory 

requirements. Moreover, the program offices that implement them 

function with considerable autonomy and sometimes dramatic indifference 

to each other. 

NAPA’s 1997 report also noted that “EPA has tried numerous strategies in the 

last few years to overcome some of the challenges of fragmentation created by its 

patchwork of authorizing statutes.” NAPA recommended that EPA create a 

“reorganization plan that would break down the walls between the Agency’s 

major ‘media’ program offices for air, water, waste, and toxic substances.” 

Fiorino noted in 2006 that the division of environmental laws, programs, and 

agencies along media-specific lines tends to fragment regulatory strategies, 

leading to missed opportunities. In a recent interview, Ruckelshaus commented 

on how, in hindsight, he would have structured the Agency differently: “I would 

have paid more attention to the integrating issues and not organized along strictly 

media lines. I would have preferred to not be forced to manage the environment 

under the pillars of air, water, etc.” 

Ruckelshaus’s original mission – to clean up America – seemed clear. However, 

according to Ruckelshaus, “ . . . most Americans did not foresee that actions 

designed to clean the natural environment and protect public health would alter 

the economy, foreign policy, race relations, personal freedom, and many other 

areas of public life.” He continued, “Each of us must begin to realize our own 

relationship to the environment. Each of us must begin to measure the impact of 

our own decisions and actions on the quality of air, water, and soil of this nation.” 

Many of these same challenges still face us almost 40 years later. 

5 
 

 

 

10-P-0140 

Scope and Methodology 

We performed our research from August 31, 2009, through February 24, 2010, in 

accordance with generally accepted government auditing standards. Those 

standards require that we plan and perform the review to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our review objectives.6 We believe that the evidence 

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

our review objectives. 

To learn about the development of EPA’s organizational structure, we interviewed 

former EPA Administrator William Ruckelshaus and reviewed EPA history, 

articles, and oral histories from previous EPA Administrators. To obtain an 

understanding of EPA’s strategic thinking in the areas of ecology, sustainability, 

and future planning, and to discuss the need for and feasibility of a national policy 

and quadrennial review, we interviewed former EPA Deputy Administrator Marcus 

Peacock and EPA staff and managers from the Office of Research and 

Development and Office of the Chief Financial Officer (responsible for strategic 

planning). We interviewed the project lead for the U.S. Department of Homeland 

Security’s Quadrennial Homeland Security Review to obtain information about the 

department’s review process and the National Strategy for Homeland Security. We 

also interviewed a New York Law School project leader who helped organize an 

effort that enlisted over 40 environmental law experts to address the legal and 

institutional question of how government should organize itself to protect the 

environment. 

To determine whether EPA had developed a national policy, we reviewed and 

analyzed past EPA efforts to identify and address national goals, including EPA 

strategic planning and environmental indicator documents. We reviewed external 

reports from environmental law scholars, NAPA, and the National Research 

Council that discussed EPA’s organizational structure, goals, and the need for a 

national policy. We also reviewed relevant prior reports issued by our office 

(including a past effort by our office to identify environmental goals shared by 

federal agencies) and the U.S. Government Accountability Office. A reference 

list is provided in Appendix B. 

We sought to determine what challenges exist in implementing a national strategy 

and subsequent review. We also considered which agencies, groups, and 

stakeholders would play key roles in a national strategy and subsequent reviews. 

6

 We used our review objectives as questions to guide our research. Those questions were (1) is there a need for a 

national environmental strategy (similar to the national homeland security strategy prepared by the U.S. Department 

of Homeland Security) and subsequent periodic review of such a strategy (similar to the Quadrennial Homeland 

Security Review); (2) what management challenges exist in implementing a national strategy and subsequent 

review; and (3) what agencies/groups/stakeholders would play key roles in a national strategy and subsequent 

review. 

6 
 

 

 

 

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Chapter 2

National Environmental Policy Needed 

The environmental protection structure created by NEPA 40 years ago has not 

resulted in a comprehensive approach. Rigid environmental laws make it difficult 

for the Agency to adequately address new, complex environmental challenges. 

The approach to environmental protection is fragmented: environmental laws 

often focus on a single media or threat, and EPA goals and offices implement 

separate legislative mandates. EPA also lacks complete authority or control over 

many activities that impact our nation’s environment. Past EPA efforts have not 

set national policy that integrates activities of other stakeholders. EPA’s Strategic 

Plan identifies 25 federal agencies that contribute to EPA’s goals and notes that 

States conduct much of the day-to-day work in air and water programs. Other 

federal agencies and countries offer examples of how to integrate efforts across all 

levels of government to solve large, complex problems. EPA should work with 

stakeholders to develop and implement a nationwide policy and quadrennial 

review for environmental protection to better leverage resources and achieve 

comprehensive environmental protection. 

New Environmental Challenges 

Since 1990, EPA shifted from controlling pollution to preventing it.7 However, 

the Agency has never had complete regulatory authority or control over many 

activities that impact the condition of our nation’s environment, such as land use 

and transportation planning. In 1990, the year of EPA’s 20th anniversary, EPA 

Administrator William Reilly noted that contemporary environmental problems 

“are the result of diffuse, difficult-to-control sources of pollution. They are not 

obvious or visible or corrected by simple enforcement actions against a spewing 

smokestack or a recalcitrant industry.” 

Indeed, the nature of environmental problems is changing. In 1997, the National 

Research Council recognized that problems such as global climate change, 

stratospheric ozone depletion, the loss of biological diversity, long-range transport 

of pollutants in air or water, global pressures on ocean resources, and regional 

water scarcity are broader, more complex environmental problems than those that 

received major attention several decades ago. For example, EPA has recently 

made attempts to solve complex environmental challenges in large coastal 

7 According to Alan Hecht, EPA’s Director for Sustainable Development, “The Pollution Prevention Act of 1990 

established the policy that pollution should be prevented or reduced at the source, that pollution which cannot be 

prevented should be recycled, and that disposal or other releases of pollutants into the environment should be only a 

last resort. EPA has also encouraged additional pollution prevention practices, such as protecting resource bases 

through conservation, reducing waste generation, and increasing efficiency in using energy, water, and other natural 

resources.” Hecht, “Sustainability at the U.S. Environmental Protection Agency: 1970–2020.” 

7 
 

 

 

 

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freshwater and marine ecosystems, including addressing hypoxia in the Gulf of 

Mexico, nutrient pollution in the Chesapeake Bay, and contaminated sediments in 

the Great Lakes.8

 Nevertheless, environmental law scholars have noted that rigid 

environmental laws do not allow EPA to confront emerging, cross-media, and 

cross-boundary challenges. 

Great Lakes National Program Office’s R/V Mudpuppy sampling in the 

Buffalo River near the Smith Street habitat restoration site, Buffalo, 

New York, August 2005. (EPA photo) 

While addressing these complex 

environmental issues, EPA 

continually works to improve 

internal coordination among its 

program offices and external 

coordination with federal and 

State agencies with which it 

shares environmental protection 

responsibilities. However, as 

noted in the Environmental Law 

Reporter, “Interagency 

coordination concerning the 

environment is uneven at best.” 

The National Resource Council 

noted that: 

With its limited budget and staff, and broad mandate, it is not possible or 

reasonable for EPA to act alone in understanding and addressing all 

environmental problems. . . . EPA cannot (and should not) by itself 

develop and apply all the knowledge needed to discharge its mandate, 

because its resources are not sufficient and because others are also 

engaged in information gathering and analysis. . . . Many other federal 

agencies, state agencies, academic institutions, and private companies 

have played and will continue to play important roles. 

A coordinated national policy would help address complex and emerging 

environmental problems by unifying efforts around common solutions. 

Fragmented Efforts 

The current, fragmented approach to environmental protection stems from 

environmental laws that often focus on a single medium or threat, and EPA goals 

and offices that implement separate legislative mandates. EPA’s media-specific 

program offices, as well as the statutes they implement, inhibit the process of 

comparing risks, setting priorities, and considering ways to integrate the program 

8 We evaluated EPA’s attempts to resolve the environmental challenges in these water bodies in several reports, 

including: EPA Needs to Accelerate Adoption of Numeric Nutrient Water Quality Standards, Report No. 09-P-0223, 

August 26, 2009; EPA Needs a Cohesive Plan to Clean Up the Great Lakes Areas of Concern, Report No. 09-P0231, September 14, 2009; and several reports on the Chesapeake Bay that can be found at 

http://www.epa.gov/oig/reports/chesapeake.htm. 

8 
 

 

 

 

 

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activities. Prior OIG reports describe situations – for example, risk management 

and climate change – in which EPA offices could better coordinate their efforts. 

During congressional hearings on elevating EPA to cabinet status in 2001 and 

2002, witnesses testified that “EPA’s ‘stovepipe’ organizational structure hinders 

the dissemination of scientific data, innovative programs, and cross-media 

analysis.”9 

Fragmentation also results from the diffuse roles of other stakeholders. For 

example, a 2005 NAPA report noted that the piecemeal evolution of 

environmental programs affects the Agency’s collection of facility data held by it 

and the States. NAPA noted, “For many years, EPA has recognized the need for 

an integrated data system that could pull together and link all of the fragmented 

pieces of environmental information about regulated facilities contained in all of 

its media programs’ databases.” NAPA further said, “The fragmented nature of 

environmental statutes, rules, and programs has made it difficult, if not 

impossible, for EPA to integrate environmental data across media programs.” 

Efforts by EPA and State environmental agencies to adopt data standards and 

share information have begun to successfully demonstrate the potential for more 

effective data integration. But these efforts do not address the root of the problem 

– the fragmented interactions among media programs and regulated facilities that, 

in turn, deprive the public, State and EPA regulators, and businesses of access to 

multimedia information about environmental impacts. An earlier NAPA report 

written in 1995 noted: 

The fragmentation of the federal effort, tensions between the states and 

federal agencies, and the tension between “top-down” environmental 

policy and “bottom-up” land use regulation ensure that environmental 

governance in the U.S. is characterized by conflict, confusion, and 

frustration. Once Congress made the decision that it would create a 

national system for environmental governance, it was probably inevitable 

that the result would be a complex and fragmented system. Congress 

works through an elaborate structure of committees, each protective of its 

jurisdiction. As the public became aware of new environmental issues, 

individual committees and congressional leaders responded by creating 

new statutes and programs, usually with minimal attention to how they 

would fit into existing policies and activities. There is little authority at 

any level of government for overall coordination. 

The Resources for the Future’s Center for Risk Management has examined efforts 

to reduce fragmentation in the U.S. pollution control system, including the idea of 

replacing the current welter of environmental laws with a single, integrated 

environmental statute. A national policy to coalesce efforts among all 

9

 Briefing Memorandum for June 6, 2003 Hearing, “Elevation of the Environmental Protection Agency to 

Departmental Level Status: H.R. 37 and H.R. 2138,” prepared by staff for then Congressman Ose (R-CA) for the 

U.S. House of Representatives Committee on Government Reform (May 30, 2003). 

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stakeholders would correct fragmentation by organizing various approaches 

toward common goals. 

Past EPA Efforts Did Not Include Setting National Policy 

It has been 40 years since the passage of NEPA, which established a broad 

environmental policy for the United States, and the formation of EPA. However, 

NEPA does not outline a national strategy, set national priorities, or unify all 

environmental protection stakeholders. Though NEPA led to EPA’s creation, past 

Agency efforts have not set national environmental policy. In 1992, EPA 

launched the National Environmental Goals Project, which culminated in EPA’s 

main effort to identify and address national goals, the Proposed Environmental 

Goals for America with Milestones for 2005 (1995). This report proposed 15 

long-range environmental goals for the nation and quantitative milestones for 

each goal. 

This effort fell short of being a national policy. The National Research Council 

said this effort did not prioritize individual goals or acknowledge tradeoffs 

between desired outcomes and/or goal choices. EPA officials we interviewed said 

the 1995 report was a creative effort that lacked follow through. Others said that 

those who read it during interagency review either did not comment or were 

overly critical, and that other agencies did not buy off on the concept or want to 

relinquish authority to EPA. 

In a November 2009 letter to our office, EPA’s Office of Policy, Economics, and 

Innovation’s (OPEI’s) Associate Administrator agreed that “coordination of 

environmental policy across agencies and with states can and should be 

improved.”10 However, OPEI’s Associate Administrator does not believe that 

creating a national environmental policy is warranted or a wise use of resources. 

OPEI believes a national policy may detract from, rather than enhance, efforts to 

address important environmental issues. OPEI pointed to initiatives underway 

that it believes have increased coordination and addressed deficiencies (Table 

2-1). However, none of them constitute national policies on environmental 

protection. 

10 Letter from OPEI Associate Administrator to OIG’s Acting Inspector General on OIG Proposed Management 

Challenge for a National Environmental Strategy, November 5, 2009. 

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Table 2-1: EPA Coordination Initiatives Highlighted by OPEI 

EPA’s Strategic Plan includes cross-media initiatives on human health, ecosystems, communities, 

compliance, and environmental stewardship. 

OIG While goal-specific chapters describe cross-media and interagency activities, the 

Comment Strategic Plan does not integrate these efforts or describe national goals that go beyond 

EPA’s current mission and goal structure. An appendix in EPA’s 2006-2011 Strategic 

Plan identifies 25 agencies that contribute to EPA’s goals. One EPA official noted that 

although the EPA Strategic Plan is stovepiped, it could offer a significant contribution to 

formulating a national strategy. 

Department of Transportation, Housing and Urban Development, and EPA entered into an interagency 

partnership creating a framework for coordinating policy and activities related to fostering sustainable 

communities. 

OIG This effort addresses transportation and housing – two important elements related to 

Comment	 sustainability – but does not include other key players related to agriculture/land use, 

energy policy, States, and business/industry. EPA’s Director for Sustainable 

Development in the Office of Research and Development characterized EPA’s effort as 

a “coordinated framework” as opposed to a strategy with timeframes and goals. In 

published work on sustainability, this EPA official also said, “EPA’s first step must be a 

clear strategic plan that coherently connects the dots among existing policies and 

programs that affect sustainability.” 

EPA has taken steps to prioritize risks across and within media. 

OIG EPA officials noted that there are opportunity costs associated with coordinated 

Comment activities, and that high-level priorities to justify the transfer of resources from one 

program office to another should be identified. 

EPA has developed two reports on the environment that provide data on cross-program issues. 

OIG In 2001, EPA sought to assemble, for the first time, an extensive set of environmental 

Comment	 indicators important to its mission. EPA presented these indicators in its Draft Report 

on the Environment Technical Document, released in 2003, and revised, updated, and 

refined the effort in the Agency’s 2008 Report on the Environment. These reports 

provided cross-program data to assess status and trends of environmental conditions at 

the time of each report. These reports did not integrate cross-agency strategies to 

address national environmental goals. EPA officials said these reports emphasized 

EPA’s mission, not national environmental policy. Indicator information within these 

reports did not appear to affect EPA’s priority setting in program offices, nor did it drive 

EPA’s strategic trends. An EPA official said the Agency’s Office of the Chief Financial 

Officer – responsible for publishing the 2008 report – did not think it feasible to use the 

report as it developed EPA’s Strategic Plan. Moreover, though monitoring data for 

many indicators came from other federal agencies, EPA officials are not sure how other 

agencies used the 2008 report, if at all. 

Source: OIG analysis of OPEI’s November 5, 2009, memorandum; OIG interviews with EPA officials. 

Although OPEI disagrees on the need for a national environmental policy, we 

believe that it is the lack of a clear policy that prevents the integration of the 

initiatives OPEI highlights. OPEI also said that the White House’s CEQ has 

efforts underway to coordinate policy on climate change, urban policy, ocean 

policy, and home energy efficiency retrofitting. However, EPA officials have 

noted that the robustness of CEQ’s role ebbs and flows with changes in 

administration. 

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Observers have also argued that it is imperative to revisit the goals of NEPA, 

noting: 

[I]n the decades that followed [NEPA’s enactment and EPA’s creation], a 

lack of coherence in environmental legislation made it increasingly 

difficult to pursue an integrated approach to environmental management. 

Unlike NEPA . . . the media- or subject-specific environmental laws have 

been described as so “fragmented and unrelated as to defy overall 

description.”11 

CEQ also recently acknowledged the need to “modernize and reinvigorate 

NEPA.” CEQ has released draft guidance concerning greenhouse gases, 

environmental mitigation commitments, and reporting NEPA activities, but has 

not issued a comprehensive national environmental policy. 

In his 1995 testimony before the Senate Committee on Government Affairs, the 

Comptroller General of the United States said, “the lack of an integrated approach 

to government leads to redundancy and waste. . . . government can make huge 

efforts to provide services to the public, yet still fall far short of its intentions 

because of faulty coordination of its efforts within and across agency lines.” 

Observations from a 1996 National Research Council report still resonate today: 

“Although substantial progress has been made in improving environmental 

quality, the country still lacks a unified national strategy. We have been making 

environmental laws, not establishing environmental goals.” Thus, though EPA 

has undertaken worthwhile efforts in the past, the Agency falls short of 

comprehensive environmental protection if it does not include efforts of other 

stakeholders. 

The Need to Coordinate Across Different Levels of Government 

EPA’s success in protecting the environment depends on the efforts of other 

federal agencies and States. In some cases, EPA partners with other entities to 

accomplish environmental goals and, in other cases, stakeholders have more 

authority than EPA over activities that impact environmental quality. The lack of 

a nationally coordinated approach to environmental protection means federal and 

State efforts function separately. EPA could more effectively protect the 

environment through a more unified approach. 

Other Federal Agencies 

An appendix to EPA’s 2006-2011 Strategic Plan identifies 25 agencies that 

contribute to EPA’s goals (Table 2-2). Chapters within the Strategic Plan 

11 Environmental Science and Technology draft article, EPA at 40: Bringing Environmental Protection into the 21st 

Century, September 23, 2009 (citing Davies, J. C. and Mazurek, J., Pollution Control in the United States: 

Evaluating the System, Washington, DC: Resources for the Future, 1999). 

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describe EPA’s individual, discrete activities with other federal agencies but do 

not mention a national policy connecting each effort. 

Table 2-2: Areas of Coordination between EPA and Other Federal Agencies 

DEPARTMENT / AGENCY 

Goal 1: 

Clean Air 

and 

Global 

Climate 

Change 

Goal 2: 

Clean and 

Safe 

Water 

Goal 3: 

Land 

Preservation and 

Restoration 

Goal 4: 

Healthy 

Communities and 

Ecosystems 

Goal 5: 

Compliance and 

Environmental 

Stewardship 

Agriculture X X X X X 

Army Corps of Engineers X X X X X 

Commerce X X 

Consumer Product Safety Commission X X X X X 

Defense X X X X X 

Education X X X X X 

Energy X X X X X 

Federal Emergency Management Agency X X X 

General Services Administration X X 

Health and Human Services X X X X X 

Homeland Security X X X X X 

Housing and Urban Development X X X X 

Interior X X X X X 

Justice X X X X X 

Labor X X X 

National Aeronautics & Space Administration X X X X X 

National Science Foundation X X 

Nuclear Regulatory Commission X X 

Small Business Administration X X X X 

State X X X 

Transportation X X X X X 

Treasury X X 

Tennessee Valley Authority X X 

U.S. Agency for International Development X X X 

U.S. Trade Representative X 

Source: 2006-2011 EPA Strategic Plan: Charting Our Course, Appendix D (September 30, 2006). 

In 2005, the OIG developed the Compendium of Environmental Programs to 

identify specific programs and activities at other federal agencies that contribute 

to EPA’s strategic goals. We found the following numbers of environmental 

programs and activities at cabinet-level departments: 

• U.S. Department of Agriculture = 65 

• U.S. Department of the Interior = 62 

• U.S. Department of Transportation = 46 

• U.S. Department of Health and Human Services = 41 

• U.S. Department of Energy = 40 

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Examples of these environment-related programs include: 

•	 Two of the U.S. Department of Energy’s five strategic themes address 

work also done by EPA (“Scientific Discovery and Innovation” and 

“Environmental Responsibility”). Example programs that are 

administered by Energy but are similar to EPA programs include 

alternative fuels, biological and environmental research, nanoscience, and 

renewable energy. Six of the 15 projects listed on Energy’s “joint 

initiatives” Website include EPA (Table 2-3). 

 Table 2-3: U.S. Department of Energy Joint Initiatives with EPA 

Program Description 

Climate VISION: 

Voluntary Innovative 

Sector Initiatives: 

Opportunities Now 

A public-private partnership initiative launched by Energy on February 12, 

2003, to contribute to the goal of reducing greenhouse gas intensity. 

EnergySavers.gov: 

Partnerships for Home 

Energy Efficiency 

An effort to improve energy efficiency in American homes by building 

awareness, delivering savings to those in low-income and subsidized 

housing, and investing in innovative research in building science 

technologies, practices, and policies. 

ENERGY STAR The government's seal of energy efficiency. The ENERGY STAR label can 

be found on everything from home appliances to electronics to windows. 

Consumers have purchased more than 1.5 billion products with the 

ENERGY STAR® label. From 2007 through 2008, Energy and EPA issued 

criteria documents for lighting with different requirements, which created 

confusion in that industry. Energy issued its ENERGY STAR Solid-State 

Lighting document in September 2007, and EPA issued a criteria document 

on residential light fixtures in 2008. Industry sources said the documents 

created two sets of criteria covering the same products, which could cause 

confusion in the marketplace. Energy and EPA issued a joint statement in 

September 2009 outlining their distinct roles and responsibilities in the 

ENERGY STAR program. 

Fueleconomy.gov Website that provides consumers with practical information on achieving the 

best possible fuel economy in their vehicles and saving money at the pump. 

Fueleconomy.gov also contains information on some of the most fuelefficient alternative vehicles on the market. 

National Action Plan 

for Energy Efficiency 

A plan that recommends investment by utility companies in cost-effective, 

energy-efficient technologies to meet consumer demand for clean energy. 

Science.gov An initiative that searches over 40 scientific databases and 200 million 

pages of scientific information with just one query (a gateway to 1,950+ 

scientific Websites). EPA is an alliance partner in this initiative. 

Source: OIG analysis of the U.S. Department of Energy’s “Joint Initiatives” Website. 

•	 The U.S. Department of Transportation has policy goals in five strategic 

areas, one of which is “Environmental Stewardship”: to promote 

transportation solutions that enhance communities and protect the natural 

and built environment. Transportation’s Office for Transportation Policy 

has an Office for Safety, Energy, and the Environment that initiates and 

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Wastewater and rainwater from an area 

where dairy cows are housed flow to the 

drain (center of photo), which is directed 

to a storage tank. (EPA OIG photo) 

coordinates policies on environmental issues affecting all aspects of 

transportation. The office has an Energy and Environment Team 

responsible for developing and reviewing transportation legislation and 

regulations, and coordinating national transportation policy initiatives 

relating to environmental matters. Major policy areas addressed by this 

team include alternative fuels, sustainability, environmental justice, 

climate change, and environmental stewardship. 

•	 The State Department has two environmental offices – the Office of 

Environmental Policy and the Office of Ecology and Natural Resource 

Conservation. One of State’s four strategic objectives is “Social and 

Environmental Issues,” and the department lists environmental protection 

as a performance goal. 

Some agencies have greater authority than EPA over other program areas. For 

example, opportunities exist to substantially increase the number of homes tested 

and mitigated for radon. Housing financed, underwritten, controlled, or owned by 

four federal departments represents a significant number of homes that could be 

tested, mitigated, or built radon resistant. These agencies 

include the U.S. Departments of Housing and Urban 

Development, Defense, Veterans Affairs, and 

Agriculture. 

Additionally, a joint 2006 report by our office and 

USDA-OIG on the Chesapeake Bay noted that while 

local farming associations support clean-up efforts, they 

oppose granting EPA authority to control nonpoint source 

pollution entering the watershed. This creates an 

opportunity for the U.S. Department of Agriculture to 

assist EPA in working with local farming communities 

surrounding the Chesapeake Bay. Our report noted: 

USDA, a Bay partner at the Federal level, could significantly assist EPA 

in implementing the needed conservation practices within the agricultural 

community. Given its many conservation programs, extensive field 

organization, and long experience working with the agricultural 

community, USDA’s commitment and collaboration would significantly 

contribute to the EPA Chesapeake Bay Program Office’s plan for longterm improvement to the Bay’s water quality. . . . Through its technical 

services, research, outreach, and cost-share programs, USDA can 

significantly affect producers’ agricultural practices . . . . The ultimate 

success of the Chesapeake Bay Program depends upon encouraging 

landowners to adopt farming and natural resources conservation 

practices consonant with the Bay’s long-term environmental health. Of 

all the agencies in the Federal Government, USDA may be best positioned 

to persuade farming producers to adopt progressive agricultural practices 

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Vegetated curb extensions used 

to decrease stormwater runoff 

as part of a “green reserve” 

project. (EPA photo) 

and to help communities and private landowners conserve natural 

resources. 

The American Recovery and Reinvestment Act of 2009 illustrates the degree to 

which other agencies have a role in protecting the environment. Almost 

20 percent ($147 billion) of the total Recovery Act funding of 

$787 billion has gone to federal agencies other than EPA that have 

environmental mandates in areas such as energy usage, air quality, 

climate change, water quality, solid and hazardous waste, materials 

management, or land conservation. EPA received $7.2 billion 

(0.9 percent of total Recovery Act funding), or 5 percent of 

Recovery Act funds with potential environmental implications. 

The Recovery Act is also an example of the importance of a 

national policy to connect federal environmental efforts. Recovery 

Act efforts lack cross-agency metrics to measure success in 

accomplishing environmental goals. For example, no standards 

exist among stakeholders on which to base measures of 

environmental risk and outcomes at a national level. 

The FY 2011 President’s Budget shows that EPA is 1 of 14 federal agencies with 

research and development programs, and 1 of 11 agencies that contributes 

research to the Global Change Research Program. EPA also participates in the 

Interagency Task Force to develop and implement the Great Lakes Restoration 

Initiative. In FY 2011, EPA will lead the Initiative’s implementation, allocating 

$300 million for programs to target the most significant environmental problems 

in the Great Lakes ecosystem. In its leadership role, EPA will distribute funding 

directly or transfer funds to other federal agencies for subsequent use and 

distribution. Using this example, a national policy could provide agencies like 

EPA that lead cross-agency efforts additional direction on utilization of resources 

to achieve environmental goals. 

Budget data also identify potential areas of duplication and the need for 

coordinating and streamlining cross-agency efforts to more efficiently achieve 

environmental goals. For example, the FY 2011 President’s Budget identifies 

budget reductions of $129 million for water and wastewater infrastructure 

projects12 at the U.S. Army Corps of Engineers that duplicated programs in other 

agencies or that could be better addressed through other federal programs. The 

12 Our report identifying FY 2010 management challenges for EPA noted, “The federal government does not have a 

national approach to bridging the water and wastewater infrastructure gap. A comprehensive approach . . . would 

realistically assess the investment requirements, alert the public and Congress of unfunded liabilities and risks, and 

work with States and local governments to organize resources to meet needs. While EPA is responsible for 

administering the Clean Water Act and Safe Drinking Water Act, it does not have resources or authority to address 

the funding gap. In its role administering the Clean Water Act and Safe Drinking Water Act, EPA should ensure 

there is a comprehensive federal understanding of the risks to public health, the environment, and the economy if 

this critical resource gap remains unresolved. . . . EPA should take the lead in organizing a coherent federal strategy 

within the limits of its statutory authorities and responsibilities.” 

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Budget identifies funds for the Rural Community Facilities program run by the 

U.S. Department of Health and Human Services, Administration for Children and 

Families, which duplicates other wastewater treatment programs in the U.S. 

Department of Agriculture and EPA. The FY 2011 President’s Budget also 

identifies funding for elimination in a competitive grant program for local 

communities to reduce greenhouse gas emissions because the program lacks 

focus, applies to disparate sectors, and duplicates more substantial greenhouse gas 

emission reduction programs across the Federal Government. The President’s 

Budget noted that emissions reductions will be better realized through existing 

EPA capacity building and recognition programs such as ENERGY STAR, Smart 

Growth, AgSTAR, and eventually, through the Administration’s comprehensive 

greenhouse gas reduction effort. 

As these examples show, environmental quality depends on policies related to 

farming, energy, water, transportation, and federal land management, but neither 

Congress nor the Executive Branch has fully engaged the task of harmonizing 

these issues. 

States 

EPA’s success in accomplishing its goals largely depends on State efforts. The 

Environmental Council of the States13 asserts that State government agencies are 

the key to delivering environmental protection afforded by both federal and State 

law. Although EPA has oversight of State agencies, the absence of a national 

policy to coordinate all levels of government has resulted in the inconsistent 

implementation of environmental programs by States. A comprehensive, national 

approach could improve the capability of State environmental agencies to protect 

and improve human health and the environment. 

EPA’s Strategic Plan notes that delegated State programs conduct much of the 

day-to-day work involved in many air and water programs. As of 2007, States 

operated 96 percent of the delegable federal environmental programs. Delegation 

includes permitting, inspections, monitoring, and enforcement, and often includes 

standards setting. States collect 94 percent of the environmental data found in 

EPA’s databases and conduct about 90 percent of all enforcement actions. 

While States play a critical role in environmental protection, EPA maintains an 

equally important oversight role that would be bolstered by a comprehensive 

national policy. EPA must resolve interstate disputes in the absence of uniform, 

13 The Environmental Council of the States is a national, nonprofit, nonpartisan association of State and territorial 

environmental agency leaders. The council seeks to improve the capability of State environmental agencies and 

their leaders to protect and improve human health and the environment of the United States of America. 

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consistent environmental goals between States.14 Additionally, our work has 

shown that inconsistent oversight of State programs can lead to: 

• Inconsistent enforcement guidance interpretation 

• States and regions not meeting minimum reporting requirements 

• Differing standards for State delegation agreements among the regions 

• Inaccurate data systems 

• Internal control deficiencies 

EPA’s coordination with State and local groups on large water bodies illustrates 

these important issues. A U.S. Government Accountability Office report noted 

that after decades of EPA and its partners’ spearheading restoration efforts in 

areas such as the Great Lakes and the Chesapeake Bay, improvements to these 

waterbodies remain elusive. The longstanding issues impeding such efforts 

include a lack of (1) targeted strategies; (2) coordination among federal, State, and 

local stakeholders; and (3) realistic goals to ensure that limited restoration 

resources are being used for the most effective restoration activities. 

Cooperative efforts between EPA, States, and other organizations under a national 

environmental policy could lead to more effective solutions and policies to 

address environmental problems. As the National Research Council found in its 

1997 publication Building a Foundation for Sound Environmental Decisions, “a 

collective effort can yield results far greater than the sum of individual, isolated 

endeavors.” Additionally, cooperative efforts could help address the 

Administrator’s priorities to expand the conversation on environmentalism15 and 

build strong State and tribal partnerships. 

Others Have Utilized National Policy Approaches 

Other Federal Departments 

EPA is not the only federal entity whose activities depend on other federal and 

State/local efforts. Federal departments that address other, critical public services 

– such as homeland security and national defense – recognized the need to 

14 For example, EPA has begun developing a watershed model to create a nutrient clean-up plan for the Oklahoma 

and Arkansas portions of the Illinois River because the States failed to reach an agreement. Previous EPA efforts – 

including a “Statement of Joint Principles and Actions” that the Agency developed with the States in 2003 – did not 

yield desired results. The dispute centers on the disparity between discharge limits for point sources in Arkansas 

and Oklahoma. Because Arkansas’ limit is less stringent, Oklahoma, as the downstream State, has a limited ability 

to improve the water quality. EPA acted because the two States have been unable to develop a water quality 

standard. 

15 On January 12, 2010, EPA Administrator Jackson issued a memorandum listing seven priorities for EPA’s future, 

one of which included “expanding the conversation on environmentalism.” Though the priority pertained to 

environmental justice and protecting historically underrepresented communities, its tenets to conduct outreach and 

build strong working relationships with external stakeholders applies in this context as well. 

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formulate national approaches to guide, integrate, organize, and unify efforts 

across all levels of government.16 

After the terrorist attacks on September 11, 2001, the White House and Congress 

created the U.S. Department of Homeland Security to organize activities spread 

across more than 40 federal agencies and an estimated 2,000 separate 

congressional appropriations accounts. Shortly thereafter, the White House 

issued the first National Strategy for Homeland Security. The new department 

noted, “More than 87,000 different governmental jurisdictions at the federal, state, 

and local level have homeland security responsibilities. The comprehensive 

national strategy seeks to develop a complementary system connecting all levels 

of government without duplicating effort. Homeland Security is truly a ‘national 

mission’.” In addition to providing direction to federal departments and agencies 

that have a role in homeland security, the strategy also includes roles and 

responsibilities for State and local governments and private companies and 

organizations. As such, the President noted that it amounted to “a national 

strategy, not a federal strategy” to “guide, organize, and unify our Nation’s 

homeland security efforts.” 

The White House revised the National Strategy for Homeland Security in 2007. 

The revised Strategy noted, “Homeland security requires a truly national effort, 

with shared goals and responsibilities for protecting and defending the Homeland. 

Our Strategy leverages the unique strengths and capabilities of all levels of 

government, the private and non-profit sectors, communities, and individual 

citizens.” 

In 2007, Congress passed legislation mandating a Quadrennial Homeland Security 

Review of the Strategy beginning in FY 2009.17 Through the Quadrennial 

Homeland Security Review, the Secretary for Homeland Security recognized that 

the department’s capacity for mission-focused innovation depends on its ability to 

reach out to partners and draw on their insights and expertise. This 

comprehensive review includes recommendations regarding long-term strategy 

and priorities for homeland security. The review will result in guidance on the 

department’s programs, assets, capabilities, policies, and authorities. 

Similarly, the legislatively mandated 2010 Quadrennial Defense Review of the 

National Defense Strategy assesses the U.S. Department of Defense’s capabilities 

16 Other national strategies we identified include the National Security Strategy, National Strategy for Combating 

Terrorism, and National Health Security Strategy. In addition, a recent U.S. Government Accountability Office 

report recommended developing a national strategy for climate change and specified the actions Congress and the 

Federal Government could take to lessen related challenges.

17 “The Implementing Recommendations of the 9/11 Commission Act of 2007,” which became law on August 3, 

2007, requires that every 4 years, beginning in FY 2009, the Secretary of Homeland Security conducts a 

Quadrennial Homeland Security Review of the United States. The Secretary planned to provide conclusions of the 

first review to Congress in a final report by December 31, 2009, but issued the report in February 2010. 

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and priorities.18 The main difference between the Defense and Homeland 

Security reviews is that the Quadrennial Defense Review occurs internally and 

focuses solely on the activities of the U.S. Department of Defense, while the 

Quadrennial Homeland Security Review provides an enterprise-wide focus on 

responsibilities across government supporting “the homeland security strategy of 

the Nation.” 

In congressional testimony on the Quadrennial Homeland Security Review 

process, one witness described common challenges to national defense and 

homeland security that underscore the need for and importance of priority setting 

and strategic planning. The witness noted that both departments are: 

•	 Charged with missions vital to the health and welfare of the nation. 

•	 Large, complex bureaucracies comprising a number of diverse and (in 

some cases, previously independent) organizations, each with its own 

cultures, traditions, and ways of doing business. 

•	 Responsible for spending billions of taxpayer dollars as efficiently and 

effectively as possible. 

•	 Perennially in the position of having more programs to pay for than their 

budgets can cover. 

•	 Trying to balance near-term demands against long-term investments. 

EPA faces similar challenges in accomplishing its goals. As such, these 

homeland security and national defense approaches could serve as useful 

examples for EPA to develop and implement a national policy and quadrennial 

review for environmental protection. 

Other Countries 

Australia and Japan have a national policy approach to their environmental 

protection legislation and activities. Both countries recognize the value of 

establishing national environmental goals and setting national policy, and their 

approaches most closely resemble what we advocate in this report. 

The Australian government enacted its primary environmental legislation – the 

Environment Protection and Biodiversity Conservation Act 1999 – in July 2000. 

The Act specifies how the Australian government will protect “flora, fauna, 

ecological communities and heritage places” of both national and international 

importance, and describes these elements as “matters of national environmental 

significance.” The Act empowers the Australian government to enlist both the 

states and territories to achieve a “truly national scheme of environment and 

heritage protection and biodiversity conservation.” The Australian government, 

in cooperation with multiple partners, lists in the Act seven items of “national 

18 The U.S. Department of Defense conducted previous Quadrennial Defense Reviews in 1997, 2001, and 2006, and 

issued its most recent review to Congress in February 2010. 

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environmental significance” to protect. The Australian government plans to 

achieve this partnership approach through establishing bilateral agreements with 

states and territories and agreements with landholders, and by involving 

indigenous people in conservation and communities in management planning. 

The Australian government established the Department of the Environment, 

Water, Heritage and the Arts to develop and implement national policy, programs, 

and legislation to protect and conserve Australia’s environment and heritage. In 

keeping with the national emphasis of environmental protection, annual reports 

prepared by Commonwealth departments, parliamentary departments, 

commonwealth authorities, commonwealth companies, and other commonwealth 

agencies must include a report on environmental matters. Per orders of the 

department’s minister, the department must prepare a “state of the environment” 

report on Australia, which the minister presents to Parliament. The minister must 

also establish an independent review, at least every 10 years, of the Act’s 

operation and how well it has met its objectives. 

Similarly, in 1993, the Japanese government established a “Basic Environmental 

Law” to chart the direction of the nation’s environmental policies. Before the 

enactment of the Basic Environment Law, Japanese environmental policies had 

been based on two fundamental laws – the Basic Law for Environmental Pollution 

Control, enacted in 1967, and the Nature Conservation Law, enacted in 1972. 

These laws, which were drafted to address serious industrial pollution and to 

preserve the natural environment, worked quite successfully. However, as 

Japan’s social/economic system and consumer lifestyles promoted mass 

production, mass consumption, and mass disposal, this legal framework (which 

consisted mainly of restrictions) could no longer deal adequately with some of the 

newer and more complex environmental problems that emerged, such as those 

relating to urban and household-generated pollution and the global environment. 

The Japanese government’s approach acknowledged that environmental issues 

cannot be divided into categories, like human health, mankind’s living 

environment, or the natural environment. Rather, the government adopted a 

comprehensive approach that considers causes and effects throughout the entire 

system. Additionally, the Japanese government understood that many current 

environmental problems arise from the routine, daily activities of companies and 

individual citizens; therefore, all members of society must actively and 

voluntarily conserve the environment. 

The first chapter of Japan’s Basic Environmental Law sets out three basic 

principles for environmental conservation and the responsibilities of each sector 

of society – national and local governments, corporations, and citizens – in 

realizing these principles. The second chapter gives a list of basic environmental 

conservation policies, including the formulation of the Basic Environment Plan, 

the promotion of environmental conservation practices, and measures to deal with 

global environmental problems. The Basic Environmental Plan, which is based 

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on the Basic Environment Law, outlines comprehensive and long-term measures 

relating to environmental conservation for the entire government. To ensure 

effective implementation, the plan calls for the government to enhance its systems 

for monitoring progress. For example, the Central Environment Council annually 

monitors the progress of the Basic Environment Plan. The council holds public 

hearings at various locations in Japan so that the views and opinions of citizens 

can be reflected in its reports to the national government. The council also 

presents performance reviews on the plan’s progress and implementation. 

Challenges to Implementing a National Policy 

We recognize that developing and implementing a national policy poses a number 

of challenges, including: 

•	 Determining and agreeing on the contents and goals of a national policy 

(i.e., national environmental goals). 

•	 Agreeing on the approach a national policy should take (e.g., 

precautionary principle, economic incentives). 

•	 Addressing opportunity costs that would result from focusing on some 

national goals and priorities over others. 

•	 Determining whether and how to increase the national perception and 

importance of ecosystem services. 

Other challenges include identifying participants; achieving buy-in;19 and 

coordinating across government, States, and other stakeholders nationwide. 

In addition to other federal agencies, States, and the White House CEQ, our 

interviewees suggested the following stakeholders as a sample of those with 

whom EPA should work on national environmental policy: 

•	 White House 

•	 Key members of Congress and relevant congressional committees 

•	 Environmental Council of the States 

•	 National Academies 

•	 National Science Foundation 

•	 Environmental Law Institute and other environmental law scholars 

•	 Groups such as the Woodrow Wilson Center’s governance section, the 

World Wildlife Fund, the World Resources Institute, and the World 

Environment Center 

19 Although EPA officials and staff said that staff-level Agency employees display great interest and enthusiasm in 

cross-program strategies and innovative approaches, senior EPA managers seem reluctant to embrace these efforts. 

Staff briefings on the Report on the Environment, for example, did not garner much reaction from senior executives. 

Others noted that no progress can be made without the commitment from senior leadership. 

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These challenges are not insurmountable. In fact, all of our interviewees agreed 

on the value in a national policy approach toward environmental protection. For 

example, the project lead for the Quadrennial Homeland Security Review said 

environmental protection could benefit from a national strategy that recognizes 

EPA’s regulatory role and the responsibilities of other players (i.e., enterprisewide approach). 

EPA’s Director for Sustainable Development, who is one of several scholars 

urging EPA to consider new approaches to 21st century problems as it heads into 

its 40th anniversary, agrees that a national approach is worthwhile. He believes 

that EPA needs a strategy to move the Agency from its important history toward 

thinking about environmental problems in a more systematic way. 

Former Deputy Administrator Marcus Peacock also found a national policy an 

intriguing idea worth pursuing. NAPA also believes that EPA should play a 

leadership role in harmonizing national efforts. Former EPA Administrator 

Ruckelshaus described the development of a national policy as an improvement 

on the way we manage the environment by working toward a common set of 

solutions. Ruckelshaus agrees that this is a massive undertaking that is well worth 

the effort. 

Conclusion 

Environmental protection – like homeland security and national defense – is a 

public good and as such requires a nationally coordinated policy approach. 

EPA’s efforts to set regulatory standards, particularly for problems that cross 

State or national borders or pose risks to future generations, would benefit from 

setting national environmental goals. Congress should provide EPA and other 

federal agencies the capacity to identify and manage environmental problems of 

national significance. Congress and the Administration should examine ways to 

leverage resources currently allotted to insular environmental protection efforts. 

The Administration should propose to Congress that it create expert panels that 

consider formulating a national environmental policy and subsequent quadrennial 

review. Congress could also consider passing legislation recommended by these 

panels that harmonizes various efforts and, where appropriate, maintains existing 

requirements in environmental statutes. Through these efforts, EPA and its 

partners could move away from isolated, media- and interest-specific initiatives 

toward a more cohesive, unified, and future-thinking approach to environmental 

protection. While EPA at 40 has much to celebrate, by 50 the Agency should 

have taken the critical – albeit challenging – steps necessary to integrate efforts 

through its role as the Nation’s environmental leader. 

Agency Comments and OIG Evaluation 

EPA’s Deputy Administrator responded to our draft report on April 30, 2010. 

Overall, the Agency disagreed with our draft report suggestion to develop a 

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national environmental policy and quadrennial review. The Agency noted, and 

we agree, that the passage of NEPA 40 years ago established a broad 

environmental policy for the United States. However, we believe the structure 

created by NEPA has not resulted in a comprehensive approach to environmental 

protection. NEPA does not outline a national strategy, set national priorities, or 

unify all environmental protection stakeholders. The Agency has never had 

complete regulatory authority or control over many activities that impact the 

condition of our Nation’s environment, such as land use and transportation 

planning. Therefore, the Agency has never been in the position to meet NEPA’s 

challenge to carry out national environmental policy on its own. We have made 

changes to the report, as appropriate, to include a broader discussion about NEPA. 

The Agency also noted that various media-specific authorities govern the way in 

which EPA and other agencies operate and that, taken together, specify national 

policy. Our report acknowledges media-specific authorities such as the Clean 

Water Act and Clean Air Act, but also notes how these approaches resulted in 

fragmented statutory frameworks. We continue to maintain that rigid 

environmental laws, regardless of general national policy statements and goals 

individual statutes may include, make it difficult for the Agency to adequately 

address new, complex environmental challenges. A comprehensive national 

policy would provide stakeholders with a clear, unified goal structure to address 

existing and new environmental challenges. 

The Agency’s response indicated that our draft report suggested that EPA 

reorganize based on functional areas. We agree with what the Agency describes 

as its organizational needs and complexities and do not recommend that EPA 

reorganize internally at this time. 

We agree with the Deputy Administrator’s comment that this approach would 

take an “enormous effort” and could “require a large investment of time and 

resources.” However, by developing a national environmental policy, the 

Administration and Congress could provide EPA and other federal agencies the 

capacity to identify and manage environmental problems of national significance. 

This approach could give EPA the force of national environmental goals to set 

regulatory standards, particularly for problems that cross State or national borders 

or pose risks to future generations. 

The Agency’s full response is in Appendix C. 

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Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Planned 

Rec. Page Completion Claimed Agreed To 

No. No. Subject Status1 Action Official Date Amount Amount 

No recommendations 

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

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

U = recommendation is undecided with resolution efforts in progress 

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Appendix A 

EPA Organizational Phases 

Phase 1: EPA Organization as of December 15, 1970: 

Source: Williams, The Guardian: EPA's Formative Years, 1970-1973, 1993. 

Phase 2: EPA Organization as of April 30, 1971: 

Source: Williams, The Guardian: EPA's Formative Years, 1970-1973, 1993. 

26 
 

Current EPA Organizational Structure: 

Administrator 

Deputy Administrator 

Office of Administration and Office of Enforcement and Office of Air and Radiation Resource Management Compliance Assurance 

Office of the Chief Office of General Counsel Office of Inspector Financial Officer General 

Office of Environmental Office of Prevention, Office of International Information Pesticides, and Toxic Affairs Substances 

Office of Research and Office of Solid Waste and Office of Water Development Emergency Response 

Region 1 Region 2 Region 3 Region 4 Region 5 

Boston New York Philadelphia Atlanta Chicago 

Region 6 Region 7 Region 8 Region 9 Region 10 

Dallas Kansas City Denver San Francisco Seattle 

Source: EPA Website, http://www.epa.gov/aboutepa/organization.html. 

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Appendix B 

References 

Dernbach, John C. “National Governance: Still Stumbling Toward Sustainability.” 

Environmental Law Reporter – Special Issue: Agenda for a Sustainable America, April 2009. 

DeWitt, John. Center for the Economy and the Environment. The Place of Regions in 

Governance of the Environment and Natural Resources in the United States. Prepared for the 

Joint U.S.-German Conference on Regionalism Below the State-Level in Germany and the 

United States, Speyer, Germany March 31-April 2, 1998. 

http://www.napawash.org/aa_federal_system/98_region_place.html. 

Environmental Council of the States Website. http://www.ecos.org/section/states/enviro_actlist. 

Fiorino, Daniel J. The New Environmental Regulation, 2006. 

———. “Toward a New System of Environmental Regulation: The Case for an Industry Sector 

Approach.” Environmental Law 26: June 22, 1996. 

Flournoy, Michele A. Center for a New American Security. “The Quadrennial Defense Review: 

A Model for the Quadrennial Homeland Security Review.” Testimony before the House 

Committee on Homeland Security, March 20, 2007. 

Hecht, Alan D. “The Next Level of Environmental Protection: Business Strategies and 

Government Policies Converging on Sustainability.” Sustainable Development Law & Policy 

8, Issue 1: Fall 2007. 

———. “Sustainability at the U.S. Environmental Protection Agency: 1970–2020.” Ecological 

Engineering, 2007. 

National Academy of Public Administration. Ash Council Case Study. Developed for the 

Standing Panel on Executive Organization and Management by Dwight Ink, March 12, 2002. 

———. Environment.gov: Transforming Environmental Protection for the 21st Century, 

November 2000. 

———. A Report of the Environmental Information Consortium: For the Office of 

Environmental Information, U.S. Environmental Protection Agency, 2005. 

———. Resolving the Paradox of Environmental Protection: An Agenda for Congress, EPA & 

the States, September 1997. 

———. Setting Priorities, Getting Results: A New Direction for EPA, 1995. 

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National Research Council. Committee on Research Opportunities and Priorities for EPA. 

Building a Foundation for Sound Environmental Decisions, 1997. 

———. Policy Division. Linking Science and Technology to Society’s Environmental Goals, 

1996. 

Resources for the Future. Resources. Issue 124, Summer 1996. 

http://www.rff.org/Documents/Resources/Resources-124.pdf. 

Schoenbrod, Richard B., Richard Stewart, and Katrina M. Wyman. Breaking the Logjam: 

Environmental Reform for the New Congress and Administration. Project Report, February 

2009. http://www.breakingthelogjam.org/. 

U.S. Department of Defense. 2010 QDR Terms of Reference Fact Sheet, April 27, 2009. 

U.S. Department of Homeland Security. History Office. Brief Documentary History of the 

Department of Homeland Security: 2001-2008. 

U.S. Department of Homeland Security Website. “Department Subcomponents and Agencies.” 

http://www.dhs.gov/xabout/structure/. 

U.S. Environmental Protection Agency. “Appendix D: Areas of Coordination Between EPA and 

Other Federal Agencies.” 2006-2011 EPA Strategic Plan: Charting Our Course, September 

30, 2006. 

———. “A Vision for EPA’s Future: An Interview with William K. Reilly.” EPA Journal, 

September/October 1990. 

———. Office of Inspector General. “The Clean Water Act after 37 Years: Recommitting to 

the Protection of the Nation’s Waters.” Statement of Wade T. Najjum, Assistant Inspector 

General for Program Evaluation, Before the Committee on Transportation and Infrastructure, 

U.S. House of Representatives, October 15, 2009. 

———. Office of Inspector General. Compendium of Environmental Programs. 

http://yosemite.epa.gov/oig/compendium.nsf/HomePage?OpenForm. 

———. Office of Inspector General. EPA Does Not Provide Oversight of Radon Testing 

Accuracy and Reliability. Report No. 09-P-0151, May 12, 2009. 

———. Office of Inspector General. EPA Has Initiated Strategic Planning for Priority 

Enforcement Areas, but Key Elements Still Needed. Report No. 08-P-0278, September 25, 

2008. 

———. Office of Inspector General. EPA Needs a Comprehensive Research Plan and Policies 

to Fulfill Its Emerging Climate Change Role. Report No. 09-P-0089, February 2, 2009. 

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———. Office of Inspector General. EPA Region 8 Needs to Better Manage the Risk 

Management Program for Airborne Chemical Releases. Report No. 09-P-0130, March 30, 

2009. 

———. Office of Inspector General. EPA’s Key Management Challenges 2009, April 28, 2009. 

———. Office of Inspector General. FY 2010 Annual Plan with Strategic Plan Update, 

October 2009. 

———. Office of Inspector General. Saving the Chesapeake Bay Watershed Requires Better 

Coordination of Environmental and Agricultural Resources. Report No. 2007-P-00004, 

November 20, 2006. 

———. Office of Policy, Economics, and Innovation. Office of Cross-Media Programs 

Website. “HUD, DOT, and EPA Partnership: Sustainable Communities,” June 16, 2009. 

http://www.epa.gov/dced/pdf/dot-hud-epa-partnership-agreement.pdf. 

———. Office of Research and Development. National Center for Environmental Assessment 

Website. “Report on the Environment home page,” http://cfpub.epa.gov/eroe/ and “Report on 

the Environment basic information,” http://www.epa.gov/ncea/eroebi/. 

U.S. Government Accountability Office. Climate Change Adaptation: Strategic Federal 

Planning Could Help Government Officials Make More Informed Decisions. GAO-10-113, 

October 2009. 

———. Environmental Protection Agency: Major Management Challenges. GAO-09-434, 

March 2009. 

———. “Government Reorganization: Issues and Principles.” Statement of Charles A. 

Bowsher, Comptroller General of the United States, Before the U.S. Senate Committee on 

Government Affairs, May 17, 1995. 

U.S. House of Representatives. Committee on Government Reform. Briefing Memorandum for 

June 6, 2003, Hearing, “Elevation of the Environmental Protection Agency to Departmental 

Level Status: H.R. 37 and H.R. 2138.” Prepared by staff for Congressman Ose, May 30, 

2003. 

Williams, Dennis C. The Guardian: EPA’s Formative Years, 1970-1973, 1993. 

Wisman, Phil. EPA History 1970-1985, November 1985. 

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Appendix C 

Agency Response to Draft Report 

April 30, 2010 

MEMORANDUM 

SUBJECT: Draft Special Report: National Environmental Policy and Quadrennial 

Review Needed 

TO: Bill Roderick

 Acting Inspector General 

Thank you for the opportunity to comment on the Draft Special Report in which you 

recommend the development of a National Environmental Policy and Quadrennial Review. My 

comments and suggestions follow. I also appreciate the several conversations we have had with 

you and your staff. 

A National Environmental Policy Already Exists 

Your report starts with the assumption that there is no overarching environmental policy 

or framework governing environmental issues that cut across the federal government. The report 

concludes that, as a result, the U.S. Environmental Protection Agency lacks authority or 

control over many activities that impact the condition of our nation's environment and that new, 

complex environmental problems require more concerted and coordinated efforts with other 

agencies, states and stakeholders. You suggest that Congress should consider integrating 

legislation to harmonize various environmental protection activities while maintaining existing 

requirements. 

Our view is that a set of national environmental policy does exist in the form of 

authorizing statutory goals and mandates embodied in the National Environmental Policy Act 

and in the various media-specific authorities under which EPA and other agencies operate. For 

example, NEPA provides as its purpose: 

To declare a national policy which will encourage productive and enjoyable harmony 

between man and his environment; to promote efforts which will prevent or eliminate 

damage to the environment and biosphere and stimulate the health and welfare of man; to 

enrich the understanding of the ecological systems and natural resources important to the 

nation; and to establish a Council on Environmental Quality. 

Title 1 of NEPA goes on to specify that it is the continuing responsibility of the federal 

government to use all practicable means to fulfill the current generation's responsibilities to 

protect the environment for succeeding generations; to attain the widest range of beneficial uses 

of the environment without its degradation or risk to human health and safety; and to enhance the 

quality of renewable resources while maximizing the recycling of depletable resources. 

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Major media-specific statutes also include national policies and goals. The stated 

objective of the Clean Water Act is to restore and maintain the chemical, physical and biological 

integrity of the nation's waters. The Clean Water Act also specifies a number of specific goals 

and policies. Similarly, one of the stated purposes of the Clean Air Act is to protect and enhance 

the quality of the nation's air resources to promote the public health and welfare and the 

productive capacity of its population. The Resource Conservation and Recovery Act lists a 

number of specific objectives and declares the national policy of the United States to be that the 

generation of hazardous waste be reduced or eliminated as expeditiously as possible. The Toxic 

Substances Control Act and the Endangered Species Act also articulate national policies as 

expressed by Congress. (See Attachment 1) 

Taken together, these major environmental statutes already specify national policies and 

goals governing all agencies of the federal government. 

Your report acknowledges that Congress has attempted to pass second generation 

environmental legislation, but has repeatedly failed to do so. In fact, the report quotes the 

National Academy of Public Administration as saying: 

Once Congress made the decision that it would create a national system 

for environmental governance, it was probably inevitable that the result 

would be a complex and fragmented system. 

It is unlikely that Congress would proceed along a different path today, considering the 

complexity of issues and the elaborate structure of existing congressional committees. 

Note that EPA has been tremendously successful despite its current organizational 

framework. For example, EPA has succeeded in reducing by more than 54 percent the emissions 

of six dangerous air pollutants that cause, among other things, smog, acid rain and lead 

poisoning. In the vast majority of communities, EPA has met the goals for safe water set in the 

1970s. More recently, EPA has aggressively and in a coordinated fashion proceeded to address 

climate change, possibly the most pressing and complex environmental issue of our time. Any 

discussion of the need for a new national environmental policy should acknowledge the 

successes of the current framework. 

The draft report includes a lengthy list of stakeholders and challenges with which the 

government would have to contend if a new national environmental policy were to be developed. 

The sweeping recommendations of the draft report simply cannot be justified by relying on the 

opinions of the small number of interviewees. I agree with former Administrator William D. 

Ruckelshaus that such an effort would be a massive undertaking, and, in light of EPA’s 

continued success in achieving its mission, the report is not persuasive that such an enormous 

effort would be worthwhile or that theoretical efficiencies would be worth the massive 

undertaking. 

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Reorganizing EPA Will Not Resolve the Problem of Stovepipes 

The draft report also suggests that EPA operates in a stovepipe manner consistent with its 

media-specific statutory mandates. The report concludes that this results in a fragmented 

approach to environmental problems, particularly because today's problems are more complex 

than those dealt with when EPA was first organized. 

I agree that EPA is organized consistent with its congressional statutes, but I believe this 

is entirely appropriate. Reorganizing the agency in some other manner to create more integration 

across media would simply create new stovepipes of a different nature. Under any 

organizational structure, EPA and the federal agencies must use matrix management. For 

example, if organized by function as suggested in the draft report (e.g., separate offices for 

standard-setting, monitoring, permitting, enforcement), there would have to be subunits within 

each of the major programs to deal with specific media (a water subunit within the Enforcement 

Office). Those subunits would then have to coordinate across the agency (all water subunits 

within the various offices would have to coordinate standard setting, monitoring, permitting, 

etc.). It is entirely possible that, if the agency had been structured along functional lines, we 

would now be bemoaning the fragmented nature of water regulations. 

Your report explains that former Administrator Ruckelshaus did not change to a missionbased organization because it would divert too much energy from performing the agency's 

mandate. I believe this to be even truer today than it was shortly after EPA was formed. It is 

also still true, as it was during the tenure of Douglas Costle as EPA Administrator, that existing 

statutes impose complex restrictions to integration and centralization. 

EPA, Other Federal Agencies, and Stakeholders are Already Coordinating on HighPriority, Complex Issues 

EPA, other agencies, and stakeholders are coordinating on high-priority, complex issues. 

The National Environmental Policy Act provides the statutory framework and mechanisms for 

formal coordination on environmental projects undertaken with federal involvement. NEPA also 

provides far-reaching authority to the Council on Environmental Quality to coordinate 

environmental issues across the federal government, with states and stakeholders. Consequently, 

the White House and the Council on Environmental Quality have selected high-priority issues on 

which to focus coordination efforts. A sampling of these issues include: 

1. Climate change and climate adaptation 

2. Sustainable communities 

3. Children's health 

4. Ocean policy 

5. Energy efficiency 

6. Environmental science 

7. Nanotechnology 

Efforts are also ongoing to ensure intra-agency coordination across media, such as the 

frequent green cabinet meetings. EPA uses high-level, cross-agency councils and committees to 

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address coordination on topics such as science, environmental justice, Indian policy, agriculture, 

international activities, performance management and information management. EPA has also 

established operating procedures to guarantee cross-program engagement on rules and policies. 

In addition, EPA establishes issue-specific initiatives as needed to deal with cross-media 

concerns. For example, EPA recently launched a cross-program initiative on the regulation of 

electric utilities. An initiative is also under way to better harmonize EPA's place-based 

activities. 

All of these efforts are necessary to deal with the inevitable fragmentation that occurs in 

any large organization. A new National Environmental Policy and Quadrennial Review will not 

change the need for taking these approaches at various levels within EPA. 

Conclusion 

EPA has had considerable success in achieving its mission, and I am confident that 

success will continue in the future. The agency's mission is already guided by statements of 

national policy and specific national objectives, as outlined in major existing environmental 

statutes. As with any large organization, EPA must coordinate across disparate internal offices. 

But these coordination issues would not disappear if the agency were reorganized along different 

lines. Creating a new National Environmental Policy and Quadrennial Review framework would 

require a large investment of time and resources but is not likely to substantially improve our 

environmental results. My view is that improving our existing cross-program coordination 

mechanisms will continue to yield benefits. 

Bob Perciasepe 

Attachment 

cc: Administrator 

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Appendix D 

Distribution 

Office of the Administrator 

Deputy Administrator 

Assistant Administrators 

Regional Administrators 

Agency Follow-up Official (the CFO) 

Agency Follow-up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

Acting Inspector General 

35