Report to the Subcommittee on Interior, 

Environment, and Related Agencies, 

Committee on Appropriations, House of 

Representatives 

United States Government Accountability Office

GAO 

ENVIRONMENTAL 

PROTECTION 

AGENCY 

Major Management 

Challenges 

March 2009 

GAO-09-434 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

View GAO-09-434 or key components. 

For more information, contact John 

Stephenson at (202) 512-3841 or 

stephensonj@gao.gov. 

Highlights of GAO-09-434, a report to the 

Subcommittee on Interior, Environment, 

and Related Agencies, Committee on 

Appropriations, House of Representatives 

March 2009

ENVIRONMENTAL PROTECTION AGENCY 

Major Management Challenges

EPA faces the following challenges that hinder its ability to implement its 

programs effectively: 

• Improving agencywide management. EPA has launched various 

initiatives to address crosscutting general management issues, including 

environmental enforcement and compliance, human capital management, 

and the development and use of environmental information. However, 

these initiatives have generally fallen considerably short of their intended 

results. 

• Transforming EPA’s processes for assessing and controlling toxic 

chemicals. EPA has failed to develop sufficient chemical assessment 

information to limit public exposure to many chemicals that may pose 

substantial health risks. In January 2009, GAO added a new issue—the 

need to transform EPA’s process for assessing and controlling toxic 

chemicals—to its list of high-risk areas warranting increased attention by 

Congress and the executive branch. 

• Improving implementation of the Clean Air Act. EPA faces many 

important challenges related to implementation of the Clean Air Act, 

including those highlighted by GAO regarding its coordination with other 

federal agencies, analyses of health impacts from air pollution, and delays 

in regulating mercury and other air toxics. EPA also faces challenges 

relating to numerous regulatory proposals that have been overturned or 

remanded by the courts. 

• Reducing pollution in the nation’s waters. EPA partners with federal, 

state, and local agencies and others to reduce pollution in the nation’s 

waters. Among the most daunting water pollution control problems, the 

nation’s water utilities face billions of dollars in upgrades to aging and 

deteriorating infrastructures that left unaddressed can affect the quality of 

our water. EPA will receive $6 billion in additional water infrastructure 

funding from the recently passed stimulus bill. 

• Speeding the pace of cleanup at Superfund and other hazardous

waste sites. Congress passed the Comprehensive Environmental 

Response, Compensation, and Liability Act, better known as Superfund, in 

1980, giving the federal government the authority to ensure the cleanup of 

hazardous waste sites both on private and public lands. Nonetheless, 

several key management problems have not been resolved since that time. 

For example, citing competing priorities and lack of funds, EPA has not 

implemented a 1980 statutory mandate under Superfund to require 

businesses handling hazardous substances to provide financial assurances 

to pay for potential environmental cleanups. 

• Addressing emerging climate change issues. In GAO’s view, the 

federal government’s approach to climate change has been ad hoc and is 

not well coordinated across government agencies. For example, the 

federal government lacks a comprehensive approach for targeting federal 

research dollars toward the development and deployment of low-carbon 

technologies. 

The Environmental Protection 

Agency’s (EPA) overarching 

mission is to protect human health 

and the environment by 

implementing and enforcing 

environmental laws intended to 

improve the quality of the nation’s 

air and water and to protect its 

land. EPA’s policies and programs 

affect virtually all segments of the 

economy, society, and government. 

As such, it operates in a highly 

complex and controversial 

regulatory arena. In recent years, 

GAO has identified several key 

challenges EPA faces and 

corrective actions that would 

enable the agency to more 

effectively accomplish its mission. 

GAO was asked to identify 

challenges at EPA that hinder its 

ability to implement its programs 

effectively, based on prior GAO 

work. These challenges include 

(1) improving agencywide 

management, (2) transforming EPA’s 

processes for assessing and 

controlling toxic chemicals, 

(3) improving implementation of the 

Clean Air Act, (4) reducing pollution 

in the nation’s waters, (5) speeding 

the pace of cleanup at Superfund and 

other hazardous waste sites, and 

(6) addressing emerging climate 

change issues. 

What GAO Recommends

GAO has made a number of 

recommendations intended to 

improve EPA’s programs by 

enhancing the information it uses 

to manage them and strengthening 

internal controls. EPA has 

concurred with most of the 

recommendations but has been 

slow to implement some of them. 
Contents 

Letter 1

Improving Agencywide Management 2

Transforming EPA’s Processes for Assessing and Controlling Toxic 

Chemicals 6

Improve Implementation of the Clean Air Act 10 

Reducing Pollution in the Nation’s Waters 11 

Speeding the Pace of Cleanup at Superfund and Other Hazardous 

Waste Sites 15 

Addressing Emerging Climate Change Issues 17 

Concluding Observations 18 

Appendix I GAO Contact and Staff Acknowledgments 20 

Related GAO Products 21 

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Page i GAO-09-434 EPA Challenges
United States Government Accountability Office

Washington, DC 20548 

 

March 4, 2009

The Honorable Norman D. Dicks 

Chairman 

The Honorable Michael K. Simpson

Ranking Member 

Subcommittee on Interior, Environment, and Related Agencies 

Committee on Appropriations 

House of Representatives 

The Environmental Protection Agency (EPA) operates in a highly complex 

and controversial regulatory arena, and its policies and programs affect 

virtually all segments of the economy, society, and government. EPA’s 

overarching mission is to protect human health and the environment by 

implementing and enforcing environmental laws intended to improve the 

quality of our air and water and to protect our land. As you know, EPA’s 

responsibilities are carried out under a complex set of environmental laws, 

such as the Clean Air Act and the Toxic Substances Control Act (TSCA). 

The agency is composed of major offices aligned with environmental laws 

and 10 regional offices. The agency’s budget has been declining in recent 

years from $7.8 billion in fiscal year 2000 to $7.1 billion requested for fiscal

year 2009––a decline of about 28 percent in real terms.1

 EPA’s 2009 budget

included about $939 million for clean air and climate change, $2.6 billion 

for clean water, and $1.7 billion for land restoration. The just-released 

President’s fiscal year 2010 budget request includes $ 10.5 billion for EPA. 

EPA will also receive an additional $7.2 billion in stimulus funding from 

the American Recovery and Reinvestment Act of 2009, primarily for water 

infrastructure projects and Superfund. 

Charged initially with cleaning up pollution of the environment, EPA’s 

tasks have become increasingly complicated as we understand more about 

the dangers and pervasiveness of toxic substances. The emergence of 

issues such as stratospheric ozone depletion and climate change suggest 

that the agency’s responsibilities will continue to grow. Furthermore, 

enforcement activities primarily occur in EPA’s 10 regions, which possess 

considerable autonomy––causing significant variations in enforcement 

 1

The change between EPA’s fiscal year 2000 budget and fiscal year 2009 requested budget 

represented a decline of about 9 percent in nominal terms. In real terms, EPA’s budget 

declined from $9.8 billion in fiscal year 2000 to the $7.1 billion requested for fiscal year 

2009. 

Page 1 GAO-09-434 EPA Challenges
 

activities from region to region. EPA also implements regulations to 

benefit public health and the environment while balancing, as appropriate, 

the cost to industry and others—a particularly controversial issue—and 

implements laws, such as the Clean Air Act, while complying with 

numerous court orders resulting from the myriad lawsuits brought against 

the agency by states, concerned citizens, special interest groups, and 

others. 

Considering EPA’s evolving roles and responsibilities, we were asked to 

identify the major management challenges and program risks that EPA 

faces as it works to accomplish its mission of protecting human health and 

the environment. These challenges include (1) improving agencywide 

management, (2) transforming EPA’s processes for assessing and 

controlling toxic chemicals, (3) improving implementation of the Clean Air 

Act, (4) reducing pollution in the nation’s waters, (5) speeding the pace of 

cleanup at Superfund and other hazardous waste sites, and (6) addressing 

emerging climate change issues. All of the material in this report is drawn 

from our work over the last few years. (See Related GAO Products at the 

end of this report). In these reports, GAO has made a number of 

recommendations intended to improve EPA’s programs by enhancing the 

information it uses to manage its programs and strengthening internal 

controls. EPA has generally concurred with our recommendations, but has 

been slow to implement some of them.2

Our past work has identified several major management challenges at 

EPA, including ensuring consistent environmental enforcement and 

compliance, addressing human capital issues, and improving the 

development and use of environmental information. 

Improving 

Agencywide 

Management 

• Ensuring consistent environmental enforcement and compliance. EPA 

has authorized states to carry out much of the day-to-day responsibilities 

for timely, appropriate enforcement of environmental laws; however, we 

found that EPA does not effectively oversee how well the states are 

carrying out these responsibilities. Specifically, we found that EPA has not 

 2

We conducted our work in accordance with all sections of GAO’s Quality Assurance 

Framework that were relevant to the objectives of each engagement. The framework 

requires that we plan and perform each engagement to obtain sufficient and appropriate 

evidence to meet our stated objectives and to discuss any limitations in our work. We

believe that the information and data obtained, and the analyses conducted, provided a

reasonable basis for the findings and conclusions in each report. 

Page 2 GAO-09-434 EPA Challenges
 

(1) identified the causes of poorly performing state enforcement programs, 

(2) informed the public about how well the states are implementing their 

enforcement responsibilities, and (3) assessed the performance of EPA’s 

regional offices in carrying out their state oversight responsibilities—

performance that has been inconsistent over the years. EPA has also been

slow to improve long-standing problems in its enforcement data, which, 

among other things, hampers its ability to accurately determine the 

universe and characteristics of entities needing regulation to ensure that 

(1) the public is afforded equal protection under environmental laws and 

(2) regulated parties, taxpayers, and ratepayers are not subjected to widely 

varying costs of environmental compliance among regions. Further, we 

have reported that how EPA calculates and reports penalties, the value of

injunctive relief, and the amount of resulting pollution reduction may 

undermine the transparency and accuracy of its reported outcomes and 

cause EPA to both over- and underreport its enforcement achievements.3

We have recommended that EPA enhance its oversight of regional and 

state enforcement activities to implement environmental programs 

consistent with the requirements of federal statutes and regulations. We 

also recommended that EPA develop an action plan for addressing 

enforcement problems identified in state programs; ensure that states have

sufficient resources to implement and enforce programs, as authorized by 

EPA; and help the states improve their capacity for enforcement.4

 EPA 

should also routinely conduct performance assessments of regional and 

state enforcement programs and communicate the results of the 

assessments to the public and the regulated industry. We also

recommended that the EPA Administrator take a number of actions to 

disclose more information when reporting penalties and estimates of the 

value of injunctive relief and pollution reduction.5

EPA has generally agreed with our recommendations and is in the process 

of implementing them. In particular, the agency has developed an initiative

known as the State Review Framework that it believes will (1) address 

many of the long-term problems related to providing fair, consistent, and 

 3

GAO, Environmental Enforcement: EPA Needs to Improve the Accuracy and

Transparency of Measures Used to Report on Program Effectiveness, GAO-08-1111R 

(Washington, D.C.: Sept. 18, 2008). 

4

GAO, Environmental Protection: EPA-State Enforcement Partnership Has Improved, but 

EPA’s Oversight Needs Further Enhancements, GAO-07-883 (Washington, D.C.: July 31,

2007). 

5

GAO-08-1111R. 

Page 3 GAO-09-434 EPA Challenges
 

transparent enforcement throughout the country and (2) obtain accurate

data that can be used to determine the extent of state compliance with 

enforcement standards and the need for corrective actions. However, such 

efforts are still in the early stages, and their success is uncertain and will 

depend on continued commitment of senior management along with 

sufficient priority and resources. EPA also stated that it would take 

actions to disclose more information when reporting estimates of 

injunctive relief and pollution reductions and consider our 

recommendation to report collected penalties. 

• Addressing human capital issues. EPA has struggled for several years to 

identify its needs for human resources and to deploy its staff throughout 

the country in a manner that would do the most good. We found that 

EPA’s process for budgeting and allocating resources does not fully 

consider the agency’s current workload, and that in preparing requests for 

funding and staffing, EPA makes incremental adjustments, largely based 

on an antiquated workforce planning system that does not reflect a 

bottom-up review of the nature or distribution of the current workload.6

Moreover, EPA’s human capital management systems have not kept pace

with changes that have occurred over the years as a result of changing

legislative requirements and priorities, changes in environmental 

conditions in different regions of the country, and the much more active 

role that states now play in carrying out day-to-day-activities of federal 

environmental programs. 

To remedy its antiquated and unscientific methods for determining 

workload and allocating staff resources, we recommended that EPA 

substantially improve its resource planning by identifying the factors that 

derive the national and regional workload and develop more realistic 

allocation systems for deploying staff with the requisite skills and 

capabilities to areas of the country where they are most needed to address 

the highest-priority needs. 

EPA has not paid sufficient attention to human capital issues over the 

years. During the past several years, EPA has taken a number of actions to

improve its workforce management. For example, the agency has 

developed a strategic approach to ensure that it has, and will continue to 

 6

GAO, EPA’s Execution of Its Fiscal year 2007 New Budget Authority for the 

Enforcement and Compliance Assurance Program in the Regional Offices, GAO-08-1109R 

(Washington, D.C.: Sept. 26, 2008). 

Page 4 GAO-09-434 EPA Challenges
 

have, the requisite competencies to carry out its programs effectively. 

Nonetheless, the number of regional staff at individual offices and their 

skills and competencies continue to be driven primarily by historical 

staffing patterns rather than a fresh assessment of regional needs, given 

the regional workload and the role that states play in the enforcement 

process, which varies greatly from region to region. 

• Improving development and use of environmental information. Critical, 

reliable environmental information is needed to provide better scientific 

understanding of environmental trends and conditions and to better 

inform the public about environmental progress in their locales. We found 

substantial gaps between what is known and the goal of full, reliable, and 

insightful representation of environmental conditions and trends to 

provide direction for future research and monitoring efforts.7

 EPA has 

struggled with providing a focus and the necessary resources for 

environmental information since its inception in 1970. While many data 

have been collected over the years, most water, air, and land programs 

lack the detailed environmental trend information to address the wellbeing of Americans. EPA program areas have also been hampered by 

deficiencies in their environmental data systems. For example, the quality 

of environmental data constrains EPA’s ability to assess the effectiveness 

of its enforcement policies and programs throughout the country and to 

inform the public about the health and environmental hazards of 

dangerous chemicals. 

We recommended that EPA better emphasize the development and use of

environmental indicators and information, not only in its strategic plan but 

also as a mechanism for prioritizing its allocation of limited resources and 

measuring the success of environmental policies and programs. GAO and 

policymakers in the executive and legislative branches have proposed the 

establishment of a Bureau of Environmental Statistics to provide the focus 

and resources needed to address the nation’s current and long-term 

environmental conditions and trends. Such a bureau would ensure toplevel commitment, interagency coordination, and clear responsibility for 

ensuring the comprehensiveness and credibility of environmental 

information. In addition, we recommended that EPA develop a consistent 

approach to ensure the transparency and accuracy of measures to 

determine its program effectiveness. Finally, we also recommended that

 7

GAO, Environmental Indicators: Better Coordination Is Needed to Develop Environmental 

Indicator Sets That Inform Decisions, GAO-05-52 (Washington, D.C.: Nov. 17, 2004).

Page 5 GAO-09-434 EPA Challenges
 

EPA ensure that information on environmental health risks and on 

companies that manufacture and use toxic chemicals is effectively 

collected and communicated to the public. 

EPA has generally agreed with our recommendations, and has made some 

progress in trying to obtain and use improved environmental information 

over the past several years. However, the agency’s efforts have been 

sporadic and spread among the various EPA offices. As such, the 

environmental information initiatives at EPA have been incomplete and 

lack a high-priority, coordinated, strategic approach that is necessary to 

link limited resources with the most critical data needs. 

EPA’s ability to effectively implement its mission of protecting public 

health and the environment depends on credible and timely assessment of 

the risks posed by toxic chemicals. Such assessments are the cornerstone 

of scientifically sound environmental decisions, policies, and regulations 

under a variety of statutes, such as TSCA. However, EPA has failed to 

develop sufficient chemical assessment information to determine whether 

it should establish controls to limit public exposure to many chemicals 

that may pose substantial health risks. As discussed below, in a number of 

reports, we have identified actions that are needed to (1) enhance EPA’s

ability under TSCA, among other things, to obtain health and safety 

information from the chemical industry and (2) streamline and increase 

the transparency of EPA’s Integrated Risk Information System (IRIS) that

provides EPA’s scientific position on the potential human health effects of 

more than 540 chemicals. 

TSCA generally places the burden of obtaining data on chemicals used in

commerce on EPA, rather than on the companies that produce the 

chemicals. For example, TSCA requires EPA to demonstrate certain health

or environmental risks before it can require companies to further test their 

chemicals. As a result, EPA does not routinely assess the risks of the 

roughly 80,000 industrial chemicals in use. Moreover, TSCA does not 

require chemical companies to test the approximately 700 new chemicals 

introduced into commerce annually for their toxicity, and companies 

generally do not voluntarily perform such testing. Further, the procedures 

EPA must follow in obtaining test data from companies can take years to 

complete. In contrast, the European Union’s chemical control legislation 

generally places the burden on companies to provide health effects data

Transforming EPA’s 

Processes for 

Assessing and 

Controlling Toxic 

Chemicals 

Page 6 GAO-09-434 EPA Challenges
 

on the chemicals they produce. In previous reports on TSCA, we have 

suggested that Congress consider statutory changes to strengthen EPA’s 

authority to obtain information from the chemical industry.8

 We continue 

to believe that giving EPA more authority to obtain data from the 

companies producing chemicals would improve the effectiveness of TSCA 

and thereby enhance EPA’s ability to protect public health and the 

environment. 

In addition, while TSCA authorizes EPA to issue regulations that may, 

among other things, ban existing toxic chemicals or place limits on their 

production or use, the statutory requirements EPA must meet present a 

legal threshold that has proven difficult for EPA and discourages the 

agency from using these authorities. For example, EPA must demonstrate 

“unreasonable risk,” which EPA believes requires it to conduct extensive 

cost-benefit analyses, to ban or limit chemical production. Since 1976, EPA 

has issued regulations to control only five existing chemicals determined 

to present an unreasonable risk. Further, its 1989 regulation phasing out 

most uses of asbestos was vacated by a federal appeals court in 1991 

because it was not based on “substantial evidence.” In contrast, the 

European Union and a number of other countries have largely banned

asbestos, a known human carcinogen that can cause lung cancer and other 

diseases. We have previously suggested that Congress consider amending 

TSCA to reduce the evidentiary burden EPA must meet to control toxic 

substances and continue to believe such change warrants serious 

consideration.9

Also, under TSCA, EPA has a limited ability to provide the public with 

information on chemical production and risk because of the act’s 

prohibitions on the disclosure of confidential business information. About

95 percent of the notices companies have provided to EPA on new 

chemicals contain some information claimed as confidential. While EPA 

believes that some claims of confidential business information may be 

unwarranted, challenging the claims is time- and resource-intensive, and 

EPA does not challenge most claims. Importantly, state environmental 

 8

GAO, Chemical Regulation: Comparison of U.S. and Recently Enacted European Union

Approaches to Protect against the Risks of Toxic Chemicals, GAO-07-825 (Washington, 

D.C.: Aug. 17, 2007), and Chemical Regulation: Options Exist to Improve EPA’s Ability to 

Assess Health Risks and Manage Its Chemical Review Program, GAO-05-458 

(Washington, D.C.: June 13, 2005). 

9

GAO-07-825. 

Page 7 GAO-09-434 EPA Challenges
 

agencies and others have said that information claimed as confidential 

would help them in such activities as developing contingency plans to alert 

emergency response personnel to the presence of highly toxic substances

at manufacturing facilities. The European Union’s chemical control 

legislation generally provides greater public access to the chemical 

information it receives. We previously suggested that Congress (1) 

consider authorizing EPA to share with the states and foreign governments 

the confidential business information that chemical companies provide to 

EPA, subject to regulations to be established by EPA that would set forth 

the procedures to be followed by all recipients of the information in order 

to protect the information from unauthorized disclosures, and (2) consider 

limiting the length of time for which information may be claimed as 

confidential without resubstantiation of the need for confidentiality.10

We have also identified significant problems with EPA’s process for 

developing chemical assessments under EPA’s IRIS program. Created in 

1985 to provide EPA with consensus opinions within the agency on the 

health effects of chronic exposure to chemicals, the IRIS database 

provides the basic information EPA needs to determine whether it should 

establish controls, for example, to protect the public from exposure to 

toxic chemicals in the air and water and at hazardous waste sites. In 2008, 

we reported that the IRIS database, which contains assessments of more 

than 540 toxic chemicals, is at serious risk of becoming obsolete because 

EPA has not been able to keep its existing assessments current or to 

complete assessments of the most important chemicals of concern.11

Factors contributing to EPA’s inability to complete assessments in a timely 

manner—including reviews required by the Office of Management and 

Budget (OMB) of IRIS assessments; certain management decisions, such 

as delaying some assessments to await new research; and the 

compounding effect of delays—can force EPA to essentially restart 

assessments to incorporate changing science and methods. 

In fact, a number of key chemicals have been caught in a seemingly 

endless review cycle, limiting EPA’s ability to protect the public health 

from ubiquitous chemicals that are likely to cause cancer or other serious 

health effects. For example, EPA’s formaldehyde and dioxin assessments 

 10GAO-07-825. 

11GAO, Chemical Assessments: Low Productivity and New Interagency Review Process 

Limit the Usefulness and Credibility of EPA’s Integrated Risk Information System, 

GAO-08-440 (Washington, D.C.: Mar. 7, 2008).

Page 8 GAO-09-434 EPA Challenges
 

have been in progress for about 12 and 18 years, respectively. Overall, EPA 

has finalized a total of only 9 assessments in the past 3 fiscal years; as of 

December 2007, most of the 70 ongoing assessments had been in progress 

for more than 5 years; and more than half of all current assessments may 

be outdated. Moreover, the OMB-required reviews, which are not publicly 

available, limit the credibility of the assessments because they involve 

federal agencies that may be affected by the assessments should they lead 

to regulatory actions. We recommended that EPA adopt a streamlined, 

more transparent assessment process. In its response, EPA estimated that 

under its proposed changes to the assessment process, most assessments 

would take from 3 to 4-1/2 years and mission-critical assessments would 

take up to 6 years. However, we believe that an IRIS assessment process 

built around such time frames is problematic. As we stated in our reports, 

when assessments take longer than 2 years, they can become subject to 

substantial delays stemming from the need to redo key analyses to take 

into account changing science and assessment methodologies.12

Some of our prior recommendations on IRIS and TSCA, aimed at providing 

EPA with information needed to support its assessment of toxic 

chemicals, have not been implemented. For example, when EPA 

implemented a new IRIS assessment process in 2008, it did not incorporate 

our recommendations to streamline and increase the transparency of the 

process. In fact, the new IRIS assessment process exacerbates the 

productivity and credibility concerns GAO identified. Further, our 

recommendations aimed at providing EPA with the information needed to

support its assessments of industrial chemicals under TSCA have not been

implemented. Without greater attention to EPA’s efforts to assess toxic 

chemicals, the nation lacks assurance that human health and the 

environment are adequately protected. Because of the importance of this 

issue, and the lack of progress in implementing much-needed change to 

TSCA, in January 2009 we added transforming EPA’s processes for 

assessing and controlling toxic chemicals to our list of high-risk areas 

needing added attention by Congress and the executive branch. 

 12GAO-08-440. 

Page 9 GAO-09-434 EPA Challenges
 

The Clean Air Act, a comprehensive federal law that regulates air pollution 

from stationary and mobile sources, was passed in 1963 to improve and 

protect the quality of the nation’s air. The act was substantially overhauled 

in 1970 when Congress required EPA to establish national ambient air 

quality standards for pollutants at levels that are necessary to protect 

public health with an adequate margin of safety and to protect public 

welfare from adverse effects. EPA has set such standards for ozone, 

carbon monoxide, particulate matter, sulfur oxides, nitrogen dioxide, and

lead. In addition, the act directed the states to specify how they would 

achieve and maintain compliance with the national standard for each 

pollutant. Congress amended the act again in 1977 and 1990. The 1977 

amendments were passed primarily to set new goals and dates for 

attaining the standards because many areas of the country had failed to 

meet the deadlines set previously. The act was amended again in 1990 

when several new themes were incorporated into it, including encouraging

the use of market-based approaches to reduce emissions, such as cap-andtrade programs. 

In recent years, our work has identified several key challenges in 

implementing the Clean Air Act, and made recommendations to EPA 

intended to enhance the effectiveness of its clean air programs. First, we 

have identified areas where EPA could improve its coordination with the 

Department of Transportation in making planning decisions.13 Second, we 

have found that while EPA had taken steps to strengthen its estimates of 

health benefits from rules reducing particulate matter air pollution, the 

agency needed to ensure continued resources toward improving analysis

of the uncertainty underlying its estimates.14 Third, we have identified 

delays and shortcomings with EPA’s development of rules intended to 

limit emissions of toxic air pollutants and recommended that the agency

develop a plan to improve its management of the air toxics program.15 In 

fact, when addressing EPA’s air quality standards in a recent hearing on 

children’s health, we noted that EPA largely disregarded recommendations 

Improve 

Implementation of the 

Clean Air Act 

 13GAO, Environmental Protection: Federal Planning Requirements for Transportation 

and Air Quality Protection Could Potentially Be More Efficient and Better Linked, 

GAO-03-581 (Washington, D.C.: Apr. 28, 2003). 

14GAO, Particulate Matter: EPA Has Started to Address the National Academies’

Recommendations on Estimating Health Benefits, but More Progress Is Needed, 

GAO-06-780 (Washington, D.C.: July 14, 2006). 

15GAO, Clean Air Act: EPA Should Improve the Management of Its Air Toxics Program, 

GAO-06-669 (Washington, D.C.: June 23, 2006).

Page 10 GAO-09-434 EPA Challenges
 

from its advisory committee, and recommended that the agency examine 

ways to use its advisors to reinvigorate its focus on the health of children, 

who are often disproportionately affected by air pollution.16 Fourth, we 

identified major shortcomings with EPA’s economic justification for a 

proposed rule to limit mercury emissions from power plants and 

recommended, among other things, that the agency conduct its analysis 

consistent with OMB guidance for economic analysis and better document 

its findings.17 EPA stated that it would address the recommendations by, 

for example, conducting additional analysis on the rule. 

EPA also faces a number of challenges related to clean air regulatory 

decisions that have been vacated or remanded to the agency by the courts. 

These include regulatory proposals or agency decisions related to (1) 

mercury emissions from coal-fired power plants; (2) long-range transport 

of sulfur dioxide and nitrogen oxides—pollutants that contribute to acid 

rain and other air quality problems—emitted by power plants; (3) the New 

Source Review program, a permitting program that among other goals 

seeks to prevent air quality degradation from the addition of new and 

modified factories, industrial boilers, and power plants; and (4) whether 

EPA and the states can use existing authority under the Clean Air Act to 

regulate greenhouse gases. Each of these issues, along with those 

identified in our prior work, will require substantial management attention 

in the near term. 

The Clean Water Act establishes the basic structure for regulating 

discharges of pollutants into the waters of the United States and regulating

the quality of surface waters. However, the law’s effectiveness has been 

challenged by the fact that many pollution sources are decentralized and 

diffuse in nature, and therefore difficult to monitor and regulate. One such 

source is urban storm water runoff. Pollutants and sediment carried by 

storm water, as well as the volume and temperature of runoff, can alter 

aquatic habitats and make it hard for fish and other organisms to survive.18

Reducing Pollution in 

the Nation’s Waters 

 16GAO, Environmental Health: EPA Efforts to Address Children’s Health Issues Need

Greater Focus, Direction, and Top-Level Commitment, GAO-08-1155T (Washington, D.C.: 

Sept. 16, 2008). 

17GAO, Clean Air Act: Observations on EPA’s Cost-Benefit Analysis of Its Mercury

Control Options, GAO-05-252 (Washington, D.C.: Feb. 28, 2005). 

18GAO, Clean Water: Further Implementation and Better Cost Data Needed to Determine

Impact of EPA’s Storm Water Program on Communities, GAO-07-479 (Washington, D.C.: 

May 31, 2007).

Page 11 GAO-09-434 EPA Challenges
 

Some pollutants can also make fish and shellfish unsafe to eat. Moreover, 

polluted storm water runoff can negatively affect those who use fresh- and 

saltwater areas for swimming and boating. For example, swimmers in 

water with high levels of bacteria have a greater risk of contracting 

gastrointestinal or respiratory illnesses. However, EPA still has not 

developed rapid water-testing methods and current water quality 

standards.19

The safety of our nation’s water is also threatened by other factors, such 

as pollutants discharged from large-scale animal feeding operations that 

enter water bodies. More than a dozen government-sponsored or peerreviewed studies since 2002 on water pollutants emitted by concentrated

animal-feeding operations found increased levels of phosphorus, nitrogen,

or hormones in surface water and groundwater near animal-feeding 

operations. According to EPA, excessive amounts of these nutrients can 

deplete oxygen in water, which could result in fish deaths, reduced aquatic 

diversity, and illness in infants.20 Despite its long-term regulation of 

concentrated animal-feeding operations, EPA still lacks comprehensive 

and reliable data on the number, location, and size of the operations that

have been issued permits and the amounts of discharges they release. As a 

result, EPA has neither the information it needs to assess the extent to 

which concentrated animal-feeding operations may be contributing to 

water pollution, nor the information it needs to ensure compliance with 

the Clean Water Act.21

EPA partners with federal, state, and local agencies, as well as

nongovernmental organizations, to develop and implement approaches 

that can reduce pollution in our nation’s significant water bodies. 

However, after decades of EPA and its partners spearheading restoration 

efforts in areas such as the Great Lakes and the Chesapeake Bay, 

improvements in these water bodies remain elusive. Lack of targeted 

strategies; coordination among federal, state, and local stakeholders; and 

realistic goals to ensure that limited restoration resources are being used 

 19GAO, Physical Infrastructure: Challenges and Investment Options for the Nation’s

Infrastructure, GAO-08-763T (Washington, D.C.: May 8, 2008). 

20GAO, Concentrated Animal Feeding Operations: EPA Needs More Information and a

Clearly Defined Strategy to Protect Air and Water Quality from Pollutants of Concern, 

GAO-08-944 (Washington, D.C.: Sept. 4, 2008).

21GAO-08-944. 

Page 12 GAO-09-434 EPA Challenges
 

for the most effective restoration activities appear to be long-standing 

issues impeding such efforts. 

In recent years, we have made many recommendations to help EPA 

address these problems. To more effectively regulate the discharges from

large-scale animal-feeding operations, EPA should complete its efforts to 

develop an inventory of permitted operations.22 In addition, we

recommended that EPA evaluate the implementation of the storm water 

program and issue additional program guidance and consider regulatory 

changes to improve the quality and consistency of activity reporting by 

communities. To better protect the safety of our nation’s beaches, EPA 

needs to publish new or revised water quality criteria for pathogens and 

pathogen indicators and develop specific guidance on monitoring 

frequency and methods of public notification.23 In addition, we 

recommended that EPA ensure that the Chesapeake Bay Program––a 

partnership between EPA, several states, and the Chesapeake Bay 

Commission––develops a coordinated implementation strategy that unifies 

its various planning documents and establishes a means to better target its 

limited resources to the most cost-effective restoration activities.24 We also

recommended that for its Great Lakes Initiative, EPA develop a more 

consistent permitting strategy for controlling mercury and gather more 

information to help it develop water quality standards and assess the 

effect of programs intended to minimize pollutants that are exceeding 

standards.25

EPA agreed with our recommendations in these areas. For example, while 

EPA expected to take several years to fully implement a national data 

system, EPA and states are currently working to develop and implement a 

national data system to collect and record facility-specific information on 

concentrated animal-feeding operations and other facilities through its 

Integrated Compliance Information System, and has initiated an effort to 

 22GAO-08-944. 

23GAO, Great Lakes: EPA and States Have Made Progress in Implementing the BEACH 

Act, but Additional Actions Could Improve Public Health Protection, GAO-07-591 

(Washington, D.C.: May 1, 2007). 

24GAO, Chesapeake Bay Program: Improved Strategies Are Needed to Better Assess, 

Report, and Manage Restoration Progress, GAO-06-96 (Washington, D.C.: Oct. 28, 2005). 

25GAO, Great Lakes Initiative: EPA and States Have Made Progress, but Much Remains to

Be Done If Water Quality Goals Are to Be Achieved, GAO-08-312T (Washington, D.C.: Jan.

23, 2008). 

Page 13 GAO-09-434 EPA Challenges
 

develop a rule to establish required data elements and reporting 

frequencies. Likewise, for the storm water program, EPA has taken steps 

to improve the quality and consistency of program data reported by 

communities and is currently developing guidance, including a reporting 

form that it believes will help the agency obtain better data for evaluating

the program. Finally, EPA agreed with our recommendations regarding the 

Chesapeake Bay Program, and plans to work with the Great Lakes states 

in assessing approaches for reducing mercury in lieu of developing a 

mercury permitting strategy. 

In addition, in coming years among the most daunting water pollution 

control problems will be those faced by the nation’s water utilities in 

grappling with the multibillion-dollar costs of upgrading aging and 

deteriorating infrastructures and building new ones to serve a growing 

population.26 Frequent and highly publicized incidences of combined sewer 

overflows into rivers and streams as well as water main breaks in the 

nation’s largest cities are the most visible manifestation of this mounting 

problem. Overall, water infrastructure needs across the country have been

estimated to cost from $485 billion to nearly $1.2 trillion over the next 20 

years. Even before the current financial crisis, many water utilities had 

difficulty raising funds to repair, replace, or upgrade aging capital assets; 

comply with regulatory requirements; and expand capacity to meet 

increased demand. For example, based on a nationwide survey of several

thousand drinking water and wastewater utilities, we reported several 

years ago that about one-third of the utilities (1) deferred maintenance 

because of insufficient funds, (2) had 20 percent or more of their pipelines 

nearing the end of their useful life, and (3) lacked basic plans for managing 

their capital assets.27

We noted in the past that better management techniques can, at least to 

some extent, help utilities make the best use of available dollars in their 

struggle to meet their infrastructure needs. For example, we 

recommended comprehensive asset management—a technique whereby 

water systems systematically identify their needs, set priorities, and better 

target their investments—as a tool for helping utilities make better use of

 26GAO-08-763T, and GAO, Water Infrastructure: Comprehensive Asset Management Has

Potential to Help Utilities Better Identify Needs and Plan Future Investments, 

GAO-04-461 (Washington, D.C.: Mar. 19, 2004). 

27GAO, Water Infrastructure: Information on Financing, Capital Planning, and 

Privatization, GAO-02-764 (Washington, D.C.: Aug. 16, 2002).

Page 14 GAO-09-434 EPA Challenges
 

available funds. Additional funds, however, will ultimately be needed to 

narrow the enormous gap between water infrastructure needs and 

available resources. Of note, EPA will receive $6 billion in additional water 

infrastructure funding from the recently passed stimulus bill. EPA agreed 

with our recommendations, and while it has undertaken a number of 

approaches to encourage asset management, such as implementing a 

sustainable infrastructure initiative and offering training sessions on best 

practices, there is further work needed to encourage comprehensive asset 

management across the nation. 

In 1980, Congress passed the Comprehensive Environmental Response, 

Compensation, and Liability Act, establishing the Superfund program and 

giving the federal government the authority to respond to chemical 

emergencies and to clean up hazardous waste sites on private and public

lands. The Superfund program addresses both short- and long-term risks 

from toxic chemicals. The act established a trust fund financed primarily 

by taxes on crude oil and certain chemicals to pay for EPA’s cleanup

activities. The authority for these taxes expired in 1995; EPA must now 

primarily rely on annual appropriations from the general fund to fund 

cleanups. These appropriations, when adjusted for inflation, have been 

declining and the pace of cleanups has slowed.28 Furthermore, citing 

competing priorities and lack of funds, EPA has not implemented a 1980

statutory mandate under Superfund to require businesses handling 

hazardous substances to demonstrate their ability to pay for potential 

environmental cleanups—that is, to provide financial assurances.29

Because of this inaction, EPA has exposed the Superfund program and 

U.S. taxpayers to potentially enormous cleanup costs at gold, lead, and 

other mining sites and other industrial operations. In addition, we found 

that EPA faces challenges in ensuring that institutional controls—legal or 

administrative restrictions on land or resource use to protect against 

exposure to residual contamination at hazardous waste sites—are 

adequately implemented, monitored, and enforced.

30 

Speeding the Pace of 

Cleanup at Superfund 

and Other Hazardous 

Waste Sites 

 28GAO, Superfund: Funding and Reported Costs of Enforcement and Administration 

Activities, GAO-08-841R (Washington, D.C.: July 18, 2008). 

29GAO, Environmental Liabilities: EPA Should Do More to Ensure That Liable Parties 

Meet Their Cleanup Obligations, GAO-05-658 (Washington, D.C.: Aug. 17, 2005). 

30GAO, Hazardous Waste Sites: Improved Effectiveness of Controls at Sites Could Better 

Protect the Public, GAO-05-163 (Washington, D.C.: Jan. 28, 2005).

Page 15 GAO-09-434 EPA Challenges
 

In 1984, Congress required EPA to devise regulations for the design and 

operation of underground tanks. In response, in 1985, EPA began 

developing the Underground Storage Tank program to prevent releases of 

petroleum and hazardous substances into the environment, detect releases

when they occur, and clean up any contamination resulting from a release. 

To support the program and provide public funding to states to ensure that 

releases from tanks are cleaned up, in 1986 Congress established the 

Leaking Underground Storage Tank Trust Fund, funded primarily through 

an excise tax on gasoline and other motor fuels. The fund has since grown 

to an estimated $3.2 billion at the end of fiscal year 2008, yet the pace of 

cleanup remains slow. Under the program, tank owners and operators are 

primarily responsible for paying to clean up releases from their tanks. 

They can demonstrate their financial responsibility by using, among other 

options, state financial assurance funds. However, we found that tank 

owners sometimes fail to maintain adequate financial responsibility 

coverage and that several states’ assurance funds may lack sufficient 

resources to ensure timely cleanups.31

Finally, in 2005 we found that federal and state agencies had identified 

perchlorate—a component of rocket fuel known to affect human health—

in groundwater, soil, or public drinking water systems at almost 400 sites 

across the country. Nevertheless, there is no federal drinking water 

standard or specific requirement to clean up perchlorate and the National 

Academy of Sciences called for additional research on the effects of 

perchlorate exposure.32

We have made several recommendations to help EPA more quickly clean 

up hazardous waste sites. Specifically, we recommended that EPA (1) 

ensure that financial assurances are in place for sites that manufacture or

use toxic chemicals; (2) improve the institutional controls at contaminated

sites to ensure better protection of the public from inappropriate use of 

such sites; (3) ensure that the owners of underground storage tanks 

maintain access to adequate financial resources for cleaning up leaks and

that state insurance funds provide reliable coverage for cleaning up 

 31GAO, Leaking Underground Storage Tanks: EPA Should Take Steps to Better Ensure the

Effective Use of Public Funding for Cleanups, GAO-07-152 (Washington, D.C.: Feb. 8,

2007). 

32GAO, Perchlorate: A System to Track Sampling and Cleanup Results Is Needed, 

GAO-05-462 (Washington, D.C.: May 20, 2005).

Page 16 GAO-09-434 EPA Challenges
 

leaking tanks; and (4) establish a formal structure to centrally track and 

monitor perchlorate detections and the status of cleanup efforts. 

EPA has generally agreed with our recommendations in these areas, but 

has not yet implemented any of them. EPA disagreed with our 

recommendation regarding establishing a perchlorate tracking structure 

because the agency believes that it already has sufficient capability to 

track and monitor perchlorate detection and cleanup efforts. Nevertheless, 

we continue to believe that such a system would better inform the public 

and others about perchlorate’s presence in their communities. 

In addition to the challenges with which EPA has struggled for years, new 

challenges are emerging, chief among them, climate change. Changes in 

the earth’s climate attributable to increased concentrations of greenhouse 

gases may have significant environmental and economic impacts in the 

United States and internationally. Among other potential impacts, climate 

change could threaten coastal areas with rising sea levels, alter 

agricultural productivity, and increase the intensity and frequency of 

floods and tropical storms. Furthermore, climate change has implications 

for the fiscal health of the federal government, affecting federal crop and

flood insurance programs, and placing new stresses on infrastructure and 

natural resources. Accordingly, there are numerous legislative proposals 

for reducing greenhouse gas emissions and reducing the nation’s use and 

dependence on fossil fuels. EPA will be at the center of the federal 

government’s strategy for addressing this monumental challenge. 

We have previously reported that the federal government’s approach to 

climate change has been ad hoc, not comprehensive, and not well 

coordinated across government agencies. Specifically, the federal 

government lacks a comprehensive approach for targeting federal 

research dollars at the development and deployment of low-carbon 

technologies. Federal land management agencies are behind in their 

efforts to develop strategies and guidance for adapting to climate change,

and federal crop insurance and flood insurance have not yet embraced the

implications of climate change on their portfolios. Moreover, the technical 

challenges of carbon capture and storage; biofuels development, 

production, and distribution; and alternative sources of energy have not 

been fully researched. Finally, energy conservation efforts have remained 

stagnant over the past decade. 

To inform Congress as it considers various legislative proposals for 

addressing climate change, we reported on the economic implications of

Addressing Emerging 

Climate Change 

Issues 

Page 17 GAO-09-434 EPA Challenges
 

different policy options, lessons learned from the European Union’s 

efforts to implement mandatory carbon reductions, and the Clean 

Development Mechanism under the Kyoto Protocol. We also reported on 

the challenges in carbon capture and storage—another key component of 

most climate change legislative proposals—and identified problems that 

must be resolved. We have also issued information on the carbon offset 

market, and identified challenges that must be resolved before this can be 

a part of climate change legislation.

We have made several recommendations to help various federal agencies 

better address climate changes, including recommending that EPA and the 

Department of Energy put more rigor into their voluntary emission 

reduction programs and track and report results. We also recommended 

that federal agencies develop clear written communications to resource 

managers that explains how managers are expected to address the effects 

of climate change.33 In addition, we recommended that federal agencies 

better coordinate and more comprehensively identify and address 

research gaps in alternative fuels, clean coal, and other emission reduction 

technologies. Finally, we recommended that federal agencies step up 

energy conservation efforts.34 Agencies responsible for voluntary climate 

change programs, including EPA, as well as agencies responsible for 

climate change research generally agreed with our recommendations but 

have been slow to implement them. 

While EPA has made some progress in improving its operations, many of 

the same issues still remain. EPA’s mission is, without question, a difficult

one: its policies and programs affect virtually all segments of the economy, 

society, and government, and it is in the unenviable position of enforcing 

myriad inherently controversial environmental laws and maintaining a

delicate balance between the benefits to public health and the 

environment with the cost to industry and others. Nevertheless, the 

repetitive and persistent nature of the shortcomings we have observed 

Concluding 

Observations 

 33GAO, Climate Change: Federal Agencies Should Do More to Make Funding Reports 

Clearer and Encourage Progress on Two Voluntary Programs, GAO-06-1126T 

(Washington, D.C.: Sept. 27, 2006), and Climate Change: EPA and DOE Should Do More to 

Encourage Progress Under Two Voluntary Programs, GAO-06-97 (Washington, D.C.: Apr. 

25, 2006). 

34GAO, Climate Change Research: Agencies Have Data-Sharing Policies but Could Do 

More to Enhance the Availability of Data from Federally Funded Research, GAO-07-1172 

(Washington, D.C.: Sept. 28, 2007).

Page 18 GAO-09-434 EPA Challenges
 

over the years points to serious challenges for EPA to effectively 

implement its programs. Until it addresses these long-standing challenges, 

EPA is unlikely to be able to respond effectively to much larger emerging 

challenges, such as climate change. Facing these challenges head-on will 

require a sustained commitment by agency leadership. As a new 

administration takes office and begins to chart the agency’s course, it will 

be important for Congress and EPA to continue to focus on the issues we 

have identified. 

We are sending copies of this report to interested congressional 

committees and the Administrator of EPA. The report also is available at 

no charge on the GAO Web site at http://www.gao.gov. 

If you or your staffs have any questions about this report, please contact 

me at (202) 512-3841 or stephensonj@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on the 

last page of this report. GAO staff who made major contributions to this 

John B. Stephenson 

report are listed in appendix I. 

Director, Natural Resources and Environment 

Page 19 GAO-09-434 EPA Challenges
Appendix I: 

A

GAO Contact and Staff 

cknowledgments 

Page 20 GAO-09-434

Appendix I: GAO Contact and Staff 

Acknowledgments 

John B. Stephenson, (202) 512-3841 or stephensonb@gao.gov 

In addition to the contact named above, other key contributors to this 

report include Kevin Bray, Antoinette Capaccio, Kate Cardamone, Steve

Elstein, Liz Erdmann, Christine Fishkin, Brian Friedman, John Gates, 

Melissa Hermes, Michael Hix, Anne Johnson, Rich Johnson, Karen Keegan, 

Ed Kratzer, Justin Mausel, Sherry McDonald, Mehrzad Nadji, Emily 

Norman, Alison O’Neill, Vincent Price, Diane Raynes, John Smith, Joe 

Thompson, and Lisa Vojta. 

GAO Contact 

Acknowledgments 

EPA Challenges
Related GAO Products 

Page 21 GAO-09-434

Related GAO Products 

High-Risk Series: An Update. GAO-09-271. Washington, D.C.: January 

2009. 

Environmental Enforcement and Compliance

EPA’s Execution of Its Fiscal year 2007 New Budget Authority for the 

Enforcement and Compliance Assurance Program in the Regional 

Offices. GAO-08-1109R. Washington, D.C.: September 26, 2008. 

Environmental Enforcement: EPA Needs to Improve the Accuracy and 

Transparency of Measures Used to Report on Program Effectiveness. 

GAO-08-1111R. Washington, D.C.: September 18, 2008. 

Environmental Protection: EPA-State Enforcement Partnership Has 

Improved, but EPA’s Oversight Needs Further Enhancement. 

GAO-07-883. Washington, D.C.: July 31, 2007. 

Environmental Compliance and Enforcement: EPA’s Effort to Improve 

and Make More Consistent Its Compliance and Enforcement Activities. 

GAO-06-840T. Washington, D.C.: June 28, 2006. 

Assessing Human Capital Issues

EPA’s Execution of Its Fiscal year 2007 New Budget Authority for the 

Enforcement and Compliance Assurance Program in the Regional 

Offices. GAO-08-1109R. Washington, D.C.: September 26, 2008. 

Environmental Protection: EPA-State Enforcement Partnership Has 

Improved, but EPA’s Oversight Needs Further Enhancement. 

GAO-07-883. Washington, D.C.: July 31, 2007. 

Environmental Compliance and Enforcement: EPA’s Effort to Improve 

and Make More Consistent Its Compliance and Enforcement Activities. 

GAO-06-840T. Washington, D.C.: June 28, 2006. 

Clean Water Act: Improved Resource Planning Would Help EPA Better 

Respond to Changing Needs and Fiscal Constraints. GAO-05-721. 

Washington, D.C.: July 22, 2005. 

Human Capital: Implementing an Effective Workforce Strategy Would 

Help EPA to Achieve Its Strategic Goals. GAO-01-812. Washington, D.C.: 

July 31, 2001.

High-Risk Series 

Improving Agencywide 

Management 

EPA Challenges
Related GAO Products 

Improving the Development and Use of Environmental information

Environmental Protection: EPA Needs to Follow Best Practices and 

Procedures When Reorganizing Its Library Network. GAO-08-579T. 

Washington, D.C.: March 13, 2008. 

Environmental Protection: EPA Needs to Ensure That Best Practices and 

Procedures Are Followed When Making Further Changes to Its Library 

Network. GAO-08-304. Washington, D.C.: February 29, 2008.

Toxic Chemical Releases: EPA Actions Could Reduce Environmental 

Information Available to Many Communities. GAO-08-128. Washington,

D.C.: November 30, 2007.

Measuring Our Nation’s Natural Resources and Environmental 

Sustainability: Highlights of a Forum Jointly Convened by the 

Comptroller General of the United States and the National Academy of 

Science. GAO-08-127SP. Washington, D.C.: October 2007. 

Environmental Right-To-Know: EPA’s Recent Rule Could Reduce 

Availability of Toxic Chemical Information Used to Assess 

Environmental Justice. GAO-08-115T. Washington, D.C.: October 4, 2007.

Environmental Justice: Measurable Benchmarks Needed to Gauge EPA 

Progress in Correcting Past Problems. GAO-07-1140T. Washington, D.C.:

July 25, 2007.

Environmental Information: EPA Actions Could Reduce the Availability

of Environmental Information to the Public. GAO-07-464T. Washington,

D.C.: February 6, 2007. 

Environmental Indicators: Better Coordination Is Needed to Develop 

Environmental Indicator Sets That Inform Decisions. GAO-05-52. 

Washington, D.C.: November 17, 2004. 

EPA’s Execution of Its Fiscal year 2007 New Budget Authority for the 

Enforcement and Compliance Assurance Program in the Regional 

Offices. GAO-08-1109R. Washington, D.C.: September 26, 2008. 

Environmental Health: EPA Efforts to Address Children’s Health Issues

Need Greater Focus, Direction, and Top-Level Commitment. 

GAO-08-1155T. Washington, D.C.: September 16, 2008. 

Transforming EPA’s 

Processes for Assessing 

and Controlling Toxic 

Chemicals 

Page 22 GAO-09-434 EPA Challenges
Related GAO Products 

Chemical Assessments: EPA’s New Assessment Process Will Further 

Limit the Productivity and Credibility of Its Integrated Risk 

Information System. GAO-08-810T. Washington, D.C.: May 21, 2008. 

Toxic Chemicals: EPA’s New Assessment Process Will Increase 

Challenges EPA Faces in Evaluating and Regulating Chemicals. 

GAO-08-743T. Washington, D.C.: April 29, 2008. 

Chemical Assessments: Low Productivity and New Interagency Review

Process Limit the Usefulness and Credibility of EPA’s Integrated Risk 

Information System. GAO-08-440. Washington, D.C.: March 7, 2008. 

Chemical Regulation: Comparison of U.S. and Recently Enacted 

European Union Approaches to Protect against the Risks of Toxic 

Chemicals. GAO-07-825. Washington, D.C.: August 17, 2007. 

Environmental Contamination: Department of Defense Activities 

Related to Trichloroethylene, Perchlorate, and Other Emerging 

Contaminants. GAO-07-1042T. Washington, D.C.: July 12, 2007. 

Perchlorate: EPA Does Not Systematically Track Incidents of 

Contamination. GAO-07-797T. Washington, D.C.: April 25, 2007. 

Chemical Regulation: Actions Are Needed to Improve the Effectiveness of 

EPA’s Chemical Review Program. GAO-06-1032T. Washington, D.C.: 

August 2, 2006. 

Chemical Regulation: Approaches in the United States, Canada, and the 

European Union. Washington, D.C.: GAO-06-217R. November 4, 2005. 

Chemical Regulation: Options Exist to Improve EPA’s Ability to Assess 

Health Risks and Manage Its Chemical Review Program. GAO-05-458. 

Washington, D.C.: June 13, 2005. 

World Trade Center: EPA’s Most Recent Test and Clean Program Raises 

Concerns That Need to Be Addressed to Better Prepare for Indoor 

Contamination Following Disasters. GAO-07-1091. Washington, D.C.: 

September 5, 2007. 

Particulate Matter: EPA Needs to Make More Progress in Addressing the

National Academies’ Recommendations on Estimating Health Benefits. 

GAO-06-992T. Washington, D.C.: July 19, 2006. 

Improving Implementation 

of the Clean Air Act 

Page 23 GAO-09-434 EPA Challenges
Related GAO Products 

Particulate Matter: EPA Has Started to Address the National Academies’ 

Recommendations on Estimating Health Benefits, but More Progress Is 

Needed. GAO-06-780. Washington, D.C.: July 14, 2006. 

Clean Air Act: EPA Should Improve the Management of Its Air Toxics 

Program. GAO-06-669. Washington, D.C.: June 23, 2006. 

Air Pollution: Estimated Emissions from Two New Mexicali Power 

Plants Are Low, but Health Impacts Are Unknown. GAO-05-823. 

Washington, D.C.: August 12, 2005. 

Clean Air Act: Emerging Mercury Control Technologies Have Shown 

Promising Results, but Data on Long-Term Performance Are Limited. 

GAO-05-612. Washington, D.C.: May 31, 2005. 

Environmental Health: EPA Efforts to Address Children’s Health Issues

Need Greater Focus, Direction, and Top-Level Commitment. 

GAO-08-1155T. Washington, D.C.: September 16, 2008. 

Recent Actions by the Chesapeake Bay Program Are Positive Steps 

Toward More Effectively Guiding the Restoration Effort, but Additional 

Steps Are Needed. GAO-08-1131R. Washington, D.C.: August 28, 2008. 

Chesapeake Bay Program: Recent Actions Are Positive Steps Toward 

More Effectively Guiding the Restoration Effort. GAO-08-1033T. 

Washington, D.C.: July 30, 2008. 

Concentrated Animal Feeding Operations: EPA Needs More Information 

and a Clearly Defined Strategy to Protect Air and Water Quality from 

Pollutants of Concern, GAO-08-944. Washington, D.C.: Sept. 4, 2008. 

Physical Infrastructure: Challenges and Investment Options for the 

Nation’s Infrastructure, GAO-08-763T. Washington, D.C.: May 8, 2008. 

International Boundary and Water Commission: Two Alternatives for 

Improving Wastewater Treatment at the United States-Mexico Border. 

GAO-08-595R. Washington, D.C.: April 24, 2008. 

Great Lakes Initiative: EPA and States Have Made Progress, but Much 

Remains to Be Done If Water Quality Goals Are to Be Achieved. 

GAO-08-312T. Washington, D.C.: January 23, 2008. 

Reducing Pollution in the 

Nation’s Waters 

Page 24 GAO-09-434 EPA Challenges
Related GAO Products 

Coastal Wetlands: Lessons Learned from Past Efforts in Louisiana 

Could Help Guide Future Restoration and Protection. GAO-08-130. 

Washington, D.C.: December 14, 2007. 

South Florida Ecosystem: Some Restoration Progress Has Been Made, 

but the Effort Faces Significant Delays, Implementation Challenges, and 

Rising Costs. GAO-07-1250T. Washington, D.C.: September 19, 2007. 

Maritime Transportation: Major Oil Spills Occur Infrequently, but Risks 

to the Federal Oil Spill Fund Remain. GAO-07-1085. Washington, D.C.: 

September 7, 2007. 

The BEACH Act of 2000: EPA and States Have Made Progress 

Implementing the Act, but Further Actions Could Increase Public Health

Protection. GAO-07-1073T. Washington, D.C.: July 12, 2007. 

South Florida Ecosystem: Restoration Is Moving Forward but Is Facing

Significant Delays, Implementation Challenges, and Rising Costs. 

GAO-07-520. Washington, D.C.: May 31, 2007. 

Clean Water: Further Implementation and Better Cost Data Needed to 

Determine Impact of EPA’s Storm Water Program on Communities. 

GAO-07-479. Washington, D.C.: May 31, 2007. 

Great Lakes: EPA and States Have Made Progress in Implementing the

BEACH Act, but Additional Actions Could Improve Public Health 

Protection. GAO-07-591. Washington, D.C: May 1, 2007. 

Chesapeake Bay Program: Improved Strategies Needed to Better Guide 

Restoration Efforts. GAO-06-614T. Washington, D.C.: July 13, 2006. 

Chesapeake Bay Program: Improved Strategies Are Needed to Better 

Assess, Report, and Manage Restoration Progress, GAO-06-96. 

Washington, D.C.: Oct. 28, 2005. 

Great Lakes Initiative: EPA Needs to Better Ensure the Complete and 

Consistent Implementation of Water Quality Standards. GAO-05-829. 

Washington, D.C.: July 27, 2005. 

Water Infrastructure: Comprehensive Asset Management Has Potential

to Help Utilities Better Identify Needs and Plan Future Investments, 

GAO-04-461. Washington, D.C.: Mar. 19, 2004. 

Page 25 GAO-09-434 EPA Challenges
Related GAO Products 

Speeding the Pace of 

Cleanup at Superfund and 

Other Hazardous Waste 

Sites 

Electronic Waste: Harmful U.S. Exports Flow Virtually Unrestricted 

Because of Minimal EPA Enforcement and Narrow Regulation. 

GAO-08-1166T. Washington, D.C.: September 17, 2008. 

Hurricane Katrina: Continuing Debris Removal and Disposal Issues. 

GAO-08-985R. Washington, D.C.: August 25, 2008. 

Superfund: Funding and Reported Costs of Enforcement and 

Administration Activities. GAO-08-841R. Washington, D.C.: July 18, 2008.

Aboveground Oil Storage Tanks: More Complete Facility Data Could 

Improve Implementation of EPA’s Spill Prevention Program. 

GAO-08-482. Washington, D.C.: April 30, 2008. 

Hazardous Waste: Information on How DOD and Federal and State 

Regulators Oversee the Off-Site Disposal of Waste from DOD 

Installations. GAO-08-74. Washington, D.C.: November 13, 2007. 

Hazardous Materials: EPA May Need to Reassess Sites Receiving 

Asbestos-Contaminated Ore from Libby, Montana, and Should Improve 

Its Public Notification Process. GAO-08-71. Washington, D.C.: October 12, 

2007. 

Aboveground Oil Storage Tanks: Observations on EPA’s Economic 

Analyses of Amendments to the Spill Prevention, Control, and 

Countermeasure Rule. GAO-07-763. Washington, D.C.: July 27, 2007. 

Hurricane Katrina: EPA’s Current and Future Environmental 

Protection Efforts Could Be Enhanced by Addressing Issues and 

Challenges Faced on the Gulf Coast. GAO-07-651. Washington, D.C.: June 

25, 2007. 

Leaking Underground Storage Tanks: EPA Should Take Steps to Better 

Ensure the Effective Use of Public Funding for Cleanups. GAO-07-152. 

Washington, D.C.: February 8, 2007. 

Recycling: Additional Efforts Could Increase Municipal Recycling. 

GAO-07-37. Washington, D.C.: December 29, 2006. 

Environmental Liabilities: EPA Should Do More to Ensure That Liable 

Parties Meet Their Cleanup Obligations, GAO-05-658. Washington, D.C.: 

Aug. 17, 2005. 

Page 26 GAO-09-434 EPA Challenges
Related GAO Products 

Perchlorate: A System to Track Sampling and Cleanup Results Is Needed, 

GAO-05-462. Washington, D.C.: May 20, 2005. 

Hazardous Waste Sites: Improved Effectiveness of Controls at Sites 

Could Better Protect the Public, GAO-05-163. Washington, D.C.: Jan. 28, 

2005. 

Climate Change: Federal Actions Will Greatly Affect the Viability of 

Carbon Capture and Storage As a Key Mitigation Option. GAO-08-1080. 

Washington, D.C.: September 30, 2008. 

Carbon Offsets: The U.S. Voluntary Market Is Growing, but Quality 

Assurance Poses Challenges for Market Participants. GAO-08-1048. 

Washington, D.C.: August 29, 2008. 

Climate Change: Expert Opinion on the Economics of Policy Options to

Address Climate Change. GAO-08-605. Washington, D.C.: May 9, 2008. 

Climate Change Research: Agencies Have Data-Sharing Policies but 

Could Do More to Enhance the Availability of Data from Federally 

Funded Research. GAO-07-1172. Washington, D.C.: September 28, 2007. 

Climate Change: Agencies Should Develop Guidance for Addressing the 

Effects on Federal Land and Water Resources. GAO-07-863. Washington, 

D.C.: August 7, 2007. 

Biofuels: DOE Lacks a Strategic Approach to Coordinate Increasing 

Production with Infrastructure Development and Vehicle Needs. 

GAO-07-713. Washington, D.C.: June 8, 2007. 

Climate Change: Financial Risks to Federal and Private Insurers in 

Coming Decades are Potentially Significant. GAO-07-820T. Washington,

D.C.: May 3, 2007. 

Climate Change: Financial Risks to Federal and Private Insurers in 

Coming Decades Are Potentially Significant. GAO-07-285. Washington, 

D.C.: March 16, 2007. 

Energy Efficiency: Long-standing Problems with DOE’s Program for 

Setting Efficiency Standards Continue to Result in Forgone Energy 

Savings. GAO-07-42. Washington, D.C.: January 31, 2007. 

Addressing Emerging 

Climate Change Issues 

Page 27 GAO-09-434 EPA Challenges
Related GAO Products 

Climate Change: Federal Agencies Should Do More to Make Funding 

Reports Clearer and Encourage Progress on Two Voluntary Programs. 

GAO-06-1126T. Washington, D.C.: September 27, 2006. 

Climate Change: Greater Clarity and Consistency Are Needed in 

Reporting Federal Climate Change Funding. GAO-06-1122T. 

Washington, D.C.: September 21, 2006. 

Climate Change: EPA and DOE Should Do More to Encourage Progress 

Under Two Voluntary Programs. GAO-06-97. Washington, D.C.: April 25,

2006. 

(361060) Page 28 GAO-09-434 EPA Challenges
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