Major Management Challenges and Program Risks: Environmental Protection
Agency (Letter Report, 01/01/2001, GAO/GAO-01-257).

This report, part of GAO's high risk series, discusses the major
management challenges and program risks facing the Environmental
Protection Agency (EPA). These challenges include (1) improving
environmental performance information management, (2) developing a
comprehensive human capital approach, and (3) strengthening working
relationships with the states.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GAO-01-257
     TITLE:  Major Management Challenges and Program Risks:
	     Environmental Protection Agency
      DATE:  01/01/2001
   SUBJECT:  Risk management
	     Internal controls
	     Accountability
	     Strategic planning
	     Human resources utilization
	     Environmental policies
	     Federal/state relations
	     Personnel management
	     Performance measures
IDENTIFIER:  High Risk Series 2001
	     GAO High Risk Program
	     Superfund Program
	     EPA National Environmental Performance Partnership System
	     EPA High Production Volume Challenge Program

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GAO-01-257

Performance and Accountability Series

January 2001 Major Management Challenges and Program Risks

Environmental Protection Agency

GAO- 01- 257

Letter 3 Overview 6 Major

13 Performance and Accountability Challenges

Related GAO 43

Products Performance

46 and Accountability Series

Lett er

January 2001 The President of the Senate The Speaker of the House of
Representatives

This report addresses the major performance and accountability challenges
facing the Environmental Protection Agency (EPA) as it seeks to meet its
mission of protecting human health and the environment. It includes a
summary of actions that EPA has taken and

that are under way to address these challenges. It also outlines further
actions that GAO believes are needed. This analysis should help the new
Congress and administration carry out their responsibilities and improve
government for the benefit of the American people.

This report is part of a special series, first issued in January 1999,
entitled the Performance and Accountability Series: Major Management
Challenges

and Program Risks. In that series, GAO advised the Congress that it planned
to reassess the methodologies and criteria used to determine which federal
government operations and functions should be highlighted and which should
be designated as “high risk.” GAO completed the assessment,
considered comments provided on a publicly available exposure draft, and
published its guidance document, Determining Performance and Accountability
Challenges and High Risks (GAO- 01- 159SP), in

November 2000. This 2001 Performance and Accountability Series contains
separate reports on 21 agencies- covering each cabinet department, most
major independent agencies, and the U. S. Postal Service. The series also
includes a governmentwide perspective on performance

and management challenges across the federal government. As a companion
volume to this series, GAO is issuing an update on those government
operations and programs that its work identified as “high risk”
because of either their greater vulnerabilities to waste, fraud, abuse, and
mismanagement or major challenges associated with their economy, efficiency,
or effectiveness.

David M. Walker Comptroller General of the United States

Overview The Environmental Protection Agency (EPA), with over 18, 000
employees and an annual budget of approximately $7 billion, funds diverse
regulatory, research, enforcement, and technical assistance programs and
activities that are directed toward controlling pollution of the air, land,
and water. The nation's annual costs to comply with environmental
regulations are substantial and have been growing, with costs estimated at
about $148 billion in 2000. We have identified the following performance and
accountability challenges that have hindered EPA in its efforts to establish
an integrated, cost- effective framework for meeting its critical mission of
protecting human health and the environment. Improve environmental and
performance

information management to set priorities and measure results

? Place greater emphasis on developing a comprehensive human capital
approach

? Strengthen working relationships with the states

Over the years, we have made recommendations to EPA to help the agency
address these challenges. EPA has concurred with most of our recommendations
and generally has made modest progress, but key challenges remain. A notable
exception is the Superfund program, in which EPA has made significant
progress addressing long- standing management challenges. We designated

the program as a high- risk area in 1990 because recurring management
problems heightened the federal government's financial risk, given the
potential for waste, fraud, abuse, and mismanagement. The agency has made
significant progress in addressing our recommendations and thus we are no
longer designating

the program as high risk. Nonetheless, our work shows that in the Superfund
program and in other areas, EPA is still confronted with challenges that
will require sustained attention by the agency's leaders.

Environmental and Responding to our recommendations and those of other
Performance

entities, EPA has given greater attention in recent years Information to
improving its management of information. For Management

example, in 1999, EPA reorganized the agency's information management
activities by establishing an Office of Environmental Information, which is
to serve as the focal point for agencywide information management. EPA
concurred with the recommendation we made in 1999 that it develop a
comprehensive information management strategy to ensure the completeness,
compatibility, and accuracy of data.

However, the agency has made slow progress in developing and implementing
such a strategy to address its long- standing and continuing information
management challenges.

Important gaps in information still exist concerning environmental
conditions and the effects of such conditions on human health. For example,
gaps in EPA's data on the quality of the nation's waters make it difficult
for the agency to effectively assess the condition of these waters and to
report on the results of its efforts to achieve water quality goals. Water
quality assessment data, which are collected by the states and provided to
EPA, are available for only 6 percent of the nation's shorelines, 19 percent
of its rivers and streams, and 40 percent of its lakes. In response to our
recommendations, EPA has taken steps toward making

greater use of other national and regional water quality assessments. These
efforts should close some gaps in the agency's data.

Furthermore, despite public concern about the health risks posed by
exposures to toxic chemicals, human exposure data are being collected for
only about 6 percent of the more than 1,450 potentially harmful chemicals we
recently reviewed. We recommended in fiscal year 2000 that EPA and the
Department of Health and Human Services develop a coordinated strategy for

the monitoring and reporting of human exposures to potentially toxic
chemicals. Both agencies agreed with our recommendation and stated that they
will work together to develop such a coordinated strategy. Obtaining and
managing environmental information has been a long- standing challenge for
EPA. Without a comprehensive picture of environmental conditions, it is
difficult for EPA to set risk- based priorities for its

programs, evaluate performance progress and environmental results, and
report on its accomplishments in a credible way as required by the
Government Performance and Results Act (GPRA). In preparing its strategic
and annual performance plans, EPA has not had the information it needs on

environmental conditions and changes over time to identify problem areas
that are emerging or that need additional regulatory actions or other
attention. According to EPA managers, the annual performance measures
established under GPRA are often selected on the basis of available data
that focus primarily on outputs rather than on environmental results, for
which

credible data are often lacking. Although output measures can provide
important information for EPA managers to use in managing their programs,
the agency recognizes that it needs to link more of its activities to
results and to develop additional outcome measures to assess progress in
protecting human health and the environment.

Moreover, as part of EPA's efforts to improve its information management, it
is very important that the agency continue strengthening its security over
its computerized information systems. We have recommended that it take a
number of steps to strengthen access controls associated with its major

computer operating systems and agencywide network, enhance computer incident
management efforts, and improve security program management and planning.
EPA concurred with our recommendations and informed us of related corrective
actions that, if properly implemented, can begin to address these

serious problems. However, without ongoing vigilance and top management
support and attention, these efforts may not have a lasting effect. EPA's
Human With a large and diverse staff spread across the nation, it Capital

is important for EPA to focus greater attention on strategic human capital
management to improve its performance and accountability in accomplishing
its critical and complex mission of protecting human health and the
environment. EPA's human capital problems can

be seen as part of a broader pattern of human capital shortcomings that have
eroded mission capabilities across the federal government. See our High-
Risk Series: An Update (GAO- 01- 263, January 2001) for a discussion of
human capital as a newly designated governmentwide high- risk area. To its
credit, the agency has recently initiated some improvements to its human
capital

activities. For example, EPA prepared an overall strategy in November 2000
to guide its human capital activities, which are being taken to align its
personnel policies with the mission and strategic goals and objectives
established for the agency under GPRA. EPA has not, however, linked these
actions to specific human

capital issues related to each of the agency's 10 strategic goals, although
it plans to do so in future updates to the strategic plan.

As part of its human capital strategy, EPA includes a specific strategy for
assessing its human capital needs but the agency has not yet implemented it.
The absence of a strategy has made it difficult for EPA to (1) link its
human capital investments with its strategic goals and objectives and (2)
determine the number of employees and types of competencies needed and the
appropriate deployment of its workforce across the organization. When the
agency does implement the strategy it will,

among other things, need to determine the number of employees and the
specific competencies they need and where they should be deployed among
various strategic goals and objectives, across program areas, and in various
parts of the country. Once the agency has made such specific determinations,
EPA's senior management will need to remain committed to and provide the
resources for ensuring that needed employees are recruited, developed, and
retained to meet the agency's goals and objectives. The agency will also
need to ensure that it collects and analyzes accurate data on the amount of
time being spent on various programs and

activities. Without such data, EPA cannot accurately determine the costs of
carrying out its strategic goals and objectives and ensure that its
workforce is being used in the most effective manner consistent with the

intent of GPRA and congressional appropriators. EPA- State Working EPA, as
authorized by various environmental statutes, Relationships has increasingly
delegated responsibilities for environmental programs to the states. EPA's
relationships with the states at times has been strained owing, in large
part, to fundamental disagreements over respective roles, the priorities
among state

environmental programs, and the appropriate extent of federal oversight.
EPA, the states, industry, and other key environmental stakeholders now
recognize that the

nation's complex future environmental challenges will require adopting
fundamentally different regulatory approaches that are more flexible and
less

administratively burdensome. EPA has initiated strategies with its state
partners and other stakeholders that it hopes will foster a climate
conducive to addressing past concerns. These strategies are designed to
create an atmosphere in which an improved environmental regulatory system
can be developed- one that is more focused on results and relies on a common
set of performance measures to help determine the agency's progress toward
meeting its strategic goals and objectives under GPRA. While EPA's recent
strategies appear to be positive steps, their effectiveness is not yet
known. EPA's primary vehicle for addressing long- standing problems between
the agency and the states is the National Environmental Performance
Partnership System (NEPPS). Although the program has yielded

some benefits most states we contacted for a recent review believed that
their investments in NEPPS outweighed the benefits and that the program had
not achieved its full potential. We recommended that EPA work with state
officials to initiate a joint evaluation process that (1) seeks agreement on
the key issues impeding progress in developing a more effective partnership
system and (2) develops mutually agreeable remedies for these issues. EPA
has deferred a formal evaluation and is instead focusing on making a number
of specific program improvements. While the agency has

taken positive steps, time will tell whether they have improved this
important program as intended. We also continue to believe that the agency
and the states should commit to conducting the type of joint evaluation
process we recommended. Consequently, we intend to continue monitoring the
program and believe that continued congressional oversight also remains

warranted. Superfund EPA has significantly improved its management of the
Superfund program- the agency's effort to clean up the

nation's abandoned hazardous waste sites- since we designated in 1990 that
the program was at high risk of fraud, waste, abuse, and mismanagement.
Specifically, consistent with our recommendations, the agency has made
significant progress in (1) allocating cleanup funds partly on the basis of
the risk that sites pose to human health and the environment, (2)
implementing a new process to recover more of its site cleanup costs from
those parties responsible for the contamination, and

(3) better controlling contractors' costs. We are no longer designating
Superfund as a high- risk area, but given that some program administration
challenges remain and uncertainty exists about the program's future policy
direction, we will continue monitoring policy and program administration
issues affecting the program.

Major Performance and Accountability Challenges

EPA has the critical and complex mission of implementing numerous federal
laws and regulations aimed at protecting human health and the environment.
To carry out its mission, the agency has an annual budget of approximately
$7 billion that supports a staff of over 18,000 employees in locations
across the country. This report summarizes our more recent findings on the
status and effectiveness of the agency's efforts to (1) improve its
management of information, (2) develop a comprehensive strategic human
capital framework, (3) strengthen its working relationships with its state
partners and other key environmental stakeholders to develop improved
approaches to environmental regulation, and (4) strengthen the

management of its Superfund program. These performance and management issues
that are confronting EPA are particularly complex in that they involve EPA,
the states, other environmental stakeholders, and a public that continues to
expect

improvements in environmental conditions. EPA Needs to EPA needs
comprehensive information on Improve environmental conditions to identify
problem areas that Environmental

are emerging and that require additional regulatory and Performance action
or some other attention. Such information is also

Information needed to inform agency decisionmakers, the Congress, Management
to

researchers, and the public of EPA's progress toward Set Priorities and
carrying out its mission of protecting human health and Measure the
environment. Absent sufficient environmental and performance information, it
is difficult for EPA to set Program Results risk- based priorities for its
programs, evaluate the success of its programs and activities, and report on
its accomplishments in a credible way as required by the Government
Performance and Results Act (GPRA).

In recent years, the agency has made strides in improving its data, better
informing the scientific community and general public of environmental and

public health risks, and measuring environmental improvements. However,
EPA's management still needs to make a long- term commitment to (1) filling
critical data gaps, (2) achieving compatibility among databases, (3)
establishing performance measures that are more results- oriented to assess
the effectiveness of its

programs and activities, and (4) strengthening the security of computerized
information systems. EPA needs a comprehensive information management
strategy to address these challenges.

Significant Gaps Although EPA and the states collect extensive amounts Exist
in

of environmental data, important gaps still exist on Environmental Data
environmental conditions and the effects of such conditions on human health.
Information obtained from monitoring environmental conditions and human

exposures to toxic pollutants is limited, and the human health and
ecological effects of many chemical pollutants are not well understood. Such
gaps in the data have hindered EPA's efforts to perform critical human
exposure and risk assessments, to consider risk in setting program
priorities, and to obtain a comprehensive understanding of environmental
conditions and changes over time. Information on the risks posed by
exposures to toxic chemicals is critical to EPA's decisionmaking. The data
needed to credibly assess these risks often do not exist. For example, in a
May 2000 report on environmental health data needs, we reported that human
exposure data were limited because data were being collected nationwide for
only 81 (or about 6 percent) of the 1, 456 potentially harmful chemicals we
reviewed. For the 476

chemicals that EPA identified as most in need of testing under the Toxic
Substances Control Act, only 10, or 2 percent, were being measured for human
exposure. We recently recommended that EPA and the Department of Health and
Human Services develop a coordinated

strategy for the monitoring and reporting of human

exposures to potentially toxic chemicals. Both agencies agreed with our
recommendation and have stated that they will work together to develop such
a coordinated

strategy. Important data gaps also exist in EPA's Integrated Risk
Information System, which is a database containing information on human
health effects that may result from exposure to chemicals in the
environment. For example, the database lacks basic data on the toxicity of
about two- thirds of the known hazardous air pollutants

and contains limited information on the ecological effects of pollutants.
Similarly, there are significant data gaps in EPA's National Water Quality
Inventory, the primary report on the condition of the nation's waters,
because only a small percentage of U. S. waters are assessed for water
quality and, importantly, only a limited number of assessments are based on
current, site- specific

monitoring information. Gaps in water quality information make it difficult
for EPA to effectively assess the condition of the nation's waters and to
report on the progress being made toward achieving established water quality
goals. As we noted in our

March 2000 report, the gaps are problematic because the inventory is used to
help agency officials make program management decisions, including
determining how certain Clean Water Act funds are to be allocated among the
states. According to the 1996 National Water Quality

Inventory (the latest report available at the time of our review),
assessment data were available for only 6 percent of the nation's
shorelines, 19 percent of its rivers and streams, and 40 percent of its
lakes. (See fig. 1).

Figure 1: Percentage of Waters Monitored, Evaluated, and Not Assessed

Percent 100

80 60 40 20

0 mi.)

and streams (mi.) Lakes (acres)

mi.) Oceanshorelines( Rivers Estuaries (sq. Types of waters

Waters not assessed Waters assessed using unspecified means Waters evaluated
Waters assessed using monitoring data

Source: 1996 National Water Quality Inventory.

To supplement its current information, we have recommended that EPA take
actions to more effectively use other available water quality data. In
response to our recommendation, EPA has taken some steps towards making
greater use of other national and regional water quality assessments.

EPA acknowledges the existence of numerous and significant data gaps and has
recently undertaken initiatives to address this problem. For example, the
agency launched the High Production Volume Challenge Program in October
1998, which asked chemical companies to voluntarily generate data on the
effects of the chemicals they manufacture or import. As of June 2000, over
400 companies had agreed that before the end

of 2005 they will release basic hazard data on over 2, 000 of 2, 800 high-
production- volume chemicals- those that are manufactured or imported into
the United States in amounts equal to or greater than 1 million pounds per
year. Nonetheless, EPA's efforts to collect better data have been hampered
by various factors, including the likely cost of meeting the agency's
information needs. Because important decisions need to be made about how
best to fill the agency's critical data gaps, we recommended in a September
1999 report that EPA develop a strategy to set priorities for filling such
gaps and identify the related milestones and needed resources. EPA agreed
with our

recommendation, but its progress has been slow. Currently, the agency is in
the initial phase of developing such a strategy.

Incompatible Data EPA's data management system is outmoded in many Systems
Limit the ways, including having separately designed databases Usefulness of
that are generally not technically compatible. This lack Environmental Data

of compatibility has made it difficult for EPA to aggregate data to present
comprehensive information on chemicals, industrial sectors, localities, and
environmental conditions and trends. EPA recognizes the importance of making
the databases compatible with each other and with those of its state
partners. For example, the agency has a major initiative under way to
standardize basic data elements so that information contained in EPA and
state databases can be combined

to present a more comprehensive picture of environmental conditions and
results. EPA officials also see data standardization as a way to reduce the
reporting burden for states and industry by enabling more integrated, and
thus more efficient, reporting of information. The agency has agreed with a
recommendation we made in a September 1999 report that it coordinate its
data standardization efforts with the states, federal agencies, and other
organizations that maintain major environmental databases. In fiscal year
2000, EPA and the states created the Environmental Data Standards Council,
comprising EPA and state information managers, to work cooperatively to
promote more rapid work on developing data standards.

EPA officials believe that the current effort to gain compatibility with
state agencies is an initial step in meeting EPA's goal of complete data
integration. Several initiatives are under way to develop standards for
selected elements in agency databases, and EPA anticipates implementing six
newly approved standards across 13 major agency databases by fiscal year
2003.

EPA recognizes that its current data improvement efforts are only a first
step towards its goal of full integration. For example, EPA has focused
primarily on

the compatibility of its data with those of state environmental agencies,
rather than with the data of other federal agencies and nongovernmental
sources. In a May 2000 report, we stated that improved collaboration among
federal agencies in meeting the needs for human exposure data is essential
because (1) individual agencies have different capacities and skills and (2)
separate attempts have fallen short of supporting the large efforts that are
needed. Along these

lines, EPA's Science Advisory Board, created by the Congress to provide the
agency with external scientific advice, recommended that EPA do more to link
its databases with external sources, noting that “answering many
health- related questions frequently requires

linking environmental data with census, cancer, or birth registry data or
other data systems (such as water distribution maps) to determine whether
there is a relationship between the environmental measures and
health.” Although EPA officials agree on the importance of linking the
agency's databases with those of other agencies, they stated that efforts
have been limited by resource constraints and a lack of statutory authority
to require other agencies to collect and report data using

formats compatible with those used by EPA. Data Limitations

For over a decade, internal and external studies have Hinder called for EPA
to “manage for environmental results” as Development of a way to
improve and better account for its

Outcome- Oriented performance. As we have pointed out, developing
Performance

effective environmental measures is important because Measures they can help
in (1) informing decisionmakers, researchers, the Congress, and the public
about

environmental conditions; (2) assessing the potential risks posed by
pollution and contamination; (3) assessing the extent to which EPA's
programs contribute to environmental improvements; and (4) setting

program priorities, planning, and budgeting. Our analyses show that most of
EPA's performance measures focus on outputs, such as the number of
environmental standards the agency establishes. (See fig. 2). These types of
activity- based output measures

can provide important information for agency managers to use in managing
their programs. Nonetheless, EPA recognizes that it needs to link more of
its daily program activities to results and to develop additional outcome
measures that can be used to assess the agency's longterm progress towards
meeting its mission of protecting human health and the environment.

Figure 2: Percentage of EPA's Output and Outcome Performance Measures for
Fiscal Year 2000

Output measures Outcome measures

Establish standards

19%

Reduce pesticide for hazardous levels

Outcome poisonings by of lead in paint, dust,

measures 20 percent

and soil Reduce emissions Issue report

of toxic air by summarizing the

81%

5 percent results of two

Output additional evaluations

measures 91 percent of the

for arsenic control population served

by community water Produce report on

systems will receive the number of civil

drinking water that and criminal

has not violated enforcement actions

any health- based initiated and concluded

standards

Source: GAO's analysis of EPA data.

According to agency officials, getting the data to measure results remains
EPA's biggest challenge in developing more outcome- oriented performance
goals and measures- especially since EPA must rely heavily on its state
partners and regulated entities to collect and provide much of the data
required to measure environmental outcomes. According to EPA managers, the
selection of annual performance measures established under GPRA is often
based on available data that focus primarily on outputs rather than on

environmental results, for which credible data are often lacking. Although
output measures can provide important information for EPA managers to use in
managing their programs, the agency recognizes that it needs to link more of
its activities to results and to develop additional outcome measures to
assess

progress in protecting human health and the environment.

Data gaps have made it difficult to link program activities with changes in
environmental conditions, and the lack of standardized data collection and
analysis methods has made it hard to aggregate data to determine outcomes.
For example, the states do not all use the same survey methods and criteria
to rate their water quality, and these inconsistencies make it difficult to
develop national performance goals and measures.

EPA officials recognize the importance of addressing such problems. They
said that developing data on environmental results will be a major part of
the agency's evolving efforts to overhaul how it collects, manages, and
disseminates information. Recently, the agency has taken actions that, in
the long run, should strengthen its ability to develop resultsoriented
measures. For example, EPA is developing processes and strategies to improve
the quality of performance measures and link the activities of program

offices with environmental results. Nonetheless, notable challenges remain.
Considerable resources and expertise will be needed to (1) identify and test
the

results- oriented performance measures that are needed and (2) gather and
analyze the data. In addition, EPA will need to work effectively with the
states and regulated entities to balance the demand for more data with
efforts to reduce the reporting burden. Moreover, it will be difficult to
assess the progress being made toward annual goals and measures because the
long- term nature of environmental programs means that the programs may not
yield measurable results for many years into the

future. EPA Needs to

In addition to the above critical information Strengthen Its

management challenges, EPA's management of its Information information
security is an area needing considerable Security Program

improvement. Our recent work identified fundamental computer security
weaknesses that have placed EPA's data and operations at significant risk of
tampering,

disruption, and inappropriate disclosure. For example, we found that the
agency's security program planning and management was largely a paper
exercise that had done little to substantively identify, evaluate, and
mitigate risks to EPA's data and systems. In addition, our tests of
computer- based controls identified widespread weaknesses associated with
EPA's operating systems

and agencywide computer network that support most of its mission- related
and financial operations. Of particular concern, many of the most serious
weaknesses we identified- those related to inadequate protection from
intrusion via the Internet and poor security planning- had been reported in
1997 by the agency's Inspector General (IG). The IG designated computer
security a material weakness in a March 2000 report. In our July 2000 report
on EPA's information security program, we recommended that the agency take a

number of steps to strengthen access controls associated with its major
computer operating systems and agencywide network, enhance computer incident
management efforts, and improve security program

management and planning. The agency concurred with our recommendations and
informed us of related corrective actions that, if properly implemented, can
begin to address these serious problems. For example, agency officials told
us that steps had been taken to strengthen its access controls, enhance its
intrusion detection capabilities, and improve its information

security management structure. Although it is too soon to draw conclusions
on the effectiveness of the steps taken or planned by EPA, the actions
described represent a comprehensive approach to improving the agency's
information security program. Nevertheless, sustaining improvements will
require ongoing vigilance

and top management support and leadership attention. Thus, we are concerned
that, unless EPA institutes fundamental changes in the way it manages
security, these efforts may not have a lasting effect.

EPA Needs a In 1999, EPA established an Office of Environmental

Comprehensive Information to function as the focal point for Information
agencywide information management. The office's Management functions include
integrating and coordinating the data Strategy

collected by the agency's diverse information systems and ensuring that EPA
has the data it needs to manage for results. However, EPA has made limited
progress in

developing a comprehensive information management strategy to ensure the
completeness, compatibility, and accuracy of data. The development of a
long- term strategy would provide the agency's managers and the Congress
with what is currently missing- the information they need to make the best
decisions on the

costs, benefits, and trade- offs involved in using scarce resources to meet
critical information requirements. We recommended in September 1999 that the
agency develop a comprehensive strategy that includes (1) establishing
milestones and identifying resources needed to fill key data gaps, (2)
identifying and developing necessary data standards, and (3)

coordinating its data standardization efforts with other federal agencies,
the states, and other entities. EPA concurred with our recommendation but
has made limited progress toward developing and implementing a comprehensive
strategy. Although the agency does not yet have a comprehensive plan, it
told us that it recently completed a plan for its new Information
Integration

Initiative. Through this initiative, EPA intends to develop a national
network that helps facilitate the exchange of environmental information with
the states and other

stakeholders. EPA intends to eventually incorporate this initiative into its
overall information plan, the first stage of which will cover broad options
for managing information over the next several years. As of December 2000,
EPA had not completed this stage of the agencywide information management
plan as it had originally anticipated. Because EPA has long- standing and
continuing challenges in how it manages

environmental information, this remains a key area requiring the continued
monitoring of the status and results of EPA's evolving initiatives. EPA
Needs to Effective alignment and management of an Place Greater
organization's employees- its human capital- are

Emphasis on essential for achieving the highest level of performance

Developing and accountability. Human capital planning must be a
Comprehensive treated as an integral aspect of an organization's overall
Human Capital

performance management process because human Approach

capital policies and practices affect an agency's ability to effectively
carry out management functions, including strategic planning and budget
formulation and execution, that are critical to meeting the agency's
mission. EPA, much like other federal agencies, has historically given
insufficient attention to strategically managing its human capital. With an
aging workforce that has grown in recent years to over 18, 000 employees,

it is important for EPA to align its human capital policies and practices to
best support its mission and help meet its strategic goals and objectives.

EPA acknowledges the importance of better managing its human capital and has
recently developed an agencywide human capital strategy. In the absence of
such a strategy, it has been difficult for EPA to (1) link its human capital
investments with its strategic goals and objectives and (2) determine the
number of employees and types of competencies needed and the

appropriate deployment of its workforce across the organization. EPA will
face management and performance challenges as it strives to ensure that its

people are aligned to accomplish its mission and strategic goals and
objectives.

EPA Needs to Better EPA has not given sufficient attention to aligning its

Link Its Human human capital policies and practices to best support its

Capital Efforts With strategic goals and objectives. Consequently, the
agency

Its Strategic Plan cannot be certain that its investments in human capital

are appropriate. EPA's human capital planning efforts, like those of other
federal agencies, have been a relatively weak link in the overall management
of the agency. Moreover, EPA's strategic plan and its annual performance
plans have generally provided little information on how EPA plans to
strategically manage its human capital. However, the agency's most recent
strategic plan, issued in September 2000, acknowledges that proactively

managing the agency's human capital must be a priority and that the agency's
approaches will be critical to achieving its 10 strategic goals and
improving program outcomes to better protect human health and the
environment. In reviewing the agency's latest plan, we

found that it includes more detailed information on human capital under its
“Effective Management” strategic goal. Under this goal, EPA
states that managing its human capital will be a key priority for the agency
to develop and retain the diverse, highly skilled workforce it needs to
carry out its mission and that it will work hard to attract and retain a
skilled workforce through such initiatives as workforce planning and
training. The additional information provided under this goal is useful.
However, the plan would be more useful if it contained a thorough discussion
of human capital initiatives as they relate to meeting the plan's nine other
strategic goals and their associated objectives, including how various human
capital activities will contribute toward achieving clean air, clean and
safe water, safe food, and pollution prevention. In November 2000, EPA
issued a comprehensive strategy for managing human capital to provide the
necessary linkage to the agency's overall strategic goals and

objectives. We noted that the strategy contained several useful components
indicating that the agency is moving in the right direction. For example,
the strategy includes

information on the agency's (1) human capital vision, values, and strategic
goals and (2) strategies and action steps for achieving the strategic goals.
Although these are positive features, the strategy did not contain
information on how the action steps would address

specific human capital issues related to each of EPA's 10 strategic goals
under GPRA. EPA officials told us that future updates to the strategic plan
will integrate human capital strategies for achieving agency goals and
objectives.

EPA Needs to Effective implementation of results- oriented Implement a

management, as envisioned by GPRA, hinges on senior Workforce Strategy
managers' willingness and ability to strategically manage all of an agency's
resources- including human

capital- to achieve its mission and goals. Specifically, this includes (1)
identifying current and future competencies needed to meet current and
future needs and any gaps, (2) developing a workforce action plan for
addressing any identified gaps or surpluses in the number or competencies of
the existing workforce, and

(3) monitoring and evaluating the workforce planning actions that are taken.
EPA's November 2000 comprehensive strategy for managing human capital
includes a specific strategy for assessing its human capital needs, but the
agency has not yet implemented it.

The importance of such a strategy is underscored by the fact that during the
past decade, when most federal agencies reduced their staffing, EPA's
workforce grew from 15,277 in fiscal year 1990 to 18, 100 in fiscal year
2000, an increase of about 18 percent. The growth in EPA's personnel levels
during this period has been accompanied by substantial changes in the roles
and responsibilities of the agency and its state partners. For example,
EPA's responsibilities increased with new

legislation, including major amendments to the Clean Air Act, the Safe
Drinking Water Act, and the Food Quality Protection Act. At the same time,
EPA, as authorized by federal statutes, was delegating significantly more
responsibility to the states for

carrying out federal environmental programs, and the states were responding
by expanding their own workforces to accommodate these increased
responsibilities. (See fig. 3).

Figure 3: Staff Growth in EPA and State Environmental Agencies, 1990- 2000

80,000 Number of staff years

49% increase 70,000

60,000 50,000 40,000 30,000

18% increase 20,000

10,000 0

EPA States

1990 2000

Source: GAO's analysis of EPA and state data.

Because EPA does not have a system in place to assess its human capital
requirements and to allocate resources

accordingly, the allocations made to its headquarters and regional offices
are based primarily on the number of staff years that were allocated in
previous years.

However, we believe that an approach based on historical data may not
accurately reflect the conditions that EPA faces today and is likely to face
in the future. For example, over the past decade, technological changes have
made a major impact on the skills and

expertise needed to carry out federal programs. In addition, changes have
occurred in EPA's regional environmental responsibilities as states have
accepted more responsibility for the day- to- day implementation of federal
environmental statutes. For example, in 1993, only eight states had accepted
responsibility for implementing provisions of the Safe Drinking Water Act.
By 1998, 36 states had done so. Such changes in responsibilities may reduce
EPA's activities in some areas, such as carrying out inspections, but may in
turn create the need for additional people and competencies in other areas,
such as providing technical assistance

and reviewing and measuring the effectiveness of state programs.

The need for taking a more strategic approach to managing EPA's human
capital is further supported by an analysis of the age of the agency's
workforce. For example, our analysis of EPA's data shows that approximately
29 percent of the agency's employees are either currently eligible for
retirement or will become eligible in the next few years. (See fig. 4).

Figure 4: Age Distribution of EPA Employees, as of May 1999

50- 60+ years

? 29% 34% 40- 49 years

9%

? 28%? 30- 39 years Under 20- 29 years

Source: GAO's analysis of EPA's most recent data.

Despite the shift in responsibility from EPA to the states and changes in
the size and age of its workforce, EPA has given limited sustained attention
to workforce planning. As a result, EPA lacks assurance that it can carry
out its mission and achieve its strategic goals and objectives. For example,
EPA has not been able to make fully informed decisions during the
preparation of its

annual budget requests because it has not had the information needed to
determine how many people are necessary to implement its strategic goals and

objectives. Nor can EPA determine whether it has any excesses or gaps in
needed competencies within its various headquarters and field components.
EPA recently completed a study that enabled the agency to (1) develop a
workforce profile identifying the general competencies, such as
communication and computer skills, of the people employed by the agency and
(2)

estimate what competencies it would need in the future under various
scenarios. Using this study, EPA identified the competencies it believes are
vital and difficult to obtain and maintain. However, the study was not
designed to determine how many employees need specific competencies or how
employees should be deployed among various strategic goals and objectives,
across program areas, and in various parts of the country. Once the agency
has made such specific determinations, EPA's senior management will need to
remain committed to and provide the resources for ensuring that needed
employees are recruited, developed, and retained to meet the agency's goals
and objectives. Furthermore, as part of its workforce strategy, EPA will
need to ensure that it collects and analyzes accurate data on the amount of
time employees spend on various programs and

activities. Without such data, EPA cannot accurately determine the costs of
carrying out its strategic goals and objectives and ensure that its
workforce is being used in the most effective manner consistent with the

intent of GPRA and congressional appropriators. Clearly, substantial
challenges remain for EPA in terms of designing, implementing, and
maintaining a flexible, results- oriented human capital management approach
that enables the agency to maximize the value of its

people to effectively accomplish its overall mission. Because overcoming
these obstacles is of such great importance to the effective management of
the agency, we will continue to monitor EPA's efforts. Good Working

A key aspect of EPA's performance management Relationships With involves
working cooperatively with its state partners in the States Remains managing
environmental programs. Cultivating strong a Challenge for relationships
with its state partners is especially EPA important for EPA because, as
authorized by

environmental statutes, the agency has delegated to the states the
responsibility for day- to- day implementation of most federal environmental
programs. However, EPA's working relationships with states has often been
strained by fundamental disagreements over respective roles, priorities
among state environmental programs, and the appropriate degree of federal
oversight. Some problems in the current jointly managed EPA- state

environmental regulatory system have been particularly difficult to resolve.
Facing pressures to develop a results- oriented approach, EPA is pursuing
initiatives that include the National Environmental Performance Partnership
System, which is focused on using environmental data, jointly setting
priorities between states and their respective EPA regions, and establishing
results- oriented goals and measures while providing states with needed
flexibility.

Cooperation Has More than a decade ago, we reported that states wanted
Improved, but greater flexibility to tailor programs to meet local needs,

Difficulties Remain opportunities to participate in decisions affecting

implementation, and EPA's trust in their ability to make day- to- day
decisions. More recently, in 1995, we found that financial constraints were
impeding states' efforts to perform key functions such as monitoring
environmental quality, setting standards, issuing permits, and enforcing
compliance. Other factors

affecting EPA's relationships with states included states' concerns that the
agency had been inconsistent in its oversight across regions, had sometimes
micromanaged state programs, and had not provided sufficient technical
support. Since then, although difficulties continued, we noted instances of
cooperation that resulted in more effective

and efficient environmental protection. For example, in April 1997, we
obtained information on five states with experience leading cleanups of
contaminated Superfund hazardous waste sites. Critical factors affecting a
state's

ability to successfully lead cleanups included (1) whether EPA and the state
had forged a constructive and efficient relationship with a clear division
of responsibility and (2) an appropriate level of EPA oversight. EPA and the
state of Washington, for instance, signed an agreement that reduced
conflicts and duplication of efforts.

Nonetheless, problems continue to affect EPA's working relationships with
states and the effectiveness of jointly administered programs. Enforcement
has been among the most problematic areas, with EPA and states frequently at
odds over the direction of state

enforcement programs and the degree of EPA oversight, with many states
fundamentally disagreeing with EPA on how to best ensure compliance by
regulated parties and the roles of federal and state authorities in ensuring
that compliance. In addition, the current joint EPA- state regulatory system
has proven to be costly and, at times, inflexible.

Although the environmental community generally recognizes that future
challenges are complex and will require fundamentally different approaches,
EPA and other stakeholders have disagreed on the direction of their
collective efforts to “reinvent” environmental regulation. In
acknowledging the need for fundamentally different regulatory approaches,
EPA, in March 1995,

announced a series of significant, high- priority actions to improve the
current regulatory system and to lay the groundwork for a new system of
environmental protection. Many reinvention efforts are consistent with
GPRA's goal of focusing on results and with the National Partnership for
Reinventing Government's past recommendations to achieve a more integrated,
costeffective approach to environmental protection. EPA officials have noted
that the initiatives are designed to, among other things, help achieve
better

environmental results through the use of innovative and flexible approaches
to environmental protection and make it easier for businesses to comply with
environmental laws by offering them compliance assistance and incentives to
prevent pollution at its source. Among EPA's initiatives are (1) the Common
Sense Initiative, termed the “centerpiece” of its reinvention
efforts, which seeks to identify innovative regulatory practices, and (2)
Project XL, which allows individual industrial facilities to test innovative
ways to achieve protection if they can demonstrate that proposed changes
will yield enhanced environmental

performance. Although EPA has been working with its state partners,
industry, and other stakeholders to develop and implement a series of
initiatives, obstacles have arisen.

For example, disagreements and misunderstandings have occurred over the role
of EPA and the states in developing and implementing reinvention projects,
how much flexibility the states would have in handling projects, and how
they were to obtain stakeholder

consensus. Environmental stakeholders also have expressed concerns over the
large number of complex and demanding initiatives that EPA has undertaken in
recent years. In addition, disagreement remains over whether the current
environmental statutes must be revised for reinvention to succeed. EPA
officials have recognized the importance of overcoming obstacles to the
agency's reinvention efforts and the need to work effectively with its
stakeholders, but many differences remain unresolved.

Opportunities Exist To address many of the long- standing challenges for
Strengthening

affecting the EPA- state relationship, EPA and its state Relationships and
partners have developed the National Environmental Establishing Performance
Partnership System (NEPPS). Launched in New Approaches for

1995, key components are the increased use of Environmental environmental
goals and indicators, state assessments Protection

of environmental and program performance, and the negotiation of performance
partnership agreements between EPA and the states to help in determining
such matters as (1) which problems will receive priority attention, (2) what
their respective roles will be, and (3) how the states' progress in
achieving clearly defined program objectives will be assessed. EPA points to
NEPPS as its primary vehicle for addressing long- standing problems,
including poor communication and concerns over micromanagement.

In our June 1999 report on the partnership system, we identified some
progress, noting that NEPPS has afforded some state participants a means of
getting buyin for innovative or unique projects and has served as a tool to
divide an often burdensome workload more efficiently between federal and
state regulators. In keeping with GPRA's intent to focus on results, EPA and
the states had structured the system to include a

common set of indicators (called “core performance measures”) to
help measure the effectiveness and success of the states' programs and to
provide a better understanding of whether programs are achieving their
intended results. Recently, we reported that EPA and the states had agreed
to a revised set of core performance

measures for fiscal year 2000 that are regarded as significantly improved
over measures negotiated in previous years.

Although initiatives sponsored under NEPPS have yielded some benefits,
challenges remain. Specifically, in our most recent examination, most state
officials held the view that (1) the benefits from their investments in

NEPPS should be greater and (2) the program has yet to achieve its full
potential. We recommended that EPA work with state officials to initiate a
joint evaluation process that seeks agreement on the key issues impeding
progress in developing a more effective partnership system and that develops
mutually agreeable remedies for these issues.

At the time our report was issued, EPA agreed that such a joint evaluation
process was warranted. Since that time, however, the agency and the states
have agreed to defer a formal joint evaluation and instead focus on making a
number of specific program improvements. These improvements resulted from a
joint informal evaluation of the program that occurred as part of a workshop
sponsored by EPA and the Environmental Council of the States in December
1999. Some of these efforts are addressed in EPA's September 2000 Strategic
Plan, which stipulates, for example, that EPA intends to enhance the program
by (1) developing guidance to make the NEPPS process more consistent
nationwide;

(2) integrating NEPPS concerns into EPA's internal processes, particularly
strategic planning and budgeting; and (3) improving the use of outcome-
based core performance measures in performance partnership agreements to
provide more comprehensive information on environmental protection efforts
nationwide. Agency officials also told us recently that the agency is in the
midst of completing a comprehensive workplan that is intended, among other
things, to ensure senior management's attention to the program and to
address NEPPS- related training needs. While these all appear to be positive
steps, time will tell whether they have their intended effect in improving
this important program. We also continue to believe that the agency and the
states should commit to conducting, at some point in the future, the type of
joint evaluation process we recommended in our June 1999 report.
Consequently, we intend to continue to monitor the program and believe

that continued congressional oversight also remains warranted. EPA Has Made

EPA's Superfund program, created by the Congress in Significant 1980, is
intended to help clean up the nation's tens of Progress in thousands of
abandoned hazardous waste sites,

Solving Some including many owned by the federal government. EPA

Superfund focuses on getting those parties responsible for Management

contamination to clean up sites or conducts cleanups Problems

itself using contractors and then seeks to recover its costs from the
responsible parties. Cleaning up the sites has proven to be far more
complicated and costly than anticipated. Cleanup costs could exceed $300
billion for

the federal government (including those costs incurred by EPA and the
departments of Defense and Energy), hundreds of billions of dollars for the
private sector. For over a decade, our work has identified recurring
problems that have put Superfund at risk. To address these problems, we
recommended that EPA (1) set funding priorities taking into account the
health and environmental risks posed by sites, (2) recover billions in
certain cleanup costs from parties responsible for contaminating sites, and
(3) better control contractors' costs. These collective problems led us,
starting in 1990,

to designate Superfund as a high- risk area, vulnerable to waste, fraud,
abuse, and mismanagement. EPA has taken steps to address many of our
recommendations and, as a result, has improved its management of the
program. Because of the agency's progress, we are no longer designating
Superfund as a high- risk area.

Table 1: EPA's Superfund Program Improvement

Setting funding priorities taking into account the health and environmental
risks posed by sites

Implementing a new process to help EPA recover more cleanup costs from
responsible parties

Taking steps to better control contractors' costs

Changes in the nature of the program also contributed to our decision to
remove Superfund's high- risk designation. Specifically, EPA has selected
the cleanup methods for most sites in the Superfund program and the cleanup
is under contract or completed. In addition, EPA has partnered more
extensively with the states to accomplish additional cleanups nationwide and
started working with the Congress to consider the program's future policy
direction. Given the uncertainty about its future policy direction, we will
continue monitoring policy and program administration issues affecting the
program.

EPA Is Using Risk to In response to our recommendations, EPA is now Set
Priorities working with the states to determine which of the remaining sites
in EPA's inventory posing relatively high risks should be considered for a
Superfund cleanup. In September 2000, EPA officials reported that the agency

had taken action in response to our recommendations on this issue, including
(1) reaching agreement with the states on who would be responsible for
assessing 88 percent of the 1, 789 backlogged sites we identified as

posing a potentially significant risk and (2) working to resolve the
management of the remaining sites. EPA has agreed to track those sites
undergoing state cleanups in its Superfund information management system,
which should help in determining whether the worst sites are being addressed
first.

The agency is also now considering health and environmental risks as factors
in setting its funding priorities for sites already in the Superfund
program.

Because EPA cannot fund cleanups of all the sites that are ready for a
cleanup remedy, the agency created the National Risk- Based Prioritization
Panel, composed of regional and headquarters cleanup managers, to help it
set funding priorities. The panel ranks all sites ready for construction
nationwide, taking into account health and environmental risks along with
other important project considerations, such as cost- effectiveness. EPA
then approves funding for projects on the basis of these rankings. Those
sites not selected in one year can

compete again for funding the following year. EPA Is Making The Superfund
program has posed a significant financial Progress in

risk to the government, in part because EPA did not Recovering More formerly
charge responsible parties for certain portions Cleanup Costs of its costs
to operate the program. The agency excluded about $3 billion in indirect
costs for such items as personnel and facilities from its final settlements
with responsible parties. EPA has agreed with most of our recommendations to
use more complete and accurate data for its cost recovery settlements, which
should increase recoveries. For example, EPA adopted a new indirect cost
rate in October 2000 in response to a

governmentwide requirement to adopt new costaccounting standards. Using this
rate should help EPA to recoup a total of over $600 million in indirect
costs from responsible parties for cleanups currently awaiting final
settlement and, on average, about $100 million annually in future
settlements. EPA is also addressing our past concerns about the reliability
of its information and financial management systems, including eliminating
the time- consuming and inefficient process of manually entering some cost
data into its financial management system and using an electronic imaging
system to store and retrieve

documents. Its effort to link its financial accounting and management
information systems should also enable the agency to better track
unrecoverable costs and more easily generate related reports.

EPA has made progress in addressing our past concerns about cost recovery.
However, EPA does not agree with our recommendation that it better track the
amount of costs it actually has recovered compared with the amount that it
potentially could have recovered, determine the underlying factors for
differences in the amounts recovered each year, and identify any actions
needed to improve its cost recovery performance. As we noted, we believe
that because EPA does not systematically analyze the underlying reasons for
its recovery rate, it cannot effectively tell whether its cost recovery
performance reflects internal factors that it can control, such as poor cost
documentation or

inexperienced negotiators, or external factors, such as parties that cannot
afford to pay EPA for the cost of cleanups. EPA and the Department of
Justice have taken

the position that tracking such data across sites is not meaningful or
appropriate because each site has specific factors, such as the responsible
parties' ability to pay for cleanup costs, that determine the amount of
settlements. As we have pointed out, establishing performance measures to
better track the outcome of EPA's cost recovery efforts is consistent with
GPRA,

which calls for agencies to set measures to assess program performance. We
believe that a performance measure to track cost recovery outcomes could
serve as a useful indicator for EPA to identify any systemic problems it
might need to address.

EPA Has Made EPA spends about one- half of its annual Superfund Significant
Progress

budget of approximately $1. 5 billion on contractors to in Controlling help
clean up Superfund sites and to monitor cleanups Contractors' Costs

done by private parties for EPA. Consequently, it is important that the
agency pay particular attention to this

critical program management activity. In past work, we noted that EPA has
had difficulties controlling the costs of its contractors, finding that the
agency (1) relied too heavily on contractors' cost proposals to determine
the price for cleanup contracts, rather than developing its

own estimates of what contracted work should cost; (2) had a significant
backlog of contract audits, which increased the risk for fraud, waste, and
abuse by contractors; and (3) spent a higher proportion of its cleanup funds
on contractor support costs rather than on actual cleanup. EPA has taken
steps to address these long- standing

contract management challenges and to respond to our recommendations. First,
EPA has increased its use of independent cost estimates to negotiate better
contract

prices for the government. As we recommended, EPA asked the U. S. Army Corps
of Engineers to evaluate EPA's cost estimation process. In December 1999,
the Corps made a number of recommendations, most of which EPA is in the
process of implementing. These include (1) establishing a clear policy on
the importance of controlling contract costs, (2) completing an
Internetbased

cost- estimating guide by March 2001 that includes more details on the costs
of various types of cleanup activities, and (3) providing EPA staff with
more training on cost estimation. Although EPA is in the process of
implementing many of these recommendations, we will continue to monitor
EPA's progress in this area because it has not implemented all of its
planned actions. In addition, the effectiveness of some actions already
taken

remains unknown, including whether EPA can effectively monitor the success
of initiatives intended to prove the quality of its cost estimates.

Effective Superfund program management also requires the auditing of
contractors that conduct cleanup activities for EPA. Such audits serve as a
primary tool for deterring and detecting fraud, waste, and abuse by the
contractors. EPA and the Defense Contract Audit

Agency (DCAA) share the workload for auditing Superfund contracts. Under
this arrangement, EPA audits contractors that work exclusively for EPA, and
DCAA audits cleanup contractors that also work for other federal agencies
with cleanup responsibilities.

Although EPA and DCAA have had long- standing contract audit backlogs, our
recent reviews disclosed that both agencies have nearly eliminated their
backlogs and have improved the timeliness of their audits.

Finally, EPA has taken significant steps to address our concern that it was
paying contractors a high rate to cover their program support costs. One
major reason for

the high support costs has been that EPA had more contracts than available
work, but nevertheless continued to pay contractors for monthly overhead
costs. Thus, the agency was spending a higher portion of its funds on
overhead (such as personnel and facilities costs) rather than cleanups. As
of June 2000, Superfund

program support cost rates had decreased significantly. Only 5 of the 18
existing contracts had program support cost rates that exceeded EPA's goal
of 11 percent of total costs, ranging from 12 to 18 percent. The rates for
the remaining 13 contracts were well within EPA's goal, ranging from 1 to 11
percent. In contrast, during our 1998 review, 10 of 15 contracts exceeded
EPA's goal, with support costs ranging from 16 to 59 percent of total

contract cleanup costs. (See fig. 5).

Figure 5: Program Support Costs Compared With Cleanup Costs for Superfund
Contracts, September 1999 and June 2000

September 1998 June 2000 7% 15% Program support

costs

85% 93%

Cleanup costs

Source: GAO's analysis of EPA data.

EPA has lowered its program support costs by, among other things, reducing
the number of Superfund contracts. It is also implementing its Contracts
2000 strategy for building more contracting competition, increasing small
and minority business participation, and adopting new types of contracts,
such as

performance- based contracts. In September 2000, EPA officials told us that
the agency had developed a specific plan and associated milestones for
implementing its

contract strategy, in response to recommendations contained in our April
1999 report. Key Contact David G. Wood, Director

Natural Resources and Environment (202) 512- 3841 woodd@ gao. gov

Related GAO Products Environmental

Environmental Information: EPA Needs Better and Performance Information to
Manage Risks and Measure Results Information (GAO- 01- 97T, Oct. 3, 2000).
Management

Observations on the Environmental Protection Agency's Fiscal Year 1999
Performance Report and Fiscal Year 2001 Performance Plan (GAO/ RCED- 00-
203R, June 30, 2000). Toxic Chemicals: Long- Term Coordinated Strategy
Needed to Measure Exposures in Humans (GAO/ HEHS- 00- 80, May 2, 2000).

Managing for Results: EPA Faces Challenges in Developing Results- Oriented
Performance Goals and Measures (GAO/ RCED- 00- 77, Apr. 28, 2000).

Water Quality: Key EPA and State Decisions Limited by Inconsistent and
Incomplete Data (GAO/ RCED- 00- 54, Mar. 15, 2000). Information Security:
Fundamental Weaknesses Place EPA Data and Operations at Risk (GAO/ AIMD- 00-
215, July 6, 2000).

Environmental Information: EPA Is Taking Steps to Improve Information
Management, but Challenges Remain (GAO/ RCED- 99- 261, Sept. 17, 1999).
Environmental Information: Agencywide Policies and Procedures Are Needed for
EPA's Information Dissemination (GAO/ RCED- 98- 245, Sept. 24, 1998).

EPA's Human Human Capital: Observations on EPA's Efforts to Capital
Implement a Workforce Planning Strategy (GAO/ T- RCED- 00- 129, Mar. 23,
2000).

Human Capital: Key Principles from Nine Private Sector Organizations (GAO/
GGD- 00- 28, Jan. 31, 2000). Human Capital: A Self- Assessment Checklist for
Agency Leaders (GAO/ GGD- 99- 179, Sept. 1999).

EPAState Environmental Protection: More Consistency Needed Working Among EPA
Regions in Approach to Enforcement Relationships

(GAO/ RCED- 00- 108, June 2, 2000). Environmental Protection: Collaborative
EPA- State Effort Needed to Improve Performance Partnership System (GAO/ T-
RCED- 00- 163, May 2, 2000).

Environmental Protection: Collaborative EPA- State Effort Needed to Improve
New Performance Partnership System (GAO/ RCED- 99- 171, June 21, 1999).

Environmental Protection: EPA's and States' Efforts to Focus State
Enforcement Programs on Results (GAO/ RCED- 98- 113, May 27, 1998). EPA's
Regulatory

Environmental Protection: EPA's and States' Efforts to Reinvention
“Reinvent” Environmental Regulation (GAO/ T- RCED98- 33, Nov. 4,
1997).

Regulatory Reinvention: EPA's Common Sense Initiative Needs an Improved
Operating Framework and Progress Measures (GAO/ RCED- 97- 164, July 18,
1997). Environmental Protection: Challenges Facing EPA's Efforts to Reinvent
Environmental Regulation (GAO/ RCED- 97- 155, July 2, 1997).

Superfund Superfund: Progress Made by EPA and Other Federal Agencies to
Resolve Program Management Issues (GAO/ RCED- 99- 111, Apr. 29, 1999).

Hazardous Waste: Information on Potential Superfund Sites (GAO/ RCED- 99-
22, Nov. 30, 1998).

Hazardous Waste: Unaddressed Risks at Many Potential Superfund Sites (GAO/
RCED- 99- 8, Nov. 30, 1998).

Superfund: Analysis of Contractor Cleanup Spending (GAO/ RCED- 98- 221, Aug.
4, 1998).

Performance and Accountability Series

Major Management Challenges and Program Risks: A Governmentwide Perspective
(GAO- 01- 241)

Major Management Challenges and Program Risks: Department of Agriculture
(GAO- 01- 242)

Major Management Challenges and Program Risks: Department of Commerce (GAO-
01- 243)

Major Management Challenges and Program Risks: Department of Defense (GAO-
01- 244)

Major Management Challenges and Program Risks: Department of Education (GAO-
01- 245)

Major Management Challenges and Program Risks: Department of Energy (GAO-
01- 246)

Major Management Challenges and Program Risks: Department of Health and
Human Services (GAO- 01- 247)

Major Management Challenges and Program Risks: Department of Housing and
Urban Development (GAO- 01- 248)

Major Management Challenges and Program Risks: Department of the Interior
(GAO- 01- 249)

Major Management Challenges and Program Risks: Department of Justice (GAO-
01- 250)

Major Management Challenges and Program Risks: Department of Labor (GAO- 01-
251)

Major Management Challenges and Program Risks: Department of State (GAO- 01-
252)

Major Management Challenges and Program Risks: Department of Transportation
(GAO- 01- 253)

Major Management Challenges and Program Risks: Department of the Treasury
(GAO- 01- 254)

Major Management Challenges and Program Risks: Department of Veterans
Affairs (GAO- 01- 255)

Major Management Challenges and Program Risks: Agency for International
Development (GAO- 01- 256)

Major Management Challenges and Program Risks: Environmental Protection
Agency (GAO- 01- 257)

Major Management Challenges and Program Risks: National Aeronautics and
Space Administration (GAO- 01- 258)

Major Management Challenges and Program Risks: Nuclear Regulatory Commission
(GAO- 01- 259)

Major Management Challenges and Program Risks: Small Business Administration
(GAO- 01- 260)

Major Management Challenges and Program Risks: Social Security
Administration (GAO- 01- 261)

Major Management Challenges and Program Risks: U. S. Postal Service (GAO-
01- 262)

High- Risk Series: An Update (GAO- 01- 263)

GAO United States General Accounting Office

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Comptroller General of the United States

Page 3 GAO- 01- 257 EPA Challenges United States General Accounting Office

Washington, D. C. 20548

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Related GAO Products Page 44 GAO- 01- 257 EPA Challenges

Related GAO Products Page 45 GAO- 01- 257 EPA Challenges

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Performance and Accountability Series

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