Results Act: Observations on EPA's Strategic Plan

Published by the Government Accountability Office on 1997-11-12.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

        United States
GAO   _ General Accounting Office
        Washington, D.C. 20548

       Resources, Community,   and
       Economic Development    Division


        November 12, 1997

        The Honorable Carol M. Browner
        Environmental Protection Agency

        Subject: Results Act: Observations on EPA’s Strategic Plan

        Dear Ms. Brownen

        In response to congressional requests, we have reviewed your agency’s July 1,
        1997, draft strategic plan and the revised plan submitted to the Office of
        Management and Budget and the Congress on September 30, 1997. We
        provided our assessment of the draft plan in a July 199’7report.’ We also
        briefed congressional staff on the results of our review of the September 1997
        plan on October 15, 1997. This letter summa&es our observations.

        We believe that the Environmental Protection Agency (EPA) has made
        considerable progress in developing a strategic plan that can serve as an
        effective cornerstone for the agency’s implementation of the Government
        Performance and Results Act. The July 1997 draft plan provided a good
        indication of EPA’s planned direction and major efforts to achieve its mission.
        It also provided a basis for holding the agency accountable for achieving
        results. The September 1997 plan improves on the draft plan, notably in
        (1) adding sections on program evaluations used in preparing the plan and the
        relationship of the plan’s general goals to annual performance go&s,
        (2) describing the coordination of the plan with other federal agencies, and
        (3) expounding on the role of the states in implementing EPA’s programs.
        However, strategic planning is a contjmring process and further improvements
        could be made in future revisions or updates of the plan, for example, in
        continuing to work to make the strategic goals and objectives more results-
        oriented and measurable and to better consider the role of other agencies in

      ‘Results Act: Observations on EPA’s Draft Stratetic Plan (GAOKRCED-97-209R,
      July 30, 1997).
                                                    GAO/RCED-9%36R EPA’s Strategic Plan
                                                            . -

  achieving national environmental goals. (The enclosure discusses in more
  de&I our observations on both the July 1997 draft plan aud the September

  In addition to these observations, we would like to highlight two issues that
  we believe are critical to the credibility and success of the agency’s strategic
  planning process: (1) ensuring the availability of sufficient scienac and
  environmental data and (2) coordinating plans and activities with other
  agenciesthat have similar or crosscutting functions. While the strategic plan
  recognizes that further work in these areas is needed, the annual performance
  plans provide an opportunity to set out more speciiic actions and milestones
  to address these issues2

  EPA needs considerable scientific and environmental data on the state of the
  nation’s environment and on the health and ecological effects of pollution.
  These data are needed to identify and establish priorities and strategies for
  addressing health and environmental problems. They are also needed to
  assessthe impact of EPA’s programs and activities in carrying out these
  priorities and strategies, as expressed in the agency’s strategic goals and
  objectives3 As pointed out in our July 1997 report, EPA has collected much
  scientific and environmental information. However, many gaps exist, and the
  data are often difficult to compile because different collection methods have
  been used. Although addressing these problems could be costly, initiatives
  such as EPA’s new Center for Environmenta Information and Statistics and
  the agency’s plans to conduct statistical assessments of national
  environmental databases that it maintains should provide the mechanism to
  identify principal data needs and establish priorities for filling them. EPA’s
  annual performance plans could include specific actions to identify and fill the
  data needs, and future updates of the strategic plan could more explicitly
  reflect the agency’s longer-term objectives and strategies concerning data

  With regard to coordination with other federal agencies, an appendix to the
  September 1997 strategic plan identised a total of 25 agencies with activities

‘Under the Government Performance and Results Act, each agency is to also
prepare annual performance plans, beginning with fiscal year 1999. These plans
are to contain annud performance goals that must be related to the general
goals and objectives of the strategic plan, and identify performance indicators
that the agency will use to assess its progress.
3Mana,aingfor Results: EPA’s Efforts to hnnlement Needed Management
Svstemsand Processes (GAO/RCED-97-156,June 18, 1997).
   2                                             GAOLRCED-9%36R EPA’s Strategic Plan

                related to EPA’s efforts under one or more of its goals. .&cording to the
                appendix, EPA has titiated steps to begin working closely with those
                agencies with which it shares responsibility for setting standards and
                managing programs to improve human health and the environment. The
                appendix further states that these actions will help to establish long-term
                efforts to address any inconsistencies, confkts, or redundancies among
                federal programs. Annual performance plans could identify the actions to be
                taken to review crosscutting or similar functions with other agencies, and
                future revisions or updates to the strategic plan could report the results and
                any changes needed in EPA’s programs.

                We are providing copies of this report to the Members of Congress who
                requested our earlier reviews of the agency’s strategic plan: the Majority
                header, House of Representatives, and the Chairmen of the House Committees
                on the Budget, Government Reform and Oversight, and Appropriations. We
                are aIlso sending copies to the Chairmen of the Senate Committee on
                Environment and Public Works, the House Committee on Commerce, and the
                House Committee on Science. In addition, we are providing copies to the
                Ranking Minority Members of these Committees and to the Director, Office of
                Management and Budget. Copies are available to others on request.

                Please call me at (202) X2-6111 if you or your staff have any questions about
                this report.

                Sincerely yours,

    fret           er
                Director, Environmental Protectio
/                Issues


                3                                            GAOBCED-98-36X EPA’s Strategic Plan
                                                                      . -
ENCLOSURE I                                                                  ENCLOSURE I
                                                     _     S
                            STRATEGIC PLAN

   The following summarizes our observations on (1) the Environmental Protection
Agency’s (EPA) July 1, 1997,draft strategic plan; (2) the improvements that were made in
preparing the September 30,1991, plan; and (3) further improvements that could be made.


    EPA’s draft strategic plan contained four of the six elements required by the Results
Act: (1) a mission statement, (2) general goals and objectives, (3) approaches or
strategies to achieve the goals and objectives, and (4) an identification of key external
factors. For these four elements, we noted that the draft plan did not contain all of the
details suggested by Office of Management and Budget (OMB) Circular A-11 and/or that
other improvements could be made to increase the plan’s usefulness. The two elements
not included in the draft plan were (1) the relationship between the general goals and
objectives and the annual performance goals and (2) the program evaluations used in
developing the plan and a schedule for future evaluations. Although the draft plan
contained a section on program evaluation, the discussion focused on the role of
evaluation in assessingfuture results and provided general criteria for deciding which
evaluations to perform in the future.

   The draft strategic plan did not discuss interagency coordination for the crosscutting
programs, activities, or functions that are similar to those of other federal agencies. It is
important that the plan do so because EPA and other agencies carry out a number of
mission-related activities that are crosscutting or similar. Our July 30, 1997, report noted
that EPA had be,- taking steps to coordinate its plan with other agencies, such as the
Department of Energy and the National Aeronautics and Space Administration, to address
crosscutting programs and activities.

   The draft plan included actions to address major management challenges that we had
previously identified, such as ensuring the quality and completeness of scientific research.
However, it provided limited details on how these long-standing problems are to be


   EPA made changes in its strategic plan to make it more responsive to the specific
requirements of the Results Act, to improve its clarity, and to provide information on the
coordination of the plan with other federal agencies. In addition, the agency strengthened
the plan’s treatment of management problems by including several additional actions to
resolve them.

4                                                          GAO/RCED-9%36R EPA’s Strategic Plan
ENCLOSUREI                                                                    ENCLOSUREI
    In the September 30, 1997, version of its strategic plan, EPA added-the two elements
required by the- Results Act that were missing Tom the draft plan: (1) the relationship of
the general goals in the strategic plan to the performance goals to be included in the
annual performance plan and (2) the program evaluations used in developing its general
baoals and objectives. The issued plan also incorporates improvements in other elements
required by the Results Act. For example, the section identifying key external factors was
expanded to include additional factors, such as changes in producer and consumer
behavior, that could directly affect the achievement of the plan’s goals and objectives.
The mission statement was also revised to coincide more closely with the language of the

    EPA improved the clarity of its strategic plan in several ways. It added information
that explains how the agency’s responsibilities for human health and the environment
intersect with or support the work of other federal departments or agencies, such as the
Departments of the Interior and Health and Human Services. It also added information
that better describes the important role of the states as having primary responsibility for
implementing many day-today environmental program activities, such as issuing permits
and monitoring environmental conditions. In addition, EPA added statements to clarify
the relationship among certain components of its plan, that is, the goals and objectives,
guiding principles, and planned cross-agency program activities. Furthermore, an
addendum listing the agency’s potential authorities was revised to ident@ the actual
authorities by goal and objective.

    The information that EPA added on interagency coordination of the plan included the
major steps it took to coordinate with other agencies. The plan also identifies a total of
25 federal agencies with activities related to EPA’s efforts under one or more of its goals.
According to the plan, the actions taken to coordinate with other agencies on the plan
will help to establish long-term efforts to address any inconsistencies, conflicts, or
redundancies among federal programs, as identified in any future strategic plan and
annual performance plans.

    To better address management problems, EPA made changes to the plan concerning
its working relationship with the states, the quality and completeness of its science, and
financial management. The National Environmental Performance Partnership System was
developed by EPA and the states in 1995 as a more collaborative approach to
implementjrtg environmental programs. The plan now sets out the objectives of the
partnership system and idenaes how they will be accomplished. In addition, the plan
now makes conducting peer reviews and providing guidance on the science underlying
the agency’s decisions an objective under the “sound science”goal. As noted in our July
1997report, the use of peer review is an important means of ensuring the credibility of
the scientific and technical documents that the agency uses in its work. Furthermore,
EPA added a performance measure to the “effective management”goal dealing with the

5                                                          GAO/RCED-98-36R EPA’s Strategic Plan
ENCLOSURE I                                                                 ENCLOSUREI
need to successfully implement the Chief F5nancia.lOfficers Act and the Government
Management Reform Act. This performance measure will help ensur& that EPA addresses
financial management issues that resulted in the agency’s receiving a qualified opinion on
its tical year 1996 financial statements.


    Several revisions that we suggested in our previous report have not been made. Some
of these suggested revisions relate to improvements in aspects of the six elements
required by the Results Act, while others deal with further improvement in the treatment
of management and data problems and the effectiveness of the plan in conveying the
agency’s priorities.

   Although the plan provides a general methodology for selecting future program
evaluations and describes how they are to be used, it does not identify the general scope
and time frasnes of the evaluations, as encouraged by OMB’s guidance. In addition, as in
the draft plan, (1) some of the goals and objectives, such as those for effective
management, are not stated in quantifiable or measurable terms; (2) staffing skills and
resources are generally not discussed as part of the plan’s description of how goals and
objectives are to be achieved, and (3) because strategies are generally organized by goal
rather than objective, it is not always clear how specific strategies relate to specific
objectives. Moreover, future revisions or updates of the plan could further benefit from a
more detailed discussion of how other federal agencies and the states are to contribute to
individual goals and objectives.

   In future revisions or updates of the plan, EPA may also want to more explicitly
identify and discuss actions to resolve the management and data problems identified by
the agency and others because of their importance to the agencys operations and the
achievement of its goals and objectives. This more explicit treatment would improve the
credibility of the plan by demonstrating that the agency recognizes the signikance of
these problems and is committed to resolving them.

    As the strategic plan evolves over time, EPA could improve its effectiveness in
conveying the agency’s priorities. The large number of goals and objectives, coupled with
the guiding principles and planned cross-agency program actions, continue to make it
dii%cult to discern EPA’s priorities. To better convey its priorities, EPA could directly
relate the cross-agency programs to specific goals and objectives or further consolidate
its goals or objectives.


 6                                                        GAO/RCED-98-36R EPA’s Strategic Plan
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