oversight

Climate Change: Observations on EPA's April 1999 Climate Change Report

Published by the Government Accountability Office on 1999-07-14.

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

      United States
GAO   General Accounting
      Washington,
                            Of&e
                    D.C. 20548

      Resources, Communily,        and
      Economic Development         Division


      B-283052


      July 14,1999


      The Honorable Christopher S. Bond
      Chairman
      The Honorable Barbara A Mikulski
      Ranking Minority Member
      Subcommittee on VA, HUB, and
       Independent Agencies
      Committee on Appropriations
      United States Senate

      Subject:          Climate Change: Observations on EPA’s Anril1999 Climate Change
                        Reuort

      In a June 1998 report, the Senate Committee on Appropriations directed the
      Environmental Protection Agency (EPA) to prepare a report on its climate change
      activities. The Committee’s directive was included in its report on the bill that
      appropriated funds for the agency for fiscal year 1999.’ The Committee’s report also
      directed us to evaluate EPA’s report and to submit our report to the Committee within 90
      days of receiving it. A subsequent Senate colloquy restated and elaborated on the
      Committee’s directive.2

      The Committee report directed the agency to explain its plan for implementing the
      President’s October 1997 proposal on climate change, called the Climate Change
      Technology Initiative. That proposal, made 2 months prior to an international
      conference on climate change, resulted in an agreement called the Kyoto Protocol. The
      United States and certain other nations agreed in principle to limit their emissions of
      carbon dioxide and other so-called greenhouse gases, which are believed to contribute to
      global climate change. The protocol has not been submitted to the Senate for
      ratification. The protocol would amend an international agreement on climate change,
      which the Senate did ratify.

      As directed, we reviewed the agency’s report” to determine the extent to which it (1)
      provides a comprehensive explanation of the agency’s climate change programs for fiscal
      year 2000, (2) justifies requested increases in funding for that fiscal year, (3) explains

      ‘S. Rep. No. 105216, at 7475 (1998).

      ‘144 Cong. Rec. S8434(daily ed. July 17,1998) (statements of Senators Bond and Byrd).

      3EPA’s Climate Change Activities, Report to the Senate Appropriations Committee (Apr. 8,1999).


                                              GAOLRCED-99-235R     EPA’s April   1999 Climate   Change Report
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how the climate change activities are justified independently of the Kyoto Protocol, and
(4) includes performance measures and goals and similar elements, as would be required
by the Government Performance and Results Act of 1993 (the Results Act).

Results    in Brief

EPA’s report on its climate change programs is not comprehensive and provides little
information about its programs’ funding and expected results. The report covers seven
of the nine broad initiatives listed in EPA’s fiscal year 2000 budget justification for
climate change programs, which account for about $240 million. The report does not
discuss two broad initiatives, which account for about $23 million, or about 10 percent,
of EPA’s total request for climate change programs. According to an agency official, EPA
understood the Committee’s directive as relating only to programs that are part of the
Climate Change Technology Initiative and omitted the two broad initiatives that are not
part of the technology initiative. Whereas the directive was linked to the technology
initiative, the colloquy called for a “comprehensive explanation” of the agency’s
programs. Accordingly, we read the colloquy as seeking information on all of the
 agency’s climate change programs, not just those that are part of the technology
 initiative. Moreover, the report generally provides data on funding and expected results
 only for the broad initiatives but does not explain how the individual programs that make
 up the initiatives will contribute to the initiatives’ expected results. For example, the
 report discusses requested funding and expected results for the industry-sector initiative
 but not for the initiative’s nine individual programs. Finally, although EPA was directed
 in the colloquy to issue the report by the time it submitted its fiscal year 2000 budget
 justification (which was Feb. l), the report was not issued until April 8,1999, about 2
  months late.

EPA’s report does not provide justifications for the proposed funding increases for
individual climate change programs for fiscal year 2000. Instead, it provides
justifications only for the total funding level requested, and this for only four of the six
initiatives for which an increase was requested. (No funding for the seventh initiative
 was requested for fiscal year 2000.) For example, to justify its request for the
 transportation sector, the report estimates the benefits-in terms of reduced greenhouse
 gas emissions-expected from the total requested funding level of $61.9 million, but it
 does not distinguish between the benefits that were anticipated from continued funding
 at the previous year’s level of $31.75 million and the additional benefits anticipated from
 the requested increase of $30.15 million. For the other two of the six initiatives for which
 an increase was requested, the report does not provide estimates of the reductions in
  greenhouse gas emissions expected to result from the combined requested increase of
  $13.8 million or explain why there are no such estimates.

 EPA’s report explains that its climate change activities are justified by long-standing
 agency goals and objectives and are not intended to implement the December 1997 Kyoto
 Protocol. Specifically, the report explains that these activities are justified by an
 international convention on climate change that was ratified by the Senate in 1992 and by
 seven specific environmental laws that EPA implements.

 EPA’s report includes information on performance measures and goals and related
 information, which is similar to the information required by the Results Act. For


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example, the report identifies reductions in greenhouse gas emissions and other ways of
measuring performance and, for each measure, specifies a reduction goal for fiscal year
2000. The information on goals is genera3ly provided for the climate change activities as
a whole, with little information on the broad initiatives and no information on individual
programs. In addition, the report provides some information on the strategies and
resources needed to achieve these goals and little information on procedures to verify
and validate reported performance.

Background

Increasing emissions of carbon dioxide, methane, and other heat-trapping gases
generated by human activity are believed to contribute to global warming. These so-
called greenhouse gases have varied effects on the atmosphere, as measured by their
potential ability to raise the earth’s temperature (global warming) over a specified period
of time. To arrive at a common measure for the various gases, their potential for global
warming is applied to the volume of emissions. This measure can be expressed in terms
of “million metric tons of carbon equivalent.”

In 1992, the United Nations Framework Convention on Climate Change was signed by
 154 nations, including the United States. The Senate ratified the convention the same
year. The convention’s objective was to stabilize the concentration of greenhouse gases
in the atmosphere. Under the convention, developed countries agreed to try to return
their greenhouse gas emissions to 1990 levels by the year 2000. However, this goal was
not binding.

In 1993, EPA began a series of climate change programs that encourage businesses and
others to voluntarily reduce energy use and otherwise curb their emissions of
greenhouse gases. These programs now include the following, among others:

l   The Energy Star Buildings and Green Lights programs encourage improved energy
    efficiency in commercial and industrial buildings in the private sector.4

l   The Partnership for a New Generation of Vehicles involves seven federal agencies
    and an automobile industry research consortium in, among other things, developing
    automobiles with low emissions and 3 times the fuel efficiency of current comparable
    vehicles.

l   The Ruminant Livestock Efficiency Program aims to increase the efficiency of
    livestock production while decreasing the amount of methane produced as a by-
    product of digestion.

l   The Transportation Partners Program promotes and supports voluntary local
    programs that reduce greenhouse gas emissions from the transportation sector by
    improving transportation choices and efficiency.




‘?he Green Lights Program was merged into the Energy Star Buildings Program at the end of 1998. The EPA
report sometimes refers to them as separate programs.


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l        The Waste Wise Program works with businesses, government units, and other
         institutions to reduce municipal solid waste by limiting waste, recycling, and buying
         and manufacturing recycled products.

The 1992 convention went into effect in 1994. However, by 1995, the parties to the
convention realized that insufficient progress was being made towards its goals and
therefore decided to begin negotiations on a legally binding protocol. In October 1997, in
anticipation of an international conference in December, the President announced a
multiyear proposal, called the Climate Change Technoloa Initiative, which involves EPA
and other federal agencies in efforts to reduce emissions of greenhouse gases. In
December 1997, the parties to the convention reconvened in Kyoto, Japan, to approve
binding measures to reduce greenhouse gas emissions. The resultant Kyoto Protocol to
the convention-agreed to in principle by the United States and 37 other nations-would
 generally establish binding limits on emissions for the years 2008 through 2012 for
 developed countries. The United States has signed the protocol but not ratified it, which
 requires the advice and consent of the Senate.

    In June 1998, the Senate Committee on Appropriations directed EPA to prepare a
    detailed plan for implementing the President’s October 1997 proposal on climate change.
    The Committee directed that EPA’s report include an annual performance goal for the
    reduction of greenhouse gas emissions that has objective, quantifiable, and measurable
    target levels and provides substantial evidence on the effectiveness of implementing the
    President’s proposal. EPA was directed, in preparing the report, to comply with the
    letter and spirit of the Results Act and to submit the report to the Committee by
    December 31,1998. 5 In addition to restating and elaborating on the report’s objectives,
    as noted above, the colloquy allowed EPA more time to prepare its report. EPA was
     directed to issue its report by the time it submitted its fiscal year 2000 budget submission
     (which occurred on Feb. 1,1999).

    Report Is Not Comprehensive   and Provides
    Little Information at Program Level

    EPA’s report does not provide a comprehensive explanation of its climate change
    programs and provides little information on the funding and expected results of
    individual programs. The report covers only seven of the nine broad initiatives listed in
    the agency’s fiscal year 2000 budget justification for climate change programs. The two
    broad initiatives included in the budget submission but not in the April report are
    Climate Change Research ($22.8 million requested) and Partnership With Industrial and
    Other Countries ($0.4 million requested). These two initiatives account for about $23
    million, or 10 percent, of the agency’s total request for climate change programs.

    According to an EPA official, EPA understood the Committee’s directive as relating only
    to programs that are part of the Climate Change Technology Initiative and omitted the

     5The Congress enacted the Results Act to improve the management of federal programs, as well as their
     effectiveness and efficiency, by establishing a system under which agencies set goals for programs’
     performance and measure their results. While EPA’s climate change report is not required under the Results
     Act, we take the Committee’s directive to mean that EPA should have included the kind of information
     contained in plans that are required by the Results Act.



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other two initiatives because they are not considered part of that initiative. While the
Committee report links EPA’s report to the Climate Change Technology Initiative, the
colloquy that restated and elaborated on the Committee report does not do so. The
colloquy calls for a “comprehensive explanation” by EPA of its energy and environment
programs, which we took to mean EPA’s climate change programs.

Although EPA’s report provides narrative information on the programs’ rationales,
operations, and examples of successes, it provides little quantitative information on
funding and explanation of how the individual programs contribute to achieving the
initiatives’ expected results. The report provides information on funding and expected
results for only the six initiatives for which increased funding was sought, even though
some of these initiatives include numerous individual programs.

For example, the industry-sector initiative accounts for $55.6 million, or 26 percent, of
the fimds requested and is expected to provide 65 percent of the reductions in
greenhouse gas emissions. However, the report does not provide fiscal year 2000
information on the amount of funding requested and the expected accomplishments of
each of the nine individual programs that make up that initiative. These individual
programs cover a wide range of industries, including coal mining, livestock production,
banking, and aluminum production, and are aimed at reducing the emissions of various
greenhouse gases. According to an EPA official, EPA has historically presented only this
type of aggregated information in its budget justifications and Results Act performance
plans. Furthermore, EPA believed that presenting information at the program level
would make the report lengthy and unnecessarily detailed and thus more dii%cult for the
Congress and others to use.

When the report provides information about programs, that information is not well
integrated. For example, the report includes descriptions of 11 program groups or
programs, which include 16 identifiable programs. However, the report does not explain
how these 11 program groups or programs relate to the six initiatives around which the
report is generally organized. (Fig. 1 illustrates the six initiatives, as well as the 11
program groups or programs and the 16 individual programs.)




5                                GAO/RCED-99-235B   EPA’s April   1999 Climate   Change Report
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Figure 1: EPA’s Climate Change initiatives, Program Groups, and Programs, as Reflected in Its April
8 Report

                                                                                           6 Initiatives




“PFC’s are perfluorocarbons, unusually long-lived greenhouse gases.

Source: GAO’s illustration based on EPA’s April 8 report and discussions with EPA officials.

Finally, the information that is presented below the initiative level seems to be
inconsistent. For example, two chapters present details on EPA’s programs. The first
chapter, which is organized by the six initiatives, identifies 16 work areas. However,
these 16 work areas are often different from the 16 programs identified in the second
chapter. For example, the first chapter lists five work areas in the buildings sector: (1)
Energy Star Products, (2) Energy Star Buildings Label, (3) the Partnership for the
Advancement of Technology in Housing, (4) Federal Energy Efficiency, and (5) the
Million Solar Roofs Initiative. The second chapter’s presentation of activities in the
buildings sector also includes the two Energy Star efforts but not the other three efforts;
conversely, it lists the Green Lights Program, which is not listed in the first chapter.

Although in the colloquy EPA was directed to issue the report by the time it submitted its
fiscal year 2000 budget justification (which was Feb. l), the report was not issued until
April 8,1999. According to EPA, the report was late because of internal reviews and
coordination with the Office of Management and Budget and the Department of Energy.
Because the report was issued on April 8, it was not available to the Congress for the first.
2 months of the annual budget process, although it has been available for the balance of
the process.




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Justification      Provided for Total Funding
Requested       but Not for Fiscal Year 2000 Increases

EPA was directed to provide “justifications for funding increases,” and its report states
that it “provides a justification” for the fiscal year 2000 funding increase. However, we
found that, while the report provides information to justify the t@JaJamount requested
for fiscal year 2000, it does not provide information to justify the requested increase for
that year.

EPA requested an increase in funding for six of the seven initiatives covered by the
report but not for the seventh initiative. For four of these six initiatives, the report
provides information to explain the &t&l funding level requested for fiscal year 2000.
However, for the other two initiatives, $13.8 million is requested, but the report provides
no estimate of the benefits-in terms of reductions in greenhouse gas emissions or other
terms-from these two initiatives.

For fiscal year 2000, the report estimates that the requested funding level of $216.4
million will result in reduced greenhouse gas emissions of 58 million metric tons of
carbon equivalent. The report also estimates other accomplishments, such as reducing
nitrogen oxide emissions by more than 152,000 tons, U.S. energy consumption by more
than 59 billion kilowatt-hours, and consumers’ and businesses’ energy bills by $8 billion.

For reductions in greenhouse gas emissions, the report shows the following distribution
of the overall goal of 58 million metric tons among four of the six initiatives: buildings,
12.7 million metric tons; industry, 37.9 million metric tons; transportation, 5.7 million
metric tons; and state and local programs, 1.7 million metric tons. (According to EPA, it
provided these benefit estimates at the initiative level because the Committee report
specifically requested them.) However, the report does not provide an estimate for the
other two initiatives-carbon removal6 and international capacity building7-of the benefits
to be achieved, in terms of reduced greenhouse gas emissions, or explain why there are
no such estimates.

Even when the report provides an estimate of the total results expected from one of the
four initiatives, it does not provide an estimate of the additional benefits that would be
achieved by the proposed increase in funding for fiscal year 2000. For example, the
report estimates that EPA’s transportation programs will reduce emissions by 5.7 million
metric tons. However, the report does not estimate how much of the reduction is
expected to result from a continuation of the existing funding level of $31.75 million and
how much is expected to result from the requested funding increase of $30.15 million.*


%missions of greenhouse gases can be offset, to some extent, by the absorption, or removal, of carbon
dioxide by growing plants. The agency’s efforts include determinin g the amount of carbon dioxide absorbed
and developing incentives to increase carbon storage on agricultural and forest lands.

?he agency’s goal is to promote actions in developing countries that reduce greenhouse gas emissions.

&rhe report does not quantify the dollar amount of the requested funding changes by initiative. We
calculated the dollar amount of the change for each initiative, as well as the percentage change, and present
this information in enclosure I.



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The report does provide information on the benefits expected over a longer time period if
funding is increased. The report explains that the request for fiscal year 2000 is part of
the 5-year Climate Change Technology Initiative. The report also estimates that
increased funding for EPA’s programs would reduce greenhouse gas emissions by at
least 354 million metric tons of carbon equivalent over 10 years.

Climate Change Activities Justified
Overall but Not for Each Program

The report explains that EPA’s climate change programs are fuMling U.S. commitments
under the United Nations Framework Convention on Climate Change, ratified by the
Senate in 1992. Nevertheless, the report would have been more helpful if it had specified
the U.S. commitment and the extent to which that commitment has been fulfilled. The
commitment was to undertake measures to reduce greenhouse gas emissions to their
 1990 level by 2000. According to the most recent estimate, U.S. carbon emissions from
energy use were about 10 percent higher in 1998 than in 1990.’

The report also lists seven laws as the “primary statutory authorities” for its climate
change programs. Specifically, it cites the Clean Air Act, Clean Water Act, Federal
Technology Transfer Act, Global Climate Protection Act, Pollution Prevention Act,
National Environmental Policy Act, and Solid Waste Disposal Act. Because of the
diversity of the six initiatives and 16 programs, on the one hand, and the seven laws, on
the other hand, the report’s information would have been more useful if it had explained
which laws cover which activities.

Finally, the report states that most of the programs began prior to December 1997 and
that the others, which started after December 1997, are extensions of the earlier
programs. However, the report does not provide start dates for all programs. For
example, while the report states that the Partnership for a New Generation of Vehicles
was announced in 1993, it does not state when the Ruminant Livestock Efficiency
Program and the Transportation Partners Program began. By stating that “most” of the
programs began prior to December 1997 and omitting the start dates for some programs,
the report does not make clear which programs started after the Kyoto Protocol was
 agreed to.

 Report Provides Performance Measures               and
 Goals but Data Quality Is Unclear

 In preparing its report, EPA was directed to provide the types of information that would
 be required by the Results Act, which seeks to improve federal management by focusing
 on program results. Under the act, agencies are to prepare performance plans that
 clearly describe (1) annual performance goals and measures, (2) the strategies and
 resources to be used to achieve those goals, and (3) procedures to verify and validate
 reported performance. Accordingly, we reviewed EPA’s report to determine the extent
 to which it includes these components. At a general level, EPA’s report provides annual
 performance measures and goals and some information on the strategies and resources


 ?Freliminq data from Energy Information Administration, Emissions of Carbon from Enerpv Sources in the
 United States-1998 Flash Estimate (June 30, 1999).


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needed to achieve these goals, but it provides little information on procedures to verify
and validate reported performance.

Performance Measures and Goals

The report identifies six performance measures that EPA uses to gauge programs’
accomplishments and success, and it specifies a goal for fiscal year 2000 for each
measure. The measures and goals for the activities covered in the report are shown in
table 1.      ’
Table 1: Performance Measures and Goals for Climate Change Programs

Measure                                                         Fiscal year 2000 goal
Reduced greenhouse gas emissions           58 million metric tons of carbon equivalent
Reduced nitrogen oxide emissions                     More than 152,000 standard tons
Reduced sulfur dioxide emissions                                220,000 standard tons
Reduced energy consumption                          More than 59 billion kilowatt hours
Money saved on utility bills                                                  $8 billion
Number of participating organizations                                    Nearly 10,000

Source: EPA’s report.

For these six measures, the report also provides-for the programs as a whole--actual
results for fiscal years 1995 through 1998, as well as goals for fiscal years 1997 through
2000. These data establish trends over the 6-year period.

However, as noted above, the report generally does not explain how the six initiatives
will contribute to EPA’s fiscal year 2000 goals for these six measures. For greenhouse
gas emissions, but not for the other five goals cited above, the report explains how the
six initiatives will contribute. And, as noted above, the report provides information for
only four of the six initiatives.

Strategies and Resources

The report provides some information on the strategies and resources EPA will use to
achieve its performance goals in f=cal year 2000. With respect to strategies, the report
provides inconsistent descriptions of program operations, actions, and activities. In
some cases, EPA explains its strategy in clear terms. For example, the report says that in
the commercial buildings area, EPA will sign up an additional 2,000 small business and
school partners for its Energy Star Buildings Program. But in other cases, it is not clear
what specific actions or activities EPA will undertake to achieve its goals. For example,
in the transportation sector, the report states that EPA’s Transportation Partners
network will expand its existing efforts “through promoting the restoration of
communities, collaboration among neighboring communities, and expanded public
involvement.” In addition, the network will encourage “better transportation decisions
that help create more livable communities.” It is unclear what specific actions EPA will
take and how these actions will accomplish the stated objectives.

With respect to resources, the report provides, as noted earlier, information on the fiscal
year 1999 funding level and the fiscal year 2000 request for each of the seven initiatives.


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As shown in enclosure I, we calculated the changes in dollar amounts and the
corresponding percentage changes for the seven initiatives and found that, while the
total funding request represents an increase of 98 percent over the current fiscal year, the
change varies considerably by initiative. For example, EPA is seeking an increase of 40
percent for international capacity building; about 100 percent for the buildings and
transportation initiatives; and about 200 percent for the industry initiative. In terms of
amounts, EPA is seeking a total increase of about $107 million, ranging from $2.1 million
more for the state and local initiative to $41.3 million more for the buildings initiative.
Finally, EPA requested no fiscal year 2000 funds for research as part of the Climate
 Change Technology Initiative. This research effort received $10 million in fiscal year
 1999, but there is no explanation for this reduction.”

Checking Reported Performance

The report explains that the methods used to collect data and estimate programs’
impacts vary from program to program, and it identifies two such methods. For the most
part, EPA relies on reports from program participants and states that such reports are
reviewed for accuracy and compared with trend data. For other programs, EPA
calculates emissions reductions from industry reports of the volume of shipments of
certain equipment (such as photocopiers), the proportion of such equipment that
 embodies EPA-approved energy-saving features, and other information. However, the
report does not discuss in any detail the procedures used to verify and validate the
 measured values of actual performance and to ensure that its performance information is
 complete, accurate, consistent, and free of significant levels of error and bias.

Specifically, the report does not explain that the trends reported by program participants
may reflect factors other than EPA’s programs. For example, we noted in a 1997 report
that reductions reported by participants in the Green Lights Program, which encourages
energy conservation in buildings, could be due--in part-to other factorsl’ We noted
that there were substantial upgrades of commercial buildings even before the Green
Lights Program was well established, that electric utility companies had offered financial
incentives to install energy-efficient lighting, and that many of the program’s participants
were in the lighting business and presumably knew of the financial and other advantages
 of energy-efficient upgrades.


 “An EPA official said that the research activities that were shown as part of the Climate Change Technology
 Initiative in fiscal year 1999were consolidated with other climate change research activities for fiscal year
 2000.

 “See Global Warming: Information on the Results of Four of EPA’s Voluntarv Climate Change Prosrams
 (GAO/RCED-97-163,June 30,1997). We reiterated the concern in a 1998report for two reasons. First,
 according to EPA, the 2,500 participants in the Green Lights and Energy Star Buildings programs saved, on
 average, about $200,000each in 1997 as a result of their energy-saving actions. These savings are clearly an
 incentive-in addition to EPA’s programs-to take such actions. Second, as part of the Oct. 1997 climate
 change proposal, the President suggested that companies be rewarded for taking voluntary actions to reduce
 greenhouse gas emissions. Although the nature or value of these rewards was not specified, they could be
 yet another factor outside EPA’s programs that could encourage businesses and others to reduce then
  emissions. See Environmental Protection: EPA’s F’iscal Year 1999Budget Rearrest (GAOIRCED-98259R,
  Sept. 29,1998).




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An example illustrates the difficulty of attributing to an EPA program all the savings
reported by a program participant. As a “success story” of the Waste Wise Program, the
report states that Bank of America recycled 14,500 tons of office paper. (It takes less
energy to recycle paper than to make new paper, thus saving energy and reducing
greenhouse gas emissions.) The report implies that the company’s recycling is due
entirely to EPA’s effort. However, according to a company official, the company began
its recycling efforts before EPA began the Waste Wise Program and would recycle its
paper even without the program. However, the official added that the program offers
valuable assistance to the company, such as information on new products and an e-mail
network, through which participating companies can share information on their
recycling efforts, and that there are few other sources of such information.
In commenting on our 1997 report, EPA said that it would study the issue of clearly
accounting for the programs’ impacts. According to EPA, two such studies-both
focusing on the buildings sector-are scheduled to be completed this fall.

Agency     Comments

We provided a draft of this report to EPA for review and comment. EPA disagreed with
four principal findings in the report, as discussed below. (Enc. II contains EPA’s
comments and our detailed responses.) Also, EPA provided technical suggestions, which
we incorporated as appropriate.

First, EPA said that its report is sufficiently comprehensive because it conforms to the
Senate Committee report’s directive to discuss the programs that make up the Climate
Change Technology Initiative. EPA’s explanation was already included in our draft
report. However, as we noted in our draft report, the subsequent Senate floor colloquy
did not limit the report’s scope in that way.= Instead, the colloquy called for Uamore
commehensive explanation by the EPA of the components of its energy and environment
programs” (emphasis added). Thus, in our opinion, limiting the report’s scope to the
programs that make up the technology initiative was not fully responsive to
congressional expectations. In fact, EPA chose to entitle its report, EPA’s Climate
Change Activities, which suggests a comprehensive scope. Because EPA limited its
report’s scope, the Committee did not receive information on climate change activities
for which EPA requested about $23 million for fiscal year 2000. Accordingly, we did not
change our report.

Second, EPA said that its report was sufficiently detailed because it has consistently
provided goals and accomplishments for climate change activities at the initiative level to
comply with the Government Performance and Results Act. As we noted, the colloquy
called for an explanation of “the comnonents of [EPA’s] energy and environment
programs” (emphasis added). Thus, in our opinion, reporting at the initiative level-
rather than at the level of the programs that make up these initiatives- was not sufficient
to meet the Committee’s needs. Moreover, by asking for this report, the Committee
indicated a desire for more detailed information than was included in EPA’s previous
reports at the initiative level. In addition, EPA states that it presented “detailed
descriptions of activities at the program level” in the final chapter of its report. We note


12Regardlessof the different views on this issue, the sufficiency of the information provided and the manner
of its presentation are matters for the Senate Appropriations Committee to decide.


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that the chapter describes the programs and some specific successes, but it does not
provide consistent information on the amount of funding requested for fiscal year 2000 or
expected program results. Accordingly, we did not change our report.

Third, EPA said that it provided appropriate information to justify its request for funding
increases. However, as we read EPA’s report and as we noted above, it discusses the
expected results from the entire amount requested, rather than the increase requested,
for fiscal year 2000. It does not provide information on the expected results from
continuing funding at the current level, as distinguished from the increase in expected
results from an increase in funding. Accordingly, we did not change our report.

Fourth, EPA questioned our finding that its report provided little information on the
methods it uses to assure the quality of data on program results. It stated that it has a
successful system for measuring performance, but it also stated that there are some
difficult analytical issues in evaluating the success of vohmtary programs and described
two current evaluations of its programs’ effectiveness. When these studies are
completed, EPA will be more certain of the success of its current measurement system.
By including such information in its report, EPA would have provided a fuller picture of
its efforts to assure the reliability of its reported results. We did not change our overaIl
characterization of EPA’s data quality efforts because these studies are not yet complete
and their impact on data quality is still unknown. We added information on the two
 current EPA studies in our report.

Scope and Methodology

To fulfill our objectives, we analyzed EPA’s April 8 report (which we received on Apr.
15), its justification of estimates for its fiscal year 2000 budget request, and other
documents, and we held discussions with EPA officials. We did not independently
validate EPA’s data We conducted our review from April through July 1999 in
accordance with generally accepted government auditing standards.



 We are sending copies of this report to the Honorable James T. Walsh, Chairman, and the
 Honorable Alan B. Mollohan, Ranking Minority Member, Subcommittee on VA, HUD, and
 Independent Agencies, House Committee on Appropriations; other interested Members
 of Congress; the Honorable Carol M. Browner, Adminiskator of EPA; and other
 interested parties. We will also make copies available to others upon request.




 12                                 GAO/RCED-99-235R   EPA’s April   1999 Climate   Change Report
     B-283052




     If you have any questions about this report, please contact me at (202) 512-6111. Key
     contributors to this report were David Marwick and James B. Mu&l.
:y--T&T&


     Peter I?. Guerrero
     Director, Environmental
      Protection Issues




     13                              GAO/RCED-99-235R   EPA’s April   1999 Climate   Change Report
ENCLOSURE I


                       FUNDING   FOR EPA’S CLIMATE             CHANGE        INITIATIVES

Dollars in thousands



initiative
                                                  I        Amount
                                                         enacted for
                                                                            Amount
                                                                         reauested for
                                                      fiscal year 1999 fisck year 2000
                                                                                             Amount of
                                                                                              increase
                                                                                             (decrease)
                                                                                                                increaw 1
                                                                                                               Percentage
                                                                                                                     ----c
                                                                                                               (decrease)
Buildings                                                      $38,800           $80,100
Transportation                                                   31,750           61,900
 industry                                                        18,600           55,600           37,oot
Carbon Removal                                                        __           3,400            n rnr
State and Local Climate Change                                    2,900            5,000
 international Capacity Building                                  7,400           10,400
 Climate Change Technology Initiative: Research                  10,000                 b
     Total                                                    $109.450          $216.400        $106.95(

“Cannot be computed.

bNofunding was requested.

Source: EPA’s data in the April 8 report for the amounts enacted and requested and our calculations based on
EPA’s data for the change in the amount of funding requested and the percentage change.




  14                                    GAO/RCED-99-235R       EPA’s April   1999 Climate Change Report
ENCLOSURE II

           COMMENTS FROM THE ENVIRONMENTAL PROTECTION AGENCY




                                UNITED STATES ENVIRONMENTAL  PROTECTION                                  AGENCY
                                             WASHINGTON, D.C. 20460




                                                                                                                                Off ICE OF
                                                                                                                            AIR AND RAOWION




       Mr. Peter F. Guenero
       Director                                                                              JUI 12 lggg
       Environmental Protection Issues
       U.S. General Accounting Office
       Washington, D.C. 20548

       Dear Mr. Guerrero:

               I appreciate the opportunity to review and comment on the draft GAO Report,
       Observations on EPA’s ADI% 1999 Climate Chanse Renort. EPA preparedthe April 1999
       Report in response to the Senatereport language (Senate Report 105216), as reiterated by the
       colloquy between Senators Byrd and Bond. I have one overarching concern about GAO’s ,
       analysis, which negates many of the conclusions in the report. My concern is that the report     See comment 1.
       construesthe Congressional directive to EPA much more broadly than is justified by the actual
       language of the Senate Report. It is disappointing that GAO criticizes EPA for not including
       information at a level of detail in EPA’s April 1999 report to Congressthat EPA believes was not
       actually requestedby the report language or by the colloquies. We discussedthis concern in our
       June 23 meeting.

               The Senatereport language states:
                      On October 22, 1997. the President announced a three-stage proposal on
                     climate change in anticipation of an international agreement to be negotiated 2
                     months later in Kyoto, Japan. With regard to programs pursued under the
                     President ‘sproposal, the Committee expectsthe EPA to COJnpIy with the letter
                     spirit of the Government Performance and Results Act (GPRA). The Committee
                     directs the Agency to provide the Committee with a detailed plan fo?
                     impiementing the President ‘sproposal. which would incIude an pe$onnance
                     goal for the reduction of greenhouse gasesthat has objective, quantifiable,
                     and measurable target levels. T%ep/an should provide substantial evidence
                      OJT the effectiveness of implementing the President 3 proposal in facilitating
                     compliance with binding greenhouse gas emissions reduction commitments
                     contained in the international agreements negotiated on behalf of the United
                     Stares. The Agency shall submit this plan to the Committeeby December 31,
                     1998. The GAO is direct to prepare a report that evaluates the Agenq’s
                     completed plan and submit its report to the Committee within POdays after
                     receipt of the Agency’s plan. (SenateReport 1OS-216)



                                                   Internet Address (URL)    l   httpYAvww.epa.gov
                     Recycledil?ecyclable   -Printed wlh Vegetable 08 Based inks on Recycled Paper   @tinimum25% Postmnsumer)




15                                            GAOLRCED-99-235R                    EPA’s April          1999 Climate         Change     Report
ENCLOSURE II




          EPA understands this language to be referring to the Climate Change Technology Initiative
          (CCTI) or the “President’s proposal” for action on climate change outlined by President Clinton
          in his October 22, 1997 speech. The report language did not ask the Agency to report on the
          broader category of “its climate change activities” as GAO statesin the first sentenceof their
          July draft report. In our April 8, 1999 report: we included ail of the information requestedby the
          committee in a comprehensive and organized fashion, and we provided this information at the
          level of detail outlined in GPRA.

                    In the report, as well as in the’2000 AmmaI Plan, EPA complied with the letter and the
           spirit.of the Government Performance and Results Act by providing detailed performance
           measuresfor each area of activity as outlined in GPRA, specifying requestedfunding levels,
          justifying requests for increased funding and ensuring that the performance information is
           complete and as accurate as possible.

               GAO has organized the draft report by four general comments. These four general
          comments and EPA’s responsesare provided below:

          I.     GAO states that the “Report is not comprehensive and Provides Little Information at
                 Program Level”

                  EPA believes the April 1999 Report provides comprehensive information regarding every
          EPA climate change initiative under the CCTI, as required by the GPRA, and also provides
          substantial program level information, even though such information was not necessaryto
          comply with the Congressional directive. EPA did not provide information about climate change
          researchbecauseit is not part of the President’s Proposal and therefore was not part of the
          Congressional request. EPA has provided, as requested, the funding level for each initiative
          (e.g. buildings, industry, etc.) and performance measuresfor each of the activities that will be
          undertaken, as well as detailed descriptions of activities to be undertakenwith additional
          funding. In the GAO Draft Report, GAO says that “the Environmental Protection Agency’s
          (EPA) report on its climate change programs is not comprehensive and provides little
          information about its programs’ funding and expected results.” EPA believes this statementis
          incorrect and, in the report, GAO has not identified the basis for this broad conclusion.

                   The Senate report language “directs the Agency to provide the Committee with a detailed
          plan for implementing the President’s Proposal, which would include an annual performance
          goal for the reduction of greenhousegasesthat has objective, quantifiable, and measurabletarget
          levels.” As GAO acknowledges later in the draft report, EPA’s report “provides performance
          measuresand goals” and the “climate change activities arejustified overall.” For the Climate
          Change Technology Initiative, EPA has consistently provided goals and accomplishmentsat the           See comment 2.
          initiative level, which is consistent with the GPR4 requirements. GAO’s criticisms that EPA
          does not present program by program contributions to the initiative 2000 goals is irrelevant to our
          compliance with the Congressional requirement, since these are not requirements under GPRA.
          Moreover, EPA does present detailed descriptions of activities at the program level in chapter 5.


                                                           2




 16                                   GAOLRCED-99-235R         EPA’s April    1999 Climate    Change Report
ENCLOSURE II




                         GAO also claimed that EPA did not justify Climate Change Researchas one of the broad
               initiatives. As statedearlier, EPA understandsthe report language to refer to the Climate Change
               Technology Initiative or the “President’s proposal” outlined by President Clinton in his October
               22, 1997 speech. Therefore, we do not believe that the report should have included Climate
               Research.

                      EPA’s interpretation of the language is a reasonable and straightfonvard interpretation of
               the report language,as further informed by the colloquy between SenatorsByrd and Bond.

               II.    Second,GAO statesthe “Justification Provided for Total Funding Requested,but not for
                      Fiscal Year 2000 Increases.”

                        GAO’s secondcomment of criticism is that EPA should have provided justification for
               the fiscal year 2000 funding increasesby identifying the greenhouse gasreductions that will          See comment 5
               occur in 2000 as a result of such increased funding. As discussed at the June 23rd meeting, EPA
               believes that measuring the greenhousegas reductions that will occur only in 2000 resulting from
               increasedfunding in 2000 would not provide any useful information that could help Congress or
               the public evaluate the benefits of the funding. It is unreasonable to expect programs of the type
               at issue here to produce significant greenhousegasreductions during the sameyear the initiative
               is developed and launched. For any new initiative it can take several months to complete the
               program design and begin signing up partners, and then depending upon the terms of the
               particular voluntary agreements,the partners may take many more months or years to implement
               the efficiency improvements that reduce emissions of greenhouse gases. For this reason,the best
               approachto quantifying the benefits of the federal dollars spent is to analyze the benefits over
               several years, which EPA has done in the April 1999 report.

                        Again, on page9 of the draft report, GAO criticizes EPA for not including information
               that EPA believes was not requestedby the amendment language or the colloquy. GAO states             See comment 4.
               that “For reductions in greenhousegas emissions, but not for the other accomplishments, the
               [EPA] report also shows how the overall goal of 58 MMTCE is distributed for four of the six
               initiatives, as follows: buildings, 12.7 MMTCE; industry...“and on page 12 the draft report goes
               on to say that “the report generally does not explain how the six initiatives will contribute to
               EPA’s fiscal year 2000 goals for these six measures.” However, the report language directed
               “the Agency to provide the Committee with a detailed plan for implementing the President’s
               Proposal, which would include an annual performance goal for the reduction of greenhouse
               gases...” EPA met that requestin our report by stating an overall goal for greenhousegas
               reductions in 2000. As requested,EPA also included the annual greenhousegas reductions for
               each initiative that contributes to the overall goal and the activities by which EPA will achieve
               eachof thesegoals. For the other accomplishments such as ener,gysaved, sulfur dioxide reduced
               and number of partners,EPA provided this information in aggregate for all initiatives for each
               year from 1995through 2000 as cobenefits.




                                                              3




 17                                    GAOLRCED-99-235R        EPA’s April    1999 Climate Change Report
ENCLOSURE II




                  On page 11 of the draft report, GAO notes that start dates for only some of the programs
          are included in the Agency’s report and that “the report does not make clear which programs            See comment 5.
          started after the Kyoto Protocol was agreedto.” As written, the draft report may suggestto the
          readerthat some of EPA’s pro,ms may implement the Kyoto Protocol simply by virtue of the
          fact that they were launched after the date of the Kyoto Protocol agreement. We would like to
          reiterate that none of EPA’s pro,mms implement the Kyoto Protocol, and this applies to
          programs launched both before and after the date of the Kyoto Protocol agreement. All of these
          programs are voluntary and they are designed to capitalize on opportunities to deploy technology
          more rapidly through the marketplace.’ These programs are working to fulfill the U.S.
          commitments under the Framework Convention on Climate Change ratified by the United States
          in 1992 and are in no way implementing the Kyoto Protocol prior to ratification.

          III.   GAO’s draft report statesthat “Climate Change Activities Justified Overall, but Not for
                 Each Program.”

                    EPA is pleased GAO found that we have justified our climate change activities overall.      See comment 6.
          However, again we believe that Congress askedus td comply with “the letter and spirit of the
          GPRA,” for the Climate ChangeTechnology Initiative, and thus asked us to just@ each of the
          initiatives in the CCTI, which we have done in the April 1999 Report.

                   EPA disagreeswith GAO’s claim that “EPA’s report does not provide justifications for
          the proposed funding increasesfor individual climate changeprograms for fiscal year 2000.” In
          fact, chapter 4 of EPA’s report lays out in detail the increased funding for each of the 6 program
          areasand explains, for each area,a justification for the increased spending (section 4.3). The
          activities resulting from the increased funding are as specific as the number of products that will
          be eligible to use the ENERGY STAR Label in 2000 and the number of commercial buildings
          that will qualify for the ENERGY STAR Label in the Buildings Programs. Iit the Industry
          Programs,EPA specifies a number of very specific activities that EPA would pursue with the
          additional funding and the environmental benefits associatedwith these activities. For example,
          EPA’s report statesthat expanding the Climate Wise Program, would result in reductions of
          about 50 million metric tons of carbon dioxide (13 MMTCE) annually and savings of $1.6
          billion per year by 2010. This section of EPA’s report very clearly and specifically justifies the
          proposed funding increases,which are laid out in Table 3 of the EPA report. Chapter 5 of EPA’s
          report supplementsthis information with program-by-program details of activities,
          accomplishments and goals.

          IV.    Finally, GAO statesthat the “Report Provides Performance Measures and Goals, But
                 Data Quality is Unclear.”

                  In this section of GAO’s draft report, GAO notes again that performance measuresother
          than greenhousegas reductions are not broken down by initiative. As stated previously, EPA
          met the Congressional directive for the report by stating an overall goal for greenhousegas
          reductions in 2000. As requested,EPA also included the annual greenhousegas reductions for

                                                           4




 18                                   GAO/NED-99-235R          EPA’s April   1999 Climate    Change Report
 ENCLOSURE II




           each initiative that contributes to the 2000 overall reduction goaI and the activities by which EPA
           will achieve eachof thesegoals. For the other accomplishments such as energy saved, sulfur
           dioxide reduced and number ofpartners, EPA provided this information in aggregatefor all
           initiatives for eachyear from 1995 through 2000 as cobenefits.

                     GAO notes on page 13 that the report would have been more “useful if it had calculated
           the changesin dollar amounts and the corresponding percentage changes for the seven
           initiatives.” EPA did not calculate the changes in dollar amounts in the April report in order to
           avoid redundancy with the 2000 Anntial Plan. However, by looking at Table 3 of EPA’s report,
           GAO was able to easily calculate these figures.

                  GAO criticizes EPA’s methods of estimating the accomplishments and the quality of the          See comment 7.
          data presentedin EPA’s report. Specifically, GAO points out that “the report doesn’t explain
          that trends reported by program participants may reflect factors other than EPA’s programs.”
          With respect to “checking reported performance,” EPA has developed a successful and extensive
          system of performancemeasuresand program evaluation. EPA devotes considerable effort to
          obtaining the best possible information upon which to evaluate the programs. For example, EPA
          reports the results of the ENERGY STAR Buildings and Green LigbhtsPartnership based
          exclusively on detailed reports submitted by the program’spartners on many thousands of
          completed projects around the country, and EPA has a quality assuranceprocess in place to
          check the validity of the partner reports. Thus, EPA has high confidence in the accuracy of the
          data reported by the partners.

                   EPA has also always recognized that there are some difficult analytical issues in using
            such data, however accuratein itself, to evaluate the success of voluntary, market-based
           programs. Thus, EPA rakestheseanalytical issues into account when evaluating its climate
           programs. EPA has discussedthese issues with your staff. There is some uncertainty, for
            example, in isolating the effects of a program such as ENERGY STAR Buildings and Green
           Lights Partnership from other factors within the market. Currently, EPA has two in-depth market
           evaluations underway to reduce this uncertainty and provide additional information regarding the
           accomplishmentsand effectiveness of the Green Lights Program and the ENERGY STAR
           Labeling Program. These evaluations are scheduled to be completed in the fall of 1999.
           Preliminary evidence indicates that EPA is handling analytical uncertainties in a manner that
           avoids overestimating program benefits. For example, in the Green Lights Program, in a
           conservative estimate,it appearsthat the effects of free riders (entities who would have taken a
           program action even if the program did not exist) and the effects of free drivers (entities who
           cqntribute to the program activities and take advantageof program offerings without formally
          joining the program, therefore, whose activities are not counted toward program benefits) would
           likely offset eachother on a kilowatthour basis. EPA believes that the current methods used
           across all of the climate programs for evaluating overall impacts are based on sound data and
           analytical assumptions,and that, in general, EPA’s estimates of the program results are
           conservative.




19                                 GAOIRCED-99-235R         EPA’s April   1999 Climate     Change Report
ENCLOSURE II




                EPA is working to ensure that its performance information is complete. accurate,
         consistent, and free of significant levels of error and bias. These efforts and the efforts of other
         programs have provided maximum accountability and valuable information for proLmm
         development. EPA’s perfomlance measureshave been reviewed in detail by GAO staff in the
         past. We have presentedthis information consistently in our Annual Plan for 2000 as well as our
         April 1999 report to Congress.

                   In addition the following comments identify additional discrepancies in the GAO draft
         report:

                   GAO claims that the information that is provided in the report is not well integrated,
         because“the report does not explain how [the] 11 program groups or programs relate to the six
         initiatives around which the report is generally organized.” However, EPA presentedthe
         information in a consistent manner throughout the report and each pro,=        is clearly categorized
         by program area or initiative in chapter 4. GAO demonstratedthis in its own report by
         synthesizing the information in the EPA April 1999 Report and presenting it as Figure 1.

                 In the “Background” section, on page 4, GAO statesthat EPA’s programs to encourage
         businessesand others to voluntarily reduce ener,g use and otherwise curb their emissions of
         greenhousegas emissions now include seven programs which GAO has enumeratedby bullets.
         However, GAO neglected to mention any of the other 8 programs included in the EPA report and
                                                                                                  .’
         in Figure 1 of the GAO draft report.

               We have some additional more detailed comments that my staff will provide separately.
         Thank you for the opportunity to comment.




                                                       Paul M. Stolpman, Director
                                                       Office of Atmospheric Programs




                                                           6




20                                    GAO/RCED-99-235R         EPA’s April   1999 Climate    Change Report
ENCLOSURE II


              COMMENTS FROM THE ENVIRONMENTAL PROTECTION AGENCY

The following are GAO’s comments on the Environmental Protection Agency’s letter dated July
12, 1999.

GAO’s Comments


1. We differ from EPA in our reading of the Committee report language and the subsequent
   Senate floor colloquy as they pertain to the desired scope of EPA’s report. In its letter, EPA
   cites only the Committee report as the basis for the scope of its report. We agree with EPA
   that the Committee report language mentioned the Chmate Change Technology Initiative
   and, if there had been no subsequent colloquy, the scope of EPA’s report would have been
   appropriate. However, the colloquy restated and elaborated upon the Committee report and,
   in EPA’s report, the agency also recognizes that the colloquy “modified” the Committee
   report. The colloquy called for ua more comnrehensive explanation by the EPA of the
   components of its energy and environment programs” (emphasis added). Thus, it did not
   mention the technology initiative, but, instead, called for a “more comprehensive”
   explanation of the agency’s climate change activities. Finally, we note that EPA entitled its
   report, C                                   which does not suggest that the scope was limited
   to activities that are part of the technology initiative. Accordingly, EPA’s report should have
   covered all of its climate change programs-including       the efforts for which EPA requested
   $23 million for fiscal year ZOOO-or,at a   minimum,    should have explained why it did not do
   so.

2. We differ from EPA in our reading of the colloquy as it pertains to the desired level of detail
   of EPA’s report. In its letter, EPA states that it provided, as requested, “the funding level for
   each initiative and the performance measures for each of the activities that will be
   undertaken.. ..” EPA also states that it has “consistently provided goals and
   accomplishments at the initiative level. . ..” However, we note that the colloquy calls for an
   explanation of “the comnonents of [EPA’s] energy and environment programs” (emphasis
   added). Moreover, by directing that EPA prepare this additional report, the Committee
   indicated a desire for more detailed information than was included in EPA’s previous reports
   at the initiative level. Also, EPA asserts that it provided program-specific information in
   chapter 5. However, we note that the chapter describes the programs, but it does not
   provide consistent information on the amount of funding requested for fiscal year 2000 or
   expected program results.

3. The colloquy directed EPA to provide “any justification for funding increases” (emphasis
   added). EPA’s report estimated the benefits-for example, in terms of reduced emissions of
   greenhouse gases-that will result from the full amount of funding requested for fiscal year
   2000. However, it does not estimate the benefits that would result from an increase in
   funding, as contrasted with the benefits that would result from continuing funding at its
   current level. EPA also states that it would be unreasonable to expect these programs to
   produce significant results during their first year. We understand that, for programs like
   these, spending in one year may yield results over a period of years. Therefore, contrary to
   EPA’s suggestion, we did not state that EPA should report the estimated results for fiscal
   year 2000 alone that would occur from increased funding in that year. Rather, we noted that


21                                GAOLRCED-99-235R   EPA’s April   1999 Climate   Change Report
ENCLOSURE II


      EPA did not provide estimates of the results (which might occur over a period of years) from
      an increase in funding for fiscal year 2000.

4. In its letter, EPA explains why it presented estimates of fiscal year 2000 benefits at the
   initiative level for reductions in greenhouse gas emissions, but presented estimates of total
   benefits for the other five performance measures. EPA notes that the Committee report
   specifically asked for expected results in terms of emissions reductions. We have modified
   our report to reflect EPA’s reason.

5. In its letter, EPA states that our report may imply that some of its programs may implement
   the Kyoto Protocol on climate change. EPA reiterates that none of its programs-regardless
   whether started before or after the protocol was agreed to-is intended to implement the
   protocol. We did not mean to suggest anything about implementing the protocol. Rather, we
   meant to suggest that EPA’s presentation itself could lead to questions. EPA’s report states
   that most-but not all-of its climate change programs were started before the protocol was
   agreed to and it provides start dates for many-but not all-of its programs. By not
   providing such information for some of its programs, EPA’s report could have raised
   questions.

6. ‘I’his section of our draft report dealt with the legal basis for EPA’s climate change activities,
   not the justification of funding. See comment 3.

7. In its letter, EPA discusses some of the issues involved in determining the effectiveness of its
   programs and states that it has evaluations under way to better understand the effect of two
   of its programs, both in the buildings sector. We agree that such evaluations have value. By
   including this type of information in its report, EPA would have alerted readers to some of
   the issues relating to data quality and would have presented a fuller picture of its efforts to
   assure the reliability of its reported results.

8. EPA claims that “each program is clearly categorized by program area or initiative in chapter
   4.” We disagree. For example, we found no mention in chapter 4 of the Waste Wise
   Program or the five methane programs, all of which are described in chapter 5. In fact, as we
   noted in our draft report, the presentations in chapters 4 and 5 are inconsistent. We
   prepared our Figure 1 to show the relationships between initiatives, program groups, and
   programs because EPA’s report does not do so and because we thought such a graphic
   would be helpful to readers of both EPA’s report and our report.

 9. EPA asserts that we “neglected to mention” some of its programs in the background section
    of our report. By way of illustration, we described several of EPA’s programs because we
    referred to them later in the report. We clarified our report to make clear that the programs
    cited are only some of EPA’s programs.


 (160476)



 22                                 GAOfRCED-99-235R   EPA’s April   1999 Climate   Change Report
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