Environmental Protection: Status of EPA's Efforts to Create a Central Information Office

Published by the Government Accountability Office on 1999-04-29.

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

                     United States General Accounting Office

GAO                  Testimony
                     Before the Subcommittee on VA, HUD, and Independent
                     Agencies, Committee on Appropriations, U.S. Senate

To Be Released
at 9:30 a.m., EDT,
April 29, 1999

                     Status of EPA’s Efforts to
                     Create a Central
                     Information Office
                     Statement for the Record by
                     Peter F. Guerrero
                     Director, Environmental Protection Issues,
                     Resources, Community, and Economic
                     Development Division

Mr. Chairman and Members of the Subcommittee:

We appreciate the opportunity to present this statement for the record,
which discusses our preliminary observations based on our ongoing work
for this Subcommittee concerning the Environmental Protection Agency’s
(EPA) information management initiatives. Specifically, this statement
provides information on (1) the status of EPA’s efforts to create a central
office responsible for information management, policy, and technology
issues and (2) the major challenges that the new office needs to address in
order to achieve success in collecting, using, and disseminating
environmental information. Our final report will be provided in
August 1999.

EPA estimates that its central information office will be operational by the
end of August 1999 and will have a staff of about 350 employees. The
office will address a broad range of information policy and technology
issues, such as improving the accuracy of EPA’s data, protecting the
security of information that EPA disseminates over the Internet, developing
better measures to assess environmental conditions, and reducing
information collection and reporting burdens. EPA recognizes the
importance of developing an information plan showing the goals of the
new office and the means by which they will be achieved but has not yet
established milestones or target dates for completing such a plan.
Although EPA has made progress in determining the organizational
structure for the new office, it has not yet finalized decisions on the
office’s authorities, responsibilities, and budgetary needs. Nor has the
agency performed an analysis to determine the types and the skills of
employees that will be needed to carry out the office’s functions. EPA
officials told us that decisions on the office’s authorities, responsibilities,
budget, and staff will be made before the office is established in
August 1999.

On the basis of our prior and ongoing reviews of EPA’s information
management problems, we believe that the success of the new office
depends on the agency’s addressing several key challenges as it develops
an information plan, budget, and organizational structure for that office.
Most importantly, EPA needs to (1) provide the office with the resources
and the expertise necessary to solve the complex information
management, policy, and technology problems facing the agency;
(2) empower the office to overcome organizational challenges to adopting
agencywide information policies and procedures; (3) balance the agency’s
need for data on health, the environment, and program outcomes with the

Page 1                                                       GAO/T-RCED-99-177
                    call from the states and regulated industries to reduce their reporting
                    burdens; and (4) work closely with its state partners to design and
                    implement improved information management systems.

                    In October 1998, the EPA Administrator announced plans to create an
Background          office with responsibility for information management, policy, and
                    technology. This announcement came after many previous efforts by EPA
                    to improve information management and after a long history of concerns
                    that we, the EPA Inspector General, and others have expressed about the
                    agency’s information management activities. Such concerns involve the
                    accuracy and completeness of EPA’s environmental data, the fragmentation
                    of the data across many incompatible databases, and the need for
                    improved measures of program outcomes and environmental quality.

                    The EPA Administrator described the new office as being responsible for
                    improving the quality of information used within EPA and provided to the
                    public and for developing and implementing the goals, standards, and
                    accountability systems needed to bring about these improvements. To this
                    end, the information office would (1) ensure that the quality of data
                    collected and used by EPA is known and appropriate for its intended uses,
                    (2) reduce the burden of the states and regulated industries to collect and
                    report data, (3) fill significant data gaps, and (4) provide the public with
                    integrated information and statistics on issues related to the environment
                    and public health. The office would also have the authority to implement
                    standards and policies for information resources management and be
                    responsible for purchasing and operating information technology and

                    Under a general framework for the new office that has been approved by
Progress Is Being   the EPA Administrator, EPA officials have been working for the past several
Made, but Key       months to develop recommendations for organizing existing EPA personnel
Questions on        and resources into the central information office. Nonetheless, EPA has not
                    yet developed an information plan that identifies the office’s goals,
Resources and       objectives, and outcomes. Although agency officials acknowledge the
Strategies Remain   importance of developing such a plan, they have not established any
                    milestones for doing so. While EPA has made progress in determining the
Unresolved          organizational structure of the office, final decisions have not been made
                    and EPA has not yet identified the employees and the resources that will be
                    needed. Setting up the organizational structure prior to developing an

                    Page 2                                                     GAO/T-RCED-99-177
                              information plan runs the risk that the organization will not contain the
                              resources or structure needed to accomplish its goals.

Information Plan Is           Although EPA has articulated both a vision as well as key goals for its new
Needed                        information office, it has not yet developed an information plan to show
                              how the agency intends to achieve its vision and goals. Given the many
                              important and complex issues on information management, policy, and
                              technology that face the new office, it will be extremely important for EPA
                              to establish a clear set of priorities and resources needed to accomplish
                              them. Such information is also essential for EPA to develop realistic
                              budgetary estimates for the office.

                              EPA  has indicated that it intends to develop an information plan for the
                              agency that will provide a better mechanism to effectively and efficiently
                              plan its information and technology investments on a multiyear basis. This
                              plan will be coordinated with EPA ‘s agencywide strategic plan, prepared
                              under the Government Performance and Results Act. EPA intends for the
                              plan to reflect the results of its initiative to improve coordination among
                              the agency’s major activities relating to information on environment and
                              program outcomes. It has not yet, however, developed any milestones or
                              target dates for initiating or completing either the plan or the coordination

Organizational Structure Is   In early December 1998, the EPA Administrator approved a broad
Not Yet Determined            framework for the new information office and set a goal of completing the
                              reorganization during the summer of 1999. Under the framework approved
                              by the EPA Administrator, the new office will have three organizational
                              units responsible for (1) information policy and collection, (2) information
                              technology and services, and (3) information analysis and access,
                              respectively. In addition, three smaller units will provide support in areas
                              such as data quality and strategic planning.

                              A transition team of EPA staff has been tasked with developing
                              recommendations for the new office’s mission and priorities as well as its
                              detailed organizational and reporting structure. In developing these
                              recommendations, the transition team has consulted with the states,
                              regulated industries, and other stakeholders to exchange views regarding
                              the vision, goals, priorities, and initial projects for the office.

                              Page 3                                                      GAO/T-RCED-99-177
                             One of the transition team’s key responsibilities is to make
                             recommendations concerning which EPA units should move into the
                             information office and in which of the three major organizational units
                             they should go. To date, the transition team has not finalized its
                             recommendations on these issues or on how the new office will operate
                             and the staff it will need.

Needed Resources Are Still   Even though EPA has not yet determined which staff will be moved to the
Unknown                      central information office, the transition team’s director told us that it is
                             expected that the office will have about 350 employees. She said that the
                             staffing needs of the office will be met by moving existing employees in
                             EPA units affected by the reorganization. The director said that, once the
                             transition team recommends which EPA units will become part of the
                             central office, the agency will determine which staff will be assigned to the
                             office. She added that staffing decisions will be completed by July 1999
                             and the office will begin functioning sometime in August 1999.

                             The funding needs of the new office were not specified in EPA’s fiscal year
                             2000 budget request to the Congress because the agency did not have
                             sufficient information on them when the request was submitted in
                             February 1999. The director of the transition team told us that in June 1999
                             the agency will identify the anticipated resources that will transfer to the
                             new office from various parts of EPA. The agency plans to prepare the
                             fiscal year 2000 operating plan for the office in October 1999, when EPA has
                             a better idea of the resources needed to accomplish the responsibilities
                             that the office will be tasked with during its first year of operation. The
                             transition team’s director told us that decisions on budget allocations are
                             particularly difficult to make at the present time due to the sensitive
                             nature of notifying managers of EPA’s various components that they may
                             lose funds and staff to the new office.

                             Furthermore, EPA will soon need to prepare its budget for fiscal year 2001.
                             According to EPA officials, the Office of the Chief Financial Officer will
                             coordinate a planning strategy this spring that will lead to the fiscal year
                             2001 annual performance plan and proposed budget, which will be
                             submitted to the Office of Management and Budget by September 1999.

                             Page 4                                                     GAO/T-RCED-99-177
                          The idea of a centralized information office within EPA has been met with
EPA’s New                 enthusiasm in many corners—not only by state regulators, but also by
Information Office        representatives of regulated industries, environmental advocacy groups,
Will Face Significant     and others. Although the establishment of this office is seen as an
                          important step in improving how EPA collects, manages, and disseminates
Challenges                information, the office will face many challenges, some of which have
                          thwarted previous efforts by EPA to improve its information management
                          activities. On the basis of our prior and ongoing work, we believe that the
                          agency must address these challenges for the reorganization to
                          significantly improve EPA’s information management activities. Among the
                          most important of these challenges are (1) obtaining sufficient resources
                          and expertise to address the complex information management issues
                          facing the agency; (2) overcoming problems associated with EPA’s
                          decentralized organizational structure, such as the lack of agencywide
                          information dissemination policies; (3) balancing the demand for more
                          data with calls from the states and regulated industries to reduce reporting
                          burdens; and (4) working effectively with EPA’s counterparts in state

Obtaining Sufficient      The new organizational structure will offer EPA an opportunity to better
Resources and Expertise   coordinate and prioritize its information initiatives. The EPA Administrator
                          and the senior-level officials charged with creating the new office have
                          expressed their intentions to make fundamental improvements in how the
                          agency uses information to carry out its mission to protect human health
                          and the environment. They likewise recognize that the reorganization will
                          raise a variety of complex information policy and technology issues.

                          To address the significant challenges facing EPA, the new office will need
                          significant resources and expertise. EPA anticipates that the new office will
                          substantially improve the agency’s information management activities,
                          rather than merely centralize existing efforts to address information
                          management issues. Senior EPA officials responsible for creating the new
                          office anticipate that the information office will need “purse strings
                          control” over the agency’s resources for information management
                          expenditures in order to implement its policies, data standards,
                          procedures, and other decisions agencywide. For example, one official
                          told us that the new office should be given veto authority over the
                          development or modernization of data systems throughout EPA.

                          To date, the focus of efforts to create the office has been on what the
                          agency sees as the more pressing task of determining which organizational

                          Page 5                                                      GAO/T-RCED-99-177
                           components and staff members should be transferred into the new office.
                           While such decisions are clearly important, EPA also needs to determine
                           whether its current information management resources, including staff
                           expertise, are sufficient to enable the new office to achieve its goals.

Overcoming Problems        EPA will need to provide the new office with sufficient authority to
Associated With EPA’s      overcome organizational obstacles to adopt agencywide information
Decentralized              policies and procedures. As we reported last September, EPA has not yet
                           developed policies and procedures to govern key aspects of its projects to
Organizational Structure   disseminate information, nor has it developed standards to assess the
                           data’s accuracy and mechanisms to determine and correct errors.1

                           Because EPA does not have agencywide polices regarding the
                           dissemination of information, program offices have been making their
                           own, sometimes conflicting decisions about the types of information to be
                           released and the extent of explanations needed about how data should be
                           interpreted. Likewise, although the agency has a quality assurance
                           program, there is not yet a common understanding across the agency of
                           what data quality means and how EPA and its state partners can most
                           effectively ensure that the data used for decision-making and/or
                           disseminated to the public is of high quality. To address such issues, EPA
                           plans to create a Quality Board of senior managers within the new office in
                           the summer of 1999.

                           Although EPA acknowledges its need for agencywide policies governing
                           information collection, management, and dissemination, it continues to
                           operate in a decentralized fashion that heightens the difficulty of
                           developing and implementing agencywide procedures. EPA’s offices have
                           been given the responsibility and authority to develop and manage their
                           own data systems for the nearly 30 years since the agency’s creation.
                           Given this history, overcoming the potential resistance to centralized
                           policies may be a serious challenge to the new information office.

Balancing the Need to      EPA and its state partners in implementing environmental programs have
Collect More Data and      collected a wealth of environmental data under various statutory and
Efforts to Reduce          regulatory authorities. However, important gaps in the data exist. For
                           example, EPA has limited data that are based on (1) the monitoring of
Reporting Burdens          environmental conditions and (2) the exposures of humans to toxic

                           Environmental Information: Agencywide Policies and Procedures Are Needed for EPA’s Information
                           Dissemination (GAO/RCED-98-245, Sept. 24, 1998).

                           Page 6                                                                    GAO/T-RCED-99-177
                           pollutants. Furthermore, the human health and ecological effects of many
                           pollutants are not well understood. EPA also needs comprehensive
                           information on environmental conditions and their changes over time to
                           identify problem areas that are emerging or that need additional regulatory
                           action or other attention.

                           In contrast to the need for more and better data is a call from states and
                           regulated industries to reduce data management and reporting burdens.
                           EPA has recently initiated some efforts in this regard. For example, an
                           EPA/state information management workgroup looking into this issue has
                           proposed an approach to assess environmental information and data
                           reporting requirements based on the value of the information compared to
                           the cost of collecting, managing, and reporting it. EPA has announced that
                           in the coming months, its regional offices and the states will be exploring
                           possibilities for reducing paperwork requirements for EPA’s programs,
                           testing specific initiatives in consultation with EPA’s program offices, and
                           establishing a clearinghouse of successful initiatives and pilot projects.

                           However, overall reductions in reporting burdens have proved difficult to
                           achieve. For example, in March 1996, we reported that while EPA was
                           pursuing a paperwork reduction of 20 million hours, its overall paperwork
                           burden was actually increasing because of changes in programs and other
                           factors.2 The states and regulated industries have indicated that they will
                           look to EPA’s new office to reduce the burden of reporting requirements.

Working More Effectively   Although both EPA and the states have recognized the value in fostering a
With State Counterparts    strong partnership concerning information management, they also
                           recognize that this will be a challenging task both in terms of policy and
                           technical issues. For example, the states vary significantly in terms of the
                           data they need to manage their environmental programs, and such
                           differences have complicated the efforts of EPA and the states to develop
                           common standards to facilitate data sharing. The task is even more
                           challenging given that EPA’s various information systems do not use
                           common data standards. For example, an individual facility is not
                           identified by the same code in different systems.

                           Given that EPA depends on state regulatory agencies to collect much of the
                           data it needs and to help ensure the quality of that data, EPA recognizes the
                           need to work in a close partnership with the states on a wide variety of

                           Environmental Protection: Assessing EPA’s Progress in Paperwork Reduction (GAO/T-RCED-96-107,
                           March 21, 1996).

                           Page 7                                                                   GAO/T-RCED-99-177
               information management activities, including the creation of its new
               information office. Some partnerships have already been created. For
               example, EPA and the states are reviewing reporting burdens to identify
               areas in which the burden can be reduced or eliminated. Under another
               EPA initiative, the agency is working with states to create data standards so
               that environmental information from various EPA and state databases can
               be more readily shared. Representatives of state environmental agencies
               and the Environmental Council of the States have expressed their ideas
               and concerns about the role of EPA’s new information office and have
               frequently reminded EPA that they expect to share with EPA the
               responsibility for setting that office’s goals, priorities, and strategies.
               According to a Council official, the states have had more input to the
               development of the new EPA office than they typically have had in other
               major policy issues and the states view this change as an improvement in
               their relationship with EPA.

               Collecting and managing the data that EPA requires to manage its programs
Observations   have been major long-term challenges for the agency. The EPA
               Administrator’s recent decision to create a central information office to
               make fundamental agencywide improvements in data management
               activities is a step in the right direction. However, creating such an
               organization from disparate parts of the agency is a complex process and
               substantially improving and integrating EPA’s information systems will be
               difficult and likely require several years. To fully achieve EPA’s goals will
               require high priority within the agency, including the long-term
               appropriate resources and commitment of senior management.

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