REGULATORY FOCUS
EPA's new management approach
Michael R. Deland
"Managing for environmental results," recently espoused by EPA Administrator Anne M. Gorsuch, is a refrain increasingly echoed by managers throughout the agency. The approach directs managers to use environmental-quality data to set goals for each program and then manage their programs to achieve those goals. This means that no longer will managers be evaluated by traditional "bean counting" methods, such as the number of inspections made or specific actions taken, but rather by how effectively their actions serve to protect the environment. The concept itself is not new but EPA's heightened interest and solicitation of state participation are. The three main facets of the approach are an accountability system, "indicators" of environmental results, and "environmental management reports." The accountability system, which was established last fall, is the basic managerial framework requiring the establishment of goals, standards, and program objectives by which performance can be judged. The indicators and management reports, now being implemented, are key to whether a meaningful managerial change will in fact occur. Indicators of environmental results EPA is evaluating responses from its regional offices and the states to a set of "possible indicators" for each medium that was circulated last month. 0013-936X/82/0916-0605A$01.25/0
The range of indicators by which environmental results can be measured runs from "programmatic" or administrative indicators (surrogates based on the assumption that certain actions will result in improved environmental quality) to "ultimate impact" indicators. Examples of programmatic indicators would be actions taken by the state or EPA, such as the issuance of permits or revisions to state implementation plans. Ultimate impact indicators include such measures as reduced incidence of pollution-related disease or return of certain species of fish to formerly polluted streams. While the agency ideally would like to rely on ultimate impact data, it recognizes that such data are not yet widely available and that it must therefore use "the best combination of existing ambient, pollutant removal, or compliance data" to judge whether a program is meeting its environmental objectives. The agency plans to use several of the more important indicators immediately and to further refine and implement others in the coming months. For example, an air quality indicator that can be immediately used is the "change over time in the number, extent and location of non-attainment areas." A "promising" air indicator "requiring further work" is the "population exposed to air quality standards violations." Management reports Environmental indicators will ultimately serve as the basis for "state of the environment" assessments or "environmental management reports" (EMRs), which each regional EPA office will be required to submit by March 1983 and on a regular basis thereafter. The regions are now working with the states to develop the proposed content and format for the EMR.
© 1982 American Chemical Society
The EMRs are intended to describe the status of trends in environmental quality, the most significant environmental problems, and the causes associated with those problems. The EMRs also are to outline the actions the region has taken or plans to take to address the problems and the implications of the information for environmental strategies over the short and long terms. State participation At the National Governor's Association conference in September, Administrator Gorsuch and her staff met with the governors and senior environmental officials from more than 30 states. As an outgrowth of this session, several EPA-state working groups were established on matters of mutual environmental concern. One, "Managing for Environmental Results," chaired by Leonard Ledbetter, director of the Environmental Protection Division of the Georgia Department of Natural Resources, is currently exploring how state and federal resources might be more cooperatively and efficiently harnessed. This developing federal-state relationship is critical to whether managing for environmental results does in fact become a successful management tool. Many states have long been frustrated by the "bean counting" required of them by EPA and are thus enthusiastically participating in the design of what they perceive to be a sensible program. The initial steps now being taken by EPA to manage for environmental results, particularly given active state support, have the potential to better direct government resources toward protection of public health and the environment.
Deland writes this column monthly and is counsel to ERT, Concord, Mass. Environ. Sci. Technol., Vol. 16, No. 11, 1982
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