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GAC Response Letter 2006
Plácido dos Santos
Chair, U.S. Governmental Advisory Committee
Border Environmental Manager
Arizona Dept. of Environmental Quality
400 W. Congress Street, Suite 521
Tucson, AZ 85701
Dear Mr. dos Santos:
On behalf of Administrator Stephen L. Johnson, I would like to thank you for the Governmental Advisory Committee's (GAC) May 10, 2006 letter reporting on its April 2006 meeting and providing valuable advice on six major topics. On a personal note, it was a pleasure to have had the opportunity to meet with you and I am glad to hear that my participation in your meeting was worthwhile. I am looking forward to meeting with members of the GAC and EPA Administrator Stephen L. Johnson, on June 27th at the Council Session.
The GAC's advice on the draft CEC Operational Plan, increasing the CEC's profile, Articles 14 & 15 follow-up, renewable energy and climate change, greening the supply chain initiative, and the new quality assurance policy and procedures has been considered by our experts and program coordinators in preparation for the 2006 Council Session and will be considered further as they continue to work on CEC management improvements and next year's operational plan. On behalf of the EPA Administrator and the United States Government, I am pleased to offer the following response to the GAC's advice:
Draft CEC Operational Plan:
As you know, the plan recently was finalized and work has begun on a host of projects that will make a difference for the North American environment. As you indicated, it is a major accomplishment and we hope it will make the development of next year's plan more efficient and effective. The U.S. agencies involved in the development of the Operational Plan, the other Parties, and the CEC Secretariat all have agreed to work together this summer to develop the 2007 Operational Plan so that it can be reviewed and approved much earlier than last year. This should result in an opportunity for more timely and meaningful input from the GAC. The GAC's advice on the annual reporting of accomplishments by projects is appreciated. Many of the activities in the operational plan are multi-year activities and it is important for the Parties to be able to consider results when next year's funds are allocated for continuing and new activities. The U.S. Government also hopes to reach agreement later this year with the other Parties on performance measures and targets for the operational plan so that progress can be measured over time.
Regarding the GAC's request for reports from the Executive Director, I have asked the CEC Team to ensure that these are provided in a timely manner beginning with the annual report that will be presented during the upcoming Council Session.
The EPA is committed to thorough and timely exchange of information about CEC projects and draft products throughout our entire interagency group, and with our public customers and advisory committees. We have recently updated our government-wide distribution and clearance lists, and we are exploring new tools which will enable us to share documents with our colleagues more quickly and effectively. The CEC Team and interagency colleagues spend a great deal of time each year to carefully review the Operational Plan and budget to ensure that tasks and deliverables are clearly identified. We recognize that some tasks are described in greater detail than others, but we expect to continue to make improvements to the operational plan in 2007 so that the project descriptions will be consistent in the level of detail provided. Along with the successful development of Quality Assurance Procedures, we will continue our efforts to ensure quality project planning from the Secretariat in the 2007 Operational Plan.
Increasing the CEC's Profile
We appreciate your advice for developing a strategic visioning session for the CEC to develop a focused marketing plan and identify specific, coordinated actions that would enhance our profile and strengthen the CEC's relevance and resonance throughout North America. This is an interesting idea which may hold a great deal of promise. We are open to discussing next steps for such a visioning session to increase CEC's profile, perhaps at your October meeting.
The GAC's advice to identify successes that have local relevance is consistent with a recommendation that has been made by the U.S. CEC Team to identify the beneficiaries of the CEC activities and products. The CEC team is regularly asked to list CEC accomplishments for our colleagues within the United States, and we are working with the Secretariat to itemize and list these results in an organized format. We will develop a list of accomplishments as you recommended, and will make it available for your next meeting.
The GAC's advice to include CEC in the EPA Strategic Plan is very helpful, and we will explore this suggestion as the EPA Strategic Plan 2006-11 is finalized this summer.
Articles 14 & 15 Follow Up:
The public submission process of the North American Agreement on Environmental Cooperation is a unique and important feature. The United States recognizes that the Parties' responses to submissions have implications for the overall relevance and success of the CEC. The United States supports the citizen submissions process. The United States also recognizes the importance of communicating with the public on the status of submissions. Information on the status of citizen submissions on enforcement matters is a prominent and detailed component of the CEC web site. A report on the status of submissions also is a standard feature of the Executive Director's report at the annual Council Sessions.
Regarding the GAC's advice that the CEC report on “community-level follow-up,” as you know, the NAAEC does not provide for any follow-up to a factual record. Both the NAAEC and the Guidelines for Submissions on Enforcement Matters under Articles 14 and 15 of the North American Agreement on Environmental Cooperation provide guidance regarding the purpose of the factual record and the type of information it should include. A factual record should provide the public with an impartial presentation of the relevant facts but should not contain conclusions as to whether a Party is, in fact, effectively enforcing its environmental law. A factual record should provide the public with the information they need to draw their own conclusions regarding the effectiveness of the enforcement by a Party of its environmental law.
Renewable Energy and Climate Change:
We appreciate the GAC's comments and advice on the inter-related issues of renewable energy and climate change. The CEC's current work on renewable energy will enhance North American trade in renewable energy as a “green product,” improve regional and national coordination, and promote policy. Through targeted actions, the Parties and the CEC can address some of the informational and transactional barriers that add to the cost of renewable energy and assist policymakers as they implement policies to promote renewable energy. The Parties have directed the Secretariat to create a North America Renewable Energy Experts' Committee (REEC) to advise the CEC on its work on renewable energy.
For many years, the U.S. Government has implemented multiple programs to improve the energy efficiency and environmental footprint of its facilities. One such program is the Department of Energy's Federal Energy Management Program (FEMP), which works to reduce the cost and environmental impact of the Federal government by advancing energy efficiency and water conservation, promoting the use of distributed and renewable energy, and improving utility management decisions at Federal sites.
As for your suggestion to consider the CEC Secretariat for a self-examination of energy demands and efficiency, we have discussed this possibility with the Secretariat. The Secretariat does not own its own facility, but rents it from the Montreal World Trade Centre. This facility is very sensitive to energy use, has conducted its own energy evaluations within the building (both for common areas and rental spaces), and has taken steps to reduce energy use. Because of this rental situation, the Secretariat has limited power to make any additional energy increases at this time.
Private Sector Engagement - Greening the Automotive Supply Chain Initiative:
We welcome your comments on the “Greening the Supply Chain” Initiative. This work will focus on multinational automotive companies with supply chains that cross North American borders. The concept for this project was informed by advice from the National Advisory Committee and the research and experience of experts from the three Parties. We welcome the GAC's suggestions on implementing international recognition programs and will look forward to the GAC's comments when the project it is incorporated into the draft 2007 Operational Plan.
Quality Assurance Policy and Procedures
We appreciate your acknowledgement of our leadership in ensuring the completion of the CEC's Quality Assurance Policy and Procedures. These procedures will help ensure that information provided by the CEC to North American decision makers and the public will be scientifically sound, objective, credible, and based on the best data and information available.
As always, the United States appreciates the advice of the Governmental Advisory Committee, which is helping us to build a cleaner, healthier, and more sustainable North American environment for future generations. I look forward to our continued collaboration and to seeing you at the Council Session later this month.
Sincerely,
Judith E. Ayres |
| cc: | M. Dolores Wesson, Chair, U.S. National Advisory
Committee |