NACEPT Committee Recommendations
November 27, 2000
Honorable Carol M. Browner
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460
Dear Administrator Browner:
It is my pleasure to submit the EPA Sector Program Plan 2001-2005 and the recommendations developed by the National Advisory Council for Environmental Policy and Technology's (NACEPT) Standing Committee on Sectors. The EPA Sector Program Plan includes a revised vision, as recommended below by the Sector Committee members. Comments from the NACEPT Council are also enclosed. It is my understanding that the Council's comments will be taken under consideration as the Agency moves forward with the Plan.
As the national program manager for the federal advisory committee management program in EPA and in keeping with the requirements of the Government Performance and Results Act (GPRA) to ensure measurable outcomes and results, the Office of Cooperative Environmental Management (OCEM) will monitor the impact and use of recommendations and advice provided by the Council. Agency feedback on the use of recommendations and advice is critical to ensuring increased communication between the Council and its subcommittees.
The Sector Committee reviewed and heartily endorses EPA's Sector Program Plan 2001-2005. The Committee agrees that the plan will move sector-based approaches forward in positive, concrete ways. While the Committee endorses the plan, it must point out that in many ways it understates the very significant potential of multimedia sector approaches to foster dramatic advances in environmental performance.
The Committee embraces the vision of the EPA Plan, but recommends that it be revised to provide a more focused and powerful message in support of future sector activities by including the following concepts:
- Integration of environmental and economic objectives
- Continuous improvement in pursuit of environmental excellence
The Committee recommends the following themes for EPA to pursue as part of its programs.
1. Aggressive implementation. To extend the transformative potential of the document, the Committee recommends the Agency's top management challenge core programs to use sector approaches to further the Agency's overall mission. Sector analysis is an essential tool. In particular,
- Sectors with the greatest environmental and human health impacts ought to be greater priorities in the planning and budgeting of agency resources.
- Where it reveals crosscutting or multimedia issues, the Agency should undertake enhanced coordination in rulemaking to achieve more effective and efficient environmental programs.
- It significantly contributes to a complete picture of pollution loading to communities and enables permitting to reach a more comprehensive reduction of adverse environmental impacts.
2. EPA program directors should consider sector opportunities as part of their annual planning. While the Sector Plan builds consideration of sector approaches into EPA planning processes, successful integration into EPA mainstream programs requires full and proactive participation by agency management, at all levels.
3. Leadership support for change. As the plan indicates, sector approaches are already in use with success in the Agency. This plan begins the process of institutionalizing sector-based experiments. Because many future environmental improvements would benefit from this approach, US EPA leadership must support this shift in Agency program activity.
4. Removing Roadblocks. This Committee recognizes the significant forward-looking perspective this sector plan represents. However, it is concerned that the Plan does not go far enough in identifying specific barriers and recommending changes necessary to allow sector-based approaches to become a mainstream agency activity. New US EPA leadership must encourage such a rigorous analysis and take the forceful actions to increase the efficiency and effectiveness of the agency's programs.
5. Build on existing efforts. EPA should build upon many prior sector approaches, both internal to EPA and outside the agency, including a greater willingness by all stakeholder groups to embrace a non-adversarial, collaborative approach to address environmental problems more effectively.
6. Ensure the quality and public availability of sector information. The Plan recognizes the need to share existing data on sector programs, but it is important to incorporate new data and knowledge into specific sector activities and to assure the quality of the information used. EPA should look for appropriate ways to provide robust, accessible, and understandable public information on the environmental challenges, opportunities, and track record of priority industry sectors.
On behalf of the NACEPT Council and Sector Committee, we look forward to your response to the recommendations.
Robert L. Rhodes, Jr.
National Advisory Council for Environmental Policy and Technology