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al Government close to $200 billion to correct. It is therefore important that the 

 United States have an organization at the Cabinet level that is designed to ensure, 

 as far as possible, that agency managers will consider and actively support national' 

 environmental policy goals as they make decisions about programs for which they 

 are responsible. 



Ability to Satisfy Other Assessment Criteria 



In recent years, when other agencies have been proposed for Cabinet status, con- 

 cerns have been expressed that increasing the number of Cabinet members report- 

 ing to the President would make the Cabinet more cumbersome and useful. While 

 these concerns are not without merit, we believe that they are overshadowed by the 

 significant impact of environmental decisions on our economy, the importance of en- 

 vironmental issues, and the interrelationship of environmental issues and other na- 

 tional issues— most of which are represented by agencies with Cabinet status. 



Furthermore, the proposal to elevate EPA to Cabinet status meets many of the 

 criteria for elevation developed by the National Academy of Public Administration 

 (NAPA) during consideration of a proposal to create a Department of Veterans Af- 

 fairs. These criteria include improving program visibility to achieve a broad nation- 

 al goal, facilitating the achievement of cross-cutting national policy goals, and im- 

 proving an. agency's oversight and accountability. We believe that establishing a 

 Cabinet department of the environment would support the broad national goal of 

 protecting our environment, and its structure would allow consolidation of functions 

 now located in other executive branch agencies. 



Although we have not analyzed the cost associated with implementing the provi- 

 sions of S. 171, the Congressional Budget Office had calculated that the costs of con- 

 verting EPA to a department would be relatively small. The bill now under consid- 

 eration contains additional features that could add to the conversion's costs — sp)ecifi- 

 cally, the creation of a Bureau of Environmental Statistics and a Commission on 

 Improving Environmental Protection. However, the creation of such entities could 

 help to resolve some long-standing concerns, discussed below, and the associated 

 costs could, in the long run, more than pay for themselves. 



Organization and Management Issues 



From our reviews of individual programs at EPA as well as a 1988 general man- 

 agement review, 2 we conclude that several problems would remain to be addressed 

 even if EPA were elevated to Cabinet status. Among other things, the agency would 

 need better means for measuring the effectiveness of its programs, better financial 

 and other management information systems, and better internal controls, as well as 

 an organizational structure that could better reflect what are considered to be the 

 most important environmental problems. 



We are therefore pleased to see that S. 171 would establish a Bureau of Environ- 

 mental Statistics within the Department of the Environment, as well as a commis- 

 sion to study organizational and jurisdictional issues. Both throughout the agency 

 and within specific programs, as we have stated, EPA lacks both performance meas- 

 ures and information for assessing the effectiveness of its programs in improving or 

 protecting environmental quality. We commend you Mr. Chairman and Mr. Roth, 

 for taking a strong position on the need for performance measurements throughout 

 the Federal Government and for introducing legislation (S. 20) that would create a 

 pilot program. EPA could benefit from participating in such a program. Although 

 environmental programs are designed to clean up or prevent unacceptable levels of 

 pollution, EPA has not had the information necessary to judge the success of its pro- 

 grams. While the agency has developed some measures of environmental out- 

 comes — meeting national air quality standards, for example — EPA has generally 

 relied on activity-based indicators, such as numbers of permits issued or enforce- 

 ment actions taken, to track its progress. Because EPA has traditionally considered 

 itself primarily a regulatory agency, it has focused its attention and resources 

 almost exclusively on setting standards and issuing permits rather than on develop- 

 ing the information necessary to measure results. 



EPA h£is made some effort to refocus its management information systems on re- 

 sults and has begun to develop environmental indicators to use in this system, but 

 considerable work remains to be done. A central unit for collecting, analyzing and 

 disseminating environmental data, such as a Bureau of Environmental Statistics, 

 could therefore be very helpful in this effort. We would add that developing a reli- 

 able set of environmental indicators, which would allow EPA to judge the Nation's 



2 Environmental Protection Agency: Protecting Human Health and the Environment Through 

 Improved Management (GAO/RCED-88-101, Aug. 16, 1988). 



