EPA Draft Policy on Environmental Results and Outcomes

INTERIM POLICY ON ENVIRONMENTAL RESULTS
UNDER EPA ASSISTANCE AGREEMENTS

GPI 04-02

1. PURPOSE:

This policy requires funding packages submitted to Grants Management Offices by Headquarters or Regional program offices to document how proposed EPA assistance agreements will further the Agency's strategic goals.

2. BACKGROUND:

EPA has been criticized for failing to consider, at the pre-award stage, how proposed assistance agreements will contribute to achieving the Agency's strategic goals. For example, in 2001, the General Accounting Office concluded that EPA programs treated the Agency's strategic goals under the Government Performance Results Act (GPRA) as a clerical tool for categorizing grants after funds had been awarded as opposed to a guide for selecting which grants to award. In audit reports issued in 2002 and 2003, the Office of the Inspector General found that many of the work plans it reviewed focused on short-term procedural results and/or lacked negotiated environmental outcomes. The Office of Management and Budget has expressed similar concerns in its Program Assessment Rating Tool reviews of EPA grant programs. Most recently, in an October 1, 2003 hearing, the House Transportation and Infrastructure Committee questioned whether Agency grants to non-profit organizations were achieving environmental results.

To address these concerns, Goal 5 of EPA's new Grants Management Plan, "Support Identifying and Achieving Environmental Outcomes", explicitly recognizes the importance of linking assistance agreements to the Agency's performance goals and includes specific objectives to ensure that assistance agreement solicitations, work plans, and decision memoranda discuss anticipated environmental results and how they will be measured. This interim policy is the first step in implementing Goal 5.

While this policy will help clarify the relationship between proposed assistance agreements and EPA's mission, it does not authorize EPA to treat assistance agreements like contracts. Under the Federal Grant and Cooperative Agreement Act and associated EPA Order 5700.1, the principal purpose of any proposed EPA assistance agreement must be, unless otherwise provided by statute (e.g., the Senior Environmental Employment Program statute, 42 U.S.C. § 4368a ), to support a recipient in carrying out a public purpose authorized by EPA's statutory authorities, as opposed to providing goods or services for the direct benefit or use of EPA or the Federal government.
3. POLICY:

a. Mandatory. All funding packages received in the Grants Management Offices on or after February 9, 2004 must describe how the project/program work plan supports the goals of the Agency's strategic plan. The discussion may be included in, or attached to, (1) the Integrated Grants Management System (IGMS) Funding Recommendation or (2) for program offices not using the IGMS funding recommendation, the decision memorandum. The Program Results Code (PRC) of the funding assigned to the project must be consistent with the discussion.

The EPA Strategic Plan can be found at: https://www.epa.gov/ocfo/plan/2003sp.pdf. The EPA Program Project Description Book (PPDB) may also help in developing the discus-sion. The PPDB can be found at: http://intranet.epa.gov/ocfo/budget/fy05ppdbook.pdf. (This link must generally be cut and pasted into a browser.)

EXAMPLES: The following are examples of acceptable discussions under Section 3.a. of this policy.

Single Goal Project Assistance Agreements

This project supports Goal 2, Clean and Safe Water of EPA's Strategic Plan. Specifically, the recipient will undertake a study of agricultural pollution in a watershed in support of a comprehensive watershed-based approach to protecting and restoring water resources. The PRC assigned to the funding for this project is consistent with that goal.

Multi -Goal Program Assistance Agreements

This Performance Partnership Grant supports Goal 1, Clean Air and Climate Change and Goal 2, Clean and Safe Water of EPA's Strategic Plan. Specifically, the recipient will carry out a State program of environmental management which will monitor, abate, and control air and water pollution by carrying out activities in accordance with the work plan of the grant and the requirements of the Clean Air and Clean Water Acts. The PRCs assigned to the funding for this project are consistent with those goals.

Senior Environmental Employment Program Cooperative Agreements

This cooperative agreement will provide EPA with technical/administrative support in carrying out activities under Goal 1, Clean Air and Climate Change and Goal 2, Clean and Safe Water of EPA's Strategic Plan. The PRCs assigned to the funding for this cooperative agreement are consistent with these goals.

b. Optional. Program offices are encouraged, but not required, to include in the funding package a description of how the project/program fits within the Agency's Strategic Plan/GPRA Architecture. This may include identifying: (1) the applicable EPA strategic goal, objective, and where available, sub-objective, consistent with the assigned PRC; (2) the outputs or, to the extent practicable, the outcomes anticipated; and (3) any annual performance goal the project/program will help implement. Program offices may use the Program Project Description Book to provide additional insight in to where to draw appropriate linkages between assistance agreements and the GPRA Architecture.

EXAMPLE: The following is an example of a discussion that could be provided under Section 3.b. of this policy.

A school district submits a proposal to EPA under the School Bus USA Assistance Program. The school district proposes to retrofit all buses newer than the 1995 model year with certified diesel retrofit technology and to use diesel fuel with 30 parts per million sulfur.

EPA goal: Clean Air and Global Climate Change

Objective: Healthier Outdoor Air

Sub-Objective: None

Program/Project: Federal Support for Air Quality Management

Outputs: Number of school buses retrofitted, number of students riding retrofitted buses, annual number of bus miles.

Outcomes: Reductions in school days missed because of illness, reductions in reported asthma attacks, and reductions in particulate matter emissions from retrofitted buses.

Annual performance goals:

APG 5, Reduce Particulate Matter

. Tons of PM10 reduced from mobile sources
. Tons of PM2.5 reduced from mobile sources

APG 7, Reduce Air Toxic Emissions.

Program offices that choose to address how State and Tribal program assistance agreements under 40 CFR Part 35 Subparts A and B fit into the Agency's Strategic Planand GPRA Architecture may do so by simply cross-referencing portions of the assistance agreement work plan that contain the relevant information.

4. ROLES AND RESPONSIBILITIES:

Program offices must include the discussion required by Section 3.a. of this policy in all funding packages submitted to the Grants Management Offices on or after February 9, 2004.

Grants Management Offices will return funding packages received on or after February 9, 2004 if they do not contain the discussion required by Section 3.a. of this policy.

5. ANTICIPATED RESULTS:

Assistance agreements will be linked to the goals in EPA's strategic plan.

6. SUNSET/REVIEW DATE:

EPA has convened an Agency-wide work group to develop policy and guidance on the incorporation of environmental outcomes and performance measures in EPA assistance agreements. When that effort is completed, it will supersede this policy.