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United States Government Accountability Office: 
GAO: 

Testimony: 

Before the Subcommittee on Interior, Environment, and Related 
Agencies, Committee on Appropriations, U.S. House of Representatives: 

For Release on Delivery: 
Expected at 9:30 a.m. EST:
Wednesday, March 2, 2011: 

Environmental Protection Agency: 

Major Management Challenges: 

Statement of David C. Trimble, Acting Director:
Natural Resources and Environment Team: 

EPA Major Management Challenges: 

GAO-11-422T: 

GAO Highlights: 

Highlights of GAO-11-422T, testimony before the Subcommittee on 
Interior, Environment, and Related Agencies, Committee on 
Appropriations, U.S. House of Representatives. 

Why GAO Did This Study: 

The Environmental Protection Agency’s (EPA) overarching mission is to 
protect human health and the environment by implementing and enforcing 
the laws intended to improve the quality of the nation’s air, water, 
and lands. EPA’s policies and programs affect virtually all segments 
of the economy, society, and government. As such, it operates in a 
highly complex and controversial regulatory arena. 

In recent years, GAO’s work has identified several significant and 
persistent challenges across a range of EPA programs and activities 
and has proposed corrective actions to enable the agency to more 
effectively accomplish its mission. Based on this work, this testimony 
highlights some of the major management challenges facing EPA today, 
the agency’s efforts to address them, and the work GAO believes 
remains to be done. 

What GAO Found: 

On the basis of recent GAO work, key management challenges facing EPA 
include the following: 

* Improving agencywide management. EPA has struggled for years to 
deploy its staff efficiently and in a manner that would do the most 
good. It has also sought to improve the reliability of its 
environmental enforcement and other program data, as well as its 
coordination among EPA offices and with other agencies to improve 
efficiency and leverage limited resources. Generally, the agency’s 
initiatives in these areas have yet to achieve their intended goals. 
In this connection, GAO is currently examining the extent to which EPA 
is taking a coordinated approach in managing its laboratories. 

* Transforming EPA’s processes for assessing and controlling toxic 
chemicals. EPA has yet to develop sufficient chemical assessment 
information for limiting public exposure to many chemicals that may 
pose substantial health risks. As a consequence, GAO in February 2011 
reaffirmed the need to transform EPA’s process for assessing and 
controlling toxic chemicals by continuing it as one if GAO’s “high-risk”
areas warranting increased attention by Congress and the executive 
branch. 

* Reducing pollution in the nation’s waters. Among the nation’s most 
pressing water quality problems with which EPA and other stakeholders 
struggle are the contributions of diffuse, or “nonpoint,” sources of 
pollution and the challenges posed by deterioration in the nation’s 
premier watersheds, such as the Chesapeake Bay and Great Lakes. 
Multibillion-dollar liabilities associated with replacing and 
upgrading the nation’s aging water infrastructure are a looming issue 
that, if not sufficiently addressed, will impact water quality. 

* Addressing the cost and pace of cleanup at Superfund and other 
hazardous waste sites. EPA’s Superfund program is intended to ensure 
the cleanup of hazardous waste sites on both private and public lands. 
Nonetheless, 30 years after the program began, GAO found that cleanup 
costs for remaining hazardous waste sites will not only be 
substantial, but that problems with the accuracy and completeness of 
data on the amount of remaining cleanup work prevent EPA from reliably 
estimating these costs. 

* Addressing the agency’s emerging role in climate change issues. As a 
highly interdisciplinary issue, climate change poses management 
challenges for the federal government at large. For EPA, particular 
climate change-related challenges pertain to the legal and 
administrative barriers facing the agency in its ongoing efforts to 
reduce carbon emissions, its difficulties in coordinating activities 
involving numerous other agencies and other levels of government, and 
its efforts to account for and manage data on greenhouse gas emissions. 

What GAO Recommends: 

GAO has made a number of recommendations intended to improve EPA’s 
programs by, for example, improving the information upon which key 
regulatory decisions are based; improving oversight over enforcement 
and other key program activities; and improving EPA’s coordination 
with other agencies in program delivery. EPA has concurred with most 
of the recommendations and has taken steps to implement some of them. 

View [hyperlink, http://www.gao.gov/products/GAO-11-422T] or key 
components. For more information, contact David Trimble at (202) 512-
3841 or trimbled@gao.gov. 

[End of section] 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss management challenges facing 
the Environmental Protection Agency (EPA). These challenges are made 
all the more important by increased demand for improved government 
performance and responsiveness, as well as greater accountability. EPA 
operates in a highly complex and controversial regulatory arena, and 
its policies and programs affect virtually all segments of the 
economy, society, and government. 

As you know, EPA's responsibilities are carried out under a complex 
array of environmental laws, including the Clean Air and Clean Water 
acts, the Toxic Substances Control Act (TSCA), and others. The legal 
framework within which the agency operates is also shaped by numerous 
court orders resulting from lawsuits that have been filed over the 
years by states, concerned citizens, special interest groups, and 
others. Structurally, EPA comprises headquarters offices largely 
aligned with its primary authorizing statutes and 10 regional offices 
that help to implement these statutes across the country. The regional 
offices possess considerable autonomy, which has sometimes led to 
questions and concerns about variation from region to region in 
enforcement and other aspects of program delivery. The agency's 
budget, while rising in nominal terms from $7.8 billion for fiscal 
year 2000 to $10.4 billion for fiscal year 2010, has remained 
relatively flat in real terms.[Footnote 1] EPA's fiscal year 2010 
budget included about $1.1 billion for clean air and climate change, 
$4.9 billion for clean water (which includes federal funding for both 
the Clean Water and Drinking Water state revolving funds), and $1.8 
billion for land restoration.[Footnote 2] 

My testimony today updates our 2009 report on EPA's management 
challenges[Footnote 3] and is drawn largely from our work over the 
last several years (see Related GAO Products at the end of this 
statement). Many of these reports included recommendations intended to 
improve EPA's programs by enhancing the information it uses to manage 
its programs and strengthening internal controls.[Footnote 4] EPA has 
generally concurred with our recommendations and has taken steps to 
implement some of them. I will highlight some notable issues arising 
from our recent work. Some are long-standing issues involving the 
agency's core programs; others are emerging challenges for which we 
believe the agency will need to become better prepared. With this in 
mind, I would like to focus my remarks today on the need to (1) 
improve key aspects of the agency's overall management, (2) transform 
EPA's processes for assessing and controlling toxic chemicals, (3) 
reduce pollution in the nation's waters, (4) address the cost and pace 
of cleanup at Superfund and other hazardous waste sites, and (5) 
address the agency's emerging role in climate change issues. 

Improving Agencywide Management: 

EPA's size, geographical dispersion, reliance on its partnership with 
state and local governments, and broad and complex mission all combine 
to make management of the agency a formidable challenge. Our recent 
work has identified several particular management challenges at EPA, 
including the need to address workload and workforce planning, to 
ensure consistent environmental enforcement and compliance data, and 
to better coordinate with other agencies to more effectively leverage 
limited resources. 

Addressing Workload and Workforce Planning Needs: 

EPA has struggled for years to identify its human resource needs and 
to deploy its staff throughout the agency in a manner that would do 
the most good. In 2008, we reported that rather than establishing a 
process for budgeting and allocating human resources that fully 
considers the agency's current workload, EPA makes requests for 
funding and staffing by making incremental adjustments, largely based 
on historical precedent.[Footnote 5] We noted that the agency has not 
comprehensively analyzed its workload and workforce since the late 
1980s to determine the optimal numbers and distribution of staff 
agencywide. Moreover, EPA's human capital management systems have not 
kept pace with changing legislative requirements and priorities, 
changes in environmental conditions in different regions of the 
country, and the much more active role that states now play in 
carrying out day-to-day-activities of federal environmental programs. 

To remedy its piecemeal methods for determining workload and staff 
allocation, we recommended that EPA improve its workforce planning by 
identifying the factors driving its workload and developing more 
accurate allocation systems for deploying staff with the requisite 
skills and capabilities to areas where they are most needed. The 
agency has taken some recent steps to improve its workforce planning. 
For example, in 2009 it hired a contractor to provide information 
about the agency's workload in several key areas, such as staffing 
levels and workload shifts. In addition, the agency asked one of its 
advisory councils to help developing its next strategic workforce plan 
to supersede the last plan established in 2006, which delegated 
responsibilities to the various offices. We have not evaluated whether 
EPA has made meaningful progress in these efforts. 

Ensuring Consistent Environmental Enforcement and Compliance Data: 

EPA has authorized states to carry out many of the day-to-day 
responsibilities for timely and appropriate enforcement of 
environmental laws and regulations. We have noted instances in the 
past where EPA has not (1) identified the causes of poorly performing 
state enforcement programs, (2) informed the public about how well the 
states are implementing their enforcement responsibilities, or (3) 
assessed the performance of EPA's regional offices in carrying out 
their state oversight responsibilities--performance that has generally 
proven to be inconsistent over the years.[Footnote 6] 

EPA has been slow to improve long-standing problems with often 
incomplete and unreliable enforcement data. Among other things, 
enforcement data are needed to accurately identify and characterize 
regulated entities to improve the transparency and accuracy of the 
agency's reports to Congress and the public when reporting on the 
effectiveness of the enforcement programs. Furthermore, we have 
reported problems in how EPA calculates and reports on measures of 
program effectiveness, such as penalties, the value of injunctive 
relief, and any resulting reduction in pollution.[Footnote 7] These 
problems may undermine the transparency and accuracy of EPA's reported 
outcomes and cause the agency to either over-or underreport its 
enforcement achievements. 

In recent years, we have recommended ways for EPA to enhance its 
oversight of regional and state enforcement activities so as to 
implement environmental programs consistent with the requirements of 
federal statutes and regulations. In particular, we recommended that 
EPA develop an action plan for addressing enforcement problems 
identified in state programs; ensure that states have sufficient 
resources to implement and enforce programs as authorized by EPA; and 
help the states improve their capacity for enforcement.[Footnote 8] We 
also suggested that EPA (1) routinely assess the performance of 
regional and state enforcement programs and communicate the results of 
these assessments to the public and the regulated industry and (2) 
disclose more information when reporting penalties and estimates of 
the value of injunctive relief and pollution reduction.[Footnote 9] 

EPA has generally agreed with our recommendations and is in the 
process of implementing them. In particular, the agency has developed 
an initiative known as the State Review Framework that it believes 
will (1) address many of the long-term problems related to providing 
fair, consistent, and transparent enforcement throughout the country 
and (2) obtain accurate data that can be used to determine the extent 
of state compliance with enforcement standards and the need for 
corrective actions. Still, implementation of the framework is clearly 
a work in progress. During its fiscal year 2008 evaluation of the 
framework, for example, EPA identified significant noncompliance with 
water permitting requirements and an unacceptably low level of 
enforcement activity. In response, in 2009 the agency issued its Clean 
Water Act Enforcement Action Plan, which described efforts to (1) 
raise the bar for EPA and state enforcement performance; (2) inform 
the public clearly and fully about serious Clean Water Act violations 
and actions to address them; and (3) use the latest technology to 
transform the collection, use, and availability of EPA data. In 
addition, EPA now publishes its State Review Framework reports and 
data on enforcement performance on its Web site and has developed new 
Web-based tools to help the public search and analyze the performance 
data. 

EPA also stated that it would take actions to disclose more 
information when reporting estimates of injunctive relief and 
pollution reductions and consider our recommendation to report 
collected penalties. For example, in 2010, EPA began reporting 
penalties in a manner that clearly indicates that penalties are 
reported as assessed, rather than as collected, and began properly 
presenting time-series data that are adjusted for inflation. Overall, 
the agency's efforts in this area are still in their early stages, and 
their success is uncertain. Much will depend on the continued 
commitment of senior management, along with sufficient priority and 
resources. 

Coordinating with Other Agencies to More Effectively Leverage Limited 
Resources: 

EPA relies on other federal and state agencies to help implement its 
programs. Given the federal deficit and the government's long-term 
fiscal challenges, it is imperative that EPA improve coordination with 
its federal and state partners to reduce administrative burdens, 
redundant activities, and inefficient uses of federal resources. For 
example, EPA and other federal agencies may work together to fund 
water infrastructure projects.[Footnote 10] In 2009, we reported that 
EPA and six federal agencies obligated $1.4 billion for drinking water 
and wastewater projects to assist communities in the U.S.-Mexico 
border region from fiscal years 2000 through 2008.[Footnote 11] 
Nevertheless, we found that the agencies' efforts to fund these 
projects were ineffective because the agencies, with the exception of 
the Indian Health Service, had not comprehensively assessed the 
region's needs and lacked coordinated policies and processes for 
selecting and building projects. As a result, we suggested that 
Congress may wish to consider establishing an interagency task force 
to develop a plan for coordinating funding to address the region's 
most pressing needs. 

In addition to funding water infrastructure projects, EPA has 
coordinated with numerous federal and state agencies as the lead 
agency in a multi-billion dollar effort to restore the Chesapeake Bay. 
We found, however, that key commitments and plans were inconsistent 
with one another, and some were viewed to be unachievable by some 
partners. We found, however, that key commitments and plans were 
inconsistent with one another, and some were viewed to be unachievable 
by some partners. In 2008, we reported that the Chesapeake Bay Program 
(a partnership among EPA, several states, and the Chesapeake Bay 
Commission) had taken several actions in response to our findings, 
such as developing a strategic framework to unify planning documents 
and identify how it will pursue its goals. While these actions are 
positive steps, we found that additional actions are needed before the 
program has the comprehensive, coordinated implementation strategy we 
recommended.[Footnote 12] 

Transforming EPA's Processes for Assessing and Controlling Toxic 
Chemicals: 

As we reported in March 2009, EPA's ability to effectively implement 
its mission of protecting public health and the environment depends on 
credible and timely assessment of the risks posed by toxic chemicals. 
Such assessments are the cornerstone of scientifically sound 
environmental decisions, policies, and regulations under a variety of 
statutes, including TSCA. EPA assesses chemicals under its Integrated 
Risk Information System (IRIS) program and is authorized under TSCA to 
obtain information on the risks of chemicals and to control those it 
determines pose an unreasonable risk. Because EPA had not developed 
sufficient chemical assessment information under these programs to 
limit public exposure to many chemicals that may pose substantial 
health risks, in 2009 we added this issue to our list of areas at high 
risk for waste, fraud, abuse, and mismanagement or in need of broad- 
based transformation.[Footnote 13] In a number of reports, we have 
also made recommendations to (1) improve the timeliness and 
credibility of EPA's IRIS program, which provides EPA's scientific 
position on the potential human health effects of more than 540 
chemicals, and (2) enhance EPA's ability under TSCA to, among other 
things, obtain health and safety information from the chemical 
industry. We also recently addressed nanotechnology as an emerging 
area of toxic substance regulation. 

Addressing IRIS' Timeliness, Transparency, and Credibility: 

EPA's IRIS database provides the basic information the agency needs to 
determine whether it should establish controls to protect the public 
from exposure to toxic chemicals in the air, in water, and at 
hazardous waste sites. In March 2008, we reported that IRIS' viability 
was at risk because EPA had been unable to complete timely and 
credible chemical assessments--including those for chemicals of 
greatest concern, such as formaldehyde and dioxin.[Footnote 14] 
Assessments of these two chemicals have been in progress for 13 and 19 
years, respectively. In addition, EPA had been unable to decrease its 
long-standing backlog of ongoing assessments or to keep its existing 
assessments current. 

In May 2009, EPA revised its IRIS assessment process. If implemented 
effectively, these assessment reforms will be largely responsive to 
our 2008 recommendations. Among other things, they will restore EPA's 
control of the process and increase its transparency. Specifically, 
under the prior process, interagency reviews were required and managed 
by the Office of Management and Budget, and EPA was not allowed to 
proceed with assessments at various stages until the office agreed 
that EPA had sufficiently responded to interagency comments. In 
contrast, under the reforms, EPA is to manage the entire assessment 
process, and all written comments on draft assessments provided during 
the interagency process are to be part of the public record. It is too 
soon to determine whether the reforms will be effective, but EPA 
reports it has made some progress in addressing its assessment 
backlog.[Footnote 15] We are currently reviewing EPA's implementation 
of the revised process. 

Addressing EPA's Ability to Obtain Chemical Health and Safety 
Information: 

We have also reported that EPA's assessments of industrial chemicals 
under TSCA provide limited information on health and environmental 
risks.[Footnote 16] In contrast to the approach taken by the European 
Union--which generally places the burden on companies to provide data 
on the chemicals they produce and to address the risks posed by these 
chemicals to human health and the environment--TSCA generally places 
the burden on EPA to obtain information about the roughly 80,000 
chemicals in the agency's TSCA inventory. For example, the act 
requires EPA to demonstrate certain health or environmental risks 
before it can require companies to further test their chemicals. 
Consequently, EPA does not routinely assess the risks of the 
industrial chemicals already in use.[Footnote 17] 

For the approximately 700 new chemicals introduced into commerce 
annually, chemical companies are required to provide EPA with certain 
information in premanufacture notices, and EPA can ban or limit the 
chemicals' use if the information is inadequate. Nevertheless, 
although 85 percent of the notices lack any health or safety test 
data, EPA does not often use its authority to obtain more information. 
After our reports, EPA began taking steps to address some of these 
issues. For example, under its existing authorities, EPA has initiated 
actions on such chemicals as mercury and lead to, for example, ban or 
phase out their use in certain products. Most of these actions are in 
their early stages of development. 

As we reported in our February 2011 High-Risk Update, EPA needs to 
continue to demonstrate a strong commitment to and support of the IRIS 
program and its TSCA initiatives. Specifically, we stated that EPA 
needs to ensure that its 2009 IRIS reforms are implemented effectively 
and that the program can routinely provide timely and credible 
assessments. Regarding TSCA, we have recommended both statutory and 
regulatory changes to, among other things, provide EPA with additional 
authorities to obtain health and safety information from the chemical 
industry and to shift more of the burden to chemical companies for 
demonstrating the safety of their chemicals.[Footnote 18] The EPA 
Administrator has expressed support for TSCA reforms and in 2010 
developed principles for addressing them. 

Addressing Nanotechnology as an Emerging TSCA Issue: 

Finally, one emerging area of toxic substance regulation on which we 
recently reported, and for which EPA faces challenges, is the area of 
nanotechnology.[Footnote 19] Nanotechnology involves the ability to 
control matter at the scale of a nanometer--one billionth of a meter. 
The world market for products containing nanomaterials is expected to 
reach $2.6 trillion by 2015. EPA has taken some regulatory action 
under TSCA to address potential risks to human health and the 
environment related to nanotechnology, but other planned actions have 
not yet gone into effect. Overall, EPA has issued four regulations 
characterizing the manufacture of four different nanomaterials as 
significant new uses of existing chemicals under TSCA. 

In our May 2010 report, we recommended, among other things, that EPA 
finalize a number of regulatory actions it had planned to pursue. 
Specifically, according to EPA, the agency plans to propose a new rule 
that would regulate, in a single rule, a range of nanoscale versions 
of existing chemicals as significant new uses of those chemicals. EPA 
also plans to require companies to provide certain information on 
nanomaterials--including production volume, methods of manufacture and 
processing, exposure and release, and available health and safety 
studies--and plans to require companies to generate test data on the 
health effects of different nanomaterials. At the time our report was 
released, EPA reported that it planned to propose these rules by 
December 2010, but has not yet done so. While EPA continues to work on 
these rules, however, products may be entering the market without EPA 
review of available information on their potential risk. In addition, 
although EPA requires chemical companies to periodically provide 
certain information on many of the chemicals currently in commerce, it 
has not extended this requirement to nanomaterials. 

Reducing Pollution in the Nation's Waters: 

The Clean Water Act establishes the basic structure for regulating 
discharges of pollutants into the waters of the United States and 
regulating the quality of surface waters. Since its enactment, much 
progress has been achieved under the act to control pollution from 
wastewater treatment plants and other specific "point sources" of 
discharge. Since that time, however, other challenges have emerged and 
continue to confront EPA and other levels of government in their 
efforts to ensure safe and abundant water supplies for the American 
people. These challenges include (1) the need to focus more attention 
on diffuse, or "nonpoint," sources of pollution to address the most 
significant of the nation's remaining water quality problems; (2) the 
unique challenges posed by deterioration in the nation's premier 
watersheds including, among others, the Chesapeake Bay and Great 
Lakes; and (3) daunting challenges posed by the multibillion dollar 
liabilities associated with replacing, maintaining, and building new 
water infrastructure. 

Controlling Nonpoint Sources of Pollution: 

The Clean Water Act's effectiveness has become increasingly challenged 
by a recognition that the largest share of the nation's remaining 
water quality problems are more decentralized and diffuse in nature--
and therefore more difficult to monitor and regulate. One such 
nonpoint pollution source, for example, is urban storm water runoff. 
Pollutants and sediment carried by storm water, as well as the volume 
and temperature of runoff, can alter aquatic habitats and make it hard 
for fish and other organisms to survive.[Footnote 20] Polluted storm 
water runoff can also make fish and shellfish unsafe to eat and can 
adversely affect people using fresh-and saltwater areas for 
recreation. In 2007, we reported that while many communities were 
still implementing their first permits for controlling storm water 
runoff, several factors influence the extent to which EPA's storm 
water program burdens a community, such as prior storm water 
management experience.[Footnote 21] We recommended that EPA evaluate 
the implementation of its storm water program, issue additional 
program guidance, and consider regulatory changes to improve the 
quality and consistency of activity reporting by communities. EPA 
agreed with our recommendations to develop guidance to help the agency 
obtain better data to evaluate the program and provided additional 
program guidance to states and regions on such items as storm water 
pollution prevention plans. In 2009, the agency issued a guide to 
assist permit writers in strengthening storm water permits in 2010. 

The agricultural sector accounts for a large share of water problems 
stemming from nonpoint sources and therefore much of the effort to 
control such pollution lies within the jurisdiction of the U.S. 
Department of Agriculture. Crop production, for example, impairs water 
quality as pesticides, fertilizer, and sediment run off fields and 
into nearby water bodies. Of particular note, a 10-year, nationwide 
study published in 2006 by the U.S. Geological Survey detected 
pesticides in 97 percent of streams in agricultural and urban 
watersheds. In 2009, we reported that many experts believe that the 
increased use of pesticides (insecticides and herbicides) related in 
particular to increased crop production for biofuels, will likely 
further degrade surface and ground water quality.[Footnote 22] 

Another major source of agriculture-related pollution stems from 
discharges associated with large-scale animal feeding operations. 
[Footnote 23] More than a dozen government-sponsored or peer-reviewed 
studies since 2002 on water pollutants emitted by concentrated animal-
feeding operations found increased levels of phosphorus, nitrogen, or 
hormones in surface water and groundwater near animal-feeding 
operations. Excessive amounts of these nutrients can deplete oxygen in 
water, which could result in fish deaths, reduced aquatic diversity, 
and illness in infants. Our 2008 report on the subject found that 
despite its long-term regulation of concentrated animal-feeding 
operations, EPA still lacks comprehensive and reliable data on the 
number, location, and size of the operations that have been issued 
permits and the amounts of discharge they release.[Footnote 24] As a 
result, EPA has neither the information it needs to assess the extent 
to which these concentrated animal-feeding operations may be 
contributing to water pollution, nor the information it needs to 
ensure compliance with the Clean Water Act. 

The question of how well EPA is coordinating its own efforts to 
control agricultural pollution with Agriculture is an important part 
of our ongoing review of the agency's Nonpoint Source Management 
Program, established under section 319 of the Clean Water Act. This 
program supports state nonpoint source management programs, providing 
funds to states to implement projects directed toward resolving 
nonpoint source pollution problems. Among the key issues being 
addressed in this broad program review are the extent to which EPA 
coordinates the implementation of its section 319 program with similar 
efforts to control agricultural nonpoint sources of pollution 
undertaken by Agriculture, as well as with other federally funded 
efforts to control nonpoint sources of pollution (including efforts 
funded through EPA's own Clean Water State Revolving Fund). 

Emphasizing a Watershed-Based Approach: 

EPA has increasingly emphasized a "watershed-based approach" that 
attempts to restore and protect the nation's water resources by taking 
into account the full range of stresses emanating from all pollution 
sources. Under this holistic approach, EPA and its partners seek to 
identify the priority threats to large, often multistate watersheds 
like the Great Lakes and Chesapeake Bay. EPA partners with federal, 
state, and local agencies and nongovernmental organizations to develop 
and implement approaches that reduce pollution in out nation's 
significant water bodies. 

Nonetheless, after decades of effort and expense by EPA and its 
partners to spearhead restoration efforts for these watersheds, we 
reported that these efforts have been impeded by a lack of targeted 
strategies; poor coordination among federal, state, and local 
stakeholders; and unrealistic goals for ensuring that limited 
restoration resources are being used for the most effective 
restoration activities. In 2006, for example, we recommended that EPA 
ensure that the Chesapeake Bay Program develop a coordinated 
implementation strategy unifying its various planning documents and 
establishing a means to better target its limited resources to the 
most cost-effective restoration activities.[Footnote 25] Along similar 
lines, in 2008 we recommended that EPA develop for its Great Lakes 
Initiative a more consistent permitting strategy for controlling 
mercury and gather more information to help it develop water quality 
standards and assess the effect of programs intended to minimize 
pollutants that are exceeding standards.[Footnote 26] 

EPA has taken some actions in response to our recommendations. In 
addition, in May 2009, the President issued an executive order 
establishing a Federal Leadership Committee for the Chesapeake Bay to 
oversee the development and coordination of programs and activities of 
agencies participating in protection and restoration of the bay. 
Chaired by EPA, the committee includes six other federal agencies. 
Part of its responsibilities included developing a strategy for 
coordinated implementation of existing programs and projects to guide 
efforts to protect and restore Chesapeake Bay. The resulting strategy 
was issued in May 2010. We are currently assessing this strategy. 
Additionally, EPA has indicated that it plans to work with the Great 
Lakes states in assessing approaches for reducing mercury in lieu of 
developing a mercury permitting strategy. 

Rebuilding the Nation's Aging Water Infrastructure: 

Some of the most daunting water pollution control problems will be 
those faced by EPA and the nation's water utilities in addressing the 
multibillion-dollar costs of upgrading aging and deteriorating water 
infrastructure and building new infrastructure to serve a growing 
population. The investment made throughout the 1970s and 1980s to 
build and upgrade the nation's water infrastructure accounted for much 
of the progress in past years to deal with what were, at that time, 
the pressing water issues of high bacterial contamination and toxic 
water pollution. Many of the wastewater treatment plants and other 
water infrastructure built in those years, however, have since 
reached, or will soon reach, the end of their design lives. Frequent 
and highly publicized incidents of combined sewer overflows into 
rivers and streams, as well as water main breaks in the nation's 
largest cities, have been perhaps the most visible manifestations that 
the problem is growing. 

EPA provides funding to the states for water infrastructure upgrades 
and construction through the Clean Water and the Drinking Water state 
revolving funds, authorized by Congress in 1987 and 1996, 
respectively. Congress provided $2.1 billion and $1.4 billion, 
respectively, for each program in fiscal year 2010. These funds 
supplement other revenue--from water rates or other taxes--raised by 
local utilities to pay for their infrastructure projects. While EPA 
also received and distributed about $6 billion in additional water 
infrastructure funding under the American Recovery and Reinvestment 
Act, the total cost to meet water infrastructure needs across the 
country through 2029 has been estimated to be from $485 billion to 
$1.2 trillion. 

EPA faces a challenge in working with the states and utilities to 
address this issue. We have noted in the past that better management 
techniques can, at least to some extent, help utilities make the best 
use of available dollars in their struggle to meet their 
infrastructure needs. We recommended comprehensive asset management--a 
technique whereby water systems systematically identify their needs, 
set priorities and better target their investments--as a tool for 
helping utilities make better use of available funds. However, 
additional funds--or revenue from rate increases--will still likely be 
needed to address future needs. 

To address options for alternative funding sources for these 
infrastructure needs, we have issued reports providing information on 
various proposals to develop alternative funding sources and 
mechanisms to address current and projected water infrastructure 
needs. In 2009, we reviewed one proposal to establish a Clean Water 
Trust Fund, which would provide a dedicated source of federal funding 
for wastewater infrastructure.[Footnote 27] Stakeholders we 
interviewed disagreed over whether EPA should administer such a trust 
fund as part of the Clean Water State Revolving Fund. These 
stakeholders also disagreed over whether funding should be provided as 
loans or grants to recipients, although a majority did agree that 
funds should pay for capital projects. We also discussed potential 
revenue sources for funding a Clean Water Trust Fund and obstacles to 
generating revenue from these sources. 

In 2010, we examined two other proposed alternative funding sources 
for water infrastructure projects: a national infrastructure bank and 
public-private partnerships.[Footnote 28] Concerning an infrastructure 
bank, stakeholders disagreed over whether an infrastructure bank 
should be administered by a federal agency or structured as a 
government corporation or other entity and over which types of 
projects--such as large infrastructure projects or small ones--should 
be eligible for bank financing. Stakeholders did agree, however, that 
federal funds should be used to finance a bank initially but that 
other mechanisms could be used to generate funds for financing 
projects over the long term. Regarding public-private partnerships, 
officials for the 7 municipalities that had experience with such 
arrangements said that advantages of public-private partnerships 
include access to nontraditional funding sources, creating potential 
efficiency through economies of scale, and completing projects more 
quickly. These officials also identified challenges to public-private 
partnerships, such as local opposition to potential or perceived rate 
increases, higher interest rates charged by private entities involved 
in the partnership, and increased project costs because of complex 
contracts and arrangements. 

As a related matter, in 2010, we reviewed 14 states' spending of 
Recovery Act funding on water infrastructure projects.[Footnote 29] 
The Recovery Act provided $6 billion in additional funding for states, 
$2 billion for the Drinking Water State Revolving Fund and $4 billion 
for the Clean Water State Revolving Fund. We found that these states 
allocated the funding to 504 drinking water projects and 890 clean 
water projects. We also found that the states met Recovery Act 
requirements for providing Clean Water revolving fund assistance for 
"green" projects (projects that included environmentally friendly 
infrastructure, provided water-or energy-efficiency improvements, or 
other environmentally innovative activities).[Footnote 30] We found, 
however, that attention and monitoring by EPA and the states of 
Recovery Act projects could be strengthened. As a result, we 
recommended that EPA work with the states to implement specific 
oversight procedures to monitor and ensure Recovery Act compliance. 
EPA issued new guidance in June 2010. We are continuing our review of 
EPA's implementation of Recovery Act funds and how the funds will help 
address states' water quality problems. As part of this work, we will 
continue to assess EPA's and the states' monitoring of Recovery Act 
projects. 

Costs and Pace of Cleanup at Superfund and Other Hazardous Waste Sites: 

To protect human health and the environment from the effects of 
hazardous substances, Congress enacted the Comprehensive Environmental 
Response, Compensation, and Liability Act in 1980, which established 
the Superfund program. Since 1980, EPA has identified more than 47,000 
hazardous waste sites potentially requiring cleanup. As of the 
beginning of fiscal year 2010, 1,269 of the most seriously 
contaminated sites were included on EPA's National Priorities List: 
1,111 nonfederal sites and 158 federal facilities. Among the key 
findings of our recent work are that (1) cleanup costs are likely to 
be substantial, (2) problems with the accuracy and completeness of 
data prevent the agency from estimating future cleanup costs, and (3) 
several key obstacles have delayed cleanup progress at Department of 
Defense (DOD) installations. Our recent work provides an indication of 
the challenges that lie ahead for this important program. 

Addressing Substantial Cleanup Costs: 

We and other organizations have cited the growing gap between the 
costs associated with cleaning up sites remaining on the National 
Priorities List and funds available to do so. Cleanup efforts at 
listed sites are typically expensive and can take many years. While 
responsible parties are liable for conducting or paying for site 
cleanup of hazardous substances--and EPA can seek reimbursement for 
its cleanup costs from these parties--the parties in some cases cannot 
be identified or may be unwilling or financially unable to perform the 
cleanup. To fund EPA-led cleanups at nonfederal National Priorities 
sites, EPA uses the Hazardous Substance Superfund (trust fund) from 
which EPA receives annual appropriations. Historically, the trust fund 
was financed primarily by taxes on crude oil and certain chemicals, as 
well as an environmental tax on corporations based on their taxable 
income. The authority for these taxes expired in 1995, however, and 
shortly thereafter the balance in the trust fund started to diminish. 
Since 2001, appropriations from general revenues have been the largest 
source of funding for the trust fund. At the start of fiscal year 
2009, the trust fund had a balance of $137 million. Superfund program 
appropriations have averaged about $1.2 billion annually since 1981, 
although the annual level of these appropriated funds has generally 
declined in recent years when adjusted for inflation. 

In June 2010 we reported that EPA's cost to remediate existing and 
future National Priorities sites will likely exceed current funding 
levels.[Footnote 31] Considerable work remains at most nonfederal 
sites on the list with unknown or unacceptable human exposures, and 
some site cleanups have not been funded at a level that is sufficient 
to ensure meaningful results. Moreover, site costs are likely to 
increase because, according to EPA, in the program's early years the 
agency focused resources on sites that needed less construction work 
and were farther along in the cleanup process. Consequently, the sites 
that have been on the National Priorities List the longest without 
completing construction of cleanup remedies are likely to face more 
complex and costly future cleanup work. 

Resolving Data Limitations Hindering Estimates of Program Costs: 

While remedial actions have been implemented or are under way at most 
sites on the National Priorities List, the amount of work remaining is 
unclear because, as we reported in July 2009, data on whether 
construction is complete at sites do not provide a clear picture of 
the amount of work that actually remains at sites, and the progress of 
cleanup is even less clear for sites where construction is not 
complete.[Footnote 32] EPA program status reports do not provide 
information on the number and cleanup status of megasites--sites with 
actual or expected total cleanup costs, including removal and remedial 
action costs, that are expected to amount to $50 million or more 
(especially mining and sediment sites). This information could help 
indicate the types of conditions driving EPA's remedy decisions at 
sites that were listed more recently, as well as the impediments to 
cleanup progress at older sites. Additionally, these reports do not 
provide information on the number of sites where responsible parties 
are financially unable to help pay for cleanup activities or on the 
potential impact on EPA's ability to carry out cleanup activities when 
it cannot obtain reimbursement from responsible parties for agency 
cleanup costs. Such information could help indicate the factors that 
are driving program expenditures and potential future costs. 

Accordingly, we recommended that EPA assess the comprehensiveness and 
reliability of the data the agency collects and, where necessary, 
improve the data to provide aggregated information on (1) the status 
and cost of cleanups at individual sites, particularly complex and 
expensive sites; (2) the extent to which there are viable responsible 
parties at sites on the National Priorities List; and (3) the 
potential financial impacts from EPA's inability to obtain 
reimbursement for agency cleanup costs from nonviable responsible 
parties. EPA agreed to assess data reported on program status and 
costs but did not agree to assess and report data on the extent to 
which there are viable responsible parties, nor on the financial 
impacts if such parties cannot be identified. We believe these data 
are essential to assess EPA's future funding needs. 

As we reported in May 2010, most EPA regional offices expect an 
increase in the number of sites added to the National Priorities List 
over the next 5 years but cannot estimate the associated cleanup 
costs.[Footnote 33] One factor that could increase the number of sites 
eligible for the list is whether EPA begins to assess the risks of 
subsurface hazardous substances leaking upward into homes and 
businesses (vapor intrusion). As a result, we recommended that EPA 
determine the extent to which EPA will consider vapor intrusion as 
part of the listing process for the National Priorities List and how 
this phenomenon will affect the number of sites listed in the future. 
EPA agreed with our recommendation. 

Confronting Difficulties in the Cleanup of DOD Superfund Sites: 

Our July 2010 report on DOD-related Superfund sites identified several 
obstacles--including poor coordination, lack of interagency 
agreements, contract management, and legal limitations--that have 
delayed cleanups.[Footnote 34] First, poor coordination with 
regulators and incomplete record reviews have resulted in poor 
decision making, such as placing military personnel in housing at risk 
of contamination, ultimately leading to their evacuation. Second, 
because DOD had not signed interagency agreements at some of its 
National Priorities List sites, EPA lacked the mechanisms to ensure 
that cleanup proceeds expeditiously, is properly done, and has public 
input as required by law. Third, DOD's use of performance-based 
contracts to clean up installations has affected how the cleanup work 
was scoped and conducted and has created pressure on contractors to 
operate within price caps and meet deadlines, which may conflict with 
regulatory review times and encourage the department to take 
shortcuts. Finally, EPA has virtually no enforcement tools available 
to compel agency compliance with the law at installations without an 
interagency agreement, unless EPA has concurrence from the Department 
of Justice, whose policy generally precludes one agency from bringing 
suit against another. 

Addressing EPA's Emerging Role in Climate Change: 

As one of the most complicated interdisciplinary environmental issues 
currently facing the federal government, climate change poses 
particular management challenges for EPA. We have previously reported 
that, in addition to its environmental implications, climate change 
has implications for the fiscal health of the federal government, 
affecting federal crop and flood insurance programs and placing new 
stresses on infrastructure and natural resources. We have also 
analyzed and reported on recent legislative and regulatory efforts to 
reduce greenhouse gas emissions. Recent GAO work has also identified a 
range of climate change management challenges for the federal 
government at large, including a broad array of departments with 
diverse missions. For EPA, particular challenges relate to the 
agency's ongoing efforts to reduce carbon emissions; to coordinate 
activities with other agencies; and to account for and manage data on 
greenhouse gas emissions. 

Legislative and Regulatory Greenhouse Gas Emissions Reduction Efforts: 

Several bills that would have established comprehensive emissions 
reduction programs were introduced and debated during the 111th 
Congress, although none became law. To provide the Congress with 
relevant information during these deliberations, however, we reported 
on the economic implications of different policy options and on 
lessons learned from the European Union's own efforts to implement 
mandatory carbon reductions. We found, for example, that the European 
Union set its overall emissions limit, or "cap," too high (i.e., at a 
level that was higher than actual emissions) because of uncertainty 
surrounding the emissions data used to set the cap.[Footnote 35] We 
also reported on carbon offsets--reductions of greenhouse gas 
emissions from an activity on one place to compensate for emissions 
elsewhere--noting that the credibility of offsets could compromise the 
environmental integrity of a system to reduce emissions.[Footnote 36] 

In the absence of a law establishing a cap-and-trade program in the 
United States, EPA is implementing a regulatory program to reduce 
greenhouse gas emissions that is facing an array of legal challenges. 
Specifically, in 2009 EPA issued a finding that greenhouse gas 
emissions from new motor vehicles are contributing to air pollution 
that is endangering public health and welfare. This finding, known as 
the Endangerment Finding, is the foundation for all of EPA's efforts 
to regulate greenhouse gases under the Clean Air Act. Twenty-six 
lawsuits have been filed challenging the endangerment finding for 
greenhouse gases. Nonetheless, the EPA rule establishing emissions 
standards for light-duty motor vehicles went into effect on January 2, 
2011. Additional rules subjecting certain stationary sources to 
regulation under the Clean Air Act as of January 2, 2011, have also 
been challenged. All of these lawsuits are to be heard together by the 
same panel of judges. Moreover, to date, five bills that would 
preclude EPA from regulating greenhouse gases under the Clean Air Act 
have been introduced in the 112th Congress. 

Coordinating Climate Change Activities with Other Agencies: 

Climate change has the potential to affect every sector and level of 
government operations. Consequently, there are areas in which EPA will 
need to work closely with other agencies and to clarify its own role 
within broader, governmentwide efforts. One example arose during our 
2008 work on the federal government's examination of carbon capture 
and storage as a means of reducing carbon emissions from the electric 
utility sector. Carbon capture and storage involves capturing carbon 
dioxide from a power plant's emissions, transporting it to an 
underground storage location, and then injecting it into a geologic 
formation for long-term storage. In addition to its formidable 
technological challenges, we noted that carbon capture and storage 
faces significant legal and regulatory uncertainties. We noted that 
EPA was addressing some of these uncertainties (specifically by 
issuing a rule to govern underground injection of carbon dioxide for 
geologic sequestration), but that "many of them fall within the domain 
of the Departments of Energy, the Interior, Transportation, the 
Federal Energy Regulatory Commission, and other agencies in a manner 
that would require collaboration between agencies and, in many cases, 
coordination with state governments and other entities."[Footnote 37] 

We recommended that EPA more comprehensively examine barriers to the 
development of carbon capture and storage by identifying key issues 
that fall outside the agency's Safe Drinking Water Act authority. 
EPA's Office of Water responded to GAO that it is committed to work 
both with other offices within the agency as well as other "partner 
federal agencies" to assess the implications of various statutes on 
the development of carbon capture and storage. As a related matter, 
the White House established an Interagency Task Force on Carbon 
Capture and Storage on February 3, 2010, to develop a comprehensive 
and coordinated federal strategy to speed the commercial development 
and deployment of clean coal technologies. Among other things, the 
Task Force's August 2010 report recommended that EPA and other 
relevant agencies work to quickly and collaboratively propose, 
finalize, and implement a regulatory framework to ensure safe and 
effective carbon capture and storage deployment. 

Developing and Managing Data on Greenhouse Gas Emissions: 

High-quality data on greenhouse gas emissions are critical to the 
development and implementation of domestic and international efforts 
to address climate change. As we recently reported, for example, a 
European Union program designed to control carbon emissions has run 
into difficulties due to a lack of facility-specific data on baseline 
emissions.[Footnote 38] 

EPA faces particular challenges in accounting for and managing 
emissions data from facilities. The Consolidated Appropriations Act of 
2008 directed EPA to issue a regulation requiring mandatory reporting 
of greenhouse gas emissions above appropriate thresholds in all 
sectors of the economy. EPA issued the regulation under its Clean Air 
Act authority on October 30, 2009. The regulation includes provisions 
to ensure the accuracy of emissions data through monitoring, record- 
keeping, and verification requirements. According to EPA, the rule 
covers approximately 10,000 facilities responsible for an estimated 85 
to 90 percent of total U.S. greenhouse gas emissions. Data collection, 
monitoring, and verification for a universe of facilities this large 
could be expected to pose a formidable challenge for EPA especially in 
light of the tight budget environment.[Footnote 39] 

Mr. Chairman, this concludes my prepared statement. I would be pleased 
to answer any questions that you or other Members of the Subcommittee 
may have at this time. 

GAO Contacts and Staff Acknowledgments: 

For further information about this testimony, please contact David 
Trimble at (202) 512-3841 or trimbled@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this statement. Individuals making key contributions 
to this testimony include Steve Elstein, Assistant Director, Nathan 
Anderson, and Joseph D. Thompson. Also contributing to this testimony 
were Liz Beardsley; Antoinette Capaccio; Ellen Chu; Emily Eischen; 
Elizabeth Erdmann; Christine Fishkin; Mike Hix; Richard P. Johnson; 
James R. Jones, Jr.; Susan Iott; Barbara Patterson; Vincent Price; 
Diane Raynes; Daniel Semick; John C. Smith; and Jeanette Soares. 

[End of section] 

Related GAO Products: 

High Risk Series: 

High Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-11-278]. Washington, D.C.: February 
2011. 

High-Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-09-271]. Washington, D.C.: January 
2009. 

Improving Agencywide Management: 

Workforce Planning: Interior, EPA, and the Forest Service Should 
Strengthen Linkages to Their Strategic Plans and Improve Evaluation, 
[hyperlink, http://www.gao.gov/products/GAO-10-413]. Washington, D.C.: 
March 31, 2010. 

Clean Water Act: Longstanding Issues Impact EPA's and States' 
Enforcement Efforts [hyperlink, 
http://www.gao.gov/products/GAO-10-165T]. Washington, D.C.: October 
15, 2009. 

EPA's Execution of Its Fiscal year 2007 New Budget Authority for the 
Enforcement and Compliance Assurance Program in the Regional Offices. 
[hyperlink, http://www.gao.gov/products/GAO-08-1109R]. Washington, 
D.C.: September 26, 2008. 

Environmental Enforcement: EPA Needs to Improve the Accuracy and 
Transparency of Measures Used to Report on Program Effectiveness. 
[hyperlink, http://www.gao.gov/products/GAO-08-1111R]. Washington, 
D.C.: September 18, 2008. 

Chesapeake Bay Program: Recent Actions Are Positive Steps Toward More 
Effectively Guiding Restoration Efforts. [hyperlink, 
http://www.gao.gov/products/GAO-08-1033T]. Washington, D.C.: July 30, 
2008. 

Environmental Protection: EPA Needs to Follow Best Practices and 
Procedures When Reorganizing Its Library Network. [hyperlink, 
http://www.gao.gov/products/GAO-08-579T]. Washington, D.C.: March 13, 
2008. 

Environmental Protection: EPA Needs to Ensure That Best Practices and 
Procedures Are Followed When Making Further Changes to Its Library 
Network. [hyperlink, http://www.gao.gov/products/GAO-08-304]. 
Washington, D.C.: February 29, 2008. 

Toxic Chemical Releases: EPA Actions Could Reduce Environmental 
Information Available to Many Communities. [hyperlink, 
http://www.gao.gov/products/GAO-08-128]. Washington, D.C.: November 
30, 2007. 

Measuring Our Nation's Natural Resources and Environmental 
Sustainability: Highlights of a Forum Jointly Convened by the 
Comptroller General of the United States and the National Academy of 
Science. [hyperlink, http://www.gao.gov/products/GAO-08-127SP]. 
Washington, D.C.: October 2007. 

Environmental Right-To-Know: EPA's Recent Rule Could Reduce 
Availability of Toxic Chemical Information Used to Assess 
Environmental Justice. [hyperlink, 
http://www.gao.gov/products/GAO-08-115T]. Washington, D.C.: October 4, 
2007. 

Environmental Protection: EPA-State Enforcement Partnership Has 
Improved, but EPA's Oversight Needs Further Enhancement. [hyperlink, 
http://www.gao.gov/products/GAO-07-883]. Washington, D.C.: July 31, 
2007. 

Environmental Justice: Measurable Benchmarks Needed to Gauge EPA 
Progress in Correcting Past Problems. [hyperlink, 
http://www.gao.gov/products/GAO-07-1140T]. Washington, D.C.: July 25, 
2007. 

Environmental Information: EPA Actions Could Reduce the Availability 
of Environmental Information to the Public. [hyperlink, 
http://www.gao.gov/products/GAO-07-464T]. Washington, D.C.: February 
6, 2007. 

Environmental Compliance and Enforcement: EPA's Effort to Improve and 
Make More Consistent Its Compliance and Enforcement Activities. 
[hyperlink, http://www.gao.gov/products/GAO-06-840T]. Washington, 
D.C.: June 28, 2006. 

Clean Water Act: Improved Resource Planning Would Help EPA Better 
Respond to Changing Needs and Fiscal Constraints. [hyperlink, 
http://www.gao.gov/products/GAO-05-721]. Washington, D.C.: July 22, 
2005. 

Environmental Indicators: Better Coordination Is Needed to Develop 
Environmental Indicator Sets That Inform Decisions. [hyperlink, 
http://www.gao.gov/products/GAO-05-52]. Washington, D.C.: November 17, 
2004. 

Human Capital: Implementing an Effective Workforce Strategy Would Help 
EPA to Achieve Its Strategic Goals. [hyperlink, 
http://www.gao.gov/products/GAO-01-812]. Washington, D.C.: July 31, 
2001. 

Transforming EPA's Processes for Assessing and Controlling Toxic 
Chemicals: 

Nanotechnology: Nanomaterials Are Widely Used in Commerce, but EPA 
Faces Challenges in Regulating Risk. [hyperlink, 
http://www.gao.gov/products/GAO-10-549]. Washington, D. C: May 25, 
2010. 

Chemical Regulation: Observations on Improving the Toxic Substances 
Control Act. [hyperlink, http://www.gao.gov/products/GAO-10-292T]. 
Washington, D.C.: December 2, 2009. 

EPA Chemical Assessments: Process Reforms Offer the Potential to 
Address Key Problems. [hyperlink, 
http://www.gao.gov/products/GAO-09-774T]. Washington, D.C.: June 11, 
2009. 

Scientific Integrity: EPA's Efforts to Enhance the Credibility and 
Transparency of Its Scientific Processes. [hyperlink, 
http://www.gao.gov/products/GAO-09-773T]. Washington, D.C.: June 9, 
2009. 

Chemical Regulation: Options for Enhancing the Effectiveness of the 
Toxic Substances Control Act. [hyperlink, 
http://www.gao.gov/products/GAO-09-428T]. Washington, D.C.: February 
26, 2009. 

High Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-09-271]. Washington, D.C.: January, 
2009. 

Environmental Health: EPA Efforts to Address Children's Health Issues 
Need Greater Focus, Direction, and Top-Level Commitment. [hyperlink, 
http://www.gao.gov/products/GAO-08-1155T]. Washington, D.C.: September 
16, 2008. 

Chemical Assessments: EPA's New Assessment Process Will Further Limit 
the Productivity and Credibility of Its Integrated Risk Information 
System. [hyperlink, http://www.gao.gov/products/GAO-08-810T]. 
Washington, D.C.: May 21, 2008. 

Toxic Chemicals: EPA's New Assessment Process Will Increase Challenges 
EPA Faces in Evaluating and Regulating Chemicals. [hyperlink, 
http://www.gao.gov/products/GAO-08-743T]. Washington, D.C.: April 29, 
2008. 

Chemical Assessments: Low Productivity and New Interagency Review 
Process Limit the Usefulness and Credibility of EPA's Integrated Risk 
Information System. [hyperlink, 
http://www.gao.gov/products/GAO-08-440]. Washington, D.C.: March 7, 
2008. 

Chemical Regulation: Comparison of U.S. and Recently Enacted European 
Union Approaches to Protect against the Risks of Toxic Chemicals. 
[hyperlink, http://www.gao.gov/products/GAO-07-825]. Washington, D.C.: 
August 17, 2007. 

Environmental Contamination: Department of Defense Activities Related 
to Trichloroethylene, Perchlorate, and Other Emerging Contaminants. 
[hyperlink, http://www.gao.gov/products/GAO-07-1042T]. Washington, 
D.C.: July 12, 2007. 

Perchlorate: EPA Does Not Systematically Track Incidents of 
Contamination. [hyperlink, http://www.gao.gov/products/GAO-07-797T]. 
Washington, D.C.: April 25, 2007. 

Chemical Regulation: Actions Are Needed to Improve the Effectiveness 
of EPA's Chemical Review Program. [hyperlink, 
http://www.gao.gov/products/GAO-06-1032T]. Washington, D.C.: August 2, 
2006. 

Chemical Regulation: Approaches in the United States, Canada, and the 
European Union. Washington, D.C.: [hyperlink, 
http://www.gao.gov/products/GAO-06-217R]. November 4, 2005. 

Chemical Regulation: Options Exist to Improve EPA's Ability to Assess 
Health Risks and Manage Its Chemical Review Program. [hyperlink, 
http://www.gao.gov/products/GAO-05-458. Washington, D.C.: June 13, 
2005. 

Reducing Pollution in the Nation's Waters: 

Wastewater Infrastructure Financing: Stakeholder Views on a National 
Infrastructure Bank and Public-Private Partnerships. [hyperlink, 
http://www.gao.gov/products/GAO-10-728]. Washington, D.C.: June 30, 
2010. 

Recovery Act: Status of States' and Localities' Use of Funds and 
Efforts to Ensure Accountability. [hyperlink, 
http://www.gao.gov/products/GAO-10-604]. Washington, D.C.: May 26, 
2010. 

Biofuels: Potential Effects and Challenges of Required Increases in 
Production and Use. [hyperlink, 
http://www.gao.gov/products/GAO-09-446]. Washington, D.C.: August 25, 
2009. 

Clean Water Infrastructure: A Variety of Issues Need to Be Considered 
When Designing a Clean Water Trust Fund. [hyperlink, 
http://www.gao.gov/products/GAO-09-657. Washington, D.C.: May 29, 2009. 

Environmental Health: EPA Efforts to Address Children's Health Issues 
Need Greater Focus, Direction, and Top-Level Commitment. [hyperlink, 
http://www.gao.gov/products/GAO-08-1155T]. Washington, D.C.: September 
16, 2008. 

Concentrated Animal Feeding Operations: EPA Needs More Information and 
a Clearly Defined Strategy to Protect Air and Water Quality from 
Pollutants of Concern, [hyperlink, 
http://www.gao.gov/products/GAO-08-944]. Washington, D.C.: Sept. 4, 
2008. 

Recent Actions by the Chesapeake Bay Program Are Positive Steps Toward 
More Effectively Guiding the Restoration Effort, but Additional Steps 
Are Needed. [hyperlink, http://www.gao.gov/products/GAO-08-1131R]. 
Washington, D.C.: August 28, 2008. 

Chesapeake Bay Program: Recent Actions Are Positive Steps Toward More 
Effectively Guiding the Restoration Effort. [hyperlink, 
http://www.gao.gov/products/GAO-08-1033T]. Washington, D.C.: July 30, 
2008. 

Physical Infrastructure: Challenges and Investment Options for the 
Nation's Infrastructure, [hyperlink, 
http://www.gao.gov/products/GAO-08-763T]. Washington, D.C.: May 8, 
2008. 

International Boundary and Water Commission: Two Alternatives for 
Improving Wastewater Treatment at the United States-Mexico Border. 
[hyperlink, http://www.gao.gov/products/GAO-08-595R]. Washington, 
D.C.: April 24, 2008. 

Great Lakes Initiative: EPA and States Have Made Progress, but Much 
Remains to Be Done If Water Quality Goals Are to Be Achieved. 
[hyperlink, http://www.gao.gov/products/GAO-08-312T]. Washington, 
D.C.: January 23, 2008. 

Coastal Wetlands: Lessons Learned from Past Efforts in Louisiana Could 
Help Guide Future Restoration and Protection. [hyperlink, 
http://www.gao.gov/products/GAO-08-130]. Washington, D.C.: December 
14, 2007. 

South Florida Ecosystem: Some Restoration Progress Has Been Made, but 
the Effort Faces Significant Delays, Implementation Challenges, and 
Rising Costs. [hyperlink, http://www.gao.gov/products/GAO-07-1250T]. 
Washington, D.C.: September 19, 2007. 

Maritime Transportation: Major Oil Spills Occur Infrequently, but 
Risks to the Federal Oil Spill Fund Remain. [hyperlink, 
http://www.gao.gov/products/GAO-07-1085]. Washington, D.C.: September 
7, 2007. 

The BEACH Act of 2000: EPA and States Have Made Progress Implementing 
the Act, but Further Actions Could Increase Public Health Protection. 
[hyperlink, http://www.gao.gov/products/GAO-07-1073T]. Washington, 
D.C.: July 12, 2007. 

South Florida Ecosystem: Restoration Is Moving Forward but Is Facing 
Significant Delays, Implementation Challenges, and Rising Costs. 
[hyperlink, http://www.gao.gov/products/GAO-07-520]. Washington, D.C.: 
May 31, 2007. 

Clean Water: Further Implementation and Better Cost Data Needed to 
Determine Impact of EPA's Storm Water Program on Communities. 
[hyperlink, http://www.gao.gov/products/GAO-07-479]. Washington, D.C.: 
May 31, 2007. 

Great Lakes: EPA and States Have Made Progress in Implementing the 
BEACH Act, but Additional Actions Could Improve Public Health 
Protection. [hyperlink, http://www.gao.gov/products/GAO-07-591]. 
Washington, D.C: May 1, 2007. 

Chesapeake Bay Program: Improved Strategies Needed to Better Guide 
Restoration Efforts. [hyperlink, 
http://www.gao.gov/products/GAO-06-614T]. Washington, D.C.: July 13, 
2006. 

Chesapeake Bay Program: Improved Strategies Are Needed to Better 
Assess, Report, and Manage Restoration Progress, [hyperlink, 
http://www.gao.gov/products/GAO-06-96]. Washington, D.C.: Oct. 28, 
2005. 

Great Lakes Initiative: EPA Needs to Better Ensure the Complete and 
Consistent Implementation of Water Quality Standards. [hyperlink, 
http://www.gao.gov/products/GAO-05-829]. Washington, D.C.: July 27, 
2005. 

Water Infrastructure: Comprehensive Asset Management Has Potential to 
Help Utilities Better Identify Needs and Plan Future Investments, 
[hyperlink, http://www.gao.gov/products/GAO-04-461]. Washington, D.C.: 
Mar. 19, 2004. 

Speeding the Pace of Cleanup at Superfund and Other Hazardous Waste 
Sites: 

Superfund: Interagency Agreements and Improved Project Management 
Needed to Achieve Cleanup Progress at Key Defense Installations. 
[hyperlink, http://www.gao.gov/products/GAO-10-348]. Washington, D.C.: 
July 15, 2010. 

Superfund: Costs to Remediate Existing and Future Sites Will Likely 
Exceed Current Funding Levels. [hyperlink, 
http://www.gao.gov/products/GAO-10-857T]. Washington, D.C.: June 22, 
2010. 

Superfund: EPA's Estimated Costs to Remediate Existing Sites Exceed 
Current Funding Levels, and More Sites Are Expected to Be Added to the 
National Priorities List. [hyperlink, 
http://www.gao.gov/products/GAO-10-380]. Washington, D.C.: May 6, 2010. 

Superfund: Litigation Has Decreased and EPA Needs Better Information 
on Site Cleanup and Cost Issues to Estimate Future Program Funding 
Requirements. [hyperlink, http://www.gao.gov/products/GAO-09-656. 
Washington, D.C.: July 15, 2009. 

Superfund: Greater EPA Enforcement and Reporting Are Needed to Enhance 
Cleanup at DOD Sites. [hyperlink, 
http://www.gao.gov/products/GAO-09-278]. Washington, D.C.: March 13, 
2009. 

Electronic Waste: Harmful U.S. Exports Flow Virtually Unrestricted 
Because of Minimal EPA Enforcement and Narrow Regulation. [hyperlink, 
http://www.gao.gov/products/GAO-08-1166T]. Washington, D.C.: September 
17, 2008. 

Hurricane Katrina: Continuing Debris Removal and Disposal Issues. 
[hyperlink, http://www.gao.gov/products/GAO-08-985R]. Washington, 
D.C.: August 25, 2008. 

Superfund: Funding and Reported Costs of Enforcement and 
Administration Activities. [hyperlink, 
http://www.gao.gov/products/GAO-08-841R]. Washington, D.C.: July 18, 
2008. 

Aboveground Oil Storage Tanks: More Complete Facility Data Could 
Improve Implementation of EPA's Spill Prevention Program. [hyperlink, 
http://www.gao.gov/products/GAO-08-482]. Washington, D.C.: April 30, 
2008. 

Hazardous Waste: Information on How DOD and Federal and State 
Regulators Oversee the Off-Site Disposal of Waste from DOD 
Installations. [hyperlink, http://www.gao.gov/products/GAO-08-74]. 
Washington, D.C.: November 13, 2007. 

Hazardous Materials: EPA May Need to Reassess Sites Receiving Asbestos-
Contaminated Ore from Libby, Montana, and Should Improve Its Public 
Notification Process. [hyperlink, 
http://www.gao.gov/products/GAO-08-71]. Washington, D.C.: October 12, 
2007. 

Aboveground Oil Storage Tanks: Observations on EPA's Economic Analyses 
of Amendments to the Spill Prevention, Control, and Countermeasure 
Rule. [hyperlink, http://www.gao.gov/products/GAO-07-763]. Washington, 
D.C.: July 27, 2007. 

Hurricane Katrina: EPA's Current and Future Environmental Protection 
Efforts Could Be Enhanced by Addressing Issues and Challenges Faced on 
the Gulf Coast. [hyperlink, http://www.gao.gov/products/GAO-07-651]. 
Washington, D.C.: June 25, 2007. 

Leaking Underground Storage Tanks: EPA Should Take Steps to Better 
Ensure the Effective Use of Public Funding for Cleanups. [hyperlink, 
http://www.gao.gov/products/GAO-07-152]. Washington, D.C.: February 8, 
2007. 

Recycling: Additional Efforts Could Increase Municipal Recycling. 
[hyperlink, http://www.gao.gov/products/GAO-07-37]. Washington, D.C.: 
December 29, 2006. 

Environmental Liabilities: EPA Should Do More to Ensure That Liable 
Parties Meet Their Cleanup Obligations, [hyperlink, 
http://www.gao.gov/products/GAO-05-658]. Washington, D.C.: Aug. 17, 
2005. 

Perchlorate: A System to Track Sampling and Cleanup Results Is Needed, 
[hyperlink, http://www.gao.gov/products/GAO-05-462]. Washington, D.C.: 
May 20, 2005. 

Hazardous Waste Sites: Improved Effectiveness of Controls at Sites 
Could Better Protect the Public, [hyperlink, 
http://www.gao.gov/products/GAO-05-163]. Washington, D.C.: Jan. 28, 
2005. 

Addressing Emerging Climate Change Issues: 

Climate Change: A Coordinated Strategy Could Focus Federal 
Geoengineering Research and Inform Governance Efforts. [hyperlink, 
http://www.gao.gov/products/GAO-10-903]. September 23, 2010. 

Carbon Trading: Current Situation and Oversight Considerations for 
Policymakers. [hyperlink, http://www.gao.gov/products/GAO-10-851R]. 
Washington, D.C.: August 19, 2010. 

Climate Change: The Quality, Comparability, and Review of Emissions 
Inventories Vary Between Developed and Developing Nations. [hyperlink, 
http://www.gao.gov/products/GAO-10-818]. July 30, 2010. 

Climate Change: Observations on Options for Selling Emissions 
Allowances in a Cap-and-Trade Program. [hyperlink, 
http://www.gao.gov/products/GAO-10-377]. Washington, D.C.: February 
24, 2010. 

Climate Change Adaptation: Strategic Federal Planning Could Help 
Government Officials Make More Informed Decisions. [hyperlink, 
http://www.gao.gov/products/GAO-10-113]. Washington, D.C.: October 7, 
2009. 

Climate Change Adaptation: Information on Selected Federal Efforts To 
Adapt To a Changing Climate GAO-10-114SP], October 7, 2009), an E- 
supplement to GAO-10-113. [hyperlink, 
http://www.gao.gov/products/GAO-10-114SP]. Washington, D.C.: October 
7, 2009. 

Aviation and Climate Change: Aircraft Emissions Expected to Grow, but 
Technological and Operational Improvements and Government Policies Can 
Help Control Emissions. [hyperlink, 
http://www.gao.gov/products/GAO-09-554]. Washington, D.C.: June 8, 
2009. 

Climate Change Science: High Quality Greenhouse Gas Emissions Data are 
a Cornerstone of Programs to Address Climate Change. [hyperlink, 
http://www.gao.gov/products/GAO-09-423T]. Washington, D.C.: February 
24, 2009. 

International Climate Change Programs: Lessons Learned from the 
European Union's Emissions Trading Scheme and the Kyoto Protocol's 
Clean Development Mechanism. [hyperlink, 
http://www.gao.gov/products/GAO-09-151]. Washington, D.C.: November 
18, 2008. 

Climate Change: Federal Actions Will Greatly Affect the Viability of 
Carbon Capture and Storage As a Key Mitigation Option. [hyperlink, 
http://www.gao.gov/products/GAO-08-1080]. Washington, D.C.: September 
30, 2008. 

Carbon Offsets: The U.S. Voluntary Market Is Growing, but Quality 
Assurance Poses Challenges for Market Participants. [hyperlink, 
http://www.gao.gov/products/GAO-08-1048]. Washington, D.C.: August 29, 
2008. 

Climate Change: Expert Opinion on the Economics of Policy Options to 
Address Climate Change. [hyperlink, 
http://www.gao.gov/products/GAO-08-605]. Washington, D.C.: May 9, 2008. 

Climate Change Research: Agencies Have Data-Sharing Policies but Could 
Do More to Enhance the Availability of Data from Federally Funded 
Research. [hyperlink, http://www.gao.gov/products/GAO-07-1172]. 
Washington, D.C.: September 28, 2007. 

Climate Change: Agencies Should Develop Guidance for Addressing the 
Effects on Federal Land and Water Resources. [hyperlink, 
http://www.gao.gov/products/GAO-07-863]. Washington, D.C.: August 7, 
2007. 

Biofuels: DOE Lacks a Strategic Approach to Coordinate Increasing 
Production with Infrastructure Development and Vehicle Needs. 
[hyperlink, http://www.gao.gov/products/GAO-07-713]. Washington, D.C.: 
June 8, 2007. 

Climate Change: Financial Risks to Federal and Private Insurers in 
Coming Decades Are Potentially Significant. [hyperlink, 
http://www.gao.gov/products/GAO-07-285]. Washington, D.C.: March 16, 
2007. 

Climate Change: Federal Reports on Climate Change Funding Should Be 
Clearer and More Complete. [hyperlink, 
http://www.gao.gov/products/GAO-05-461]. Washington, D.C.: August 25, 
2005. 

[End of section] 

Footnotes: 

[1] In real terms, using 2011 dollars, EPA's budget equated to $9.9 
billion in fiscal year 2000 and $10.4 billion in fiscal year 2010. 

[2] EPA's 2011 budget is uncertain, given that the federal government 
is operating under a continuing resolution set to expire on March 4, 
2011. 

[3] GAO, Environmental Protection Agency: Major Management Challenges, 
[hyperlink, http://www.gao.gov/products/GAO-09-434] (Washington, D.C.: 
Mar. 4, 2009). 

[4] We conducted our work in accordance with all sections of GAO's 
Quality Assurance Framework that were relevant to the objectives of 
each engagement. The framework requires that we plan and perform each 
engagement to obtain sufficient and appropriate evidence to meet our 
stated objectives and to discuss any limitations in our work. We 
believe that the information and data obtained, and the analyses 
conducted, provided a reasonable basis for the findings and 
conclusions in each report. 

[5] GAO, EPA's Execution of Its Fiscal Year 2007 New Budget Authority 
for the Enforcement and Compliance Assurance Program in the Regional 
Offices, [hyperlink, http://www.gao.gov/products/GAO-08-1109R] 
(Washington, D.C.: Sept. 26, 2008). 

[6] For example, see GAO, Clean Water Act: Longstanding Issues Impact 
EPA's and States' Enforcement Efforts, [hyperlink, 
http://www.gao.gov/products/GAO-10-165T] (Washington, D.C.: Oct. 15, 
2009). 

[7] GAO, Environmental Enforcement: EPA Needs to Improve the Accuracy 
and Transparency of Measures Used to Report on Program Effectiveness, 
[hyperlink, http://www.gao.gov/products/GAO-08-1111R] (Washington, 
D.C.: Sept. 18, 2008). 

[8] GAO, Environmental Protection: EPA-State Enforcement Partnership 
Has Improved, but EPA's Oversight Needs Further Enhancements, 
[hyperlink, http://www.gao.gov/products/GAO-07-883] (Washington, D.C.: 
July 31, 2007). 

[9] [hyperlink, http://www.gao.gov/products/GAO-08-1111R]. 

[10] The agencies are the Department of Agriculture; the Department of 
Housing and Urban Development; the U.S. Army Corps of Engineers; the 
Economic Development Administration in the Department of Commerce; the 
Indian Health Service within the Department of Health and Human 
Services; and the Bureau of Reclamation, within the Department of the 
Interior. 

[11] GAO, Rural Water Infrastructure: Improved Coordination and 
Funding Processes Could Enhance Federal Efforts to Meet Needs in the 
U.S.-Mexico Border Region, [hyperlink, 
http://www.gao.gov/products/GAO-10-126] (Washington, D.C.: Dec. 18, 
2009). 

[12] GAO, Chesapeake Bay Program: Recent Actions Are Positive Steps 
Toward More Effectively Guiding Restoration Efforts, [hyperlink, 
http://www.gao.gov/products/GAO-08-1033T] (Washington, D.C.: July 30, 
2008). In May 2009, the President issued an executive order 
establishing a Federal Leadership Committee for the Chesapeake Bay to 
oversee the development and coordination of programs and activities of 
agencies participating in the protection and restoration of the bay. 
The committee is chaired by EPA and includes six other federal 
agencies. Part of the Committee's responsibilities included developing 
a strategy for coordinated implementation of existing programs and 
projects to guide efforts to protect and restore the Chesapeake Bay. 
The resulting strategy was issued in May 2010. We have ongoing work 
assessing this strategy. 

[13] GAO, High Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-09-271] (Washington, D.C.: Jan. 22, 
2009); GAO, High Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-11-278] (Washington, D.C.: Feb. 16, 
2011). 

[14] GAO, Chemical Assessments: Low Productivity and New Interagency 
Review Process Limit the Usefulness and Credibility of EPA's 
Integrated Risk Information System, [hyperlink, 
http://www.gao.gov/products/GAO-08-440] (Washington, D.C.: Mar. 7, 
2008). 

[15] [hyperlink, http://www.gao.gov/products/GAO-08-440]. 

[16] GAO, Chemical Regulation: Options for Enhancing the Effectiveness 
of the Toxic Substances Control Act, [hyperlink, 
http://www.gao.gov/products/GAO-09-428T] (Washington, D.C.: Feb. 26, 
2009). 

[17] [hyperlink, http://www.gao.gov/products/GAO-11-278]. 

[18] GAO, Chemical Regulation: Options Exist to Improve EPA's Ability 
to Assess Health Risks and Manage Its Chemical Review Program, 
[hyperlink, http://www.gao.gov/products/GAO-05-458] (Washington, D.C.: 
June 13, 2005). 

[19] GAO, Nanotechnology: Nanomaterials Are Widely Used in Commerce, 
but EPA Faces Challenges in Regulating Risk, [hyperlink, 
http://www.gao.gov/products/GAO-10-549] (Washington, D.C: May 25, 
2010). 

[20] Discharges from urban storm water runoff share many of the traits 
of a diffuse, nonpoint source, but they are technically treated and 
regulated under the Clean Water Act as a point source. 

[21] GAO, Clean Water: Further Implementation and Better Cost Data 
Needed to Determine Impact of EPA's Storm Water Program on 
Communities, [hyperlink, http://www.gao.gov/products/GAO-07-479] 
(Washington, D.C.: May 31, 2007). 

[22] GAO, Biofuels: Potential Effects and Challenges of Required 
Increases in Production and Use, [hyperlink, 
http://www.gao.gov/products/GAO-09-446] (Washington, D.C.: Aug. 25, 
2009). 

[23] Discharges from concentrated animal feeding operations share many 
of the traits of a diffuse, nonpoint source, but they are technically 
treated and regulated under the Clean Water Act as a point source. 

[24] GAO, Concentrated Animal Feeding Operations: EPA Needs More 
Information and a Clearly Defined Strategy to Protect Air and Water 
Quality from Pollutants of Concern, [hyperlink, 
http://www.gao.gov/products/GAO-08-944] (Washington, D.C.: Sept. 4, 
2008). Among other things, the report recommended that EPA complete 
its efforts to develop an inventory of permitted operations. 

[25] GAO, Chesapeake Bay Program: Improved Strategies Are Needed to 
Better Assess, Report, and Manage Restoration Progress, [hyperlink, 
http://www.gao.gov/products/GAO-06-96] (Washington, D.C.: Oct. 28, 
2005). 

[26] GAO, Great Lakes Initiative: EPA and States Have Made Progress, 
but Much Remains to Be Done If Water Quality Goals Are to Be Achieved, 
[hyperlink, http://www.gao.gov/products/GAO-08-312T] (Washington, 
D.C.: Jan. 23, 2008). 

[27] GAO, Clean Water Infrastructure: A Variety of Issues Need to Be 
Considered When Designing a Clean Water Trust Fund, [hyperlink, 
http://www.gao.gov/products/GAO-09-657] (Washington, D.C.: May 29, 
2009). 

[28] GAO, Wastewater Infrastructure Financing: Stakeholder Views on a 
National Infrastructure Bank and Public-Private Partnerships, 
[hyperlink, http://www.gao.gov/products/GAO-10-728] (Washington, D.C.: 
June 30, 2010). 

[29] GAO, Recovery Act: States' and Localities' Use of Funds and 
Actions Needed To Address Implementation Challenges and Bolster 
Accountability, [hyperlink, http://www.gao.gov/products/GAO-10-604] 
(Washington, D.C.: May 26, 2010). 

[30] States were also required to use at least 20 percent of funds 
provided under the Recovery Act for Clean Water revolving funds as a 
"green reserve" to provide assistance for green infrastructure 
projects, water or energy efficiency improvements, or other 
environmentally innovative activities. 

[31] GAO, Superfund: Costs to Remediate Existing and Future Sites Will 
Likely Exceed Current Funding Levels, [hyperlink, 
http://www.gao.gov/products/GAO-10-857T] (Washington, D.C.: June 22, 
2010). 

[32] GAO, Superfund: Litigation Has Decreased and EPA Needs Better 
Information on Site Cleanup and Cost Issues to Estimate Future Program 
Funding Requirements, [hyperlink, 
http://www.gao.gov/products/GAO-09-656] (Washington, D.C.: July 15, 
2009). 

[33] GAO, Superfund: EPA's Estimated Costs to Remediate Existing Sites 
Exceed Current Funding Levels, and More Sites Are Expected to Be Added 
to the National Priorities List, [hyperlink, 
http://www.gao.gov/products/GAO-10-380] (Washington, D.C.: May 6, 
2010). 

[34] GAO, Superfund: Interagency Agreements and Improved Project 
Management Needed to Achieve Cleanup Progress at Key Defense 
Installations, [hyperlink, http://www.gao.gov/products/GAO-10-348] 
(Washington, D.C.: July 15, 2010); GAO, Superfund: Greater EPA 
Enforcement and Reporting Are Needed to Enhance Cleanup at DOD Sites, 
[hyperlink, http://www.gao.gov/products/GAO-09-278] (Washington, D.C.: 
Mar. 13, 2009). 

[35] GAO, International Climate Change Programs: Lessons Learned from 
the European Union's Emissions Trading Scheme and the Kyoto Protocol's 
Clean Development Mechanism, [hyperlink, 
http://www.gao.gov/products/GAO-09-151] (Washington, D.C.: Nov. 18, 
2008). GAO did not recommend executive action in response to this 
work, but stated that, in deliberating legislation for emissions 
trading, Congress may wish to consider the lessons learned from the 
European Union's efforts. 

[36] GAO, Carbon Offsets: The U.S. Voluntary Market Is Growing, but 
Quality Assurance Poses Challenges for Market Participants, 
[hyperlink, http://www.gao.gov/products/GAO-08-1048] (Washington, 
D.C.: Aug. 29, 2008). GAO did not recommend executive action based on 
this work, but stated that, as it considers legislation that allows 
the use of offsets for compliance, Congress might consider, among 
other things, directing the establishment of standardized quality 
assurance mechanisms. 

[37] GAO, Climate Change: Federal Actions Will Greatly Affect the 
Viability of Carbon Capture and Storage As a Key Mitigation Option. 
[hyperlink, http://www.gao.gov/products/GAO-08-1080] (Washington, 
D.C.: Sept. 30, 2008). 

[38] [hyperlink, http://www.gao.gov/products/GAO-09-151]. 

[39] GAO, Climate Change Science: High Quality Greenhouse Gas 
Emissions Data are a Cornerstone of Programs to Address Climate 
Change. [hyperlink, http://www.gao.gov/products/GAO-09-423T] 
(Washington, D.C.: Feb. 24, 2009). 

[End of section] 

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