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United States Government Accountability Office: 
GAO: 

Report to the Ranking Member, Subcommittee on Energy and Environment, 
Committee on Science, Space, and Technology, House of Representatives: 

July 2011: 

Environmental Protection Agency: 

To Better Fulfill Its Mission, EPA Needs a More Coordinated Approach 
to Managing Its Laboratories: 

GAO-11-347: 

GAO Highlights: 

Highlights of GAO-11-347, a report to the Ranking Member, Subcommittee 
on Energy and Environment, Committee on Science, Space, and 
Technology, House of Representatives. 

Why GAO Did This Study: 

The Environmental Protection Agency (EPA) operates 37 laboratories to 
provide the scientific foundation for its mission. Over the past 20 
years, independent evaluations have identified problems with the 
laboratories’ operations and management and called for improved 
planning, coordination, and leadership, as well as consolidation of 
laboratories. In its 2012 budget, EPA requested $2 million for another 
independent study of its laboratories. GAO was asked to examine the 
extent to which EPA (1) has addressed the findings of prior 
independent evaluations; (2) uses an agencywide, coordinated approach 
to manage its laboratory infrastructure and whether its new study will 
achieve stated cost savings and laboratory improvement goals; and (3) 
uses a comprehensive planning process to manage its laboratory 
workforce. GAO reviewed agency documents and independent evaluations, 
visited EPA laboratories, interviewed agency officials, and examined 
agency databases. 

What GAO Found: 

EPA has not fully addressed the findings and recommendations of 
independent evaluations of its science activities. For example, EPA 
has yet to implement an overarching issue-based planning process 
integrating and coordinating scientific efforts throughout the agency, 
including the important work of its 37 laboratories as recommended by 
a 1992 independent evaluation. The agency also has not fully addressed 
recommendations from a 1994 independent evaluation to consolidate or 
realign its laboratory facilities and workforce, although several 
studies found that such action could eliminate unnecessary duplication 
and improve planning and coordination. In addition, although three 
independent evaluations identified weaknesses in EPA’s scientific 
leadership, the agency has not appointed a top science official with 
responsibility and authority over all of the agency’s research, 
science, and technical activities, including integrating and 
coordinating the science activities conducted by its laboratories. 
Instead, these activities remain fragmented and largely uncoordinated, 
reflecting the independent organizational and management structures of 
the 15 senior officials charged with managing the scientific work 
performed at each laboratory. 

EPA has not taken an agencywide, coordinated approach to managing its 
scientific efforts and related facilities as part of an interrelated 
portfolio of facilities, as recommended by the National Research 
Council. As a result, EPA cannot be assured that it is allocating its 
limited capital improvement funds most appropriately. EPA officials 
said they attempt to spread capital improvement funds equitably across 
the 15 organizations that maintain the laboratories, but this does not 
ensure that all mission-critical laboratory assets are functioning at 
an optimal or acceptable level. In 2008, EPA reported that because the 
laboratories operate independently, opportunities for increased 
resource sharing and operating efficiencies are inhibited. EPA also 
has not finalized the scope and methodology to be used for its 
proposed new laboratory study, and therefore, it is unclear whether 
the proposed study will produce meaningful change or fulfill the 
envisioned cost-savings targets. In addition, EPA lacks complete and 
reliable data about use of laboratory space, condition, and operating 
costs, and therefore cannot be assured of making informed decisions 
about capital investments or the disposition of its real property 
assets. 

EPA does not use a comprehensive planning process for managing its 
laboratories’ workforce. To the extent that workforce planning is 
performed for the laboratories, it is done independently by each of 
the 15 separate organizations that maintain laboratories. EPA also 
lacks basic information on its laboratory workload and workforce, 
including demographic data on the number of federal and contract 
employees currently working in its 37 laboratories. Such information 
is essential to identify, on an agencywide basis, any critical skill 
gaps in its current workforce and the workforce it may need in the 
future. Without such information, EPA cannot successfully undertake 
succession planning and management to help the organization adapt to 
meet emerging and future needs. 

What GAO Recommends: 

GAO recommends, among other things that EPA develop a coordinated 
planning process for its scientific activities and appoint a top-level 
official with authority over all the laboratories, improve physical 
and real property planning decisions, and develop a workforce planning 
process for all laboratories that reflects current and future needs of 
laboratory facilities. EPA generally agreed with the findings and 
recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-11-347] or key 
components. For more information, contact David C. Trimble at (202) 
512-3841 or trimbled@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

EPA Has Not Fully Addressed Findings of Evaluations on Long-standing 
Planning, Coordination, or Leadership Issues: 

EPA Has Not Taken an Agencywide, Coordinated Approach to Manage Its 
Laboratory Physical Infrastructure: 

EPA Does Not Use a Comprehensive Workforce Planning Process for Its 
Laboratories: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: EPA's Inventory of Laboratory Properties: 

Appendix III: Summary of the Planning, Coordination, and Leadership 
Findings and Recommendations of Independent Evaluations and EPA's 
Response: 

Appendix IV: Comments from the Environmental Protection Agency: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: EPA's Inventory of Laboratory Properties: 

Figures: 

Figure 1: Location of EPA's Laboratories: 

Figure 2: Organizational and Management Structure for EPA's 
Laboratories: 

Figure 3: Incomplete and Unreliable EPA Data Used to Make Facility 
Disposition Decisions: 

Abbreviations: 

EPA: Environmental Protection Agency: 

FTE: full-time equivalent: 

OMB: Office of Management and Budget: 

ORD: Office of Research and Development: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

July 25, 2011: 

The Honorable Brad Miller 
Ranking Member: 
Subcommittee on Energy and Environment: 
Committee on Science, Space, and Technology: 
House of Representatives: 

Dear Mr. Miller: 

The Environmental Protection Agency (EPA) was established in 1970 to 
consolidate a variety of federal research, monitoring, standard- 
setting, and enforcement activities into one agency for ensuring the 
joint protection of environmental quality and human health.[Footnote 
1] Scientific research, knowledge, and technical information are 
fundamental to EPA's mission and inform its standard-setting, 
regulatory, compliance, and enforcement functions. The agency's 
scientific performance is particularly important as complex 
environmental issues emerge and evolve, and controversy continues to 
surround many of the agency's areas of responsibility. EPA works with 
many providers of scientific information to accomplish its mission, 
including international and domestic academic institutions, state and 
local agencies, industry, and other federal scientific agencies. But 
unlike other primarily science-focused federal agencies, such as the 
National Institutes of Health or the National Science Foundation, 
EPA's scientific research, technical support, and analytical services 
underpin the policies and regulations the agency implements. 
Therefore, the agency operates its own laboratory enterprise. This 
enterprise is made up of 37 laboratories that are housed in about 170 
buildings and facilities located in 30 cities across the nation. 

Over the past 20 years, independent evaluations by the National 
Research Council and others have addressed planning, coordination, or 
leadership issues associated with the EPA's science activities. 
[Footnote 2] While the scope of these evaluations varied, collectively 
they recognized the need for EPA to improve long-term planning, 
priority setting, and coordination of laboratory activities; establish 
leadership for agencywide scientific oversight and decision making; 
and better manage the laboratories' workforce and infrastructure. In 
addition, in response to budget pressures, in 2006 EPA's Chief 
Financial Officer called for a 10 percent reduction in the cost of the 
agency's laboratory physical infrastructure by fiscal year 2009 and 
another 10 percent reduction by fiscal year 2011. Specifically, the 
Chief Financial Officer requested that the Office of Research and 
Development (ORD), along with the program and regional offices, 
develop a plan that would achieve the cost-savings targets through 
closing, relocating, and consolidating laboratories. In lieu of 
developing such a plan, however, ORD and the regions proposed 
conducting near-and long-term studies of the agency's laboratory 
capabilities and operations, with the goal of identifying and 
implementing cost savings and efficiencies and improving the 
laboratories' ability to support the agency's mission. EPA completed 
the near-term study in 2008,[Footnote 3] but since then, senior EPA 
managers have been considering the proposed scope and methodology of 
the long-term study, to be conducted by an independent expert panel 
convened by the National Academy of Sciences. EPA requested $2 million 
for the study in the President's fiscal year 2012 budget but provided 
no details about why the proposed study is needed in its congressional 
budget justification. The study's prospects for fiscal year 2012 are 
unclear, given current efforts to reduce the federal budget deficit 
and the significant cuts that have been proposed for the budgets of 
most departments and agencies, including EPA's. 

In the present atmosphere of constrained budgets, coupled with EPA's 
increasing need to understand complex environmental problems so as to 
formulate sound environmental protection policies, you asked us to 
evaluate the ability of EPA's laboratory enterprise to meet the 
agency's mission and current and future program needs. Specifically, 
our objectives were to examine the extent to which EPA (1) has 
addressed the findings of independent evaluations performed by the 
National Research Council and others regarding long-term planning, 
coordination, and leadership issues; (2) uses an agencywide, 
coordinated approach for managing its laboratory physical 
infrastructure and whether the agency's near-and long-term studies 
will achieve their stated cost saving and laboratory improvement 
goals; and (3) uses a comprehensive planning process to manage its 
laboratory workforce. 

To address these objectives, we identified and reviewed the major 
independent evaluations of EPA's science activities over the past 20 
years. Of these evaluations, five addressed planning, coordination, 
and leadership issues, including issues related to the organization 
and infrastructure of the agency's laboratories. We analyzed EPA's 
relevant funding and workforce documents, policies, procedures, and 
guidance, as well as related laws, requirements, and leading practices 
pertinent to EPA's laboratories and efforts to improve the agency's 
operations. We interviewed officials in EPA headquarters and officials 
representing all ORD and program laboratories and 5 of 10 regional 
offices and laboratories. In addition, we visited a nonprobability 
sample of laboratories located in Athens, Georgia; Chapel Hill, 
Durham, and Research Triangle Park, North Carolina; Corvallis, Oregon; 
Denver, Colorado; Edison, New Jersey; Fort Meade, Maryland; and Port 
Orchard, Washington. We selected the offices and laboratories we 
visited based on geographic dispersion and proximity to other EPA 
laboratories. Because we used nonprobability sampling to select these 
EPA offices and laboratories, information we obtained from these 
visits cannot be generalized to other laboratories, but the visits 
provide us with information on the perspectives of various laboratory 
officials. We also interviewed representatives from EPA's Science 
Advisory Board and Board of Scientific Counselors and discussed 
various aspects of the organization and operation of EPA's 
laboratories.[Footnote 4] To examine the organizational and management 
structure of EPA's laboratories, we analyzed the policies and 
procedures EPA follows to plan the work of its laboratories, internal 
and external studies, and the steps it has taken to coordinate its 
program offices and laboratories. To examine EPA's management of its 
physical laboratory infrastructure, we analyzed the agency's inventory 
of laboratory property and its policies; and guidance for acquiring, 
maintaining, and disposing of laboratories. To examine EPA's 
management of its laboratory workforce, we analyzed EPA's strategic 
workforce documents of offices with laboratories. In addition, we 
examined EPA budget documents and our and EPA's Inspector General's 
report on workforce planning. 

We found that some of the laboratory property data maintained by EPA's 
facility management and real property tracking system lacked 
sufficient data quality controls necessary for assuring sufficiently 
reliable data for management decisions. Although we determined that 
descriptive data on EPA's inventory of laboratory buildings and 
facilities in the database were sufficiently reliable for our 
purposes, other data such as operating costs and condition assessments 
were not sufficiently reliable for the purposes of our review. As EPA 
does not publish the number of employees in EPA's laboratories, either 
separately or in total, we made several efforts to gather such 
information including requesting it from program managers and regional 
offices with laboratories and from the ORD. However, we were unable to 
verify the reliability of the data the offices provided because they 
used inconsistent data sources and did not provide supporting 
documentation describing how the data were compiled. Because reliable 
data were not available, we were unable to document trends in the 
laboratory workforce and operating costs. Appendix I presents a more 
detailed description of our scope and methodology. 

We conducted this performance audit from January 2010 through July 
2011, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

When it was established in 1970, EPA inherited 42 laboratories from 
programs in various federal departments, including the Department of 
the Interior; the former Department of Health, Education and Welfare; 
and the Department of Agriculture. According to EPA's historian, EPA 
closed or consolidated some laboratories it inherited and created 
additional laboratories to support its mission. Nevertheless, EPA's 
historian reported that the location of most of EPA's present 
laboratories is largely the same as the location of its original 
laboratories (see fig. 1), in part because of political objections to 
closing facilities; the relative ease of acquiring space in existing 
federal facilities; the relative ease of securing funds for renovation 
and expansion, compared with planning and building entirely new 
facilities; and conflicting organizational philosophies, such as 
operating centralized laboratories for efficiency versus operating 
decentralized laboratories for flexibility and responsiveness. 
[Footnote 5] Other federal agencies face similar challenges. Since GAO 
designated federal real property as an area of high risk in 2003, 
federal agencies continue to face problems with excess and underused 
property. In 2007, we reported that as a result of competing 
stakeholder interests, decisions about federal real property often do 
not reflect the most cost-effective or efficient alterative but 
instead reflect other priorities.[Footnote 6] In particular, this 
situation often arises when the federal government attempts to 
consolidate facilities or otherwise dispose of unneeded assets. We 
recommended that the Office of Management and Budget (OMB) develop an 
action plan to reduce the effect of competing stakeholder interests. 
[Footnote 7] 

EPA's 37 laboratories, that are housed in about 170 buildings and 
facilities, occupy approximately 4.5 million square feet of space and 
represent almost half (47 percent) of EPA's total square footage of 
real property.[Footnote 8] EPA owns approximately 80 percent of its 
laboratory space and leases the other 20 percent (see app. II for 
EPA's inventory of laboratory properties). 

Figure 1: Location of EPA's Laboratories: 

[Refer to PDF for image: illustrated U.S. map] 

Office of Research and Development laboratories (ORD): 
Ada, Oklahoma; 
Athens, Georgia; 
Chapel Hill, Durham and Research Triangle Park, North Carolina; 
Cincinnati and Milford, Ohio; 
Corvallis and Newport, Oregon; 
Duluth, Minnesota; 
Edison, New Jersey; 
Gaar Corner, Oklahoma; 
Grosse Ile, Michigan; 
Gulf Breeze, Florida; 
Las Vegas, Nevada; 
Narragansett, Rhode Island. 

Regional laboratories: 
Athens, Georgia; 
Chelmsford, Massachusetts; 
Chicago, Illinois; 
Edison, New Jersey; 
Fort Meade, Maryland; 
Golden, Colorado; 
Houston, Texas; 
Kansas City, Kansas; 
Port Orchard, Washington; 
Richmond, California; 
Westlake, Ohio; 
Wheeling, West Virginia. 

Program laboratories: 
Anne Arbor, Michigan; 
Bay St.Louis, Mississippi; 
Edison, New Jersey; 
Fort Meade, Maryland; 
Lakewood, Colorado; 
Las Vegas, Nevada; 
Montgomery, Alabama. 

Sources: GAO; Map Resources (map). 

Note: EPA's 37 laboratories are located in 30 cities. Some 
laboratories are located in more than one city. 

[End of figure] 

EPA's current enterprise of 37 laboratories is managed by a total of 
15 senior officials--10 assistant administrators and 5 regional 
administrators--and is organized into three distinct groups (see 
figure 2): 

* ORD laboratories: This office operates 18 laboratories grouped under 
three national laboratory organizations with primary responsibility 
for research and development. Examples of work performed include 
evaluating human exposure to multiple pollutants, assessing the risks 
that pesticides pose to humans and the environment, and developing 
methods to prevent and control pollution. The ORD laboratories are 
managed by one assistant administrator. 

* Program office laboratories: Four of EPA's five national program 
offices--the Office of Air and Radiation, the Office of Enforcement 
and Compliance Assurance, the Office of Chemical Safety and Pollution 
Prevention, and the Office of Solid Waste and Emergency Response-- 
operate nine laboratories with primary responsibility for basic and 
applied research and analytical services supporting regulatory 
implementation, compliance, enforcement, and emergency 
response.[Footnote 9] Examples of work performed include testing and 
certifying vehicle emission and fuel economy compliance; developing 
and validating testing methods for pesticides; conducting technical 
and forensic analysis to support civil and criminal enforcement; and 
performing radiation testing. Four assistant administrators--one from 
each national program office--manage the program laboratories. 

* Regional laboratories: Each of EPA's 10 regional offices operates a 
laboratory with responsibilities for a variety of applied sciences; 
analytical services; technical support to federal, state, and local 
laboratories; monitoring; compliance and enforcement; and emergency 
response. Examples of work performed include the development and 
modification of analytical methods to detect emerging chemicals of 
concern; identifying and monitoring the levels of contaminants in the 
air, water, soil, and animal tissues; providing expert witness 
testimony in enforcement cases; and auditing states' drinking water 
certification programs. Ten regional administrators--one from each 
regional office--manage the regional laboratories. 

Figure 2: Organizational and Management Structure for EPA's 
Laboratories: 

[Refer to PDF for image: illustration] 

Regional laboratories: 
Region 1: one regional administrator or one assistant administrator; 
Region 2: one regional administrator or one assistant administrator; 
Region 3: one regional administrator or one assistant administrator; 
Region 4: one regional administrator or one assistant administrator; 
Region 5: one regional administrator or one assistant administrator; 
Region 6: one regional administrator or one assistant administrator; 
Region 7: one regional administrator or one assistant administrator; 
Region 8: one regional administrator or one assistant administrator; 
Region 9: one regional administrator or one assistant administrator; 
Region 10: one regional administrator or one assistant administrator. 

Program laboratories: 

Office of Enforcement and Compliance Assurance (one regional 
administrator or one assistant administrator): 
National Enforcement Investigations Center. 

Office of Solid Waste and Emergency Response(one regional 
administrator or one assistant administrator): 
Environmental Response Team. 

Office of Chemical Safety and Pollution Prevention Office(one regional 
administrator or one assistant administrator): 
Aanalytical Chemistry Lab; 
Microbiology Lab; 
Microarray Lab; 
Environmental Chemistry Lab. 

Office of Air and Radiation(one regional administrator or one 
assistant administrator): 
National Vehicle and Fuel Emissions Laboratory; 
National Air and Radiation Environmental Laboratory; 
Radiation and Indoor Environments National Laboratory. 

Office of Research and Development laboratories: 

National Exposure Research Laboratory(one regional administrator or 
one assistant administrator): 
Atmospheric Sciences Modeling Division; 
Ecological Exposure Research Division; 
Ecosystems Research Division; 
Environmental Sciences Division; 
Human Exposure and Atmospheric Sciences Division; 
Microbiological and Chemical Exposure Assessment Research Division. 

National Health and Environmental Effects Research Laboratory(one 
regional administrator or one assistant administrator): 
Integrated Systems Toxicology Division; 
Environmental Public Health Division; 
Toxicity Assessment Division; 
Atlantic Ecology Division; 
Gulf Ecology Division; 
Mid-Continent Ecology Division; 
Western Ecology Division. 

National Risk Management Research Laboratory(one regional 
administrator or one assistant administrator): 
Air Pollution Prevention and Control Division; 
Land Remediation and Pollution Control Division; 
Ground Water Ecosystems Restoration Division; 
Sustainable Technology Division; 
Water Supply and Water Resources Division. 

Source: GAO. 

[End of figure] 

EPA Has Not Fully Addressed Findings of Evaluations on Long-standing 
Planning, Coordination, or Leadership Issues: 

Although EPA has taken some actions, it has not fully addressed the 
findings and recommendations of five independent evaluations over the 
past 20 years regarding long-standing planning, coordination, and 
leadership issues that hamper the quality, effectiveness, and 
efficiency of its science activities, including its laboratory 
operations (see appendix III for details on the evaluations). 
Specifically, EPA has not fully implemented recommendations intended 
to address planning and coordination issues including (1) developing 
and implementing an overarching issue-based planning process that 
integrates and coordinates scientific efforts throughout the agency or 
(2) consolidating, reorganizing, or streamlining laboratory facilities 
and workforce. In addition, EPA has not addressed the leadership 
issues raised in these evaluations by appointing a top science 
official with the authority and responsibility to coordinate and 
oversee scientific activities throughout the agency, including the 
work of all program, regional, and ORD laboratories. 

EPA Lacks an Overarching Planning Process for Its Scientific 
Activities: 

EPA has yet to fully address planning and coordination issues 
identified by a 1992 independent evaluation[Footnote 10] that 
recommended that EPA develop and implement an overarching issue-based 
planning process that integrates and coordinates scientific efforts 
throughout the agency, including the important work of its 37 
laboratories. That evaluation found that EPA's science was of uneven 
quality and the agency lacked a coherent science agenda and 
operational plan to guide scientific efforts throughout the agency. In 
response to this evaluation, EPA appointed a science advisor to 
provide advice to the administrator on agencywide science issues, but 
later evaluations found that the position does not provide the level 
of authority needed to oversee and coordinate laboratory activities. 
Further, EPA did not implement the evaluation's recommendation 
regarding an overarching planning process for all of the agency's 
scientific efforts. Consequently, EPA's programs, regional officials, 
and ORD continue to independently plan and coordinate the activities 
of their respective laboratories based on their own office's 
priorities and needs. Although EPA has pursued other initiatives in an 
effort to improve laboratory coordination, these efforts do not fully 
address the planning and coordination issues in the 1992 evaluation. 
In 2008, EPA's Administrator acknowledged that planning and 
coordination issues continue to affect EPA's science credibility and 
decision making in a letter to the Science Advisory Board requesting a 
new study on strengthening scientific assessments.[Footnote 11] 

EPA Has Not Consolidated Its Laboratories as Recommended: 

EPA has also not fully addressed recommendations from a 1994 
independent evaluation[Footnote 12] to consolidate and realign its 
laboratory facilities and workforce--even though this evaluation found 
that the geographic separation of laboratories hampered their 
efficiency and technical operations and that consolidation and 
realignment could improve planning and coordination issues that have 
hampered its science and technical community for decades. The 1994 
evaluation was in response to congressional direction to explore, and 
report back to Congress, whether a consolidated laboratory structure 
would better enable EPA to accommodate the need for integrated 
research and monitoring.[Footnote 13] As such, EPA tasked the MITRE 
Corporation to perform an independent evaluation of its laboratories 
to be used by the agency as one of the inputs in developing its report 
to Congress. 

In its evaluation, MITRE identified various restructuring options and 
identified opportunities for EPA to improve the efficiency and 
effectiveness of its operations. The MITRE recommendations were 
intended to eliminate apparent duplications of facilities and 
equipment and increase disciplinary strength of EPA's human resource 
base. Specifically, MITRE recommended that EPA (1) realign and 
consolidate the ORD laboratories; (2) consolidate laboratories in the 
Office of Prevention, Pesticides and Toxic Substances[Footnote 14] and 
the two laboratories under the Office of Radiation and Indoor Air; and 
(3) through consolidation, reduce the number of regional office 
laboratories to a few laboratories with a national service focus. 
According to the evaluation, these changes could be made over time, as 
leases for current facilities expired or investment decisions on 
facility and major equipment upgrades were being made. In addition to 
the MITRE evaluation, in 1994 EPA tasked the National Academy of 
Public Administration and EPA's Science Advisory Board to review 
MITRE's evaluation and provide EPA with input regarding the management 
and organization of EPA's laboratories. Both reviews generally 
supported the MITRE recommendations but emphasized the importance of 
key management improvements as part of any reorganization of ORD 
laboratories. 

After considering its restructuring and consolidation options, an 
agencywide steering committee issued a report to the administrator in 
July 1994.[Footnote 15] Although the steering committee report stated 
that combining ORD laboratories at a single location could improve 
teamwork and raise productivity, the report concluded that, for the 
near term, ORD should be functionally reorganized but not physically 
consolidated. The report's justification for this decision suggests 
that other important science and management improvements should be 
implemented and given time to be integrated into planning and 
budgeting operations before any decision on physical consolidation and 
relocation of staff would occur. Regarding program office laboratory 
consolidations, EPA's 1994 report recommended maintaining the current 
structural configuration of program office laboratories but requested 
that the Office of Radiation and Indoor Air and Office of Prevention, 
Pesticides, and Toxic Substances evaluate the merits of laboratory 
consolidation. Upon evaluation, while the Office of Radiation and 
Indoor Air did not physically consolidate its laboratories, it did 
administratively and physically consolidate its Las Vegas laboratory 
with ORD's Las Vegas radiation laboratory and the Office of 
Prevention, Pesticides, and Toxic Substances colocated three of four 
laboratories with the region 3 laboratory. The report also recognized 
the advantages of colocation, including the sharing of laboratory 
equipment and technical knowledge, facility services, and cost 
savings, and the need to address existing and potential duplication. 
Therefore, the report recommended improved planning processes across 
EPA's laboratories; however, EPA has yet to implement an overarching, 
long-term planning process for all of its laboratories. As for the 
regional laboratories, EPA's 1994 report endorsed the current 
decentralized regional model but did not provide a justification for 
its position. 

EPA Has Not Addressed Leadership Issues: 

EPA has not fully addressed recommendations from the independent 
evaluations regarding leadership of its research and laboratory 
operations. Over the past two decades, three independent evaluations 
[Footnote 16] have identified weaknesses in EPA's scientific 
leadership. For example, the National Research Council's evaluation in 
2000 concluded that the lack of a top science official was a formula 
for weak scientific performance in the agency and poor scientific 
credibility outside the agency. Nonetheless, EPA has not appointed a 
top science official with responsibility and authority for all the 
research, science, and technical functions of the agency, including 
integrating and coordinating the science activities conducted by EPA's 
laboratories. 

EPA's efforts to establish leadership over its laboratory enterprise 
have relied on consensus and voluntary cooperation of ORD and the 
agency's program and regional offices. As discussed previously, EPA 
created a science advisor position to provide advice to the 
administrator on agencywide science issues in response to a 1992 
expert panel recommendation aimed at strengthening EPA's scientific 
coordination and leadership. Then, in 1993, EPA formed the Science 
Policy Council[Footnote 17] to serve as a mechanism for addressing 
significant science policy issues that go beyond regional and program 
boundaries. However, in 2000, the National Research Council reported 
that efforts relying on consensus and voluntary cooperation were not 
an effective approach to providing needed scientific leadership. 
Further, in 2008, EPA's Administrator noted that the agency's existing 
science coordinating bodies lack the longer-term strategic viewpoint 
needed to address today's more complex environmental problems as they 
primarily focus on the immediate scientific needs of the agency. 

Because of the limited success of EPA's advisory positions and 
councils and in the absence of a central science policy authority, the 
National Research Council in 2000 recommended that EPA request 
authority from Congress to create a new position of deputy 
administrator for science and technology, with managerial authority to 
coordinate and oversee all the agency's scientific and technical 
activities. The council reported that EPA's designation of the 
assistant administrator of the Office of Research and Development as 
coordinator for scientific planning had proven to be insufficient 
because the position did not provide adequate authority or 
responsibility for oversight, coordination, and decision making. To 
date, EPA has not requested authority to create a new position of 
deputy administrator for science and technology and continues to 
operate its laboratories under the direction of 15 different senior 
officials using 15 different organizational and management structures. 
As a result, EPA has a limited ability to know if scientific 
activities are being unintentionally duplicated among the laboratories 
or if opportunities exist to collaborate and share scientific 
expertise, equipment, and facilities across EPA's organizational 
boundaries. Instead, these activities remain fragmented and largely 
uncoordinated--reflecting the independent organizational and 
management structure of EPA's 15 senior officials charged with 
planning and managing the scientific work performed at each of EPA's 
laboratories. 

EPA Has Not Taken an Agencywide, Coordinated Approach to Manage Its 
Laboratory Physical Infrastructure: 

EPA's laboratories are an integral part of the infrastructure 
necessary for the agency to meet the analytical services and 
scientific research aspects of its mission, yet the agency has not 
taken an agencywide, coordinated approach to managing its investment 
in the approximately 170 laboratory buildings and facilities it owns 
or leases as part of an interrelated portfolio of facilities. In 
addition, EPA's 2008 near-term laboratory study identified reasons 
hindering an agencywide approach for managing the laboratories. EPA 
also lacks complete and reliable data on which to make informed 
decisions about the management of its laboratory facilities. 

EPA Does Not Manage Its Laboratory Facilities as Part of an 
Interrelated Portfolio of Facilities: 

As discussed above, EPA's management of its laboratory enterprise is 
decentralized, with 15 different senior officials using 15 different 
organizational and management structures. Since 2003, when GAO 
designated federal real property management as an area of high risk, 
agencies have come under increasing pressure to manage their real 
property assets more effectively.[Footnote 18] In 2004 the National 
Research Council recommended that federal departments and agencies 
make investment and management decisions about individual projects in 
relation to their entire portfolio of facilities.[Footnote 19] Based 
on our analysis of EPA's master planning process, we found that EPA 
manages its facilities on a site-by-site basis and does not evaluate 
each site in the context of all the agency's real property holdings. 
As a result, EPA cannot be assured that it is investing its capital 
improvement funds most appropriately or identifying possible cost- 
savings opportunities. 

According to EPA's real property asset management plan, developing and 
updating facility master plans is an integral part of managing the 
agency's laboratory infrastructure. Master plans should contain, among 
other things, information on mission capabilities, use of space, and 
condition of individual laboratory sites. EPA's facility master plans 
are intended to be the basis for justifying its building and 
facilities spending, which was $29.9 million in fiscal year 2010, and 
allocating those funds to specific repair and improvement projects. 
However, we found that EPA does not use its master planning process to 
manage its laboratory infrastructure as a portfolio that considers 
mission capabilities, facility condition, and space allocation across 
all sites. Instead, the Office of Administration and Resource 
Management, which is responsible for allocating funds for repairs and 
improvements to buildings and facilities, uses each facility's master 
plans to make decisions in isolation for individual sites. In 
addition, we found that most facility master plans were out of date. 
Although EPA's real property asset management plan states that 
facility master plans are supposed to be updated every 5 years to 
reflect changes in facility condition and mission, we found that 11 of 
20 master plans were out of date and 2 of 20 had not been created yet. 
[Footnote 20] 

EPA May Not Be Allocating Capital Improvement Funds Most Appropriately: 

Because the Office of Administration and Resource Management makes 
capital improvement decisions on a site-by-site basis using master 
plans that are often outdated, EPA cannot be assured it is allocating 
its funds most appropriately. According to senior Office of 
Administration and Resource Management officials responsible for 
allocating capital improvement resources, they try to spread these 
funds across the agency's offices and regions equitably. These 
officials said that EPA's capital improvement funds have not kept pace 
with requests--funds declined from $32.6 million to $29.9 million 
between fiscal years 2006 and 2010, while requests for laboratory 
capital improvements call for spending about $78 million per year. The 
pressure and need to effectively share and allocate limited resources 
among EPA's many laboratories were also noted in the 1994 National 
Academy of Public Administration report on EPA's laboratory 
infrastructure, which found that EPA has "too many labs in too many 
locations often without sufficient resources to sustain a coherent 
stable program."[Footnote 21] Office of Administration and Resource 
Management officials told us some challenges to reducing space are 
stakeholder interest, an organizational culture that equates space 
with power, and programs that do not mind paying laboratory operating 
costs because the expense is relatively small compared to their 
overall program budget.[Footnote 22] 

The following examples illustrate EPA's need for more effective 
management of its limited resources and the limitations of its 
allocation process for ensuring that all mission-critical laboratory 
assets are functioning at an optimal or acceptable level. At one 
laboratory in Oregon, officials told us the laboratory's heating and 
cooling system allows temperatures to fluctuate as much as 17 degrees, 
requiring scientists to frequently recalibrate sensitive laboratory 
equipment and adjust the results. Laboratory officials said this 
situation disrupts operating efficiency and could create perceptions 
about the results' quality. Consequently, according to laboratory 
officials, they have had to invest additional time and resources in a 
rigorous quality assurance program to ensure quality results. At 
another laboratory in New Jersey, the 2007 master plan states that the 
conditions of the laboratory facilities are deficient in quantity, 
quality, and functionality, and raise a number of safety concerns. The 
plan states that the facilities hinder the conduct of scientific 
research and analysis. The plan also states that a lack of adequate 
environmental controls requires repetitive tests to be performed on 
the same samples to obtain valid results, and vibrations in trailer 
laboratories cause delays in completing sensitive analytical 
procedures. 

Possible Cost-Savings Opportunities May Be Lost: 

In addition to impeding EPA's ability to effectively allocate its 
capital improvement resources, the agency's lack of an agencywide 
coordinated approach for managing its laboratory infrastructure as an 
interrelated portfolio presents other challenges. Because decisions 
regarding laboratory facilities are made independently of one another, 
opportunities to improve operating efficiencies can be lost. 
Specifically, we found cases where laboratories that were previously 
colocated moved into separate space without considering the potential 
benefits of remaining colocated. For example, ORD and Region 4 once 
operated laboratories in one EPA-owned facility in Athens, Georgia. 
According to agency officials, space limitations, different management 
structures, and mission differences led the regional laboratory to 
move to another building across the parking lot within the same 
campus. The relocation increased operating costs because the 
laboratories then had two facility managers and two security contracts 
and associated personnel because of different requirements for the 
leased facility. Similarly, we found that the National Enforcement 
Investigations Center laboratory and Region 8 once operated colocated 
laboratories in a leased facility in Denver, Colorado, and then moved 
into separate new leased laboratories several miles apart. However, 
agency officials did not know to what extent this move may have 
resulted in increased operating cost. 

In contrast, we found two laboratory locations that demonstrated the 
potential benefits from colocation and having a single facility 
manager, neither of which are factors considered by EPA's site-by-site 
facility-planning process. ORD, the Office of Solid Waste and 
Emergency Response, and Region 2 operate colocated laboratories at 
Edison, New Jersey. One agency official manages facility operations, 
including building maintenance, utilities, and security. Laboratory 
officials said colocation has provided opportunities to share 
laboratory equipment and technical knowledge, facility services, and 
cost savings. Likewise, the Office of Chemical Safety and Pollution 
Prevention and Region 3 operate colocated laboratories at Fort Meade, 
Maryland. The EPA-owned building allows the two laboratories to share 
one facility manager, security, and common areas such as storage space 
and conference rooms that would otherwise be duplicated at extra cost 
at two independent locations. These examples demonstrate the potential 
benefits of colocation, which could occur more frequently if EPA 
managed its laboratory infrastructure as part of a portfolio. 

Our findings are consistent with the conclusion reached by a 2008 
study[Footnote 23] aimed at identifying and implementing cost savings. 
As discussed earlier, in response to EPA's Chief Financial Officer's 
2006 call for developing a laboratory consolidation plan that would 
achieve a 10 percent reduction in the cost of the agency's laboratory 
infrastructure in fiscal 2009 and another 10 percent reduction by 
fiscal year 2011, the agency proposed conducting near-and long-term 
studies to identify and implement cost savings and improve the 
laboratories' ability to support the agency's mission. EPA's 2008 near-
term study describes examples where individual laboratories have 
worked together to share resources. The study also found, however, 
that because EPA's laboratories operate independently, opportunities 
for increased resource sharing and operating efficiencies are 
inhibited by institutional barriers, such as concerns about laboratory 
autonomy and sensitivity about laboratory consolidation. Although EPA 
briefed congressional staff on the results of the near-term study and 
plans for the long-term study in 2008 and 2009 and requested funding 
in the President's fiscal year 2012 budget, the agency has yet to 
finalize the scope and methodology to be used for its long-term study. 
However, given that EPA has not responded to recommendations from 
prior independent evaluations to close, relocate, or consolidate 
laboratories, it is unclear whether the proposed study will produce 
meaningful change or fulfill the cost-savings targets envisioned by 
the Chief Financial Officer. 

EPA Lacks Sufficiently Complete and Reliable Data for Agencywide 
Management of Its Laboratory Facilities: 

EPA lacks sufficiently complete and reliable data to make informed 
decisions for managing its facilities. Since most of EPA's laboratory 
facility master plans are outdated, decisions made using these plans 
are based on outdated usage, condition, and operating cost data. In 
addition, for those plans that have been updated within the last 5 
years, we found that EPA does not use objective benchmarks to 
determine laboratory usage rates, a guiding principle in real property 
asset management. Moreover, we found that the agency's real property 
database lacked the checks and controls necessary for helping to 
ensure the reliability of data, such as data on operating costs and 
condition assessments, needed to manage its facilities and for 
reporting to Congress and other external parties, such as OMB. 

In February 2004, the President issued an executive order requiring 
agencies to, among other things, improve the operational and financial 
management of their real property inventory.[Footnote 24] The order 
established a Federal Real Property Council within OMB, which has 
developed guiding principles for real property asset management. The 
council required agencies to draft an asset management plan that 
addresses these guiding principles, including support for agency 
mission and goals, use of public and commercial benchmarks and best 
practices, life-cycle cost-benefit analysis, full and appropriate 
utilization, disposal of unneeded assets, and accurate inventory and 
description of all assets. The council also expects agencies to ensure 
that all real property initiatives are carried out in a manner that is 
consistent with these principles. 

The need to better manage federal real property was underscored in a 
June 2010 presidential memorandum that directs agencies to accelerate 
efforts to identify and eliminate excess properties. According to the 
memorandum, agencies' collective efforts are to produce a total of $3 
billion in cost savings by 2012. These savings are to be measured by 
usage and occupancy rates and annual operating costs.[Footnote 25] In 
response to the President's directive, in July 2010 EPA reported to 
OMB that it does not anticipate the disposal of any of its owned 
laboratories and major assets in the near future because these assets 
are fully used and considered critical for the mission of the customer 
and overall agency.[Footnote 26] EPA stated that decisions regarding 
facility disposal are made using the Federal Real Property Council's 
disposition decision tree. Nevertheless, as shown in figure 3, we 
found that at four key points in the decision-making process, EPA 
lacks accurate and reliable information regarding (1) the need for 
facilities, (2) property usage, (3) facility condition, and (4) 
facility operating efficiency--thereby undermining the credibility of 
any decisions based on this approach. 

Figure 3: Incomplete and Unreliable EPA Data Used to Make Facility 
Disposition Decisions: 

[Refer to PDF for image: illustration] 

GAO's finding: 
Data on agency need of facilities are out of date. 

GAO's finding: 
Data on space needs and usage are out of date. Analysis of use of 
space is not based on objective benchmarks. 

GAO's finding: 
Data on condition assessment are out of date. 

GAO's finding: 
Data on operating costs are incomplete and may be unreliable. 

Federal Real Property Council's Disposition Decision Tree: 

Is there an agency need, either mission critical or mission dependent, 
for the facility? 
No: Dispose of the facility; 
Yes: Continue. 

Is the facility utilized: 
No: Dispose of the facility or look for opportunities to share 
facility space; 
Yes: Continue. 

Is the facility in good condition? 
No: Dispose of the facility, replace the facility or upgrade the 
facility; 
Yes: Continue. 

Does the facility operate efficiently? 
No: Dispose of the facility, replace the facility or upgrade the 
facility; 
Yes: Keep the facility. 

Source: GAO. 

[End of figure] 

First, EPA lacks accurate data to determine if there is an agency need 
for laboratory facilities because many facility master plans are often 
out of date. According to EPA's asset management plan, the master 
plans are tools that communicate the link between mission priorities 
and facilities. However, without up-to-date master plans, EPA does not 
have accurate data to determine if laboratory facilities are needed 
for its mission. 

Second, the agency lacks accurate data on space needs and usage 
because many facility master plans containing space utilization 
analyses are out of date. EPA also does not use public and commercial 
benchmarks to calculate usage rates for its laboratories even though 
the Federal Real Property Council identifies the use of such 
benchmarks as one of its guiding principles. Instead, EPA measures 
laboratory usage on the basis of interviews with local laboratory 
officials. According to EPA officials, they do not use benchmarks 
because the work of the laboratories varies. In 2008, however, an EPA 
contractor created a laboratory benchmark based on those used by 
comparable facilities at the Centers for Disease Control and 
Prevention, the National Institutes of Health, the Department of 
Energy, and several research universities to evaluate space at two ORD 
laboratories in North Carolina. Consequently, we believe that 
objective benchmarks can be developed for EPA's unique laboratory 
requirements. In addition, the contractor's analysis concluded that 
EPA could save $1.68 million in annual leasing and $800,000 in annual 
energy costs through consolidation of the two ORD laboratories. Agency 
officials told us they hope to consolidate the laboratories in fiscal 
year 2012 if funds are available. 

Third, the agency lacks accurate data for assessing facilities' 
condition because condition assessments contained in facility master 
plans are often outdated. Moreover, the out-of-date condition 
assessment is the basis for data reported to the Federal Real Property 
Council on facilities' condition. The data may also be unreliable 
because data entered by local facility mangers are not verified, 
according to agency officials. Such verification could involve edit 
checks or controls to help ensure the data are entered accurately. 
[Footnote 27] 

Fourth, EPA does not have reliable operating cost data for its 
laboratory enterprise, because the agency's financial management 
system does not track operating costs in sufficient detail to break 
out information for individual laboratories or for the laboratory 
enterprise as a whole. Reliable operating cost data are important in 
determining whether a laboratory facility is operating efficiently, a 
determination that should inform both capital investment and property 
disposal decisions. Operating cost data are also required by the 
Federal Real Property Council. Consequently, facility managers for 
each EPA-owned and EPA-leased laboratory compile and manually enter 
laboratory operating cost data into EPA's real property database, 
where the data are tracked and ultimately reported to the 
council.[Footnote 28] However, the EPA officials responsible for 
reporting operating cost data to the Federal Real Property Council 
expressed concerns over the source and integrity of the data entered 
by facility managers. We found that the data entered by local facility 
managers, such as operating costs and condition assessments, lacked 
the edit checks and controls necessary for ensuring their reliability. 
These data are reported to external parties, such as the OMB's Federal 
Real Property Council. 

EPA Does Not Use a Comprehensive Workforce Planning Process for Its 
Laboratories: 

EPA does not use a comprehensive planning process for managing its 
laboratories' workforce and does not plan across its laboratories. In 
addition, EPA lacks basic information on its laboratory workload and 
workforce, including demographic data on the number of federal and 
contract employees currently working in its 37 laboratories. 

EPA Lacks a Laboratory Workforce Plan, and Its Agencywide Workforce 
Plan Does Not Discuss Laboratory Workforce: 

In fiscal year 2006, EPA issued its first agencywide workforce plan. 
The plan did not include a specific discussion of the agency's 
laboratory workforce or the agency's workload, but it did identify 19 
mission-critical occupations--of which, many were science-related 
occupations such as toxicologists, geneticist, biologists, and 
chemists. The stated purpose of the 2006 agencywide plan was to 
provide guidance to program and regional offices so they could develop 
their own workforce plans and submit them to the Office of Human 
Resources in 2007. However, we found that not all of the regional and 
program offices with laboratories prepared workforce plans, and for 
those that did, most did not specifically address their laboratories' 
workforce. In fact, some regional management and human resource 
officials we spoke with were unaware of the requirement to submit 
workforce plans to the Office of Human Resources. Some of these 
managers told us the program and regional workforce plans were a 
paperwork exercise, irrelevant to the way the workforce is actually 
managed. Managers in program and regional offices said that workforce 
planning for their respective laboratories is fundamentally driven by 
the annual budgets of program and regional offices and ceilings for 
full-time equivalents (FTE).[Footnote 29] These remarks align with our 
May 2010 report, which found that EPA's 2006 agencywide workforce plan 
does not directly link workforce planning with its strategic planning. 
[Footnote 30] EPA's process for allocating resources involves making 
annual incremental adjustments and relies primarily on historical 
precedent. 

EPA Does Not Plan Across Its Laboratories: 

None of the program and regional workforce plans we reviewed described 
any effort to work across organizational boundaries to integrate or 
coordinate their workforce with the workforces of other EPA 
laboratories. Consequently, EPA cannot successfully undertake 
succession planning and management to help the organization adapt to 
meet emerging and future requirements. For example, although two 
regional workforce plans discussed potential vulnerability if highly 
skilled laboratory personnel retired, neither plan explored options 
for sharing resources across regional boundaries to address potential 
skill gaps. According to EPA's Regional Laboratory System 2009 Annual 
Report, many of the regional laboratories provide the same or similar 
core analytical capabilities--including a full range of routine and 
specialized chemical and biological testing of air, water, soil, 
sediment, tissue, and hazardous waste. Nonetheless, in these workforce 
plans, each region independently determines and attempts to address 
its individual workforce needs. As a result, by not exploring options 
for sharing resources among the ORD, program, and regional boundaries 
to address potential skill gaps, EPA may be missing opportunities to 
fill critical occupation needs through resource sharing. 

EPA Lacks Basic Data about Its Laboratory Workforce: 

In addition, EPA lacks basic demographic information on the number of 
federal and contract employees currently working in its 37 
laboratories. Specifically, EPA does not routinely compile the 
information needed to know how many scientific and technical employees 
it has working in its laboratories, where they are located, what 
functions they perform, or what specialized skills they may have. 
Moreover, the agency does not have a workload analysis for the 
laboratories to help determine the optimal numbers and distribution of 
staff among the enterprise. We believe that such information is 
essential for EPA to prepare a comprehensive laboratory workforce plan 
to achieve the agency's mission with limited resources. Because EPA's 
laboratory workforce is managed separately by 15 independent senior 
officials, information about that workforce is tracked separately and 
is not readily available or routinely compiled or evaluated. Instead, 
EPA has relied on ad hoc calls for information to compile such data. 
According to agency officials, the most recent request for EPA-wide 
information was initiated in 1994 in support of the MITRE 
Corporation's evaluation. 

As part of our work, we requested demographic information on EPA's 
laboratory workforce, but after multiple attempts to compile these 
data, EPA was unable to provide us with data for the laboratory 
workforce as a whole that were sufficiently reliable for our purposes. 
Specifically, we were unable to verify the reliability of the data the 
managers of program and regional offices with laboratories and the ORD 
provided because they used inconsistent data sources and did not 
provide supporting documentation describing how the data were 
compiled. In addition, we asked EPA's Office of Human Resources to 
query its personnel database to provide us with a special report of 
federal personnel working in the laboratories.[Footnote 31] However, 
we could not be assured of the accuracy or reliability of the data 
provided by this office either because, in part, EPA does not have an 
official master list of database codes showing each laboratory 
separately from any colocated facilities or clearly identifying 
whether an employee was assigned to the laboratory or another 
facility.[Footnote 32] Federal standards for internal control state 
that effective management of an organization's workforce is essential 
to achieving results and that, among other things, operational success 
is only possible when the right personnel for the job are on board. 

In response to our prior reports[Footnote 33] and the work of the EPA 
Inspector General, EPA hired a contractor in 2009, in part, to conduct 
a study to provide information about the agency's overall workload, 
including staffing levels and workload shifts for six major functions, 
including scientific research. In its budget justification for fiscal 
year 2012, however, the agency reported to Congress that a survey of 
the existing workload information provided by the contractor will not 
immediately provide information sufficient to determine whether 
changes are needed in workforce levels. EPA has not released the 
results of this study, and we therefore cannot comment on whether its 
content has implications for the laboratories. Further, the agency 
asked its National Advisory Council for Environmental Policy and 
Technology to help address scientific and technical competencies as it 
develops a new agencywide workforce plan. However, the new plan is not 
complete, and therefore it is too early to tell whether the Council's 
recommendations will have implications for the laboratories. 

Conclusions: 

EPA's laboratories play an integral role in supporting EPA's mission 
by providing the scientific research, technical support, and 
analytical services that underpin the policies and regulations the 
agency implements. The complexity of EPA's mission, the rapid pace of 
scientific and technological advances, and shifts in policy require 
that the agency's laboratory enterprise be responsive to change and 
equipped to meet the scientific challenges ahead. Although independent 
evaluations of EPA's scientific activities have called on EPA to 
address long-standing planning, coordination, and leadership issues, 
little has changed with respect to EPA's laboratory organization over 
the past 20 years. EPA' scientific activities remain fragmented and 
largely uncoordinated--reflecting the independent organizational and 
management structure of EPA's 15 senior officials charged with 
planning and managing the scientific work performed at each of EPA's 
laboratories. In light of current efforts to reduce the federal budget 
deficit, which include significant proposed cuts in the budgets of 
most departments and agencies, including EPA, the agency will need to 
more effectively use its scientific and laboratory resources across 
the agency to ensure the agency is best positioned to fulfill the 
critical scientific work for its core mission. However, EPA's ability 
to respond to this challenge may be hampered by the lack of an 
overarching issue-based planning process that integrates and 
coordinates scientific efforts throughout the agency and reflects the 
collective goals, objectives, and priorities of the laboratories and a 
top science official to coordinate, oversee, and make management 
decisions regarding major scientific activities throughout the agency. 

Although the laboratories' current operating model may provide its 15 
senior officials with greater flexibility to use laboratory resources 
in support of individual program and regional priorities, this 
flexibility comes at a price. Beyond potential duplication of effort, 
EPA's current decentralized approach makes it difficult for the agency 
to effectively manage its laboratory facilities and workforce. With no 
single top science official with the authority and responsibility to 
coordinate, oversee, and make management decisions regarding major 
scientific activities throughout the agency, EPA does not manage its 
laboratory infrastructure as an interrelated portfolio of facilities 
that considers mission capabilities, facility condition, and space 
allocation across all sites to ensure the most effective use of 
limited agency resources. EPA also lacks up-to-date facility master 
plans, objective benchmarks to assess the use of space for both owned 
and leased laboratories, and complete and reliable operating cost and 
other data needed to make informed decisions about the management of 
its laboratory facilities and report to external parties. Finally, 
because EPA does not attempt to plan for its workforce needs across 
organizational boundaries and lacks reliable agencywide data needed to 
identify and fill workforce gaps, EPA does not have a workforce 
planning process for all laboratories that reflects current and future 
needs in overall number of federal and contract employees, skills, and 
deployment across laboratory facilities. Consequently, EPA cannot 
successfully undertake succession planning and management to help the 
organization adapt to meet emerging and future requirements. 

Although EPA's laboratory organizational and management structure and 
footprint have remained largely the same over the past 20 years--in 
spite of multiple calls for change--in the current budget climate the 
agency may not be afforded the luxury of maintaining its current 
number of laboratory facilities. Past independent evaluations have 
made numerous recommendations concerning steps EPA can take to address 
many of its long-standing planning, coordination, and leadership 
challenges--including steps EPA could implement without conducting 
another study. It is unclear whether the proposed long-term study 
being considered by EPA will address the organization of the 
laboratories' workforce and infrastructure or whether it will identify 
opportunities for sharing and consolidation. If EPA should conduct its 
proposed long-term study, to be successful where past independent 
evaluations have failed to produce change, decisions based on the 
study's results cannot be made by those with a vested interest in 
maintaining the status quo. Unless responsibility for making difficult 
choices falls under the authority and responsibility of one official, 
such a study is unlikely to yield real improvements in the 
laboratories' efficiency and effectiveness--including opportunities 
for sharing and consolidation through alternative approaches for 
organizing the laboratories' workforce and infrastructure. Such 
improvements would allow the agency to concentrate its limited 
resources on the agency's most pressing science priorities. 

Recommendations for Executive Action: 

To improve cohesion in the management and operation of EPA's 
laboratories, we recommend that the Administrator of EPA take the 
following seven actions: 

* Develop an overarching issue-based planning process that reflects 
the collective goals, objectives, and priorities of the laboratories' 
scientific activities. 

* Establish a top-level science official with the authority and 
responsibility to coordinate, oversee, and make management decisions 
regarding major scientific activities throughout the agency, including 
the work of all program, regional, and ORD laboratories. 

* Improve physical infrastructure and real property planning and 
investment decisions by: 

- managing individual laboratory facilities as part of an interrelated 
portfolio of facilities; 

- ensuring that master plans are up-to-date and that analysis of the 
use of space is based on objective benchmarks; and: 

- improving the completeness and reliability of operating-cost and 
other data needed to manage its real property and report to external 
parties. 

* Develop a comprehensive workforce planning process for all 
laboratories that is based on reliable workforce data and reflects 
current and future agency needs in overall number of federal and 
contract employees, skills, and deployment across all laboratory 
facilities. 

* If EPA determines another independent study is needed, the agency 
should include alternative approaches for organizing the laboratories' 
workforce and infrastructure, including options for sharing and 
consolidation. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to EPA for review and comment. We 
received written comments from EPA's Deputy Administrator. These 
comments and our detailed response to them are presented in Appendix 
IV. EPA also provided technical comments, which we incorporated into 
the report as appropriate. 

EPA generally agreed with our findings and recommendations. 
Specifically, EPA agreed that it should (1) do more to develop a 
planning process that better reflects the collective goals, 
objectives, and priorities of the scientific activities across its 
laboratory enterprise, (2) establish a top-level science official with 
the authority and responsibility to coordinate, oversee, and make 
recommendations to the Administrator regarding major scientific 
activities throughout the agency, (3) improve physical infrastructure 
and real property planning and investment decisions by managing 
individual laboratory facilities as part of an interrelated portfolio 
of facilities, (4) maintain up-to-date master plans that include 
effective benchmarks, (5) improve the completeness and reliability of 
operating cost and other data needed to manage its real property, (6) 
develop a comprehensive work-force-planning process for its laboratory 
enterprise, and (7) include alternate approaches for organizing the 
laboratory workforce and infrastructure in a proposed independent 
study of EPA's laboratories. 

As agreed with your staff, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to the 
appropriate congressional committees, the administrator of EPA, and 
other interested parties. In addition, this report will be available 
at no charge on the GAO website at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions on this report, please contact 
me 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 report. GAO staff who made major contributions 
to this report are listed in appendix V. 

Sincerely yours, 

Signed by: 

David C. Trimble: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Our objectives were to examine the extent to which the Environmental 
Protection Agency (EPA) (1) has addressed the findings of independent 
evaluations performed by the National Research Council and others 
regarding long-term planning, coordination, and leadership issues; (2) 
uses an agencywide, coordinated approach for managing its physical 
laboratory infrastructure and whether the agency's near-and long-term 
studies will achieve their stated cost saving and laboratory 
improvement goals; and (3) uses a comprehensive planning process to 
manage its laboratory workforce. 

To complete our work, we reviewed agency documentation including 
strategic plans, budget justifications, Office of Research and 
Development (ORD) multiyear research plans, regional laboratory annual 
reports, and information on EPA's laboratory organization and 
management. We analyzed EPA's relevant funding and workforce 
documents, policies, procedures, and guidance, as well as related 
laws, requirements, and leading practices pertinent to EPA's 
laboratories and efforts to improve its operations. We reviewed our 
prior reports that were appropriate for this review, such as our high-
risk series and those relating to EPA, federal laboratories, federal 
asset management, human capital and workforce issues, and strategic 
planning, among others. 

In addition, we interviewed officials in EPA headquarters and 
officials representing all ORD and program laboratories and 5 of 10 
regional offices and laboratories. In addition, we visited a 
nonprobability sample of laboratories located in Athens, Georgia; 
Chapel Hill, Durham, and Research Triangle Park, North Carolina; 
Corvallis, Oregon; Denver, Colorado; Edison, New Jersey; Fort Meade, 
Maryland; and Port Orchard, Washington. We selected the ORD, program, 
and five regional offices and laboratories we visited based on 
geographic dispersion and proximity to other EPA offices. Because we 
used nonprobability sampling to select these EPA offices and 
laboratories, information we obtained from these visits cannot be 
generalized to other laboratories, but the visits provide us with 
information on the perspectives of various laboratory officials. We 
interviewed laboratory managers, facility managers, scientists, 
technical employees, contractors, and officials who manage the work of 
the laboratories and program officials who are the laboratories' 
customers. We also interviewed representatives from EPA's Science 
Advisory Board and Board of Scientific Counselors and discussed their 
views on the organization and operation of EPA's laboratories. 

To examine EPA's response to the findings of major independent 
evaluations of EPA science activities, including the organizational 
and management structure of EPA's laboratories, we identified and 
reviewed the major independent evaluations of EPA's science activities 
over the past 20 years, including reports from the National Research 
Council, MITRE Corporation, Science Advisory Board, and Office of 
Inspector General. For the purpose of this report, we focused 
specifically on five evaluations that addressed planning, 
coordination, and leadership issues, including issues related to the 
organization and infrastructure of the agency's laboratories. We also 
analyzed internal studies of EPA's laboratories and the policies and 
procedures the agency uses to plan and coordinate the work of its 
laboratories. In addition, we examined documentation on EPA's proposed 
long-term laboratory study. While we considered the budget for the 
laboratories to be an important part of describing the organization 
and management structure, our scope was limited because EPA's Office 
of Budget could not provide us with reliable budget data for all the 
laboratories. We made several attempts to obtain budget data from the 
individual offices with laboratories, but they also could not provide 
us with complete budget data for each laboratory that could be 
compiled in a consistent manner. 

To examine EPA's management of its laboratories' physical 
infrastructure, we analyzed the agency's facility management and real 
estate tracking system, called the Strategic Lease and Asset Tracking 
Enterprise. We also analyzed EPA's asset management plan; operating 
plans; facility manual; federal real property profile data; Real 
Property Cost Savings and Innovation Plan; property master plans; 
nationwide facilities guides; conference presentations from the 2010 
Energy, Security and Facilities Workshop; and guidance for acquiring, 
maintaining, and disposing of laboratories. We also reviewed relevant 
executive orders, presidential memorandums, and a report from the 
National Research Council. We assessed the reliability of the 
laboratory property data maintained in EPA's facility management and 
real property tracking system by (1) reviewing information about the 
data and the system that produced it; (2) interviewing agency 
officials and the database contractor; and (3) analyzing the data for 
missing, inconsistent, and invalid data. When we found incomplete or 
contradictory data, we discussed them with agency officials to 
understand the reasons for inconsistencies. We determined that 
descriptive information on EPA's inventory of laboratory buildings and 
facilities, such as property descriptions and estimated square 
footage, was sufficiently reliable for our purposes. However, we found 
that other data contained in the database, such as operating costs and 
condition assessments, were not sufficiently reliable for the purposes 
of our review, and we reported these limitations as appropriate. 
Specifically, we found that the database lacked controls necessary for 
assuring the reliability of data, such as operating costs or condition 
assessments that are manually entered by individual facility managers 
and subsequently used by EPA to report to external parties, such as 
Office of Management Budget and the Federal Real Property Council. 

To examine EPA's management of its laboratory workforce, we analyzed 
EPA's 2006 strategic workforce plan; workforce documents from program 
and regional offices and ORD; our and EPA's Inspector General's 
reports on workforce planning; and budget documents. In addition, we 
interviewed managers in the program and in regional offices and in the 
ORD who were responsible for workforce planning at their respective 
laboratories. We obtained information from the agency's budget office 
about the ongoing contractor study of workforce planning, and we 
attended meetings of the National Advisory Council for Environmental 
Policy and Technology and reviewed their documents on EPA workforce 
planning. We also interviewed EPA officials responsible for contract 
management to obtain information on contractors providing analytical 
services. Our scope was limited because EPA could not provide us with 
data on its laboratory workforce that GAO could determine to be 
sufficiently reliable for our purposes. As EPA does not publish the 
number of employees in EPA's laboratories, either separately or in 
total, we made several efforts to gather such information. First, we 
made several requests to the managers of program and regional offices 
with laboratories and to the ORD. Ultimately, we were unable to verify 
the reliability of the data the offices provided because they used 
inconsistent data sources and did not provide supporting documentation 
describing how the data were compiled. In addition, we also asked 
EPA's Office of Human Resources to query its personnel database to 
provide us with a special report of federal personnel working in the 
laboratories. This office is responsible for managing a database used 
by EPA to provide the Office of Personnel Management with information 
on all EPA personnel. Nevertheless, we could not be assured of the 
accuracy or reliability of the data because, in part, EPA does not 
have an official master list of database codes showing each laboratory 
separately from any colocated facilities nor clearly identifying 
whether an employee was assigned to the laboratory or another facility. 

We conducted this performance audit from January 2010 through July 
2011, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: EPA's Inventory of Laboratory Properties: 

EPA's real property database contains descriptive information for the 
agency's owned and leased buildings and facilities. Table 1 provides 
descriptive information about all laboratory and laboratory-related 
buildings and facilities contained in EPA's real property database. 
Many properties contain not only the laboratory building, but also 
additional buildings and facilities that support the work of the 
laboratory, including offices and conference rooms, storage rooms, 
greenhouses, fitness centers, maintenance shops, backup generators, 
and security guard houses. For example, at the Edison, New Jersey, 
laboratory property, buildings and facilities included structures 
housing the laboratory, offices, storage, training complex, mobile 
laboratory garage, landscape equipment, and security guards. 

Some of EPA's laboratory property is also occupied by tenants other 
than laboratory personnel. For example, at Research Triangle Park, 
North Carolina, office space in laboratory buildings is shared with 
agency personnel from the Office of Inspector General, Office of the 
Chief Financial Officer, and the Office of the General Counsel, among 
others. Similarly at the Edison, New Jersey, property, the Federal 
Emergency Management Agency occupies a storage building on the 
laboratory property. EPA's database does not provide the proportion of 
a property's square footage that is used by nonlaboratory occupants. 

Table 1: EPA's Inventory of Laboratory Properties: 

Property[A]: National Air and Radiation Environmental Laboratory; 
Number of buildings and facilities: 5; 
Estimated total square feet[B]: 88,605; 
Owned or leased: Owned; 
Region or office using property: Office of Air and Radiation; 
Location: Montgomery, Alabama. 

Property[A]: Region 9 Laboratory; 
Number of buildings and facilities: 2; 
Estimated total square feet[B]: 46,350; 
Owned or leased: Leased; 
Region or office using property: Region 9; 
Location: Richmond, California. 

Property[A]: Denver Federal Center; 
Number of buildings and facilities: 2[C]; 
Estimated total square feet[B]: 125,514[C,D]; 
Owned or leased: GSA Leased; 
Region or office using property: Office of Enforcement and Compliance 
Assurance; 
Location: Lakewood, Colorado. 

Property[A]: Central Regional Laboratory; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 34,100; 
Owned or leased: Leased; 
Region or office using property: Region 8; 
Location: Golden, Colorado. 

Property[A]: Gulf Ecology Division; 
Number of buildings and facilities: 21; 
Estimated total square feet[B]: 83,292; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Gulf Breeze, Florida. 

Property[A]: Region 4 Science and Ecosystems Support Division 
Laboratory[E]; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 51,758; 
Owned or leased: Leased; 
Region or office using property: Region 4; 
Location: Athens, Georgia. 

Property[A]: Ecosystems Research Division[E]; 
Number of buildings and facilities: 10; 
Estimated total square feet[B]: 83,778; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Athens, Georgia. 

Property[A]: Field Research Annex; 
Number of buildings and facilities: 8; 
Estimated total square feet[B]: 7,702; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Athens, Georgia. 

Property[A]: Federal Building, South Clark Street; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 58,537; 
Owned or leased: GSA Leased; 
Region or office using property: Region 5[F]; 
Location: Chicago, Illinois. 

Property[A]: Kansas City Science and Technology Center; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 58,147; 
Owned or leased: Leased; 
Region or office using property: Region 7; 
Location: Kansas City, Kansas. 

Property[A]: Environmental Science Center; 
Number of buildings and facilities: 2; 
Estimated total square feet[B]: 167,745; 
Owned or leased: Owned; 
Region or office using property: Region 3[F]; 
Office of Chemical Safety and Pollution Prevention; 
Location: Fort Meade, Maryland. 

Property[A]: New England Regional Laboratory; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 49,262; 
Owned or leased: Leased; 
Region or office using property: Region 1; 
Location: Chelmsford, Massachusetts. 

Property[A]: Environmental Research Laboratory; 
Number of buildings and facilities: 7; 
Estimated total square feet[B]: 89,950; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Duluth, Minnesota. 

Property[A]: Large Lakes and Rivers Forecasting Research Station; 
Number of buildings and facilities: 5; 
Estimated total square feet[B]: 35,547; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Grosse Ile, Michigan. 

Property[A]: National Vehicle Fuel and Emissions Laboratory; 
Number of buildings and facilities: 4; 
Estimated total square feet[B]: 244,308; 
Owned or leased: Owned and Leased; 
Region or office using property: Office of Air and Radiation; 
Location: Ann Arbor, Michigan. 

Property[A]: Environmental Chemistry Laboratory; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 26,785; 
Owned or leased: Leased[G]; 
Region or office using property: Office of Chemical Safety and 
Pollution Prevention; 
Location: Bay St. Louis, Mississippi. 

Property[A]: UNLV La Plaza Building; 
Number of buildings and facilities: 5; 
Estimated total square feet[B]: 105,526[D]; 
Owned or leased: GSA Leased; 
Region or office using property: Office of Air and Radiation; 
Location: Las Vegas, Nevada. 

Property[A]: UNLV On-campus EPA facilities; 
Number of buildings and facilities: 5; 
Estimated total square feet[B]: 53,100; 
Owned or leased: Leased; 
Region or office using property: Office of Research and Development; 
Office of Air and Radiation; 
Location: Las Vegas, Nevada. 

Property[A]: Edison Laboratory; 
Number of buildings and facilities: 14; 
Estimated total square feet[B]: 761,827[D,H]; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Region 2; 
Office of Solid Waste and Emergency Response; 
Location: Edison, New Jersey. 

Property[A]: Human Studies Facility; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 136,786[D]; 
Owned or leased: Leased; 
Region or office using property: Office of Research and Development; 
Location: Chapel Hill, North Carolina. 

Property[A]: Grand Slam Building; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 43,436[D]; 
Owned or leased: Leased; 
Region or office using property: Office of Research and Development; 
Location: Durham, North Carolina. 

Property[A]: Reproductive Toxicology Facility; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 58,000[D]; 
Owned or leased: Leased; 
Region or office using property: Office of Research and Development; 
Location: Durham, North Carolina. 

Property[A]: Research Triangle Park; 
Number of buildings and facilities: 6; 
Estimated total square feet[B]: 1,067,316[D]; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Research Triangle Park, North Carolina. 

Property[A]: Test and Evaluation Facility; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 36,101[D]; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Cincinnati, Ohio. 

Property[A]: Andrew W. Breidenbach Environmental Research Center; 
Number of buildings and facilities: 6; 
Estimated total square feet[B]: 434,636[D]; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Cincinnati, Ohio. 

Property[A]: Center Hill Research Facility; 
Number of buildings and facilities: 4; 
Estimated total square feet[B]: 28,388; 
Owned or leased: Owned and leased; 
Region or office using property: Office of Research and Development; 
Location: Cincinnati, Ohio. 

Property[A]: Experimental Stream Field Station; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 3,791; 
Owned or leased: Leased; 
Region or office using property: Office of Research and Development; 
Location: Milford, Ohio. 

Property[A]: Steinmart Plaza; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 15,000[D]; 
Owned or leased: Leased; 
Region or office using property: Region 5[F]; 
Location: Westlake, Ohio. 

Property[A]: Robert S. Kerr Environmental Research Center; 
Number of buildings and facilities: 8; 
Estimated total square feet[B]: 98,609; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Ada, Oklahoma. 

Property[A]: Gaar Corner; 
Number of buildings and facilities: 2; 
Estimated total square feet[B]: 2,550; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Gaar Corner, Oklahoma. 

Property[A]: Willamette Research Station; 
Number of buildings and facilities: 6; 
Estimated total square feet[B]: 19,710; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Corvallis, Oregon. 

Property[A]: Environmental Research Laboratory Corvallis; 
Number of buildings and facilities: 7; 
Estimated total square feet[B]: 102,568; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Corvallis, Oregon. 

Property[A]: Environmental Research Laboratory Office; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 24,182; 
Owned or leased: Leased; 
Region or office using property: Office of Research and Development; 
Location: Corvallis, Oregon. 

Property[A]: Coastal Ecology Branch; 
Number of buildings and facilities: 4; 
Estimated total square feet[B]: 41,223; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Newport, Oregon. 

Property[A]: Environmental Effects Research Laboratory; 
Number of buildings and facilities: 7; 
Estimated total square feet[B]: 96,870; 
Owned or leased: Owned; 
Region or office using property: Office of Research and Development; 
Location: Narragansett, Rhode Island. 

Property[A]: Environmental Laboratory; 
Number of buildings and facilities: 2; 
Estimated total square feet[B]: 41,749; 
Owned or leased: Leased; 
Region or office using property: Region 6; 
Location: Houston, Texas. 

Property[A]: Manchester Regional Lab; 
Number of buildings and facilities: 14; 
Estimated total square feet[B]: 72,680; 
Owned or leased: Owned; 
Region or office using property: Region 10; 
Location: Port Orchard, Washington. 

Property[A]: Wheeling Field Office; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 13,865[D]; 
Owned or leased: Leased; 
Region or office using property: Region 3[F]; 
Location: Wheeling, West Virginia. 

Property[A]: The Valley Building; 
Number of buildings and facilities: 1; 
Estimated total square feet[B]: 1,968; 
Owned or leased: Leased; 
Region or office using property: Region 3[F]; 
Location: Wheeling, West Virginia. 

Totals: 39 properties; 
Number of buildings and facilities: 171 buildings and facilities[I]; 
Estimated total square feet[B]: 4,511,261 square feet[B,D]; 
Location: 30 cities. 

Source: GAO analysis of the data from EPA's real property database, 
called the Strategic Leasing and Asset Tracking Enterprise. 

[A] Some laboratory properties have multiple buildings and facilities. 

[B] EPA's database contain three measures of square footage. In almost 
all cases, we report total usable square feet. For buildings and 
facilities where usable square feet were unavailable, we report 
rentable square feet. For buildings and facilities where EPA lacked 
data for both usable and rentable square feet, we used gross square 
feet, when available. 

[C] EPA's database did not have complete information on the buildings 
occupied by the Office of Enforcement and Compliance Assurance 
laboratory. Therefore, the square footage for the hazardous chemical 
storage facility is not included. 

[D] Some of this space is shared with other occupants. EPA's database 
does not indicate what proportion of a property's square footage is 
used by nonlaboratory occupants. 

[E] The Region 4 Science and Ecosystems Support Division Laboratory 
and the Ecosystems Research Division are considered two separate 
properties but they are located adjacent to each other. The properties 
share a perimeter fence and there is a parking lot in between them. 

[F] Regions 3 and 5 have more than one laboratory facility. In 
addition to its laboratory in Chicago, Illinois, Region 5 utilizes the 
Steinmart Plaza property which consists of offices, laboratories, and 
machine shop, among other space. In addition to its laboratory in Fort 
Meade, Maryland, Region 3 has two properties in Wheeling, West 
Virginia. The Wheeling Field Office houses field and office personnel 
and the Valley Building is used for storage. 

[G] This property is operated under a special use agreement with the 
National Aeronautics and Space Administration. 

[H] Two of the buildings at the Edison laboratory, referred to as 
buildings 245 and 246, are warehouses with 390,829 square feet. Agency 
officials said these buildings are unusable, however, they were 
reported to the Federal Real Property Council as active properties. 

[I] This number does not include the agency's mobile laboratories, 
such as the Bold and Lake Guardian ships and the Trace Atmospheric Gas 
Analyzers buses. 

[End of table] 

[End of section] 

Appendix III: Summary of the Planning, Coordination, and Leadership 
Findings and Recommendations of Independent Evaluations and EPA's 
Response: 

Evaluation: 1992 Independent Expert Panel Study[A]; 
Key findings: EPA science is of uneven quality, and the agency's 
policies and regulations are frequently perceived as lacking a strong 
scientific foundation. EPA did not have a coherent science agenda and 
operational plan to guide scientific efforts throughout the agency; 
Key recommendations: EPA should further expand its issue-based 
planning process with a goal of producing a broadly based, rational 
plan to acquire and use the best scientific information that applies 
to science produced throughout the agency. EPA should appoint a 
science advisor to ensure that EPA generates credible scientific 
information; 
EPA response: EPA developed a strategic plan and multiyear research 
planning process for the science performed by the Office of Research 
and Development laboratories to support all of EPA's programs. EPA 
appointed a science advisor in the office of the administrator. 

Evaluation: 1994 MITRE Corp. Laboratory Study[B]; 
Key findings: The number of laboratories and their geographic 
separation from one another and often from their principal customers 
raised concerns about their efficiency and technical operations. Many 
of the laboratory facilities are in need of significant repairs 
requiring substantial financial resources. Because the activities of 
laboratories are highly visible and expensive, it is important that 
they be organized to achieve a high degree of effectiveness in the 
expenditure of public funds; 
Key recommendations: EPA could improve the efficiency and 
effectiveness of its operations, eliminate apparent duplications of 
facilities and equipment, and increase the disciplinary strengths of 
its human resource base by making the following management changes: 
Realign and consolidate the Office of Research and Development 
laboratories. Consolidate laboratories in the Office of Prevention, 
Pesticides and Toxic Substances and the two laboratories under the 
Office of Radiation and Indoor Air. Reduce the number of regional 
office laboratories through consolidation to a few laboratories with a 
national service focus; 
EPA response: EPA implemented a functional, but not physical, 
consolidation of Office of Research and Development laboratories under 
national laboratories to support EPA's research focus on risk 
assessment and risk management. EPA did not consolidate the Office of 
Prevention, Pesticides and Toxic Substances and the two laboratories 
under the Office of Radiation and Indoor Air. EPA maintained the 
decentralized structure of EPA's program and regional laboratories. 

Evaluation: 1995 National Research Council Interim Report[C]; 
Key findings: EPA's science advisor lacked substantial managerial 
authority and generally lacked the means to effectively perform the 
agencywide role envisioned by the 1992 expert panel recommendation; 
Key recommendations: Designate the assistant administrator of the 
Office of Research and Development as EPA's chief scientific and 
technical officer, with responsibility for coordinating and overseeing 
agencywide science activities; 
EPA response: EPA's deputy administrator asked the assistant 
administrator of the Office of Research and Development to coordinate 
the agency's scientific planning and peer-review activities. 

Evaluation: 1997 EPA Office of Inspector General Report[D]; 
Key findings: EPA's regional laboratories lack a shared identity and 
national leader to better coordinate the regional laboratories' 
collective contributions to EPA's science knowledge; 
Key recommendations: Identify the appropriate responsibilities for a 
national leader for its regional laboratories; 
EPA response: EPA designated the director of the Office of Regional 
Operations as the central advocate to represent regional laboratory 
and regional office interests in the formulation of EPA polices and 
decisions. 

Evaluation: 2000 National Research Council Final Report[E]; 
Key findings: EPA's designation of the assistant administrator of the 
Office of Research and Development as coordinator for the agency's 
scientific-planning and peer-review activities had proven to be 
insufficient because the position did not provide the level of 
authority or responsibility for oversight, coordination, and decision 
making and EPA's regulatory offices were generally not required to 
follow the Office of Research and Development's guidance regarding 
scientific activities or science policy. EPA efforts to improve 
science collaboration rely on consensus and voluntary cooperation of 
the agency's regulatory and regional offices. EPA's lack of a top 
science official is a formula for weak scientific performance and poor 
scientific credibility. The assistant administrator of the Office of 
Research and Development could not be reasonably expected to direct 
world-class science at the office and also try to improve science 
practices throughout the rest of the agency; 
Key recommendations: Establish a deputy administrator for science and 
technology with the authority and responsibility to coordinate and 
oversee scientific activities throughout the agency; 
EPA response: In 2002, EPA appointed the Assistant Administrator of 
the Office of Research and Development as science advisor. In 2001, 
Congress considered two bills to establish a deputy administrator of 
science and technology but no legislation was enacted. 

Source: GAO analysis of independent evaluations. 

[A] Environmental Protection Agency, Safeguarding the Future: Credible 
Science, Credible Decisions, The Report of the Expert Panel on the 
Role of Science at EPA, EPA/600/9-91/050 (Washington, D.C., March 
1992). 

[B] MITRE Corporation, Center for Environment, Resources, and Space, 
Assessment of the Scientific and Technical Laboratories and Facilities 
of the U.S. Environmental Protection Agency (McLean, Va., May 1994). 

[C] National Research Council, Interim Report of the Committee on 
Research and Peer Review in EPA (Washington, D.C., National Academies 
Press, 1995). 

[D] Environmental Protection Agency, Office of Inspector General, 
Regional Laboratories (Washington, D.C., Aug. 20, 1997). 

[E] National Research Council, Strengthening Science at the U.S. 
Environmental Protection Agency: Research-Management and Peer Review 
Practices (Washington, D.C., National Academies Press, 2000). 

[End of table] 

[End of section] 

Appendix IV: Comments from the Environmental Protection Agency: 

Note: GAO comments supplementing those in the report text appear at 
the end of this appendix. 

United States Environmental Protection Agency: 
Deputy Administrator: 
Washington, D.C. 20460: 

July 11 2011: 

Mr. David C. Trimble: 
Acting Director:
Natural Resources and the Environment: 
U.S. Government Accountability Office: 
Washington, D.C. 20548: 

Dear Mr. Trimble: 

Thank you for the opportunity to review and respond to the draft 
report prepared by the U.S.Government Accountability Office, titled 
Environmental Protection Agency: To Better Fulfill Its Mission, EPA 
Needs a More Coordinated Approach to Managing its Laboratories. 
[Reference 1] We appreciate the work of the GAO team that developed 
this report and its recommendations, which are intended to improve the 
cohesion and management of the U.S. Environmental Protection Agency's 
laboratory enterprise. 

The agency agrees with GAO findings about the importance of the EPA's 
laboratory enterprise and its scientific contributions to policies and 
decisions that protect human health and the environment: 

1. Scientific research, knowledge and technical information are 
fundamental to the EPA's mission and inform its standard-setting, 
regulatory, compliance and enforcement functions. The agency's 
scientific performance is particularly important as complex 
environmental issues emerge and evolve, and controversy continues to 
surround many of the agency's areas of responsibility. The
EPA works with many providers of scientific information to accomplish 
its mission, including international and domestic academic 
institutions, state and local agencies, industry and other
federal scientific agencies. But unlike other primarily science-
focused federal agencies, such as the National Institutes of Health or 
the National Science Foundation, the EPA's scientific research, 
technical support and analytical services underpin the and regulations 
the policies agency implements.[Reference 2] The essential connection 
between the EPA's laboratory science and regulatory decision-making 
illustrates why the agency sustains intramural laboratories. 

2. The complexity of the EPA's mission, the rapid pace of scientific 
and technological advances and shifts in policy require that the 
agency's laboratory enterprise be responsive to change and equipped to 
meet the scientific challenges ahead.[Reference 2] 

3. Current efforts to reduce the federal budget deficit — including 
significant proposed cuts to the budgets of most federal departments, 
the EPA and other agencies — require all federal agencies to use their 
scientific and laboratory resources more effectively. For the EPA, 
more effective use of its laboratory enterprise will help ensure that 
its scientific activities respond to the agency's highest-priority 
needs.[Reference 2] 

The agency recognizes that findings and recommendations in the draft 
GAO report are germane to governmentwide challenges to managing the 
portfolio of federal facilities.[References 3-5] One major challenge 
we discussed with the GAO team is the high cost of maintaining the 
portfolio of aging federal facilities. Recent policy mandates from 
Congress and the Executive Office of the President are designed in 
part to reduce the energy, environmental and materials impacts.of 
current and future federal facilities. These policy mandates include 
(a) legislation such as the Energy Policy Act of 2005 (Public Law 109-
58) and the Energy Independence and Security Act of 2007 (Public Law 
110-140) and (b) Executive Orders 13423 and 13514. Executive Order 
13423 requires more widespread use of environmental management systems 
as the framework within which to manage and continually improve 
sustainable facility practices. Executive Order 13514 requires that 
each federal agency prepare a strategic sustainability plan to guide 
its efforts to green its facilities to improve their effectiveness and 
efficiency. The costs to comply with these policies affect laboratory 
facilities significantly. This is because laboratory facilities 
consume more energy and emit more greenhouse gases per square foot of 
floor than type facility from five times to 10 times the than
space virtually any other of — amount of energy office buildings with 
an equivalent footprint. Despite their costs, these policies are 
important for our nation's strategy to achieve energy independence, 
improve the environment and reduce consumption of natural resources. 
For example, buildings in the United States account for 12 percent of 
water consumption, 40 percent of total carbon-dioxide emissions, 68 
percent of electricity use, 40 percent of raw materials use and 30 
percent of waste generated.[Reference 6] These environmental, energy 
and resource impacts serve as an important reminder of why a 
commitment to energy-efficient and sustainable buildings is important 
to every community in which EPA employees and facilities are located. 

These building-related environmental, energy and resource impacts help 
explain why the EPA has a strong leadership commitment to managing its 
facilities in an efficient and effective manner. One example of the 
EPA's leadership commitment is the Labs 21R program, co-sponsored by 
the EPA and the U.S. Department of Energy. Labs 21R, named for 
laboratories for the 21st century, is a voluntary partnership program 
dedicated to improving the environmental and energy performance of 
laboratories across the U.S.7[Reference 7] Labs21R is dedicated to the 
pursuit of sustainable, high-performance and low-energy laboratories 
that will: 

* minimize overall environmental impacts;
* protect occupant safety;
* optimize whole building efficiency on a life-cycle basis; and
* establish goals, track performance and share results for continuous 
improvement. 

GAO Recommendations: 

The GAO report recommends that the EPA Administrator take seven 
actions to improve the cohesion and management of the agency's 
laboratory enterprise.[Reference 8] Each GAO recommendation is 
described below and is followed by an EPA response. 

GAO Recommendation 1: The EPA Administrator should develop an 
overarching issue-based planning process that reflects the collective 
goals, objectives and priorities of the laboratories' scientific 
activities. 

EPA Response: The EPA agrees with the GAO that more can be done to 
develop a planning process that better reflects the collective goals, 
objectives, and priorities of the scientific activities across its 
laboratory enterprise. 

In its draft report, the GAO describes an "issue-based planning 
process" in the context of recommendations — from two different 
independent evaluations[References 9,10] — about systematic planning, 
coordination and priority-setting. The GAO uses the term "overarching" 
to refer to the integration of laboratory planning, coordination and 
priority-setting across the agency's laboratory enterprise to ensure 
that the laboratories contribute to the EPA's highest priority needs 
for laboratory science. It is important to note that the issue-based 
planning process mentioned in the GAO report has evolved since the 
1990s in response to governmentwide requirements for outcome-oriented 
planning, performance and accountability — first in the Government 
Performance and Results Act of 1993 and recently in the GPRA
Modernization Act of 2010. 

Today, each component of the EPA's laboratory enterprise plans and 
manages its science activities in the context of its particular 
program or region. Scientific activities contribute to specific 
scientific issues and mission-relevant outcomes linked to a particular 
GPRA goal and objective. Frequently, outcome-oriented laboratory 
contributions are linked also to specific clients within the EPA or, 
in some cases, to a specific client in stakeholder organizations such 
as state, local or tribal agencies. In most respects, the
EPA's management of the scientific activities of its laboratory 
enterprise for GPRA results meets the objectives identified in this 
GAO recommendation. [See comment 1] 

The agency acknowledges that it does not manage its scientific 
activities under GPRA with a single overarching system that integrates 
planning, priority-setting and coordination across the laboratory 
enterprise. The EPA will consult with GAO, Congress and the Office of 
Management and Budget to determine the best approach to develop an 
overarching planning process and system that "reflects the collective 
goals, objectives and priorities of the laboratories' scientific 
activities" described in this GAO recommendation. 

GAO Recommendation 2: The EPA Administrator should establish a top-
level science official with the authority and responsibility to 
coordinate, oversee, and make management decisions regarding major 
scientific activities throughout the agency, including the work of all 
program, regional, and research laboratories. 

EPA Response: The EPA agrees with the underlying principle and 
objectives of this GAO recommendation. As GAO mentions in its draft 
report, Congress considered two bills in 2001 to establish a deputy 
administrator of science and technology at the EPA, and neither bill 
was enacted.[Reference 11] After its 2001 discussion with Congress, 
the EPA took several steps to strengthen significantly its executive-
level science management structure. For example, the EPA Administrator 
created the position of science advisor,[Footnote 12] the Office of 
the Science Advisor, a Science and Technology Policy Council and the 
Office of Science Policy to serve as mechanisms for addressing 
overarching science policy issues that span regional, research and 
program boundaries. These changes have strengthened the EPA's 
management and decision making for science priorities, science science 
advice and risk policy, assessment. 

In response to the GAO recommendation, the EPA will expand the 
authority and responsibility of the science advisor to coordinate, 
oversee and make recommendations to the Administrator regarding major 
scientific activities throughout the agency, including the work of all 
program, regional and Office of Research and Development laboratories. 
[See comment 2] 

In considering the best structure to accomplish the objectives in this 
GAO recommendation, the EPA recognizes that the management of its 
laboratory enterprise must help the enterprise adapt to significant 
external pressures. These pressures create a demand for: 

* solutions to complex, interdependent and dynamic systems problems 
for many EPA clients across the nation; 

* interdependence and a high level of knowledge sharing with many 
clients, in many regions, at many geographic and temporal scales and 
in many communities across the nation; 

* sharing resources, including shared facilities that are more 
efficient and sustainable, shared expertise and human resources and 
shared equipment and supplies; and; 

* responding proactively to declining financial resources and to 
increasing mandates for energy-efficient and sustainable facilities. 

GAO Recommendation 3: The EPA Administrator should improve physical 
infrastructure and real property planning and investment decisions by 
managing individual laboratory facilities as part of an interrelated 
portfolio of facilities. 

EPA Response: The EPA agrees with the GAO that more can be done and 
believes that the strength of its master planning process overall has 
kept the agency's 35 laboratories and 68 laboratory support buildings 
in good condition. During the next three to five years, depending on 
funding, the agency plans to upgrade and streamline the master 
planning process, update the plans as required, reinforce the current 
master planning portfolio perspective and strengthen the ties between 
the current annual and five-year Buildings and Facilities call letter 
process, which is described below, and the master plans. 

As the GAO points out, the EPA's internal real property asset-
management plan states that facility master plans are supposed to be 
updated every five years to reflect changes in facility condition and 
mission. As part of our plan to upgrade the master planning process, 
the EPA intends to revise this guidance to ensure that the master 
plans are updated as required to reflect mission or condition changes 
versus a time line, even if this occurs on a more frequent basis than 
the current five-year guidance. Again, as the GAO points out, almost 
50 percent of the EPA's master plans have been updated to reflect 
changing mission or infrastructure needs. Some examples are the 
Cincinnati laboratory five-phase infrastructure replacement project, 
based on a 2003 master plan, which has been carried out over eight 
fiscal years; the Research Triangle Park laboratory consolidation; and 
the Region 10 laboratory modernization based on a 1998 master plan and 
implemented between FY2003 and FY2011, all of which are multi-year, 
multi-million-dollar master planning projects. 

The agency notes that the draft GAO report does not take into account 
the agency's annual Buildings and Facilities call letter process, 
which collects and prioritizes all project requests agencywide as a
portfolio. In this process, each project is prioritized by the 
programs and regions to ensure that it is aligned with the mission of 
that program or region and meets the agency's priorities and strategic 
plans. The projects are first reviewed to balance the mission, 
programmatic and legislative requirements that the EPA must weigh when 
allocating its limited resources. The projects are then evaluated 
against agency and industry standards for health and safety, 
environmental compliance, infrastructure requirements such as green-
building requirements and energy-reduction goals. The results of this 
process form an annual capital spending plan, which effectively 
allocates limited resources on a portfolio and agencywide basis. [See 
comment 3] 

However, projects identified through the master planning process and 
implemented through the Building and Facilities call letter process, 
as described previously, are taking six years to 10 years longer to 
complete than the five years originally anticipated. Obviously, the 
master plan projects can only be completed as funding becomes 
available; this forms the basis of the EPA's position that the master 
plans need to be updated as required, not on any set time line. 

GAO Recommendation 4: The EPA Administrator should improve physical 
infrastructure and real property planning and investment decisions by 
ensuring that master plans are up-to-date and that analysis of the use 
of space is based on objective benchmarks. 

EPA Response: The EPA agrees with the GAO that the agency's master 
plans must be up-to-date and include effective benchmarks and metrics. 
As noted above, the GAO points out that the EPA's real property asset 
management plan states that facility master plans are supposed to be 
updated every five years to reflect changes in facility condition and 
mission. Again, as stated previously, the agency plans to revise this 
guidance to ensure that the master plans are updated as required to 
reflect mission or condition changes versus a time line, even if this 
happens on a more frequent basis than the current five-year guidance. 

The agency again notes that projects identified through the master 
planning process and implemented through the Buildings and Facilities 
call letter process are taking six years to 10 years longer to 
complete than the five years originally anticipated. Obviously, the 
master plan projects can only be completed as funding becomes 
available; this forms the basis of the EPA's position that the master 
plans need to be updated as required, not on any set time line. 

The space conditions and utilization metrics identified in the master 
plans are updated annually by the facility managers as part of the 
Federal Real Property Council process and validated through audits. 
[See comment 4] Objective benchmarks for laboratory usage are employed 
when the laboratories have sufficient size to establish a valid 
baseline; most of the EPA's laboratories, however, are small and have 
specific functional requirements for each lab module. The functional 
requirement establishes the need for the space allocation rather than 
the population of the laboratory. [See comment 5] 

As the EPA continues to upgrade its master planning process, the 
agency will continue to work with other federal agencies and industry 
associations to define relevant laboratory benchmarks. Once benchmarks 
are updated and proven valid, the agency will include the benchmarks 
in its master plans. 

GAO Recommendation 5: The EPA Administrator should improve physical 
infrastructure and real property planning and investment decisions by 
improving the completeness and reliability of operating-cost and other 
data needed to manage its real property and report to external parties. 

EPA Response: The EPA agrees with the GAO that the agency's operating 
metrics should be updated. As stated above, as the EPA continues to 
refine the master planning process, the agency will work internally to 
upgrade and validate its internal operating costs and other metrics. 
The EPA agrees that reliable data are needed for effective management 
of its laboratory enterprise. Beginning in FY 2011, the agency added 
coding to track operating costs at program-funded laboratory 
facilities not previously tracked. The agency will review options for 
improving data reliability and completeness for the remaining labs 
within its laboratory enterprise. [See comment 6] 

However, as a rule, the agency already uses benchmarks for the square 
footage of a typical laboratory module. The GAO states that the EPA 
does not use benchmarking to determine appropriate space allocations 
for laboratory operations or cost. In fact, the agency uses industry 
averages, national and comparable agency references to determine 
laboratory space and operating costs. As guidelines noted throughout 
the audit process, the EPA's laboratory space allocation process 
depends upon the nature of the activities being performed and, 
consequently, is not always suited to a benchmark. That said, the 
agency will continue to revise and refine its benchmarks. [See comment 
7] 

GAO Recommendation 6: The EPA Administrator should develop a 
comprehensive work-force planning process for all laboratories that is 
based on reliable work-force data and reflects current and future 
agency needs in the overall number of federal and contract employees, 
skills and deployment across all laboratory facilities. 

EPA Response: The EPA agrees with this recommendation and recognizes 
that opportunities exist to improve work-force-planning procedures for 
its laboratory enterprise. The EPA will develop a comprehensive work-
force-planning process for its laboratory enterprise as part of a 
broader agency work-force-planning process. The comprehensive work-
force-planning process for EPA laboratories will be based on 
information about: 

* the EPA's priority needs for mission relevant laboratory science; 

* laboratory functions and systems required to meet these needs and to 
transform laboratory outputs into results that contribute to agency 
decisions; and; 

* work force skills and disciplines required to sustain each 
laboratory and the agency's portfolio of laboratories, including 
capability and capacity, across the scope of the agency's functions, 
systems, programs and facility lifetime. 

Collectively, these three components define a framework for 
comprehensive laboratory work-force planning.[Reference 13] 

The MITRE study of the EPA's laboratory enterprise underscored an 
important aspect of agency laboratories: "It is important to emphasize 
that different laboratories have different purposes; some laboratories 
concentrate on performing analytical work, while others conduct 
fundamental or applied research."[Reference 14] The MITRE study 
recognized that each laboratory organization has distinct mission-
relevant functions, systems and contributions to agency decisions. 
Thus, in general, comprehensive work-force planning should not be 
combined across laboratory organizations or centralized as in a single-
agency organization. 

Beginning in FY11, the EPA plans to strengthen its existing strategic 
work-force-planning process by integrating work-force planning with 
its annual budget process. The agency will annually assess if its work 
force has the skills to meet the nation's environmental priorities 
today and in the future. Each regional office and headquarters program 
office will consider the EPA's Strategic Plan and the Administrator's 
priorities to establish their optimal work force based on needed 
occupations. By using planned FTE resource levels for FY12 and 
proposed resource levels for FY 2013-2015, each office, including 
laboratories, can better identify potential skill and work force gaps 
in developing plans and strategies for obtaining the resources with 
the proper skills. Overall, these efforts will strengthen succession-
planning efforts, lead toward improved strategic recruitment and 
outreach efforts and ensure office position management, staffing and 
hiring plans are aligned to mission success. 

GAO Recommendation 7: If the EPA Administrator determines that another 
independent study of EPA laboratories is needed, then the agency 
should include, within the charge questions for this study, alternate 
approaches for organizing the laboratory work force and 
infrastructure. These alternate approaches should include options for 
sharing and consolidation. 

EPA Response: President Barack Obama has requested funds to begin a 
long-term study of the EPA's laboratory enterprise in FY12. If funded, 
this long-term study will be conducted by an independent expert 
committee of the National Academy of Sciences. When the NAS committee 
prepares its design for the long-term study, the EPA will request that 
the NAS consider information in this GAO report and alternate 
approaches for organizing the work force and infrastructure of the 
EPA's laboratory enterprise. 

Both President Obama and EPA Administrator Lisa P. Jackson have 
emphasized that science must be the backbone for EPA programs and 
decisions. As the GAO has indicated in its draft report, knowledge and 
technical information from the agency's laboratories, scientists and 
partners are more important than ever to inform decisions that protect 
human health and our nation's environment. Threats to the environment 
and human health, such as the 2010 oil spill in the Gulf of Mexico, 
further increase the demand for laboratory science, technical services 
and research. Simultaneously, a number of external trends and 
pressures are creating challenges to the capability, capacity and 
effectiveness of EPA laboratory facilities and to the supply of 
laboratory science to meet the agency's highest-priority needs and to 
address emerging, complex environmental challenges. 

GAO Conclusions, Technical Information And Evidence: 

Laboratories and their facilities are among the most complex built 
systems in the federal government. To improve the accuracy and clarity 
of its draft report on the EPA's laboratory enterprise, the GAO
requested that the EPA identify any technical information, evidence or 
conclusions in its draft report, which may require correction or 
editing. 

The results of this EPA review are presented in two enclosures. The 
corrections described in the first enclosure improve the general 
accuracy of the report and several of its conclusions. The corrections 
presented in the second enclosure improve the accuracy of information 
about EPA laboratory facilities presented in Appendix III, Table 2. 

In closing, I want to thank you again for the opportunity to review 
and respond to the draft GAO report. 

Sincerely, 

Signed by: 

Bob Perciasepe: 

Enclosures: 

cc: Lisa P. Jackson: 
Paul Anastas: 
Barbara Bennett: 
Diane Thompson: 
Arvin Gamma: 

References: 

[1] "Environmental Protection Agency: To better Fulfill Its Mission, 
EPA Needs a More Coordinated Approach to Managing its Laboratories" 
(GAO, 2011). Draft Report Number GAO-11347. 

[2] Ibid., pages 1, 26. 

[3] Investments in Federal Facilities: Asset Management Strategies for 
the 21st Century (NAS, 2004). 

[4] Stewardship of Federal Facilities: A Proactive Strategy for 
Managing the Nation's Public Assets (NAS, 1998). 

[5] Federal Real Property: Progress Made toward Addressing Problems, 
but Underlying Obstacles Continue to Hamper Reform. (GAO, 2007). 
Report No. GAO-07-349. 

[6] Federal Research and Development Agenda for Net-Zero Energy, High-
Performance Green Buildings. National Science and Technology Council 
Committee on Technology, October 2008, page 13. 

[7] Laboratories for the 21st Century home page [hyperlink, 
http://www.labs21century.gov/] last accessed July 3, 2011. 

[8] GAO, 2011. Op.cit., pages 28-29. 

[9] Safeguarding the Future: Credible Science, Credible Decisions. The 
Report of the Expert Panel on the Role of Science at EPA. U.S. EPA, 
EPA/600/9-91/050, Washington, D.C., March 1992. 

[10] Assessment of the Scientific and Technical Laboratories and 
Facilities of the U.S. Environmental Protection Agency." The MITRE 
Corporation, Center for Environment, Resources, and Space. McLean,
Virginia: May 1994 (Revised). Report No. MTR 94W0000082V1. Pages 4-29, 
4-3, 6-2. 

[11] GAO, 2011. Op.cit. Appendix II, page 35. 

[12] U.S. EPA Science Advisor home page [hyperlink, 
http://www.epa.gov/osa/] last accessed July 3, 2011. 

[13] Commonsense Actions and Best Practices that Improve Laboratory 
Efficiency and Effectiveness. U.S. EPA, Washington, D C , October 
2008. Report Number EPA 600/R-03/069 available from [hyperlink, 
htp://www.epa.gov]. Exhibit 4, page 10. 

[14] The MITRE Corporation, May 1994 (Revised), op.cit., page 1-4. 

The following are GAO's comments to EPA's letter dated July 11, 2011. 

GAO's Comments: 

1. We believe that EPA's scientific activities remain fragmented and 
largely uncoordinated--reflecting the independent organizational and 
management structure of EPA's 15 senior officials charged with 
planning and managing the scientific work performed at each of EPA's 
laboratories. In light of current efforts to reduce the federal budget 
deficit, which include significant proposed cuts in the budgets of 
most departments and agencies, including EPA, the agency will need to 
more effectively use its scientific and laboratory resources across 
the agency to ensure that the agency is best positioned to fulfill the 
critical scientific work for its core mission. However, EPA's ability 
to respond to this challenge may be hampered by the lack of an 
overarching issue-based planning process that integrates and 
coordinates scientific efforts throughout the agency and reflects the 
collective goals, objectives, and priorities of the laboratories. 

2. We believe that improvement in scientific leadership of EPA's 
research and laboratory operations will be driven by the level of 
authority and responsibility provided to the chosen top-level science 
official, including management of resources. However, assigning these 
responsibilities to the science advisor, who is also the head of the 
Office of Research and Development (ORD), may introduce additional 
challenges for EPA. We note that in 2000, the National Research 
Council reported that it had previously "underestimated the level of 
authority needed to achieve the necessary degree of cooperation and 
coordination of scientific activities and policy in the regulatory and 
regional offices." The Council also concluded that "no single 
individual could reasonably be expected to direct a world-class 
research program in ORD while also trying to improve scientific 
practices and performance throughout the rest of the agency," stating 
that "these jobs are inherently different." Lastly, the Council 
cautioned that "assigning agency-wide scientific authority to the 
assistant administrator for ORD might produce a conflict of 
responsibilities, because many decisions about science in the 
regulatory programs could affect ORD's budget or favor ORD's research 
over research done elsewhere." 

3. In 2004 the National Research Council recommended that federal 
departments and agencies make investment and management decisions 
about individual projects in relation to their entire portfolio of 
facilities. Based on our analysis of EPA's master planning process, 
including the agency's annual "call letter process," we found that EPA 
manages its facilities on a site-by-site basis and does not evaluate 
each site in the context of all of the agency's real property 
holdings. As a result, EPA cannot be assured that it is investing its 
capital improvement funds most appropriately or identifying possible 
cost-savings opportunities. 

4. We assessed the reliability of the laboratory property data 
maintained in EPA's facility management and real property tracking 
system. We determined that descriptive information on EPA's inventory 
of laboratory buildings and facilities, such as property descriptions 
and estimated square footage, was sufficiently reliable for our 
purposes. However, we found that other data contained in the database, 
such as operating costs and condition assessments, were not 
sufficiently reliable for the purposes of our review, and we reported 
these limitations as appropriate. Specifically, we found that the 
database lacked controls necessary for assuring the reliability of 
data, such as operating costs or condition assessments that are 
manually entered by individual facility managers and subsequently used 
by EPA to report to external parties, such as the Office of Management 
and Budget and the Federal Real Property Council. 

5. We continue to believe that EPA could develop objective benchmarks 
for its unique laboratory requirements. 

6. EPA does not have reliable operating cost data for its laboratory 
enterprise because the agency's financial management system does not 
track operating costs in sufficient detail to break out information 
for individual laboratories or for the laboratory enterprise as a 
whole. Reliable operating cost data are important in determining 
whether a laboratory facility is operating efficiently, a 
determination that should inform both capital investment and property 
disposal decisions. Operating cost data are also required by the 
Federal Real Property Council. 

7. EPA lacks accurate data on space needs and usage because many 
facility master plans containing space utilization analyses are out of 
date. EPA also does not use public and commercial benchmarks to 
calculate usage rates for its laboratories even though the Federal 
Real Property Council identifies the use of such benchmarks as one of 
its guiding principles. Instead, EPA measures laboratory usage on the 
basis of interviews with local laboratory officials. According to EPA 
officials, they do not use benchmarks because the work of the 
laboratories varies. Also see comment 5. 

8. EPA provided technical comments and clarifications, which we have 
incorporated into the report as appropriate. 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

David C. Trimble, (202) 512-3841 or trimbled@gao.gov: 

Staff Acknowledgments: 

In addition to the contact above, Ed Kratzer, Assistant Director; 
Diane LoFaro, Assistant Director; Ellen W. Chu; John H. Edwards; 
Angela Miles; Daniel Semick; John C. Smith; Kwame Som-Pimpong; Tim 
Persons; Cheryl Peterson; Vasiliki Theodoropoulos; and Greg Wilmoth 
also made key contributions to this report. 

[End of section] 

Footnotes: 

[1] Reorganization Plan No. 3 of 1970, 35 Fed. Reg. 15623 (Dec. 2, 
1970) (5 U.S.C. Appendix 1). 

[2] The National Research Council is the principal operating agency of 
both the National Academy of Sciences and the National Academy of 
Engineering. 

[3] Environmental Protection Agency, Commonsense Actions and Best 
Practices That Improve Laboratory Efficiency and Effectiveness, EPA 
600/R-03/069 (Washington, D.C., October 2008). 

[4] The Board of Scientific Counselors is a federal advisory committee 
created by EPA to provide advice and recommendations on all aspects of 
technical and management issues of the Office of Research and 
Development. The Science Advisory Board is a federal advisory 
committee established by Congress in 1978 to provide independent 
advice to EPA's administrator on the scientific and technical aspects 
of environmental issues. 

[5] Environmental Protection Agency, EPA Regional Facilities: A 
Historical Perspective on Siting (Washington, D.C., March 1993). 

[6] GAO, Federal Real Property: Progress Made Toward Addressing 
Problems, but Underlying Obstacles Continue to Hamper Reform, 
[hyperlink, http://www.gao.gov/products/GAO-07-349] (Washington, D.C.: 
Apr. 13, 2007). 

[7] OMB has yet to develop an action plan. 

[8] EPA also maintains mobile laboratories housed in buses, such as 
the Trace Atmospheric Gas Analyzers buses, and ships, such as the Bold 
and Lake Guardian that are water monitoring vessels. 

[9] The Office of Water does not operate its own laboratory. 

[10] Environmental Protection Agency, Safeguarding the Future: 
Credible Science, Credible Decisions, The Report of the Expert Panel 
on the Role of Science at EPA, EPA/600/9-91/050 (Washington, D.C., 
March 1992). 

[11] EPA Administrator request for Science Advisory Board Study, 
October 20, 2008. 

[12] MITRE Corporation, Center for Environment, Resources, and Space, 
Assessment of the Scientific and Technical Laboratories and Facilities 
of the U.S. Environmental Protection Agency (McLean, Va., May 1994). 

[13] S. Rep. No. 103-137 (1993). 

[14] Now known as the Office of Chemical Safety and Pollution 
Prevention. 

[15] Environmental Protection Agency, Research, Development, and 
Technical Services at EPA: A New Beginning, Report to the 
Administrator, EPA/600/R-94/122 (Washington, D.C., July 1994). 

[16] National Research Council, Interim Report of the Committee on 
Research and Peer Review in EPA (Washington, D.C., National Academies 
Press, 1995); Environmental Protection Agency, Office of Inspector 
General, Regional Laboratories (Washington, D.C., Aug. 20, 1997); and 
National Research Council, Strengthening Science at the U.S. 
Environmental Protection Agency: Research-Management and Peer Review 
Practices (Washington, D.C., National Academies Press, 2000). 

[17] The Science Policy Council was reconsituted as the Science and 
Technology Policy Council in July 2010 with the goal of integrating 
EPA policies that guide agency decision makers in their use of 
scientific and technical information. The council works to implement 
and ensure the success of selected initiatives recommended by external 
advisory bodies such as the National Research Council and the EPA's 
Science Advisory Board, as well as others such as Congress, industry 
and environmental groups, and agency staff. EPA's science advisor 
chairs the council, which comprises senior managers from EPA's 
programs and regions and is supported by ad hoc working groups formed 
to study specific topics. 

[18] GAO, High-Risk Series: Federal Real Property, [hyperlink, 
http://www.gao.gov/products/GAO-03-122] (Washington, D.C.: January 
2003). 

[19] National Research Council, Investments in Federal Facilities: 
Asset Management Strategies for the 21st Century (Washington, D.C., 
National Academies Press, 2004). 

[20] Master plans are created for owned properties only. We found 
there were no master plans for two laboratory properties located in 
Research Triangle Park, N.C., and Fort Meade, Md. We also found that 9 
of the 11 outdated master plans were over 10 years old. 

[21] National Academy of Public Administration, A Review, Evaluation, 
and Critique of a Study of EPA Laboratories by the MITRE Corporation 
and Additional Commentary on EPA Science and Technology Programs 
(Washington, D.C., May 1994), 10. 

[22] Stakeholders include members of Congress, OMB, the real property- 
holding agencies, state and local governments, business interests in 
the communities where the real property assets are located, private 
sector construction and leasing firms, historic preservation 
organizations, various advocacy groups, and the public in general, 
which often views the facilities as the physical face of the federal 
government in their communities. [hyperlink, 
http://www.gao.gov/products/GAO-07-349], 5. 

[23] Environmental Protection Agency, Commonsense Actions, 2. 
Contributors included officials from the Office of Administration and 
Resource Management, Office of Air and Radiation, Office of Research 
and Development, Office of Chemical Safety and Pollution Prevention, 
and Regions 1, 3, 5, 6, 7, and 9. 

[24] Federal Real Property Asset Management, Exec. Order No. 13327, 69 
Fed. Reg. 5897 (Feb. 4, 2004). 

[25] Presidential Memorandum, Disposing of Unneeded Federal Real 
Estate, 75 Fed. Reg. 33987 (June 16, 2010). 

[26] Environmental Protection Agency, Real Property Cost Savings and 
Innovation Plan (Washington, D.C., July 23, 2010). 

[27] Edit checks and controls require a review of at least a sample of 
data entries to ensure that key fields are accurate, nonduplicative, 
and consistent. For example, the date an injury claim was filed should 
precede the date of adjudication. 

[28] The General Services Administration is responsible for reporting 
property it leases for EPA to the Federal Real Property Council. 

[29] An FTE consists of one or more employed individuals who 
collectively complete 2,080 work hours in a given year. Therefore, 
both one full-time employee and two half-time employees equal one FTE. 

[30] GAO, 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.: Mar. 31, 2010). 

[31] This office is responsible for managing a database used by EPA to 
provide the Office of Personnel Management with information on all EPA 
personnel. 

[32] EPA staff had to create a list of laboratory codes based on their 
personal knowledge to respond to our request. 

[33] GAO, 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); Human Capital: Key Principles for Effective Strategic Workforce 
Planning, [hyperlink, http://www.gao.gov/products/GAO-04-39] 
(Washington, D.C.: Dec. 11, 2003); 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); 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); Environmental Protection Agency: Major Management Challenges, 
[hyperlink, http://www.gao.gov/products/GAO-09-434] (Washington, D.C.: 
Mar. 4, 2009). 

[End of section] 

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