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					                                                                                                             DRAFT
                                             Assessment of Measures Review Initiative Results for Goal 1
NPM                 Cell entries below are hypothetical examples
        Sub- Note: FY 07 ACS Commitment Code & Text                           Regions &      Region or State Explanation for         NPM response, new code, and New Text                          NPM Rationale
      objective                                                                States &            Recommendation
                                                                             recommend
                                                                                 ation

                                                                                                                                    Modify
                                                                                                                                    Work with OTAQ to implement the National Clean Diesel
               OTAQ 01 - Regions work with OTAQ to implement the
                                                                                                                                    Campaign which includes voluntary emissions control
               National Clean Diesel Campaign which includes voluntary
                                                                                                                                    programs for existing heavy duty diesel engines and
               emissions control programs for existing heavy duty diesel                  * Joint NPM/ region negotiation process                                                           Following-up to identify
OAR   1.1.                                                                                                                          school buses. This includes administration and
               engines and school buses. This includes administration and                                                                                                                   NPM/Lead Region rationale
                                                                                                                                    implementation of the Diesel Emission Reduction grant
               implementation of the Diesel Emission Reduction grant
                                                                                                                                    program and confirmation that the Regions have
               program.
                                                                                                                                    entered the information regarding these grants (federal
                                                                                                                                    $) into the National Clean Diesel Database.

                                                                                                                                    Modify
               OTAQ 03 - Regions review conformity determinations for
                                                                                                                                    Make attainment determination by 12/31/07 for             Following-up to identify
OAR   1.1.     nonattainment and maintenance areas for transportation                     * Joint NPM/ region negotiation process
                                                                                                                                    remaining EAC areas with designation deferrals and        NPM/Lead Region rationale
               related criteria pollutants (e.g., ozone, CO, PM2.5, PM10).
                                                                                                                                    take required action by 4/15/2008.
               OAQPS M01 - HQ monitors for backlog of unresolved                                                                    Modify
               critical review records and flags each quarter for Regional                                                          Identify and resolve completeness and timeliness issues Following-up to identify
OAR   1.1.1                                                                               * Joint NPM/ region negotiation process
               Office resolution. .                                                                                                 with regard to quarterly data submission by monitoring  NPM/Lead Region rationale
                                                                                                                                    agencies.
               OAQPS M02 - HQ coordinates with Regions to ensure
                                                                                                                                    Modify
               adequate and independent QA of NAAQS monitoring sites.                                                                                                                         Following-up to identify
OAR   1.1.1                                                                               * Joint NPM/ region negotiation process   Review QA programs and ensure compatibility of air
                                                                                                                                                                                              NPM/Lead Region rationale
                                                                                                                                    toxics measurements across 22 NATTS.

               OAQPS M04 - HQ issue network design guidance for the
               revised 24-hour PM2.5 NAAQS and the PM10-2.5 NAAQS.                                                                                                                            Following-up to identify
OAR   1.1.1                                                                               * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                              NPM/Lead Region rationale


               OAQPS M06 - Regions evaluate all state/local Primary
                                                                                                                                    Modify
               Quality Assurance Organizations' annual data certification                                                                                                                     Following-up to identify
OAR   1.1.1                                                                               * Joint NPM/ region negotiation process   Evaluate submitters‟ annual data certification requests
               requests and documentation for CY 2006 and forward to                                                                                                                          NPM/Lead Region rationale
                                                                                                                                    and documentation and forward to HQ when adequate.
               HQ when complete and adequate in the view of the RO.

               OAQPS M07 - Regions perform Technical Systems Audits
                                                                                                                                    Keep                                                      Following-up to identify
OAR   1.1.1    on 1/3 of state/local Primary Quality Assurance                            * Joint NPM/ region negotiation process
                                                                                                                                                                                              NPM/Lead Region rationale
               Organizations.

               OAQPS M08 - Regions review all requests for changes in                                                               Keep                                                      Following-up to identify
OAR   1.1.1                                                                               * Joint NPM/ region negotiation process
               State monitoring plans and act on requests within 120 days.                                                                                                                    NPM/Lead Region rationale

               OAQPS M09 - Regions ensure all state/local Primary
               Quality Assurance Organizations' quality management
                                                                                                                                                                                              Following-up to identify
OAR   1.1.1    plans (QMPs) and QAPPs have been approved and reflect                      * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                              NPM/Lead Region rationale
               the current network.




                                                                                                                Page 1
                                                                                                            DRAFT
                                             Assessment of Measures Review Initiative Results for Goal 1
NPM                 Cell entries below are hypothetical examples
        Sub- Note: FY 07 ACS Commitment Code & Text                          Regions &      Region or State Explanation for             NPM response, new code, and New Text          NPM Rationale
      objective                                                               States &            Recommendation
                                                                            recommend
                                                                                ation

               OAQPS M10 - Regions work with S/L/Ts to implement the
               National Monitoring Strategy and revised monitoring rules,
               including conducting workshops (or equivalent training
                                                                                                                                                                               Following-up to identify
OAR   1.1.1    process) to assist S/L/Ts in understanding changes in                     * Joint NPM/ region negotiation process      Delete
                                                                                                                                                                               NPM/Lead Region rationale
               monitoring rule and strategy, conducting network
               assessments, implementing the quality system, and
               developing plans for change. Value in cell is yes/no


               OAQPS M11 - All State/local Primary quality assurance
                                                                                         NY- Report PM 10 data using local conditions.                                         Still collected though a different
               organizations submit NAAQS pollutant data, PAMS, and
                                                                            NY           Using standard conditions does not allow for                                          system. See NPM response in
OAR   1.1.1    QA data to AQS directly or indirectly through another                                                                   Delete
                                                                            M            easy comparison to other PM monitoring                                                reporting burden reduction
               organization according to schedule in 40 CFR part 58.
                                                                                         data.                                                                                 summary

               OAQPS M12 - States submit annual network report
               required by 40 CFR 58.20 by July 1 unless another                                                                                                               Following-up to identify
OAR   1.1.1                                                                              * Joint NPM/ region negotiation process      Delete
               schedule has been approved.                                                                                                                                     NPM/Lead Region rationale

               OAQPS M13 - Ensure adequate, independent QA audits of
               state/local NAAQS monitors or participate in NPAP and                                                                                                           Following-up to identify
OAR   1.1.1                                                                              * Joint NPM/ region negotiation process      Delete
               PEP QA programs.                                                                                                                                                NPM/Lead Region rationale


               OAQPS N001 - Improve O3 concentrations. Reduce the
                                                                                                                                                                               Following-up to identify
OAR   1.1.1    population-weighted ambient concentrations of ozone in all                * Joint NPM/ region negotiation process      Delete
                                                                                                                                                                               NPM/Lead Region rationale
               monitored counties from the 2003 baseline.

               OAQPS N002 - Improve PM2.5 concentrations. Reduce the
                                                                                                                                                                               Following-up to identify
OAR   1.1.1    population-weighted ambient concentrations of PM2.5 in all                * Joint NPM/ region negotiation process      Delete
                                                                                                                                                                               NPM/Lead Region rationale
               monitored counties from 2003 baseline.

               OAQPS N003 - Reduce AQI days over 100, weighted by                                                                                                              Following-up to identify
OAR   1.1.1                                                                              * Joint NPM/ region negotiation process      Delete
               population and AQI value.                                                                                                                                       NPM/Lead Region rationale
               OAQPS N004 - Reduce O3 exceedances. Reduce average
               number of days during the ozone season that the ozone                                                                                                           Following-up to identify
OAR   1.1.1                                                                              * Joint NPM/ region negotiation process      Delete
               standard is exceeded in baseline non-attainment areas,                                                                                                          NPM/Lead Region rationale
               weighted by population.
               OAQPS N01 - HQ will provide to the Regional Offices the
               annual air quality reports for the criteria pollutants, as                                                                                                      Following-up to identify
OAR   1.1.1                                                                              * Joint NPM/ region negotiation process      Delete
               appropriate, by August 1, 2006.                                                                                                                                 NPM/Lead Region rationale

               OAQPS N02 - HQ will finalize the 1997 PM2.5 NAAQS
                                                                                                                                                                               Following-up to identify
OAR   1.1.1    Implementation Rule.                                                      * Joint NPM/ region negotiation process      Delete
                                                                                                                                                                               NPM/Lead Region rationale

               OAQPS N03 - HQ will publish FRN to defer the designation
                                                                                                                                                                               Following-up to identify
OAR   1.1.1    dates for the EACs meeting the deferral requirements.                     * Joint NPM/ region negotiation process      Delete
                                                                                                                                                                               NPM/Lead Region rationale



                                                                                                               Page 2
                                                                                                            DRAFT
                                            Assessment of Measures Review Initiative Results for Goal 1
NPM                 Cell entries below are hypothetical examples
        Sub- Note: FY 07 ACS Commitment Code & Text                          Regions &      Region or State Explanation for         NPM response, new code, and New Text                         NPM Rationale
      objective                                                               States &            Recommendation
                                                                            recommend
                                                                                ation
               OAQPS N04 - HQ promulgates 5 category actions for
               §183(e) consumer product rules (1 rule, 3 CTGs) for                                                                                                                         Following-up to identify
OAR   1.1.1                                                                              * Joint NPM/ region negotiation process   Delete
               OAQPS; 1 rule for OTAQ.                                                                                                                                                     NPM/Lead Region rationale

                                                                                                                                   Modify
               OAQPS N05 - Regions review air quality data reports                                                                 Review annual air quality reports and work with states to
                                                                                                                                                                                             Following-up to identify
OAR   1.1.1    provided by HQ and take appropriate actions dealing with                  * Joint NPM/ region negotiation process   develop appropriate actions addressing newly
                                                                                                                                                                                             NPM/Lead Region rationale
               areas newly-discovered violating any NAAQS.                                                                         discovered areas violating the NAAQS for any criteria
                                                                                                                                   pollutant.

                                                                                                                                   Modify
               OAQPS N06 - Regions take rulemaking actions on CAIR
                                                                                                                                   Review and take action within 18 months of receipt of    Following-up to identify
OAR   1.1.1    SIPs within 18 months of receipt.                                         * Joint NPM/ region negotiation process
                                                                                                                                   any high-priority CAA-required SIP including 8-hr Ozone, NPM/Lead Region rationale
                                                                                                                                   PM 2.5, Regional Haze, and CAIR.


                                                                                                                                   Modify
                                                                                                                                   As necessary, provide policy and technical assistance
               OAQPS N08 - Regions consult with their States to develop
                                                                                                                                   and comments to USDOT and State and Local
               approvable SIPs to attain the PM2.5 and 8-hour ozone
                                                                                                                                   governments for transportation conformity               Following-up to identify
OAR   1.1.1    NAAQS including inventories and control strategy                          * Joint NPM/ region negotiation process
                                                                                                                                   determinations in 8-hour ozone, PM2.5, PM10, and CO     NPM/Lead Region rationale
               development, air quality modeling, and adoption of
                                                                                                                                   nonattainment and maintenance areas. Process any
               enforceable measure. Bid yes or no.
                                                                                                                                   Transportation Conformity-related SIP revisions
                                                                                                                                   submitted by States in FY 2008, as appropriate.

               OAQPS N09 - Regions review and take action within 18
               months of receipt of any NAAQS redesignation requests.                                                              Keep                                                    Following-up to identify
OAR   1.1.1                                                                              * Joint NPM/ region negotiation process
               Bid yes or no.                                                                                                                                                              NPM/Lead Region rationale


               OAQPS N11 - Regions complete rulemaking action on any
               remaining PM10 SIPs for existing PM10 nonattainment
                                                                                                                                                                                           Following-up to identify
OAR   1.1.1    areas within 18 months of receipt. Value in cell is number                * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                           NPM/Lead Region rationale
               of PM10 SIP actions to be completed.


               OAQPS N12 - State submit approvable attainment
                                                                                                                                                                                           Following-up to identify
OAR   1.1.1    demonstration SIPs to attain the 8-hour ozone NAAQS for                   * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                           NPM/Lead Region rationale
               moderate and higher classified areas.
               OAQPS N14 - State submit approvable attainment
                                                                                                                                   Modify
               demonstration SIPs to attain the 8-hour ozone NAAQS for                                                                                                                     Following-up to identify
OAR   1.1.1                                                                              * Joint NPM/ region negotiation process   Take action on any requests for voluntary bump-ups,
               subpart 1areas.                                                                                                                                                             NPM/Lead Region rationale
                                                                                                                                   including subpart 1 areas.

               OAQPS N15 - States submit RFP SIPs for moderate ozone
                                                                                                                                                                                           Following-up to identify
OAR   1.1.1    and higher Subpart 2 areas.                                               * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                           NPM/Lead Region rationale

               OAQPS N17 - States submit RFP SIPs for Subpart 1 ozone
                                                                                                                                                                                           Following-up to identify
OAR   1.1.1    areas that request an extension of their attainment date.                 * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                           NPM/Lead Region rationale



                                                                                                               Page 3
                                                                                                              DRAFT
                                             Assessment of Measures Review Initiative Results for Goal 1
NPM                 Cell entries below are hypothetical examples
        Sub- Note: FY 07 ACS Commitment Code & Text                           Regions &      Region or State Explanation for              NPM response, new code, and New Text           NPM Rationale
      objective                                                                States &            Recommendation
                                                                             recommend
                                                                                 ation
               OAQPS N18 - States submit RACT SIPs for Subpart 1
               ozone areas that request an extension of their attainment                                                                                                            Following-up to identify
OAR   1.1.1                                                                               * Joint NPM/ region negotiation process       Delete
               date.                                                                                                                                                                NPM/Lead Region rationale

               OAQPS N19 - States submit §110(a)(1) maintenance SIPs
                                                                                                                                                                                    Following-up to identify
OAR   1.1.1    for required 8-hr ozone attainment areas.                                  * Joint NPM/ region negotiation process       Delete
                                                                                                                                                                                    NPM/Lead Region rationale

               OAQPS N20 - States submit by June 1, 2007 the 2005
               State-wide emission inventories for criteria pollutants
                                                                                                                                                                                    Following-up to identify
OAR   1.1.1    required by the CERR, via CDX, covering all sources types.                 * Joint NPM/ region negotiation process       Delete
                                                                                                                                                                                    NPM/Lead Region rationale


               OAQPS N21 - States submit redesignation requests for 8-
               hour ozone and PM 2.5 areas with 3 years of clean air                                                                                                                Following-up to identify
OAR   1.1.1                                                                               * Joint NPM/ region negotiation process       Delete
               quality data.                                                                                                                                                        NPM/Lead Region rationale


                                                                                          AL- Draft SIP revisions have been sent to
                                                                                          EPA for comments prior to beginning the
                                                                                          rulemaking process. After those comments
               OAQPS N22 - States submit §110(a)(2)(D) SIPs for PM2.5
                                                                      AL                  were addressed and the process initiated,                                                 Not an ACS issue - comment
OAR   1.1.1    and ozone.                                                                                                                Delete
                                                                      M                   different EPA staff reviewed the submittal and                                            delegated to region 4
                                                                                          provided more comments. EPA should
                                                                                          provide all its comments during the draft
                                                                                          phase.

                                                                                          EPA has reviewed information and agreed to
                                                                                          support the submittal and then withdrew their
               OAQPS N23 - States adopt CAIR model trading program or
                                                                                          support during the process. EPA should not                                                Not an ACS issue - comment
OAR   1.1.1    submit CAIR Abbreviated SIP by March 31, 2007                                                                            Delete
                                                                                          put the state in the awkward position of                                                  delegated to region 4
                                                                                          having to withdraw a proposal that it said it
                                                                                          would support.

               OAQPS N25 - Regions consult with their respective RPO
               and States on 308 and 309 SIP development and issues,                                                                                                                Following-up to identify
OAR   1.1.1                                                                               * Joint NPM/ region negotiation process       Delete
               including BART and reasonable progress.                                                                                                                              NPM/Lead Region rationale


               OAQPS P001 - Percent of major NSR permits issued within 3                  R1- Not an environmental outcome indicator.
OAR   1.1.1                                                                                                                             PART measure/ headquarters will calculate   PART measure
               one year of receiving a complete permit application.    D                  This program indicator has little value.

               OAQPS P01 - Percent of final orders issued by HQ based
                                                                                                                                                                                    Following-up to identify
OAR   1.1.1    on drafts from Regions on citizen petitions received within                * Joint NPM/ region negotiation process       Delete
                                                                                                                                                                                    NPM/Lead Region rationale
               past year.
               OAQPS P02 - Percent of final orders issued by HQ based
               on drafts from Regions on citizen petitions with court-                                                                                                              Following-up to identify
OAR   1.1.1                                                                               * Joint NPM/ region negotiation process       Delete
               ordered deadlines.                                                                                                                                                   NPM/Lead Region rationale




                                                                                                                Page 4
                                                                                                                 DRAFT
                                              Assessment of Measures Review Initiative Results for Goal 1
NPM                 Cell entries below are hypothetical examples
        Sub- Note: FY 07 ACS Commitment Code & Text                               Regions &      Region or State Explanation for            NPM response, new code, and New Text                          NPM Rationale
      objective                                                                    States &            Recommendation
                                                                                 recommend
                                                                                     ation

               OAQPS P06 - Regions perform 1/4 of follow-up Title V
               program evaluations for programs with at least 20 permits                                                                  Keep                                                     Following-up to identify
OAR   1.1.1                                                                                   * Joint NPM/ region negotiation process
               pursuant to Feb 05 OIG report and set target to issue                                                                                                                               NPM/Lead Region rationale
               evaluation report within 120 days of evaluation.

               OAQPS P07 - Regions continue working on completing, per
                                                                                                                                          Keep                                                     Following-up to identify
OAR   1.1.1    agreed upon schedules, any remaining first-round Title V                       * Joint NPM/ region negotiation process
                                                                                                                                                                                                   NPM/Lead Region rationale
               program evaluations pursuant to March 2002 OIG report.

               OAQPS P08 - Regions review proposed initial, significant
                                                                                                                                          Keep                                                     Following-up to identify
OAR   1.1.1    modifications and renewal operating permits, as necessary,                     * Joint NPM/ region negotiation process
                                                                                                                                                                                                   NPM/Lead Region rationale
               to ensure consistent implementation of the Title V program.

               OAQPS P09 - Regions review NSR permits and major
               modifications, as necessary, to ensure consistent                                                                          Keep                                                     Following-up to identify
OAR   1.1.1                                                                                   * Joint NPM/ region negotiation process
               implementation of the NSR program.                                                                                                                                                  NPM/Lead Region rationale


               OAQPS P10 - Regions prepare draft orders to citizen
                                                                                                                                          Keep                                                     Following-up to identify
OAR   1.1.1    (public) petitions. Issue Title V permits to respond to                        * Joint NPM/ region negotiation process
                                                                                                                                                                                                   NPM/Lead Region rationale
               objections where the permitting authority refuses to act.

                                                                                              R3- This is a program indicator to determine
               OAQPS P11 - Regions encourage States to submit
                                                                                 3            the efficiency of the state‟s program. Should Keep
OAR   1.1.1    timeliness data on Title V permits for new and significant                                                                                                                          NPM to fill in
                                                                                 M            be modified to include issuance of permit
               permit modifications and enter into TOPS.
                                                                                              renewals and initial renewals (P012 and P013

               QAQPS P12 - States ensure timely issuance of Title V              3                                                                                                                 Following-up to identify
OAR   1.1.1                                                                                   R3- Combine into P011.                      Deleted
               permit renewals.                                                  M                                                                                                                 NPM/Lead Region rationale
               OAQPS P13 - Region obtains commitment from States to
                                                                                 3                                                        Keep
OAR   1.1.1    issue Title V initial permits and significant modifications, as                R3- Combine into P011.                                                                               NPM to fill in
                                                                                 M
               practicable.
               OAQPS P14 - Region obtains commitment from States to
               work with EPA in Title V permit program evaluations, with a
                                                                                                                                          Keep                                                     Following-up to identify
OAR   1.1.1    target to respond within 90 days to EPA's evaluation report                    * Joint NPM/ region negotiation process
                                                                                                                                                                                                   NPM/Lead Region rationale
               and implement recommendations the State believe are
               warranted.
               OAQPS P17 - States provide all RBLC data, including
               timeliness data on NSR permits issued for new major
                                                                                                                                          Keep                                                     Following-up to identify
OAR   1.1.1    sources and major modifications by entering data into the                      * Joint NPM/ region negotiation process
                                                                                                                                                                                                   NPM/Lead Region rationale
               RBLC national database.

                                                                                                                                          Modify
                                                                                                                                                                                                   Following-up to identify
OAR   1.1.1    OAQPS P19 - Issue PSD permits in Indian county.                                * Joint NPM/ region negotiation process     Issue PSD and Part 71 permits in Indian country. Value
                                                                                                                                                                                                   NPM/Lead Region rationale
                                                                                                                                          in cell is yes/no




                                                                                                                    Page 5
                                                                                                             DRAFT
                                             Assessment of Measures Review Initiative Results for Goal 1
NPM                 Cell entries below are hypothetical examples
        Sub- Note: FY 07 ACS Commitment Code & Text                           Regions &      Region or State Explanation for         NPM response, new code, and New Text                          NPM Rationale
      objective                                                                States &            Recommendation
                                                                             recommend
                                                                                 ation
               OAQPS P20 - Regions work with their states/local and tribal
               governments to implement the Title V and NSR permit
               programs. Regions shall bid yes/no and include in the
                                                                                                                                    Keep                                                      Following-up to identify
OAR   1.1.1    comments which of the individual Title V and/or NSR ACS                    * Joint NPM/ region negotiation process
                                                                                                                                                                                              NPM/Lead Region rationale
               commitments they expect to be most relevant/highest
               priority in their Region.


               OAQPS Tr03 - Regions provide resources and technical
               support to tribes for voluntary, educational, outreach,                                                                                                                        Following-up to identify
OAR   1.1.1                                                                               * Joint NPM/ region negotiation process   Delete
               and/or regulatory development and implementation                                                                                                                               NPM/Lead Region rationale
               programs (TIPs, TAS, ordinances, DITCAs, etc.)


               OAQPS Tr04 - Regions provide technical support to tribes
               assessing their air quality including those conducting
               monitoring analysis and those monitoring and submitting
               data to EPA's AQS, MDN, IMPROVE or other appropriate
               national databases. Value in cell is yes if all tribes                                                                                                                         Following-up to identify
OAR   1.1.1                                                                               * Joint NPM/ region negotiation process   Delete
               requesting such assistance receive it. Report number of                                                                                                                        NPM/Lead Region rationale
               tribes funded to operate ambient monitors and number that
               have submitted complete data in the comments field (e.g.,
               xx of yy tribes funded have submitted data).


               OAQPS Tr05 - Tribes, with regional and HQ support
               participate in national level meetings, conferences, and
                                                                                                                                    Keep                                                      Following-up to identify
OAR   1.1.1    teleconferences on CAA policy development and seek                         * Joint NPM/ region negotiation process
                                                                                                                                                                                              NPM/Lead Region rationale
               training and support to build capability for effective
               participation.
               OAQPS Tr06 - Tribes implement tribal, CAA and voluntary                                                              Keep                                                      Following-up to identify
OAR   1.1.1                                                                               * Joint NPM/ region negotiation process
               programs.                                                                                                                                                                      NPM/Lead Region rationale
               OTAQ 02 - Regions make adequacy/inadequacy
                                                                                                                                    Modify
               determinations, as necessary, for identified mobile source
                                                                                                                                    Make adequacy/inadequacy determinations, as
               budgets included in control strategy SIPs or maintenance
                                                                                                                                    necessary, for identified mobile budgets included in 8-   Following-up to identify
OAR   1.1.1    plans for transportation related criteria pollutants (e.g.                 * Joint NPM/ region negotiation process
                                                                                                                                    hour ozone, CO, and PM2.5 control strategy SIPs           NPM/Lead Region rationale
               ozone, CO, PM2.5, PM10) submitted by states, and/or
                                                                                                                                    submitted by States and approve/ disapprove such
               approve/disapprove such budgets at the time of SIP
                                                                                                                                    budgets at the time of SIP processing.
               processing.

               OAQPS M15 - HQ conducts Proficiency Testing and
                                                                                                                                                                                              Following-up to identify
OAR   1.1.2    Technical System Audits for national contract lab and S/L/T                * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                              NPM/Lead Region rationale
               labs servicing NATTS, and report results annually.

               OAQPS M16 - HQ provides national/regional-scale analysis
               of currently available air toxics data by 9/07, with
                                                                                                                                                                                              Following-up to identify
OAR   1.1.2    conclusions relevant to air quality management and to                      * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                              NPM/Lead Region rationale
               establishing future goals for the NATTS program and other
               monitoring initiatives.



                                                                                                                Page 6
                                                                                                             DRAFT
                                             Assessment of Measures Review Initiative Results for Goal 1
NPM                 Cell entries below are hypothetical examples
        Sub- Note: FY 07 ACS Commitment Code & Text                           Regions &      Region or State Explanation for         NPM response, new code, and New Text                         NPM Rationale
      objective                                                                States &            Recommendation
                                                                             recommend
                                                                                 ation
               OAQPS M18 - Regions participate in at least 50% of TSA
                                                                                                                                    Keep                                                     Following-up to identify
OAR   1.1.2    lab and field site audits.                                                 * Joint NPM/ region negotiation process
                                                                                                                                                                                             NPM/Lead Region rationale

               OAQPS M19 - Regions ensure QAPPs for NATTS
               operation are adequate to provide quality data for
                                                                                                                                                                                             Following-up to identify
OAR   1.1.2    submission to AQS and that project results meet approved                   * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                             NPM/Lead Region rationale
               QAPP requirements.


                                                                                                                                    Modify
               OAQPS M20 - NATTS grantees operate NATT sites
                                                                                                                                    The regions will work with their states to ensure NATTS Following-up to identify
OAR   1.1.2    according to national grant and technical guidance and in                  * Joint NPM/ region negotiation process
                                                                                                                                    sites are operated in accordance with EPA's technical   NPM/Lead Region rationale
               keeping with the terms of QAPP and QMP.
                                                                                                                                    guidance and the terms of the QAPP and QMP.

               OAQPS T001 - Reduce percentage of cancer causing toxic
                                                                                                                                                                                             Following-up to identify
OAR   1.1.2    pollutant emissions. Base year is 1993.                                    * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                             NPM/Lead Region rationale


               OAQPS T002 - Reduce percentage of non-cancer causing
                                                                                                                                                                                             Following-up to identify
OAR   1.1.2    toxic pollutant emissions. Base year is 1993.                              * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                             NPM/Lead Region rationale


               OAQPS T01 - Per court-ordered schedule of 10/06, HQ
               proposes area source standards for hospital sterilizers,                                                                                                                      Following-up to identify
OAR   1.1.2                                                                               * Joint NPM/ region negotiation process   Delete
               gasoline distribution, stationary internal combustion                                                                                                                         NPM/Lead Region rationale
               engines, as well as additional 4 categories by 12/15/06.

               OAQPS T02 - HQ promulgates oil and natural gas
               production area source standard (under court order for                                                                                                                        Following-up to identify
OAR   1.1.2                                                                               * Joint NPM/ region negotiation process   Delete
               12/06).                                                                                                                                                                       NPM/Lead Region rationale

               OAQPS T03 - HQ compiles and analyzes CY2006 air toxics
               monitoring data to characterize ambient air toxics by                                                                                                                         Following-up to identify
OAR   1.1.2                                                                               * Joint NPM/ region negotiation process   Delete
               9/30/07.                                                                                                                                                                      NPM/Lead Region rationale


                                                                                                                                    Modify
               OAQPS T05 - Regions work with S/L/T on community-                                                                    Work with States/Locals/Tribes and/or communities
               based projects including Community Action for Renewed                                                                (e.g., CARE communities/projects) to assess and          Following-up to identify
OAR   1.1.2                                                                               * Joint NPM/ region negotiation process
               Environment (CARE) to work to obtain reductions from                                                                 address sources of air toxics, including the use of      NPM/Lead Region rationale
               mobile, indoor and stationary sources. .                                                                             voluntary air toxic reduction programs in their
                                                                                                                                    communities.
                                                                                                                                    Modify
               OAQPS T06 - Regions delegate and provide
                                                                                                                                    Delegate and provide implementation assistance to
               implementation assistance to S/L/Ts for toxic requirements,                                                                                                                   Following-up to identify
OAR   1.1.2                                                                               * Joint NPM/ region negotiation process   States/Locals/Tribes, as needed, for section 111
               as needed. This includes the residual risk and the area                                                                                                                       NPM/Lead Region rationale
                                                                                                                                    (including CAMR), section 112 (including residual-risk
               source programs.
                                                                                                                                    requirements), and section 129 standards.




                                                                                                                Page 7
                                                                                                           DRAFT
                                            Assessment of Measures Review Initiative Results for Goal 1
NPM                 Cell entries below are hypothetical examples
        Sub- Note: FY 07 ACS Commitment Code & Text                         Regions &      Region or State Explanation for         NPM response, new code, and New Text                          NPM Rationale
      objective                                                              States &            Recommendation
                                                                           recommend
                                                                               ation
               OAQPS T07 - Regions work with States to submit by June
               1, 2007 the integrated 2005 emissions inventory for HAPs.                                                                                                                    Following-up to identify
OAR   1.1.2                                                                             * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                            NPM/Lead Region rationale

               OAQPS Tr02 - OAQPS provides support for training to
                                                                                                                                                                                            Following-up to identify
OAR   1.1.2    tribes on air toxics voluntary programs. .                               * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                            NPM/Lead Region rationale


               ORIA IE1A - Train healthcare professionals, community
               workers, and other trained individuals on environmental
               management of asthma so they can counsel people with
               asthma. Bid the number of individuals to be trained
               (common definitions of healthcare professionals and
                                                                                                                                  delete (combined into ORIA IE1B)                          Following-up to identify
OAR   1.2.     community workers will be provided). At mid- and end-of-                 * Joint NPM/ region negotiation process
                                                                                                                                                                                            NPM/Lead Region rationale
               year, use comment field in ACS to describe highlights,
               innovations, and anecdotal information about health
               outcomes and number of patients with asthma seen by
               healthcare professionals (HCPs).




                                                                                                                                  Modify
                                                                                                                                  Educate people with asthma or their caregivers, and
                                                                                                                                  train healthcare professionals, community workers, and
                                                                                                                                  other trained individuals, about environmental
               ORIA IE1B - Educate people with asthma or their                                                                    management of asthma triggers and childhood (0-6
               caregivers through home, daycare, community, and school                                                            years) exposure to ETS. Bid aggregate total number of
               interventions. Bid aggregate total number of people to be                                                          people with asthma to be educated and aggregate total
                                                                                                                                                                                            Following-up to identify
OAR   1.2.     educated. At mid- and end-of-year, use comment field in                  * Joint NPM/ region negotiation process   number of health care providers to be trained (common
                                                                                                                                                                                            NPM/Lead Region rationale
               ACS to describe highlights, innovations, and anecdotal                                                             definitions of health care professionals and community
               information about health outcomes.                                                                                 workers will be provided). At mid- and end-of-year, use
                                                                                                                                  comment field in ACS to describe highlights,
                                                                                                                                  innovations, and anecdotal information about health
                                                                                                                                  outcomes, number of patients with asthma seen by
                                                                                                                                  healthcare professionals, and number of families and
                                                                                                                                  caregivers educated about childhood exposure to ETS.



               ORIA IE2A - Train healthcare professionals, community
               workers and other individuals in educating patients and
               caregivers on children¿s exposure to ETS. Bid the number
               of individuals to be trained where possible. (Common
               definitions of healthcare professionals and community                                                              delete (combined into ORIA IE1B)                          Following-up to identify
OAR   1.2.                                                                              * Joint NPM/ region negotiation process
               workers will be provided). At mid- and end-of-year, use                                                                                                                      NPM/Lead Region rationale
               comment field in ACS to describe highlights, innovations,
               anecdotal information about health outcomes and number
               children exposed to ETS counseled.




                                                                                                              Page 8
                                                                                                                   DRAFT
                                               Assessment of Measures Review Initiative Results for Goal 1
NPM                 Cell entries below are hypothetical examples
        Sub- Note: FY 07 ACS Commitment Code & Text                                 Regions &      Region or State Explanation for         NPM response, new code, and New Text                       NPM Rationale
      objective                                                                      States &            Recommendation
                                                                                   recommend
                                                                                       ation

               ORIA IE2B - Educate parents and caregivers on childrens'
               exposure to ETS through home, daycare, and community
               interventions. Bid total aggregate number of
                                                                                                                                                                                                Following-up to identify
OAR   1.2.     caregivers/parents educated where possible. At mid- and                          * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                                NPM/Lead Region rationale
               end-of-year use comment filed in ACS to describe
               highlights, innovations, and anecdotal information.




               ORIA IE3A - Report on all radon work designed to increase
               mitigations and radon-resistant new construction. Bid yes
               or no. Work in this area includes: a) Promote work with
               builders to adopt radon-resistant new construction in
               medium/high risk areas. Encourage residential radon
               testing and mitigation as part of real estate transactions. At
               mid- and end-of-year, use comment filed in ACS to report
               number of homes built radon-resistant, areas newly-                                                                                                                              Following-up to identify
OAR   1.2.                                                                                      * Joint NPM/ region negotiation process   Delete
               developing radon-related building codes, new states/local                                                                                                                        NPM/Lead Region rationale
               governments requiring disclosure language for radon
               hazards/risks, and other information about
               accomplishments. b) Report on radon
               certification/registration efforts in States. At mid- and end-of-
               year use comment field in ACS to report on
               accomplishments.



                                                                                                                                          Modify
               ORIA IE3B - Promote mitigation of homes, schools, and
                                                                                                                                          Promote radon testing and mitigation in homes, schools
               buildings for radon. Bid aggregate number to be mitigated.
                                                                                                                                          and buildings. Encourage use of radon resistant new
               At mid- and end-of-year, use comment field in ACS to                                                                                                                               Following-up to identify
OAR   1.2.                                                                                      * Joint NPM/ region negotiation process   construction and state radon certification/registration
               report number mitigated and describe highlights,                                                                                                                                   NPM/Lead Region rationale
                                                                                                                                          efforts. Bid on number of state grants with workplans
               innovations, anecdotal information about health
                                                                                                                                          that quantify both mitigations & radon resistant new
               outcomes.
                                                                                                                                          construction.
               ORIA IE3C - Promote testing of homes, schools, and
               buildings for radon. Bid aggregate number to be tested. At
               mid- and end-of-year, use comment field in ACS to                                                                          Delete (combine into IE3B)                            Following-up to identify
OAR   1.2.                                                                                      * Joint NPM/ region negotiation process
               describe highlights, innovations, and anecdotal information                                                                                                                      NPM/Lead Region rationale
               about health outcomes.




                                                                                                                      Page 9
                                                                                                              DRAFT
                                             Assessment of Measures Review Initiative Results for Goal 1
NPM                 Cell entries below are hypothetical examples
        Sub- Note: FY 07 ACS Commitment Code & Text                            Regions &      Region or State Explanation for         NPM response, new code, and New Text                         NPM Rationale
      objective                                                                 States &            Recommendation
                                                                              recommend
                                                                                  ation

               ORIA IE4A - Promote work with schools to adopt and
               implement indoor air quality management practices
               consistent with TFS. Bid aggregate number of schools
               newly using organized indoor air quality management
                                                                                                                                     Keep                                                    Following-up to identify
OAR   1.2.     practices consistent with EPA TFS. At mid- and end-of-                      * Joint NPM/ region negotiation process
                                                                                                                                                                                             NPM/Lead Region rationale
               year, use comment field in ACS to describe highlights,
               innovations, students reached, and anecdotal information
               about health outcomes and/or student performance.



                                                                                                                                     Modify
                                                                                                                                     Support radiation emergency response operations
                                                                                                                                     through technical assistance, communication, training
                                                                                                                                     exercises, and logistical support. Ensure that Region
               ORIA RAD1 - Support radiation emergency response
                                                                                                                                     identifies one radiation advisor and one RERT Liaison   Following-up to identify
OAR   1.4.     operations through technical assistance, communication,                     * Joint NPM/ region negotiation process
                                                                                                                                     and certifies that each meets the minimum position      NPM/Lead Region rationale
               training exercises, and logistical support.
                                                                                                                                     functional requirements. Value in cell is number of
                                                                                                                                     radiation exercises. At mid- and end-of-year, use
                                                                                                                                     comment field in ACS to describe radiation emergency
                                                                                                                                     response highlights.

               ORIA RAD2 - Ensure that 2 people per Region are Region-
               certified as meeting minimum functional requirements to                                                                                                                       Following-up to identify
OAR   1.4.                                                                                 * Joint NPM/ region negotiation process   Delete
               serve as regional radiation advisors and RERT liaisons.                                                                                                                       NPM/Lead Region rationale



                                                                                                                                     Modify
                                                                                                                                     Lead and coordinate the installation of RadNet monitors
               ORIA RAD3 - Lead and coordinate the installation of
                                                                                                                                     in region, including the identification of operators and
               RadNet monitors, including the identification of operators
                                                                                                                                     location and preparation of monitor sites. Provide        Following-up to identify
OAR   1.4.     and location and preparation of monitor sites. Value in cell                * Joint NPM/ region negotiation process
                                                                                                                                     RadNet-related support to station operators and ORIA      NPM/Lead Region rationale
               is number of monitoring sites to be installed.
                                                                                                                                     labs as requested for operational monitors. Value in cell
                                                                                                                                     is number of monitoring sites to be installed in region
                                                                                                                                     and operational monitors.

               ORIA RAD4 - Provide RadNet-related support to station
                                                                                                                                                                                             Following-up to identify
OAR   1.4.     operators and ORIA labs as requested.                                       * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                             NPM/Lead Region rationale




                                                                                                                Page 10
                                                                                                               DRAFT
                                             Assessment of Measures Review Initiative Results for Goal 1
NPM                 Cell entries below are hypothetical examples
        Sub- Note: FY 07 ACS Commitment Code & Text                            Regions &      Region or State Explanation for              NPM response, new code, and New Text                           NPM Rationale
      objective                                                                 States &            Recommendation
                                                                              recommend
                                                                                  ation

                                                                                                                                          Modify
                                                                                                                                          Buildings: Through provision of promotion, outreach,
                                                                                           R8- Instead of “yes”/”no” bids, the Region
                                                                                                                                          and/or technical assistance, contribute to the
                                                                                           recommends that the measure simply quantify
               OAP1 - Buildings: Benchmark or re-benchmark buildings in                                                                   benchmarking (through obtaining an energy
                                                                                           the number of buildings benchmarked or re-
               one or more of the following categories: public sector and                                                                 performance rating) of buildings in one or more of the
                                                                                           benchmarked. Regions should have the
               education (K-12 schools, government offices, courthouses,                                                                  following categories: public sector and education (K-12
                                                                                           flexibility to meet the number of buildings
               college residence halls, college office buildings); healthcare 8                                                           schools, government offices, courthouses, college          Following-up to identify
OAR   1.5.                                                                                 benchmarked or re-benchmarked in any or all
               (acute care hospitals, children's hospitals, and medical       D                                                           residence halls, college office buildings); healthcare     NPM/Lead Region rationale
                                                                                           of the subcategories mentioned. The
               offices); or commercial office and retail (commercial and                                                                  (acute care hospitals, children's hospitals, and medical
                                                                                           ENERGY STAR program tracks these
               corporate office buildings, bank branches, hotels, grocery                                                                 offices); and commercial office and retail (commercial
                                                                                           numbers by the subcategories mentioned
               stores, and warehouses. Bid yes or no.                                                                                     and corporate office buildings, bank branches, hotels,
                                                                                           already, so it is unnecessary to include the
                                                                                                                                          grocery stores, retailers, and warehouses). Bid a
                                                                                           subcategories in the measure.
                                                                                                                                          percentage increase in total square footage
                                                                                                                                          benchmarked in the Region.

                                                                                           R8- New partner recruiting yields only a small
                                                                                           portion of the overall results of the ENERGY
               OAP2 - Energy Star Partner Recruiting: Recruit new             8                                                                                                                      Following-up to identify
OAR   1.5.                                                                                 STAR program and the Regions can have          Deleted
               partners in all categories. Bid yes or no.                     M                                                                                                                      NPM/Lead Region rationale
                                                                                           more impact by concentrating their efforts on
                                                                                           OAP1 and/or OAP3.

                                                                                                                                      Modify
               OAP3 - Residential Buildings: Support Energy Star for                                                                  Residential Buildings: Support Energy Star for
               residential buildings in at least one of three priority areas:              R8- Instead of “yes”/”no” bids, the Region residential buildings in at least one of three priority
               (1) assist in moving regional market to Energy Star Homes; 8                recommends that the ENERGY STAR            areas: (1) assist in moving regional market to Energy   Following-up to identify
OAR   1.5.
               (2) promote Energy Star in local affordable housing; or (3) M               program develop a way to quantify measures Star Homes; (2) promote Energy Star in local affordable NPM/Lead Region rationale
               help establish Home Performance with Energy Star with key                   of progress or success.                    housing; and (3) help establish Home Performance with
               stakeholders. Bid yes or no.                                                                                           Energy Star with key stakeholders. Bid which priority
                                                                                                                                      area(s) will be addressed.

                                                                                                                                         Modify
                                                                                                                                         Products: Support Energy Star national product
                                                                                                                                         campaigns by organizing and participating in local
                                                                                           R8- This measure should be deleted based on
               OAP4 - Products: Support Energy Star national product                                                                     promotional efforts including: events, placing public
                                                                                           the limited impact of the Regions‟ efforts on
               campaigns by organizing and participating in local                                                                        service announcements in local media, issuing localized
                                                                             8             national product campaigns and the difficulty                                                         Following-up to identify
OAR   1.5.     promotional efforts including: events, placing public service                                                             press releases, and coordinating with non-retail
                                                                             D             of accurately assessing the impacts of the                                                            NPM/Lead Region rationale
               announcements in local media, and coordinating with                                                                       partners. In addition, for the ES Change a Light
                                                                                           Regions‟ efforts on the success of product
               partners. Bid yes or no.                                                                                                  Campaign specifically, sign up as a pledge driver or
                                                                                           campaign.
                                                                                                                                         engage other local organizations as pledge drivers. Bid
                                                                                                                                         number of events and/or releases and pledges/pledge
                                                                                                                                         renewals.

                                                                                                                                          Modify
                                                                                                                                          Work with OTAQ to assist States, and Tribes, as
               OTAQ 04 - SmartWay Transport Program: Conduct
                                                                                                                                          appropriate, to support SmartWay Transport and          Following-up to identify
OAR   1.5.     outreach and/or recruitment events/efforts in support of the                * Joint NPM/ region negotiation process
                                                                                                                                          Smartway Grow and Go through recruitment of partners NPM/Lead Region rationale
               SmartWay Transport Program.
                                                                                                                                          and outreach efforts to local and regional governments,
                                                                                                                                          non-profit agencies, and businesses.



                                                                                                                Page 11
                                                                                                              DRAFT
                                             Assessment of Measures Review Initiative Results for Goal 1
NPM                 Cell entries below are hypothetical examples
        Sub- Note: FY 07 ACS Commitment Code & Text                            Regions &      Region or State Explanation for         NPM response, new code, and New Text                             NPM Rationale
      objective                                                                 States &            Recommendation
                                                                              recommend
                                                                                  ation
               OTAQ 05 - Best Workplaces for Commuters: Conduct
                                                                                                                                                                                                  Following-up to identify
OAR   1.5.     outreach and/or recruitment events/efforts in support of the                * Joint NPM/ region negotiation process   Delete
                                                                                                                                                                                                  NPM/Lead Region rationale
               Best Workplaces for Commuters Program.
                                                                                                                                     New
                                                                                                                                     Provide support to implement existing I/M programs,     Following-up to identify
                                                                                           * Joint NPM/ region negotiation process
                                                                                                                                     including OBD2. Work with the States/Locals in revising NPM/Lead Region rationale
                                                                                                                                     SIPs, as necessary.

                                                                                                                                     New
                                                                                                                                     Work with the States/Locals /Tribes and other affected
                                                                                                                                     parties to implement fuel programs in accordance with
                                                                                                                                                                                                  Following-up to identify
                                                                                           * Joint NPM/ region negotiation process   the applicable provisions of the CAA and EPAct,
                                                                                                                                                                                                  NPM/Lead Region rationale
                                                                                                                                     including activities related to the reformulated gasoline
                                                                                                                                     program, the renewable fuels standard, low RVP
                                                                                                                                     programs, biofuels, ULSD, and state fuels programs.

                                                                                                                                     New
                                                                                                                                     Regions work with OTAQ to encourage MPOs, state and
                                                                                                                                     local governments to increase CMAQ funding allocated Following-up to identify
                                                                                           * Joint NPM/ region negotiation process
                                                                                                                                     for clean diesel projects, and report these funded       NPM/Lead Region rationale
                                                                                                                                     projects, where data is available, in the National Clean
                                                                                                                                     Diesel Database.

                                                                                                                                     New
                                                                                                                                                                                           Following-up to identify
                                                                                           * Joint NPM/ region negotiation process   Review and approve/disapprove second and later
                                                                                                                                                                                           NPM/Lead Region rationale
                                                                                                                                     requests for Approved Regional Methods (ARM), if any.

                                                                                                                                     New
                                                                                                                                                                                                  Following-up to identify
                                                                                           * Joint NPM/ region negotiation process   Determine whether marginal areas attain 8-hr NAAQS
                                                                                                                                                                                                  NPM/Lead Region rationale
                                                                                                                                     and initiate bump-up for failure to attain.
                                                                                                                                     New
                                                                                                                                                                                                  Following-up to identify
                                                                                           * Joint NPM/ region negotiation process   Continue to coordinate with Federal Land Managers on
                                                                                                                                                                                                  NPM/Lead Region rationale
                                                                                                                                     regional haze issues.
                                                                                                                                     New
                                                                                                                                     Provide support to tribal air quality assessment and     Following-up to identify
                                                                                           * Joint NPM/ region negotiation process
                                                                                                                                     monitoring activities, and submission of monitoring data NPM/Lead Region rationale
                                                                                                                                     into the appropriate database.
                                                                                                                                     New
                                                                                                                                                                                                  Following-up to identify
                                                                                           * Joint NPM/ region negotiation process   Provide support for Tribes on the SIP and TIP
                                                                                                                                                                                                  NPM/Lead Region rationale
                                                                                                                                     processes.
                                                                                                                                     New
                                                                                                                                     Provide support and technical assistance to reservation Following-up to identify
                                                                                           * Joint NPM/ region negotiation process
                                                                                                                                     and tribal communities to understand and address        NPM/Lead Region rationale
                                                                                                                                     indoor air quality concerns.

                                                                                                                                     New
                                                                                                                                                                                                  Following-up to identify
                                                                                           * Joint NPM/ region negotiation process   Regions will encourage States to prepare and submit
                                                                                                                                                                                                  NPM/Lead Region rationale
                                                                                                                                     appropriate response to identified air quality violations.




                                                                                                                Page 12
                                                                                                   DRAFT
                                        Assessment of Measures Review Initiative Results for Goal 1
NPM                 Cell entries below are hypothetical examples
        Sub- Note: FY 07 ACS Commitment Code & Text                 Regions &      Region or State Explanation for         NPM response, new code, and New Text                           NPM Rationale
      objective                                                      States &            Recommendation
                                                                   recommend
                                                                       ation

                                                                                                                          New
                                                                                                                          Regions will consider action on any request from a         Following-up to identify
                                                                                * Joint NPM/ region negotiation process
                                                                                                                          State/City for establishing innovative, voluntary, early   NPM/Lead Region rationale
                                                                                                                          action initiatives such as the 8-hour Ozone Flex.

                                                                                                                          New
                                                                                                                                                                                     Following-up to identify
                                                                                * Joint NPM/ region negotiation process   Regions will encourage States to submit Regional Haze
                                                                                                                                                                                     NPM/Lead Region rationale
                                                                                                                          SIPs
                                                                                                                          New
                                                                                                                          The regions will work with their states to ensure that the
                                                                                                                                                                                     Following-up to identify
                                                                                * Joint NPM/ region negotiation process   State's monitoring networks for NAAQS, PM2.5
                                                                                                                                                                                     NPM/Lead Region rationale
                                                                                                                          speciation and PAMS meet applicable regulatory and
                                                                                                                          guidance requirements.




                                                                                                     Page 13
                                                                                               DRAFT

                                    Assessment of Measures Review Initiative Results for Goal 2
NPM    Sub-        Note: Cell entries below are hypothetical
                   FY 07 ACS Commitment Code & Text                    Regions & Region or State Explanation for                            NPM response, new code, and                        NPM Rationale
       objective                                                       States & Recommendation                                              New Text
                                                                       recommen
                                                                       dation

                                                                                                                                            Modify
                                                                                                                                            Subobjective 2.1.1 Water Safe to Drink -By
                   2.1.1 - Percent of the population served by
                                                                                                                                            2011, 91 percent of the population served by
                   community water systems that receive drinking
                                                                                                                                            community water systems will receive drinking
  OW   2.1.1       water that meets all applicable health-based
                                                                                                                                            water that meets all applicable health-based
                   drinking water standards through effective
                                                                                                                                            drinking water standards through approaches
                   treatment and source water protection.
                                                                                                                                            including effective treatment and source water
                                                                                                                                            protection.


                   A - Percent of the population served by community
                                                                                  R5 - 2006-2011 Strategic Plan no longer breaks out
                   water systems that receive drinking water that
                                                                     5,7          compliance with health-based standards for existing     Delete
  OW       2.1.1   meets health-based drinking water standards with
                                                                     D, D         and new rules. Percent population served by CWSs in
                   which systems need to comply as of December
                                                                                  compliance with all rules is captured in 2.1.1 in FY08.
                   2001.
                                                                                  R7 - Removed in new strategic plan

                   B - Percent of the population served by community              R5 - 2006-2011 Strategic Plan no longer breaks out
                   water systems that recieve drinking water that    5,7          compliance with health-based standards for existing     Delete
  OW   2.1.1
                   meets health-based standards with a compliance D, D            and new rules. Percent population served by CWSs in
                   date of January 2002 or later.                                 compliance with all rules is captured in 2.1.1 in FY08.
                                                                                  R7 - Removed in new strategic plan


                   C - Percent of community water systems that                    R5 - 2006-2011 Strategic Plan no longer breaks out
                   provide drinking water that meets health-based    5,7          compliance with health-based standards for existing        Delete
  OW   2.1.1                                                                      and new rules. Percent CWSs in compliance with all
                   standards with which systems need to comply as of M, M
                   December 2001.                                                 rules will be captured in single strategic target in FY08.
                                                                                  R7 - Use language in new strategic plan by ending the
                                                                                  measure at the word “standards”

                                                                                  R5 - 2006-2011 Strategic Plan no longer breaks out
                   D - Percent of community water systems that
                                                                                  compliance with health-based standards for existing
                   provide drinking water that meets health-based   5,7                                                                      Delete
  OW   2.1.1                                                                      and new rules. Percent CWSs in compliance with all
                   standards with a compliance date of January 2002 D, D
                                                                                  rules will be captured in single strategic target in FY08.
                   or later.
                                                                                  R7 - Removed in the new Strategic Plan.

                                                                                                                                            SP-3
                   E - Percent of the population served by community
                                                                                                                                            By 2011, 86 percent of the population in Indian
                   water systems in Indian country that receive
  OW   2.1.1                                                                                                                                country served by community water systems will
                   drinking water that meets all applicable health-
                                                                                                                                            receive drinking water that meets all applicable
                   based drinking water standards.
                                                                                                                                            health-based drinking water standards.



                                                                                              Page 14           OW Lead Region 4 is in agreement with OW's proposed list of measures
                                                                                              DRAFT

                                     Assessment of Measures Review Initiative Results for Goal 2
NPM    Sub-        Note: Cell entries below are hypothetical
                   FY 07 ACS Commitment Code & Text                   Regions & Region or State Explanation for                               NPM response, new code, and                        NPM Rationale
       objective                                                      States & Recommendation                                                 New Text
                                                                      recommen
                                                                      dation
                                                                                 R5 - Will be modified in 2008 to measure “community
                                                                                 water systems” and not “source water areas”.
                                                                                 56 - Region 6 proposes the description be clarified to
                                                                                 read: Percent of community water systems (both
                                                                                 surface and ground water) that achieve minimized risk
                                                                                 to public health (cumulative).
                                                                                 The reasons for offering this clarification are as
                                                                                 follows: 1. The Safe Drinking Water Act as amended
                                                                                 in 1996 specifically targets public water supply
                                                                                 systems for assessments under Section 1453 of the
                                                                                 statute. EPA has narrowed that focus down to                 SP-4                                               Public comment on the
                                                                                 targeting Community Water Systems - a subset of              By 2011, minimize risk to public health through    draft Strategic Plan
                                                                                 public water supply systems that has the greatest            source water protection for 50 percent of          including Strategic plan
                   F - Percent of source water areas (both surface               potential to impact a large portion of the population.       community water systems and for the associated     measures was from May 31
                   and groundwater) for community water systems       5,6, SC    The statute does not offer any discussion or definition
  OW   2.1.1                                                                                                                                  62 percent of the population served by             to July 17. Since strategic
                   that achieve minimized risk to public health.      M, M, M    of what constitutes a "source water area." 2. EPA            community water systems (i.e., "minimized          plan measures are now
                   (cumulative)                                                  guidance on source water protection carries a footnote       risk" achieved by substantial implementation, as   final, the Agency cannot
                                                                                 for Strategic Target F which states: For the purpose         determined by the state, of actions in a source    make changes to the
                                                                                 of this measure, "source water areas" are treated as         water protection strategy).                        measure text
                                                                                 community water systems; universe is the number of
                                                                                 community water systems. It appears as though the
                                                                                 guidance document recognizes the need for a
                                                                                 clarification and attempts to use a footnote as a
                                                                                 means of clarification when in fact, further confusion is
                                                                                 introduced. 3. For the purposes of meeting targets,
                                                                                 Regions will find it less difficult to meet those that are
                                                                                 based on the number of "source water areas" since
                                                                                 there can be multiple source water areas for a single
                                                                                 community water system (e.g., many community water
                                                                                                                                              SP-5
                                                                                                                                              By 2015, in coordination with other federal
                   G - Number of households on tribal lands lacking
  OW   2.1.1                                                                                                                                  agencies, reduce by 50 percent the number of
                   access to safe drinking water.
                                                                                                                                              homes on tribal lands lacking access to safe
                                                                                                                                              drinking water.

                                                                                                                                              Modify
                   SDW-01a - Percent of community water systems
                                                                                                                                              Percent of community water systems (CWSs)
                   (CWSs) in states that have undergone a sanitary
                                                                                                                                              that have undergone a sanitary survey within the
                   survey within the past three years (five years for 5                                                                                                                        Key public health related
  OW   2.1.1                                                                                                                                  past three years (five years for outstanding
                   outstanding performers) as required under the      D                                                                                                                        activity
                                                                                                                                              performers) as required under the Interim
                   Interim Enhanced and Long-Term 1 Surface Water
                                                                                                                                              Enhanced and Long-Term 1 Surface Water
                   Treatment Rules.                                              Make into Indicator measure – can be tracked within
                                                                                                                                              Treatment Rules.
                                                                                 the program.


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                   FY 07 ACS Commitment Code & Text                      Regions & Region or State Explanation for                             NPM response, new code, and   NPM Rationale
       objective                                                         States & Recommendation                                               New Text
                                                                         recommen
                                                                         dation

                   SDW-01b - Number of tribal community water
                   systems that have undergone a sanitary survey
                   within the past three years (five years for    5                                                                            Keep                          Key public health related
  OW   2.1.1
                   outstanding performers) as required under the  D                                                                                                          activity
                   Interim Enhanced and Long-Term 1 Surface Water                      Make into Indicator measure – can be tracked within
                   Treatment Rules.                                                    the program.

                   SDW-02 - Percent of the data for violations of                      R3 - The Region has no means to accurately measure
                   health-based standards at public water systems                      the commitment (Percent of complete data in the data
                                                                         3,5,7,8,9     system).
                   that is accurate and complete in SDWIS-FED for                                                                           Keep
  OW   2.1.1
                   all maximum contaminant level and treatment
                                                                         D, D, M, D,   R5 - Indicator measure – can be tracked within the                                    Key to high data quality
                                                                         D             program.
                   technique rules (excluding the Lead and Copper
                   Rule).                                                              R7 - Include Lead and Copper rule and delete
                                                                                       measure SDW-03.


                                                                                       R3 - This measure seeks a reflection of “Complete”
                                                                                       lead and copper data without specifying whether it is
                                                                                       for the current monitoring period or for a compilation of
                   SDW-03 - Percent of the Lead and Copper Rule                        all potential data. It is not possible to determine
                   action level data for community water systems         3,5,7,8,9     whether a “Blank” in the data system is due to a failure Keep
  OW   2.1.1                                                                                                                                                                 Key public health measure
                   serving over 3,300 people that is complete in         D, D, D, D, D to submit the data, or that the system was not required
                   SDWIS-FED.                                                          to submit the value during the period of review.
                                                                                       Therefore, the system may reflect “incomplete” data
                                                                                       when the data is not yet required.
                                                                                       R5 - Indicator measure – can be tracked within the
                                                                                       program.
                                                                                       R7 - Combine with modified measure SDW-02
                   SDW-04a - Percent of Community Water Systems                        R5 - An indicator measure that looks at CWS
                                                                      4,5,8,9                                                                  Delete
  OW   2.1.1       that do not exceed the action level for lead of 15                  compliance with part of one rule – LCR. Can be
                                                                      D, D, D, D
                   ppb at the 90th percentile value.                                   tracked within the program.
                   SDW-04b - Percent of non-transient, non-
                   Community Water Systems that do not exceed the 4,5,8,9              R5 - An indicator measure that looks at NTNCWS          Delete
  OW   2.1.1
                   action level for lead of 15 ppb at the 90th percentile D, D, D, D   compliance with part of one rule – LCR. Can be
                   value.                                                              tracked within the program.




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       objective                                                       States & Recommendation                                               New Text
                                                                       recommen
                                                                       dation




                                                                                   R8 - A simple reading of the measure creates
                                                                                   confusion. Measure is of questionable value and
                                                                                   requires detailed explanation to understand what it
                                                                                                                                             SP-2
                                                                                   means.
                   SDW-05 - Percent of "person months" (i.e., the                                                                            By 2011, community water systems will provide
                                                                                   IL - State water programs have approximately 180
                   population served by community water systems                                                                              drinking water that meets all applicable health-
                                                                       8, IL, SC   program activity measures. Need to distill down to the                                                     Included in Strategic Plan
  OW   2.1.1       times 12 months) during which community water                                                                             based drinking water standards during 96
                                                                       D, D, M     most important ones. These measures are not used                                                           at request of Regions.
                   systems provide drinking water that meets all                                                                             percent of person months (i.e., all persons
                                                                                   for any other purpose (like PART or grant template)
                   applicable health-based drinking water standards.                                                                         served by community water systems times 12
                                                                                   and could be eliminated
                                                                                                                                             months).
                                                                                   SC - I Believe this was included to show when a CWS
                                                                                   has a violation in one month, it doesn't look like they
                                                                                   are not meeting the standards for the whole year. If
                                                                                   so, then shouldn't the description of a person month
                                                                                   be "population served by a CWS times the number of
                                                                                   months it met health based DW standards"?

                   SDW-06 - Fund utilization rate (cumulative dollar
                   amount of loan agreements divided by cumulative                                                                           SDW-4
  OW   2.1.1
                   funds available for projects) for Drinking Water
                   State Revolving Fund (DWSRF).


                                                                                   R5 - Not required for PART. If not deleted, change to
                   SDW-07a - The number of Drinking Water State                    indicator with no Regional commitment or reporting
                                                                       5,7         obligation. HQ can pull data without requesting          SDW-5                                           Key indicator of major
  OW   2.1.1       Revolving Fund projects that have initiated
                                                                       D, M        separately from Regions                                                                                  Agency investment.
                   operations. (cumulative)
                                                                                   R7 - The size of the projects varies widely. The size of
                                                                                   the population that is impacted by the project is more
                                                                                   important than just the number of projects.




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                   FY 07 ACS Commitment Code & Text                      Regions & Region or State Explanation for                             NPM response, new code, and   NPM Rationale
       objective                                                         States & Recommendation                                               New Text
                                                                         recommen
                                                                         dation




                                                                                       R2 - This measure needs to be more clearly defined and
                                                                                       until such time the measure should be deleted. Based on
                                                                                       the description of "will assist in returning a community
                                                                                       water system to compliance," the answer will be the
                                                                                       cumulative number of loans (since each loan is a project).
                                                                                        Furthermore, the measure does not consider the effect of
                                                                                       single project that receives multiple loans. This measure is
                   SDW-07b - The number of Drinking Water State                        NOT linked to any of the following measures; PART, FY 07
                                                                         2,4,5,8,9, IL
                   Revolving Fund projects that will assist in returning               State Grant Template, FY 07 Annual Performance Measure, Delete
  OW   2.1.1                                                             D, D, D, D,
                   a community water system to compliance with                         FY 06 Regional Priority Measure, nor the FY 06 Regional
                                                                         D, D
                   drinking water standards (cumulative)                               Organizational Assessment Measure.
                                                                                       R5 - Not required for PART. If not deleted, change to
                                                                                       indicator with no Regional commitment or reporting
                                                                                       obligation. HQ can pull data without requesting separately
                                                                                       from Regions
                                                                                       R8 - Data available in NIMS database.
                                                                                       IL - State water programs have approximately 180 program
                                                                                       activity measures. Need to distill down to the most
                                                                                       important ones. These measures are not used for any other
                                                                                       purpose (like PART or grant template) and could be
                                                                                       eliminated

                   SDW-08 - EPA will install and begin initial
                   operations of monitoring and surveillance pilots to   4,5,9                                                                 Delete
  OW   2.1.1
                   provide early warning of contamination in select      D, D, D
                                                                                      R5 - Indicator measure – can be tracked within the
                   drinking water systems.
                                                                                      program.



                                                                                        R5 - Not required for PART. If not deleted, change to
                                                                                        indicator with no Regional commitment. Any Regional
                   SDW-09a - The percentage of Class I wells
                                                                          4,5,7,8,9, IL input annually at the program level, informally.
                   identified in significant violation that are addressed                                                                      Delete
  OW   2.1.1                                                              D, D, D, D, R7 - For purposes of over-all programmatic results
                   by the Underground Injection Control (UIC)                           measure SDW11 provides better information.
                                                                          D, D
                   program.                                                             R8 - Measure easy to report but of questionable value.
                                                                                        New measure is needed to connect “health” of
                                                                                        groundwater to UIC program.
                                                                                        IL - Nine measures for a minor program like UIC is too
                                                                                        many.


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       objective                                                        States & Recommendation                                                New Text
                                                                        recommen
                                                                        dation



                                                                                        R5 - Not required for PART. If not deleted, change to
                                                                                        indicator with no Regional commitment. Any Regional
                   SDW-09b - The percentage of Class II wells
                                                                          4,5,7,8,9, IL input annually at the program level, informally.
                   identified in significant violation that are addressed                                                                      Delete
  OW   2.1.1                                                              D, D, D, D, R7 - For purposes of over-all programmatic results
                   by the Underground Injection Control (UIC)                           measure SDW11 provides better information.
                                                                          D, D
                   program.                                                             R8 - Measure easy to report but of questionable value.
                                                                                        New measure is needed to connect “health” of
                                                                                        groundwater to UIC program.
                                                                                        IL - Nine measures for a minor program like UIC is too
                                                                                        many.



                                                                                     R5 - Not required for PART. If not deleted, change to
                                                                                     indicator with no Regional commitment. Any Regional
                   SDW-09c - The percentage of Class III identified in 4,5,7,8,9, IL input annually at the program level, informally.
                                                                                                                                            Delete
  OW   2.1.1       significant violation that are addressed by the     D, D, D, D, R7 - For purposes of over-all programmatic results
                   Underground Injection Control (UIC) program.        D, D          measure SDW11 provides better information.
                                                                                     R8 - Measure easy to report but of questionable value.
                                                                                     New measure is needed to connect “health” of
                                                                                     groundwater to UIC program.
                                                                                     IL - Nine measures for a minor program like UIC is too
                                                                                     many.



                                                                                      R5 - Not required for PART. If not deleted, change to
                                                                                      indicator with no Regional commitment. Any Regional
                   SDW-09d - The percentage of Class V wells            4,5,7,8,9, IL input annually at the program level, informally.
                                                                                                                                             Delete
  OW   2.1.1       identified in violation that are addressed by the    D, D, D, D, R7 - For purposes of over-all programmatic results
                   Underground Injection Control (UIC) program.         D, D          measure SDW11 provides better information.
                                                                                      R8 - Measure easy to report but of questionable value.
                                                                                      New measure is needed to connect “health” of
                                                                                      groundwater to UIC program.
                                                                                      IL - Nine measures for a minor program like UIC is too
                                                                                      many.
                   SDW-10 - Percent of identified Class V Motor                       UIC program priorities have shifted.
                                                                        7, IL                                                                                                Key indicator of drinking
  OW   2.1.1       Vehicle Waste Disposal wells that are closed or                    IL - Nine measures for a minor program like UIC is too
                                                                        D, D                                                                                                 water source protection.
                   permitted.                                                         many.




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                   FY 07 ACS Commitment Code & Text                    Regions & Region or State Explanation for                               NPM response, new code, and   NPM Rationale
       objective                                                       States & Recommendation                                                 New Text
                                                                       recommen
                                                                       dation

                                                                                     R5 - PART indicator – can be tracked within the
                   SDW-11a - The percent of Class I wells that
                                                                       5, IL         program, no more than annual input from region.        SDW-7a
  OW   2.1.1       maintain mechanical integrity.                                                                                                                            Top priority UIC measure
                                                                       D, D          IL - Nine measures for a minor program like UIC is too
                                                                                     many.
                                                                                     R5 - PART indicator – can be tracked within the
                   SDW-11b - The percent of Class II wells that        5, IL         program, no more than annual input from region.        SDW-7b
  OW   2.1.1                                                                                                                                                                 Top priority UIC measure
                   maintain mechanical integrity.                      D, D          IL - Nine measures for a minor program like UIC is too
                                                                                     many.
                                                                                     R5 - PART indicator – can be tracked within the
                   SDW-11c - The percent of Class III salt solution    5, IL         program, no more than annual input from region.        SDW-7c
  OW   2.1.1                                                                                                                                                                 Top priority UIC measure
                   mining wells that maintain mechanical integrity.    D, D          IL - Nine measures for a minor program like UIC is too
                                                                                     many.

                                                                                     R5 - PART indicator – can be tracked within the
                                                                                     program, no more than annual input from region.
                   SDW-12 - Number, and national percent, of high                    R7 - Change this measure to “The volume of all
                   priority Class V wells identified in ground water   5,7, IL       wastewater safely disposed into underground geologic SDW-8
  OW   2.1.1                                                                         reservoirs via deep injection wells and which is                                        Top priority UIC measure
                   based community water system water areas that       D, D/M, IL
                   are closed or permitted.                                          thereby prevented from entering underground sources
                                                                                     of drinking water”
                                                                                     IL - Nine measures for a minor program like UIC is too
                                                                                     many.


                                                                                     R5 - Indicator measure – can be tracked within the
                                                                                     program.
                                                                                     R8 - Data systems do not currently support accurate
                   SDW-13 - Percent of community water system                        reporting on this indicator measure. While this is
                                                                       4,5,8,9,10    useful information for managing at the regional level, it Delete
  OW   2.1.1       intakes using source water that has been
                                                                       D, D, D, D, D does not rise to the level of meriting reporting on a
                   designated for a drinking water use.
                                                                                     national level. Several states are reluctant to share
                                                                                     information on drinking water intakes or protect the
                                                                                     information from public disclosure, making the
                                                                                     collection of accurate information for this measure
                                                                                     challenging.
                   SDW-14 - Percent of community water system
                                                                                                                                                                             Key to integration of Clean
                   intakes for which the source water was assessed     5,8,9,10                                                               SDW-9
  OW   2.1.1                                                                                                                                                                 Water/Drinking Water
                   for the drinking water use during the most recent   D, D, D, D    Indicator measure – can be tracked within the
                                                                                                                                                                             Program
                   reporting cycle.                                                  program.




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       objective                                                        States & Recommendation                                                New Text
                                                                        recommen
                                                                        dation


                                                                                      R2 - SDW 15a and 15b - both of these measures should be
                                                                                      deleted for 07 and 08. They are extremely complex to
                   SDW-15a - Percent of waterbody impairments                         report and are not required in any of the agency reporting
                   identified by states in 2002, in which there is a                  formats.
                                                                        2,5,8,9,10    These 2 measures are NOT linked to any of the following                                Key to integration of Clean
                   community water system intake and the                                                                                          SDW-10a
  OW   2.1.1                                                            D, D, M, D,   measures; PART, FY 07 State Grant Template, FY 07                                      Water/Drinking Water
                   impairment cause is for either a drinking water use
                                                                        D             Annual Performance Measure, FY 06 Regional Priority                                    Program
                   or a pollutant that is regulated as a drinking water
                   contaminant for which there is a TMDL.                             Measure, nor the FY 06 Regional Organizational
                                                                                      Assessment Measure.
                                                                                      R5 - Indicator measure – can be tracked within the program.
                                                                                      R8 - HQ to report results as national number rather than
                                                                                      region by region. Merge 15a and b.


                                                                                      R2 - SDW 15a and 15b - both of these measures should be
                                                                                      deleted for 07 and 08. They are extremely complex to
                   SDW-15b - Percent of waterbody impairments                         report and are not required in any of the agency reporting
                   identified by states in 2002, in which there is a                  formats.
                   community water system intake and the                              These 2 measures are NOT linked to any of the following
                                                                        2,5,8,9,10                                                                SDW-10b                    Key measure to improve
  OW   2.1.1       impairment cause is for either a drinking water use
                                                                        D, D, M, D, d measures; PART, FY 07 State Grant Template, FY 07                                      source of drinking water.
                   or a pollutant that is regulated as a drinking water               Annual Performance Measure, FY 06 Regional Priority
                   contaminant for which those waterbody                              Measure, nor the FY 06 Regional Organizational
                   impairments have been restored.                                    Assessment Measure.
                                                                                      R5 - Indicator measure – can be tracked within the program.
                                                                                      R8 - HQ to report results as national number rather than
                                                                                      region by region. Merge 15a and b.




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       objective                                                        States & Recommendation                                                New Text
                                                                        recommen
                                                                        dation
                                                                                    R3 - FS-1a, WQ-02a and SS-1a all reflect Agency
                                                                                    priorities that we have identified in the 2006 to 2011
                                                                                    EPA Strategic Plan as measures that will result in
                                                                                    human health and/or environmental improvement.
                                                                                    These are the environmental priorities that are
                                                                                    appropriately spotlighted in our WQS measures. It is
                                                                                    significant to note that although a state or territory may
                                                                                    adopt nutrient criteria, fish tissue criterion for mercury
                                                                                    or current pathogen criteria into its WQS, none of
                                                                                    these criteria are effective for CWA purposes until
                                                                                    EPA approves the new or revised WQS. Therefore,
                                                                                    EPA‟s prompt action on the WQS, and approval if
                                                                                    appropriate, is the measure that we endorse for FS-
                                                                      3,4,5,8,9, IL 1a, WQ-02a and SS-1. This also allows accountability
                   FS-1a - Number of States and Territories that have                                                                          Delete
  OW   2.1.2                                                          M, D, D, D, for the targets we identified as important for meeting
                   adopted the new fish tissue criterion for mercury.
                                                                      D, D          our goals, as well as allowing us some accountability
                                                                                    for our CWA statutory responsibilities. Our statutory
                                                                                    requirement is to act promptly not to approve
                                                                                    promptly.
                                                                                    R5 - This is a measure of the States‟ WQS programs
                                                                                    and not the Region‟s. Also, in Region 5, 3 States
                                                                                    have adopted mercury water column criterion that
                                                                                    correlate to fish tissue levels. They are not inclined to
                                                                                    adopt the national criterion when they already have an
                                                                                    equivalent criterion. The region‟s success or failure is
                                                                                    inextricably linked to HQ‟s ability get out the mercury
                                                                                    criterion implementation guidance. If we keep this
                                                                                    PAM, we should add a PAM on issuance of final


                                                                                      R5 - This is a measure of the Tribes‟ WQS program
                                                                                      and not the Region‟s. Also, in Region 5, those tribes
                                                                                      with WQS either utilize the Great Lakes Initiative (GLI)
                                                                                      mercury criterion which is equivalent to the national
                                                                                      criterion. They are not inclined to adopt the national
                   FS-1b - Number of authorized Tribes that have        4,5,8,9       criterion when they already have an equivalent           Delete
  OW   2.1.2
                   adopted the new fish tissue criterion for mercury.   D, D, D, D    criterion.
                                                                                      R8 - Advisories are quite variable from state to state,
                                                                                      and often advisory policies are not the authority of the
                                                                                      water quality agency. Typically in Region 8, fish
                                                                                      collection is not in the water quality agency‟s scope of
                                                                                      activities. Most states do not have mercury analytical
                                                                                      capability and must rely on EPA or other labs.


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                   FY 07 ACS Commitment Code & Text                      Regions & Region or State Explanation for                         NPM response, new code, and                       NPM Rationale
       objective                                                         States & Recommendation                                           New Text
                                                                         recommen
                                                                         dation

                                                                                     R5-This is a measure of the States monitoring
                                                                                     programs and not the Regions. We have not and do
                   FS-2a - Percent of river miles where fish tissue will             not plan to run this type of monitoring program and
                   be assessed to support waterbody-specific or          5,8,9,10    thus have nothing to report for this measure. If this  FS-1a
  OW   2.1.2                                                                                                                                                                                 Key measure for fish safety
                   regional consumption advisories or a determination D, M, D, D     measure is not dropped, it should be changed to an
                   that no consumption advice is necessary.                          indicator.
                                                                                     R8- Change from target to indicator. Report nationally
                                                                                     rather than region by region.
                                                                                     R5-This is a measure of the States monitoring
                   FS-2b - Percent of lake acres where fish tissue will              programs and not the Regions. We have not and do
                   be assessed to support waterbody-specific or                      not plan to run this type of monitoring program and
                                                                        8,9,10       thus have nothing to report for this measure. If this  FS-1b
  OW   2.1.2       regional consumption advisories, or a                                                                                                                                     Key measure for fish safety
                                                                        D, M, D, D   measure is not dropped, it should be changed to an
                   determination that no consumption advice is
                   necessary.                                                        indicator.
                                                                                     R8- Change from target to indicator. Report nationally
                                                                                     rather than region by region.

                   H - Improve the quality of water and sediments to
                   allow for increased consumption of safe fish in a
                                                                                                                                           Delete
  OW   2.1.2       percentage of the river miles/lake acres identified
                   by States or Tribes as having a fish consumption
                   advisory in 2002.

                                                                                                                                           SP-7
                   I - Increase the percentage of shellfish-growing                                                                        By 2011, maintain or improve the percentage of
  OW   2.1.2       acres monitored by States that are approved or                                                                          state-monitored shellfish-growing acres
                   conditionally approved for use.                                                                                         impacted by anthropogenic sources that are
                                                                                                                                           approved or conditionally approved for use.

                   2.1.3 - Restore water quality to allow swimming in
                                                                                                                                           Delete
  OW   2.1.3       waters identified by states in 2000 as unsafe for
                   swimming.

                                                                                                                                                                                             Public comment on the
                                                                                                                                                                                             draft Strategic Plan
                                                                                                                                           SP-9
                                                                                                                                                                                             including Strategic plan
                   K - Percent of days of the beach season that                                                                            By 2011, maintain the percentage of days of the
                                                                                                                                                                                             measures was from May 31
                   coastal and Great Lakes beaches monitored by      5                                                                     beach season that coastal and Great Lakes
  OW   2.1.3                                                                                                                                                                                 to July 17. Since strategic
                   state beach safety programs will be open and safe M                                                                     beaches monitored by state beach safety
                                                                                                                                                                                             plan measures are now
                   for swimming.                                                                                                           programs that are open and safe for swimming
                                                                                                                                                                                             final, the Agency cannot
                                                                                     The target is not a measure of our or the State's     at 96 percent.
                                                                                                                                                                                             make changes to the
                                                                                     program effectiveness. It should be changed from a                                                      measure text
                                                                                     target to an indicator.

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                   FY 07 ACS Commitment Code & Text                      Regions & Region or State Explanation for                               NPM response, new code, and   NPM Rationale
       objective                                                         States & Recommendation                                                 New Text
                                                                         recommen
                                                                         dation
                                                                                     R3 - FS-1a, WQ-02a and SS-1a all reflect Agency
                                                                                     priorities that we have identified in the 2006 to 2011
                                                                                     EPA Strategic Plan as measures that will result in
                                                                                     human health and/or environmental improvement.
                                                                                     These are the environmental priorities that are
                                                                                     appropriately spotlighted in our WQS measures. It is
                                                                                     significant to note that although a state or territory may
                                                                                     adopt nutrient criteria, fish tissue criterion for mercury
                                                                                     or current pathogen criteria into its WQS, none of
                                                                                     these criteria are effective for CWA purposes until
                                                                                     EPA approves the new or revised WQS. Therefore,
                                                                                     EPA‟s prompt action on the WQS, and approval if
                   SS-1a - Number of States and Territories that have                appropriate, is the measure that we endorse for FS-
                                                                       3,4,5,8,9, IL 1a, WQ-02a and SS-1. This also allows accountability
                   adopted current pathogen criteria for non-coastal                                                                            Delete
  OW   2.1.3                                                           M, D, D, D, for the targets we identified as important for meeting
                   recreational waters (i.e. waters not covered by the
                                                                       D, D          our goals, as well as allowing us some accountability
                   BEACH Act.)
                                                                                     for our CWA statutory responsibilities. Our statutory
                                                                                     requirement is to act promptly not to approve
                                                                                     promptly.
                                                                                     R5 - Progress on this measure depends on National
                                                                                     efforts to resolve technical questions related to the
                                                                                     criteria. EPA must either convince the states and
                                                                                     stakeholders of the technical validity of its arguments
                                                                                     for the criteria or compel them through disapproval
                                                                                     and promulgation. If EPA doesn‟t intend to do either,
                                                                                     then this measure should be deleted.
                                                                                     R8 - Headquarters has agreed to drop this measure.
                                                                                     IL - State water programs have approximately 180


                                                                                       R5 - Progress on this measure depends on National
                                                                                       efforts to resolve technical questions related to the
                   SS-1b - Number of Tribes that have adopted                          criteria. EPA must either convince the states and
                   current pathogen criteria for non-coastal             4,5,8,9       stakeholders of the technical validity of its arguments   Delete
  OW   2.1.3
                   recreational waters (i.e. waters not covered by the   D, D, D       for the criteria or compel them through disapproval
                   BEACH Act.)                                                         and promulgation. If EPA doesn‟t intend to do either,
                                                                                       then this measure should be deleted.
                                                                                       R8 - Headquarters has agreed to drop this measure.


                   SS-2 - Number, and national percent, of CSO
                                                                                       R5 - Commitment and definitions for counting used by
                   permits with schedules in place in permits or other 5,7                                                                  SS-1                               Measure critical to reporting
  OW   2.1.3                                                                           OECA and OW need to be identical.
                   enforceable mechanisms to implement approved        M, M                                                                                                    swimming uses
                                                                                       R7 - Modify to % total volume being addressed rather
                   Long Term Control Plans (LTCPs). (cumulative)
                                                                                       than number of communities.

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       objective                                                       States & Recommendation                                                 New Text
                                                                       recommen
                                                                       dation




                                                                                     R5 - Indicator – can be tracked within the program.
                                                                                     R7 - The states are not receiving funding for the on-
                                                                                     site systems. So they are not obliged to adopt the
                   SS-3 - Number of States that adopted the
                                                                       5,7,8,9, IL   guidelines and not expected to report to the EPA. This Delete
  OW   2.1.3       Voluntary Management Guidelines for on-site
                                                                       D, D, D, D, D measure does not indicate any environmental
                   sewage management. (cumulative)
                                                                                     benefits.
                                                                                     R8 - Headquarters has agreed to drop this measure.
                                                                                     IL - State water programs have approximately 180
                                                                                     program activity measures. Need to distill down to the
                                                                                     most important ones. These measures are not used
                                                                                     for any other purpose (like PART or grant template)
                                                                                     and could be eliminated
                                                                                     This is a measure of States monitoring programs and
                   SS-4 - Percent of all Tier I (significant) public                 not the Region‟s. Also, our States define high priority
                                                                       5,9                                                                     SS-2                          Key beach program
  OW   2.1.3       beaches that are monitored and managed under                      beaches as the ones they monitor, so we will always
                                                                       D, D                                                                                                  measure
                   the BEACH Act program.                                            report 100% for this measure, rendering it
                                                                                     meaningless.

                   2.2.1a - Use both pollution prevention and                        R2 - 2.2.1a and b - should be deleted: These measures will
                   restoration approaches to increase watersheds       2,7           be replaced by alternative measures for watershed wide     Delete
  OW   2.2.1
                   where water quality standards are met in at least   D, D          improvement in the new strategic plan. 2.2.1a is linked to
                   80% of the assessed water segments.                               the FY 07 Annual Performance Measure.
                                                                                     R7 - Removed in new Strategic Plan.


                                                                                     R2 - 2.2.1a and b - should be deleted: These measures will
                   2.2.1b - Use both pollution prevention and                        be replaced by alternative measures for watershed wide
                   restoration approaches to increase the number of                  improvement in the new strategic plan.
                   the watersheds where all assessed water             2,7           2.2.1b is NOT linked to any of the following measures;     Delete
  OW   2.2.1
                   segments maintain their quality and at least 20% of D, D          PART, FY 07 State Grant Template, FY 07 Annual
                   assessed water segments show improvement                          Performance Measure, FY 06 Regional Priority Measure,
                   above conditions as of 2002.                                      nor the FY 06 Regional Organizational Assessment
                                                                                     Measure.
                                                                                     R7 - Removed in new Strategic Plan.




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                                                                      recommen
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                                                                                                                                                                                               Public comment on the
                                                                                                                                                                                               draft Strategic Plan
                                                                                                                                           SP-10                                               including Strategic plan
                   L - Number and national percent of those
                                                                                                                                           By 2012 attain water quality standards for all      measures was from May 31
                   waterbodies identified in 2000 as not attaining    7
  OW   2.2.1                                                                                                                               pollutants and impairments in more than 2,250       to July 17. Since strategic
                   standards where water quality standards are        M
                                                                                                                                           water bodies identified in 2002 as not attaining    plan measures are now
                   restored. (cumulative)
                                                                                                                                           standards. (cumulative)                             final, the Agency cannot
                                                                                                                                                                                               make changes to the
                                                                                                                                                                                               measure text
                                                                                 Baseline revised in new strategic plan



                                                                                 R5 - This is a PART measure so it can‟t be changed,
                                                                                 but we‟d like to send the comment, if possible.
                                                                                 Most tribes have not operated long term stationary
                                                                                 monitoring programs and thus have little data to report
                                                                                 on trends. We have to rely on USGS stations that are
                                                                                 located on tribal land for the data and there are very
                                                                                 few of those. Considering the paucity of data for this
                                                                                 measure and that it will take years for the tribes to                                                         Public comment on the
                                                                                                                                           SP-14
                                                                                 build up a database sufficient to detect trends, this                                                         draft Strategic Plan
                                                                                                                                           By 2012, improve water quality in Indian
                                                                                 measure won‟t tell us much.                                                                                   including Strategic plan
                                                                                                                                           country at not fewer than 50 baseline monitoring
                   N - Show improvement of at least 10% in each of               R6 - For FY08 program guidance, the text should be                                                            measures was from May 31
                                                                      5,6,7                                                                stations in tribal waters (i.e., show improvement
  OW   2.2.1       four key parameters at a number of the 900 water              revised to language in the 2006-2011 Strategic Plan -                                                         to July 17. Since strategic
                                                                      D, M, M                                                              in one or more of seven key parameters:
                   monitoring stations in tribal waters.                         Goal 2 (see page 40):                                                                                         plan measures are now
                                                                                                                                           dissolved oxygen, pH, water temperature, total
                                                                                 By 2012, improve water quality in Indian country at not                                                       final, the Agency cannot
                                                                                                                                           nitrogen, total phosphorus, pathogen indicators,
                                                                                 fewer than 50 baseline monitoring stations in tribal                                                          make changes to the
                                                                                                                                           and turbidity). (cumulative)
                                                                                 waters11 (cumulative) (i.e., show improvement in one                                                          measure text
                                                                                 or more of seven key parameters: dissolved oxygen,
                                                                                 pH, water temperature, total nitrogen, total
                                                                                 phosphorus, pathogen indicators, and turbidity). (2006
                                                                                 baseline: 185 monitoring stations on tribal waters
                                                                                 located where water quality has been depressed and
                                                                                 activities are underway or planned to improve water
                                                                                 quality, out of an estimated 1,661 stations operated by
                                                                                 tribes.)
                                                                                 R7 - Revised in new strategic plan
                                                                                                                                           SP-15
                                                                                                                                           By 2015, in coordination with other federal
                   O - Reduce the number of households on tribal
  OW   2.2.1                                                                                                                               agencies, reduce by 50 percent the number of
                   lands lacking access to basic santiation.
                                                                                                                                           homes on tribal lands lacking access to basic
                                                                                                                                           sanitation. (cumulative)

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       objective                                                      States & Recommendation                                            New Text
                                                                      recommen
                                                                      dation

                   WQ-01 - Number of new or revised pollutant
                   criteria documents published in draft or final by
                   Headquarters annually that assist states and tribes 4,5,9                                                             Delete
  OW   2.2.1
                   to better control water pollution through improved D, M, D
                   water quality standards and ecological/human                  This should be modified to drop the phrase “draft or”
                   health risk assessment under the Clean Water Act.             and only measure finalized documents to give impetus
                                                                                 to HQ to finalize criteria documents.




                                                                                 FS-1a, WQ-02a and SS-1a all reflect Agency priorities
                                                                                 that we have identified in the 2006 to 2011 EPA
                                                                                 Strategic Plan as measures that will result in human
                                                                                 health and/or environmental improvement. These are
                                                                                 the environmental priorities that are appropriately
                                                                                 spotlighted in our WQS measures. It is significant to
                   WQ-02a - Number of States and Territories that                note that although a state or territory may adopt                                     Key measure for standards
                                                                      3          nutrient criteria, fish tissue criterion for mercury or WQ-1a
  OW   2.2.1       have adopted EPA approved nutrient criteria into                                                                                                    development; nutrients are
                                                                      M          current pathogen criteria into its WQS, none of these
                   their water quality standards. (cumulative)                                                                                                         major water pollutant
                                                                                 criteria are effective for CWA purposes until EPA
                                                                                 approves the new or revised WQS. Therefore, EPA‟s
                                                                                 prompt action on the WQS, and approval if
                                                                                 appropriate, is the measure that we endorse for FS-
                                                                                 1a, WQ-02a and SS-1. This also allows accountability
                                                                                 for the targets we identified as important for meeting
                                                                                 our goals, as well as allowing us some accountability
                                                                                 for our CWA statutory responsibilities. Our statutory
                                                                                 requirement is to act promptly not to approve
                                                                                 promptly.
                                                                                 This measure, as is, fails to account for states that are
                   WQ-02b - Number of States/Territories that are on
                                                                                 developing numeric nutrient criteria under a plan that                                Key measure for standards
                   schedule with a mutually agreed-upon plan to      7                                                                     WQ-1b
  OW   2.2.1                                                                     isn‟t mutually agreed-upon by the state and EPA.                                      development; nutrients are
                   adopt nutrient criteria into their water quality  M
                                                                                 Deletion of the words “mutually agreed-upon” from the                                 major water pollutant
                   standards. (annual)
                                                                                 PAM would remedy this situation.




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                                                                      recommen
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                                                                                      R5 - This measure does not adequately differentiate
                                                                                      between basic and advanced programs. Considering
                                                                                      that a biocriteria program is complex and takes years
                                                                                      to develop, this measure should be modified to
                                                                                      measure completion of the interim steps on the path to
                                                                                      a high quality biocriteria program. The first step is to
                                                                                      set a baseline and assess the states using the
                                                                                      national critical elements guidance. We suggest the
                                                                                      PAM be modified to be: Number of States assessed
                   WQ-03 - Number of States and Territories that
                                                                                      against the Critical Technical Elements of a
                   have incorporated into their water quality programs 4,5,8,9,10, IL
                                                                                      Bioassessment Program. After the baseline is set, in Delete
  OW   2.2.1       for streams and small rivers, quantitative biological D, M, D, D,
                                                                                      future years, the PAM can be the number of States
                   criteria that are used to help assess attainment of D, D
                                                                                      with bioassessment programs at certain levels, or
                   water quality standard. (cumulative)
                                                                                      movement from one level to the next.
                                                                                      R8 - Regions already negotiate this in PPAs and
                                                                                      assessment programs methodologies. A program
                                                                                      expectation which is too specific for ACS.
                                                                                      IL - State water programs have approximately 180
                                                                                      program activity measures. Need to distill down to the
                                                                                      most important ones. These measures are not used
                                                                                      for any other purpose (like PART or grant template)
                                                                                      and could be eliminated




                                                                                    Not a PART measure and does not lend itself to
                   WQ-04 - Number of Tribes that have water quality   5             reliable targets/commitments. If retained in any form, WQ-2
  OW   2.2.1                                                                                                                                                             Key measure for tribes
                   standards approved by EPA. (cumulative)            D             it should be an indicator tracked internally by
                                                                                    programs.




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       objective                                                         States & Recommendation                                                New Text
                                                                         recommen
                                                                         dation
                                                                                    R3 - Our initial preference was to delete WQ-05a as a
                                                                                    strictly bean counting measure as well, but there may
                                                                                    be state or territory issues that require new or revised
                                                                                    water quality criteria to effect human health or
                                                                                    environmental benefits. However, holding states and
                                                                                    territories to a strict 3 year time table does not
                                                                                    enhance our collaborative relationship with our state
                                                                                    partners, and can even interfere with a good working
                                                                                    relationship. The CWA indicates that a state shall
                                                                                    from time to time, but at least once each 3 year
                                                                                    period, hold public hearings for the purpose of             WQ-3a
                   WQ-05a - Number of States and Territories that                   reviewing applicable WQS and, as appropriate,               Number, and national percent, of States and
                   within the preceding three year period, submitted                modifying and adopting standards.                           Territories that within the preceding three year
                   new or revised water quality criteria acceptable to   3,6        We suggest that WQ-05a be rewritten to read as              period, submitted new or revised water quality     Key water quality standards
  OW   2.2.1                                                                        follows: “Number of States and Territories that have,
                   EPA that reflect new scientific information from      M, M                                                                   criteria acceptable to EPA that reflect new        measure.
                   EPA or other resources not considered in the                     within 3 years of EPA‟s action on the previous WQS          scientific information from EPA or other
                   previous standards.                                              submittal, held public hearings for the purpose of          resources not considered in the previous
                                                                                    reviewing applicable WQS and, as appropriate,               standards.
                                                                                    modifying and adopting standards”.
                                                                                    This language tracks closer to the CWA mandate by
                                                                                    requiring states and territories to review their existing
                                                                                    standards, but to provide discretion to the states and
                                                                                    territories for WQS modifications, as appropriate. F
                                                                                    Region 3 does not have any tribes, but we would
                                                                                    recommend that corresponding tribal measures also
                                                                                    be modified as indicated above.or example, it may be
                                                                                    beneficial to await standards modifications until further
                                                                                    development of criteria or use attainability analysis is

                                                                                                                                                WQ-3b
                   WQ-05b - Number of authorized Tribes that within                                                                             Number, and national percent, of authorized
                   the preceding three year period, submitted new or                                                                            Tribes that within the preceding three year
                   revised water quality criteria acceptable to EPA                                                                             period, submitted new or revised water quality
  OW   2.2.1
                   that reflect new scientific information from EPA or                                                                          criteria acceptable to EPA that reflect new
                   other resources not considered in the previous                                                                               scientific information from EPA or other
                   standards.                                                                                                                   resources not considered in the previous
                                                                                                                                                standards.




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                                                                         recommen
                                                                         dation




                                                                                      Region 3 believes that WQ-06a [i.e., Percent of State
                                                                                      and Territorial water quality submissions (received in
                   WQ-06a - Percent of States and Territorial water                   the 12 month period ending April 30th of the fiscal       WQ-4a
                   quality standards submissions (received in the 12                  year) that are approved by EPA] should be deleted         Percent of State and Territorial water quality
                                                                         3            because it is a tracking measure that commits the                                                           Key water quality standards
  OW   2.2.1       month period ending April 30th of the fiscal year)                                                                           standards submissions (received in the 12 month
                                                                         D            region to „approval‟ of WQS in many cases before the                                                        measure.
                   that are approved by EPA. Partial approvals                                                                                  period ending April 30th of the fiscal year) that
                   receive fractional credit.                                         public participation is conducted. Clearly this casts a   are approved by EPA.
                                                                                      shadow on the value of the public input process by
                                                                                      expressing a regional „bias‟ towards approving the
                                                                                      water quality standard. We feel that there are better
                                                                                      ways of illustrating our efforts to meet the statutory
                                                                                      requirements of the CWA than by counting a bean.



                                                                                      This measure places too much emphasis on approval.
                   WQ-06b - Percent of Tribal water quality standards                 EPA completes its work if it either approves or
                                                                                      disapproves and promulgates. If we focus solely on        WQ-4b
                   submissions (received in the 12 month period
                                                                                      approvals, we create a disincentive to disapprovals.      Percent of Tribal water quality standards
                   ending April 30th of the fiscal year) that are     5                                                                                                                          Key measure of regional
  OW   2.2.1                                                                          In some instances, disapprovals are an appropriate        submissions (received in the 12 month period
                   approved by EPA. Partial approvals receive         M                                                                                                                          performance
                                                                                      and environmentally protective response to non-           ending April 30th of the fiscal year) that are
                   factional credit.
                                                                                      protective WQS submitted by a state or tribe. This        approved by EPA.
                                                                                      measure should be modified by adding “or
                                                                                      disapproved” into the measure. As written, the
                                                                                      implication of this PAM is that a higher percentage of
                                                                                      approvals/FY is better. This isn't always the case.
                                                                                      R3 - Region III has reached full coverage in the
                   WQ-07 - Number of States and Territories that
                                                                                      number of States implementing monitoring strategies.
                   have adopted and are implementing their               3,7,9,10                                                             WQ-5                                               Key measure of monitoring
  OW   2.2.1                                                                          No longer needed as a measure.
                   monitoring strategies in keeping with esablished      D, D, D, D                                                                                                              program progress.
                                                                                      R7 - Vast majority of states/territories comply (54 vs.
                   schedules.
                                                                                      2008 target of 56).
                   WQ-08a - Number of Tribes that currently receive
                   funding under Section 106 of the Clean Water Act
                   that have developed and begun implementing            9,10                                                                   WQ-6a
  OW   2.2.1                                                                                                                                                                                     Key tribal measure
                   monitoring strategies that are appropriate to their   D, D
                   water quality program consistent with EPA
                   Guidance.




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       objective                                                       States & Recommendation                                           New Text
                                                                       recommen
                                                                       dation

                                                                                                                                         WQ-6b
                   WQ-08b - Number of Tribes that are providing                                                                          Number of Tribes that currently receive funding
                                                                       9,10
  OW   2.2.1       water quality data in a format accessible for                                                                         under Section 106 of the Clean Water Act that Key tribal measure
                                                                       D, D
                   storage in EPA's data system.                                                                                         are providing water quality data in a format
                                                                                                                                         accessible for storage in EPA's data system.

                   WQ-09 - Number of national probabilistic
                                                                       4,8,9                                                             Delete
  OW   2.2.1       monitoring assessments completed.
                                                                       D, D, D
                                                                                      R8 - Headquarters tracks.


                                                                                      R4, 9 - FMFIA measure (possible combination with
                                                                                      WQ-11)
                                                                                      R5 - This is a measure of the States monitoring
                                                                                      programs and not the Regions. Since States aren‟t
                                                                                      required to submit integrated reports in odd-numbered
                                                                                      years, very few States will submit them and we don‟t
                                                                                      make it a priority to request the States to do them. If
                   WQ-10 - Number of States and Territories that                      this measure isn‟t deleted, it should only be included in
                   provide Integrated Reports consistent with EPA's    4,5,8,9, IL,   even-numbered years.
                   Guidance for Assessment, Listing, and Reporting     MS             R8 - Already in the PPAs and found in the NAD. HQ Delete
  OW   2.2.1
                   requirements pursuant to Sections 303(d), 305(b),   D, D, D, D,    program is closely involved in the activity, making this
                   and 314 of the Clean Water Act. (cumulative)        D, M           measure redundant.
                                                                                      IL - State water programs have approximately 180
                                                                                      program activity measures. Need to distill down to the
                                                                                      most important ones. These measures are not used
                                                                                      for any other purpose (like PART or grant template)
                                                                                      and could be eliminated
                                                                                      MS - Modify to allow the 303(d) to mesh with the basic
                                                                                      rotation plan. 20% a year with a complete statewide
                                                                                      list every 5 years.




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                                                                     recommen
                                                                     dation



                                                                                 R4 - There are currently two versions of ADB in use by
                                                                                 the States. This measure should be reworded to
                                                                                 make it clear if a specific version is required to be
                                                                                 used or if either version is acceptable. Also, one of
                                                                                 our States uses a watershed approach to conducting
                                                                                 and recording assessments rather than a segment
                                                                                 approach. The guidance for this measure should
                   WQ-11 - Number of States and Territories using                make it clear that the watershed approach is                WQ-7
                   the Assessment Database (ADB) (or compatible                  acceptable and provide guidance on how geo-                 Number of States and Territories that provide
                   electronic format) to record their assessment                 reference information should be recorded. Also, this        electronic information using the Assessment
                                                                     4, IL, MS   measure should be changed to an indicator since it                                                              Geographic data needed to
  OW   2.2.1       decisions (Integrated Report/303(d)/305(b)) and                                                                           Database version 2 or later (or compatible
                                                                     M, D, D     has no environmental or programmatic outcome                                                                    meet PART measures
                   provide geo-referencing information for                                                                                   system) and georeference the information to
                   assessment unit locations. (cumulative)                       associated with it. As long as a State is able to           facilitate the integrated reporting of assessment
                                                                                 accurately report their 305(b)/303(d) information, it       data. (cumulative)
                                                                                 makes little difference if they used ADB or some other
                                                                                 system.
                                                                                 IL - State water programs have approximately 180
                                                                                 program activity measures. Need to distill down to the
                                                                                 most important ones. These measures are not used
                                                                                 for any other purpose (like PART or grant template)
                                                                                 and could be eliminated
                                                                                 It is a burden to Integrate these reports and comply
                                                                                 with the Fed. Consent agreement. Inegration should
                                                                                 be postponed until the TMDL C.D. is finished.
                   WQ-12 - Number of methods developed or
                   validated for new or emerging biological or       4,9                                                                     Delete
  OW   2.2.1
                   chemical contaminants.                            D
                                                                                 R4, R9 - HQ reports data nationally
                   WQ-13a - Number of TMDLs, and national percent,
                                                                   5                                                                         WQ-8a                                               Percent needed to provide
  OW   2.2.1       that are established by States or EPA on a                    This should be reported as a number, not as a
                                                                   M                                                                                                                             context.
                   schedule consistent with national policy.                     percent.


                                                                                 R2 - Region 2 suggests that this commitment take into
                                                                                 account TMDLs submitted by the states that are
                   WQ-13b - Number of TMDLs, and national percent,               disapproved and established by EPA. Once EPA
                                                                   2,5                                                                          WQ-8b                                            Needed to meet PART/
  OW   2.2.1       that are established by States on a schedule                  disapproves a TMDL it is no longer being established and
                                                                   M, D                                                                                                                          grant commitments
                   consistent with national policy.                              approved consistent with state/EPA schedules consistent
                                                                                 with national policy (8-13 years to establish TMDLs).
                                                                                 R5 - 13b is exactly like 13a except it doesn't include Federal
                                                                                 TMDL tracking.

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                                                                      recommen
                                                                      dation

                   WQ-14 - Number of TMDLs for impaired                               R5 - Non-PART indicator
                   waterbodies which affect Tribal waters approved by                 R7 - This PAM tracks no tangible environmental
                   EPA where the Tribe participated in the TMDL or    4,5,7,8,9       impact; it is an administrative measure only.           Delete
  OW   2.2.1
                   comparable watershed restoration planning          D, D, D, D, D   R8 - Premature measure for tribal programs or
                   process.                                                           state/tribal relationships. Not a clear strategic
                                                                                      advantage created by this measure.


                                                                                      MT - Provide guidance to ensure consistent reporting
                   WQ-15a - Estimated annual reduction in million
                                                                      MT              by States. SDWIS Fed should be modified to extract      WQ-9a                         Key measure of program
  OW   2.2.1       pounds of nitrogen from nonpoint sources to
                                                                      D               this data so States do not have to spend time and                                     results.
                   waterbodies (Section 319 funded projects only).
                                                                                      funds procuring data that should be available to EPA.
                                                                                      It is expensive, not useful, and time consuming.


                                                                                      MT - Provide guidance to ensure consistent reporting
                   WQ-15b - Estimated annual reduction in million
                                                                      MT              by States. SDWIS Fed should be modified to extract      WQ-9b                         Key measure of program
  OW   2.2.1       pounds of phosphorus from nonpoint sources to
                                                                      D               this data so States do not have to spend time and                                     results.
                   waterbodies (Section 319 funded projects only).
                                                                                      funds procuring data that should be available to EPA.
                                                                                      It is expensive, not useful, and time consuming.


                                                                                      MT - Provide guidance to ensure consistent reporting
                   WQ-15c - Estimated annual reduction in million
                                                                      MT              by States. SDWIS Fed should be modified to extract      WQ-9c                         Key measure of program
  OW   2.2.1       pounds of tons of sediment from nonpoint sources
                                                                      D               this data so States do not have to spend time and                                     results.
                   to waterbodies (Section 319 funded projects only).
                                                                                      funds procuring data that should be available to EPA.
                                                                                      It is expensive, not useful, and time consuming.




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       objective                                                       States & Recommendation                                              New Text
                                                                       recommen
                                                                       dation




                                                                                   R5 - The criteria for reporting on this measure (i.e,
                                                                                   statistically significant changes based on existing
                                                                                   baseline data) assumes that we have substantial data
                                                                                   on every waterbody that we are trying improve. This
                                                                                   unflexible criteria for reporting precludes us being able
                   WQ-16 - Number of waterbodies identified by                     to show progress on many waters where we may other
                   States (in 2000 or subsequent years) as being       5, MI, MA   wise be able to report improvement.                        WQ-10                                           Key measure of program
  OW   2.2.1
                   primarily NPS-impared that are partially or fully   M, D, D     MI - Extremely difficult to identify, guidance non                                                         results.
                   restored. (cumulative)                                          existent.
                                                                                   MA - It is not clear if this information is expected to be
                                                                                   provided by the states in a new report. Currently this
                                                                                   information is provided within reports submitted to
                                                                                   EPA. Information can be culled from those reports by
                                                                                   EPA and cross referenced with the 2000 list. If an
                                                                                   additional report is expected to be submitted by the
                                                                                   States, then this will result in duplicate data
                                                                                   submission and is a reporting burden.


                                                                                   R5 - (PER follow-up) Most activities are completed.
                                                                                   R7 - The measure does not show any direct impact on
                                                                                   the environment.
                                                                                                                                            WQ-11                                             Follow-up actions critical to
                   WQ-17 - Number, and national percent, of follow- 5,7,8,9,10,    IL - State water programs have approximately 180
                                                                                                                                            Number, and national percent, of follow-up        assessing NPDES program
                   up actions that are completed by assessed NPDES IL, SC          program activity measures. Need to distill down to the
  OW   2.2.1                                                                                                                                actions that are completed by assessed National   integrity in response to
                   programs. (cumulative)                           D, D, D, D,    most important ones. These measures are not used
                                                                                                                                            Pollutant Discharge Elimination System            citizen program withdrawl
                                                                    D, D, D        for any other purpose (like PART or grant template)
                                                                                                                                            (NPDES) programs. (cumulative)                    petitions.
                                                                                   and could be eliminated
                                                                                   SC - Seems like a meaningless measure. What is a
                                                                                   follow-up action?



                                                                                                                                                                                              Public comment on the
                                                                                                                                                                                              draft Strategic Plan
                                                                                                                                                                                              including Strategic plan
                   WQ-18a - Number, and national percent, of non-                                                                                                                             measures was from May 31
                                                                       5                                                                    WQ-12a
  OW   2.2.1       tribal NPDES permits that are considered current.                                                                                                                          to July 17. Since strategic
                                                                       D
                                                                                                                                                                                              plan measures are now
                                                                                                                                                                                              final, the Agency cannot
                                                                                   (State permit backlog) Can be tracked within the                                                           make changes to the
                                                                                   program as indicator, not commitment, no more than                                                         measure text
                                                                                   annual input from region to OWM

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       objective                                                      States & Recommendation                                             New Text
                                                                      recommen
                                                                      dation

                   WQ-18b - Number, and national percent, of tribal
                                                                                                                                          WQ-12b
  OW   2.2.1       permits that are considered current.

                   WQ-19a - Number, and national percent, of Phase
                   I and Phase II stormwater permits that are issued              R5 - (Industrial Storm water permit reissuance) This
                                                                     4,5,8,9                                                              Delete
  OW   2.2.1       and current for industrial stormwater general                  has little or no value, as permits can be rolled over
                                                                     D, D, D, D
                   permits.                                                       with no changes.
                                                                                  R8 - If needed, capture in measure WQ-20b
                                                                                  R5 - (Construction storm water permit reissuance)
                   WQ-19b - Number, and national percent, of Phase                This is somewhat more useful than the previous
                   I and Phase II stormwater permits that are issued              measure, as current permits must be maintained to
                                                                     4,5,8,9      allow for permitting of new construction projects. Can Delete
  OW   2.2.1       and current for construction stormwater general
                                                                     D, D, D, D   be tracked within the program as indicator, not
                   permits.
                                                                                  commitment, no more than annual input from region to
                                                                                  OWM
                                                                                  R8 - If needed, capture in measure WQ-20c
                   WQ-19c - Number, and national percent, of Phase                R5 - (MS4 permit issuance/reissuance) Can be
                   I and Phase II stormwater permits that are issued              tracked within the program as indicator, not
                                                                     4,5,8,9                                                           Delete
  OW   2.2.1       and current for MS-4 general and individual                    commitment, no more than annual input from region to
                                                                     D, D, D, D
                   permits.                                                       OWM
                                                                                  R8 - If needed, capture in measure WQ-20a


                                                                                    R5 - (# of facilities covered under industrial storm
                                                                                    water permits)
                   WQ-20a - Number, and national percent, of                        IL - State water programs have approximately 180
                   facilities covered under either an individual or   5,9,10, IL,   program activity measures. Need to distill down to the
                                                                                    most important ones. These measures are not used WQ-13a                             Key measure for
  OW   2.2.1       general permit by MS-4s (including co-             SC
                                                                                                                                                                        stormwater program.
                   permitees).                                        D, D, D, D, D for any other purpose (like PART or grant template)
                                                                                    and could be eliminated
                                                                                    SC - Overkill. Already have permits issued and
                                                                                    current. However, if this is transparent to the states,
                                                                                    i.e. EPA pulls from data systems, then it doesn't seem
                                                                                    to matter.




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       objective                                                       States & Recommendation                                             New Text
                                                                       recommen
                                                                       dation


                                                                                     R5 - (# of facilities covered under industrial storm
                                                                                     water permits)
                                                                                     IL - State water programs have approximately 180
                   WQ-20b - Number, and national percent, of                         program activity measures. Need to distill down to the
                                                                       5,9,10, IL,
                   facilities covered under either an individual or                  most important ones. These measures are not used WQ-13b                             Key measure for
  OW   2.2.1                                                           SC
                   general permit by industrial storm water permits.                                                                                                     stormwater program.
                                                                       D, D, D, D, D for any other purpose (like PART or grant template)
                                                                                     and could be eliminated
                                                                                     SC - Overkill. Already have permits issued and
                                                                                     current. However, if this is transparent to the states,
                                                                                     i.e. EPA pulls from data systems, then it doesn't seem
                                                                                     to matter.


                                                                                     R5 - (# of facilities covered under industrial storm
                                                                                     water permits)
                                                                                     IL - State water programs have approximately 180
                   WQ-20c - Number, and national percent, of           5,9,10, IL,   program activity measures. Need to distill down to the
                                                                                     most important ones. These measures are not used WQ-13c                             Key measure for
  OW   2.2.1       facilities covered under either an individual or    SC
                                                                                                                                                                         stormwater program.
                   general permit by construction storm water permits. D, D, D, D, D for any other purpose (like PART or grant template)
                                                                                     and could be eliminated
                                                                                     SC - Overkill. Already have permits issued and
                                                                                     current. However, if this is transparent to the states,
                                                                                     i.e. EPA pulls from data systems, then it doesn't seem
                                                                                     to matter.


                                                                                     R5 - (Facilities under CAFO permits) Can be tracked
                                                                                     within the program as indicator, not commitment, no
                   WQ-20d - Number, and national percent, of                         more than annual input from region to OWM
                                                                       5,9,10, IL,
                   facilities covered under either an individual or                  IL - CAFO program becoming compliance-based             WQ-13d                      Key measure for
  OW   2.2.1                                                           SC
                   general permit by CAFOs.                                          rather than permit-based.                                                           stormwater program.
                                                                       D, D, D, D, D
                                                                                     SC - Overkill. Already have permits issued and
                                                                                     current. However, if this is transparent to the states,
                                                                                     i.e. EPA pulls from data systems, then it doesn't seem
                                                                                     to matter.
                   WQ-21a - Number, and national percent, of
                   Significant Industrial Users (SIUs) in POTWs with
                                                                                                                                                                         This is the only
                   Pretreatment Programs that have control             5,9                                                                 WQ-14a
  OW   2.2.1                                                                                                                                                             pretreatment program
                   mechanisms in place that implement applicable       D, D, D      R5 - Pretreatment workgroup is developing new
                                                                                                                                                                         measure.
                   pretreatment requirements.                                       measures for 2008. Track as indicator at program
                                                                                    level, no ACS commitment.


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       objective                                                   States & Recommendation                                             New Text
                                                                   recommen
                                                                   dation



                   WQ-21b - Number, and national percent, of                    R5 - Pretreatment workgroup is developing new
                   Categorical Industrial Users (CIUs) in non-                  measures for 2008. Track as indicator at program
                                                                                level, no ACS commitment.                                                            This is the only
                   pretreatment POTWs that have control            5,9,10, IL                                                          WQ-14b
  OW   2.2.1                                                                    IL - State water programs have approximately 180                                     pretreatment program
                   mechanisms in place that implement applicable   D, D, D, D
                                                                                program activity measures. Need to distill down to the                               measure.
                   pretreatment requirements.
                                                                                most important ones. These measures are not used
                                                                                for any other purpose (like PART or grant template)
                                                                                and could be eliminated


                                                                                R5 - Keep this but suggest that it be revised to better
                                                                                mirror the PART statistic which is calculated on a
                   WQ-22a - Percent of major dischargers in                     three year running average. Potential rewording is
                   Significant Noncompliance (SNC) at any time     5,6          “SNC rate for majors, calculated on as a three year     WQ-15a                       PART measure linked to
  OW   2.2.1
                   during the fiscal year.                         M, D         running average”. We would delete the number and                                     106 grant.
                                                                                just have the percentage as the PART statistic is only
                                                                                the percentage, and the number, in and of itself,
                                                                                doesn‟t tell us much
                                                                                R6 - better tracked through OECA measures



                                                                                R5 - We expect that the degree to which the majors
                                                                                are both in SNC and the pollutant discharged is one
                                                                                which is a pollutant of concern on an impaired water is
                                                                                really a pretty small universe. As it is we are at a 17%
                                                                                SNC rate for majors, and I think about half of this is for
                                                                                late reporting. A subset of those having effluent
                   WQ-22b - Number, and national percent, of major              violations would be on listed waters. A further subset
                   dischargers in Significant Noncompliance (SNC)   5,6         would actually have had the violation be for a pollutant WQ-15b                      Key measure to restore
  OW   2.2.1
                   any time during the fiscal year, discharging the D, D        for which the waterbody is listed. It is a possibly                                  impaired waters.
                   pollutants of concern on impaired waters.                    interesting statistic, but not one which results in a
                                                                                useful management tool. If this remains, suggest it be
                                                                                an indicator only, and that the measure be reworded
                                                                                as follows: Percent of majors in SNC at any time
                                                                                during the fiscal year, where the SNC is associated
                                                                                with the discharge above permit limits, of a pollutant
                                                                                for which the receiving water has been listed as
                                                                                impaired.
                                                                                R6 - better tracked through OECA




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       objective                                                       States & Recommendation                                              New Text
                                                                       recommen
                                                                       dation

                   WQ-23 - Number, and national percent, of all major             R5 - This is not a PART statistic. If HQ wants to
                   publicly-owned treatment works (POTWs) that                    monitor this as an indicator, that is fine, but we
                   comply with their permitted wastewater discharge 5,6,7         shouldn‟t make an associated commitment, beyond          WQ-16                          Key measure of pollution
  OW   2.2.1                                                                      that which we make for the overall SNC rate under
                   standards (i.e. POTWs that are not in significant  D, D, D                                                                                             control.
                   non-compliance).                                               WQ 22a
                                                                                  R6 - better tracked through OECA
                                                                                  R7 - Seems to be a subset of WQ-22
                   WQ-24 - Fund utilization rate [cumulative loan
                   agreement dollars to the cumulative funds                                                                               WQ-17
  OW   2.2.1
                   available for projects] for the Clean Water State
                   Revolving Fund.




                                                                                  HQ-CWSRF is in discussions with OMB in regard to WQ-
                                                                                  25a and WQ-25b. At this time these two measures should
                                                                                  both be deleted. Both these measures attempt to treat a
                                                                                  $225 million wastewater treatment plant upgrade and a
                   WQ-25a - Number of waterbodies restored or                     $325,000 wastewater treatment plant upgrade as if they
                   improved per million dollars of CWSRF assistance 2             were the same. For example, for WQ-25a, a $225 million      WQ-18a                      Measures major Agency
  OW   2.2.1
                   provided.                                        D             project would result in an answer of 0.004 projects per                                 investment.
                                                                                  million, while a $325,000 project would result in an answer
                                                                                  of 3 projects per million. Combining these two projects
                                                                                  would result in an answer of 0.009 project per million.
                                                                                  None of these answers inform the public as to what the
                                                                                  CWSRF program is accomplishing. HQ-CWSRF is
                                                                                  attempting to have data from the environmental benefits
                                                                                  reporting system be used as measures in place of what is
                                                                                  currently being proposed for WQ-25a and WQ-25b.




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       objective                                                     States & Recommendation                                                   New Text
                                                                     recommen
                                                                     dation




                                                                                     HQ-CWSRF is in discussions with OMB in regard to WQ-
                                                                                     25a and WQ-25b. At this time these two measures should
                                                                                     both be deleted. Both these measures attempt to treat a
                                                                                     $225 million wastewater treatment plant upgrade and a
                   WQ-25b - Number of waterbodies protected per                      $325,000 wastewater treatment plant upgrade as if they
                                                                     2               were the same. For example, for WQ-25a, a $225 million      WQ-18b
  OW   2.2.1       million dollars of CWSRF assistance provided.                                                                                                             Key PART measure
                                                                     D               project would result in an answer of 0.004 projects per
                                                                                     million, while a $325,000 project would result in an answer
                                                                                     of 3 projects per million. Combining these two projects
                                                                                     would result in an answer of 0.009 project per million.
                                                                                     None of these answers inform the public as to what the
                                                                                     CWSRF program is accomplishing. HQ-CWSRF is
                                                                                     attempting to have data from the environmental benefits
                                                                                     reporting system be used as measures in place of what is
                                                                                     currently being proposed for WQ-25a and WQ-25b.
                   WQ-26 - EPA will work with water and wastewater
                   utilities and others to begin implementing a
                                                                     4,9                                                                       Delete
  OW   2.2.1       strategy for promoting sustainable management
                                                                     D, D
                   practices.


                   WQ-27 - Number of watershed-based plans
                   supported under State Nonpoint Source
                   Management Programs since the beginning of FY     4,5,8,9, MI                                                               Delete
  OW   2.2.1
                   2002 that have been substantially implemented.    D, D, D, D, D
                   (cumulative)                                                      R8 - Headquarters has agreed to drop this measure.
                                                                                     MI - No clear guidance on this one.


                   WQ-28 - Number of Tribes that have developed
                   and begun to implement a watershed based-plan     4,5,7,8,9     R7 - A better indicator would measure # of plans       Delete
  OW   2.2.1
                   for tribal waters.                                D, D, D, D, D implemented, similar to WQ-27 for states, instead of #
                                                                                   of tribes that have developed a plan. This is more of
                                                                                   an accounting measure and doesn‟t drive results.
                                                                                   R8 - Headquarters has agreed to drop this measure.

                   WQ-29a - Number, and national percent, of high
                                                                                     R5 - broaden definition to include all expired priority
                   priority state NPDES permits that are issued as   5, MI                                                                     WQ-19a                        Critical measure of program
  OW   2.2.1                                                                         permits, not just those expired 2 years or more
                   scheduled.                                        M, D                                                                                                    performance.
                                                                                     MI - Nonsensical for states that have eliminated their
                                                                                     permit backlog.

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       objective                                                      States & Recommendation                                               New Text
                                                                      recommen
                                                                      dation

                   WQ-29b - Number, and national percent, of high                                                                           WQ-19b
                   priority EPA non-tribal NPDES permits that are                                                                           Number, and national percent, of high priority
  OW   2.2.1
                   issued as scheduled.                                                                                                     EPA (including tribal) NPDES permits that are
                                                                                                                                            issued as scheduled.
                   WQ-29c - Number, and national percent of high
                   priority tribal NPDES permits that are issued as   4,8,9                                                                 Delete
  OW   2.2.1
                   scheduled.                                         D, D, D
                                                                                    R8 - Add into measure WQ-29b


                                                                                    R5 - (Permits with trading) Can be tracked within the
                                                                                    program as indicator, not commitment, no more than
                                                                                    annual input from region to OWM
                   WQ-30a - Number of permits providing for trading                 R7 - Total amount of pollution reduction due to trading                                                  Critical measure of
                   between the discharger and other water pollution   5,7, IL, MI   is more important than just the number of permits with WQ-20                                             progress in implementing
  OW   2.2.1
                   sources.                                           D, M, D, D    trades. Also, convert this measure into an indicator.                                                    this important program
                                                                                    IL - Trading and watershed-based permitting are not                                                      innovation.
                                                                                    related to program effectiveness or environmental
                                                                                    results.
                                                                                    MI - Not related to water quality improvement or
                                                                                    protection.



                                                                                    R5 - (Trades undertaken) Can be tracked within the
                                                                                    program as indicator, not commitment, no more than
                   WQ-30b - Number of dischargers that carried out
                                                                      4,5,7,8,9,10, annual input from region to OWM
                   trades in those permits provided for training                    R7 - If WQ-30a is modified than there is no need for
                                                                      IL                                                                    Delete
  OW   2.2.1       between the discharget and other water pollution
                                                                      D, D, D, D, this measure. The number of dischargers that carried
                   sources. (cumulative)                                            out trades does not provide any information about the
                                                                      D, D, D
                                                                                    environmental impact or benefits.
                                                                                    R8 - Measure of little value. Manage at regional level.
                                                                                    IL - Trading and watershed-based permitting are not
                                                                                    related to program effectiveness or environmental
                                                                                    results.




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       objective                                                         States & Recommendation                                                 New Text
                                                                         recommen
                                                                         dation


                                                                                       R5 - (Watershed permits) Can be tracked within the
                                                                                       program as indicator, not commitment, no more than
                                                                         4,5,7,8,9,10, annual input from region to OWM
                   WQ-31 - Number of current watershed-based                           R7 - The size of the watershed that is impacted by the Delete
                                                                         IL
  OW   2.2.1       permit(s) issued. (cumulative)
                                                                         D, D, M, D, permits is more important than just a number for the
                                                                         D, D, D       watershed based permits.
                                                                                       R8 - Measure of little value. Manage at regional level.
                                                                                       IL - Trading and watershed-based permitting are not
                                                                                       related to program effectiveness or environmental
                                                                                       results.


                   WQ-32 - Number of impaired watersheds (at the 12                                                                              SP-12
                   digit scale) where water quality conditions improve. 5,7,8        R5 - Retain as indicator – will become measure W in         By 2012, improve water quality conditions in   Measure developed by the
  OW   2.2.1
                   (cumulative)                                         Retain, D, D 2008, and is necessary to excuse OW/Regions from            250 impaired watersheds nationwide using the   regions.
                                                                                     reporting on 2.2.1a and 2.2.1b
                                                                                                                                                 watershed approach. (cumulative)
                                                                                     R7 - Becomes a strategic target in new strategic plan
                                                                                     R8 - Headquarters has agreed to drop this measure.

                                                                                     R2 - It is not a key measure in any of the reporting formats,
                                                                                     and it is largely redundant with the TMDL approval
                                                                                     measures.
                                                                                     R3 - Indicator measure only – Region is not certain of the
                   WQ-33 - Number of water segments known to be                      value of this measure
                   impaired or threatened for which States and EPA                   R7 - This measure just tracks plans (TMDLs and Watershed
                   agree that initial restoration planning is complete               Plans); isn’t Measure L, which tracks actual restoration                                                   Critical measure of
                   (e.g. EPA has approved all needed TMDLs for         2,3,7,8,9, IL more relevant to our effort?
                                                                                                                                                   WQ-21                                        progress towards
  OW   2.2.1       pollutants causing impairments to the waterbody or D, D, D, M, R8 - We have never sufficiently understood this measure, or
                                                                                                                                                                                                restoration of impaired
                   has approved a 303(d) list that recognizes that the D, IL         how to apply and evaluate it, if other plans besides                                                       waters.
                   waterbody is covered by a Watershed Plan                          TMDLS/4Bs are acceptable. HQ has agreed to look at
                   (Category 4/B)). (cumulative)                                     clarifying the measure.
                                                                                     IL - State water programs have approximately 180 program
                                                                                     activity measures. Need to distill down to the most
                                                                                     important ones. These measures are not used for any other
                                                                                     purpose (like PART or grant template) and could be
                                                                                     eliminated




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       objective                                                         States & Recommendation                                          New Text
                                                                         recommen
                                                                         dation

                                                                                                                                          Modify
                                                                                                                                          Subobjective 2.2.2 Improve Coastal and Ocean
                   2.2.2 - Improve national and regional coastal                                                                          Waters - By 2011, prevent water pollution and
  OW   2.2.2       aquatic system health on the "good/fair/poor" scale                                                                    protect coastal and ocean systems to improve
                   of the National Coastal Condition Report.                                                                              national coastal aquatic ecosystem health on the
                                                                                                                                          "good/fair/poor" scale of the National Coastal
                                                                                                                                          Condition Report.

                   CO-01 - Headquarters to publish a revised national
                                                                      4,9                                                                 Delete
  OW   2.2.2       Coastal Condition Report describing the quality of
                                                                      D, D
                   the Nation's ocean and coastal waters.

                                                                                    IL - State water programs have approximately 180
                                                                                    program activity measures. Need to distill down to the
                   CO-02 - Number of coastal waterbody impairments 9,10, IL                                                                CO-1                                              Key measure of costal
  OW   2.2.2                                                                        most important ones. These measures are not used
                   restored                                        D, D, D                                                                                                                   water improvements.
                                                                                    for any other purpose (like PART or grant template)
                                                                                    and could be eliminated


                                                                                    IL - State water programs have approximately 180
                   CO-03 - Number of coastline miles protected from                 program activity measures. Need to distill down to the                                                   Key measure of control of
                                                                         9,10, IL                                                          CO-2
  OW   2.2.2       vessel sewage by "no discharge zone(s)."                         most important ones. These measures are not used                                                         key source of costal
                                                                         D, D, D
                   (cumulative)                                                     for any other purpose (like PART or grant template)                                                      nutrients.
                                                                                    and could be eliminated



                                                                                 R4, R9 - Drop - Tentative
                                                                                 R2 - Existing GIS and data base capability is not
                   CO-04 - Number of coastal waterbody impairments 2,4,9,10, IL available.                                              Delete
  OW   2.2.2
                   restored within NEP study areas.                D, D, D, D, D IL - State water programs have approximately 180
                                                                                 program activity measures. Need to distill down to the
                                                                                 most important ones. These measures are not used
                                                                                 for any other purpose (like PART or grant template)
                                                                                 and could be eliminated




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                                                                       recommen
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                                                                                     IL - State water programs have approximately 180
                                                                                     program activity measures. Need to distill down to the
                                                                                     most important ones. These measures are not used
                                                                                     for any other purpose (like PART or grant template)
                   CO-05a - Number of National Estuary Program         4,9,10, IL,   and could be eliminated
                   priority actions in Comprehensive Conservation      TX            TX - Region 6 requires TCEQ‟s Galveston Bay              Delete
  OW   2.2.2
                   Management Plans (CCMPs) that have been             D, D, D, D,   Estuary Program (GBEP) to provide an annual report
                   intiated in the current reporting year.             M             of activities, two semi-annual reports, an annual report
                                                                                     for the Government Performance & Results Act
                                                                                     (GPRA), and an annual report for the Program
                                                                                     Assessment Rating Tool (PART) review, relating to
                                                                                     estuary program activities. Each type report requests
                                                                                     somewhat different things.


                                                                                     IL - State water programs have approximately 180
                                                                                     program activity measures. Need to distill down to the
                                                                                     most important ones. These measures are not used
                                                                                     for any other purpose (like PART or grant template)
                   CO-05b - Number of National Estuary Program                       and could be eliminated                                                                This measures collective
                   priority actions in Comprehensive Conservation      9, IL, TX     TX - Region 6 requires TCEQ‟s Galveston Bay              CO-3
  OW   2.2.2                                                                                                                                                                progress under NEP
                   Management Plans (CCMPs) that have been             D, D, M       Estuary Program (GBEP) to provide an annual report                                     projects.
                   completed. (cumulative)                                           of activities, two semi-annual reports, an annual report
                                                                                     for the Government Performance & Results Act
                                                                                     (GPRA), and an annual report for the Program
                                                                                     Assessment Rating Tool (PART) review, relating to
                                                                                     estuary program activities. Each type report requests
                                                                                     somewhat different things.
                   CO-06 - Rate of return on Federal investment for
                   the National Estuary Programs [dollar value of
                   "primary" leveraged resources (cash or in-kind)
                                                                                                                                                                            Key measure of multiplying
                   divided by Section 320 funds received by the        9, IL         IL - State water programs have approximately 180       CO-4
  OW   2.2.2                                                                                                                                                                inpact of Federal NEP
                   National Estuary Programs (including                D, D          program activity measures. Need to distill down to the                                 investment.
                   supplemental, line items, earmarks, and (for LIS)                 most important ones. These measures are not used
                   Sections 119)]                                                    for any other purpose (like PART or grant template)
                                                                                     and could be eliminated


                                                                                     IL - State water programs have approximately 180                                       Key measure of
                   CO-07 - Number of dredged material management IL                  program activity measures. Need to distill down to the CO-5                            cooperative work with Army
  OW   2.2.2
                   plans that are in place for major ports and harbors. D            most important ones. These measures are not used                                       Corps of Engineers to
                                                                                     for any other purpose (like PART or grant template)                                    protect costal waters.
                                                                                     and could be eliminated
                                                                                                 Page 43           OW Lead Region 4 is in agreement with OW's proposed list of measures
                                                                                                  DRAFT

                                      Assessment of Measures Review Initiative Results for Goal 2
NPM    Sub-        Note: Cell entries below are hypothetical
                   FY 07 ACS Commitment Code & Text                        Regions & Region or State Explanation for                          NPM response, new code, and                      NPM Rationale
       objective                                                           States & Recommendation                                            New Text
                                                                           recommen
                                                                           dation


                   CO-08a - Number of active dredged material ocean                   IL - State water programs have approximately 180                                                         Key measure of
                   dumping sites that are monitored in the reporting IL               program activity measures. Need to distill down to the CO-6                                              cooperative work with Army
  OW   2.2.2
                   year.                                             D                most important ones. These measures are not used                                                         Corps of Engineers to
                                                                                      for any other purpose (like PART or grant template)                                                      protect costal waters.
                                                                                      and could be eliminated

                   CO-08b - Number of active dredged material ocean
                                                                                      IL - State water programs have approximately 180
                   dumping sites where action has been initiate in the
                                                                       4,9,10, IL     program activity measures. Need to distill down to the Delete
  OW   2.2.2       reporting year to ensure that the site meets
                                                                       D, D, D, D     most important ones. These measures are not used
                   environmentally acceptable conditions.
                                                                                      for any other purpose (like PART or grant template)
                                                                                      and could be eliminated

                                                                                                                                             SP-20
                   CO-09 - Number of active dredged material ocean
                                                                                                                                             Percent of active dredged material ocean          Key measure of
                   dumping sites achieving environmentally                            IL - State water programs have approximately 180
                                                                      IL                                                                     dumping sites that will have achieved             cooperative work with Army
  OW   2.2.2       acceptable conditions (as reflected in each site's                 program activity measures. Need to distill down to the environmentally acceptable conditions (as
                                                                      D                                                                                                                        Corps of Engineers to
                   Site Management Plan) in the reporting year.                       most important ones. These measures are not used
                                                                                                                                             reflected in each site's management plan and      protect costal waters.
                                                                                      for any other purpose (like PART or grant template)
                                                                                                                                             measured through on-site monitoring programs).
                                                                                      and could be eliminated

                   P - Maintain water clarity and dissolved oxygen in
                                                                                                                                              Delete
  OW   2.2.2       coastal waters at the national levels reported in the
                   2002 National Coastal Condition Report.

                   Q1 - Improve ratings reported on the national
                                                                                                                                              Delete
  OW   2.2.2       "good/fair/poor" scale of the National Coastal
                   Condition Report for coastal wetlands loss.

                   Q2 - Improve ratings reported on the national
                                                                                                                                              Delete
  OW   2.2.2       "good/fair/poor" scale of the National Coastal
                   Condition Report for contamination of sediments.

                   Q3 - Improve ratings reported on the national
                                                                                                                                              Delete
  OW   2.2.2       "good/fair/poor" scale of the National Coastal
                   Condition Report for benthic quality.
                   Q4 - Improve ratings reported on the national
                                                                                                                                              Delete
  OW   2.2.2       "good/fair/poor" scale of the National Coastal
                   Condition Report for eutrophic conditions.
                                                                                                                                              New
                                                                                                                                              By 2011, 90 percent of the community water
  OW   2.1.1       SP-1 -                                                                                                                     systems will provide drinking water that meets
                                                                                                                                              all applicable health-based drinking water
                                                                                                                                              standards.

                                                                                                  Page 44          OW Lead Region 4 is in agreement with OW's proposed list of measures
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                                   Assessment of Measures Review Initiative Results for Goal 2
NPM    Sub-        Note: Cell entries below are hypothetical
                   FY 07 ACS Commitment Code & Text            Regions & Region or State Explanation for             NPM response, new code, and                            NPM Rationale
       objective                                               States & Recommendation                               New Text
                                                               recommen
                                                               dation

                                                                                                                     New
                                                                                                                     Subobjective 2.1.3 Water Safe for Swimming -
  OW   2.1.2       -
                                                                                                                     By 2011, improve the quality of recreation
                                                                                                                     waters.

                                                                                                                     New
                                                                                                                     By 2011, the number of waterborne disease
                                                                                                                     outbreaks attributable to swimming in or other
  OW   2.1.2       SP-6 -
                                                                                                                     recreational contact with coastal and Great
                                                                                                                     Lakes waters will be maintained at two,
                                                                                                                     measured as a 5-year average.

                                                                                                                     New
                                                                                                                     Subobjective 2.1.3 Water Safe for Swimming -
  OW   2.1.3       -
                                                                                                                     By 2011, improve the quality of recreation
                                                                                                                     waters.

                                                                                                                     New
                                                                                                                     By 2011, the number of waterborne disease
                                                                                                                     outbreaks attributable to swimming in or other
  OW   2.1.3       SP-8 -
                                                                                                                     recreational contact with coastal and Great
                                                                                                                     Lakes waters will be maintained at two,
                                                                                                                     measured as a 5-year average.

                                                                                                                     New
                                                                                                                     Subobjective 2.2.1 Improve Water Quality on a
                                                                                                                     Watershed Basis - By 2012, use pollution
  OW   2.2.1       -
                                                                                                                     prevention and restoration approaches to protect
                                                                                                                     the quality of rivers, lakes, and streams on a
                                                                                                                     watershed basis.

                                                                                                                     New
                                                                                                                     By 2012, remove at least 5,600 of the specific
  OW   2.2.1       SP-11 -
                                                                                                                     causes of waterbody impairment identified by
                                                                                                                     states in 2002. (cumulative)

                                                                                                                     New
                                                                                                                     Through 2012, the condition of the nation's
                                                                                                                     wadeable streams does not degrade (i.e., there is
  OW   2.2.1       SP-13 -
                                                                                                                     no statistically significant increase in the percent
                                                                                                                     of streams rated "poor" and no statistically
                                                                                                                     significant decrease in the streams rated "good").


                                                                                   Page 45       OW Lead Region 4 is in agreement with OW's proposed list of measures
                                                                                   DRAFT

                                   Assessment of Measures Review Initiative Results for Goal 2
NPM    Sub-        Note: Cell entries below are hypothetical
                   FY 07 ACS Commitment Code & Text            Regions & Region or State Explanation for             NPM response, new code, and                         NPM Rationale
       objective                                               States & Recommendation                               New Text
                                                               recommen
                                                               dation

                                                                                                                     New
                                                                                                                     By 2011, at least maintain aquatic ecosystem
  OW   2.2.2       SP-16 -                                                                                           health on the "good/fair/poor" scale of the
                                                                                                                     National Coastal Condition Report in the
                                                                                                                     Northeast Region.
                                                                                                                     New
                                                                                                                     By 2011, at least maintain aquatic ecosystem
  OW   2.2.2       SP-17 -                                                                                           health on the "good/fair/poor" scale of the
                                                                                                                     National Coastal Condition Report in the
                                                                                                                     Southeast Region.
                                                                                                                     New
                                                                                                                     By 2011, at least maintain aquatic ecosystem
  OW   2.2.2       SP-18 -                                                                                           health on the "good/fair/poor" scale of the
                                                                                                                     National Coastal Condition Report in the West
                                                                                                                     Coast Region.
                                                                                                                     New
                                                                                                                     By 2011, at least maintain aquatic ecosystem
  OW   2.2.2       SP-19 -                                                                                           health on the "good/fair/poor" scale of the
                                                                                                                     National Coastal Condition Report in the Puerto
                                                                                                                     Rico Region.


                                                                                                                     New
                                                                                                                     Subobjective 4.3.2 Facilitate the Ecosystem-
                                                                                                                     Scale Restoration of Estuaries of National
                                                                                                                     Significance - By 2011, working with partners,
       4.3.2       4.3.2 -
                                                                                                                     protect or restore an additional (i.e., measuring
                                                                                                                     from 2007 forward) 250,000 acres of habitat
                                                                                                                     within the study areas for the 28 estuaries that
                                                                                                                     are part of the National Estuary Program.




                                                                                   Page 46       OW Lead Region 4 is in agreement with OW's proposed list of measures
                                                                                                                  DRAFT
                                                 Assessment of Measures Review Initiative Results for Goal 3
 NPM              FY 07 entries below are hypothetical
          Sub- Note: CellACS Commitment Code & Text                      Regions &          Region or State Explanation for                 NPM response, new code, and New                            NPM Rationale
        objective                                                         States &                Recommendation                                         Text
                                                                         recommen
                                                                           dation

                HW3 - Number of RCRA hazardous waste
                                                                                                                                          Keep
OSWER   3.1.2   management facilities with permits or approved
                controls in place.
                                                                                                                                          Modify
                HW7 - Number of RCRA facilities with updated
                                                                                                                                          Number of RCRA hazardous waste management
OSWER   3.1.2   controls for preventing releases due for permit
                                                                                                                                          facilities with updated controls for preventing
                renewal by 2006.
                                                                                                                                          releases.
                                                                                                                                          Keep
OSWER   3.1.2   ST1 - Number of confirmed UST releases nationally.

                ST6 - Percent increase of UST facilities that are in
                significant operational compliance with both release                                                                      Keep
OSWER   3.1.2
                detection and release prevention (spill, overfill, and
                corrosion protection requirements).
                TR1 - Number of tribes covered by an integrated                                                                           Keep
OSWER   3.1.2
                waste management plan .
                TR2 - Number of open dumps in Indian country and
                                                                                                                                          Keep
OSWER   3.1.2   other Tribal lands that are closed, cleaned up, or
                upgraded.


                                                                                     R5- Traditionally, Superfund removal completions
                                                                                     always have been broken down into fund-lead
                                                                                     completions (#132) and PRP-lead completions. In
                                                                                     the past few years, a third category of voluntary
                                                                                     completions (#133) was added. Starting in FY06, it
                                                                                     appears that the PRP-lead removal completion
                                                                                     measure has been completely deleted from tracking
                                                                                     by OSWER or OECA; at least, it doesn‟t appear in
                                                                                     ACS (for FY2007) along with measures #132 and
                                                                                     #133, and it doesn‟t appear in the FY2007 NPM
                132 - Number of Superfund-lead removal actions           5,6                                                                Keep
OSWER   3.2.1                                                                        Guidance. Since PRP-lead removal completions are                                                       OMB PART and Strategic Plan Measure.
                completed.                                               D, M
                                                                                     the primary evidence of our Enforcement First efforts
                                                                                     to be more efficient, make the pollutors pay, and save
                                                                                     the trust fund‟s money, this is an important category
                                                                                     to report on. Also, if the other two categories are
                                                                                     reported but not this one, we will be under-reporting
                                                                                     our total removal completion work.

                                                                                     R6- This measure is no longer meaningful to the
                                                                                     Superfund removal program and needs to be
                                                                                     rewritten.




                                                                                                                   Page 47
                                                                                                               DRAFT
                                              Assessment of Measures Review Initiative Results for Goal 3
 NPM              FY 07 entries below are hypothetical
          Sub- Note: CellACS Commitment Code & Text                 Regions &           Region or State Explanation for                    NPM response, new code, and New              NPM Rationale
        objective                                                    States &                 Recommendation                                            Text
                                                                    recommen
                                                                      dation



                                                                                R5- Traditionally, Superfund removal completions
                                                                                always have been broken down into fund-lead
                                                                                completions (#132) and PRP-lead completions. In
                                                                                the past few years, a third category of voluntary
                                                                                completions (#133) was added. Starting in FY06, it
                                                                                appears that the PRP-lead removal completion
                                                                                measure has been completely deleted from tracking
                                                                                by OSWER or OECA; at least, it doesn‟t appear in
                                                                                ACS (for FY2007) along with measures #132 and
                                                                                #133, and it doesn‟t appear in the FY2007 NPM
                133 - Number of voluntary removal actions, overseen 5,6                                                                Keep
OSWER   3.2.1                                                                   Guidance. Since PRP-lead removal completions are                                             OMB PART and Strategic Plan Measure.
                by EPA, completed.                                  D, M
                                                                                the primary evidence of our Enforcement First efforts
                                                                                to be more efficient, make the pollutors pay, and save
                                                                                the trust fund‟s money, this is an important category
                                                                                to report on. Also, if the other two categories are
                                                                                reported but not this one, we will be under-reporting
                                                                                our total removal completion work.

                                                                                R6- This measure is no longer meaningful to the
                                                                                Superfund removal program and needs to be
                                                                                rewritten.




                                                                                R5- We recommend that these or any other variation
                                                                                on an SPCC or FRP compliance or compliance rate
                                                                                measure be deleted until such time as there is
                                                                                national agreement on what “compliance” means,
                                                                                including whether it means compliance with just major
                                                                                requirements or every requirement, and whether the
                                                                                facility is in compliance at the time of the inspection or
                                                                                comes into compliance after the inspection (and, if
                327A - Number of inspected facilities subject to                the latter, do we only count if that occurred within the
                                                                     5,6                                                                   Keep
OSWER   3.2.1   Facility Response Plan (FRP) regulations found to be            same year as the inspection?).
                                                                     D, D
                in compliance.
                                                                                R6- This measure is, “number of inspected facilities
                                                                                subject to Facility Response Plan regulations found to
                                                                                be in compliance.” This measure measures the
                                                                                compliance rate of the facilities at the time of
                                                                                inspection. As this measure is currently written, the
                                                                                measure provides an incentive to target inspection
                                                                                resources to inspect compliant facilities in order to
                                                                                meet the commitment.




                                                                                                                Page 48
                                                                                                                    DRAFT
                                                 Assessment of Measures Review Initiative Results for Goal 3
 NPM              FY 07 entries below are hypothetical
          Sub- Note: CellACS Commitment Code & Text                      Regions &           Region or State Explanation for                    NPM response, new code, and New                           NPM Rationale
        objective                                                         States &                 Recommendation                                            Text
                                                                         recommen
                                                                           dation



                                                                                     R5- We recommend that these or any other variation
                                                                                     on an SPCC or FRP compliance or compliance rate
                                                                                     measure be deleted until such time as there is
                                                                                     national agreement on what “compliance” means,
                                                                                     including whether it means compliance with just major
                                                                                     requirements or every requirement, and whether the
                                                                                     facility is in compliance at the time of the inspection or
                                                                                     comes into compliance after the inspection (and, if
                328A - Number of inspected facilities subject to Spill               the latter, do we only count if that occurred within the
                                                                         5,6                                                                    Keep
OSWER   3.2.1   Prevention, Control and Countermeasure (SPCC)                        same year as the inspection?).
                                                                         D
                regulations found to be in compliance.
                                                                                     R6- This measure is, “number of inspected facilities
                                                                                     subject to Facility Response Plan regulations found to
                                                                                     be in compliance.” This measure measures the
                                                                                     compliance rate of the facilities at the time of
                                                                                     inspection. As this measure is currently written, the
                                                                                     measure provides an incentive to target inspection
                                                                                     resources to inspect compliant facilities in order to
                                                                                     meet the commitment.



                                                                                     R6- The core-ER measure is meaningful to the
                C1 - Percentage of emergency response readiness          6           Superfund program, but may no longer be             Keep                                                 Need to keep in place while new
OSWER   3.2.1
                improvement.                                             D           appropriate for ACS due to emphasis being placed on                                                      measure(s) are developed.
                                                                                     development of Homeland Security measures.

                                                                                                                                              Modify
                112 - Reduce the number of LUST cleanups that
                                                                                                                                              Number of cleanups that meet state risk-based
                exceed state risk-based standards for human
OSWER   3.2.2                                                                                                                                 standards for human exposure and groundwater    OMB PART and Strategic Plan Measure.
                exposure and groundwater migration (tracked as
                                                                                                                                              migration (tracked as the number of LUST
                number of LUST cleanups completed).
                                                                                                                                              cleanups completed).
                                                                                     R6- Delete as a commitment measure, but retain as a
                                                                                                                                              Modify
                113 - Reduce the number of LUST cleanups that                        reporting measure. This should be reporting
                                                                         6                                                                    Number of cleanups that meet risk-based
OSWER   3.2.2   exceed risk-based standards for human exposure                       measure but not a commitment. The States have                                                            OMB PART and Strategic Plan Measure.
                                                                         D                                                                    standards for human exposure and groundwater
                and groundwater migration in Indian Country.                         primary control over the number of cleanups
                                                                                                                                              migration in Indian County.
                                                                                     completed, not EPA.
                121 - Number of Superfund final site assessment                                                                               Keep
OSWER   3.2.2
                decisions.
                141 - Number of Superfund construction                                                                                        Keep
OSWER   3.2.2
                completions.




                                                                                                                     Page 49
                                                                                                                DRAFT
                                               Assessment of Measures Review Initiative Results for Goal 3
 NPM              FY 07 entries below are hypothetical
          Sub- Note: CellACS Commitment Code & Text                   Regions &           Region or State Explanation for                   NPM response, new code, and New                   NPM Rationale
        objective                                                      States &                 Recommendation                                           Text
                                                                      recommen
                                                                        dation


                                                                                  R5- This is not a request for modification of the
                                                                                  measures themselves, but rather of the reporting out
                                                                                  on these measures.
                                                                                  #151 and #152 measure the net change from one
                                                                                  year to the next and the status of a site is usually only
                                                                                  evaluated once a year, so these measures should
                                                                                  only be reported on at the end of the year (i.e., we
                                                                                  should not be asked to report on them more
                151 - Number of Superfund sites with human health                 frequently than that).
                protection achieved (exposure pathways are                        #155 was deleted from the latest version of the           Modify
                                                                      5
OSWER   3.2.2   eliminated or potential exposures are under health-               Strategic Plan, should have been deleted from the         Number of Superfund Sites with Human
                                                                      M
                based levels for current use of land or water                     FY2007 Annual Performance Plan, and will be               Exposures under Control.
                resources).                                                       deleted after this year. Thus, we believe that we
                                                                                  should only be asked to report on this measure once
                                                                                  at the end of the year.
                                                                                  While our Brownfields program chose not to request
                                                                                  deletion of any of the list of Brownfields measures,
                                                                                  they do so with the caveat that the regions should not
                                                                                  have to report out on any of the measures, i.e., that
                                                                                  Headquarters themselves should pull any reports
                                                                                  they need directly from ACRES.



                                                                                  R5- This is not a request for modification of the
                                                                                  measures themselves, but rather of the reporting out
                                                                                  on these measures.
                                                                                  #151 and #152 measure the net change from one
                                                                                  year to the next and the status of a site is usually only
                                                                                  evaluated once a year, so these measures should
                                                                                  only be reported on at the end of the year (i.e., we
                                                                                  should not be asked to report on them more
                                                                                  frequently than that).
                                                                                                                                                                                   OSWER requires periodic updates for
                                                                                  #155 was deleted from the latest version of the
                152 - Number of Superfund hazardous waste sites       5                                                                     Keep                                   these OMB PART and Stategic Plan
OSWER   3.2.2                                                                     Strategic Plan, should have been deleted from the
                with groundwater migration under control.             M                                                                                                            measures for reporting and assessment
                                                                                  FY2007 Annual Performance Plan, and will be
                                                                                                                                                                                   purposes.
                                                                                  deleted after this year. Thus, we believe that we
                                                                                  should only be asked to report on this measure once
                                                                                  at the end of the year.
                                                                                  While our Brownfields program chose not to request
                                                                                  deletion of any of the list of Brownfields measures,
                                                                                  they do so with the caveat that the regions should not
                                                                                  have to report out on any of the measures, i.e., that
                                                                                  Headquarters themselves should pull any reports
                                                                                  they need directly from ACRES.




                                                                                                                  Page 50
                                                                                                                DRAFT
                                                Assessment of Measures Review Initiative Results for Goal 3
 NPM              FY 07 entries below are hypothetical
          Sub- Note: CellACS Commitment Code & Text                  Regions &           Region or State Explanation for                   NPM response, new code, and New                NPM Rationale
        objective                                                     States &                 Recommendation                                           Text
                                                                     recommen
                                                                       dation

                                                                                 R2- While this was an ACS Commitment Measure in
                                                                                 FY06, it is no longer a GPRA measure in FY07.
                                                                                 Though the program has been asked to include and
                                                                                 continue tracking it in ACS/BAS, Region 2
                                                                                 recommends that it be officially deleted for FY08.

                                                                                 R5- This is not a request for modification of the
                                                                                 measures themselves, but rather of the reporting out
                                                                                 on these measures.
                                                                                 #151 and #152 measure the net change from one
                                                                                 year to the next and the status of a site is usually only
                                                                                 evaluated once a year, so these measures should
                                                                                 only be reported on at the end of the year (i.e., we
                                                                                 should not be asked to report on them more
                                                                                 frequently than that).
                155 - Number of final remedies (cleanup targets)     2,5,6
OSWER   3.2.2                                                                    #155 was deleted from the latest version of the           Delete
                selected at Superfund sites.                         D
                                                                                 Strategic Plan, should have been deleted from the
                                                                                 FY2007 Annual Performance Plan, and will be
                                                                                 deleted after this year. Thus, we believe that we
                                                                                 should only be asked to report on this measure once
                                                                                 at the end of the year.
                                                                                 While our Brownfields program chose not to request
                                                                                 deletion of any of the list of Brownfields measures,
                                                                                 they do so with the caveat that the regions should not
                                                                                 have to report out on any of the measures, i.e., that
                                                                                 Headquarters themselves should pull any reports
                                                                                 they need directly from ACRES.

                                                                                 R6- This measure will no longer be meaningful due to
                                                                                 the introduction of modified measures in the next
                                                                                 Strategic Plan.
OSWER   3.2.2   323 - Oil spills responded to or monitored by EPA                                                                         Delete

                CA1 - Number of high priority RCRA facilities with                                                                        Keep
OSWER   3.2.2
                human exposures to toxins controlled. (CA725)

                                                                                 R10- The CA2 groundwater goal is largely duplicative
                CA2 - Number of RCRA hazardous waste facilities
                                                                     10          of and a distraction from the more relevant CA5      Keep
OSWER   3.2.2   with migration of contaminated groundwater under                                                                                                             OMB PART and Strategic Plan Measure.
                                                                     D           remedy construction complete goal recently
                control.
                                                                                 introduced by OSW in the FY06 cycle.
                CA3 - Number of RCRA hazardous waste facilities
OSWER   3.2.2                                                                                                                             Delete
                assessed. (CA075)
                                                                                 R10- If you are looking for areas to streamline,
                                                                                 generally the CA4 remedy selection measure and the
                CA4 - Number of RCRA hazardous waste facilities      10                                                              Deleting RCRA Final Remedies Selected   Proposed for deletion as part of last
OSWER   3.2.2                                                                    CA5 remedy construction measure are so interrelated
                with final remedies selected.                        D                                                               measure in FY 2008.                     summer's ACS streamlining effort.
                                                                                 that the CA5 can easily stand alone as a single
                                                                                 measurement of progress.
                CA5 - Number of RCRA hazardous waste facilities                                                                           Keep
OSWER   3.2.2
                with remedy construction completed.



                                                                                                                 Page 51
                                                                                                                      DRAFT
                                                 Assessment of Measures Review Initiative Results for Goal 3
 NPM              FY 07 entries below are hypothetical
          Sub- Note: CellACS Commitment Code & Text                       Regions &            Region or State Explanation for                      NPM response, new code, and New                               NPM Rationale
        objective                                                          States &                  Recommendation                                              Text
                                                                          recommen
                                                                            dation

                 S10 - Number of Superfund sites ready for reuse (site-                                                                            Keep
OSWER   3.2.2
                 wide).
                 OSRE-01 - Each year through 2008, reach a
                 settlement or take an enforcement action before the
                                                                                       R6- This measure is no longer meaningful to the
                 start of a remedial action at 95 percent of Superfund    6                                                                        Keep
OSWER   3.2.3                                                                          Superfund enforcement program and needs to be                                                                 OECA Measure
                 sites having viable, liable responsible parties other    D
                                                                                       rewritten.
                 than the federal government.

                 OSRE-02 - Each year through 2008, address all
                                                                                       R6- This measure is no longer meaningful to
                 Statute of Limitations cases for Superfund sites with 6                                                                           Keep
OSWER   3.2.3                                                                          Superfund enforcement program and needs to be                                                                 OECA Measure
                 unaddressed total past costs equal to or greater than D
                                                                                       rewritten.
                 $200,000.
                                                                                                                                                   new
                                                                                       Millions of tons of construction and demolition debris
OSWER   3.1.1    -                                                                                                                                 Millions of tons of construction and demolition
                                                                          new          that is reused or recycled.
                                                                                                                                                   debris that is reused or recycled.
                                                                                                                                                   new
                                                                                       Percent of coal combustion ash that is used instead
OSWER   3.1.1.   -                                                                                                                                 Percent of coal combustion ash that is used
                                                                          new          of disposed.
                                                                                                                                                   instead of disposed.
                                                                                       R1- Not useful to track measures when there is a
                                                                                       significant time lag – and incredibly laborious to do so.
                                                                                       First suggestion is to delete all of these measures.
                                                                                       Failing that, suggest that all of these state
                                                                                       commitments are measured on the end-of-3rd-
                                                                                       quarter interval, recognizing that this would entail an
                                                                                       increase in progress reporting for these entities and
                                                                                       for all levels of EPA that track this information.

                                                                                       R5- There are many inconsistencies between the text
                                                                                       of our performance measures as they appear in the
                                                                                       Strategic Plan, the Annual Performance
        GENERAL                                                                        Plan/Congressional Justification, NPM Guidance,
                                                                          1, 5         ACS, the SPIM, and CERCLIS SCAP reports. We
OSWER   COMMEN N/A -
                                                                          D and/or M   hope that OCFO, OSWER, and OECA will use this
        TS
                                                                                       initiative to review these different documents and
                                                                                       revise the text so that the same measure is worded
                                                                                       the same way in all documents.
                                                                                       In addition, there is inconsistency between which
                                                                                       measures are included in each of these documents.
                                                                                       While it may be the case that some measures are not
                                                                                       relevant to a particular document‟s purpose, we
                                                                                       encourage OCFO, OSWER, and OECA to use this
                                                                                       initiative to ensure the consistency of the list of
                                                                                                                                                                                                     Measures appendix to NPM Guidance will
                                                                                       measures between documents, as appropriate. (For
                                                                                                                                                                                                     be pulled from ACS – these measures will
                                                                                       example, even the cross-walk distributed by OCFO
                                                                                                                                                                                                     be identical. Will strive to describe program
                                                                                       for this exercise was missing several ACS measures.)
                                                                                                                                                                                                     in a consistent manner.
                                                                                       We also encourage OSWER to distribute to the




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          Sub- Note: CellACS Commitment Code & Text      Regions &           Region or State Explanation for                     NPM response, new code, and New               NPM Rationale
        objective                                         States &                 Recommendation                                             Text
                                                         recommen
                                                           dation



                                                                     R5- Regarding the following measure in the new
                                                                     Strategic Plan: “By 2011, reduce by 25% the gallons
                                                                     of oil spilled by facilities subject to FRP regulations
                                                                     relative to the 601,000 gallons of oil spilled in 2003”:
                                                                     We have no control over the amount of oil that is
                                                                     spilled at an FRP facility. Even if a facility is in full
                                                                     compliance, it can have a spill.

                                                                     Regarding the following efficiency measure reported                                           The assumption is that FRP facilities are
                                                                     to OMB under PART: “Gallons of oil spilled to                                                 also SPCC facilities. Compliance
                                                                     navigable waters per million program dollars spent                                            assistance and other activities related to
        OIL SPILL                                        5
OSWER               -                                                annually on prevention and preparedness at FRP                                                accident prevention should contribute to
        PMs
                                                                     facilities”:                                                                                  lowering the number of gallons spilled. The
                                                                     We believe that the significant effort that would be                                          gallons of oil spilled per costs measure is
                                                                     required to collect this information would far out way                                        an OMB PART efficiency measure.
                                                                     the benefit gained from reporting it. We do not
                                                                     currently have a way to track the amount of money
                                                                     spent on these activities and it would be difficult to
                                                                     calculate that figure. Also, we assume that the
                                                                     gallons spilled would be obtained from spill reports,
                                                                     which don‟t identify if the spill occurred at an FRP
                                                                     facility and often either don‟t include the actual
                                                                     amount of the spill or the amount is inaccurate.




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      objective                                         States &         Recommendation                           Text
                                                       recommen
                                                         dation




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                       FY 07 ACS Commitment Code & Text                         Regions & Region or State Explanation for Recommendation                     NPM response, new code, and New                NPM Rationale
         objective                                                               States &                                                                                 Text

                                                                                           NY- Revise reporting elements to reflect activities and
                                                                                           results that can be achieved in shorter time frames – some
                                                                                           management strategies for water and groundwater may take                                            This measure was developed in large part by
                                                                                           years to have a measurable effect. An equation using                                                States to be as effective as possible given
                                                                                           pesticides managed and demonstrated reduction of                                                    resource constraints.
                     10A - Number of State and Tribal pesticide agencies                   concentration, with the intervening time lag (years) is not                                         In developing this measure, it was recognized
                     meeting water quality commitments, which include                      realistic. The measure should be modified to reflect                                                that such changes do not take place in a matter
                                                                          NY                                                                            Delete
OPPTS   4.1.1        the national water quality measures and end-of-year                   activities within the scope of the program mission and                                              of months, but in terms of years. The idea of
                                                                          M
                     reporting on active ingredients being evaluated, and                  funding. Direct management/remediation of water quality is                                          this measurement is to track trends in water
                     managed.                                                              not a function of the NYSDEC pesticides program. To                                                 quality improvements with regards to key
                                                                                           increase effectiveness of this measure, share responsibility                                        pesticides.
                                                                                           for it at the national level between pesticides and water
                                                                                                                                                                                               The focus of this measure is on key pesticides;
                                                                                           programs. Pesticides should be included in water program
                                                                                                                                                                                               therefore, it is within the scope of the National
                                                                                           work plans/grant funds to provide for coordination between
                                                                                                                                                                                               Pesticide Program. We would also like to note
                                                                                           water and pesticides programs.
                                                                                                                                                                                               that this measure was generated in cooperation
                                                                                                                                                                                               with EPA’s Office of Water.
                     26 - Number of state grant dollars per pesticide       6                                                                               Keep
OPPTS   4.1.1
                     applicator certification.
                     3A - Increase state, tribal, territory, and public                                                                                     Keep
OPPTS   4.1.1
                     knowledge of the Endangered Species Program

                                                                                           R8- This is a “reporting on reporting” commitment. Regions
                                                                                           are asked to report that States/tribes are reporting, and this
                                                                                           is accomplished through the national end-of-year oversight
                     4A - For all States and/or Tribes in the
                                                                                           reports that the regions are required to write and send to
                     Region,assuring appropriate implementation of
                                                                                           HQ.
                     pesticide worker safety programs that meet national
                     program commitments as established in National
                                                                         8, NY             NY- EPA‟s Amended Cooperative Agreement Guidance                 Delete
OPPTS   4.1.1        Pesticide Cooperative Agreement Guidance. This
                                                                         D                 outlines new worker safety measures designated as WS1
                     includes assuring that all reports required by the
                                                                                           through 6, but insufficient explanation of measures is
                     Cooperative Agreement Guidance for the support of
                                                                                           provided and additional information would be needed to
                     national program and performance measures are
                                                                                           comment on whether the measures need modification or
                     submitted to HQ/OPP/CWPB.                                                                                                                                                 It is EPA’s intent to ensure that measures
                                                                                           deletion. In the guidance, EPA states that they will not rely
                                                                                           on Cooperative Agreement data for these measures and                                                balance the need for information with
                                                                                           states involvement is an optional “supplemental” activity.                                          resources available. The guidenace will
                                                                                                                                                                                               address the issue for each pertinant year.
                     7A - For all States and/or Tribes in the Region,
                     assuring that C&T State Plans are implemented and                     R8- This is a “reporting on reporting” commitment. Regions
                     maintained per 40 CFR Part 171.8, and complete                        are asked to report that States/tribes are reporting, and this
                                                                       8                                                                                  Delete
OPPTS   4.1.1        C&T accomplishment reporting information required                     is accomplished through the national end-of-year oversight
                                                                       D, M
                     by 40 CFR Part 171.7(d) is submitted to                               reports that the regions are required to write and send to
                     HQ/OPP/CWPB via the C&T State Plan & Reporting                        HQ.
                     database
                     8 - 4-6 model agricultural field projects per Region                                                                                   Delete
OPPTS   4.1.1
                     over 3 yr period (1-3 per year)
                     9 - 80 collaboration/outreach activities to foster                                                                                     Delete
OPPTS   4.1.1
                     transition (over 3 years 2005-2007)




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                       FY 07 ACS Commitment Code & Text                     Regions & Region or State Explanation for Recommendation                     NPM response, new code, and New                         NPM Rationale
         objective                                                           States &                                                                                 Text
                                                                                       R2- Region 2 agrees with OPPT and other regions that
                                                                                       these two measures should be retained as separate
                                                                                       measures (rather than combined into single measure). The
                                                                                       measures should be redefined to capture inventories of
                                                                                       active individual certifications at points in time, rather than
                                                                                       capturing workloads (certifications and re-certifications
                                                                                       issued during the reporting period), in part because tracking
                                                                                       inventories is more outcome oriented than tracking
                                                                                       workloads. However, Region 2 disagrees with OPPT and
                                                                                       other regions that these two certification measures should
                                                                                       be classified as commitment measures. Region 2 and its
                                                                                       grantee states certify all qualified applicants and have no
                                                                                       control over the number of applications we receive.
                     11A - Total number of active individual certifications            Therefore we believe these two certification measures
                                                                                                                                                       Modify
                     for lead-based paint activities issued by EPA and      2,5,6      should both be for reporting only.
OPPTS   4.1.3                                                                                                                                          Number of active individual certifications for
                     authorized states, tribes and territories within the   M, M, D
                                                                                                                                                       lead-based paint activities in the Region.
                     Region                                                            R5- Region 5 recommends retaining the measure of
                                                                                       certifications as a reporting measure, but not as a target or
                                                                                       commitment measure since neither the Regions nor the
                                                                                       States have any control on the numbers of certifications.
                                                                                       We took a close look at this measure and our certification
                                                                                       data. We looked at the last 4 years of certification data (see
                                                                                       attached) and we are unable to identify any trends in the
                                                                                       data, or causal influences. We compared HUD grant funds
                                                                                       available to the States to the number of certifications/State
                                                                                       and even allowing for a time lag, could find no relationship.                                                    HQ Agreed to modify the measure
                                                                                       We also looked at a three year rolling annual average (see
                                                                                                                                                                                                        language for 11A and 11B and make
                                                                                       attached). Although the average sometimes “smoothed” out
                                                                                       the differences in the annual certifications, we did not find                                                    them both reporting measures for FY
                                                                                       the averages helpful in targeting for subsequent years.                                                          2008.
                                                                                       Under the present legal framework, which links certification




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                       FY 07 ACS Commitment Code & Text                     Regions & Region or State Explanation for Recommendation                       NPM response, new code, and New                          NPM Rationale
         objective                                                           States &                                                                                   Text

                                                                                       R2- Region 2 agrees with OPPT and other regions that
                                                                                       these two measures should be retained as separate
                                                                                       measures (rather than combined into single measure). The
                                                                                       measures should be redefined to capture inventories of
                                                                                       active individual certifications at points in time, rather than
                                                                                       capturing workloads (certifications and re-certifications
                                                                                       issued during the reporting period), in part because tracking
                                                                                       inventories is more outcome oriented than tracking
                                                                                       workloads. However, Region 2 disagrees with OPPT and
                                                                                       other regions that these two certification measures should        Modify
                     11B - Total number of active individual certifications
                                                                            2, 5, 6    be classified as commitment measures. Region 2 and its            Number of active individual certifications for
OPPTS   4.1.3        for individual lead-based paint activities issued by
                                                                            M, M, D    grantee states certify all qualified applicants and have no       lead-based paint activities in the grantee
                     grantees.
                                                                                       control over the number of applications we receive.               State.
                                                                                       Therefore we believe these two certification measures
                                                                                       should both be for reporting only.

                                                                                       R5- See above rationale for measure 11A

                                                                                       R6- This should be deleted as a commitment measure for
                                                                                       the same reasons as in 11A. In addition, this measure ia
                                                                                                                                                                                                          HQ Agreed to modify the measure
                                                                                       redundant. All data contained same rationale as above for                                                          language for 11A and 11B and make
                                                                                       11A, 11B should be deleted                                                                                         them both reporting measures for FY
                                                                                                                                                                                                          2008.
                                                                                                                                                         Modify
                     12 - Cumulative number of authorized state and
                                                                                                                                                         Cumulative number of authorized state and
OPPTS   4.1.3        tribal certification and training programs for lead-
                                                                                                                                                         tribal programs for lead-based paint
                     based paint professionals.
                                                                                                                                                         professionals.

                                                                                       R2- Region 2 agrees with OPPT and other regions to delete
                                                                                       the three PCB measures due to transfer of resources to
                     13A - Number of individuals in the regulated           2                                                                    Delete
OPPTS   4.1.3                                                                          OSWER. However, if the resource transfer does not occur,
                     community reached through PCB outreach.                D
                                                                                       we recommend maintaining these measures under OPPTS.
                                                                                                                                                                                                          HQ agreed to delete the measure for
                                                                                                                                                                                                          FY 2008.

                                                                                       R2- Region 2 agrees with OPPT and other regions to delete
                                                                                       the three PCB measures due to transfer of resources to
                                                                                       OSWER. However, if the resource transfer does not occur,
                                                                                       we recommend maintaining these measures under OPPTS.
                     14 - Acres of property to be remediated under
                                                                       2,10            R10- These two commitments (acres of property & number            Delete
OPPTS   4.1.3        issued 761.61(c) approvals and 761.61(a) reviewed
                                                                       D               of sites) are impossible to predict and completely out of
                     approvals.
                                                                                       Regional control. PCB spills (and their relative scope and
                                                                                       importance) are not events that can be planned or
                                                                                       predicted. Regions are making widely varying
                                                                                       “guesstimates” and it is unclear how useful these
                                                                                       guesstimates can really be.




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         objective                                                             States &                                                                              Text

                                                                                         R2- Region 2 agrees with OPPT and other regions to delete
                                                                                         the three PCB measures due to transfer of resources to
                                                                                         OSWER. However, if the resource transfer does not occur,
                                                                                         we recommend maintaining these measures under OPPTS.

                     14A - Number of sites receiving 761.61(a) or (c)        2,10        R10- These two commitments (acres of property & number        Delete
OPPTS   4.1.3
                     approvals for remediation during the year.              D           of sites) are impossible to predict and completely out of
                                                                                         Regional control. PCB spills (and their relative scope and
                                                                                         importance) are not events that can be planned or
                                                                                         predicted. Regions are making widely varying
                                                                                         “guesstimates” and it is unclear how useful these
                                                                                         guesstimates can really be.                                                                                HQ agreed to delete the measure for
                                                                                                                                                                                                    FY 2008.
                     15 - Number of school children attending institutions
                     reached through general toxic fibers education and                                                                                Keep
OPPTS   4.1.3
                     outreach activities.


                                                                                         R2- Region 2 agrees with OPPT and other regions to
                                                                                         transfer the mercury partnership measure for H2E from the
                     16 - Number of partnerships established with                        Mercury Program to the Pollution Prevention Program within
                     hospitals and other health facilities to reduce                     OPPTS.
                     Mercury in waste streams following the process          2, 8, 9                                                                   Delete
OPPTS   4.1.3
                     established under the Hospitals for a Healthy           M, D, D     R8- This should be deleted in favor of keeping #25 as the
                     Environment (H2E) program.                                          measure for the number of new partnerships. It is most
                                                                                         efficient to measure this at the Headquarters level via #25

                                                                                         R9- [NO WRITTEN COMMENT PROVIDED]
                                                                                                                                                                                                    HQ agreed to delete the measure for
                                                                                                                                                                                                    FY 2008.
                                                                                         R2- R2 agrees with OPPT and other regions to delete the
                     19A - Develop a network among at least 5
                                                                                         HPV measure
                     organizations (such as health and environmental
                     state agencies, academia and/or chemical                2,8                                                                       Delete
OPPTS   4.1.3                                                                            R8- This should be a Headquarters measure. Regions do
                     manufacturers and producers) and encourage              D, D
                                                                                         not receive resources to support the measure, and it is a
                     familiarity with the High Production Volume
                                                                                         poor measure of progress toward an outcome that is worth                                                   HQ agreed to delete the measure for
                     Information System
                                                                                         achieving.                                                                                                 FY 2008.
                     21 - Number of outreach partnerships addressing                                                                                   Modify
                     lead-based paint hazards and exposure reduction.                                                                                  Number of outreach partnerships addressing
OPPTS   4.1.3
                     These partnerships must be consistent with the                                                                                    lead based paint hazards and exposure
                     Regions lead poison prevention priorities.                                                                                        reduction.




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         objective                                                        States &                                                                                 Text
                                                                                    R2- Region 2 agrees with OPPT and other regions to
                                                                                    eliminate the mercury partnerships (non-H2E) measure

                     22 - Number of H2E partners who have won the                   R8- This should also be tracked at the Headquarters level
                                                                        2,8,9                                                                    Delete
OPPTS   4.1.3        Regions Making Medicine Mercury Free Award in                  because the data are compiled at that level. Otherwise this,
                                                                        D, D, D,
                     FY2007.                                                        too, would be a “reporting on reporting” measure. The
                                                                                    award in question is not a Regional award.

                                                                                    R9- [NO WRITTEN COMMENT PROVIDED]
                                                                                                                                                                                        HQ agreed to delete the measure for
                                                                                                                                                                                        FY 2008.

                                                                                    R8- The NPM guidance will have to carefully define the
                                                                                    terminology for this measure. The proximity and meaning of
                                                                                    the words “new product partnerships” is vague and
                                                                                    confusing. Does the measure seek to quantify “new
                                                                                    partnerships” partnerships that address mercury, “new
                                                                                    products” or only “new partnerships that aim to reduce the
                                                                                    contributions of new products” to the amount of mercury in
                     23 - Number of new product partnerships aimed at   8,9         the waste stream? Is this a step backwards from the 2006   Delete
OPPTS   4.1.3
                     reducing mercury in the waste stream.              M or D, D   ACS measure 18, which at least quantified the number of
                                                                                    pounds of mercury eliminated by sectors other than H2E
                                                                                    participants? #23 seems more like an intermediate
                                                                                    outcome, whereas #18 seems more like a long-term
                                                                                    outcome of the type that OMB seems to encourage
                                                                                    agencies to strive for.

                                                                                    R9- [NO WRITTEN COMMENT PROVIDED]                                                                   HQ agreed to delete the measure for
                                                                                                                                                                                        FY 2008.
                                                                                    R6- Suggested replacement language: “Number "The
                                                                                    number of states/tribes that certified and train all qualified
                                                                                    pesticide applicators."
                                                                                    The Office of Pesticide Programs (OPP) has not issued
                     26 - Number of state grant dollars per pesticide   6           definitive guidance on how the States/Regions should             Delete
OPPTS
                     applicator certification.                          M           calculate this measure. There are multiple issues with the
                                                                                    reporting of this measure. The measure appears to be an
                                                                                    efficiency measure which may be misleading since not all
                                                                                    resource aspects (non-federal funding) are considered in
                                                                                    the measure.




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         objective                                                          States &                                                                               Text

                                                                                      R6- The reporting commitments for the number of risk
                                                                                      management plan audits completed.
                                                                                      (ACS code CH2) responds to the reporting requirements
                                                                                      under Goal 4. In FY 07, OECA instituted the Goal 5
                                                                                      reporting commitment for conducting inspections at 5% of
                                                                                      total number of facilities required to submit risk
                                                                                      management plans (ACS CAA11). The purpose was that
                                                                                      HQ wanted the regions to do more actual inspections at
                                                                                      RMP facilities.
                                                                                       For Region 3, the reporting requirements under both
                                                                                      commitments result in the same number of reported facility
                                                                                      reviews. Region 3 conducts only RMP inspections which
                                                                                      are more rigorous than audits. Therefore we satisfy the                                             Implementation and reporting issue. Both
                     CH2 - Number of risk management plan audits          3,6                                                                        Modify
OSWER   4.1.4                                                                         intent of the HQ inspection reporting requirements. Our                                             HQ and the Superfund lead region are
                     completed.                                           M, D, D                                                                    Number of RMP audits completed.
                                                                                      facility inspections also meet the reporting requirement for                                        reviewing these measures.
                                                                                      facility audits. We report the same number of facility
                                                                                      reviews in satisfaction of both ACS reporting requirements
                                                                                      (CH2 and CAA11).
                                                                                      Region 3 suggests that we may continue to report the
                                                                                      number of regional RMP inspections in satisfaction of
                                                                                      OSWER Goal 4, ACS Code CH2 („RMP audits completed‟)
                                                                                      and this same number will also satisfy the reporting
                                                                                      requirements for OECA Goal 5, ACS Code CAA11 („RMP
                                                                                      inspections completed).

                                                                                      R6- This measure is no longer meaningful and needs to be
                                                                                      rewritten to be more meaningful for the program.

                                                                                                                                                     Keep
OSWER   4.2.3        B29 - Number of Brownfields properties assessed.

                     B32 - Properties cleaned up using Brownfields                                                                                   Keep
OSWER   4.2.3
                     funding.
                     B33 - Acres of Brownfields property made ready for                                                                              Keep
OSWER   4.2.3
                     reuse.

                                                                                                                                                                                          The “Number of jobs leveraged at
                                                                                                                                                                                          brownfields properties” measure
                                                                                      R6- This measure, “Jobs leveraged from Brownfields                                                  quantifies the direct economic and social
                                                                                                                                                Modify
                                                                          6           activities”, does not focus on environmental results, but                                           impact of investing dollars in assessment
OSWER   4.2.3        B34 - Jobs leveraged from Brownfields activities.                                                                          Number of jobs leveraged at Brownfields
                                                                          D           instead focuses on something that should be a measure for                                           and cleanup of brownfields properties.
                                                                                                                                                sites.
                                                                                      the Department of Labor.                                                                            Typically, this is an estimate and may
                                                                                                                                                                                          involve follow up with the developer, town
                                                                                                                                                                                          officials, building owners.


                                                                                                                                                                                          The “percentage of Brownfields job
                                                                                      R6- This measure, “percentage of Brownfields job training                                           training trainees placed” tracks the
                     B36 - Percentage of Brownfields job training         6           trainees placed”, is another measure that does not focus on Keep                                    activities of the Brownfields Job Training
OSWER   4.2.3
                     trainees placed.                                     D           environmental results, but instead focuses on something                                             grants. These grants are administered by
                                                                                      best measured by the Department of Labor                                                            EPA; it is not appropriate for Department
                                                                                                                                                                                          of Labor to collect this information.



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         objective                                                           States &                                                                             Text
                                                                                                                                                                                                       Measure B37 is “Billions of dollars of
                     B37 - Billions of dollars of cleanup and                                                                                                                                          cleanup and redevelopment funds
                                                                            6          R6- This measure, “assess and clean up brownfields”, is a   Keep
OSWER   4.2.3        redevelopment funds leveraged at Brownfields                                                                                                                                      leveraged at Brownfields sites.” Measure
                                                                            D          duplicate of measure B29.
                     sites.                                                                                                                                                                            B29 is “Number of Brownfields properties
                                                                                                                                                                                                       assessed.”
                     B38 - Number of Tribes supported by Brownfields                                                                               Keep
OSWER   4.2.3
                     cooperative agreements.
                                                                                                                                                   SP-23
                     IV-A - Achieve currently exceeded water quality
                                                                                                                                                   By 2012, achieve a majority of currently
                     standards in impaired reaches or segments of
OW      4.2.4                                                                                                                                      exceeded water quality standards in impaired
                     significant shared and transboundary surface
                                                                                                                                                   transboundary segments of U.S. surface
                     waters.
                                                                                                                                                   waters.
                                                                                                                                                   SP-24
                     MB-1 - Provide safe drinking water to homes in the
                                                                                                                                                   By 2012, provide safe drinking water to 25
                     Mexico Border area that lacked access to safe
OW      4.2.4                                                                                                                                      percent of homes in the U.S.-Mexico border
                     drinking water in 2003.
                                                                                                                                                   area that lacked access to safe drinking
                                                                                                                                                   water in 2003.

                                                                                                                                                   SP-25
                     MB-2 - Provide adequate wastewater sanitation to
                                                                                                                                                   By 2012, provide adequate wastewater
                     homes in the Mexico Border area that lacked
OW      4.2.4                                                                                                                                      sanitation to 25 percent of homes in the U.S.-
                     access to wastewater sanitation in 2003.
                                                                                                                                                   Mexico border area that lacked access to
                                                                                                                                                   wastewater sanitation in 2003.


                                                                                                                                                   4.3.2
                                                                                                                                                   Subobjective 4.3.2 Facilitate the Ecosystem-
                     IV-D - Working with National Estuary Program                                                                                  Scale Restoration of Estuaries of National
                     partners, protect or restore additional acres of                                                                              Significance - By 2011, working with
OW      4.3.1        habitat within the study areas for the 28 estuaries                                                                           partners, protect or restore an additional (i.e.,
                     that are part of the National Estuary Program (NEP).                                                                          measuring from 2007 forward) 250,000 acres
                     (cumulative)                                                                                                                  of habitat within the study areas for the 28
                                                                                                                                                   estuaries that are part of the National Estuary
                                                                                                                                                   Program.

                                                                                                                                                                                                       Public comment on the draft Strategic
                                                                                                                                                   Modify
                     4.3.2 - Working with partners, achieve a net                                                                                                                                      Plan including Strategic plan measures
                                                                                                                                                   Subobjective 4.3.1 Increase Wetlands. By
                     increase of acres of wetlands per year with an         7                                                                                                                          was from May 31 to July 17. Since
OW      4.3.2                                                                          R7- Becomes a strategic target in new strategic plan        2011, working with partners, achieve a net
                     additional focus on biological and functional          M                                                                                                                          strategic plan measures are now final, the
                                                                                                                                                   increase in wetlands acres with additional
                     measures. (cumulative)                                                                                                                                                            Agency cannot make changes to the
                                                                                                                                                   focus on assessment of wetland condition.
                                                                                                                                                                                                       measure text
                                                                                                                                                                                                       Public comment on the draft Strategic
                     IV-E - Annually, beginning in FY 2004, work with the
                                                                                                                                                                                                       Plan including Strategic plan measures
                     U.S. Army Corps of Engineers (COE) and other
                                                                          7                                                                        SP-22                                               was from May 31 to July 17. Since
OW      4.3.2        partners to achieve no net loss of wetlands under                 R7- Becomes a strategic target in new strategic plan
                                                                          M                                                                        under 4.3.1                                         strategic plan measures are now final, the
                     Section 404 of the Clean Water Act regulatory
                                                                                                                                                                                                       Agency cannot make changes to the
                     program
                                                                                                                                                                                                       measure text
                     WT-1 - Number of wetland acres restored and                       R5- Eliminate using these measures in favor of HQ
                                                                            5                                                                 Keep
OW      4.3.2        enhanced, attributable to the President's Earth Day               proposed 08 measures. Use the proposed 08 measures for                                                          Supports President's initiative
                                                                            D                                                                 under 4.3.1
                     Initiative. (cumulative)                                          reporting only in 07 as a test run.



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                      FY 07 ACS Commitment Code & Text                     Regions & Region or State Explanation for Recommendation              NPM response, new code, and New                           NPM Rationale
        objective                                                           States &                                                                          Text
                                                                                      R5- Eliminate using these measures in favor of HQ
                    WT-2a - Number of States that have built capacities               proposed 08 measures. Use the proposed 08 measures for
                    in wetland monitoring, regulation, restoration, water 5,7,9       reporting only in 07 as a test run.                     Keep
OW     4.3.2                                                                                                                                                                                    Key measure of States' role.
                    quality standards, mitigation compliance, and         D, D                                                                under 4.3.1
                    partnership building.                                             R7- Measure is subjective and focuses mainly on the few
                                                                                      regions with Program Grants under WPDG Program.


                                                                                      R5- Eliminate using these measures in favor of HQ
                    WT-2b - Number of Tribes that have built capacitites              proposed 08 measures. Use the proposed 08 measures for
                    in wetland monitoring, regulation, restoration, water 5,8,9       reporting only in 07 as a test run.                     Keep
OW     4.3.2                                                                                                                                                                                    Key measure of Tribal role.
                    quality standards, mitigation compliance, and         D, D                                                                under 4.3.1
                    partnership building.                                             R7- Measure is subjective and focuses mainly on the few
                                                                                      regions with Program Grants under WPDG Program.

                                                                                      R2- Measure is subjective and doesn‟t drive results.

                                                                                      R4-
                                                                                                                                             WT-3 (combine WT-3a and WT-3b)
                                                                                                                                             Number of watershed-based wetlands and
                    WT-3a - Number of watershed-based wetlands and                    R5- Eliminate using these measures in favor of HQ
                                                                                                                                             stream corridor projects in States and on
                    stream corridor projects in States (combined 5-Star               proposed 08 measures. Use the proposed 08 measures for
                                                                        2,5,7,8,9                                                            Indian Reservations (combined 5-Star and
OW     4.3.2        and non-5-Star projects) for which EPA has                        reporting only in 07 as a test run.                                                                       Streamlines measure.
                                                                        D, D,                                                                non-5-Star projects) for which EPA has
                    provided / contributed significant financial and/or
                                                                                                                                             provided /contributed significant financial
                    technical assistance. [cumulative projects]                       R7-
                                                                                                                                             and/or technical assistance. [cumulative
                                                                                                                                             projects]
                                                                                      R8- Merge with WT-3b.

                                                                                      R9-

                                                                                      R2-
                    WT-3b - Number of watershed-based wetlands and
                    stream corridor projects on Indian reservations                   R5- Eliminate using these measures in favor of HQ
                                                                        2,5,7                                                                Delete
OW     4.3.2        (combined 5-Star and non-5-Star projects) for which               proposed 08 measures. Use the proposed 08 measures for
                                                                        D, D
                    EPA has provided/contributed significant financial                reporting only in 07 as a test run.
                    and/or technical assistance. (cumulative projects)
                                                                                      R7- Measure is subjective and doesn‟t drive results.

                    WT-4 - Number of States where the trend in wetland                R5- Eliminate using these measures in favor of HQ
                                                                       2,5,9                                                                 Keep
OW     4.3.2        condition has been measured as defined through                    proposed 08 measures. Use the proposed 08 measures for                                                    Key measure of program performance.
                                                                       D
                    biological metrics and assessments.                               reporting only in 07 as a test run.

                                                                                                                                                Modify
                                                                                                                                                Subobjective 4.3.3 Improve the Health of the
                    4.3.3 - Prevent water pollution and improve the                                                                             Great Lakes - By 2011, prevent water
OW     4.3.3        overall aquatic ecosystem health of the Great Lakes                                                                         pollution and protect aquatic systems so that
                    using the Great Lakes 40-point scale.                                                                                       the overall ecosystem health of the Great
                                                                                                                                                Lakes is at least 23 points on a 40-point
                                                                                                                                                scale.
                    GL-1 - Number and percent of all NPDES permitted
                    discharges to the Lakes or major tributaries that                                                                           Keep
OW     4.3.3
                    have permit limits that reflect the Guidance's water
                    quality standards.


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                      FY 07 ACS Commitment Code & Text                     Regions & Region or State Explanation for Recommendation                  NPM response, new code, and New                          NPM Rationale
        objective                                                           States &                                                                              Text
                    GL-2 - Number and percent of all CSO permits in
                                                                                                                                                   Keep
OW     4.3.3        the Great Lakes basin that are consistent with the
                    national CSO policy.
                    GL-3 - Number of sediment remedial actions                                                                                     Keep
OW     4.3.3
                    (annual).
                    GL-4 - Percent of high priority Tier 1 (significant)
                    Great Lakes beaches where States and local                        R5- This is a measure of States monitoring programs and
                    agencies have put into place water quality             5          not the Region‟s. Also, our States define high priority      Keep
OW     4.3.3                                                                                                                                                                                        Key program measure.
                    monitoring and public notification programs that       D          beaches as the ones they monitor, so we will always report
                    comply with the U.S. E.P.A. National Beaches                      100% for this measure, rendering it meaningless.
                    Guidance.
                                                                                                                                                   SP-29
                                                                                                                                                   Through 2011, maintain or improve an
                    IV-G - Reduce the average concentrations of PCBs
                                                                                                                                                   average annual 5 percent decline for the long-
OW     4.3.3        in whole lake trout and walleye samples from 2000
                                                                                                                                                   term trend in average concentrations of
                    levels.
                                                                                                                                                   PCBs in whole lake trout and walleye
                                                                                                                                                   samples.
                                                                                                                                                   SP-30
                    IV-H - Reduce the average concentrations of toxic                                                                              Through 2011, maintain or improve an
                    chemicals (PCBs) in the air in the Great Lakes                                                                                 average 7 annual decline for the long-term
OW     4.3.3
                    basin from 2000 levels (average annual long-term                                                                               trend in average concentrations of toxic
                    decline).                                                                                                                      chemicals (PCBs) in the air in the Great
                                                                                                                                                   Lakes Basin.
                                                                                                                                                   SP-31
                    IV-I - Restore and de-list Acres of Concern (AOCs)                                                                             By 2010, restore and delist a cumulative total
OW     4.3.3
                    within the Great Lakes basin.                                                                                                  of at least 8 Areas of Concern (AOCs) within
                                                                                                                                                   the Great Lakes Basin.
                                                                                                                                                   SP-32
                    IV-J - Remdiate cubic yards (in millions) of
                                                                                                                                                   By 2011, remediate a cumulative total of 7
OW     4.3.3        contaminated sediment in the Great Lakes.
                                                                                                                                                   million yards of contaminated sediment in the
                    (cumulative from 1997)
                                                                                                                                                   Great Lakes.

                                                                                                                                                   Modify
                    4.3.4 - Prevent water polllution and protect aquatic
                                                                                                                                                   Subobjective 4.3.4 Improve the Health of the
                    systems so that overall aquatic system health of the
                                                                                                                                                   Chesapeake Bay Ecosystem By 2011,
OW     4.3.4        Chesapeake Bay is improved and acres of
                                                                                                                                                   prevent water pollution and protect aquatic
                    submerged aquatic vegetation (SAV) increase.
                                                                                                                                                   systems so that the overall aquatic system
                    (cumulative)
                                                                                                                                                   health of the Chesapeake Bay is improved.

                    CB-1a - Percent of the point source nitrogen
                                                                                                                                                   Keep
OW     4.3.4        reduction goals achieved.

                    CB-1b - Percent of the point source phosphorus                                                                                 Keep
OW     4.3.4
                    reduction goals achieved.
                    CB-2 - Percent of the forest buffer planting goal                                                                              Keep
OW     4.3.4
                    achieved.




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                      FY 07 ACS Commitment Code & Text                    Regions & Region or State Explanation for Recommendation     NPM response, new code, and New                NPM Rationale
        objective                                                          States &                                                                 Text
                                                                                                                                     SP-35
                                                                                                                                     By 2011, achieve 59 percent (95.88 million
                                                                                                                                     pounds) of the implementation goal for
                    IV-K - Reduction in the number of pounds of                                                                      nitrogen reduction practices necessary to
OW     4.3.4        nitrogen entering the Chesapeake Bay each year                                                                   achieve Chesapeake Bay water quality
                    from 1985 levels.                                                                                                standards, expressed as nitrogen reduction
                                                                                                                                     in relation to achieving a 162.5 million pound
                                                                                                                                     reduction from 1985 level (based on long-
                                                                                                                                     term average hydrology simulations).

                                                                                                                                     SP-36
                                                                                                                                     By 2011, achieve 74 percent (10.63 million
                                                                                                                                     pounds) of the implementation goal for
                                                                                                                                     phosphorus reduction practices necessary to
                    IV-L - Reduction in the number of pounds of
                                                                                                                                     achieve Chesapeake Bay water quality
OW     4.3.4        phosphorus entering the Chesapeake Bay each
                                                                                                                                     standards, expressed as phosphorus
                    year from 1985 levels.
                                                                                                                                     reduction in relation to achieving a 14.36
                                                                                                                                     million pound reduction from 1985 levels
                                                                                                                                     (based on long-term average hydrology
                                                                                                                                     simulations).

                                                                                                                                     SP-37
                                                                                                                                     By 2011 achieve 74 percent (1.25 million
                                                                                                                                     tons) of the implementation goal for sediment
                    IV-M - Reduction in the number of tons of sediment                                                               reduction practices necessary to achieve
OW     4.3.4        entering the Chesapeake Bay each year from 1985                                                                  Chesapeake Bay water quality standards,
                    levels.                                                                                                          expressed as sediment reduction in relation
                                                                                                                                     to achieving a 1.69 million ton reduction from
                                                                                                                                     1985 levels (based on long-term average
                                                                                                                                     hydrology simulations).

                                                                                                                                     SP-38
                    GM-1 - Number of the impaired segments in the 12
                                                                                                                                     By 2011, restore water and habitat quality to
                    priority coastal areas where water and habitat
OW     4.3.5                                                                                                                         meet water quality standards in 162 impaired
                    quality is restored to levels that meet state water
                                                                                                                                     segments (cumulative) in 13 priority coastal
                    quality standards.
                                                                                                                                     areas.
                    GM-2 - Number of additional acres of important in                                                                SP-39
                    coastal and marine habitats that are restored,                                                                   By 2011, restore, enhance, or protect a
OW     4.3.5
                    enhanced, or protected, above improvements                                                                       cumulative 20,000 acres of important coastal
                    accomplished through 2003.                                                                                       and marine habitats.
                    GM-3 - Implement integrated bi-national (U.S. and
                    Mexican Border States) early-warning system to                                                                   GM-1
OW     4.3.5
                    support State and coastal community efforts to
                    manage harmful algal blooms (HABs).
                    GM-4 - Reduce the rate of shellfish-borne Vibrio
                    vulnificus illnesses caused by consumption of
                                                                                                                                     GM-2
OW     4.3.5        commercially-harvested raw or undercooked oysters
                    from the average illness rate for the years 1995-
                    1999.



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                      FY 07 ACS Commitment Code & Text                     Regions & Region or State Explanation for Recommendation     NPM response, new code, and New                 NPM Rationale
        objective                                                           States &                                                                 Text
                                                                                                                                      4.3.5
                    IV-N - Prevent water pollution and improve the                                                                    Subobjective 4.3.5 Improve the Health of the
                    overall aquatic ecosystem health of coastal waters                                                                Gulf of Mexico - By 2011, the overall health of
OW     4.3.5        of the Gulf of Mexico by 0.2 on the "good/fair/poor"                                                              coastal water of the Gulf of Mexico will be
                    scale of the National Coastal Condition Report, a 5-                                                              improved from 2.4 to 2.6 on the
                    point scale in which 1 is poor and 5 is good.                                                                     "good/fair/poor" scale of the National Coastal
                                                                                                                                      Condition Report.
                                                                                                                                      SP-40
                                                                                                                                      By 2015, reduce releases of nutrients
                    IV-O - Reduce releases of nutrients throughout the                                                                throughout the Mississippi River Basin to
OW     4.3.5        Mississippi River basin to reduce the size of the                                                                 reduce the size of the hypoxic zone in the
                    hypoxic zone in the Gulf of Mexico.                                                                               Gulf of Mexico to less than 5,000 km2, as
                                                                                                                                      measured by the 5-year running average of
                                                                                                                                      the size of the zone.
                                                                                                                                      new
                                                                                                                                      By 2011, working with partners, achieve a net
                                                                                                                                      increase of 100,000 acres of wetlands per
OW     4.3.1        SP-21 -
                                                                                                                                      year with additional focus on biological and
                                                                                                                                      functional measures and assessment of
                                                                                                                                      wetland condition.
                                                                                                                                      new
                                                                                                                                      Subobjective 4.2.4: Sustain and Restore the
                                                                                                                                      U.S.-Mexico Border Environmental Health.
OW     4.2.4        -                                                                                                                 By 2012 , sustain and restore the
                                                                                                                                      environmental health along the U.S. -Mexico
                                                                                                                                      border through implementation of the "Border
                                                                                                                                      2012" plan.

                                                                                                                                      new
                                                                                                                                      Subobjective 4.2.5 Sustain and Restore
                                                                                                                                      Pacific Island Territories - By 2011, sustain
OW     4.2.5        -                                                                                                                 and restore the environmental health of the
                                                                                                                                      U.S. Pacific Island Territories of American
                                                                                                                                      Samoa, Guam, and the Commonwealth of
                                                                                                                                      the Northern Mariana Islands.

                                                                                                                                      new
                                                                                                                                      By 2011, 95 percent of the population in each
                                                                                                                                      of the U.S. Pacific Island Territories served
OW     4.2.5        SP-26 -                                                                                                           by community drinking water systems will
                                                                                                                                      receive drinking water that meets all
                                                                                                                                      applicable health-based drinking water
                                                                                                                                      standards throughout the year.
                                                                                                                                      new
                                                                                                                                      By 2011, the sewage treatment plants in the
                                                                                                                                      U.S. Pacific Island Territories will comply 90
OW     4.2.5        SP-27 -
                                                                                                                                      percent of the time with permit limits for
                                                                                                                                      biochemical oxygen demand (BOD) and total
                                                                                                                                      suspended solids (TSS).




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                      FY 07 ACS Commitment Code & Text          Regions & Region or State Explanation for Recommendation    NPM response, new code, and New                NPM Rationale
        objective                                                States &                                                                Text
                                                                                                                           new
                                                                                                                           By 2011, beaches in each of the U.S. Pacific
                                                                                                                           Island Territories monitored under the Beach
OW     4.2.5        SP-28 -
                                                                                                                           Safety Program will be open and safe for
                                                                                                                           swimming 96 percent of days of the beach
                                                                                                                           season.

                                                                                                                           new
OW     4.3.3        GL-5 -                                                                                                 The percentage of near term Great Lakes
                                                                                                                           Actions completed or on track. (cumulative)

                                                                                                                           new
                                                                                                                           By 2011, achieve 45 percent (83,250 acres)
OW     4.3.4        SP-33 -                                                                                                of the 185,000 acres of submerged aquatic
                                                                                                                           vegetation necessary to achieve Chesapeake
                                                                                                                           Bay water quality standards.

                                                                                                                           new
                                                                                                                           By 2011, achieve 40 percent (29.92 km3) of
                                                                                                                           the long-term restoration goal of 100 percent
OW     4.3.4        SP-34 -
                                                                                                                           attainment of the dissolved oxygen water
                                                                                                                           quality standards in all tidal waters of the
                                                                                                                           Bay.

                                                                                                                           new
                                                                                                                           The percentage of near term Gulf of Mexico
OW     4.3.5        GM-3 -
                                                                                                                           Alliance Governors' Action Plan that are
                                                                                                                           completed or on track. (cumulative)


                                                                                                                           new
                                                                                                                           Subobjective 4.3.6 Restore and Protect Long
                                                                                                                           Island Sound - By 2011, prevent water
                                                                                                                           pollution, improve water quality, protect
OW     4.3.6        -
                                                                                                                           aquatic systems, and restore the habitat of
                                                                                                                           Long Island Sound by working through the
                                                                                                                           Long Island Sound Management Study
                                                                                                                           Conference partnership.

                                                                                                                           new
                                                                                                                           By 2014, reduce point source nitrogen
                                                                                                                           discharges to Long Island Sound by 58.5
OW     4.3.6        SP-41 -
                                                                                                                           percent as measured by the Long Island
                                                                                                                           Sound Nitrogen Total Maximum Daily Load
                                                                                                                           (TMDL).




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                      FY 07 ACS Commitment Code & Text          Regions & Region or State Explanation for Recommendation     NPM response, new code, and New                NPM Rationale
        objective                                                States &                                                                 Text
                                                                                                                           new
                                                                                                                           By 2011, reduce the size of hypoxic area in
                                                                                                                           Long Island Sound (i.e., defined as the area
                                                                                                                           in which the long-term average maximum
OW     4.3.6        SP-42 -
                                                                                                                           July-September dissolved oxygen level is
                                                                                                                           <3mg/l by 25 percent; reduce average
                                                                                                                           duration of maximum hypoxic event by 25
                                                                                                                           percent.

                                                                                                                           new
                                                                                                                           By 2011 , restore or protect an additional 300
OW     4.3.6        SP-43 -                                                                                                acres of coastal habitat, including tidal
                                                                                                                           wetlands, dunes, riparian buffers, and
                                                                                                                           freshwater wetlands from the 2005 baseline.


                                                                                                                           new
                                                                                                                           By 2011, reopen an additional 50 miles of
                                                                                                                           river and stream corridor to anadromous fish
OW     4.3.6        SP-44 -
                                                                                                                           passage from the 2005 baseline through
                                                                                                                           removal of dams and barriers or installation
                                                                                                                           of by-pass structures such as fishways.

                                                                                                                           new
                                                                                                                           Subobjective 4.3.7 Restore and Protect the
                                                                                                                           South Florida Ecosystem - Protect and
OW     4.3.7        -
                                                                                                                           maintain the South Florida ecosystem,
                                                                                                                           including the Everglades and coral reef
                                                                                                                           ecosystems.

                                                                                                                           new
                                                                                                                           By 2011, achieve "no net loss" of stony coral
                                                                                                                           cover (mean percent stony coral cover) in the
                                                                                                                           Florida Keys National Marine Sanctuary
OW     4.3.7        SP-45 -
                                                                                                                           (FKNMS) and in the coastal waters of Dade,
                                                                                                                           Broward, and Palm Beach Counties, Florida,
                                                                                                                           working with all stakeholders (federal, state,
                                                                                                                           regional, and local).

                                                                                                                           new
                                                                                                                           Through 2011, beginning in 2008, annually
                                                                                                                           maintain the overall health and functionality
                                                                                                                           of sea grass beds in the FKNMS as
OW     4.3.7        SP-46 -
                                                                                                                           measured by the long-term sea grass
                                                                                                                           monitoring project that addresses
                                                                                                                           composition and abundance, productivity,
                                                                                                                           and nutrient availability.

                                                                                                                           new
                                                                                                                           Through 2011, beginning in 2008, annually
OW     4.3.7        SP-47 -
                                                                                                                           maintain the overall water quality of the near
                                                                                                                           shore and coastal waters of the FKNMS.



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                      FY 07 ACS Commitment Code & Text          Regions & Region or State Explanation for Recommendation     NPM response, new code, and New                NPM Rationale
        objective                                                States &                                                                 Text
                                                                                                                           new
                                                                                                                           Through 2011, beginning in 2008, improve
                                                                                                                           the water quality of the Everglades
                                                                                                                           ecosystem as measured by total phosphorus,
                                                                                                                           including meeting the 10 parts per billion
OW     4.3.7        SP-48 -
                                                                                                                           (ppb) total phosphorus criterion throughout
                                                                                                                           the Everglades Protection Area marsh and
                                                                                                                           the effluent limits to be established for
                                                                                                                           discharges from storm water treatment
                                                                                                                           areas.

                                                                                                                           new
                                                                                                                           Subobjective 4.3.8 Restore and Protect the
                                                                                                                           Puget Sound Basin - By 2011, improve water
OW     4.3.8        -
                                                                                                                           quality, air quality, and minimize the adverse
                                                                                                                           impacts of rapid development in the Puget
                                                                                                                           Sound basin.
                                                                                                                           new
                                                                                                                           By 2011, improve water quality and enable
                                                                                                                           the lifting of harvest restrictions in 1,000
OW     4.3.8        SP-49 -
                                                                                                                           acres of shellfish bed growing areas
                                                                                                                           impacted by degraded or declining water
                                                                                                                           quality.
                                                                                                                           new
OW     4.3.8        SP-50 -                                                                                                By 2011, remediate 200 acres of prioritized
                                                                                                                           contaminated sediments.

                                                                                                                           new
OW     4.3.8        SP-51 -                                                                                                By 2011, restore 3,500 acres of tidally- and
                                                                                                                           seasonally-influenced estuarine wetlands.

                                                                                                                           new
                                                                                                                           Subobjective 4.3.9 Restore and Protect the
                                                                                                                           Columbia River Basin - By 2011, prevent
OW     4.3.9        -                                                                                                      water pollution and improve and protect
                                                                                                                           water quality and ecosystems in the
                                                                                                                           Columbia River Basin to reduce risks to
                                                                                                                           human health and the environment.
                                                                                                                           new
                                                                                                                           By 2011, protect, enhance, or restore 13,000
OW     4.3.9        SP-52 -                                                                                                acres of wetland habitat and 3,000 acres of
                                                                                                                           upland habitat in the Lower Columbia River
                                                                                                                           watershed.
                                                                                                                           new
OW     4.3.9        SP-53 -                                                                                                By 2011, clean up 150 acres of known highly
                                                                                                                           contaminated sediments.




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                       FY 07 ACS Commitment Code & Text          Regions & Region or State Explanation for Recommendation     NPM response, new code, and New               NPM Rationale
         objective                                                States &                                                                 Text
                                                                                                                            new
                                                                                                                            By 2011, demonstrate a 10 percent reduction
OW      4.3.9        SP-54 -
                                                                                                                            in mean concentration of contaminants of
                                                                                                                            concern found in water and fish tissue.

                     -

                                                                                                                            new
                                                                                                                            Annual percentage of viable lead-based paint
OPPTS   4.1.3        -                                                                                                      certification applications that require less
                                                                                                                            than grantee state-established timeframes to
                                                                                                                            process.
                                                                                                                            new
                                                                                                                            Annual percentage of viable lead-based paint
OPPTS   4.1.3        -                                                                                                      certification applications that require less
                                                                                                                            than X days of EPA Regional effort to
                                                                                                                            process.
                                                                                                                            Annual percentage of viable lead-based paint
                                                                                                                            certification applications that require less
OPPTS
                                                                                                                            than grantee state-established timeframes to
                                                                                                                            process.
                                                                                                                            Annual percentage of viable lead-based paint
                                                                                                                            certification applications that require less
OPPTS
                                                                                                                            than X days of EPA Regional effort to
                                                                                                                            process.
                                                                                                                            Average percent change in the utilization of
                                                                                                                            reduced risk pest management practices
OPPTS
                                                                                                                            over time as determined by the SAI
                                                                                                                            Transition Gradient.
                                                                                                                            Increase knowledge of the container-
                                                                                                                            containment rule requirements among states,
OPPTS                                                                                                                       retailers, refillers, commercial pesticide
                                                                                                                            applicators, custom blenders, and pesticide
                                                                                                                            users.

                                                                                                                            Increase the state‟s ability to ensure
OPPTS                                                                                                                       compliance with containment requirements of
                                                                                                                            the container-containment rule.

                                                                                                                            Increase the state‟s ability to ensure
OPPTS                                                                                                                       compliance with the residue removal
                                                                                                                            requirements for clean refillable containers.

                                                                                                                            Number of evaluated pesticides of concern
                                                                                                                            that have been placed under State or Tribal
                                                                                                                            Program management due to their propensity
OPPTS
                                                                                                                            to exceed national water quality standards or
                                                                                                                            other human health or ecological reference
                                                                                                                            points.




                                                                                            Page 69             OW Lead Region 4 is in agreement with OW's proposed list of measures
                                                                                                           DRAFT
                                                        Assessment of Measures Review Initiative Results for Goal 4
 NPM       Sub-        Note: Cell entries below are hypothetical
                         FY 07 ACS Commitment Code & Text                  Regions & Region or State Explanation for Recommendation                       NPM response, new code, and New                NPM Rationale
         objective                                                          States &                                                                                   Text
                                                                                                                                                        Number of Region-specific projects or
                                                                                                                                                        initiatives contributing to the implementation
                                                                                                                                                        and enhancement of the C&T field program,
OPPTS                                                                                                                                                   and the improved competency of certified
                                                                                                                                                        pesticide applicators.


                                                                                                                                                        Number of Region-specific projects or
                                                                                                                                                        initiatives contributing to the implementation
                                                                                                                                                        and enhancement of the worker protection
OPPTS                                                                                                                                                   (WPS) field program, and the protection of
                                                                                                                                                        agricultural pesticide workers.


                                                                                                                                                        Number of SAI collaborative actions that
                                                                                                                                                        support the sustainability of American
OPPTS                                                                                                                                                   agriculture by working with others to address
                                                                                                                                                        pesticide risk issues of Regional and National
                                                                                                                                                        concern.

                                                                                                                                                        new
OSWER   4.1.2           -
                                                                                                                                                        Number of inspection/drills at FRP facilities


                                                                                      Not useful to track measures when there is a significant time
                                                                                      lag – and incredibly laborious to do so. First suggestion is
                                                                                      to delete all of these measures. Failing that, suggest that all
                         n/a - All measures that track state or grantee   1
                                                                                      of these state commitments are measured on the end-of-3rd-
        All measures performance                                          M or D
                                                                                      quarter interval, recognizing that this would entail an
        that track state                                                              increase in progress reporting for these entities and for all
        or grantee                                                                    levels of EPA that track this information.
        performance




                                                                                                            Page 70                     OW Lead Region 4 is in agreement with OW's proposed list of measures
                                                                                                                            DRAFT

                                                          Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                    Regions &       Region or State Explanation for Recommendation                      NPM response, new code, and                  NPM Rationale
        objectiv                                                                  States &                                                                                    New Text
                987 - Percentage of regulated entities seeking assistance
                from EPA-sponsored CA centers and clearinghouse                  2           This measure only relates to HQ-controlled activities and thus is not   Delete
OECA    5.1.1
                reporting that they improved EMP as a result of their use of     D           appropriate for ACS.
                the centers or the clearinghouse.
                                                                                             This measure only captures reported changes. It should be modified
                988 - Percentage of regulated entities receiving direct
                                                                                             to capture actual changes. Modification: Percentage of regulated
                compliance assistance from EPA (e.g, training, on-site visits) 2                                                                                Delete
OECA    5.1.1                                                                                entities receiving direct compliance assistance from EPA (e.g.
                reporting that they improved EMP as a result of EPA            M
                                                                                             training, on-site visits) that improved EMP as a result of EPA
                assistance.
                                                                                             assistance.
                989 - % of regulated entities seeking assistance from EPA-
                sponsored CA centers and clearinghouse reporting that they 2                 This measure only relates to HQ-controlled activities and thus is not   Delete
OECA    5.1.1
                reduced, treated, or eliminated pollution as a result of that D              appropriate for ACS.
                resource.
                990 - % of regulated entities seeking assistance from EPA-
                sponsored CA centers and clearinghouse reporting that they 2                 This measure only relates to HQ-controlled activities and thus is not   Delete
OECA    5.1.1
                increased their understanding of env. rqmts. as a result of D                appropriate for ACS.
                their use of the resources.
                                                                                             This measure only captures reported changes. It should be modified
                991 - % of regulated entities receiving direct CA from EPA
                                                                                             to capture actual changes. Modification: % of regulated entities
                (e.g., training, on-site visits) reporting that they increased   2                                                                                 Delete
OECA    5.1.1                                                                                receiving direct assistance from EPA (e.g., training, on-site visits)
                their understanding of env. rqmts. as a result of EPA            M
                                                                                             that increased their understanding of environmental requirements as
                assistance.
                                                                                             a result of EPA assistance.
                                                                                             R1- Largely duplicative of ASST 01 and a better measure – Just add
                                                                                             “workshops” and “revisits” to the text of this measure and track in
                992 - % of regulated entities receiving direct assistance from
                                                                                             ICIS
                EPA (e.g., training, on-site visits) reporting that they reduced, 1,2,8                                                                              Delete
OECA    5.1.1
                treated, or eliminated pollution, as a result of EPA              M
                                                                                             R2- Largely duplicative of ASST 01 and a better measure – Just add
                assistance.
                                                                                             “workshops” and “revisits” to the text of this measure and track in
                                                                                             ICIS
                                                                                             R1- Not a particularly useful measure and tracking the status of this
                                                                                             manual measure in FY 06 was laborious and inefficient. Information
                                                                                             is already contained in #992 above with slight modifications noted –                                  The GPRA measures for compliance assistance
                                                                                             and is automatically generated once input into ICIS.                                                  (CA) and the ACS commitment for CA do not
                                                                                                                                                                                                   track the same or significantly similar data. The
                                                                                             R2- 100% commitments are not appropriate for the ACS since they                                       CA data collected for GPRA includes all direct
                                                                                             do not allow a region to make a commitment based on a realistic                                       CA provided by EPA to regulated entities. The
                                                                                             assessment since OECA insists on a commitment level at the 100%                                       ACS commitment, on the other hand, is specific
                                                                                             level. Also, some CA activities are conducted in partnership with                                     to a subset of EPA CA activities
                                                                                             others and we do not always have the ability to conduct                                               (workshops/training and onsite visits/revisits) for
                                                                                             measurement. For example, if we partnered with the NYS Empire                                         OECA‟s national priorities only. The commitment
                ASST01 - Conduct outcome measurement for 100% of all                         State Development on an activity for small businesses, we would not Keep                              tracks whether EPA staff conducted
                                                                              1,2,6
OECA    5.1.1   compliance assistance workshops, training, onsite visits, and                be able to collect certain measures since New York has statutory                                      measurement to ascertain if the recipients (both
                                                                              D, M
                revisits which support the OECA national priorities.                         provisions that require confidentiality for small business assistance                                 regulated entities and assistance providers) of
                                                                                             and ESD is barred from sharing names of facilities, mailing lists,                                    this CA reported outcomes, e.g., increased
                                                                                             attendee lists, etc. with us. Also, in some partnering situations, the                                understanding of environmental requirements,
                                                                                             partner sets the agenda and does not allow us the opportunity to                                      improved EMPs, etc. The goal of having this
                                                                                             collect core evaluation information or conduct pre/post testing due to                                ACS commitment is to ensure that EPA staff
                                                                                             time constraints or conflicts with their evaluations. HQ expectations                                 measure, at a minimum, the outcomes of CA
                                                                                             (as evidenced during regional visits) are that we attempt to collect all                              activities supporting OECA‟s national priorities
                                                                                             three measurement types for all direct CA. For activities conducted                                   where they have the greatest opportunity to ask
                                                                                             in the 4Q, insufficient time will have passed before quality                                          for this information and then report the results in
                                                                                             measurement can occur. Also, ICIS is not properly designed to                                         ICIS.
                                                                                             accurately capture certain types of measurement. For example, a
                                                                                             survey that attempts to capture measurement of a range of activities




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                                                          Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                 Regions &       Region or State Explanation for Recommendation                       NPM response, new code, and                  NPM Rationale
        objectiv                                                               States &                                                                                     New Text
                                                                                                                                                                                                 General response: As a general matter, FFEO is
                                                                                                                                                                                                 open to discussing with all regions alternatives to
                                                                                                                                                                                                 structuring ACS commitments to focus on
                                                                                                                                                                                                 Integrated Strategies (see details on this below);
                                                                                                                                                                                                 however, FFEO believes that specific numerical
                                                                                          R-2 This commitment is so broad as to be meaningless. A
                                                                                                                                                                                                 commitments are necessary to maintain a viable
                                                                                          compliance assistance activity could range from simply answering a
                                                                                                                                                                                                 EPA field presence and an effective federal
                                                                                          question from a regulated entity or recording a visit to a website
                                                                                                                                                                                                 facility compliance and enforcement program.
                                                                                          (response to inquiry) or could involve a substantial expenditure of
                                                                                                                                                                                                 Any restructuring of ACS commitments must
                                                                                          resources to develop, organize, and present a full-day or multi-day
                                                                                                                                                                                                 include specific numerical commitments for
                                                                                          workshop. Also, since these are activities to support integrated
                                                                                                                                                                                                 compliance assistance and compliance
                                                                                          strategies and the integrated strategy approach allows the selection
                                                                                                                                                                                                 monitoring activities. FFEO would work with
                                                                                          of the best tool to address non-compliance, the Region should be
                                                                                                                                                                                                 Region 2, as lead Region, to involve all Regions
                                                                                          allowed to select tools other than compliance assistance if other
                FEDFAC01 - Each Region shall conduct at least two                                                                                                                                in an ACS restructuring discussion. Region 6‟s
                                                                              2,6,10      tools are believed to provide better results.                        Keep
OECA    5.1.1   compliance assistance activities for Federal facilities to                                                                                                                       comment concerns recording inspections in data
                                                                              D
                support the integrated strategy areas.                                                                                                                                           bases. Even though completed inspections are
                                                                                          R6- No value added. Inspections for Federal Facilities will be
                                                                                                                                                                                                 recorded in various data systems, simply
                                                                                          captured under the various programmatic areas.
                                                                                                                                                                                                 recording of them does not commit a region to
                                                                                                                                                                                                 conduct them. The measure is key to ensuring
                                                                                          R10- Compliance assistance at federal facilities in the Integrated
                                                                                                                                                                                                 that multimedia inspections are conducted by
                                                                                          Strategy areas may not the highest priority activities in a particular
                                                                                                                                                                                                 Regions.FFEO understands the Region 2 and 10
                                                                                          Region each year. Asking for at least two activities substantially
                                                                                                                                                                                                 comments to add flexibility to the ACS
                                                                                          reduces Regional flexibility to address other or more critical needs.
                                                                                                                                                                                                 commitments. FFEO is open to discuss with all
                                                                                          Federal facility compliance assistance would continue to be reported
                                                                                                                                                                                                 the Regions a restructuring of the ACS
                                                                                          in ICIS and therefore would be reported outside ACS.
                                                                                                                                                                                                 commitments to focus on Integrated Strategies
                                                                                                                                                                                                 which could provide Regions with more visible
                                                                                                                                                                                                 flexibility in balancing compliance assistance and
                                                                                                                                                                                                 compliance monitoring activities in a strategy
                                                                                                                                                                                                 area. However, FFEO believes that any new
                                                                                                                                                                                                 structure must include numerical commitments
                                                                                                                                                                                                 OECA is currently reviewing and revising its
                PBS-CAFO05 - Number of workshops, training sessions,                                                                                                                             national priority strategies for the FY 2008 - 2010
                and /or presentations given for AFO/CAFO operators,           6                                                                                    Keep                          period. Based on this review goals and
OECA    5.1.1
                states/tribes, compliance assistance providers, and Ag        (M)                                                                                                                measures will likely change. Given this, we will
                organizations.                                                             Make into a Non-commitment Indicator only. This is the means for                                      consider these comments as appropriate when
                                                                                          obtaining and recording results. Recommend tracking but not                                            new priority measures are developed.
                                                                                          making a commitment

                                                                                                                                                                                                 OECA is currently reviewing and revising its
                PBS-CSO05 - Number of *facilities that will receive
                                                                                                                                                                                                 national priority strategies for the FY 2008 - 2010
                assistance in '07. (*Permitted CSOs that will not have an
                                                                              2                                                                                    Keep                          period. Based on this review goals and
OECA    5.1.1   approved LTCP with an enforceable schedule or where an                    This is not a significant measure. More important than the number of
                                                                              D                                                                                                                  measures will likely change. Given this, we will
                action will result in an enforceable LTCP has not been                    facilities receiving assistance is the number of CSOs that have or                                     consider these comments as appropriate when
                planned or initiated.)                                                    are on the path to have LTCPs in place, which is already covered                                       new priority measures are developed.
                                                                                          under PBS-CSO01 and PBS-CSO02

                                                                                          R6- Recommend tracking but not making a commitment. These                                              OECA is currently reviewing and revising its
                                                                                          activities are part of each of the individual programmatic areas.                                      national priority strategies for the FY 2008 - 2010
                PBS-TB03 - By September 30, 2007, Regions will provide
                                                                              6910                                                                                 Keep                          period. Based on this review goals and
OECA    5.1.1   compliance assistance to Bureau of Indian Affairs (BIA) and
                                                                              D, M        R9- This is just a request to do something. Rewrite or drop.                                           measures will likely change. Given this, we will
                non-BIA schools.
                                                                                                                                                                                                 consider these comments as appropriate when
                                                                                          R10- This is just a request to do something. Rewrite or drop.                                          new priority measures are developed.




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                                                         Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                    Regions &       Region or State Explanation for Recommendation                        NPM response, new code, and                  NPM Rationale
        objectiv                                                                  States &                                                                                      New Text
                                                                                             R6- No value added
                PBS-TB05 - By September 30, 2007, Regions will provide                                                                                                                               OECA is currently reviewing and revising its
                compliance assistance to 100% of tribal public water                         R7- Measure unnecessary. It does not provide any clear results                                          national priority strategies for the FY 2008 - 2010
                systems. Regional Compliance Assistance Coordinators will 6,7,10             and this work is being done anyway under Goal 2.                          Keep                          period. Based on this review goals and
OECA    5.1.1
                work with program offices to report into ICIS the outcomes of D                                                                                                                      measures will likely change. Given this, we will
                any direct compliance assistance activities provided to these                R10- Since the data are already reported in ICIS, it seems redundant                                    consider these comments as appropriate when
                systems.                                                                     to have an ACS commitment to provide compliance assistance to                                           new priority measures are developed.
                                                                                             100% of tribal public water systems.

                                                                                                                                                                                                     OECA is currently reviewing and revising its
                                                                                                                                                                                                     national priority strategies for the FY 2008 - 2010
                PBS-TB08 - By September 30, 2007, Regions will provide
                                                                                 6                                                                                     Keep                          period. Based on this review goals and
OECA    5.1.1   waste management compliance and technical assistance to                      No value added
                                                                                 D                                                                                                                   measures will likely change. Given this, we will
                tribes.
                                                                                                                                                                                                     consider these comments as appropriate when
                                                                                                                                                                                                     new priority measures are developed.

                174 - Percentage of audits or other actions that result in the
                                                                                 2                                                                                 Delete
OECA    5.1.2   reduction, treatment, or elimination of pollutants and the                   “Other actions” should be defined in this measure so that there is no
                                                                                 M
                protection of populations or ecosystems.                                     misunderstanding as to what is included.
                175 - Percentage of audits or other actions that result in       2           “Other actions” should be defined in this measure so that there is no Delete
OECA    5.1.2
                improvements in env. management practices.                       M           misunderstanding as to what is included.
                                                                                             “Other actions” should be defined in this measure so that there is no
                                                                                             misunderstanding as to what is included. Also, OECA has previously
                176 - Pounds of pollutants reduced, treated, or eliminated, as 2             clarified that this measure is intended to capture reductions from all Delete
OECA    5.1.2
                a result of audit agreements or other actions.                 M             voluntary disclosures; not just audit agreements. Therefore the
                                                                                             wording should be modified to accurately reflect the intent of this
                                                                                             measure.
                                                                                             “Other actions” should be defined in this measure so that
                177 - Dollars invested in improving environmental                            there is no misunderstanding as to what is included. Also,
                                                                                 2                                                                                     Delete
OECA    5.1.2   management practices as a result of audit agreements or                      dollars invested in returning to compliance should be
                                                                                 M
                other actions.
                                                                                             captured separately from dollars invested in going beyond
                                                                                             compliance.
                                                                                             OECA only counts certain types of reductions in this category (see
                                                                                             select logic from EOY workbooks), therefore this measure should be
                                                                                             modified to more accurately reflect what it is measuring. Another
                                                                                             concern associated with this measure is the lack of a suitable report
                                                                                             in ICIS that would enable the region to monitor its progress
                                                                                             throughout the year. Currently, environmental benefits are entered
                                                                                             into ICIS in various units (e.g., pounds, gallons, cubic yards, housing
                                                                                             units, etc.) depending on the program area. The available report in
                                                                                             ICIS uses these same units. However, the mid-year and end-of-year
                178 - Pounds of pollution estimated to be reduced, treated,      2           data certifications use only a subset of these benefits (e.g.,             Delete
OECA    5.1.3                                                                                environmental benefits from soil cleanups under RCRA are
                eliminated as a result of concluded enforcement actions.         D or M
                                                                                             excluded) and the data are manually converted by HQs staff into
                                                                                             pounds for reporting purposes. This prevents the region from
                                                                                             monitoring progress on achievements in these areas throughout the
                                                                                             year. Either ICIS should be modified so that environmental benefits
                                                                                             data can be entered in pounds for all programs (if a program also
                                                                                             wants the data reported in another unit, then a second data entry
                                                                                             field could be utilized for the alternate reporting) or a report should be
                                                                                             created that allows the region to monitor its progress without having
                                                                                             to wait for the environmental benefits spreadsheet provided by HQs
                                                                                             once or twice a year. If such a report is not made available, this




                                                                                                                               Page 73
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                                                         Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                    Regions &       Region or State Explanation for Recommendation                        NPM response, new code, and                   NPM Rationale
        objectiv                                                                  States &                                                                                      New Text

                                                                                             This measure should be modified such that the percentage is
                                                                                             calculated solely from the universe of concluded cases for which
                179 - Percentage of concluded enforcement cases (including                   such results are reasonably expected. For example, in instances
                                                                           2                 where the violations involved are paperwork or reporting violations,      Delete
OECA    5.1.3   SEPs) requiring that pollutants be reduced, treated, or
                                                                           M                 where a facility has ceased operating the noncompliant unit, or
                eliminated and protection of populations or ecosystems.
                                                                                             where the action was solely to collect a penalty, it is not generally
                                                                                             reasonable to expect a facility to implement changes or conduct a
                                                                                             SEP that would result in reduced pollution and/or improved
                                                                                             environmental practices.

                                                                                             R1- We understand that OMB has agreed in principle to delete this
                                                                                             measure, and we support this decision.

                                                                                             R2- This measure should be modified such that the percentage is
                                                                                             calculated solely from the universe of concluded cases for which
                180 - Percentage of concluded enforcement cases (including
                                                                           1,2               such results are reasonably expected. For example, in instances           Delete
OECA    5.1.3   SEPs) requiring implementation of improved env.
                                                                           D, M              where the violations involved are paperwork or reporting violations,
                management practices.
                                                                                             where a facility has ceased operating the noncompliant unit, or
                                                                                             where the action was solely to collect a penalty, it is not generally
                                                                                             reasonable to expect a facility to implement changes or conduct a
                                                                                             SEP that would result in reduced pollution and/or improved
                                                                                             environmental practices.

                181 - Number of inspections, civil investigations and criminal                                                                                         Delete
OECA    5.1.3
                investigations conducted.
                                                                                             R1- We understand that OMB has agreed in principle to delete this
                                                                                             measure, and we support this decision.
                183 - Dollars invested in improved env. performance or
                                                                          1,2                                                                                          Delete
OECA    5.1.3   improved EMP as a result of concluded enforcement actions
                                                                          D, M               R2- This measure should be modified such that dollars invested in
                (i.e., injunctive relief and SEPs)
                                                                                             returning to compliance are captured separately from dollars
                                                                                             invested in going beyond compliance.



                                                                                             R2- This requirement is redundant since it is already covered in the
                                                                                             NPM annual guidance and in the Compliance Monitoring Strategy
                                                                                                                                                                                                     We do not agree that guidance and an ACS
                                                                                             R6- Combine CAA01, 02, 03, and 05, for a total Air
                                                                                                                                                                                                     commitment are equivalent. Guidance identifies
                                                                                             inspection/investigation commitment, and eliminating state by state
                                                                                                                                                                                                     a performance requirement or expectation while
                                                                                             breakouts. New language: Total number of federal CAA
                                                                                                                                                                                                     the ACS commitment is an up-front agreement to
                                                                                             Inspections/Investigations (excluding CAA112r). Recommend
                                                                                                                                                                                                     a level of performance for the coming year that is
                                                                                             combining with other Air inspections/investigations measures into
                                                                                                                                                                                                     used as a work planning tool for the core
                                                                                             one total Air commitment. This will provide flexibility for the Regions
                CAA01 - Number of federal FCEs to be conducted at Title V        2, 6,8,10                                                                             Keep                          program and national priorities.
OECA    5.1.3                                                                                while providing OECA an overall commitment.
                majors.                                                          D, M                                                                                                                The commitments are needed to verify that the
                                                                                                                                                                                                     regions and states proactively conduct activities
                                                                                             R8- These measures are not activities that are generally relevant to
                                                                                                                                                                                                     to meet the CAA Compliance Monitoring Strategy
                                                                                             most of the Air Enforcement Programs outcome measures. (Martin
                                                                                                                                                                                                     objectives and goals. The eight ACS measures
                                                                                             Hestmark, Region 8)
                                                                                                                                                                                                     that apply to the regions and states are not overly
                                                                                                                                                                                                     difficult to achieve, and provide clear indicators of
                                                                                             R10- Delete all on this sheet. Come up with 1 significantly critical
                                                                                                                                                                                                     program results.
                                                                                             inspection measure for Air, NPDES & RCRA only and one each for
                                                                                             States. Remaining program inspections are already entered in ICIS
                                                                                             and legacy databases for HQ to retrieve.




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                                                      Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples               Regions &       Region or State Explanation for Recommendation                     NPM response, new code, and                   NPM Rationale
        objectiv                                                             States &                                                                                   New Text

                                                                                        R2- Make into a Non-commitment Indicator only. This is a State                                       The commitments are needed to verify that the
                                                                                        commitment. Recommend tracking but not making a commitment.                                          regions and states proactively conduct activities
                                                                                                                                                                                             to meet the CAA Compliance Monitoring Strategy
                                                                                        R6-This is a State commitment. Recommend tracking but not                                            objectives and goals. The eight ACS measures
                                                                                        making a commitment.                                                                                 that apply to the regions and states are not overly
                                                                                                                                                                                             difficult to achieve, and provide clear indicators of
                CAA01.s - Number of state FCEs to be conducted at Title V   2, 6,8,10   R8- These measures are not activities that are generally relevant to   Keep                          program results.
OECA    5.1.3
                majors.                                                                 most of the Air Enforcement Programs outcome measures. (Martin                                       It is important that the regions obtain information
                                                                                        Hestmark, Region 8)                                                                                  from the states for these commitments since it
                                                                                                                                                                                             impacts what the regions commit to for CAA01,
                                                                                        R10- Delete all on this sheet. Come up with 1 significantly critical                                 CAA02, and CAA03. The CAA Compliance
                                                                                        inspection measure for Air, NPDES & RCRA only and one each for                                       Monitoring Strategy applies to both the regions
                                                                                        States. Remaining program inspections are already entered in ICIS                                    and states, but the majority of the activities are
                                                                                        and legacy databases for HQ to retrieve.                                                             implemented by the states.



                                                                                        R2- This requirement is redundant since it is already covered in the
                                                                                        NPM annual guidance and in the Compliance Monitoring Strategy

                                                                                        R6- Combine with CAA01
                CAA02 - The number of federal FCEs at "80% synthetic        6,8,10                                                                             Keep
OECA    5.1.3                                                                           R8- These measures are not activities that are generally relevant to
                minors" and other sources.                                  D
                                                                                        most of the Air Enforcement Programs outcome measures. (Martin
                                                                                        Hestmark, Region 8




                                                                                                                                                                                             The commitments are needed to verify that the
                                                                                                                                                                                             regions and states proactively conduct activities
                                                                                        R2- Make into a Non-commitment Indicator only. This is a State
                                                                                                                                                                                             to meet the CAA Compliance Monitoring Strategy
                                                                                        commitment. Recommend tracking but not making a commitment.
                                                                                                                                                                                             objectives and goals. The eight ACS measures
                                                                                                                                                                                             that apply to the regions and states are not overly
                                                                                        R6- This is a State commitment. Recommend tracking but not
                                                                                                                                                                                             difficult to achieve, and provide clear indicators of
                                                                                        making a commitment.
                CAA02.s - The number of state FCEs at "80% synthetic        2, 6,8,10                                                                          Keep                          program results.
OECA    5.1.3
                minors" and other sources.                                  D                                                                                                                It is important that the regions obtain information
                                                                                        R8-These measures are not activities that are generally relevant to
                                                                                                                                                                                             from the states for these commitments since it
                                                                                        most of the Air Enforcement Programs outcome measures. (Martin
                                                                                                                                                                                             impacts what the regions commit to for CAA01,
                                                                                        Hestmark, Region 8
                                                                                                                                                                                             CAA02, and CAA03. The CAA Compliance
                                                                                                                                                                                             Monitoring Strategy applies to both the regions
                                                                                        R10
                                                                                                                                                                                             and states, but the majority of the activities are
                                                                                                                                                                                             implemented by the states.




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                                                        Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                  Regions &       Region or State Explanation for Recommendation                     NPM response, new code, and                   NPM Rationale
        objectiv                                                                States &                                                                                   New Text

                                                                                                                                                                                                We do not agree that guidance and an ACS
                                                                                                                                                                                                commitment are equivalent. Guidance identifies
                                                                                                                                                                                                a performance requirement or expectation while
                                                                                           R2- This requirement is redundant since it is already covered in the
                                                                                                                                                                                                the ACS commitment is an up-front agreement to
                                                                                           NPM annual guidance and in the Compliance Monitoring Strategy
                                                                                                                                                                                                a level of performance for the coming year that is
                                                                                                                                                                                                used as a work planning tool for the core
                                                                                           R6- Combine with CAA01
                                                                               2, 6,8,10                                                                          Keep                          program and national priorities.
OECA    5.1.3   CAA03 - Number of PCEs to be conducted by the regions.
                                                                               D                                                                                                                The commitments are needed to verify that the
                                                                                           R8- These measures are not activities that are generally relevant to
                                                                                                                                                                                                regions and states proactively conduct activities
                                                                                           most of the Air Enforcement Programs outcome measures. (Martin
                                                                                                                                                                                                to meet the CAA Compliance Monitoring Strategy
                                                                                           Hestmark, Region 8)
                                                                                                                                                                                                objectives and goals. The eight ACS measures
                                                                                                                                                                                                that apply to the regions and states are not overly
                                                                                                                                                                                                difficult to achieve, and provide clear indicators of
                                                                                                                                                                                                program results.




                                                                                                                                                                                                The commitments are needed to verify that the
                                                                                                                                                                                                regions and states proactively conduct activities
                                                                                                                                                                                                to meet the CAA Compliance Monitoring Strategy
                                                                                           R2- Make into a Non-commitment Indicator only. This is a State
                                                                                                                                                                                                objectives and goals. The eight ACS measures
                                                                                           commitment. Recommend tracking but not making a commitment.
                                                                                                                                                                                                that apply to the regions and states are not overly
                                                                                                                                                                                                difficult to achieve, and provide clear indicators of
                CAA03.s - The number of state PCEs to be conducted that                    R6- This is a State commitment. Recommend tracking but not
                                                                               2, 6,8,10                                                                          Keep                          program results.
OECA    5.1.3   were the result of the negotiation process for the year (could             making a commitment
                                                                               D, M                                                                                                             It is important that the regions obtain information
                be the result of redirecting resources from FCEs to PCEs).
                                                                                                                                                                                                from the states for these commitments since it
                                                                                           R8- Not a useful measure. Unclear why this is being reported in the
                                                                                                                                                                                                impacts what the regions commit to for CAA01,
                                                                                           ACS. (Martin Hestmark, Region 8)
                                                                                                                                                                                                CAA02, and CAA03. The CAA Compliance
                                                                                                                                                                                                Monitoring Strategy applies to both the regions
                                                                                                                                                                                                and states, but the majority of the activities are
                                                                                                                                                                                                implemented by the states.




                                                                                                                                                                                                We do not agree that guidance and an ACS
                                                                                                                                                                                                commitment are equivalent. Guidance identifies
                                                                                                                                                                                                a performance requirement or expectation while
                                                                                                                                                                                                the ACS commitment is an up-front agreement to
                                                                                                                                                                                                a level of performance for the coming year that is
                                                                                           R2- This requirement is redundant since it is already covered in the                                 used as a work planning tool for the core
                CAA05 - Regions should project the number of investigations 2, 6           NPM annual guidance and in the Compliance Monitoring Strategy          Keep                          program and national priorities.
OECA    5.1.3
                to be initiated in FY 2007.                                 D                                                                                                                   The commitments are needed to verify that the
                                                                                           R6- Combine with CAA01                                                                               regions and states proactively conduct activities
                                                                                                                                                                                                to meet the CAA Compliance Monitoring Strategy
                                                                                                                                                                                                objectives and goals. The eight ACS measures
                                                                                                                                                                                                that apply to the regions and states are not overly
                                                                                                                                                                                                difficult to achieve, and provide clear indicators of
                                                                                                                                                                                                program results.




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  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                 Regions &         Region or State Explanation for Recommendation                      NPM response, new code, and                  NPM Rationale
        objectiv                                                               States &                                                                                      New Text

                                                                                            R2- This requirement redundant since it is already covered in the
                                                                                            NPM annual guidance.

                                                                                            R3- See explanation for CH2
                CAA11 - Conduct inspections at 5% of the total number of      2, 3,6                                                                                Keep
OECA    5.1.3
                facilities in the region required to submit RMPs.             D, M
                                                                                            R6- New language: Total number of CAA 112r
                                                                                            inspections/investigations for facilities required to submit RMPs.
                                                                                            To clarify that this is under CAA 112r. Also removes the reference to
                                                                                            a percentage of a universe, as this can be a moving target



                                                                                                                                                                                                  We do not agree that guidance and an ACS
                                                                                                                                                                                                  commitment are equivalent. Guidance identifies
                                                                                            R2- This requirement is covered in the NPM annual guidance, in the
                                                                                                                                                                                                  a performance requirement or expectation while
                                                                                            Compliance Monitoring Strategy, and in state grants. Also, this is
                                                                                                                                                                                                  the ACS commitment is an up-front agreement to
                                                                                            covered under the State Review Framework.
                                                                                                                                                                                                  a level of performance for the coming year that is
                                                                                                                                                                                                  used as a work planning tool for the core
                                                                                            R6- This is part of our Core work for State oversight and we do not
                                                                                                                                                                                                  program and national priorities. While it is easier
                                                                                            see a value added as an ACS commitment.
                                                                                                                                                                                                  for the regions to meet fewer measures, we don't
                                                                                                                                                                                                  believe the NPM guidance provides sufficient
                                                                                         R10- There‟s likely no specific written requirement that states agree
                                                                                                                                                                                                  accountability. These two ACS commitments
                                                                                         in writing to these measures. In addition, having ACS measure
                                                                                                                                                                                                  demonstrate the importance OECA places on
                                                                                         doesn‟t influence whether or not states do the reporting. For the
                                                                                                                                                                                                  complete and accurate entry of compliance
                                                                                         MDR, if states don‟t agree, then Regions would do. And lastly, and
                CAA16 - Regions should ensure that delegated agencies                                                                                                                             monitoring and enforcement data into national
                                                                                         perhaps most importantly, these measures do not seem to contribute
                have written agreements to provide complete, accurate, and                                                                                                                        databases by the regions and states. Also, these
                                                                                         to any significant mission or environmental success. As ACS
                timely data consistent with the Agency policies and ICR;   1,2, 6,10, IL                                                                            Keep                          commitments also are needed to verify that the
OECA    5.1.3                                                                            measures, what difference have these made.
                identify the agreement; and provide copies of the relevant D, M                                                                                                                   regions and states are following the CAA
                language.                                                                                                                                                                         Compliance Monitoring Strategy.
                                                                                         IL- Illinois EPA does have an agreement with Region 5. However,
                                                                                                                                                                                                  While it is easier for the regions to meet fewer
                                                                                         some of the information the Region says is mandatory to send to
                                                                                                                                                                                                  measures, we don't believe the NPM guidance
                                                                                         AFS is of limited or no discernable value. Illinois has commented on
                                                                                                                                                                                                  provides sufficient accountability. These two
                                                                                         these specifically under the State Reporting Burden Review, but
                                                                                                                                                                                                  ACS commitments demonstrate the importance
                                                                                         briefly, these include reporting of stack test reviews, reporting of Title
                                                                                                                                                                                                  OECA places on complete and accurate entry of
                                                                                         V annual certification reviews, and reporting of HPV criteria code,
                                                                                                                                                                                                  compliance monitoring and enforcement data into
                                                                                         violating pollutant, and method of violation discovery to AFS. Region
                                                                                                                                                                                                  national databases by the regions and states.
                                                                                         5 has yet to explain why it is necessary to report HPV criteria code,
                                                                                                                                                                                                  Also, these commitments also are needed to
                                                                                         violating pollutant, and method of violation discovery. Reporting the
                                                                                                                                                                                                  verify that the regions and states are following
                                                                                         pollutant and method by which every violation is discovered are
                                                                                                                                                                                                  the CAA Compliance Monitoring Strategy.
                                                                                         added steps that provide essentially meaningless data. These
                                                                                         requirements should be eliminated.
                                                                                                                                                                                                  This comment only covers federal Clean Air Act
                                                                                                                                                                                                  activities.




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                                                          Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                    Regions &        Region or State Explanation for Recommendation                     NPM response, new code, and                  NPM Rationale
        objectiv                                                                  States &                                                                                    New Text

                                                                                                                                                                                                   We do not agree that guidance and an ACS
                                                                                                                                                                                                   commitment are equivalent. Guidance identifies
                                                                                                                                                                                                   a performance requirement or expectation while
                                                                                                                                                                                                   the ACS commitment is an up-front agreement to
                                                                                                                                                                                                   a level of performance for the coming year that is
                                                                                                                                                                                                   used as a work planning tool for the core
                                                                                                                                                                                                   program and national priorities. While it is easier
                                                                                              R2- This requirement is covered in the NPM annual guidance, in the
                                                                                                                                                                                                   for the regions to meet fewer measures, we don't
                                                                                              Compliance Monitoring Strategy, and in state grants. Also, this is
                                                                                                                                                                                                   believe the NPM guidance provides sufficient
                                                                                              covered under the State Review Framework.
                                                                                                                                                                                                   accountability. These two ACS commitments
                CAA17 - Regions and delegated agencies should enter all                                                                                                                            demonstrate the importance OECA places on
                                                                                              R6- This is part of our Core work for State oversight and we do not
                MDRs in AFS consistent with the agency policies and the                                                                                                                            complete and accurate entry of compliance
                                                                                              see a value added as an ACS commitment.
                ICR. If for some reason a delegated agency does not agree                                                                                                                          monitoring and enforcement data into national
                                                                                  1,2, 6,10                                                                          Keep
OECA    5.1.3   to enter the MDRs, the region is responsible for ensuring that                                                                                                                     databases by the regions and states. Also, these
                                                                                  D           R10-There‟s likely no specific written requirement that states agree
                the data is entered into AFS in a timely manner. If the region                                                                                                                     commitments also are needed to verify that the
                                                                                              in writing to these measures. In addition, having ACS measure
                is responsible for entering state/local/tribal data, identify the                                                                                                                  regions and states are following the CAA
                                                                                              doesn‟t influence whether or not states do the reporting. For the
                agency                                                                                                                                                                             Compliance Monitoring Strategy.
                                                                                              MDR, if states don‟t agree, then Regions would do. And lastly, and
                                                                                                                                                                                                   While it is easier for the regions to meet fewer
                                                                                              perhaps most importantly, these measures do not seem to contribute
                                                                                                                                                                                                   measures, we don't believe the NPM guidance
                                                                                              to any significant mission or environmental success. As ACS
                                                                                                                                                                                                   provides sufficient accountability. These two
                                                                                              measures, what difference have these made.
                                                                                                                                                                                                   ACS commitments demonstrate the importance
                                                                                                                                                                                                   OECA places on complete and accurate entry of
                                                                                                                                                                                                   compliance monitoring and enforcement data into
                                                                                                                                                                                                   national databases by the regions and states.
                                                                                                                                                                                                   Also, these commitments also are needed to
                                                                                                                                                                                                   verify that the regions and states are following
                                                                                                                                                                                                   the CAA Compliance Monitoring Strategy.



                                                                                                                                                                                                   No. CAA 19 is not redundant with SRF 01. The
                                                                                                                                                                                                   December 9, 2005 memo from Lisa Lund to
                                                                                              R2- This is already covered as part of the State Review Framework                                    regional Compliance/ Enforcement Directors
                CAA19 - Consistent with CMS, regions should conduct at                        under SRF01.                                                                                         explains the significant differences between the
                                                                                 2,6,8                                                                               Keep
OECA    5.1.3   least one in-depth evaluation of a delegated program per                                                                                                                           CMS evaluation and the SRF review, and how
                                                                                 D            R6- This is part of our Core work for State oversight and we do not
                year and provide the written results to HQ.                                                                                                                                        they can be implemented in a “coordinated,
                                                                                              see a value added as an ACS commitment.                                                              mutually supportive manner.” The CMS
                                                                                                                                                                                                   evaluation is an important component of the CAA
                                                                                              R8- An unnecessary measure, due to the redundancy and lack of                                        Compliance Monitoring Strategy.
                                                                                              integration with the SRF. (Martin Hestmark, Region 8)




                                                                                                                              Page 78
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                                                       Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                Regions &      Region or State Explanation for Recommendation             NPM response, new code, and                  NPM Rationale
        objectiv                                                              States &                                                                          New Text
                                                                                                                                                                                     No. We do not agree that guidance and an ACS
                                                                                                                                                                                     commitment are equivalent. Guidance identifies
                                                                                                                                                                                     a performance requirement or expectation while
                                                                                                                                                                                     the ACS commitment is an up-front agreement to
                                                                                                                                                                                     a level of performance for the coming year that is
                                                                                                                                                                                     used as a work planning tool for the core
                                                                                                                                                                                     program and national priorities. We want to keep
                                                                                                                                                                                     this ACS measure, but would consider making
                                                                                                                                                                                     both the EPA and state components non-
                                                                                                                                                                                     commitment indicators. At the end of the year we
                                                                                                                                                                                     look at the combined EPA/state performance
                                                                                         R6- Combine CWA01, 03, 05 and eliminate the State by State                                  under CWA01 and CWA01.s to determine
                                                                                         breakout. New Language: Total number of federal CWA                                         whether NPDES major‟s inspection coverage is
                                                                                         Inspections/Investigations.                                                                 adequate from a national perspective. The
                CWA01 - Project by state the number of federal inspections   6,10        Recommend combining with other Water inspections measures into Keep                         breakout of the EPA and state components is
OECA    5.1.3
                at NPDES major facilities.                                   D,M         one total Water commitment. This will provide flexibility for the                           useful to some regions as they negotiate their
                                                                                         Regions while providing OECA an overall commitment.                                         annual EPA/state plans, but from a HQ
                                                                                                                                                                                     perspective the most important metric is the
                                                                                         R10- no comment, just recommended deletion                                                  combined performance at the end of the year,
                                                                                                                                                                                     and how that performance compares to previous
                                                                                                                                                                                     years for specific states; how the multi-year trend
                                                                                                                                                                                     looks; and how it compares to the combined
                                                                                                                                                                                     national average.
                                                                                                                                                                                     No. We want to keep the CWA01, CWA01.s,
                                                                                                                                                                                     CWA03, and CWA05 in ACS for FY 2008. A
                                                                                                                                                                                     single commitment would combine too many
                                                                                                                                                                                     activities from too many different regulated
                                                                                                                                                                                     universes and would have virtually no value for
                                                                                                                                                                                     national program management. We are
                                                                                                                                                                                     developing a new compliance monitoring
                                                                                                                                                                                     strategy (CMS) for the NPDES program that




                                                                                                                      Page 79
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                                                       Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                Regions &       Region or State Explanation for Recommendation                         NPM response, new code, and                  NPM Rationale
        objectiv                                                              States &                                                                                       New Text
                                                                                                                                                                                                  No. We want to keep the CWA01, CWA01s,
                                                                                                                                                                                                  CWA03, and CWA05 in ACS for FY 2008. A
                                                                                                                                                                                                  single commitment would combine too many
                                                                                                                                                                                                  activities from too many different regulated
                                                                                                                                                                                                  universes and would have virtually no value for
                                                                                                                                                                                                  national program management. We are
                                                                                                                                                                                                  developing a new compliance monitoring
                                                                                                                                                                                                  strategy (CMS) for the NPDES program that
                                                                                                                                                                                                  moves away from highly aggregate inspection
                                                                                                                                                                                                  counts to more refined inspection frequency
                                                                                                                                                                                                  expectations that are tailored to account for
                                                                                         R2- State commitments are not appropriate for the ACS as they are                                        differences among the various regulated
                                                                                         not entirely in the Region‟s control. Also, state activities are already                                 universes. We have received many positive
                                                                                         captured in state grants and the State Framework Review.                                                 comments from the regions and states on this
                CWA01.s - Project by state the number of state inspections   2, 6,10                                                                                Keep                          approach, and have heard no negative
OECA    5.1.3
                at NPDES major facilities.                                   D,M         R6- This is a State commitment. Recommend tracking but not                                               comments on the draft CMS approach from
                                                                                         making a commitment.                                                                                     Region 10.
                                                                                                                                                                                                  We want to keep this ACS measure, but would
                                                                                         R10- no comment, just recommended deletion                                                               consider making both the EPA and state
                                                                                                                                                                                                  components non-commitment indicators. At the
                                                                                                                                                                                                  end of the year we look at the combined
                                                                                                                                                                                                  EPA/state performance under CWA01 and
                                                                                                                                                                                                  CWA01s. to determine whether NPDES major‟s
                                                                                                                                                                                                  inspection coverage is adequate from a national
                                                                                                                                                                                                  perspective. The breakout of the EPA and state
                                                                                                                                                                                                  components is useful to some regions as they
                                                                                                                                                                                                  negotiate their annual EPA/state plans, but from
                                                                                                                                                                                                  a HQ perspective the most important metric is
                                                                                                                                                                                                  the combined performance at the end of the year,
                                                                                                                                                                                                  and how that performance compares to previous
                                                                                                                                                                                                  years for specific states; how the multi-year trend




                                                                                                                          Page 80
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                                                        Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                 Regions &      Region or State Explanation for Recommendation   NPM response, new code, and                  NPM Rationale
        objectiv                                                               States &                                                                New Text
                                                                                                                                                                            No. We want to keep the CWA01, CWA01s,
                                                                                                                                                                            CWA03, and CWA05 in ACS for FY 2008. A
                                                                                                                                                                            single commitment would combine too many
                                                                                                                                                                            activities from too many different regulated
                                                                                                                                                                            universes and would have virtually no value for
                                                                                                                                                                            national program management. We are
                                                                                                                                                                            developing a new compliance monitoring
                                                                                                                                                                            strategy (CMS) for the NPDES program that
                                                                                                                                                                            moves away from highly aggregate inspection
                                                                                                                                                                            counts to more refined inspection frequency
                                                                                                                                                                            expectations that are tailored to account for
                                                                                                                                                                            differences among the various regulated
                                                                                                                                                                            universes. We have received many positive
                CWA03 - Project by state the number of federal oversight                                                                                                    comments from the regions and states on this
                                                                                          R6- Combine with CWA01
                inspections to be conducted. The regions must provide a        6,10                                                           Keep                          approach, and have heard no negative
OECA    5.1.3
                detailed explanation if no oversight inspections are projected D                                                                                            comments on the draft CMS approach from
                                                                                          R10-
                in this area.                                                                                                                                               Region 10.
                                                                                                                                                                            No. We want to keep the CWA01, CWA01.s,
                                                                                                                                                                            CWA03, and CWA05 in ACS for FY 2008. A
                                                                                                                                                                            single commitment would combine too many
                                                                                                                                                                            activities from too many different regulated
                                                                                                                                                                            universes and would have virtually no value for
                                                                                                                                                                            national program management. We are
                                                                                                                                                                            developing a new compliance monitoring
                                                                                                                                                                            strategy (CMS) for the NPDES program that
                                                                                                                                                                            moves away from highly aggregate inspection
                                                                                                                                                                            counts to more refined inspection frequency
                                                                                                                                                                            expectations that are tailored to account for
                                                                                                                                                                            differences among the various regulated
                                                                                                                                                                            universes. We have received many positive
                                                                                                                                                                            comments from the regions and states on this




                                                                                                                   Page 81
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  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                    Regions &       Region or State Explanation for Recommendation                  NPM response, new code, and                  NPM Rationale
        objectiv                                                                  States &                                                                                New Text
                                                                                                                                                                                               No. We do not agree that guidance and an ACS
                                                                                                                                                                                               commitment are equivalent. Guidance identifies
                                                                                                                                                                                               a performance requirement or expectation while
                                                                                                                                                                                               the ACS commitment is an up-front agreement to
                                                                                                                                                                                               a level of performance for the coming year that is
                                                                                                                                                                                               used as a work planning tool for the core
                                                                                                                                                                                               program and national priorities. We want to keep
                                                                                                                                                                                               this ACS measure, but would consider making
                                                                                                                                                                                               both the EPA and state components non-
                                                                                                                                                                                               commitment indicators. At the end of the year we
                                                                                                                                                                                               look at the combined EPA/state performance
                                                                                                                                                                                               under CWA01 and CWA01.s to determine
                                                                                                                                                                                               whether NPDES major‟s inspection coverage is
                                                                                                                                                                                               adequate from a national perspective. The
                CWA05 - Project by state the number of federal and state                     R6- Combine with CWA01
                                                                                 6,10                                                                            Keep                          breakout of the EPA and state components is
OECA    5.1.3   inspections of POTWs with an approved pretreatment
                                                                                 D                                                                                                             useful to some regions as they negotiate their
                program in both approved and unapproved states.                              R10-
                                                                                                                                                                                               annual EPA/state plans, but from a HQ
                                                                                                                                                                                               perspective the most important metric is the
                                                                                                                                                                                               combined performance at the end of the year,
                                                                                                                                                                                               and how that performance compares to previous
                                                                                                                                                                                               years for specific states; how the multi-year trend
                                                                                                                                                                                               looks; and how it compares to the combined
                                                                                                                                                                                               national average.
                                                                                                                                                                                               No. We want to keep the CWA01, CWA01.s,
                                                                                                                                                                                               CWA03, and CWA05 in ACS for FY 2008. A
                                                                                                                                                                                               single commitment would combine too many
                                                                                                                                                                                               activities from too many different regulated
                                                                                                                                                                                               universes and would have virtually no value for
                                                                                                                                                                                               national program management. We are
                                                                                                                                                                                               developing a new compliance monitoring
                                                                                                                                                                                               strategy (CMS) for the NPDES program that
                                                                                             R2- This requirement redundant since it is already covered in the
                                                                                             NPM annual guidance.

                                                                                             R6- Combine EPCRA01 and 02. New Language: Total number of
                EPCRA01 - Number of federal EPCRA data quality                   2, 6,10     federal EPCRA Inspections/Investigations .                           Keep
OECA    5.1.3
                inspections; provide an explanation if below the target level.   D, D,M      Recommend combining with other EPCRA inspection measures into
                                                                                             one total EPCRA inspection commitment. This will provide flexibility
                                                                                             for the Regions while providing OECA an overall commitment.

                                                                                             R10-


                                                                                                                                                                                               We do not agree that guidance and an ACS
                                                                                             R2- This requirement redundant since it is already covered in the                                 commitment are equivalent. Guidance identifies
                                                                                             NPM annual guidance.                                                                              a performance requirement or expectation while
                EPCRA02 - Number of federal EPCRA 313 inspections;               2, 6,10                                                                         Keep                          the ACS commitment is an up-front agreement to
OECA    5.1.3
                provide an explanation if below the target level.                D           R6- Combine with EPCRA01                                                                          a level of performance for the coming year that is
                                                                                                                                                                                               used as a work planning tool for the core
                                                                                             R10-                                                                                              program and national priorities.




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  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                  Regions &       Region or State Explanation for Recommendation                         NPM response, new code, and                  NPM Rationale
        objectiv                                                                States &                                                                                       New Text
                                                                                                                                                                                                    General response: As a general matter, FFEO is
                                                                                                                                                                                                    open to discussing with all regions alternatives to
                                                                                                                                                                                                    structuring ACS commitments to focus on
                                                                                                                                                                                                    Integrated Strategies (see details on this below);
                                                                                                                                                                                                    however, FFEO believes that specific numerical
                                                                                                                                                                                                    commitments are necessary to maintain a viable
                                                                                           R2- Each Region will conduct two multi-media inspections to support                                      EPA field presence and an effective federal
                                                                                           the Integrated Strategy areas. Regions may substitute four single                                        facility compliance and enforcement program.
                                                                                           media inspections in lieu of each multi-media inspection. The                                            Any restructuring of ACS commitments must
                                                                                           wording of this measure should be clarified so that there is no                                          include specific numerical commitments for
                                                                                           misunderstanding as to what is required. Also, since these are                                           compliance assistance and compliance
                                                                                           activities to support integrated strategies and the integrated strategy                                  monitoring activities. FFEO would work with
                                                                                           approach allows the selection of the best tool to address non-                                           Region 2, as lead Region, to involve all Regions
                                                                                           compliance, the Region should be allowed to use tools other than                                         in an ACS restructuring discussion.
                                                                                           inspections (e.g., self audits) to address noncompliance.
                FEDFAC03 - Each Region will conduct two multi-media                                                                                                                                 FFEO understands the Region 2 and 10
                inspections to support the Integrated Strategy areas.          2,6,9,10    R6- No value added. Inspections for Federal Facilities will be             Keep                          comments to add flexibity to the ACS
OECA    5.1.3
                Regions may substitute four single media inspections in lieu   D,M         captured under the various programmatic areas.                                                           commitments. FFEO is open to discuss with all
                of one multi-media inspection.                                                                                                                                                      the Regions a restructuring of the ACS
                                                                                           R10- As above, conducting two multimedia inspections at Federal                                          commitments to focus on Integrated Strategies
                                                                                           Facilities to support the IS areas may not be the highest priority                                       which could provide Regions with more visible
                                                                                           activity in a particular Region each year. This reduces Regional                                         flexibility in balancing compliance assistance and
                                                                                           flexibility to address other critical needs. Conducting inspections just                                 compliance monitoring activities in a strategy
                                                                                           to meet a number is not the best and highest use of continually                                          area. However, FFEO believes that any new
                                                                                           reduced resources. The inspection data is entered in ICIS.                                               structure must include numerical commitments
                                                                                           Appropriate discussions with Regions should be conducted if there                                        for each Regional activity under the IS, including
                                                                                           are questions or clarifications about the type or # of Federal Facility                                  commitments to do a specific number of
                                                                                           inspections conducted in any given year.                                                                 assistance activities and/or inspections. FFEO
                                                                                                                                                                                                    would like to work with the lead Region, Region
                                                                                                                                                                                                    2, to include all Regions in any ACS restructuring
                                                                                                                                                                                                    discussions. Region 6‟s comment concerns
                                                                                                                                                                                                    recording inspections in data bases. Even
                                                                                                                                                                                                    though completed inspections are recorded in
                                                                                                                                                                                                    various data systems, simply recording of them




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                                                     Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples             Regions &       Region or State Explanation for Recommendation               NPM response, new code, and                  NPM Rationale
        objectiv                                                           States &                                                                             New Text


                                                                                                                                                                                     FFEO agrees to eliminate the measure for EPA
                                                                                                                                                                                     inspection of federal TSDFs, FEDFAC04. FFEO
                                                                                                                                                                                     agrees to eliminate the sole federal facility state
                                                                                                                                                                                     measure, FEDFAC04s. The Regions are
                                                                                                                                                                                     reminded that 100% of federal TSDF facilities are
                                                                                                                                                                                     required, by statute, to be inspected annually.
                                                                                                                                                                                     Removing FEDFAC04 from the ACS does not
                                                                                                                                                                                     eliminate the statutory annual inspection
                                                                                                                                                                                     requirement.
                                                                                      R6- No value added. Inspections for Federal Facilities will be
                FEDFAC04 - Number of federal inspections to be conducted                                                                                                             FFEO agrees to eliminate the measure for EPA
                                                                           6,10       captured under the various programmatic areas.                   Delete
OECA    5.1.3   at federal RCRA treatment, storage or disposal facilities.                                                                                                           inspection of federal TSDFs, FEDFAC04. The
                                                                           D
                Provide an explanation if below the 100% target level.                                                                                                               Regions are reminded that 100% of federal
                                                                                      R10-
                                                                                                                                                                                     TSDF facilities are required, by statute, to be
                                                                                                                                                                                     inspected annually. Removing FEDFAC04 and
                                                                                                                                                                                     FEDFAC04.s from the ACS does not eliminate
                                                                                                                                                                                     the statutory annual inspection requirement.
                                                                                                                                                                                     The Regions are reminded that 100% of federal
                                                                                                                                                                                     TSDF facilities are required, by statute, to be
                                                                                                                                                                                     inspected annually. Removing FEDFAC04s from
                                                                                                                                                                                     the ACS does not eliminate the statutory annual
                                                                                                                                                                                     inspection requirement.




                                                                                                                                                                                     FFEO agrees to eliminate the measure for EPA
                                                                                                                                                                                     inspection of federal TSDFs, FEDFAC04. The
                                                                                      R6- No value added. Inspections for Federal Facilities will be
                FEDFAC04.s - Number of state inspections to be conducted                                                                                                             Regions are reminded that 100% of federal
                                                                           6,10       captured under the various programmatic areas.                   Delete
OECA    5.1.3   at federal RCRA treatment, storage or disposal facilities.                                                                                                           TSDF facilities are required, by statute, to be
                                                                           D
                Provide an explanation if below the 100% target level.                                                                                                               inspected annually. Removing FEDFAC04 and
                                                                                      R10-
                                                                                                                                                                                     FEDFAC04.s from the ACS does not eliminate
                                                                                                                                                                                     the statutory annual inspection requirement.




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                                                      Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples              Regions &           Region or State Explanation for Recommendation                    NPM response, new code, and                  NPM Rationale
        objectiv                                                            States &                                                                                      New Text

                                                                                         R2- This commitment should be modified to allow for compliance
                                                                                         monitoring by means other than inspection. Since these are
                                                                                         activities to support integrated strategies and the integrated strategy
                                                                                         approach allows the selection of the best tool to address non-
                                                                                         compliance, the Region should be allowed to use the audit policy to
                                                                                         encourage facilities to self-audit and self-disclose violations in lieu of
                                                                                         inspections. Also, the commitment should be modified to allow for
                                                                                         multimedia inspections in lieu of single media inspections.
                FEDFAC05 - Number of Federal facility single media                                                                                                                             The Regions are reminded that 100% of federal
                                                                                         Modification: Number of Federal facility compliance evaluations
                inspections to be conducted by EPA to support Integrated                                                                                                                       TSDF facilities are required, by statute, to be
                                                                           2,6,9,10      (inspections to be conducted by EPA or facility self-audits) to support Delete
OECA    5.1.3   Strategy areas: CWA/NPDES Wastewater; CWA/NPDES                                                                                                                                inspected annually. Removing FEDFAC04s from
                                                                           D,M           Integrated Strategy areas: CWA/NPDES Wastewater; CWA/NPDES
                Storm Water; Federal Laboratories; and Federal                                                                                                                                 the ACS does not eliminate the statutory annual
                                                                                         Storm Water; Federal Laboratories; and Federal Underground
                Underground Storage Tanks.                                                                                                                                                     inspection requirement.
                                                                                         Storage Tanks.

                                                                                         R6- No value added. Inspections for Federal Facilities will be
                                                                                         captured under the various programmatic areas

                                                                                         R9-

                                                                                         R10-



                                                                                                                                                                                               Acceptable so long as federal is not interpreted
                                                                                                                                                                                               to include inspections conducted by states or
                FIFRA-FED1 - Project regional FIFRA inspection             6                                                                                    Keep
OECA    5.1.3                                                                                                                                                                                  tribes using federal credentials. This is meant to
                commitments.                                               M             New Language: Total number of federal FIFRA                                                           be only a measure of EPA work. Working to
                                                                                         inspection/investigations.                                                                            revise text with HQ contacts.
                                                                                          To make consistent with other program's language.
                                                                                                                                                                                               State grant template measures must appear in
                                                                                                                                                                Keep                           the NPM guidance, ACS, and measures
OECA    5.1.3   LEAD-G01 - Number of 402/406 inspections by state.
                                                                                                                                                                                               appendix per OCFO's guidance to programs on
                                                                                                                                                                                               NPM guidance development.
                                                                                                                                                                                               State grant template measures must appear in
                                                                                         State commitments are not appropriate for the ACS as they are not
                                                                           2                                                                                    Keep                           the NPM guidance, ACS, and measures
OECA    5.1.3   LEAD-G02 - Number of enforcement actions taken by state.                 entirely in the Region‟s control. Also, state activities are already
                                                                           D                                                                                                                   appendix per OCFO's guidance to programs on
                                                                                         captured in state grants.
                                                                                                                                                                                               NPM guidance development.
                                                                           2, 6
                                                                                                                                                                                               OECA is currently reviewing and revising its
                                                                           (D) (M)       R2- This requirement is redundant since it is already covered in the                                  national priority strategies for the FY 2008 - 2010
                                                                           Make into a   NPM annual guidance.                                                   Keep                           period. Based on this review goals and
OECA    5.1.3   PBS-ATX03 - Number of MACT investigative activities.       Non-
                                                                                                                                                                                               measures will likely change. Given this, we will
                                                                           commitment    R6- The actual commitment would be captured in the overall CAA                                        consider these comments as appropriate when
                                                                           Indicator     inspection commitment, and report here as a non-commitment                                            new priority measures are developed.
                                                                           only          indicator.

                                                                                                                                                                                               OECA is currently reviewing and revising its
                                                                                                                                                                                               national priority strategies for the FY 2008 - 2010
                                                                           6             Make into a Non-commitment Indicator only and combine with PBS-        Keep                           period. Based on this review goals and
OECA    5.1.3   PBS-CAFO02 - Number of CAFO federal inspections                          CAFO04. New language: Total number of CAFO inspections.
                                                                           M                                                                                                                   measures will likely change. Given this, we will
                                                                                         The actual commitment would be captured in the overall CWA                                            consider these comments as appropriate when
                                                                                         inspection commitment, and report here as a non-commitment                                            new priority measures are developed.
                                                                                         indicator.




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                                                         Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                    Regions &        Region or State Explanation for Recommendation                    NPM response, new code, and                  NPM Rationale
        objectiv                                                                  States &                                                                                   New Text
                                                                                                                                                                                                  OECA is currently reviewing and revising its
                                                                                                                                                                                                  national priority strategies for the FY 2008 - 2010
                PBS-CAFO04 - Number of joint EPA/state joint CAFO                6                                                                                  Keep                          period. Based on this review goals and
OECA    5.1.3                                                                                 Combine with PBS-CAFO02
                inspections                                                      (D)                                                                                                              measures will likely change. Given this, we will
                                                                                                                                                                                                  consider these comments as appropriate when
                                                                                                                                                                                                  new priority measures are developed.


                                                                                                                                                                                                  OECA is currently reviewing and revising its
                                                                                                                                                                                                  national priority strategies for the FY 2008 - 2010
                PBS-CSO01 - Number of permitted CSOs addressed
                                                                                                                                                                    Keep                          period. Based on this review goals and
OECA    5.1.3   through an action that will result in an enforceable long term
                                                                                                                                                                                                  measures will likely change. Given this, we will
                control plan (LTCP).
                                                                                                                                                                                                  consider these comments as appropriate when
                                                                                                                                                                                                  new priority measures are developed.


                                                                                                                                                                                                  OECA is currently reviewing and revising its
                                                                                                                                                                                                  national priority strategies for the FY 2008 - 2010
                PBS-CSO02 - Number of federal CSO actions that will result
                                                                                                                                                                    Keep                          period. Based on this review goals and
OECA    5.1.3   in an enforceable LTCP at high priority CSOs (90% of '05
                                                                                                                                                                                                  measures will likely change. Given this, we will
                target for Goal #1)
                                                                                                                                                                                                  consider these comments as appropriate when
                                                                                                                                                                                                  new priority measures are developed.


                                                                                                                                                                                                  OECA is currently reviewing and revising its
                                                                                                                                                                                                  national priority strategies for the FY 2008 - 2010
                PBS-CSO03 - Number of outfalls at permitted CSOs
                                                                                                                                                                    Keep                          period. Based on this review goals and
OECA    5.1.3   evaluated and addressed that are located within 1 mile
                                                                                                                                                                                                  measures will likely change. Given this, we will
                upstream of a surface drinking water intake. ('05)
                                                                                                                                                                                                  consider these comments as appropriate when
                                                                                                                                                                                                  new priority measures are developed.


                                                                                              R2- This is not a significant measure. More important than the
                                                                                              number of facilities receiving assistance is the number of CSOs that                                OECA is currently reviewing and revising its
                                                                                              have or are on the path to have LTCPs in place, which is already                                    national priority strategies for the FY 2008 - 2010
                                                                                 2,7          covered under PBS-CSO01 and PBS-CSO02.                               Keep                           period. Based on this review goals and
OECA    5.1.5   PBS-CAFO05
                                                                                 D,D                                                                                                              measures will likely change. Given this, we will
                                                                                              R7- At this point most permitees should have LTCP submitted or well                                 consider these comments as appropriate when
                                                                                              under development to the point where compliance assistance would                                    new priority measures are developed.
                                                                                              be unnecessary.


                                                                                 6                                                                                                                OECA is currently reviewing and revising its
                                                                                 (M) Make                                                                                                         national priority strategies for the FY 2008 - 2010
                PBS-FA01 - RCRA Closure and Post Closure - Number of
                                                                                 into a Non-                                                                        Keep                          period. Based on this review goals and
OECA    5.1.3   Preliminary Financial Assessments for Closure and Post-
                                                                                 commitment                                                                                                       measures will likely change. Given this, we will
                Closure Financial Responsibility Requirements.
                                                                                 Indicator                                                                                                        consider these comments as appropriate when
                                                                                 only        Activity commitment will be captured the overall RCRA inspection                                     new priority measures are developed.
                                                                                             commitment, but will report here as a non-commitment indicator.

                                                                                                                                                                                                  OECA is currently reviewing and revising its
                PBS-FA02 - RCRA Closure and Post Closure - Number of                                                                                                                              national priority strategies for the FY 2008 - 2010
                Owners/Operators in Complinace or on the path to                6                                                                                   Keep                          period. Based on this review goals and
OECA    5.1.3                                                                                 No value added
                compliance for closure or post-closure financial responsibility (D)                                                                                                               measures will likely change. Given this, we will
                requirements.                                                                                                                                                                     consider these comments as appropriate when
                                                                                                                                                                                                  new priority measures are developed.




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                                                        Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                Regions &        Region or State Explanation for Recommendation                     NPM response, new code, and                  NPM Rationale
        objectiv                                                              States &                                                                                    New Text
                                                                             6                                                                                                                 OECA is currently reviewing and revising its
                                                                             (M) Make                                                                                                          national priority strategies for the FY 2008 - 2010
                PBS-FA03 - RCRA Corrective Action - Number of
                                                                             into a Non-                                                                         Keep                          period. Based on this review goals and
OECA    5.1.3   preliminary financial assessments for corrective action
                                                                             commitment                                                                                                        measures will likely change. Given this, we will
                financial assurance requirements.
                                                                             Indicator                                                                                                         consider these comments as appropriate when
                                                                             only        Activity commitment will be captured the overall RCRA inspection                                      new priority measures are developed.
                                                                                         commitment, but will report here as a non-commitment indicator.

                                                                                                                                                                                               OECA is currently reviewing and revising its
                                                                                                                                                                                               national priority strategies for the FY 2008 - 2010
                PBS-FA04 - RCRA Corrective Action - Number of
                                                                            6                                                                                    Keep                          period. Based on this review goals and
OECA    5.1.3   owners/operators in compliance or on the path to compliance               No value added
                                                                            (D)                                                                                                                measures will likely change. Given this, we will
                for corrective action financial assurance requirements.
                                                                                                                                                                                               consider these comments as appropriate when
                                                                                                                                                                                               new priority measures are developed.


                                                                                                                                                                                               OECA is currently reviewing and revising its
                                                                                          Conducting in-house file reviews to determine if settlements contain
                                                                                                                                                                                               national priority strategies for the FY 2008 - 2010
                                                                                          language requiring financial assurance is unnecessary. Presently
                PBS-FA05 - CERCLA - Number of preliminary financial      6                                                                                       Keep                          period. Based on this review goals and
OECA    5.1.3                                                                             agreement models contain financial assurance requirement
                assessments for CERCLA financial assurance requirements. D                                                                                                                     measures will likely change. Given this, we will
                                                                                          language and it is unlikely the language would be omitted in current
                                                                                                                                                                                               consider these comments as appropriate when
                                                                                          final documents.
                                                                                                                                                                                               new priority measures are developed.


                                                                                                                                                                                               OECA is currently reviewing and revising its
                                                                                                                                                                                               national priority strategies for the FY 2008 - 2010
                PBS-FA06 - CERCLA - EPA determination of compliance          6            This measure is no longer meaningful to Superfund enforcement and Keep                               period. Based on this review goals and
OECA    5.1.3
                with CERCLA financial assurance requirements.                D            needs to be revised.                                                                                 measures will likely change. Given this, we will
                                                                                                                                                                                               consider these comments as appropriate when
                                                                                                                                                                                               new priority measures are developed.


                                                                             6                                                                                                                 OECA is currently reviewing and revising its
                                                                             (M) Make                                                                                                          national priority strategies for the FY 2008 - 2010
                PBS-MNP04 - Number of investigations in the non-             into a Non-                                                                         Keep                          period. Based on this review goals and
OECA    5.1.3
                phosphoric acid mineral processing sector.                   commitment                                                                                                        measures will likely change. Given this, we will
                                                                             Indicator                                                                                                         consider these comments as appropriate when
                                                                             only        Activity commitment will be captured the overall RCRA inspection                                      new priority measures are developed.
                                                                                         commitment, but will report here as a non-commitment indicator.

                                                                             6                                                                                                                 OECA is currently reviewing and revising its
                PBS-SSO01 - For FY 2006, Regions will address one-third of   (M) Make                                                                                                          national priority strategies for the FY 2008 - 2010
                the number of LARGE systems (including satellites) they      into a Non- This is the means for obtaining and recording results. Recommend        Keep                          period. Based on this review goals and
OECA    5.1.3
                committed to addressing for 05-07 in the Workforce           commitment tracking but not making a commitment                                                                   measures will likely change. Given this, we will
                Deployment information they submitted.                       Indicator                                                                                                         consider these comments as appropriate when
                                                                             only                                                                                                              new priority measures are developed.


                                                                             6                                                                                                                 OECA is currently reviewing and revising its
                PBS-SSO05 - For FY2006, Regions will address one-third of    (M) Make                                                                                                          national priority strategies for the FY 2008 - 2010
                the number of medium systems (including satellites) they     into a Non- This is the means for obtaining and recording results. Recommend        Keep                          period. Based on this review goals and
OECA    5.1.3
                committed to addressing for 05/07 in the workforce           commitment tracking but not making a commitment                                                                   measures will likely change. Given this, we will
                deployment strategy.                                         Indicator                                                                                                         consider these comments as appropriate when
                                                                             only                                                                                                              new priority measures are developed.




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                                                        Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                  Regions &         Region or State Explanation for Recommendation                 NPM response, new code, and                  NPM Rationale
        objectiv                                                                States &                                                                                 New Text
                                                                               6                                                                                                              OECA is currently reviewing and revising its
                                                                               (M) Make                                                                                                       national priority strategies for the FY 2008 - 2010
                PBS-STW01 - Number of federal 2007 stormwater                  into a Non-                                                                     Keep                           period. Based on this review goals and
OECA    5.1.3
                construction inspections.                                      commitment                                                                                                     measures will likely change. Given this, we will
                                                                               Indicator                                                                                                      consider these comments as appropriate when
                                                                               only        Activity commitment will be captured under overall CWA inspection                                  new priority measures are developed.
                                                                                           commitment, but will report here as a non-commitment indicator.

                                                                               6                                                                                                              OECA is currently reviewing and revising its
                                                                               (M) Make                                                                                                       national priority strategies for the FY 2008 - 2010
                PBS-STW02 - Number of federal stormwater non-                  into a Non-                                                                     Keep                           period. Based on this review goals and
OECA    5.1.3
                construction industry inspections.                             commitment                                                                                                     measures will likely change. Given this, we will
                                                                               Indicator                                                                                                      consider these comments as appropriate when
                                                                               only        Activity commitment will be captured under overall CWA inspection                                  new priority measures are developed.
                                                                                           commitment, but will report here as a non-commitment indicator.

                                                                               6                                                                                                              OECA is currently reviewing and revising its
                                                                               (M) Make                                                                                                       national priority strategies for the FY 2008 - 2010
                                                                               into a Non-                                                                     Keep                           period. Based on this review goals and
OECA    5.1.3   PBS-STW04 - Number of MS4 Phase 1 audits.
                                                                               commitment                                                                                                     measures will likely change. Given this, we will
                                                                               Indicator                                                                                                      consider these comments as appropriate when
                                                                               only        Activity commitment will be captured under overall CWA inspection                                  new priority measures are developed.
                                                                                           commitment, but will report here as a non-commitment indicator.

                                                                                                                                                                                              OECA is currently reviewing and revising its
                                                                                                                                                                                              national priority strategies for the FY 2008 - 2010
                PBS-TB02 - By September 30, 2007, Regions will increase        6                                                                               Keep                           period. Based on this review goals and
OECA    5.1.3                                                                                No value added
                number of EPA - authorized tribal inspectors.                  (D)                                                                                                            measures will likely change. Given this, we will
                                                                                                                                                                                              consider these comments as appropriate when
                                                                                                                                                                                              new priority measures are developed.

                PBS-TB04 - By September 30, 2007, Regions will inspect
                                                                               6,9                                                                                                            OECA is currently reviewing and revising its
                BIA and non-BIA schools for one or more of the following                     R6- Recommend tracking but not making a commitment. These
                                                                               (M) Make                                                                                                       national priority strategies for the FY 2008 - 2010
                programs if applicable: AHERA, drinking water, lead-based                    inspections will be reflected in the individual programmatic
                                                                               into a Non-                                                                     Keep                           period. Based on this review goals and
OECA    5.1.3   paint, pesticides, disposal of spent laboratory chemicals or                 commitments.
                                                                               commitment                                                                                                     measures will likely change. Given this, we will
                other applicable programs and will conduct follow-up
                                                                               Indicator                                                                                                      consider these comments as appropriate when
                activities as necessary to address identified areas of non-                  R9- This is just a request to do something. Rewrite or drop.
                                                                               only                                                                                                           new priority measures are developed.
                compliance.

                                                                                                                                                                                              OECA is currently reviewing and revising its
                                                                                                                                                                                              national priority strategies for the FY 2008 - 2010
                PBS-TB06 - Number of tribal public water system SNC            6             Measure unnecessary. It does not provide any clear results and this Keep                         period. Based on this review goals and
OECA    5.1.3
                exceptions returned to compliance in FY07.                     D             work is being done anyway under Goal 2.                                                          measures will likely change. Given this, we will
                                                                                                                                                                                              consider these comments as appropriate when
                                                                                                                                                                                              new priority measures are developed.


                                                                                                                                                                                              OECA is currently reviewing and revising its
                PBS-TB07 - Number of nitrates and microbial violations                       R6- No value added                                                                               national priority strategies for the FY 2008 - 2010
                addressed in FY07. (Target is 15% over FY03 baseline). If a 6,7                                                                                Keep                           period. Based on this review goals and
OECA    5.1.3
                region has a reduction in the number of such violations from D               R7- This measure is already covered under PBS-TB06 and is not                                    measures will likely change. Given this, we will
                FY03, all will be addressed.                                                 needed                                                                                           consider these comments as appropriate when
                                                                                                                                                                                              new priority measures are developed.




                                                                                                                             Page 88
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                                                          Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                    Regions &         Region or State Explanation for Recommendation                        NPM response, new code, and                  NPM Rationale
        objectiv                                                                  States &                                                                                        New Text
                                                                                                                                                                                                       OECA is currently reviewing and revising its
                                                                                             R6- There is no regulatory authority
                                                                                                                                                                                                       national priority strategies for the FY 2008 - 2010
                PBS-TB09 - By September 30, 2007 Regions will assess
                                                                                 6,10                                                                                    Keep                          period. Based on this review goals and
OECA    5.1.3   and close open dumps on tribal lands or bring them into                      R10- This commitment related to assessing and closing open dumps
                                                                                 D                                                                                                                     measures will likely change. Given this, we will
                compliance. (Target: 12 dumps Nationwide)                                    on tribal lands or bring into compliance is already reported under
                                                                                                                                                                                                       consider these comments as appropriate when
                                                                                             OSWER and is duplicative.
                                                                                                                                                                                                       new priority measures are developed.


                                                                                                                                                                                                       OECA is currently reviewing and revising its
                PBS-TB10 - By September 30, 2007, Regions will work with                                                                                                                               national priority strategies for the FY 2008 - 2010
                                                                                             R6- This activity will be obsolete by FY08.
                states and tribes to identify off-reservation regulated facilities 6,9                                                                                   Keep                          period. Based on this review goals and
OECA    5.1.3
                that present the top compliance priorities inside Indian           D,M                                                                                                                 measures will likely change. Given this, we will
                                                                                             R9- Unclear - This should be dropped.
                country.                                                                                                                                                                               consider these comments as appropriate when
                                                                                                                                                                                                       new priority measures are developed.



                                                                                                                                                                                                       Largely agree with comment. It is too early to
                                                                                                                                                                                                       assess the value of the measures, including
                                                                                                                                                                                                       determining national trends because of variability
                                                                                             R1-                                                                                                       in reporting. New York‟s decision to not follow
                                                                                                                                                                                                       the measures guidance and report only work
                PST- G01 - Percent of violators committing subsequent            1,6                                                                                     Keep
OECA    5.1.3                                                                                R6- Need clarification as to what program this is for (PST). If it is for                                 supported by the grant is only one example of the
                violations.                                                      D,M
                                                                                             just one program, such as Pesticides, then spell that out in the                                          potential variability. AgD, the regions and states
                                                                                             description.                                                                                              will start assessing how these measures can be
                                                                                                                                                                                                       used as tools in improving program performance
                                                                                                                                                                                                       by analyzing the data received and other
                                                                                                                                                                                                       program information.




                                                                                                                                                                                                       Largely agree with comment. It is too early to
                                                                                                                                                                                                       assess the value of the measures, including
                                                                                                                                                                                                       determining national trends because of variability
                                                                                             R1-                                                                                                       in reporting. New York‟s decision to not follow
                                                                                                                                                                                                       the measures guidance and report only work
                PST- G02 - Percent of compliance actions taken as a result       1,6                                                                                     Keep
OECA    5.1.3                                                                                R6- Need clarification as to what program this is for (PST). If it is for                                 supported by the grant is only one example of the
                of inspection/enforcement.                                       D,M
                                                                                             just one program, such as Pesticides, then spell that out in the                                          potential variability. AgD, the regions and states
                                                                                             description.                                                                                              will start assessing how these measures can be
                                                                                                                                                                                                       used as tools in improving program performance
                                                                                                                                                                                                       by analyzing the data received and other
                                                                                                                                                                                                       program information.




                                                                                                                               Page 89
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                                                       Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                Regions &         Region or State Explanation for Recommendation                        NPM response, new code, and                  NPM Rationale
        objectiv                                                              States &                                                                                        New Text

                                                                                                                                                                                                   It is not clear what is meant by the comment. If
                                                                                         R1-
                                                                                                                                                                                                   the commenter is saying that the measure does
                                                                                                                                                                                                   not do a good job of measuring the cost of an
                                                                                         R6- Need clarification as to what program this is for (PST). If it is for
                                                                                                                                                                                                   enforcement action, we strongly agree. But this
                                                                                         just one program, such as Pesticides, then spell that out in the
                                                                                                                                                                                                   is not the purpose of this measure. This
                                                                                         description.
                                                                                                                                                                                                   measure is a rough guide at determining the
                                                                                                                                                                                                   efficiency of a grantee‟s program – taking into
                                                                                         NY- This measure is significantly skewed and does not reflect a true
                                                                                                                                                                                                   account all the different costs associated with
                                                                                         measure of the cost of an enforcement action. The numerator and/or
                                                                                                                                                                                                   funding an enforcement program - in identifying
                PST- G03 - Number of enforcement actions taken (federal & 1,6, NY        the denominator in the calculation for the cost of each enforcement Keep
OECA    5.1.3                                                                                                                                                                                      violations. As explained in the full measures
                state) per millions dollars of cost (federal & state).    D,M            action shown in EPA‟s guidance for this measure should be clarified.
                                                                                                                                                                                                   guidance, the use of enforcement actions in the
                                                                                         “Base enforcement” funding, an element of the existing numerator,
                                                                                                                                                                                                   measure is a stand-in for violations found.
                                                                                         supports a broad range of activities such as inspections, sample
                                                                                                                                                                                                   Grantees already collect and report number of
                                                                                         collection and analyses, and enforcement actions and not the other
                                                                                                                                                                                                   enforcement actions. Use of enforcement
                                                                                         activities. Otherwise, issuing a warning letter (one of the actions
                                                                                                                                                                                                   actions in the measure, rather than some newly
                                                                                         defined by EPA as enforcement) could cost thousands of dollars.
                                                                                                                                                                                                   collected data, was a way to reduce grantees‟
                                                                                         Alternatively, the denominator could be changed to be more inclusive
                                                                                                                                                                                                   reporting burden. We believe it is a good stand
                                                                                         – e.g., factor in the number of inspections, and sample collections
                                                                                                                                                                                                   in, considering the purpose and intended use of
                                                                                         and analyses as well as enforcement.
                                                                                                                                                                                                   the measure.


                                                                                                                                                                                                   We do not agree that guidance and an ACS
                                                                                                                                                                                                   commitment are equivalent. Guidance identifies
                                                                                                                                                                                                   a performance requirement or expectation while
                                                                                                                                                                                                   the ACS commitment is an up-front agreement to
                                                                                                                                                                                                   a level of performance for the coming year that is
                                                                                                                                                                                                   used as a work planning tool for the core
                                                                                                                                                                                                   program and national priorities.
                                                                                         R2- This requirement redundant since it is already covered in the
                                                                                         NPM annual guidance. Also, there is no need to project inspections                                        We do not intend to reduce the RCRA
                                                                                         by state. Regions should be held responsible only for the total                                           commitments further than we have already (used
                                                                                         number of federal inspections in the Region thus allowing Regions to                                      to be 5 now 3 with RCRA 01 and RCRA 02
                                                                                         make adjustments in inspections targeted in individual states as the                                      continuing to have state components). RCRA01
                                                                                         need arises. This requirement redundant since it is already covered                                       and RCRA03 are statutory requirements to
                                                                                         in the NPM annual guidance.                                                                               inspect different universes of facilities
                RCRA01 - Project by state the number of federal TSDFs to                                                                                                                           (Commercial TSDFs and State/local TSDFs)
                be inspected during the year. The regions must commit to     2, 6,10     R6- Combine RCRA01, 02, and 03 for a total RCRA                      Keep                                 over different time periods. We want to ensure
OECA    5.1.3                                                                                                                                                                                      that combined (EPA and state), they will meet
                inspecting at least 2 TSDFs in each state unless approval is D, D,M      inspection/investigation commitment and eliminate the state by state
                obtained from headquarters to deviate from this requirement.             breakouts. New language: Total number of federal RCRA                                                     our NPM guidance. We also specify how many
                                                                                         Inspections/Investigations.                                                                               inspections/state minimum (again, there is
                                                                                         Recommend combining with other RCRA inspections/investigations                                            flexibility) as a way of ensuring Federal presence
                                                                                         measures into one total RCRA commitment. This will provide                                                in each state and universe of facilities. Not
                                                                                         flexibility for the Regions while providing OECA an overall                                               having this info separate would just make it more
                                                                                         commitment.                                                                                               difficult for us to manage the program.

                                                                                         R10-                                                                                                      We do not intend to reduce the RCRA
                                                                                                                                                                                                   commitments further than we have already (used
                                                                                                                                                                                                   to be 5 now 3 with RCRA 01 and RCRA 02
                                                                                                                                                                                                   continuing to have state components). RCRA01
                                                                                                                                                                                                   and RCRA03 are statutory requirements to
                                                                                                                                                                                                   inspect different universes of facilities
                                                                                                                                                                                                   (Commercial TSDFs and State/local TSDFs)
                                                                                                                                                                                                   over different time periods. We review RCRA01
                                                                                                                                                                                                   and 01s to ensure that combined, 100% of the




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  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples              Regions &      Region or State Explanation for Recommendation                    NPM response, new code, and                  NPM Rationale
        objectiv                                                            States &                                                                                 New Text
                                                                                                                                                                                          We do not intend to reduce the RCRA
                                                                                                                                                                                          commitments further than we have already (used
                                                                                                                                                                                          to be 5 now 3 with RCRA 01 and RCRA 02
                                                                                                                                                                                          continuing to have state components). We
                                                                                                                                                                                          review RCRA01 and 01s to ensure that
                                                                                                                                                                                          combined, 100% of the universe will be
                                                                                                                                                                                          thoroughly inspected every 2 years (50% per
                                                                                                                                                                                          year on average). We want to ensure that
                                                                                                                                                                                          combined (EPA and state), they will meet our
                                                                                                                                                                                          NPM guidance. We also specify how many
                                                                                       R5- 1. More closely adheres to RCRA §3007(e)(1) requirement.                                       inspections/state minimum (again, there is
                                                                                       2. Eliminates incorrect suggestion that only TSDs that are owned                                   flexibility) as a way of ensuring Federal presence
                                                                                       and/or operated by State government entities were to have been                                     in each state and universe of facilities. Not
                                                                                       projected.                                                                                         having this info separate would just make it more
                                                                                       3. Removes ambiguity as to the time period being the fiscal year that                              difficult for us to manage the program.
                RCRA01.s - Project by state the number of state TSDFs to   5,6,10                                                                            Keep
OECA    5.1.3                                                                          runs from October 1 through September 30.
                be inspected during the year.                              D,M
                                                                                                                                                                                          We will consider this recommendation to change
                                                                                       R6- This is a State commitment. Recommend tracking but not                                         the language in the commitment as we revise the
                                                                                       making a commitment.                                                                               NPM Guidance.

                                                                                       R10-                                                                                               We review RCRA01 and 01s to ensure that
                                                                                                                                                                                          combined, 100% of the universe will be
                                                                                                                                                                                          thoroughly inspected every 2 years (50% per
                                                                                                                                                                                          year on average). We want to ensure that
                                                                                                                                                                                          combined (EPA and state), they will meet our
                                                                                                                                                                                          NPM guidance. We also specify how many
                                                                                                                                                                                          inspections/state minimum (again, there is
                                                                                                                                                                                          flexibility) as a way of ensuring Federal presence
                                                                                                                                                                                          in each state and universe of facilities. Not
                                                                                                                                                                                          having this info separate would just make it more
                                                                                                                                                                                          difficult for us to manage the program.




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  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples               Regions &       Region or State Explanation for Recommendation                       NPM response, new code, and                  NPM Rationale
        objectiv                                                             States &                                                                                     New Text
                                                                                                                                                                                               We do not agree that guidance and an ACS
                                                                                                                                                                                               commitment are equivalent. Guidance identifies
                                                                                                                                                                                               a performance requirement or expectation while
                                                                                                                                                                                               the ACS commitment is an up-front agreement to
                                                                                                                                                                                               a level of performance for the coming year that is
                                                                                                                                                                                               used as a work planning tool for the core
                                                                                                                                                                                               program and national priorities. We do not intend
                                                                                        R2- This requirement redundant since it is already covered in the                                      to reduce the RCRA commitments further than
                                                                                        NPM annual guidance. Also, there is no need to project inspections                                     we have already (used to be 5 now 3 with RCRA
                                                                                        by state. Regions should be held responsible only for the total                                        01 and RCRA 02 continuing to have state
                                                                                        number of federal inspections in the Region thus allowing Regions to                                   components). RCRA01 and RCRA03 are
                                                                                        make adjustments in inspections targeted in individual states as the                                   statutory requirements to inspect different
                                                                                        need arises. This requirement redundant since it is already covered                                    universes of facilities (Commercial TSDFs and
                                                                                        in the NPM annual guidance.                                                                            State/local TSDFs) over different time periods.
                RCRA02 - Project by state the number of federal LQGs to be
                inspected during the year. The regions must commit to                                                                                                                          We want to ensure that combined (EPA and
                                                                                        R6- Combine with RCRA01                                                                                state), they will meet our NPM guidance. We
                inspecting at least 6 LQGs in each state unless approval is 2, 6,8,10                                                                            Keep
OECA    5.1.3                                                                                                                                                                                  also specify how many inspections/state
                obtained from HQ to deviate from this requirement.           D,M
                                                                                        R8- We disagree with the statement "regions must commit to                                             minimum (again, there is flexibility) as a way of
                Generally, these LDQ inspections (or substitute inspections)
                                                                                        inspecting at least 6 LQGs in each state" as federal lead inspections.                                 ensuring Federal presence in each state and
                should be compliance evaluation inspections.
                                                                                        For some of our states, this represents a large percentage of the                                      universe of facilities. Not having this info
                                                                                        universe (ND and SD) in particular. We would recommend                                                 separate would just make it more difficult for us
                                                                                        modifying the language to allow Regions the ability to determine the                                   to manage the program.
                                                                                        appropriate level of inspections per state. (Sharon Kercher, Region
                                                                                        8)                                                                                                     We do not intend to reduce the RCRA
                                                                                                                                                                                               commitments further than we have already (used
                                                                                        R10-                                                                                                   to be 5 now 3 with RCRA 01 and RCRA 02
                                                                                                                                                                                               continuing to have state components). RCRA01
                                                                                                                                                                                               and RCRA03 are statutory requirements to
                                                                                                                                                                                               inspect different universes of facilities
                                                                                                                                                                                               (Commercial TSDFs and State/local TSDFs)
                                                                                                                                                                                               over different time periods. We review RCRA01
                                                                                                                                                                                               and 01s to ensure that combined, 100% of the
                                                                                                                                                                                               universe will be thoroughly inspected every 2

                                                                                                                                                                                               We review RCRA01 and 01s to ensure that
                                                                                                                                                                                               combined, 100% of the universe will be
                                                                                                                                                                                               thoroughly inspected every 2 years (50% per
                                                                                                                                                                                               year on average). We want to ensure that
                                                                                                                                                                                               combined (EPA and state), they will meet our
                                                                                        R5- Project by authorized State the number of inspections of large                                     NPM guidance. We also specify how many
                                                                                        quantity generators to be inspected by the authorized State                                            inspections/state minimum (again, there is
                                                                                        inspectors during the federal fiscal year.                                                             flexibility) as a way of ensuring Federal presence
                                                                                        1. Corrects unrecognizable acronym “LDQ”.                                                              in each state and universe of facilities. Not
                                                                                        2. Eliminates incorrect suggestion that only large quantity generators                                 having this info separate would just make it more
                                                                                        (LQGs) who are also State government entities were to have been                                        difficult for us to manage the program.
                RCRA02.s - Project by state the number of state LQGs        5,6,9,10                                                                           Keep
OECA    5.1.3                                                                           projected.
                inspections to be inspected during the year.                D,M
                                                                                        3. Removes ambiguity as to the time period being the fiscal year that                                  We will consider this recommendation to change
                                                                                        runs from October 1 through September 30.                                                              the language in the commitment as we revise the
                                                                                                                                                                                               NPM Guidance.
                                                                                        R6- This is a State commitment. Recommend tracking but not                                              We want to ensure that combined (EPA and
                                                                                        making a commitment.                                                                                   state), they will meet our NPM guidance. We
                                                                                                                                                                                               also specify how many inspections/state
                                                                                                                                                                                               minimum (again, there is flexibility) as a way of
                                                                                                                                                                                               ensuring Federal presence in each state and
                                                                                                                                                                                               universe of facilities. Not having this info
                                                                                                                                                                                               separate would just make it more difficult for us
                                                                                                                                                                                               to manage the program.




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  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                 Regions &       Region or State Explanation for Recommendation                  NPM response, new code, and                  NPM Rationale
        objectiv                                                               States &                                                                                New Text



                                                                                                                                                                                            We do not intend to reduce the RCRA
                                                                                                                                                                                            commitments further than we have already (used
                                                                                                                                                                                            to be 5 now 3 with RCRA 01 and RCRA 02
                                                                                                                                                                                            continuing to have state components). We want
                                                                                                                                                                                            to ensure that combined (EPA and state), they
                                                                                                                                                                                            will meet our NPM guidance. We also specify
                                                                                                                                                                                            how many inspections/state minimum (again,
                RCRA03 - Annually inspect each treatment, storage or
                                                                                                                                                                                            there is flexibility) as a way of ensuring Federal
                disposal facility operated by states or local governments as
                                                                                                                                                                                            presence in each state and universe of facilities.
                required under SDWA 3007(d). The Regions are to annually
                                                                                                                                                                                            Not having this info separate would just make it
                inspect each treatment, storage or disposal facility operated             R2- This requirement redundant since it is already covered in the
                                                                                                                                                                                            more difficult for us to manage the program.
                by state or local governments as required under SWDA                      NPM annual guidance. Also, these inspections are statutorily
                                                                              2, 6                                                                            Keep
OECA    5.1.3   3007(d). Pursuant to RCRA Section 3007(d), TSDFs                          required.
                                                                              (D)                                                                                                           We do not agree that guidance and an ACS
                operated by State or local government for which a permit is
                                                                                                                                                                                            commitment are equivalent. Guidance identifies
                required must be thoroughly inspected (i.e. generally a                   R6- Combine with RCRA01
                                                                                                                                                                                            a performance requirement or expectation while
                compliance evaluation inspection). The same type of RCRA
                                                                                                                                                                                            the ACS commitment is an up-front agreement to
                Info evaluations will be counted for this measure as is
                                                                                                                                                                                            a level of performance for the coming year that is
                counted for RCRA01.
                                                                                                                                                                                            used as a work planning tool for the core
                                                                                                                                                                                            program and national priorities. We do not intend
                                                                                                                                                                                            to reduce the RCRA commitments further than
                                                                                                                                                                                            we have already (used to be 5 now 3). RCRA03
                                                                                                                                                                                            is a commitment to thoroughly inspect 100% of
                                                                                                                                                                                            the universe annually and must be carried out by
                                                                                                                                                                                            Federal inspectors.




                                                                                                                                                                                            We are working with OGWDW to see if we can
                                                                                          R2- A similar measure is included in the OGWDW commitments.
                SDWA01 - Number of surveys to be conducted where the          2,6                                                                                                           get them to broaden their measure for sanitary
                                                                                          Sanitary survey commitments should be under OGWDW not OECA Keep
OECA    5.1.3   region has direct implementation authority. Provide a         D (R2),                                                                                                       surveys so we can drop our measure.
                                                                                          since they are part of program implementation and are not
                breakout for number on tribal lands.                          Keep (R6)
                                                                                          considered to be inspections.
                                                                                                                                                                                            Accepted


                                                                                                                                                                                            We do not agree that guidance and an ACS
                                                                                                                                                                                            commitment are equivalent. Guidance identifies
                                                                                          R2- This requirement redundant since it is already covered in the
                                                                                                                                                                                            a performance requirement or expectation while
                                                                                          NPM annual guidance.
                                                                                                                                                                                            the ACS commitment is an up-front agreement to
                SDWA02 - Public Water Systems listed on a 'Fixed Base'
                                                                              2, 6,7                                                                          Keep                          a level of performance for the coming year that is
OECA    5.1.3   SNC/Exceptions list will be addressed or resolved either by a             R6- No value added
                                                                              D,M                                                                                                           used as a work planning tool for the core
                state or tribe with primacy, or by EPA.
                                                                                                                                                                                            program and national priorities.
                                                                                          R7- Suggest measurement period from July – June so we have a
                                                                                          result at the end of the FY.
                                                                                                                                                                                            We are looking into that but no final decision has
                                                                                                                                                                                            been made yet.


                SDWA03.a - Regions/States and tribes with primacy are to
                                                                                                                                                              Delete
OECA    5.1.3   address 100% of microbial SNCs at large and medium public
                water systems before they become exceptions.

                SDWA03.b - Regions/states and tribes with primacy are to
                address at least 90% of microbial SNCs at small (serving up                                                                                   Delete
OECA    5.1.3
                to 3,300) users) public water systems before they become
                exceptions.




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  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                 Regions &      Region or State Explanation for Recommendation                  NPM response, new code, and                  NPM Rationale
        objectiv                                                               States &                                                                               New Text
                SDWA04.a - Regions/States and tribes with primacy are to
                address 100% of nitrates SNCs at large and medium public                                                                                    Delete
OECA    5.1.3
                water systems (CWS, NTNCWS, and TCNCWS) before they
                become exceptions.

                SDWA04.b - Regions/states and tribes with primacy are to
                                                                                                                                                            Delete
OECA    5.1.3   address at least 85% of nitrates SNCs at small public water
                systems before they become exceptions.


                SDWA05.a - Regions /states and tribes with primacy are to
                address 100% of lead SNCs initial tap monitoring,
                optimization of corrosion control, and public education at                                                                                  Delete
OECA    5.1.3
                large and medium community and non-transient non-
                community water systems before they become exceptions.


                SDWA05.b - Regions/states and tribes with primacy are to
                address 85% of lead SNCs at small community and non-                                                                                        Delete
OECA    5.1.3
                transient non-community water systems before they become
                exceptions.

                SDWA06.a - Regions/states and tribes with primacy are to
                address 100% of all other chronic SNCs (other than lead) at
                large and medium community and non-transient non-                                                                                           Delete
OECA    5.1.3
                community water systems, and 100% of all Consumer
                Confidence Report (CCR) rule SNCs at large and medium
                systems, before they become exceptions.


                SDWA06.b - Regions/states and tribes with primacy are to
                address at least 85% of all other chronic contaminant SNCs
                                                                                                                                                            Delete
OECA    5.1.3   at small community and non-transient non-community
                systems, and 85% of all CCR rule SNCs at small
                commmunity systems, before they become exceptions.


                                                                                                                                                                                           The SRF program is in its initial benchmarking
                                                                                          This commitment was okay for the first round of reviews. From now                                phase. It is necessary to track SRF regional
                SRF-01 - The number of State Review Framework reviews         6                                                                               Keep
OECA    5.1.3                                                                             on, it should be considered as core work to conduct state oversight                              progress in meeting annual commitments toward
                to be completed in Fiscal Year 2007.                          (D)
                                                                                          and no longer tracked in the ACS.                                                                the overall goal to assess all state programs in a
                                                                                                                                                                                           three year time frame.




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  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples               Regions &         Region or State Explanation for Recommendation                     NPM response, new code, and                   NPM Rationale
        objectiv                                                             States &                                                                                     New Text
                                                                                                                                                                                               We do not agree that guidance and an ACS
                                                                                                                                                                                               commitment are equivalent. Guidance identifies
                                                                                                                                                                                               a performance requirement or expectation while
                                                                                                                                                                                               the ACS commitment is an up-front agreement to
                                                                                          R2- his requirement redundant since it is already covered in the                                     a level of performance for the coming year that is
                                                                                          NPM annual guidance.                                                                                 used as a work planning tool for the core
                                                                                                                                                                                               program and national priorities. This commitment
                                                                                          R6- Combine TSC01, 03, 05, and 10 for a total TSCA                                                   is integral to the program. We see no need to
                                                                                          inspection/investigation commitment. New language: Total number                                      eliminate this commitment though we are
                                                                                          of federal TSCA Inspections/Investigations.                                                          discussing with Regions and States the
                                                                                          Recommend combining with other TSCA inspection/investigation                                         possibility of altering the criteria. That has not yet
                                                                                          measures into one total TSCA inspection commitment. This will                                        been determined, and as such, we should
                                                                                          provide flexibility for the Regions while providing OECA an overall                                  presume that the commitments will not be
                                                                                          commitment.                                                                                          altered. All ACS commitments identified in the
                TSC01 - Project the number of core federal TSCA
                                                                            2, 6,8,9,10                                                                          Keep                          ACS system are integral to the program. We
OECA    5.1.3   inspections for Regions maintaining an investment in core
                                                                            D,M           R8- Most Regions no longer conduct TSCA Core Inspections.                                            need to be aware of the activities by both the
                TSCA (sections 4,5,8,12 amd 13).
                                                                                          (Martin Hestmark, Region 8)                                                                          Regions and States in these areas. As we have
                                                                                                                                                                                               noted above, we discuss these commitments
                                                                                          R9-We still would like to see just one measure for TSCA inspections.                                 with the Regions and States on an ongoing basis
                                                                                          Currently we have 4. We recommend one measure that would be                                          and if believed that a revision is needed to
                                                                                          "Number of TSCA inspections conducted." Inspection targets should                                    address changes in the program, we propose
                                                                                          be consistent with MOA priorities. We would report by individual                                     such revisions.
                                                                                          program, but we think our commitment should be aggregated for
                                                                                          TSCA.                                                                                                This commitment is integral to the program. We
                                                                                                                                                                                               see no need to eliminate this commitment though
                                                                                          R10-                                                                                                 we are discussing with Regions and States the
                                                                                                                                                                                               possibility of altering the criteria. That has not yet
                                                                                                                                                                                               been determined, and as such, we should
                                                                                                                                                                                               presume that the commitments will not be
                                                                                                                                                                                               altered. All ACS commitments identified in the
                                                                                                                                                                                               ACS system are integral to the program. We




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  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples           Regions &         Region or State Explanation for Recommendation                     NPM response, new code, and                   NPM Rationale
        objectiv                                                         States &                                                                                     New Text
                                                                                                                                                                                           We do not agree that guidance and an ACS
                                                                                                                                                                                           commitment are equivalent. Guidance identifies
                                                                                                                                                                                           a performance requirement or expectation while
                                                                                                                                                                                           the ACS commitment is an up-front agreement to
                                                                                                                                                                                           a level of performance for the coming year that is
                                                                                                                                                                                           used as a work planning tool for the core
                                                                                                                                                                                           program and national priorities. This commitment
                                                                                      R2- his requirement redundant since it is already covered in the                                     is integral to the program. We see no need to
                                                                                      NPM annual guidance.                                                                                 eliminate this commitment though we are
                                                                                                                                                                                           discussing with Regions and States the
                                                                                      R6- Combine with TSC01                                                                               possibility of altering the criteria. That has not yet
                                                                                                                                                                                           been determined, and as such, we should
                                                                                      R8- The measures cross-walk at the OCFO web link                                                     presume that the commitments will not be
                                                                                      http://intranet.epa.gov/ocfo/acs/crosswalk lists this measure as a                                   altered. All ACS commitments identified in the
                                                                                      FY07 State grant template measure. The link of this measure with                                     ACS system are integral to the program. We
                                                                                      the State grant template measure seems questionable in light of the                                  need to be aware of the activities by both the
                TSC03 - Inspect 33% of the PCB commercial storage and   2, 6,8,9,10                                                                          Keep
OECA    5.1.3                                                                         PCB program not being a delegated program.                                                           Regions and States in these areas. As we have
                disposal facility universe.                             D,M
                                                                                                                                                                                           noted above, we discuss these commitments
                                                                                      R9-We still would like to see just one measure for TSCA inspections.                                 with the Regions and States on an ongoing basis
                                                                                      Currently we have 4. We recommend one measure that would be                                          and if believed that a revision is needed to
                                                                                      "Number of TSCA inspections conducted." Inspection targets should                                    address changes in the program, we propose
                                                                                      be consistent with MOA priorities. We would report by individual                                     such revisions.
                                                                                      program, but we think our commitment should be aggregated for                                        We do not agree that guidance and an ACS
                                                                                      TSCA.                                                                                                commitment are equivalent. Guidance identifies
                                                                                                                                                                                           a performance requirement or expectation while
                                                                                      R10-                                                                                                 the ACS commitment is an up-front agreement to
                                                                                                                                                                                           a level of performance for the coming year that is
                                                                                                                                                                                           used as a work planning tool for the core
                                                                                                                                                                                           program and national priorities. For PCBs, the
                                                                                                                                                                                           ACS measure is an important component of the
                                                                                                                                                                                           Agency's PBT strategy. While OECA's
                                                                                                                                                                                           commitment is minimal, to continue the current
                                                                                                                                                                                           coverage, if a region were only required to




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  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                Regions &       Region or State Explanation for Recommendation                     NPM response, new code, and                  NPM Rationale
        objectiv                                                              States &                                                                                   New Text


                                                                                                                                                                                              We do not agree that guidance and an ACS
                                                                                                                                                                                              commitment are equivalent. Guidance identifies
                                                                                                                                                                                              a performance requirement or expectation while
                                                                                         R2- his requirement redundant since it is already covered in the                                     the ACS commitment is an up-front agreement to
                                                                                         NPM annual guidance.                                                                                 a level of performance for the coming year that is
                                                                                                                                                                                              used as a work planning tool for the core
                                                                                         R6- Combine with TSC01                                                                               program and national priorities. While it is easier
                                                                                                                                                                                              for the regions to meet one overall number rather
                                                                                         R8- The second sentence in the measure should be stripped from                                       than four different numbers, we don't believe we
                                                                                         the measure because we understand that the comment field is not                                      would have the same leverage on each program
                TSC10 - Number of 1018/402/406 federal inspections. In the               captured in the consolidated results reported. We would rather that                                  if it was a combined number, even if the NPM
                regional comment field provide an explanation if no activity             the measure simply report the numbers of §1018, §402 & §406                                          guidance included language, because the
                                                                             6,8,9,10                                                                           Keep
OECA    5.1.3   projected in this area or if Section 402 inspections in                  inspections.                                                                                         regions appear to mainly be concerned about
                                                                             D,M
                unauthorized states is the rationale for trade-offs with the                                                                                                                  what is captured in the data base, not the
                Disclosure Rule or Section 406 inspections.                              R9-We still would like to see just one measure for TSCA inspections.                                 language in the NPM guidance. The TSCA
                                                                                         Currently we have 4. We recommend one measure that would be                                          programs are distinct programs with very
                                                                                         "Number of TSCA inspections conducted." Inspection targets should                                    different regulated communities and each
                                                                                         be consistent with MOA priorities. We would report by individual                                     program is organized differently (along with HQ)
                                                                                         program, but we think our commitment should be aggregated for                                        and negotiations for a consolidated commitment
                                                                                         TSCA.                                                                                                would be difficult to reach and for the Regions
                                                                                                                                                                                              where the programs are in different Branches or
                                                                                         R10-                                                                                                 Divisions, would be difficult to implement. In the
                                                                                                                                                                                              past, regions have traded within the TSCA
                                                                                                                                                                                              programs which resulted in a lack of coverage in
                                                                                                                                                                                              some regions for specific programs.




                                                                                                                                                                                              We do not agree that guidance and an ACS
                                                                                                                                                                                              commitment are equivalent. Guidance identifies
                                                                                                                                                                                              a performance requirement or expectation while
                                                                                                                                                                                              the ACS commitment is an up-front agreement to
                                                                                                                                                                                              a level of performance for the coming year that is
                                                                                                                                                                                              used as a work planning tool for the core
                                                                                         R2- his requirement redundant since it is already covered in the                                     program and national priorities. While it is easier
                                                                                         NPM annual guidance.                                                                                 for the regions to meet one overall number rather
                                                                                                                                                                                              than four different numbers, we don't believe we
                                                                                         R6- Combine with TSC01                                                                               would have the same leverage on each program
                                                                                                                                                                                              if it was a combined number, even if the NPM
                                                                                         R9-We still would like to see just one measure for TSCA inspections.                                 guidance included language, because the
                TSCA05 - Report the number of federal TSCA asbestos          2, 6,9,10                                                                        Keep
OECA    5.1.3                                                                            Currently we have 4. We recommend one measure that would be                                          regions appear to mainly be concerned about
                inspections.                                                 (D)
                                                                                         "Number of TSCA inspections conducted." Inspection targets should                                    what is captured in the data base, not the
                                                                                         be consistent with MOA priorities. We would report by individual                                     language in the NPM guidance. The TSCA
                                                                                         program, but we think our commitment should be aggregated for                                        programs are distinct programs with very
                                                                                         TSCA.                                                                                                different regulated communities and each
                                                                                                                                                                                              program is organized differently (along with HQ)
                                                                                         R10-                                                                                                 and negotiations for a consolidated commitment
                                                                                                                                                                                              would be difficult to reach and for the Regions
                                                                                                                                                                                              where the programs are in different Branches or
                                                                                                                                                                                              Divisions, would be difficult to implement. In the
                                                                                                                                                                                              past, regions have traded within the TSCA
                                                                                                                                                                                              programs which resulted in a lack of coverage in
                                                                                                                                                                                              some regions for specific programs.




                                                                                                                         Page 97
                                                                                                                           DRAFT

                                                         Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                   Regions &       Region or State Explanation for Recommendation                     NPM response, new code, and                               NPM Rationale
        objectiv                                                                 States &                                                                                   New Text
                                                                                                                                                                                                               State grant template measures must appear in
                TSC-G01 - Number of PCB inspections conducted by state                                                                                             Keep                                        the NPM guidance, ACS, and measures
OECA    5.1.3
                at PCB treatment and storage sites.                                                                                                                                                            appendix per OCFO's guidance to programs on
                                                                                                                                                                                                               NPM guidance development.

                TSC-G02 - Number of inspections condicted by state at:
                                                                                                                                                                                                               State grant template measures must appear in
                - Charter schools                                                           State commitments are not appropriate for the ACS as they are not
                                                                                2                                                                                  Keep                                        the NPM guidance, ACS, and measures
OECA    5.1.3   - LEAs in EJ areas                                                          entirely in the Region‟s control. Also, state activities are already
                                                                                D                                                                                                                              appendix per OCFO's guidance to programs on
                - Schools not inspected in last 6 years                                     captured in state grants.
                                                                                                                                                                                                               NPM guidance development.
                - Worker Protection

                262 - Percent of significant impacts identified by EPA during
                                                                                                                                                                   Delete
OECA    5.2.    the NEPA review of all major proposed federal actions that
                will be mitigated.

                960 - Percent of projects subject to NEPA Environmental
                                                                                                                                                                   Delete
OECA    5.2.    Assessment or EIS requirements that are expected to result
                in no significant environmental impact.


                                                                                            R6-No value added                                                                                                  HQ (currently is aligning ACS measure
                                                                                                                                                                   Modify
                234A - Pounds of hazardous materials (to air, water, land)      6,8
OPPTS   5.2.2                                                                                                                                                      Annual pounds of hazardous material         language with FY 2008 President's Budget
                reduced/avoided through pollution prevention efforts.           D,M         R8- The term “hazardous materials” should be replaced by
                                                                                                                                                                   reduced by P2 program participants.         and PART language The PART measure
                                                                                            “hazardous pollutants”.
                                                                                                                                                                                                               reads hazardous materials.)
                                                                                            R2- Region 2 agrees with OPPT and other regions to convert the
                                                                                            “Other Pollutants” (formerly “non-hazardous”) measure to a reporting
                                                                                            measure (instead of commitment measure)
                                                                                                                                                                   Modify
                234B - Pounds of non-hazardous materials (to air, water,        2,6,8       R6-No value added
OPPTS   5.2.2                                                                                                                                                      Annual pounds of other pollutants reduced
                land) reduced/avoided through pollution prevention efforts      D,M
                                                                                                                                                                   by P2 program participants.
                                                                                            R8- The term “non-hazardous materials” should be replaced by “non-
                                                                                            hazardous pollutants,” and it should be made clear that this is a
                                                                                            reporting measure, not a commitment or accountability measure at                                                   HQ agreed to shift this measure to a
                                                                                            this time.                                                                                                         reporting measure.
                                                                                            R6- No value added
                                                                                                                                                                   Modify
                235 - Dollars saved through pollution prevention efforts.Dis-   6,8         R8- The second sentence in this measure should be deleted              Annual business, institutional and
OPPTS   5.2.2
                aggregate of Agency strategic target.                           D,M         because it is confusing and difficult to track. Instead, it can be     government costs reduced by P2 program
                                                                                            addressed in the process of establishing the NPM guidance and          participant.                                HQ (will address this issue. This language
                                                                                            GPRA goals for pollution prevention.                                                                               has been deleted for other P2 measures)
                                                                                                                                                                   Modify
                239 - Gallons of water reduced or conserved through             6
OPPTS   5.2.2                                                                               No value added                                                         Annual gallons of water reduced by P2
                pollution prevention efforts.                                   (D)
                                                                                                                                                                   program participants.
                                                                                            R2- Region 2 agrees with OPPT and other regions to convert the
                                                                                            Pollution Prevention megawatts measure to a reporting measure
                                                                                            (instead of commitment measure)                                        Modify
                                                                                2,6,8                                                                              Annual Megawatts of energy reduced,
OPPTS   5.2.2   24 - Megawatts of energy use reduced, conserved, or offset
                                                                                D,M         R6- No value added                                                     conserved or offset by P2 program
                                                                                                                                                                   participants.
                                                                                            R8- It should be made clear that this is a reporting measure, not a                                                HQ agreed to shift this measure to a
                                                                                            commitment or accountability measure at this time.                                                                 reporting measure.
                                                                                                                                                                   Modify
                                                                                6                                                                                  Annual BTUs of energy reduced,
OPPTS   5.2.2   243 - Billions of BTUs of energy conserved.                                 No value added
                                                                                (D)                                                                                conserved or offset by P2 program
                                                                                                                                                                   participants.




                                                                                                                             Page 98
                                                                                                              DRAFT

                                                       Assessment of Measures Review Initiative Results for Goal 5
  NPM               Cell entries Commitment Code & Text
         Sub- Note: FY 07 ACS below are hypothetical examples                 Regions &   Region or State Explanation for Recommendation   NPM response, new code, and                 NPM Rationale
        objectiv                                                               States &                                                             New Text
                                                                                                                                           Modify
                PB8 - Number of pounds reduced (in millions) in generation                                                                 Number of pounds reduced (in millions) of
OSWER   5.2.2   of priority list chemicals from 2001 baseline of 84 million                                                                priority chemicals, as measured by
                pounds.                                                                                                                    National Partnership for Environmental
                                                                                                                                           Priorities members.




                                                                                                               Page 99
                                                                            DRAFT
        Assessment of Measures Review Initiative Results for Administrative
   Goal.     ACS Code                  Note: Cell entries below are hypothetical
                            FY 07 ACS Commitment Text & Code Non- examples and not States
                                                                                  Regions          NPM Proposed
 Objective.                    commitment indicators are in italics                with     with    Measures for
Subobjective                                                                     comments comments Streamlining

5.2.3      1            Identify regional number of PT applications received.           6
                        Identify regional number of States, tribes, or territories in
                        which PT incentives have been adopted and made
5.2.3      2                                                                            6
                        available to PT members. Please use comments to
                        indicate which incentives and which states.
                        Identify regional number of State environmental
5.2.3      3            performance agreements that incorporate Performance             6
                        Track.




                                                                            Page 100

				
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