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3
A Sustainability Framework for EPA
INTRODUCTION
EPA asked the Committee on Incorporating Sustainability in the U.S. EPA to
address the question “What should be the operational framework for sustainabil-
ity for EPA?” The primary design feature of such a framework is that it support
and guide EPA’s actions to further sustainability goals. On the basis of presenta -
tions made to the committee by various representatives of EPA and other experts,
the sustainability literature, and the experience of committee members, certain
other key attributes of the operational framework are suggested. The framework
will more likely be successful if it is (1) transparent and clear, (2) practical to
implement within the existing program structure of EPA, (3) leads to goals and
objectives that can be measured and reported publicly, (4) provides flexibility to
deal with scientific, technical and economic developments over long time frames
(more than 5 years), (5) works consistently with the current risk assessment/risk
management paradigm, and (6) facilitates decision making that supports EPA’s
ongoing mission to protect human health and the environment.
EPA has made progress in implementing sustainability within the agency and
in providing opportunities to advance sustainable practices by other agencies
and organizations in the United States through its programs, research and devel -
opment (R&D), and regulatory mandates. However, clarifying its intent to incor-
porate sustainability concepts and practices across and within the organization
will help to accelerate progress toward achieving EPA’s overarching sustainability
goals as discussed later in the chapter. Although media-specific approaches still
exist within EPA, one strength of a sustainability approach is that it encourages
cross-media approaches. Additionally, the committee does not anticipate EPA will
use the Sustainability Framework for all decisions, but does anticipate that over
35
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36 SUSTAINABILILTY AND THE U.S. EPA
time there will be an increasing use of the framework. As with all decision mak -
ing at EPA, uncertainty needs to be acknowledged and addressed, the approach
needs to be transparent, and key stakeholders need to be engaged.
Figures 3-1 and 3-2 illustrate the committee’s recommended Sustainability
Framework for EPA. The overall approach is driven by sustainability principles
and goals and involves setting, meeting, and reporting on measurable perfor-
mance objectives. As such, the approach reflects an overall management system
framework for sustainability. The framework includes a specific “Sustainability
Management and Assessment” component for incorporating sustainability into
individual EPA decisions and actions, represented by the inset in Figures 3-1
and 3-2. The Sustainability Assessment and Management process is intended to
be applicable to all types of issues, including human health and ecological risks.
Similar approaches have been used successfully in both the private and public
sectors, including several examples described in Box 3-1. In addition, the com -
mittee was informed by several efforts to synthesize the literature on sustainable
development and propose sustainability frameworks (including Graedel and Klee
2002; Marshall and Toffel 2005; Porritt 2007; Jabareen 2008). In fact, EPA has
been a user and promoter of environmental-management-system frameworks.
This topic was the subject of Executive Order 13148, which was later reaffirmed
by President Bush’s administration in a 2006 memorandum “Commitment to
the Integration and Utilization of Environmental Management Systems” (EPA
2006). The agency has also prepared guidance for developing environmental-
management-system frameworks for organizations and businesses, noting in its
introductory remarks to these entities, “As one of your organization’s leaders,
you probably know that interest in environmental protection and sustainable
development is growing each year. You might hear about these issues from cus-
tomers, the public, or others. Like many, your organization may be increasingly
challenged to demonstrate its commitment to the environment. Implementing an
[environmental management system] can help you meet this challenge in several
important ways” (EPA 2008).
THE SUSTAINABILITY FRAMEWORK
A management system framework will accelerate incorporation of sustain -
ability into the operational activities of EPA, which has many motivated and
committed professionals who enjoy their jobs and do them well with the goal
of protecting public health and ecosystem health. The framework will guide
their management of competing priorities and the “pushes and pulls” inher-
ent in their roles by providing a basis for setting priorities based in part on
sustainability considerations. In particular, decision makers in the agency at
all levels have a special responsibility in considering and making the trade-offs
and finding balances inherent in a sustainability framework. This recommended
operational framework for sustainability will accelerate alignment and culture
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FIGURE 3-1 A framework for EPA sustainability decisions
37
S-1 and 3-1
revised le 7/26/11
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38
FIGURE 3-2 A framework for EPA sustainability decisions (Level 1). This level consists of a number of components that define the agency-
wide process.
3-2 new gure
Bitmapped
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39
A SUSTAINABILITY FRAMEWORK FOR EPA
BOX 3‑1
Examples of Management System Frameworks for Sustainability
A management-system approach, built on vision, objectives, goals, and etrics, m
is a commonly used approach to changing cultures and delivering significant
course corrections and performance improvement. A well-known example of this
approach is the setting of the U.S. aspiration to send a man to the moon, with a safe
return, by President John F. Kennedy. This vision and goal set into motion strategic
planning and goal setting that helped the country to achieve what was then, and is
now, a remarkable breakthrough. Many other government agencies have used this
kind of approach—for example, in the eradication of certain infectious diseases and
reduction of smoking rates. Currently, the U.S. Geological Survey (USGS) is using
a similar approach (USGS 2007, 2010) by realigning its management and budget
structure to support a newly developed science strategy designed to address the
major scientific issues facing the nation, including global climate change, water
resources, natural hazards, energy and minerals, ecosystems, and data integration
(USGS 2007, 2010).
Several NGOs have been involved in collaborative sustainability activities,
including the World Resources Institute, the Environmental Defense Fund, and
the World Wildlife Fund. Additionally, sustainability has been embraced as a
cost-effective organizing principle by the private industry. For example, Proctor
& Gamble (P&G) recently released a long-term vision in sustainability and new
2020 goals related to products, operations, and social responsibility (P&G 2011).
Similarly, Unilever released its Sustainable Living Plan which includes 50 goals
related to the company’s environmental impacts of its products (Unilever 2011).
Wal-Mart has also made enormous changes in energy and resource consumption
in their supply chains (Quinn 2009).
change in the agency and provide a platform for more integrated decision
making in the future.
EPA is already engaged in many projects and approaches that further sus-
tainability aims, but adoption of this approach with staged and programmatic
implementation will lead to a growing body of agency successes and experiences
with the incorporation of sustainability. The adoption of the overall management
system approach could occur quickly, and the use of the Sustainability Assess -
ment and Management process can be phased in over time on agency decisions
and actions.
Much of the acceleration of progress will occur as the culture of EPA moves
toward incorporation of sustainability, and as EPA’s intentions and goals in sus -
tainability become clear to employees. The good work of EPA already in prog-
ress is encouraged, and more experimentation in the program offices and in the
regions will help lead the way to a new EPA culture.
The Sustainability Framework is organized into a two-level process and is
presented in Figure 3-1. Level 1 consists of a number of components that define
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40 SUSTAINABILILTY AND THE U.S. EPA
the agency-wide process (Figure 3-2). Level 1 components are depicted in gray
and described in this chapter. Level 2 (Figure 4-1) articulates the elements of
the Sustainability Assessment and Management component that are described
in Chapter 4.
THE SUSTAINABILITY FRAMEWORK: LEVEL 1 COMPONENTS
Level 1 of the Sustainability Framework, described below, includes the
sustainability paradigm, principles, and legal mandates that feed into the pro -
cess; EPA’s sustainability vision as well as objectives, goals, and indicators and
“metrics” (see Appendix C); organization and culture; sustainability assessment
and management; and periodic evaluation and public reporting activities.
Sustainability Paradigm, EPA Sustainability Principles,
and Legal Mandates
EPA needs to specify and acknowledge a set of principles and assumptions
that underlie its approach to sustainability. First, the committee recommends that
EPA formally adopt as its sustainability paradigm the “Three Pillars” approach
of “Social,” “Environment,” and “Economic” dimensions of sustainability as a
well-recognized and established model for evaluating sustainability in its deci -
sions. The committee recognizes that there are other sustainability models and
paradigms, but the “Three Pillars” model has stood the test of time in many orga -
nizational implementations owing to its utility and its relative simplicity and clar-
ity. For example, the United Nations et al. (2003) has noted that this three-pillar
approach to sustainable development is widely held, wide-ranging, and complex.
EPA already has a strong focus on the environmental component of the paradigm
and on the social pillar as it relates to managing human health risks. However,
an integrated approach across all dimensions has not been the usual practice of
EPA. The “Three Pillars” approach should become a key part of educating all
employees about agency philosophy, principles, and performance expectations.
It is a powerful yet simple paradigm for explaining and incorporating the key di -
mensions of sustainable development. (The “Three Pillars” approach is also com-
monly known as the “Triple Bottom Line” approach. As explained in Chapter 2,
the roots of both are the same.) Neither the pillar labeled “environment” nor the
“social” pillar explicitly convey the inclusion of human health and well-being.
The social pillar traditionally includes human health aspects (Chapter 2) and the
inclusion of human health under it would be made transparent by defining it as
the “social pillar (including human health).” This inclusion would clarify the im -
portant place of human health in the Sustainability Framework. The committee
recognizes that the social pillar also includes environmental justice and employ -
ment, among other things, but human health deserves explicit mention because
of its historical role as part of the agency’s mission.
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A SUSTAINABILITY FRAMEWORK FOR EPA
It is important for EPA to optimize all three of the pillars of sustainability.
Although addressing economic issues is not a core part of EPA’s mission, it is ex-
plicitly part of the definition of sustainability (NEPA[1969], E. O.13514[2009]).
Inherent in the definition of sustainability is the recognition of the importance
of the three pillars. Optimizing this three pillar approach is key to the Trade-off
Analysis and Synergy component of the Sustainability Framework. The economic
factors in question will depend, in part, on the decision at hand, and how to ad -
dress those factors will depend on the tool EPA chooses in its analysis. Decisions
that further one of the three pillars should, to the extent possible, further the other
two. Where EPA has the legal authority to consider economic factors, integrating
sustainability into EPA’s decision making means furthering all three pillars as
much as possible at the same time.
Second, and equally important, EPA could benefit from formally develop-
ing, adopting, and publishing a set of broad “EPA Sustainability Principles,”
which underlie all agency policies and programs. These principles would guide
the agency’s implementation of regulatory mandates and discretionary programs
in ways to optimize benefits as they relate to the three pillars—social, environ-
mental, and economic. Several key principles of public administration include
openness and transparency, reliability, accountability, efficiency, and effectiveness
(OECD 1999). A wide variety of principles have been articulated by government
agencies, nongovernmental organizations (NGOs), international governmental
organizations (IGOs), and companies. Box 3-2 identifies sample principles that
have been used internationally or by specific countries. The committee included
these principles for illustration purposes only. Although EPA has had agency-
wide guiding principles (EPA 1997) and may utilize or research sustainability
principles for particular applications (EPA 2007), it has yet to clearly articulate
a broad set of sustainability principles to guide decisions agency-wide. The most
widely cited and used set of principles in the world are the sustainable develop -
ment principles from the Rio Declaration of 1992 (Chapter 2). Others have been
developed within the OECD, where the United States has joined in the consensus
leading to their adoption. Some of the key dimensions of the principles that EPA
should debate and adopt include intergenerational and intragenerational equity, 1
justice, and a holistic-systems approach to environmental problems and solu -
tions. Abbott and Marchant (2010) stated that a “notable aspect of sustainability
1 Professor Edith Brown Weiss explained intergenerational equity as having three elements,
including an intragenerational aspect. First, each generation should conserve the options of future
generations by conserving “the diversity of the natural and cultural resource base.” Second, each
generation is entitled to a quality of planet enjoyed by prior generations, and also has an obligation to
pass to the next generation a quality of planet that is no worse than it received. Third, all people in the
current generation should have the same minimal level of access to this legacy. Because poverty and
environmental degradation are inseparably linked, equity within the current generation is necessary
for equity between generations (Weiss 1989).
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42 SUSTAINABILILTY AND THE U.S. EPA
BOX 3‑2
Selected International and National Sustainability Principles
Some selected principles developed internationally to guide sustainability efforts
are listed below.
Rio Declaration (described in Chapter 2)
• “In order to achieve sustainable development, environmental protection shall
constitute an integral part of the development process and cannot be consid-
ered in isolation from it.”
• Precautionary approach: “Where there are threats of serious or irreversible
damage, lack of full scientific certainty shall not be used as a reason for post-
poning cost-effective measures to prevent environmental degradation.”
• Intergenerational equity: The Rio Declaration acknowledges the need “to
e
quitably meet developmental and environmental needs of present and future
generations.”
• Internalization of environmental costs: The “approach that the polluter should,
in principle, bear the cost of pollution,” is reflected in varying degrees through-
out U.S. environmental law.
• “Environmental issues are best handled with participation of all concerned
citizens, at the relevant level” (UNCED 1992).
OECD Environmental Strategy for the First Decade of the Twenty-first Century
• “Regeneration: Renewable resources shall be used efficiently and their use
shall not be permitted to exceed their long-term rates of natural regeneration.”
• “Substitutability: Non-renewable resources shall be used efficiently and their
use limited to levels which can be offset by substitution by renewable resources
or other forms of capital.”
• “Assimilation: Releases of hazardous or polluting substances to the environ-
ment shall not exceed its assimilative capacity; concentrations shall be kept
below established critical levels necessary for the protection of human health
and the environment.”
• “Avoiding Irreversibility: Irreversible adverse effects of human activities on
ecosystems and on biogeochemical and hydrological cycles shall be avoided”
(OECD 2001).
is its holistic and cross-cutting nature—it cannot be achieved by any single rule,
statute, or agency” (p.1924).
Third, EPA would benefit from making sustainability part of the “how” EPA
goes about implementing its regulatory authorities and objectives, thus creating
more value in its work but not at the expense of its responsibilities under the law.
Implementing its regulatory mandates is the core work of the agency. Also, under
the Sustainability Framework, EPA would continue to promote human well-being
and protect human health in implementing core mandates while more deliberately
addressing the other dimensions (e.g., giving ecosystem well-being higher prior-
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A SUSTAINABILITY FRAMEWORK FOR EPA
Australia’s National Strategy for Ecologically Sustainable Development’s Guiding
Principles
• “Decision making processes should effectively integrate both long and short-
term economic, environmental, social and equity considerations.”
• “Where there are threats of serious or irreversible environmental damage,
lack of full scientific certainty should not be used as a reason for postponing
measures to prevent environmental degradation.”
• “The global dimension of environmental impacts of actions and policies should
be recognised and considered.”
• “The need to develop a strong, growing and diversified economy which can
enhance the capacity for environmental protection should be recognized.”
• “The need to maintain and enhance international competitiveness in an envi-
ronmentally sound manner should be recognized.”
• “Cost effective and flexible policy instruments should be adopted, such as
improved valuation, pricing and incentive mechanisms.”
• “Decisions and actions should provide for broad community involvement on
issues which affect them” (AESDSC 1992).
Canada’s Federal Sustainable Development Strategy
The Federal Sustainable Development Act (FSDA) states that “The Govern-
ment of Canada accepts the basic principle that sustainable development is based
on an ecologically efficient use of natural, social and economic resources.” The
government of Canada’s approach to sustainable development therefore reflects a
commitment to minimize the environmental impacts of its policies and operations
as well as maximize the efficient use of natural resources and other goods and
services. Canada’s environmental policy is guided by the precautionary principle
and is reflected in the Federal Sustainable Development Strategy (FSDS) as re-
quired by the Federal Sustainable Development Act, which states that the Minister
of Environment must “develop a Federal Sustainable Development Strategy based
on the precautionary principle” (Environment Canada 2010).
ity than in previous EPA efforts). EPA is in a unique position to further sustain -
ability opportunities for all stakeholders by implementing this framework and by
working collaboratively to find more optimal sustainability solutions.
EPA Sustainability Vision
A clear statement of sustainability vision is an important step to helping all
EPA employees understand and execute their responsibilities in sustainability.
EPA needs to formally develop and specify its vision for sustainability. Vision,
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44 SUSTAINABILILTY AND THE U.S. EPA
in the sense discussed here, is a future state that EPA is trying to reach or is
trying to help the country or the world to reach. There is literature evaluating
whether visions promote organizational effectiveness (Zaccaro and Banks 2001,
Kantabutra 2010, O’Connell et al. 2011), including conceptual models developed
to evaluate how visions promote organizational effectiveness suggest that they
do influence organizational effectiveness in several ways (Projasek 2003, Parrish
2010), including by “providing a source of envisioned empowerment that mo-
tivates followers” (Zaccaro and Klimoski 2001). Although EPA has always had
clear statements of mission, times call for a very clear articulation of the sustain -
ability vision that EPA is trying to help deliver through its work. It is important
that EPA debate and adopt a sustainability vision as an organic process to guide
the agency forward.
EPA’s stated mission—to protect human health and the environment—
appropriately reflects the agency’s statutory authority. In addition to its mission,
EPA lists seven specific purposes that explain the mission (see Chapter 1 for
discussion about EPA’s mission). For example, one purpose for EPA is “to ensure
that environmental protection is an integral consideration in U.S. policies con -
cerning natural resources, human health, economic growth, energy, transporta -
tion, agriculture, industry, and international trade, and these factors are similarly
considered in establishing environmental policy” (EPA 2011). Another purpose is
“to ensure that environmental protection contributes to making our communities
and ecosystems diverse, sustainable and economically productive” (EPA 2011).
Together with the mission statement, those purposes address the question; Why
does EPA exist? They also reflect sustainability principles. Still, EPA may wish
to reconsider these statements at the same time it finalizes its sustainability vision
to assure coherence and clarity.
EPA Objectives, Goals, Indicators, and Metrics
Once articulated, the sustainability vision will be a touchstone in the future
that guides the setting of objectives and goals. EPA could benefit from consid-
ering a goal-setting approach that starts with a long-term vision. One such ap -
proach, for illustration, is a “backcasting” approach developed for sustainability
(Holmberg and Robert 2000, Natural Step 2011).
In backcasting, a future vision is articulated. With that vision in mind, goals
and objectives are developed for immediate implementation that in a shorter
term will help the organization to make significant progress toward the long-term
vision (Natural Step 2011). Setting several breakthrough 3-5 year objectives 2
could assist EPA in delivering a new level of performance in driving more sus-
2 Commonly referred to in the business community, breakthrough objectives are goals that extend
far beyond the current capabilities and experiences of an organization and require new strategies and
approaches to ensure successful attainment of these goals. These objectives are generally designed to
improve performance throughout an organization.
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A SUSTAINABILITY FRAMEWORK FOR EPA
tainable outcomes and most important, will guide EPA employees in seeing the
commitment of agency leadership to new ways of operating. For example, EPA
can specify several 3-5 year objectives and associated short-term measureable
goals that advance the agency and the country toward the sustainability vision.
For illustration purposes only, EPA could set a 3-5 year objective that “by 2015,
the EPA will have facilitated 25 green infrastructure projects that deliver regula-
tory performance comparable to conventional pollution control systems, but at
lower costs, with higher conservation values and outcomes, and measurable net
job creation.”
This kind of objective would be a strong signal of the need to shift to place-
based sustainability projects and experimentation with green infrastructure ap -
proaches. The indicators for assessing performance against this objective could
be the number of green infrastructure projects completed, associated cumulative
value of cost savings and ecosystem service value gained, and human health risk
reduction. Again, this example is only for illustrative purposes; however, the
pursuit of breakthrough 3-5 year objectives, chosen well, could help EPA reshape
its culture and its cross-program teamwork and help all employees—headquarters
and regional—align their professional goals and activities. The NRC (2006) noted
that “successfully targeting and sustaining programs linking knowledge with
action for sustainability generally requires a clear, readily understood statement
of the beneficial outcomes that successful project completion would deliver. Op -
erationally, this translates into the articulation of clear, broadly shared goals, and
the development and operational measurement of generally accepted indicators
of goal achievement” (p.18).
Organization and Culture
Identifying and communicating the objectives selected, the indicators and the
associated metrics needed for implementation is the next step. EPA could benefit
from staying focused on implementation and minimizing structural changes in the
organization to help it embrace the new goals and objectives in the current orga -
nizational configuration. To a great extent, the committee’s primary focus is much
more on developing a new culture of sustainability in the agency (Chapter 6)
rather than on organizational changes. The agency could benefit from specifically
focusing on education, learning, and alignment of senior staff, and eventually
all employees, with the new sustainability approach and the roles everyone can
play in helping to accelerate progress. The fastest progress will be made through
empowering the employees of EPA and by building a strong sustainability culture
at the agency.
The Office of Research and Development (ORD) has already begun to or-
ganize its programs around sustainability-related themes (Figure 3-3), which is
consistent with the “sustainability journey” described, and several EPA regional
programs have also begun to think about their programs and projects in a new
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46 SUSTAINABILILTY AND THE U.S. EPA
FIGURE 3-3 Reorganization themes of the Office of Research and Development.
SOURCE: Hecht 2010.
sustainability-oriented manner (Chapter 7). Organizing programs and themes
around accomplishing sustainability Figure 3-3 accelerate progress.
objectives can
R01984 Sustainability in EPA, Green Book
bitmapped
Sustainability Assessment and Management
The overall framework covers the highest levels of visioning and goal setting
for EPA, but it also covers the daily implementation of sustainability as part of
the ongoing decisions and actions. The component of the framework “Sustain -
ability Assessment and Management,” provides a decision-making approach for
incorporation of sustainability into the daily work of the agency. It is intended
to deal with the “nuts and bolts” of implementation. Chapter 4 of this report is
devoted to describing the elements of the Sustainability Assessment and Manage-
ment component and the analytic tools for use in applying it.
EPA at all levels, offices, and regions faces daily decisions and potential ac -
tions in various contexts—for example, routine permitting, enforcement actions,
reviewing significant new-use chemical applications, development of regulations,
and major policy initiatives. The general approach recommended by the com-
mittee for sustainability assessment and management—laid out as Level 2 in
Figure 3-3 and discussed in greater depth in Chapter 4—will need to be shaped
for application in EPA’s various programs, and some routine decision making
may not be best served by formal sustainability reviews for each project.
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A SUSTAINABILITY FRAMEWORK FOR EPA
EPA will need to decide what kinds of activities or actions to address in a
sustainability assessment process. Adopting a sustainability framework is dis -
cretionary, and EPA will choose where to focus its attention and resources. For
example, the agency may wish to focus on major new rules, programs, or policies;
priorities for program improvement; and complex and important emerging issues,
such as the periodic review of the impacts of biofuels production and use required
by Congress (Public Law 110-140). Another option could be for EPA’s program
and regional offices to be tasked with selecting priority initiatives or activities in
their fields of work for sustainability assessments. The choices made may or may
not be related to the goals set at the beginning. Certain categories of actions, such
as routine permits, grants, and enforcement actions, could be excluded altogether
from consideration for sustainability review, or the agency could decide to infuse
sustainability thinking and practices into routine decision-making processes as
they are periodically reviewed and updated.
Over time, EPA will need to develop approaches to decide when and how to
incorporate sustainability considerations into agency decisions and actions, par-
ticularly those significant enough to be moved through the Sustainability Assess -
ment and Management approach (Level 2); staff training on this approach will
be needed. The scale and depth of the analysis and other aspects of the process,
including stakeholder involvement, will need to be commensurate with the deci -
sion type and potential sustainability impact. The committee realizes that it will
take some time to effect this change in culture and process.
Periodic Evaluation and Public Reporting
The collective actions of an EPA program and the agency as a whole (and
its partners in communities and other agencies) will have an impact on the sus -
tainability indicators (linked to breakthrough objectives and goals) of the agency
as well as on many other indicators. The metrics for these indicators should be
evaluated annually, checking for progress over time and informing needs for
change within the agency in terms of organization, focus, and resource allocation.
For purposes of this report, the committee will refer to “metrics” as the
measured values used to assess specific indicators of progress (see Box 3-3
and additional discussion of indicators and metrics in Chapter 4). Indicators, in
general, are measures of impact that can be aggregated to track overall progress.
EPA would benefit from an effort to develop metrics (measurement systems) for
those indicators that could serve as a “dashboard of progress” for the agency and
its administration. The selection of a slate of metrics is a challenging endeavor,
requiring appropriate resources. It is necessary to directly link selected metrics to
EPA’s vision as well as to the long-term goals and objectives of the agency. Once
objectives and indicators are identified and metrics specified, they can become
part of the long-term commitments of the agency to be reported annually in public
reports and administrator summaries of accomplishments.
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48 SUSTAINABILILTY AND THE U.S. EPA
BOX 3‑3
Goal, Indicator, and Metric
Goal—what is specifically sought to be achieved. The goal is determined through
the use of measured indicators.
Example: Reducing mercury emissions from electric utility steam generating units.
Indicator—“A summary measure that provides information on the state of, or
change in, a system” (OECD 2011b), that is, what is being measured.
Example: Mass of mercury emitted per heat energy input, for example, pounds
per gigawatt hours.
Metric—“Defines the unit of measurement or how the indicator is being measured”
(OECD 2011a).
Example: Using the first definition, an example metric would be [grams Hg (of
mercury)/Kwh (of energy input)]. The description below illustrates the metric in the
latter sense—specifying exactly how one arrives at the measure—so that any two
individuals in different institutions would come up with the same number.
Example: A mercury continuous-emissions monitoring system is used to measure
molecules of the element Hg (mercury) in the stack gas as they pass through a
sorbent trap. This measure is reduced to an hourly mass emissions rate. Then the
indicator is calculated from a formula that uses the Hg hourly concentration, the flow
rate of the stack gas, the electrical load, the diluent gas concentration, and moisture
data. This indicator is then compared with a reference value to determine whether
the unit is in compliance (EPA 2010)
A set of indicators and associated metrics (associated with goals and objec -
tives) and indicators associated with international reporting protocols could be
published periodically by EPA to inform its employees and the public about
progress toward national objectives and goals. Over time, this reporting will be-
come a key part of a new culture at EPA that is linked to delivering measureable
progress toward sustainability. Goals, objectives, and indicators and associated
metrics would benefit from being periodically reviewed for relevance to improv-
ing sustainability and for EPA’s ability to have an impact on them positively
through their actions.
Federal agencies are required under the Government Performance and Results
Act (GPRA) to prepare strategic plans, annual performance plans, and annual per-
formance reports (31 U.S.C. § 1115). Agencies must clearly identify high-priority
performance goals in their strategic plans, annual performance plans, and annual
reports and are expected to internally review performance related to their goals. The
Office of Management and Budget (OMB) directs senior agency leaders to hold
“goal-focused, data-driven reviews at least once every quarter to review progress on
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A SUSTAINABILITY FRAMEWORK FOR EPA
agency priorities and to assure that follow-up steps are taken to increase the likeli-
hood of achieving better outcomes, higher productivity, and priority goals” (OMB
2010). Meeting GPRA requirements and developing sustainability indicators and
associated metrics could be coupled, for example, under EPA’s 5 year Strategic
Plan (EPA 2010).
FINDINGS AND RECOMMENDATIONS
3.1. Key Finding: Organizations that most effectively integrate sustainabil-
ity into their work and culture are those that base their programs on clear
principles, vision, strategic goals, and implementation processes (p.45-47).
3.1. Key Recommendation: EPA should adopt or adapt the comprehen-
sive Sustainability Framework proposed in Figure 3-1. The proposed
Sustainability Framework requires a comprehensive approach includ-
ing specific processes for incorporating sustainability into decisions and
actions. As part of the framework, EPA should incorporate upfront,
consideration of sustainability options and analyses that cover the three
sustainability pillars, as well as trade-off consideration into its decision
making. This framework was developed with the intent that EPA could
apply it to any decision to which a need arose.
3.2. Key Finding: Organizational incorporation of sustainability requires
clear, broadly shared goals, and the development and operational measure -
ment of generally accepted indicators and associated metrics of goal achieve-
ment (p.47).
3.2. Key Recommendation: For programs, EPA should set several stra-
tegic 3-5 year breakthrough objectives related to its sustainability imple-
mentation and its performance indicators and associated metrics. These
goals would be designed to improve performance throughout the agency
by extending beyond its current capabilities and experiences and requir-
ing new strategies and approaches to ensure their attainment. EPA
should begin periodic public sustainability reporting to transparently
review its progress versus goals.
3.3. Key Finding: For successful implementation of sustainable-development
principles in organizations and their work, the “Three Pillars” paradigm has a
proven track record of effectiveness in the United States and globally. Practi-
cally all of EPA’s activities under its environmental statutes are intended to
protect human health and well-being. However, the pillar for “environment”
may not convey the inclusion of human health and well-being under that
heading. The committee proposes that EPA consider defining the social pillar
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50 SUSTAINABILILTY AND THE U.S. EPA
as the “social pillar (including human health)” to clarify the important place
of public health in the Sustainability Framework (p.40).
3.3. Key Recommendation: The committee recommends expressly in-
cluding the term “health” in the social pillar to help ensure that EPA
regulatory and scientific staff primarily concerned with human-health
issues recognize their existing role in sustainability and recommends
that EPA pay particular attention to explaining the role of human health
in the social pillar, thereby ensuring that staff and stakeholders involved
in the area of human health recognize that their activities are an integral
part of EPA’s sustainability work. Further, expressly including health
in the social pillar will more clearly communicate outside of EPA the
agency’s role in that pillar of sustainability.
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