Cooperative Environmental Management

National Advisory Council
for
Environmental Policy & Technology

November 6, 2003

Dear Administrator Leavitt:

On behalf of the National Advisory Council for Environmental Policy and Technology (NACEPT), I am pleased to welcome you as the new Administrator and to present to you the attached advice letter fulfilling the second part of our commitment to provide EPA with comments and recommendations in response to the Draft Report on the Environment (ROE). This advice letter was developed by the NACEPT Report on the Environment Working Group and endorsed by the full Council.

The NACEPT commends EPA for the extensive work that resulted in the Draft ROE. The document is a necessary and valuable first step in identifying the critical indicators of the health of the nation’s environment. We strongly support the Agency’s efforts to engage policymakers and the interested public in discussing the ROE’s findings and identifying next steps. To that end, our comments focus on three overarching issues:

• The indicators themselves - their appropriateness, their accuracy, their completeness
• The public consultation process
• The next steps - issues for further study and inclusion in future reports

Although the comments include a number of recommendations, I would like to emphasize three issues. First, we strongly recommend that EPA issue a final report and a schedule for subsequent periodic updates. At a minimum the report should be issued on a schedule that will allow the findings to inform the preparation of EPA’s Strategic Plan. Further, we believe that the nation needs and wants accurate and meaningful indicators for evaluating the health of the environment. As the current effort shows, however, such a project is too complex to trust to an ad hoc process. We believe that EPA should have lead responsibility for developing and publishing environmental indicators and should be provided with the staff and funding resources necessary to carry out this important task.

We commend the EPA for soliciting public input and feedback on the draft ROE. However, we noted that no forums are planned for the Mid-Atlantic or Northeast. We recommend that the Agency schedule a public forum or webcast in this region. Further, we encourage the EPA to consider expanding its use of technology, and particularly the Internet, to increase the opportunity for the public to respond to the draft ROE. The NACEPT stands ready to assist your Agency in its outreach efforts, and we expect that NACEPT members will attend the regional forums.

Finally, we note that EPA staff, have been participating in an international effort to develop common environmental indicators and measurement methodologies. As we move from activity to outcome-based environmental protection programs, it will become increasingly important to understand how the actions taken by different agencies, and for differing environmental media, interrelate. Likewise, we will need to better understand how our programs in the U.S. affect worldwide environmental quality and vice versa. The NACEPT commends EPA staff’s participation in that effort and supports fully any attempts to integrate the national-level indicators discussed in the draft ROE with parallel efforts to identify appropriate data at state and local, as well international levels.

Thank you again for the opportunity to comment on this seminal effort. EPA’s issuance of the draft ROE could not be timelier, and the NACEPT looks forward to assisting in the preparation and review of subsequent reports.

Attachment

cc: Marianne Horinko
Kim Nelson
Paul Gilman