Detailed Information on the
Pollution Prevention Program Assessment

Evaluate Science Advisory Board Report recommendations for improving performance measures to better demonstrate P2 results.

Identifying and reducing barriers associated with core EPA activities that limit implementation of pollution prevention practices by industry.

Fully implement Grant Trak and P2 State Reporting System. Obtain consistent 2007 results from Regions.

Complete P2 Program Strategic Plan and commence implementation of targeted actions in priority focus areas.

Developing additional P2 Program efficiency measures to expand the portion of the program's resources that are addressed.

Measure: Pounds of hazardous material reduced by Pollution Prevention (P2) program participants.

Explanation:The P2 program is designed to facilitate the incorporation of pollution prevention concepts and principles into the daily operations of government agencies, businesses, manufacturers, nonprofit organizations, and individuals. This long term performance measure tracks the cumulative pounds of hazardous materials reduced as a result of these activities for participants in the P2 program only. P2 activities capture source reduction and reduce the amount of toxic chemicals that enter the waste stream thereby reducing the need to recycle, treat, or dispose of hazardous materials. Baseline is 44 million pounds in 2000. Since 2000, the number of programs/efforts within the Pollution Program that have come on-line to produce results has increased from one in 2000 to seven in 2006 and beyond.

Measure: Cumulative pounds of hazardous materials reduced by Pollution Prevention (P2) program participants.

Explanation:The P2 program is designed to facilitate the incorporation of pollution prevention concepts and principles into the daily operations of government agencies, businesses, manufacturers, nonprofit organizations, and individuals. This long term performance measure tracks the cumulative pounds of hazardous materials reduced as a result of these activities for participants in the P2 program only. P2 activities capture source reduction and reduce the amount of toxic chemicals that enter the waste stream thereby reducing the need to recycle, treat, or dispose of hazardous materials. Baseline is 44 million pounds in 2000. Since 2000, the number of programs/efforts within the Pollution Program that have come on-line to produce results has increased from one in 2000 to seven in 2006 and beyond.

Measure: Business, institutional and government costs reduced by Pollution Prevention (P2) program participants.

Explanation:The Pollution Prevention (P2) program is designed to facilitate the incorporation of pollution prevention concepts and principles into the daily operations of government agencies, businesses, manufacturers, nonprofit organizations, and individuals. This annual performance measure tracks the amount of money saved by businesses, institutions and government from implementing pollution prevention activities. P2 activities use source reduction to reduce the amount of hazardous materials that enter the waste stream, reducing the need to recycle, treat, or dispose of hazardous materials, thereby generating cost savings from these forgone activities. Baseline for this measure is zero dollars in 2002. Starting in 2003, the program was able to quantify cost savings from two programs. In 2006 and beyond, seven programs are generating cost savings results.

Measure: Cumulative business, institutional and government costs reduced by Pollution Prevention (P2) program participants.

Explanation:The P2 program is designed to facilitate the incorporation of pollution prevention concepts and principles into the daily operations of government agencies, businesses, manufacturers, nonprofit organizations, and individuals. This annual performance measure tracks the amount of money saved by businesses, institutions and government from implementing pollution prevention activities. P2 activities use source reduction to reduce the amount of hazardous materials that enter the waste stream, reducing the need to recycle, treat, or dispose of hazardous materials, thereby generating cost savings from these forgone activities. Baseline for this measure is zero dollars in 2002. Starting in 2003, the program was able to quantify cost savings from two programs. In 2006 and beyond, seven programs are generating cost savings results.

Measure: Annual Reductions of Design for the Environment (DfE) chemicals of concern per federal dollar invested in the DfE program.

Explanation:This measure formerly tracked efficiencies from the formulators program within the Office of Pollution Prevention and Toxic's (OPPT) DfE program. For the FY 2008 Spring PART Update, the scope of this measure was expanded to include all DfE programs currently producing results. This is consistent with OMB requests to tie efficiency measures with larger portions of the Program's resource base.

Measure: Cumulative Metric Tons of Carbon Equivalent (MTCE) reduced, conserved, or offset by Pollution Prevention (P2) Program participants.

Explanation:The P2 program is designed to facilitate the incorporation of pollution prevention concepts and principles into the daily operations of government agencies, businesses, manufacturers, nonprofit organizations, and individuals. This annual performance measurestracks the reduction, conservation, or offset of greenhouse gases through electricity conservation, fuel specific substitutions, renewable energy offsets, or changes in the manufacturing process of chemicals or products. Baseline for this measure is 0.156 MMTCE in 2005. Starting in 2005, the program was able to quantify energy conservation from program activities.

Measure: Metric Tons of Carbon Equivalent (MTCE) reduced, conserved, or offset by Pollution Prevention (P2) program participants.

Explanation:The P2 program is designed to facilitate the incorporation of pollution prevention concepts and principles into the daily operations of government agencies, businesses, manufacturers, nonprofit organizations, and individuals. This annual performance measure tracks the reduction, conservation, or offset of greenhouse gases through electricity conservation, fuel specific substitutions, renewable energy offsets, or changes in the manufacturing process of chemicals or products. Baseline for this measure is 0.187 MMTCE in 2005. Starting in 2005, the program was able to quantify energy conservation from program activities.

Measure: Cumulative gallons of water reduced by Pollution Prevention (P2) program participants.

Explanation:The P2 program is designed to facilitate the incorporation of pollution prevention concepts and principles into the daily operations of government agencies, businesses, manufacturers, nonprofit organizations, and individuals. This annual performance measure tracks the reduction or conservation water through source reduction efforts. Baseline for this measure is 220 million gallons of water conserved in 2000.

Measure: Gallons of water reduced by Pollution Prevention (P2) program participants.

Explanation:The P2 program is designed to facilitate the incorporation of pollution prevention concepts and principles into the daily operations of government agencies, businesses, manufacturers, nonprofit organizations, and individuals. This annual performance measure tracks the reduction or conservation of water through source reduction efforts. Baseline for this measure is 220 million gallons of water conserved in 2000.

Is the program purpose clear?

Explanation: The Pollution Prevention Act of 1990 (PPA) established a national policy to prevent or reduce pollution at the source whenever feasible. The rationale for this policy is based on the benefits realized from pollution prevention for protecting the environment and reducing risks to worker health and safety, and the substantial savings in reduced raw material, pollution control and liability costs. The purpose of the program is to implement numerous activities provided for in the Act. These include facilitating the adoption of pollution prevention (P2) practices through technical assistance, developing state and tribal capacity, recognizing excellence in P2, using federal procurement to encourage source reduction, and establishing standard methods of measuring results. As intended by statute, the program also works to coordinate P2 efforts and integrate P2 across the agency. The program accomplishes its mission through seven centers for results: 1) The center of 10 Regions report results from matching grants to state/tribal P2 programs, source reduction grants to promote P2 practices by industry, and direct regional efforts to facilitate business P2 practices and interstate coordination on promoting P2. 2) The Pollution Prevention Resource Exchange (P2Rx) center provides national-level P2 information to state and tribal P2 technical assistance providers, and records the results of state P2 programs. 3) The Design for Environment (DfE) center provides technical guidance to industry, as well as information on critical hazard, comparative risk, cost, and performance data for industrial processes. 4) The Green Chemistry center challenges industry and the research community to develop and implement scientifically innovative and cost competitive green chemistry technologies. An annual Presidential recognition is awarded. 5) The Environmentally Preferable Purchasing (EPP) provides computer training modules on environmental purchasing. EPA has regulations and guidance regarding EPP as well as a database with preferable products and services that can be purchased. EPP also provides assistance to federal agencies in complying with Executive Order 13101, which requires federal agencies to procure "green" products and services. 6) The Hospitals for a Healthy Environment (H2E) is a voluntary partnership with individual hospitals, hospital suppliers, and related healthcare organizations, to reduce and eliminate mercury and hazardous chemical use. H2E provides technical assistance and an awards program. 7) The Green Suppliers Network (GSN) center collaborates with the Department of Commerce's Manufacturing Extension Partnership Centers and original equipment manufacturers (OEMs) to provide the OEM's suppliers with technical assistance on cost-competitive P2 opportunities through environmental reviews.

Evidence: Pollution Prevention Act of 1990, EO 13101, Toxic Substances Control Act

Does the program address a specific and existing problem, interest, or need?

Explanation: The program addresses the continuing problem of pollution released into the environment and the associated risk to human health and the environment, and the need to prevent the problem at its source. As stated in the Pollution Prevention Act, the United States annually produces millions of tons of pollution and spends tens of billions of dollars every year controlling this pollution. While the U.S. has made great strides in reducing pollution at the source, the problem the program was created to address still exists. On an annual basis, the U.S. still emits more than 100 million tons of criteria air pollutants and over 7 billion tons of greenhouse gases , and generates 30 million tons of hazardous wastes from more than 17,000 sources. Some pollution streams are increasing. For example, end-of-life impacts of used and obsolete electronics are part of an increasing and complex waste stream that poses significant environmental management problems. Electronic products contain hazardous materials such as lead, mercury, brominated flame retardants and cadmium. Almost 3 million tons of consumer electronics entered the municipal waste stream in 2003, up from 2 million in 2001. Pollution control equipment and operation can be costly for industry. Controls can be especially difficult to put in place and manage by small businesses, thereby putting such companies at a disadvantage in achieving full business competitiveness that can result from solving environmental design inefficiencies, reducing or eliminating disposal and liability costs, and improving public image through greener operations. In the most recent Census Bureau survey available, industry reported spending $17.6 billion on pollution controls, and expenses by states and local governments add billions more to the national costs. Accordingly, the program will need to continue its efforts in preventing pollution at its source.

Evidence: US Census Bureau report "Pollution Abatement Costs and Expenditures:1999", Nov.2002; National Biennial RCRA Hazardous Waste Report;

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: The P2 program is designed to promote and assist with implementation of pollution prevention in both the government and the private sector. Current programs coordinate their efforts with other offices of EPA or with other agencies or departments as well with partnerships in the private sector. 1)The H2E program provides technical assistance to the American Hospital Association as well as individual hospitals to reduce pollution such as mercury in thermometers and hazardous materials in computers. 2)The Manufacturing Extension Partnership in the National Institute of Standards and Technology provides technical assistance to manufacturers on greening their supply chain in a collaboration with the Green Suppliers Network. Technical Assistance Providers provide facility assessments, but do not duplicate energy assessements if they have already been performed by the Department of Energy. 3)Through its Regional and P2Rx database, the P2 program gives financial and informational assistance to state, tribal, and local P2 technical assistance providers.The P2Rx centers collect and disseminate pollution prevention information to state, tribal and local governments, and industry. The P2Rx database is extensive and other programs within EPA, such as Compliance, use the information on the database to provide more comprehensive information to businesses without duplicating effort. 4) P2 Grants: P2 grants provide funding for a comprehensive assessment for pollution prevention activities which include possible substitutions, modifications, and improvements - raw material inputs (including chemicals, energy, water, product components), equipment and technology being used, procedures, formulation and design of products, housekeeping, packaging, maintenance, training, and inventory control. Energy assessments are also performed by the Department of Energy's (DOE) Industrial Technologies Program. These assessments provide technical assistance to industry to reduce energy consumption to promote sustainability and resource onservation. The DOE assessment (if completed for the facility) is taken into consideration by the P2 program and is not repeated in the assessment. The Presidential Green Chemistry Challenge motivates industry and the research community to develop and use innovative and cost-competitive green chemistry technologies. Although the Presidential Green Chemistry Challenge has been copied internationally by other countries including Australia, Italy, and the UK, national management prevents duplicationof the domestic program . DfE promotes voluntary P2 partnerships to industry to facilitate use of safer alternative chemicals. Dfe also encourages best practices for chemicals that have no safer alternatives. State programs adopt DfE methodologies and use DfE technical results in their assistance programs. EPP helps federal agencies to evaluate and purchase products that are environmentally preferrable. Other Federal green purchasing efforts typically address one environmental attribute such as recycled content, or energy efficiency, or bio-based content. Only EPP has created life-cycle based Federal green purchasing guidance. GSN uses NIST Manufacturing Extension Partnership Centers and State technical assistance providers to create national coordination to disseminate environmental improvement through the extensive supply chains of large manufacturers.

Evidence:

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: Overall program design includes voluntary partnerships, grants, Executive Order mandates and activities with Regional offices. There are no regulatory requirements for the P2 program. P2 program design specifically includes information dissemination through databases, direct technical assistance at regions and headquarters, and direct funding for grants. Together, these design elements provide important flexibility for accomplishing the broad program mission. The combination of headquarters and regional components provides flexibility to focus resources and efforts according to location of need. Any grant-based or direct regional technical assistance effort can be deployed in tandem with headquarters technical assistance efforts. The program does not have a standard method of measurement for source reduction across all 10 Regions that supports program effectiveness. The Draft National Pollution Prevention Roundtable P2 Results Report 2001-2003 indicates some programs use different units of measurement to track the same source reduction data. The program is developing standard metrics, definitions and methods for measuring source reduction. A voluntary Memorandum of Understanding has been signed by over 30 state and local programs to use the common P2 metrics. The program's design will not be a hinderance to developing a standard method of measurement for source reduction.

Evidence: NPPR P2 Results Report 2001-2003

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: The P2 program targets resources to the program's purpose and beneficiaries. The program maximizes the use of its resources by focusing on key program areas. These include: Focusing on chemicals of concern to industry, where Design for the Environment can assist businesses to identify less hazardous chemicals. Focusing on industry and researcher development of new chemical technologies, in the Green Chemistry program as well as development of new federal purchasing program for electronics. The P2 program also awards state grants to provide technical assistance to businesses on reducing pollution at the source while also focusing on industry interest in reaching its supply chains. P2Rx data (2001-2005) show an average 83% of direct requests for technical assistance came from government, education/non-profits (technical assistance providers are usually in government and universities) and industry. H2E targets hospitals which have subsequently dropped mercury emissions. EPP targets the purchasing of the federal government and provides technical assistance on the purchase of electronics with less hazardous materials.The Green Chemistry program targets the supply chain of manufacturers to decrease use of toxic and/or non-renewable materials.

Evidence: P2Rx 2004 Users Survey Data;

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The program has 2 long term performance measure that directly and meaningfully supports the program's purpose. The long-term perforamance measures are as follows: 1) Cumulative pounds of hazardous materials reduced by P2 program participants. Hazardous materials include those released to air, water, land, incorporated in products, or used in an industrial process. This measure is for hazardous materials reduced by voluntary participants in the P2 program only. 2) Cumulative dollars saved through pollution prevention improvements in business, institutional, and government by P2 program participants. Both long term performance measures proposed are Level 3 "end outcomes", as defined by GAO report GAO/RCED-00-77. Both long-term measures, extending to 2011, and have been proposed in the Agency's draft 2006-2011 Strategic Plan. In the long term performance measures, "reductions" can mean reducing or eliminating, "Materials" has replaced "pollution" to make clear that hazardous substances in products or used in industrial processes are covered.

Evidence: FY2006 P2 Grant Request for Proposal 1990 Pollution Prevention Act

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: The 2011 targets reflect the cumulative accomplishments expected from the specified baseline years and values, requiring annual targets to be established in order to calculated the long-term targets. Annual targets for 2006 through 2011 were established by each program component by projecting from currently available data and program development plans known at this time, assuming no increases or decreases in program resources over the planning period. The long term performance measure has specific quantified targets and time frames that are ambitious. These are the program's targets and time frames for its long-term measures. 1) By 2011, reduce 4.46 billion pounds of hazardous materials cumulatively from the 2000 baseline amount of 44 million pounds. 2) By 2011, save $791.9 million through pollution prevention improvements in business, institutional, and governmental costs cumulatively from the 2002 baseline amount of $0.0. Over the coming years, the program will work on ever more challenging pollution prevention opportunities. The program will re-evaluate the targets to make more ambitious to support an increasing rate of outcome results through 2011.

Evidence:

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: The program has two annual measures that demonstrates progress toward achieving the long term goals: 1)Pounds of hazardous materials reduced from P2 program participants 2)Business, institutional and government costs reduced by P2 program participants The program also has one efficiency measure: 1) Reductions of hazardous chemicals per dollar spent by federal, state and private sectors.

Evidence:

Does the program have baselines and ambitious targets for its annual measures?

Explanation: Program does have ambitious targets for its annual measure "Pounds of hazardous materials reduced by P2 program participants". The targets are increasing for years 2007-2011 forall annual measures. The P2 program established baselines for its annual measures based on the earliest year with reliable data reported in from P2 participants. Annual baselines are expressed in annual increments from the long-term baselines. The annual measure "business, institutional, and government costs reduced by government, institutional and private sector" has a baseline established using the National Pollution Prevention Roundtable (NPPR) survey for 2000-2003. This survey includes information collected by state,county and municipal governments in surveys as well as state and university P2 programs. NPPR asked state and local P2 programs to provide results in each of the categories (e.g., pollution prevented). In the future, it is anticipated that NPPR reports will use the data reported to the P2Rx centers using the P2 Results Task Force's common measures and data dictionary. This will ensure more consistency in data reported.

Evidence: Presidential Green Chemistry Award nominations Design for Environment proigram participant submissions NPPR State P2 Program Survey data for 2001-2003 Grant report data in EPA Annual Commitment System Regional office reports into Annual Commitment System

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: The Request for Proposal for 2006 grantees contains requirements for commitment to programs goals. The draft RFPs contains a commitment for 10 out of 10 regional offices. The draft RFP requires P2 grantees to report progress on specific actions outlined in their grant agreements semi-annually, however, results are not currently in the GranTrack database. GranTrack database does not show performance measures with targets for all grants for 2006. In cases where performance measures have been entered for 2007, the measure is for hazardous waste reduced, not hazardous materials reduced. The GrantTrak database is being corrected to reflect performance measures for 2006. Contractors. Program did submit adequate evidence that contractors commit toward the annual and long-term goals of the program. Three letters signed by contractors acknowledge their activities are linked to the performance goals listed and in one letter contractor writes in support of P2's "overall" goals. However, the two measures submitted in the letters to contractors were not the performance measures in this 2006 PART for hazardous material reduction, only for conservation. The program will correct contractor confirmation of commitment and include all relevant goals from this 2006 PART. The program does provide evidence how the H2E program is commited to working toward the annual and long term goals. Other activities of the P2 program: The Manufacturing Extension Partnership contributes to performance results in the Green Suppliers Network program through a Request for Proposal which has been finalized and placed on the MEP network system and available to all centers. MEP Centers will work toward achieving the GSN contribution to the program's annual or long-term measures as specified in the RFP by conducting green supply chain reviews for manufacturers. Formulator partners in DfE sign a memorandum of understanding that commits them to the goal of reducing hazardous emissions, continual investigation of safer chemistries for all company products, encouraging suppliers to gather data on chemical ingredients, educating consumers on safer chemical products, and reporting quantified data towards accomplishing these goals.

Evidence: Draft FY2006 Request for Proposals (Regions 1-10) Interagency Agreement for Green Suppliers Network & NIST P2 Mission Contractor Letters

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: The program values this approach, and did make an effort to meet the OMB standards for conducting non-biased evaluations of sufficient scope on a regular or as-needed basis to fill gaps in performance information. The P2 Program obtained an estimate from the National Academy of Public Administration for an independent evaluation, but did not have adequate resources to cover the costs of the evaluation. The program just concluded having an evaluation done of the H2E Center for Results through EPA's Office of Policy, Economics, and Innovation (OPEI).

Evidence: H2E Program Evaluation

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: Agency and OPPT processes and systems address all of the requirements for this question: Element 1. The program has effective budgeting in place that defines the relationship between annual/long-term performance targets and budget resources. EPA's entire annual budget is directly aligned with its Strategic Plan. [A] The Pollution Prevention program is comprised of two discrete Program/Projects that are the focus of congressional appropriations (Pollution Prevention Program in the EPM account; and Categorical Grant: Pollution Prevention in the STAG account). All of the program's resources are aligned with the program's annual and long-term outcome performance measures. [B, C] Changes in program resources affect performance towards those goals, as evidenced in EPA's Budget Analysis System (BAS). [D] All of the program's components (centers of results) contribute in a quantifiably documented manner to the program's long-term and annual performance measures. [B, C] The program's resource information is derived directly from an internal EPA budget database that links resources directly to strategic objectives in the agency's strategic plan. Element 2. The program has an integrated budget presentation that makes clear the impact of funding, policy, or legislative decisions and provides evidence that the requested performance/resource mix will enable the program to achieve its performance goals. [B, C] Because of its status as an exclusive combination of two Program/Projects in EPA's budget and strategic architecture, the program has its own section in the annual Congressional Justification supporting the President's Budget requests. [B, C] An integrated presentation is provided for each Program/Project articulating the activities to be supported by the requested resources and the associated external annual performance measures and targets. [B, C] Key elements of this presentation (resources and performance measures/targets) are continued in BAS through the development of the Agency Operating Plan. In establishing the FY 2005 Operating Plan and in formulating the FY 2006 President's budget, the program conveyed the impact of significant budget reductions by making clearly communicated adjustments to its annual performance measure targets to provide a performance/resources mix that is still considered ambitious but also achievable. Element 3. The program reports all direct and indirect costs needed to attain the performance results, including applicable Agency overhead, retirement, and other costs that might be budgeted elsewhere. In addition to Agency-level procedures that account for fully loaded personnel, enabling support and infrastructure (e.g., Working Capital Fund) costs, OPPT conducts a rigorous annual program planning process, requiring all of its programs to justify funding requests on the basis of expected performance. Program Plan Project Forms identify performance to be provided at requested funding levels and clearly indicate how performance levels change with changes in allocated resources. OPPT's program planning process accounts for indirect as well as direct costs, including funds supporting administrative and infrastructure requirements.

Evidence: See P2 PART Evidence Index and Evidence Document Files hand delivered to OMB and EPA reviewers on April 14, 2006.

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: The program has taken meaningful steps to address strategic planning deficiencies. Prior to 2003, the program had only one outcome measure based on Toxics Release Inventory (TRI), and all its other measures were based on outputs. In 2003, the program kept the TRI outcome measure and added measures (some outcome and some output) directly tied to program activities. Now in 2006, the program has moved entirely to intermediate outcome measures (Level 3) that are all directly linked to its own activities, and that have targets that have been raised at an increasing rate. The program has fine-tuned all long-term and annual performance targets and time lines to be ambitious and achievable. All centers will now be reporting streams of multimedia results to these quantified outcome goals. Finally, the program is also developing two efficiency measures. The program has reviewed its planning efforts. Besides participating fully in the Agency strategic planning process, the program has also created its own cohesive, systematic process for headquarters-regional review of program focal areas, goals, and priorities to strengthen strategic planning. The program moved in late 2003 to define this process and began implementing it in 2005. [E] The process provides for macro-level review of focal areas, goals, and priorities every third year (the year of the Agency strategic planning process) and for micro adjustments to program priorities in alternate years. Priorities are evaluated, among other things, for their potential and actual outcome results in reducing hazardous materials. To strengthen its measurement capabilities, the program has improved program-wide metrics, performance reporting systems, and agency-wide approaches for documenting outcome results. The program has also worked to obtain external recommendations relevant to strategic planning, including convening and responding to the P2 recommendations of the National Pollution Prevention and Toxics Advisory Committee. [C, D]

Evidence: See P2 PART Evidence Index and Evidence Document Files hand delivered to OMB and EPA reviewers on April 14, 2006.

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The P2 Program did not provide evidence that credible performance information is collected from program partners. The National Pollution Prevention Roundtable P2 Results 2001-2003 compiled data from state, local and university P2 programs. The 2005 Draft P2 Region Results collect data from the regions. The data collected is for pollution prevented to air, water, waste, and combined. It is not clear from the survey that only hazardous pollutants, substances or contaminants are being measured. For example, energy conserved data is collected, then converted into pollution prevented by using a conversion factor for NOx, SOx and CO2. These criteria pollutants are not hazardous air pollutants or toxic chemicals as defined by the Pollution Prevention Act. The program has not provided evidence on how the data collected for air, water and waste, energy conservation and water conservation are defined to substantiate credibility. Standards for measurement have not been adopted by all key program partners. The program has also not provided evidence that the P2Rx database collection is credible. The P2Rx Survey 2004 and P2Rx 2001-2005 activity reports did not provide information on performance measures that are directly supporting the program. These reports track number of user sessions, not the adoption of source reduction techniques by businesses. The program does not currently collect credible information on performance on P2 Grants with GranTrack. Currently there is one entry for 2006 and 2007(?), however neither grant has performance measures for "pounds of hazardous material reduced". Grants reviewed for 2005 and earlier do not contain any performance measures from this PART, therefore do not provide credible performance information to improve the program. Some performance measures that are indicated are for regulatory issues (Indiana 2005 ) and it is not clear how they help to improve program performance. Program has developed performance criteria for the FY06 Grant RFP for the awards process. All 2006 awards are not recorded in GranTrack, and performance data from these awards will not be available until 2007 or 2008 depending on the length of the grant. Green electronics purchases in the EPP program does not collect performance data at all since the program is too new and the data available is forecasted using an electronics environmental benefit model. This model is under peer review and has not been finalized. H2E Evaluation indicates data collected from this program is from a very small sample and can not determine a significant statistical difference from EPA's involvement with H2E hospitals versus hospitals that have reduced toxic chemicals on their own. Program has not provided evidence how this data has affected program management. The pollution prevention program collects data and uses it to manage the program as follows: 1)GC collects data (syntheses, processes, chemical substitutions, environmental/cost benefits) each award cycle, which experts review and GC enters into a benefits database. GC outcome data identifies program gaps and informs future program targets and priorities 2)DfE regularly collects direct partner data and market data, including from trade associations. DfE survey data on implementation of best practices in pilot shops persuaded the air program to develop an area source rule based on using these best practices nationwide 7)GSN collects potential supplier results in aggregated form. Annual Manufacturing Extension Partnership Center outcome data are forthcoming. GSN is using potentials data to inform the development of guidance for answering performance surveys, the modification of agreements, and the development of targets.

Evidence: NPPR Survey 2001-2003 P2Rx 2001-2005 Activity Reports P2Rx Users Survey 2004

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: Grantees: Program did not provide any evidence of performance evaluation of grantees and how past performance ratings were utilized in future grant awards. The program only provided guidance, agreements or terms and conditions that stipulates the grantee must meet certain criteria--not evidence that their performance, schedule and cost was evaluated. Contractors. The program evaluates contract performance at periodic intervals for quality, timeliness, and cost. Contract awards and renewals consider past performance. These contracts include all program mission contracts. Federal managers for the P2 Program in the Pollution Prevention Division, the Exposure, Economics, and Technology Division, and the Regions have clearly defined or quantifiable performance standards which hold them accountable for cost, schedule, and performance results. Interagency partners. In the agreement between the GSN center for results and the National Institute for Standards and Technology (NIST), terms state that NIST will measure the annual performance of the NIST Manufacturing Extension Partnership (MEP) Centers participating in the GSN program. Terms also state that falling below a standard of performance two years in a row would result in an MEP Center no longer participating in the GSN program. This agreement is signed as of March 22, 2006, and it is too early to have received a performance evaluation. Other partners. In the DfE Memorandum of Understanding with formulator partners, DfE may terminate the agreement for failure to live to obligations, after reasonable notice to respond. [Q]

Evidence: PARS Standards for Managers ASRC Performance Evaluation for PPIC Green Suppliers Network, Interagency Agreement with NIST

Are funds (Federal and partners') obligated in a timely manner, spent for the intended purpose and accurately reported?

Explanation: The program meets all three elements required for this question. Element 1. Program funds are obligated consistently with the program plan and only a limited amount of program funds remain unobligated prior to lapsing. OPPT augments Agency-level processes and systems with additional office- and program-level planning, financial and performance management processes and systems. The keystone to OPPT's performance-based management processes is OPPT Finance Central, an internally designed system, implemented and administered that supports key aspects of program planning, financial management and performance accountability [A, B, C, F, L]: 1) Prior to Congressional enactment, Projects Forms detailing funding requests and associated performance commitments are entered into the Finance Central. 2) Upon establishment of the Final Operating Plan, program resource targets are adjusted to reflect Agency-level decisions, with corresponding adjustments at the Project level negotiated by managers. 3) Final project-level allocations are established in Finance Central and spending against those allocations is tracked using unique project codes attached to IFMS commitments and obligations. 4) Finance Central has supported OPPT in achieving record-setting obligation rates for allocated funds, approaching the 100% level in each of the past four fiscal years. OPPT's use of Finance played a key role in EPA's successful efforts to secure a Green rating on the President's Management Agenda for Financial Management. [M] Element 2. The program and its partners establish schedules for obligations that properly correspond with the needs of the program. Headquarters funds allocated through the OPPT Program Plan process are associated with specific milestones and schedules for use of funds and completion of key activities. [A] Obligation of program grant funds to states and tribes through the regional offices are scheduled to meet the needs of the program partners they support, ensuring that funds reach intended recipients in time to meet planned needs. Element 3. Adequate procedures exist for reporting actual expenses, comparing them against intended use, and taking timely action to correct problems. As Finance Central is refreshed, reports at the project and organizational levels inform management on exceptions from established financial management requirements, including spending beyond allocated resource levels, significant delays between commitment vs. obligation, incomplete obligations of committed funds and use of funds for unintended purposes. Attention to needed corrections are tracked by checking for responses to these communications and by checking for recurrence of items in subsequent weekly updates. [C, D, E, G, H] Element 4. Monthly reports addressing HQ and regional funds are provided to the Office Director for identifying potential spending deficits. [C, D, E] Quarterly meetings are also held between the OPPT central financial management staff and individual program managers to assess financial management performance at a detailed project level and regional funds. [F, G, H, I, J, K]

Evidence: See P2 PART Evidence Index and Evidence Document Files hand delivered to OMB and EPA reviewers on April 14, 2006.

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The program has regular procedures in place to achieve efficiencies and cost effectiveness, and is presenting two proposed efficiency measures with baselines and targets. OPPT has been successful in a competitive A-76 review of selected functions, including aspects of the P2 Program. Element 1. Regular procedures to achieve efficiencies and cost effectiveness include the following. 1) Using competitive grant and contract sourcing following Agency guidelines. 2) Providing P2Rx data distribution centers for state technical assistance providers to use, to avoid states using P2 grant money to duplicate each other's efforts in creating P2 technical assistance resource documents, case studies, etc. 3) Making IT improvements for efficiency and cost effectiveness: (a) Creation of a green chemistry benefits database. (b) GranTrack online database searchable by recipient, project area, other key topics, which allows a study of trends in grants issued, and adjustments to funding priorities accordingly, avoiding duplication; also allows public availability of grant performance data by read-only access to certain screens. (c) Building a national network of P2 Results databases for systematized annual reporting of P2 outcomes by states, local governments, and the federal government. (d) Adoption of a CVS "continuous versioning software" server that automatically tracks updates to software shared by 8 grantees. (e) Adoption of free Bugzilla defect tracking system by P2Rx Centers to report software problems and post solutions online. (f) Adoption of RSS "really simple syndication" by P2Rx Centers for sharing news stories (RSS being quickly adopted by major news organizations). (g) Software for direct user update of directory information, saving P2Rx staff time. (h) Modification of NIST MEP customer relationship management database to centralize GSN and MEP operations into one business unit. 4) Inter-agency (federal-state) coordination on IT issues. (See (b) and (c) above). 5) Inter-agency (federal-state) coordination on data definitions to support uniform data submissions. 6) Use of a web site to provide the majority of technical support. 7) Use of a list serve as a peer-to-peer technical support forum with 1,000 partner and champion subscribers, requiring minimal program staff support. Element 2. The two proposed efficiency measures with baselines and targets are as follows. The program's proposed annual efficiency measure is outcome-based, for the DfE Formulator Recognition project. It is expressed as the annual total amount of hazardous chemicals reduced by all partners, divided by program resources. The baseline year was 2004, when the efficiency (or cost-effectiveness) was 30 pounds of reductions per program dollar spent. In 2005, the efficiency was 50 pounds of reductions achieved per program dollar spent. The target for 2006 is 73 pounds of reductions per program dollar spent.

Evidence: See P2 PART Evidence Index and Evidence Document Files hand delivered to OMB and EPA reviewers on April 14, 2006.

Does the program collaborate and coordinate effectively with related programs?

Explanation: The program collaborates and coordinates effectively with related federal, state, local, and private programs. Regional P2 coordinators use their institutional knowledge to connect P2 projects and related regional activities. (e.g., Regions submit sample supplemental environmental projects (using P2) for the enforcement office to use when negotiating settlements.) The coordinators also coordinate regularly with state/local P2 programs. By participating in state P2 roundtable meetings, P2 coordinators helped state grantees make a transition from reporting grant outputs to reporting grant outcomes in one year. [I, q] The P2 program co-sponsors a national summit with the Office of Compliance and the National Center for Environmental Innovation to promote innovative P2 activities. A survey sent to Summit participants indicates that 39 % of responders plan to refine or improve the design of an existing program within their organization as a result of the Summit. [C] Most P2Rx Centers co-locate with other programs (e.g., small business development center, agricultural extension service, a university) resulting in shared expertise, technologies, and outreach strategies for sub-populations of intended beneficiaries. [E, F, G, H, g, h] P2Rx Centers thus reach intended beneficiaries more effectively and efficiently. P2Rx Centers worked with the National P2 Roundtable on the National P2 Results Task Force to develop a data dictionary for all P2 technical assistance providers to use to enhance consistency in reporting P2 results. [J] P2Rx Centers collaborated with Colorado on a proposal for a National Environmental Information Exchange Network grant. Upon award, Colorado sub-granted $500,000 to P2Rx Centers to build an IT database for state and national P2 programs to use in reporting annual P2 results. [K] Green Chemistry collaborates with the American Chemical Society, the National Science Foundation, and others to convene independent panels of experts to judge nominated winning technologies and recommend awardees. DfE collaborates with other agency programs and other governmental agencies to promote efficiency. [S] Under the guidance of the Office Directors' Multimedia and Pollution Prevention Forum, and with the input of the Forum on State and Tribal Toxics Action, DfE is working with the air program to make DfE Auto Refinishing Best Practices "common-sense" regulatory requirements in an area source regulation. [L, o, p, r, s, t] DfE works with Formulator Recognition partners (who make and use safer detergents) to enhance compliance with an action taken by the Office of Water. [i, M] DfE collaborates with the Department of Defense and the Environmental Council of States on a P2 strategy. [N] EPP coordinates with other green purchasing programs such as EnergyStar, the Office of Solid Waste (on Comprehensive Procurement Guidelines), and USDA's Biobased Products Program, resulting in EPP products (Federal Green Construction Guide for Specifiers; Electronic Products Environmental Assessment Tool) -- that combine elements of these programs. [j, k, l] H2E collaborated with the Office of Compliance Assistance to create a combined website (both offices co-funding the development of the site; one staff member managing both grants). The site combines compliance assistance and P2 data to help hospitals reduce their environmental impact. The public can access the website through either program's portal. [m, n] This is the first time this has been done for a compliance assistance center. GSN collaborates with Performance Track (PT), so that PT facilities are eligible to participate in GSN reviews to identify commitments for the PT program. Companies applying for the corporate leader's designation can join GSN and use their work to satisfy the supply chain requirement. [c]

Evidence: See P2 PART Evidence Index and Evidence Document Files hand delivered to OMB and EPA reviewers on April 14, 2006.

Does the program use strong financial management practices?

Explanation: The program is not the subject of any material internal control weaknesses reported in the FY 2005 EPA Inspector General's annual FMFIA report. 1) The program follows EPA financial management guidelines for committing, obligating, reprogramming and reconciling appropriated funds. OPPT process and systems ensure that payments of program funds are made properly for the intended purposes. 2) EPA's financial management systems meet statutory requirements and agency officials have a system of controls and accountability, based on GAO, Treasury and OMB guidance as well as generally accepted accounting principles (GAAP), to ensure that improper payments are not made. At each step in the process, the propriety of the payment is reviewed. EPA trains individuals to ensure that they understand their roles and responsibilities for invoice review and for carrying out the financial aspects of program objectives. 3) In FY 2004, the deadline for submitting annual financial information was accelerated from five months after the end of the fiscal year to 45 days. EPA not only met this new deadline, but also met accelerated deadlines for submission of quarterly financial statements. 4) OPPT developed and uses Finance Central to provide even greater financial management oversight, providing state-of-of-the-art project- and program-level financial reports, issue identification and resolution, and program/project planning capabilities. 5) EPA received an unqualified audit opinion on its FY 2005 financial statements. The audit found no Agency level material weaknesses and no substantial noncompliance. 6) EPA performs audits of the Agency contract and grants offices (or program offices) to ensure that proper financial procedures are followed in contracts/grants. [F]

Evidence: EPA OIG Audit Report Fiscal Years 2004 and 2005

Has the program taken meaningful steps to address its management deficiencies?

Explanation: No material weaknesses were identified in the agency-level and program-level review process. The program has a system for identifying and correcting program management deficiencies and uses it to make corrections within agreed time frames. The systematic approach for identifying and correcting program management deficiencies includes the following elements. 1) Annual review to address FMFIA material weaknesses. 2) Semi-annual, office-level planning sessions. 3) Annual program-wide priority-setting (at macro level every third year in tandem with the Agency strategic planning process, and at micro level during years in between). [A] 4) Headquarters review of regional activities through on-site visits and reviews to discuss budgeting, performance measurement and regional priorities. [B] 5) Regional review of state activities at State Roundtables to coordinate on issues. [E] 6) Review of the grant process for continual improvement. 7) Review of performance measurement for continual improvement. 8) A Human Capital Strategy and Action Plan. The plan has goals, strategies, and actions supported by measures and time frames for (a) retaining and attracting a diverse and skilled workforce to meet critical needs; ensuring growth, (b) developing the vitality of the workforce; and, (c) promoting effective management approaches. 9) Review of IT for continual improvement. 10) A Performance Appraisal Management System (PARS) for all managers and employees that link job performance standards to Agency strategic goals and objectives. Examples of corrective actions taken include the following. 1) Clarifying one of three focal areas of the program (spring 2006). [A] 2) Clarifying program priorities for grant purposes (fall 2004). 3) Communicating to states at State Roundtables about impending changes in grants (criteria for outcome performance measurement, public availability of all grant performance results, available guidance on sources of measurement data, development of IT system for data entry) (ongoing). [E] 4) Implementing an OPPTS Regional Award Assurance Request, where regional senior managers certify that grants are awarded based on the ability to produce environmental results and alignment with EPA's Strategic Plan (spring 2006). [F] 5) Revising grant guidance to clarify that grant applications that fail to document the ability to produce outcome results will be ranked the lowest. (2005) 6) Developing measurement data guidance for regional P2 coordinators (2005-2006). 7) Redesigning GranTrack database so it tracks expected and actual outcome measures and results (2005-2006). [D] 8) Designing IT system for systematized local/state/national reporting of outcome results (2005-2006).

Evidence: See P2 PART Evidence Index and Evidence Document Files hand delivered to OMB and EPA reviewers on April 14, 2006.

Are grants awarded based on a clear competitive process that includes a qualified assessment of merit?

Explanation: Grants are issued and managed by the P2 Program in accordance with EPA's competition policy for assistance agreements.] P2 grant and SRA grant notices are posted to EPA's Pollution Prevention web site each fiscal year. A synopsis of the notices is posted to Grants.gov. Applicants have a statutory minimum number of 45 days to submit an application. The announcement is open to all eligible applicants as indicated by the Catalog of Federal Domestic Assistance number. No institution is given preference in the competitive process. The Pollution Prevention Act sets the eligibility criteria for the grants awarded under its authority. The Act states that the grants are for states (or state entities, like universities) and that federal funding must be matched dollar for dollar by the grantee. Through the competitive process each work plan is evaluated based on the same criteria that are published in the public notice requesting proposals. These criteria must include past performance, cost effectiveness, and expected environmental results, along with other criteria determined by the program manager. None of the evaluation criteria or threshold eligibility criteria is restrictive. All applicants are reviewed using the same guidelines outlined in the grant notices. There are no requirements or criteria in the notices tailored to a specific product, feature, or characteristic unique to a particular applicant that would give an unfair advantage in competition. As of 2006, Regional managers will certify to OPPTS that the P2 grants they propose to award have been appropriately competed. Grant applications for P2Rx are reviewed and approved in headquarters before the grants are awarded in the regions. Program needs to demonstrate

Evidence: www.grants.gov for P2 grant opportunities Federal Register for P2 grant Notice of Availability

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: The program has an overarching grants management oversight process for a systematic approach to grants management. The program has grants oversight guidance for grant project officers, which outlines administrative procedures for grants oversight and also provides programmatic tools for maximizing outcome performance results for grants. [G] Element 1. The program has reporting systems in place for regions and headquarters to document grantees' use of funds in eligible activity categories. [K, L] These reporting systems allow for a continuum of shared grant oversight between regions and headquarters. (a) A senior regional manager certifies to OPPTS that proposed awards are in support of and advance P2. [F] (b) The Integrated Grants Management System creates reports on grant administration, starting with the initial budget evaluation conducted by the grant project officer that will form the basis for tracking grant expenditures. [J] (c) The Integrated Financial Management System creates grant financial reports that are available on demand by the project officer, the grant officer, regions, and headquarters. [J] (d) GranTrack, a recently upgraded database managed by PPD, is a reporting system that helps project officers track P2 grant outcomes and outputs and manage their grants towards results. Project officers enter financial, administrative, and P2 analysis into GranTrack, which then offers numerous fields and customized reports for analyzing and managing grants towards results. [A, I] GranTrack also provides information needed in headquarters to answer program oversight and budget questions. [A] (e) The Agency Annual Commitment System tracks regional commitments and results generally, and can receive grant-related inputs from GranTrack. [A] Element 2. The program conducts site visits for a substantial number of grantees on a regular basis, at least 10% a year. Each region has a Post Award Monitoring Program (PAMP) with an annual strategy for all its grants and a schedule for desk reviews and site visits. [H] Element 3. The program audits grantee performance through management effectiveness reviews. [G] Element 4. The program tracks actual expenditures to verify that funds are used for their designated purpose. (a) The budget evaluation conducted by the PO for the funding recommendation forms the basis for tracking actual expenditures. (b) Grant officers and project officers look in IFMS for an accounting of payments to grantees as work progresses, review Financial Status Reports, and conduct site reviews and audits. [J] (c) OPPT headquarters tracks actual expenditures through custom monthly financial status reports generated from IFMS for the Office Director's review of the status of regional and headquarters grant funds. [J] (d) OPPT headquarters uses GranTrack reports to respond to GAO and upper management requests. [A]

Evidence: See P2 PART Evidence Index and Evidence Document Files hand delivered to OMB and EPA reviewers on April 14, 2006.

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: The program has not provided grant performance information that is directly related to the program. Existing grant information in GranTrack does not demonstrate the performance of individual grants in meeting the performance measures of the P2 program. GranTrack is expected to be enhanced to include giving the public direct access to GranTrack reports on annual grantee performance data. The public will gain access to GranTrack through the P2 Program web site. Public access to GranTrack is anticipated to occur early this summer (2006). In these GranTrack reports, annual grantee performance data will be both aggregated on the program level and dis-aggregated at the grantee level. The program has collected program-wide activity information for P2Rx. Semi-annual activity reports from the grantees are posted on a public web site, but the lastest report is from 2004. The P2Rx website also provides summaries of activites such as meetings and conferences, case studies, best practices, technology innovations which is available to the public. However, there is no information on the specific performance of grantees.

Evidence:

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: The program has demonstrated substantial progress in achieving its long-term performance goals. The program is on track to meet its goal of reducing 7.3 billion pounds of hazardous materials by 2011. 2 billion of those pounds have been achieved through 2005. On the surface, the associated annual average results (400 million pounds per year in 2001 - 2005) appears to be inadequate to achieve the 2011 target. But additional results centers commence contributing results in 2006, which will increase the pace of progress towards the ambitious 2011 target. Similarly, the program believes it is on track to meet its goal of reducing 774 trillion BTUs of energy by 2011, with progress through 2005 surpassing 200 trillion BTUs. Similarly, the program is on track to meet its goal of conserving 52 billion gallons of water by 2011, with 13.7 billion gallons conserved through 2005.. Finally, the program is on track to meet its goal of saving $1.1 billion through pollution prevention steps by 2011, with $157 million of those dollars already banked through 2005. [A, E] The program has guided state and tribal grantees to make a timely and effective transition from reporting output results to reporting outcome results. The program has collaborated effectively with states on a methodology and national reporting system for state outcome results. [C]

Evidence: See P2 PART Evidence Index and Evidence Document Files hand delivered to OMB and EPA reviewers on April 14, 2006.

Does the program (including program partners) achieve its annual performance goals?

Explanation: The program has met or exceed all established targets for its annual measures for 2004 through 2005. The aggregate targets of 452 million and 608.1 million pounds in 2004 and 2005 were substantially exceeded (1.1 billion and 2.0 billion, respectively). The aggregate target of 667 billion BTUs for 2005 was similarly exceeded (200 trillion); no annual targets for BTU reductions were established for this measure in the 2003 New Chemicals PART. The aggregate 2004 and 2005 targets for water savings (440 million and 912 milllion) were exceeded (7.2 billion and 3.7 billion). Cost savings targets were significantly exceeded in 2005 ($40.7/$157 million) (no annual targets for cost reductions were established for this measure in the 2003 New Chemicals PART). In addition to meeting or exceeding the aggregate targets, the Green Chemistry program exceeded both of its New Chemical PART measure targets (pounds and gallons) in both 2004 and 2005

Evidence: See P2 PART Evidence Index and Evidence Document Files hand delivered to OMB and EPA reviewers on April 14, 2006.

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: We anticipate meeting our efficiency measures for 2006, and we can also demonstrate other improved efficiencies or cost effectiveness in achieving program goals on an annual basis. The program's first proposed annual efficiency measure is outcome-based. It is expressed as the annual total amount of hazardous chemicals reduced by all partners, divided by program resources. The baseline year was 2004, when the efficiency (or cost-effectiveness) was 30 pounds of reductions per program dollar spent. The improved efficiency in 2005 was 60.6 %, because 50 pounds of reductions were achieved per program dollar spent. Other improved efficiencies or cost effectiveness have occurred in achieving program goals on an annual basis. 1) The program successfully underwent an A-76 competition. [O, P] 2) The program at least tripled the cost-effectiveness of its 2004 grant (832-091) of $145,000 for developing a consensus-based data dictionary and prototype P2 results database. The P2Rx Center, with the prototype database, collaborated with Colorado on a 2005 grant proposal. Colorado won the competitive National Environmental Information Exchange Network 2005 grant, and sub-granted $500,000 of the $744,035 to the P2Rx Centers for building a national network of linked databases (in all eight P2Rx Centers) that will compile annual national P2 results. The grant application cited the prototype database and dictionary. Based on estimates of $60,000 per region to develop an electronic reporting system, the cost for getting a system established nation wide could have been $600,000. 3) By agreeing to buy a server with continuous versioning software (CVS) in 2003, all P2Rx Centers accepted the idea of using common programming to eliminate time spent tracking programming differences. Centers now automatically get the latest version of customized programming code without searching or calling each other. This has saved 800 hours of staff time (100 hours per center) in 2004 and 2005. 4) Eliminating the incentive for programmers in different P2Rx centers to be individually creative led to an even larger efficiency. In 2003, the centers reduced the personnel assigned to creating custom programming for specialized web-based products to one programmer, for centralized distribution to all centers. [H] Before, centers had to train and re-train graduate student programmers and work out differences in code created by different centers. This step saved 3,136 hours in 2004 (448 [hours spent on programming in one center] x 7 [centers that no longer address programming]) and 5,964 hours in 2005. [M] 5) By using a database that targets deficiencies in award nominations, the Green Chemistry Center achieved greater cost effectiveness in 2005 over 2004. It received an improved quantity and quality of award nominations in 2005 for fewer resources expended. [J]

Evidence:

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: Programs exist at the state level which have purposes and goals similar to the overall P2 Program, and several other state, private, or federal programs have purposes and goals similar to those of certain Centers for Results. The P2 Program compares favorably with these other programs, especially in its quantification of outcome results, its technical rigor, its overall productivity, and its facilitation of national networks. The EPA P2 Program overall can compare its performance with states generally, but is more specifically comparing its performance with that of California, which has the fifth largest economy in the world and a well-funded P2 program. Both promote P2 as the principle of first choice in environmental protection, and both have goals of supporting more local programs, achieving measurable results, coordinating with other environmental offices, networking, and providing technical assistance. Both have significant achievements, yet the California P2 program does not set numeric targets, and its performance is measured primarily in outputs. The EPA P2 Program compares favorably, as it establishes numeric outcome targets to which all of its centers for results contribute, has greater chemical and technical expertise, and facilitates interstate synergies in the delivery of P2 services. [C] Since the California P2 program does not have a grant component, the EPA P2 Program is comparing its grants performance to that of Michigan, Minnesota, Pennsylvania, and Massachusetts, which do. All share a similar purpose and focus on targeting various sectors to accomplish their goals. The grants performance of the EPA P2 Program compares favorably to theirs. [B, M] The EPA grant program compares favorably in the impact of its grants, its greater outputs, its use of numeric outcome targets, and its creation of regionally-based P2 Resource Exchange Centers which benefit not only its own grantees but state program grantees as well. Some of the program's Centers for Results - such as Green Chemistry and some aspects of DfE - employ mechanisms that rely on such unique technical expertise as to make performance comparisons difficult. For other Centers, there is a range of state, federal, and private programs that can serve as a basis of comparison. Some are listed below, and additional ones are cited in the evidence. [B, M] EPP Center for Results (EPEAT) - both EPEAT and Green Seal develop standards for environmentally preferable products, and promote their use by large institutional purchasers and the federal government. More widely adopted by federal agencies, EPEAT's standard for electronics is being integrated into federal IT contracts, including those for DoD/Army, DOE, DOI, and NASA. [B, M] DfE Center for Results (Alternatives Assessments) - the state legislature created a purpose and goal for Washington State Department of Ecology that is similar (on a limited scale) to DfE's - assess chemical alternatives to a chemical of concern. WA DOE chose to use DfE's hazard assessment methodology to comply with the legislative directive to assess alternatives to Decabromodiphenyl ether (decaBDE). [A] H2E - the California Mercury (Hg) Elimination Leadership Program (HELP) shares similar purpose and goals with H2E. HELP exemplifies a "Champion" participant in H2E; HELP refers its award winners to H2E for national recognition. [B, M] Of even greater note, the American Hospital Association views H2E so favorably that it recently incorporated a business subsidiary to take over the administration of H2E as a profit-making venture. [L] GSN - both GSN and Baxter Healthcare Inc. work to improve supplier efficiency and environmental performance, and have similar goals to induce adoption of P2. After Baxter's pilot efforts, it chose to join GSN instead, citing GSN's greater capacity to reach suppliers effectively than Baxter could do alone. [J]

Evidence: See P2 PART Evidence Index and Evidence Document Files hand delivered to OMB and EPA reviewers on April 14, 2006.

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: Program evaluations indicate that the program is effective and achieving results. [A, B] However, these evaluations do not uniformly meet the OMB standards for independence and scope

Evidence: See P2 PART Evidence Index and Evidence Document Files hand delivered to OMB and EPA reviewers on April 14, 2006.