Sustainability and the U.S. EPA (2011)

6


Changing the Culture in EPA

EFFECTING CULTURAL CHANGE IN THE AGENCY

Implementation of sustainability efforts in EPA will be fostered if the culture of the agency changes so that sustainability is a common way of thinking for everyone in the agency. This would provide agency personnel with the opportunity to integrate sustainability into their work. Although EPA has developed significant tools and knowledge with which to implement the Sustainability Framework, further innovations and implementing transitions (long-term changes in an encompassing system that serves a basic societal function) will be necessary to meet the increasingly complex challenges it faces (Elzen and Wieczorek 2005). Therefore, EPA should foster cultural change and innovation at all levels of the organization to meet the challenges of increasingly complex problems. EPA also would benefit from the experience of other organizations and countries that are considering similar cultural changes concerning sustainability and from a growing literature on effecting this change (Kemp et al. 2007, Nill and Kemp 2009).

The agency has had several successful initiatives to manage significant internal change. The early efforts to educate staff and appointees on risk assessment and its use in decision making is one example. Others include a subsequent effort to change how risk characterization was performed as well as implementing pollution prevention activities. Similar efforts should be undertaken regarding sustainability as a first step in its wider use in the agency. Materials developed for this effort should be shared broadly outside the agency for the benefit of its stakeholders and its partners in program implementation.

To be responsive to a sustainability vision, there needs to be a broadening of disciplinary approaches toward understanding underlying processes. Tools that are pertinent to making sustainability decisions need to be developed. Indicator

sets and appropriate metrics need to be made available to program and regional offices that assess programs; that project progress toward sustainability; and that permit the public and decision makers to address sustainability issues efficiently and effectively (Box 6-1). Specifically, EPA must recognize the challenges of the long-term impacts of environmental management decisions made in the near-term time frame.

Creating a Culture of Sustainability

Incorporating sustainability into EPA’s mode of operation will require a shift toward a more systems-based approach that integrates multiple media, with multiple objectives in social, environmental, and economic pillars and considers both short-term and long-term consequences. Changing thinking within the organization is a large task with responsibilities throughout the agency. It requires a clear statement of principle about the importance of sustainability for the agency from

the top. It also requires bottom-up incorporation of sustainability into everyday operation for regions and programs. In addition to changes in thinking, incorporating sustainability into EPA operations will require integrating and extending existing approaches and, in some cases, developing new approaches. The agency can accelerate its cultural change by practicing sustainability in its day-to-day operations.

Including progress in programs and projects that incorporate the sustainability approach in individual performance reviews will further accelerate the cultural change, as will hiring and training staff with expertise in sustainability issues (McKenzie-Mohr and Smith 1999). Communicating the basic elements of sustainability is an important step in achieving the cultural change within the agency. EPA would benefit from undertaking an employee communication and education program to effect the cultural change necessary to support the adoption of the Sustainability Framework and to enable employees at all levels to participate in its implementation.

EPA would also benefit from hiring multidisciplinary professionals who are proficient in many disciplines. The Science Advisory Board (SAB) in 2010 recommended that EPA increase its investment in social, behavioral, and decision sciences across the Office of Research and Development (ORD) research portfolio to help EPA develop and implement workable solutions to major environmental challenges (EPASAB 2010). EPA would also benefit from the inclusion of multiple fields, such as integrated transport and landscape architecture and ecosystem services, that relate to managing landscapes in an ecologic way and for conservation purposes (Lindenmayer et al. 2008). At first, the strategy may be to hire from outside sectors leaders to aid EPA in shifting to a more cross-cutting mind-set (NRC 2010). The ORD has focused on six broad research themes in their approach to achieving sustainability (EPA 2007), and EPA could further collaboration among existing professional expertise to encourage dialogue and understanding of the various fields and work already within EPA.

In addition to being used by staff at all levels, the Sustainability Framework could also be incorporated into all agency advisory committees’ considerations and recommendations. An internal advisory group focused on sustainability during the initial phases of effecting cultural change and adopting the Sustainability Framework could be useful to the agency. This group could be part of the already functioning communication between the 10 regional administrators. They have on-the-ground knowledge of, and in many cases, connections to local leaders, who may be able to understand and advise on sustainability initiatives that could have the greatest impacts if leveraged and supported by the agency.

The Committee on Incorporating Sustainability in the U.S. EPA recognizes that further reorganization within EPA may be the consequence of the further pursuit of sustainability. However, the incorporation of a culture of sustainability within the operations of the agency is essential, and managing this change should take precedence over organizational change.

A final and important point to make about instigating cultural change within the agency deals with putting money where the focus is. To change the direction of an organization, its budgets must reflect that change, and, to that end, modifying budget proposals to reflect the sustainability objectives at the regional and program levels might help. It might also be helpful to make room within the agency’s budget for national and regional work to test and implement sustainability initiatives. Ensuring that available federal funding more expressly addresses sustainability’s social, environmental, and economic objectives is likely to produce greater benefits for each dollar expended. The committee recognizes that, during tight budget times, obtaining new funding will be difficult and will require creative and continual evaluation of existing funding initiatives on a program-by-program basis. Funding partnership opportunities sought out at every juncture will help to ensure continuity, as leveraging funding successfully benefits a variety of stakeholders. A 2009 NRC workshop report on enhancing the effectiveness of sustainability partnerships (NRC 2009) provides guidance on this issue.

RESEARCH AND DEVELOPMENT

Given the overall mission of EPA’s ORD,¹ it can play a lead role in the development of specific tools (Chapter 4) that are useful for implementing the Sustainability Framework (Chapter 3). Additionally, ORD can identify relevant research needs to address many of the unresolved challenges. Many of the issues discussed in this report highlight the need to develop scientific and analytic tools to support this framework. The committee provides here suggestions on conceptual approaches that could form the bases for establishing research and development (R&D) priorities and incorporating sustainability concepts into this decision process.

Incorporating sustainability into EPA operations does not require fundamentally new approaches; in many instances, simply modifying or expanding on the application of existing tools so that they are more integrative and intergenerational will be sufficient. On the other hand, attention to some issues raised by the Sustainability Framework will depend upon R&D support. Recognition of the need for EPA’s science to be responsive to the increasing complexity of EPA’s challenges has been voiced in many external and internal reviews (Powell 1999). Despite this recognition and the improved understanding and development of tools that fit well under a sustainability paradigm, EPA must go further to recognize sustainability specifically as a key driver for its research program.

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¹ The mission of the ORD is to “perform research and development to identify, understand, and solve current and future environmental problems; provide responsive technical support to EPA’s mission; integrate the work of ORD’s scientific partners (other agencies, nations, private sector organizations, and academia); and provide leadership in addressing emerging environmental issues and in advancing the science and technology of risk assessment and risk management” (EPA 2010a).

That the environmental science community has come a long way but needs to go further is exemplified by the reports of two companion NRC committees, which were funded by Congress and EPA to explore the role and the future direction of EPA’s science and technology (NRC 1997, 2000a). These companion documents emphasized the importance of ORD in performing the long-term core research necessary to achieve EPA’s mission. As noted in the latter report,

The research activities considered in these two documents fit primarily within the goal of decreasing pollution rather than maximizing overall social, environmental, and economic benefits. The 1997 committee’s formulation of four components of environmental research—understanding underlying processes, developing tools, acquiring data, and communicating results—remains central to the R&D necessary to achieve EPA’s sustainability goals. The above paragraph is one of the few instances in either NRC report that sustainable development or sustainability is mentioned.

The ORD has already taken a number of steps along this path. Hecht (2009) noted that EPA launched its Sustainability Research Strategy “with the dual goals of advancing an understanding of biological, physical, and chemical interactions through a systems and life-cycle approach, and developing effective models, tools and metrics that enable decision makers to achieve sustainable outcomes.” In this strategy, ORD laid out a strategy for sustainability research at EPA that included important elements:

The committee did not have the time or detailed information necessary to develop specific recommendations on changes or additions to the current R&D programs within the ORD. The committee notes, however, the six major research themes that the ORD identified emphasize an integrated and systems-based approach to achieve sustainability (EPA 2007):

• Renewable Resource Systems: determining how best to obtain the benefits that renewable resources provide, while considering the system-wide effects their use has on the regenerative capacity of the entire system
• Non-Renewable Resource Systems: promoting sustainable management of non-renewable resource operations and supporting the shift to renewable resources
• Long-Term Chemical and Biological Impacts: assessing and eliminating the long-term impacts posed by harmful chemical and biological materials in order to improve our use of materials, shift to environmentally preferable materials, and protect human health. Developing alternate chemicals, new industrial processes, and new decision support tools for evaluating environmental dimensions of new chemicals and processes
• Human-Built Systems and Land Use: researching sustainable building design and efficiency, management of urban systems, life cycle assessment for building design and land use, and decision support tools for urban land development and revitalization
• Economics and Human Behavior: developing ecosystem valuation methods and analyzing the role of incentives in decision making and the causes of market failures
• Information and Decision Making: identifying appropriate indicators and ensuring their quality

If sustainability is to become the “true North” or main vision for ORD, clearly the R&D programs and projects would need to reflect this new vision. In this context, there are key themes for ORD to consider in achieving alignment of R&D activities within the Sustainability Framework. Topical areas for ORD to consider in modification of current research priorities and in establishing future ones include the following:

• Create a suite of decision-support tools for long-term impact analysis and simple decision tools for use by communities.

• Set research priorities using strategic objectives related in part to sustainability.
• Develop system models capable of providing projections and develop alternative projections for present and future outcomes for key types of issues.
• Develop robust methods that can readily incorporate uncertainty, variability, vulnerability, and resilience.

In July 2010, the SAB commented on the ORD’s strategic research directions, identifying several priority issues, including the importance of a systems approach and integrated transdisciplinary research (ITR), the importance of incorporating social and behavioral sciences into ORD’s research programs, and the need for the agency to provide leadership in establishing multiagency partnership for leveraging of resources (Swackhamer 2010). In response, Lisa Jackson, the EPA administrator, agreed with each of the SAB’s points. Regarding ITR, Ms. Jackson stated that the agency believes that “ITR can potentially be a driving force in the EPA’s pursuit of sustainable environmental solutions” and reiterated the agency’s focus on effectively implementing ITR through research partnerships and in adopting a systems approach to research planning (Jackson 2010).

Incorporating Sustainability Through Place- and Programmatic-Based Opportunities for Collaboration

Incorporating sustainability requires a systematic, programmatic approach: Adopt a framework, retrain and educate employees, alter fiscal priorities to reflect the framework, and evaluate on-the-ground initiatives for effectiveness. Place-based projects, or projects that are based in a specific locale with measurable outcomes, whether in collaboration with others or under the sole auspices of EPA, are a logical step in creating the culture change within the agency, as recommended by the Sustainability Framework. Planning and executing successful place-based projects will assist the agency’s programmatic approach to cultural change. An early pilot effort in the use of sustainability in a well-defined programmatic area will help facilitate change in EPA’s headquarters. Successfully incorporating sustainability into any organization requires commitment from both the top down and the bottom up as both a directive and an owned initiative. Therefore, EPA should consider a set of place-based and programmatic-based pilots to develop the cultural change necessary for the successful adoption of the Sustainability Framework; however, place-based projects have the advantage that they are more often collaborations both within and outside EPA.

During committee discussions with agency stakeholders, a number of examples of the incorporation of sustainability in carrying out place-based and programmatic-based projects were given. Examples include the following:

• Boston’s Fairmont Rail Corridor was redeveloped (Box 6-2).
• The city of New York invested in protecting and restoring its watershed to meet EPA’s requirement to filter drinking water from surface-water sources to protect the public from waterborne diseases (Box 6-3).
• The University of Minnesota Water Resources Center was tasked by the state legislature to develop a framework that addresses aspects of water sustainability in that state. These include drinking water, stormwater, agricultural and industrial water use, surface and groundwater interactions, infrastructure water needs, and water use within the context of predicted changes in climate, demographics, and land use. The resulting framework identified the 10 priority issues that present the challenges and the solutions to address those challenges. Each of these priority

issues falls within the three areas that define sustainability: social, environmental, and economic (UMN-WRC 2011).

Pursuing sustainability-related projects where collaboration is fostered with regions, states, communities, nongovernmental organizations, businesses, tribes, and internationally allows the partners to learn from each other and promote the dissemination of best practices. Experiences from these collaborations and place- and programmatic-based efforts will provide engineers and social, physical, and biologic scientists with new challenges for developing tools, indicators, and more fundamental research. For example, EPA has demonstrated that it can support sustainable land-use activities at the state and local level without being overly prescriptive (Box 6-4). Under the committee’s framework, EPA could consider how best to work with state and local health departments to complement and reinforce their land-use guidance.

A continued special effort to collaborate with other federal agencies who share responsibility at the federal level for sustainability is called for. Collaborations such as the Federal partnership for sustainable communities between the U.S. Department of Transportation, the U.S. Department of Housing and Urban Development, and EPA promise similar advances at the federal level that are

being realized in other collaborations. It is important for EPA to make a conscious effort to identify stakeholders for individual initiatives and plan strategically during each budget year to fund efforts and to incorporate the outcomes of those efforts to agency performance measures. Exploring fiscal and technical partnerships with other federal agencies and at the regional and local levels in all sectors will increase sustainable leveraging potential (see Box 6-5 for an example of agency collaboration to promote more sustainable approaches to roof design). Sustainability cannot be achieved at a national level through EPA’s efforts alone, so placing emphasis on making decisions and funding efforts in conjunction with other agencies and partners, especially at the federal level, is key. Empowering interagency and regional collaborations will foster accelerated progress and successes in achieving sustainability objectives and will support other agencies’ efforts to adopt sustainability in their activities.

Promoting partnerships when developing approaches to public problems will ensure that EPA is both a voice at the table and a driver for full and careful considerations of decisions that have an impact on the environment (subsidy and development of alternative fuels, e.g.). It is also important to promote a diverse mix of governmental partners and stakeholders at the local, regional, and national levels in community and place-based decision making, which will allow the

agency to maximize every opportunity to collaborate with and leverage resources from all sectors to promote a cultural change that will support sustainability as a mind-set.

External Cultural Change

Sustainability can be promoted by EPA in its public information and education programs through technical assistance, incentives, and regulatory programs to local governments and other stakeholders. A national education campaign to clarify what sustainability is and how it changes the way the nation operates would be a beneficial starting point. The campaign could be rolled out to address the widest possible audience so that Americans could understand the importance of considering the environment, the economy, and society in all decisions. Making sustainability information accessible and available to the public needs to be a priority (Bruch et al. 2009).

There is also a very real need for education and sharing of national and international best-management practices for sustainability, especially at a local level. This sharing of practices can be done by posting examples online, and through stakeholder webinars, workshops, and field collaboration. It is especially necessary to engage in this type of community education when new permits are

introduced. Not only do local department heads need this training and information, but local designers and contractors do as well so that the design process can be informed and collaborative in nature, resulting in the reduction of perceived risk that is typically incorporated into project design and construction fees when there is discomfort with the concepts.

Technical assistance should be available to stakeholders. Nationally, EPA would become more available and interactive with the public. The flow of question and answer will benefit both the agency in knowing what needs funding or support and the stakeholder, who to date does not have a comprehensive source of knowledge available to them about the overarching concepts of sustainability. This type of dialogue will also help EPA to evaluate how it can change to aid a sustainable culture change on a broader level.

EPA could also contribute to an effort in conjunction with public and private stakeholders to develop, post, and maintain a Wikipedia analogue for sustainability practices, laws, and policies at the local, state, national, and even international level. The purpose of this web-based program would be to provide up-to-date and high-quality information about what practices and processes work most effectively for sustainability.

In addition to public education and information, incentives could be created for sustainable behavior and disincentives for unsustainable behavior. Some of the best positive motivators include incentives that involve fiscal contributions from the agency to drive behavior change and public recognition of innovative achievements. Nonfinancial incentives may be the best pursuit in times of economic difficulties for the agency. Continuing sustainable best-practice and innovation awards that are high profile and well publicized is a positive way to reinforce the good work already in progress in communities and to establish healthy competition for recognition, which can grow local economies through marketing and public perception. These awards are strictly honorific in nature but can be highly publicized on a national level. For example, EPA is already providing this type of recognition in its green chemistry and brownfield programs.

Another consideration for the agency is an adoption of a “green star program,” which would be an offshoot of the green products for businesses but be geared toward the civilian consumers (see Box 6-6). A program of this type would include reporting to the consumer a broader range of product impacts, much like Wal-Mart’s new carbon footprint index. Programs such as Energy Star are great examples of EPA’s current collaboration with other government agencies and active interaction with stakeholders at all levels.

Consideration should be given to evaluation of fast tracking and slow tracking sustainability-related regulations. An example is issuing new stormwater permits in a timely manner and offering technical assistance to assure a community that new initiatives, such as bioswales and permeable pavement, will be counted as credits toward meeting targets. Without this time and technical investment from EPA to help communities trust new ways of managing runoff, there is a tendency

to discount new methods as too expensive and risky and a tendency to duplicate infrastructure (e.g., installing a full stormwater system under a swale system).

Finally, it is useful for EPA to examine the extent to which its governing laws provide opportunities or obstacles to achieving sustainability. A prominent example of the removal or lowering of a barrier involves the landowner liability provisions of the 1980 CERCLA (Superfund) statute. Originally established to impose liability on persons who used or allowed their land to be used for improper management of hazardous substances, the landowner liability provision of CERCLA became an obstacle to the sale and redevelopment of these properties. State and federal programs now provide mechanisms to assist both the remediation and the redevelopment of these properties. These programs foster more sustainable development in urban areas, where many of the contaminated sites exist and where there is already infrastructure (e.g., roads, sewer, and water service) and a close-by workforce to support development, rather than in “greenfields,” where there is no existing infrastructure and the available workforce may live some distance away (Eisen 2002, 2009). The agency would benefit from identifying any other legal barriers to sustainability and remove or help to remove them to promote sustainability.

FINDINGS AND RECOMMENDATIONS

6.1. Key Finding: Integrating sustainability into the agency’s work and culture will be most effective when based on clear principles, vision, strategic goals, and implementation processes (p.43-45).

6.1. Key Recommendation: EPA should institute a focused program of change management to achieve the goal of incorporating sustainability into all agency thinking to optimize the social, environmental, and economic benefits of its decisions, and create a new culture among all EPA employees.

6.2. Finding: Although EPA has developed tools and significant knowledge to implement the Sustainability Framework, further innovations will be necessary to meet the increasingly complex challenges it faces (p.59-65).

6.2. Recommendation: The committee recommends EPA foster innovation at all levels of the organization to meet the challenges of increasingly complex problems.

6.3. Finding: The agency can accelerate its cultural change by practicing sustainability in its day-to-day operations (p.94-95).

6.3.1. Recommendation: Consistent with Executive Order 13514, EPA should implement an internal program to identify key sustainability indicators and associated metrics and implement a tracking and reporting system to demonstrate progress toward the goals of more sustainable operational practices and benchmark performance against other federal or government agencies and private-sector organizations (e.g., nongovernmental organizations [NGOs]).

6.3.2. Recommendation: The agency should at the regional and headquarters level regularly produce a sustainability report on its operations by using widely recognized metrics (such as those of the Global Reporting Initiative).

6.4. Finding: Communicating the basic elements of sustainability to EPA staff is an important step in achieving the cultural change (p.94-95).

6.4. Recommendation: The committee recommends EPA undertake an employee communication and education program to produce the cultural change necessary to support the adoption of the Sustainability Framework and to enable employees at all levels to participate in its implementation.

6.5. Finding: Early pilot efforts in the use of sustainability in a well-defined geographic area will facilitate change in EPA’s headquarters (p.97-101).

6.5. Recommendation: EPA should consider a set of place-based and programmatic-based pilots to develop expertise, encourage the cultural change necessary, and demonstrate value for the successful adoption of the Sustainability Framework.

6.6. Finding: The committee supports the refocusing of EPA’s ORD as part of the agency’s turn toward sustainability. The committee recognizes that further reorganization may be the consequence of the further pursuit of sustainability but that reorganization at the federal level is a process that requires careful consideration (p.96-97).

6.6. Recommendation: The incorporation of a culture of sustainability within the operations of the agency is essential. Managing this cultural change should take precedence over organizational change.

6.7. Finding: To change the direction of an organization, its budgets must reflect that change (p.96).

6.7. Recommendation: The agency’s plans and budgets should make room for national and regional work to test for and implement sustainability initiatives.

6.8. Finding: EPA needs to remove barriers to the promotion of sustainability. EPA leadership has long recognized that its organizational structure built around the regulation of specific laws has led to stove-piping and other obstacles to maximizing the benefits of effective and efficient integration of agency actions (p.95).

6.8.1. Recommendation: EPA should examine the extent to which its governing laws provide opportunities or obstacles to the achievement of sustainability.

6.8.2. Recommendation: To accomplish sustainability, greater emphasis in the R&D planning and budgeting process needs to be placed on long-term and multimedia activities.

6.9. Finding: EPA needs to utilize partnerships to incorporate sustainability at all levels (p.92).

6.9.1. Recommendation: The committee recommends EPA maximize opportunities to collaborate with other federal agencies, state and local governments, NGOs, and the private sectors by promoting partnerships that ensure EPA is both a voice at the table and a driver for full and careful consideration of sustainability issues in major national initiatives. EPA should also ensure that an optimal mix of local, regional, and federal agencies are at the table in community and other place- and programmatic-based decision making and ensure that other stakeholders, including NGOs and business groups, are involved.

6.9.2. Recommendation: EPA should, in partnership with appropriate stakeholders, incorporate sustainability in its public education campaigns and encourage other agencies and organizations to adopt a sustainability approach.

6.9.3. Recommendation: EPA should continue to work with other federal agencies to address and implement sustainability research.

6.10. Key Finding: Incorporating sustainability into EPA’s mode of operation will require a shift in thinking toward a more systems-based approach that integrates multiple media with multiple objectives in social (including health), environmental, and economic pillars and that considers both short-term and long-term consequences. To accomplish that, EPA will need expertise across many disciplines in implementing a sustainability framework (p.95).

6.10. Key Recommendation: The committee recommends that EPA hire multidisciplinary professionals who are proficient in many disciplines, have experience in the development and implementation in the sustainability assessment tools described, and have a working knowledge in all three pillars and their application to environmental issues. The agency should hire leaders and scientists including from outside sectors to aid the agency in shifting to a more cross-cutting mind-set. Although EPA has existing staff in all the main areas of sustainability-related fields, the agency should further facilitate collaboration among existing professional expertise to encourage dialogue and understanding of the various fields and work already being done within EPA.

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