Improving the Environment An Evaluation of the DOE's Environmental Management Program (1995) / Chapter Skim
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Part 3: Priority-setting, Timing, and Staging
Part 3: Priority-setting, Timing, and Staging
Pages 57-96
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From page 57... ...
Part 111 Pnonty-Setting, Timing, and Staging
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58 PART 111: PRIORITY-SE7TING, TIMING, AND STAGING SUBCOMMITTEE ON PRIORITY-SETTING, TIMING, AND STAGING EDWIN H CLARK II (Chairs, President, Clean Sites, Inc.
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The second, focusing on the issues of timing and staging, dealt with how the environmental management program can schedule technology development and remediation and restoration efforts to maximize cost savings and minimize risks to the environment, public, and workers. The two issues are closely related.
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60 PART III: PRIORITY-SETTING, TIMING, AND STAGING · Stakeholder involvement in the priority-setting process that is both timely and integrated between local and national levels. · Priority-setting that is comprehensive in scope (including intersite rankings among different geographic regions)
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In making its decisions and undertaking its actions, DOE is perforce establishing priorities. The subcommittee has gained, in the short time available, as much understanding as it could of the historical context and current practices for setting priorities in the DOE Office of Environmental Management (EM)
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With the creation of the Office for Environmental Restoration and Waste Management (later the Office of Environmental Management) came an attempt at more centralized planning; meanwhile DOE was continuing in its efforts to accommodate federal and state environment regulators who had only recently been given some jurisdiction over the sites.
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· Strong partnerships with stakeholders. The subcommittee defined its task as providing recommendations to DOE for improving its priority-setting system so that it allocates its available resources at its facilities to manage wastes, restore degraded environments, and otherwise protect the public's health and welfare in a cost-efficient and credible manner.
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At the same time it is important to note that DOE does not require a sophisticated system to identify the highest-risk cases first; we recommend that DOE continue to act immediately to identify high-risk cases. The subcommittee believes that pnority-setting, timing, and staging are comprehensive planning activities that must take place within an organized and effective management context.
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The recent Report to Congress, Risks and the Risk Debate: Searching for Common Ground (DOE, l995d) , is a step toward recognizing that funding and other constraints will preclude complete environmental restoration and preservation to everyone's satisfaction.
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Is it going to have a comprehensive technology-development program to reduce costs of waste management and environmental restoration activities? EM must establish specific goals (both short-term and long-term)
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Should EM establish regional waste repositories for ultimate disposal of certain wastes? Should EM target technology-development activities for the most-costly problems or problems with no current technical solution?
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The subcommittee recommends that He priority-setting system be established through a careful process that involves substantial opportunity for input from the full range of stakeholders. The subcommittee also recommends Mat once established, the priority-setting system be described and implemented consistently.
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with respect to DOE's use of risk assessment in its environmental remediation program.) However, public and stakeholder interest is strongly aligned with the interests of specific sites, and DOE's current mechanisms for public involvement appear to do a better job of promoting the budgetary stakes of particular sites than of facilitating intersite budgetary tradeoffs.
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Stakeholder involvement in different EM program components e.g., Community Leaders Network, the Military Toxics Project (a network of community groups concerned with environmental justice) , Transportation External Coordinating Committee, Environmental Management Advisory Board, and State and Tribal Government Working Group (STGWG)
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From page 71... ...
In the case of EM, for instance, three groupings of activities can be made as follows: · Activities that provide a measurable benefit for the Program as defined on He basis of cost, risk management or risk reduction, and schedule. · Activities that support a measurable benefit.
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DOE should aggressively explore these opportunities with the goal of reaching agreements that will result in faster and greater risk reduction, lower expenditures, and implementation plans that are more in accord with scientific and budgetary realities. RELATIONSHIP OF OTHER MANAGEMENT SYSTEMS TO PRIORITY-SETTING More must occur than the definition of mission, vision, goals, and objectives.
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IMPLEMENTATION OF A PRIORITY-SE7TING SYSTEM Activity Groupings Directly measurable benefit Overlap Required by: regulation law or agreement Supporting Activities Additional unnecessary activities Utilization of an effective prioritization should result in: Directly measurable \ benefit \ ll — / \ I between activities with directly measurable benefits ~ ~ Reduce and required activities / / ~ non/ / beneficial / / requirements \ Reduce supporting activities and infrastructure where possible Delete unnecessary activities FIGURE 1 Activity Groupings 73
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From page 74... ...
Progress in cleaning up is often in conflict with this goal and often appears to lose in the conflict. · Costs as a "good," risks as an "asset." Because the funding allocated to a site is often influenced by the magnitude of the risks at the site and the estimated cost of cleaning up its contamination, there is a strong incentive to overestimate both risks and costs to increase the amount of money available and the salaries, responsibility, attention, and employment that typically result from large budgets.
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The general perception in recent years has been that public funds for environmental restoration have not been well spent, but there are no concrete measures of progress to substantiate this perception. The number of facilities decontaminated or removed from a status where monitoring is necessary and the relative cost per square foot of building space are better measures than the number of reports filed with a regulatory agency.
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BUDGETING In the budget process the role of Headquarters is to set general policy guidance and secure funding through Congress. The sites have the specific knowledge of those activities with the highest potential for harm, those that can be delayed in implementing remedial action, and those with the best potential for risk reduction.
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"Bundling" is the process of lumping dissimilar things into packages that are then thought of as constituting a single activity. In the case of DOE's Environmental Remediation Program, bundles of proposed remedial actions might be made up of elements that if examined individually, would be seen to pose different types of risks or to require different kinds of processing from an engineering and technical standpoint.
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DOE should also establish some process for rewarding units that bundle activities properly and penalizing units that do not. The result of such an audit, however conducted, would increase the number of activities in the budgeting process in such a way that the costs associated with individual activities would, on the average, be lower in some cases, the subcommittee believes, by a considerable amount.
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Only then can the department be sure that the performance measures incorporated in the contracts accurately reflect and incorporate the goals of the department.
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A process of consolidation and redefinition would follow. The goal of this process would be to derive a manageable set of priority factors that are inclusive and clearly defined so that they are interpreted consistently by everyone involved in the EM priority-setting system, from Headquarters staff to local advisory panels and other stakeholders.
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Examples of possible primary factors related to risk are the risks that would exist were the activity not undertaken, the reduction in risk that would result from undertaking the activity, and the risk reduction per dollar of expenditure that would be associated with undertaking the activity. The subcommittee recommends that, to the extent possible, a single set of general methodological guidelines for risk assessment be applied to all sites and proposed activities.
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The subcommittee believes that using these screening-level (possibly judgmental or qualitative) risk assessments is possible.
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An earlier NRC committee report, Ranking Hazardous Waste Sites For Remedial Action (NRC, 1994b) provides a synopsis of the qualities of good tools, and reviews of three specific existing tools that could be of relevance here.
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Site-ranking considering only risk can be useful for setting priorities for site assessment but not be efficient or effective for setting priorities for cleanup activities themselves. Site-ranking tools can range from strictly qualitative check-list approaches, through such scoring systems as EPA's Hazard Ranking System (HRS)
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EPA's experience in initial applications of this approach is that it is particularly useful for identifying strategic directions without the detailed analysis required of CBA, for gaining insight into why some strategies appear to meet goals better than others, and for building consensus.
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ERPS is a detailed application of the MAU approach that is tailored explicitly to deal with the many unique features of DOE's EM organization in the process of allocating budgets among sites. Although questions have been raised on particular technical points, its main limitations are that it had poor stakeholder involvement during its development and depends excessively on judgments made by the model builders rather than reflecting widespread stakeholder consensus; it is perhaps too ambitious in attempting to incorporate all values, no matter how subjective and qualitative, into a single quantitative metric; and, as a result it failed to meet the objectives of clarity, transparency, and simplicity.
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It needs to demonstrate that decisions in all these areas, both within DOE sites and across sites, are being made consistently. Again, establishing such a system is not a simple task.
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Even when there appear to be current legal requirements, if the action is not addressing a significant risk, we recommend that the agency "push back" on the regulatory drivers. Ultimately, in this period of tight federal budgets, everyone will benefit if the agency can demonstrate that it is efficiently spending its resources on the most serious problems.
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Prepared for the US DOE Office of Environmental Restoration and Waste Management.
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The framework begins with the clear articulation of DOE's priorities for EM expenditures and, proceeding through a nine-step process, finally gives some leeway to the local stakeholders to make a final choice about the priorities which best suit them. Define Priorities: The proposed process would begin with EM, with substantial input from its various stakeholders, identifying the full list of factors that should be taken into account in setting priorities.
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From page 92... ...
The goal of this process would be to come up with a manageable set of priority factors which are inclusive and clearly defined so that they are interpreted consistently by everyone involved in the EM priority-setting system, from Headquarters staff to local advisory panels and other stakeholders. DOE might want to consider involving a national stakeholders panel in this winnowing and definition process to ensure that the criteria of inclusiveness and clarity are met.
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From page 93... ...
The ratings for the other factors would also benefit from reasonable quantification, but a qualitative indication of relative importance would suffice as well. The development of these summary sheets should begin at He local level and be fully informed by review and contributions of local advisory panels and other stakeholder input.
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The trustee representing EM's innovative technology priority might argue that a particular innovative technology activity be raised in the ranking and several clean up activities be lowered, because the innovative technology activity promises to achieve significant cost savings in these types of cleanups in the future. If such a re-ranking were agreed upon, the individuals responsible for those cleanup activities would have an incentive to ensure that the technology development activity achieved that goal.
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From page 95... ...
However, the ranking and re-ranking are carried out, albeit informed by this local information and assessment, predominately at the national level. The DOE may, if it is allowed to do so, want to provide the local level with a final opportunity to modify the ranking.
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