Environmental Protection: Status of GAO Recommendations Made to EPA since Fiscal Year 2007

EPA's mission is to protect human health and the environment. To accomplish this mission, EPA develops and enforces environmental regulations; awards grants; and studies environmental issues, among other things. GAO has conducted reviews focused on various aspects of EPA's operations and programs. Through this work, GAO has made numerous recommendations to improve EPA's performance and the efficiency and effectiveness of its operations.

GAO follows up with executive branch agencies to determine the extent to which they have implemented its recommendations. In fiscal year 2015, GAO began sending letters annually to the heads of key executive branch agencies, including EPA, identifying unimplemented recommendations that warrant priority attention.

This statement discusses (1) the status of EPA's implementation of GAO recommendations made since fiscal year 2007 and how these recommendations relate to EPA's operations and programs and (2) examples of benefits realized by EPA and others based on GAO's work, including through the agency's implementation of these recommendations. This statement is based on GAO's work since fiscal year 2007 and on an analysis of recommendations GAO has made to EPA during this period.

As of August 23, 2017, the U.S. Environmental Protection Agency (EPA) had implemented 191 of the 318 recommendations GAO made since fiscal year 2007. EPA had not yet implemented the remaining 127 recommendations. The figure below shows the status of the 318 recommendations. The recommendations fall into six broad categories that relate to EPA programs and operations: (1) management and operations; (2) water issues; (3) environmental contamination and cleanup; (4) toxics, chemical safety, and pesticides; (5) public health and environmental justice; and (6) air quality, climate change, and energy efficiency. Almost three-fourths of the recommendations fall into the first three categories and include actions for EPA to better manage grants, improve the regulation of drinking water contaminants, and better manage hazardous waste cleanup. Most of the recommendations that have not yet been implemented concern EPA management and operations and water issues. For example, regarding management and operations, EPA has not yet implemented GAO's recommendation to link its workforce plan with its strategic plan to help ensure EPA has an appropriately skilled workforce to achieve its mission. Similarly, for water issues, EPA has not fully implemented GAO's recommendation to provide guidance to regional offices on overseeing state water quality programs.

GAO has identified many benefits—that is, process and programmatic improvements and financial benefits—based on EPA taking actions on GAO's recommendations and related work. For example, in October 2012, GAO recommended that EPA and the U.S. Department of Agriculture (USDA) develop guidelines to assist states in developing uniform environmental analyses to meet state and federal requirements for water and wastewater infrastructure projects. EPA and USDA issued a joint memorandum in February 2017 that, among other things, highlighted best practices to eliminate duplicative environmental reviews. In addition, GAO has identified financial benefits from the implementation of its recommendations and related work. For example, during the course of work related to a July 2008 report, GAO identified an error in EPA's calculation of recoverable indirect costs for hazardous waste cleanup. EPA acknowledged the error and published revised indirect costs rates. As a result, GAO estimated in 2010 that EPA had recovered or would recover $42.2 million.

Thank you for the opportunity to testify on the status of recommendations  GAO has made to the U.S. Environmental Protection Agency (EPA). As  you know, the mission of EPA is to protect human health and the  environment, with the purpose of protecting all Americans from significant  risks to human health and the environment where they live, learn, and  work, among other things. To accomplish this mission, EPA develops and  enforces environmental regulations; awards grants to state environmental  programs, non-profits, educational institutions, and others; studies  environmental issues; and sponsors partnerships, among other things.  We have conducted reviews focused on various aspects of EPA’s  operations and programs. For example, we have conducted reviews  focused on aspects of EPA’s operations, such as managing grants,  workforce planning, and processes for developing and enforcing  regulations. We have also conducted reviews on EPA’s programs to  manage toxic chemicals, improve water infrastructure, and clean up  hazardous waste sites. Through these reviews, we have made numerous  recommendations to improve EPA’s performance and the efficiency and  effectiveness of its operations and programs. Today I will discuss (1) the  status of EPA’s implementation of recommendations we have made since  fiscal year 2007 and how these recommendations relate to EPA’s  operations and programs and (2) examples of benefits realized by EPA  and others based on our work, including through the agency’s  implementation of our recommendations.

This statement is based on our reports issued since fiscal year 2007,  including reports issued from October 1, 2006, through May 31, 2017. To  determine the number and status of recommendations we made to EPA  during this period, we reviewed data from our internal database that  maintains information on the status of recommendations we have made  to all agencies. To determine how these recommendations relate to EPA  operations and programs, we developed categories based on areas of  EPA’s work and its organizational structure. Two analysts then  independently categorized each of the recommendations and resolved  any differences. To identify benefits realized by EPA in implementing our  recommendations, we also relied on our internal database for information  on financial and non-financial benefits. In addition, we asked EPA to  review the information provided in this statement for completeness and  accuracy. Detailed information about the scope and methodology used to  conduct our prior work can be found in each of our issued reports.

We conducted the work on which this statement is based in accordance  with generally accepted government auditing standards. Those standards  require that we plan and perform the audit to obtain sufficient, appropriate  evidence to provide a reasonable basis for our findings and conclusions  based on our audit objectives. We believe that the evidence obtained  provides a reasonable basis for our findings and conclusions based on  our audit objectives.

Many of our reports and testimonies include recommendations that, if  acted upon, may result in tangible benefits for the U.S. taxpayer by  improving the federal government’s efficiency, effectiveness, and  accountability. Implemented recommendations can result in financial or  nonfinancial benefits for the federal government. An estimated financial  benefit is based on agency actions taken in response to our  recommendations; such benefits can result in reduced government  expenditures, increased revenues, or a reallocation of funds to other  areas. For example, in fiscal year 2016, our work across the federal  government resulted in $63.4 billion in financial benefits. Other benefits  that result from our work cannot be measured in dollar terms, and we  refer to them as nonfinancial or other benefits. During fiscal year 2016,  we recorded a total of 1,234 other benefits from our work that cannot be  measured in dollars, but that led to program and operational  improvements to the federal government. These benefits are linked to  specific recommendations or other work that we completed over several  years and could include improvements to agency programs, processes,  and policies. In some cases, benefits are realized based on the actions of  Congress. For example, since 1994, we have found that EPA faces  challenges in its ability to assess and control toxic chemicals under the  Toxic Substances Control Act of 1976—largely due to issues of statutory  choice, regulatory control, data, confidentiality, workload, and resources.  In response to our work and the work of others, Congress passed the  Lautenberg Act in 2016, giving EPA greater authority to implement  several of our outstanding recommendations related to these six areas  and positioning the agency to better protect public health and the  environment from the risks posed by toxic chemicals.

As part of our responsibilities under generally accepted government  auditing standards, we periodically follow up on recommendations we  have made to agencies and report their status to Congress. Agencies  also have a responsibility to monitor and maintain accurate records on  their progress made toward addressing our recommendations. After  issuing a report, we follow up with audited agencies at least once a year  to determine the extent to which they have implemented our  recommendations and the benefits that they have realized. During these  follow-up contacts, we identify for agencies what additional actions, if any,  they would need to take to address our recommendations. A  recommendation is considered implemented when agencies have taken  actions that, consistent with our recommendation, address the issue or  deficiency we identified and upon which the recommendation is based.  Experience has shown that it takes time for agencies to implement some  recommendations. For this reason, we actively track unaddressed (i.e.,  open) recommendations for 4 years and review them to determine  whether implementation can be reasonably expected. The review  includes consideration of alternative strategies an agency may have for  implementing recommendations. Our experience has shown that  recommendations remaining open after 4 years are generally not  implemented in subsequent years. We will close a recommendation as  not implemented if an agency has indicated that it was not planning to  take action or if we have determined that it is unlikely that the agency will  take action to address the recommendation. Figure 1 shows our process  for monitoring and reporting on recommendations.

We maintain a publicly available database with information on the current  status of most open recommendations. The database allows searches  by agency, congressional committee, or key words and is available at  http://www.gao.gov/openrecs.html.

In addition to our process for monitoring and reporting on  recommendations, we use other mechanisms to encourage agencies to  implement our recommendations in a timely manner. For example, we  initiated an effort in fiscal year 2015 to call attention to unimplemented  recommendations that we believe warrant priority attention by the  Secretary or agency heads at key departments and agencies. We sent  letters to the heads of key executive branch agencies, including EPA, in  fiscal years 2015, 2016, and 2017 identifying these high-priority  recommendations and urging the agency head to continue to provide  attention to these issues.

EPA Has Implemented 191 of 318 GAO Recommendations, Which Relate to a Variety of EPA Operations and Programs

As of August 23, 2017, EPA had implemented 191 of the 318  recommendations we made since fiscal year 2007, and the  recommendations fall into six broad categories that relate to EPA  operations and programs. EPA had not yet fully implemented the  remaining 127 recommendations. Figure 2 shows the status of the 318  recommendations. For recommendations that we made over 4 years ago  (i.e., fiscal years 2007 to 2012), EPA had implemented 77 percent. For  recommendations made since fiscal year 2013, EPA had implemented 34  percent.

The 318 recommendations we made to EPA since fiscal year 2007 fall  into six broad categories that relate to EPA operations and programs and  generally align with many of the goals and strategies identified in EPA’s  Fiscal Year 2014-2018 Strategic Plan. These six broad categories are:  (1) management and operations; (2) water issues, which includes water  infrastructure, drinking water, water quality, and ecosystem restoration;  (3) environmental contamination and cleanup, which includes  environmental cleanup, pollution prevention, hazardous and other waste  programs, and emergency management; (4) toxics, chemical safety, and  pesticides; (5) public health and environmental justice; and (6) air quality,  climate change, and energy efficiency. The percentage of  recommendations implemented within each category ranged from 80  percent for the environmental contamination and cleanup category to 48  percent in the management and operations category. Figure 3 shows  the number of recommendations we identified in each of these categories and the percentage of recommendations within each category that had  been implemented and not implemented.

Almost three-fourths of the recommendations we made since fiscal year  2007 fall into three categories: management and operations, water  issues, and environmental contamination and cleanup. The  recommendations to EPA relating to management and operations  included actions for better managing its grants, better coordinating  management of its laboratories, and improving the agency’s information  security. Recommendations on water issues included actions targeted at  improving the regulation of contaminants in drinking water, improving  water quality and ecosystem health in regions such as the Great Lakes  and Chesapeake Bay, and better managing water pollution from both  point and nonpoint sources. Recommendations related to environmental  contamination and cleanup included: taking actions for better managing  cleanup at hazardous waste sites; enhancing responses to disasters,  such as the collapse of the World Trade Center on September 11, 2001,  and Hurricane Katrina in August 2005; and promoting proper disposal and  recycling of electronic waste. The remaining quarter of the  recommendations fell into the other three categories of toxics, chemical  safety, and pesticides; air quality, climate change, and energy efficiency;  and public health and environmental justice. Appendix I lists, by category,  our reports with recommendations to EPA since fiscal year 2007, and for  each report lists the numbers of implemented, not implemented, and total  recommendations, as of August 23, 2017.

Of the 127 recommendations that EPA has not implemented, we made  82, or 65 percent, since fiscal year 2013 and 45, or 35 percent, earlier  (i.e., fiscal years 2007 to 2012). Most of these recommendations  concern EPA management and operations and water issues. Some  examples of recommendations that have not yet been implemented in  these categories are described below.

In January 2017, we made recommendations to EPA related to their  management of grants. In 2015, EPA awarded roughly $3.9 billion,  about 49 percent of its budget, in grants to states, local governments,  tribes, and other recipients. These grants supported activities such as  repairing aging water infrastructure, cleaning up hazardous waste sites,  improving air quality, and preventing pollution. In our January 2017 report,  we concluded that EPA’s ability to manage this portfolio depended  primarily on grant specialists and project officers, but the agency did not  have the information it needed to allocate grants management resources  in an effective and efficient manner. In addition, EPA had not identified  project officer critical skills and competencies or monitored its recruitment  and retention efforts for grant specialists. We recommended that EPA,  among other things, develop documented processes that could be  consistently applied by EPA offices to collect and analyze data about  grants management workloads and use these data to inform staff  allocation. We also recommended that EPA review project officer critical  skills and competencies and determine training needs to address gaps  and develop recruitment and retention performance measures and collect  performance data for these measures. According to a May 2017 letter,  EPA agreed with the five recommendations we made in the report and  identified steps it was initiating to address them. We will continue to  monitor EPA’s actions to implement these recommendations.

In August 2014, we made recommendations to EPA related to information  security. Federal agencies rely on contractors to operate computer  systems and process information on their behalf. Federal law and policy  require that agencies ensure that contractors adequately protect these  systems and information. In our August 2014 report, we evaluated how  six agencies, including EPA, oversaw contractor-operated systems. With  regard to EPA, we found that the agency generally established security  and privacy requirements for contractors to follow and prepared for  assessments to determine the effectiveness of contractors’  implementation of controls but was inconsistent in overseeing the  execution and review of those assessments. We recommended that EPA  develop, document, and implement oversight procedures for ensuring  that, for each contractor-operated system: (1) a system test is fully  executed and (2) plans of action and milestones with estimated  completion dates and resources assigned for resolution are maintained.  In comments on the report, EPA generally agreed with our  recommendations and has recently told us that it has taken steps to  implement these recommendations. We will evaluate whether these steps  meet the intent of the recommendations.

In March 2010, we made recommendations to EPA related to workforce  planning. The ability of federal agencies to achieve their mission and  carry out their responsibilities depends in large part on whether they can  sustain a workforce that possesses the necessary education, knowledge,  skills, and other competencies. We and others have shown that  successful organizations use strategic workforce planning to help meet  present and future mission requirements. In our March 2010 report on  workforce planning at EPA and other agencies, we found that EPA’s  workforce plan was not clearly aligned with its strategic plan or budget  formulation, consistent with leading workforce planning principles. For  example, EPA’s workforce plan did not show how full-time equivalent  employees, skills, and locations would be aligned with the strategic plan  or budget. Without alignment to the strategic plan, we concluded that EPA  was at risk of not having the appropriately skilled workforce it needs to  effectively achieve its mission. We recommended, among other things,  that EPA incorporate into its workforce plan clear and explicit links  between the workforce plan and the strategic plan, and describe how the  workforce plan will help the agency achieve its strategic goals. In  comments on our report, EPA generally agreed with our recommendation.  According to EPA, the agency has taken some positive steps toward  better workforce planning, such as developing workforce planning gap  analyses. However, EPA has not fully implemented this recommendation.

In May 2012, we made recommendations to EPA related to a key  program under section 319 of the Clean Water Act to address water  pollution from nonpoint sources. Under this program, EPA provides  grants to states to implement programs and fund projects that address  nonpoint source pollution. We found that EPA’s regional offices had  varied widely in the extent of their oversight and the amount of influence  they had exerted over states’ nonpoint source pollution management  programs. In addition, EPA’s primary measures of effectiveness of states’  management programs did not always demonstrate the achievement of  program goals, which are to eliminate remaining water quality problems  and prevent new threats from creating future water quality problems in  water bodies currently of high quality. To help protect water quality, we  recommended that EPA (1) provide guidance to its regional offices on overseeing state programs and, (2) in its revised reporting guidelines to  states, emphasize measures that more accurately reflect the overall  health of targeted water bodies and demonstrate states’ focus on  protecting high-quality water bodies, where appropriate. EPA agreed  with these recommendations in its comments on the report. In 2013, EPA  issued final guidelines laying out expectations for EPA’s regional  oversight and issued a memorandum to its regional managers  highlighting their oversight responsibilities. However, in a subsequent  report issued in July 2016, we found that EPA’s 2013 guidance did not  completely address our recommendation to provide sufficient guidance to  states to fulfill their oversight responsibilities. We also found that  according to EPA officials, the agency planned to make changes to some  of the program’s measures of effectiveness. Although EPA has taken  some action, these recommendations remain open pending EPA’s (1)  ensuring that the guidelines to states incorporate specific instructions on  how to review states’ plans and criteria for ensuring funded projects  reflect characteristics of effective implementation and tangible results,  and (2) improving its measures of program effectiveness.

EPA’s Implementation of GAO Recommendations and Related Work Has Resulted in Process and Programmatic Improvements and Financial Benefits

We have identified many benefits—process and programmatic  improvements and financial benefits—based on EPA taking actions on  our recommendations and related work. Since fiscal year 2007, we have  identified improvements to EPA’s operations and programs in categories  such as management and operations, water issues, and public health and  environmental justice. In addition, we have identified financial benefits  resulting from the implementation of our recommendations and our  related work.

The following are examples of process improvements we have identified  based on actions EPA has taken in response to our recommendations.

In August 2015, we reviewed EPA’s grant management program,  including the extent to which its grants management plan followed leading  practices for federal strategic planning. We found that EPA could better  ensure the effectiveness of its planning framework for meeting grants  management goals. We recommended that EPA incorporate all leading  practices in federal strategic planning relevant to grants management as  it finalized its draft 2016-2020 grants management plan, such as defining  strategies that address management challenges and identifying the  resources, actions, and time frames needed to meet EPA’s goals. In  response to our recommendation, EPA fully incorporated each of the  relevant leading practices for federal strategic planning in its final 2016- 2020 grants management plan, issued in February 2016. Specifically,  EPA included an annual priority-setting process to identify strategies to  address management challenges and the resources needed to achieve  its goals. EPA also incorporated mechanisms to ensure leadership  accountability for achieving results, including numeric targets and time  frames for each action identified in performance measures.  Consequently, EPA has better assurance that its 2016-2020 grants  management plan is an effective framework to guide and assess its  efforts to meet its grants management goals.

In August 2011, we found that EPA operated 37 laboratories across the  nation to provide the scientific research, technical support, and analytical  service to support its mission. In that report, we also found that EPA did  not use a comprehensive process for managing its laboratories’ workforce  and lacked basic information on its laboratory workload and workforce.  Without such information, we found that EPA could not undertake  succession planning and management to help the organization adapt to  meet emerging and future needs. We recommended that EPA for all of its  laboratories develop a comprehensive workforce planning process that is  based on reliable workforce data and reflects the agency’s current and  future needs in the overall number of federal and contract employees,  skills, and deployment across all laboratory facilities. EPA generally  agreed with our recommendation and, in 2015, developed a  comprehensive workforce planning process for all of its laboratories and,  according to the agency, collected, verified, and analyzed, from all of its  laboratories, workforce data that included personnel’s organization,  location, grade levels, and area of expertise.

In October 2012, we found that funding for rural water and wastewater  infrastructure was fragmented across the three largest federal  programs—EPA’s Drinking Water and Clean Water State Revolving Fund  programs and the U.S. Department of Agriculture’s (USDA) Rural Utilities  Service Waste and Waste Disposal program—leading to program overlap  and possible duplication of effort when communities applied for these  programs. For example, we found that some communities had to  prepare separate environmental analyses for each program, resulting in  delays and increased costs to communities applying to the programs. We  recommended that EPA and USDA work together and with state and  community officials to develop guidelines to assist states in developing  uniform environmental analyses that could be used, to the extent  appropriate, to meet state and federal requirements for water and  wastewater infrastructure projects. In February 2017, EPA and USDA  issued a joint memorandum to address concerns identified in our report  and highlighted best practices currently employed in some states to  eliminate duplicative environmental reviews. In particular, the  memorandum highlighted a uniform environmental review document  developed by the state of Pennsylvania. To eliminate potential duplication  of effort during the environmental review process, the memorandum  encouraged state programs to evaluate the best practices and  incorporate the practices into their own operations where applicable.

The following are examples of programmatic improvements we have  identified based on actions EPA has taken in response to our  recommendations.

Under the Clean Water Act, EPA currently regulates 58 industrial  categories of wastewater pollution—such as petroleum refining, fertilizer  manufacturing, and coal mining—with technology-based regulations  called “effluent guidelines.” Such guidelines are applied in permits to limit  the pollutants that facilities may discharge. The Clean Water Act also  calls for EPA to revise the guidelines when appropriate. EPA has done  so, for example, to reflect advances in treatment technology or changes  in industries. EPA uses a two-phase process to identify industrial  categories needing new or revised effluent guidelines, including an initial  “screening” phase in which EPA ranks industrial categories according to  the total toxicity of their wastewater. In September 2012, we concluded  that limitations in EPA’s screening phase may have led the agency to  overlook some industrial categories that warrant further review for new or  revised effluent guidelines. For example, during the screening phase,  EPA had not considered the availability of advanced treatment  technologies for most industrial categories. We recommended that EPA  modify the screening phase of its review process to include a thorough  consideration of information on the treatment technologies available to  industrial categories as it considered revisions to its screening and review  process. In comments on the report, EPA agreed that factoring treatment  technology information into its reviews would be valuable. In September  2014, EPA published a combined Final 2012 and Preliminary 2014  Effluent Guidelines Program report that discussed revisions to its  screening process in response to our report. Specifically, EPA stated that  it recognized the need to consider the availability of treatment  technologies, process, changes, or pollution-prevention practices in the  screening phase of its process and said that it was targeting new data  sources to provide such information. In July 2015, EPA published its  “Final 2014 Effluent Guidelines Program” with a diagram showing the  change to EPA’s screening process to include screening of treatment  technologies.

EPA established a 1995 Policy on Evaluating Health Risks to Children to  ensure that the agency consistently considers children in its actions, since  children can be more vulnerable than adults to certain environmental  hazards. In August 2013, we found that EPA did not have a specific  process for program offices that led regulatory workgroups to document  how the agency considers children’s health risks in rulemakings and other  actions or how the agency’s analyses comply with the 1995 policy. We  recommended that EPA require lead program offices to document their  decisions in rulemakings and other actions regarding how health risks to  children were considered and that their decisions be consistent with  EPA’s children’s health policy. In comments on our report, EPA generally  agreed with the recommendation and stated that the Office of Children’s  Health Protection worked with the Office of Policy and the program offices  to assure a consistent approach for documenting these decisions as part  of EPA’s process to develop rules, regulations, and other agency actions.  Subsequently, in October of 2014, EPA finalized a template for all EPA  employees to use that outlined how to address EPA’s 1995 policy and  other requirements under various situations. The template instructs lead  program offices to document their decisions in rulemaking and other  actions regarding how they considered health risks to children (e.g.,  conducting a children’s health risk assessment), or provide a rationale for  why such an evaluation was not necessary.

The following are examples of financial benefits we have identified based  on actions EPA has taken in response to our prior reviews.

During the course of work related to a July 2008 report on the funding and  reported costs of Superfund enforcement and administrative activities,  we reviewed EPA’s methodology for calculating the indirect costs—or  administrative costs for managing the Superfund program—that EPA  charged responsible parties in fiscal year 2006. In conducting this work,  we identified two spending codes for which associated administrative  costs had not been carried over into EPA’s calculations of the indirect  cost rate applicable to each region for fiscal year 2006. As a result of  this error, we determined that the percentage that EPA was charging  responsible parties for indirect costs associated with fiscal year 2006  spending was lower than it should have been. In response to our finding,  EPA published revised indirect cost rates for fiscal years 2005 and 2006  in May 2008 to correct the error. EPA acknowledged that correcting this  error would result in more money being potentially recoverable from  responsible parties. In 2010, we estimated that the additional amount  EPA has recovered (or would recover) had a present value worth about  $42.2 million.

Since fiscal year 2000, we have issued a body of work aimed at raising  the level of attention given to improper payments across government.  Our work demonstrated that improper payments have been a long- standing, widespread, and significant problem in the federal government  and as a result, contributed to Congress passing the Improper Payments  Information Act of 2002 (IPIA). This act, as amended, requires, among  other things, that all agencies annually identify and review programs and  activities that may be susceptible to significant improper payments,  provisions that coincide with recommendations we have made that  agencies estimate, reduce, and publicly report improper payments.  Subsequently, in 2005, EPA began reporting on the improper payment  rate for the Clean Water and Drinking Water State Revolving Funds. By  2009, the most recent year for which we identified financial benefits from  the agency addressing improper payments, EPA reported that its total  improper payment error rates for the State Revolving Funds declined by  0.16 percent since it first reported on this issue. This resulted in about a  $4.5 million decrease in improper payments from the Clean Water and  Drinking Water State Revolving Funds for fiscal years 2008 and 2009.

In conclusion, as the fiscal pressures facing the government continue, so  too does the need for executive branch agencies to improve the efficiency  and effectiveness of government programs and activities. Our  recommendations provide a significant opportunity to improve the  government’s fiscal position, better serve the public, and make  government programs more efficient and effective. We believe that EPA’s  implementation of our outstanding recommendations will enable the  agency to continue to improve its performance and the efficiency and  effectiveness of its operations. We will continue to work with Congress to  monitor and draw attention to these important issues.

Chairman Murphy, Ranking Member DeGette, and Members of the  Committee, this completes my prepared statement. I would be pleased to  answer questions that you may have at this time.

If you or your staff members have any future questions about this  testimony, please contact Alfredo Gómez at (202) 512-3841 or  gomezj@gao.gov. Contact points for our Offices of Congressional  Relations and Public Affairs may be found on the last page of this  statement. Key contributors to this testimony include Barb Patterson,  Assistant Director; Cindy Gilbert; Anne Hobson; Richard Johnson; Dan C.  Royer; and Kiki Theodoropoulos.

Appendix I: GAO Reports since Fiscal Year  2007 with Recommendations to EPA, by  Category This is a work of the U.S. government and is not subject to copyright protection in the  United States. The published product may be reproduced and distributed in its entirety  without further permission from GAO. However, because this work may contain  copyrighted images or other material, permission from the copyright holder may be  necessary if you wish to reproduce this material separately.

Through our work, we've made numerous recommendations to EPA about its management and operations, as well as its programs related to water issues; environmental contamination and cleanup; toxics, chemical safety, and pesticides; public health and environmental justice; and air quality, climate change, and energy efficiency.

We testified that, as of August 23, 2017, EPA had implemented 191 of 318 recommendations we made since 2007. Most of the unimplemented recommendations concern management and operations and water issues. For example, EPA has not fully implemented our recommendation to link its workforce plan to its strategic plan.