Unpacking U.S. EPA’s Strategic Plan & Budget

The U.S. Environmental Protection Agency (U.S. EPA) published its Strategic Plan for Fiscal Year (FY) 2022-2026 on March 28, 2022. As described by U.S. EPA, “the Strategic Plan provides a roadmap to achieve EPA’s and the Biden-Harris Administration’s environmental priorities over the next four years.” Shortly after releasing the Strategic Plan, U.S. EPA released its justification for the FY 2023 Congressional Budget (Budget), in which the Biden Administration requested nearly $11.9 billion for U.S. EPA. I will not pretend to have read the nearly 1,400 pages of material comprising the Strategic Plan and Budget, but as one would expect, the requested Budget generally aligns with the goals of the Strategic Plan. Let’s explore each in a little more detail.

Strategic Plan

U.S. EPA released both a 5-page overview as well as the full 99-page Strategic Plan. The Strategic Plan begins by identifying the following four principles:

• Follow the Science
• Follow the Law
• Be Transparent
• Advance Justice and Equity

U.S. EPA states in its news release that the first three principles reflect a “renewed commitment to the three principles articulated by EPA’s first Administrator, William Ruckelshaus,” while the fourth principle of advancing justice and equity is new.

The Strategic Plan continues by outlining seven strategic goals. U.S. EPA states that “for the first time, EPA’s final Strategic Plan includes a new strategic goal focused solely on addressing climate change and an unprecedented goal to advance environmental justice and civil rights.” The seven strategic goals are as follows:

• Goal 1: Tackle the Climate Crisis
• Goal 2: Take Decisive Action to Advance Environmental Justice and Civil Rights
• Goal 3: Enforce Environmental Laws and Ensure Compliance
• Goal 4: Ensure Clean and Healthy Air for All Communities
• Goal 5: Ensure Clean and Safe Water for All Communities
• Goal 6: Safeguard and Revitalize Communities
• Goal 7: Ensure Safety of Chemicals for People and the Environment

Each of the seven goals has at least two objectives, and each objective has several Long-Term Performance Goals (LTPGs). Perhaps unsurprisingly, of the seven strategic goals, the goal pertaining to environmental justice and civil rights – relating directly to the new principle – leads in the number of LTPGs with 14. The goal pertaining to the safety of chemicals follows with 10 LTPGs. The observation that these two goals lead in LTPGs aligns with actions that U.S. EPA has already taken (more on that later).

We often hear that when setting goals, they should be measurable, and U.S. EPA applies that concept by establishing “a suite of measures that will help the Agency monitor progress and ensure accountability for achieving its priorities to protect human health and the environment for all Americans.” Of the 51 LTPGs in the Strategic Plan, 41 have numerical measures (e.g., percentages, quantities, dollars, etc.). For those LTPGs that do not appear to be as measurable, U.S. EPA footnotes in the Strategic Plan that the first-year activities will include further defining the scope of those goals.

A few examples of U.S. EPA’s LTPGs are to “conduct 55% of annual EPA inspections at facilities that affect communities with potential environmental justice concerns,” “increase the percentage of updated permits at RCRA facilities to 80% from the FY 2021 baseline of 72.7%,” and “complete at least eight High Priority Substance TSCA risk evaluations annually within statutory timelines compared to the FY 2020 baseline of one.”

The Strategic Plan goes on to present four cross-agency strategies to achieve the plan’s goals:

• Ensure Scientific Integrity and Science-Based Decision Making
• Consider the Health of Children at All Life Stages and Other Vulnerable Populations
• Advance EPA’s Organizational Excellence and Workforce Equity
• Strengthen Tribal, State, and Local Partnerships and Enhance Engagement

Most of these strategies also have measurable metrics, and clearly align with the previously stated principles and goals.

Finally, the Strategic Plan presents three U.S. EPA Priority Goals:

• Phase down the production and consumption of hydrofluorocarbons (HFCs)
• Deliver tools and metrics for EPA and its Tribal, state, local, and community partners to advance environmental justice and external civil rights compliance
• Clean up contaminated sites and invest in water infrastructure to enhance the livability and economic vitality of overburdened and underserved communities

These priority goals also align with the stated principles, goals, and strategies – particularly pertaining to climate change, environmental justice and civil rights, and water and chemical safety – and similarly align with the aforementioned actions U.S. EPA has already taken that I promised to discuss later.

Budget

U.S. EPA states in its news release that “the Budget makes historic investments to advance key priorities in the FY 2022-2026 EPA Strategic Plan, including tackling the climate crisis, advancing environmental justice, protecting air quality, upgrading the Nation’s aging water infrastructure, and rebuilding core functions at the Agency.” The requested FY 2023 budget ($11,880,841) represents nearly a 30% increase over FY 2022 ($9,237,153). The following priorities are listed:

• Upgrading Drinking Water and Wastewater Infrastructure Nationwide
• Ensuring Clean and Healthy Air for All Communities
• Tackling the Climate Crisis
• Advancing Environmental Justice
• Protecting Communities from Hazardous Waste and Environmental Damage
• Strengthening our Commitment and Ability to Successfully Implement Toxic Substances and Control Act (TSCA)
• Tackling Per- and Polyfluoroalkyl Substances (PFAS) Pollution
• Enforcing and Assuring Compliance with the Nation’s Environmental Laws
• Restoring Critical Capacity to Carry Out EPA’s Core Mission

Most of these nine priorities directly align with the seven goals of the Strategic Plan, with PFAS applying to both the air and water goals. (Interestingly, PFAS are not specifically mentioned in the Strategic Plan overview, only in the full plan.) The priority of restoring U.S. EPA’s capacity is an overarching priority needed to achieve the others.

As with the Strategic Plan, U.S. EPA released both a summary – 90-page Budget in Brief (BIB) – and the full 1,205-page Fiscal Year 2023 Justification of Appropriation Estimates for the Committee on Appropriations. While the Budget priorities align with the Strategic Plan goals, the order or the goals changes when listed from highest to lowest monetary investments:

There may be a few reasons for these differences. First, not all goals require the same amount of investment to be achieved. For example, upgrading water infrastructure clearly requires a significant investment for planning, materials, labor, construction, etc. Additionally, recall that the budget is only for FY 2023 while the Strategic Plan is for FY 2022-2026, so other goals may receive additional funding in future years.

Results

U.S. EPA’s Strategic Plan and Budget are thorough and organized, and contain a significant number of goals, priorities, and strategies, with many (mostly) measurable metrics. U.S. EPA states these “will help the Agency monitor progress and ensure accountability for achieving its priorities to protect human health and the environment for all Americans.” Results will be published on U.S. EPA’s Planning, Budget, and Results page. As of the time of this blogpost, the FY 2021 Agency Financial Report is available, with additional data “coming soon.”

However, since the Strategic Plan was released (and even prior to that), U.S. EPA has already taken actions that align with the plan’s goals. A few notable actions are provided below:

• On February 18, U.S. EPA released a new version of EJSCREEN. On the same day, the White House Council on Environmental Quality (CEQ) released a new tool called the Climate and Economic Justice Screening Tool (CEJST). You can read more about these tools here.
• On April 5, U.S. EPA proposed to ban the use of asbestos under TSCA.
• On April 14, U.S. EPA released its Equity Action Plan, which identifies six priority actions of its own. You can read more about that here.
• On April 19, U.S. EPA released an update on their progress on implementing the American Innovation and Manufacturing (AIM) Act, which pertains to a phased reduction of the use, manufacture, and import of hydrofluorocarbons (HFCs).
• On April 21, U.S. EPA released a White Paper on Reducing Climate Pollution from New Gas-Fired Turbines.
• On April 28, U.S. EPA announced three actions pertaining to their 2021-2024 PFAS Strategic Roadmap; specifically, “by improving methods to detect PFAS in water, reducing PFAS discharges into our nation’s waters, and protecting fish and aquatic ecosystems from PFAS.”

It’s nearly impossible not to hear something in the news almost daily about environmental justice, climate change, infrastructure, or other environmental issues. It’s no coincidence that U.S. EPA’s Strategic Plan and Budget align with those concerns and it’s clear that U.S. EPA is actively and continuously taking steps to execute the goals of the Strategic Plan. While it may take me through FY 2023 to read all of the material, I expect many more actions will have taken place by that time.

As public interest grows stronger and U.S. EPA focuses their resources on addressing public concerns, the regulated community must also ensure they are prepared to transparently communicate with public stakeholders, in addition to maintaining ongoing compliance with Federal, state, and local regulations. Having a communication strategy in place and digital tools to manage and present environmental data are becoming more and more necessary to keep up with public expectations. Please feel free to contact me at 610.422.1122 or lkroos@all4inc.com if you have any questions about the FY 2022-2026 Strategic Plan or FY 2023 Congressional Budget and how U.S. EPA’s goals and priorities may impact your facility.