                            



                          

                                         National Advisory Council for

                                   Environmental  Policy and Technology


      March #,  2013



      The Honorable Robert Perciasepe

      Acting Administrator

      United States Environmental  Protection Agency

      1200  Pennsylvania Avenue, NW Washington D.C. 20460




      Dear Acting Administrator Perciasepe:


  1	The National Advisory Council for Environmental  Policy and Technology (NACEPT) is pleased to
  2	present its Second Advisory Letter on Sustainability. We believe the idea of sustainability is central
  3 	to EPA's mission and our recommendations in this letter are consistent with, but expand on, those
  4 	in the National Academy of Sciences (NAS) Report   sustainability and the U.S. EPA"l. NACEPT met
  5 	with representatives from the NAS panel and concluded in our First Advisory letter on
  6	Sustainability:

  7

  8 	"The National Council for Environmental Policy and Technology (NACEPT) unanimously
  9 	supports the EPA adopting  the National Academies' overall recommendation in its
 10	Sustainability and the U.S. EPA report that  EPA more fully incorporate sustainability
 11 	considerations into its decision-making processes and day-to-day operations".

 12

 13 	In this Second Advisory letter, NACEPT will respond to specific charge questions and provide
 14 	recommendations for immediate  next steps EPA could take to accelerate the Agency's, and
 15 	America's, path to sustainability.

 16


      1Sustainability and the U.S. EPA, National Research Council, National Academies Press, 2011


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 17 	Specifically, EPA requested that NACEPT address the following questions  in its Second Advisory
 18 	letter:

 19 	1.   What strengths can EPA leverage to successfully deploy, across the Agency, sustainability
 20 	strategies drawing upon both the National Academies report recommendations and, also,
 21 	approaches to sustainability and recommendations  from other sources and stakeholders?
 22 	How can EPA's deployment also achieve positive influence with other agencies and
 23 	stakeholders?

 24 	a)   Are there internal or external challenges- barriers and gaps- that EPA will need to
 25	address, manage and overcome to successfully deploy sustainability strategies drawing
 26 	upon both the National Academies report recommendations  and, also, approaches to
 27 	sustainability and recommendations  from other sources and stakeholders?

 28 	b) 	If yes: (1) Identify the significant internal challenges and then recommend strategies to
 29 	address, manage and overcome them; and (2) Identify the significant external challenges
 30 	and the stakeholders involved, and then recommend strategies to address, manage and
 31 	overcome them and contribute to the EPA's successful roll-out of its defined sustainability
 32 	strategy while engaging with key stakeholders.

 33

 34 	2. Using EPA Sustainability Vision as a starting  point, and back-casting from that vision, what
 35 	breakthrough  objectives does NACEPTrecommendfor  EPA over the next 3-5 years drawing
 36 	upon both the National Academies report recommendations and, also, approaches to
 37 	sustainability and recommendations  from other sources and stakeholders?

 38 	a)   What measurement systems does NACEPT recommend for assessing progress towards
 39 	these breakthrough objectives and EPA's sustainability vision?

 40 	b)   What tools are available to help EPA consider the qualitative and quantitative
 41 	environmental, public health, social and economic benefits?

 42 	c)   What approaches should EPA use to share progress with the public?

 43 	d)   What other new approaches might be necessary to implement the breakthrough goals
 44 	that NACEPT has identified?

 45

 46	To address  these questions,  NACEPT organized into two work teams.  One addressed EPA's
 47	strengths and challenges related to incorporating sustainability across the Agency. The second
 48 	developed  recommendations for a vision, mission, and breakthrough objectives.  See further
 49 	detail about our work approach  in Appendix A.
 so

 51 	Executive Summary of Recommendations

 52	NACEPT makes ten recommendations in three categories:  I) Aligning EPA on its path to
 53 	sustainability, II) Ensuring Stakeholder Engagement and III) Asserting Sustainability  Leadership.


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 54 	Together, these recommendations provide an implementation roadmap for the Agency's more
 55 	complete incorporation of sustainability as a guiding  concept for executing its fundamental mission.
 56 	Each of these will be further elaborated on throughout the letter.

 57

 58 	SUMMARY OF RECOMMENDATIONS

 59

 60	I. Setting Direction and Creating Alignment on EPA's Path  to Sustainability

 61 	Recommendation 1:  EPA Should Build Upon Its Significant Strengths To Develop And Deploy A
 62 	Robust Sustainability Strategy.

 63 	Recommendation 2: EPA Should Clarify And Expand Its Current Mission To Explicitly Address
 64 	Environmental, Social And Economic  Goals.

 65 	Recommendation 3:  EPA Should Adopt A Compelling Sustainability Vision Based On The Needs Of
 66 	Present And Future Generations.

 67 	Recommendation 4:  EPA Should  Endorse A Small Number  Of Breakthrough Objectives To Be
 68 	Achieved By 2020  To Accelerate Implementation Of Its Sustainability Strategy And Demonstrate
 69 	Visible Leadership.

 70 	Recommendation 5:  EPA Should  Develop Quantitative Metrics To Analyze Net Impacts And
 71 	Benefits Of Decisions  In Terms  Of Contributions To A More Sustainable Society And Incorporate
 72 	These  In Goal-Setting Processes.

 73

 74 	II.  Engaging Stakeholders In EPA's Commitment To Sustainability

 75 	Recommendation 6.  EPA Should Clearly Connect  Its Sustainability Strategy To Its Existing
 76 	Authorities And Engage Stakeholders In Implementation.

 77 	Recommendation 7: EPA Should  Link Sustainability, Community Engagement And Environmental
 78 	Justice Approaches Across EPA.

 79

 80 	III. Asserting EPA's Leadership In Sustainability

 81 	Recommendation 8:  EPA Should  Develop The Organization And Culture  Needed To Transition And
 82 	Strengthen Its Sustainability Capabilities: Leadership, Innovation, and Collaboration.

 83 	Recommendation 9:  EPA Should  Enhance  Its Presence In Sustainability Both Inside The Agency
 84 	And Across The Federal  Government.

 85 	Recommendation 10: EPA Should  Establish A Stronger Role As Convener Of Sustainability
 86 	Discourse And Collaboration Involving Government And Society At Large.

 87

 88 	Implementing these recommendations will help EPA set direction toward a more sustainable
 89 	future, create alignment within the agency and across the federal government, connect EPA's


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  90 	commitment with  people around the country and across the world,  and set the country on an
  91 	accelerated path to sustainability. These  recommendations will establish EPA as a game changer
  92 	working with the rest of the Federal  Government, industry, state and local governments, and other
  93 	nations. Each of these recommendations will be expanded upon  below.

  94

  95 	I. SETTING DIRECTION AND CREATING ALIGNMENT ON EPA'S PATH TO SUSTAINABILITY

  96

  97 	Recommendation 1: EPA Should Build  Upon  Its Significant Strengths To Develop and Deploy
  98 	A Robust Sustainability Strategy.

  99 	There  are two widely accepted definitions of sustainability that  are good background for EPA to
 100 	consider as it embarks on a more  explicit sustainability strategy. In 1987, the Brundtland
 101 	Commission - or the World Commission on Environment & Development- headed by then
 102 	Norwegian Prime  Minister  Gro Harlem  Brundtland, defined sustainable development as
 103 	"development that meets the needs of the present without compromising the ability of future
 104 	generations to meet their needs".2   This defined  sustainability at the scale of national or global
 105 	governance, and focused  on intergenerational societal needs.

 106

 107 	John Elkington,  founder of the think  tank SustainAbility, built on the Brundtland definition and
 108 	introduced the idea of the 'triple bottom line'. Elkington  advocated this sustainability decision-
 109 	making framework to help organizations optimize the environmental, social and economic
 110 	outcomes from their  activities.

 111

 112 	NACEPT believes that  both the Brundtland definition, focused  on needs, and the Elkington
 113 	definition, focused  on environment, society  and economy, should inform  EPA's approach to
 114 	sustainability. While adapting definitions of sustainability will vary with the circumstances and
 115 	needs  of individual organization, most agree  that  11SUstainability" includes the foundational 11pillars"
 116 	that  address environmental, economic and social considerations, and intergenerational needs,
 117 	when  making decisions and looking  at impacts associated with that  organization's mission.

 118

 119 	EPA has a solid foundation to embrace sustainability. While the term  11SUstainability" was not in
 120 	common  use when  EPA was launched over forty years  ago, its mission  is directly in line with the
 121 	idea.  The NAS Sustainability report3  correctly notes  that  EPA's mission  has never  been focused
 122 	solely on environmental protection. EPA operates with  explicit directives to protect human health,
 123 	to make communities more livable, and to develop and deploy technologies and practices that  can


      2 Sustainable Development: a guide to our common future, the report of the World Commission on Environment and
       Development; Oxford University Press, 1987.
       3 Sustainability and the U.S. EPA, National Research CounciiJ National Academies Press, 2011


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 124 	reduce emissions cost-effectively.  As such, NACEPT believes sustainability concepts have long been
 125 	central to EPA's approach,  representing it's 11true  north."

 126

 127 	Bob Perciaseppe succinctly captured that idea when he said:

 128 	[-EPA to provide]

 129

 130 	Since its inception in 1970, EPA has developed expertise,  experience and understanding about
 131	protecting  human health and the environment through setting performance standards, requiring
 132 	control technology, permitting operations, assisting compliance, protecting community  health, and
 133 	recommending best practices across many sectors of the economy 4.  EPA's activities, both
 134 	regulatory  and non-regulatory, have been driven by protective  ecosystem standards, human health
 135 	standards and considerations of impacts to society, as well as environmental justice. In some
 136 	aspects of its mission, EPA already takes economic factors into consideration, since its actions have
 137 	an impact on economic development, both positive and negative.  NACEPT believes EPA can further
 138 	address economic considerations with its sustainability strategy,  while fulfilling its statutory
 139 	obligations to protect  the environment and human health. In fact, greater  focus on the econo ic leg
 140 	of sustainability may enrich all of EPA's activities particularly in the current context where
 141 	addressing the deficit and encouraging economic growth are national priorities.  EPA has the
 142 	opportunity to address and rectify the possible perception inside and outside the EPA that there is a
 143 	cost premium to advance sustainability strategies.

 144 	NACEPT believes that advancing sustainability can drive significant economic benefits for the U.S.
 145 	government as it has with industry.  The surprising outcome of many corporate sustainability
 146 	efforts has been substantial economic benefit through, for example, energy efficiency, reduced
 147 	waste, or innovation, enabled by looking at old problems  with a new lens of sustainability. Perhaps
 148 	most importantly, by pursuing a holistic approach  to sustainability, EPA may be able to better
 149 	invest the Agency's limited resources and enable more cooperative relationships across federal
 150 	agencies, among regulators (federal, state and local) and with regulated  entities.

 151

 152 	Some of the most innovative sustainability initiatives involve collaboration  between  companies,
 153 	NGOs and government5.    A particular advantage  for EPA in multi-stakeholder collaboration is
 154 	enhancing the influence of the Agency to advance sustainability along supply chains that originate
 155 	largely outside of the U.S (many of which cannot be addressed within, even though they affect, the


       4
        Many EPA programs already intentionally incorporate  two or more pillars of sustainability such as Brownfields and Land
       revitalization program, Energy Star, Urban Waters, Partnership for Sustainable Communities grants program, The Office of Solid
       Waste and Emergency Response Community Engagement Initiative, Infrastructure and environmental education.
       5  For example, the Sustainability Consortium in which about 80 companies, some NGOs and, in some areas, EPA's Design for the Environment (DfE), are developing sustainability profiles .for consumer products that will be used by retailers to prioritize
       their purchases; WRI's Aqueducts program involves collaboration across multiple stakeholder to map and respond to water risks.


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 156 	U.S.). They provide an opportunity for EPA to use its scientific expertise to help address critical
 157 	sustainability issues in ways consistent with its mission.

 158

 159 	Despite the many strengths outlined above, EPA will encounter challenges and barriers to
 160 	successful implementation of a sustainability strategy.  Regulated entities may be resistant if they
 161 	believe EPA intends to regulate or require sustainability, if they believe that the strategy will
 162 	increase costs, or decrease the likelihood that a plant, operation or business will be allowed to
 163 	function economically. Some entities may express preference  for a smaller government role in
 164 	sustainability to allow for competition  and the marketplace to define the best sustainable choice for
 165 	that entity.  Some in the private sector may see a competitive  advantage  to their own sustainability
 166 	efforts and resist the implementation of an EPA sustainability strategy, while yet others  may view
 167 	implementing the NAS recommendations as an unfunded and perhaps  expensive mandate.  We
 168 	believe EPA can address these concerns with careful and transparent implementation.

 169

 170 	The first step in developing a robust sustainability strategy  is to reconsider  EPA's Mission.

 171

 172 	Recommendation 2: EPA Should Clarify And Expand  Its Current Mission Statement To
 173 	Explicitly  Endorse A Sustainability Approach.

 174 	EPA's current  mission statement to (protect human health and the environment' has served the
 175 	Agency well for many decades.  A more explicit focus on sustainability does not imply departing
 176 	from this mission but enhancing it in line with the NAS recommendation.

 177 	NACEPT recommends three simple, but significant, changes to the Mission: one encourages  EPA to
 178 	not just protect human health and the environment, but improve it; a second recognizes long term
 179 	economic growth as a pillar of sustainability,  and a third addresses the societal desire for improving
 180 	quality of life.

 181 	NACEPT recommends the following new mission statement for EPA:

 _182
 183

 184 	EPA's Mission is to improve human  health and the environment while maintaining or
 185 	enhancing  quality of life.

 186

 187 	EPA's Mission is to improve human  health and the environment and to encourage actions
 188 	and solutions that advance the health, well-being and benefit of all.

 189

 190 	EPA's Mission is to improve human  health and the environment while advancing long term
 191 	economic viability and the quality of life for all Americans.

 192

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 193 	One advantage of this (these)  updated  mission statement(s) is that it/they maintains the central
 194 	ideas in EPA's long-standing mission statement while incorporating the concept  that improving
 195 	quality of life requires  addressing the economy, while remaining clear and succinct.  A second
 196 	advantage is that it/they make a significant statement that decouples the notion that environmental
 197 	and human health protections come at a cost to society.  EPA's mission would reinforce that
 198 	environmental and human health protections can be compatible with achieving the nation's
 199 	economic goals.

 200

 201 	Recommendation 3: EPA Should Adopt  A Compelling Sustainability Vision based on the
 202	needs of present and future generations.

 203 	As discussed, EPA has a Mission that drives its every day work.  However, it does not have a clearly
 204	articulated Sustainability Vision statement to establish  a future  oriented goal and a broader context
 205 	for executing the Agency's Mission. Both the NAS report  and NACEPT's first letter on sustainability
 206	recommend  creating a vision statement as a necessary  first step for the Agency6::   A vision statement
 207	will allow EPA's various and diverse activities and programs  to cohere and support one another
 208	under the common umbrella of sustainability and will signal to stakeholders inside and outside the
 209	Agency that EPA has a long term goal to advance a leadership role in sustainability.

 210

 211 	A compelling Sustainability Vision statement will present a clear picture of a future state where EPA
 212	is widely recognized as a global leader on sustainability. EPA's current Mission succinctly and
 213 	effectively addresses the environmental and human health aspects of sustainability, but both the
 214 	Mission and Vision statements should incorporate long term quality of life and standard of living as
 215 	equally important aspirations of sustainability.

 216

 217	While EPA leadership needs to undertake its own dialogue to develop a sustainability Vision for the
 218	Agency, NACEPT suggests that EPA focus on a vision of sustainability that reflects environmental,
 219	social and economic ambitions  and considers intergenerational needs.  NACEPT proposes:

 220


 221
 222
 223

 224

 225
 226

 227

      EPA's Vision is to propel America towards sustainability, protecting the environment and health in a way that meets the environmental, social and economic needs of the present without compromising the ability of future generations to meet their needs.


      EPA Vision is a more sustainable American society and environment, now and for future generations.




6  First Sustainability Advice letter to Administrator Jackson, NACEPT, April 5, 2012



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 228 	EPA's Sustainability Vision statement and mission statements should be presented together.  The
 229 	Vision expresses  the Agency's long term goal and the Mission clarifies how the vision will be
 230 	achieved.  To illustrate  how the expanded mission and new vision will be implemented by the
 231 	Agency, NACEPT recommends announcing a series of breakthrough objectives that will provide
 232 	definition through sustainability in action.

 233

 234 	Recommendation 4:   EPA Should Endorse A Small Number of Breakthrough Objectives To
 235 	be Achieved By 2020  To Accelerate Implementation Of Its Sustainability Strategy &
 236 	Demonstrate Visible Leadership.

 237 	The National Academy of Sciences recommended that EPA develop "Breakthrough  ObjectivesJJ to
 238 	guide and energize EPA's sustainability plan7.  Breakthrough Objectives should galvanize the
 239 	Agency and help people understand the concepts of sustainability by demonstrating what it means
 240 	in a specific context.

 241

 242 	NACEPT recommends the following criteria be used to evaluate Breakthrough  Objectives. The
 243 	objectives must:

 244 	a. 	Support  the Sustainability Vision
 245 	b.	Encompass new and/or more effective directions for the Agency to take.
 246 	c.	Improve performance throughout the Agency, not just in one area
 247 	d.   Advance environmental, social and economic goals.
 248 	e. 	Be implementable and measurable  at national, state and community scales
 249 	f.	Be able to be completed in 3-5 years
 250 	g.	Be simple and intuitively understandable
 251

 252 	This is not a foreign concept for a government agency.  Perhaps the most famous historical
 253 	"Breakthrough  ObjectiveJJ was President John F. Kennedy's 1961 bold exhortation to Congress that
 254 	the United States should safely put a man on the moon before the end of the decade in response to
 255 	advances in the Soviet Union's space program. This met the criteria above of being simple,
 256 	understandable, measurable,  an advance from the current state, and specific as to the timeline.
 257 	Most importantly,  it provided great internal  alignment within NASA and galvanized that Agency
 258 	into action.  The United States achieved that goal.  Breakthrough Objectives could be EPA's game-
 259 	changers.

 260


       7As the Academy wrote:"Commonly referred to in the business community, breakthrough objectives are goals that extend  far beyond current capabilities and experiences  of an organization and require new strategies  and approaches to ensure successful attainment of these  goals.  These objectives are generally designed to improve  performance throughout  an organization."
       Sustainability and the U.S. EPA, The National Academies report, 2011



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 261 	In considering the type of Breakthrough Objectives to recommend, NACEPT first considered the
 262	types of themes the objectives could be structured around. Example themes include:
 263 	11	Project-based objectives i.e. focused on industry or infrastructure
 264	11	Internally  themed  objectives i.e. focused on EPA buildings or operations
 265	11	Environmental issue themed objectives e.g. focused on water  or waste or pollution
 266	11	Federal government themed objectives i.e. focused on the operations of all Federal Agencies
 267	:: 	Societally themed  objectives i.e. focused on EPA interactions with society writ-large
 268
 269	We then developed a range of possible breakthrough objectives within these theme types, without
 270	excluding any theme type when considering potential  recommendations. A partial list of our
 271 	suggestions  are provided below for EPA to consider.  NACEPT recommends EPA select no more
 272	than 3 final objectives and that at least one Objective be internally focused to serve as a role model
 273 	for other entities and to provide a demonstration that operating more sustainably is attainable by
 274	any entity.
 275
 276	Possible Breakthrough Objectives for EPA to consider8:
 277
 278	1.   By 2020 EPA will have facilitated 25 green infrastructure  projects that deliver regulatory
 279	performance comparable to conventional pollution control systems, but at lower costs, with higher
 280	conservation values and outcomes, and measurable net  job creation.

 281 	This possible breakthrough objective is very focused on a set of projects, but serves to illustrate
 282	the viability of achieving a sustainable 'triple-win', through  pilots.  Infrastructure projects will
 283 	provide environmental protection  and beneficial economic activity in local communities.

 284

 285	2.   By 2020, work with at least 10 firms in high carbon-emitting industries (steel, cement  aluminum,
 286	paper and plastic) to develop approaches to incentivize 25% increase in energy and carbon
 287	efficiency without reducing profitability or employment.

 288	This possible breakthrough objective is very focused on a priority environmental issue: climate
 289	change, with large energy users.  It serves to help EPA prioritize  work with production
 290	industries that have the highest relative contribution to energy use and GHG emissions.
 291 	Achieving this objective would allow EPA to use the power of collaboration  and voluntary
 292	initiative to drive progress  on climate change.

 293

 294	3.   EPA will work with priority industries and or communities to reduce water, carbon and waste
 295 	emissions by 33% by 2020.




      8 In Appendix B, NACEPT has provided a template for evaluating Breakthrough Objectives and a longer list of suggestions.


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 296
 297
 298
 299

 300
This possible breakthrough objective is focused  on priority industries as well as communities and expands to three environmental issues,  not just climate  change, setting a specific improvement goal.  This goal would  require beneficial collaboration and result in significant environmental and economic benefits.


 301 	4.    By 2020J improve  air quality to reduce soot 20% without raising the price of electricityJ nor
 302 	causing disproportionate impacts on affected low-income  communities or resulting in significant
 303 	reduction  in local employment.

 304 	This possible breakthrough objective is focused  on a specific  health  and environmental
 305 	justice issue as soot  pollution is linked to asthma and respiratory health  conditions. It also
 306 	presents an opportunity to address climate  change  and visibility.

 307

 308 	5.   By 2020 create 'one EPA' by dramatically increasing  collaboration across departments and
 309 	creating  joint programs  focused on sustainability.

 310 	This possible breakthrough objective is internally focused  and builds on the One EPA concept-
 311 	expanding it to ensure there is true  collaboration.  As one example,  the range  of EPA-controlled
 312 	ecolabels such as Energy Star, WaterSense, Design for Environment etc could work much more
 313 	closely together to develop a joint program related to environmental sustainability overall.

 314

 315 	6.   By 2020J EPA Will Be Carbon Positive.

 316 	This possible Breakthrough Objective goes beyond  the more  common  corporate objective of
 317 	carbon neutrality. To be carbon-positive, EPA would  need to avoid more carbon than  it emits.
 318 	By pursuing carbon-positivity, EPA would send  a signal to other agencies  and regulated entities
 319 	that  it is going beyond  today's terms of addressing climate  change.  EPA would  build on a
 320 	foundation of activity  already focused  on its footprint and stretch even further.

 321

 322 	7.   EPA Will Help the Federal Government Achieve 95% Sustainable Purchasing For All Goods And
 323 	Services [with the exception  of weapons  systems) Used By The US Government.

 324 	This possible Breakthrough Objective recognizes that  use of Federal  purchasing as a driver of
 325 	sustainability has already been  recognized in numerous Executive Orders, the latest of which,
 326 	E013514, sets out the goal to advance sustainable acquisition9.   While the Executive  Order
 327 	does provide high level guidance on the types of product and services attributes that  are
 328 	considered 'sustainable acquisition', and stipulates that  95%  of 'all contract actions' meet such

       9 [Section (2}{h)} advance sustainable  acquisition to ensure that 95 percent of new contract actions including task and delivery orders, for products and services with the exception of acquisition of weapon systems, are energy-efficient (Energy Star or Federal Energy Management Program (FEMP} designated), water-efficient, bio-based, environmentally preferable (e.g., Electronic Product Environmental Assessment Tool (EPEAT} certified}, non-ozone  depleting, contain recycled content, or are non­ toxic or less-toxic alternatives, where such products and services meet agency  performance requirements.

                             


329

 a test, there is considerable opportunity for EPA, working with GSA, other federal agencies,
330

 cross-stakeholder initiatives1°, NGOs and businesses, to help define exactly what constitutes
331

 'sustainable acquisition', and how to measure achievement of the 95% targetll.
332


333
 8.
 By 2020, EPA will help America's industries achieve a 20% reduction  in lifecycle environmental
334

 impacts, while improving  their long-term economic competitiveness and job-creation  potential
 335 	This possible breakthrough objective formalizes the widespread use of lifecycle assessment
 336 	(LCA) as an environmental tool, and expands the use of LCA from an environmental focus
 337 	only, to a broader sustainability context.

338

339
 9.
 EPA Should Undertake  Educating The Next Generation Of Decision-Makers On Sustainability.
340

 This possible breakthrough objective focused on educating the next generation of decision
341

 makers on what sustainability is- and what it isn't- as a critical objective for EPA. This is a
342

 'societal' objective in that it implies focusing on wider U.S. society in an effort to educate and
343

 engage them in a multi-decade effort to put the US on a path to sustainability. To accomplish
344

 this will require  innovative and creative multi-stakeholder collaboration  by EPA, including
345

 using sources  of knowledge from academia, to corporate problem-solving,  to NGOs to native
346

 cultures.  Successful training and outreach  will result in improved  knowledge of sustainability
347

 leading to better  decision-making that optimizes social, environmental and economic outcomes
348

 for the United States.
349


 350 	The following diagram (Figure 1)  is a succinct visual of the Vision, Mission and Breakthrough
 351 	Objectives connected  across the organization  and programs at EPA.

 352







       1° For example, The Sustainability Consortium is a collaborative effort  of over 70 companies, some NGOs, and (so far) limited government agency participation (EPA's Design for the Environment has participated  in one category) to develop sustainability assessment measures for all categories of consumer goods sold by retailers.  Initially funded, but not owned, by Walmart;
       managed by Arizona State University and the University of Arkansas. This task is moving into high gear and could benefit from EPA engagement. It is focused on supply chains, not just on the American brands selling the final products.  There is potential for major leverage on chemicals in processes and products worldwide.  In many areas, there is a real need for better technical tools- whether for assessment or tracing and understanding environmental  impacts, as well as social/community/labor impacts.
       11 In the Executive Order, it is not clear how a product would qualify as 'less toxic or non toxic", or for which product types recycled content is a relevant attribute. It does not clarify how Federal purchasers should evaluate the hundreds of sustainability-oriented standards or ecolabels, and it does not make clear how to achieve the ultimate  goal of sustainable acquisition: to reduce lifecycle environmental impacts in areas of greatest concern and optimize social and economic outcomes associated with Federal purchasing.


                             



  Vision
  Option 2

                     EPA Vision is a more sustainable American  society and environment, now and for future generations












  Mission
 Option 1
                EPA's Mission is to improve human health and the environment, while maintaining  or enhancing  quality of life



















 353

 354

 355

 356 	Recommendation 5: EPA Should  Develop  Quantitative Metrics To Understand Net Impacts
 357 	And Benefits Of Decisions In Terms Of Contributions To A More Sustainable Society And
 358 	Incorporate In Goal Setting Processes.

 359	One of EPA's greatest strengths is its capacity to develop and deploy metrics of pollution- of
 360 	emissions and concentrations of substances that can create  risks to human health and ecosystem
 361 	conditions.  EPA can share  both t}lese data and the agency's human skills in gathering and using
 362	such data with the rapidly growing number of corporations, small businesses  and non profits,
 363 	certifying organizations, and collaborative, multi -sector efforts.  The Office of Research and
 364 	Development, could play an important role in connecting with the most current research in
 365 	academic and other institutions and in assisting other offices to incorporate and disseminate new
 366 	sustainability knowledge more rapidly.  ORD and other EPA offices, such as Energy Star, DfE and
 367 	other non-regulatory offices and initiatives have distinctive  competencies, valuable knowledge and
 368 	metrics needed by businesses and non-profits to build their capacity to operate sustainably.

 369

 370 	By sharing skills, EPA can forge more productive  relationships with regulated  entities and build its
 371 	own capacities.  Given the complexities of understanding interaction and interconnectivities among
 372	natural and social systems, EPA can build upon both its access to data and its ability to handle,
 373 	analyze, report  and explain data. In its varied roles as a source of data and information, an educator,


                             


 374 	an analyzer, a convener, and a decision-maker, it can make a difference in growing sustainability
 375 	capacity across the United States.   EPA is already leveraging its research programs to better
 376 	understand interconnectivity among and across  both natural and social systems. This
 377 	recommendation could also be a topic to be more specifically expanded upon by a future NACEPT
 378 	Council.

 379
 380 	NACEPT recommends that  EPA use the Breakthrough Objectives  and metrics to better reflect its
 381 	strategy on sustainability in its FY 2016-2020 Strategic Plan.  NACEPT believes  that  EPA can
 382 	demonstrate a stronger focus on sustainability using its strategic planning and goal-setting
 383 	processes and identifying sustainability as a central theme of its work.
 384
 385 	II. ENGAGING STAKEHOLDERS IN EPA'S COMMITMENT TO SUSTAINABILITY
 386
 387 	Recommendation 6.  EPA Should Clearly Connect Its Sustainability Strategy To Its Existing
 388 	Authorities and Engage Stakeholders in Implementation.

 389 	EPA will need to address the fact that  its various authorizing statutes do not explicitly  reference
 390 	sustainability the way business and governments commonly understand sustainability today.  Some
 391 	may question EPA's adoption of a sustainability strategy, believing that  sustainability is beyond  its
 392 	statutory mission. NACEPT does not believe this is a barrier to moving forward on a sustainability
 393 	strategy. Language  in a number of authorizing statutes is strongly indicative of a vision of a more
 394 	sustainable approach to addressing environmental and societal health  issues.  EPA will need to be
 395 	transparent and open with stakeholders and justify its path forward 12.

 396

 397 	NACEPT believes  that  EPA has authority to acknowledge sustainability as core to its  Mission.
 398 	Congress set the stage  for Federal  Government agencies to address sustainability when  it enacted
 399 	the National Environmental Policy Act (NEPA) which declared:

 400 	"the continuing policy of the Federal  Government is to create and maintain conditions,
 401 	under which humans and nature can exist in productive harmony, which permits
 402 	fulfilling the social, environmental, and economic and other requirements of present
 403 	and future generations"B

 404

 405 	NEP A reflects  both the three pillars  of sustainability as well as the intergenerational aspect of
 406 	sustainability. NEPA's strong mandate for public participation and input in generating integrated
 407 	analysis  of environmental, economic and social factors is central to the workings of sustainability.

 408


       12  NACEPT notes that the Office of General Counsel at EPA is currently undertaking a review of all Agency legal authority  to support implementing a sustainability strategy.
       13  National Environmental Policy Act, 42 U.S.C. 4331(a}L 1969


                             


 409 	More recently, President  Obama, in Executive Order 13514, provided further specific' directive to
 410 	the executive branch agencies:

 411 	11tO establish an integrated strategy  towards  sustainability in the Federal Government",
 412 	providing a definition of sustainability 'to create and maintain conditions, under which
 413 	humans and nature can exist in productive  harmony, that permit fulfilling the social,
 414 	economic, and other requirements of present and future generations"14

 415

 416 	NACEPT members  believe that active community engagement and meaningful community and
 417 	stakeholder input will improve the effectiveness of EPA's commitment to sustainability. EPA has
 418 	deep connections and relationships with many key stakeholders including state, local and tribal
 419 	governments, corporations, small businesses, nonprofits, academic institutions and other entities,
 420 	many of which are similarly engaged in determining the most sustainable direction for their
 421 	organizations.  They have embraced  sustainability to drive innovation, educate and engage their
 422 	employees and citizens, reduce costs, become more competitive  and address  key global issues, such
 423 	as global climate change, the decreasing availability of fresh water, loss of biodiversity  and
 424 	associated  habitats, improving the standard of living, eliminating poverty, and improving the health
 425 	and welfare of global citizens.

 426

 427 	For example, in the private sector, corporations have demonstrated a significant interest in
 428 	developing more sustainable approaches. Increasingly, they are evaluated and rated for their
 429 	sustainability programs  and progress, creating a competitive imperative.15  Their actions range
 430 	from building explicit business  models to grow a company using a sustainability strategy to
 431 	management of sustainability throughout corporate supply chains to greater  transparency in
 432 	reporting on a Company's environmental footprint and efforts to reflect improvement efforts
 433 	relating to employees, and local and global communities.  This corporate drive, while not explicitly
 434 	driven by EPA, clearly stems from the strong focus and foundation  of environmental performance
 435 	that EPA has driven over the last forty years.  Given the highly regulated  aspect of U.S. businesses,
 436 	there is a great opportunity for the regulated community and EPA to collaborate further, for
 437 	example, pursuing  public/private partnerships with EPA on important issues16. The opportunity to
 438 	leverage sustainability efforts through  partnerships and collaboration  also exists in state, local and
 439 	tribal governments as well as non-governmental organizations.


       14 Executive Order, 13514 {2009)
       15  Examples: Dow Jones Sustainability Index, Newsweek Magazine's annual ranking of Greenest U.S. Companies, annual ranking of the Global100 Most Sustainable Corporations in the World, Maplecroft  Climate Innovation Index- annual ranking of largest
       330 or so U.S. companies re: climate actions, Bloomberg Renewable Energy ranking of companies using renewable energy, US EPA Green Power Partnership -largest purchasers of renewable energy in the U.S. (Top 10 Federal Government, companies, retail, universities, Top 20 K-12 schools, etc.), Carbon Disclosure Project, 100 Best Corporate Citizens, World's Most Ethical Companies.
       16 A good recent example of this is the joint public-private effort to raise corporate average fuel efficiency across American
       automobile manufacturers.


                                                                             14
                                                                               
                             


 440

 441 	Recommendation 7: EPA Should Link Sustainability, Community Engagement and
 442 	Environmental Justice Approaches across EPA.

 443 	The directive to improve environmental justice is incorporated in sustainability and is already
 444 	underway.  The Obama Administration expanded  the commitment to ensuring federal agencies also
 445 	advance the goals of environmental justice (EJ) by signing the "Memorandum  of Understanding on
 446 	Environmental  Justice and Executive Order 12898"  (EJ MOU) in August, 2011.17 The Interagency
 447 	Working Group on Environmental Justice (EJIWJ) has expanded its ranks to include additional
 448 	federal agencies representing the intersecting concerns of the environmental quality, social impacts
 449 	and economic development. Administrator Lisa Jackson explained how these are interconnected:

 450 	11All too often, low-income, minority and Native Americans live in the shadows  of our
 451 	society's worst pollution, facing disproportionate health impacts and greater obstacles to
 452 	economic growth in communities that can't attract  businesses  and new jobs. Expanding the
 453 	conversation on environmentalism and working for environmental justice are some of my
 454 	top priorities  for the work of the EPA...Every agency has a unique and important role to play
 455 	in ensuring that all communities  receive the health and environmental protections they
 456 	deserve."ls

 457

 458 	Environmental  justice scholars and community activists have stressed the importance of
 459 	integrating the three factors that comprise sustainability (environmental, social and economic
 460 	factors)  rather than seeing them as separate concerns.  Environmental  justice and community-
 461 	based organizations,  communities of color and low income, and Tribal communities across the
 462 	United States are developing a vision of healthy and sustainable communities.  Many of them are
 463 	proactively exploring sustainability through planning, alternative energy solutions, community-
 464 	driven decision-making, and community design.  Working with governmental agencies and the
 465 	private sector, communities are urging problem-solving approaches aimed at minimizing
 466 	environmental degradation while building community capacity to contribute to sustainable
 467 	development decisions.19 The work, experiences, and traditional environmental knowledge (TEK)
 468 	and cultural heritage of environmental justice organizations and Tribal communities  provide
 469 	valuable insights and best practices for advancing sustainability and creating healthy communities

 470

 471 	This recommendation has challenges.  Budget reductions  have limited funds for coinmunity
 472 	programs, such as the CARE program which focused on community-based environmental
 473 	management. There are limited channels for community input to effectively influence
 474 	governmental decisions.  Lack of informed opportunities to engage in the process of planning,


      17 EJMOU (2011} http://epa.gov/environmentaljustice/resources/publications/interagency/ej-mou-2011-08.pdf
       1s http:/ jwww.whitehouse.gov/administration/ eop/ ceq/Press_Releases/August_04_2 011
      19  Remarks of Deeohn Ferris at the Environmental  Law Institute  Sustainability Forum, (Washington, DC,September 27, 2011)


                                                                             15
                                                                               
                             


 475 	decisions and investments and insufficient resources are major barriers to underserved
 476	communities  being able to achieve these goals. Limited ethnic, linguistic and culturally diverse staff
 477	at EPA inhibits communications and partnerships with EJ communities.  Lastly, community
 478 	concerns about anti-immigration backlash create distrust of federal government agencies.

 479

 480 	However, there are meaningful steps EPA can take to address these challenges.  EPA could provide
 481 	technical assistance  to communities  to collaborate  on sustainability at the locat state, regionat  and
 482	national levels.  EPA's assistance  could help fund communities  to participate in annual conferences
 483 	to improve collaboration with EJ communities, as well as training, and capacity building.
 484	Additionally, EPA can be proactive in nominating and appointing individuals with expertise  on
 485 	environmental justice, racial justice, and equitable  development to federal advisory committees  to
 486 	incorporate their expert insights and lessons.

 487	There are numerous  examples where states, tribal and local governments have made significant
 488 	sustainability commitments as well. EPA can learn from those efforts and ensure that its
 489	sustainability strategy complements,  rather  than contrasts or confronts those locally-developed
 490 	sustainability initiativeszo.

 491


 492

 493

III. ASSERTING SUSTAINABILITY LEADERSHIP


 494	Recommendation 8.  EPA Should  Develop  The Organization And Culture Needed To Transition
 495 	And Strengthen Its Sustainability Capabilities: Leadership, Innovation, and Collaboration.

 496 	EPA's regulatory  programs focus on national standards, applied consistently and uniformly across
 497 	the country to address specific environmental concerns.  Sustainability addresses a broad spectrum
 498 	of environmentat social and economic concerns in individual situations.. These are different lenses
 499	with which to view approaches to the problems EPA must address.  While many EPA employees are
 500 	already knowledgeable about sustainability concepts and see implementing EPA's sustainability
 501 	strategy  as highly compatible  with EPA's mission to protect human health and the environment,
 502 	EPA should strengthen employee knowledge of sustainability principles and their application  in
 503 	actions of the Agency.
 504
 505 	EPA can accelerate  building sustainability capacity within the EPA by utilizing tools such as
 506 	websites, training, newsletters, new hire orientation, and Sustainability forums to ensure
 507 	employees understand what sustainability is and what EPA's strategy entails.  This




       20   Examples of a strengthened EPA outreach in this area include: 1) Partnering with community-based environmental science initiatives (citizen science, community-based monitoring, and bucket brigade) to design collaborative research programs, and 2) collaborating with indigenous scientists and tribal organizations developing new sustainability practices and technologies
       incorporating traditional environmental  knowledge (TEK).


                                                                             16
                                                                               

                             


 508 	recommendation dovetails with NACEPT's recommendations and EPA initiative to foster a 110ne
 509 	EPA" culture using its sustainability strategy  as a prevailing theme.

 510

 511 	By partnering with other institutions EPA can train, educate, and increase awareness and
 512 	understanding about sustainability. For example, academic institutions are rapidly responding to
 513 	student desire for a sustainability curriculum21.  Students  are clearly responding to the direction
 514 	they see corporations and governments moving and want to develop marketable skills. EPA can
 515 	leverage its expertise  in fundamental  science, systems thinking, community outreach, and law and
 516 	policy to provide technical assistance in developing sustainability curriculum.  This would have the
 517 	additional benefit of attracting new EPA hires that have been through  an academic curriculum  that
 518 	would align with the skills and expertise  that EPA anticipates needing in the future.

 519

 520 	Other opportunities for ORD and other EPA offices to partner with external institutions to advance
 521 	sustainability include:

 522 	1.   Develop a National Sustainability  Report.  It is imperative that some national identification,
 523 	collection and reporting of sustainability metrics and the progress America is making to achieve
 524 	the EPA Vision be done on a regular basis.  EPA is a logical agency to play a leading role to
 525 	accomplish that goal.
 526 	2.   Assess existing, or develop if needed, methodologies  for measuring  natural  resource
 527 	sustainability,  such as life cycle analysis, ecosystem services, and water foot printing.zz
 528 	3.    Develop, vet or bless tools that could be used across industry  and governments for measuring
 529 	sustainability and that are practical and could be used in a comparative  way.
 530 	4.   Partner with academic institutions to encourage the use of defined sustainability programs
 531 	(example STARS23), encourage sustainability curriculum  development and research.
 532 	5.   Partner  with U.S. cities to highlight what cities are doing to advance sustainability, including
 533 	community's  development initiatives such as locally grown food, green buildings, sustainability
 534 	programs in schools.
 535 	6.   Develop a program  to serve as an enterprise model for stakeholders such as other federal
 536 	agencies and local governments.


       21   Many Junior colleges and universities now have fulltime  sustainability coordinators and defined sustainability programs with this trend increasing across the network of higher education. Many of these sustainability programs are comprised of three elements; advancing sustainability concepts into the courses, facilities (ex: enhanced energy and water efficiency, natural landscaping, local & organic foods} and community  (ex: offering community  outreach activities to advance sustainabiljty in the communities}.  More and more universities now offer degrees (some on-line} in sustainability. Beyond Grey Pinstripes is a ranking of MBA programs focused on social and environmental impact. Beyond Grey Pinstripes is an independent, biennial survey conducted by the Aspen Institute  highlighting how academic institutions  prepare students to meet the business challenges of tomorrow, including training in social and environmental  issues.
      22  For example, the Global Footprint Network 22  measures the ecological foot of nations and the world as a whole.
       The Sustainability Tracking, Assessment & Rating System'M (STARS} is a transparent, self-reporting framework  for colleges and universities to measure their sustainability performance. STARS(R) was developed by AASHE with broad participation  from
       the higher education community.


                                                                             17
                                                                               

                             


537
 7.
 Work with state governments to understand and promote  best sustainability practices at the
538

 state level.
539
 8.
 Leverage existing EPA programs to advance and champion sustainability in the built
540

 environment. EPA already has programs  that address many aspects of green building.24  These
541

 building efficiency/green programs  align with elements  of private standards green building
542

 certification programs.25    EPA can utilize its existing authority and roles as permit writers,
543

 approvers, grant-providers to educate and encourage greater adoption  and utilization of green
544

 building techniques.z6
545


 546 	Recommendation 9. EPA Should Enhance Its Presence In Sustainability Both Inside The
 547 	Agency And Across The Federal Government.

 548 	.   To build its presence  as a sustainability leader and to ensure alignment across EPA, NACEPT
 549 	recommends:

550
   a)
 EPA establish an EPA Sustainability Steering Committee (EPA SSC) including high-
551

 level representatives from  key EPA departments.  EPA should target a SSC of 10-12
552

 individuals to make the sse manageable and effective, including high-ranking career
553

 employees in EPA's primary  jurisdictional offices: air, water, waste, etc. It is important that
554

 these individuals be in a position to influence the direction  being taken for programs  and
555

 processes  in their specific EPA department. The SSC would be internaluchampions" for
556

 EPA's sustainability strategy.  Such a Committee would accelerate  the integration of
557

 sustainability across and into the EPA to help achieve EPA's missions, goals and
558

 sustainability leadership within the U.S. governmept. NACEPT recommends such a
559

 Committee be convened quickly, commit to regular meeting session to facilitate and inform
560

 the implementation and execution of it's sustainability strategy, and periodically rotate the
561

 chair among the leaders.
       24  For example, including Energy Star, Water Sense, Air Indoor Plus, Environmentally Preferable Purchasing, and Brownfield's programs.
       25 The push toward greater use of sustainable design concepts for buildings increased in momentum  in the late 1990s with the
       creation of Building Research Establishment's Environmental Assessment Method {BREEAM), the first green building rating system in the U.K. In 2000, the U.S. Green Building Council {USGBC} followed suit and developed and released its own set of criteria also aimed at improving the environmental  performance of buildings through its Leadership in Energy and Environmental Design {LEED) rating system for new construction. Later, the Green Building Initiative  {GBI), was created to assist the National Association of Homebuilders {NAHB) in promoting  its Green Building Guidelines for Residential Structures. Although originally developed for Canada, GBI helped to make Green Globes 21available for use in the U.S. in 2005 and tailored for the ecotourism industry. Today many countries have developed green building standards. Most green building systems address broader issues of sustainability and evolving concepts such as net zero energy use, building orientation & landscaping considerations, and living & restorative building concepts that improve the natural environment, or those that model nature's processes.
       26   Actions identified  by NACEPT members include: train more individuals on green building techniques and practices, b)
       Coordinate with other departments, such as the Department of Energy, to achieve the full potential  of existing green building related programs within the U.S. Government, and c) Explore the merits of developing a Federal Green Building Program to be
       used by Federal Government Agencies,	·




                                                                             18
                                                                               
                             



 562
 563
 564
 565
 566
 567
 568
 569
 570
 571
 572
 573

 574	b)
 575
 576
 577

 578
 579

 580
 581
 582
 583

 584
 585
 586
 587
 588
 589
 590
 591
 592

 593
 594
 595
This is similar to the approach  many large corporations and other entities have used to implement  sustainability as a strategy for their institutions. These Committees are usually comprised  of senior leaders who meet regularly to evaluate sustainability strategies, goals, targets,  progress, and developments. Each member of the SSC should take explicit ownership of a sustainability priority, such as a recommended specific Breakthrough Objective. That visible leadership will accelerate alignment and focus attention of employees across the organization.  A best practice many companies also deploy is bringing in outside advisors, either in a permanent advisory role, or on a periodic basis and this
would include advisors on innovative sustainability practices and technologies  representing and emerging from underrepresented communities and Tribal organizations.  This ensures the Agency is aware of developments in the field and gains the advantage of a fresh perspective.
EPA convene and lead  a U.S. Government Sustainability Steering Committee (U.S. Gov SSC), with  high-level representatives from different U.S. Government agencies. Sustainability leadership within EPA and across the Federal Government is critical to move the Federal Government to more sustainable approaches. As John Dernback notes:
      An ((inherent challenge(s)  for sustainability governance continues to be lack of coordination among different levels of government."27
This Committee would set U.S. government sustainability priorities  and goals, such as integrating Federal Government sustainability reporting into one or more high level government reports,  evaluating processes to green the Supply Chain for the U.S. Government, and reviewing sustainability best practices across the Federal Government28 ::
NACEPT notes that Sustainability  approaches are often most effective when focused on specific situations. One of the great advantages for many private sector companies has been defining a sustainability strategy  in context of their most relevant aspects.  For example, a textile manufacturer may be more focused on worker  conditions in small factories and an agricultural  based company may be more focused on nutrient loading to aquatic
ecosystems.  And yet, flexibility presents  a challenge for entities charged with achieving
mandated  missions and specific performance targets.  The US SSC should have the flexibility to set goals and objectives within logical context for different agencies and their jurisdictions.
EPA need not be the sole convener and leader.  NACEPT recommends a rotating chair, with work groups on specific topics and situations. In these efforts, as in internal  EPA work on
sustainability, the key is to focus on specific situations or opportunities, as well as on



       27 Acting as if Tomorrow Matters: Accelerating the Transition  to Sustainability- John C. Dernback, Environmental  Law
       Institute, 2012, page 83.
       28  For example, this group could provide direction and support to the National Institute of Governmental Purchasing28 (NIGP) in
       its effort to develop and implement a sustainability evaluation system for government suppliers of goods and services to be implemented in the U.S.


                                                                             19
                                                                               

                             



 596
 597

 598
broader strategies that would enhance and facilitate cooperative  work in particular communities, industries, and situations.


 599 	Recommendation 10.  EPA Should Establish A Stronger Role As Convener Of Sustainability
 600 	Discourse And Collaboration Involving Government And Society At Large.

 601 	EPA should expand its role as a collaborator  and convener with other government agencies and a
 602	wide range of stakeholders to develop, support and promote  initiatives to meet environmental and
 603 	human health goals beyond its specific regulatory/performance requirements29 ::    The importance of
 604 	these roles will continue to grow in an increasingly interconnected world in which many of the
 605 	most critical strands are beyond the nation's borders  and/or EPA's direct regulatory authority,
 606	even though critical to the Agency's broader  environmental mission.

 607

 608 	Capacity building within the agency should build on case studies of successful sustainability
 609	approaches such as the Kendall Station permit in Cambridge, MA. The Kendall Generating Station's
 610 	renewed water quality permit reflects integrated  and sustainable decision-making in that  an EPA
 611 	action in the water medium will yield positive outcomes in multiple media (water and air), as well
 612	as in the economic and social domains.  To meet Clean Water Act requirements, the Cambridge,
 613 	Massachusetts  plant needed to reduce its thermal loadings to the Charles River. However,
 614 	conventional cooling towers to reduce waste heat were too expensive and too big for the property.
 615 	Working in a collaborative fashion, the parties identified an innovative alternative solution: the
 616 	plant would sell its waste heat to homeowners in Boston, where the steam could be used to
 617	generate  electricity otherwise obtained from old, oil-fired boilers.  In addition to significantly
 618 	improved water quality and protected fish in the Charles River at lower cost, the arrangement will
 619	benefit neighboring communities in Boston by improving air quality and reducing illnesses like
 620 	asthma. In addition, the plant is expected to make money selling its waste heat and new jobs will be
 621 	created for workers  hired to build the pipe conveying the steam from Cambridge to Boston.

 622

 623 	EPA's broad geographic presence  enables extensive outreach  with external stakeholders to
 624 	incorporate sustainability considerations in its decision-making and disseminate  best practices.
 625 	EPA national headquarters and Regional Offices allow EPA a perspective and presence across all
 626 	industries,  all states, and comparison  to the accomplishments of other countries globally. EPA's
 627	national presence can facilitate information gathering, networking, and publicizing best practices


       29 EPA is already an effective convener and partner for sustainability in three different  ways. (1) Using its existing network of regional offices and affiliations  with State agencies, EPA has been increasingly active in convening and in helping to define and implement  local, state, and regional sustainability efforts; 2) EPA is helping to convene and participate in sustainability efforts with other federal agencies, (e.g. the E3 program and the EPA-HUD-DOT Smart Cities Effort.L and  {3) A third kind of convening/partnership is practiced by EPA programs that work with private businesses and other groups in programs like
       Energy Star, Design for the Environment and others.



                                                                             20
                                                                               
                             


 628 	among all stakeholders. Industry can bring practices  developed in ·one industry to another industry
 629	that may have a similar challenge.  Also, EPA can see the direction one industry may be headed in
 630 	and use that knowledge to better  understand the ecosystem impacts that may occur based on the
 631 	activities in other industries. EPA's strong regional presence  alo allows it to understand operations
 632	at the ground level. EPA may see emerging issues in one region that may not yet be apparent in
 633 	another region.  Lastly, very few of the global sustainability issues addressed will ultimately be
 634 	solved at the country level. Given the challenges of forging global compacts, it is important that EPA
 635 	understand best practices that may be emerging in other regions of the world, or, issues that may
 636 	be exacerbated  by the activities in other countries.

 637	Importantly, EPA has the opportunity to generate a more informed dialogue and more cooperative
 638 	collaboration  among all stakeholders (corporate, NGOs, academics, local governments) as
 639	sustainability becomes a common language and replaces rhetoric that has historically positioned
 640 	different stakeholders in adversarial positions.

 641

 642	CONCLUSION

 643 	The recommendations herein provide EPA a roadmap  for incorporating sustainability as central to
 644 	both its vision and mission, and practical steps that it can take to initiate this evolution quickly. Key
 645 	to EPA's success is ensuring a clear understanding of what sustainability means and how it
 646	complements and can improve its ability to derive innovative solutions and approaches to its
 647 	everyday regulatory, permitting,  research and education activities to propel this country to a more
 648 	sustainable America.

 649
 650

 651
 652
 653
 654
 655

 656

 657
Sincerely,





William Ross
















                                                                             21
                                                                               
                             


 658 	Appendix A: Summary of Work Teams Efforts

 659

 660 	The Strengths & Challenges team

 661 	Members: Ron Meissen (co-chair)Alison Taylor (co-chair)Fernando Abrufia}
 662 	Giovanna Di Chiro} Deeohn Ferris}  Sara  Kendall} Howard Learner} Trish Gallagher}
 663 	Ondrea Barber; John  DeVillars

 664 	Approach: conducted the following work to develop the  recommendations: The team
 665 	identified major areas of  strength at EPA related to sustainability including} air and
 666 	water quality}  brownfields} education} green building}  energy star} collaboration}
 667 	community engagement} infrastructure} as well as challenges} action opportunities and
 668 	developed recommendations.

 669

 670 	The Vision  & Breakthrough Objectives team

 671 	Members: Bridgett Luther (co-chair)Olufemi Osidele (Co-Chair)Erica Bannerman}
 672 	Kurt  Erichsen} DeWitt John} Robert Kerr} Judith Mazique} Mark  Mitchell} Bob Olson}
 673 	Yalmaz Siddiqui

 674 	Approach: conducted the  following work tasks:

 675 	Reviewed the  NAS Sustainability Framework

 676 	Reviewed EPA}s FY 2011- 2015 strategic plan


 677
 678

 679
 680
 681.

 682

 683

 684

 685
 686

 687

   11		Reviewed the  EPA website including mission and  2012/13 strategic plan updates
   11	Held conference calls with  a series of EPA senior staff including but  not limited to: Bicky Corman}  Derry Allen} Allison  Kinn-Bennet1 Stan  Meiburg} Vivian  Daub} Kathy O}Brien} Viccy Salazar
11	Held a Sustainability Visioning session

11	Brainstormed over  30 possible 3-5 year Breakthrough Objectives

11	Established criteria to select final  recomm'ended Breakthrough Objectives

   11	Obtained EPA input on viability of breakthrough objectives and  finalized recommended Breakthrough Objectives













                                                                             22
                                                                               
                             


 688
 689
 690 	Appendix B: Summary of Breakthrough Objectives Considered by NACEPT
 691
 692	Attach the large spreadsheet.
 693
























































                                                                             23
                                                                               
 #
Possible Breakthrough  Objectives
(cells shaded yellow represent wording variations on the objective in the row above)
Theme
Scope
 Screen in/out?

[Why?]
Evaluation criteria





                                        1
                                        2
                                        3
                                        4
                                        5
                                        6
                                        7
                                        8
                                        9
                                       10





                           Supports new EPA vision?
                    Implies new directions for the Agency?
                         Beyond current capabilities?
                    Improves performance throughout agency?
             Advances environment, social & economic benefits?
                                 Simple &
                         intuitively understand able?
                          Complete- able in 3-5 years
Measurable?
                 Can be broken down into goals and indicate rs
Able to scale up?
                                       1
EPA offices will create Zero waste by 2020
Enviro issue
Internal
In with change










 1a
By 2020 EPA will lead the US Government towards zero waste to landfill, and do so on a cost-neutral basis while creating millions of jobs
Enviro issue
Federal government
In

























                                                                              i
                                       2
EPA offices will be carbon neutral by 2020
Enviro issue
Internal
In with change










 2a
By 2020 EPA will lead the US Government towards carbon neutraility, and do so on a cost-neutral basis while creating millions of jobs


In










                                       3
EPA will work with priority industries to reduce water, carbon and waste emissions by 33% by 2020
Industry
Targeted external stakeholders
In










                                       4
By 2020 EPA will have facilitated 25 green infrastructure projects that deliver regulatory performance  comparable to conventional pollution control systems, but at lower costs, with higher conservation values and outcomes, and measurable  net  job creation.
Project
Targeted external stakeholders
In as detail










                                       5
By 2020, work with at least 10 firms in high carbon industries (steel, cement, aluminum, paper and plastic) to develop production and purchasing standards to incentivize energy and carbon efficiency to drive 25% reduction in C02 emissions from these firms -without reducing profitability or employment.
Industry
Targeted business stakeholders
In as detail










                                       6
By 2020, EPA will help America's industries achieve a 20%
reduction in
lifecycle environmental impacts, while improving their long- term economic competitiveness and job-creation potential
Industry
All industry
In- add detail










 6a
By 2020, EPA will help America's industries understand their lifecycle environmental impacts and help them on a path to
20% reduction in impact, while improving their long-term economic competitiveness and job-creation potential
Industry
All industry
In- add detail










 6b
By 2020, EPA will work with select industry sectors to help them understand their lifecycle environmental impacts, and develop plans to reduce their key impacts by 20%, while improving their long-term economic competitiveness and job- creation potential
Industry
All industry
In- add detail










 7
By 2020 EPA will help improve the level of environmental literacy in
American by training the next generation of environmental
scientists
 Education
Acedemia
In- Combined










 ?a
By 2020 EPA will help improve the nations understanding  of sustainability by educating every american student on the what it means and how to achieve it
 Education
Acedemia












  !



















































                                                                              - 	- - -

    #    IPossible Breakthrough Objectives	!Theme
       (cells shaded yellow represent wording variations on the bjective in the row above)

Scope

Screen
in/out?	2 	3 	4 	5 	6 	7 	8 	9 	10

      new EPA  I








      7b   !By 	, initiate programs  and strategies for educating citizens about the scientific support for and health benefits of sustainable economic  development and product selection







      Education   !Academia and Public
[Why?]







In­ Combined
      Implies 	Beyond 	Improves 	Advances 	Simple &    Complete-    Measurable?   Can be    Able to
       new 	current 	performance   environment,    intuitively    able in 3-5 	broken   scale up?
vision? 	directions    capabilities? 	throughout 	social & 	understand 	years 	down
      for the 	agency? 	economic 	able? 	into
                                                       Agency? 	benefits? 	goals and
                                                        indicate rs

    7c   IBy 	partner with the Department of Education to
Education

Select federal lin -

      develop grade/high school curricula designed to provide systematic environmental education with a goal of adoption by at least 5% of school districts nationwide by 2015.
agencies
Combined









        	, EPA will adopt decision-making screens at ensure actions are moving us toward the Agency's
      sustainability  program goals.

           		, initiate leadership  and set deadlines to lish the following:
      Validation of the Kyoto Protocols by publishing a timetable of carbon reduction targets consistent with our new scientific understanding  of global warming.
      b. Develop an international  database of cleanup technologies focused primarily on water and soil contamination.   ·
      c. Develop an international  database of closed loop industrial processes  with emphasis  on redefining the concept of waste. d. Review and put in place rules that create impediments to allowing one industrial processes  waste to become another processors feedstock.
      e. Partner with others in the international  community on cross border, cross-ocean contamination with a goal of a 20% reduction in shipments  of waste by 2015
      f. Define "technical nutrients"  (Non-toxic, non-harmful synthetic materials that have no negative effects on the natural environment and thus can be used in continuous cycles as the same product without losing their integrity or quality) and support projects that endeavor  to utilize and develop products composed  of technical nutrients.
      g. Distribute key messages  distributed through multiple channels  publicizing  the legitimacy of renewable energy, carbon-neutral  fuels and substitution of toxic substances into the environment.
Org &
culture


Enviro issue

 #
Possible Breakthrough  Objectives
(cells shaded yellow represent wording variations on the objective in the row above)
Theme
Scope
 Screen in/out?

[Why?]
Evaluation criteria





                                        1
                                        2
                                        3
                                        4
                                        5
                                        6
                                        7
                                        8
                                        9
                                       10





                           Supports new EPA vision?
                    Implies new directions for the Agency?
                         Beyond current capabilities?
                    Improves performance throughout agency?
             Advances environment, social & economic benefits?
                   Simple & intuitively understand able?
                          Complete- able in 3-5 years
Measurable?
                 Can be broken down into goals and indicato rs
Able to scale up?
 10
By  	, establish an EPA policy that requires its permitting and research and development functions to work together to stimulate the development of alternative chemicals  that would produce better more sustainable outcomes than those currently determined to be "legal".
Enviro issue
Internal
Out- general recommen
dation 	_,










 11
By  	expand the number of Energy Star and/or LEED type industry programs prioritized by environmental impact and degree of risk.
Program
Internal
Out- general recommen dation










 12
By  	direct the Office of Research  and Development
(ORO) to focus its research on "families of chemicals"  that have similar properties rather than individual chemicals.
Enviro issue
Internal
Out- general recommen dation










 13
By  	partnering with the Department  of Energy to evaluate "Clean Coal" to confirm its viability.
Enviro issue
Select federal agencies
Out- general recommen dation










 14
By 2020 create 'one EPA' by dramatically  increasing collaboration across departments  and creating joint programs focused on sustainability
Org &
culture
Internal
Out- move to org










 15
By 2020, inventory toxicity of all parcels of property in the
U.S.
Enviro issue
Targeted external stakeholders
Out- One issue










 16
Combine with others and include Environmental  Justice


Out- One issue










 17
By 2020, improve air quality to meet national standards without raising the price of electricity in ways that cause disproportionate impacts on 90% of affected low-income communities or closure I relocation of enough firms to cause "significant" reduction in local employment.
Regulation
Targeted external stakeholders
Out- One issue










 18
By 2020, have completed actions resulting the reduction of body burden, (the total amount of a chemical,  metal or radioactive substance present at any time after absorption in the body of man or animal), for EPA's top 50 chemicals  of concern
Enviro issue
Targeted external stakeholders
Out- One issue






















































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