Even as EPA Administrator Scott Pruitt works to roll back a host of Obama-era rules as a relatively short-term priority, he is preparing a set of medium-term plans for the agency’s budget and policy agenda that would remake the agency and institutionalize the Trump administration’s deregulatory agenda.
Among other things, the agency is crafting previously scheduled guidance for program managers for fiscal years 2018-19 that sets a host of goals and priorities and is also revising the Obama-era strategic plan for FY14-18 that makes climate change a priority, starting in FY18.
The revised strategic plan is likely to follow the outlines of the Trump administration’s budget request for EPA in FY18, which sought to slash EPA’s budget by 31 percent — even though lawmakers are not planning cuts that deep.
For example, House appropriators July 12 took an initial step toward providing EPA with $7.5 billion in FY18, a reduction of $528 million from FY17 but $1.9 billion above the Trump administration’s request.
One former EPA official who worked for Democratic administrations and has helped develop strategic plans says that Pruitt can revise the plan before the five-year cycle is up if he chooses.
“There’s no reason not to do that, and I think administrations typically want to get their arms around the strategic plan to make sure it is consistent with what they plan to do, so it is not particularly surprising that they would be focusing on revising the strategic plan,” the source says.
The former official adds that the possible effort to revise the plan early — and without early input from career staff — suggests that Pruitt may want to use it to “make a big splash and say, ‘The new guys are here, we’ve changed the agency’s mission and this is what we’re going to be doing.’”
While Pruitt is working to re-set priorities for EPA through FY18, the agency is also working on plans for FY19 and beyond.
The White House late last week released initial budget guidance for EPA and other agencies for FY19 that requires leaders to submit strategic planning documents for FY18-22 by Sept. 11, when their draft budget requests are due.
The July 7 guidance from Mick Mulvaney, director of the Office of Management & Budget, reiterated that EPA could see a slight increase over what the administration sought for FY18, suggesting the agency’s request would be no higher than $6.02 billion, a slight bump relative to the proposed $5.6 billion the administration sought for EPA in FY18, though Congress is poised to provide the agency with more than that.
Nevertheless, Mulvaney touts the FY19 request as an opportunity to present a “comprehensive plan” for “reforming” the government and cutting its workforce, telegraphing continued steep cuts despite signs of Capitol Hill blowback.
Mulvaney said he and other top officials will give “special consideration to bold reform reorganization proposals that have the potential to dramatically improve effectiveness and efficiency of government operations.”
“Agencies should develop agency priority goals that are near-term, implementation and outcome focused, measurable, and reflect the performance priorities of agency leadership,” Mulvaney said.
Program Managers Guidance
One of the first areas where EPA could begin to demonstrate how it plans to implement and prioritize its FY18 budget is its national program managers guidance. The agency late last month released draft national program managers (NPM) guidance for FY18-19 that detail proposed performance measures and other goals and priorities that agency managers are planning to meet in the coming fiscal years.
Among the goals, the agency indicated it plans to overhaul rules governing its new source review permit program, signaling that the Trump administration is backing widespread calls from industry and labor groups to reform the controversial permit program even before formal advice from the Commerce Department that is expected to seek such reforms.
While the Obama administration had shifted the NPM process to a two-year cycle for the 2016-17 period, David Bloom, EPA’s acting chief financial officer, said in a June 2 memo that officials “explored various options for developing this cycle of the NPM guidances in light of the transition to the new administration and the adjusted budget release date.”
But after consulting with a state-EPA work group, decided to “proceed with developing two-year NPM
guidances for FY 2018-2019 to maintain alignment with multi-year grant work planning.”
EPA also looks to be revising the current five-year strategic plan developed by the Obama administration. Although the current plan runs through the end of FY18, the agency is working to revise it one year early.
The current FY14-FY18 plan is heavy on climate change, so sources outside the agency expect that Pruitt would want to revise it as part of his long-term strategy to steer the agency away from the Obama agenda.
The current plan lists “addressing climate change and improving air quality” as the first of five goals. It also includes protecting America’s waters; cleaning up communities and advancing sustainable development; ensuring the safety of chemicals and preventing pollution; and protecting human health and the environment by enforcing laws and assuring compliance.
Bypassing Career Staff
An informed source says a draft version of the revised strategic plan was developed by Pruitt and his inner circle, and then sent to the White House before any agency staff saw it.
EPA’s press office did not respond to questions from Inside EPA about whether the strategic plan is being updated and timing of any update.
The former Democratic official notes that the description of how this update is being executed — first by Pruitt’s inner circle and then to the White House before staff sees it — is unusual and potentially worrisome.
“Normally, there’s sort of a bottom-up process for doing the strategic plan because it really contains a lot of nitty-gritty information on performance metrics and program outputs and quantitative measures for determining whether programs are succeeding or not. It is a very detailed, nitty-gritty document,” the source says. “The overall themes are important but a lot of the detail is, I think, not terribly interesting to most people . . . But Pruitt certainly has his ideas about what the agency ought to be doing and the existing five-year plan is not consistent with that.”
Yet, the “notion of doing it without a lot of input from the career staff . . . is sort of scary . . . because the plan is very granular and sets specific programmatic goals and performance metrics, and it’s tied into the whole system . . . of bean counting and performance tracking within the agency, and is also tied into the budget process.
“So I don’t see how you could pull a credible plan together without a lot of input” from career-level staff, the source says.
The Democratic former official cautions that the top-down approach means it is not a real strategic plan but instead would be more of a “thematic statement” and if they want it to tie the plan into the established system of budgets and performance reviews within EPA, then “they need to be pretty granular. I don’t know what they’re trying to accomplish here but I can certainly understand why Pruitt would not like the current plan. Among other things, it formalizes the role of climate change as one of the biggest and most important parts of the EPA’s mission.”
Finally, the source notes that it is difficult to write a good strategic plan when the budgetary parameters are unknown, as is the case now since the Trump proposed budget is vastly lower than what Congress is expected to approve.
A former Obama EPA official agrees, and notes that when Gina McCarthy became administrator in 2013, she developed a strategic vision that included seven themes to guide the agency’s work that was developed by top political appointees. But McCarthy and her top advisers did not see the FY14-18 strategic plan update until it was nearly finalized, and that effort was fully initiated and executed by staff.
This source agrees it would not be surprising if Pruitt is seeking to revise the strategic plan to seek to impose his long-term vision on the agency but questions whether he has enough staff in place to be able to explain the substance that would be needed in such a document.
Another former EPA official who worked for a Republican administration says that strategic plans do not usually receive a lot of attention and instead are “usually something that goes on a shelf unless someone needs it to make a political point” during a rule review.
The plans are generally not used for day-to-day business but instead for “waging more philosophical battles with the agency” as to whether its actions align with the plan, that source says. The plans are important but less so than budgets in terms of resources and priorities. — Dawn Reeves (firstname.lastname@example.org)
Editor’s Note: An earlier version of this story did not accurately describe revisions to EPA’s FY14-18 strategic plan.