19
by program. EPA officials acknowledged, "Some EPA oversight practices resulted in
duplication of effort, burdensome reporting, and unproductive relationships."
58
One set
of NAPA researchers predicted:
“…EPA is unlikely to be able to efficiently and effectively maintain two
distinct and separate systems of program oversight and management. If
NEPPS is to continue to make progress toward its original vision, states
and regions operating under NEPPS cannot simultaneously meet the
requirements of both NEPPS and the traditional system.”
59
A similar observation came from a second NAPA report:
“One reason NEPPS has not succeeded is because it could not change the
system of guidance and memoranda of understanding. Instead of a new
way of facilitating exchange and trust, it became an overlay on deeply
entrenched systems, processes and attitudes. Some headquarters and
regional program managers simply refused to abandon the established
practice of negotiating detailed EPA-state agreements about specific
activities the states would conduct. Some regional officials did agree to
eliminate workplans, but when headquarters asked regions to deliver
certain activities, officials passed those requests on to state agencies,
making it clear they expected action regardless of what NEPPS documents
said.”
60
The arrangement of the EPA, with a single headquarters and ten regional offices,
complicates efforts to "get the word out" to all frontline regional staff. However, more
than geographic distance seems to exist between EPA headquarter and regional officials.
EPA regional officials in specific programs (such as air, water, hazardous waste) ongoing
compliance problems in state programs necessitated close oversight. EPA regulators
were reluctant to reduce oversight without assurance that state would maintain
enforcement efforts.
Even at EPA headquarters, offices divided sharply on the level of state oversight.
The Office of Enforcement and Compliance Assurance was particularly vocal in support
of pre-NEPPS oversight system to ensure adequate enforcement. Officials felt that
Convention