The pages following
provide more detailed information on the following common performance
measures:
1. Federal housing assistance program
performance
2. Job Training and employment
3. Wildland Fire Management
4. Flood Mitigation
5. Participation in Disaster Insurance
6. Health
7. Environment (Note addition
to measures covered in guidance
letter above).
A. Rural
Water Project Performance
B. Non-Point
Source Water Pollution Program Performance
C. Wetlands
The above information was provided to affected agencies under separate
cover.
A Comparative
Measure of Federal Housing Assistance Program Performance
Description of the Measure:
The relative performance of federal housing programs with similar functions
and purposes can be assessed using a uniform cost-effectiveness measure.
This comparative measure is based upon a discounted net present value
of the subsidy costs required to serve an eligible family of a particular
income level over an extended period of time. This measure can be adjusted
for family size, household income, timing of occupancy, and other relevant
factors. This analysis uses a 30-year life cycle to conform to standards
in the housing industry.
This statistic of relative cost-effectiveness can be used to derive another
important measure of program performance – the number of households
served with any given level of budgetary resources. A more sophisticated
version of the measure might account, on the cost side, for displacement
of private investment and, on the benefit side, for the estimated value
of the housing units and their locations for the beneficiaries.
Applicable Programs:
This measure can be applied to a range of housing programs at HUD (Housing
Vouchers, Section 202 for the Elderly, Section 8 New Construction, Public
Housing, HOPE VI), as well as housing programs in other agencies, such
as Military Housing at DOD and Section 515 Rural Rental Housing Program
at USDA.
Analytical Issues:
The Federal government has, over the years, used an evolving set of programs
to address the affordable housing needs of lower-income households. Initially,
subsidy was provided for direct production of low-income housing. Beginning
in the 1960s, HUD used several combinations of subsidized or guaranteed
financing, construction grants, and ongoing rent subsidies to support
the development and operation of privately owned, assisted housing with
"project-based" subsidies. Currently, five major Federal programs
support production, including the Low-Income Housing Tax Credit, construction
grants for the Elderly and Disabled, revitalization of severely distressed
public housing under HOPE VI and local construction or rehabilitation
using HUD's HOME and CDBG block grants. Together these programs provided
$6.6 billion for subsidized production in FY 2001.
Beginning in the 1970s, a new form of tenant-based Section 8 rental assistance
was developed that has evolved into the housing voucher program. We would
expect a measure to help evaluate the relative cost-effectiveness of providing
housing assistance through a tenant-based or a project-based approach.
In doing so, the additional criteria should be considered:
Costs
- Targeting of resources.
- Minimizing substitution for private investment
- Long-term federal liability or exposure
Benefits
- Quality of unit and neighborhood
- Promotion of self-sufficiency
- Housing stability
An Example:
Attached is an example illustrating how this comparative measure has
been used to compare a set of housing assistance program models. The assumptions
are detailed in order to clarify how such an approach can account for
a wide range of factors and treat each approach in a similar manner to
facilitate comparison.
Description of Alternatives and Costing Assumptions
The following cost analysis compares four alternative ways to spend $5
billion to strengthen affordable housing efforts. Modeled on existing
programs, the four alternatives are (a) Construction using Project-based
Subsidies for Mortgage and Operating Costs, (b) Production Grants plus
Operating Subsidies, (c) Housing Vouchers, and (d) Low-Income Housing
Tax Credits plus Vouchers. In order to compare costs for different programs,
all costs have been discounted to their present value in FY 2002. To provide
a rough idea of how many households each alternative will reach, the cost
per household is then divided into $5 billion.
|
Present Value of Federal Cost Per Unit of Various
Subsidized Housing Alternatives
|
Net Present Value
|
Households
Served with $5B
|
Construction using Project-based
Subsidies for Mortgage and Operating Cost
(Modeled on former Section 8 New Construction) |
$123,409
|
40,515
|
Production Grants plus Operating Subsidies
(Based on Section 202 Housing for the Elderly) |
$131,973
|
37,886
|
| Housing Voucher Program |
$86,827
|
57,585
|
| Low-Income Housing Tax Credit Plus Vouchers |
$97,895
|
51,075
|
|
General Assumptions for Cost Comparison
- Net Present Value discount rate of 6.3%.
- Tenancy begins in FY 2005.
- Construction of project-based programs begins in 2002 and extends
through 2004.
- Operating costs and rents increase at GDP Price Index from OMB
Economic Assumptions (2 percent in most years).
- Amortization terms: 30-year loan at an interest rate of 9.0%.
- Households occupy 2 Bedroom units.
- National median income for FY 2000 is $45,180 adjusted for a
family that might occupy a two-bedroom unit.
- Tenant contribution is assumed to be $200/month for all alternatives.
|
A. Construction using Project-based Subsidies for Mortgage and Operating
Costs
Description:
Modeled on the former Section 8 New Construction program. Privately owned
and
operated multi-family housing projects would be constructed with long-term
rental
assistance and mortgage financing (either FHA or conventional). Tenants
pay 30% of
their income for rent.
Net Present Value: $123,409
Households Served with $5 Billion: 40,515
Assumptions:
- Total development costs estimated at $82,024 in 2002 dollars based
on Cummings and Dispasquale's research on the LIHTC program. There
are some concerns that these cost projections underestimate expenses.
For example, in a number of projects, land costs are not included.
- Total Development Costs amortized at 9% over 30 years.
- Operating Expenses estimated at $3,288 in 2002 based on FHA, Office
of Housing data. Similar estimate derived from Institute of Real Estate
Management data.
- Administration fee added 3% of gross rent.
- No net cost assumed for FHA-guaranteed financing.
- Tenant Contribution $200/month in 2002.
B. Production Grants plus Operating Subsidies
Description:
Based on the Section 202 Housing for the Elderly program. An upfront grant
covers all construction costs. Projects do not carry any debt service.
Ongoing operating costs are covered. Tenants pay 30% of their income for
rent.
Net Present Value: $131,973
Households Served with $5 Billion: 37,886
Assumptions:
- $79,417 production grant, expenses in equal amounts over three years.
- $4,222 operating expenses in 2002 based on 202 Project estimates.
C. Housing Vouchers
Description:
Vouchers cover the difference between 30% of recipient's income and local
Fair Market Rent. Vouchers provide access to the lower half of the private
rental market (roughly the 40th percentile of market rents). Portable
assistance enables tenants to move when their lease expires and retain
housing benefits.
Net Present Value: $86,827
Households Served with $5 Billion: 57,585
Assumptions:
- $5,950 per unit costs in 2002 dollars.
- Administration Fee of 3% included.
- Tenant Contribution $200/month in 2002.
- National average FMR in 2000 approximately $625 for a two-bedroom
unit.
D. Low-Income Housing Tax Credit Plus Vouchers
Description:
The LIHTC provides state-administered tax credits to private equity investors
in affordable housing. A small ($800) one-time capital grant is used to
encourage certain types of development, such as larger units in non-poverty
neighborhoods. Vouchers allow "worst case needs" households
to afford higher rent levels.
Net Present Value: $97,895
Households Served with $5 Billion: 51,075
Assumptions:
- Equal distribution of credit over 10 years.
- Tax credit $38,000 in 1996 dollars. (Cummings and Dipasquale)
- LIHTC rent for a household at 60% of median income is $678 in 2000.
- Administration fee added 3% of gross rent.
Job Training
and Employment
Comparison Measure
Last year we reviewed nearly 50 federal job training and employment programs.
That review showed that there was little consistency across programs in
measuring outcomes. That review also highlighted that not all job training
and employment programs provide the same services. Some programs focus
on classroom or on-the-job training; others on employment and re-employment
assistance; while still others include a combination of services. We also
found that few serve the same target populations. Some programs focus
on adults, some on youth and young adults, and others on special target
populations like veterans, the disabled, or American Indians. Even within
a particular group, certain programs may serve people with different economic
needs. But what was clear was that programs did not always measure what
is their primary goal—participants leaving their programs with a
job. The purpose of this proposal is to develop a common performance measure
that addresses the goal of getting a job for participants in all affected
programs.
While we recognize that some agencies may not have data now, over the
summer we will develop a framework and time line for getting the data
for performance on the primary outcome measure of getting a job where
those data are deficient or non-existent. Among other things, this will
involve ensuring we are measuring the same thing (e.g., "placement"
may be defined differently among programs), and we have common definitions
for these measures.
Agencies proposed to be involved in this common performance measure initiative
include the Departments of Labor (including its Workforce Investment Act
programs for youth, adults, and dislocated workers), Education (including
such programs as Vocational Rehabilitation, Vocational and Adult Education),
Housing and Urban Development (Youthbuild), Veterans Affairs (Vocational
Rehabilitation and Employment), and Interior (Bureau of Indian Affairs
programs). We are proposing four possible measures for program outcomes,
but are open to other possibilities. Three are outcome measures and one
is an efficiency measure.
Measure 1—Attainment of a job
To determine how effective programs are in meeting the outcome goal
of job training programs—placement in a job. Agencies would report
their methodology for measuring job attainment and the data collected
by them or by their grantees to determine what data exists, how and
when job placement is measured, and what proportion of participants
actually exit the program into a job.
Measure 2—Attainment of a certificate or degree by program
participants
To determine how effective programs are in meeting intermediate goals
that can lead to better jobs and long-term earnings. Even though the
primary outcome goal of job training and employment programs is a job,
a significant intermediate outcome measure can be whether a program
increases participants' skills needed to get and retain a job. We suggest
attaining a degree or certificate as a possible common measure since
this often is an intermediate step to another training or employment
program before gaining a job and, as such, is a reasonable indicator
for eventual success in the job market. As above, agencies would report
on data now collected and available and describe the basis for that
data.
Measure 3—Earnings gains
To determine whether programs have an effect on participants' earnings
compared to their earnings prior to program enrollment. While job attainment
has many benefits, having a job that doesn't pay more than the participant
was earning before program enrollment undermines the programs' long-term
outcome goal of improving employment and earnings. Agencies would report
on surveys or on other program data for this outcome.
Measure 4—Total program cost per placement in a job
This efficiency measure would aggregate total annual program costs (something
else that will need to be standardized) divided by the number of placements
in a job or in postsecondary education.
Wildland Fire
Management
Proposed Comparative Performance Measures
In response to the historic 2000 fire season, the Departments of the
Interior and Agriculture both received large increases in funding for
hazardous fuels reduction activities. In fact, fuels reduction funding
for USDA increased by 193% to $205 million while Interior funding increased
298% to $195 million. These increases are premised on the common sense
notion that around homes and communities in the wildland-urban interface
(WUI), it is better to prevent fires than to try and fight them after
they start. However, little data exists on how best to make these programs
effective at reducing these risks.
To improve performance, OMB proposes that the agencies develop common
measures to track and compare agency progress in reducing community fire
risks. Further, we reiterate the importance of developing measures that
focus on the efficiency of delivering a particular level of service (i.e.,
unit cost). Thus, the following measures also include a comparative measure
(with an implied efficiency objective) relating to fire preparedness and
suppression.
Measure 1: Percent of adjacent at-risk communities removed
from the at-risk list as a result of agency actions or assistance.
This measure would provide a direct assessment of the impact of federal
fuels treatment programs on reducing risks to communities and would allow
for a comparison of DOI and USDA efforts. Other assistance programs could
also be included, allowing for cross-comparison of the effectiveness of
various types of assistance.
In order for this measure to be useful, a number of questions must be
answered:
- Should the size of a community be a control factor or should communities
be grouped by size?
- What standards should be used to determine whether a community can
be removed from the at-risk list? The extent to which a buffer is
established around the community? Whether or not adequate defensible
space is created to allow firefighter access in an emergency?
- What agency actions or assistance should be included? Fuels treatments
only? Or other community actions resulting from federal assistance
programs like FIREWISE?
Measure 2: Completion of Fire Management Plans (FMPs).
This would include working with States on coordinated fire management
plans covering federal, state and local lands. The Forest Service previously
announced it would update its fire management plans by 2003, and then
altered the date to 2004. DOI has a similar target. This timeline could
be accelerated to achieve an earlier date in 2003. The agencies have
already established a Fire Management Planning Workgroup to ensure a
seamless, consistent, and coordinated approach to fire management planning
efforts.
Measure 2a: Percent of total acres burned that is managed
with wildland fire use. This is a byproduct of completed fire management
plans.
Ensuring FMPs are completed implies that there will be more opportunities
for fires to be allowed to burn within prescribed parameters. Managing
wildland fires for beneficial uses is usually much less expensive than
suppressing them, particularly over the long-term and in remote areas.
(This type of management requires that the agency or agencies have a carefully
crafted fire management plan in place.) Establishing this measure could
encourage the two agencies to improve development of fire management plans.
Measure 3: Average cost per fire and cost per acre burned
for large fires, small fires, WUI fires, non-WUI fires, management units
with current FMPs, and units without current FMPs.
Agencies would also be required to prepare explanations on procedures
used for any fires 50% above baseline. Agencies would also establish a
routine audits process to assess actual costs and reasons for cost increases
(checklist of actions and behaviors) whenever annual spending exceeds
thresholds.
The goal is to improve agency evaluation of the reasonableness of suppression
costs. The agencies need to establish procedures, whether in requiring
the use of cost-benefit analysis tools for field personnel in ordering
equipment, like tankers or helicopters, or establishing new national guidelines
on equipment usage. There are no incentives presently to hold down costs
in the field. In fact, the reverse is true. Moreover, there are concerns
that the agencies have used the fire program to fund broader needs (indirect
expenses, equipment purchases, construction needs, etc.).
Effectiveness
of Flood Mitigation Programs
Multiple Federal disaster programs attempt to reduce, or "mitigate,"
property damage caused by flooding. The Office of Management and Budget
has identified four programs that share this goal but that rely on differing
strategies.
- FEMA Hazard Mitigation Program (HMGP),
- FEMA National Flood Insurance Program (NFIP),
- U.S. Army Corp of Engineers (Civil Works) Flood Mitigation program,
and
- USDA Natural Resources Conservation Service (NRCS) Small Watershed
Program.
To evaluate the relative effectiveness of these programs, ideally agencies
should develop common performance measures that compare net societal benefits
against federal costs of a program. Since the full range of societal benefits
are very difficult to put in monetary terms, OMB recommends that a common
performance measure be developed to estimate net economic benefits (e.g.,
flood damages avoided), per Federal dollar spent. Note that there is a
similar comparison of benefit/cost measures in the Army Corps of Engineers
chapter of the FY 2003 Budget (page 295).
Benefits from Each Dollar Invested in Selected
Federal Flood Damage Reduction Programs
|
Corps of Engineers
|
Federal Emergency Management Agency's 404 Flood
Risk Mitigation (HMGP)
|
Department of Agriculture's Small Watershed Program
(NRCS)
|
|
$1.90
|
$2.30
|
$1.40
|
Because the four programs are designed and operate differently, the challenge
for agencies is to measure comparable benefits and costs. Attached is
a basic analysis of agencies' current benefit cost methodologies and guidance
on developing a benefit-cost measure for this exercise. OMB staff will
be available to work with agencies to help develop a common approach for
evaluating program effectiveness.
Discussion of Proposed Benefit Cost Calculations
The agencies should develop a measure of the ratio of net non-Federal
economic benefits to Federal budget costs. Mathematically, this means:
(Total project benefits—non-Federal costs)
Federal budgetary costs
For FEMA's Hazard Mitigation Grants Program (HMGP), the NRCS Small Watershed
Protection program and the Corps of Engineer's Flood Mitigation program
the primary benefits are avoided damage to property due to mitigation
measures. The estimate should be based on probabilistic estimates of flood
events. The non-Federal costs would include the non-Federal cost of the
project (e.g., cost share contributions). The net of the project benefits
and non-Federal costs would be divided by the Federal share of the project
costs. The cost of conducting assessment and feasibility studies as well
as operation and maintenance cost should be included in the project costs,
since it is necessary for completing a project.
For FEMA's National Flood Insurance Program (NFIP), the primary benefits
are also avoided damage to property due to mitigation measures. Again,
this estimate should based on probabilistic estimates of flood events.
FEMA currently calculates the value of avoided property damage resulting
from compliance with flood plain management requirements. However, it
is not clear what method is used to calculate benefits. The NFIP should
base its benefits calculations on the HMGP methodology, which uses time
value of money and probabilistic analyses.
For NFIP, the non-Federal cost is the cost of complying with the NFIP's
flood plain management requirements. Property owners must elevate structures
in the flood plain to the base flood elevation and make other structural
modifications, and local governments must expend resources to ensure compliance.
If it has not already, FEMA should conduct a standard regulatory analysis
of its flood plain management requirements. This should provide information
on costs identified above.
Unlike the other three programs, NFIP is fully funded by policyholders
and has no appropriated expenditures. FEMA should work to find a meaningful
measure of Federal costs, considering perhaps appropriated funds for its
flood mapping program which underlies its flood plain management activities
or the implied annual Federal subsidy to the NFIP.
For all four programs, agencies will need to develop a common metric
for measuring budgetary spending. Some options include the average cost
per project, mean cost per project, or average annual program expenditures.
Agencies should also agree on common time frame for referencing past spending.
Benefits and costs not covered by this analysis
Benefits and costs that cannot be easily put into monetary terms, such
as environmental costs and benefits are important aspects of these programs.
However, we currently do not have a good method of displaying these types
of effects in numerical terms that would be consistent across different
types of projects or programs. These benefits and costs are not included
in this measure. However, to the extent that non-monetary benefits can
be measured or described, OMB would like for those measures and descriptions
to accompany information on the economic performance measure.
Projects and programs may also have affects on property values and/or
future levels of development. Typically, these are not measured by the
programs. For example, a flood prone area that is protected by a project
may lead to greater confidence that flooding is unlikely in that area.
This may result in induced development or increased property values for
existing development. A program that takes property out of the market
to reserve it as floodplain, may also affect the value of that property
and the adjacent properties. These changes are not currently estimated
by agencies in project development for several reasons. First, changes
in property values and levels would be difficult to predict. Second, if
decisions about whether to proceed with a project to protect a flood plain
were made based on projected development rather than on existing development,
the Federal government would find itself subsidizing the elimination of
natural flood areas that serve important environmental as well as flood
mitigation functions. These types of changes are also not included in
the proposed performance measures. However, if there are data available
in this area, OMB would like to be provided with summary information.
Participation
in Disaster Insurance Programs
In response to market failures, the Federal government offers two forms
of disaster insurance—FEMA flood insurance and USDA crop insurance.
Yet despite the real risks of floods and other natural disasters, both
agencies face difficulties in maximizing the number of units covered by
their programs. FEMA does not regularly measure participation rates, though
past studies report a wide variance in participation. USDA's reported
participation rate averages approximately 75 percent. That is, 75 percent
of all crops eligible for crop insurance are actually covered. Efforts
to increase the participation rate by greatly decreasing the cost of such
insurance have not been successful. Despite increasing the federal subsidy
for such insurance by 96 percent over the last 5 years, participation
only increased by 16 percent. Instead, the increased subsidy has resulted
in participating producers shifting to higher levels of coverage, which
is an additional goal of the program. However, increased participation
in these programs is critical since insurance diminishes economic and
personal suffering of families and offsets the cost of direct Federal
disaster assistance. Importantly, program enrollment encourages the individual
policyholders to undertake risk-reducing measures rather than relying
solely on the Federal government's intervention.
To improve performance, OMB recommends that the Crop Insurance Program
and National Flood Insurance Program develop a common performance measure
for participation. Further, agencies should identify and share "best
practices" that contribute to improving participation. As part of
this process, OMB expects that agencies will consider factors such as
statutory purchase requirements, the role of private insurance partners,
the effectiveness of advertising, and subsidization and pricing of policies.
(Note that program participation must not be achieved by compromising
actuarial soundness.) OMB staff will be available to work with agencies
on this effort.
FY 2004 Health
Comparison Measures
Measure 1—DOD, VA, and HHS' Indian Health Service and Community
Health Centers
To quantify the resources expended on direct and Federally-funded health
care programs and better understand the cost differences, we propose the
following measure.
- Cost Measure: Per capita expenditures on direct and Federally-funded
health care services.
- Methodology: Agencies calculate actual expenditures divided
by the number of people served (each patient counted only once regardless
of number of encounters). Health expenditure data would include all
appropriated funds (including collections and reimbursements) for
facilities, personnel, equipment, and other ancillary services. This
would not include separate appropriations for research. In order to
adjust for differences in patient health status and case mix, the
Agencies will adjust the population numbers for age and sex differences.
Measure 2—DOD, VA, and HHS' Indian Health Service and Community
Health Centers
To assist with evaluating the efficiency of these programs, we propose
the following measure.
- Efficiency Measure: Average number of patients seen per day
per physician/nurse practitioner/physician assistant.
- Methodology: Agencies calculate the total number of patients
seen per year divided by the FTEE number of physicians/nurse practitioners/physician
assistants seeing patients, divided by the number of days care was
provided (i.e., work days). In order to adjust for differences in
patient health status and case mix, the Agencies will adjust the population
numbers for age and sex differences.
Measure 3—DOD and VA
To compare health outcomes, we propose the following measure.
- Quality Measure: Total number of readmissions for all patients
admitted for medical or surgical conditions, divided by the total
number of inpatient admissions for those purposes.
- Methodology: Agencies would calculate readmission rates for
inpatient admissions by measuring the number of patients readmitted
within a 72 hour, 15 day, and 30 day period after discharge, divided
by the total number of patients admitted during the year. In order
to adjust for differences in patient health status and case mix, the
Agencies will adjust the population numbers for age and sex difference.
Environmental
Common Measures
A. Comparative Measure of Rural
Water Project Performance
Description of the Measure:
The federal government administers at least five different programs that
serve the same dual objectives: to help communities located in rural areas
of the country to improve the quantity and quality of their water. Because
the programs may address different stages of water delivery, applying
a suite of measures can help in evaluating program effectiveness.
The results could aid a review intended to improve the government's efficiency
and
customer service in its efforts to address rural water issues.
We suggest a suite of three measures:
- Number of water connections per million dollars;
- Quantity of potable water delivered per million dollars;
- Quantity of water treated to EPA drinking water quality standards
per million dollars.
Although not every program would be able to use all of these measures,
every rural water program should be able to use at least one, providing
one comparison of program effectiveness. Different programs have different
desired outcomes; for instance, some programs focus on developing water
to spur economic growth, while others develop it for health reasons or
to meet regulatory standards. Our proposed measures are outcome-oriented
but would not handicap program comparability by being too specific.
Applicable Programs:
These measures can be applied to at least 5 programs that can be classified
as addressing rural water issues in the Departments of the Interior, Agriculture,
Housing and Urban Development, and Health and Human Services, and the
Environmental Protection Agency. A specific list is attached. There may
be other programs that we have not identified here which qualify as programs
that address rural water needs, and these should be identified during
the review.
Analytical Issues:
OMB has begun evaluations of rural water programs in the past, but they
were not followed through to completion. The first step in evaluating
these programs will be to conduct an inventory to identify all the programs
addressing rural water needs. Second, programs need to be assessed to
determine specific areas of redundancy. Despite serving the same goal,
an uncoordinated proliferation of programs has developed, based on the
different specific target groups. Some, such as the Bureau of Reclamation,
construct large storage, conveyance, and treatment facilities, which Reclamation
sometimes does on behalf of other agencies (for instance the Bureau of
Indian Affairs). Others, such as USDA's Rural Utilities Service, focus
on the needs of lower-income rural communities by providing loans and
grants to finance water facilities and hookups. Still others, such as
the Environmental Protection Agency's Drinking Water State Revolving Fund
(which serves all areas, not just rural parts of the country) provides
loans for drinking water infrastructure through a state revolving fund.
While each individual program may meet its mission in serving its clients,
these programs have developed in an uncoordinated fashion, resulting in
a number of policy problems. Establishing a suite of common performance
measures for these programs can help to evaluate their effectiveness,
and will aid in making decisions about program priorities.
Specific Methodology:
In general, project cost calculations should be on a net present value
basis.
- Number of water connections per million dollars. Many rural
water projects are designed to provide Municipal, Industrial, and
Residential (MR&I) water; therefore we should measure the total
extent of service provided to the community, not just number of families,
businesses, or government entities. Counting the number of water connections
should measure service to all of these.
- Quantity of potable water delivered per million dollars,
both gross and net, to account for programs that have a cost-share
component, or are reimbursable.
- Quantity of water treated to acceptable standards per million
dollars; similar to the water delivery measure, this should track
both gross and net costs.
| Department |
Agency |
Program |
| Agriculture |
Rural Utilities Service |
Water and Wastewater Loans and Grants |
| Housing and Urban Development |
Community Planning and Development |
Community Development Block Grants: State Program |
| Interior |
Bureau of Reclamation |
Water and Related Resources account, on a project-by-project
basis. |
| Environmental Protection Agency |
|
Drinking Water State Revolving Fund |
| Health and Human Services |
Indian Health Service |
Sanitation Facilities Program |
B. A Comparative Measure
of Non-point Source Water Pollution Program Performance
Description of the Measure:
The Federal Government administers several programs aimed at reducing
non-point source pollution. Since the Clean Water Act became law in 1972,
water quality has dramatically improved in many areas. However, these
gains came largely from reductions in the discharges of point sources,
leaving non-point sources as the largest remaining water quality problem.
Without a significant reduction in non-point source pollution, it is unlikely
that water quality will further improve.
A comparison of the effectiveness and efficiency of Federal non-point
source programs could be helpful in targeting limited resources. The ideal
situation might be to compare programs that address different impacts
to a river or waterway, such that you can compare the relative impact
of a program to reduce sediment loading with one that is designed to reduce
nutrient loading.
We suggest the following measures:
- Tons of sediments reduced per million dollars.
- Pounds of nutrients reduced per million dollars.
- Estimates of the percentage impact of agency actions on exceedences
and contaminant occurrences.
Applicable Programs:
These measures can be applied to the Section 319 Non-point Source Management
Program (EPA), the Environmental Quality Incentives Program (USDA), and
the Conservation Reserve Program's continuous signup (USDA).
Analytical Issues:
EPA's 319 Non-point Source Management Program supports a wide variety
of activities including technical assistance, financial assistance, education,
training, technology transfer, demonstration projects, and monitoring
to assess the success of specific non-point source projects. USDA's Environmental
Quality Incentives Program (EQIP) provides educational, financial, and
technical assistance to farmers and ranchers to implement conservation
practices on land currently in production. Eligible water quality practices
include animal waste nutrient and pesticide management, as well as livestock
water development projects. The continuous signup option within USDA's
Conservation Reserve Program (CRP) provides farmers with financial and
technical assistance to enroll acres to prevent water resources and install
conservation practices such as riparian buffers, grass waterways, and
filter strips.
Work is needed to identify the components of each program and determine
whether only a subset of each program should be compared. Data must be
collected on easements and acquisition costs, and other various practices.
Estimates of sediment and nutrient reductions must be ascertained from
models if real monitoring data are not available. A NOAA study of the
economic costs and benefits of methods to reduce nutrient loads in the
Gulf of Mexico relied on modeling data from USDA's Economic Research Service
(U.S. Mathematical Programming Model) as there was limited real data available.
A comparable baseline is needed across programs. Program data sources
must be identified and reviewed. A literature search of academic and government
studies should be conducted to determine if any previous work in this
area would be helpful. Consideration should be given to whether other
Federal or nonfederal non-point source programs should be included in
the comparison.
Specific Methodology:
Below is a methodology to compare programs such that you can compare
the relative impact of a program to reduce sediment loading with one that
is designed to reduce nutrient loading.
- Show nutrient levels. Identify loads by land use (i.e., farmlands,
forests, and urban/suburban). Show total phosphorus in streams by tons.
Also show total phosphorus in streams by gradient.
- Show sediment levels. Identify loads by land use. Show total sediment
in streams by tons and group streams by sediment load. For example,
X percent of streams have loads of Y tons. Appropriate outcome measures
for sediment loading needs to be further developed.
- Data sources: U.S. Geological Survey National Water Quality Assessment
Program for inland streams and rivers and EPA's Environmental Monitoring
and Assessment Program for coastal areas.
- By program, by year, and by land use estimate the tons of sediments
reduced per million dollars; estimate the pounds of nutrients reduced
per million dollars.
C. Program Comparisons on
the Environment—Wetlands
Programs
The Army Corps of Engineers construction program, Mississippi River and
Tributaries program, and regulatory program; the Louisiana Coastal Wetlands
Planning, Protection, and Restoration program; the Natural Resources Conservation
Service Wetlands Reserve program; the Fish and Wildlife Service Partners
for Fish and Wildlife program, Coastal program, Coastal Wetlands program,
North American Wetlands Conservation Act program, and National Wildlife
Refuge System; National Oceanic and Atmospheric Administration programs
whose principal purpose includes the protection or improvement of wetlands;
and the programs of a representative group of non-Federal entities.
Metrics
- Total wetlands acres established or re-established in FY 2001 as a
result of agency action.
- Total wetlands acres that will be lost (before mitigation) as a result
of FY 2001 agency action.
- Acres of wetlands (1) established, (2) re-established, (3) rehabilitated,
(4) enhanced, and (5) protected/maintained in FY 2001 primarily as a
result of agency action, per $1 million in total costs.
- Additional acres of wetlands (1) established, (2) re-established,
(3) rehabilitated, (4) enhanced, and (5) protected/maintained in FY
2001 primarily as a result of action by representative non-Federal entities,
per $1 million in total costs.
- The quality of the wetlands (1) established, (2) re-established, (3)
rehabilitated, (4) enhanced, and (5) protected/maintained.
Methodology
- In characterizing the wetlands action (i.e., established, re-established,
rehabilitated, enhanced, or protected/maintained), use the definitions
developed by the Committee for Defining and Tracking Wetlands Gains
and Losses of the White House Wetlands Working Group (1999)(attachments).
For metric #1, do not count the restoration of farmed wetlands.
- Provide a copy of any ranking factors that the agency uses to select
the sites to be acquired or improved.
- For metrics #1, #2, and #3, include only wetlands actions completed
in FY 2001. For metric #2, include the losses that will result from
decisions reached in FY 2001 (e.g., a permit issuance, or a construction
start of a project that will result in wetlands losses before mitigation).
- For metrics #1, #2, #3, and #4, do not include acres of related
non-wetlands habitat.
- For metrics #3 and #4, estimate the average cost for each of the
five categories of wetlands action. Present all costs using October
2001 price levels. Estimate the full cost (Federal and non-Federal)
of the action, including administrative and supervisory costs; overhead;
technical assistance; engineering and design. Display Federal and
non-Federal costs separately. Show land acquisition costs and provide
a separate annual cost estimate for any long-term operation, maintenance,
or monitoring.
- For metric #3, the Army Corps of Engineers regulatory program may
limit its estimates of average costs to the permits that involve 5
acres or more of compensatory wetlands mitigation. It should develop
its estimates through a statistically valid sample of wetlands banks
operators or by reference to other reliable data. Include the applicant's
cost to develop a mitigation plan and to collect supporting data,
and all costs incurred by the Federal and State agencies that review
the permit application.
- For metric #3, in addition to estimating the average cost of all
wetlands actions, each agency should submit a table with acreage and
cost data on each action involving 15 acres of wetlands or more. Please
identify the type of wetlands involved using the Cowardin, Carter,
and La Roe classification system (http://www.fws.gov/stand/standards/cl_wetl.html),
and indicate how the agency scored the action under its ranking system
(if any). Also, please prepare a graph showing the distribution of
the actions listed on the table by cost (in acres per $1 million)
and a brief assessment of the justification for any of these actions
that cost more than twice the agency average on a per acre basis.
- For metrics #1, #2, and #3, the Army Corps of Engineers should combine
its submission for the construction program and Mississippi River
and Tributaries program, but separate the data on ecosystem restoration
projects from the data on compensatory mitigation actions.
- The Fish and Wildlife Service will be responsible for metric #4.
For this metric, it should treat the value of any land rights donated
to non-profit entities as a non-Federal cost, and should include the
value of any tax credits associated with such donations as a Federal
cost.
- The Army Corps of Engineers will be responsible for providing data
on the Louisiana Coastal Wetlands Planning, Protection, and Restoration
program.
- On metric #5, the agencies will work with the Office of Management
and Budget to select two or more geographic or regional areas for
a qualitative, comparative evaluation of each agency's efforts.