Appendix II Comments From the Environmental See comment 6 programs are improving through time, and does not believe that the forecasted program impacts are optimistic. As mentioned previously, the program impact is increasing rapidly: 40 percent of the program's current accomplishments have been generated by upgrades that were reported within the last year, despite the fact that the program is 6 years old. Finally, I would like to point out that the draft report inaccurately uses the Energy Information Administration's (FIA's) survey of commercial floorspace to suggest that EPA overstates the reductions achieved by the Green Lights program. The EIA survey is based on 1992 data. EPA only measures additional energy savings for the Green Lights program that would be above and beyond the pre-existing "conservation features" identified in ELA's survey. Also, as we have noted to you in the past, EIA has only asked respondents to indicate the presence of some energy conservation features in their buildings. They have not evaluated the effectiveness of these energy conservation features. In fact, EIA found that the energy intensities for buildings with conservation features, as defined by ELA, are "the same or even greater than the energy intensities of buildings without those features" (p. 11). In contrast, Green Lights program partners are, on average, reducing their lighting energy consumption by 48 percent through comprehensive lighting retrofits. There are some additional numbers and references that appear somewhat inconsistent with information that we have provided to you. My staff is providing these clarifying comments separately. Sincerely, Paul St Paul M. Stolpman Office of Atmospheric Programs GAO Comments The following are GAO'S Comments on the Environmental Protection 1. When we began our work on this assignment, one of our objectives related to the types of performance measures used for EPA's climate change programs. As agreed with the requesters' offices, we did not pursue this issue in detail. However, our report does provide information about EPA's performance targets, collection of data from participants, and related matters. 2. As part of our review, we considered the Office of the Inspector General's (OIG) report. The OIG's report differs somewhat from our report in terms of both scope and objectives. Whereas we reviewed only voluntary climate change programs, the OIG reviewed voluntary climate change programs, as well as the Radon Action Program, which is not related to climate change. In terms of objectives, we focused exclusively on the reported and projected reductions of greenhouse gas emissions for the four climate change programs. The OIG's objectives were to determine (1) the management practices that worked well and areas in which improvements are needed and (2) whether voluntary programs achieve environmental benefits. Although the second OIG objective sounds similar to our objectives, the OIG did not attempt to determine whether nonprogram factors may account for some of the reductions reported by EPA. The OIG's report states that "it is difficult to directly attribute changes in the environment to a particular statute, regulation, or program." For these reasons, we believe that the OIG's report is not directly comparable to ours, and we therefore did not change our report to address this comment. 3. EPA noted that measuring the success of programs to bring about change in specific markets is difficult. We agree. EPA characterized its approach in estimating the effects of its programs as "conservative" and stated that the "true program impact of the Green Lights program is likely much larger than the reductions reported by EPA. While EPA states that the program's total impact is likely to be much larger than its reported impact, this can be true only if the unreported reductions that are due to the program are larger than the reported reductions that are due to nonprogram factors. However, EPA has not attempted to measure either of these indicators. With respect to the issue of evaluating the net effect of the Green Lights Appendix II Comments From the Environmental means of measuring" the program's total impact. Successful completion of this study and implementation of its suggestions should help ensure that, in the future, there will be more reliable information on the program's gross and net impacts. 4. EPA raises questions about both the purpose and the results of our discussions with the organizations that participated in the Green Lights Program. The purpose was to ask them about their experience with the program, including the extent to which the program contributed to their lighting upgrades. By contacting only those organizations that had participated successfully, we were dealing with a group that was likely to be relatively favorable toward the program. The result of the discussions was that, rather than exhibiting perfect hindsight, as EPA's response suggests, all gave credit to EPA for providing valuable and reliable information and for being responsible for some or all of their upgrades. We believe this information, along with the other information presented, supports the point that only some, but not all, of these organizations' upgrades were due to the program. 5. With respect to possible improvements in the program's effectiveness, we presented data from EPA on results through 2 years for organizations that joined in 1995 (the class of 1995). The future implications of this reported improvement are unclear for two reasons. First, we also noted that, unlike the four previous classes, the class of 1995 was the only one to meet EPA's goal of upgrading 18 percent of upgradable floorspace after 2 years. Second, the reason for the improvement is not clear. EPA claimed that its improved efforts accounted for the improvements. However, it is also possible that a change in reporting practices may have contributed to the reported improvement. Specifically, starting in 1993, organizations joining the program were permitted to claim credit for upgrades they had completed prior to joining the program. Initially, they were permitted to claim credit for upgrades made in the previous 12 months; later, they were permitted to claim credit for upgrades made in the previous 18 months. Thus, the larger reported results for the class of 1995 may, in part, reflect a change in reporting practices. 6. We cited the 1992 Energy Information Administration's survey data for the same reason we interviewed former participants (see comment 4). We wanted to see whether there was evidence that companies with commercial office space were undertaking energy audits and installing energy-efficient lighting independent of the Green Lights Program. The survey data confirmed that there was substantial activity in the years Appendix II Comments From the Environmental before the program was established. If energy-efficient lighting was installed in some buildings before the program was established, we believe that energy-efficient lighting installed afterwards in other buildings may have been due, at least in part, to nonprogram factors. Appendix III Scope and Methodology As agreed with your offices, of th› Environmental Protection Agency's To address our objectives for all four programs, we met with EPA program In addition, as noted below, we discussed the programs with selected current or former participants and nonparticipants. Although we tried to select a mix of organizations, in terms of size and geographic location, the organizations we contacted may not be representative of all such organizations. Finally, as noted below, we used other data sources. For the Green Lights program, we interviewed officials at seven former participants, which had graduated from the program, about their motivations for joining the program and their experiences in the program. We picked these seven from a list of about 300 program graduates provided by EPA. The seven included small, medium, and large organizations, which are located in various regions of the country and are in different industries. Because program officials said they were concerned that our contacting current Green Lights participants might discourage participation, we did not contact any current participants. We also interviewed officials at two major corporations that were not participating in the program, to determine whether they had undertaken |