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The third challenge facing IRS and the National Taxpayer Advocate is to develop performance measures to be used in managing operations and assessing the effectiveness of the Office of the Taxpayer Advocate and PRP . The proposed change in the standards – to – permit derivation procedure is the result of two consultants ’ reviews of the existing procedure and the Iowa Water Pollution Control Association ’ s ( IWPCA ) concerns that the existing procedure produces overly conservative ( i.e ., too stringent ) permit limits for some facilities . The second challenge facing IRS and the National Taxpayer Advocate is to strengthen advocacy efforts within the Advocate 's Office . ( ICANN also suggests on this page that you participate through one of the Supporting Organizations or the At Large Advisory Committee , neither of which we have studied closely in preparing this report . The first challenge facing IRS and the National Taxpayer Advocate is the need to address staffing and operational issues while ensuring the independence of the Advocate 's Office . The State 's cost allocation plan adequately captures administrative and program costs at the varying percentage rates depending on the specific types of activities being performed or the specific JOBS component or supportive service being purchased . Growing scarcity and the decline in water quality clearly challenge the viability of traditional technical solutions and show that a global , multidisciplinary approach is urgently needed .