White Papers Letters and Comments

The Environmental Compliance Consortium

Adobe Acrobat File 305 KB Measure to Comply, Measure to Perform
A Government Performance White Paper (Dr. Shelley Metzenbaum)
This paper discusses methods agencies can use to analyze the measurement data they gather. Performance measurement and reporting is on the rise in governments around the world, but too often is executed as a mindless response to a measurement mandate rather than as a management tool. This paper explores how agencies can use measures to identify problems that need attention and successes that warrant replication, and how they can use measurement to disseminate those findings and spread effective practices.

House website  Congressional Hearing on EPA and State Enforcement of Water Laws (October 2003)
PDF Document 52 KB  Testimony(Dr. Shelley Metzenbaum's testimony)
In October 2003, the House Committee on Government Reform Subcommittee on Energy Policy, Natural Resources, and Regulatory Affairs held a Hearing on EPA and State Enforcement of Water Laws. This hearing took place following press coverage suggesting that EPA and the states may not be adequately enforcing the nation's water laws. The testimony discusses the historical and remaining obstacles to effective implementation of water law and other environmental laws. It also discusses encouraging EPA and State efforts to use environmental and compliance information to effectively manage regulatory programs in ways deserving of Congressional support.

PDF Document 107 KB   ECC Comments on EPAs Watershed Initiative
The Environmental Compliance Consortium's comments on EPA Watershed Intitiative in July of 2002.

Word Document 39 KB   ECC Comments on EPAs Compliance and Enforcement Data Standards
Shelley Metzenbaum's comments on EPAs compliance and enforcement data standards, including compliance assistance data standards.

PDF Document 26 KB   New Hampshire's comments on EPAs Compliance and Enforcement Data Standards
Gretchen Rule's comments on EPAs compliance and enforcement data standards from the New Hampshire Department of Environmental Services.

Adobe Acrobat File 305 KB   Realizing the Value of a Permit Compliance System Upgrade
ECC working paper suggesting ways EPA might upgrade its Permit Compliance System.

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