Member State Projects

ECC member states are involved in a number of internal projects and experiments designed to help them better manage their compliance and enforcement programs. Some of these projects are described below.

A One-Page, Outcome-Focused Strategic Plan from the Minnesota Pollution Control Agency

The Minnesota Pollution Control Agency (MPCA) has recently undertaken efforts to streamline its processes, align its programs and processes with outcome-based goals, and communicate these goals more effectively. MPCA Commissioner Sheryl Corrigan shared with the ECC a one-page version of the MPCA's strategic plan. This "Goal Tree" illustrates how MPCA's mission, guiding principles, vision, goals and objectives roll-down and back up into a coherent set of outcome-focused objectives guided by the mission and vision for the agency. Minnesota Pollution Control Agency's One-Page Goal Tree/Strategic Plan

Colorado's SCORE Pilot Project Finds Benefits of Self-Certification

The Hazardous Materials and Waste Management Division (HMWMD) of the Colorado Department of Public Health and Environment needed to find a way to regulate about 1,100 small quantity generators (SQGs) with a small staff of 4.6 full-time equivalent inspectors. They decided to develop a project to see if self-certification would be an effective, efficient, and accurate method for assessing SQG compliance. They asked SQGs to self-assess and self-certify by filling out a checklist of all applicable regulatory requirements prepared by HMWMD for the project. After receiving the self-certifications, inspectors followed-up using identical checklists.

The project found self-certification to be an effective way to assess compliance, as well as an efficient and accurate way to obtain valuable data not previously collected, such as compliance rates and waste generation rates. The project concluded that self-certification can improve the regulation of the SQG universe by making it easier to provide compliance assistance targeted to specific problems and facilities. The project also found that most facilities completed the checklist in less than one hour and that the self-certification process helped re-familiarize personnel with hazardous waste requirements.

Because of the program's success, the Division plans to propose regulations requiring SQGs to self-certify every two years, similar to large quantity generators. The final report was published January 2004 and is available at Colorado's website:  Colorado's SCORE Pilot Project.

Sampling and Scouting: Promising New Approach to Managing Programs with Many Regulated Facilities

Many environmental protection programs share a problem: the need to ensure compliance by far more regulatory facilities then they have staff to inspect. A recent experiment by the state of NH suggests a practical, effective, and affordable way to tackle this problem. It is worthy of replication in many other programs and by many other states.

The state hired and trained workers to conduct partial inspections of a set of facilities that had been selected by statistically valid random sampling methods. The workers visited the randomly sampled facilities to determine their performance on 10 dimensions its experienced inspectors had identified as important. (Seven of theses were compliance obligations of the facilities and three were pollution prevention practices.) The sampling inspectors noted what they found -- indicating a yes for each dimension where a facility was in compliance or had adopted a pollution prevention measure and no where it had not. When a sampling inspector found a problem that looked serious, an experienced state inspector was called in to conduct a full inspection of the facility. At the same time, the sampling inspector dropped off information to each facility about its compliance obligations.

This approach to managing a regulatory program with a large number of facilities had many benefits. First, it allowed the state to get an accurate assessment of the overall compliance rate for its program, as well as a sense of the nature of noncompliance (and pollution prevention patterns.) If the state conducts sampling inspections every year, it can get a sense of compliance trends over time. Second, the sampling inspectors served as scouts, getting to a larger number of facilities then experienced inspectors could reach, helping them to find serious problems at facilities they would not have otherwise visited. Third, the sampling inspectors visited facilities that had never previously been visited, and was able to provide them with compliance assistance information they had not previously received.

This experiment provides a valuable model for others; indeed, the state of Connecticut is now experimenting with an adaptation (facilitated by meetings coordinated by EPA Region One.)attached The NH experiment also benefited from a previous experiment conducted in Massachusetts, the Environmental Results Program. It learned from the ERP experience how useful it can be to code individual compliance characteristics consistently over time to show more precisely the nature of noncompliance, allowing “treatment” with a more tailored intervention.

The project report for New Hampshire's RCRA Compliance Measures Project describes the costs, benefits, and compliance rate results and is available at New Hampshire's website:  Compliance Measures Project. Information about Connecticut's efforts to use partial compliance evaluations to enable programs to cope with many regulated facilities are available here: compliance survey fact sheet for facilities, UST survey, RCRA survey, SOPs for interns, intern job description, facility acknowledgement form.

Grants from EPA's OECA (Office of Enforcement and Compliance Assurance) provided funding for both projects.

Pennsylvania Surveys 50 States to Analyze Complaint Management

The Pennsylvania Department of Environmental Protection conducted a survey of 50 states to determine how state environmental agencies handle citizen complaints. The specific goal was to compile a list of performance measures that could be used by other states' managers as an idea resource. The survey also collected data on the following: if each state currently tracks complaints, and if so, in an automated system; if the historical data is formally analyzed; if the data is used to forecast future complaints; and the methods states use to communicate complaint results to citizens.

  Are Environmental Complaints from Citizens of Any Value? (ECOStates, Spring 2004)
  Pennsylvania's 50 State Complaint Management Survey
  Pennsylvania's Complaints Analysis

Connecticut Assesses Compliance with General Permits

With grant funding provided by EPA, Connecticut objectively assessed industry compliance with the General Permit for the Discharge of Minor Tumbling or Cleaning of Parts Wastewater ("tumbling general permit"). The tumbling general permit requires registrants to monitor for certain pollution parameters at a particular frequency, maintain the analytical results at the facility, and make them available to the Commissioner immediately upon request.
  Connecticut's General Permit Program Compliance Initiative (description)
  Connecticut's General Permit Program Compliance Initiative (presentation)
  Connecticut's General Permit Program Compliance Initiative (analysis)

Maine Measures Emission Trends at Wastewater Treatment Plant

Maine analyzed a wastewater treatment plant for trends in 13-year monthly average emissions of fecal coliform, BOD volume and concentration, TSS volume and concentration flow, and TRC concentration emissions. The pollutant levels are graphed as a percentage above or below that pollutant's license limit. They are graphed from 1990 through 2002.
  Freeport, Maine Wastewater Treatment Plant Emission Trends

Making the Case to the Legislature: How Minnesota Persuaded Its Legislature to Restructure Environmental Agency Funding

Faced with a large budget shortfall for fiscal year 2004-2005, the Minnesota Pollution Control Agency (MPCA) needed to decide where to cut its budget. To help it determine environmental priorities, it decided to survey citizens and stakeholders. (Survey details and findings are available at: http://www.pca.state.mn.us/about/funding-materials.html )

Unfortunately, even though the survey results helped the MPCA determine the state's top environmental issues, the structure of the agency's budget did not allow the agency to modify its spending to address these issues or to change its priorities as problems were solved. MPCA realized it needed to persuade the state legislature to revise the agency's funding structure to make it more flexible and responsive to changing environmental needs. To make its case to the legislature, the MPCA used the survey data and diagrams to explain the budget structure story to the legislature.

The agency's use of citizen input and its creative use of diagrams proved successful-the legislature approved the agency's proposed solution. This article summarizes how MPCA did it. More detailed information explaining how the Minnesota PCA successfully communicated its need to its legislature is available on the agency's web site: http://www.pca.state.mn.us/about/funding.html
  Making the Case to the Legislature: How Minnesota Persuaded Its Legislature to Restructure Environmental Agency Funding

Updated April 27, 2005

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