Dacambar 1ST74
A MANAGEMENT ASSISTANCE STUDY
THE ENVIRONMENTAL PROTECTION BRANCH
THE MICHIGAN DEPARTMENT OF NATURAL RESOURCES
By. Qavtd Ackacman
Don Jacobs
Cliff Steward
Ward Stonaman
Lao Waiabackar
Prapard by Standford Raaaarch Inatttuta fen
U.S. ENVIRONMENTAL PROTECTION AGENCY
CHICAGO, ILLINOIS 60604
EPA Contract No. 6B-O1-1S64
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
230 SOUTH DEARBORN STREET %
CHICAGO, ILLINOIS 60004
DEC 311974
Me. Ralph Purdy
Deputy Director
for Environmental Protection
Michigan Department of Natural Resources
Steven. T* Mason Building
Lansing, Michigan 48926
Dear Me* Purdyr
The enclosed final report entitled "A. Management Assistance Study
For The Environmental Protection Branch of the Michigan Department
of natural Resources", has been prepared by the Stanford Research
Institute. It is a source of satisfaction to us to have been in the
position to provide this font of assistance to you and your staff*
The study provided an opportunity for your staff managers to do some
introspective examination of their functional relationships as they
relate to their program objectives, activities and interface with
other public and private organizations* X believe that the report
provides thoughtful perspective on concepts of inter-relating our
roles in such a. way as to be responsive to die- mandates given us as
administrators of the environmental protection programs by the citizens
of Michigan* Society's recognition of die long overdue need to plan
for effective use and management of our natural resources must be
addressed by us In a timely and responsive manner.that will assure
the public that we are t-afc-t^g a comprehensive and balanced approach.
to die successful resolution of abating pollution, and protecting
die quality of our environment where it is yet unspoiled and where
pollution has been abated*
The report offers rationale and an approach to manage human resources
in accomplishment of die Department's environmental protection objectives.
In die final analysis of determining how and when to Implement acceptable
recommendations resulting from a management assistance study, a certain
amount of pragmatic judgement must be applied.
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DEC 311974
We recognize this and hope that to the extent appropriate, implementation
activities will be pursued in the near future.
We wish you continued success in building and managing an effective
effort to accomplish the environmental quality goals of the State of
Michigan.
Sincerely,
• ). ,
IMoMtr
A
Regional Administrator (J
ii
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CONTENTS
LIST OF ILLUSTRATIONS v
LIST OF TABLES vii
I INTRODUCTION 1
II EXECUTIVE SUMMARY 7
Management Operations Findings 8
Management Review Recommendations 9
Technical Operations Findings .'.... 9
Technical Operations Re'commendations 10
Manpower and Personnel Findings 10
Manpower and Personnel Recommendations 11
Intergovernmental Process Findings 11
Intergovernmental Process Recommendations 12
Stakeholder Processes^ Findings 13
Stakeholder Processes Recommendations 14
III ANALYSIS OF PRESENT ORGANIZATION 15
Present Organizations 15
Manpower and Personnel 45
Intergovernmental Affairs 50
Stakeholder Processes in Environmental Protection 54
IV TECHNICAL OPERATIONS 59
V FINDINGS AND RECOMMENDATIONS 69
Management Review Findings 69
Management Review Recommendations 82
Technical Operations Findings 85
Technical Operations Recommendations 88
Manpower and Personnel Findings 91
Manpower and Personnel Recommendations 93
Intergovernmental Process Findings 94
Intergovernmental Process Recommendations 96
Stakeholder Processes Findings 98
Stakeholder Processes Recommendations 100
iii
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ILLUSTRATIONS
1 The Present Organization 17
2 Hydrological Survey Division 19
3 Funds Control in the Hydrological Survey Division .... 26
4 Water Development Services Division . . . 28
5 Water Quality Control Division 33
6 Municipal Wastewater Division 37
7 Air Pollution Control Division 43
3 Manpower Planning System ...... 48
9 Branch Budget System 73
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TABLES
1 Hydrological Survey Division 20
2 Hydrological Survey Division Functional Breakdown .... 22
3 Water Development Services Division Functional Analysis
of Work 29
4 Municipal Wastewater Division Functional Breakdown .... 39
5 Solid Waste Division Functional Breakdown 42
6 Air Pollution Control Division Functional Breakdown
Estimated Report by APCO 44
vii
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I INTRODUCTION
In June 1973, a management assistance study oriented to the responsi-
bilities and needs for organizational accountability of the newly estab-
lished Environmental Protection Branch within Michigan's Department of
Natural Resources was funded by the United States Environmental Protection
Agency through its Region V offices. This study was a joint effort per-
formed by the State of Michigan and Stanford Research Institute.
The impetus for this study had its source in the executive order
issued by Governor Milliken on January 11, 1973, which reorganized the
environmental protection functions of the State government by consoli-
dating these activities in a single branch within the Department of
Natural Resources. An additional executive order issued on March 13, 1973
modified the earlier order and clarified certain provisions. The Gov-
ernor's actions, concurred in by the legislature, became effective
April 1, 1973. As a result of these actions, the augmented Department
of Natural Resources now consisted of two major branches, the Natural
Resources Branch and the Environmental Protection Branch which included
activities pertaining to air, water, and solid waste; both branches now
reported directly to the Director of the Department of Natural Resources.
The Governor also established within this enlarged department the Office
of Land Use Planning which contained the State's land use planning and
control activities. This function formerly operated within the Executive
Office.
When this consolidation occurred, Mr. Francis Mayo, Regional Admin-
istrator of EPA Region V, extended an offer to the State of Michigan to
fund a management assistance study for the newly created Environmental
Protection Branch. Mr. A. Gene Gazlay, Director of the Department of
Natural Resources, agreed that such a study offered a valuable opportunity
for examining the implications of the State's coordinated response to
environmental problems and recommended to its Commissions that the study
be performed. In July 1973, Stanford Research Institute, a nonprofit
contract research organization, was selected to perform the study.
The main thrust of this research effort was to implement the objec-
tives of the Governor's executive order by providing the management of
the enlarged Department of Natural Resources with the most efficient and
effective management and policy system for achieving the State's environ-
mental protection goals. The specific objectives of this study were to:
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(1) Identify, analyze, and define the environmental functional
relationships that exist within the Michigan Department of
Natural Resources as they relate to intrastate governmental
agencies, interstate and international agencies and com-
missions, and the Federal government.
(2) Examine the Department's interrelationships with the public
and private sectors of the community with respect to the
concerns and expectations that these bodies have regarding
environmental policies and actions that affect their in-
terest positions.
(3) Analyze and define the interfaces that exist within the
Department between the Natural Resources Branch and the
Environmental Protection Branch with special emphasis on
how policy decisions that occur within these branches
affect the objectives and operations of each.
(4) Review the Department's operations that are required to
accomplish the State's environmental protection goals and
identify opportunities for upgrading human resource
capabilities in the Department.
(5) Provide consulting services to the Department with the aim
of identifying opportunities for improving the effectiveness
and efficiency of operations in the functional and supporting
activities of the Environmental Protection Branch.
The scope of the SRI study did not provide for an assessment of the
overall functions of the Department of Natural Resources despite recog-
nition by all parties involved in the study of the interdependency of
the relationship between the activities in both branches, especially
those functions affecting Departmental policies and objectives. Although
it would have been desirable to include in the study both Natural Resources
Branch and department-wide functions, such as land use responsibilities,
it was not feasible to do so because of the substantial costs and time
constraints involved; it was decided, however, that the impact of the
Environmental Protection Branch's policy and operations on the activities
of the Natural Resources Branch could be addressed only by means of an
analysis of the interfacing transactions following a comprehensive review
of the responsibilities and function of the Natural Resources Branch.
The results of the present study suggest that the findings and rec-
ommendations that emerged deal adequately with the interfaces between
the two branches; it is quite possible, however, that immediate imple-
mentation of organizational alternatives for internal restructuring of
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the Environmental Protection Branch could have such unwanted effects as
(1) unanticipated influences on some activities and programs in the
Natural Resources Branch, (2) establishing functions and activities at
the branch level that might be more appropriately placed at departmental
decision-making levels, and (3) premature foreclosure of opportunities
open to the Department for taking advantage of interdependent trade-offs
now available because natural resources management, environmental pro-
tection activities, and the land use function are located within the same
State agency.
Because the implications of this study extend beyond the Environmental
Protection Branch to the entire Department, it is hoped that in the future
sufficient resources might be found to fund a study that would expand the
scope of this present effort to include a full spectrum of interrelated
issues. An augmented study of this kind would provide an opportunity to
develop an integrated organizational concept for unifying natural re-
sources management, environmental protection, and the emerging issues
of land use planning and control. This fortunate combination of factors
in the State of Michigan presents a unique opportunity to address these
issues within the context of a single organizational setting.
The basic strategy of the SRI project team in performing this study
was to utilize participative methods where possible. Groups and individuals
from the different functional units worked closely with the SRI project
team to identify organizational problems and input ideas and suggestions
for their solution. SRI attempted to tap as broad a spectrum of repre-
sentative viewpoints as possible with the expectation that this approach
would stimulate intensive discussion of the major issues and lead toward
a reasonable consensus by the time the study was completed. This process
generated much productive interaction and communication between the member-
ship of the Department and the SRI project team. Many ideas and suggestions
that emerged from these discussions were incorporated in the findings and
recommendations developed in this study.
An additional objective of the SRI team was to introduce into the
diagnostic discussions new ideas and perspectives for viewing departmental
work processes so as to encourage a rethinking of present modes of per-
forming departmental activities and responsibilities. It was also hoped
that by combining the knowledge, experience, and insights of the SRI
project team with those of the membership a new concept of organizational
operations would emerge that incorporated these characteristics:
• Openness of communications within the Department.
• Broadened group perceptions.
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• Recognition, of the capabilities and resources within the
total organization.
• Continuing examination of alternative methods for improving
the quality and quantity of services.
• Sensitivity to new service applications.
• Awareness of cost/benefit implications for different work
methods and processes.
• Development of a group capacity to plan for and cope with the
impacts of change.
SRI also worked within a system context to merge the appropriate
technical perspectives and disciplines required to cope with the com-
plexities of departmental operations. This approach required a systematic
assessment of all functional elements within the Department including
consideration of available technology, structural arrangements, resources,
and the patterning of relationships used in performing the various tasks.
In performing this study, SRI focused its efforts on understanding the
systemic bases of organizational dysfunction to avoid becoming enmeshed
in the more readily perceived surface symptoms. Emphasis was, therefore,
placed on those processes that link organizational elements into a totality
for accomplishing the overall purposes. SRI used behavioral science methods
as well as the more traditional forms of analysis to understand the environ-
mental pressures and task demands facing the organization and the individuals
comprising it.
This report summarizes the study team's effort to assist the State
of Michigan to improve the efficiency of those environmental activities
recently transferred to the Department of Natural Resources under the terms
of the executive order issued by Governor Milliken. Included is a review
of present operations and management functions; assessment of problems
related to work flow, policy generation and implementation, priorities,
and methods and procedures related to work processes, staffing patterns,
and other related issues; review of technical operations and supporting
information systems; the Branch's pattern of intergovernmental relation-
ships; and an analysis of the needs, interests, and problems associated
with stakeholder groups.
The SRI project team wishes to express its appreciation for the
considerable help and support that it received from Department of Natural
Resources personnel at all levels. Mr. A. Gene Gazlay, Director, and
his staff were extremely cooperative and helpful in providing needed
support throughout the study. To Mr. Ralph W. Purdy, Deputy Director of
the Environmental Protection Branch, the team owes special thanks for his
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patience, guidance, and generosity in making available information, tech-
nical expertise, and staff support. The same can be said for Dr. David
H. Jenkins, Deputy Director, Natural Resources Branch, whose assistance
greatly facilitated the SRI effort. Above all, the SRI project team
owes a debt of gratitude to the managerial, technical, and clerical
personnel within the Department who provided much valuable information
and services, without which this research could not have been performed.
The study was sponsored by the Midwest Regional Office of the United
States Environmental Protection Agency under the direction of Mr. Francis
T. Mayo, Regional Administrator. Technical coordination from this office
and project administration was provided by Mr. James A. Marth, Director
of State and Interstate Program.
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II EXECUTIVE SUMMARY
Michigan has long been recognized for its outstanding environmental
protection programs as well as its responsiveness to national environ-
mental policies and goals. The excellence of its programs has not been
emphasized throughout this report because the intent of the study has
been to identify opportunities for updating operational effectiveness
in light of recent changes in Federal legislation. Therefore, Stanford
Research Institute, with the collaboration of the State of Michigan and
the U.S. Environmental Protection Agency, completed a management assistance
study of the newly established Environmental Protection Branch of the
Department of Natural Resources.
The main thrust of this effort was to assist the Department to enhance
the effectiveness and efficiency of its environmental activities including
those recently transferred to the Department under the terms of Governor:
Milliken's executive order. Included within the scope of the SRI program
of technical.assistance was a. review of present operations and management
functions; identification of problems related to work flow, policy gen-
eration and implementation, priority setting, and staffing patterns; re-
view of technical operations and supporting information systems; Branch
intergovernmental relationships; and analysis of the needs, interests,
and problems associated with stakeholder groups. The scope of the study
did not include a full assessment of the overall functions of the other
branch or programs of the Department of Natural Resources because of the
significant costs and time constraints involved; the impact of the Environ-
mental Protection Branch's policy and operations on other departmental
functions was studied by analyzing the interfacing transactions. Finally,
a series of recommendations designed to enhance the effectiveness and
efficiency of the Branch's consolidated operations were developed by the
SRI project team. Some of these recommendations were implemented during
the course of the study.
The following major findings and recommendations emerged from the
study by the SRI project team.
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Management Operations Findings
The review of current management activities identified the following
areas of operational dysfunction:
• Compartmentalization causing problems in coordination and
internal communications.
• Inappropriate match between work programs and resources.
• Absence of a soundly based systems analysis capability for
dealing with problems related to information processing,
work flow, paper-work processes, and integrated filing
systems.
• Absence of sophisticated management techniques in such areas
as work planning, management by objectives, performance
evaluation, and management controls.
• A reactive rather than anticipative operating posture within
the Branch.
• Absence of a formal system for generating and organizing
policies in a structured, documented format.
• Management control systems that require further updating.
• Absence of a formal system of procedures documentation.
• Absence of a methodology for systematically establishing
priorities.
• Need for better utilization of performance appraisal as a
management tool.
• Planning activities are primarily oriented to the preparation
of environmental compliance plans and programs required by
law; systematic strategic and operational planning is under-
emphasized and not part of the formal processes.
• Significant improvement can be made in handling information
related to management and technical operations; data
processing support also needs strengthening.
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Management Review Recommendations
• Establish a centralized planning function that would
include provisions for (a) strategic planning, (b)
operational planning, and (c) preparation of state
environmental programs required by law (see page 80).
• Assign to the planning function responsibility for de-
fining and developing objectives, determining alternative
means for accomplishing these objectives, providing mech-
anisms for changing or modifying objectives, and com-
municating these objectives to appropriate levels in the
organization (see page 81).
• Establish an organizational unit that centralizes all in-
formation processing activities performed in the Branch
and that would include provisions for developing and
managing (a) a management data system for augmenting
management decision making and (b) a technical data system
to support the technical functions involved in managing
environmental quality (see page 33).
Technical Operations Findings
SRI's review of the Branch's technical operations resulted in
delineating the following problem areas:
• A formal, integrated process for reviewing permit applications
in terms of intermedia impacts is not available; nor has
permit processing been stabilized against a computational
model or an organized data base.
• Surveillance operations can be improved, especially in such
areas as follow-up to permit authorization and systematic
intelligence to detect unauthorized actions.
• Monitoring is approached more from an enforcement perspective
than from an environmental point of view. Coverage of
parameters that define potential demand for uses and describe
extant uses on public health, welfare, and other relevant
socioeconomic characteristics are in need of improvement.
• The press of everyday enforcement work usually results in an
underemphasis on special studies related to procedure de-
velopment or evaluation of unique environmental problems.
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• New approaches to public participation are needed.
• More formal educational programs are needed to keep Branch
professional and technical personnel up to date in their
specialty areas.
Technical Operations Recommendations
• Consolidate the separate permitting processes in the Branch
into a centralized system that would allow the paperwork
associated with these applications to be handled in a
logical, efficient manner (see page 86).
• Establish a schedule of surveillance activities as part of
the permitting process (see page 86).
• Distinguish institutionally the purpose of monitoring for
enforcement from the purpose of monitoring for environmental
resource management (see page 87).
• Use special studies to (1) support state environmental quality
goals and objectives, (2) acquire new technology and perspec-
tive, (3) continue to build a national reputation of scientific
and technical excellence, and (4) build credibility with the
State's constituents (see page 87).
• Give the public participation function an organizational
focus (see page 88).
• Implement a program of technology acquisition for all the
specialists of the Branch's technology base (see page 88).
Manpower and Personnel Findings
A review of manpower programs related to Branch operations revealed
the following areas of concern:
• There is no systematic process for determining future man-
power requirements, to assess the capability of existing
manpower resources to meet these requirements, or to
establish a framework for developing action programs to solve
existing or anticipated manpower problems.
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An employee information system which provides ready access
to data about employees' personal and experiential char-
acteristics is not available.
A formal personnel training and development program designed
to meet Branch needs for technical, supervisory, and man-
agerial personnel does not exist. There is a need to
establish a formal career development program.
The employment process is too lengthy and cumbersome; ad-
justments are necessary to reduce the time span for filling
vacancies.
Civil Service wage administration policies do not provide
sufficient incentives for encouraging the exceptional
employee. Present policies are geared to the average
performer.
Manpower and Personnel Recommendations
* Establish a manpower planning system that provides for (a)
an employment function, (b) formal training and development
programs for inside staff as well as local agency personnel,
(c) effective manpower utilization programs, and (d) a
methodology for achieving efficient manpower resource
allocations (see page 91).
• Develop a performance review system that goes beyond meeting
just the minimum standards of the Civil Service Commission
(see page 92).
• Develop an employee information system to provide the necessary
data to facilitate the workings of the management process.
This system would also augment vertical and horizontal com-
munications within the organization (see page 92).
Intergovernmental Process Findings
The findings reported below are based on the emerging needs for
intergovernmental process program elements both within the State and
between the State and Federal government.
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There is no single, identifiable source within the Branch to
which a local government authority can go to determine the
status of actions affecting his jurisdiction. An action,
once started, must be pursued through the agency on a per-
sonal contact basis.
Different actions concerning the same local jurisdiction are
handled by different sections and personnel in the Branch.
Coordination is a matter of personal initiative, and the
lack of a formal mechanism for achieving appropriate linkage
leads to tensions and misunderstandings between Branch field
staff, headquarters staff, and local authorities.
Responsibility for developing new State programs in response
to State legislation is divided and scattered. Therefore,
the intergovernmental aspects of such programs lack systematic
development.
There are 119 points of contact within the Branch which have
198 points of contact with staff in 12 agencies, departments,
bureaus, and commissions in the Federal government; these
contacts involve at least 31 categories of program activities
There is no centralized activity within the Branch responsible
for coordinating these intergovernmental activities.
The Branch lacks a systematic data base which can determine
the impact of proposed Federal statutory and regulatory
actions on state interests; nor is there an informed
methodology for conducting such assessments.
Federal statutes, rules, and regulations require socioeconomic
projections, cost-benefit determinations, demographic projec-
tions, and impact analysis in connection with the Branch's
obligations in meeting specific program requirements. Many
of these requirements must be met for regional or local jur-
isdictions. The Branch has neither the organizational
capabilities for carrying out these requirements nor the
means to negotiate the specific determinations, projections,
and analyses with the local governmental units in the State.
Intergovernmental Process Recommendations
• Establish an organizational component within the Environmental
Protection Branch to be responsible for intergovernmental
affairs. Assign to this component the means for developing
and managing all intergovernmental programs for the Branch
(see page 95).
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Stakeholder Processes Findings
The findings presented below are based upon an analysis of SRI
interviews with members of the Environmental Protection Branch and
representatives of interest groups throughout the State of Michigan as
well as the experience of the SRI team members in this growing area of
concern.
• Little formal recognition of stakeholder interests exists
within the Branch. Consequently, -there is no management
provision for objective assessment of the various interest
positions nor is there any systematic means for relating
such claims to ongoing policies and programs or determining
the areas of consensus and difference between the groups.
• The Branch has not developed a systematic methodology for
determining the critical issues and actions of interest to
the various stakeholder groups and disseminating pertinent
information to the public and the interested groups. Com-
munication channels that do exist are fragmented and dis-
persed among the various components and individuals in the
Branch.
• The Branch has not developed an informed constituency of
stakeholder interests in regard to emerging or pending
issues that contain potential for public controversy.
Stakeholder positions are apt to develop fortuitously or
depend upon individual initiative to develop information
and expertise relevant to the issues. Effective work in
this area can facilitate the formation of public consensus
on critical issues and thereby reduce abrasive and disruptive
controversy.
• On some issues, the staff has adopted an adversary posture
with respect to positions of some stakeholder groups. This
often leads to "win-lose" situations on specific issues.
Few of the Branch's regulatory actions or other decisions
can be reduced to such clear-cut alternatives when viewed
in the context of larger environmental goals set for the
Branch and its Commissions by the Legislature. These hard
decisions are seldom cast in the more reasonable and tractable
framework of broader goals and objectives. The adversary
role carries with it the unfortunate tendency to reduce
future opportunities for constructive stakeholder relations.
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The Branch does not systematically develop and maintain an
integrated data base related to stakeholder groups. In-
formation pertaining to stakeholder interests is maintained
by particular individuals or components in the Branch.
Stakeholder Processes Recommendations
• Establish within the intergovernmental component a group
whose specific responsibilities and duties are related to
stakeholder interests in all of the Branch's programs.
Delegate to this group the responsibility for coordinating
all presently required public participation activities
for the Branch (see page 99).
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Ill ANALYSIS OF PRESENT ORGANIZATION
In July and August of 1973 the SRI project team made several visits
to Lansing for the purpose of conducting an on-site assessment of the
operations of the Environmental Protection Branch of the Department of
Natural Resources. During this period all key management and technical
personnel in the Branch were interviewed in depth. Communications were
also established with public officials in relevant State and municipal
agencies, regional planning bodies, and the Midwest Region Office of the
U.S. Environmental Protection Agency and with individuals and organiza-
tions throughout the State representing diverse interest positions in
regard to policies, programs, and activities related to environmental
protection. In addition to the general goal of conducting an evaluation
of the current and future operational capability of the Branch, the spe-
cific objectives of this effort were to:
(1) Develop an understanding of the responsibilities and oper-
ations of the organization.
(2) Assess the management processes existing in the orga-
nization.
(3) Identify the process of policy generation, policy selection,
and policy implementation with emphasis on the mechanisms
for instituting changes, updating, and measuring effects.
(4) Identify the management styles employed at the different
organizational levels including leadership methods and
control processes.
(5) Identify operating problems relating to work flow, staff-
ing patterns, work priorities, methods and procedures
related to work processes, redundancy, and other relevant
issues.
Present Organizations
The Environmental Protection Branch under the direction of a deputy
director is one of two major functional components which comprise the
Natural Resources Department, the other being the Natural Resources Branch
also managed by a deputy director. The Natural Resources Department, in
addition to the two main branches, consists of the following organizational
15
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units: the Administrative Bureau, Office of Land Use Planning, Council
of Tourism, an executive assistant for policy coordination, and an exec-
utive assistant for public relations, all reporting to the Director's
Office. These relationships are given in more detail in Figure 1.
Overall policy guidance for the Department is provided by the Natural
Resources Commission whose designated executive officer is Director of
the Department.
Policy guidance for the Water Management Bureau is provided by the
Water Resources Commission. The membership of the Water Resources Com-
mission is composed of the following:
• The Director of the Natural Resources Department
• The Director of the Public Health Department
• The Director of the Agriculture Department
• The Director of the Highway Department
• An appointed member representing conservation groups
• An appointed member representing municipalities
• An appointed member representing industry.
The Director of the above-named State agencies may delegate their
representation on the Commission by naming a surrogate from inside their
department. The Director of the Natural Resources Department is currently
represented on the Commission by the Chief of the Resources Bureau of the
Natural Resources Branch. The Deputy Director responsible for the Envi-
ronmental Protection has been designated Executive Secretary of the Water
Resources Commission and his Bureau Chief for Water Management serves as
the Assistant Executive Secretary. These individuals, together with the
Director's representative, all serve to represent the Water Resources
Commission with the Natural Resources Commission.
In addition to the formal Commission relationships outlined above,
various staff members of the Water Management Bureau are selected to make
periodic reports to the Natural Resources Commission to keep it informed
on current activities and programs. From time to time, the Commission
will request the services of 'staff members to perform specific assignments
or support duties.
The Air Pollution Commission provides policy direction for all activi-
ties now subsumed under the Division of Air Pollution Control. Membership
on this commission includes the following:
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/ NATURAL \
i RESOURCES
x^" X
/ WATER \
' RESOURCES \
\COMMISSION
\
\
POLLUTION \
CONTROL I
\ COMMISSION/
DIVISION CHIEF
WATER QUALITY
CONTROL AND
CHIEF ENGINEER
1
ASSISTANT
DIVISION CHIEF
AND ASSISTANT
CHIEF ENGINEER
1
REGION 1
ENGINEER
REGION II
ENGINEER
DIVISION CHIEF
HYDROLOGICAL
SURVEY
DIVISION CHIEF
WATER
DEVELOPMENT
SERVICES
ASSISTANT
DIVISION CHIEF
ASSISTANT
DIVISION CHIEF
DIVISION CHIEF
MUNICIPAL
WASTEWATER
|
REGION 1
ENGINEER
DIVISION CHIEF
SOLID WASTE
MANAGEMENT
1
REGION II
ENGINEER
ESCANABA AREA
ENGINEER
DIVISION CHIEF
AIR POLLUTION
CONTROL
FIGURE 1 THE PRESENT ORGANIZATION
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• The Director of the Public Health Department.
• The Director of the Agriculture Department.
• The Director of the Department of Natural Resources.
• Two appointed members representing industrial management,
one of whom must be a registered engineer trained in matters
related to air pollution management and control.
• Two appointed members representing local governing bodies,
one of whom must be a full-time air pollution officer.
• A Doctor of Medicine experienced in the toxicology of air
contaminants.
• An appointed member representing organized labor.*
• Two appointed members representing the general public.
All appointed members of the Air Pollution Commission serve three year
terms.
The Environmental Protection Branch comprises the following major
organizational components:
• Water Management Bureau
• Air Pollution Control Division
• Solid Waste Management Division.
The Water Management Bureau, in turn, is further subdivided into the
following divisions:
• Water Control Division
• Hydrological Survey Division
• Water Development Services Division
• Municipal Wastewater Division.
Generally speaking, the Environmental Protection Branch is organized
in such a manner that the work of the Branch is performed by essentially
autonomous sections loosely combined into divisions. These sections vary
in size from one to approximately 30 technical personnel. The technical
complexity of these sections also varies greatly and tends to have dif-
ferential impacts on the Branch as a whole. The activities of these
sections and their organizational relationships are described in greater
detail in other sections of this report. The reporting relationships of
the Branch are also delineated in Figure 1.
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Hydrological Survey Division
The Hydrological Survey Division is a functional component operating
under the jurisdiction of the Water Management Bureau. A functional break-
down of this division is shown in Figure 2.
An overall picture of the organizational interfaces of this division,
which is given in Table 1, also illustrates the varied nature of the
activities and responsibilities that it performs. Many interfunctional
HYOROLOGICAL SURVEY
DIVISION
This Component is Regulatory in
Nature and Administers 15 State
Laws by Means of Five
Operating Sections
SUBMERGED LANDS
SECTION
Regulates the Creation and Use
of Submerged Lands
HYDROLOGICAL
ENGINEERING SECTION
Regulates Dam Construction and
Conducts Hydrologie Studies
FLOOD PLAIN
CONTROL SECTION
Assists Watar Resources
Commission to Control
Flood
WATERSHED PLANNING
I PARTY
Assists Federal Watershed
Planning For Flood Control and
Irrigation Projects
SUBDIVISION
CONTROL SECTION
Reviews All Plans For
Construction of Subdivisions;
Approves or Rejects Such Plans
FIGURE 2 HYDROLOGICAL SURVEY DIVISION
19
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Table 1
HYDROLOGICAL SURVEY DIVISION
Major interfaces with the Department
Water Quality Control Division
Fish and Wild Life Division
Geological Survey Division
Water Ways Division
Parks and Recreation Division
Land Division
Engineering Division
Other State government departments
Public Health Department
Highway Department
Agriculture Department
Commerce Department
State Police Emergency Service
Division
Legislature
Governor's Office
Water Resources Commission
Natural Resources Commission
Federal agencies
U.S. Corps of Engineers
Soil Conservation Services
U.S. Geological Survey
U.S. Weather Bureau
International Joint Commission
Great Lakes Basin Commission
Groups Considering Dredging
20
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transactions performed within the Department have their inception in the
work processes of this division. The division's interrelationship with
important programs and activities inside and outside the department high-
lights the pivotal position that this component occupies as initiator,
coordinator, and liaison agent. Because of this centrality within the
network of Branch and Departmental operations, reduction in any area of
functional efficiency through overload, redundancy, compartmentalization,
or misperception of critical priorities can have unfavorable impacts on
the operations of other departmental functions.
The functional significance of this division is further emphasized
by the increasing volume of work that has accrued over the years. In 1966,
the division processed 496 permit applications under the Inland Lakes and
Streams Act; by 1972 the volume of permits processes had increased to
1,600, and by 1973 to approximately 2,500. Given the trend toward in-
creased legislation of this particular sector, the volume and complexity
of the work can be expected to increase even further in the future.
Table 2, which gives a functional breakdown of the divisional
activities, indicates that more than 55 percent of the work performed
falls within the category of issuing permits and licenses, and approving
local ordinances. Technical services and liaison with the Commissions and
state and Federal agencies account for the other significant portion of
the work but essentially represents a rather small fraction of the entire
work load. It is apparent that improved methods and procedures backed up
by an effective information processing system will be an important con-
sideration in coping with the increasing proliferation of paper work.
A summary of the major responsibilities of each of the sections is
included in the discussion that follows.
Hydrological Engineering Section
This section is divided into two operating units.
Unit I, Lake Engineering Unit, is responsible for:
• Issuance of dam construction permits under Public Act
184 which requires that a permit be issued for all dams
that will result in 5 acres of water or a body of water
with a 5-foot head. This unit issues approximately 15
permits per year.
21
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Table 2
HYDROLOGICAL SURVEY DIVISION FUNCTIONAL BREAKDOWN
Estimated Effort by Section
(percent of total)
Issues permits, licenses, and
approval of local ordinances
Interactions with commissions
Surveillance and monitoring
Enforcement
Represent State, WRC, DNR on
various study groups and
commissions
Interaction with Federal agencies
Public relations
Provide technical services
Develop rules and regulations
Interact with the State Legislature
and U.S. Congress
Prepare recommendations for the
Governor
Process information and data
Other administration
Administer grants
Field reconnaissance
Hydrol -^ic
Engineering
33%
2
15
10
5
5
5
15
1
1
1
5
2
Submerged
Subdivision Lands Watershed
Control Management Planning
60% 56%
— 3 2
2
1 2 —
1 1 —
10 20 10
556
10 2 70
1 2
__ J-j _
1
1 10
2 — 2
Flood
Plain
Control
80%
—
—
3
—
2
4
10
—
—
—
—
1
10
22
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• Approval of plans to build dams or other structures to
establish a lake level on a particular lake. There are
approximately 30 such plans processed each year. The
work in this unit is processed under Public Act 146
(1961) as amended.
• Work with local government jurisdictions to improve the
lakes by such actions as weed control and dredging.
There are 14 Local Lake Improvement Boards that have
been established, of which 8 are still active. This
unit represents the department in these matters and pro-
vides guidance and counsel to local boards under Public
Act 345 (1966).
Unit II, the Hydrologic Studies Unit, is responsible for:
• Conducting hydrologic studies, including flood plain dis-
charge and frequency estimates, drought flow forecasts for
design of wastewater control facilities, discharges, and
fisheries management problems.
* Provision of consulting engineering services to other de-
partments within the state government such as the Highway
Department.
• Work with other divisions within the Department of Natural
Resources on joint technical studies such as fish poisoning.
• Performance of duties under administrative statutes:
- Issuance of permits under Public Act 143 (1959) which
requires an iron ore company to obtain permits to divert
water for use in internal processes.
- Performance of studies under Public Act 20 (1964) which
is concerned with surplus water flow and requires the
preparation of plans for the management of water (to be
approved by the Water Resources Commission).
- Assistance in organizing watershed councils as authorized
under Public Act 253 (1964) and provision of information
to these councils as well as advice and counsel as re-
quired.
- Answering of inquiries and random questions related to
duties as they arise.
23
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Submerged Land Management Section
The primary objectives of this section are to administer two
prime statutes—The Great Lakes Submerged Lands Act, Public Act 247
(1955), and the Inland Lakes and Streams Act, Public Act 346 (1972).
The major effort of this section is subdivided into the following
categories:
• Issuance of permits to dredge and fill along the shoreline.
During 1972 approximately 1,800 permits were issued under
the Inland Water Act and 300 permits under the Great Lakes
Act for a total of 2,100 permits; 80 percent of these per-
mits were issued to individuals and created only minor changes
in the environment, and the remaining 20 percent were issued
for major construction projects, which created significant
change in the environment.
• Clearance of title to bottomland that has already been filled.
• Review of all reports of island filling.
• Conduct of a public awareness program through meetings and
seminars and issuance of information to the public regarding
Departmental functions under the law.
• Implementation of all litigation against violators of the
two acts through the medium of the Attorney General's office.
• Preparation of all legal documents related to land exchanges,
legal conveyances, and bases and agreements for use of the
Great Lakes submerged bottomlands. These documents are sub-
ject to approval by the Natural Resources Commission and the
State Administrative Board prior to final execution.
Flood Plain Control Section
The principal responsibility for this section is to review all
applications for occupation or alteration of the flood plain including:
(1) The main channel
(2) The entire overbank area of the flood plain.
Public Act 167 (1968) requires an individual or entity to obtain a permit
from the Water Resources Commission before occupying or altering the
channel of a water course.
24
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The staff of the Flood Plain Control Section is responsible for
studying each application and determining the proposed hydraulic effect
of flood stage and direction of flow. The report on this proposal is then
sent to the Commission along with an analysis of any potential detrimental
effects that may result from an increase in the flood stage. The Water
Resources Commission then determines whether or not the proposal meets
the requirements of the law. If so, the Commission issues an order autho-
rizing the permit. The actual preparation of the permit is performed in
this section.
Subdivision Control Section
This section is primarily responsible for reviewing preliminary
plat plans for proposed subdivisions, ensuring that all requirements under
the various acts are met. This section also coordinated the preliminary
plat plans with others in the Branch and recommends approval or rejection
of these plans. Included in this review are such matters as:
• Ensuring that the flood plain (normally dry land that
could be submerged if the highest stage in 50 years
occurred) is shown on the map.
• Ensuring that there is a minimum of 3,000 square feet of
land on each proposed lot that is above the 50 year flood
level standard required under Public Act 288 (1967).
• Determining whether or not filling on the flood plain is
involved and ensuring that all requirements under Public
Act 245 (1929) and Public Act 167 (1968) are met.
• Ensuring that related requirements of cognizant divisions
and sections of the Department are met.
• Ensuring that the final plat plan properly reflects all
restrictions imposed, in the preliminary plan review and
the proposal makes no encroachments on State-owned land.
• Preparing a letter of approval to the applicant indicating
the approved course of action.
Funds Control
Under Public Act 346 (1972), the Hydrological Survey Division is
empowered to handle funds that are derived from applications for permits
to dredge or fill along the shoreline. A schematic describing the cash
flow and the control measures prescribed by the Auditor General is given
in Figure 3,
25
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APPLICATION
AND
$25 FEE
SUBMERGED LANDS SECTION
• Receives Application and Fee
• Checks for Completeness
• Returns if Incomplete
ADMINISTRATIVE
SERVICES
RECEIVES
• Original Application
• Deposit Receipt
• $25.00 Deposit
VALIDATES
• Original Application
• Deposit Receipt
• Records Receipt
RETURNS TO SECTION
• Original Application
• Receipt for Deposit
APPLICANT
Receives His Package
Corrects and Resubmits
SUBMERGED LANDS SECTION
FILES IN PROJECT FILE
• Original Application
• Deposit Receipt
AUDITORS
• Obtains Record of Receipt for
Administrative Services Division
I • Matches With Validation in
Project File
FIGURE 3 FUNDS CONTROL IN THE HYDROLOGICAL SURVEY DIVISION
26
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Water Development Services Division
The Water Development Services Division is a functional component of
the Water Management Bureau. Many of the activities within this division
are closely coordinated with the Water Resources Commission. An overview
of the key functions in the Division is shown in Figure 4 and a func-
tional analysis of the Division's activities is given in Table 3.
A more detailed summary of the principal duties of the above sec-
tions follows.
Construction Grants Section
The primary responsibility of this section is to administer
grants as authorized by the Water Pollution Control Act as amended in
1972, PL 92-500, effective 1972, and other Federal laws as appropriate
at any point in time.
There are four kinds of grants now authorized under existing
Federal legislation:
(1) Preliminary planning and studies
(2) Preparation of construction plans and specifications
(3) Construction
(4) Turnkey (probably none in 1974).
Approximately 350 projects have been established on the 1974 priority list
for Departmental consideration.
The major actions performed by this section are to:
• Send out notices to communities who have expressed interest
in applying for grants and advise them of deadlines for
filing applications.
• Help the local communities to complete required forms and
procedures.
• Review applications.
• Assign priorities based on statutory requirements.
• Notify applicants of priorities assigned.
• Invite personal contact if there is a disagreement with the
applicant.
27
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CONSTRUCTION
GRANTS SECTION
Administers Federal and State
Construction Grants
WATER DEVELOPMENT
i SERVICES DIVISION
Administers Construction Grant
Program, Assists in Local Water
Management, and Conducts
Planning For Water Resources
and Water Quality
LOCAL WATER MANAGEMENT
ASSISTANCE SECTION
Administers Soil Erosion and
Sediment Control, Coordinates
River Basin Development, and
Provides Liaison With
Watershed Group
WATER QUALITY
MANAGEMENT PLANNING
SECTION
Provides Water Quality
i Management and Plans and
Coordinates With the Federal EPA
SHORELINES AND
INVESTIGATIONS SECTION
Administers Shore Erosion
Program, Identifies High Risk
Erosion Areas, and Monitors
and Reports
WATER RESOURCES
PLANNING SECTION
Performs Water Resources
Planning Studies To Meet Bureau,
State and Federal Requirements
FIGURE 4 WATER DEVELOPMENT SERVICES DIVISION
28
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Table 3
WATER DEVELOPMENT SERVICES DIVISION FUNCTIONAL ANALYSIS OF WORK
Estimated Effort by Section
(percent of total)
Water Local Shorelands Water Quality
Construction Resource Government and Resource Management
Grants Planning Assistance Investigation Planning
Prepare recommendations for
the Governor —% 2% —% 1% —%
Interactions with commissions 15 1 5 1
Interactions with Federal
agencies — 55 1 5
Interaction with the State
Legislature and the U.S.
Congress 115 1 5
Represent State, WRC, DNR,
or various commissions and
study groups 2 31 5 1 5
Develop water quality manage-
ment plans and water resource
plans 5 30 48 5 75
Issue permits, licenses, and
approve local ordinances -- -- -- —
Surveillance and monitoring — -- — 39
Develop rules and regulations 1 — 2 1
Enforcement — . — — -- .--
Public relations 115 4 5
Process information and data — 25 — 25 —
Administer grants 75 2 -- —
Provide technical services — — 20 14
Other administration --25 7 5
29
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section:
• Resolve conflicts and disagreements if possible.
• If differences cannot be resolved, the applicant is
advised of his right to appeal to the Commission. The
Department will then prepare information and adminis-
trative support for a public hearing.
• Present recommendations of priority at a public
hearing.
• Adopt Commission decisions in refprct to the priority
list.
• Submit priority lists to the Federal government for
approval.
• Inspect ongoing work.
• Receive and process payment requests.
Local Water Management Assistance Section
There are three primary areas of responsibility assigned to this
• Soil erosion and sediment control under PA 347 (1972)—
This act provides for control of soil erosion to protect
the water of the State from sedimentation and further
provides for the mechanism to implement the act in the
form of such things as rules, remedies, and penalties.
This act took effect in July 1974. The rules for imple-
menting the act were developed and circulated by the end
of 1973, and public hearings were held in early 1974.
• Coordinate Federal, State, and local government interests
in the Kalamazoo Blocks and the Paw Paw River Basin
Development—This includes establishing an executive board
to provide general policy direction, regional councils to
ensure that regional interests are considered, and local
task forces to provide local direction along with technical
support for such things as to develop the plans and organize
the data. This activity also includes documentation of a
written plan for performing the work.
• Provide liaison with water shed groups as required—This
work is performed chiefly by the section manager with a
minimum of outside support.
30
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Shore lands and Investigation. Section
The work of this section is carried out through the medium of
two operating units:
Shoreland Unit
• Administers shore erosion programs as provided under the
terms of PA 245 {1970).
• Identifies and designates high risk areas of shore
erosion on the Great Lakes Shoreland.
• Provides engineering studies to prevent undeveloped land
from being developed in an undesirable manner.
Resources Investigation Unit
• Identifies other high risk areas.
• Monitors the risk areas annually to determine changes,
and documents these changes. •
• Determines which protection methods are working as
designed.
• Gathers shore recession rates by use of aerial photographs
and provide? this data to local governmental agencies.
Water Quality Management Planning Section
The basic responsibilities of this section are to:
(1) Provide water quality management plans.
(2) Process official plans for adoption by the Water
Resources Commission.
Certain aspects of the work that fall within the section's responsibili-
ties are carried out by outside consultants. In these circumstances, the
section's role is to administer the contractual agreements made with the
consultants and monitor technical competence standards. This also in-
cludes obtaining EPA approval of consultant subcontracts and receiving
reimbursement.
31
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The working philosophy of this section is, "if you want to do
it, we can help you with the financial aspects but you must meet certain
requirements." This approach is significantly different than the enforce-
ment philosophy of "do it—or else."
Activities of this section include:
• Provision of staff support for the Michigan Great Lakes
Commission. The present Manager of the Water Development
Services Division is the designated Alternative Com-
missioner and has a major role in executing the Com-
mission's programs.
• Provision of staff assistance for the Interdepartmental
Committee on land and water resources. The Committee
was established by the Governor's Office and the Division
Manager is also Chairman through appointment by the Gov-
ernor. The Committee is composed of all State agencies
(approximately 14) with responsibility for land manage-
ment.
• Provision of assistance to the Land Drainage Board of
the International Joint Commission. This effort is pro-
grammed for two to three years further existence.
• Other special assignments.
• Provision of administrative and technical support for the
State agency designated by law to serve as Executive Water
Personnel Planning Assistant, under PL 92-500 (Title 3).
Water Quality Control Division
The Water Quality Control Division is composed of the Water Quality
Studies Group, the Enforcement Group—Region I, and the Enforcement Group-
Region II. A functional overview of this Division is shown in Figure 5.
A more detailed summary of the principal duties of these sections follows.
32
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WATER aUALITY
CONTROL DIVISION
Regulatory and Enforcement in
[ Character. Field Organization
Covers tha State
WATER QUALITY
STUDIES GROUP
Prepare iPA Plan, Conduct
Surveys, Licanse Wacta Handlers;
and Examine Oparation of
Watttwatar PacMties
REGION I
Enforce Watar Quality Law,
Prepare Permits to Discharge in
Waters. Sarva A* FieW Contact
For tha Division
REGION II
Enforce Watar Quality Law,
Prepare Pannits to Discharge in
Waters, Sarva As Field Contact
I For tha Division
FIGURE 5 WATER QUALITY CONTROL DIVISION
Water Quality Studies Group
The Water Quality Studies Group is composed of five specialized
sections:
• Water Quality Appraisal Section
• Oil Pollution Control Section
• Special Programs Section
• Laboratory Section
• Comprehensive Studies Section.
A detailed discussion of activities and programs assigned to each section
follows.
33
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Water Quality Appraisal Section
The Water Quality Appraisal Section is composed of two components-
the Industrial Waste Survey Unit and the Biological Survey Unit. Their
work activities are described below.
The Industrial Waste Survey Unit is responsible for:
• Sampling the effluent generated by industries.
• Designing, building and maintaining sampling equipment.
• Conducting surveys to ensure that requirements are met
on a continuing basis.
• Conducting hearings and taking other actions necessary
to ensure that requirements are met.
• Meeting periodically with enforcement personnel and
industry representatives to discuss current activities
and problems.
The Biological Survey Unit is responsible for:
• Conducting river surveys including the collection of
aquatic insects above and below a discharge to determine
the nature and extent of damage.
• Monitoring discharges from nuclear power plants and de-
termining the impact on water quality.
• Conducting bioassays of marine life, including the use
of mobile laboratories that are capable of covering
extensive areas for the purpose of testing water from
streams and taking analytic samples from lakes.
• Issuing permits to discharge chemical substances that
produce skin irritations.
Special Programs Section
The Special Programs Section is primarily concerned with the
following:
• Preparing and administering examinations to operators of
industrial wastewater facilities.
34
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Providing tax exemption certificates for the installation
of wastewater pollution control devices. This activity
also includes examining sites, reviewing plans, and
resolving all problems that interfere with the issuance
of an exemption.
Inspecting and issuing certificates ensuring that toilet
facilities on boats meet the requirements of the boat
pollution control program. There are approximately
400,000 active boats in the State. This necessitates
close liaison and coordination with the Conservation
Department, Sheriffs' Departments, and other internal
Departmental personnel.
Laboratory Section
The Water Quality Control Division maintains two laboratories—
one reporting to the Enforcement Division and located at Pt. Mouillee,
which partially supports the monitoring and surveillance activities in the
Detroit metropolitan area, and the main laboratory in Lansing, reporting
to the Water Quality Studies Division, which performs all the water chem-
istry and pesticide analyses for the remainder of the Bureau of Water
Management. This laboratory also provides analytical services to other
departments of state government.
The Lansing Laboratory is equipped to perform a wide range of chem-
ical determinations on wastewater and freshwater samples (e.g., all in-
organics, all pesticides on critical materials register; other organics
determinations are contracted to private labs). It performs around
100,000 individual determinations on 12,000 samples per year. Bacterio-
logical analyses are performed by Public Health. In turn chemical analy-
ses of municipal well waters are performed for Public Health. Analyses
of fish and animal tissue samples for mercury and other heavy metals are
normally performed by the Department of Agriculture Laboratory. Bio-
assays are conducted by the Water Quality Appraisal Section. About 80 per-
cent of the Lansing Laboratory work is for the Water Quality Control
Division while 20 percent is for others. About 20 percent of the labora-
tory's effort is devoted to quality control.
35
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Comprehensive Studies Section
The Comprehensive Studies Section is one of the largest components
in the Branch, with basic responsibilities in the following areas:
• Preparing the State Program Plan for submission to EPA.
• Preparing comprehensive studies with respect to the use of
river basins and projecting possible impacts resulting from
present and future usage. These are basically diagnostic
activities.
• Performing long-term water quality monitoring exclusive of
biological monitoring.
• Providing mechanized analytical reports required to support
the activities of other sections in the division.
• Implementing the industrial waste surveillance program
(approximately $1.2 million in fees is projected for FY74).
• Keeping informed about current usage of toxic materials in
the state and identifying existing stockpiles of these
materials.
• Licensing of industrial waste handlers with respect to
approval of vehicles used and location of sites.
Municipal Wastewater Division
The Municipal Wastewater Division was recently transferred from the
Department of Health to the Water Management Bureau of the Environmental
Protection Branch under the provision of the Governor's executive order
consolidating environmental protection activities and programs into the
Department of Natural Resources. A schematic describing organizational
relationships of this division is given in Figure 6.
All activities and programs performed in this division are covered
under the provisions of Public Act 98 (1913) and include the following
areas of emphasis:
• Approving the design of municipal Wastewater treatment
facilities.
• Issuing permits to construct Wastewater construction
facilities.
36
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MUNICIPAL
WASTEWATER
DIVISION
1 1
REGION I
FIELD
OPERATIONS
REGION n
FIELD
OPERATIONS
1 1
-
i REGION m
i FIELD
OPERATIONS
INDUSTRIAL
WASTE
SURVEILLANCE
AND
INVESTIGATION
AND TRAINING
TRAINING OF
1 WASTE
. TREATMENT
PERSONNEL AND
i MANPOWER
PLANNING
FIGURE 6 MUNICIPAL WASTEWATER DIVISION
• Training operators to man municipal wastewater facilities.
• Conducting surveillance programs to ensure that conditions
are maintained to meet effluent standards.
The division also maintains an extensive field operation. Under its
present plan of organization, all field work in the division is performed
within three regional subdivisions based on the following considerations:
* Region I--Covers all territory which drains into Lake Huron,
Lake Erie, and Lake St. Clair.
• Region II—Covers territories which drain into Lake Michigan.
• Region III—Covers the entire upper peninsula.
37
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The duties performed by this division are accomplished with a work
force of 32 people. A functional breakdown of their work activities is
shown in Table 4. It should be noted that 75 percent of all divisional
activities fall into four main areas: issuance of permits and licensesj
surveillance and monitoring, provision of technical services, and develop-
ment of program recommendations.
The Municipal Wastewater Division, per se, is not involved to any
great extent in direct planning functions. Staff members do become
indirectly involved through consultation with communities and their engi-
neers in the planning stages for the establishment of local water pollu-
tion control programs and the design, construction, and operation of
municipal wastewater facilities.
A program where the division does get directly involved with planning
is in municipal wastewater facility manpower development and training.
This is accomplished by:
(1) Conducting an employment and planning survey to assess
the labor related needs and characteristics at municipal
wastewater treatment plants.
(2) Determining the current and expected future values of
employment characteristics. This involves calculating
turnover rates and estimating employment increases due
to plant expansions and higher water quality objectives.
(3) Developing training plans and action steps in response to
current and projected manpower training needs and problems.
This is accomplished in close cooperation with the divi-
sion's Investigation and Training Unit.
Solid Waste Management Division
The Solid Waste Management Division was also transferred from the
Department of Health into the Environmental Protection Branch of the
Department of Natural Resources under the terms of the Governor's exec-
utive order consolidating all environmental activities. As presently
constituted, the division is organized into six sections, each represent-
ing a geographical area. All field personnel work out of the Lansing
office except the divisional field representative for the upper peninsula
who is now located in Escanaba. The basic work of this component is per-
formed in support of Public Act 87 (1965) as amended in 1971.
38
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Table 4
MUNICIPAL WASTEWATER DIVISION FUNCTIONAL BREAKDOWN
Activity
Issue permits, licenses, and approval of
local ordinances
Surveillance and monitoring
Provide technical services
Enforcement
Interaction with Federal agencies
Public relations
Interaction with the State Legislature and the
U.S. Congress
Develop program recommendations
Other administration
Represent State, Water Resources Commission,
and Department of Natural Resources on various
commissions and study groups
Prepare recommendations for the Governor
Interaction with commissions
Develop rules and regulations
Process information and data
Administer grants
Percent of Total Time
25%
20
15
5
5
5
5
10
5
3
1
1
39
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The major work areas included in this division's effort are:
• Licensing of solid waste disposal facilities including land
fills, open dumps, hog feeding operators, and incinerators.
As part of this activity, the division also oversees plants
that process waste materials and includes transfer stations
as well as all transporting units in the State. In this
particular case, it is the container not the vehicle that is
licensed. The division also licenses junk collection centers
established for collecting material to be recycled.
• Providing consultation to local governmental agencies in all
spheres of solid waste management.
• Providing surveillance assistance and support to local health
departments to ensure that the conditions prescribed under
the licenses issued are met.
• Providing rules to be used by local governmental entities in
developing plans for managing solid waste in their areas;
and approving or disapproving such plans. Local entities
dealt with include county boards of supervisors, city councils,
township supervisors, and so forth. The plans involved include:
- Identification and evaluation of alternative methods of
handling solid waste.
- Selection and justification of the proposed alternative.
- Implementation schedules specifying what will be done and
the time frames.
• Assisting the Federal government in implementation of solid
waste programs.
• Conducting public information and public education programs
on matters relating to solid waste management.
40
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The functional distribution of this division's work is as follows:
District Representatives—Spend 80 percent of their time
in technology transfer and consultation with local health
departments—including assistance in performing on-site
inspections—and 20 percent in processing applications
and performing miscellaneous administrative work.
Headquarters Staff—Efforts in this area are devoted pri-
marily to processing applications and performing administra-
tion duties. A more detailed breakdown of work is shown in
Table 5.
Air Pollution Control Division
The Air Pollution Control Division was also transferred from the
Department of Health into the Environmental Protection Branch of the
Department of Natural Resources under the terms of the Governor's execu-
tive order, which consolidated all environmental activities into one
functional component. As presently constituted, the division is organized
into four sections, three of which perform technical duties and one which
is concerned primarily with administrative functions. The organizational
relationships are shown in more detail in Figure 7.
The basic work of the Air Pollution Control Division is performed in
support of Public Act 250 (1965) as amended (Tax Exemption Act) and Public
Act 348 (1965) as amended (Air Pollution Act). In addition, administra-
tive rules for air pollution control have been promulgated under the au-
thority of Public Act 348. A functional breakdown of work activities is
shown in Table 6. ^- "..
The Air Pollution Control Commission which maintains policy guidance
over the activities of the Division has delegated some of its responsi-
bilities and functions to air pollution control units of local government.
The Wayne County Air Pollution Control Division covering most of Detroit
Metropolitan Area operates with a large degree of autonomy.
The State is divided into six air quality control regions. The
enforcement services are broken down into nine geographic districts (in-
cluding Wayne County as one district). The enforcement districts and the
air quality regions do not necessarily coincide.
The enforcement district offices are staffed with engineers and in-
vestigators. Four district offices have not been established at present.
The engineers represent the Commission in their assigned geographic area
41
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Table 5
SOLID WASTE DIVISION FUNCTIONAL BREAKDOWN
Activity
Consultation
Provide technical services
Issue permits, licenses, and approval of
local ordinances
Interaction with Legislature and Congress
Represent State, Water Resources
Commission, and Department of Natural
Resources on various commissions and
study groups
Enforcement
Surveillance and monitoring
Prepare recommendations for the Governor
Interaction with Federal agencies
Develop program recommendations
Develop rules and regulations
Other administration
Interaction with commissions
Public relations
Process information and data
Administer grants
Percent of Total Time
30%
20
15
10
10
10
5
Occasionally
Occasionally
When needed
Only when needed
When needed
42
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AIR POLLUTION CONTROL
DIVISION
ENFORCEMENT AND
FIELD SERVICES
SECTION
ADMINISTRATIVE
SECTION
| ENGINEERING
I SECTION
TECHNICAL SERVICES
SECTION
FIGURE 7 AIR POLLUTION CONTROL DIVISION
in all aspects of air pollution control activities; i.e., maintaining
liaison with local governmental officials, including local health depart-
ments and local air pollution control agencies; making self-initiated
investigations on a planned basis and other investigations on the basis
of complaints or other evidence of violations; evaluating needs for com-
munity air sampling and source sampling; and planning, developing, and
carrying out an effective air pollution control program. The investi-
gators work under the direction of the district engineers and conduct
source inspections (including visual emission evaluations), operate and
maintain air monitoring equipment (including air monitoring trailers),
and generally assist in the conduct of the district air pollution control
program.
Permits are required for the installation of any new processing equip-
ment that may be a source of air contaminants, for the alteration of exist-
ing sources, for the installation or alteration of emission control systems,
and for the installation of incineration equipment. Engineers of the Engi-
neering Section give the permit applications a critical review in light
of the emission limits. The review also takes into account regional fac-
tors to assure that the proposed installation will not compromise ambient
43
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Table 6
AIR POLLUTION CONTROL DIVISION FUNCTIONAL BREAKDOWN
ESTIMATED REPORT BY APCO
Activity Percent of Total Time
Prepare recommendations for the Governor 1%
Interaction with commissions 5
Interaction with Federal agencies 3
Interaction with the State Legislature
and the U.S. Congress 2
Represent State, WRC, DNR, or various
commissions and study groups 1
Develop program recommendations 5
Issue permits, licenses, and approve
local ordinances 10
Surveillance and monitoring 25
Develop rules and regulations 2
Enforcement 12
Public relations 3
Process information and data 8
Administer grants 1
Provide technical services 10
Other administration 12
44
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air standards. An operating permit is issued after the installation is
completed and observations, investigations, and possibly source emission
tests demonstrate that the installation performs in accordance with the
conditions of the installation permit and in compliance with all air
pollution rules. This operational evaluation is conducted with district
and central office technical personnel in cooperation with local air
pollution agencies.
The Engineering Section conducts a statewide emissions inventory
that is updated annually. In conducting the inventory, a questionnaire
is mailed to establishments considered to be potential polluters. This
is followed up by phone calls and investigations until all suspected
sources have provided the data. The section also administers a tax
exemption program for air pollution control facilities and a surveillance
fee program. Special studies are conducted and the section performs the
computer programming and data processing functions for the Bureau. The
Technical Services Section conducts air quality monitoring and source
surveillance programs and provides laboratory analysis and instrumentation
maintenance support.
Manpower and Personnel
As part of its analysis of the Environmental Protection Branch, the
SRI project team performed an assessment of the manpower and personnel
functions that support the Branch operations. The primary focus of this
effort was to determine how the Branch derived estimates of the amount and
kinds of personnel required to meet organization goals. In modern prac-
tice, the objective of a manpower planning system is to establish a set of
functional programs and activities oriented toward meeting staffing require-
ments, determining present staff capability, assessing labor market condi-
tions, evaluating fluctuating service demands, and integrating these ele-
ments into a system for supporting organizational missions, goals, and
objectives. Such a framework enables cognizant managers to formulate
appropriate programs to meet their needs. Underlying such an approach are
the following assumptions:
45
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• Manpower planning is a derivative of the planning perspec-
tives and posture of the organization.
• The tasks of manpower planning exist to identify, delineate,
perform, and evaluate the human resource implications of the
organization's planning projections.
•
• The central purpose of manpower planning is to develop and
maintain the manpower capability required to support the
organization's missions, goals, objectives, programs, and
activities.
• The manpower planning system should also include the capa-
bility to determine present as well as future manpower needs
of local pollution control agencies.
In performing the manpower planning function, personnel charged with
the responsibility must be able to manage the forecasting process that
translates missions, program plans, budgetary allocations, and changes in
technology and facilities and productivity levels into short-term, medium-
range, and long-range manpower requirements. The outputs of this planning
process will be:
• Compilation of manpower needs by functional categories.
• Compilation of manpower needs by specific skills and experi-
ential categories.
• Summaries of manpower requirements by Branch, division, lower
echelons, and position categories.
An important element in this kind of a manpower system would be a man-
power skills inventory with a capability for recording and indexing the
experience, education, special skills, interests, job preferences, and
training and development increments acquired by all categories of Branch
personnel. Data generated by this system would:
• Enable manpower planners to identify individuals within the
organization by significant, personnel, experiential, and
performance categories.
• Enable planners to develop manpower profiles by programs,
projects, groups, and other functional designations.
• Assist in programming training, job rotation, promotion, and
succession planning.
A manpower concept of this type would require a backup system of
data collection instruments, summary output forms, and reporting formats.
46
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Manpower forecasts would be based upon an analysis of projected work loads,
budgetary allocations, technology-man interfaces, and manpower supply and
demand* The system would also take into consideration such process fac-
tors as attrition from all sources, promotions, transfers, training, and
recruiting strategies. If appropriate and economically feasible, these
programs could be produced by the use of computer technology. A simpli-
fied schematic design of the elements and processes incorporated in this
model is shown in Figure 8.
In performing its assessment of the manpower and personnel functions
in the Branch, the SRI project team used the above described manpower
planning concept as a framework for guiding its efforts, deriving its
findings, and recommending changes in the present mode of operation.
The responsibilities and disposition of the manpower and personnel
function as it is currently consitituted is discussed in the following
sections of the report.
Civil Service Commission
^Article XI, Jectipns 5 and 6 of the Constitution of_the State_of
Michigan specifies that the Civil Service Commission shall be nonsalaried
and shall consist of four persons, not more than two of whom shall be
members of the same political party, appointed by the Governor for terms
of eight years, no two of which shall expire in the same year.
The Commission's powers are vested in a State personnel director who
is a member of the classified service and who is fully responsible to the
Commission. These responsibilities are to:
• Classify all positions in the classified service according
to their respective duties and responsibilities.
• Fix rates of compensation for all classes of positions.
• Approve or disapprove disbursements for all personnel
services.
• Determine by competitive examination and performance exclu-
sively on the basis of merit, efficiency, and fitness the
qualifications of all candidates for positions in the classi-
fied service.
• Make rules and regulations covering all personnel transac-
tions and regulate all conditions of employment in the
classified service.
47
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00
MANPOWER REQUIREMENTS , ^^Z™** \ MANPOWER ACTION PROGRAMS
1 t*A" AoiLt T It0 |
r 1 1
* 1 * _i_
INVENTORY ,
BUDGET i WORK i AND ' MANPOWER OF EXISTING ^^^
ALLOCATIONS' PROGRAMS , lYricc PRODUCTIVITY ' ; MANPOWER ' ^P^
FACILITIES j SK(LLS
i i ! ••
1
1
r~ ~J
i ^
RECRUITMENT
1
i •
QUALITY AND | CURRENT ATTRITION
QUANTITY OF : , PROGRAMMED i ppL^I ,,
MANPOWER , TRAINING ' CAUSES
REQUIRED ' DEVELOPMENT '
! I
1 i
* A 1 K f
FUTURE, / T^£'ii \ pRO^CTED
DEMAND \. ^^00655 'O" / CAPABILITIES
\, ,/
I Mil/
INTERNAL
! TRAINING
AND
DEVELOPMENT
1
1
I
\
i
j PROMOTION,
REASSIGNMENT,
JOB EXPANSION,
COMPENSATION
1
r
1 .
! EXTERNAL
1 DEVELOPMENT
]
1 REQUIRED
•MMt MANPOWER
^^^^ ACQUISITION
AND
DEVELOPMENT
PROGRAMS
Feedback to
Influence Work i
Plans
I
i r^! i
FIGURE 8 MANPOWER PLANNING SYSTEM
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Personnel Division, Department of Natural Resources
The Personnel Division reports directly to the Administrative Bureau
Chief with the responsibility to provide personnel services to all manage-
ment and employees of the Department of Natural Resources. These func-
tional activities include the following:
• Interpretation of Civil Service rules, regulations, and admin-
istrative policies, Department personnel policies, and acts,
regulations, and policies of other agencies allied with
personnel.
• Preparation of all payrolls for the Department and maintenance
of the establishment list, attendance reports, records of sick
and annual leave, and records of compensatory time.
• Representation of the Department in hearings before various
boards and commissions including the Civil Service Commission.
• Processing of all employment requisitions for new and vacated
positions.
• Administration of the insurance program, unemployment compen-
sation, workmen's compensation, social security, and retire-
ment.
• Administration of training programs provided by the Civil
Service Commission.
• Management of the Department's Equal Opportunity Affirmative
Action Program.
• Processing of all classification studies.
• Conducting of employee grievance hearings and representation
of the Department with employee organizations.
Office Management Section, Environmental Protection Branch
This section currently reports to the Deputy Director, Environmental
Protection Branch, with the assigned responsibility to provide fiscal,
personnel, and office services as required. Functional assignments include
the following:
*
• Fiscal—Preparation of budget estimates, annual budget re-
quests, and other supporting datar checking of all expense
accounts, vouchers, and payrolls; preparation of all vouchers
and field requisitions and responsibility for all other methods
49
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used in handling and accounting for agency funds; maintenance
of all records on receipt and disbursement of Federal program
grant funds and matching State funds for air and water pollu-
tion control, water planning, and solid waste management.
Personnel—Verification of the Personnel Division's prepara-
tion and maintenance of all personnel forms and records in
accordance with Department regulations and agency needs;
understanding and interpretation of Civil Service rules per-
taining to position descriptions, hiring procedures, retire-
ment policies, leave and other absences, employee evaluation
procedures, travel regulations, and equipment operation pro-
cedures .
Office Services—Maintenance of all in-Branch service records,
expense accounts, vouchers, and other forms necessary or
desirable for fiscal, personnel, property, and other adminis-
trative matters.
Purchasing—Maintenance of the quality and quantity of sup-
plies, materials, equipment, and service required by the
Branch; preparation of invoice vouchers and requisitions;
comparison of deliveries with orders; and issuance of
approvals or rejections as necessary.
Intergovernmental Affairs
The intergovernmental function is unique when compared with other
subject areas covered in internal management studies. Intergovernmental
factors affecting agency processes are generally external to the organiza-
tion, often beyond its power to control, and may operate with disregard
for the internal problems that result from their impact. Analysis of this
function requires a capacity for looking at the force, effect, and influ-
ence of legislation on all governmental units and agencies and an ability
to relate common elements of these impacts back to the internal management
and organizational needs of the agency. A successful intergovernmental
affairs program therefore depends upon the development of a careful, real-
istic, and sympathetic evaluation of the aims, positions, and needs as
well as the political and legal responsibilities of the governmental enti-
ties involved. Formulation of a pertinent intergovernmental strategy
requires that all these factors be accurately assessed and taken into
account.
The SRI analysis indicates that Michigan has long enjoyed a reputa-
tion for sound, responsive intergovernmental relations in its environmental
protection programs. The State has developed and maintained effective
50
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State-Federal and State-local-regional relationships in a period when
many sister states have experienced much tension and conflict between these
levels of government in environmental matters. Because of the aggressive
and competent leadership of personnel responsible for environmental pro-
tection, the State has played an important role in developing and influ-
encing Federal policy in this area. This combined with a positive legis-
lative and administrative approach to Federal requirements has been
instrumental in pushing Michigan to the forefront in environmental protec-'"
tion management. As a result, Michigan's intergovernmental relations have
benefited in the following ways:
«
• Reduction of conflict between State and Federal requirements.
• Capacity to make positive use of Federal requirements and
funding in support of state programs.
• Constructive working relationships between State and Federal
administrative personnel responsible for developing policies
and guidelines, standards, aad operational programs in envi-
ronmental protection.
• An informed legislature able to assess the impact of Federal
requirements and funding opportunities within the context
of the State's needs and organized to respond quickly and
effectively with State legislation designed to translate
these realities into compatible State authorizing programs.
• Informed and balanced Commissions which develop the rules and
regulations for carrying out legislative requirements and set
the policies and guidelines for administering the responsi-
bilities and programs assigned to their jurisdictions.
• County, Municipal, Township, and other specialized units of
local government whose needs and problems with respect to
environmental protection are acknowledged and incorporated
in State programs and effectively represented by the State
government in its interactions with Federal agencies.
• State leadership in policymaking and program development on
international and interstate Commissions in which the State of
Michigan participates.
The field of intergovernmental relations, by its very nature, pos-
sesses a high potential for conflict and adversary behavior. This results
from traditional concepts of federalism which, in the past, have tended
to establish static patterns of hierarchical relationships with the
Federal government placed at the apex of the pyramid of Federal-state-
local governments. In its approach to program development, the State of
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Michigan has evolved an intergovernmental relationship style that resem-
bles a cooperative partnership with the different governmental entities
who may be engaged in similar environmental protection endeavors. In
doing so, the State has been successful in reducing much of the nonproduc-
tive conflict that often characterizes intergovernmental relations. At
the same time, the State has retained necessary mechanisms for handling
legitimate areas of disagreement through negotiation and adjustment pro-
cesses that are appropriate to the governmental interests involved. This
constructive mode of operation provides a meaningful precedent for develop-
ing new State roles that may be needed to meet evolving administrative
requirements for coping with the complexities in intergovernmental as-
pects of environmental protection.
The conduct and regulation of transactions between cognizant govern-
mental entities within the United States is rapidly undergoing significant
changes; this is especially evident in the environmental field. These
shifts result from fundamental changes in the exercise and delegation of
governmental authority at the Federal level. Recent Federal trends in
legislative and administrative practices seem to indicate that the Federal
government has assumed the significant policy role of developing the guide-
lines, standards, operational parameters, and conceptual requirements for
environmental protection programs while assigning the implementation and
enforcement roles to the states. Under this concept, the Federal govern-
ment will still retain overall supervision and backup enforcement authority.
It is quite apparent that this emerging governmental thrust will probably
necessitate major shifts and realignments in the conduct of intergovern-
mental relations.
These new directions in the exercise of federal authority present the
states with unique opportunities and challenges at all governmental levels.
An evolving and demanding role for the states is that of the "honest
broker" charged with distributing authority and responsibility to local
jurisdictions within the context of two apparently conflicting trends:
the perceived national need to centralize, standardize, and monitor the
critical parameters of environmental protection, and the equally urgent
need to return governmental decision making and control to the lowest
level of government—that is, to the people. The obligation for recon-
ciling these different processes will fall most heavily on the shoulders
of those officials responsible for ensuring state action. The states will
also be expected to assume full responsibility for the development, imple-
mentation, and support of their own environmental programs adapted to the
unique requirements of their constituencies. To successfully accomplish
this complex undertaking, the states will be required to develop new
patterns of intergovernmental participation. Furthermore, this role of
intergovernmental management will be performed against a background of
increasingly complex, interrelated institutional, technical, and socio-
economic problems associated with environmental protection.
52
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Within this evolving pattern of events, the field of intergovern-
mental relations assumes a new significance as an integral part of gov-
ernmental program requirements and processes. Intergovernmental rela-
tions has indeed become a substantive element in modern government
practice; its role has been subtly implied in the past but more clearly
expressed in recent legislative enactments. The "Water Pollution Control
Act Amendments of 1972" (Public Law No. 92-500, 86 Stat. 816, approved
October 18, 1972) is an example of this new reality. Included in this
legislative design, as well as in the regulations developed and promul-
gated within its framework, is a complex network or planning structure
designed to link a wide spectrum of interdependent elements into a sys-
tematic process for decision making, operations, and implementation in
water quality programs.
These developments will have considerable practical impact on the
operations of the Department of Natural Resources. The Environmental
Protection Branch will be required to evolve new programs and management
styles for the intergovernmental function. An increase in interactions
with local elected officials and representatives of organizations with
environmental interest can be expected; more individuals and groups will
desire more intense participation in development of complex environmental
plans and programs particularly if these activities have social, political,
economic, or recreational impacts on local or regional interest. Branch
mangement will be required to augment their skills in such disparate
activities as consensus building, conflict management, and the provision
of assistance in negotiating the allocation of burdens and benefits among
Michigan's local jurisdictions and the constituencies they represent.
In the area of water quality alone, Branch management will have to
work closely with different groups or clusters of local units of govern-
ment on matters related to water quality planning, operations, and control.
Its responsibility for statewide water quality standards will require the
Environmental Protection Branch to maintain an equitable basis for deal-
ing with local and regional jurisdictions in setting the critical param-
eters governing their planning requirements especially in such sensitive
matters as availability of funding, industrial pretreatment requirements,
and effluent limitations. All Environmental Protection Branch actions
will invite close scrutiny and comparisons with restrictions and require-
ments imposed on other areas of the State.
To effectively manage the intergovernmental function, Branch manage-
ment will need to develop formal systems and methods for monitoring and
controlling its diverse processes: plan management; interlocal agreements;
intergovernmental coordination; grant processing; scheduling construction,
monitoring, enforcement, compliance, and the like. The local/regional
53
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jurisdictions will also expect the Branch to provide governmental pro-
cessing support as well as technical expertise in formulating their
substantive programs and services.
This requirement for enhanced capabilities in intergovernmental pro-
cessing is also related to subtle integrating factors that are rapidly
becoming critical to all aspects of environmental protection. Programs
in air, water, solid waste, resource recovery, and land use planning can
no longer be considered independent functions to be dealt with in isola-
tion. In a growing number of cases, the advent of sophisticated tech-
nology has made possible flexible trade-offs of different kinds and
qualities of discharges between the environmental resources of air, water,
and land to achieve desired end results. It is no longer possible to
ignore these interdependencies when making decisions that affect alloca-
tions of discharges, either on a case-by-case basis or on matters related
to broader regional and statewide environmental protection issues.
Because it will be necessary for the Branch to recognize and deal
with these interdependencies, the complexities of its intergovernmental
processes will grow. The importance of the intergovernmental function
within the context of the organization is also apparent, especially in
light of recent amendments to the Water Quality Act, the developing body
of administrative rules and regulations implementing the act, and newly
emerging administrative issues related to air quality, transportation
planning and control, and pending omnibus of solid and hazardous waste
control legislation. These dynamic processes, coupled with possible major
shifts in the locus of government authority, suggest that the Branch re-
quires a new perspective with which to view its present intergovernmental
operations.
Stakeholder Processes in Environmental Protection
During the course of this study, the SRI project team conducted
intensive interviews throughout the State with individuals from the differ-
ent interest groups who represented a distinct point of view toward envi-
ronmental protection activities in the State of Michigan. Although it was
not possible to contact all the interested groups because of time and
budgetary constraints, it is felt, however, that the interview sample on
which the following discussion is based is a reasonably representative
cross section of key groups with a meaningful stake in the State's envi-
ronmental protection activities.
The essential focus of the SRI survey was to determine the scope and
programmatic thrust of each interest group. This step was deemed necessary
54
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because such groups exert an important and legitimate influence on the
character and direction of the Branch's environmental programs. Because
the aims and prescriptions set forth by these groups are often conflict-
ing, it is essential for the management of the Branch to fully understand
stakeholder interests and their possible effects on the public interest
when developing the State's strategic posture with respect to policies,
programs, and actions.
Environmental protection laws and programs consist of regulatory or
enforcement activities coupled with alleviative measures designed to miti-
gate inequitable impacts. For example, the requirement for industry to
meet water and air quality standards is mitigated by provisions in the
laws that extend tax exemptions to those facilities that must be installed
by industry to comply with a given set of standards. Also, under State
and Federal policy, municipalities are given grants for constructing waste-
water facilities but at the same time are brought under legally enforceable
requirements to provide and operate such facilities according to specified
performance standards.
The policy framework established by legislative action suggests the
desire to maintain an equitable balance between the obligations imposed
upon private and public entities by exercise of the State's regulatory
powers and the recognition that such entities are entitled to reasonable
redress from these burdens because of the public benefit that is likely
to accrue from these transactions. The Environmental Protection Branch
and its Commissions, because of their roles as implementing agents of this
legislative framework, receive considerable attention from a wide spectrum
of interest groups who are impacted by the resulting operative actions.
Even with the expressed intent to maintain a reasonable equitable balance,
it is clear that the burden of environmental protection is likely to fall
more heavily on some groups than on others. On the other hand, it is
also apparent that all the desires and expectations of groups interested
in enhancing and protecting the environment cannot be met regardless of
the best of intentions.
Under these circumstances, the management of the Branch is confronted
with the responsibility for resolving complex issues into decision pro-
cesses that are reasonable, equitable, and in the public interest. This
task is even more formidable because the resulting decision must be devel-
oped within the context of inconsistent and often conflicting stakeholder
values, perspectives, and interests. It stands to reason, therefore, that
the more easily and readily the stakeholder groups can perceive the envi-
ronmental programs and activities of the Branch as a legitimate and fair-
minded exercise of its powers and responsibilities, the greater is the
likelihood that the Branch will receive public support in administering
legislative programs.
55
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The SRI project team found a broad base of public support for the
quality, competence, and reasonableness of the Branch's performance among
the stakeholder groups that were interviewed. Although some of the groups
interviewed hold sharply critical positions based on differences resulting
from opposing philosophies and expectations with respect to the current
direction and thrust of Branch programs and activities, in no case did any
group feel that its position was absolute or nonnegotiable. There appeared
to be a general recognition that the adversary nature of their position
was founded on goals and objectives that must compete with those of other
interest groups desiring to influence the overall direction of the State's
environmenta1 programs.
It was also apparent that those interest groups most actively engaged
in the attempt to develop broad bases of public support for stronger envi-
ronmental programs were, for the most part, inclined to assume a long range
view of the effort required to bring their programs into being. These
groups hold strong views on what constitutes effective environmental pro-
tection and are not easily discouraged by adverse decisions or setbacks.
In the main, their efforts are directed toward the accomplishment of the
fundamental objectives underlying their programs. They are seldom dis-
tracted by transient issues that are not directly related to their central
concepts. Such stakeholder groups serve an important function in main-
taining the long-term stability required to develop affirmative environ-
mental protection programs.
A substantial portion of the criticism generated by stakeholder groups
is based on careful study of the complex issues involved. It is fair to
say that the Branch is subject to a wide range of competent criticism from
industrial and commercial interests adversely affected by the programs of
conservation and environmental groups seeking stronger regulatory measures
or other groups with related but indirect interest in these activities.
In this respect, the Branch is indeed fortunate to be stimulated and chal-
lenged by informed and constructive criticism directed toward its programs
and actions. The SRI project team found most of this criticism to be tem-
perate and responsible.
Michigan's stakeholder groups vary from formally organized special
interests of long standing to loosely associated groups of individuals
joined for the purpose of addressing a specific action of a Commision.
A representative listing of these groups is shown below:
• Construction and economic development interests
• Conservation clubs
• Agricultural interests, associations, and clubs
56
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• Lumber interests
• Associations representing industry and commerce
• Municipal, County, and Township associations
• Environmental protection groups
• Tourist and recreation interests
• Hunting and fishing interests
• University centers
• School groups and educational programs
• Civic associations
• Student groups and student associations.
The strength of the State's present environmental programs is founded,
in part, on the capacity of a balanced spectrum of groups to perceive their
own self-interest, to organize their programs effectively, and to present
their points of view on significant issues in public competition with other
points of view. The various components of the Environmental Protection
Branch have been effectively handling their relationships with the State's
stakeholder groups but usually on an individual basis. The recent execu-
tive order which consolidated the State's environmental protection activi-
ties into a single branch within the Department of Natural Resources offers
the State of Michigan an excellent opportunity to develop a new management
posture for meeting evolving stakeholder needs and requirements in the
future.
57
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IV TECHNICAL OPERATIONS
Technical operations, as defined by the SRI project team, are those
functions that utilize the principles, findings, and methodology of science
and technology. Practitioners of technical operations are usually trained
in some aspect of the physical, biological, social, and engineering
sciences. Not all activities subsumed within this concept are technical
in nature. Within an organizational setting technical operations can
also be related to either individuals or the jobs they perform; more
specifically, technical operations refer to those aspects or functions
of the work situation that are technical in nature. In the discussion
that follows, the scope of technical operations will be viewed in terms
of the above definition but must also be conditioned by the definitions
given the remaining organizational functions discussed in this report.
The technical operations of the Environmental Protection Branch of
the State of Michigan's Department of Natural Resources have been examined
within the framework of a technical concept of environmental protection.
The results of this assessment are presented as a series of findings and
recommendations that can be applied both as generalizations pertaining
to the Branch as a whole or as specifics that relate to a particular
organizational component or activity. The environmental concept, used
in this study as the basis for deriving the SRI findings, is discussed
in the following sections of this report.
It should be emphasized, however, that the findings and recommendations
relevant to the technical operations within the Branch may also have some
impact on those findings and recommendations derived for the other func-
tional elements. Apparent conflicts can be resolved by compromise or
by ranking the limited goals served against some broader objectives.
The purpose of environmental protection is to restrain the rate of
environmental degradation; that is, to slow, stop, or reverse processes
that may be considered deleterious to predetermined standards of environ-
mental quality. The expression "environmental degradation" raises two
questions: What is the environment, and what is meant by degradation?
In the case of environmental protection, the environment has several
meanings. It can mean the physical environment, such as the level of a
lake, the flow of a river, or the contours of the land. This term may
also refer to the biological life space of fish or wildlife habitats or
59
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even the ecological system that sustains a sport fishery. The concept
may include the total human situation, such as physical and psychological
health, and socioeconomic well-being. The particular definition of environ-
ment that is used is often a function of the way the environment is
measured or used. Degradation, on the other hand, is a value laden term
for undesirable change. Because values are derived from human beliefs,
perceptions, and needs, they are usually expressed in a pattern of
priorities established by societal consensus.
Environmental change results from both natural processes and the
actions of man. The natural process of flooding may produce undesirable
change, if man has chosen to settle in the flood plain. Disposal of the
residues of man's activities in the air or water or on land may produce
undesirable changes because the uses of these media may become less wanted
and more costly. Accordingly, environmental protection functions to
intervene in the various natural and human processes to establish a
priority of uses. This statement implies that the mode of intervention
can be readily related to its effects. To do so requires a detailed
understanding of the environmental system from several points of view:
• What are the cause-effect relationships between man's
activities, environmental characteristics, and the biological
systems that depend upon the environment?
• What are the possible modes of intervention by environmental
protection and how do the effects propagate through the
entire system?
• How can the effects be measured and how do the measurable
effects relate to the objectives desired as environmental
protection?
Human actions that affect the environment and their resulting impact
on the social system are accompanied by a pattern of transactions that
involve individuals and interest groups. In the former situation, these
transactions represent causal elements, and in the latter, corresponding
effects. Such transactions carry implicit and explicit values such that,
if the system could be traced, these would represent a redistribution
of values. This redistribution of values identifies, in effect, the costs
and benefits as well as the recipients for a given action having environ-
mental effects.
Governmental protection agencies have often intervened at this trans-
action level. Environmental protection agencies have generally granted
permits to build, remove, modify, or discharge without an overall environ-
mental perspective. Rather, there appears to be a heavy dependence upon
60
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technical criteria established within the agencies' authorization powers.
These standards can be readily expressed in physical-chemical or biological
terms; they can also be developed for a variety of reasons. Some examples
are:
• They represent a certain level of public health
• They represent protection of certain uses
• They represent a level of technical feasibility
• They are easily administered
• They^ treat everyone equally
• They represent a compromise of different interests
• They are easily measured properties.
Environmental objectives and standards are established in the author-
izing legislation often in broadly defined terms that may invite varied
interpretations. It is commonly held that they are an expression of the
will of the people. Inasmuch as such standards can be applied generally,
this may approximate the situation if the legislative process is truly
representative. In any case, this is the level at which political
settlements are made among conflicting interests. This situation may be
theoretically applicable in a general sense but may require practical
adaptation to fit the specific case. As standards are developed and
applied through the permitting process., there may be strong local interests
and opinions to consider. The process must be capable of accommodating
this body of opinion if it is to function successfully.
The basic function of granting permits for individual actions that
meet specified standard conditions and are responsive to local interests
is institutionalized in the environmental protection agency. From a
technical point of view, this requires several direct and ancillary
functions:
* Predicting the effects of an action. As a minimum this will
require a determination that standards be met. However, there
may also be broader interests to be satisfied that will re-
quire determining the resultant environmental quality,
biological effects, or socioeconomic impacts.
• Surveillance of the action. This requires a determination
that the action is accomplished under the conditions imposed.
Inspections during and after construction and operational
monitoring are vital activities.
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• Monitoring of the effects. The effects will be manifested as
incremental changes in environmental quality, biological
effects, and socioeconomic impacts related to individual and
collective actions. However, these changes can only be related
to the systems in which they are felt. Therefore, candidates
for effects monitoring include parameters related to the in-
cremental changes, measurements of baseline characteristics,
and descriptions of the relevant systems and the interaction
process.
• Special studies. Certain characteristics of affected systems
and interaction processes can best be determined by carefully
designed studies rather than long term monitoring. These may
be analytical, laboratory, and field studies having specific
objectives, a carefully delineated scope, and a limited
duration.
• Planning. Because the demands will exceed the available re-
sources, at least initially, planning is required that
evaluates alternatives and sets a priority for addressing
the set of desired and necessary actions. The criteria for
ranking proposals should be related to the need for environ-
mental improvement, the improvements to be provided, the
anticipated biological effects, socioeconomic impacts, and
local concerns, and the resources necessary.
• Awareness and public participation. The technical facts of
a proposed action should be explained to the concerned and
affected public in terms that they can comprehend if their
opinion is to be based on an informed judgment. In turn,
the expressions of public sentiment must be related to the
technical aspects of the proposed action. Public partici-
pation is an information exchange process that is accomplished
by translating between sophisticated and detailed technical
knowledge and the layman's language and point of reference.
The difficulties involved in accomplishing this objective
should not be underestimated.
• Data processing, storage, retrieval, and display. The environ-
mental protection functions listed above generate the require-
ments to handle large amounts of data, to conduct repetitive
complex calculations; to develop correlations, trends, and
functional relationships; to model complex systems; to
evaluate and rank alternatives against objective criteria; to
generate exception and trend reports; and to display results
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in the form of graphs, maps, and pictorial representations.
Therefore, this data management function is an important
support to the other functions listed.
• Technology acquisition. The technical operations functions
of environmental quality protection requires a current
knowledge of technical facts, concepts, procedures, and
methodologies. This is embodied primarily in persons but
often for an expression in practice requires interaction
between a knowledgeable individual and a complex machine or
instrument. Knowledge is constantly increasing and new
machines are constantly being devised; thus, technology
acquisition is a continuous process of training and education
as well as equipment procurement.
At the state government level, these functions may be split among
different organizational entities in several ways. The division may be
according to disposal media (air, water), categories of waste (liquid,
solid), some combination of media and categories (air, water, solid),
or some jurisdiction over type of actions involved (water resources,
highway construction) or type of effect generated (fish and game, public
health). The tendency, which is exemplified by Governor Milliken's
executive order, is to bring these functions together into a single agency.
The problem of conducting an effective program then shifts from a posture
of interagency coordination to that of organization structure and manage-
ment effectiveness.
The current state of the environment gives rise to State institutions
responsible for maintaining the quality of the environment that respond,
for the most part, to two sets of mandates: those derived from the
Federal government and those imposed by the state legislature. In practice,
Federal mandates are generally incorporated into state laws to which the
state agency is directly responsive. Accordingly, there are Federal-state
programs and state-only programs. The detailed requirements of Federal
programs that relate to the technical functions to be conducted by the
state agency are promulgated in a series of Federal regulations and
guidelines. Although. Federal programs provide funding support for state
environmental activities and make provision for Federal intercession in
the event that responsibilities mandated to the states are not performed,
ample room remains for the states to express their own philosophies,
management styles, and application of technical capabilities. Under these
circumstances, it is not surprising to find that response patterns of the
states do not follow a uniform course; indeed, the variety of state re-
sponses often places considerable management pressures on the staffs of
the Federal administrators.
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The Federal government has taken an aggressive role in developing the
policy framework for environmental protection. At the same time, however,
several states have initiated strong innovative programs in many areas.
When the Federal government has moved legislatively or initiated a rule-
making action in an environmental area, there has been a tendency to pro-
mulgate the minimum it wishes to achieve nationally. In this process, the
Federal government does not ignore the need, wishes, and experiences of
the states, but the end result of this action is to preempt most state
action except that necessary to respond to the Federal mandate. Therefore,
the Federal momentum and direction both with respect to legislation in
environmental areas that are not adequately protected and with respect to
rule making in areas that are for the time being legislatively settled
are a clear indication of the manner in which the technical functions of
environmental protection will have to be conducted at the state level.
Several important directions can be discerned in Federal environmental
initiatives:
• Environmental regulation on an intermedia basis. Existing air
and water quality legislation independently put severe limits
on the discharge of residual materials to these media. As a
result, more of the material that is difficult to treat so
that it may be discharged to the air or to water bodies is
being disposed on the land. Legislation has been introduced
to control these hazardous wastes. The legislation would
store the most hazardous wastes in Federally operated re-
positories. The less hazardous materials would be disposed
by commercial operators on licensed sites. The development
of regulations to implement state programs to conduct a
hazardous waste program could provide a vehicle for rethinking
the intermedia implications of existing state implemented
Federal programs.
• Land use implications of environmental regulation. It is
evident that air quality standards cannot be met by applying
emission limits to all sources. Nevertheless, in some
situations the concentration or numbers of sources will have
to be brought under control. Federal regulations with respect
to transportation controls, complex sources, and nondegradation
are significant excursions into control of the use of land. It
is likely that control of discharge of wastes from point sources
into waterways will be supplementary measures to achieve
adequate water quality in many areas. If technical solutions
to the problem of pollution from dispersed or nonpoint sources
cannot be found, the only recourse will be to control the use
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of land from which the pollution runs off to the waterway.
This may be accomplished through control of land use or the
activities that take place on it or perhaps indirectly
through the materials applied to it. Broad Federal land
use legislation is now pending; implementation at the state
and local level will require accommodation to the land use
imperatives of environmental quality regulation. In addition,
there may be environmental quality implications of land use
policies. Other special areas of proposed land use control
in which environmental quality can be affected include
coastal zone management, siting of energy facilities, and
surface mining.
Resource recovery. The recovery of resources from residual
materials will gradually take on an increased importance in
environmental quality protection. The principal focus will
be the solution of solid waste problems in metropolitan areas.
However, as increasingly strict air and water emission limits
are applied, industrial operations will seek and find resource
recovery opportunities within a plant and among industries.
State agencies can act as a clearinghouse to facilitate inter-
company transfers of residual materials. The recovery of
resources from solid waste materials will focus on three con-
cepts. These include the recovery of energy from the organic
fraction of the solid waste, the recovery of secondary materials
that could be recycled and used by various industries, and the
direct reuse of selected materials. Wastewater reuse will
take on increasing importance. Direct reuses will become im-
portant in some water-short areas. Indirect reuse, such as
land disposal and groundwater recharge, may become feasible
alternatives to other modes of wastewater treatment. The
energy content of heated wastewater may become an important
resource for several different uses. The concept of resource
recovery reinforces the need for an intermedia approach to
environmental quality protection. It also broadens the scope
to include regulation of materials that are used in products
and the design of the products themselves.
Public participation. The most recent major Federal environ-
mental legislative mandate, the Water Pollution Control Act
Amendments of 1972, states in section 101(e): "Public par-
ticipation in the development, revision, and enforcement of
any regulation, standard, effluent limitation, plan, or
program established by the Administrator or any State under
this Act shall be provided for, encouraged, and assisted by
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the Administrator and the States," The rules and regulations
relevant to State Program Elements Necessary for Participation
in the National Pollution Discharge Elimination System that
have been published describe procedures for public notification
of proposed actions and hearings, the format and content of
documentation to be made available, the facilities for public
viewing of relevant materials, the protection of confidential
information, and the procedures for determining the need for
and conducting of public hearings. The states are encouraged
to expand upon the rules given. The art and science of
achieving effective public participation in highly technical
decisions is still in an embryonic stage. As the process now
works, the responsibility rests largely with the public. It
takes a determined, skillful, intelligent, and articulate
individual to influence the decision-making process. In the
future the responsibility can be expected to fall on the
agency. It will then be its responsibility to seek and obtain
a valid picture of representative public sentiment.
Regionalization. Both the Federal air and water quality
legislation allow for and encourage planning and adminis-
tration of environmental quality control programs by regional
agencies. The rationale is that problems that extend across
jurisdictional lines can best be solved by an agency whose
authorities extend across the same boundaries. A further
justification, which is reinforced by the impetus for public
participation, is that the local agencies are closer to the
needs and desires of the people affected. State agencies will
have to make adjustments that depend upon the regulations
under which the regional programs are implemented. If the
regional agencies are essentially independent of the state
agency, then the impact upon the state agency consists of
losing a part of its program. In other situations the state
agency may be in a position of ensuring the quality of the
local agency's work.
Balancing of national objectives. Under this policy which
is articulated in the National Environmental Policy Act,
unavoidable environmental damage must be justified in terms
of other national benefits. This justification is made
public in an environmental impact statement which discusses,
among other things, the range of alternatives that were con-
sidered in selecting the desired action. Many of the actions
administered by state environmental quality protection agencies
come under the requirements of the environmental impact
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statement process. Examples are new source permits and grants
for municipal wastewater facilities under the Water Pollution
Control Act Amendments of 1972. The implications of this are
two-fold. The record of values established by the process
can, in time, provide a new criterion of social acceptability
for setting standards. Secondly, environmentally damaging
actions that may not be permitted under existing standards
may be allowed because of pressing national needs. Meeting
future energy needs is a good example that began with approval
of the Alaskan pipeline. Another example is relaxation of
air quality standards in metropolitan regions for which highly
unpopular transportation plans have been promulgated.
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V FINDINGS AND RECOMMENDATIONS
The salient problem areas that emerged from the management review
and functional analysis of the Environmental Protection Branch are iden-
tified and discussed below. The recommendations that follow from these
findings are designed to provide alternative approaches for coping with
these organizational issues.
Management Review Findings
1. The present organization ia overly fragmented and this results in
difficulties in coordination and internal communication between
related: programs and activities. The historical pattern of organ-
izational growth is based upon the enactment of new legislation;
new autonomous groups are created to cope with additional responsi-
bilities assigned by the legislature. The proliferation of these
groups over the years results in excessive redundancy and complex-
ity. Other impacts on the organization are:
• Similar responsibilities and duties are performed by several
groups.
* Involving appropriate personnel in interdependent organizational
transactions is becoming more difficult.
• Maintaining adequate communication between the numerous organi-
zational components is time-consuming and costly.
• Operating philosophies and field boundaries of the components
brought together by the recent executive order reorganization
are strikeingly different and present the possibility of "cul-
ture conflict."
• The organization does not present a common face to its clients
or to the general public.
• New legislation generally affects several groups but activities
associated with it are usually assigned to one specific group.
• An integrated organizational thrust is not evident.
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2. New responsibilities are added to existing units without considera-
tion of whether or not the required resources are available to per-
form the work. At best, resources tend to be late because of the
characteristics of the budget cycle which are not usually congruent
with the time-frame in which the work is allocated. Budget approval
is based on considerations other than those related to work require-
ments. The new budgeting system
-------
As changing legislative concepts and programs at both the Federal
and State levels continue to make their impacts felt, pressures for
corresponding changes within the organization will become more in-
sistent. The present organization does not appear to be sufficiently
adaptive to cope with these pressures. It is probable that if addi-
tional responsibilities were placed on the present operational struc-
tures, a diminution of effectiveness would occur. Rerationalization
of present organizational and managerial concepts are the most prom-
ising avenue for favorable results.
6. Day-to-day decisions made by individuals at the technical and opera-
tional levels appear to be based upon personal estimates and best
Judgments of what the system requires rather than a body of policy
guidelines developed to direct the operations of the organization.
In the absence of a codified policy structure, decisions made may
or may not reflect the values and best interests of the Branch or
the Department despite the best of intentions. SRI.'s observations
of the Branch's operations revealed the following:
• The role of policy in the conduct of Branch activities is not
clearly understood.
• There does appear to be a general understanding throughout the
Branch that policies are established by the:
- Natural Resources Commission
- Water Resources Commission
- Air Pollution Commission
- Director, Natural Resources Department
- Deputy Director, Environmental Protection Branch
- Chief, Water Management Bureau.
• There is no written reference available specifying the conditions
under which policies are issued or guidance on the subject matter
covered.
• There does not appear to be a formal system for:
Generating policies.
- Organizing policies in a structured, documented format.
- Specifying the organizational level at which the work will
be performed.
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- Providing a methodology for facilitating the retrieval of
policy documentation.
- Providing a methodology for updating policies to meet chang-
ing conditions.
- Monitoring the actions taken to ensure that the desired
results are obtained.
7. Management controls used in the Branch fall into three main classi-
fications:
• Personnel Controls—Specified in budgetary and Civil Service
requirements. To add a person to the payroll, a position de-
lineating responsibilities and duties must be prepared, submitted,
and approved. Also, the position and accompanying salary alloca-
tion must be provided within the budgetary procedure. This kind
of control prevents the addition of excess personnel to the staff.
Problems can result, however, when personnel are removed from the
payroll once the specific need has been fulfilled. Although the
possibility of carrying excess personnel exists, in reality it
does not occur because of the rapid expansion of the Branch with
corresponding increases in requirements for personnel.
• Budget and Expense Controls—The budgeting process now in use
in the Branch appears to be a workable system. A flow diagram
outlining the sequence of steps in the system is given in Fig-
ure 9. A possible shortcoming in the system, however, is the ab-
sence of a direct relationship between the amount of resources
provided in the budget and the actual amount of resources re-
quired to accomplish the assigned work. The general process
now in operation appears to be based on the assignment of new
work to the existing organization when new legislation is enacted,
while the provision of the resources to perform the work is allo-
cated to subsequent budgets. Even then, the allocation of the
required resources will be contingent upon the legislative urgen-
cies of the moment. In short, the budgetary process tends to be
more an accounting procedure than an effective management operat-
ing tool. Basically, the concept of the budget employed as an
operating plan expressed in financial terms is not part of cur-
rent management practice in the Branch.
• Program/Project Planning and Control—The primary evaluation
technique employed in program/project planning is the Program
Revision Request Systems. Little or no use is made of this sys-
tem in the Branch. Most of the managers interviewed had never
72
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B. O. B.
• Request for Planned Additions
of > $10,000
(Expanded Budget)
(May, 1972}
j DEPARTMENT
; • Determine Planned Additional i
1 Expenditures of > $10,000 ,
; • Advise B. O. B. |
; (May. 19721
B. 0. B.
* Requested Expanded Budget
by PBES Element
• Request Continuing Budget
by PBES
(July. 19721
-
DEPARTMENT [
• Prepare and Submit Total FY7<
Budget by PBES Element
• Establish Priority Sequence
(August, 1972)
»l
1 B. 0. B.
;• Review Total FY74 Budget
j Submission
|* Request Additional Information
; From Department
'(October-December, 1972)
B. O. B.
• Prepare Governor's Budget
(January. 1973)
I
HOUSE OF REPRESENTATIVES j
COMMITTEE 1
• Review Bill I
i HOUSE :
| FLOOR i
• Consider FY74 Budget
SENATE
COMMITTEE 1
• Review BUI
• Request Justification
u
DEPARTMENT!
• Appear and Justify |
, JOINT COMMITTEE
• Resolve Differences t
• Recommend to Governor
GOVERNOR
• Sign Bill !
B. O. B.
• Notify Department of Allotment!
• Indefinite Source of Funds
(July 15, 1973)
j DEPARTMENT
• Bring 74 Allotment by PBES
(Basis For FY76 Budget)
(August 20, 1973)
DEPARTMENT
Divide By: Bureau of Water
Management
- Air Pollution
- Solid Wastes
- Specific Project
DEPARTMENT
Divide Bureau of Water :
Management by Division <
Notify Division Chief of
Budget by Expenditure
Classification
FIGURE 9 BRANCH BUDGET SYSTEM
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used the system nor were they familiar with its purpose or
methodology.
8. The use of documented procedures does not appear to be widespread
in the Branch. SRI team members found only limited instances of
sound documentation in existence. Much of the Branch's fund of
technical, operational, and administrative know-how is carried
around in people's heads. This situation poses serious problems
to the Branch in the event that key individuals die, retire, or
decide to leave the employ of the State. The lack of a commonality
of procedural knowledge leads to excessive specialization with the
resulting reduction in opportunities for career growth and advance-
ment. The Branch appears to have too heavy an investment in partic-
ular individuals and too little emphasis on a data base of documented
procedural knowledge or a practical system of personnel backup.
9. In general management practice, establishment of work priorities is
related to:
• Management's identification of those areas considered vital to
accomplishment of the organization's missions and objectives.
• Classification of those work areas in terms of relative impor-
tance.
• Optimum deployment of resources such as people, money, tech-
nology.
• Difficulty in performing the various tasks.
• Knowledge and skill available to perform these tasks.
• A plan for implementing the selected pattern of choices.
It is not readily apparent that work priorities within the Branch
are based on a systematic consideration of the above factors. Top
priority appears to be given to those legislative pressures which
require the shortest response time. A legislative act specifying
response actions within 30 days is usually given priority over an
action required within a 60-day period, regardless of when the work
request was received. In those cases where a definite response time
is not specified, it is likely that these pieces of work will re-
ceive low priority and be delayed or not completed for an extensive
period of time. The observations of the SRI project team indicate
that the setting of priorities within the Branch is generally left
to the discretion and judgment of the Section Manager.
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10. Performance appraisal has been traditionally used by management to
compare the contributions of individuals or groups and hopefully
provide an objective means of justifying salary or promotional
actions. The performance review process is also regarded as an
opportunity to motivate employees to improve their performance.
Recent advances in management practice have drawn attention to
some of the more systematic uses that can be derived from this
tool:
• Integration of organizational objectives with the individual's
own personal goals and aspirations.
• Assignment of individual accountability and correlation of
this accountability with work flow and unit responsibility.
• Identification of program needs.
• Identification of technical training and personal development
needs of individuals and groups.
• Identification of individuals having potential and talent.
• Personal counseling and career development.
The recent review of management practices made by the SRI project
team revealed that the use of the appraisal tool is not fully
utilized. Present practice appears to consist of:
• Mandatory performance appraisals conducted at the end of the
third and sixth months after an individual is employed or
changes jobs.
• Performance appraisal can be conducted at other times to draw
attention to either outstanding or substandard performance.
11. There are three functional areas of planning that are applicable
and useful for facilitating the operational efforts of the Environ-
mental Protection Branch. These can be categorized as:
• 3trategic Planning—-The development of the conceptual framework
for defining the essential character and posture of the organi-
zation and providing the guidelines for allocating resources
and structuring the programs and activities for achieving the
desired goals.. The strategic planning function also serves as
the mechanism for dealing with uncertainty and change by deter-
mining the internal conditions required for adaptation to exter-
nal realities.
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• Operational Planning—The programmatic framework that determines
the sequences and schedules the significant activities, processes,
and events required to efficiently implement the organization's
goals and strategies. This particular aspect of planning is pri-
marily concerned with such internal processes as budgeting, time/
cost relationships, formulating decision rules for operational
control, and appraising, measuring, and influencing management
performance so that the desired results set forth in the strate-
gic plan occur as projected.
• Preparation of Plans and Programs Required by Law—This kind of
planning is in response to Federal and State laws and regulations
requiring continuing planning for relating resources to programs
and services for achieving desired states of environmental quality.
The planning activities observed in the Branch appear to be primarily
oriented to the preparation of plans and programs required by law.
Other types of planning were not readily visible possibly because:
• Strategic planning as an organizational and managerial concept
is not well understood and has not been practiced in the past.
• Operational planning is more familiar but most individuals inter-
viewed were too busy coping with the day-to-day pressures to make
the time investment that systematic planning requires.
• The prevailing mode of operation is to work one's way out of
problem situations by reacting to events as they occur rather
than anticipating probable occurrences and making provisions
for coping with them.
12. The information needs of the Branch can be divided into two main
categories, management information and technical operations infor-
mation. The following concept has been developed as a framework
within which the Branch can view its information needs in relation
to its goals and purposes. This concept was used as a basis for
appraising the present information activities.
• Management Information—Data categorized under this heading are
designed to fulfill management's need to provide effective
decision-making capability at all organizational levels. To
accomplish this purpose, people, equipment, and procedures must
be arranged in such a manner that information related to the
Branch's present and future operations can be systematically
collected, processed, and analyzed in a reliable and timely
76
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manner. When this function is effectively performed, managers
are better able to make decisions designed to optimize the effi-
ciency of their operations and to control the direction and scope
to conform to the intent of those decisions. To accomplish this
objective, it is necessary to receive management support in the
following areas:
- Data Collection—Information related to planning, resource
management (people, money, and facilities), costs control,
time and activity reporting, and work status in respect to
schedules and performance.
- Information Analysis-—Requires the capability to aggregate
collected data in accordance with program and process needs
and relate these variables to organizational effects.
- Information Dissemination—Effective management performance
at all organizational levels depends on the receipt of rele-
vant information that is timely, accurate, complete, and in
the proper format.
Technical Operations Information—-Data collected under this head-
ing are organized to support the diverse functions involved in
managing environmental quality. The key functional processes
comprising this activity are:
- Adopting, maintaining, and updating environmental quality
goals, objectives, criteria and standards, and policy guide-
lines.
- Using the appropriate technical processes and environmental
management actions required to support the achievement of
environmental goals.
- Organizing authorities and responsibilities for the environ-
mental quality management program.
- Conducting monitoring, evaluation, and reporting programs '
to support the technical operations.
- Allocating resources to the various organizational elements
to support their authorities and responsibilities.
The technical operations information system is most directly
related to the organization's monitoring, evaluation, and
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environmental status reporting programs. An effective informa-
tion system should (1) provide feedback for process control,
(2) establish an environmental quality baseline and record
historical trends, and (3) provide outputs that contribute to
the understanding of the relationship between environmental re-
source use and the corresponding effects. Ideally, a technical
information system should be structured around an environmental
concept model which has the capability to describe the interre-
lationships between human activities, the resulting environmental
effects, and their socioeconomic consequences. Such a system
would enable management to visualize how environmental quality
management decisions and interventions would affect the interre-
lationships between system variables in accomplishing selected
goals. It is recognized that in any specific situation the scope
of management actions may be relatively limited and the informa-
tion may also be constrained. A possible environmental concept
model—An Environmental Effects Framework—is described in the
discussion of Technical Operations in this chapter of the report.
Under such a system, information would be processed in the follow-
ing manner:
- Data Collection—Data would be required by various means rang-
ing from counts of activities or transactions, samples of emis-
sions, discharge and environmental media, instrumental measure-
ments to synoptic monitoring by remote sensing. In gathering
this data, critical concerns would be:
• Accuracy—How well do the results represent reality?
• Validity—To what parameter (geographic, volumetric,
mass, or population limits) does the data relate?
• Perishability—For what period of time is the data valid?
- Data Management—This includes those activities that facili-
tate input, validation, retrieval processes, and other trans-
actions with the data base. For example, when the information
analysis function (see below) requires data, the appropriate
index is interrogated and the requested data is retrieved and
provided for the completion of the analysis.
As data enter the system and reports are generated, it may be
necessary to convert both the format and the medium, i.e.,
data may have to be keypunched or computer output may need
to be placed on microfilm for storage, and so on. As the
data base is expanded, the index files and cross-reference
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linkages must be updated to enable the required pieces of
data to be located efficiently.
- Information Analysis—The basic querying process of an envi-
ronmental information system relates a source of emissions
to the environmental effects in proportion to the influence
exerted by the control actions. In answering any specific
questions, something unique must be stated or assumed about
the source, thus enabling either the control factors or the
effects to be determined as a function of the other. Such
questions can be stated directly or in an inverted form.
The information system should have the capability of classify-
ing and processing data so that the information needs (in the
form of user questions) of the Environmental Protection Branch
can also be met in terms of cost/effectiveness.
- Information Dissemination—Many information system users re-
quire periodic responses in a fixed format. Other users are
interested in reports only when- certain conditions are made
manifest by an analysis of the data. The information system
should be able to respond to both types of requirements.
SRI's analysis of the Branch's information processing and data man-
agement capability based on the above discussed concept revealed
the following:
Management Information
* Most of the managers interviewed do not give sufficient thought
to the problem of what information is needed to operate their
part of the Branch.
• In the early stage of the study, several key managers retired;
in some cases their successors were not in a position to define
their information needs.
• Most section managers rely on their daily involvement in the
work and their personal understanding of the work flow processes
to keep themselves informed about the work in progress and to
identify problems as they arise.
• Division chiefs tend to rely on section managers to keep them
informed about potential problems. Little reliance is placed
on status reports or information flows.
79.
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• Managers in the Branch believe that all required information
can be made available when requested but such an effort would
divert attention from other ongoing activities.
• If planning is omitted or delegated to lower operating levels,
managers will tend to find limited use for management control
information.
Technical Operations Information
• Information related to technical operations is oriented toward
a specific number of special purposes. Primary emphasis tends
to be placed on enforcement data and only a weak secondary in-
terest is shown in environmental management data.
• There is more emphasis placed on data gathering as opposed to
data manipulation. More information utility can be derived
from the existing data base.
• Restructuring present data programs to fit an environmental
management concept could result in a better cost/effectiveness
ration.
• Present data systems have limited dissemination and utilization
outside of the Environmental Protection Branch.
• The present data system cannot relate environmental quality
improvement to the costs and benefits generated.
• The water quality data system is limited to WISE which is en-
forcement oriented and STORET which is primarily used in archive
capacity.
• The air quality data base still is in a relatively rudimentary
state.
• There is no solid waste data base to use in systematic monitor-
ing or environmental management.
Systems Definition, Systems Design, and Work Flow Processes
• Very little emphasis is placed on a systematic conception of
work flow.
• The work flow concept and methodology are generally left to
the discretion and judgment of the section manager.
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• The Branch does not appear to place any great reliance on formal
delineations of work flow such as flow charts and other visual
methods. Work flow is essentially an intuitive process in the
section manager's head; in some instances, work flow tends to
be defined by procedural instructions contained in sections of
the laws.
• Systems analysts are not readily available to assist section
managers in defining and designing the systems required to per-
form the section's work.
Data Processing Support
* Basic support in data processing is provided by the Highway
Department.
• Access to the Michigan State University computer is available
through terminals.
* Hardware used for data processing is adequate but control of
schedules and response time to problems and priorities is out
of the Branch's hands. Decisions regarding these important
factors are made by non-Branch management.
Common Files and Information Retrieval Capability
• There is much uncertainty regarding the timeliness, ac'curacy,
relevance, and completeness of information contained in Branch
files.
• The Hydrological Survey Division is presently considering the
establishment of common files and retrieval processes for their
division.
• Systems analysis support to develop manual or mechanized filing
and retrieval systems is not available.
• Efforts directed to this area to alleviate problems that emerge
require diversion of attention from other work activities.
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Management Review Recommendations
The following recommendations incorporate the full range of findings
reported above and seek to integrate constructive measures for coping with
the dysfunctions and difficulties observed in the various operational areas
of the present organizational alignment. It is apparent that the Environ-
mental Protection Branch, if it is to successfully perform its missions,
must be structured in such a way that its internal processes can make full
use of new evolving technology and modern management methods and can effec-
tively employ the wide spectrum of technical and management skills avail-
able in its talented work force. This organization must also be capable
of performing the various organizational tasks in a more flexible and re-
sponsive manner to take full advantage of new opportunities or to adapt
to conditions imposed by its environment. This capacity to deal with
change will enhance all aspects of organizational performance. To achieve
desired results in organizational and operational effectiveness, efficiency,
and services, major changes in functional relationships will be necessary
in all areas of Branch operations.
Based on the management review findings, the SRI project team recom-
mends the following measures for bringing the observed difficulties under
control.
Establish a centralized planning function that would include
provisions for (a) strategic planning, (b) operational planning,
and (c) preparation of State environmental programs required
by law.
This step would facilitate management control of ongoing operations
by determining in advance:
• Areas of significant resource expenditure.
• Situations requiring close management scrutiny and monitoring.
• Mechanisms for ensuring that organizational priorities will
be implemented.
• Operational mechanisms for linking planning objectives with
day-to-day activities.
A centralized planning function would then provide the means for
defining the basis of operations for those responsible for accomplishing
the organization's purposes. Programmatic aspects of the planning pro-
cess would be responsible for informing management whether or not goals
have changed, schedule slippage has occurred, costs have risen beyond
original projections, or other variant conditions have surfaced within
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critical organizational processes. Such a function would also serve as
an essential communication link tying together the various functional
processes and resolving conflicting viewpoints into a unified focus
for action as well as ensuring that all internal programs, activities,
and services support the organization's goals, missions, and objectives.
Assign to the planning function responsibility for defining and
developing objectives, determining alternative means for accom-
plishing these objectives, and providing mechanisms for changing
or modifying objectives and communicating these changes to appro-
priate levels in the organization.
This function should also be given the responsibility for determining
the level o.f resources required to achieve these objectives and for devel-
oping the policy framework needed to regulate the acquisition, use, and
maintenance of these resources. As part of its responsibility, the plan-
ning function would be responsible for establishing a formal system for
issuing, codifying, controlling, and updating policies, regulations, and
procedures.
Analyze and systematize the Branch's internal work processes.
This function is necessary to accomplish the following:
• Develop a work flow system that will integrate related work
activities, avoid redundancy and duplication in function, and
clearly delineate task responsibilities within each organiza-
tional component. Rules and procedures should also be devel-
oped and documented for each task to be performed.
• Review annually position descriptions to determine whether or
not actual responsibilities are adequately reflected in the
work being performed. Descriptions should not only define
each individual's role behavior in respect to task demands
but also provide that individual with information about the
role expectancies of other individuals performing interrelated
tasks. Within these descriptions, accountability should be
specified in terms of:
- Discretionary areas of decision making
- Decisions outside of one's area of discretionary action
- Referral procedures in those cases where authority is
withheld.
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• Develop communication channels for quickly transmitting infor-
mation required by each pattern of interrelated tasks. This
communication network should provide sufficient information
for facilitating decision making and also provide each indi-
vidual with the means for accurately assessing the consequences
of his decisions.
• Enable division managers to establish work priorities for each
section and monitor the work flow to ensure that Branch guide-
lines are implemented. Priorities should be set only by those
with the authority to influence resource allocations and judge
the relative merits of the various requests for service.
• Institute as quickly as possible active use of the PBES system
as a management tool. This system offers an effective methodol-
ogy for subdividing the work process by major work elements, de-
termining the resources required, and presenting this information
in priority sequence. The system also appears to be an effective
method for justifying budget requests.
• Establish a systems analysis group within the Branch to assist
managers with problems related to work flow, work simplification,
methods and procedures, and data base design, development, and
management.
Establish a program development unit as a Branch staff function.
This new unit would perform the following activities:
• Evaluate new responsibilities assigned to the Branch in terms
of the resources and capabilities (money, technology, people,
special skills, and time frame) needed to transform legal re-
quirements into ongoing operational procedures.
• Obtain the necessary resources required for performing prelimi-
nary studies and developing the pilot program.
• Conduct functional analyses of the new program in terms of
component subsystems in the Branch and determine their inter-
relationships.
• Implement, monitor, evaluate, and modify the new program
prior to placing it on an operational status.
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• Turn over the new program to the designated organizational
component for inclusion into ongoing Branch operations.
Establish an organizational unit that centralizes all informa-
tion processing activities performed in the Branch and that
would include provisions for developing and managing (a) a man-
agement data system for augmenting management decision-making
capability and (b) a technical operations data system to support
the technical functions involved in managing environmental quality.
This component would be assigned the following responsibilities:
• Developing and implementing systematic data collection procedures,
supporting data processing equipment, and coordinating operational
systems.
» Developing uniform user procedures for all information processing
activities in the Branch.
• Designing, developing, and implementing information processing
systems which would include integrated common files and an infor-
mation retrieval capability to permit sophisticated analysis and
manipulation of data bases supporting managerial functions and
technical operations.
• Providing Branch operations with technical support in the areas
of systems analysis, system design and development, data process-
ing, methods and procedures, and data management.
Technical Operations Findings
The SRI assessment of the technical operations of the Environmental
Protection Branch is presented in terms of the Environmental Protection
Concept discussed in Chapter IV.
13. Predicting the effects of an action. This is the basic function
of evaluating permit applications. The evaluation criteria are
established by law and are usually expressed as physical, chemi-
cal, and biological standards, or as technical processes. In a
few cases the priorities for permit processing are assigned by
law—e.g., NPDES—however, they are generally established by the
©valuator. The permit application processing is handled in its
entirety by the organizational element to which the responsibility
is assigned. There is no institutionalized process for reviewing
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applications for intermedia impacts. The evaluation is very much
dependent on the evaluator's knowledge base and to some extent on
his work load. In only a few cases has the process been standard-
ized against a computational model and an organized data base.
Nevertheless the work is generally competent and fair. The func-
tion is presently understaffed in most major areas. The NYPDES
program is likely to add a large burden to the Water Resources
Commission Staff. However, the Air Pollution Control staff is
approaching the status of a maintenance agency.
14. Surveillance of the action. Surveillance (as opposed to monitor-
ing) is generally in need of improvement. There is a need to
strengthen follow-up to permit authorization; also, a strong
systematic intelligence function is needed to detect unauthorized
actions. Operators of stationary air pollution sources, and waste-
water and sewage treatment facilities submit periodic reports on
emissions but there is insufficient independent surveillance of
these operations to deter would-be violators. Public complaints
are relied upon but the process is neither facilitated nor encour-
aged.
15. Monitoring the effects. Monitoring is approached more from the
enforcement perspective than from an environmental management point
of view. Nevertheless, the coverage of air and water physical,
chemical, and to a lesser extent biological quality parameters is
good. The coverage of those parameters that define the resource
and the characteristics that describe its potential for various
uses including assimilation of wastes is only fair. Coverage of
parameters that define potential demand for uses and describe the
impacts of the extant uses of public health, welfare, and other
relevant socioeconomic characteristics tend to be poor and nonex-
istent. In general, the enforcement viewpoint of monitoring is
certainly adequate for State implementation of Federal programs.
The State's monitoring programs are supported by an effective sur-
veillance fee program, but this tends to reinforce the enforcement
approach. The routine support provided by the laboratories has
been adequate. Up-to-date maps displaying hydrological character-
istics (including delineation of flood plains) as they are affected
by development and other activities are not presently being main-
tained.
16. Special studies. Studies to develop procedures or to evaluate
unique environmental problems are regularly conducted by the staff
and occasionally by a private contractor. The State universities
are seldom used for consulting purposes although individuals from
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the academic community occasionally serve on advisory boards. The
studies conducted by the staff examine well-defined problems that
must be addressed but seldom are of an exploratory nature to discover
incipient problems. The press of everyday enforcement work usually
receives priority over study efforts.
17. Planning. Planning is conducted in response to State legislative
mandates. It is generally performed in a reactive mode but is very
competently done. However, there does not appear to be a directed
effort to establish objectives or select a course of action from
among alternatives to influence future directions.
18. Public participation. Public participation as practiced in Branch
operations consists mainly of open hearings conducted by the commis-
sions. At one time, this approach was considered to be quite pro-
gressive but the 'present conditions under which the Branch now oper-
ates requires further rethinking of this important interface. The
current philosophy of the agency places the onus on the public for
initiating its participation. Generally speaking, this process as
it becomes institutionalized can, with some adjustments, meet Federal
requirements for State implementation of Federal programs. It will
not, however, without a fundamental shift in philosophy, be respon-
sive to the .evolving spirit of the requirements.
In responding to the challenge of public participation, field repre-
sentation of the Branch can play an important role in performing
this function. The field representatives have a good public image.
They are viewed by those with whom they interact as competent, fair-
minded professionals who are responsive to local needs.
If the public participation function is to be- performed effectively,
it must develop a cooperative sharing relationship with regional and
local entities. The agency has made some positive strides in this
direction but has not as yet built this capability into all of its
programs.
19. Technology acquisition. Technology acquisition is primarily the
responsibility of the individual. He is expected to maintain tech-
nical competence commensurate with his job responsibilities. There
are limited training and orientation programs in some of the organ-
izational elements; in others, individuals are designated as focal
points for maintaining currency in particular technical specialties.
There is no formal program of job rotation to enhance career develop-
ment. Neither is there a formal educational program leading to ad-
vanced degrees or to a broadened perspective. There is little
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day-to-day interaction with the nearby academic institutions regard-
ing technical problems. Because of limited resources, consultants
and contractors are used to handle work overloads rather than acqui-
sition and application of new knowledge, methodologies, and concepts.
The salary scale and available career opportunity should attract the
advanced degree graduate, but there is no directed program to recruit
these individuals. Despite this state of affairs, the work is being
accomplished in a technically competent manner. This suggests that
the individuals are remaining current on their own and that the tech-
nology is not presently changing at too rapid a rate.
Technical Operations Recommendations
The following recommendations are based on the findings reported in
the previous section. It is recognized that the Branch may be institu-
tionally constrained from implementing some of the proposals.
Consolidate the separate permitting processes in the Branch
into a centralized system that would allow the paperwork asso-
ciated with these applications to be handled in a logical,
efficient manner.
Such a system would include a single point of contact for all com-
munications related to applications and their status; a common policy
for establishing processing priorities; intermedia and interagency review
and coordination of applications; utilization of common data bases and
methods of evaluation; delegation of certain responsibilities by the com-
misions in the form of rules and regulations that can be uniformly applied ;
and subprofessional support for all processing functions except those re-
quiring professional judgment. This recommendation does not circumvent
the Commissions' responsibilities for generating policy or approvals as-
signed under law; it refers solely to the paper work processes that ac-
company Commission actions or preparations for Commission action.
Establish a schedule of surveillance activities as a part of
the permitting process.
These schedules would be entered into an information system that
would publish a periodic statement of requirements, accept reports of
surveillance activities and complaints, and publish compilations of the
results including exception reports for missed activities and activities
in apparent violation. This recommendation in effect would extend the
Branch's WISE system concept to all permitting activities.
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Regional telephone numbers, differentiated from regular business
numbers, should be established and publicized for public use in making
complaints. The complainant should receive a report of the action taken.
Distinguish institutionally the purpose of monitoring for
enforcement from the purpose of monitoring for environmental
resource management.
The above recommendations relative to surveillance will further this
objective. However, it is important that the environment be viewed as a
resource that is valued for different purposes by different interests.
Since many of these purposes are conflicting in terms of their environ-
mental quality requirements and effects, it is the purpose of environ-
mental resource management to set priorities and regulate uses consistent
with a level of environmental quality. Monitoring should provide the in-
formation necessary for management decisions and should demonstrate how
effectively this.is being done. It should, therefore, include informa-
tion related to the demand for various uses, the actions taken to control
uses; the uses and their physical, chemical, and biological effects; and
the impacts of these effects on ecological and socioeconomic systems.
Accordingly, it is recommended that an environmental monitoring system
be established around a predictive system concept encompassing these
elements. The system should have the capability to develop a baseline,
trends, correlations, and functional relationships, and to display up-to-
date resource use demands and patterns, environmental quality conditions,
resource characteristics (including flood plain delineations), and socio-
economic impacts. Much of the nonenvironmental quality information will
be available from other governmental agencies. The system will provide
a logical statewide focal point for remotely sensed date.
It is recommended that the laboratory support be rationalized in
terms of procedures and determinations rather than the sample media.
These determinations and procedures should use instrumental methods where
available and cost-effective. The use of other state laboratory facili-
ties and private laboratories should be evaluated for specific routine
determinations. The laboratory should develop the capability to conduct
special studies and to develop analytical procedures.
Use of special studies to (1) support State environmental
quality goals and objectives, (2) acquire new technology and
perspective, (3) continue to build a national reputation of
scientific and technical excellence, and (4) build credibility
with the State's constituents.
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Special studies should be undertaken on subjects that have been
identified in the planning process as critical issues. The studies
should be designed to frame the findings in terms of management proce-
dures and options. Much greater use should be made of academic investi-
gators and consultants but with active participation of State personnel.
Contractors and consultants should be used to give credibility to contro-
versial issues.
Establish a centralized planning function.
This function should establish objectives and goals, define critical
issues, evaluate alternatives, and adopt a strategy for achieving the goals
and objectives. This central planning function will coordinate and inte-
grate the planning efforts of the various organizational elements.
Give the public participation function an organizational focus.
This is not the kind of focus that presents the official organiza-
tional face to the public, but rather one which defines needs and inte-
grates and coordinates the activities of the Branch in this regard. As
part of this activity, periodic information sheets should be prepared on
Branch activities and status of actions for distribution to interests,
the media, and the general public. From the viewpoint of effective public
participation, it is recommended that the field operations of the Branch
be strengthened and consolidated. The representatives of various organi-
zational elements should respond to common geographic areas and should
share common office space in that district. One of the representatives
should be designated the senior representative, the office manager, and
the spokesman for the Branch in that district. The public should be en-
couraged to make contacts with the Branch through this senior representa-
tive. The establishment of a strong and effective field force may reduce
some of the pressure for delegation of powers to regional and local enti-
ties. However, even when the powers are delegated, the State's presence
should be made evident either to back up the local authority or to take
over if the local authority fails to meet its responsibilities.
Implement a program of technology acquisition for all the
specialists of the Branch's technology base.
If the previous recommendations are implemented, the Branch will
acquire a changed concept of its purpose, objectives, and scope. This
will require a broadened technological base. This will include special-
ties such as sociology, economics, remote sensing, urban and land use
planning, and systems engineering. However, more importantly, generalists
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should be created by a planned program of exposure to different work
assignments. These should include different technical areas, different
functional areas, and different geographical areas. This should be a
part of a career development program for those individuals identified
as potential managers. To acquire the technological bases, a program
must be implemented in all of these specialties of the technology base.
This can include:
• Hiring qualified people—experienced in new technologies (if
available) or new degree holders who have been exposed to the
latest concepts in university research.
• Training existing employees—courses and seminars by visiting
lecturers specifically for staff; closed circuit TV courses
from the universities; time off for course work at universities;
and participation in advanced degree programs.
• Sponsorship of contract research in advanced areas, with par-
ticipation of staff on research teams.
• Strengthening of laboratory to include capabilities to conduct
special research studies.
• Formation of boards of advisors to evaluate specific technical
problems or to review the technical performance generally.
• Formation of a technical library including standard references
and journals and an aggressive program of acquisition of perti-
nent technical reports.
Manpower and Personnel Findings
Today, as never before, managers are compelled to make the fullest
possible use of human resources. The increasing size of organizations,
changing social values, increasing economic affluence, and the emergence
of new managerial technologies have swept us into an era of unprecedented
change. Effective use of available talent has become a principal operat-
ing imperative for even the smallest of organizations. Refusal to recog-
nize this fact of life runs the risk of imperiling individual and group
productivity as well as commitment to organizational goals. When indi-
vidual needs and values collide with the requirements of organizational
efficiency and effectiveness, the resulting decrement in motivation and
morale, not to mention the stifling of initiative, imagination and per-
sonal growth, can lead to situations in which both individuals and
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organizations fall short of meeting their basic goals. This appears to
be a common problem in government and industry today.
Fortunately, managers are becoming increasingly aware that organiza-
tions must provide a humanistic climate that can meet each individual's
needs for personal satisfaction and realization of his own potential and
goals. This recognized need for the organization and its membership to
be congruent is a fundamental tenet of modern managerial practice.
A review of manpower programs related to Branch operations revealed
the following areas of concern:
20. There is no systematic process for determining future manpower
requirements or to assess the capability of existing manpower
resources to meet these requirements, or framework for developing
action programs to solve existing or anticipated manpower problems.
21. An employee information system which provides ready access to
data about employees' personal and experiential characteristics
is not available.
22. A formal personal training and development program designed to
meet Branch needs for technical, supervisory, and managerial per-
sonnel does not exist. Some training is provided by the operat-
ing divisions and Civil Service sponsors a limited number of
training courses for supervisors and managers. The organization
has grown rapidly, new personnel have been added, and significant
changes have occurred in all sectors of the work environment; yet,
no systematic effort has been made to upgrade the human resource
capability.
23. The employment process is lengthy and cumbersome. Filling vacant
positions has sometimes taken over three months to accomplish.
Operating supervisors believe the time span for filling vacancies
is excessive but are uncertain about what recourse is available
for solving staffing problems. The gap between the operating
groups and the staffing practices of the Civil Service Commission
causes frustration and breakdown in communications.
24. Civil Service wage administration policies provide basically the
same increases in salary for the average performer as for the out-
standing performer. This is not unusual in government service
salary practice. However, it does point out the need to seek
other rewards or incentives for the exceptional employee.
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Manpower and Personnel Recommendations
The following recommendations are directed toward assisting the
Environmental Protection Branch in upgrading its manpower practices.
Because much of the responsibility and authority for personnel practices
is vested outside the Branch, the suggested approaches permeate and in-
tertwine with the functional responsibilities of the Personnel Division,
Department of Natural Resources, and the Civil Service Commission. The
development of an effective manpower program will therefore require sub-
stantial agreement and understanding of the organizational requirements
of each of these entities to provide an appropriate division of responsi-
bility for enabling the Environmental Protection Branch to fulfill its
needs for operational effectiveness by making available the necessary
resources to meet its objectives and goals.
Based on manpower and personnel review findings, the following
recommendations were made for improving the present programs.
Establish a manpower planning system that provides for (a)
an employment function, (b) formal training and development
programs for inside staff as well as local agency personnel,
(c) effective manpower utilization programs, and (d) a
methodology for achieving efficient manpower resource
allocations (see page 91).
The employment function is concerned with the numbers, kinds, and
quality of people recruited, selected, hired, and placed in their initial
assignments. Training and development programs are designed to maximize
the skills and potentials by providing opportunities for individuals to
upgrade their capabilities and prepare themselves for career advancement
in the organization. These programs should also include continued and
increased use of Federal grants to support local agency personnel train-
ing and development. Manpower utilization focuses on the effective use
of personnel in terms of the appropriate structurings of roles, tasks,
and work processes. Effective organization of work increases the proba-
bility of a good fit between the person and his job and reinforces the
individual's performance and motivation. Manpower allocation covers the
proper movement and balance of talent through transfer, rotation, and
promotion and ensures the most effective use of manpower 'resources in
the organization.
This step would enable the Environmental Protection Branch to link
manpower planning with its strategic and operational planning efforts
and derive the human resource implications related to its missions, pro-
grams, and diverse technical activities. The manpower planning system
will also be used to support local pollution control agencies.
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Develop a performance system that goes beyond meeting just the
minimum standard of the Civil Service Commission.
This appraisal system should be attuned to the needs of the employee
and the goals and objectives of the Environmental Protection Branch. It
should be one that not only measures an individual's contribution, but
one that motivates the employee to improve. Recent advances in this man-
agement practice have drawn attention to some of the more systematic uses
that can be derived from this tool. These are:
• Integration of organizational objectives and the individual's
own personal goals and aspiration.
• Assignment of individual accountability and correlation of
this accountability to work flow and unit responsibility.
• Identification of program needs.
• Identification of individual and group technical training and
personal development needs.
• Identification of individuals with potential and talent.
• Personal counseling and career development.
Develop an employee information system to provide the necessary
data to facilitate the workings of the management process.
In order to accomplish this, it will be necessary to examine present
methods for generating information on employees, identify current needs
and future needs based on manpower planning, and determine what informa-
tion is available through the Department and Civil Service Commission.
Then the plans for the system can be developed and the system can be
implemented.
Intergovernmental Process Findings
The following findings were developed through interviews with staff
members of the Environmental Protection Branch and discussions and inter-
views with persons outside the Branch. These findings are based on the
emerging needs for intergovernmental process program elements both within
the State and between the State and the Federal government.
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25. Michigan has 83 counties, 522 municipalities, 1,253 townships,
and 1,145 school and other special districts served by approxi-
mately 23,074 elected officials.* The Branch lacks a comprehen-
sive set of policy statements and procedures to govern the rela-
tionships with these various units of government. Both field and
headquarters staff deal with local units of government on a case-
by-case basis; these experiences and precedents are not systemati-
cally retained and Branch staff is given no guidance in applying
rules and regulations.
26. There is no single identifiable source within the Branch to which
a local governmental authority can go to determine the status of
actions affecting his jurisdiction. An action, once started, must
be pursued through the agency on a personal contact basis.
27. Different actions concerning the same local jurisdiction or juris-
dictions are handled by different sections and personnel within
the Branch. Coordination is a matter of personal initiative and
the lack of a formal mechanism for achieving appropriate linkage
leads to interpersonal tensions and misunderstandings between
Branch field staff, headquarters staff, and local authorities.
28. The Branch is unable to identify the intergovernmental activities
within its organization because there ±a no express distinction
between an action under a categorical program—such as the sub-
mittal of a grant application for waste treatment facilities—
and the intergovernmental processes involved in that action—such
as the actions required by local and/or regional government and
the Federal government with respect to the application. Thus,
the Branch is unable to account for the allocation and expenditure
of resources to attend to the intergovernmental aspects of its
work.
29. Responsibility for developing new State programs in response to
State legislation is divided and scattered. As a result, the
intergovernmental aspects of such programs lack systematic de-
velopment.
30. There are 119 points of staff contact within the Branch which have
198 points of contact with staff in 12 agencies, departments, bu-
reaus and commissions in the Federal government; these contacts
involve some 31 categories or program activities. While a majority
*
Some municipal and township officials also serve county governments; the
total has been adjusted to remove duplication.
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of these contacts involve the processing of routine matters, there
is no centralized activity within the Branch that is responsible
for coordinating these intergovernmental activities and there is
no point where responsibility rests for systematically developing
and maintaining State policy on the Federal-State aspects of the
Branch's work.
31. As the result of passage of The Clean Air Act of 1970 and subse-
quent Amendments, recent judicial decisions interpreting air quality
statutes, and other decisions at the Federal level, there has been
a substantial increase in the number of proposed and final regula-
tory actions by EPA. Included in these regulations are dozens of
actions that affect the work of the Branch and/or some major inter-
est in the State. Proposed regulations require a detailed analysis
and assessment as to their impact on existing programs, State law
and regulations, interests within the State—both governmental and
private—and the preparation of responses. The Branch lacks a sys-
tematic data base from which it could determine the impact of pro-
posed regulations on the interests in the State and a systematic,
informed methodology for conducting such assessments.
32. Federal statutes, rules and regulations require socioeconomic pro-
jections, cost-benefit determinations, demographic projections, and
impact analysis in connection with the Branch's obligations in meet-
ing specific program requirements. Many of these requirements must
be met for regional or local jurisdictions. The Branch neither has
the capabilities to carry out these types of requirements nor to
communicate and, when applicable, negotiate them effectively with
the local units of government.
Intergovernmental Process Recommendations
These recommendations go beyond acknowledging that establishment of
appropriate intergovernmental processes within the State are an expressly
required element of some Federal environmental protection programs. They
address the Branch's growing need to deal with the complex, interdependent
and interrelated technical, institutional, legal and regulatory, economic,
financial, and social aspects of all environmental protection programs
within the State as they bear on the conduct and regulation of affairs
between the Branch and other units and levels of government. The recom-
mendations will require changes in the Branch's functional responsibilities
and relationships. But beyond the internal organizational realignments
required to implement these changes, the recommendations will require new
ways of perceiving tasks within the Branch and the development of shared
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and cooperative perspectives towards the organization's intergovernmental
activities in environmental protection.
A successful intergovernmental affairs program depends upon the de-
velopment of a careful, sympathetic, and realistic perception of the aims,
positions, needs, and political and legal responsibilities of other govern-
mental interests involved, and the formulation of a strategy that will take
these factors into account in institutionalizing new and changing programs
with the governmental units affected.
The task of developing such a program will be difficult. It will be
complex because different governments will have different relationships
with the State over different issues and time frames. It will be uncer-
tain because the specific interests affected will be different at differ-
ent stages of each program's development and execution. It will be dynamic
because there will be legislative and regulatory adjustments over time to
existing environmental programs, as well as new programs added at both the
State and Federal levels of government. The intergovernmental aspects of
environmental protection will require imagination, foresight, and sound
reasoning on the facts involved because many of the actions that will be
required lack precedents or useful analogies. The area will produce sub-
stantial intergovernmental conflicts because law and regulation will re-
quire adjustments to the scope and authorities of various governmental
entities for specialized purposes.
The following recommendations were developed to address the problems
being encountered by the Branch in the intergovernmental process area and
to take advantage of the opportunities they present for enhancement of the
Branch's operations.
Establish an organizationalcomponent within the Branch which
is responsible for intergovernmental affairs, andassign to this
component the responsibility for developing and conducting an.
intergovernmental affairs program for the Branch.
Included in this recommendation are the following responsibilities
which should be assigned to this component:
• Require the component to include in its program the development
and maintenance of a systematic and comprehensive data base of
local, regional, federal and international intergovernmental
process impacts, requirements, needs, and problems.
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Delegate to the component responsibility for assessing new and
proposed laws and regulations with respect to their impacts
and program requirements in the intergovernmental area and for
developing policy with respect to such.
Designate the component as the central coordinating point and
clearinghouse for all of the Branch's actions which involve
aspects of the intergovernmental process, such as the process-
ing of grant applications.
Require coordination of the Branch's planning and operational
activities with the intergovernmental component to assure that
intergovernmental needs, requirements, interests, and perspec-
tives have been accounted for in the development of long-range
and operational plans.
Direct the intergovernmental component to provide support to
the Branch's field services for special problems and situations
involving intergovernmental matters.
Assign to the component, as agent for the Deputy and, where
applicable, the Director, the responsibility for official rep-
resentation on liaison with all interstate, international,
national and other commissions, committees, boards, panels,
and the like. In this connection, assure that the component
is responsible for assuring that the interests and duties of
the other elements within the Branch are adequately represented,
including attendance by the appropriate personnel within the
Branch where applicable.
Charge the component with the responsibility for developing,
in cooperation with other elements within the Department and
agencies within State government, the socioeconomic, demographic
and related impacts of the Branch's present and proposed pro-
grams as they relate to governmental decisions.
Stakeholder Processes Findings
The findings presented below are based upon an analysis of SRI inter-
views with members of the Environmental Protection Branch and representa-
tives of interest groups throughout the State of Michigan:
98
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33. Little formal recognition of stakeholder interests exists within
the Branch. Consequently, there is no management provision for
objective assessment of the various interest positions nor is there
any systematic means for relating such claims to ongoing policies
and programs, or determining the areas of consensus and difference
between the groups.
34. The Branch has not developed a systematic methodology for determin-
ing the critical issues and actions of interest to the various
stakeholder groups and disseminating pertinent information to the
public and the interested special groups. Communication channels
that do exist are fragmented and dispersed among the various compo-
nents and individuals in the Branch.
35. Individual staff members do develop relationships with interest
groups in regard to specific issues, programs, and actions but the
Branch does not possess a systematically developed policy framework
to guide staff members in the development and conduct of these trans-
actions. The end result of this condition is that the interest
groups often find the Branch's policies, decisions, and actions
inconsistent and confusing. Categorical programs such as air,
water, and solid waste as well as the different components and
levels in the Branch tend to project differing views of organiza-
tional reality.
36. The Branch does not systematically develop an informed constituency
of stakeholder interests in regard to emerging or pending issues
that contain potential for public controversy. Stakeholder posi-
tions are apt to develop fortuitously or depend on individual ini-
tiative to develop information and expertise relevant to the issues.
Effective effort in this area can facilitate the formation of public
consensus on critical issues thereby reducing abrasive and disruptive
controversy.
37. By law and policy, the Branch has maintained public access to in-
formation about its activities. In practice, however, individuals
seeking information are often left to their own devices for finding
authoritative sources within the Branch. The difficulties inherent
in this process are compounded by the attitudes and/or actions of
the staff, who, lacking definitive guidance, training or responsi-
bility for this area, are sometimes not sufficiently supportive or
uninformed about information sources in the Branch.
38. The organization expends insufficient effort to determine what groups
or individuals are interested or uninformed on matters related to the
99
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Branch's operations and subsequently take steps to rectify this
situation. Many groups and individuals are apt to challenge the
Branch's actions while operating from an inadequate base of infor-
mation. This often leads to wasting staff and Commission time as
well as ill will or embarrassment on the part of the groups or
individuals involved.
39. On some issues, the staff has adopted an adversary posture with
respect to the positions of stakeholder groups. This sometimes
leads to "win-lose" situations on specific issues. Few of the
Branch's regulatory actions or other decisions can be reduced to
such clear-cut alternatives when viewed in the context of larger
environmental protection goals set for the Branch and its Commis-
sions by the Legislature. These hard decisions are seldom cast
in the more reasonable and tractable framework of broader goals
and objectives. The adversary role carries with it the unfortu-
nate tendency to reduce future opportunities for constructive
stakeholder relations. No "win-lose" decision permanently excludes
an individual or group from a legitimate place in the State's envi-
ronmental programs but the Branch has thus far failed to develop a
program for inviting an even-handed participation by all stakeholder
groups in its continuing decision making and planning processes.
40. The branch does not systematically develop and maintain an inte-
grated data base related to stakeholder groups. Information con-
cerning stakeholder interests is maintained by particular individ-
uals or components in the Branch. This situation prevents the Branch
from performing periodic surveys to determine the beneficial or
detrimental impacts of its programs on the wide spectrum of special
interests in the State. Consequently, it becomes rather difficult
to account to the Legislature, except on the basis of personal con-
tact, for the present impacts of its programs on the various inter-
est groups, and to make use of inputs from these interests to indi-
cate possible legislative needs. Accountability to the Legislature
in this manner is closely related to the requirement that the Branch
be publicly accountable for its activities.
Stakeholder Processes Recommendations
Based upon the SRI project team's review of the Bureau's activities
and stakeholder needs within the State, the following recommendations
were developed to address the problems and opportunities encountered.
100
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Establish within the intergovernmental component, a group whose
specific responsibilities and duties are toward stakeholder
interests for all of the Branch's programs.
The following responsibilities should be assigned to this group:
• Delegate to the group the responsibility for coordinating all
presently required public participation activities for the
Branch.
• Charge the group with the duty of developing and recommending
additional requirements with respect to public participation
in the Branch's activities based upon a continuing assessment
of the need for such within the State.
• Assign to the group the responsibility for liaison with all
stakeholder groups and the public, including development and
dissemination of information on the Branch's present and pro-
posed plans, programs, operations, and decisions.
• Require, by Departmental policy, coordination of the Branch's
planning activities with the group in order to include a bal-
anced and continuing assessment of stakeholder's interests in
the development of the Branch's programs.
• Charge the group with the responsibility of developing, in
cooperation with other elements in the Intergovernmental com-
ponent, the socioeconomic impacts of the Branch's present and
proposed programs. This includes not only the federally man-
dated land use related aspects of the Branch's air and water
programs, but also State programs.
It is the SRI belief that this area of concern in the industrial
and private citizens' sectors is one of the most vital considerations
affecting governmental responsiveness and credibility at all levels of
government. These issues must be addressed by all governmental bodies.
101
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BIBLIOGRAPHIC DATA '• ReP°« No. 2.
SHEET EPA-905/9-74-019
4. Title and Subtitle A Managenumt Assistance Study for the
Environmental Protection Branch of the Michigan Depart-
ment of Natural Resources
7. Author(s)
Dr. David Ackennan, Don Jacobs, Cliff Steward, Ward Stoneman,
9. Performing Organization Name and Address 1-6O WeiSDectcer
Stanford Research Institute
Menlo Park, California
12. Sponsoring Organization Name and Address
OS Environmental Protection Agency, Ofc. of State Programs
230 So. Dearborn St., Chicago, Illinois 60604
3. Recipient's Accession No.
5. Report Date
6.
8. Performing Organization Kept.
No.
10. Project/Taslc/Work Unit No.
MSC 2736
11. Contract /Grant No.
EPA 68-01-1564
13. Type of Report & Period
Covered
Final
14.
15. Supplementary Notes
16. Abstracts
The Federal Government sponsored a study to assist the State of
Michigan in a review of its newly established Environmental Protection Branch of the
Department of Natural Resources; the impact of the new branch on interstate agencies
and the private sector; the impact of the new branch on intrastate agencies and the
private sector; and the new branch's staffing requirements as these factors affect
the State's environmental protection goals.
17. Key Words and Document Analysis. 17o. Descriptors -
Management Engineering, Personnel Management, Environmental Surveys, Pollution,
Waste Disposal, Natural Resources, Manpower, Environmental Engineering, Organizations,
Planning
17b. Identifiers/Open-Ended Terms
Michigan
17c. COSATI Field/Group
18. Availability Statement
19.. Security Class (This
Report)
UNCLASSIFIED
20. Security Class (This
Page
UNCLASSIFIED
21. No. of Pages
22. Price
FORM NT1S-35 (REV. 3-72)
THIS FORM MAY BE REPRODUCED
USCOMM-OC 14952-P72
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INSTRUCTIONS FOR COMPLETING FORM NTIS-35 (10-70) (Bibliographic Data Sheet based on COSATI
Guidelines to Format Standards for Scientific and Technical Reports Prepared by or for the Federal Government,
PB-180 600).
1. Report Number. Each individually bound report shall carry a unique alphanumeric designation selected by the performing
organization or provided by the sponsoring organization. Use uppercase letters and Arabic numerals only. Examples
FASEB-NS-87 and FAA-RD-68-09.
2. Leave blank.
3. Recipient's Accession Number. . Reserved for use by each report recipient.
4. Title and Subtitle. Title should indicate clearly and briefly the subject coverage of the report, and be displayed promi-
nently. Set subtitle, if used, in smaller type or otherwise subordinate it to main title. When a report is prepared in more
than one volume, repeat the primary title, add volume number and include subtitle for the specific volume.
5. Report Dote. Each report shall carry a date indicating at least month and year. Indicate the basis on which it was selected
(e.g., date of issue, date of approval, date of preparation.
6. Performing Organization Code. Leave blank.
7. Author(s). Give name(s) in conventional order (e.g., John R. Doe, or J.Robert Doe). List author's affiliation if it differs
from the performing organization.
8. Performing Organization Report Number. Insert if performing organization wishes to assign this number.
9. Performing Organization Name and Address. Give name, street, city, state, and zip code. List no more than two levels of
an organizational hierarchy. Display the name of the organization exactly as it should appear in Government indexes such
as USGRDR-I.
10. Project/Task/Work Unit Number. Use the project, task and work unit numbers under which the report was prepared.
11. Contract/Grant Number. Insert contract or grant number under which report was prepared.
12. Sponsoring Agency Name and Address. Include zip code.
13. Type of Report and Period Covered. Indicate interim, final, etc., and, if applicable, dates covered.
14. Sponsoring Agency Code. Leave blank.
15. Supplementary Notes. Enter information not included elsewhere but useful, such as: Prepared in cooperation with . . .
Translation of ... Presented at conference of ... To be published in ... Supersedes . . . Supplements . . .
16. Abstract. Include a brief (200 words or less) factual summary of the most significant information contained in the report.
If the report contains a significant bibliography or literature survey, mention it here.
17. Key Words and Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the
proper authorized terms that identify the major concept of the research and are sufficiently specific and precise to be used
as index entries for cataloging.
(b). Identifiers and Open-Ended Terms. Use identifiers for project names, code names, equipment designators, etc. Use
open-ended terms written in descriptor form for those subjects for which no descriptor exists.
(c). COSATI Field/Group. Field and Group assignments are to be taken from the 1965 COSATI Subject Category List.
Since the majority of documents are multidisciplinary in nature, the primary Field/Group assignment(s) will be the specific
discipline, area of human endeavor, or type of physical object. The application(s) will be cross-referenced with secondary
Field/Group assignments that will follow the primary'posting(s).
18. Distribution Statement. Denote releasability to the public or limitation for reasons other than security for example "Re-
lease unlimited". Cite.any availability to the public, with address and price.
19 & 20. Security Classification. Do not submit classified reports to the National Technical
21. Number of Pages. Insert the total number of pages, including this one and unnumbered pages, but excluding distribution
list, if any.
22 Price. Insert the price set by the National Technical Information Service or the Government Printing Office, if known.
FORM NT1S-3S (REV. 3-72) USCOMM-DC 14952-P72
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