United States
Environmental Protection
Agency
Office of Enforcement and
Compliance Assurance
EPA 305-R-07-001
March 2007
Guide for Addressing
Environmental Problems:
Using an Integrated Strategic Approach
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Disclaimer
The Guide for Addressing Environmental Problems: Using an Integrated Strategic
Approach was created primarily for employees of the United States Environmental
Protection Agency (EPA) and state, tribal and local environmental regulatory agencies,
and secondarily for stakeholders interested in partnering or collaborating with regulatory
agencies in the implementation of a strategy. This Guide is intended to explain a
strategic approach and its use in addressing environmental problems. It includes federal
and state case examples, hypothetical examples, suggestions and illustrations on how to
plan for each element in the strategic approach. The strategic approach and the
supporting information are viewed as a planning tool only and do not constitute EPA
rulemaking, policy or guidance. Thus, this Guide may not be relied on to create any
rights, substantive or procedural, enforceable by any party in litigation with the United
States. EPA may take action at variance with the Guide and its internal procedures.
Download this document from:
www.epa.gov/compliance/resources/policies/assistance/strategicguide.pdf
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Introduction
Contents
Element 1: Developing a Statement of the Environmental Problem and Justification for
Its Selection 1-1
Element 2: Establishing Goals and Measures 2-1
Element 3: Selecting, Sequencing and Segmenting Tools 3-1
Element 4: Establishing Roles and Assigning Responsibilities 4-1
Element 5: Developing an Implementation Plan, Schedule and Milestones 5-1
Element 6: Designating Resources/Workforce Deployment 6-1
Element 7: Communicating the Strategy 7-1
Element 8: Monitoring and Evaluating the Strategy 8-1
Element 9: Exiting the Strategy 9-1
Attachments
A. Framework for a Problem-based Approach to Integrated Strategies
B. Contacts for the EPA Regions 2002-2004 Integrated Strategy Pilot Projects
C. Template for Developing a Performance-based Strategy for National Compliance
and Enforcement Priorities
D. EPA Region 2 Healthcare Compliance Initiative
E. Enforcement Alert on Sanitary Sewer Overflows, March 2003
F. Evaluation of OECA "Framework for a Problem-based Approach to Integrated
Strategies" and "Guide to Implementing the Integrated Strategies Framework"
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Introduction
Guide for Addressing
Environmental Problems:
Using an Integrated Strategic Approach
Introduction
The U.S. Environmental Protection Agency (EPA) and state and local
environmental agencies have several tools available to address
environmental problems. This Guide will focus on the compliance
assistance, incentives, monitoring, enforcement and other tools that
have been used in different forms and combinations over many years.
Each iteration of using these tools has demonstrated EPA's evolved
thinking and experience about how to most efficiently and effectively
solve environmental and compliance problems. The result is EPA's
strategic approach for achieving improved compliance and better
protecting human health and the environment. The term "strategic
approach" is used throughout this Guide to capture the critical elements
that EPA has identified for developing and implementing its strategies
for resolving identified environmental problems.
Purpose
This Guide is specifically intended to:
Explain in detail the concept of the strategic approach and its use in
addressing environmental problems and improving performance
Elaborate on and provide examples to illustrate the key elements
that should be considered in planning, implementing and measuring
the effectiveness of the approach
Promote consistency in planning and implementing the approach
Encourage knowledge transfer using lessons learned from federal
and state case studies
Provide documentation of the decision-making and planning
Key Concepts
The strategic approach:
Promotes better
characterization and
prioritization of
environmental problems
Defines up-front what
success will look like
Provides flexibility and is
designed to be iterative and
allow concurrent
consideration of elements
Promotes transparency in
and documentation of
decision-making
Advocates up-front
consideration, but not
necessarily use, of all
available compliance and
enforcement tools
Recognizes the importance
of effective communication,
coordination and
collaboration throughout
the process
Encourages leveraging of
resources and optimization
of workforce deployment.
process from the case studies to assist practitioners in future strategic planning.
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Introduction
Audience
The primary audience for this Guide includes managers and staff from EPA as well
as state, tribal and local environmental regulatory agencies. Secondary audiences for
this Guide include stakeholders, such as industry and trade associations, community-
based groups, assistance providers and affected communities, interested in partnering
or collaborating with regulatory agencies in the implementation of the approach.
These audiences can benefit from adopting or participating in the strategic approach.
Some of the significant benefits the approach offers include:
Increased communication between managers and staff and across different
offices, resulting in the generation of new ideas to address environmental
problems
More sharing of knowledge and lessons learned, resulting in less time spent
"reinventing the wheel"
Enhanced efficiency and effectiveness of human capital as a result of better
understanding of the roles and responsibilities of the various participants in the
strategy
More measurable results and better accounting of resources used to achieve those
results, which can in turn help establish benchmarks for future resource allocation.
Background
In 2002 an internal EPA advisory group, the Compliance Assistance and Policy
Infrastructure Steering Committee (CAPI), developed the Framework for a Problem-
based Approach to Integrated Strategies (the Framework; see Attachment A,). The
Framework, which was endorsed and issued by EPA, provides a model for strategically
and systematically addressing environmental problems and, for the first time, explicitly
requires up-front consideration of compliance assistance as a tool, development of goals
and measures, and documentation of the decision-making process. The Framework
includes nine elements that guide the user through the planning process: (1) establishing
the environmental problem; (2) justifying selection of the problem as a priority;
(3) identifying anticipated performance measures; (4) selecting appropriate tools to
address the problem; (5) identifying resource needs; (6) developing a schedule to
implement the strategy; (7) establishing partners' and stakeholders' roles and
responsibilities; (8) developing a communication plan for all interested parties; and
(9) monitoring and evaluating the progress of the strategy.
The Office of Enforcement and Compliance Assurance (OECA) tested the elements of
the Framework by funding ten pilot projects across eight EPA Regions. See Attachment
B for a list of the pilots and contacts. The pilots focused on an array of environmental
problems (e.g., hazardous waste and solid waste management and disposal, stormwater
runoff, groundwater and drinking water contamination) in several sectors, including
schools, colleges and universities, healthcare facilities, auto salvage and construction.
Between 2002 and 2004, EPA headquarters solicited participating EPA Regions and
states to share their experiences in applying the Framework elements to their planning
process and the impact it had on addressing the environmental problem(s). This
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Introduction
information was shared through quarterly conference calls, six-month summary reports
and a final case study for each pilot.
Pilot project participants provided EPA's Planning Council with lessons learned on
application of the Framework elements and recommendations for future planning of
strategies. The Planning Council, comprised of EPA headquarters and regional
managers, evaluates OECA's planning and priority-setting process for selecting and
addressing its national priorities. As a result of the Council's evaluation of the existing
planning process and with input from the pilots, OECA developed the Template for
Developing a Performance-based Strategy for National Compliance and Enforcement
Priorities (Template) to strategically plan for and address OECA's FY 2005-2007
national priorities. The Template uses a similar planning process, covering the same
basic elements as the Framework, but condensed into six elements: (1) defining the
environmental problem; (2) establishing goals and measures; (3) developing the
strategy, including tool selection, environmental justice, internal and external
communication, monitoring and evaluation, and roles and responsibilities;
(4) determining when to exit the strategy; (5) defining workforce deployment and
resources; and (6) establishing a schedule. See Attachment C for the Template.
While implementation of the national priorities is ongoing, the authors of this Guide
interviewed some of the EPA managers and staff who developed certain of the
strategies addressing OECA's national priorities to inquire about the application of the
Template elements to their planning process. In this Guide, we have incorporated the
experiences from testing the Framework through the Regional and state pilots, from
developing strategies using the Template, and from developing other Regional and state
strategies. These experiences highlight real-life cases and the challenges and
opportunities of planning and implementing the strategic approach.
Layout of the Guide
The Guide is structured around nine elements, combining the elements of the
Framework and the Template that are needed to plan for and implement the strategic
approach. The elements are:
Element 1 - Developing a Statement of the Environmental Problem and Justification for
its Selection
Element 2 - Establishing Goals and Measures
Element 3 - Selecting, Sequencing and Segmenting Tools
Element 4 - Establishing Roles and Assigning Responsibilities
Element 5 - Developing an Implementation Plan, Schedule and Milestones
Element 6 - Designating Resources/Workforce Deployment
Element 7 - Communicating the Strategy
Element 8 - Monitoring and Evaluating the Strategy
Element 9 - Exiting the Strategy
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For each element, we describe its purpose, key
concepts, general approach, a step-by-step
process for implementation, and key challenges
and opportunities. Most importantly, each
element highlights examples and lessons learned
from the pilot project case studies and the
development of the strategies implementing
OECA's national environmental priorities. To the
extent possible, we also provide you with
suggestions on how to overcome barriers in
planning and factors to consider when looking at
each element's relationship to other elements in
the strategic approach. The accompanying
diagram of a wheel depicts all the elements of the
strategic approach and illustrates the continuous
motion of the planning process. This wheel will be
used throughout the Guide and is intended to
focus you on the element that is being addressed
while highlighting the other elements that need to
be considered in connection with it to ensure a
well-thought-out and comprehensive strategy.
For each chapter the element being addressed
will be shown in white, and the highlighted
elements will be shown in light gray.
The Guide also includes one case study to summarize
all of the elements of the strategic approach (Attachment D). The case study and other
examples cited in each chapter give regulatory managers and staff an opportunity to
learn from colleagues about tips for effective planning and suggestions on creative and
efficient resource allocation that will yield positive results. There is no single way to
address an environmental problem; multiple approaches and strategies may be
equally valid and appropriate. We hope, however, through the documentation of these
examples and case studies to begin to demonstrate when particular situations can be
most effectively addressed through the strategic approach. The emphasis here is on the
decision-making process and evaluating the range of possible approaches, even if only
one approach is ultimately selected.
^k Key Lessons Learned in Planning for and
^^Implementing the Strategic Approach
Below are some of the key lessons learned from both the pilots and the national
priorities While these suggestions may be discussed in more detail under the relevant
element, we are also sharing here a few of the more important ones to have a
successful strategy.
Designate one or two senior managers for each strategy who are responsible for
ensuring that resources are committed up-front and the strategy is coordinated and
managed across the appropriate offices and Regions.
Ensure that sufficient time and resources are allocated to adequately characterize
the problem, understand the audience and select tools. The Agency should consider
giving some form of "credit" during the planning phase to recognize the level of effort
required to fully scope out the environmental problem and to address unique
circumstances in each Region.
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Maintain regular coordination and communication across relevant EPA and
state offices and with external partners to manage information and resources.
Pilot participants reported that they found the monthly or quarterly calls and
reports useful in sharing approaches/techniques to addressing the elements
and in providing insight into the decision-making process.
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Element 1: Developing a Statement
of the Environmental Problem and
Justification for Its Selection
Objectives
Introduce techniques and information sources that can help you
locate and define an environmental problem.
Provide an example of one step-by-step process for defining
environmental problems and selecting problems to work on.
Identify key challenges and opportunities in defining environmental
problems and selecting problems to work on.
Purpose
This element of the strategic approach focuses on locating the most
complete and accurate information on the environmental problem,
putting it into a usable format for decision makers, and explaining why
this problem has been selected for action over other environmental
problems. This element corresponds to Elements 1 and 2 of the
Framework, "Statement of Environmental Problem" and "Justification for
Selecting This Problem Over Others," and Element 1 of the Template, "Problem
Statement."
Key Concepts
Baseline Information:
All key information
related to the: a) health
and environmental
impacts; b) potential
risks; and c) root and
contributory causes of an
environmental problem
before an intervention.
Compliance Baseline:
In the context of
compliance with
environmental
regulations, it means
making a preliminary
assessment of a sector's,
facility's or entity's
compliance status
before an intervention.
Approach
For several years, EPA has been soliciting both internal staff and external stakeholders
(states, tribes, non-governmental organizations, trade associations, etc.) to nominate
environmental problems that are candidates for EPA's attention. EPA then periodically
reviews these candidate problems, analyzes available data on the problem and its
potential impact on human health and the environment, and seeks out additional
information to better characterize the nature of the problem and its relative priority for an
EPA response at the national or regional level. For a well-thought-out selection of
environmental problems, EPA managers should consider:
Soliciting nominations of potential problems for EPA response from a broad array of
interested parties.
Reviewing and updating the results of any previous examinations of the candidate
problem.
Determining how EPA's authorities complement or conflict with those of other
federal, state or local governmental agencies.
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Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection
Key Considerations
Setting aside resources to purchase external
publicly-available industry data, if needed.
As you consider what data will best define a problem
and subsequently, if warranted, justify action, heed
the words of Harvard University professor Malcolm
Sparrow: "pick important problems and fix them." Do
not get bogged down pursuing absolutely thorough or
perfect information, as it probably does not exist.
Explore available information sources that are the
most informative; then look for indicators that will
help you narrow your research. Look for alternative
information sources. Acknowledge that you may
make false starts while looking for especially serious
unaddressed problems. Be flexible and ready to
adjust at mid-course as your analysis and
assumptions are confirmed or repudiated by new
information.
Keep in mind that environmental problems can be
defined in many forms, such as by industry sector,
chemical, process unit, geographic area or medium
(i.e., air, water, land disposal, etc). Define the
problem by whichever form makes the most sense
and will allow an efficient response. For example,
EPA's Office of Enforcement and Compliance
Assurance (OECA) often includes violations of
enforceable regulations in its definition of the
problem. It is important to ensure that the solutions
pursued in addressing the problem do not transfer
pollutants from one medium to another or cause a
noncompliance problem under another statute.
Examples of well-defined environmental problems:
Human health and environmental impact of smog. Air monitoring is conducted by
states and EPA, and the ozone non-attainment status of cities and counties is
announced. Health impacts are clear (e.g., lung damage, eye irritation, damage to
plants). The cause and sources of the pollutants are well understood (VOCs, NOX
and SO2, heat and sunlight). Environmental regulations and permitting systems are
in place to address the problem.
Based on lessons learned from the pilot projects and
other experience in developing and implementing
strategies, we provide the following considerations for
defining environmental problems and justifying your
selection of problems to work on:
Do not expect to find flawless data on the
universe of pollutant sources (e.g.,all
manufacturing processes that use a particular
chemical). However, many information sources
will cover, at least partially, your area of concern.
Pay attention to government data systems but
conduct a thorough search for other information to
help you understand how much of the pollutant
source universe is known and regulated.
Be ready to adjust your assumptions and shift
direction as you refine your data and obtain
feedback from field personnel (e.g., inspectors).
As your research progresses, focus on narrower
areas that pose the greatest risk and that can be
effectively addressed with available resources
(i.e., agency personnel and contract dollars).
Document the range of problems reviewed and
why a particular problem was selected to be
addressed. Documentation is important to
demonstrate good management of resources, as
required under the Government Performance and
Results Act (GPRA).
If applicable, point out ways that addressing the
problem could satisfy other goals at the national,
EPA Region or state level.
Consider the timing of EPA and state priority
selection processes.
Child Lead Poisoning. Tests are available to measure blood lead
levels, and some state/city health agencies and the Centers for
Disease Control actively monitor blood lead levels. Lead poisoning
impacts on children are well understood (neurological damage).
Sources of lead are also well understood (paint, lead solder water pipes, leaded
gasoline). Regulations are in place to address the problem.
"Pick important problems and fix
them."
Malcolm Sparrow
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Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection
Example of a poorly defined environmental problem:
Nanotechnology. Nanotechnology is engineering at the atomic or molecular level of
functional systems such as electronic circuits, drug delivery, and fabric protection.
There is little information currently available on the potential impacts of this
technology to human health and the environment. Where data does exist, there is no
clear consensus on its meaning. Few, if any, regulations are in place to control nano
particles. These factors make it difficult to characterize whether a health or
environmental problem exists as a result of nanotechnology and as such, it would not
lend itself to being addressed by the strategic approach.
Clearly justify why the environmental problem you are working to solve is important so
that you can justify why resources are being dedicated to it at the expense of competing
problems. The more substantiating information (e.g., inspector reports, inspection
violation data, national reports, chemical Material Safety Data Sheets, national priority
chemical initiatives) you can bring to bear, the more easily you will be able to deflect
criticism; build support for the compliance activity; and potentially tie it to other national,
EPA Region, and state environmental goals and priorities.
In some instances, if a problem is obvious, it may not be necessary to
expend resources on thoroughly analyzing and documenting why the
problem is serious and why it should be addressed. One example of an
obvious problem might be a state or EPA Region in a watershed with
many concentrated animal feeding operations and few other industries
that suffers from poor water quality due to high nutrient run-off and
strong odor, high numbers of violations and citizen complaints about
odor, and water body eutrophication.
Finally, because choosing a particular problem raises its profile and involves the building
of transferable expertise, familiarization of national managers with the problem, and use
of resources, it can pave the way for further activity as a regional or national priority. This
is further reason why clear justification is warranted.
The following factors can play a role in identifying a problem and justifying selection or
both.
Baseline of compliance information: Seek to define the problem in a way that will
allow you to measure results. Plan to conduct inspections or exploratory
investigations to determine the kinds of noncompliance that may be encountered.
Depending on the compliance activities' focus (sector, chemical or geographic area),
you will need to locate the best available information that will enable you to show an
impact on compliance and risk over time. For instance, if you are working to improve
compliance with requirements for construction permit applications, comparing the
number of annual permit applications with an industry variable such as new housing
starts will enable you to determine if compliance has increased.
Health and/or environmental impacts and risks: Enhance information on
compliance levels with information about the risks the subject pollutants pose to
human health and the environment. Be as specific as possible by giving details on
how the subject pollutant causes damage. For example, "mercury is a potent
neurotoxin causing harm to the human brain and nervous system, especially to those
of embryos and children." Express your approach in terms that convey the urgency
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Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection
of the problem or the harm prevented; for example, by tying increased compliance to
improved water quality, aquatic habitat protection, lower sedimentation at drinking
water treatment plants, or the health of the larger estuary. Refer to well-vetted,
published reports that make the case for action.
Pollutant (or indicator) identification and characterization: Clearly describe the
pollutant or related indicators. Include specific chemical characteristics, the forms the
pollutant can take, when it occurs most frequently, and how the strategy aims to
eliminate or reduce its harm.
Distribution of geographic and population impacts: Describe the geographic
range of the pollutant and its impacts on the environment and groups of people,
including at-risk populations such as children, seniors or economically disadvantaged
communities. Although a narrow geographic area may be affected, your description
of the pollutant's impacts on the area should to some extent inform the national
priority selection process. Examples include the Great Lakes Initiative, Hudson River,
and Anacostia River Watershed.
Existing noncompliance issues and patterns: Using data you have gathered from
EPA data systems, such as the Online Tracking Information System (OTIS) and the
Integrated Compliance Information System, other available data systems, inspection
reports, or accounts from witnesses, define and analyze what regulations are being
violated. Describe any patterns that may exist. These could be types of
requirements, such as monitoring, reporting or training, that are troublesome,
geographic clusters of violations, or types of companies or sectors that are exhibiting
problems.
Sector characterization: If the problem is associated with a particular sector,
compile information on the sector's characteristics. This information could be based
on Standard Industrial Code (SIC) or North American Industrial Classification System
(NAICS) code definitions or particular groups or subsets. Your description of the
sector's characteristics could include references to products produced, raw materials
used, proximity to water bodies, air emissions and major pollutant sources. By
assigning SIC and NAICS codes, you can analyze data in the context of other
information sources such as the U.S. Business Census, OTIS, or Dun and
Bradstreet, which can help to identify other impacts associated with the sector that
may not have been evident initially. If the problem in question is specific to a
particular industry sector, determine the following:
Sector size: Examine multiple information sources to determine the size of the
sector. Suggested sources are the U.S. Census, Dun and Bradstreet, EPA data
systems, industry directories, and national business phone directories.
Sector differentiation/variability: Characterize the sector, noting how different
segments pose different challenges, perhaps from facility size, materials used,
location, or proximity to other pollutant sources.
Small businesses: Determine what portion of the sector is considered small
business. Be sure to note whether it is small as defined by EPA (100 or fewer
employees) or by another classification standard such as the one used by the
Small Business Administration.
Businesses with limited capacity to comply: If a significant number of
businesses are not able to comply, factor this into your strategy since it will likely
raise political questions and pressures that need to be addressed to minimize
their impact. Determine how you will handle companies that are unable to comply
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Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection
(e.g., by accepting widespread closing, locating grant funds to assist, or
approaching business leaders to find a solution). Alternatively, if the problem is
posed by a specific type of process operation, chemical(s), or is geographically
based, conduct your research accordingly.
Exploratory investigations: Once you suspect a particular problem with a particular
set of facilities, conduct one or more well-planned, in-depth investigations, perhaps
with the assistance of EPA's National Enforcement Investigations Center. These
"exploratory investigations" should confirm that the suspected problem exists,
refocus attention on more serious or additional problems, reveal underlying causes,
or simply find that serious problems do not exist.
Existing regulatory gaps: Determine what regulations apply, what gaps exist in the
regulatory structure and where there are opportunities for filling these gaps. The
results from exploratory investigations can help you develop suggestions for
voluntary initiatives, new regulations or combinations of multiple approaches to fill
these gaps.
Contribution of noncompliance to the problem: Determine if the problem is
broader than noncompliance; that is, would the problem be solved if 100 percent
compliance were achieved? If the problem is based on more than noncompliance,
suggest remedies, including the modification of regulations or voluntary pollution
prevention initiatives.
Significance relative to other environmental problems: By defining the adverse
impacts that you aim to eliminate, you will be more likely to make a convincing case
that it is worthwhile to address the selected environmental problem.
Relevance to EPA's mission, role and authority: Consider the problem's
relevance to EPA's mission and statutory authorities to ensure that EPA has
authority to act and that there is a clear federal role. Consider conducting an
exploratory investigation if it is unclear whether the problem is within EPA's scope or
jurisdiction. Look for ways that your compliance activities can support existing goals
and priorities.
Current level of attention: Examine EPA data systems to determine EPA and the
states' current compliance activities in the problem area and their effectiveness.
Decide whether the activities should continue and how they can be more effective.
Pending regulatory actions relevant to the problem: Determine what
enforcement cases or new regulatory actions (promulgation of new rules) are
underway in order to avoid undermining ongoing compliance activities and to
coordinate with other experts working on the activities.
Planning cycles and opportunities to leverage resources: Aim to have results of
your problem analysis available in time to inform government planning cycles (e.g.,
for negotiating activity under Memoranda of Agreement and partnership
agreements). Also, be sure to highlight opportunities for collaboration between the
problem at hand and high-profile national or regional initiatives that could enable you
to leverage resources.
Relationship to other elements: Use the information gathered and analyzed to
define the problem to inform other components of your strategy. For example, if your
research shows that the sector universe is too large to handle through traditional
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Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection
inspections alone, plan for sizable self-auditing and compliance assistance
components.
W^r Step-by-Step Process for Defining and Selecting
^^Environmental Problems -A Sector-Based Example
EPA regional offices generally know which
sectors and media problems are the most serious
in the geographical areas they cover, so they
should be able to focus attention on narrowly
defined areas that can be examined in-depth with
exploratory investigations and state information.
To ascertain which problems are the most
significant and warrant increased attention, we
suggest using a process similar to the one
outlined below for sector analysis.
Here is one example of an approach used to
review problems on a sector basis. It was
conducted in order to help EPA focus resources
on environmental problems that would yield the
highest return on resources. A systematic review
of all 192 major manufacturing sectors in the US
economy was conducted. The results of this
study were used to inform selection of EPA's
Enforcement and Compliance Assurance
National Priorities in 2003/04.
1
Perform an initial screening using the following
factors:
This diagram focuses on the statement of the
environmental problem and highlights in gray the
other elements that are particularly important in
stating the problem and justifying its selection.
Patterns of non-compliance with the major federal
environmental statutes, e.g. Clean Water Act, Clean Air Act, etc.
Environmental impact indicators including whether the sector produces or uses
chemicals on the High Production Volume (HPV) list, produces chemicals that are
persistent bioaccumulative toxics (PBT) or persistent organic pollutants (POP), or
produces chemicals that have high Toxics Release Inventory (TRI) emissions
National prevalence of facilities
Recent or forthcoming regulatory activity
To help determine which sectors meet the initial screening factors, pull information from
numerous sources, including EPA's Enforcement Docket; federal government
information (e.g., U.S. Census, and the Department of Energy; Regional, state, local and
program Web pages; rule promulgation activity; Dun and Bradstreet; National Center for
Manufacturing Sciences; Small Business Office annual report; and the news media (i.e.,
investigative reports).
2 Carry out more research on the sectors that have passed the initial screening.
Then, compare your list to the ongoing sector-based activity of EPA and the states
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Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection
in order to capitalize on their expertise and interest. Consider the following sector-based
activity indicators with regard to each sector. Has the sector been:
Recently affected by new rules, the Small Business Regulatory Enforcement
Fairness Act (SBREFA) and/or rules that EPA considers to be economically
significant)?
Considered and previously deferred as a priority problem?
The subject of active enforcement or received compliance assistance?
Considered as the subject of new Compliance Assistance Centers?
The subject of sector-based programs in other offices such as the EPA Office of
Policy, Economics, and Innovation's Sector Strategies?
Ranked high on the previously generated candidates list based on data from the
Integrated Data for Enforcement Analysis (IDEA) system?
Receiving significant, recent state attention?
The subject of compliance inspector nominations for attention?
I Finalize list of candidate sectors using the abovementioned screening criteria
and detailed selection criteria, such as:
Is there a compliance problem in the sector? Information sources include compliance
rates trends from the On-Line Targeting Information System (OTIS)
Is there an environmental or human health problem in the sector? Are any problems
defined in rulemaking background or support documents? Have any problems been
identified by EPA staff research?
Is the problem currently widespread or anticipated to be widespread or a growing
problem? Is a problem associated with the sector being addressed by a new rule? Is
this a growth industry (economic, market indicators)? Are releases reported via the
Toxic Release Inventory (TRI) increasing overtime?
Do possible solutions fall within EPA's role? Is there a nexus with existing
Compliance Assistance Centers or a national or regional priority? Is there trade
association interest in partnerships? Is the sector best suited for compliance
assistance, incentives, or enforcement attention or some combination of tool use? Is
the sector under the control of an industry environmental management system? Is
the sector of concern under SBREFA?
Is the problem large enough to merit EPA's attention? Is the problem nationwide or
multi-Regional?
Does the proposed response fit EPA's three- to five-year planning horizon?
What is the current level of attention to the sector? Is the sector already being
addressed by the Agency? Is the sector being addressed by a number of state or
local agencies or an outside group such as a trade association?
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Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection
4 Select priority sector(s) to address. The answers to the selection criteria that
you have utilized and any weighting that you have assigned to particular criteria will
direct the selection of what problem you will address. Remember that there are
competing resource needs and priorities in the Agency. Therefore, it will be important to
describe the factors that make this problem(s) ripe for resolution and a relative priority
and to document the process and criteria used to make your selection decisions.
Challenges and Opportunities
The following case examples provide insights into some projects that employ the
concepts described in this chapter. They illustrate some of EPA's attempts to define and
prioritize environmental problems and justify their selection as problems to work on.
Challenge: Adequately characterizing an environmental problem
Opportunities and Suggestions
It is important to characterize, in writing, the environmental problem to
be addressed so there is a common understanding by all affected
parties. Most problems take many years to address. With changes in
Agency staff and the potential involvement of other stakeholders
throughout the process, it is helpful to document the problem in terms
that clearly make the link to protecting human health and the
environment and that contain enough detail to understand the extent
and nature of the problem that it is to be solved. This doesn't mean that
the characterization has to be lengthy. For example, EPA identified Combined Sewer
Overflows (CSOs) as a National Priority in 2005. The strategy EPA developed to
address CSOs clearly defines their impact on human health and the environment, and
the scope of the problem in only a few paragraphs. Following is a portion of the
characterization of the CSO problem in that strategy:
Combined sewer systems (CSS) are designed to collect rainwater runoff, domestic
sewage and industrial wastewater in the same pipe. When properly operating, combined
sewer systems transport all of their wastewater to a sewage treatment plant, where it is
treated and then discharged to a water body. During periods of rainfall or snow melt,
however, the wastewater volume in a combined sewer system can exceed the capacity
of the sewer system or treatment plant. When the capacity of the system or the
treatment plant is exceeded, the excess wastewater flows directly into nearby streams,
rivers or other water bodies, typically violating water quality standards.
CSOs are a significant cause of water quality impairment as documented in Clean Water
Act (CWA) Section 305(b) reports; often occur in areas frequented by the public such as
parks, beaches, backyards, city streets and playgrounds; and represent significant
threats to public health and the environment due to the risks they create for spreading
disease through direct contact with or ingestion of water contaminated with human waste
and toxic chemicals.
Overflows affect approximately 836 permits in the United States for combined sewer
systems. Affected communities are located in 32 states (including the District of
Columbia), primarily concentrated in the Northeast and Midwest, and serve
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Element 1: Developing a Statement of the Environmental Problem and Justification for Its Selection
approximately 46 million people. Regions 1, 2, 3 and 5 collectively account for
91 percent of the permitted CSOs in the United States.
According to the EPA Office of Water Report to Congress, "Impacts and Control of
Combined Sewer Overflows - Final Agency Review," Draft dated November 2003:
There are 836 National Pollutant Discharge Elimination System (NPDES) permits for
CSOs covering 9,501 outfalls
Annual discharges from CSOs are estimated to be 850 billion gallons (based on
modeling)
Receipt of CSO discharges: 75 percent to rivers, streams or creeks; 10 percent to
oceans, estuaries and bays; 2 percent to ponds, lakes and reservoirs; and 13
percent to other waters (ditches, canals, unclassified)
141 CSO permit holders do not have an enforceable schedule to implement Long-
Term Control Plans (LTCPs)
559 CSO permit holders have enforceable requirements to implement LTCPs (457 in
a permit, 102 in enforcement orders)
16 CSOs are within 1 mile upstream of a drinking water intake (from a surface water
source)
EPA's CSO Control Policy set a January 1997 deadline for CSSs to meet the nine
minimum controls. There are still a significant number of communities with CSSs that
have not implemented the nine minimum controls, do not have a Long-Term Control
Plan in place, or have long implementation schedules.
This example provides a good characterization of the environmental problem that the
strategy is addressing and documents the main source of baseline information used to
characterize the problem.
Challenge: Identify ing serious cross-media compliance
problems
Opportunities and Suggestions
Region 3's Vinyl Chloride Initiative provides an excellent example of how to identify
serious cross-media compliance problems. Cross-media compliance problems are
created by processes or activities in one media (air, water, land, etc.) that lead to non-
compliance issues in another media, e.g., Volatile Organic Chemical (VOC) emissions
from wastewater discharges can result in a facility exceeding its air emission limits. The
Region 3 initiative used a targeting methodology that examined public health data,
environmental data and environmental justice/hotspot issues. From this targeting,
releases of six chemicals of concern (probable or known carcinogens) were identified. Of
these six chemicals, it was vinyl chloride emissions from the chemicals and allied
products industry that was identified as the greatest threat to human health and the
environment. A series of multi-media investigations were conducted that targeted vinyl
chloride facilities in EPA Regions 2, 3, 4, 5 and 6. The initiative was also a good
example of establishing goals that ranged from general, performance-based
benchmarks to industry benchmarks, as well as environmental justice, and pollutant
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reductions goals. This initiative also contributed to elevating national awareness and
expertise among the regions in the area of cross-media emission transfers.
Challenge: Correcting widespread violations efficient!'
Opportunities and Suggestions
Region 2's Healthcare Strategy includes a well-researched
definition of the problem along with a reasoned explanation of
why the problem was selected for action. It is worth noting that
Region 2's healthcare initiative evolved out of an effort to
eliminate mercury from hospitals and in their colleges and
universities compliance initiative. During that initiative, the
Region unearthed evidence of widespread noncompliance in an
industry that had been relatively free of environmental oversight.
As explained in the full case study of this Healthcare Strategy
(Attachment D), Region 2 demonstrated that despite the large
number of pollutant sources, with strategic use of inspections, enforcement, self-auditing
and assistance outreach they were able to correct violations at nearly all sources without
having to conduct inspections or pursue enforcement actions at all sources. The initiative
is also a good example of a pattern of noncompliance at healthcare facilities in a single
medium (hazardous waste) that led to the discovery of numerous violations in other
media. In this case, the hazardous waste violations led inspectors to find noncompliance
with other regulations, including Clean Water Act (CWA), Clean Air Act (CAA), and Oil
Spill Prevention Control and Countermeasure (SPCC).
Region 2's Healthcare initiative is instructive in that the Region identified serious
problems following a limited number of inspections associated with a separate project
(Mercury elimination at hospitals). Motivated by the trend of poor compliance
encountered by their inspectors and the significant level of enforcement, the Region
conducted research to better define the universe of hospitals in the Region and the
extent of their environmental problems. Later, once the self-audit and disclosure phase
progressed, the Region was able to confirm their assessment that most hospitals were
out of compliance with one or more regulation.
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Element 2: Establishing Goals
and Measures
Objectives
Explain how goals and measures work together.
Provide a step-by-step process for identifying your strategy's
desired results and whether the results have been achieved.
Identify key challenges and opportunities in goal-setting and
selecting and using measures.
Purpose
This element of the strategic approach addresses establishing:
An overarching goal or result that is measurable and reasonably
achievable in the given time frame
Outcome and output measures
Baselines for all measures, or a plan for developing a baseline for
each of the measures
It corresponds to Element 3 of the Framework, "Desired/Anticipated
Outcomes/Results," and Element 2 of the Template, "Establishing
Goals and Measures."
Approach
The key questions are "What do you hope to accomplish?" (goals)
and "How will you determine your progress?" (measures). You can
use measures to show progress toward the anticipated goal, the need
for mid-course corrections, the effectiveness of a particular strategy and
lessons learned for evaluating the overall approach. During the
development of the strategy, identify both final measures of success and
interim measures and milestones. Where appropriate, measure the
impact of each type of compliance tool (e.g., compliance assistance,
incentives, compliance monitoring and enforcement) you use as well as the synergistic
effect of the tools to resolve the environmental problem. Measurement occurs
throughout the planning and implementation of the strategic approach and for a variety
of purposes as illustrated in the measurement continuum below:
Key Concepts
Baseline: The reference or
starting point against which
progress will be measured.
Outputs: Product or service
delivery targets you aim to
produce. Often presented as
the number of activities, work
products or actions.
Outcomes: Changes or
benefits resulting from activities
and outputs. Outcomes can be:
=f> short term (changes in
learning, knowledge,
attitude, skills or
understanding)
=f> intermediate (changes in
behavior, practice or
decisions)
=f> long term (changes in an
environmental condition).
Goals and Measures should be:
S - specific
M - measurable
A- attainable
R - realistic
T-time sensitive
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Element 2: Establishing Goals and Measures
Continuum of Measures
Baseline
Develop
Baselir
r
)ing
es
Capacity
Buildina
Establishing
Compliance
Baselines
Output Measures
Tools
Developed F ,
Reach Act
EXAMPLES:
cement
vities
Customer
Satisfaction
Outcome Measures
Changes in Ch<
Understanding Be
EXAMPLES:
Enforcement -AOs, Penalties Enforcement -
Incentives- # disclosures
Identifying
compliance
CA-outreach materials
problems/universe distributed
Inspections - # conducted
Compliance Assurance
Environmental and
anges in Human Health
shavior Improvements
^^^=*-
L
injuncttve relief
Incentives-violations corrected
CA-emissions
reduced after CA visit
Inspections/CA - facility process change
Understand need to apply for permit
Activities/Tools
Step-by-Step Process for Conducting Measurement
1 Review baseline information on the
environmental problem and target
audience. The goals and measures that you
establish for your strategy will flow directly from
the information that you have collected on the
problem and the populations (e.g., sectors, the
public) that are contributing to the environmental
problem. In addition to the goals and measures
themselves, the methods you choose for
collecting both baseline and subsequent
performance measurement data may be
influenced by the following factors:
Characteristics of the population of concern,
such as knowledge, sophistication, size and
resources. Some segments or sub-
populations may need to be treated
differently.
The scope of the problem and gaps where
more information is needed.
and highlights in gray the other elements that
are particularly important in establishing goals
and measures.
2 Identify goals. Establishing a good goal statement
for your strategic approach is critical. Your goal
statement should define, as specifically as possible, what you hope to accomplish and
the time frame in which you expect this to occur. Be realistic in defining what you can
achieve in the specified time period. For instance, a goal of "clean drinking water for all
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residents of (a large state) within two years" may be desirable but is probably not
realistic within a two-year time frame. In addition, "clean drinking water" as an
overarching, general goal is fine, but as a goal statement for a specific strategy it is too
vague (what is the standard for "clean"?). A better goal statement would be, "By 2009,
90 percent of public water systems (in a large state) will have drinking water that meets
all Safe Drinking Water Act standards as determined through annual water testing."
Remember, too, that the strategic approach is iterative, and you may need to revise your
goal statement over time. You may frame the initial goal of your strategy in more general
terms, but your goal may become more specific or even change as you learn more
information about the problem you are addressing. For instance, in response to multiple
chemical spills in a district's high schools, an initial goal may be "all schools in the district
will safely manage toxic chemicals stored on their property by X date." However, after
additional assessment, you may determine that this goal is not practical or feasible. You
may need to revise the goal to include "removal of toxic chemicals from individual
schools with central storage at the district level" or "substitution of toxic chemicals with
non-toxic chemicals."
Identify, either here or in the statement of the environmental problem section of your
strategy, the baseline or reference point against which you will measure progress. You
may also want to identify the compliance assurance tool or tools that you plan to use to
achieve the goal. For example, "By X date, X percent of all permitted Combined Sewer
Overflows (as identified in the 2004 baseline) will have an approved Long-Term Control
Plan with an enforceable schedule that will ultimately result in compliance with the
technology-based and water quality-based requirements of the Clean Water Act, or a
formal enforcement action will have been initiated to achieve that result."
3 Develop measures to determine if you are achieving desired results. Identify
specific measures for each goal. These measures may be aligned with the
compliance assurance tool or tools that you plan to use. By measuring the impact of the
selected compliance assurance tool(s) in addressing the identified environmental
problem, you can better manage for results and communicate the effectiveness of all
aspects of the enforcement and compliance assurance program (i.e., compliance
assistance, incentives, monitoring and enforcement). After you have undertaken your
activity, you also need to conduct a follow-up measurement activity to assess overall
impact of the intervention(s). The purpose is to determine how well you addressed the
problem and if you are reaching your goals.
Listed below are some of EPA's national outcome measures for compliance assistance,
compliance incentives, and monitoring and enforcement. Some of these national
measures or similar ones have been used to assess progress in meeting the goals of
specific strategies.
Compliance Assistance Measures
Percentage of regulated entities receiving direct compliance assistance from EPA
(e.g., training, on-site visits) reporting that, as a result of that assistance, they:
Increased understanding of environmental requirements
Improved environmental management practices
Reduced, treated or eliminated pollution
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Element 2: Establishing Goals and Measures
Percentage of non-EPA compliance assistance providers reporting an improved
ability to deliver assistance as a result of EPA assistance
Compliance Incentives Measures
Percentage of audits or other actions resulting in:
Reduction/elimination of pollution and protection of populations and ecosystems
Improvements in environmental management practices
Pounds of pollutants reduced, treated or eliminated and populations/ecosystems
protected as a result of audit agreements or other actions; dollars invested in
improving environmental management practices as result of audit agreements or
other actions
Monitoring and Enforcement Measures
Percentage of entities taking complying actions as a result of monitoring
Percentage of concluded enforcement cases
Percentage of concluded enforcement cases requiring improved environmental
management practices
Pounds of pollution reduced, treated or eliminated and populations/ecosystems
protected as a result of concluded enforcement actions
Dollars invested in improved environmental performance/environmental
management practices through concluded enforcement actions
Inspections, civil investigations and criminal investigations in high-risk areas, areas
displaying patterns of noncompliance or areas including disproportionately exposed
populations
4
Identify how the measurement data will be collected
and tracked. Appropriate mechanisms for collecting the
If you don't measure it, it didn't
happen.
measurement data are essential for assessing progress toward
achieving the goal. Regardless of how good a performance measure is, if a method for
collecting the data does not exist or requires an excessive amount of resources it will not
be a useful measure. An illustration comes from EPA's tribal priority strategy. EPA
wanted to track the number of tribes receiving solid waste management compliance
assistance as one of its measures. While this is a perfectly acceptable measure, the
Agency's database for compliance and enforcement activities and measures could not
be used to track this information. The database's information on audiences for
compliance assistance was limited to higher-level groupings, making it impossible to
differentiate how many tribal representatives had received the compliance assistance.
EPA determined that there was not sufficient time or resources to modify the existing
database to capture the needed information. Capturing this information manually would
also require too many financial and staff resources for the value of the information being
collected. As a result, the measure was dropped.
Another lesson learned on collecting and tracking measurement data comes from EPA's
Region I. Regional staff developed a phone survey script with many open-ended
questions to use with a large number of school personnel. The result was a large
number of responses that were difficult to review, tabulate and summarize.
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Element 2: Establishing Goals and Measures
The following table provides examples of strategy goals and measures and of data
collection methods appropriate to them:
Strategy Goals
By X date, verify the compliance
status of all facilities in X sector.
Sample Performance
Measures, Including Interim
Measures
Percentage of facilities in the
sector that have been inspected.
Percentage of enforcement
actions/settlement agreements
in the sector.
Data Collection Methods
Review of information in Agency
compliance and enforcement
databases.
By X date, reduce by 30% the
number of facilities in sector X
that are in significant
noncompliance (SNC) with air,
waste and water regulations
(from the baseline established in
2000).
Percentage of facilities in sector
that evaluate their air, water and
waste process-related
operations through self-audits
and address associated
compliance problems.
SNC rate of the sector
Self-audit disclosures and
manual tracking.
Review of information in Agency
databases.
By X date, 50% of hospitals in
the state will eliminate the use of
mercury.
Number/percentage of hospital
staff who increased their under-
standing, as a result of
assistance provided, of the
potential problems that may
result from storing and using
equipment containing mercury.
On an annual basis, percentage
of hospitals in the state that
have conducted baseline
assessments of their mercury
use and waste.
On-site visits
Pre/post-workshop survey
Response to mail or phone
survey
On an annual basis, percentage
of hospitals in the state that
have established mercury
removal and purchasing policies.
By X date, achieve 20%
Total reduction of 205,760 short Data collected through emission
reduction in emissions of sulphur tons per year of SOx/NOx
oxides (SOx) and nitrogen
oxides (NOx) (from the 1995
baseline) by the petroleum
refining sector.
emissions as a result of
settlements and enforcement
actions.
calculations and air monitoring.
Tracked through the Integrated
Compliance Information System
(ICIS).
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Strategy Goals
By 2010, all colleges and
universities in EPA Region X (as
identified in EPA's 2005
inventory of institutions) will
meet applicable RCRA
requirements.
Sample Performance
Measures, Including Interim
Measures
Number/percentage of
college/university staff who
increased understanding of
RCRA obligations as a result of
assistance.
Number of colleges and
universities obtaining the
required RCRA permits.
Number/percentage of colleges
and universities inspected by
EPA with no RCRA violations
identified.
Data Collection Methods
Pre/post workshop test, written
or phone sector-wide survey
after distribution of RCRA
assistance materials.
Review of information in Agency
databases.
Inspection reports.
5 Conduct measurement activities. Use of each tool constitutes a separate activity
that should, when possible, include a step to measure the outcome of the activity or,
at a minimum, record the "outputs" from the activity. For some compliance assurance
tools, follow-up may already be built into the compliance assurance activity. For
example, complying actions undertaken during a compliance monitoring inspection can
be recorded by the inspector at that time on the Inspection Conclusion Data Sheet. In
other cases, you may need to undertake a specific or additional follow-up activity or
verification to assess the outcome of the intervention. For example, a follow-up to an
inspection may be an enforcement action requiring specific injunctive relief. Reviewing
documentation sent by a facility disclosing under the Audit Policy or sending an
inspector to the facility can provide information on whether the audit resulted in reduced
pollution or a changed environmental management practice. Compliance assistance
almost always requires an additional follow-up activity (e.g., a survey, a follow-up site
visit or an inspection). For compliance assistance, the follow-up may take the form of
survey questions (e.g., on a test, through the mail, on e-mail or over the telephone) or
questions asked during a site visit. Some of these methods may need to address the
Paperwork Reduction Act (PRA) restrictions on the number of non-federal respondents
that EPA can contact to ask questions. If you do need to collect information from non-
federal respondents an Information Collection Request (ICR) may need to be prepared
and submitted to the Office of Management and Budget. The time needed to do this
should be factored into your measurement planning. See the Challenges section of this
chapter and page 11 in Chapter 8 for more details on the PRA and ICR process.
6 Track the results of compliance assurance activities. It is important to establish
some mechanism for tracking the progress of your strategy in achieving its goals.
This may be achieved through something as simple as keeping a notebook with
summaries of all activities, strategy and measure modifications, and outputs and
outcomes of activities. It is more common, however, for EPA staff to create a database
dedicated to tracking a specific strategy or entering the data into a national database. In
general, EPA staff is expected to enter both the outputs and the outcomes of EPA's
compliance assistance, compliance monitoring, incentives and enforcement into the
Agency's Integrated Compliance Information System (ICIS) or medium-specific
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databases, as appropriate. There are certain instances, however, when it may be
necessary to track information manually.
71 Analyze the data. After collecting information on results, perform appropriate
analysis. The type and complexity will depend on the quantity of information you
have, whether it is quantitative or qualitative, or your available resources. If you identify
gaps, earmark necessary resources and allocate appropriate time to collect additional
information. Review, reassess and revise the strategy as needed. Prepare results in a
clear, presentable form, understandable to a general audience.
8 Communicate results. Use the data collected to demonstrate the value of the work
being undertaken. You can communicate results in a variety of forms, including
press conferences and releases, e-mail list announcements, magazine or trade journal
articles, newsletters, reports, and internal briefing of program managers, to name a few.
Do not wait until the end of the strategy's implementation to begin reporting results.
There is value in reporting on interim milestones (both outputs and outcomes); for
instance, the communication helps inform other entities that may be contributing to the
environmental problem that a problem exists and how it is being addressed. This
increased awareness may, in turn, lead to increased compliance. Following is a sample
of interim results included in a press statement:
In 2005, EPA entered into legally binding agreements with 11 major domestic
airlines and nine smaller airlines to ensure the safety of the drinking water used
by their passengers and crew. The actions came after an EPA investigation of
327 U.S. and foreign airplanes at 19 airports in 2004 found coliform
contamination in 15 percent of them. ... EPA will continue to work with smaller,
regional and charter airlines to ensure the safety of their drinking water.
Challenges and Opportunities
The following case examples highlight a few of the key goal-setting and measurement
challenges that have been encountered during EPA's implementation of the strategic
approach. The examples also identify some opportunities and suggestions for
addressing these challenges that have come out of the pilots using the strategic
approach.
Challenge: Disconnect between the goals of the strategic
approach and the performance measures
This challenge came up several times during the pilot phase testing the strategic
approach. In some cases the disconnect was the result of changes being made during
implementation of the strategy with either the goal statement or the specific measures
being modified but not both, resulting in inconsistency. In other instances, performance
measures were identified for each tool being utilized to address the environmental
problem, but the measures did not provide enough information to indicate whether the
goal or goals were being achieved.
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A hypothetical example of the latter would be a strategy with a goal of having
construction sites in a particular geographic area comply with all applicable stormwater
regulations within three years and performance measures limited to:
Number of guides on stormwater requirements distributed to the target audience
Number of representatives from construction companies in that area attending a
stormwater workshop
Number and percentage of workshop attendees indicating that they
improved their understanding of the stormwater requirements ^
Number of stormwater inspections conducted at construction sites in
the area
While there is nothing wrong with these measures per se, they do not
go far enough to measuring progress towards the goal. One cannot
discern whether providing stormwater information, and any reported
improvements from the target audience about their understanding of the requirements,
has translated into improved compliance. In addition, the number of inspections alone is
not a useful measure. What were the results of the stormwater inspections? Did they
occur after the compliance assistance was provided? Had baseline information already
been established about compliance with the stormwater requirements before the
compliance assistance was provided?
Opportunities and Suggestions
Utilize the many existing resources for developing good environmental performance
measures that are directly linked to the goal of your strategy. The table under Step 4 in
this chapter illustrates performance measures that are clearly linked and designed to
achieve the identified goals. Other resources include EPA's Guide for Measuring
Compliance Assistance Outcomes, which is available at
www.epa.gov/compliance/resources/publications/assistance/measures/index.html. This
document contains detailed information on developing measures and collecting and
analyzing compliance assistance data. In addition, go to EPA's Web site at
www.epa.gov/evaluate for more information that is specific to evaluation but addresses
many of the same steps involved in developing goals and measures.
Challenge: Emphasis is on implementing the strategy rather
than measuring results
Several of the teams piloting the strategic approach reported that this was one of their
greatest obstacles. They reported that once an environmental problem had been
identified, there was often a great urgency to take action to address the problem. This
translated into the majority of their time being spent on planning for and conducting the
inspections; developing and distributing materials to inform the regulated community
about the problem; conducting workshops; inviting facilities to self-audit, correct and
disclose violations; and initiating enforcement actions as needed. Measurement was
often an afterthought. Although the strategic approach emphasizes spending time up
front to scope out the problem and establish good goals and measures, doing so was
still a struggle for many of the teams. Staff knew how to provide compliance assistance,
conduct inspections, etc. However, many of the team members reported lack of
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knowledge about and experience with goal-setting and measurement as one of the
impediments to doing it.
Opportunities and Suggestions:
The following suggestions for addressing this challenge were made by the teams piloting
the strategic approach:
Establish a review process to ensure that the tools selected and the strategy's
performance measures are directly linked to each strategy's goals. It was
recommended that this review be done by an individual or individuals with expertise
in measurement and the strategic approach. It was also suggested that the Agency
develop guidance providing examples that link the environmental problem, the
approach's goals, the tools selected and the corresponding measures.
Make measurement a management priority. Get senior management to buy in,
support it with resources and staff time, and recognize that staff may complete fewer
activities if they spend time on measurement.
Require measurement of activities (e.g., include language in grant specifications)
and require goals and measures of individual projects.
Dedicate and train a person to do measurement, and provide support and outreach
to others. Hire college interns to do follow-up phone/mail surveys of regulated
entities after they attend an EPA workshop or receive an on-site compliance
assistance visit from EPA.
Use the measurement data to inform others of progress on meeting the goals of the
strategy.
Challenge: Obtaining measurement data to set baselines and
measure results
Setting and achieving measurable goals has been a challenge for several of the projects
testing EPA's strategic approach. One reason for this problem has been the difficulty
with obtaining data and other information on a sector's, or other regulated entity's
environmental performance prior to and following the compliance assurance activities.
This is particularly true for sectors with many small businesses where EPA has minimal
compliance and enforcement data, and when reporting of data is voluntary.
The Paperwork Reduction Act (PRA) also limits the Agency's ability to obtain
measurement data. This law attempts to minimize the federal paperwork burden on the
public and requires federal agencies to obtain Office of Management and Budget (OMB)
approval prior to collecting substantially similar information from ten or more non-federal
respondents. EPA has a generic ICR for collecting some limited outcome data from its
compliance assistance activities. Regions requesting approval for information
collections using the generic ICR for compliance assistance can expect the process to
take approximately thirty days to obtain OMB approval. Certain activities are not subject
to the Act; the main one applicable to EPA's compliance assurance and enforcement
program is the collection of information during the conduct of a criminal or civil
enforcement action. For more information on the PRA and information collection
requests, go to EPA's Web site, www.epa.gov/icr.
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Opportunities and Suggestions
One approach for obtaining additional measurement data is illustrated
by EPA Region 1. The Region funded the development of tools to
encourage voluntary reporting of information. One such tool was the
Environmental Assessment Template, which helps federal and state
agencies collect information from hospitals on environmental
performance indicators, waste generation, pollution prevention and
energy/water conservation. The information collected from 25 hospitals
in three states was used to evaluate hospital mercury programs; identify
sector-wide environmental, health and safety challenges; develop
compliance assistance tools; and further define the need for assistance
activities for the sector. The federal template was modified into three
state-specific tools for Connecticut, Rhode Island and New Hampshire.
The federal template is available at:
www.epa.gov/region1/healthcare/pdfs/EPAHospitalTool.pdf
Challenge: Choosing the right data collection method
Gathering data is often the most difficult, time-consuming and resource-intensive step in
conducting measurement activities. Therefore, selecting the data collection tool or
method that will provide the best information is critical. A number of data collection tools
are available, including surveys, Inspection Conclusion Data Sheets, focus groups,
pre/post tests, and mandatory reporting forms like permit applications and Toxics
Release Inventory forms.
Opportunities and Suggestions
Remember that the methods you choose for collecting both baseline and subsequent
performance measurement data may be influenced by factors like existing information
gaps; the scope of the problem; the knowledge, sophistication, and size of the audience
or universe of facilities; and available resources. Some segments or sub-populations
may need to be treated differently.
By way of example, EPA Region 1's pilot strategy team for schools reported that they
initially planned to send a written survey to all the schools in the region to: (1) identify
barriers to improving the school's environmental performance; and (2) solicit information
regarding the kinds of tools, services and incentives needed to get schools to make
broad-scale behavior changes that would result in increased compliance and healthier,
safer schools. However, through some initial contact with school representatives and
feedback from inspectors, they learned that many schools were unaware of the
environmental issues affecting schools and the regulatory requirements with which they
needed to comply. In light of this information, EPA decided that a detailed written survey
would be an ineffective means of obtaining data. Instead, EPA staff used, with great
success, a series of focus group discussions that included representatives from several
groups associated with K-12 schools, including those knowledgeable about their
environmental issues.
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Element 2: Establishing Goals and Measures
Challenge :~f\\Q length of time it may take to achieve the goals of
the strategy
Opportunities and Suggestions
Be realistic about how long things take. Try to factor in contingencies (i.e., school
schedules if the target audience is schools, contractual factors if using a contract). Be
ready for mid-course corrections.
EPA Region 2's Healthcare Initiative provides a good example of the time that can be
involved in addressing an environmental problem. The initiative began in 2002 with 480
healthcare facilities. The initial approach focused on correcting hazardous waste
violations and a voluntary effort to have hospitals remove mercury-containing waste from
the healthcare waste stream. The initial results included mainly outputs (e.g., number of
workshops on identifying and managing healthcare wastes delivered, number of
compliance assistance tools developed and distributed, number of audit agreements
signed, and number of voluntary self-disclosures with or without signing an audit
agreement) and some interim outcomes from the use of these tools.
Four years later, the Region is reporting on significant human health protection from
voluntary self-disclosures, which have resulted in the correction of more than 1,700
violations. More than 150,000 staff and more than 20 million hospital visitors annually
are now better protected because of this initiative. These self-disclosures have also
yielded significant protection of the environment. More than one million gallons of oil,
more than 200,000 pounds of hazardous wastes and more than 150,000 pounds of
Chlorofluorocarbons (CFCs) are now being managed properly. Mercury use also has
been reduced by 96,000 pounds.
This effort demonstrates that meaningful results can be achieved, but it often takes
several years to implement the strategy and to collect enough data to show significant
results.
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Element 3: Selecting, Sequencing and
Segmenting Tools
Objectives
Introduce types of tools and considerations for their use that will
address the target audience contributing to the environmental
problem.
Identify key challenges and suggestions in selecting and
implementing the tools.
Purpose
In this section, we will examine some of the more common
considerations in selecting, sequencing and segmenting compliance
assurance tools. This element corresponds to Element 4 of the
Framework, "Use of Available Compliance Assurance and Enforcement Tools," and
Element 3 of the Template, "Priority Strategy."
Key Concepts
Segmentation (of the target
audience): The selection and
implementation of more than
one tool to address different
needs within the target
audience to yield a compre-
hensive approach.
Sequencing: The implemen-
tation of more than one tool in a
particular order to address the
entire target audience to
achieve maximum efficiency
and impact.
The goal is to select the tool or mix of tools that will
best address the environmental problem. The
information provided is intended to illustrate the
breadth of considerations that could affect the tool
selection process, rather than provide an exhaustive
list of factors or a formula. Professional judgment and
creative problem solving are still important in
identifying the best approach for addressing the
problem.
Approach
Select the tool or combination of tools that will best
address the environmental problem and lead to
improved performance by the target audience. Below
are five general categories of tools. For more
information about these tools and how they are used
at EPA, look at http://www.epa.gov/compliance/.
Key Considerations
Based on lessons learned from the pilot projects and
other experience in developing and implementing
strategic approaches, we provide the following
considerations for selecting tools:
Consider the full range of possible tools to
address the problem and evaluate the impact on
the target audience; even if only one tool is
ultimately selected. You may modify the tool(s)
you initially select as you learn more information
about the audience contributing to the problem.
When sequencing tools, consider how to transition
from one to the next and the impact on the target
audience.
When segmenting tools, consider the impact on
the target audience and outcome for each set
within that population.
Identify the anticipated resources (internal and
external) needed to utilize each tool.
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Element 3: Selecting, Sequencing and Segmenting Tools
Compliance Assistance (CA). Compliance assistance involves activities, tools or
technical assistance that provides clear and consistent information for helping:
(1) the regulated community to understand and meet its obligations under
environmental regulations; or (2) compliance assistance providers to aid the
regulated community in complying with environmental regulations. Compliance
assistance may also help the regulated community find cost-effective ways to comply
with regulations or go "beyond compliance" through the use of pollution prevention,
environmental management practices and innovative technologies, thus improving its
environmental performance. To be categorized as a compliance assistance project
or activity, at least one objective of the project or activity must be related to achieving
or advancing regulatory compliance.
Compliance Monitoring (CM). Compliance monitoring determines compliance
status and detects violations of regulatory requirements and other legal obligations.
Compliance monitoring personnel develop and use targeting tools and conduct
inspections, investigations and evaluations of facilities to determine compliance
status, respond to citizen tips and complaints, and support case development.
Compliance monitoring involves the development and dissemination of new
compliance monitoring tools and technologies for inspectors and the regulated
community, and the training of compliance monitoring personnel. It also involves
developing state, local, tribal and international capacity for monitoring.
Compliance Incentives (Cl). Incentives may provide encouragement for companies
to take proactive measures and to take advantage of compliance assistance
resources and opportunities. In essence, incentives prompt facilities to monitor their
own compliance. Some EPA compliance incentive strategies or policies (e.g., Audit
Policy, Small Business Compliance Policy) limit companies' exposure to penalties or
inspections if they have taken voluntary measures to discover, disclose and correct
violations and have a solid compliance record. Compliance incentive strategies may
also include partnerships between government and the regulated community, such
as the Environmental Results Program.
Enforcement. Enforcement requires the correction of environmental problems and
returns a violator of the law to compliance. It can discourage the violator and other
similarly situated entities from further violation by placing all regulated entities on an
equal footing, eliminating any economic advantage to noncompliance.
Innovations & Sound Business Practice. There are additional innovative practices
to improve facilities' compliance profile. These may take the form of voluntary,
sustainability-oriented programs and projects such as pollution prevention,
environmental management systems, best management practices and peer
mentoring. Such innovative activities often encourage environmental performance
beyond compliance.
Before considering which tool or tools will best address the environmental problem,
consider how you wish to influence a change in the target audience's behavior. A range
of options is available to foster compliance and improve environmental performance.
Some of the more commonly used options that lead to behavior change include:
Education. Compliance requires that the regulated community be aware of and
understand the regulations that apply to it and that it have the means for achieving
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Element 3: Selecting, Sequencing and Segmenting Tools
compliance with those requirements. Education makes information available in ways
that meet the needs of the regulated community for access, ease-of-use and
understanding, and practical technical assistance.
Encouragement. Removing actual or perceived barriers to compliance, providing
incentives for responsible action, and supporting a culture of environmental
stewardship and superior environmental performance can enhance compliance and
improve environmental quality.
Accountability. To achieve compliance, it is necessary to have measures in place
that determine the success of actions taken by the regulated community and
regulators. The regulator must be able to gather information on the regulated
community's compliance and to take appropriate action when the requirements of the
law are not being met. The regulated community needs to know that it will be held
responsible for its environmental performance and how that performance will be
determined.
Deterrence. The complement to providing incentives for compliance is providing
disincentives for noncompliance. This means leveling the playing field to remove
unfair economic advantages derived from noncompliance and ensuring that
everyone in the regulated community is held to the same standard of responsibility
and performance.
Many factors inform the decision as to which compliance assurance tool(s) to use to
address a particular environmental problem and influence behavior change by the target
audience. There is no set formula. Your strategy may include one tool, or a mix of tools.
The important point is that all tools should be considered in the planning process.
All tools should be considered
in the planning process.
The following table serves to illustrate some of the considerations that
can inform tool selection. Each of these tools can embody several of the
behavior-changing options discussed above. For example, compliance
monitoring can educate, provide accountability and function as a deterrent for the facility
being inspected. Each tool has been assigned a "primary behavior option," while
recognizing that the tool may also be used to fulfill the other options.
Note, too, that there is no expectation that a tool should only be used when both the
situational and audience characteristic considerations associated with it have been met.
For instance, when there is a threat or actual harm to human health or the environment
that requires immediate correction, EPA may use enforcement even if there is no
indication that the person or entity responsible for that threat or harm willfully violated the
law.
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Element 3: Selecting, Sequencing and Segmenting Tools
Factors to Consider for Tool Selection
Primary Behavior Situational Considerations
Option
Compliance Education
Assistance
As part of the initial effort to implement
a new rule.
When the rules have been out for a
number of years and data indicate "hot
spots" of noncompliance or
misunderstanding of certain aspects of
the regulatory requirements.
When enforcement and inspections do
not seem to be improving compliance in
a sector.
When the regulations are particularly
complex.
When a regulated entity requests
assistance.
When considering compliance assistance
as a tool, refer to federal or state policies
that may require up-front compliance
assistance such as the U. S. EPA Indian
Policy.
Audience Characteristic Considerations
When the sector is populated primarily with
small businesses.
When regulatory compliance information is
not readily available or accessible due to
demographic, geographic, language,
economic or other barriers.
For sectors with well-defined networks (e.g.,
trade associations) that are willing to partner
or maximize the potential to make compliance
assistance accessible.
When the regulations are perceived as
complex.
Compliance
Monitoring
Accountability
Before and after a compliance
assistance effort to determine level of
compliance/effectiveness of effort.
As follow-up with nonresponders to an
incentives letter.
To follow up on citizen, employee, state,
local, other federal agency tips or
complaints.
To determine compliance with
regulations, often on a schedule that is
mandated by the regulation or statute.
To address specific sectors based on
significant noncompliance or recurring
violations.
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Element 3: Selecting, Sequencing and Segmenting Tools
Primary Behavior Situational Considerations
Option
Compliance
Incentives
Encouragement
To encourage identification and
correction of noncompliance and
negative environmental impacts.
To encourage innovative approaches to
environmental compliance or
environmental performance.
As part of a stepped-up enforcement
activity.
To promote increased self- or third-party
auditing.
To promote improved performance that
goes beyond compliance.
Audience Characteristic Considerations
The noncompliance involves multiple
programs and facilities.
The sector consists of large numbers of
smaller sources that the agency does not
have enough resources to address.
Economies of scale are possible.
The sector's compliance history may indicate
that certain incentives are appropriate (i.e.,
incentives will actually motivate improved
performance or changed behavior).
The sector has well-defined networks (e.g.,
trade associations) that are willing to partner
or maximize the potential to make compliance
assistance accessible.
Enforcement Deterrence
When there is a threat or actual harm to
human health or the environment that
requires immediate correction.
Where the cost of the remedy is
expected to be high.
When enforcement supports efforts of
other entities such as states or citizen
groups.
When the situation may set a
precedent.
When the threat crosses state lines, is
regional in impact or has national
implications.
When considering enforcement as a tool,
refer to U. S. EPA and state Enforcement
Response Policies to assess agencies'
position on specific types of violations.
Parties have demonstrated unwillingness to
achieve compliance voluntarily (i.e.,
inspections reveal continued noncompliance
within sector after a CA effort, or individual
facilities have a history of noncompliance).
If the violations are willful.
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Element 3: Selecting, Sequencing and Segmenting Tools
Primary Behavior Situational Considerations
Option
Innovative and
Sound
Business
Practices
Encouragement
To encourage innovative approaches
and technology transfer that will
improve environmental performance
beyond compliance.
To encourage practices that will
address both the facilities' economic
interests and improvements to the
environment such as pollution
prevention, environmental management
systems and best management
practices.
Audience Characteristic Considerations
To promote "greening initiatives" for facilities
with vendors/suppliers.
To encourage mentoring between large and
small, or leading and following, facilities.
If the facility, company or sector volunteers to
test or incorporate new business practices.
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Element 3: Selecting, Sequencing and Segmenting Tools
Step-by-Step Process for Selecting Tools
Tool selection is one of the most critical elements
in the success of the strategic approach.
Selecting the best option for behavior change
requires review of, and cross-reference with,
other key elements during the planning process.
Provided here are suggestions and examples of
the type of information to consider and the other
elements in the strategy that you should consider
in the decision-making process.
1 Review the information acquired from the
baselining of the environmental
problem(s) and the target audience(s).
Map the target audience's characteristics.
Audience characteristics can include knowledge
of their environmental responsibilities; level of
sophistication to understand the problem; size
and location of the potential target audience;
available resources of each facility to address the
problem in a timely manner; history of noncompliance
across and within the sector; willingness to partner
with you to address the problem; target audience
obstacles to overcome such as language, cultural and socioeconomic obstacles; and
sector-market barriers such as high turnover, transient workforce, and organizational
and structural makeup.
Identify and justify segments or subpopulations that may need to be treated
differently. For example, a target audience may have different skill and resource levels.
Compliance assistance could be used for the facilities needing to understand the
environmental requirements, while compliance monitoring could be used for the facilities
possessing a higher level of sophistication and greater resource availability.
Identify gaps where more information on the target audience is needed and
identify the approach you will take to acquire that information. Some approaches to
gathering more information may include focus groups with the target audience to identify
the root cause of the problem and their compliance needs; meetings with trade
associations to gain an overall understanding of the sector's compliance issues and
identify vehicles to communicate with the associations' members; and meetings with
other regulatory agencies that may have information on location of or compliance issues
with facilities that are subject to other requirements and are not easily identified through
typical channels.
21 Review the overarching goals and measures of the strategy and select tools that
j will meet those goals and address the target audience needs. For example, if the
overarching goal is to reduce air toxics emissions by 700,000 tons over a two-year
period, assess whether more than one tool will be needed to achieve such a goal. If
This diagram focuses on tool selection and
sequencing and highlights in gray the other
elements that are particularly important during
the decision-making process for tool selection.
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Element 3: Selecting, Sequencing and Segmenting Tools
more than one tool is required (e.g., compliance assistance and enforcement) evaluate
the tools' impact on the target audience's compliance and the collective contribution of
the tools in meeting the goal.
3 If you find that multiple tools will best address the environmental problem and
influence behavior change, plot the order of the tools (if sequencing), the
relationship across tools (if segmenting), and the approach for transitioning tools.
4 For each tool selected, research the potential available resources within and
outside of your agency. To the extent possible seek commitment from the
appropriate authority. Do not assume that the expertise, material and funding will be
available at the time of implementation.
Challenges and Opportunities
The following case examples and suggestions provide insight into the circumstances
under which different types of tools have been used. They illustrate the Regions' and
states' thought processes in responding to the questions:
Why was a certain tool(s) selected?
Why were certain tools used in a particular order or sequence?
Why were certain tools used for different sets within the target audience?
There is often no single tool or clear set of tools that best addresses a problem
and influences behavior change; however, these case examples can provide
you with ideas on ways to most effectively address your environmental problem
through use of a specific tool or sequencing of tools.
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Element 3: Selecting, Sequencing and Segmenting Tools
Challenge: How to address sector-wide compliance problems
through sequencing of tools that will best address the
environmental problem given the target audience's
characteristics
Opportunities and Suggestions
OECA's Stormwater Compliance Integrated Strategy provides an example of how some
of the compliance assurance tools were sequenced and the rationale for these
decisions. The requirements for Phase I National Pollutant Discharge Elimination
System (NPDES) storm water permit applications and coverage have been in effect for
more than 10 years. EPA and states spent years educating industry about storm water
compliance requirements ( compliance assistance efforts include numerous trainings,
storm water web sites, public service announcements, guidance documents, fact sheets,
brochures and model permits). Nonetheless, in 2000, many industrial dischargers were
still illegally discharging storm water. In response, EPA sequenced from outreach and
compliance assistance toward increased enforcement for industrial dischargers across a
targeted watershed or geographic area or against a specific sector with potential for
highly contaminated runoff.
Then, when the Phase II NPDES storm water requirements became effective in March
2003, EPA again offered compliance assistance to all regulated entities affected by
these requirements because they were new.
Another approach to tool selection and sequencing is illustrated by the Indiana
Department of Environmental Management (IDEM) Auto Salvage Yards program. IDEM
received more than 100 individual complaints per year about auto salvage compliance
issues. Armed with the knowledge that there was a compliance problem across a sector
that had minimal resources and limited understanding of the requirements, but not aware
of the breadth of the problem across the state, IDEM provided compliance assistance
to all the auto salvage facilities in the state so that they could learn about proper
environmental practices and make corrections. Following the delivery of assistance,
they also conducted compliance monitoring to gather more information on all the
potential facilities through aerial flyovers and multimedia inspections. These steps were
followed by enforcement for facilities not taking the steps to comply.
Challenge: When to consider addressing a sector-wide problem
through segmentation of the sector universe
Opportunities and Suggestions
Not all of the target audience within a sector is subject to the same legal requirements
due to a number of factors (e.g., facility size or age, location in a sensitive ecosystem
area, additional state or local regulations). Moreover, there are sector characteristics
(e.g., willingness to comply and take corrective action voluntarily, history of
noncompliance, seriousness of violations identified, structural and organizational
complexity of the facility) that will factor into treating facilities differently to achieve the
same compliance goal. Assess the best tool mix for the target sector response by
reviewing the legal requirements impacting the sector, and past compliance rates and
current compliance issues. This type of assessment could help in your tool selection and
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Element 3: Selecting, Sequencing and Segmenting Tools
segmentation process. Below are two case examples. The first highlights legal
requirements based on facility size, and the second emphasizes sector characteristics
based on facilities' complexities, resources and willingness to participate in the strategic
approach.
In the EPA Region 2/New York and New Jersey Technical Assistance Providers Initiative
for 1400 Dry Cleaners, the Region distinguished the sector between small (one dry
cleaning machine) and larger, "industrial"-sized facilities (four to six dry cleaning
machines with small quantity generators of hazardous waste). Compliance assistance
developed and delivered by EPA, the state and the dry cleaners association included
multimedia information packets, workshops and on-site visits for all facilities to help them
understand their regulatory requirements. In addition, EPA provided an incentive,
promoting its Small Business Policy to encourage facilities to assess and change their
operations. For this purpose facilities were treated differently or segmented based on the
size of the facility. Small facilities were offered on-site compliance assistance, while the
larger facilities received RCRA compliance monitoring inspections to address
imminent environmental problems through timely enforcement.
For the EPA Region 1 Colleges and Universities Initiative, the region developed a
phased approach that segmented the use of the tools based on the characteristics of the
subpopulations within the sector, such as varying size and institutional complexity,
knowledge of environmental requirements, availability of resources, and seriousness of
violations. Facilities had the opportunity to select which phase of the strategy would best
fit their given characteristics. In doing so the entire sector could be addressed. The
strategic approach was as follows:
Well-publicized enforcement presence to ensure accountability and address more
serious violations
Compliance assistance delivered through multiple vehicles to reach the entire
audience
Compliance incentive promoting EPA's Audit Policy and encouraging facilities to
self-regulate
Sound business practice promoting innovative approaches such as peer auditing
and greening pilots on campuses to encourage sustainability and environmental
stewardship.
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Element 4: Establishing Roles and
Assigning Responsibilities
Objectives
Discuss how to engage a team that will plan and implement the
strategic approach.
Provide a process for identifying the individuals and organizations to
implement the strategy that have the desired expertise.
Identify challenges and opportunities in establishing and
maintaining a team.
Purpose
Key Concepts
Stakeholder: An individual or
entity that has an interest in or
is affected by the planning,
implementation or results of the
strategy.
Partnerships: A commitment
within or across organizations to
leverage resources and
expertise to address environ-
mental problems.
Collaborative Problem
Solving: When affected stake-
holders work together and bring
their collective resources to
solve common problems that
cannot be solved individually.
This information on this element includes some of the considerations in
assembling a team that is well suited to develop and implement the
strategy as well as desirable attributes of potential partners. This
element of the strategic approach corresponds to Element 7, "Involved
Stakeholders and Roles and Responsibilities" of the Framework and
Element 3, "Priority Setting," Section E, "Assign Roles and Responsibilities," of the
Template.
After initially discussing the need to establish clear internal leadership roles, this chapter
focuses on the wide range of external expertise available to engage in the strategy's
development and collaborate with you to implement the strategy. The goal for this
element is to identify the internal and external team members that meet the needs of the
strategy and ensure that each group (and member) has a clear understanding of their
role.
Approach
Planning and implementing a strategy requires a team of experts
with clearly defined roles and responsibilities. Also required is a
team with the appropriate levels of knowledge and skill sets.
Selecting the strategy's leadership is the obvious first step to
developing, implementing and adjusting the strategy. The
leader(s) must have the time to work on the strategy, the ability
to select team members and marshal available or needed
resources. Finally, the leader(s) must have decision making
authority or direct access to decision makers.
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Element 4: Establishing Roles and Assigning Responsibilities
The team leaders should select team members based on their knowledge of the
problem, relationship to the target audience, resources allocated to plan and implement,
and access to information. A core number of "permanent" team members will ensure
continuity over the strategy's life. The team may want to engage additional members on
an intermittent basis to address challenges as they arise.
External entities or stakeholders can also play an important role in the strategy. The role
stakeholder's play is defined by whom they are, the type and extent of interest in the
strategy, your need for input and support, and how they are impacted by the strategy,
including their ability to promote or change behavior associated with the environmental
problem addressed. Examples of external stakeholders that could participate on your
team and share in the success of the strategy include:
Government agencies (e.g., federal, state, tribal,
local, cross-border agencies with Canada and
Mexico)
Educational/academic institutions (e.g., colleges,
universities, vocational schools, K-12 schools,
research centers)
Business community (e.g., industry, consultants,
vendors and suppliers, economic development
centers)
Nonprofit organizations (e.g., trade and
professional associations, advocacy groups, non-
regulatory assistance organizations such as
Small Business Assistance Providers and Small
Business Development Centers)
Community groups (e.g., civic and community
organizations, neighborhood associations)
It is extremely important to engage potential
stakeholders on your team early in the planning process and communicate with them
throughout the strategy's implementation. Without a feeling of ownership and a stake in
the outcome - particularly when collaborative problem solving is the goal - buy in and
success is illusive. The following table illustrates some of the considerations in whether
to create partnerships, with whom you might partner and what the partner may have to
offer to the strategy.
Key Considerations
Based on lessons learned from the pilot projects and
other experience in developing and implementing
strategic approaches, we provide the following
considerations for creating your team:
Identify a lead manager and staff who are
responsible for coordinating and communicating
with all of the managerial and staff partners
throughout the planning and implementation
process.
Identify internal or external partners that have
(1) the requisite expertise and skill level to assist
in addressing the problem or (2) an understanding
of or sound relationship with the target audience.
Assign individual responsibilities that match the
person's skill level and knowledge and
complement the responsibilities of the rest of the
team; do not duplicate and do not underutilize.
Considerations for
Partnering
Limited baseline information
requiring outside data to
assess breadth of problem and
scope of target audience
Potential Partners to Fulfill Potential Partner's
Role Contribution to Strategy
State, tribal, and local
governments
Ambient environmental
monitoring data; facility
identification, contact
information and profiles;
discharge and emissions data
and reports; enforcement
and/or compliance histories
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Considerations for
Partnering
National or regional
compliance problem requiring
substantial resources
Potential Partners to Fulfill Potential Partner's
Role Contribution to Strategy
Other federal, state, or tribal
agencies regulating the target
audience
Leveraging of committed
resources for dual purposes or
sharing of underutilized
resources (FTEs, funds,
equipment)
Existing partnerships or
networks in place to gain
access to and more
information about the target
audience
Trade and professional
associations, economic
development agencies,
community organizations
Facility identification, contact
information and profiles;
introductions to target facilities;
onsite assistance at facilities,
development of assistance
material; monitoring of
environmental improvements;
providing venues for meetings
and training
Building capacity to share
information with the target
audience
State, tribal, and local
government, community
groups, trade associations,
regulated facilities
Leveraging of existing
communication vehicles (e.g.,
newsletters, Web sites,
meetings, site visits) to inform
the target audience and
interested stakeholders
Understanding the target
audience's complexities that
will drive improved
performance and address root
causes of the problem
Technological barriers to
enhancing process and
environmental performance
Small business or
businesses with limited
environmental expertise or
resources
Culturally and linguistically
diverse target audience
Academic institutions, research
centers, professional
associations, small business
assistance providers,
vocational training centers,
trade associations
Technical and process
assessments and assistance;
small business assistance;
vocational training; alternative
communication vehicles to
reach non-receptive members
of target audience
Environmental problems with
potential community impact or
impact on business
communities located in
residential areas
Local government, civic
associations, community
groups, local business owners,
economic development
agencies
Conduct surveillance of the
target audience; make
informed consumer choices
that impact the facilities (e.g.,
green dry cleaners); use
community or business
communication venues to
publicize good environmental
stewardship actions
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Step-by-Step Process for Developing a Team
Creating a team that will complement each other and work together to address the
ultimate goals of the strategy requires consideration of some of the other elements
during the planning process.
Provided here are suggestions and examples of
the type of information to consider in planning for
this element.
1 Designate team leadership. Effective
leadership is essential to developing,
implementing, and adjusting the strategy. The
team leaders should set aside specific, dedicated
time for the strategy and be available and ready to
make decisions. Ultimately, the team leader(s) is
responsible for each step in this chapter and those
of Element 5 (e.g., developing and overseeing the
implementation work plan and schedule).
Identify the list of skills and expertise
needed to understand the complexities of the
environmental issue; have information about and
access to the target audience; and develop and/or
implement the identified compliance assurance tools.
This diagram focuses on identifying roles and
assigning responsibilities and highlights the other
elements that are particularly important during
the decision-making for this element.
3 Identify potential partners (individuals where possible and organizations at a
minimum) with the desired skill set, knowledge and abilities. View broadly potential
partners both within and outside your organization. The type of partners and the
decision whether to expand your team to outside stakeholders is at the discretion of the
strategy's leaders. For example, if a more traditional approach such as enforcement only
is determined to be the best approach, then your team will remain with the parties privy
to the enforcement action. On the other hand, for strategies where you will use a
combination of tools, such as compliance assistance followed by compliance monitoring,
consider partnering with individuals or entities that have an established relationship with
the target audience.
4 Identify and commit resources. The strategy team should identify resource
needs and propose and confirm workforce deployment. The team leader will
present these needs to final Agency decision-makers and share decisions that are
made on resources to support strategy implementation with all team members. In
addition to considering the information acquired at this point and any decisions on ways
to implement the strategy, factor in the possibility that the strategic approach could
change based on resource allocation and workforce deployment constraints. These
limitations could be the ultimate decision on the makeup of your team.
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Element 4: Establishing Roles and Assigning Responsibilities
5 Work with the designated senior manager to execute the partnership for team
members from outside stakeholders, either by a written instrument (e.g.,
Memorandum of Understanding, Interagency Agreement), if the partnership is long
term or complex, or by oral agreement if the partner's role is short term or limited in
scope.
Challenges and Opportunities
The following case examples and suggestions provide insight into creating, executing
and maintaining effective teams. They illustrate some of the processes used by EPA
Regions and states to identify partners and gain their commitment during the pilot phase
of testing the Framework. The pilot participants were asked to answer the following
questions: (1) how did you address challenges in developing and implementing your
strategic approach; and (2) with limited resources, how did you work with other
organizations to reach the desired outcomes? Their responses and examples may help
you gain insight and ideas on some of the issues associated with team building.
Challenge: How to work with partners where there are target
audience complexities that need to be addressed to return to
compliance
Opportunities
An obstacle that may hinder working with small business owners
is the resource commitment to train and return owners to com-
pliance. This concern is heightened when the business owners'
primary language is not English. To address a community-wide
environmental issue, EPA Region 3, the Maryland Department
of the Environment, the Park Heights Community Group and the
auto body shops located in the residential neighborhood proved
that working together would be beneficial for all involved. The
federal and state regulators met with the community group and
the auto body shop owners to evaluate the scope and causes of
the issues, and to discuss the best approach to promote
compliance. Through several meetings and site visits, trust grew, roles were defined and
responsibilities were assigned. The community group members shared their knowledge
of the shop owners; EPA led (with the participation by the state), inspections and
assessed the owners' understanding of their obligations; the state reviewed the
inspection reports, led the development of an auto body shop compliance manual and
conducted training for the shop owners. By working together and working directly with
the owners of the facilities, the federal and state regulators were able to develop
assistance material to address a target audience where English is a second language.
This three-year partnership resulted in improved compliance by owners, monitoring of
the owners' compliance by the community group and the creation of an auto body shop
owners' association to train new shop owners.
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Element 4: Establishing Roles and Assigning Responsibilities
Each target audience has its own characteristics and complexities, but taking the time to
meet with the audience, build the relationships and discuss options to improve
compliance is a resource well invested. EPA Region 3, the Maryland Department of the
Environment, and Maryland School Administrators and Teachers met to discuss the
environmental issues placing their students at risk of accidental spills, hazardous waste
mishandling and mold. While the federal and state regulators were working with the
schools, they realized that there was limited knowledge of environmental requirements.
During the next year all stakeholders participated in developing a program that would
raise awareness and an understanding of the obligations to the environment and to
schoolchildren. EPA took the role of conducting surveys to understand the schools' level
of understanding and was also the lead on developing a compliance workbook. The
state reviewed the workbook including state-specific obligations, and the Maryland
School Board reviewed it to ensure that it was in a language understood by the
education community. While the state took the lead on conducting the training across
Maryland, the School Board took advantage of existing networks and associations to
market the training and share the workbooks. As a result of partnering and defining the
roles and assigning responsibilities, the training was transparent and well received.
Challenge: How to secure partners through trust in and
ownership of the approach and outcome
Opportunities
Building capacity across all stakeholders impacted by an
environmental issue may appear to be a daunting and
unattainable task. However, if there is a clear goal, transparent
approach and reasonable timetable, then creating and defining a
partnership to complete that task could be quite easy. EPA
Region 10, the Idaho and Alaska chapters of the Associated
General Contractors (AGO), the Army Corps of Engineers, the
Idaho and Alaska departments of transportation and local
governments all had a hand in meeting the common goal of
protecting water quality and preparing the construction industry
for increased inspections. To prepare the industry for under-
standing their federal/state/local requirements, EPA and AGC worked cooperatively to
develop and deliver workshops for the sector on National Pollutant Discharge
Elimination System (NPDES) erosion, sediment and pollution control. All levels of
government were present at the training and during the inspections. Working in tandem
the inspectors provided their expertise on the different regulations and educated each
other as well as the target audience. Recognizing the collaboration across the various
regulatory agencies, AGC took the lead on hosting the training sessions and
emphasized the importance of working together to increase awareness of the
stormwater requirements. In the end, the partnership built trust and increased capacity to
continue training and developing additional assistance material to be distributed by all
parties engaged in this partnership.
EPA Region 10 also used its partnership approach under a completely new set of
circumstances and environmental issues. EPA responded to compliance issues on the
Yakama Reservation in Alaska with increased oversight of pesticides application and
worker safety practices. EPA's efforts did not end there. By partnering with a local
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Element 4: Establishing Roles and Assigning Responsibilities
pesticide inspector funded through a tribal agreement, the Region was able to receive
credible and timely information to pursue enforcement actions within the reservation.
Providing the resources to the local inspector through a clearly defined written
agreement, EPA relied on the expertise of the inspector and used its efforts on
enforcement. Partnering between federal and local governments to achieve a common
goal of worker protection on tribal lands generated cases with multiple violations by both
tribal and nontribal owners.
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Element 5: Developing an
Implementation Plan, Schedule and
Milestones
Objectives
Introduce techniques associated with effective planning.
Provide a step-by-step process to ensure successful planning
and scheduling.
Identify key challenges and opportunities in planning and
scheduling that may arise during the development and
implementation of a strategy.
Purpose
Key Concepts
Plan: A "detailed scheme,
program, or method worked out
beforehand for the
accomplishment of an object."
The goal of planning is to
ensure the development and
implementation of a well-
thought out strategic approach.
Schedule: The "production plan
allocating work and specifying
deadlines," which includes
identifying roles and
responsibilities. The schedule's
goal is to ensure process
transparency, facilitate
oversight and communication
with key stakeholders, and
provide opportunities to
reassess and realign the plan.
The information on this element includes some common considera-
tions associated with developing and implementing a work plan (plan
and schedule). It also examines some common pitfalls associated
with planning and scheduling and identifies ways to ensure successful implementation.
This element supports Element 6 of both the Framework and the Template, both titled
"Schedule." The goal of this element is to provide an overview of how to effectively plan,
monitor and oversee a strategy.
Approach
The Team Leaders must commit to establishing and
maintaining a work plan.
One of the most effective ways to establish a work
plan is for the team to "brainstorm" about the primary
activities associated with each element of the strategy
and the appropriate milestones for completing these
activities. This will ensure the work plan is based on
the team's knowledge of the problem and that the full
range of solutions are identified. During the
brainstorming, activities should be grouped together
so they either build on each other or are related in
some way. Team Leaders should make final
Key Considerations
Ownership/Engagement: The team leaders
must assume overall I responsibility for the
work plan and monitoring progress. Team
members must be given ownership of specific
tasks in the work plan. If only the managers
or a few of the staff follow upon the work
plan, many of the activities and the
associated milestones will not be completed.
Updating of the Work Plan: Keep the work
plan current because dates and tasks often
evolve overtime.
Format: Use a format (e.g., Microsoft Excel)
for the plan and schedule that is optimal for
the team and the managers.
Outside Forces: There will always be
obstacles to implementation that are outside
your control. Just expect them and work
around them.
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5-1
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Element 5: Developing an Implementation Plan, Schedule and Milestones
decisions about the work plan and assign specific team members responsibility for
tracking tasks.
Throughout the implementation of the strategy, Team
Leaders should check in with the team member
responsible for each task and make decisions on
whether adjustments to specific activities or milestones
are appropriate.
Step-by-Step Process for
Developing an Implementation
Plan, Schedule and Milestones
Provided here are suggestions and examples of the
type of information to consider in planning for this
element. See the sample work plan at the end of this
chapter.
1 Brainstorm the work plan. The team should
discuss the entire range of potential primary activities
to be implemented in the strategy. It is recommended
that at least one face-to-face brainstorming session take
place.
This diagram focuses on developing a workplan
for the strategy and highlights in gray the other
elements that are particularly important during
the decision-making process for this element.
2 Develop the work plan. The work plan is a functional calendar that contains the
primary elements and activities of the strategy. The work plan should be
prospective, be built around specific calendar dates, and include each program activity
and associated measure. At a minimum, the work plan should contain the following:
Each program activity and associated deadline(s). Include a team leader and team
member point of contact for each program activity.
Each program measure and its associated method for tracking progress. Include a
management and staff point of contact for each measure.
New or existing mechanisms to track and measure results.
The date and time for each activity and/or meeting.
Dates to consider revising program activities, deadlines and measures.
Baseline information. The work plan should include the baseline data used to
establish the strategy's activities and measures. Inclusion of baseline data is
important to track performance according to the existing measures.
A formal evaluation phase so that team leaders and their managers can determine
whether activities are being completed in a timely manner and, if not, why. The
evaluation phase is essential to determine whether and when mid-course
adjustments are required.
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Element 5: Developing an Implementation Plan, Schedule and Milestones
Including the following components will increase the work plan's functionality and value:
Information on relevant internal and external stakeholder meetings (e.g., of OECA's
Planning Council, states, tribes, the regulated community, nongovernmental
organizations, including environmental justice communities).
Anticipated timeframes for internal budget requests.
Anticipated funding opportunities and associated deadlines for external grants and
cooperative agreements.
Anticipated congressional or Office of Management and Budget hearings or
requests.
3 Team leaders assign activity and progress coordinators. For each strategy, the
team leaders should oversee each activity and assign a team member to "manage"
each activity on a day-to-day (or regular) basis. See the chart on page 5 of this chapter
for an example of how to create a Strategy work plan and monitoring progress.
Together, the team leader and team member with oversight responsibility can.
Focus additional attention in a particular area and develop (or apply existing
expertise.
Draft and maintain documents within their area of responsibility, including a record of
all final decisions.
Track and report on issues within their area of responsibility, including designing
necessary adjustments or other outstanding issues.
Scheduling meetings.
4 Ensure team participation. Team leaders should ask team members for a
1 minimum level of commitment (e.g., average of X hours a week on the strategic
approach or engagement in, or responsibility for, a certain number of projects each
year). The commitment of hours would depend on the quantity of work to be done and
the number of team members who are available.
5 Review the activity milestones. Be pragmatic about the work plan's timetable.
There are many issues outside your influence that affect the ability to accomplish
activities and meet milestones. Revisit your milestones on a quarterly basis and update
them as necessary and appropriate.
6 Maintain regular communication and manage strategy documents. The
following are appropriate for each strategic approach:
Establish regular conference calls. The frequency will depend on the issues to be
discussed.
Make the work plan and all final documents available through a shared network
directory. This will enable managers and staff to revise existing documents.
Guide for Addressing Environmental Problems Through a Strategic Approach | 5-3
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Element 5: Developing an Implementation Plan, Schedule and Milestones
NATIONAL PERFORMANCE BASED STRATEGY - COMMUNICATION AND COORDINATION PLAN
FY 2005 WORKPLAN
LEAD
David
Team Leaders
Team
Team Managers
Smith
Team Leads
Team Leads
Bobby Brown
Carol Reese
Smith
Sally
Team Leads
Clayton
Sally
Jim Smith
Smith & Hubert
Smith
Smith
CURRENT
STATUS
Ongoing
Ongoing
Ongoing
Ongoing
Completed
CHAMPION: Sally Douglas |HQ LEAD STAFF: David Painter (REGIONAL LEAD STAFF: Lori Thomas
TACTICAL STEPS
Internal: conference calls every other week
. .
9 9 9 9 P P 5
Internal: brief senior managers
Internal: identify and select EPA advisory board
Internal: scope & prepare for senior managers meeting: What outcome are we
lookina for? How can we aet buv-in?
Senior managers to meet with key internal & external partners
Stakeholders: identify key external stakeholders
Stakeholders: Establish regular communication with key groups
Stakeholders: Work with Department of Education on schools emphasis area
Press: draft & update communication material to share with stakeholders
Press: plan two events for FY 2005 - D.C. and California
Press: Event on mid year & end of year successes
Public meetings: Kansas (1 1/05); New York (1/06), Denver (3/06), D.C. 9/06)
Internet Portal: get senior management support &B check-in
Portal: What $ do we have? How do we get more?
Portal: focus groups with key internal & external stakeholders
Internet Portal - beta tests
Portal: go live with press event
A
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Y COMMENTS
Starting convene meetings as needed
Team Managers
Specifically - Regions 5, 6 and 7. ( both engaged and
on the team)
Meeting scheduled for Nov 15; quarterly or semi-
annuallv durina the fiscal vear.
What topics and who is the lead? [Ask for clarification]
By December, 2004.
Jasper to begin working on a brochure
May 5, 2005
Identify 6/06 meeting
Sally will discuss event with senior managers
Can this wait until Dec or should we be thinking about
how best to allocate these funds sooner?
10/04/2004 Discussion of available resources
Mary to send via email & demonstrate
Hold in Silicon Valley?
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5-4
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Element 6: Designating Resources/
Workforce Deployment
Objectives
Discuss how to assess what resources you need to plan, execute
and measure the strategy.
Provide a step-by-step process for identifying and leveraging
available resources.
Identify challenges and opportunities in committing and effectively
deploying available resources.
Purpose
The information provided on this element highlights considerations in
securing the appropriate mix of resources necessary to implement the
strategic approach. This element supports Element 5, "Resources," of
the Framework and Element 5, "Workforce Deployment Strategy," of
the Template.
Key Concepts
Resources: The money and time
dedicated to implementing the
strategic approach, including
management and staff time,
professional services, equipment
and supplies, travel or training.
Funding Vehicles: Any agency-
approved agreement to commit
resources.
Human Capital: People with the
skills, knowledge and experience
needed to most effectively
implement the strategy.
The goal is to ensure that the necessary resources are in place to operate an effective
team that has the requisite skills, knowledge and experience to carry out its
responsibilities. This element provides a broad overview of the types of resources that
you may need to carry out the strategy. It also provides case examples to illustrate
creative leveraging of resources, which are always at a premium. Using this element in
combination with Element 4, Establishing Roles and Assigning Responsibilities, you
should be able to effectively implement the strategy.
Approach
Identifying, leveraging and managing needed resources within and outside your
organization is critical to ensuring that you can complete all the activities identified in
your strategy to achieve your goal. The following are examples of the types of resources
that you may need to utilize implementing the strategy:
Funding Vehicles: Contracts, grants, interagency agreements, cooperative
agreements.
Human Capital Team: Internal and external partners that you select based on their
skills, knowledge and experience.
Professional Services: Agency contractors that are not team members but are
providing certain types of services for the approach (e.g., laboratory services).
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Element 6: Designating Resources/Workforce Deployment
Supplies: Items needed to implement the
strategy (e.g., vehicles, sampling equipment,
computers, office supplies).
Travel: Travel required for team members and
contractors to conduct and implement certain
elements of the strategy (e.g., inspections,
investigations, site visits, workshops, meetings).
Training: Appropriate training for team members
to help them understand the environmental issues
(e.g., statute- or regulation-specific issues) and
implement activities (e.g., safety training for
inspections and hazardous materials), and for
regulated entities as part of compliance
assistance.
To make planning for resources committed by others
seem less daunting, be realistic about the type and
amount of resources needed. Factor in unanticipated
changes and prepare for contingencies. Moreover,
work with your team to develop creative approaches for the unforeseen issues and for
resource constraints. To ensure efficient use of limited resources, take the time to
assess the capacity of potential partners to contribute to the team and actually deliver on
their commitment. Competing priorities and projects may hinder partners' ability to
implement elements in a timely way; creative management and leveraging of resources
across partners or even with others in your organization may be necessary.
The following are some considerations in planning for resource management.
Considerations in Planning for Resources
Key Considerations
Based on lessons learned from the pilot projects and
other experience in developing and implementing
strategic approaches, we provide the following
considerations for designating resources and
deploying your workforce:
The resource demands of the strategic approach
will compete with other priorities and projects; you
will need to assess available resources and
clearly define and prioritize needs.
Invest in training as needed for team members
and other appropriate staff before implementing
the strategy.
When creating internal and external partnerships,
work with the assigned senior manager to ensure
that the partners have a clear and common
understanding of the type of resources and timing
of their use, as well as roles and responsibilities in
implementing the strategy.
Developing Your Team
Assess in-house expertise available to implement each tool
selected for the strategy.
Identify and seek commitment from partners with the experience
and capacity to implement the compliance assurance tools selected
and measure success.
Cross-train team members and other relevant staff who will support
the strategy.
Encourage team members to balance their time to work on other
projects and to notify the team lead of time limitations.
Set a schedule and adhere to it so that team members are
available to implement tools at critical times.
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Element 6: Designating Resources/Workforce Deployment
Considerations in Planning for Resources
Designating Your Resources
Coordinate work with other projects dealing with related areas or
issues.
Identify and secure appropriate grants for states and other grant
recipients.
Secure contract funds for specific needs of the team such as
gathering data, defining the baseline or developing materials.
Prepare to make adjustments when capacity or funding is not
available at critical points in the strategy.
Anticipate future resource needs for continuing or maintaining the
strategy.
Step-by-Step Process for Managing and Leveraging
Resources
Identifying resources and securing commitments
is essential to the success of your strategy. The
availability of resources can influence decisions
about which tool or tools will be used to address
the environmental problem. Provided here are
suggestions and examples on the type of
information to consider and the other elements in
the strategy that should be considered in the
decision-making process.
1 Develop a complete list of resources and
expertise necessary to implement the
activities of the strategy requiring such
funds and/or expertise. In many cases these
activities include collecting information to fully
understand the scope of the environmental
problem and address the target audience;
analyzing data to determine the success of the
strategy and measure its accomplishments;
implementing any or all of the compliance
assurance tools selected to address the problem; and
training personnel in any of the previously mentioned
activities.
"-35s '
This diagram focuses on designating
resources/workforce deployment and highlights
the other elements that are particularly important
during the decision making process for
resource designation.
2 Match available internal resources to your
needs. Search both within your own office and across other offices within your
organization to identify experts in the fields that you need (e.g., media-specific
experts to help you and your team understand the appropriate regulatory requirements,
inspectors to conduct inspections or investigations for baselining, compliance
evaluations, and onsite visits). Also identify resources to be leveraged (e.g., existing
grants or contracts that meet your scope of work and are not at capacity, other projects
underway where activities can be coordinated such as tagging onto scheduled
inspections or trainings).
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Element 6: Designating Resources/Workforce Deployment
3 Identify resource gaps where external partners will be needed. Some instances
where gaps occur that could be fulfilled by external partners are: understanding the
full scope of the environmental problem and the impacted audience; identifying existing
compliance assistance material that can be modified for the strategy; securing venues to
conduct training for the targeted audience.
4 Develop a list of potential external partners and their capacities. Potential
partners can range from other federal, state or local agencies that also regulate the
target audience, to trade associations able to provide additional information about the
target audience.
5 If you cannot retain all needed resources and experts or if you foresee
commitments that will be needed down the road to complete the strategy, identify
the gaps and future opportunities for leveraging resources. For ease of
implementation and to refresh your memory as you continue the strategy align these
resource needs with the implementation schedule and milestones.
Challenges and Opportunities
The following case examples and suggestions illustrate some Regions' and states'
experiences in identifying needed resources and the factors they considered in
assembling the resources. It also looks at how they balanced existing resources for
ongoing projects with the additional resources needed for the work by answering the
questions: (1) What resources and deployment of resources were used to develop and
implement the strategy; and (2) Was there an impact of deploying resources on this
priority with regard to other priorities or projects?
Challenge: Identify ing efficiencies to reduce personnel burdens
Opportunities and Suggestions
The workforce is the most precious commodity we have to ensure that
the environment is protected. However, there are not enough staff and
not enough time for staff to carry out all the activities necessary to meet
all needs. There are, however, creative solutions to build capacity. EPA
Region 2 planned for the possibility that up to 480 healthcare facilities
would self-disclose under EPA's Audit Policy after the Region provided
an incentive for facilities to report violations to the agency. To maximize
limited resources, the Region developed a model agreement for
healthcare facilities disclosing under the initiative. The Region also
created a small, ad hoc team of multimedia experts to review all the
disclosures. By streamlining the negotiation process and the
management of audit disclosures through the use of the model agreement, the Region
had a viable and efficient tool to address an entire sector without unduly impacting the
inspection and enforcement presence. The results of the process yielded 143
disclosures covering 540 facilities with 40 audit agreements, and 2,173 violations
corrected.
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Element 6: Designating Resources/Workforce Deployment
Another creative approach was demonstrated during the EPA
Region 3 Schools Initiative. The region was aware that
schools in Maryland and the District of Columbia had
multimedia compliance issues and that these schools had
limited understanding of regulations and limited resources to
return to compliance. The Region, however, was not in a
position to have full-time EPA employees focus the time
required to identify the schools' assistance needs. To continue
with this effort, the Region hired a student intern to evaluate
the schools' compliance assistance needs. This cost-efficient
approach allowed an intern to gain job experience while
satisfying EPA's resource need. In turn EPA reserved its extramural funds to develop the
schools' laboratory practices training, which was requested by the schools.
Challenge: How to leverage committed resources to accomplish
multiple objectives
Opportunities and Suggestions
Addressing new environmental issues does not always require
commitment of additional resources. Be aware of work underway in
your Region and state and take advantage of existing commitments to
satisfy multiple objectives from a single task. The Oklahoma
Department of Agriculture did just that when the state was trying to
develop an inventory of large Concentrated Animal Feeding Operations
(CAFOs) that may need to apply for National Pollution Discharge
Elimination System (NPDES) permits under a soon-to-be released rule.
Traveling across Oklahoma to inventory all the facilities was expensive.
Since the state had partial delegated authority for NPDES, EPA Region
6 and the state worked together and expanded the schedule of inspections to gather
additional NPDES data while providing assistance on the new CAFO rule. Two hundred
sixty facilities were inspected and added to the NPDES inventory with minimal additional
resource expenditure.
A similar approach was used by the New Mexico Environmental Department. The
state developed compliance assistance material informing 150 CAFO facilities how to
comply with the new NPDES general permits. In this case, the state took advantage of
scheduled inspections of its inventory of facilities to optimize time and travel resources
by providing compliance assistance information during the inspections.
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Element 7:
Communicating the Strategy
Objectives
Discuss how to communicate the strategy throughout its planning
and implementation.
Provide a process for selecting the communication vehicles that will
most effectively convey information to various stakeholders.
Identify challenges and opportunities in planning and executing
communication options.
Purpose
The information for this element will provide ideas on what type, in what form and when
to convey messages about the strategy. Informing interested stakeholders throughout
the planning and implementation process is important for transparency of the strategic
approach. This section supports Element 8 of the Framework, "Communication," and
Element 5 of the Template, "Communication."
The goal for this element is to identify all the potential stakeholders, the type of
information that will be of interest to them and the best vehicle to communicate that
message. The information provided is intended to illustrate options and suggestions for
effective communication on the strategy. The type of stakeholders, the role of the
partners, the type of tools selected and your organization's communication policies and
procedures will factor into your decision on how to
communicate the strategy.
Key Concepts
Communication Vehicle: Any
form of media that will convey a
message to the audience.
Networks: Existing organiza-
tional groups that will assist in
conveying the message.
Approach
Stakeholders within and outside of your organization
will have varying levels of interest in the progress of
the strategy. Depending on the type and scope of the
environmental issue and the affected audience, the
communication approach could be straightforward
with clearly identified stakeholders and
communication vehicles, or complex with a web of
networks and organizations (see diagram). Work with
the stakeholders to determine their particular
interests. There are three levels of stakeholders
involved in any strategy:
Key Considerations
Based on lessons learned from the pilot projects and
other experience in developing and implementing
strategies, we provide the following considerations for
deciding how, in what form and when to communicate
the strategy:
Identify all potential stakeholders, the information
of interest to them, and the communication vehicle
for conveying the message.
Align the communication messages with
milestones and other critical points during the
strategy so as to promptly inform the appropriate
stakeholders.
Work with the public affairs, press offices and
Web-based coordinators so that you understand
the press and publication parameters.
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Element 7: Communicating the Strategy
Internal Partners: Managers and staff within your office and organizations who need
to be either engaged in the process or kept informed of progress.
External Partners: Individuals or organizations that have committed to participating
in the planning and/or implementation of the strategy (e.g., other regulatory
agencies, trade associations or universities).
Public: Individuals or organizations that have an interest in the outcome of the
strategy or have an interest in assisting (e.g., the public at large, community groups
or neighbors).
Communication Partners for Targeted Audience
State Reg.
Agencies
(HQ and
regional)
Trade
Associations
Other
Plants
Sister
Plants
Vendors
*
Lawyers
hi
Trade:
journals,
websites.
newsletter
etc.
Universities
(ind. ext,
MEP,
SBDCs)
These two stakeholder groups are differentiated by the involvement and role of the
participants. External partners play an active role and contribute to the success of the
strategy. The public does not generally play an active role in the planning and
implementation, but should be kept informed of its progress and results.
In addition, the type of communication vehicle used is just as important as the audience
you address. Not all stakeholders receive their information using the same technology,
and you may need to convey your message through more than one vehicle. Just as you
created a team with various areas of expertise, identify communication vehicles that will
best address your audience.
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Element 7: Communicating the Strategy
Communication vehicles to consider include the following:
Mass media: Broadcast messages (e.g., Federal Register notices,
advertisements/press releases, newsletters, agency/organizational/topical Web sites)
Targeted media: Messages focused on specific audience or segments of an
audience (e.g., emails, educational brochures, listservs, newsletters, trade shows,
conferences)
Targeted interactive: Messages focused on structured feedback from audience to
presenter (e.g., Web-based tools, focus groups, face-to-face meetings, workshops)
Exclusive interactive: Messages focused on one target audience member at a time
and may include exchange of confidential information (e.g., mentoring, partner
meetings, facility visits, audits, hotlines, word of mouth)
The following table illustrates some of the considerations in communicating your
message and in deciding with whom and with what vehicle you would communicate.
Communication Objective
Notify the target audience of a
new rule and/or compliance
assistance tools
Promote participation in an
incentive program
Encourage attendance at
compliance assistance training
or workshops
Notify the public of significant
enforcement actions
Gain access to the target
audience/business community
and verify baseline information
Update partners on the
strategy's progress and
resource allocations
Build trust with new or potential
partners
Audience for Message
Target audience
Target audience
Target audience
Target audience/Public
Target audience/Partners
Partners
Partners
Vehicle to Communicate
Message
Federal Register to put the target
audience on notice, workshops to
understand how to comply
Targeted mailing to those who can
participate in the incentive
Listservs, trade media, emails
notifying of the training,
enforcement press release of
similarly situated facilitates
encouraging reluctant facilities
Press release to deter similarly
situated facilities from noncompliant
behavior
Face-to-face meetings, facility visits
for interactive discussion on the
target audience's compliance
issues
Periodic meetings, conference
calls, emails for a focused and goal-
oriented conversation
Focus groups, meetings,
workshops to demonstrate your
interest in working with partners
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Element 7: Communicating the Strategy
Step-by-Step Process for Communicating the
Strategy
This diagram focuses on communicating the
strategy and highlights the other elements that
are oarticularlv imoortant durina the decision
Upfront planning will advance your strategic goals
by evaluating the most appropriate times to
engage stakeholders in the strategy.
Provided here are suggestions and examples of
the type of information needed for effective
communication on the strategy.
1 Identify all the potential stakeholders. You
will identify potential stakeholders throughout
the process of developing and implementing
the strategy. Keep updating your list of
stakeholders and their contact information as you
go along.
2 Identify vehicles and messages for
conveying information. Tailor the main
points for the specific audience and frame
them to have the desired impact (i.e., do not assume
that you can always use the same message or terms
for different audiences). Tailor your communication
approach for your stakeholders by considering the following:
Understand your stakeholders and their culture.
Note communication issues or barriers for each stakeholder group (e.g., your public
audience's primary language, access to different types of media).
Work with stakeholder groups to address the communication issues.
Determine who on the team will be responsible for delivering the message. The audi-
ence may respond to the same message differently depending on who is the
messenger.
3 Align your messages with the milestones and critical points of the strategy so
stakeholders can be engaged in or notified of the strategy's progress in a timely
manner.
4 Identify any resources to develop and deliver the message. Where multiple
communication vehicles are available and used by the audience, assess the relative
cost effectiveness and timeliness of implementation.
5 Develop the message and seek team, managerial and organizational approval
(if needed). Each organization has its own policies and procedures for external
communications. Become familiar with them.
6 Once conveyed, monitor and evaluate the messages and methods of delivery.
An idea developed during the planning phase may not be successful when you
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Element 7: Communicating the Strategy
implement it. You may need to consider revising the communication vehicle and/or
message.
Challenges and Opportunities
The following suggestions provide insight into communication
planning. They illustrate the Regions' and states' use of
messages and mechanisms to communicate the strategy. The
scope of the audience, the type of information to convey and the
method of conveying information varies for each strategy. We
hope that these suggestions will give you insight and ideas on
some common issues associated with communicating the
strategy.
Challenge: How to efficiently and effectively target the message
Opportunities and Suggestions
Every communication option has strengths and weaknesses. Given limited resources,
first consider existing agency communication vehicles and their availability for
communicating the strategy. While press releases may appear to be high profile, in
many cases their actual use by the agency may be limited (e.g., significant enforcement
actions). EPA frequently uses the Web to post periodic updates on the implementation of
its strategies and initiatives but for more time-critical or sensitive information, it may not
be timely or appropriate. Sometimes the methods that require the least time and are
most readily available to your team may be the best options. For example, develop and
maintain an email group of all partners and another for interested stakeholders. Wth
those groups in place, create periodic updates on the progress on, milestones of and
modifications to the strategy. Moreover, inventory existing communication vehicles
(newsletter, brochures) in your agency and the timing of their release so you can include
your strategy's information (e.g., updates, articles, contact information, URLs) in them.
An example of this is the March 2003 edition of the Enforcement Alert newsletter
(Attachment E). This newsletter provided a mechanism to highlight the environmental
problems posed by sanitary sewer overflows, and to highlight the strategic use of EPA's
enforcement and compliance assistance tools being implemented during that time frame
to address the problem.
Challenge: How to identify the message and vehicle for the
target audience
Opportunities and Suggestions
Develop a communication approach that can be used when and where the target
audience will have heightened interest in the strategy and be able to act upon the
information conveyed. This means studying the recipients of the message to determine
their education and behavior status, and identifying what points in the strategy are most
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effective for conveyance. Because individuals who will react to messages and take steps
to address the message are located throughout an organization, you should identify
existing communication networks within the organization to have the broadest impact.
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Element 8: Monitoring and Evaluating the Strategy
Element 8: Monitoring and Evaluating
the Strategy
Objectives
Define evaluation and its relationship to measurement
Describe major steps in conducting an evaluation
Identify key challenges and opportunities in evaluating the
effectiveness of the strategic approach in addressing the
environmental problem(s).
Key Concepts
Evaluation: A systematic study
that uses objective
measurement and analysis of
answers to specific questions
that explain how well a
program, strategy or approach
is working to achieve its
outcomes and why.
Formative Evaluations are
intended to inform and improve
the approach while it is still
being designed or during
implementation.
Summative Evaluations are
intended to make judgments
about the approach after it has
been established for some time
or has ended.
Purpose
The goal of this element is to:
Assess whether progress has been made throughout the interim
stages of the strategy and if so, why.
Identify whether some elements or aspects of the strategic
approach are working but not others, and if so, why.
Determine the overall effectiveness of the strategic approach.
This element supports Element 8 of the Framework, "Monitoring & Evaluation
Processes," and Element 3 of the Template, "Priority Strategy." This element differs
from Element 3 in that you are not evaluating progress towards the strategies goals but
rather the overall strategic approach itself.
Broadly defined, evaluation and measurement are a systematic way to learn from past
experiences. The terms "evaluation" and "measurement" are not synonymous but are
closely related. Measurement is the ongoing monitoring and reporting of accomplish-
ments, particularly progress toward established goals. Measurement provides a picture
of "what is" but not "why it has occurred." Measurement data provide information needed
to conduct an evaluation and assess the overall effectiveness of the approach, program
or project being evaluated. In this Guide we will focus on EPA's strategic approach as
the object of evaluation. The following table further illustrates the relationship and some
of the differences between measurement and evaluation:
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Measurement Evaluation
Ongoing monitoring and reporting of
accomplishments.
Examines achievement of the strategic
approach's goals.
Describes achievements in terms of outputs and
outcomes in a given time against a pre-
established goal.
Presents a picture of what is happening at various
points in time. This picture can give management
an early warning about potential problems.
In-depth, systematic study that is conducted
periodically or on an ad hoc basis.
Examines a broader range of information on
performance than is feasible to monitor on an
ongoing basis.
Explains why the results occurred.
Longer-term review of effectiveness.
Approach
There are different types of evaluation that EPA or state agencies could apply to the
design, development and implementation of the strategic approach to address
environmental problems. Evaluations are generally categorized as either formative or
summative. These categories typically describe how the evaluation results will be used.
Formative evaluations inform and improve the strategy or strategic approach while it is
still being designed or during implementation. Summative evaluations make judgments
about the approach after it has been established for some time or has ended.
Additionally, an evaluation can focus on one or more aspects of the strategic approach.
An evaluation can be one or a combination of these types. Following are descriptions of
these types:
Formative Evaluations
Design evaluation focuses on the theory behind the integrated approachgiven the
context, is it reasonable to expect that the proposed activities will yield needed
changes? Is the approach conceptually sound?
Process evaluation answers questions about how the strategic approach operates
and documents the procedures and activities undertaken.
Summative Evaluations
Outcome evaluation answers questions about whether the approach has achieved
its expected goals and results.
Impact evaluation focuses on questions of causality. It attempts to establish cause
and effect by linking observed outcomes, changes or improvements in the condition
of the environment to the specific actions of the approach. An example of this would
be to evaluate the individual contributions of each compliance assurance tool
identified in the strategy toward achieving the goals. (Not sure if these is really a
good example of impact.)
Cost evaluation addresses how much the approach or its components cost,
preferably in relation to alternative uses of the same resources and to the benefits
that the approach is producing.
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In planning an evaluation, you must determine whether the evaluation will have a broad
or narrow scope. For instance, a summative evaluation can be designed to include
outcomes, impact and costs or focus on only one of these aspects.
Remember, a good evaluation can:
Ensure that you are meeting the goals of your approach.
Determine whether allocated resources are yielding the greatest environmental
benefit.
Identify what works well, what does not and why; and answer questions such as:
What internal and external factors influenced performance? (Retrospective)
What effect will this level of performance have on future performance if the
approach or activity is not modified? (Prospective)
W^z Step-by-Step Process for Evaluating the
^^Effectiveness of the Strategic Approach
Whatever type of evaluation you plan, the basic steps remain the same:
Step 1: Develop an
Evaluation Plan
Step 2: Describe What
Is Being Evaluated
Step 3: Develop
Evaluation Questions
and the Evaluation
Design
Step 4: Collect Data
Step 5: Analyze the
Data
Step 6: Present the
Evaluation Results
1 Develop an evaluation plan. The evaluation plan serves as the "roadmap" for
conducting the evaluation. To develop the plan, you will need to concurrently
identify the key stakeholders involved in the evaluation. These include individuals
responsible for designing and conducting the evaluation and reporting the results;
people who have an intimate knowledge of the approach being evaluated; and other
individuals who have a vested interest in the conduct or impact of the strategy. The
evaluation plan should include the following components:
Purpose of the evaluation
Primary audience
Design of the evaluation
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Element 8: Monitoring and Evaluating the Strategy
This diagram focuses on monitoring and
evaluating the strategy and highlights in gray
the other elements that are particularly
important in evaluation.
Evaluation questions
Roles and expectations for evaluators, staff,
participants and key stakeholders
Data collection/analysis process and protocols
Reporting
Resources (staff and budget)
Timeline
Communications
2 Describe the strategic approach. It is often
very difficult to evaluate a program, project or
approach that you don't understand. Having a clear
picture and understanding of how a program is
designed to operate is an essential step of
conducting an evaluation. The description of the
subject of the evaluation can take many forms but
should, at a minimum, identify what it consists of,
how it is implemented and who the target audience or
customers are, and should include a description of
key activities and expected outcomes. One approach
that EPA has used to graphically illustrate the subject of the evaluation is the logic
model.1 While there are many ways to implement this step, we will use the logic model
as an illustrative example. The logic model illustrates the logical and causal relationships
among elements of the approach
and the problem to solve, thus
defining measures of success. It
synthesizes the key activities
intended to achieve the goals of
the approach into a picture linking
inputs to activities and to expected
outputs and outcomes.
3 Develop evaluation
questions and the
evaluation design.
Evaluation questions are the
broad questions the evaluation is
designed to answer. They should
reflect the general objectives of the
evaluation and should address
what is important for your
audience to know about the
strategic approach. Determine
what your stakeholders need to
A logic model is a diagram and text that illustrates/describes the
logical (causal) relationships among program elements and the
results to be achieved
OUTCOME STRUCTURE
Sphere of
influence
EXTERNAL CONDITIONS INFLUENCING PERFORMANCE (+/-)
1Adapted from "Introduction to Program Evaluation" training course material developed by EPA's National
Center for Environmental Innovation, September 2005.
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Element 8: Monitoring and Evaluating the Strategy
know, and for what purpose and in what format they need the evaluation information.
Also decide on the scope of the evaluationis it formative or summative (i.e., does it
address design, process, outcomes, impact or cost)?
In identifying the evaluation questions, remember to:
Review the goals of the strategic approach and the evaluation.
Generate a potential list of questions.
For each question, ask, "Why is the question important? How will the information be
used, and by whom?"
Identify the standard or baseline that you will use to assess the information.
Assess feasibility of the question in terms of data collection, analysis and reporting.
Select the final list of questions.
Consult management and stakeholders.
Revisit your questions periodically and continue to consult management.
The following table provides sample evaluation questions to ask when designing the
evaluation:
Sample Evaluation Questions2
1 Approach
Elements
Evaluation
Questions
2 Adapted from
Resources/
Inputs
(We use
these)
Do we
have
enough?
Are they
the right
ones?
What level
is needed?
|_ l^nm
is there
consis-
tency?
Why or
why not?
"Introduction to Program
Activities/
Outputs
(to do these
things)
Are we
doing things
the way we
say we
should?
Are we
producing
results at the
level
anticipated?
Are we
producing
results
according to
anticipated
quality
indicators?
Why or why
not?
Target Short-term
Audience Outcome
(for these
people)
Are we
reaching
our target
audience?
Are we
reaching
the
anticipated
number?
Are they "
satisfied?
Why or why
not?
Evaluation" training course material
Did the
target
audience's
under-
standing,
knowledge,
skills or
attitude
change?
What
evidence do
we have
that the
approach
caused the
desired
changes?
developed by
Intermediate
Outcome
Is our
audience
using the
information,
knowledge,
skills and/or
attitude
change as
expected?
With what
results?
Is the
audience
changing
behaviors/
practices in
the
expected
direction/
level?
If so, what
did we do in
relation to
the
changes?
EPA's National
Long-term 1
Outcome 1
1
1
What
changes in
condition
(environ-
ment) have
occurred?
Why?
Center for Environmental Innovation, September 2005.
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Approach
Elements
External
Conditions
Resources/ Activities/ Target
Inputs Outputs Audience
(We use (to do these (for these
these) things) people)
What factors might influence the success of the strategy?
Short-term Intermediate Long-term
Outcome Outcome Outcome
Remember that questions that attempt to establish a direct cause/effect link between the
strategic approach and observed outcomes pose the greatest challenge and require a
well thought out evaluation design.
Evaluation design refers to the plan or protocol you will use to ensure that the
evaluation's results are reliable and valid. The goal of evaluation design is to rule out
other possible explanations in order to state (with a high level of confidence) that your
strategic approach caused the observed impact. There are a number of evaluation
designs, including experimental with control groups, non-experimental and case study
designs. Select the design that will provide the appropriate level of reliability and validity
you need to support your evaluation results and any claims you want to make about your
approach. Evaluation design is important because it helps strengthen the credibility of
the evaluation, provide confidence in the results of the evaluation and respond to
challenges that critics might have about the validity of the evaluation results.
In selecting an evaluation design, consider the internal and external validity of the
design. Internal validity asks, how sure are you that the action you undertook made the
difference in this specific experimental instance? External validity asks, how sure are
you that you can generalize these findings to other populations, settings and treatment
variables? In general, the more you control the internal validity (controlling external
influences to be sure that the action is indeed what "causes" the "effect"), the less you
are able to control for external validity.3
4 Collect data. Data collection usually involves collecting both qualitative and
quantitative data. Qualitative data are subjective and can come from observations,
interviews, and descriptions of actions or processes. Quantitative data are numerical and
can be collected from tests, reports, surveys and existing databases.
Methods used to collect data include questionnaires, surveys,
checklists, interviews, document review, direct observation, focus
groups and case studies. If you use methods such as questionnaires or
focus groups, data collection includes writing and carefully crafting
questions to administer to your test group. Ideally, you should pretest
your data collection instrument to be sure it is clear and provides
unambiguous responses wherever possible.
5 Analyze the data. To make the raw data meaningful, you must
analyze them. Data analysis is a complex but important task that
involves comparison and scrutiny of the data to enhance interpretability.
Perform analysis throughout the life cycle of your strategy, not just at
the end. You will need as much time for analysis as you took to collect
Tips on Data Collection
Use both qualitative and
quantitative data.
Gather data from multiple
sources.
Use one data collection
process to meet the needs
of multiple evaluation
questions if possible.
Weigh the costs and
challenges against the
benefits of the data
collection methods.
Adapted from Campbell and Stanley, Experimental and Quasi-Experimental Designs for Research. Rand
McNally, 1966.
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the data. Following are a few basic guidelines for analyzing evaluation data.4
Review for consistency and accuracy: Perform additional checks to ensure the
accuracy and consistency of the data, and eliminate incorrect or insufficient data. A
simple scan of data will usually reveal extreme data points or values that are
inaccurate.
Use all relevant data: In most evaluations, the person conducting the evaluation
desires positive results, which may provide a built-in bias. It may be tempting to
eliminate data that do not support the desired outcome. For a valid analysis, use all
relevant data. If not, explain why they were deleted.
Treat individual data confidentially: Frequently, data collected will be the result of
individual performances. In analyzing and interpreting the data and reporting results,
maintain the confidentiality of the individuals.
Use the simplest statistics possible: You can use a variety of statistical
manipulators to compare changes in performance. Keep the analysis as simple as
possible and confine it to what is necessary to draw the proper conclusions from the
data.
The use of statistics in evaluation serves the following primary purposes:
Enables large amounts of information to be summarized: There are two basic
measures used in summarizing evaluation data. One is the measure of central
tendency, usually the mean, less often the median and mode. This measure
presents, in a single number, a summary of the characteristics of the entire group,
such as the average compliance rate of a group of facilities. The second measure is
the dispersion, or variance, which is usually measured by the standard deviation.
This reveals how much the individual items in the group are dispersed.
Allows for the determination of the relationship between two or more items: In
analyzing data, the relationship between one or more items may be important. The
term used for this relationship is correlation, which represents the degree to which
the items are related. A positive correlation between two items means that as one
item increases, the other increases. For example, if the owner of a dry cleaning
facility receives a high posttest score at a course on environmental requirements for
dry cleaners, this high score might correlate to better compliance back on the job.
There can also be a negative correlation between items (i.e., as one item increases,
the other decreases). In this case, the correlation coefficient would be negative.
Shows how to compare the differences in performance between groups: When
performance improves after EPA has implemented the strategic approach, you are
likely to be asked: "Did the improvements occur because of the approach, or could it
have occurred by chance?" In other words, without the program, would the same
results have been achieved? How accurately can the conclusions be drawn?
Statistics enable you to place a confidence level on your conclusions about the
differences in groups of data.
Statistics also allow you to make comparisons to show trends over time and actual
performance against targets. Finally, remember to include multiple sources of data
whenever possible to strengthen and validate a particular finding or conclusion.
Yeonard Nadler, The Handbook of Human Resource Development. John Wiley & Sons, 1984.
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Present the evaluation results. Choose the format for presenting the data and any
findings based on your audience, the nature of the data and the way that the
information will be used. Most importantly, select a presentation method that will
clearly communicate the results of your evaluation. There are several environmental
evaluation reports on EPA's Web site at www.epa.gov/evaluate that you may find useful
to reference. This site provides a few examples of evaluation reports that have focused
specifically on the results of using compliance assurance tools. One is an evaluation of
Oregon's Toxic Use and Waste Reduction Assistance Program (see
www.epa.gov/evaluate/tuwrap1 .pdf). The other is EPA New England's (Region 1's)
evaluation of its Colleges and University Initiative in 2003. This initiative was also one of
the national strategic approach pilots. This evaluation focused primarily on one of the
tools the Region used to address the environmental issues at colleges and universities;
namely, the self-audit compliance incentive tool. As an example of how evaluation
results can be presented, excerpts from the Executive Summary of the Region 1
evaluation follow; for the complete evaluation report, see
www.epa.gov/newengland/assistance/univ/pdfs/Final-CU-lnitiative-Evaluation6-03.pdf.
Colleges and Universities Evaluation Executive Summary
The New England Colleges and Universities Initiative (the C/U Initiative)
provides compliance information and training to C/Us; promotes innovative
self-audit and environmental management system (EMS) initiatives; and
encourages environmental best management practices. The overall goal of the
program is to improve environmental performance at C/Us while enhancing
environmental awareness on campus.
EPA New England developed an evaluation of the C/U Initiative, focusing
primarily on the Audit component, under which participating schools were
given low inspection priority and reduced penalties in exchange for completing
self-audits of their facilities. The evaluation was based primarily on a survey of
52 C/Us participating in the Audit component of the Initiative, as well as on a
series of additional interviews with regulators and schools that chose not to
participate in the program.
The objectives of the evaluation were to help determine if C/Us were implementing
preferred environmental practices as a result of the C/U Initiative; examine the factors
that motivated C/Us to take part in the program; and consider the applicability of the C/U
Initiative approach to other EPA Regions or other sectors of the regulated community.
The evaluation yielded a variety of findings and conclusions about the effectiveness of
the C/U Initiative:
Program incentives encouraged participation: Roughly half of all New England
C/Us took part in the Audit Initiative. While the threat of enforcement actions
encouraged many C/Us to participate, nearly all C/Us were motivated by the
incentives offered under the Audit Initiative, particularly the desire to achieve a lower
inspection priority.
Participants addressed violations identified in self-audits: About three-quarters
of the Audit Initiative participants implemented short-term corrective actions to
address problems found in their self-audits. Common actions included waste
labeling, spill prevention and waste removals.
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Participants are implementing long-term environmental management changes:
Rather than simply implementing "band-aid" corrections to issues uncovered in
audits, nearly all of the Audit Initiative participants are implementing long-term
environmental management improvements. Common changes include improved
recordkeeping and information management, labeling programs, and enhanced
training requirements.
Participants intend to perform audits in the future: As further evidence of the
potential for the Audit Initiative to yield future dividends, more than three-quarters of
the schools surveyed intended to perform additional self-audits in the future. This
finding demonstrated that, although participants found the self-audit process
demanding, it was valuable and worth repeating.
Participants find outreach tools useful: Survey respondents voiced satisfaction
with the technical support efforts that EPA has taken as part of the overall C/U
Initiative. Respondents cited the workshops, the common violations list, the
regulatory interpretations and the summary of the SPCC regulations as being
especially useful in completing self-audits.
Many schools are implementing or considering EMSs: Nearly half of the survey
respondents are implementing, planning or considering an environmental
management system. These schools cite the self-audit process and EPA's overall
educational efforts as influencing their decision to explore EMSs. This finding
suggests that EPA efforts to increase awareness and encourage adoption of EMS
are succeeding. However, most schools are in an early stage with their EMS and
were not yet able to identify specific benefits yielded by the approach.
Two factors appeared to be most responsible for the success of the C/U Initiative. First,
the C/U sector has characteristics that are highly conducive to a self-auditing approach.
Key features of the sector include the technical sophistication of decision makers (e.g.,
Environment, Health and Safety staff); sensitivity to public image; peer pressure
between schools to maintain clean environmental records; and a mutually supportive
exchange of technical information between schools. Second, the C/U Initiative was well
managed and administered. State regulators and other stakeholders complimented
EPA's management of the program, highlighting EPA's willingness to coordinate with the
states, the open information exchange between EPA and the C/Us, and the quality of
EPA outreach efforts such as workshops and guidance materials. By providing C/Us with
a point of contact at the Agency, the program has improved communication and
coordination between EPA and the C/Us. This positive rapport represents a noteworthy
contrast to the adversarial relationship that often prevails in regulatory programs and has
contributed to the overall success of the C/U Initiative. EPA may wish to consider ways
in which it can maintain this relationship through a continued presence in the C/U sector.
The evaluation also considered whether the self-audit approach could be readily
transferred to other regulated sectors or other EPA Regions. Based on a qualitative
review of the extent to which other sectors have features similar to the C/U sector, it
appears that the approach may hold promise for sectors such as hospitals and research
labs. In particular, these sectors possess the structure (e.g., many geographically
scattered facilities), technical sophistication and image sensitivity that characterize the
C/U sector. Likewise, several other EPA Regions are already applying the self-audit
approach to manage compliance at C/Us. The success of these efforts has yet to be
determined, but it is possible that the dominance of large, public university systems in
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some Regions may offer advantages (e.g., resource sharing, system-wide auditing) not
realized in New England, where smaller, private campuses dominate. Overall, it was
recommended that relevant Regions implement a comparative analysis of the self-audit
programs completed thus far in order to identify key determinants of success that may
guide future initiatives.
In summary, this evaluation indicated that the New England C/U Initiative had
successfully realized its key objectives, achieving compliance and environmental
benefits with limited enforcement resources. Participants have implemented numerous
corrective actions in response to audit findings and also have introduced long-term
management changes designed to improve environmental performance. Collaboration
between EPA and the schools has been extensive, and the participants speak highly of
the technical support they have received. This collaboration allowed C/U environmental
managers to meet their obligations and, in some cases, to move beyond basic
compliance and institute innovative measures such as environmental management
systems.
Challenges and Opportunities
Challenge: Lack of Agency experience and expertise in
conducting evaluations
Demand for information about the performance, operation and results of EPA programs
and strategies has continued to increase. However, EPA has undertaken evaluation on
an informal basis, and evaluation expertise has been limited.
Opportunities and Suggestions
The Government Performance and Results Act (GPRA) has served as a driver for EPA
to focus on more systematically using evaluation. GPRA requirements to measure
program results, outcomes and performance in terms of goals and measures are
creating an opportunity for the Agency to think more critically about the underlying logic
of its programs. Program evaluation can help identify program impacts, reasons for
observed outcomes and how programs can be improved. However, program evaluation
should be viewed in a context broader than GPRA alone.
Other drivers for conducting program evaluation include the Office of Management
and Budget's (OMB) Program Assessment Rating Tool (PART). The PART is used
to assess and evaluate programs across government and emphasizes use of
"independent and quality evaluations" to determine if programs are effective and
achieving results.
The President's Management Agenda (PMA) identifies five areas for improving the
management and performance of the federal government using a scorecard to rate
federal agencies on each initiative, giving a "score" of red, yellow or green.
Program evaluation provides a range of strategies that can support the ongoing
performance measurement that is required under GPRA and the other drivers discussed
above. By constantly evaluating its environmental programs, EPA can capitalize on
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Element 8: Monitoring and Evaluating the Strategy
lessons learned and incorporate that experience into other programs and environmental
arenas.
To assist in these efforts, EPA's Evaluation Support Division (ESD) in the National
Center for Environmental Innovation is working to identify, build and leverage evaluation
capacity throughout the Agency. This work demonstrates how program evaluation can
be a valuable tool and an integral component of the Agency's emerging results-based
management framework.
ESD has taken a leadership role in identifying and building evaluation skill and
knowledge throughout the Agency through a number of activities. These have included:
Co-chairing the EPA Program Evaluation Network.
Designing and conducting evaluation training.
Serving as an advisor to program offices conducting evaluations.
Networking with state, academic and other program evaluation practitioners outside
EPA.
Serving as an information clearinghouse for information resources encompassing
program evaluation standards, tools, journals and associations.
In continuing to build capacity for program evaluation in the Agency, ESD will continue to
identify and disseminate knowledge of evaluation, and harness diverse information
resources and tools. Environmental program evaluation has recently emerged nationally
as a recognized sub-discipline that applies the principles and approaches of traditional
program evaluation, tailored to the specific needs and challenges of environmental
policy management. Go to www.epa.gov/evaluate for an extensive listing of evaluation
resources.
Challenge: Lack of data needed for evaluations
Data collection is an ongoing problem for the Agency's measurement and evaluation
efforts. The availability of quantifiable data on environmental results to tie to the
implementation of EPA's strategic approach has been highly variable. When an activity
or approach results in a change in the level of emissions or discharges that are already
being monitored and tracked for regulatory purposes, data are easily obtained. However,
if the approach is aimed at an environmental problem for which few or no data exist
(e.g., non-point source pollution), it will be more difficult to quantify the level of
improvement through environmental indicators directly related to the implementation of
the approach.
EPA has relied on qualitative and anecdotal data for many efforts. Lessons learned
and information on how people involved with the strategic approach perceive it to
be working are of some value. But even that information may be difficult to gather.
For example, during the pilot phase when the Framework was being tested, EPA
attempted to evaluate the usefulness of the Framework itself by use of a survey.
Attachment F contains a copy of that survey. Unfortunately, due to insufficient
responses, EPA was unable to complete the evaluation of the Framework.
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Element 8: Monitoring and Evaluating the Strategy
Another challenge to collecting data on results is the restrictions under the Paperwork
Reduction Act on surveys and questions that the federal government can ask of non-
federal entities or persons. OMB must grant permission to collect this type of information
through an Information Collection Request (ICR). ICRs are required for most EPA
surveys to collect measurement or evaluation information from more than 10 non-federal
recipients.
Opportunities and Suggestions
The Agency is exploring various mechanisms for improving data collection, including
generic ICRs for evaluation, additional training on data collection and additional sources
of data beyond those that EPA has traditionally relied upon.
Guide for Addressing Environmental Problems | 8-12
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Element 9: Exiting the Strategy
Element 9: Exiting the Strategy
Objectives
Introduce considerations for deciding whether and how long to
sustain the strategy and when to exit and transition to a core
program or maintenance approach (see Key Concepts).
Provide considerations on when to transition and a step-by-step
process on how to plan for a transition.
Identify key challenges and opportunities for deciding when to
transition or sustain the approach.
Purpose
This information on this element examines some of the basic
considerations in assessing the most appropriate point to transition the
strategy to a maintenance level or to sustain the strategy. It supports
Element 4 of the Template, titled "Exit Strategy." The goal in planning
for this element is to recognize that at some point the strategy will no
longer have a heightened level of resources and attention; the
resources committed and the roles and responsibilities of the team will
shift back to the core program or a maintenance mode.
Approach
Key Concepts
Core Program: The
fundamental activities
implemented by EPA, state and
local agencies (or a delegated
authority) to protect the
environment.
Priority: Recognized
environmental problems that
warrant heightened resource
and commitment levels for a
designated period of time.
Maintenance: The level of
commitment to the strategy
shifts from a resource-intensive
priority to a level commensurate
with the agency's mission and
long-term goals and objectives.
Sustain: The level of
commitment to the approach
remains elevated until further
assessment.
Planning for a strategic approach includes planning
how to exit it. Ignoring this element of the planning
process leads to a higher possibility of failure and
logistical complications. Think of exiting as the
beginning of the next phase of the strategy. Most, if
not all, of the elements of a strategic approach (e.g.,
goals, monitoring, resources, communicating) need
to be addressed for a long-term maintenance plan.
When a strategy ends, the need for environmental
protection remains. Unforeseen circumstances and
changes that arise during implementation of the
strategy could affect your decision on when and how
to transition; however, obvious and predictable
factors (presented in the following table) will also
influence your decision to either transition and exit or
to sustain the strategy. These factors are not
mutually exclusive; the decision for the next phase of
the strategy could be based on any or all of them.
Key Considerations
Based on lessons learned from the pilot projects and
other experience in developing and implementing
strategies, we provide the following considerations for
deciding when and how to exit the strategy:
Include this element from the start of the planning
process.
Identify all the long-term options for continuing to
address the environmental issue in the future,
while balancing the resource commitment with the
environmental impact for each option.
Develop a transition and maintenance plan that
specifies future resource obligations, whether and
how to address regulated entities not covered by
the approach, and actions to safeguard
improvements achieved.
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Element 9: Exiting the Strategy
Factors to consider in
determining whether to
sustain or exit the strategy
Are the goals met?
Sustain the strategy if.
Goals for the approach are not
achieved.
Transition and exit the
strategy if...
Goals for the approach are
substantially achieved.
Goals cannot be substantially
achieved, but activities are
completed according to
schedule.
Are you prepared to evaluate the
approach and measure the
goals?
Data are insufficient for
program evaluation and
performance measures.
Data are sufficient to evaluate
the approach and address the
goals.
Are resources allocated to
perform key activities?
Resources are available to
continue key activities.
None or limited resources
remain to carry out key
activities.
If identified as a goal, is
environmental compliance by
the target audience being
achieved?
Environmental compliance is
not achieved, and further
actions as a high priority are
warranted.
The environmental problem is
substantially addressed and is
ready for a long-term
maintenance plan.
Are there competing priorities
where resources could be used
more effectively?
The target audience is
responding positively to the
strategy, and continuation of
the approach will most likely
prove successful.
The target audience has
responded to the strategy, and
external partners are sustaining
the return to compliance or
beyond compliance.
The target audience is not
responding positively to the
strategy, and transitioning to the
core program or to enforcement
only is warranted.
Step-by-Step Process for Exiting and Transitioning
the Strategy
Determining when and how to exit the strategy and what will be the next phase to
address an environmental problem that was once viewed as a priority requires
consideration of all the other elements in the strategy.
Provided here are suggestions and examples on the type of information to consider in
planning for this element.
IThe default position for exiting a strategy is when the goals are met and measured.
With this position in mind, take the time up front to assess whether the goals
and measures are clear, realistic and tangible, and whether the data to
demonstrate success is obtainable. Assuming the strategy goes as planned, it will be
obvious when to exit. However, that is not always the case. That is why you need to
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Element 9: Exiting the Strategy
consider how to best use other elements in the strategy to help you determine when to
exit or when to sustain. More importantly, deciding "when" does not inform you "how" to
transition and to determine what constitutes the "next phase."
2 Incorporate exiting the strategy with the
development of the implementation plan (i.e.,
schedules and milestones). Factor into the schedule
the anticipated time and approach for exiting.
Recognize that you may need to transition sooner
than expected (e.g., goals met earlier, competing
resources), or you may need to sustain the approach
longer than you initially realized (e.g., strategy is
successful but more time is needed to address the
entire target audience, changed selection of tools
midcourse, environmental issue is broader than
initially determined).
3 Incorporate exiting the strategy with the
development of monitoring and evaluation.
Consider what actions (e.g., target audience's
response to the tools, compliance improvements,
team resources) you will need to monitor to move
toward exiting and what steps (e.g., communicating to
interested and impacted stakeholders) will need to
occur to prepare for exiting. Environmental protection is
dynamic and requires continuous monitoring to address
the success of the strategy.
This diagram focuses on exiting the strategy and
highlights the other elements that are particularly
important during the decision-making process for
this element.
4 Develop a transition proposal. Even though your attention is focused on planning
for a strategy, take the time to draft a transitioning and maintenance proposal,
assuming the best case scenario but preparing for obstacles along the way. At a
minimum, include in your proposal the following:
The tools used in the strategy that need to be maintained in the next phase.
The current resource level (or the level used throughout the approach) and the level
of resources required after the transition occurs.
The roles and responsibilities for the office that will be in charge of the next phase.
5 Communicate the transition and maintenance proposal with your team and
share and seek concurrence on the proposal with the managers in the office that
will be responsible for the maintenance phase. Seek concurrence in a timely manner so
the office (or delegated authority) has time to secure resources for the next budgeting
cycle and notify all affected personnel for the next planning cycle.
Challenges and Opportunities
The following case examples and suggestions provide insight into assessing whether to
transition and exit or to sustain the strategy. These examples illustrate Regions' and
states' response to the question: What factors or situational changes occurred during
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Element 9: Exiting the Strategy
implementation of the integrated approach that justified exiting, continuing or expanding?
Each approach has a unique set of challenges, but these suggestions may help you find
the justification for exiting or continuing your strategy.
Challenge: When and how to continue to address a sector-wide
compliance problem as a priority
Opportunities and Suggestions
In many cases the decision to continue the strategy beyond its original exit date turns on
the knowledge gained about the scope and breadth of the environmental problem during
implementation of the strategy. Your initial strategy may have focused on a defined
population faced with a single environmental problem. But once the strategy starts, you
realize that the targeted population has doubled and the environmental problems are
numerous. This is the time to step back and assess how much more work needs to be
accomplished to gain a better perspective on the problem and determine the most
effective and efficient approach to acquire that information. Some regions take the
approach of setting up focus groups and widely publishing the intent of their strategy to
gather additional information on the scope of the problems. In other instances, regions
may undertake new multimedia inspections or increase the number of scheduled
inspections to understand the breadth of the environmental problems. This is not the
time to stay the course as initially planned just to meet an end date you set a few months
ago. At a minimum, you will need to reevaluate your strategy to determine whether it
should be expanded to address and improve the additional problems identified.
Challenge: When and how to make the transition from a priority
to a core program or maintenance plan
Opportunities and Suggestions
Some level of non-compliance and related environmental problems will remain
after a priority strategy ends. This underscores the importance of defining clear,
realistic goals for priority areas that can be met and measured in a reasonable
number of planning cycles. Identifying when it is time to transition from a
priority to a core program level of attention in a particular program area
requires a discrete endpoint by which the "mission is accomplished." Not every
mission will be defined in the same way. For example, some may use
improvements in compliance rates for a particular sector or requirement, while
others may be based on elevating attention to long-standing requirements that
are in need of renewed focus. In EPA's Safe Drinking Water Act (SDWA)
Microbial Rules National Strategy, EPA and stakeholders realized that a
short-term intense focus on core requirements of the SDWA could provide
needed attention on reducing drinking water contamination from microbial
pathogens, but would not completely eliminate non-compliance. Forty-nine out of 50
states and most U.S. territories have primacy for implementing and enforcing the SDWA
program; therefore, EPA enforcement presence could not necessarily change overall
compliance rates associated with the microbial regulations. During the period of the
drinking water microbial priority, the increased focus on and Federal attention to this
environmental problem did, however, stimulate overall compliance and enforcement
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Element 9: Exiting the Strategy
activity in this area and helped decrease microbial contamination in drinking water
provided by public water systems.
All stakeholders agreed to transition from a national priority to the core program at the
end of EPA's first three-year planning cycle in FY 2004. In EPA's judgment, transitioning
to the core program allowed EPA to shift Federal attention to program management and
oversight efforts aimed at ensuring that primacy authorities continued to focus
appropriate compliance and enforcement efforts to address microbial noncompliance
and improve drinking water quality.
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ATTACHMENT A Page 1
Final 11/5/02
Framework for a Problem-based Approach to Integrated Strategies
BACKGROUND
The "Interim Final 11/18/96 Operating Principles for an Integrated EPA Enforcement and
Compliance Assurance Program " describes a set of core principles for EPA 's enforcement and
compliance program, the various "tools" available to address environmental problems and guidance on
the integration of those tools. Over the years, there has been different experience in using the guidance
and effectively integrating these tools by the Headquarters and Regional offices who implement the
national compliance assurance program. This Framework reaffirms the "Operating Principles " and the
general approach its sets forth. A draft white paper on the Use of Integrated Strategies (May 25, 2001)
was also developed by OECA which reaffirms the approaches laid out in the Operating Principles and
discusses lessons learned in integrating compliance assurance tools. Both of these documents provide
relevant background information. This Framework builds on these documents and advocates using a
problem-based approach to using and assessing the impact of our compliance assurance tools. Further,
the Framework advocates the consideration of all tools and the elements of the Framework - not
necessarily the use of each tool and the application of each element to every problem. In some cases, for
example, an immediate enforcement response may be the most appropriate approach given the situation
andproblem.
This Framework is intended to be utilized after national and/or Regional problems have been
identified on which federal resources will be expended. The Framework provides guidance for
developing "integrated strategies " a strategic approach which gives up front consideration to which
tool or tools - compliance assistance, enforcement, compliance monitoring and compliance incentives
- to use when addressing identified environmental problems. The Framework encourages proactive
consideration of the elements of an integrated strategy: 1) data gathering to further define the problem
and universe and develop compliance baselines, 2) tool selection and sequencing to effectively address
the environmental problem(s), 3) up front development of measures to assess progress and outcomes
and 4)communication with stakeholders, partners and the public. Use of the framework can add
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ATTACHMENT A Page 2
transparency to EPA 's decision-making process.
I. STATEMENT OF ENVIRONMENTAL PROBLEM {"What" (specify) is the environmental
problems or issues?}
To understand the impact and significance of environmental problems/issues, establish a baseline
of information on: a) health and environmental impacts; b) potential risks; and c) root and contributory
causes. Establishing a baseline of information will help create the framework for the type and level of
integrated strategy to be developed and the approach to measure the integrated strategy's effectiveness.
Below is a list of factors to be considered when establishing the baseline:
Pollutants involved
Geographic areas impacted
Population impacted (environmental justice communities)
Distinct/specific noncompliance issues or patterns that need to be addressed
Industry sectors that appear to contribute to the problem
Health and environmental consequences of the problem
Current applicable federal, state, & local regulations, regulatory gaps, and opportunities for use of
other regulatory authorities or innovative approaches
II. JUSTIFICATION FOR SELECTING THIS PROBLEM OVER OTHERS {"Why is the
identified problem one that EPA should devote resources to now?}:
Given competing resource needs and priorities, describe the factors that make this problem(s) ripe
for resolution and a relative priority.
Questions to consider when making this decision:
What is the scope/seriousness of the health or an environmental problem?
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ATTACHMENT A Page 3
How does this environmental problem rank relative to others being considered?
Is noncompliance contributing to the problem and could it be addressed by EPA intervention?
Has there been an EPA or state presence in the sector?
Are there a large number of facilities which will benefit?
Are there a large percentage of small businesses with limited capacity to comply?
Is the problem widespread or a growing problem?
Do the problems fall within EPA's role/authority?
Does the problem merit the attention of OECA and the Regions?
Does the proposed problem fit EPA's planning horizon?
What is the current level of attention?
Are there new or pending rules that may impact the problem?
Are there environmental justice considerations?
III. DESIRED/ANTICIPATED OUTCOMES/RESULTS {"What" (specify) are the goals and
objectives? "What" (specify) do we hope to accomplish?}:
What do we want to measure? Measures can be used to show: a) progress toward the anticipated
outcome - interim measures; b) need for mid course corrections, c) the effectiveness of the integrated
strategy and, d) lessons learned for program evaluation. During the development of the integrated
strategy identify both final measures of success and interim measures and milestones. Where appropriate,
measure each type of tool used in the integrated strategy as well as the synergistic effect of the tools.
Measuring each type of tool used may be more appropriate as an interim measure. In determining desired
outcomes, consider compliance and "beyond" compliance goals.
Below are examples of the generic outcome measures to be considered in problem based
integrated strategies.
Increased understanding of regulatory requirements
Facility Management Changes
Facility Process changes
Return to Compliance
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ATTACHMENT A Page 4
Regulatory actions taken
Pollutant Reductions
Capacity Building
Adopt sustainable practices
Promote/demonstrate changes in industry supply chain
Below are some examples of interim measures:
Tools developed
CAP program letters sent
Reach/outputs can be used as interim measures
How will we measure our progress? Identify the outputs/outcomes for your activity and the type
and sequence of measurement tools to be used to assess your progress/results. The measurement
continuum is far reaching and ranges from gathering baseline data to measuring environmental
improvements.
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Page5
IV. USE OF AVAILABLE COMPLIANCE ASSURANCE & ENFORCEMENT TOOLS {"How"
are we going to address/solve the problems or issues?)
Continuum of Measures
Baseline
Develof
Baselir
C
)ing
ies
Capacity
Building
Output Measures
Tools
Developed Enfor
Reach Act
cement
vities
Customer
Satisfaction
Outcome Measures
Changes in Ch<
Understanding Be
Environmental and
anges in Human Health
jhavior Improvements
, 1
'
Establishing
Compliance
Baselines
Identifying
compliance
problems/universe
EXAMPLES:
Enforcement -AOs, Penalties
Incentives- # disclosures
CA-outreach materials
distributed
Inspections - # conducted
EXAMPLES:
Enforcement - injunctive relief
Incentives-violations corrected
CA-emissions reduced after CA visit
Inspections/CA - facility process change
Understand need to apply for permit
Compliance Assurance Activities/Tools
Consider any of the elements below when deciding on and developing integrated strategies In some
cases, enforcement or compliance assistance alone may be an appropriate strategy. It may be appropriate
to use cross-programmatic, multimedia and/or cross-regional teams to develop a plan for using the most
appropriate tool/tools and sequence of tools. Various partners in the strategy may use different tools (
e.g., state Small Business Assistance Programs may use compliance assistance; EPA may use incentives
or enforcement). See the attached guidance on factors to consider in choosing and sequencing tools (TO
BE DEVELOPED)
Overview1
Element 1: Compliance assistance activities - What will be the level of CA? Determine the
1 Briefly discuss the sequencing of the elements (and their integration into the overall effort), how the use
of a particular element complements the use of the others, etc.
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Page 6
appropriate levels and types of CA that could be used to address the environmental
problem. Who will provide it? What tools exist or need to be developed? What
will EPA's role be as a CA provider and how will EPA work with other providers?
Element 2: Compliance incentive activities - Will EPA or state policies or activities be used to
provide incentives? Consider the usage of policies and activities, including EPA's
Audit Policy, Small Business Compliance Policy, Small Communities Policy, and
CAPs.
Element 3: Compliance monitoring activities - What is the appropriate level of CM? Will CA
be integrated with CM activities? Is there or can we develop common terminology
on levels of CM/CA that can facilitate this integration? " The Role of the Inspector
in Providing CA" and the ICDS may be useful starting points.
Element 4: Enforcement activities - What Enforcement Response Policies may be used?
Determine what kinds of enforcement activities may be used to address the
environmental problem.
Element 5: Other Relevant Activities - what other EPA or state activities will be included in
the strategy? (e.g., developing new regulations, sustainable industry program
activities and other innovative approaches, coordination with other federal
agencies, use of compliance-based environmental management systems, pollution
prevention activities and other beyond compliance activities, best management
practices that help ensure compliance and improved environmental performance,
mentoring and demonstration of environmental leadership)
V. RESOURCES [ What resource needs and issues are associated with the effort?]
Questions to consider:
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ATTACHMENT A Page 7
What is the best sequence of tools to address the problem? Are there any cost efficiencies
associated with certain tools or combination of tools?
Will different tools be applied to various segments of the regulated community?
Are the resources available to implement each tool of the integrated strategy?
What are potential sources for obtaining needed resources, i.e., where can we look for
additional resources if we don't have them?
Can there be varying levels of implementation of the tools to reduce costs?
What are the economic cost and environmental benefit for implementing each type of
tool/cost of implementing the integrated strategy as a whole?
VI. SCHEDULE - (What is the schedule for undertaking the specific tasks in implementing the
strategy?]
Draft a schedule with milestones for undertaking the strategy. Consider resource needs, the
MOA and state planning processes, reporting deadlines
VII. INVOLVED STAKEHOLDERS AND ROLES AND RESPONSIBILITIES - (Who are the
involved stakeholders and what are their roles and responsibilities?)
Questions to consider:
How will EPA work with other regulators, including other federal agencies?
How will OECA and the regions coordinate with the other EPA program offices, and state offices?
4 Which regulatory body will take the lead?
4 Enforcement - what regulatory body has the lead for enforcement actions?
4 Compliance monitoring - What regulatory body has the lead for conducting inspections?
4 CA - Who has the lead for delivering CA to the regulated entities?
Which unit within the organization will have the lead for coordinating and implementing the
integrated strategy?
What is the role of the supporting regulatory agencies?
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What is the role of 3rd parties in the development and implementation of the strategy?
a) Federal Regulators:
HQ - which offices? which programs?
Regions - which offices? which programs?
b) Other Regulatory bodies: State/local tribal
c) Third Parties: Trades, industry, nonprofit, community groups, suppliers, etc.
VIII. COMMUNICATION {"How" will stakeholders be informed of the status and results of the
activities reflected in the strategy? Has a communication strategy been developed?}
There are three key audiences that must be kept informed throughout the implementation of the
integrated strategy. Each of these audiences has a need for different types of information at different
stages of the strategy. These three groups are: a) participants that are working on the integrated strategy;
b) federal and state Agency management; and c) external stakeholders including the regulated community
and the public (includes the news media).
a) Participants working on the integrated strategy: They need to know all of the elements and actions of
the strategy and have a clear understanding of all the activities and outcomes. It is critical to develop a
glossary of clear and consistent terms and concepts to ensure that all parties are in agreement. If they
are expected to communicate the strategy to others, should talking points and presentations be developed
and shared?
b) Federal and state agency managers: A communications plan needs to be developed at the onset of the
strategy's implementation to ensure that management is appraised of the strategy's progress, and to gain
support and potential partnership of the Agency's efforts to address the compliance issue. The
communications plan usually includes strategies and implementing tools/activities.
c) External stakeholders: A communications plan needs to be developed at the onset of the strategy's
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ATTACHMENT A Page 9
implementation to ensure that the regulated community is adequately informed of its compliance
responsibilities and EPA's efforts to address the compliance issue/problem. Likewise, the Agency has a
responsibility to inform the public on what EPA is doing to address compliance issues/problems,
particularly in environmental justice communities. The communications plan usually includes strategies
and implementing tools/activities. Regardless, there is a need to ensure consistent messages.
IX. MONITORING & EVALUATION PROCESSES: { "How " will progress relative to goals and
objectives be monitored?}
Questions to consider:
Are we making progress throughout the various interim stages of the strategy?
Have we addressed the environmental/health problem(s) identified in Section I. The Statement of
the Environmental Problem?
Have parts of the strategy worked but not others?
Do we need to modify the strategy?
What is the overall effectiveness of the Integrated Strategy approach?
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ATTACHMENT B
Contacts for the EPA Regions 2002-2004 Integrated Strategy Pilot Projects
Region 1: Schools. EPA New England K-12 Schools Integrated Strategy Mary Dever, (617)
1717
Hospitals: Healthcare Sector Strategy / Baseline Information. Janet Bowen (617)
918-1795
Region 2: Hospitals: Compliance Assistance for Hospitals as Part of Integrated Strategy
Initiative for the Healthcare Sector. Kathleen Mai one (212) 637-4083, John
Gorman (212) 637-4008
Region 3: Schools: Preventing Risks to Children's Health in Schools by Increasing
Compliance.. Betty Barnes, (215) 814-3447
Region 4: Wood Preserving: Developing a Baseline of Wood Preservers in Region 4 States.
Shannon Maher (404) 562-9623
Region 5: Auto Salvage: Indiana Department of Environmental Management Auto Salvage
Facility Sector Project. Matthew Deaner, Indiana
Region 6: Construction (Oil and Gas): Integrated Strategy Pilot for NPDES Storm Water
Phase II Rule Implementation the Oil and Gas Industry in Region 6. Casey
Luckett, (214) 665-7393
Agriculture: Integrated Strategy Pilot for Compliance with new NPDES CAFO
Permits at Concentrated Animal Feeding Operations. Abu Senkayi (214) 665-
8403, Richard Powell, New Mexico, Norma Aldridge, Oklahoma
Region 9: Auto Salvage: Storm Water Protection Program Compliance Assistance for
AutoWreckers/Recyclers: Assessment of Effectiveness of Compliance Assistance
Methods. Angela Baranco (415) 947-4262
Region 10: Construction: Alaska Stormwater Integrated Strategy Pilot Project for the
Construction Sector. Chae Park (206) 553-1441
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ATTACHMENT C
Final Draft
2/18/04
Template for Developing a
Performance-Based Strategy for National
Compliance and Enforcement Priorities
I. Problem Statement
A. Define and characterize the environmental or non-compliance problem for the priority area
B. Provide baseline information on the size of the priority universe, geographic distribution of
the problem, level of compliance, and any environmental justice issues
C. Address how the problem relates to each OECA criteria for priority selection
D. Address how the problem affects Environmental Justice (all strategies) and Federal Facilities
issues (where appropriate).
E. Describe known or suspected causes of the problem
F. Identify existing policies and guidance that address the priority; and past strategies or
initiatives used to address the problem
II. Goals and Measures
A. Establish an outcome goal for the priority area
1. The goal should address the priority area, be measurable, and reasonably achievable in
the given time frame
2. Achievement of the goal will serve as the end point for the priority
B. Establish outcome and output measures for the priority area
1. Outcome Measures should be directly linked to, and serve as the primary indicator of
progress toward achieving the outcome goal
2. Output Measures serve as indicators of progress toward implementing the components of
the priority strategy, and will enable managers to track implementation milestones
3. Measures should be developed for EJ (all strategies) and Federal Facilities (where
appropriate)
C. Establish baselines for all measures, or develop a plan for developing a baseline for each of
the measures
III. Priority Strategy
A. Identify a mix of tools that will be used to address the priority area, and how they will result
in achieving the outcome goal
B. Describe how the tools will be used in conjunction with each other to achieve the best results
1. Include the sequence in which tools will be used, targeting priorities, how long they will
be used, implementation milestones, resource issues, and implementation roles (i.e.,
headquarters, regions, others)
2. Include a description of how Environmental Justice (all strategies) and Federal Facility
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issues (where appropriate) will be addressed by the application of the tools
C. Develop a plan for periodically reviewing progress and making adjustments to the strategy as
needed
D. Develop internal and external communication strategies. The internal strategy should focus
on providing managers information on strategy implementation and periodic performance
measure updates to enable them to track progress and make needed corrections. The external
strategy should inform the regulated community and stakeholders, help improve strategy
effectiveness, and communicate results.
E. Assign Roles and Responsibilities. Identify all of the parties that will play a role in
developing and implementing the strategy, and assign responsibilities for all of the
development and implementation tasks. Responsibilities should be broken out by
headquarters, regions, and others.
IV. Exit Strategy
A. Identify steps to discontinue formal priority treatment once the outcome goal has been met
B. Develop a maintenance plan to include:
1. Significant resource obligations
2. Whether and how to address regulated entities not addressed as part of the strategy
3. Actions to safeguard to improvements achieved; including periodic monitoring, review
and adjustment
V. Workforce Deployment Strategy
A. The priority sector or problem area should be assessed to identify the skill sets needed to
effectively address the priority and implement the priority strategy. This assessment should
anticipate the different skills needed at different points in the strategy (e.g., compliance
assistance early on, more enforcement towards the end).
B. Taking into account the strategy's ultimate goal, time line, and exit strategy; responsible
parties in headquarters and regions should estimate the activity levels needed to achieve
strategy's ultimate goal in the given time frame.
C. Gap Analysis - headquarters and regions should identify workforce gaps that will impact
achieving priority goals, including deficits in overall number of employees to address a
problem area, and in particular skill sets.
D. Workforce Deployment Recommendations - based on the gap analysis recommendations for
making workforce adjustments within individual regions and headquarters, and between
regions, and regions and headquarters should be identified to maximize strategy
effectiveness.
VI. Schedule
Develop an overall schedule for addressing the priority area
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ATTACHMENT D
EPA Region 2 Healthcare Compliance Initiative
06/08/2005
Executive Summary
| Sector
| Healthcare
Environmental Problem
The 480 hospitals in New York, New Jersey, Puerto Rico, and the
Virgin Islands pose a major environmental and public health concern.
First, they contribute to the mercury in the environment which is of
great concern in the Northeast. Rates of mercury deposition are
estimated to be higher in the northeastern U.S. relative to most other
parts of the country and extensive scientific data indicate that
mercury is pervasive in freshwater fish in the Northeast at levels that
pose health risks to people and some species offish eating wildlife.
According to a May 2002 New York Academy of Sciences report,
hospitals, dental facilities and laboratories account for 90% of the
mercury being discharged to the New York-New Jersey Harbor at
this time. In addition to mercury, hospitals are also generators of a
wide variety of hazardous wastes, (e.g., chemotherapy and
antineoplastic chemicals, solvents, epinephrine, and Pharmaceuticals)
and produce two million tons of solid waste which is 1% of the total
municipal solid waste in the U.S. Finally, random inspections at
hospitals in Region 2 and across the country as well as results of self-
audits being conducted by healthcare facilities under EPA's audit
policy indicate a pattern of noncompliance with environmental
requirements across much of the sector, especially in regards to the
management of hazardous waste. Many hospitals have only one
person in charge of all health, safety and environmental issues at the
hospital and it is very difficult for one person to manage all the
environmental aspects of a healthcare facility let alone the health and
safety issues as well.
Goals
In response to the above concerns, EPA Region 2 embarked upon a
healthcare initiative for the purposes of improving environmental
compliance and safety at main and off-site healthcare facilities;
changing the culture of the healthcare community to one in which
environmental compliance is a priority; promoting compliance of the
entire sector; not just those reached through inspections; and ensuring
continued compliance by implementing permanent changes such as
through the development of environmental management systems. We
also encouraged as part of our initiative that hospitals join Hospitals
for a Healthy environment, a voluntary program that is trying to
educate healthcare professionals about pollution prevention
opportunities in hospitals with the goal of reducing the environmental
footprint of the healthcare sector.
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ATTACHMENT D
Measures
Results
The success of our healthcare strategy was measured in the following
way:
Increased awareness among the healthcare community regarding
environmental requirements based on pre/post tests given at
seminars/workshops and a survey;
Increased number of healthcare facilities in Region 2
participating in Hospitals for a Healthy Environment;
Number of violations corrected by hospitals as a result of our
initiative as measured by case-conclusion data sheets (for both
enforcement actions and voluntary disclosures) and a survey.
Amount of pollution reduced as a result of our initiative as
measured by case-conclusion data sheets and a survey.
Number of pollution prevention and best management practices
undertaken by hospitals as a result of our initiative as measured
by a survey.
Environmental measures gathered for our approach to the healthcare
sector has proven effective in improving the compliance rate and
environmental footprint of healthcare facilities in our Region. For
instance, as a result of our initiative:
Between 60-65% of hospitals that participated in our workshops
increased their knowledge of environmental requirements (Note: R2
also used workshop surveys to measure increased knowledge of the
requirements which consistently provide results that show increases
greater than 95%. Due to the large disparity between these results,
R2 has chosen to use the measured results rather than the increase in
knowledge reported by the attendees);
So far, 57 hospitals/healthcare systems in NY and NJ have joined
the H2E Program and have pledged to eliminate mercury and reduce
the volume of waste they generate;
More than 2173 violations have been corrected of which 69%
were RCRA, 4% CWA, 7% EPCRA, 18% CAA, 1% TSCA and
0% SDWA;
At least 11,660 Ibs/year of hazardous waste, 80,930 gallons of oil
and 2100 pounds of chlorofluorocarbons are now being
appropriately managed; and
Approximately 341 residential units are now in compliance with
lead-based paint rules.
Tools Selected
EPA Region 2 set out to accomplish the above goals through a three-
prong strategy. First, we provided environmental assistance to
healthcare facilities to help them understand their environmental
obligations, identify P2 opportunities, and develop an EMS. This
assistance included holding 11 environmental compliance 101
workshops which gave a general overview of the various statutes that
applied to hospitals; conducting more than a dozen full-day hospital-
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ATTACHMENT D
specific hazardous waste identification and management workshops
since 60% of the violations uncovered at healthcare facilities
involved hazardous waste; sponsoring EMS tutorials and performing
environmental management reviews for federal hospitals which are
required to develop an EMS under Executive Order 13148; and
developing a healthcare website, a CD-ROM of healthcare
environmental assistance tools, RCRA decision diagrams, a poster of
RCRA generator requirements, a handbook of hazardous waste
management at hospitals and an EMS guide for healthcare facilities.
Second, we sent a letter to hospitals in December 2002 informing
them of our intent to target healthcare facilities for inspections and
enforcement and urging them to perform self-audits and to enter into
corporate-wide audit agreements under EPA's voluntary audit policy.
A model audit agreement was developed in order to reduce the time
needed for review and negotiation. So far, 37 hospitals/ hospital
systems have entered into audit agreements with EPA covering all
major federal environmental programs. These agreements included
the first ever audit agreement with the Veterans Healthcare
Administration which encompassed all the federal VA hospitals in
New York and New Jersey. To date, more than 1100 violations have
been corrected under our voluntary audit program and $9,739,076 in
potential penalties have been waived.
Finally, we conducted 44 inspections, and issued 24 enforcement
actions, 10 of which were complaints totaling $1,289,913 in penalties
under our healthcare compliance initiative. These inspections and
enforcement actions were done concurrently with the above
environmental assistance and compliance incentives activities.
Factors for Tool Selection
EPA Region 2 adopted this three-prong strategy for the following
reasons: 1) a well-publicized enforcement presence throughout the
initiative promoted accountability, encouraged facilities to take
advantage of the environmental assistance and compliance
incentives offered, and addressed serious threats to human health and
the environment as well as identifying and addressing recalcitrant
offenders; 2) environmental assistance increased the awareness and
knowledge of environmental regulations, pollution prevention
opportunities, and environmental management systems within the
healthcare sector and provided tools to help healthcare facilities come
into compliance and reduce their environmental footprint; and 3) the
use of the audit policy allowed us to reach more healthcare facilities
than we would have through inspections alone, resulted in permanent
compliance changes not just quick fixes and allowed us to target our
inspections toward those hospitals that, for whatever reason, were not
interested in voluntarily complying with environmental regulations.
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ATTACHMENT D
| Time Frame | 2002-2005
A. What is the environmental problem or issue and its significance for priority selection?
There are 480 hospitals (both private and public) in New York, New Jersey, Puerto Rico, and the
Virgin Islands. Given this large universe, EPA Region 2 did not have the resources to conduct
inspections at every hospital in the region. Particularly, considering that these are large
institutions with diverse operations and waste streams. A hospital may have, for example,
laboratories, operating rooms, pharmacies, radiological facilities, cafeterias, housekeeping and
laundry units, fleet maintenance facilities, boilers, medical waste incinerators, emergency
generators, grounds and landscaping facilities, underground or above ground oil and fuel storage
tanks, air conditioning and refrigeration equipment, morgues, lead-based paint, and asbestos. As
a result, they are regulated by a myriad of environmental statutes including the Resource
Conservation and Recovery Act, Clean Air Act, Clean Water Act, Safe Drinking Water Act, Oil
Pollution Act and the Emergency Planning and Community Right to Know Act, not to mention
the various state and local regulations that may be more stringent than the federal laws.
More importantly, the waste and emissions caused by these activities posed a significant risk to
human health and the environment if not controlled properly. Hospitals, for example, contribute
to the presence of toxic chemicals such as phthalates, mercury, and dioxin in the environment.
Mercury, in particular, is of great concern in the Northeast. Rates of mercury deposition are
estimated to be higher in the northeastern U.S. relative to most other parts of the country and
extensive scientific data indicate that mercury is pervasive in freshwater fish in the Northeast at
levels that pose health risks to people and some species offish eating wildlife. In New York, for
instance, the Department of Environmental Conservation's most recent fish advisories had 35
bodies of water contaminated with mercury throughout the state, and 10 with dioxin. In New
Jersey, there are 85 different fish advisories (many with 2-4 sub advisories by species offish) for
streams, creeks, parts of rivers, lakes and reservoirs for mercury alone. There are also dioxin,
chlordane and PCB advisories for various species in all of New Jersey's coastal waters.
According to a May 2002 New York Academy of Sciences report, hospitals, dental facilities and
laboratories account for 90% of the mercury being discharged to the New York-New Jersey
Harbor at this time.
In addition to mercury, hospitals are generators of a wide variety of hazardous wastes, such as
chemotherapy and antineoplastic chemicals, epinephrine, pharmaceuticals, solvents,
formaldehyde, photographic chemicals, radionuclides, and waste anesthetic gases. They also
produce 2 million tons of solid waste which is 1% of the total municipal solid waste in the
United States. Furthermore, medical facilities contribute to various air pollution problems
including smog, climate change, the depletion of the stratospheric ozone layer, and air toxics.
Finally, random inspections at hospitals in Region 2 and across the country as well as results of
self-audits being conducted by healthcare facilities under EPA's audit policy indicated a pattern
of noncompliance with environmental requirements across much of the sector. Many hospitals,
in fact, had only one person in charge of all health, safety and environmental issues at the
hospital and it was very difficult for one person to manage all the environmental aspects of a
healthcare facility let alone the health and safety issues as well. Sixty-percent of the violations
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ATTACHMENT D
discovered were related to hazardous waste management. Other violations involved spill
prevention, control, and countermeasure plans, air conditioning and refrigeration disposal and
repair, asbestos, Clean Air Act State Implementation Plans, lead paint disclosures for leased
housing, PCB management, drinking water, and Emergency Planning and Community Right to
Know Requirements.
B. What was the approach and methods used to baseline the environmental problem and
understand the target audience that was contributing to the problem?
EPA Region 2 used random inspections of hospitals and the establishment of healthcare focus
groups to baseline the environmental and compliance problems among hospitals and to
understand the target audience that was contributing to the problem.
C Identify each tool (e.g. CM, Enf, CA, CI, EMS, P2, and Sustainability) that was selected
to address the environmental problem(s) and the factors considered to use that tool?
EPA Region 2 used all the tools at its disposal to improve the compliance and environmental
footprint within the healthcare sector for the following reasons:
Compliance Monitoring/Enforcement: A well-publicized enforcement presence throughout the
initiative promoted accountability, encouraged facilities to take advantage of the environmental
assistance and compliance incentives offered, and addressed serious threats to human health and
the environment as well as recalcitrant offenders.
Environmental Assistance: Environmental assistance increased the awareness and knowledge of
environmental regulations, pollution prevention opportunities, and environmental management
systems within the healthcare sector and provided tools to help healthcare facilities come into
compliance and reduce their environmental footprint. Please note the use of the term
environmental assistance instead of compliance assistance. When EPA Region 2 conducts
workshops, and develops guides, fact sheets, and websites, we include information on pollution
prevention, environmental management systems, and Sustainability along with regulatory
information because we believe these other tools promote long-term compliance. If a hospital
eliminates mercury from its hospital, for instance, then the hospital does not need to worry about
the hazardous waste, air, and water regulations associated with mercury.
Compliance Incentives: The promotion of voluntary audits and corporate-wide audit agreements
under EPA's audit policy allowed us to reach more healthcare facilities than we would have
through inspections alone, resulted in permanent compliance changes not just quick fixes and
allowed us to target our inspections toward those hospitals that, for whatever reason, were not
interested in voluntarily complying with environmental regulations.
D. Where more than one tool was selected to address the environmental problem discuss
the relationship between the tools and the factors considered in sequencing and
segmentation?
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ATTACHMENT D
EPA Region 2 used environmental assistance, compliance incentives, compliance monitoring,
and enforcement concurrently throughout our initiative. There was no waiting period prior to
enforcement. This was a lesson-learned from our college and university initiative where we told
academic institutions that they had a year before enforcement would start believing that would
give them time to take advantage of the environmental assistance and compliance incentives
offered prior to inspectors going out in the field. However, we found out that some colleges,
instead of trying to come into compliance during this year grace period, actually cut their
environmental budget when they knew we would not be inspecting them for a year.
Also, by using all the tools concurrently we were able to take advantage of information gathered
from each aspect of our initiative to improve the cost-effectiveness of the other elements. For
example, it was through inspections and audit disclosures that we learned that 60% of the
violations at healthcare facilities were related to hazardous waste which prompted us to develop
the first-ever healthcare-specific workshop on hazardous waste identification and management
that has been widely acclaimed among healthcare facilities nationwide. Also, regional
enforcement personal can better target their healthcare inspections by taking into account the
hospitals that are participating in our voluntary audit program.
E. Describe any changes from the initial strategy during implementation and factors
contributing to those change(s)?
EPA Region 2 developed a strategy that was designed to be flexible and adaptable. We have
learned through previous compliance initiatives that the strategy is a living document that needs
to be modified several times during implementation to take into account unanticipated
situations, changes in rules or policies, changes in emphasis based upon compliance findings,
etc. For this initiative, the changes that we made mainly concerned the level of outreach that
was needed to address RCRA violations (i.e., development of full-day RCRA Waste
Identification Workshop and associated tools, and adding more seminars than anticipated) and
in
increasing the emphasis on certain hospital wastes (e.g., chemotherapy wastes, universal wastes,
pharmaceutical wastes, waste epinephrine, etc.) and certain waste management practices (e.g.,
handling of universal wastes, chemo wastes, bulb crushing operations, and non-mercury
alternatives for devices other than temperature and blood pressure measurement.)
F. What were the goals of the strategy and the measures that addressed them? What were
the results of this approach?
EPA Region 2's healthcare compliance initiative was undertaken for the purposes of improving
environmental compliance and safety at main and off-site healthcare facilities; changing the
culture of the healthcare community to one in which environmental compliance is a priority;
promoting compliance of the entire sector; not just those reached through inspections; and
ensuring continued compliance by implementing permanent changes such as through the
development of environmental management systems. We also encouraged as part of our
initiative that hospitals join Hospitals for a Healthy environment, a voluntary program that is
trying to educate healthcare professionals about pollution prevention opportunities in hospitals
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ATTACHMENT D
with the goal of reducing the environmental footprint of the healthcare sector.
The success of our healthcare strategy was measured in the following way:
Increased awareness among the healthcare community regarding environmental requirements
based on pre/post tests given at seminars/workshops and a survey;
Increased number of healthcare facilities in Region 2 participating in Hospitals for a Healthy
Environment;
Number of violations corrected by hospitals as a result of our initiative as measured by case-
conclusion data sheets and a survey.
Amount of pollution reduced as a result of our initiative as measured by case-conclusion data
sheets and a survey.
Number of pollution prevention and best management practices undertaken by hospitals as a
result of our initiative as measured by a survey.
Although we are still awaiting responses from our survey that we sent out to all the hospitals in
New York, New Jersey, and the Caribbean, the environmental measures we have gathered so far
show that our approach to the healthcare sector has proven effective in improving the
compliance rate and environmental footprint of healthcare facilities in our Region. For instance,
as a result of our initiative:
Between 60-65% of hospitals that participated in our workshops increased their knowledge
of environmental requirements;
So far, 57 hospitals/healthcare systems in NY and NJ have joined the H2E Program and have
pledged to eliminate mercury and reduce the volume of the waste they generate.
More than 1100 violations have been corrected of which 60% were RCRA, 17% CWA, 12%
EPCRA, 7% CAA, 3% TSCA and 1% SDWA;
At least 11,660 Ibs/year of hazardous waste, 80,930 gallons of oil and 2100 pounds of
chlorofluorocarbons are now being appropriately managed; and
Approximately 341 residential units are now in compliance with lead-based paint rules.
G. Describe the mechanisms used to communicate the strategy to internal (EPA managers
and staff) and external (partners in implementing strategy, targeted audience and
public) stakeholders.
EPA Region 2's healthcare compliance initiative would not have been successful without
coordination and communication both internally within EPA Region 2 as well as externally with
other EPA offices and Regions, hospital associations, state/local environmental and health
agencies and other federal government agencies. Internal communication was accomplished
through the R2's Multimedia Enforcement Team (MET - an ad hoc group of senior enforcement
staff in various media programs that provides support to senior managers), the R2 Multi Program
Enforcement Steering Committee (MPESC - a group of enforcement program branch chiefs and
others that coordinate multimedia inspection and enforcement activities), the R2 Pollution
Prevention Council (R2P2C - a multi-Divisional workgroup that advises regional management
of issues related to pollution prevention, sustainability, and outreach), and the Regional LAN.
Communication with other EPA offices and Regions was accomplished through the monthly
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ATTACHMENT D
pollution prevention, federal facility, and compliance assistance conference calls and through E-
mail as needed. As for our external stakeholders, we developed a healthcare focus group in New
York State which included representatives from state/local environment and health
organizations, trade associations, and major NY hospitals. We also participated in conference
calls/meetings with Hospital for a Healthy Environment and the Veterans Health Administration
and with a national workgroup for issues related to EMS development for hospitals. We also
awarded a grant to H2E to work with NYC hospitals to promote compliance, mercury
elimination, and pollution prevention, and sent a number of mailings and emails to hospitals in
the region to provide compliance assistance and regulatory updates. Finally, we asked for
feedback on our workshop evaluation forms and tracked the requests for information that we
received for additional explanations of various regulations and practices.
H. Identify and discuss the resources and deployment of resources used to develop and
implement the strategy. Address the impact of deploying resources on this priority
with regard to other priorities
This initiative required 4.0 FTEs in resources internally each year from Region 2 in order to
conduct the necessary environmental assistance and enforcement. We also needed the help of
external stakeholders such as hospital associations and other government agencies. Moreover,
we used federal facility, pollution prevention, environmental priority, and compliance assistance
extramural funds as needed and available to develop tools and hold workshops. The deployment
of these resources on this priority did not greatly affect any national priorities or other regional
priorities since resources were reassigned accordingly. It, however, did impact to some extent a
few core programs. However, Region 2 believes that the environmental results gained from this
initiative far outweigh any losses in the core program. We would not have achieved such an
improvement in the compliance rate and the environmental footprint within the healthcare sector
if we had relied on our traditional compliance and enforcement techniques.
I. What steps were taken to monitor and evaluate the strategy's progress?
Although the ultimate success of our healthcare strategy was determined by the outcome
measures listed in Section F above, EPA Region 2 throughout the initiative looked at various
output measures (e.g. # of inspections, enforcement actions, penalties, workshops, compliance
assistance tools developed, audit agreements, disclosures, entities reached through compliance
assistance, etc) to assess the strategy's progress. We also evaluated any feedback we received
from our external stakeholders through workshop evaluations, meetings, conference calls, and
focus groups to ascertain if we were on the right track in achieving our goals.
J. What factors or situational changes occurred during implementation of the strategy to
justify exiting or continuing/expanding?
EPA Region 2 believes that the majority of the healthcare facilities in NY, NJ, PR, and the VI
have been given ample opportunity to participate in our workshops and our voluntary audit
program. Furthermore, of the 480 hospitals in Region 2, % are either conducting their own
self audits or have been inspected. Thus, we have decided to put healthcare facilities back into
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ATTACHMENT D
the core program. As such, we will continue to conduct random inspections of hospitals, answer
any regulatory questions that hospitals may have, maintain our healthcare website, and process
any audit disclosures that are received. However, we will not be holding any more workshops,
developing new tools, or actively promoting the audit program.
K. Discuss any barriers/challenges in developing or implementing the strategy and
opportunities for addressing them in the future.
The major barrier to this initiative was the lack of environmental data on hospitals in the
enforcement databases when we started. Very few inspections had been conducted at hospitals
and thus, little was known about the compliance status of healthcare facilities at that time. Many
at EPA, particularly Headquarters, are leery about starting compliance initiatives or even doing
inspections in sectors that have never been targeted before. This led to much push back from
EPA management in Headquarters. However, Regional management was willing, giving the
limited data we had ascertained, to take a chance and target our limited compliance assistance
and enforcement resources at hospitals. As you can see from our results, this risk taking on the
part of Regional management paid off and several other Regions, seeing the results obtained by
Region 2, are now seriously considering starting healthcare initiatives themselves. Another
major barrier was the lack of clear, understandable compliance assistance information that
healthcare facilities could use to identify the regulatory requirements that applied to them and to
determine their compliance status. During the initiative, R2 developed or helped to develop
many tools to assist healthcare facilities with these tasks including: the Healthcare
Environmental Resource Center, the sector notebook, an EMS guide for healthcare facilities,
many presentations and workshop materials, and a CD/ROM that contains all of these resources
and links to additional information (e.g., pollution prevention and green building information for
healthcare facilities.) The last major barrier was the lack of experienced staff in both the
compliance assistance and the compliance monitoring and enforcement staff related to hospital
operations (e.g., typical hospital waste streams and waste generating processes, alternatives to
hazardous components, health and safety concerns, etc.)
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United States
Environmental Protection
Agency
Office of Enforcement
and Compliance
Assurance(2248A)
EPA300-N-03-001
&EPA Enforcement Alert
Volume 6, Number 1
Office of Regulatory Enforcement
March 2003
EPA Strategically Addressing Raw Sewage Discharges
Across Nation to Protect Public, Environment
EPA Reaches Settlements with Baltimore,
Other Municipalities to Stop Sewage
Overflows, Overhaul Sewer Systems
Sanitary sewer systems that are
properly designed, operated, and
maintained, collect and transport all of
About
Enforcement Alert
Enforcement Alert is published
periodically by the EPA's Office of
Regulatory Enforcement, Office of
Enforcement and Compliance
Assurance to inform and educate
the publicand regulated community
of important environmental
enforcement issues, recenttrends
and significant enforcement
actions.
This information should help the
regulated community anticipate
and prevent violations of federal
environmental law that could
otherwise lead to enforcement
action. Reproduction and wide
dissemination of this publication
are encouraged. For information
on how you can receive this
newsletter electronically, send an
email to the editor.
Director, Office of Regulatory
Enforcement: Walker B. Smith
Editor: Virginia Bueno
bueno.virginia@epa.gov
the sewage and indus-
trial wastewater that
flow into them to a
publicly owned treat-
ment works (POTW)
for appropriate treat-
ment before being dis-
charged into our
nation's rivers,
streams, and other water bodies. How-
ever, when sanitary sewer systems are
not maintained, or lack adequate ca-
pacity, discharges of raw sewage and
industrial wastewater can occur with-
out receiving appropriate treatment. In
some systems, these sanitary sewer dis-
charges occur on a regular basis.
These discharges, called sanitary
sewer overflows (SSOs), occur when
there is an overflow, spill, or release of
raw or partially-treated sewage from a
sanitary sewer collection system be-
fore it reaches a
sewage treatment
plant. Such releases
regularly contami-
nate our nation's
waters, degrade
water quality, and
expose humans to
pathogens and vi-
ruses that can
cause serious ill-
ness. In addition,
these discharges can occur as base-
ment backups, causing property dam-
age and further threatening public
One of EPA's ongoing
enforcement priorities is
to identify and correct
these raw sewage
discharges to protect
public health and the
environment.
Some sanitary sewer overflows can
occur at deteriorated manholes.
(Photo courtesy of the Orange
County Sanitation District.)
health. EPA estimates that there are
20,000 separate sanitary sewer sys-
tems, and thousands of overflows oc-
cur each year.
Section 301 of the Clean Water Act
prohibits the discharge of any pollutant
to waters of the United States from a
point source, unless the discharge is au-
thorized by a permit. Limits in permits
for discharges from
publicly owned treat-
ment works must
meet technology-
based effluent limita-
tions based upon sec-
ondary treatment, and
any, more stringent
limits to meet water
quality standards. In
addition, permits re-
quire proper operation
and maintenance for sewage collection
systems and treatment facilities, for
-------
Enforcement Alert
example, to ensure continued system
integrity and prevention of unauthorized
overflows of untreated wastewater.
Sanitary sewer overflows are pro-
hibited as unpermitted discharges, and
when they are prohibited in a permit.
Given the seriousness of the problem
in many major municipalities, one of
EPA's ongoing enforcement priorities is
to identify and correct these raw sew-
age discharges to protect public health
and the environment.
SSOs Endanger Public
Health and the Environment
People can be exposed to raw sew-
age through recreational contact such
as swimming and fishing, in their homes
and neighborhoods because of basement
or street flooding, and through drink-
ing contaminated water. Contact with
raw sewage exposes people to a vari-
ety of pathogenic microogranisms, vi-
ruses, and intestinal worms that can
cause serious illnesses such as chol-
era, dysentery, infectious hepatitis, and
gastroenteritis. Sensitive populations
children, the elderly, and those with
weakened immune systemsare at a
higher risk of illness.
Beach closures and recreational
water warnings are designed to limit the
human health impacts of bacteria and
pathogens present in water, whether
from SSOs, stormwater, or urban run-
off.
Sanitary sewer overflows degrade
the environment by polluting our wa-
terways, adversely affecting fish and
other wildlife species. For example,
sewage can cause the explosion of al-
gal growth, depleting oxygen in the
water and killing fish. Raw sewage dis-
charges cause property damage and
public health problems when overflows
flood homes and businesses that sub-
sequently require cleanup, large scale
disinfection, and the replacement of
rugs, furniture, wallboard panels, and
flooring. Raw sewage discharges also
can lead to a drop in tourism and eco-
nomic loss from beach closures and
shellfish and fishing restrictions.
Why SSOs Occur
Separate sanitary collection systems
are intended to collect sewage that flows
into them, and transport those flows
for treatment. Municipalities must evalu-
ate their collection systems to identify
the causes of SSOs so that they can be
anticipated and stopped before they
harm public health and the environment.
Chronic SSOs can be the result of
excessive amounts of rainfall or snow-
melt seeping through the ground and
overwhelming leaky sewers (infiltra-
tion), and excess rainwater feeding into
sewers through illegally-connected roof
drains, or basement sump pumps (in-
flow). In addition, municipalities with
poor operation and maintenance pro-
grams may experience SSOs as a re-
sult of system deterioration. Pipes can,
and often do, settle and crack, and need
repair and replacement on a regular
schedule. Sediment, grease, and other
debris can build up and cause pipes to
plug, break, and collapse. SSOs also
may be caused by a lack of system ca-
pacity to collect, store, and/or convey
flows for treatment.
To Eliminate SSOs, EPA
Uses Mix of Compliance,
Enforcement Tools
EPA's compliance goal is to elimi-
nate SSOs from municipal collection
systems and to ensure that sanitary
When sanitary sewer systems are not maintained, or
lack adequate capacity, discharges of raw sewage and
industrial wastewater can occur and potentially en-
danger the public and environment. (U.S. EPA photo-
graphs.)
March 2003 ^^^^^^^^^^^^^^^^
-------
Enforcement Alert
wastewater is being conveyed to treat-
ment plants for treatment in accordance
with the requirements of the Clean Wa-
ter Act. EPA uses a variety of compli-
ance and enforcement tools to achieve
environmental and human health im-
provements, including enforcement ac-
tions, compliance assistance, and com-
pliance incentives.
Enforcement
To date, EPA's enforcement actions
have resulted in the elimination of bil-
lions of gallons of raw sewage dis-
charges and the assessment of signifi-
cant penalties. States also have joined
EPA as co-plaintiffs in many lawsuits.
In these enforcement actions, EPA
typically places municipalities under a
compliance schedule that is as expedi-
tious as practical (up to 15 years) to
address deficiencies in their systems.
Under settlement agreements, munici-
palities must assess their systems to
understand the scope of the problem,
then create a plan to improve, update,
and repair their wastewater collection
system. These municipalities also are
usually required to develop and imple-
ment effective operation and mainte-
nance programs.
Baltimore Settlement
On Sept. 30, 2002, a consent de-
cree implementing a significant settle-
ment with Baltimore to eliminate unper-
mitted discharges of raw sewage from
the city's sanitary waste collection sys-
tem was entered in federal court. All of
the waterbodies affected by these dis-
charges fail to meet permit effluent lim-
its based on Maryland's water quality
standards for total coliform, an indica-
tor of disease-carrying pathogens.
Baltimore owns and operates two
sewage treatment plants and 1,312 miles
of collection system that transport
wastewater to the plants. The plants
>Os One Cause of
Beach Closings
A gencies participating in EPA's
/^annual beach survey reported
that of the 2,445 beaches reported
in 2001, 672 were affected by ad-
visories or closings, most often
due to elevated bacteria levels.
Sanitary sewer overflows were
identified as one of the sources of
pollution that resulted in these ad-
visories or closings. The number
of such beach advisories and clo-
sures reported every year is on the
rise.
Municipalities must strive to
eliminate the discharges, which
often can lead to serious illness
and disease. People who swim
near storm drains or off beaches
polluted by sewage can become
ill with fever, nausea, gastroenteri-
tis, and flu-like symptoms, or more
serious diseases.
serve a population of approximately 1.8
million people. The anticipated reduc-
tion in raw sewage discharges attribut-
able to this settlement is more than 30
million gallons a year.
The settlement requires Baltimore to
implement injunctive relief valued at ap-
proximately $940 million over the next
14 years. The City will spend more than
$260 million to eliminate 54 sanitary
sewer structures, increase the capac-
ity of the collection system associated
with these structures, and completely
separate the combined portion (where
sanitary wastewater and storm water
are conveyed through a single pipe for
treatment) of the system.
The City also will undertake a com-
prehensive, systematic investigation of
its entire collection system, and imple-
ment and complete action plans to rem-
edy problems identified during the in-
vestigation. Baltimore plans to install and
maintain a computerized collection and
transmission system model to evaluate
the impact of various remedial action
projects on the transmission capacity
and performance of the collection sys-
tem. The City also will undertake a sig-
nificant construction program to repair
and rehabilitate pumping stations.
Baltimore also agreed to spend sig-
nificant additional funds to identify and
enforce against illegal sewer connec-
tions, implement an information man-
agement system program, develop and
implement an emergency response plan
for unpermitted discharges, improve the
operation and maintenance program for
the collection system, and report all un-
permitted discharge events.
Finally, Baltimore agreed to pay a
civil penalty of $600,000, and imple-
ment a supplemental environmental
project estimated at $2.72 million de-
signed to remove nitrogen from waste-
water and improve water quality in the
Chesapeake Bay.
Other Recent Settlements
An agreement reached with Baton
Rouge and East Baton Rouge, La., will
reduce discharges of untreated sewage
to public areas and U.S. waters by more
than 1.2 billion gallons annually. Baton
Rouge and East Baton Rouge paid a
$729,500 penalty and are spending up
to $461 million on selecting and imple-
menting a comprehensive collection
system improvement plan.
Also, a recent agreement with To-
ledo, Ohio, which has both a combined
and a separate sanitary sewer system,
will eliminate roughly 800 million gal-
lons of untreated sewage annually.
As part of case settlements such as
these, EPA also encourages municipali-
ties to perform supplemental environ-
mental projects to help lessen the envi-
ronmental impacts of their violations
and secure additional environmental ben-
March 2003
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6ERA
United States
Environmental Protection Agency
Office of Regulatory Enforcement
(2248A)
Washington, D.C. 20460
Official Business
Penalty for Private Use $300
'Enforcement Alert' newsletter
efits. For example, Baltimore will de-
sign a $2.7 million biological nutrient
reduction facility at its treatment plant
to remove nitrogen from wastewater.
Under a settlement with the Water
and Sewer Board of Mobile, Ala., the
Board agreed to spend $2.5 million to
purchase and preserve valuable habitat
in Mobile County and the Dog River
watershed, repair private residential ser-
vice laterals in low-income areas, and
partially fund a database of water qual-
ity monitoring data that is available to
the public.
Compliance Assistance
EPA provides guidance, training,
compliance assistance, and other tech-
nical and financial assistance tools to
state and local agency personnel. EPA's
regional offices lead these efforts, con-
ducting training and workshops, par-
ticipating in workshops, and conduct-
ing site visits to assess municipalities'
progress in improving the capacity,
management, operation, and mainte-
nance (CMOM) of their sewage col-
lection systems to eliminate and pre-
vent SSOs.
Municipal officials looking for SSO-
related information will find a wealth
of regulatory, technical, and financial
assistance on a number of EPA
websites. For example, on the Office
of Water's website at www.epa.gov/
npdes/sso, EPA offers fact sheets on
financing capital improvements for SSO
abatement and implementing an asset
management approach. Links to guides
for operating and managing sewage col-
lection systems and developing sanitary
sewer overflow response plans are also
included. Users also will soon have
online access to the Office of Water's
CMOM self-assessment checklist.
For more information about sani-
tary sewer overflows, see websites in
"Useful Compliance Resources" col-
umn at right.
For information regarding cases
discussed in this Enforcement Alert,
contact Amanda A. Gibson, (202) 564-
4239, Email: gibson.amanda@epa.gov,
or Kevin Bell (202) 564-4027, Email:
bell.kevin@epa.gov, Water Enforce-
ment Division, Office of Regulatory
Enforcement, Office of Enforcement
and Compliance Assurance.
For compliance assistance infor-
mation, contact Sharie Centilla, (202)
564-0697, Email: centilla.sharie@epa.gov,
or Walter Brodtman,(202) 564-4181,
Email: brodtman.walter@epa.gov, Office
of Compliance, Office of Enforcement
and Compliance Assurance.
Useful Corrmliance
Assistance Resources
Office of Enforcement and
Compliance Assurance:
http://www.epa.gov/compliance
Office of Water:
http://www.epa.gov/npdes/sso
Local Government Environmental
Assistance Network:
http://www.lgean.org
National Small Flows Clearing-
house (aids small communities
with wastewater problems):
http://www.nesc.wvu.edu/nsfc
Region 4 POTW Management,
Operation and Maintenance
Program (MOM):
http://www.epa.gov/region04/water/
wpeb/momproject/index.html
National Compliance Assistance
Clearinghouse:
http://www.epa.gov/clearinghouse
Compliance Assistance Centers:
http://www.assistancecenters.net
Small Business Gateway:
http://www.epa.gov/smallbusiness
EPA's Audit Policy:
http://oecaftp.sdc-moses.com/
compliance/incentives/auditing/
auditpolicy.html
f Recycled/Recyclable. Printed with Soy/Canola Ink on paper that contains at least 30% recycled fiber
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ATTACHMENT E
EVALUATION OF OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE
FRAMEWORK FOR A PROBLEM-BASED APPROACH
TO INTEGRATED STRATEGIES (Final, 11/25/02)
and
GUIDE TO IMPLEMENTING THE INTEGRATED STRATEGIES FRAMEWORK'
(Interim Draft, June 2003)
Part A. Framework Work for a Problem-based Approach to Integrated Strategies (IS) (Final,
11/25/02)
Objective: The purpose of these questions is to evaluate whether the Framework for a Problem-based Approach to
Integrated Strategies, (Framework) issued 11/25/02, meets its goal of "encouraging pro-active consideration of the
elements of an integrated strategy; including 1) data gathering to further define the problem and universe and develop
compliance baselines, 2) tool selection and sequencing to effectively address the environmental problems (s), 3) up
front development of measures to assess progress and outcomes and 4) communication with stakeholders, partners
and the public.
1. In what capacity did you receive a copy of the Framework? Please select your primary position:
EPA Regions
Q Regional IS Project Leader
Q Regional IS Project Contributor
Q Regional Compliance Assistance Coordinator
Q Regional Enforcement Program Manager
Q Regional Compliance Assurance Manager
a Other
EPA Headquarters (HQ)
Q HQ Project Leader
Q HQ project contributor
Q HQ Program Manager
Q HQ Compliance Assurance Manager
Q Other
Yes
No
Not Certain
2. Have you read the entire Framework?
3. Is the Framework easy to understand?
4. Do you understand what the term "integrated strategy" means?
5. Have you used the Framework to plan, design or develop an integrated strategy
pilot project or other project?
6. Which elements of the Framework did you use? (Select all that apply.)
cs= None (If you choose "None," do not select any other option below; continue
to question 7.)
Elements of Framework Methodology
Q 1) Define the environmental problem, the universe or develop a compliance
baseline?
cs= 2) Consider all compliance assurance and enforcement tools available to
address the problem?
Q 3) Select and sequence tools to effectively address the environmental
problem(s)
Q 4) Develop measures to assess progress and outcomes?
Q 5) Define and acquire resources needed to implement the approach?
cs5 6) Create an implementation schedule?
Q 7) Define roles and responsibilities of involved stakeholders?
Q 8) Create an effective communications strategy with all stakeholders?
Q 9) Create a means of monitoring and evaluating progress through all stages
of the strategy?
Rating of Elements
Somewhat Not
Helpful Helpful
NA
7. Would you recommend to a colleague that s/he read and use the Framework?
Yes
No
Not
Certain
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8. Please comment on the Framework as follows:
a) Were the questions under each element of the Framework useful to you in developing that part of the
strategy?
b) Can you suggest additional questions or points to consider under each element?
9. Please provide your comments and suggestions to improve the Framework, e.g. additions, deletions,
corrections. Please be as specific as possible.
10. How would you assess the overall effectiveness/ usefulness of the Framework in developing and
implementing an Integrated Strategy Pilot Project?
Part B. Guide for Implementing the Integrated Strategies Framework (IS Guide) (Interim draft, June 2003)
Objective: The IS Guide has been developed to provide further assistance in planning for and piloting the initial
group of eight regional integrated strategies. The purpose of the following questions is to evaluate whether the
supplemental guidance meets the purposes stated: 1 ) ensure consistency in the planning, evaluation, and
measurement of outcomes processes across the IS pilots; 2) identify and explain expectations for the IS pilots; 3)
elaborate on and provide examples to illustrate select sections of the Framework', and 4) help document the decision-
making process used in selecting tools to address environmental problems (knowledge management).
Yes No Not Certain
2. Have you read the IS Guide 1
3. Is the IS Guide easy to understand?
4. Have you used the IS Guide to plan, design or develop an integrated strategy pilot
project or other project?
5. Which elements of the IS Guide did you use? (Select all that apply.)
cs5 None (If you choose "None," do not select any other option below; continue
to question 6.)
Rating of Elements
Elements of IS Guide Methodology Very Somewhat Not
Helpful Helpful Helpful NA
Q 1) Develop measures to assess progress and outcomes?
cs= 2) Consider factors listed for selection, sequencing and segmentation of
compliance assurance and enforcement tools available to address the
problem?
Q 3) Define and acquire resources needed to implement the approach?
cs5 4) Create an effective communications plan with all stakeholders?
Q 5) Create a means of monitoring and evaluating progress through all stages
of the strategy?
6. Would you recommend to a colleague that s/he read and use the IS Guide? Yes No Not
Certain
7. Please comment on the IS Guide as follows:
a) Were the questions under each element of the IS Guide useful to you in developing that part of the strategy?
b) Can you suggest additional questions or points to consider under each element?
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8. Please provide your comments and suggestions to improve the IS Guide, e.g. additions, deletions, corrections.
Please be as specific as possible.
9. How would you assess the overall effectiveness/usefulness of the IS Guide in developing and implementing an
Integrated Strategy Pilot Project?
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