AN APPROACH TO
ENVIRONMENTAL ORGANIZATION
CHANGE ANDMANPOWER
PLANNING IN THE STATE OF OHIO
U.S. ENVIRONMENTAL PROTECTION AGENCY
CHICAGO, ILLINOIS 60606
September 1972
STANFORD RESEARCH INSTITUTE
Menlo Park, California 94025 • U.S.A.
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Menlo Park, California 94025 • U.S.A.
September 1972
AN APPROACH TO
ENVIRONMENTAL ORGANIZATION
CHANGE AND MANPOWER
PLANNING IN THE STATE OF OHIO
By: DAVID ACKERMAN
ALFRED BOYD
RICHARD DAVIS
RICHARD SCHMIDT
WARD STONEMAN
Prepared for:
U.S. ENVIRONMENTAL PROTECTION AGENCY
ONE NORTH WACKER DRIVE
CHICAGO, ILLINOIS 60606
CONTRACT 68-01-0174
SRI Project MSD-1738
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EPA Review Notice
This report has been reviewed by the Environmental Protection Agency
and approved for publication. Approval does not signify that the
contents necessarily reflect the views and policies of the Environmental
Protection Agency, nor does mention of trade names or commercial products
constitute endorsement or recommendation for use.
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION V
1 NORTH WACKER DRIVE
CHICAGO, ILLINOIS 6O6O6
Honorable John J. Gilligan
Governor of the State of Ohio
State Capitol
Columbus, Ohio 43215
Dear Governor Gilligan:
I am enclosing a copy of the final report entitled "An Approach
To Environmental Organization Change And Manpower Planning In
The State Of Ohio", prepared by the Stanford Research Institute,
for your consideration. It has been a pleasure, and is a source
of satisfaction to us in the Environmental Protection Agency, to
have been in the position to provide this form of assistance to
the State of Ohio.
We believe that the SRI study and this resultant report have been
highly successful in fulfilling the mandate which the State of
Ohio - USEPA Project Advisory Group conveyed to SRI; namely,
that this study complement the study effort of your Citizens Task
Force On Environmental Protection. The conclusions and recom-
mendations of the SRI study team represent a culmination of
considerable and thorough effort on their part, and meaningful
participation and deliberation on the part of many State of Ohio
and Federal officials and staff members.
This,study is the first environmentally - integrated approach to
organizational management and manpower planning to be attempted
and accomplished as a joint State - Federal cooperative effort.
I feel that through sincere, cooperative efforts of this character,
attainment of the quality of life concept for all of our citizenry
is not unrealistic, but truly within our capability at all levels
of community and inter community bonded society. The study pre-
sented an opportunity for designing an effective organization
structure that could address itself in a meaningful and efficient
manner to accomplishment of Ohio's balanced goals to attain a
healthy and desirable environment. Passage and enactment of
comprehensive environmental protection legislation including the
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- 2 -
creation of the Ohio EPA has certainly provided an initial
meaningful framework toward these ends. The Report provides
a blueprint for effecting many of the institutional changes
and identification of commitments that will be necessary to
assure pursuit of successful courses of action in accomplishing
your meaningful goals. We feel that Stanford Research Institute,
and in particular Dr. David Ackerman, Study Project Manager/
deserve our compliments and gratitude for performing a very
challenging assignment in a very capable manner.
Please accept this Report with our best wishes for your future
success in designing and accomplishing a meaningful and well
articulated environmental protection program.
Sincerely,
Francis T. Mayo'
Regional Administrate^/
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STANFORD RESEARCH INSTITUTE
MENLO PARK. CALIFORNIA 94025
(415) 326-6200
Mr. Francis T. Mayo
Regional Administrator, Region V
Environmental Protection Agency
1 North Wacker Drive
Chicago, Illinois 60103
Dear Mr. Mayo:
Stanford Research Institute is pleased to present to you the
findings and recommendations that resulted from the study conducted
in the State of Ohio under Contract #68-01-0174. The report is en-
titled "An Approach to Organizational Change and Manpower Planning."
We believe that the environmental protection organization recommended
in this study will provide the State of Ohio with a positive means
for effectively coping with the State's environmental problems.
In order to be effective, such an organization must be capable
of dealing constructively with rapid changes in technology, legis-
lation, and strategies for accomplishing environmental objectives and
goals. Therefore, an important element in our design was the inclu-
sion of an organizational means for accomplishing the orderly change
necessary to meet public expectations regarding environmental issues.
We believe that this study may also prove to be of value in aiding
other states to address similar problems.
We would also like to express our appreciation for the consid-
erable help that your office provided to the SRI project team. The
State of Ohio was very receptive and helpful in all aspects of the
study. Without the close cooperation of the State of Ohio and the
Federal EPA, this study would have been considerably more difficult
to accomplish. We gratefully acknowledge the substantive contribu-
tions made by the many individuals from both organizations who par-
ticipated in this effort, but we must also point out that the findings
presented in this report represent the independent assessment of the
SRI project team.
S incerely,
David Ackerman
DA:w Project Leader
CABLE: STANRES. MENLO PARK / TWX 910-373-1246
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CONTENTS
LETTER
iii
LETTER FROM SRI PROJECT LEADER TO ENVIRONMENTAL
PROTECTION AGENCY v
LIST OF ILLUSTRATIONS ix
LIST OF TABLES xi
I INTRODUCTION 1
II EXECUTIVE SUMMARY 5
Finding 1 5
Recommendation 1 6
Finding 2 6
Recommendation 2 6
Finding 3 6
Recommendation 3 7
Finding 4 7
Recommendation 4 7
Finding 5 8
Recommendation 5 8
Finding 6 9
Recommendation 6 9
III CRITICAL ISSUES 11
Quality of Life 11
Superstructure 13
The Scope of the Environmental Organization 14
Public Participation 18
Pending Federal Legislation 19
IV ORGANIZATION DESIGN 21
Introduction 21
Criteria for Organizational Design 22
Strategic Planning Concept 24
Alternative Organizational Concepts 26
vii
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V ANALYSIS OF PRESENT ORGANIZATION 33
Present Organizations 33
Functional Analysis 36
Findings and Recommendations 40
VI THE NEW ORGANIZATION CONCEPT 51
Goals and Objectives 51
The New Organization Structure 54
Manpower and Staffing Requirements 80
Testing the Organization Design 85
VII IMPLEMENTATION 93
Organizational Work Group 94
Priorities 95
Implementation Process Design Factors 96
Organizational Relocation 97
Schedule 101
viii
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ILLUSTRATIONS
1 Organization Based on Resource Categories—I 27
2 Organization Based on Resource Categories—II 29
3 Functional Organization 30
4 The Macro-Structure ... 33
5 Department of Natural Resources 34
6 Department of Health 35
7 Positions for Department of Health as of February 1972 ... 38
8 Positions for Department of Natural Resources
as of February 1972 39
9 Data Support System File Structure ". 49
10 Recommended Organization 56
11 Strategic Planning Organizational Scheme 57
12 Public Interest Center 59
13 Program Monitoring Organization 62
14 Information and Procedures Organization 63
15 Surveillance Organization 63
16 Technical Services Organization 67
17 Finance and Administration Organization 68
18 Four District Offices 69
19 Intergovernmental Organization 71
20 State/Local Administration Section—State Agencies „..
21 State/Local Administration Section—Local Governments ... 72
22 State/Federal Administration Section 72
23 Interstate/International Coordination Section 73
24 General Interrelationships 73
25 Authorization and Compliance Organization 79
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26 Source Inventory Registration ... 86
27 Authorization to Construct or Modify 88
28 Permit to Operate 89
29 Source Surveillance and Compliance 90
30 Schematic of Reorganization by Present Units 99
31 Task Reassignment Matrix 100
32 Tentative Schedule \ 102
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TABLES
1 Present Positions for Department of Health and Department
of Natural Resources 37
2 Staff Estimates 83
3 Staff Position Analysis 84
XI
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I INTRODUCTION
Ohio's environment is a matter of intense public concern. Public
attention is addressed to problems of pollution of air and water, treat-
ment and disposal of wastes, and management or conservation of essential
resources. Although environmental problems occurring in Ohio are similar
to those present in other parts of the nation, Ohio's large population
and high degree of industrial, municipal, and agricultural development
accentuate these problems and underscore the need for a coordinated
approach directed toward achieving environmental quality goals. The
promixity of diverse activities in Ohio leads to complex interrelation-
ships among their products, making the realization of effective means
of pollution abatement and control more difficult. Therefore, prospective
solutions to environmental problems should take cognizance of the influ-
ences of related activities to avoid creating different but equally
unacceptable situations. A first step in dealing with these problems is
the establishment of a new environmental protection unit in the executive
branch of State government.
Design of governmental organizations to carry out present and emerg-
ing programs of pollution abatement and conservation of natural resources
can shape the response to the "environmental crisis" and can influence
the effectiveness of approaches to improvements in environmental quality.
In recognition of the importance of environmental aspects of the quality
of life in Ohio, Governor John J. Gilligan of Ohio appointed a Citizens
Task Force to study and report to him the nature and extent of Ohio's
needs concerning protection of the environment. The Citizens Task Force
reported to the Governor in June 1971 that the State was not coping
effectively with environmental problems and recommended that comprehensive
legislation be introduced to provide Ohio with the ways, means, and
resources to accomplish effective environmental protection for the public.*
Subsequent to the completion of this study, the Ohio General Assembly
passed Amended Substitute Senate Bill No. 397 on July 6, 1972, which
established the Ohio State Environmental Protection Agency. The
organizational design recommended in this report is consistent with
the objectives and functions of this legislation.
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In response to this concern, the federal government sponsored this
study to assist the State of Ohio in an intensive review of its environ-
mental protection activities, which led to a recommended design for con-
solidation of presently separated environmentally related activities into
a single State agency. By mutual agreement, the performance of the study
was a joint effort of the executive branch of the State of Ohio and the
federal agency, providing assistance to and participation with members
of the Stanford Research Institute study team in detailed aspects of
the design effort.
\
The approach employed in the study was based on the use of partici-
pative methods in all aspects of the study where possible. Communications
were established with public officials of municipal agencies and regional
planning bodies, as well as with private organizations throughout the
State that represented diverse interest positions in regard to policies
and activities related to environment protection. These methods emphasized
the development of a consensus among the different interests and respon-
sibilities represented by members of individual working groups established
to address problems of State policy, intergovernmental relations, man-
power planning, and technical operations. This approach employed applied
theory and research in the behavioral sciences and management practice
in identifying means to achieve constructive change within organizational
structures. In particular, the approach emphasized the definition of
critical institutional transactions that exert a major influence upon
functional aspects of the organization.
The scope of the study covered:
• An assessment of environmental issues and objectives that have
implications for organizational design, and a diagnosis of
present operations and functions leading to findings and recom-
mendations for organizational design.
• Development of a new organizational concept in keeping with goals
and objectives of the organization, diagnostic findings and
recommendations, and principles of organization and management.
• Definition of structural relationships of the new organizational
concept, including description of authority, accountability,
and responsibilities.
• Evaluation and estimation of staffing levels for the new
organization.
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• Development of guidelines for implementation of the new organi-
zation, including consideration of priorities, transition
process guidelines, and schedules.
• Preparation of a manpower planning model to be used in defini-
tion of staffing requirements for critical functional activities.
This report summarizes the organizational design study effort; the
assessment of environmental issues and objectives; and the study team's
diagnosis of present operations, including findings and recommendations
for organizational design. The new organizational design is described
in detail, with examples illustrating how sample operations would be
handled; and an approach to implementation of the new design is presented,
The study was sponsored by- the Midwest Regional Office of the U.S.
Environmental Protection Agency and was funded in part by the Division
of Applied Technology, Office of Air Programs and the Manpower Develop-
ment Staff of the Office of Water Programs.
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II EXECUTIVE SUMMARY
In collaboration with the State of Ohio and the U.S. Environmental
Protection Agency, SRI completed an intensive review of environmental
activities currently being performed by separate agencies in the State
o*f Ohio. The basic aim of this study was to conduct a diagnostic
assessment of the present operations and, on the basis of the findings,
to recommend a new organizational concept that would effectively con-
solidate the environmental-related activities into a single State agency.
Another product of this study was a manpower model that was used as an
^
aid to generate estimates of the staffing levels required to operate the
new organization. Finally, guidelines for implementation were developed
that included consideration of priorities, interim operations, and
schedules.
The findings and recommendations that emerged from this study are
those of the SRI project team and do not necessarily reflect the opinions
and viewpoints of individuals or groups from any of the operating depart-
ments of the State of Ohio or the U.S. Environmental Protection Agency.
The SRI study team benefited greatly, however, from the information,
suggestions, and practical experience supplied by members of these organi-
zations. Valuable inputs were also received from interested individuals
and organizations throughout the State of Ohio.
The following are the major findings and recommendations that
resulted from this study.
Finding 1
Environmental planning activities are presently divided among the
Ohio Department of Natural Resources (ODNR), the Ohio Department of
Health (ODH), and the Ohio Water Development Authority (OWDA); some
elements of planning are also present in activities carried out by the
Water Pollution Control Board. Planning, as it now exists, is performed
on a piecemeal basis. Strategic planning as an operating concept does
not exist.
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Recommendation 1
Develop an organizational structure that centralizes the planning
function and effectively insulates everyday operational processes from
policy and future-oriented activities. Within this function, provision
should be made for specialized sections responsible for categorical
resource planning, intergovernmental planning, research and development
planning, socioeconomic planning, and manpower planning.
Finding 2 \
Technical operations dealing with aspects of environmental quality
are presently divided between the ODH and the ODNR. The resulting
fragmentation decreases operating efficiency and creates problems of
coordination that consequently increase the cost of achieving environ-
mental objectives.
Recommendation 2
Develop an organization structure that will integrate all technical
operations related to surveillance activities in order to avoid func-
tional duplication and divided responsibility. A separate function
should also be established to perform information processing and to be
responsible for maintaining an environmental data base. An internal
center of specialized technical expertise in environmental disciplines
should be established to provide technical support for departmental
operations.
Finding 3
Ohio has more than 2,500 political planning entities involved in
environmental protection programs; they are governed by over 20,000
elected local officials. This diversity of local governments creates
a climate of disunity with respect to environmental programs. Strong
home-rule political and legal traditions encourage local resistance to
direct State-local government cooperation and act as a barrier to regional
cooperation and planning for the attainment of common environmental
objectives.
There is no single responsible State focal point for coordinating
the diverse intergovernmental activities and assuring accountability for
performance of programs related to environmental protection. Responsi-
bility for many of the programs involved in intergovernmental relations
6
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is shared by several State agencies. This results in conflicting
demands being placed on local governments, with no one responsible
authority accountable for resolving these conflicts. Additionally, this
divided responsibility provides no unified method for assessing the
views, needs, and positions of local governments in regard to pending
State and federal legislation. This resulting ambiguity places manage-
ment obstacles in the path of officials responsible for administering
the programs and projects of the several Federal agencies involved in
environmental protection.
Recommendation 3
Develop a specific functional component within the State's environ-
mental protection organization that is charged with the responsibility
for coordinating all aspects of intergovernmental relations. Within the
central planning function of the environmental protection organization,
establish an intergovernmental planning section that will be responsible
for developing State policies, standards, and criteria for intergovern-
mental operations and institutional transactions. This section should
also be responsible for developing measures for evaluating the effective-
ness of intergovernmental operations with respect to environmental pro-
grams and activities.
Finding 4
There is presently no single, coordinated approach to providing the
information support required for management of technical and functional
activities concerned with environmental problems. The present responsi-
bility for collecting and disseminating information is divided between
several State agencies. This difficulty is compounded by the use of dif-
ferent computer systems having different file-management techniques,
programming languages, and data formats. No single organization component
or agency has been designated as responsible for analyzing, designing,
implementing, and maintaining a single, coordinated information system.
Recommendation 4
Establish a single, separate organization component with assigned
responsibility for the following data management activities:
• Providing a single, unified, consistent, and compatible service
for systems analysis, systems design, program development, data
base design and management, and software development.
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Developing uniform user procedures, compatible forms design and
control, and user orientation and training.
Developing and implementing coordinated and effective data col-
lection procedures, equipment, and operations.
Designing and implementing a statewide system for data communica-
tion and voice communication to serve the total needs of environ-
mental agencies.
Providing access tVa single, uniform, and compatible electronic
computer system for data input, analysis, modeling, and re-
trieval throughout the environmental protection organization.
Planning, designing, and implementing a comprehensive set of
information systems employing a coordinated set of master files
to serve the needs of all users and permit retrieval and analysis
of relevant data for such functions as planning, operations, and
management analysis and control, in order to provide a single
source of key environmental data for all functions and categorical
programs.
Promoting and supporting programs for mathematical modeling and
other data analysis techniques.
Finding 5
Legal services for environmental protection activities are presently
provided by personnel assigned to the State Attorney General and by small
legal staffs in both the ODH and the ODNR. Departmental legal personnel
are also involved in legal matters outside of the environmental field.
Consequently, this dispersion of legal responsibilities leaves the various
environmental components in the present organizations without legal sup-
port. The modest legal resources now available to deal with environ-
mental issues must be used to cope with pressing day-to-day problems.
Adequate time and resources are not available for developing consistent
and routine applications of case law precedents in enforcement of
environmental laws and regulations.
Recommendation 5
Establish within the new organization an adequate and qualified
legal staff, responsible to both the Attorney General and the Director
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of the environmental protection organization. This legal staff would
be responsible for providing support to the organization's activities
related to hearings, litigation, and other judicial proceedings. Legal
representation should be assigned also to each district office to provide
local legal support and services. These field services would be coordi-
nated by the central legal staff.
Finding 6
Interface and communication between the ODH and the ODNR and the
State Personnel Department are presently inadequate and pose serious
difficulties. Some of these problems result from the lack of a well
defined reporting relationship between the State Personnel Department
and other operating departments. Other serious problems that may have
an adverse effect on the operation of the recommended organization are
the following:
• A shortage of experienced, qualified professional personnel
exists at both the supervisory and operational levels.
• Basic employment and salary administration policies are outdated.
• Manpower planning, training, staff development, and career path
planning are not being performed; consequently, the human resource
management function is limited in scope and capability.
• Recruiting of high talent personnel will be difficult under
present circumstances because professionals will be unable to
perceive possibilities for upward career progression.
• Staff professionals are underutilized in both the ODH and the
ODNR; in many cases, engineers and scientific personnel are per-
forming functions usually assigned to technicians or aides.
• The present organization is overcompartmentalized, and this con-
dition serves to prevent appropriate interaction between
professionals.
Recommendation 6
An organizational analysis of the personnel function at operating
department levels should be performed prior to staffing to ascertain
whether or not some functions now performed at the Personnel Department
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level might be more advantageously executed by the operating department.
If such is the case, appropriate steps should be taken to have these
activities delegated to the operating department. Once that task is com-
pleted, the following additional steps should be taken:
• Personnel policies, practices, and procedures should be formu-
lated and codified as a logical first step in developing a com-
patible personnel system.
• The data base of the State central personnel information system
should be reviewed ror completeness and adequacy, and considera-
tion should be given to the development of additional modules to
accommodate manpower planning and staff development.
• The basic functions of recruiting, placement, training, com-
pensation, and career development should be included in the per-
sonnel section of the environmental protection organization.
• A skills survey should be undertaken to inventory and document
the existing professional and technical capability of the staff
in the ODNR and ODH.
• A complete and systematic job analysis of all jobs that will be
included in the new environmental protection organization should
be performed in order to establish position requirements, grades,
and equitable pay scales.
• A program should be established to develop and coordinate environ-
mental education programs with the universities, colleges, and
junior colleges within the State to ensure an adequate supply of
professional, technical, and paraprofessional environmental
specialists to staff environmental programs administered by State,
local, and private entities.
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Ill CRITICAL ISSUES
This study was initiated at a point in time when the State of Ohio
was intensely involved with finding solutions for the critical environ-
mental problems confronting the State. In this context, the problems
that this study has had to face deal mainly with questions concerning:
relationships between governments, organizations, industry, and the
people of Ohio; changing relationships between Ohio and her sister states;
relationships between the State of Ohio and the federal government; and,
most importantly, the changing pattern of traditional State programs
with respect to emerging environmental issues. The central concern of
this study is not the physical environment of the State of Ohio per se,
but rather a search for more effective ways to restructure the organiza-
tional means of addressing these problems.
The primary objective of this chapter is to delineate those issues
that appear most relevant to the study and to indicate their impact on
the organizational design for the proposed environmental entity. The
factors that were excluded from the design considerations are specified,
and the reasons for their exclusion are discussed. Also, the recommended
organizational design is related to those issues that are still unsettled,
and the alternatives that remain open are examined in case the State of
Ohio decides to implement the recommendations before these issues are
settled.
Quality of Life
The concept of quality of life is a pervasive idea that permeates
many of the public issues competing for decision in the State of Ohio.
This concept includes not only the quality of Ohio's physical environ-
ment, but also refers to the style of life and opportunities for realiz-
ing the potentiality for enhanced experience and creative living inherent
in the social fabric of the State. In this context, the Governor's
announced goal of "improving the quality of life" implies that the impact
of any proposed program must be balanced against the sum total of its
effects upon a wide spectrum of factors that collectively influence the
expectancies of the citizens, organizations, and social institutions in
the State of Ohio. Thus, the goal of improving the quality of life
includes not only specific environmental protection programs, but also
the impact of those programs on other sectors of Ohio's activities.
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In pursuing this goal, the SRI project team contacted many diverse
groups representing private and public viewpoints at the local and
regional level, within the academic community, and within the legal
profession, as well as conservation interests and other interested
individuals. The project team was particularly concerned about identi-
fying the perceptions and interest position of each of these groups in
order to present a balanced input into the design of the organization.
Quality of life, then, is more than'the quality of the environment; it
is the criterion against which all competing interests in Ohio can and
should be measured.
This broad concept is a powerful force for bringing together the
discrete actions of those diverse departments and agencies of State
government charged with the responsibility for coping with the multi-
faceted problems of the environment. The concept also requires their
coordination and collaboration on problems that may normally be under
the jurisdiction of a specific department or on problems that fall within
the jurisdiction of several cognizant agencies.
For this organizational study, the issue of quality of life has had
two major consequences. First, in order to meet the expectations of
the State of Ohio as set forth in the report of the Citizens Task Force,
the proposed organizational structure would require a capability for
assessing all aspects of environmental protection actions as they affect
the quality of life within the State. This essentially means that the
State's environmental protection organization will require the capability
for assessing social, economic, and financial impacts of major environ-
mental actions in addition to the technical capability required to pro-
tect the physical environment. Secondly, the environmental protection
organization would be required to relate the totality of its programs
and proposed actions to those of other State, federal, and local govern-
mental agencies in order to meet the test for balanced improvement across
all critical sectors of the State's activities. This requirement has
been met by designing an organization capable of developing, implement-
ing, and evaluating its own projected programs and activities. In the
recommended organization, the process of developing and approving goals
and objectives is also the means for deriving the standards against which
the organization's contributions to the objective of improving the
quality of life in Ohio are evaluated.
Such an organization will have other implications, of course, for
State-federal relations, program accountability, and citizen participa-
tion. The aspect of the organization that is relevant to the issue under
discussion here concerns the role of the State environmental protection
entity in contributing to the statewide objective to improve the quality
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of life vis-a-vis other State departments that share the same common
objective. The following example may help to illustrate this interplay
between the environmental organization's goals and objectives and the
statewide objective to improve the quality of life in Ohio.
If an objective is established by the State environmental organiza-
tion to clean up the waters of the State, and specific goals with firm
schedules are established for designated municipal and industrial waste
treatment facilities, then there will be statewide financial, economic,
and social impacts resulting from the implementation of these goals.
The environmental protection organization will be responsible for asses-
sing the financial, economic, and social implications of its goals and
objectives from its own internal planning and evaluation capability.
However, the organization will not have the jurisdiction to avoid all
the adverse effects that are likely to result from the implementation
of programs derived from the overall goals and objectives, nor will it
be able to capitalize on the opportunities that could also occur as a
result of this effort. Furthermore, goals related to cleaning up the
waters of the State may require all industries on designated streams to
install waste treatment facilities to treat their effluents by a spec-
ified date.
Conversely, testing the environmental protection organization's
goals against the resources that can be brought to bear on similar problem
areas by other State, federal, and local governments and agencies may
indicate that, on balance, unless an infusion of new resources is provided
by other collaborating organizations, the programs of the organization
could have an adverse impact on the quality of life.
Superstructure
All parties involved in the study effort agreed that no consideration
would be given to defining the superstructure of the environmental pro-
tection organization during the course of this study. Instead, the study
was limited to designing the "microstructure" required of an effectively
functioning environmental protection organization. Although the SRI
study team adhered fully to this ground rule, the team was influenced in
its conceptual thinking on the design of the new organization by the
issues within the State bearing some relationship to questions of super-
structure.
Within the context of this study, the question of superstructure
included all reference to whether or not the environmental protection
organization was to be a new and separate department for the State,
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or whether it was to be an organizational unit within an existing depart-
ment, such as a division of the Department of Health or the Department
of Natural Resources.*
In terms of organizational requirements, it was not necessary to
have new legislation defining the superstructure in order to complete the
study. The recommended structure is a flexible, self-contained unit with
all the capabilities, functions, and processes required to conduct an
effective State program for protection of the environment. The concepts
upon which the new organization is based would be valid and consistent
regardless of whether the organization were treated as a new and separate
department or as a unit within an existing department. Only the imple-
mentation plan is concerned with the transfer of personnel and functions
from existing departments. However, even the implementation plan provides
for alternative treatments of the superstructure. Provision was made for
the possible establishment of an environmental protection organization by
legislative action, or in the absence of such legislation, the organiza-
tion can be developed by executive action from existing functions as they
are currently established within the present departments.
The Scope of the Environmental Organization
Issues regarding the scope of the environmental organization are
concerned with the nature of the proposed organization's capabilities and
responsibilities. From a continuum of possible environmental concerns,
the public, through the normal process of legislation and funding, has
indicated its willingness to support protection activities related to
programs to alleviate problems affecting the quality of air, water, water
supply, and solid waste disposal. There are additional candidate pro-
grams, such as noise and radiation, that may be included within the scope
of the new organization without disruption. It is only when the question
of responsibility for the management of the State's land and other natural
resources arises that debate becomes intense. The incorporation of these
conservation responsibilities within the purview of the new organization
is sought by the proponents of expanded "superagency"responsibilities,
whereas the opponents of this concept favor a more limited regulatory
scope consisting of activities directed toward the prevention of environ-
mental pollution.
This issue was resolved after completion of the study through passage
of new legislation.
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This study was undertaken with the benefit of previous work per-
formed by the Citizens Task Force on Environmental Protection, whose
members discussed these issues at length and made the following
recommendation:
All current activities relating to environmental protection,
conservation, development, and management in existing State
agencies shall be consolidated into a single State department
for environmental protection. New environmental functions
and activities not presently a part of any department shall
also be vested in this single agency.
A reading2 of the recommendations of the Citizens Task Force Report
as to the functions to be assigned to the department of environmental
protection indicates that the organization would have responsibility not
only for existing and customary pollution control activities, but also
for existing regulatory activities that affect the environment but that
were not specifically created as environmental functions (such as general
construction permits, soil conservation programs, agricultural permits,
and functions of the Department of Natural Resources). The Task Force
also had in mind the possibility of creating new functions, such as land
use management and power plant siting for inclusion within the scope of
the new agency.
The study team also had the opportunity to discuss the issue of
organizational scope with a number of interested and well informed
individuals who represented a cross section'of interests and concerns
in the matter. In addition, the study team had access to the working
papers prepared for the Citizens Task Force, which included discussions
of the approaches and solutions adopted by other states, as well as the
more academic analyses of political scientists.3 Three salient points
related to questions of organizational design emerged from this material:
(1) The issue regarding the appropriate role or mission for an
organization created specifically for the purpose of addressing
environmental problems remains to be resolved. Uncertainty
Report of the Citizens Task Force on Environmental Protection,"
p. Ill (June 1971).
2 Ibid., pp. 112-115 passim.
3 "Task Force Working Papers," Vol. II, material prepared as a back-
ground report for the session on proposals and alternatives for the
May 26 and June 2, 1971 meetings of the Task Force, p. 17 (Illinois),
p. IV (Minnesota), p. V (Ohio) for examples, and pps. 13-71 passim.
15
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remains about the question of whether such an organization
should be primarily regulatory in its functional responsibil-
ities or whether it should also be held accountable for the
management of the State's environmental resources. This prob-
lem is not unique to Ohio; there is no clear consensus among
either political scientists or practitioners in those states
that have directly addressed the problem. The following ob-
servation by the Citizens Task Force summarizes the problem:
"The linking of pollution control and conservation programs is
perhaps the most interesting public administration issue."4
"
(2) The Task Force's decision to recommend an environmental protec-
tion organization that would include both conservation and
regulatory functions was based on the assumption that the new
organization would need resource management programs in order
to provide a sufficiently large interest basis to make its
programs effective in the context of adverse pressures created
by other departments and interests.5
(3) There is a strong consensus to the effect that an environmental
organization must be more than control or protection oriented
(a remedial concept); it must also be responsible for mainte-
nance and preservation of the environment (a concept focused
on development of the environment).
These three points represent different views of organizations.
Implicit in the first point is the acknowledgment that inclusion of
regulatory and development functions in the same environmental organiza-
tion is fundamentally a political question rather than an administrative
or organizational one. The solution to this problem lies in^ future
legislative action. The essential factor in the second point is the felt
need to create an entity strong enough to perform its regulatory func-
tions in an energetic and effective manner relative to both public and
private sector activities. The third point relates to a developing under-
standing that, although remedial environmental measures may be required
immediately, future development within the State should not only be com-
patible with an enhanced environment, but should also include independent
efforts to further develop and husband the resources of the environment
itself.
Ibid, p. 13; emphasis is in the original, which quotes Elizabeth
Haskell, a fellow of the Woodrow Wilson Center at the Smithsonian
Institute.
E. F. Murphy, J.S.D., Professor of Law, Ohio State University, a
member of the Task Force Executive Staff (private communication).
16
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Each of these points has a common thread that is pertinent to the
organizational design effort. First, each point is concerned with
the scope of the organization. Secondly, the SRI concept of the new
environmental protection organization is designed to accommodate the
various facets of this issue but does not purport to settle it. For
the SRI study team to have addressed these issues directly would have
required judgments of a political nature, which would have preempted the
right to decision on the issue. In the new organizational concept, the
issue is addressed on grounds independent of, but compatible with, the
eventual political settlement of this issue by the people of the State
of Ohio. Future settlement of this issue will have the following con-
sequences for the scope of the organization:
• Additional environmental responsibilities can be added to the
new organization without affecting or disrupting other on-going
activities. For instance, the organization could assume the
responsibility for establishing standards for acquisition and
use of the State lands without requiring a functional realignment
to absorb such a program.
• The proposed new organization does not require a decision on the
issue of environmental control versus maintenance or development
of the environment to function effectively. The organizational
processes of the new concept are equally responsive to either
regulatory or developmental responsibilities. Should Ohio decide
to undertake a statewide program of solid waste disposal sites,*
the new organization could exercise its responsibilities for
surveying, licensing, inspecting, etc., such sites through its
existing functions. It could also undertake land use planning
responsibility, either through its existing planning functions
or through the establishment of an additional component dedicated
to that task.
• Conservation and resource management responsibilities could be
assigned to the new organization, but such responsibilities would
be additions to rather than functions of the organization. The
This possibility could emerge out of a State-federal partnership
resulting from a Congressional decision to implement a system of
Hazardous Waste National Disposal Sites. A report to Congress is
due by June 1973; EPA is investigating the feasibility of such a
system. See Section 212 of Public Law No. 91-512.
17
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addition of a conservation or resource management function would simply
require the establishment of a separate component in the new organization.
Little or no disruption would occur to the on-going processes of basic
organizational elements. For example, the management of the State's
lands could be assigned to the agency by establishing a division of land
management within the organization.
The new organizational concept clearly provides for a separation of
environmental control standards development and planning functions from
resource management and development. The study team found no firm justi-
fication in theory or prac^tice for combining on a program basis the
several functions, such as standards setting, regulation, control, plan-
ning, and impact analysis, that have direct responsibility for resource
management functions. Such a combination would be a tactical response
to a strategic problem that would impair the flexibility of the organiza-
tion in meeting new situations.
It is important to note that the above separation of environmental
standards and planning from resource management and development respon-
sibilities does not imply that the latter functions cannot or should not
be assigned to the environmental protection organization. Assignment of
such responsibilities to the organization, however, would require the
establishment of an additional organizational component whose activities
would be coordinated with those of other components through the normal
management control functions of the organization.
Public Participation
Public participation* in environmental matters has been a funda-
mental element of the developing concerns of the people of the United
States. This widespread issue is reflected in the attitudes of the
people, groups, organizations, and governmental entities in Ohio. In
Ohio; as with the rest of the nation, there appears to be no clear con-
sensus on what the process of public participation means in terms of
specific situations and particular actions and decisions concerning the
environment. In some cases, public participation appears to involve the
dissemination of environmental action information (a public information
or public relations concept). A closely related approach is one that
would make all data and information concerning the environment and
sources of pollution available to the public upon request (a freedom of
information concept).
This term includes "citizen's participation" and "public involvement'
for purposes of this discussion.
18
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In many circumstances, however, what is meant by public participation
is a direct involvement in the decision-making processes—including the
processes of formulation of goals and objectives—with respect to control
of the environment and conservation of resources. This use of the term
may also extend to participation in the execution of environmental pro-
tection functions and/or to the exercise of some form of public over-
sight with respect to how effectively environmental protection is being
executed by the responsible governmental authorities.
As with several other critical issues addressed in this report, this
study took cognizance of questions concerning the meaning of public
participation and its implications with respect to organizational design.
Participation must be tempered by the organization's need to be shielded
from interference in its routine operations. Such interference could be
disruptive of the organization's processes, authorities, and management
responsibilities.
The design for the new organization took this consideration into
account by insulating the processes of the organization from direct in-
volvement by the public. However, this concept does not prohibit the
public from exercising an important role in identifying issues and influ-
encing environmental policies. Organizationally speaking, participation
by the public has been facilitated by the establishment of a Public
Interest Center, an organizational component reporting directly to the
agency's Director. The center is described more fully in a later section
of the report. This recommended approach is responsive to the desires of
diverse segments of the public for participation in matters affecting the
environment and the quality of life in the State of Ohio.
Pending Federal Legislation
Even the most casual observer of environmental issues cannot help
but notice the rate at which the legislative and regulatory scheme for
protection and control of the environment is changing. The changes making
the most dramatic and immediate impact are the emerging federal legislative
enactments with their accompanying implementing regulatory actions.
Rapid changes in the statutory and regulatory environment cause dis-
organizing effects in the more traditional and less flexible organizations
that adapt to change slowly and only with great effort and internal dis-
ruption. Such organizations are ill-suited to cope with the rapidly in-
creasing volume of governmental regulations affecting environmental programs.
At best, these organizations find themselves continually off balance
19
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because, while contending with the most recent statutory and regulatory
development, new and often superceding legislation is being enacted.
The SRI study team, within the scope of its work, was required to
anticipate pending federal legislation and also to consider possible
implications for the new environmental organization. Although an anal-
ysis of pending and proposed federal legislation was performed, the pro-
gram requirements of such prospective enactments are not—and could not
be—directly reflected in the organization's components. An important
design consideration that emerged from this analysis of pending federal
legislation and regulation was the requirement for organizational stabil-
ity and continuity in the presence of rapidly changing program require-
ments. Consequently, in conceptualizing the design for the new organiza-
tion, it was necessary to provide flexible and responsive structural
arrangements that could adapt to changing circumstances without sacrificing
organizational integrity and effectiveness.
Traditionally, organizations have gone to great lengths to constrain
and stabilize the effects of change. While this tradition can be preserved,
it can no longer be achieved by founding organizations on long term, un-
changing programs. Confronted by problems of change, many organizations
have solved the problem of stability by establishing internal functions
and processes that can adapt to meeting changing tasks and programs. The
SRI study team has employed this course of action.
While performing the study, the SRI team had many opportunities to
discuss the pros and cons of pending legislation with individuals, groups,
and government representatives and was exposed to a wide diversity of
opinion. Like other issues discussed in this chapter, these matters are
essentially within the political realm and clearly outside the permissible
scope of this study. However, it should be pointed out that the organiza-
tional design recommended for the State of Ohio is capable of anticipating
and absorbing new legislative and regulatory requirements, regardless of
the outcomes of individual pending items, and it can do so without compro-
mising its effectiveness or jeopardizing its equilibrium. The design of
this new organization does not require that specific federal legislative
and regulatory issues be settled; it does provide., however, for their
orderly execution when called upon to do so.
The most significant federal legislation now pending in Congress is
the Water Pollution Control Legislation, separate versions of which
have been passed by the Senate and the House of Representatives and
are now pending in conference committee as this report goes to press.
The legislation, if enacted, would substantially affect the funding
and program requirements in the water pollution control field.
20
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IV ORGANIZATION DESIGN
Introduction
Organization design has played an important role in management prac-
tice and research during the past three decades, and indications are that
it will play an even more central role in the future. The pressures of
technological and social change have been instrumental in reducing the
effectiveness of many institutional and organizational structures. Rapid
change often brings in its wake new values and concepts, broader perspec-
tives, sharply differing.expectations, and demanding challenges. The
diversity of technical processes and the magnitude of operations—both
in government and industry—will require organizations that can perform
efficiently despite their size and complexity. Innovative and more adapt-
able organizations will be needed if society's expectations for mastering
the complex problems it faces are to be met.
As used here, organization design refers to the development of struc-
tures that relate roles, tasks, and authority relationships to the resource
transformation process by which the organization's goals are achieved.
As a discipline, organization design draws upon a variety of sources—
management science, industrial engineering, systems analysis, economics,
and the behavioral and political sciences. A primary emphasis is on in-
tegrating the different theoretical and functional concepts to develop
the principles and methods for designing flexible and responsive organi-
zational entities.
In pursuing the objectives of this study, the SRI project team worked
within a systems frame of reference to merge the appropriate theoretical
perspectives and disciplines. When applied to organization design, this
interdisciplinary emphasis is on the totality of organizational patterns
rather than any one element in isolation. This viewpoint provides a more
comprehensive framework for organizing the complex sequence of events and
processes comprising organizational life, and it facilitates the develop-
ment of the structures required to support rational decision-making. In
addition, the systems approach underlines the importance of the close re-
lationship between organizational structure and its supporting environment,
especially those factors that influence an organization's ability to achieve
its goals and objectives.
21
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The critical issue facing the designer is not so much improving the
existing organization--which can always be done to some extent because
a variety of technical means are available to do so—but determining what
kind of an organization is required to cope most effectively and efficiently
with the problems and challenges confronting it. This requires that any
programs, activities, and structures included within such a framework be
predicated on their capacity to support the organizations missions and
goals.
In undertaking the design of an environmental organization for the
State of Ohio, SRI's project team sought to develop a concept specifically
oriented to Ohio's\problems and concerns. Emphasis was placed on a struc-
ture that would maximize task performance and provide the necessary flex-
ibility and responsiveness to meet changing conditions, new technological
requirements, new patterns of organizational authority, staff acceptance,
and the capacity to adapt to future enlargement of responsibility. The
following processes were paramount in developing the design:
• The analysis must be performed within the context of the
organization's ability to meet stated goals and objectives.
• Policy, functions, authority roles, and technological re-
quirements must be structured to meet stated goals and
objectives.
• Control and feedback processes serve as a means of main-
taining consistency and stablity in on-going operations.
• Systematic use must be made of information processes to
guide and facilitate organizational decision-making.
• All levels of staff membership must be involved in the devel-
opment of the new organization design to facilitate accep-
tance and commitment to new directions in policy, function,
roles, and patterns of authority.
Criteria for Organizational Design
The influence of organizational structure on human behavior is an
increasingly important consideration in modern organization design. Care-
ful examination of current trends in organization practice suggests that
the rigid bureaucratic structure is giving way to more flexible, less
restrictive forms. Organizations that can achieve a high degree of coor-
dination while maintaining group and individual latitude for independent
thinking and action are gaining preference over those forms that stifle
innovation and initiative.
22
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The success of any organization depends primarily on the human element.
In the final analysis, the organization is a collection of people, and
its goals, and the means developed to achieve its purposes are products
of human desire and need. Cooperation within the organizational system
is a fragile matter and cannot be taken for granted. The neglect of human
requirements is often a major reason for the difficulties observed in
organizational performance.
In developing an organization design for the State of Ohio, the SRI
project team sought to balance the more impersonal aspects of organization
structure by building a framework within which the personal satisfaction
and well-being of the membership receive adequate recognition. The criteria
employed in this effort assume that an effective organization should:
• Achieve the multiplicity of goals and subgoals that comprise
the organizational purposes.
• Seek to maximize the organization's output, given the avail-
able resources.
• Maintain balance in the distribution of decision-making
responsibilities among management levels, i.e., a balance
between centralization and decentralization.
• Use as few management levels as are necessary to function
effectively.
• Separate policy-making from everyday operations.
• Maintain an equitable balance between the purposes and goals
of the organization and the needs and career goals of the
membership.
• Have sufficient flexibility to be responsive to change in its
internal and external environments, i.e., strategic and opera-
tional responsiveness.
• Anticipate problems and opportunities.
• Show clear lines of responsibility and authority.
• Maintain technical and management expertise in functions
where needed.
• Provide flexibility for new program development.
• Have well defined channels of communications and decision-
making.
• Have well defined areas of responsibility and accountability.
23
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Faciliate the capacity of its membership to exercise in-
telligence, imagination, and initiative in solving the or-
ganization's problems.
Strategic Planning Concept
In recent years, strategic planning has been recognized as an indis-
pensable tool in organizational practice. Far-reaching changes in all
aspects of societal processes have convinced most managers that continuing
attention to environmental analysis and strategy formulation is directly
related to organizational survival and effective performance. To carry
out its role of adaptation, management must anticipate the challenges and
opportunities that follow in the wake of change and translate its percep-
tions into meaningful organizational programs—and these must be acted
upon.
A clear understanding of the purposes of an organization is necessary
for effective performance. When goals and objectives are ill-defined,
ambiguous or conflicting, behavior of the membership will probably reflect
these influences. Coordinated activity is difficult to attain under such
conditions. Modern organizational activity, which involves the coordina-
tion of ideas, technology, resources, and people, requires a systematic
framework for conceiving and ordering the appropriate relationships.
Strategic planning is the framework that defines the essential character
and posture of the enterprise and provides.the guidelines for the action
and allocation resources to achieve specified goals. The decisions related
to these activities may include expansion or contraction of services in
response to change in political, social, or economic conditions, or they
may simply reflect technological developments. Significant changes in
the basic objectives may cause readjustments in the skill mix, or the
addition of new equipment and facilities. It is quite apparent that the
strategies adopted by an organization play an important role in shaping
the organizational structure.
The topic of organizational structure deserves special attention.
Structure is generally visualized as the formal arrangement of institu-
tional patterns through which enterprise is governed. Therefore, a sound
structural design is a basic requirement for effective planning, coordina-
tion, and evaluation—management functions essential to the integration
of the resources and operations of the organization. In designing organi-
zations, the elements of structure that usually receive the most prominence
are the following:
24
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• Organizational goals and objectives
• Policies
• Technical operations
• Task definition
• Positions and roles
• Authority patterns
• Interpersonal and group relations
• Division of labor
• Departmentation
• Communication channels
• Decision networks.
The close relationships between the structural form of the organiza-
tion and the strategies that the organization adopts in order to cope
with the vicissitudes of its environment have been well documented.6 In
periods of rapid change, it is important that the structure of an organiza-
tion be capable of intelligent and responsive action in dealing with the
rapid emergence of new problem situations. Organizations responsible
for protecting the environment must have this capability built into the
structure if they are to keep pace with changing technological, political,
social, and economic realities.
On the basis of its assessment of these critical factors, SRI empha-
sized the strategic planning function in the proposed new organization
for the State of Ohio. The salient features of this concept are listed
below.
• Strategic planning is responsible for setting the parameters
for:
- Environmental goals, objectives, and policy
- Evaluation of alternative goals
- Resource allocation
- Organization structure
- Operational criteria
- Evaluation of emerging issues
6. A. D. Chandler, Jr., Strategy and Structure (MIT Press, Cambridge,
Massachusetts, 1962).
25
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- Guidelines for change.
• The functions of the strategic planning process include:
Determination of guidelines for the strategic plan
Assessment of social, economic, and political factors
Assessment of technological trends
Setting of prevailing values
- Identification of opportunities and threats
Identification of information requirements
- Formulation of criteria for program evaluation
- Assessment of organizational accomplishments.
• Organizational implications of strategic planning include:
Providing top management with policy alternatives.
- Being staff rather than line oriented.
- Emphasizing development of environmental plans to address
public concerns rather than operations.
Enabling performance accountability in terms of environ-
mental goals and derived objectives.
As part of the strategic planning concept, provision was also made
to include a management control system capability to ensure that opera-
tions in all functional areas would be performed to support strategic
objectives. This provision also makes possible better coordination be-
tween tactical and strategic planning. By establishing appropriate pol-
icies, procedures, and standards, programmatic data can be made available
to monitor progress toward objectives and initiate corrective action when
operational activities vary from planning guidelines.
Alternative Organizational Concepts
The SRI project team explored and evaluated several alternative
organizational concepts as possible prototypes for use in designing the
State of Ohio environmental entity. The principal features of each con-
cept were carefully assessed, as were their advantages and disadvantages.
At one end of the spectrum, an organization structure can be founded
on the idea of differentiation by resource category. This structure is
prevalent in State environmental programs and is illustrated in Figure 1.
26
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to
I
Vir
illance
1 1
Air
Engr. and Tech.
Services
^ Air
District
Operations
Ai
Author
an
Compl
1
ater
illance
1 1
Water
Engr. and Tech.
Services
Water
District
Wat
anc
Compli
Operations
Solid Waste
Surveillance
Solid Water
Engr. and Tech.
Services
Solid Water
Authorization
and
Compliance
FIGURE 1 ORGANIZATION BASED ON RESOURCE CATEGORIES—I
-------
An adaptation of this form, which introduces functional specialization
at the supervisory level but retains resource category specialization at
the operating levels, is shown in Figure 2. Figure 3 illustrates an
organizational concept in which functional specialization is present at
all levels of the organization. A brief summary of each of these alter-
natives is presented below.
Organizational Plan I: Resource Category Specialization
Resource category specialization structure (Figure l) offers certain
organizational advantages. Because of its similarity to the present or-
ganization, implementation would be relatively easier than for other al-
ternatives and would require the least change from present arrangements.
In addition, many of the existing organizational units would remain intact
when transferred to the organization. Reorientation, retraining, and
relearning would therefore be minimized. Not the least of the advantages
is its close correspondence to the present federal EPA structure, which
would ease the disruption in present contacts, technical relationships,
funding, and collaboration between federal and State organizations.
Disadvantages of the resource-specialized organization include:
• Much of present redundancy of staff functions would be re-
tained (particularly in field organizations, where signifi-
cant numbers of positions are involved), thus increasing
the apparent cost.
• Resistance to change would be significant, as old habits,
methods, and commitments are retained.
• Each resource category would tend to become committed to
its special area; interface problems between resources would
be a source of conflict; and coordination, control, and inter-
resource trade-offs would be difficult.
• Local agencies, health departments, and planning groups or-
ganized to deal with multiple environmental problems would
be required to maintain contact with separate subagency
programs in order to receive services.
• Career development paths for technical, professional, and
staff personnel would be limited to single-resource channels,
lacking any added breadth beyond present avenues.
• Information interchange, data based integration, and com-
munication between categories would be difficult.
28
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EPA
to
CO
Engr. and Tech.
Services
Authorization
and
Compliance
Operations
J.
Air
Engr. and Tech.
Services
Water
Engr. and Tech.
Services
Air
District
Operations
Water
District
Operations
FIGURE 2 ORGANIZATION BASED ON RESOURCE CATEGORIES—II
-------
Information
Procedures and
Communication
Finance
and
Administration
1
V
Surveillance
Administration
State of
Ohio
EPA
Engineering
and Technical
Services
Public
Interest
Center
Environmental
Planning
1
Authorization
and Compliance
Operations
Engineering
District
Operations
FIGURE 3 FUNCTIONAL ORGANIZATION
Firmly established and heavily staffed programs (in the case
of Ohio water programs) might tend to overwhelm the other
emerging programs and make it difficult to attain a balance
in level of importance between resources.
The addition of new programs in the future would imply
completely new organizational components with consequent
redundancy.
Organizational Plan II; Combination Model
The organizational concept illustrated in Figure 2 represents a
compromise between resource specialization and functional specialization,
assigning the surveillance functions to a single middle-management com-
ponent and technical services to a second middle-manager, while retaining
resource specialization at the lower operating levels in the organization.
Authorization and compliance are considered as a single functional organiza-
tion dealing with all categorical programs in these concepts.
Advantages of this concept include the following:
• Since several of the present section-level and unit-level
organizations could be fitted into this structure without
major change, this concept would be relatively easy to im-
plement.
30
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• Interdisciplinary and interprogram career development paths
can be more easily visualized than in the resource category
specialization concept.
• Interprogram trade-offs and establishment of priorities be-
tween resources can be handled somewhat more easily at a lower
organization level than in the resource category specializa-
tion concept.
• Relations between the federal EPA and State components would
be somewhat clearer than in a purely functional organization.
Several disadvantages of this concept can be identified:
• This midspectrum structure would require more supervisory
positions than would a strictly functional organization
(such as that shown in Figure 3), and it would apparently
have considerable position redundancy at the operating
levels.
• Local sources would be impacted by separate requirements
articulated by multiple subagencies (although these sub-
agencies would be coordinated at a lower organizational
level than in the resource category specialization concept).
• The addition of new resource categorical programs would
imply the addition of several new subcomponents in the
organization, with consequent redundancy.
• Information systems and data base development would not
be markedly simpler than in the resource category special-
ization concept in view of the fragmentation of program
elements at the detailed operational levels.
• Difficulties would be apparent in reorientation of middle-
management to achieve interprogram balance and coordination.
Organizational Plan .III: Functional Specialization
One form of pure functional organization is illustrated in Figure 3.
This concept visualizes the utilization of surveillance skills—especially
at the field and operating levels—to perform prescribed functions inde-
pendent of resource categories. Similar broad utilization of skills across
resource lines is visualized in the assignment of technical service per-
sonnel. Certain advantages of such a structure can be identified:
31
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• Such a structure offers single-agency contact for all environ-
mental problems at the local source level, consistent with
many local agency organizations, thus presenting a more effec-
tive and efficient response to problems and opportunities.
• Greater flexibility is afforded strategically, structurally,
and operationally, since new program requirements can be
added and interprogram shifts in priorities can be made with
only moderate rearrangements in staff and little disruption
to management structures and relationships.
• Increased visibility to both the general public and the sources
should signal the fact that "Ohio means business" in improving
environmental quality. Public interest environmental groups
should be responsive to this "total environment" organization,
and communication with them should be improved.
• Broad, interdisciplinary career development paths can be
clearly seen by incumbents and new candidates; this may be
an important consideration in view of the apparent need for
new professional and technical staff.
• More effective utilization of staff—particularly at the field
level—reduced redundancy, and reduced overhead in managerial
and clerical positions should result from this structure, along
with better membership identification with overall environmental
goals and less localism.
Several concomitant disadvantages should also be listed:
• This structure will require more substantial rearrangement of
organizational functions than any other. Continuity of present
programs will require greater resourcefulness and innovation to
plan and achieve during the transition.
• It will be more complex and require advanced techniques to
project budget and staffing requirements in the initial phase
of implementation, as there is no prior basis of experience on
which to base estimates.
• Staff retraining and orientation will be more extensive than
with other alternatives if personnel—especially at the local
field level—are to become qualified in multiple program
disciplines.
• Habit may lead the general public, the State legislature, and
federal agencies to expect separate reports of accomplishments
and expenditures for each environmental category. This may
imply the need for a true PPBS capability and resource account-
ing to individual programs on a routine basis.
32
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V ANALYSIS OF PRESENT ORGANIZATION
Responsibilities for environmental protection in Ohio are presently
assigned to seven boards and commissions, and two major departments, con-
taining 5 offices and bureaus, 5 divisions, and 42 section-level and unit-
level organization components that deal in categories of air and water
pollution, water supply, and solid waste. Approximately 240 full-time
employee positions are involved in the discharge of the State's respon-
sibilities in these programs. General revenue fund expenditures totaled
$3.59 million in 1971, and a total of over $90 million in capital invest-
ment bond funds were administered by these organizations.
Present Organizations
The principal components that have responsibilities for environ-
mental protection within the Department of Health and Department of Nat-
ural Resources are shown in Figure 4. Although these two departments
share major responsibilities are assigned to seven separate boards and
commissions, of which the Directors of the Departments of Health and
Natural Resources are members. Environmental protection responsibil-
ities form only a part of the responsibilities assigned to the two de-
partments, as the ODH has broad responsibilities in the entire spectrum
DEPARTMENT
OF HEALTH
BUREAU OF
ENVIRONMENTAL
HEALTH
BUREAU OF
GENERAL
SERVICES
BUREAU OF P.H.
LABORATORIES
BOARDS AND
COMMISSIONS
DEPARTMENT
OF NATURAL
RESOURCES
OFFICE OF
ENVIRONMENTAL
PROTECTION
OFFICE OF
PLANNING
AND RESEARCH
FIGURE 4 THE MACRO-STRUCTURE
33
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of public health issues, while the ODNR is charged with a wide range of
management and resource functions that are beyond the scope of environ-
mental programs considered in this study.
As a general indication of the division of responsibilities between
the ODH and the ODNR, water resource and water quality management plan-
ning, water inventory, and ambient quality problems are dealt with in
the Department of Natural Resources. The Department of Health deals
with the implementation engineering plans for water, as well as air
quality and solid waste programs, and supports the enforcement actions
of the respective cognizant boards.
Further details of organization of the ODNR components responsible
for environmental programs are shown in Figure 5. The Division of Water,
in the Office of Environmental Protection, is concerned with inventories
of ground water and surface water and with monitoring the quantity and
quality of underground waters, streams, lakes, and reservoirs. It responds
to public requests for information related to water supplies and water
management problems. It operates a few automated stream monitoring sta-
tions around the State, which collect and report hourly data on several
key parameters.
Major planning responsibilities for water resources are assigned
to the Water Planning Section of the Office of Planning and Research in
the ODNR. Cognizance of interstate and international water plans is
maintained through representation on boards and commissions, including
the Ohio River Basin Commission, Great Lakes Basin Commission, and similar
bodies. Investigation, research, and planning are performed in relation
to flood plains and adjacent land usage. A major function of the Water
OFFICE OF
ENVIRONMENTAL
PROTECTION
Division of Water
MHMBM^B
•Water Management
•Ground Water
•Surface Water
OFFICE OF
PLANNING
AND RESEARCH
Water Planning Section
Researcn Planning
State Interstate Planning
-Regional Water Planning
Flood Plain and
Land Use Planning
FIGURE 5 DEPARTMENT OF NATURAL RESOURCES
34
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Planning Section is the development of detailed, long range water quality
management plans for the five major regions of the State. In the past,
this responsibility for regional planning has been discharged through
detailed administration by the ODNR of contracts with private research
and planning consultants who have provided the detailed field personnel
and planning resources.
Figure 6 shows the subcomponents of the Department of Health having
major assigned responsibilities for environmental programs. In the Bureau
of Environmental Health, the Division of Sanitation is responsible for
licensing, inspection, and enforcement of laws and regulations relating
to all solid waste disposal sites, as well as for the training of oper-
ators. The Division of Engineering has general responsibilities for sur-
veillance and data collection; review and approval of engineering plans
and specifications for new facilities related to solid waste, water supply,
sewage and industrial waste, and air pollution programs; and it provides
technical assistance to the regulatory activities of the Water Pollution
Control Board and Air Pollution Control Board. Four District Offices
provide local representation to the Divisions of Sanitation and Engineer-
ing, and a central laboratory and four district laboratories support the
Divisions in analyzing and testing samples collected by the field per-
sonnel. Both the field and central staff offer counsel and advice to
local governments and industries on the several environmental programs
in which they specialize.
BUREAU OF
ENVIRONMENTAL
HEALTH
'Division of Sanitation
^^^••MBH*
Solid Waste and Rec.
•w*
Solid Waste
- Division of Engineering
BUREAU OF
GENERAL
SERVICES
BUREAU OF
P.H.
LADORATORIES
f- Four District |- Four Laboratories
Offices
•General Engineering
-Solid Waste
-Water Supply
-Sewage and Ind. Waste
-Air Pollution
FIGURE 6 DEPARTMENT OF HEALTH
35
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The Directors of the ODH and ODNR are members of several boards
and commissions:
• Public Health Council
• Air Pollution Control Board
• Water Commission
• Water Development Authority
. Water Pollution Control Board
• Water and Sewer Rotary Commission
• Air Quality Development Authority
These boards and commissions have various assigned roles for environ-
mental programs. Responsibility for the enforcement of environmental
laws and regulations is vested in the Water Pollution Control Board and
Air Pollution Control Board. Prior to enactment of SB 397, important
funding and financing responsibilities and authorities were assigned to
the Ohio Water Commission (for flood control programs),* to the Ohio
Water Development Authority and the Ohio Water and Sewer Rotary Commis-
sion (for sewage and waste water treatment facilities), and to the Air
Quality Development Authority (for air pollution control projects). The
Ohio Public Health Council has judicial, legislative, and advisory duties
in public health matters, including environmental health.
Functional Analysis
As of February 1972, the Departments of Health and Natural Resources
contained a total of 239 employee positions assigned full time to activ-
ities falling within the scope of environmental protection. Of these
positions, 22 were assigned to air pollution control and 10 to solid
waste programs. The remaining 207 positions (86 percent of the total)
were involved with various aspects of water supply and water pollution
control. For purposes of analysis leading to a clear understanding of
present organizational functions, a generalized set of functions was
identified from present assignments and activities. Based on analysis
of position descriptions, interviews with key personnel, and background
information provided by the several study working groups, each of the
* The Ohio Water Pollution Board was abolished by the provisions of
Amended Substitute SB 397.
36
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239 positions was assigned to one of the six descriptive functions,
based on the major content of the work performed by each position. The
distribution of positions by function is shown in Table 1. It should
be noted that the administration function defined and applied in this
analysis includes, in addition to general supervisory positions, such
administrative functions as finance and budget control, information
systems activities, and personnel administration functions, though many
of these are represented by fractional portions of positions shared with
other nonenvironmental-related responsibilities.
Table 1
PRESENT POSITIONS FOR DEPARTMENT OF HEALTH
AND DEPARTMENT OF NATURAL RESOURCES
Percent
Functions Positions of Total
Environmental planning 24 10.0%
Surveillance 62 26.0
Technical services 89 37.2
Authorization and compliance 7 2.9
Intergovernmental administration 7 2.9
Administration 50 20.9
Total 239 100.0%
Figures 7 and 8 indicate the distribution of positions within the
major organizational components of the ODH and the ODNR, respectively.
The boards and commissions mentioned earlier have a variety of
assigned responsibilities and functions. Their staff support is usually
drawn from the appropriate departmental positions analyzed above, with
their membership serving on a part-time basis. The Ohio Water Develop-
ment Authority is an exception to this general situation, as it has a
full-time, salaried staff of seven positions who are performing functions
about equally divided between administration and intergovernmental admin-
istration.
37
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FUNCTIONS PERFORMED
Environmental planning
Surveillance
Technical services
Authorization and compliance
Intergovernmental administration
Administration
O
i|
=5 X
~~ rr
•a a-
co <5
1
4
*
2
at
B
— o>
a 01
o> B*
C9 uu
*
7
*
*
4
1
=5
•g
!5
CO
*
2
*
1
0.
B.
a
CO
,
QJ
S
1
1
2
*
3
H
B
CO —
OJ ^
S -o
CO —
1
3
12
2
*
2
e
4=
BS —
o- ts
sl
*
7
4
3
4
4
8"
o
^^
o
•c
CA
5
25
32
2
10
.i
3
O
(B
16
5
X
a
o 5
o
-5 «=
•s'5
2
52
62
7
6
31
160
»^
0
^J
E
U -=
15
1.2
32.5
38.7
4.4
3.8
19.4
100.0
'Partial positions.
FIGURE 7 POSITIONS FOR DEPARTMENT OF HEALTH AS OF FEBRUARY 1972
38
-------
FUNCTIONS PERFORMED
Environmental planning
Surveillance
Technical services
Authorization and compliance
Intergovernmental administration
Administration
c
Q9
w ™
gj 10
™ e
55
1
2
2
*
*
3
^_
i
o
ti
E 5
i i
Ul
B
JO
C
0 J;
cn «-•
QJ CO
8
*
2
8
JO "O
0. C
ID
-n _J
U» n
4
1
8
I4~
O
*J
M
O
3
2
5
DC
^i e
0 e
|1
22
10
27
0
1
19
79
"5
c
27.8
12.7
34.2
0.0
1.3
24.0
100.0
•Partial positions
FIGURE 8 POSITIONS FOR DEPARTMENT OF NATURAL RESOURCES AS
OF FEBRUARY 1972
39
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Findings and Recommendations
The organizational and functional analyses summarized above resulted
in the identification of several significant findings leading to key rec-
ommendations. These recommendations were important considerations in the
development of alternative organizational designs and the assignment of
functions within those organizational concepts. Major findings and rec-
ommendations in certain critical areas are summarized in the following
paragraphs.
Policy and Planning Findings
Environmental planning activities are presently divided among the
ODNR, the ODH, and the Ohio Water Development Authority. Some elements
of planning are also present in activities carried out by the Water Pol-
lution Control Board. Planning, as it now exists, is performed on a
piecemeal basis:
• In the ODNR, planning is essentially contract monitoring of
planning studies carried out by private consulting firms.
There is no effective means for controlling the relation-
ship between the organization and changing facets of its
environment.
• In the ODH, comprehensive health planning is primarily con-
cerned with developing local participation in activities and
programs concerned with identifying health needs, determining
priorities, and generating inputs into State plans. There
is little or no linkage between planning and everyday oper-
ations.
• In the Ohio Water Development Authority, planning is pri-
marily related to financing construction projects.
• Planning is not well articulated as a functional entity.
• Policy and planning activities are intermingled with routine,
repetitive functions.
Policy and Planning Recommendations
It is recommended that an organizational structure be developed that
centralizes the planning function and effectively insulates everyday oper-
ational processes from policy and future-oriented activities. Within
this function, provision should be made for specialized sections responsible
40
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for categorical resource planning, intergovernmental planning, research
and development planning, socio-economic planning, and manpower planning.
Technical Operations Findings
Technical operations dealing with aspects of environmental quality
are presently divided between the Department of Health and the Department
of Natural Resources. The following observations were made:
• Multiple groups carry out similar or related functions in
either the same general area (e.g., there are three sections
on water quality) or in different categories of activities
(e.g., there are separate sections dealing with municipal,
local, residential, and industrial pollution control). In
some instances, there is no clear-cut division of responsi-
bility.
• Technical operations are complexly intertwined with non-
technical activities.
• Technical operations are not coordinated with planning.
• Technical operations for short t;erm (surveillance or en-
forcement) purposes are usually combined with longer term
(monitoring) activities. The needs of short term programs
are given precedence.
• Programs and results of measurements of individual environ-
mental factors are not integrated and correlated.
• Technical operations data are disseminated randomly. Data
collected from present measurements are not compiled and
maintained as a basis for long term evaluation of environ-
mental progress.
Technical Operations Recommendations
It is recommended that an organization be developed to:
• Integrate technical operations with regard to surveillance
activities to avoid duplication in function and ambiguity
in responsibility.
• Provide a separate function to perform information process-
ing and maintenance of an environmental data base.
41
-------
Provide an internal center of specialized technical expertise
in environmental disciplines.
Intergovernmental Processes Findings
In Ohio the inherent complexity of intergovernmental relationships
and activities in the environmental protection field is intensified by
a number of factors peculiar to the State agencies involved, the local
governmental situation in Ohio, and the nature of the federal agencies
and programs bearing on the area.
• There are over 2,500 political planning entities within the
State of Ohio involved in environmental protection programs;
these entities are governed by over 20,000 elected local
officials. This number of entities and officials creates
a climate of disunity towards environmental programs.
Strong home-rule political and legal traditions encourage
local resistance to direct State-local cooperation.
• The traditional independence of local government entities
encourages them to oppose each other and the State in
matters requiring regional cooperation for the attainment
of common environmental objectives.
• Those intergovernmental relations that do exist between the
State and local governmental entities have developed over
different times to meet the needs of individual projects
and programs, and they have continued to function haphaz-
ardly on a project-by-project, case-by-case basis.
• Different State agency personnel make uncoordinated de-
cisions affecting intergovernmental relations.
• Three or four State agencies share responsibility for each
program, and each is involved in the intergovernmental re-
lations and activities of each project. There is no over-
all State coordination of these activities; so conflicting
demands tend to be placed on local governmental entities
with no responsible authority accountable to resolve these
conflicts.
• Because of divided program responsibility, the State often
finds itself in the position of having responded to pending
federal legislation and regulations with disparate view-
points that apparently express contradictory State policy.
42
-------
There is no unified method for assessing the needs, views,
and positions of local units of government on pending State
and federal legislation and no way of developing and spon-
soring legislation on their behalf; so local units of govern-
ment are left to shift for themselves on matters of vital
interest.
Because of divided responsibilities, the State has not been
able effectively and comprehensively to administer the pro-
grams and projects of the several federal agencies involved
in environmental protection.
Ohio's State agencies lack the flexibility to rapidly and
effectively respond to the changing character and adminis-
trative requirements of new and pending legislation that
is responding to shifts in national priorities.
Federal grant programs that are available to'the State and
local governments contain substantial funds for environ-
mental protection tasks, of which the State cannot take
advantage, primarily because of the lack of an organized
institutional effort to meet the federal requirements as-
sociated with those programs.
There is no single, responsible State focal point for coor-
dinating the diverse intergovernmental activities and as-
suming accountability for the performance of programs re-
lated to environmental protection.
A single environmental protection project or program com-
monly involves the interest of more than one federal agency
or department. The State's present ad hoc method of coor-
dinating the various and differing federal agency and de-
partment requirements for a single project or program places
this burden on the several discrete local agencies involved,
and it causes delays and missed opportunities for all gov-
ernments concerned.
The State is unable to evaluate the effectiveness of inter-
governmental relations and activities because it lacks the
planning necessary to determine the State's intergovern-
mental objectives with respect to environmental matters.
43
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Intergovernmental Processes Recommendations
The following recommendations are made:
* Develop a specific organizational entity within the State's
environmental protection organization that is charged with
all aspects of intergovernmental relations, activities,
and operations, and that insulates both the State's organi-
zation and its relationships with its local/regional govern-
mental entities from the organizational disruption of un-
coordinated action.
• Establish the function of intergovernmental planning in
the organization's central planning function, insulated
from the everyday processes of intergovernmental operations.
• Charge the intergovernmental planning function with respon-
sibility for developing State policies, standards, and
criteria for intergovernmental operations and institutional
transactions.
• Charge the intergovernmental planning function with the
responsibility for developing the goals and objectives of
the organization with respect to intergovernmental opera-
tions, and with evaluating the organization's effectiveness
in meeting those goals and objectives.
Manpower and Personnel Findings
Interfaces and communication between the Departments of Health and
Natural Resources and the State Personnel Department are presently in-
adequate and pose serious difficulties. Some of these problems result
from the lack of a well defined reporting relationship between the State
Personnel Department and other operating departments. Other serious
problems that may have an adverse effect on the operation of the rec-
ommended organization are the following:
• A shortage of experienced, qualified professional personnel
exists at both the supervisory and operational levels.
• Basic employment and salary administration policies are
outdated.
• Manpower planning, training, staff development, and career
path planning are not being performed; consequently, the
human resource management function is limited in scope and
capability.
44
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• Recruiting of high talent personnel will be difficult be-
cause, under present circumstances, professionals will find
it difficult to perceive possibilities for upward career
progression.
• Staff professionals are underutilized in both ODH and the
ODNR; in many instances, engineers and scientific personnel
are performing functions usually assigned to technicians
or aides.
• The present organization is overcompartmentalized, and
this condition serves to prevent appropriate interaction
between professionals.
Manpower and Personnel Recommendations
An organizational analysis of the personnel function at the oper-
ating department level should be performed prior to staffing to ascer-
tain whether or not some functions now performed at the Personnel De-
partment level might be more advantageously executed by the operating
department. If such is the case, appropriate steps should be taken to
have these activities delegated to the operating department. Once that
task is completed, the following additional steps should be taken:
• Personnel policies, practices, and procedures should be
formulated and codified as a logical first step in de-
veloping a compatible personnel system.
• The basic functions of recruiting, placement, training,
compensation, and career development should be included
in the personnel section of the environmental protection
organization.
• A skills survey should be undertaken to inventory and
document the existing professional and technical capa-
bility of the staff in the ODNR and the ODH.
• A complete and systematic job analysis of all jobs that
will be included in the new environmental protection
organization should be performed in order to establish
position requirements, grades, and equitable pay scales.
« A program should be established to develop and coordinate
environmental education programs with the universities,
colleges, and junior colleges within the State to ensure
an adequate supply of professional, technical, and
45
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paraprofessional environmental specialists to staff en-
vironmental programs administered by State, local, and
private entities.
Information Support Services Findings
There is presently no single coordinated approach to providing the
information support required for management of the technical and func-
tional activities concerned with environmental problems.
• Fiscal management data related to budgets, commitments,
and expenditures are supplied by the Department of Finance.
• Personnel data related to positions and employees are
being planned by the Department of Personnel but will not
provide all personnel data needs, as discussed above.
• A wide range of statewide health data, including environ-
mental health, is being implemented by the Comprehensive
Health Planning Service.
• The Department of Natural Resources is collecting auto-
mated stream monitor data via telemetry, but no analytical
capabilities, history file, trend forecasts, or relation-
ship to specific pollution sources have been included in
the system.
• A data base that includes air quality data is being planned
for the 'air protection program, but the system has not yet
been implemented.
• The Department of Health is collecting raw data on water
treatment and supply inspections and sample analysis,
but no analytical, trend forecast, or history file capa-
bilities are included.
Several different computer systems having different file-management
techniques, programming languages, and data formats are being used in
accomplishing the above:
• Expanded participation in the STORET system, developed by
the Federal EPA, is being considered for water pollution
control program applications.
• U.S. Geological Survey facilities are being used by the
Department of Natural Resources.
46
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• The Department of Finance on-line system is being used by
Comprehensive Health Planning Service.
• The Department of Finance batch system is used for manage-
ment data.
No single organization component has been identified as responsible for
analyzing, designing, and implementing a single, coordinated information
system.
No comprehensive procedures documentation is available that might
standardize approaches to uniformity of data, control of forms used for
recording data, procedures for data control, and the like.
Several different approaches are being planned for mathematical
modeling using available data sources. The Miami Conservancy District
has a mathematical model of a river basin for waste treatment plant
planning; the Federal EPA is developing an air diffusion model; and the
Federal EPA has a gross manpower model for air programs. None of these
is in current use in Ohio State agencies.
Information Support Services Recommendations
A single, separate organization component with assigned responsi-
bility for the following functions should be established:
• Providing a single, unified, consistent, and compatible
service for systems analysis, systems design, program
development, file on data base design and management,
and software development.
• Developing uniform and effective user procedures, com-
patible forms design and control, and user orientation
and training.
• Developing and implementing coordinated and effective data
collection procedures, equipment, and operations.
. Designing and implementing a statewide system for data
communication and voice communication to serve the total
needs of environmental agencies.
• Providing access to a single, uniform, and compatible
electronic computer system for data input, analysis,
modeling, and retrieval throughout the environmental pro-
tection organization.
47
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Planning, designing, and implementing a comprehensive set
of information systems employing a coordinated set of
master files to serve the needs of all users and to permit
retrieval and analysis of relevant data for such functions
as planning, operations, and management analysis and con-
trol , in order to provide a single source of key environ-
mental data for all functions and categorical programs.
Illustrating the classes of data that might be included
in a set of comprehensive master files. Figure 9 represents
some of the interfile\relationships that could be useful to
multiple users of such an integrated file system.
Promoting and supporting programs and analysis for mathe-
matical modeling and other data analysis techniques.
Findings: Legal Services
Legal services for environmental protection activities are presently
provided by personnel assigned to the State Attorney General and by small
legal staffs in both the Department of Health and the Department of Nat-
ural Resources. The departmental legal staff personnel are also involved
in legal matters for other departmental concerns outside the environmental
field. As a result of this recognized dispersion of assignment of legal
responsibilities, agreement has been reached by the affected parties for
the provision of legal support to the various environmental components
of the present organizations. The very modest legal resources that are
now available to deal with environmental issues must, of necessity, be
applied to the pressing day-to-day problems. Adequate time and resources
have not been available for development and routine application of well
developed precedents of case law that would provide for the consistent
application of legal precedent in enforcement of environmental laws and
regulations.
Legal Services Recommendations
It is recommended that the new organization include an adequate and
qualified legal staff, responsible to both the Attorney General and the
Director of the environmental protection organization. This legal staff
should be assigned responsibility for providing legal counsel to support
the organization's activities related to hearings, litigation, and other
Judicial proceedings. Legal representation should be considered for as-
signment as well to each district office to provide local legal support
and services, coordinated by the central legal staff.
48
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to
• Organization
Class
• Level
Skills
• Incumbent name
• Pay
. Job history
Air
Solid waste
Water supply
Water treatment
Other
Budget
• Grants
• Fees
- Fines
1
Financial
Status
File
• Grant
• Contract
1
Location
Control
- Funds
• Allocated
• Spent
I
1
Process
• Technology
L Specs.
- Plans/progress
Source
• Input
analysis
Physical/
chemistry
Output
Analysis
Volume
Reported
Organizational
Character
• Geographic
State
District
County
Zip
Census
Tract
•Public — related to
county,
region,
interstate,
population/
demography
- Basin/region ^- Private — related to
corporate,
History
Status
SIC
code
number.
employees
and
sales
FIGURE 9 DATA SUPPORT SYSTEM FILE STRUCTURE
-------
VI THE NEW ORGANIZATION CONCEPT
A detailed analysis of the functions performed by the organizational
components encompassing the environmental activities of the State of Ohio
revealed the existence of several dysfunctional areas. Many specific in-
stances of situations requiring attention can be cited, but the following
appeared to be the most representative, salient factors with significance
for organizational design:
• Wide dispersion of planning functions.
• Overlap and redundancy in technical operations.
• Complex intergovernmental transactions and processing.
• A personnel structure lacking logicality, equity, and con-
sistency.
• Inadequate manpower planning and development programs.
• Rudimentary and dispersed information systems.
• Insufficient legal support.
These general conclusions were reached after extensive analysis of cur-
rent organization charts, individual position descriptions, search of
existing records, and intensive interviews and discussions with key manage-
ment personnel in the Department of Health and Natural Resources.
Based on the above analysis, the findings and recommendations dis-
cussed in detail in Chapter V were developed, and a new organizational
concept was designed to remedy the structural problems identified during
the diagnostic phase of the study. A discussion of the assumptions, cri-
teria, and methodology underlying the design effort are covered in Chap-
ter IV, which deals with design considerations. The final results of the
design effort are presented in this chapter.
Goals and Objectives
The attainment of an organization's purpose depends on:
• The ability to translate its general philosophy and values
into aims that are viewed by its diverse publics as appropriate.
51
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• A structure that responds effectively and efficiently to ex-
ternal and internal conditions.
• A structure that responds effectively and efficiently to ex-
ternal and internal conditions.
• A management structure that provides guidance and incentives
for the membership to contribute their imagination, skills,
and commitment.
• An organizational environment that provides challenge, work
satisfaction, and persona^ growth. Each of these factors plays
an important part in the overall integration and strength of an
organization.
In developing the framework for the goals and objectives of the pro-
posed new organization for the State of Ohio, SRI drew upon the above
principles as a basic foundation. The work of the Citizens Task Force
on Environmental Protection served as a starting point for the project
team's deliberations and strongly influenced the thinking that led to the
development of the organization design. The contributions of each of the
project work groups were also a critical source of input into the problem-
solving process. Discussions were held with individuals from the dif-
ferent departments within the State government in order to provide a
broad spectrum of viewpoints and interests in the hope that a reasonable
consensus on environmental objectives would be reached. The SRI staff
maintained communications with individuals and groups representing uni-
versity, industry, conservation, and local government viewpoints to widen
the scope of impact on the study. Many suggestions and ideas incorporated
in the statement of objectives were derived from these diverse sources.
The goals and objectives for the proposed new organizational entity
are stated as follows:
(1) General Policy
(a) Establish State environmental quality standards for air,
water, and land that meet or exceed Federal specifica-
tions, criteria, and implementation schedules.
(b) Establish a comprehensive environmental planning function
that can study and assess significant trends in both the
external and internal milieu of the organization and
thereby provide effective response to change through the
medium of new program development for the conservation,
protection, and upgrading of the State's environmental
resources.
52
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(c) Establish and maintain active public participation in
improving the State's environmental quality.
(d) Establish a system of reciprocal intergovernmental co-
operation to prevent discharges, emissions, or pollutants
from causing degradation to the environment or waters of
neighboring or adjacent jurisdictions; develop and main-
tain a cooperative relationship between the State environ-
mental protection unit and local governmental entities to
more effectively implement programs involving the abate-
ment of air, water, and solid waste pollution, protection
of domestic water supplies, and management of environ-
mental quality.
(e) Perform the duties and responsibilities delegated to the
State environmental protection unit and stand ready to
assume other responsibilities in new areas of environ-
mental concern that may be assigned through future legis-
lative action.
(2) Operational
(a) Provide for the maintenance and protection of the State's
environmental resources by establishing appropriate stan-
dards, and ensure compliance to the environmental rules
and regulations by maintaining an effective surveillance
and monitoring system.
(b) Control sources of emissions and discharges by implement-
ing new technology and systematically upgrading the present
environmental protection techniques and operations.
(c) Provide full environmental protection coverage to meet the
varying needs of each section of the State by establishing
regional organizational units to perform the necessary
technical services in cooperation with local governmental
entities.
(d) Establish a system of controls, permits, and certifica-
tions for the authorized use of the State's environmental
resources that will ensure compliance with the State's
law, standards, and regulations by all users.
53
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(3) Administrative and Personnel
(a) Establish an administrative system that would provide
executive direction and support to the operating ele-
ments of the organization, set priorities, allocate
resources for the attainment of objectives, and maintain
control over the use of human, technical, and financial
resources.
(b) Maintain a professional organization by attracting and
retaining competent personnel and by providing job and
career continuity insulated from policy and political
changes.
(c) Develop a professional organizational climate that is
innovative and challenging and that gains the commitment
of the membership by providing personal development,
career growth, and opportunity to achieve and accomplish.
(d) Develop a systematic program for continuously assessing
State needs for skilled manpower to staff local and pri-
vate entities engaged in environmental activities.
(e) Encourage the growth of a State manpower pool with ap-
propriate skills to meet the environmental technology
and operations requirements of the State by increasing
educational and training opportunities within the State.
The New Organization Structure
Based on the findings and recommendations derived from the analysis
of operations within the two departments responsible for protection of
the environment in the State of Ohio, a new organizational concept was
proposed that would combine components from each of the departments into
a new organizational entity. In conformance with the principles stressed
throughout this report, the structure of the new organization was designed
to support the goals and objectives enumerated in the preceding section
of this chapter. The structural form chosen for the new concept is a
derivative of the functional specialization model discussed previously
in Chapter IV.
The organizing principle underlying the functional form of structure
is to group similar operational activities under such functional headings
as surveillance, technical operations, finance and administration, etc.,
which report to a centrally placed executive, in this instance, the Deputy
54
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Director. The structural relationships characteristic of this organiza-
tional form are shown in Figure 10, and its essential strengths and weak-
nesses are summarized in Chapter IV.
The individual components that are included within the framework of
the new organization are described below.
Executive Functions
Executive functions are performed by the Director and Deputy Director,
assisted and supported by an office staff of two administrative assistants
and four secretaries.
The primary responsibility of the Director is to guide and assist
the Governor and the State Legislature in developing the basic depart-
mental objectives. He is also responsible for developing the policies
to regulate organization-wide operational processes, methods, and proce-
dures. As chief executive officer of the department, he coordinates the
activities of the Environmental Planning Service, the Public Interest
Center, and the Legal Counsel and Representation, all of which report
directly to him. Overall, the Director is fully accountable to the Gov-
ernor and the people of the State of Ohio for the State's posture and
position with respect to the environment questions.
The Deputy Director collaborates with the Director in developing the
organization's policies, objectives, and goals, and he assumes respon-
sibility for coordinating the activities of the six operating divisions
that report directly to him. In his capacity as chief operating officer,
he establishes the operating goals, methods, and procedures to ensure
maximum operating efficiency and services commensurate with the best in-
terests of the people of the State of Ohio. In addition, he supervises
the Program Monitoring Staff, who control the processing of categorical
resource programs through the various components of the organization and
who assess the accomplishments of the organization.
Environmental Planning Service
The Environmental Planning Service develops and maintains long range
strategic plans for the protection and improvement of the environment
within the State. Such plans must also be systematically appraised to
ascertain how they impact or are affected by other interstate and inter-
national programs and plans. Additional services provided by this unit
55
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Legal Counsel
and
Representation
Program
Monitoring
Staff
—
Director
\
Deputy
Director
tm
•
Public
Interest
Center
Environmental
Planning
Service
1
Information and
Procedures
Services
1 1
Surveillance
Administration
r~
Field
Surveillance
Operations
Finance and
Administration
Operations
1
District
Administration
i
1
Technical
Services
•
1 1
Intergovernmental
Administration
Field
Technical
Services
Regional/Local
Intergovernment
Administration
Authorization
and Compliance
Operations
FIGURE 10 RECOMMENDED ORGANIZATION
56
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include: developing and recommending standards for maintaining environ-
mental quality; drafting legislation required to support such plans and
standards; maintaining cognizance of research and development activities
related to environmental improvement; supporting and maintaining continu-
ing economic cost-benefit analyses of environmental impacts and improve-
ments; and defining missions, objectives, and organizational relation-
ships required to achieve such plans.
The Environmental Planning Service is a staff function that reports
directly to the Director of the department. The proposed structure for
this function appears in Figure 11, which shows the specialized units
with the following capabilities:
• Resource Plans Development—This unit is concerned with evaluat-
ing basic data, establishing baselines for setting standards
and criteria, assessing long term environmental quality impli-
cations of prospective actions, initiating new programs in re-
source evaluation, preparing and reviewing basin and metropolitan/
regional water quality management plans, and providing support
to other elements. In addition, this unit is responsible for
formulating criteria for program evaluation.
• Intergovernmental Planning—This unit reviews, assesses, and
evaluates pending and enacted State and federal legislation;
develops needs and plans for financing; identifies problems
and analyzes solutions; recommends State policy for local gov-
ernmental entities; and proposes criteria for multijurisdic-
tional coordination and development.
Environmental
Planning
Services
1 1
Resource , A
Plans lnte
Development
, Socio-
rgovernmental Ec(jnomjc
Planning p|anning
1
Research and
Development
Planning
Manpower
Planning
FIGURE 11 STRATEGIC PLANNING ORGANIZATIONAL SCHEME
57
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• Socioeconomic Planning—This unit is responsible for maintain-
ing information regarding socioeconomic factors relative to
environmental planning, defining guidelines for including en-
vironmental considerations in development planning, evaluating
the impact of alternative control strategies upon socioeconomic
factors, and developing methods and procedures to measure the
relative costs and benefits of prospective measures to improve
environmental quality.
• Research and Development Planning—This unit is responsible for
monitoring the state of the art and facilitating technology
transfer, assessing the\environmental effects of technological
changes, establishing research into particular environmental
quality factors, and serving as a focal point for coordination
and dissemination of environmental research among researchers
in Ohio.
• Manpower Planning—This unit is responsible for forecasting man-
power needs relative to environmental programs, defining skill
requirements and recommending training qualifications require-
ments, recommending manpower development programs, and coordinat-
ing manpower planning requirements with statewide manpower re-
sources through programs such as CAMPS.
The Environmental Planning Service provides the department with the
means of anticipating and controlling the rate of change through the use
of systematic planning procedures. Innovation and new program develop-
ment can be introduced with a minimum of disruption to on-going activities.
The inclusion of a strategic planning capability, in addition to increas-
ing flexibility and responsiveness, makes possible management by objectives
and, with it, systematic evaluation of all aspects of departmental opera-
tions.
Public Interest Center
The Public Interest Center reports directly to the Director of the
environmental protection organization. The primary concern of this func-
tion is to maintain two-way communication between the department and
interested groups and individuals. As part of its responsibilities, this
activity would be sufficiently staffed to be able to quickly and effi-
ciently answer inquiries by the general public about environmental matters.
It would also maintain close liaison relationships within the department
to inform the appropriate organizational component of problems and
58
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situations identified by the public. The Public Interest Center would
be responsible for developing and maintaining a public communication
program on activities of the organization and matters of environmental
concern.
In addition to its communication and public participatory functions,
the Public Interest Center would also play a vital role in environmental
protection education. The Center would provide educational resource
materials to support the development of educational programs by private
and public groups and institutions. One of its vital functions would
be to encourage and promote educational training, and retraining programs
and curricula to meet statewide manpower training needs. The organiza-
tional schematic of the Public Interest Center is shown in Figure 12.
Director
Environmental
Protection
Organization
Public
Interest
Center
_L
Public
Communication
Section
Public
Participation
Section
Public
Education
Section
Manpower
Resources
Development
Section
Deputy
Director
FIGURE 12 PUBLIC INTEREST CENTER
Legal Counsel and Representation
Legal Counsel and Representation is comprised of a staff of legal
professionals who provide the environmental protection organization with
legal counsel and appearance for all administrative hearings and adjudi-
cations that affect the legal responsibilities of the organization. These
services include the handling of all appeals from actions of the organiza-
tion before administrative tribunals and other judiciary bodies. The
legal staff also renders legal counsel and advice on formal and informal
rules and procedures with respect to their legal and procedural suffi-
ciency. The overall aim of the staff is to assist and support the en-
vironmental protection organization in maintaining a strong and effective
59
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enforcement and compliance posture with respect to matters under its
jurisdiction. Successful conduct of environmental programs also requires
representation and legal support for all organizational activities and
functions concerned with regulation and enforcement of environmental
standards in addition to the customary executive agency representation.
The specific responsibilities and activities of the legal staff are
listed below.
• It prepares the environmental protection organization's legal
cases with respect to administrative hearings adjudicating
permits, which the organization has the authority to issue or
deny,
• It appears for the environmental protection organization in
all such cases.
• It prepares the environmental protection organization and/or
the State's cases in actions with respect to omissions or fail-
ures to file applications for permits and, at the request of
the Director of the organization, brings the action and provides
legal representation in the case.
• It prepares the environmental protection organization and/or
State's case for violations of permit conditions and, at the re-
quest of the Director, files such legal action as is necessary
and appropriate and provides legal representation for the Di-
rector in such actions.
• It develops rules and procedures for use by the Authorization
and Compliance component in its administrative proceedings. It
drafts standard forms, contracts, agreements and other instru-
ments in support of the Intergovernmental Administration com-
ponent's activities.
• It prepares the environmental protection organization's legal
case for cases of administrative and judicial appeals, and it
provides legal representation for the Director and the organi-
zation in all such cases.
• It provides legislative research, drafting, and analysis ser-
vices to other components of the environmental protection or-
ganization with respect to federal, State and local legislation,
rules and regulations, and guidelines material.
• It advises the Director, or his designee, and other heads of
the organization's components, as to the legal sufficiency of
policies, .standards, and courses of action.
60
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It provides general guidance material to Surveillance Adminis-
tration and to Technical Services with respect to procedures
to be used in gathering and analyzing technical data that is
to be used, or may be used, as evidence in administrative and/or
legal proceedings.
It approves the form of legal instruments, contracts, grants,
and other agreements to be executed between the environmental
protection organization and State, federal, and local/regional
governments and entities, and private consultants.
It provides legal assistance and counsel in negotiations be-
tween the environmental protection organization and persons or
governmental entities leading to compliance with environmental
protection standards.
It prepares the legal research necessary to support the organi-
zation's legal positions with respect to matters within its
jurisdiction.
It maintains constant surveillance and analysis of current case
and statutory law, and it prepares opinions on the effects of
changing case law on the policies, procedures, standards, etc.,
of the organization when the cases so warrant.
Program Monitoring Staff
The Program Monitoring Staff reports directly to the Deputy Director
and is responsible for maintaining schedules for processing of all cate-
gorical program work in the various components of the organization. This
unit is necessary because federal programs are presently funded in terms
of resource categories. For effective control, identification of specific
elements of a total program is often required. This can be accomplished
by maintaining status records of work in progress for all categorical pro-
grams. The staff also serves as expediters and negotiators on questions
of schedule conflict and adjustment. The work of the staff will be fa-
cilitated by the maintenance of schedules, logs, and records pertaining
to significant inquiries or problems relating to categorical projects and
programs. To aid the Deputy Director in coordinating and assessing the
operational performance of the organization, the Program Monitoring Staff
keeps him constantly apprised of any significant problems that arise in
regard to accomplishment of goals, schedules, work loads and program re-
quirements, and decisions between components of the organization. Fig-
ure 13 shows a diagram of the Program Monitoring Staff, depicting the
subunits and showing relationships with the rest of the organization.
61
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FIGURE 13 PROGRAM MONITORING ORGANIZATION
Information and Procedures Services
Information and Procedures Services is one of the six operational
components reporting directly to the Deputy Director. The basic objec-
tive of this function is to provide information support services to all
functional components of the organization. A significant aspect of this
work would be the development and implementation of a comprehensive, inte-
grated environmental data base. This projected system would be designed
to serve the interfunctional data needs with respect to contributing
sources and the general environmental situation for all resources, i.e.,
air, water, and solid waste. This service would also be responsible for
processing and maintaining technical data for Surveillance Administration
and for Technical Services. To control these activities, the unit will
be responsible for developing uniform user procedures and providing user
orientation and training.
A capability would be developed and maintained for designing and im-
plementing all automated data collection, retrieval, and analytical sys-
tems, including program routines, to accomplish the technical and manage-
ment information needs of the agency. Also within its scope is the
responsibility for designing and implementing a statewide system of data
communication and voice communication to serve the various elements of
the agency. It would also be responsible for providing a records reten-
tion and records management system for the organization. An organiza-
tional schematic is shown in Figure 14.
62
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Systems
Analysis and
Design
Information and
Procedures
Services
Procedures
Development and
Records
Management
Communications
Network
Operations
Data
Collection and
Processing
FIGURE 14 INFORMATION AND PROCEDURES ORGANIZATION
Surveillance Administration
Surveillance Administration performs one of the critical operations
in the conduct of the environmental protection mission. It has the re-
sponsibility for maintaining a consistent and up-to-date picture of the
total environment situation in the State. To carry out this mandate, the
division is separated into two distinctly different operations: a head-
quarters unit, and field surveillance services performed in the district
offices, as shown in Figure 15.
Surveillance
Administration
1 1
Surveillance
Planning
Surveillance
Operations
1 1
District
Offices
Laboratory and
Equipment
Support
Emergency
Procedures and
Operations
Inspection
Monitoring
Lab and equipment
Source and supply inventory
Data conversion
FIGURE 15 SURVEILLANCE ORGANIZATION
63
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The headquarters staff maintains cognizance over all surveillance
activities in the organization. In addition to providing administration
services for the division, the staff is responsible for developing plans
and procedures for collecting surveillance data for displaying and report-
ing purposes. It is also responsible for administering, scheduling, and
supervising field operations. In this capacity, the staff receives and
assigns for investigation all complaints emanating from the different
parts of the State. It is responsible for developing and implementing
emergency procedures when critical situations occur. The division also
supports the enforcement actions carried out by other operating components.
The headquarters staff is made up of the following sections:
• Surveillance Planning—This section is responsible for establish-
ing surveillance objectives for each resource category and site,
and it translates these objectives into program objectives. It
designs surveillance techniques, procedures, equipment require-
ments, and reporting systems to achieve program objectives. A
key duty is to communicate changes in recommended or approved
programs to operating components and to maintain an accurate
documentation service. It proposes the guidelines and standards
for the operation and maintenance of surveillance activities
performed by municipal and other public agencies. It works closely
with Information and Procedures Services to design and develop
techniques for displaying and reporting environmental information.
• Surveillance Operations—This section analyzes existing and pro-
posed programs to identify facilities and personnel required to
accomplish program objectives, and"it allocates resources when
appropriate and within established priorities. It also establishes
field and laboratory assignments and schedules and monitors the
results.
• Laboratory and Equipment Support—This section develops the plans
and specifications for laboratory facilities and equipment to
meet existing or projected needs of the different surveillance
programs. The certification of facilities, equipment, personnel,
and quality standards for conducting analytic processes fall
within its purview. It also develops the procedures and tech-
niques used is sample gathering for laboratory analysis, and it
maintains the standards necessary to support testimonial evidence.
• Emergency Procedures and Operations—This section develops, docu-
ments, and communicates comprehensive plans for prompt response
to environmental incidents that might affect public health or
constitute a substantial threat to the environment. In an actual
emergency, this section initiates emergency actions and draws on
64
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whatever State and local government resources are necessary to
protect public health, safety, and environmental integrity.
Field Surveillance Operations maintains continuous surveillance over
all water supplies, water pollution, air pollution, and solid waste sources
and sites within an assigned area. It also samples, analyzes, and reports
on the quality and quantity of water supplies, water and air pollution
emissions and effluents, and solid waste disposal operations, and it main-
tains the laboratory and equipment to support these activities. In ad-
dition to investigating all complaints involving sources, this function
reports on all aspects of the environmental situation in its territory.
It is also responsible for monitoring the progress and quality of con-
struction work on new or changed environmental facilities in its territory.
The overall field operation is composed of the following sections:
• Field Inspection Operations—This section performs the routine
and special inspections of all assigned sources and sites of water
supply, water pollution, air pollution, and waste disposal, using
specified procedures and schedules. Its responsibilities include
collecting samples of emissions, effluent:, and in-process materials
either for analysis on-site or for transmission to designated
laboratories. It makes comprehensive technical reports of the
findings of inspections and sample analyses in an appropriate
format and transmits this data to the designated data collection
agency or user. It is also responsible for inspections and re-
ports regarding the status, progress, and quality of construction
of environmental facilities when requested to do so by Authoriza-
tion and Compliance Operations. Surveillance activities performed
by municipal and other public agencies are periodically evaluated
for compliance with the guidelines established by this agency.
. Field Monitoring Operations—This section installs, operates, and
maintains automated continuous monitoring equipment to measure
environmental quality at designated sites within an assigned ter-
ritory. These sites may be fixed or mobile.
• Field Laboratory and Equipment Operations—This section installs,
operates, and maintains analytical laboratories that perform
qualitative and quantitative analyses of samples submitted by
Field Inspection Operations or other agencies. The technical
reports of these findings are then transmitted to the appropriate
agency or user. This section is responsible for maintaining per-
formance standards for equipment and personnel both for certifica-
tion and for providing data to be used as evidence in hearings and
legal actions. Also, it maintains complete and accurate records
of all laboratory procedures and findings, documented as to source
and site.
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Field Source and Supply Inventory Operations—This section plans,
schedules, and conducts inventory studies of underground waters,
surface waters, solid waste activities, and air quality within
the guidelines developed by the Environmental Planning Service
and reports the findings to the requesting agency or organizational
component.
Field Clerical and Data Conversion Operations—This section pro-
vides stenographic and clerical support for all field surveillance
operations in the assigned territory. These services include
correspondence, repc-Vt transcription, and record maintenance.
This section also is responsible for providing data conversion/
data input operations under procedures specified by Field Sur-
veillance Operations and Information and Procedures Services.
The unit maintains personnel schedules and transportation facilities
for all personnel assigned to the Field Surveillance Operation in
a designated territory.
Technical Services
Technical Services is an operational division that reports directly
to the Deputy Director. Its primary mission is to plan, design, and
implement technical programs to achieve environmental quality standards
in a cost-effective manner while operating within specified technological
and economic restraints. It provides the environmental organization with
the major part of its technical expertise and engineering capability.
Divisional services are performed by a well rounded headquarters staff
and a small field contingent located in each of the district offices.
Organizational relationships are delineated in Figure 16.
The headquarters staff maintains cognizance over all engineering ac-
tivities in the organization. The staff offers engineering counsel and
consultation to public and private agencies on technical problems relating
to the environment. It maintains records relating to past equipment per-
formance and projects statistics on future performance. Technical Services
reviews all proposals and plans for'improvements in control facilities,
siting, or operations, and it recommends conditions or variances in
authorizations to construct or modify and permits to operate. The head-
quarters staff consists of the following operational sections:
• Impact Evaluation and Planning—This section converts data received
from Surveillance Administration into a continuously updated in-
ventory of sources and ambient conditions in the State. Based on
this data base, the section generates a forecast of probable en-
vironmental quality levels that may result from man-made changes
66
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1
Impact
Evaluation and
Planning
Technical
Services
1
Permit
Review and
Processing
1
Technical
Liaison and
Consultation
Technical District
Support offices
Services
• Applications
review
• Consultation
• Support
FIGURE 16 TECHNICAL SERVICES ORGANIZATION
or natural fluctuations in seasonal phenomena. It also reviews
impact statements and assesses their accuracy with respect to
known and foreseen changes in environmental conditions. When
declarations of emergencyxare contemplated, this unit serves as
a technical consultant,
• Permit Review and Processing—This section is responsible for re-
viewing the engineering plans for proposed environmental facilities,
including feasibility studies on environmental standards, time
schedules, and social and economic impact of the construction on
federal, State, and local interests. The section draws support
from other sections within Technical Services and coordinates its
efforts with external agencies and other divisions in the organiza-
tion.
• Technical Liaison and Consultation—This section maintains an
experienced and highly qualified engineering staff to provide
counsel and advice to public and private agencies in the planning
and design of environmental facilities. It also engages in public
discussion on questions of environmental significance and provides
objective evaluation of alternatives that are made available to
all constituencies.
• Technical Support Services—This section provides and maintains a
technical library of documents, books, journals, and reports and
other technical reference material that may be required to sup-
port the on-going work. It also supplies auxiliary services,
such as drafting, art work, and other support functions related
to report production. It is responsible for providing clerical,
stenographic, and record maintenance services.
67
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Field Technical Services is responsible for providing technical
support for all environmental problems occurring within an assigned
territory. These services include initial review of applications for
authorization to construct or modify facilities and permits to operate;
recommendations issued from the field are forwarded to headquarters for
appropriate action. A significant part of the field engineering work
load consists of rendering assistance to the surveillance and enforcement
functions in the performance of their duties. This involves a consider-
able amount of liaison and coordination effort. Technical support and
consultation are also furnished to local agencies whenever their con-
struction programs involve questions of siting and environmental impact.
All field operations are centered in the district offices.
Finance and Administrative Operations
Finance and Administrative Operations is responsible for controlling
and accounting for the fiscal resources and assets of the State and other
sources as they are applied to environmental programs. This division
develops a fiscal plan to match the environmental plans of the organiza-
tion. In performing the controlling function, the division administers
the fiscal budget and provides responsibility accounting to the operations
and services. Other financial support furnished includes the administra-
tion of executive budget funds, tax exempt statutes applying to environ-
mental improvements, revenue bonds, and the management of the purchasing
and contract functions. Organizational relationships are shown in
Figure 17.
Finance and
Administration
Operations
Financial
Services
Personnel
Administration
District
Office
Management
Procurement
and Contract
Administration
FIGURE 17 FINANCE AND ADMINISTRATION ORGANIZATION
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The personnel management function is a concomitant responsibility
assigned to Finance and Administration Operations that includes recruiting,
placement, compensation, training and development, and other programs re-
lated to attracting and retaining a competent work force. Manpower plan-
ning, however, has been placed in the Environmental Planning Service to
facilitate the integration of all planning functions. Close liaison be-
tween the two operations is required on all matters pertaining to human
resource utilization.
Finance and Administration also serves an important administrative
function in the district offices. Under the proposed new organizational
concept, this division would be responsible for supplying field personnel
to service the administrative needs of the district offices. It must be
emphasized, however, that administrative field personnel would have no
jurisdiction over field technicians assigned to district offices from the
other operating divisions. These individuals would report to their own
field supervisors who, in turn, would report to their superiors in
headquarters. All technical direction in the field would come from
Surveillance, Technical Services, and Intergovernmental Administration.
These specific organizational relationships are shown in Figure 18.
1
i
1
1
FIELD
SURVEILLANCE
i
T"
1
f ' f 1
DISTRICT
ADMINISTRATI
1
J
FIELD
TECHNICAL IN
SERVICES
ON
1
1
k
FIELD
TERGOVERNMENTAL
RELATIONS
FIGURE 18 FOUR DISTRICT OFFICES
District Administration would be primarily concerned with facilities
management and "housekeeping" duties. Its responsibility would be to
keep the office running smoothly and take care of all nontechnical details
to enable field personnel to devote as much time as possible to technical
problems. In addition, the field administrator would serve as the organ-
ization spokesman in the field and would route calls, inquiries, and in-
formation to the appropriate individuals. He may be called upon to
represent the organization at local public functions to explain the organ-
ization's point of view or posture on certain issues.
69
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Intergovernmental Administration
Intergovernmental Administration as a structural component does not
exist in the present organization. This new division has been developed
to fill a void in present operations, i.e., the lack of a specific entity
charged with the responsibility for integrating and coordinating all
aspects of intergovernmental relations. Under this new concept, federal
State, and local government activities are centralized to provide improved
management control, to establish specific group and individual account-
ability, and to develop guidelines for evaluating the effectiveness of
this function in meeting its goals and objectives.
The increasing importance of intergovernmental coordination in coping
with the problems of environmental protection requires improved planning,
communication, and decision-making. The new organization concept contends
with these realities by establishing an intergovernmental planning section
in the central planning function. This added capability provides the or-
ganization with the means for responding flexibly to the changing charac-
ter of new legislation and shifts in national and State priorities.
Intergovernmental Administration has been designed to achieve the
following organizational ojectives:
• To assure that State and federal policies, laws, and regula-
tions are effectively executed by local and regional govern-
ments and entities within the State of Ohio.
• To represent the State on interstate and international
Commissions.
• To coordinate the policies and activities of the State's
environmental protection organization with other State
agencies and programs.
• To provide a single point of contact with respect to State,
federal, and local programs, policies, and criteria.
• To coordinate and rationalize State and federal funding of
environmental programs and projects of local/regional govern-
ments and units within the State of Ohio.
Figure 19 shows the structure proposed for the Intergovernmental
Administration organization in detail, indicating the sections and field
units that would be included in the operation. Figures 20 to 24 are
descriptions of each of the three sections and indicate the kinds of
interactions and activities that are likely to occur. A more complete
summary of the responsibilities and activities of each of the sections
is described below.
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Superintendent
State/Local
Administration
Intergovernmental
Administration
Superintendent
State/Federal
Administration
1 1
N.E. District
Intergovernmental
Administration
N.W. District
Intergovernmental
Administration
S.W. District
Intergovernmental
Administration
1
Superintendent
Interstate/
International
Coordination
1
S.E. District
Intergovernmental
Administration
FIGURE 19 INTERGOVERNMENTAL ORGANIZATION
Intergovernmental
Administration
Supervisor
State/Local
Administration
1
Soil
and Water
Conservation
Commission
I I
Public
Health
Council
Water
Commission
Water and
Sewer
Rotary
Commission
i
Public
Utilities
Commission
Water
Development
Authority
NOTE: Under the provisions of Amended Substitute S.B. 397, the Ohio Water Commission
wes abolished. The establishment of the Ohio EPA necessitates interfaces with
sever*) other State agencies, including the parent organizations and newly created
commissions.
FIGURE 20 STATE/LOCAL ADMINISTRATION SECTION—STATE AGENCIES
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Intergovernmental Administration
Supervisor State/Local Administration
| District Offices
-| Counties (88)
Municipalities
- • 5000 or more population (194)
• Under 5000 population {739}
Soil and Water Conservation
Districts (90)
Conservancy Districts (23)
Air Quality Authorities (14)
Regional Water and Sewer
Districts (5)
Watershed Districts (1)
Sanitary Districts (2)
-
-
J
FIGURE 21 STATE/LOCAL ADMINISTRATION SECTION—LOCAL GOVERNMENTS
1
Appalachian
Regional
Commission
Intergovernmental
Administration
I
Supervisor
State/Federal
Administration
1
1 1
Cn rf •ESS?
ngmeers Agency
Soil
Conservation
Service
1
Housing an
Urban
Developmer
Economic
Development
Administration
1
d Farmers
Home
it Administration
FIGURE 22 STATE/FEDERAL ADMINISTRATION SECTION
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Intergovernmental
Administration
J_
Supervisor
Interstate/International
Coordination Section
Enforcement
Conferences
FIGURE 23 INTERSTATE/INTERNATIONAL COORDINATION SECTION
i.
l_
Program
Monitoring
Staff
S X
Operating
Organizational
Components
«t | Program
>L i (Requirements)
S. \ ' ^..., -J
\V_L
^
1
1
1
1
J
+
[ Grant
I Applications!
Intergovernmental
Administration
1
'"State and^
Federal
Policy,
Standards,
Programs \
j
t
C Local A
Grant
\Applicationsj
Environmental Protection Organization
T
FIGURE 24 GENERAL INTERRELATIONSHIPS
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State/Local Administration—This section reviews all local/
regional, State, and federal grant applications in the environ-
mental area for compliance with institutional policies and
standards* It also coordinates environmental protection with
review and approval of federal grant applications by local/
regional governments and entities . It reviews the performance
of local/regional governments and entities and certifies them
to undertake specific tasks. It prepares contracts and agree-
ments with local/regional governments and entities to carry-
out State and federal programs. It supervises and coordinates
intergovernmental\field services. Its other auxiliary services
and activities are as follows:
- Transmits State and federal policies, laws, and regula-
tions to local/regional governmental agencies and sup-
ports field services' programs of implementation.
- Assists local/regional governments and entities in the
development of grant applications for projects and pro-
grams and coordinates these activities with regional,
State, and federal agencies.
- Develops information on the impact of current State and
federal programs on local/regional governments and pro-
vides this information to Intergovernmental Planning.
- Obtains the view and position of local/regional units of
government on proposed and pending State and federal legis-
lation, regulations, and guidelines, and it transmits this
information to planning for development of State policy,
plans, and standards.
- Maintains schedules of required governmental approvals
and institutional transactions with respect to projects
and programs undertaken by local/regional units of govern-
ment for air and water quality, solid waste disposal, and
water supply development; this includes the coordination
and timing of any permits and compliance authorizations in
conjunction with other institutional transactions.
- Coordinates local/regional governmental review of environ-
mental impact statements and actions requiring approval
through the clearinghouse procedures (OMB circular A-95).
- Represents Ohio at federal enforcement conferences, in
cooperation with State/Federal Administration.
- Maintains a continuous review of local/regional government
legislation and regulations to ensure its conformity to
State policies, guidelines, and standards in matters of
74
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environmental protection; in this capacity, it assists
these agencies in developing, enacting, or promulgating
new legislation and regulations.
- Reviews funding and other terms of local/regional con-
tracts and grants on programs where State and/or federal
funds are involved to ensure compliance with the policies
and standards established by Intergovernmental Planning.
- Develops and maintains, with the assistance of the assigned
Assistant Attorney General, standard agreement and contract
forms of general applicability for use by local/regional
units of government in their transactions with consultants,
the State and federal governments,and other local units of
government.
- Gathers information and data on local/regional governmental
entities, including relevant mailing and contact lists, and
provides this material to Information and Procedures Services.
State/Federal Administration—This section forwards all grant
applications to the appropriate federal agency and receives
grant approvals. It is responsible for ensuring that multi-
agency projects and programs are coordinated with the State,
local government, and federal agencies involved. It monitors
developing federal program requirements with respect to
intergovernmental issues and State performance of environ-
mental protection matters; in this capacity, any necessary
approvals of State policies and procedures are obtained from
the appropriate federal agency. The following activities are
also within its scope of responsibilities:
- Identifies funding sources for State and local programs.
- Forwards State certifications of federal permit applica-
tions (RAPP Program permit applications).
- Forwards all environmentally related actions requiring
State and local review and comment under A-95 (clearing-
house) procedures.
- Forwards all environmental impact comments for the environ-
mental protection organization.
- Receives federal notices with respect to noncompliance with
environmental laws and regulations, and coordinates internal
review of such notices. Transmits such notices to State/
Local Administration for appropriate actions with local/
regional units of government when applicable.
- In cooperation with State/Local Administration, it rep-
resents Ohio at .federal enforcement conferences.
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• The Interstate/International Coordination—This section is
charged with the following areas of responsibility:
- Attends meetings of interstate and international commissions
on environmental matters.
- Develops State policy and procedures for commission activ-
ities in cooperation with other components of the environ-
mental protection organization.
- Coordinates the State's provision of services, studies,
and other support, to commissions where it is in the
interests of the State or otherwise required by law.
- Maintains constant awareness of developing policies and
positions of the commissions and provides the information
developed to Intergovernmental Planning.
- Coordinates Ohio's activities directly with the activities
of other states on matters of mutual concern and cooperation
that are not covered by a formal interstate body.
- Coordinates the activities and programs of the commissions
and other states with other sections of Intergovernmental
Administration for their appropriate action with respect to
other government jurisdictions affected.
The field services arm of Intergovernmental Administration is super-
vised by State/Local Administration. Under this arrangement, field rep-
resentatives are located in each of the four district offices to assist
local/regional entities in the performance of their responsibilities for
State and federal environmental protection programs. It is expected that
field office personnel will exert a positive influence in helping to
rationalize the diverse programs that exist at the local level. Their
presence at the grass roots level will provided needed expertise and sup-
port in places where resources and skills are in short supply. Frequent
face-to-face contact between State and local representatives coping with
mutual problems in a collaborative mode should, over a period of time,
build a firm basis for reciprocal confidence and cooperation.
Because of the innovative aspects of Intergovernmental Administration,
a detailed summary of representative field activies is presented below.
« It assists local/regional entities in the preparation of
grant applications in the environmental area and assures that
they are in compliance with policies, standards, and guidelines
of the State with respect to institutional and intergovern-
mental criteria.
76
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It assists local/regional entitites in identifying appropriate
sources of funding for environmental protection projects and
programs and in obtaining a preliminary State and, if neces-
sary, federal review of feasibility and funding availability.
It surveys local/regional entities as to performance, capa-
bilities, authorities, and composition.
It identifies specific intergovernmental and/or institutional
problems for local/regional entities within the jurisdiction
of the field office and assists in anticipating solutions to
these problems in advance of their becoming crisis situations.
It prepares proposed findings and recommendations as to cer-
tification of local/regional entities to perform specified
environmentally related tasks delegated by the State, and
it forwards them to State/Local Administration for final
action.
It assists local/regional entitites in the enactment of leg-
islation and regulations that conform to State policy and
standards.
It assists in negotiations between local/regional entities
for the conduct of specific environmental projects and pro-
grams and negotiates directly on behalf of the organization
with local/regional entities for the conduct of State and/or
federal projects and programs, within policy and standards
established by the environmental protection organization,
and with the assistance of standard forms, agreements, con-
tracts, and other instruments.
It develops information on the impact of current State and
federal programs on local/regional units of government and
provides this information to State/Local Administration for
consolidation with information provided from other districts
and for the development of State policy, standards, and cri-
teria.
It transmits State and federal policies, standards, and pro-
cedures to local elected officials and administrators re-
sponsible for environmental affairs, and it interprets these
matters with these officials and administrators and identi-
fies any potential conflicts.
It obtains the views and positions of local/regional entities
of government on proposed and pending State and federal leg-
islation, regulations, and guidelines; it transmits this
information to State/Local Administration for consolidation
77
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with information provided from other districts and for the
development of State policy, standards, and criteria.
It performs special studies of local/regional entities and
their needs at the request of Intergovernmental Administra-
tion and in support of other programs of the environmental
protection organization.
It provides the local information required to establish and
maintain detailed schedules of required governmental approvals
and institutional transactions for individual projects and
programs being undertaken by local/regional units of govern-
ment; it keeps the local/regional unit informed of approval
status.
It obtains ordinances, regulations, and authorities of local/
regional entities of governments and their departments, agen-
cies, and commissions; it maintains a file of this material
in the district office and forwards copies of selected mate-
rial to State/Local Administration.
It maintains a continuous review of local/regional govern-
mental legislative and regulatory actions to assure that
they conform to State policies, standards, and guidelines
for environmental protection.
Authorization and Compliance Operations
Authorization and Compliance Operations is charged with the respon-
sibility for reviewing, processing, and approving all applications for
authority to construct or modify and for permits to operate all facilities
that impact on the environment. In addition, this function has the au-
thority to place conditions on its approval or to allow variances within
legal limits and valid circumstances. Renewal of such permits also falls
within its jurisdiction. Authorization and Compliance maintains a data
file containing information on the operating characteristics of facilities
and makes this data available to the public when requested to do so.
It issues licenses and certificates to operators, technicians, and
laboratory facilities. This responsibility is handled through the medium
of a testing program for individuals and an inspection program for veri-
fying the capabilities of different categories of facilities.
Authorization and Compliance should strive to negotiate voluntary
compliance with environmental standards whenever possible. In situations
of public interest and concern, this division prepares and conducts public
78
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hearings on standards, authorizations, and permits under its authority
for improvement actions. On those occasions when it is necessary to
undertake legal actions , Authorization and Compliance prepares and sup-
ports such legal actions and recommends fines, penalties, and assessments,
In all of its actions, the division should seek to achieve equitable en-
forcement of applicable standards, regulations, and laws. A description
of the organizational characteristics of Authorization and Compliance
Operations is shown in Figure 25. The division is composed of three
sections whose activities are summarized below:
. Registration and Permits—This section develops consistent
and equitable procedures and policies regarding the submis-
sion of applications, comprehensive reviews, and issuance
of authorizations to construct or modify and permits to
operate. It relies on advice and counsel from Technical
Services and Legal Counsel and Representation. The section
also administers an authorization and permit system within
the context of appropriate legislation, policies, and regu-
lations. It calls upon relevant service from the environ-
ment protection organization to ensure that conditions,
schedules, and variances are consistent with the standards
promulgated. It provides prompt service through sound ad-
ministrative procedures and controls, and at the same time,
it assures adequate review of applications and plans by all
appropriate components of the organization.
. Licensing and Certification—This section, with the advice
and assistance of technical personnel from other components,
develops examinations to support t-he licensing of operators
of technical equipment, treatment plants, and control de-
vices for protection of environmental quality—including air,
water supply, water treatment, and solid waste disposal.
Examinations are developed to support the certification of
laboratory technicians, professionals, and paraprofessionals
ration
ermits
Authorization
and Compliance
Operations
1
License and
Certificates
Hearing
Legal A
FIGURE 25 AUTHORIZATION AND COMPLIANCE ORGANIZATION
79
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engaged in the analysis and reporting of the components of
effluents, emissions, and ambient data that may be used in
administrative hearings and legal actions. Examinations
are also developed for the registration of employees en-
gaged in inspections and investigations of environmental
problems, sites, and sources. The unit maintains appro-
priate records and a system for collecting fees.
Hearings and Legal Actions—This section draws on the ad-
vice of legal counsel and technical support from components
of the environmental protection organization to develop the
testimony, exhibits-, and data relevant to administrative
hearings on standards, authorizations, and permits. It
supports the conduct of administrative hearings through
proper scheduling of hearings to assure prompt and effec-
tive response to the legal situation. In addition, it
records, transcribes, and publishes the testimony; and it
provides the hearing officer with other required support
services. It is responsible for maintaining appropriate
files and data on all actions and orders that emanate from
public hearings and litigation. It develops—with advice
of legal counsel—testimony, exhibits, and data to support
litigation in any court of jurisdiction in cases involving
the environmental protection organization. It records,
collects, and books all fines, penalties, and assessments
ordered by hearing officers or courts. It provides access
to proper legal authority for the issuance of warrants to
enter private property when such warrants are required for
the conduct of environmental protection organization in-
spections, investigations, and related actions.
Manpower and Staffing Requirements
The estimates of staff requirements presented here are based on the
implementation of the organization structure previously described; these
estimates provide reasonable approximations of the staff requirements
for the responsibilities assigned to those organizational components.
It is assumed that the degree of functional specialization on the one
hand and categorical resource generalization on the other hand can be
implemented as recommended in the body of this report. It should be
recognized that, particularly in the majority of headquarters positions,
some detailed adjustment of these staff projections may be required
during the process of implementation and organizational "shakedown" as
the actual work load for these recommended positions becomes clear as
80
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during individual familiarization with the revised procedures and prac-
tices necessary in a functionally specialized operation.
It should be fully recognized that the staffing estimates shown in
this section are projected from present program responsibilities and
operations. It is possible that the provisions of Amended Substitute
S.B. 397 and pending federal legislation may require considerable re-
evaluation of manpower needs. New technology and expanded program re-
quirements may necessitate upward revisions of this estimate. The or-
ganization structure recommended in this report has been designed to
accommodate these very real possibilities.
Insofar as possible, the position estimates described here are based
on approximations of work load extrapolated from observation of the pres-
ent organization, detailed task analyses (particularly in the Field Sur-
veillance and Technical Services Operations), and the background descrip-
tion of the division of responsibilities between the State organization
and local governmental entities, as described in the available resource
plans early in 1972.
New Functional Components
Several of the organizational components recommended in the new
organization structure do not have a corresponding entity or fully
staffed positions, as such, in the present organizational arrangements.
The staffing levels of these newly identified functions and organiza-
tional components are based on informed estimates of probable need for
such services tempered by what seems rational in the organization's
ability to attract personnel to these staff positions and to provide the
necessary budgetary funding to support them. These newly identified
positions are included in the following organizations:
• Information Systems—This component recognizes the need for
development of a comprehensive, integrated, and consistent
information system and procedures organization to serve the
needs of all environmental protective functions.
• Public Interest Center—This activity recognizes the need
for focus on public issues and concerns and the establish-
ment of a two-way communication channel with public con-
stituencies.
. Program Monitoring—No presently identified function exists
to fill this newly defined need for central program admin-
istration within the organization and for the provision of
a single source of categorical program status.
81
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• Intergovernmental Administration—A substantial increase
from presently identified staffing levels springs from the
need for consolidation and consistency in the servicing of
intergovernmental transactions for all resource categories.
• Authorization and Compliance—Again, a substantial increase
in presently identified staffing levels responds to the
need for a single, comprehensive function to discharge the
responsibilities now distributed among several boards and
to bring consistency to the overall enforcement activities.
• Legal Counsel and Representation—Estimated staffing levels
provide for what isNionsidered adequate legal support in the
development of case law and in the support of planned ap-
proaches to enforcement operations. It should be noted that
the Attorney General has the authority to obtain special
counsel for purposes of representation in certain circum-
stances. Specific case loads required to cope with its
authorization of air and water permits are unknown at this
time. Where fluctuations in case loads can be anticipated,
use of special counsel may be a more attractive alternative
than permanent lawyer staffing. The manpower estimates are
based on the need to provide legal support for routine func-
tions where the development and application of environment
standards are involved, in addition to the customary legal
support to executive branch agencies.
• Environmental Planning—Staffing levels in this function
recognize the expressed need for development of self-
sufficient planning operations with less dependency on
outside contracted services.
. Field Operations
The staffing of field operations is based on the organiza-
tion of four district offices. Each district office is ad-
ministered by a district administrator with appropriate
support staff, including supervisory and professional rep-
resentation from Field Surveillance, Field Technical Services,
and Field Intergovernmental Relations. Four district of-
fices, located in the four quadrants of the State, would
provide a reasonable base for such operations, balancing the
need for administrative services against the requirements
of travel time for those filed personnel required to have con-
tact with local governmental entities distributed across the
State. The professional and technical staff levels for Field
82
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Surveillance Operations and Field Technical Services have
been developed through the application of a mathematical
manpower planning model described in detail in a separate
working paper supplementing this report.
Estimated Staffing Requirements
The estimated staff manpower requirements shown in Table 2 are
based on detailed analyses of individual position functions, summarized
here from an earlier revised working draft. In total, these estimates
indicate an increase from a present staffing level of 238 positions to
a complement of 655 positions within a forecasted time span of approxi-
mately two to three years. The recruiting, training, development, and
orientation of approximately 400 additional staff members in the envi-
ronmental protective organization represent a substantial challenge to
the State of Ohio. No less important is the requirement for continuing
budgetary support for the level of operation that this implies.
Table 2
STAFF ESTIMATES
Full
Present Complement
Function Staff Organization
Director-Deputy Director 8
Environmental Planning Service 23 62
Surveillance Administration 62 211
Technical Services 89 138
Authorization and Compliance Operations 7 53
Legal Counsel and Representation 25
Intergovernmental Administration 7 40
Information and Procedures Services 37
Finance and Administration Operations 50 61
Program Monitoring Staff 10
Public Interest Center 10
Total 238 655
83
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From the detailed analysis contained in the working draft, a staff
position analysis has been developed and is shown in Table 3. This table
indicates a professional and technical staff component of 57 percent, ad-
ministrative and supervisory positions totaling 17 percent, and a cler-
ical and support staff of approximately 25 percent of the total of 655
staff positions.
Table 3
STAFF POSITION ANALYSIS
Administrative/ Professional/ Clerical
Director
Environmental
Planning Service
Legal Counsel and
Representation
Information and
Procedures Services
Surveillance
Administration
Finance and Adminis-
tration Operations
Technical
Services
Intergovernmental
Administration
Authorization and
Compliance Operations
Program Monitoring
Staff
Public Interest Center
Total staff
Percent of
total staff
Supervisory
2
9
8
7
30
15
18
10
5
4
4
112
17.1%
Technical
2
38
12
23
145
22
80
17
29
4
4
375
57.5%
Support
4
15
5
7
36
24
40
13
19
2
2
166
25.4%
Total
8
62
25
37
211
61
138
40
53
10
10
655
100.0%
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Testing the Organizational Design
To illustrate the intercomponent relationships of the new organiza-
tional design, it is helpful to trace certain selected examples of rela-
tively high volume activities and to briefly describe the functional re-
sponsibilities of each organizational component in processing these trans-
tions. Since the major work load of the organization, in terms of man-
years of applied effort, is concerned with detailed transactions involving
individual pollution sources in all resource categories, transactions de-
scribing source inventory registration, authorizations to construct or
modify facilities, permits to operate, and the routine surveillance and
compliance activities have been selected for detailed description.
In the concept of functional specialization and resource category
generalization on which this organizational structure is based, the func-
tional descriptions that follow are independent of resource categories;
i.e., these activities would be performed for transactions involving air
pollution sources, water pollution sources, water supply sources, or
solid waste disposal sites.
Source Inventory Registration
The series of activities shown in Figure 26 is initiated by the
distribution of registration forms from Authorization and Compliance
Operations to each known source within the State. The registration
forms, completed by the responsible individual of the source organiza-
tion, are returned to Field Technical Services having jurisdiction within
their district. Within established guidelines, either the Field Tech-
nical Services operation would compute the emission levels inherent in
the data provided by the source, or, if they are beyond guidelines, would
transmit the data that has been edited and confirmed at the field level
to the headquarters Technical Services operation. Technical Services
would then confirm the source inventory data calculations, transmit the
information to Authorization and Compliance, and record the essential
identification and inventory information on the comprehensive data base.
To close the loop, Authorization and Compliance would confirm the regis-
tration information directly to the registered source.
Authorization to Construct or Modify
In order to bring his source into compliance, a source applicant
would complete the necessary engineering plans, specifications, and other
relevant application requirements under competent technical and engineering
85
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Leyal Counsel
and
Representation
Program
Monitoring
Staff
— .
Director
Deputy
Director
-
"
Public
Interest
Center
Environmental
Planning
Service
00
O
JL
Information and
Procedures
Services
Surveillance
Administration
r~
Finance and
Administration
Operations
Technical
Services
I
intergovernmental
Administration
JL
Authorization
and Compliance
Operations
Field
Surveillance
Operations
Interyovernmwii
Admmistratjtrt
X
Complete
Data —
Forms
FIGURE 26 SOURCE INVENTORY REGISTRATION
-------
supervision, utilizing the Field Technical Services personnel for con-
sultation as appropriate. As shown in Figure 27, these plans, submitted
to Field Technical Services, would be validated and confirmed at the field
level prior to their transmission to the headquarters Technical Services
component, where the improvement factors in the emission level would be
verified. Meanwhile, Intergovernmental Administration would take what-
ever steps are appropriate to arrange for available funding sources and
to provide other necessary intergovernmental services. Authorization
and Compliance Operations would then arrange for the conduct of whatever
hearings may be required or desired prior to the issue of a final permit
for construction or modification of the applicant's facilities.
Permit to Operate
Following the completion of the construction program, at the time
the new facility is scheduled to go onstream, Authorization and Compliance
Operations would issue the appropriate application forms to the source.
As shown in Figure 28, the completed application forms, transmitted to
Field Technical Services, then trigger collection of appropriate samples
and inspections by Field Surveillance Operations personnel. The results
of these inspections and sampling procedures, transmitted to Technical
Services headquarters for review, result in Technical Services' recom-
mendation for appropriate permit conditions. Again, Intergovernmental
Administration provides the source applicant with consultation and advice,
where such steps appear necessary, before transmitting the final appli-
cation and recommended permit conditions to Authorization and Compliance
Operations. Authorization and Compliance.conducts whatever hearings and
investigations may be further required before issuing the final permit
for operation to the source applicant.
Source Surveillance and Compliance
As shown in Figure 29, following schedules designed by headquarters
Surveillance Administration, Field Surveillance Operations conducts rou-
tine inspections, sampling, and analysis of all operating sources within
the State, reporting its findings to Field Technical Services. Having
validated the surveillance data, Field Technical Services reports any
questionable source emission levels to Authorization and Compliance
Operations. After appropriate interaction with headquarters Technical
Services, a determination is made of the noncompliance of the individual
source. In an effort to achieve voluntary compliance, consultation and
advice are conducted before action is recommended to Authorization and
Compliance, where, as a final recourse, evidential data for prosecution
87
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Legal COUIISB)
and
Representation
Program
Monitoring
Staif
—
Director
Deputy
Director
•M
Public
Interest
Center
Environmental
Planning
Service
00
oo
JL
Information arid
Procedures
Services
Surveillance
Administration
Field
Surveillance
Op era tint is
J_
Technical
Services
I
Validate.
Visit Site,
Confirm Oat
IT-
Intergovernmental
Administration
Verify /
Improvement
Factors
Field
Technical
SHI vices
Authorization
arid Compliance
Operations
^ Arrange
Cooperation
and Funding
Conduct
Hearings,
Issue Permit
HIL
Regional/Local
IntergovofftiTifint
Administration
Monitor
Construction
Progress •
' Complete
Plans —
Applicant
FIGURE 27 AUTHORIZATION TO CONSTRUCT OR MODIFY
-------
Director
Legal Counsel
and
Representation
Program
Monitoring
Staff
Deputy
Director
Public
Interest
Center
Environmental
Planning
Service
oo
CD
Inspei t and Sample Administration
Tochnical
Services
Intergovernmental
Administration
V Recommend / ^Consult with
Permit / and Advise«
Permit
Conditions
Field
Technical
Services
Review Application. >/
* Specify Sampling**^
and Inspections
Authorization
and Compliance
Operations
' and Advise
Applicant
7
/ ft
Regional/Local
Intergovernment
Administration
Issue
Application
Conduct Forms
Hearings and
Issue Permit
Complete
Application'
Applicant
FIGURE 28 PERMIT TO OPERATE
-------
CO
o
' 1 , .
Information and
Procedures
Services
Director
Legal Counsel
Representation
MProf"" Deputy
Monitor nig — „• *
Staff Oirector
Public
Internsi
Center
Environmental
^" Planning
Service
Consult and Advise
-, for Voluntarf
f Action X
1 I 1 /
r. n Finance and
Surveillance A . . .
, . ... .. Administration
Administration _
Operations
1
Issue
Sutveillan
Schedule
_\
1
e District
Administration
i
_ i
Technical 1 ntergovenmieiita!
Services Administration
r • ~ * • ' •— i - -
Fiolrj
Surveillance
Operations
^^*^ N
T
Attorney
General
\
Recommem
V Prosecutioi
^ j ^
Authorization
and Compliance
Operations
Determine * f
incompliance /
Validate
Surveillance
Data
Field RegioijiiJifCjjr.al
Technical •. Jwrtfgovernmgnt
Services Administration
Inspect,
Sample,
and Analyze
FIGURE 29 SOURCE SURVEILLANCE AND COMPLIANCE
-------
are accumulated and recommended to the attention of the Attorney General
through the appropriate legal channels.
The above brief descriptions of certain technical transactions il-
lustrate the general procedures that would be followed by the new organi-
zational components, demonstrating the philosophy of functional special-
ization and the clean separation of technical specialization inherent in
the recommended organization.
91
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VII IMPLEMENTATION
The implementation of a new organizational design involves more than
specifying functions, roles, or policies. In addition to a clear under-
standing of the mechanics of the organization and the interrelationships
of its components, the implementation process requires each individual's
recognition of new expectations, attitudes, and behavior. At the same
time, it requires management's realization that the allegiance and support
of the staff for the new organization must be developed rather than de-
manded. In order to accomplish this commitment of the entire staff in
implementing the new organization, it will be necessary to observe the
following principles.
• Identification and Assessment of Human Impacts
Although organizational designs are relatively impersonal,
they can be perceived as opportunities or threats to indi-
vidual staff members through actual or prospective influence
on their status, career development, or working patterns.
In order to deal with these situations, it will be essential
to establish an open communication link with the staff so
that each aspect of the new organization can be explained
fully as problems or questions are raised.
• Development of an Implementation Strategy
The manner in which the new organization is implemented
can have a significant influence upon its prospects for
success. Recognizing the need to satisfy the legitimate
concerns of the staff, an effective strategy may be one
that combines the traditional directive approach with a
nondirective, participative method.
• Organizing for Implementation
Careful planning will be required to guide the implementa-
tion process. This will include identification of respon-
sibilities for the implementation work, as well as alloca-
tion of resources to carry it out. The implementation work
need not necessarily be entirely congruent with either the
93
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new or old organization, as the transition process will
involve distinct and separate tasks.
• Participation and Feedback
Any new endeavor that alters behavioral patterns will
probably not be developed exactly as planned, no matter
how much care is exerted in the preparation of plans.
The implementation process must be sufficiently flexible
to respond to the "changing situations that arise and to
address the specific questions regarding transition and
operation of the new organization.
In short, the above principles for implementation merely reflect the
need to encourage the cooperation and receptivity of the staff toward the
new organization and to enable the organization to learn from its own ex-
perience both before and after the transition process. Staff familiarity
with everyday operations can be effectively channeled toward positive,
beneficial purposes for individuals and the organization.
Organizational Work Group
To assist in the implementation process through providing a means
for more direct participation of the staff, SRI suggests the establish-
ment of an organizational work group. The purpose of the work group is
to provide for the representation of interests and viewpoints of the
staff at several levels of the existing organizations. The work group
should include members from a cross-section of horizontal and vertical
elements of the organization to create a balanced perspective on the
implementation process. The work group should be relatively small,
preferably seven to ten members, to encourage participation and open
discussion in its meetings and activities. Since the group would be a
mechanism for personal staff participation in the implementation process,
it may be desirable to encourage staff selection of members of the work
group.
The group would conduct meetings, hold discussions, and arrange
orientation sessions to acquaint the membership of the existing organiza-
tions with the new organization and to explain their roles and respon-
sibilities. The group could also carry out special studies of problems
that arise during the implementation process, and it could respond to
questions and concerns that are raised by individuals. Working closely
with both management and employees, the group would help solve problems
and facilitate the implementation process.
94
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The organizational work group would provide both staff and manage-
ment with an alternative means of communication to the traditional, direc-
tive approach. It could relieve possible pressures that might stifle the
initiative essential for successful implementation of the new organization.
The group would also provide a means for staff anxieties to be aired and
heard by management, while at the same time offering management an avenue
to provide clarification of meanings, explanation of concepts, and resolu-
tion of any ambiguities that impair full implementation of the new organ-
ization.
Without the organizational work group, the staff would have little
participation in the implementation process. Key positions would be
filled, and then these incumbents would fill positions in their unit by
assignments or by drawing upon available personnel. For a variety of
reasons, some staff members may find such a process inconsistent with
their basic interests or objectives. If they conclude that their interests
are not served by their assignment under such a traditional approach,
their choice is clear—they can either accept it or leave. In view of
the shortage of trained personnel in enviornmental areas, however, the
potential loss of professional staff should be regarded as adverse to
the goals and objectives of the organization. The opportunity should be
given to staff members (especially those members showing talent and
promise) to play an important role in shaping the new organization and,
thus, to directly bring about their involvement in the process and provide
a better means for resolving potential conflicts. In this context, the
organizational work group would therefore serve as a safety valve that
influences potential management actions by bringing the views of the
staff to management attention. If successful, such an approach could
also help the organization in the period following the implementation
phase by serving as a means for channeling feedback and internal evalua-
tion.
Priorities
The leadership of the organization will need to establish priorities
for implementation. Among the priority items to be addressed early in
the implementation process are the following:
• Develop procedures for governing the process of orderly
transition to the new organizational structure.
• Analyze existing legislative authorities assigned to the
new organization, and ensure that proper coverage is pro-
vided for in the integrated functions of the new organiza-
tion.
95
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• Determine facilities and support needs.
• Formulate detailed implementation plans for physical and
organizational relocation into the new structure.
• Establish a comprehensive implementation schedule for full
conversion to the new structure, and set its effective date.
The setting of priorities would be based on the same general approach
employed in the design of the new organization, e.g., it falls within the
scope of the strategic concepts and follows the behavioral principle of
staff participation. Specific design factors for the implementation
process are described below.
Implementation Process Design Factors
The process of implementing the new organization will naturally re-
sult in alteration of present patterns of operations. Based on the priori-
ties established by the organizational management and the work group, the
implementation process should be designed to account for the following
factors:
• Ensure continuity of operational performance of statutory
responsibility during the transition phase.
• Describe details of functions to be performed by each organi-
zational element (as well as relationships with other parts
of the organization upon which each element is dependent for
information or services).
• Employ functional descriptions to guide staffing require-
ments in terms of qualifications, training, and experience
to aid in personnel selection, placement, and advancement.
• Provide for maintenance technical expertise in environ-
mental investigations (e.g., air, water, solid waste, etc.).
• Establish separation of technical from nontechnical func-
tions.
• Maintain field inspection and permit programs.
• Continue plan review and comprehensive planning activities.
• Provide for environmental sampling and surveillance pro-
grams and facilitate the compilation and exchange of in-
formation*' from these activities.
96
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• Ensure maintenance of program relationships with counterpart
agencies of the federal government (including interstate and
international programs), regional governmental bodies, and
local governments during the transition process.
• Describe sequences of responsibility for typical programs
among new organizational elements (i.e., information, sup-
port, and operational requirements to fulfill assigned
tasks) to determine the details of internal cross-checking
and feedback that will serve to permit continuous evaluation
of functional performance.
• Maintain relationships with other State agencies that carry
out programs related to those of the new environmental pro-
tection organization.
Knowledge of the positive and negative factors of present operations
by units that will become part of the new organization is essential in
formulating detailed design factors for implementation. These factors
will need to be evaluated critically to properly guide the design of the
implementation activities. The evaluation will need to be objectively
and impartially performed if it is to be of real value in shaping imple-
mentation activities. This means that those who participate in this
activity (especially nonmanagement members of the organizational work
group) will need to be given assurance that their candor in evaluation
will be respected rather than resented by those presently in positions
of responsibility.
Organizational Relocation
The implementation process will doubtless result in organizational
relocation of certain elements from present agencies. It will be important
to plan the implementation to address the following relocation (in both
a physical and administrative sense) guidelines:
• Relocate like functions to provide for integrated and co-
ordinated operations.
• Consider intact transfer of present organizational entities
to the new structure to the extent practicable according to
their functions.
• Emphasize placement of technical expertise in the new structure
where either its general availability to the organization is
enhanced or where environmental problems are such that they
warrant more direct expert attention.
97
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• Provide a central executive and administrative control cap-
ability at the outset so that organizational leadership
will be centralized, even if physical limitations do not
permit initial consolidation of all elements.
The basic purpose of organizational relocation in implementing the
new design is to achieve efficient operational and management control of
activities conducted in concurrence with the new structure. This implies
that the relocation should be planned to coincide with the initiation of
new operating practices or procedures as determined by the overall im-
plementation strategy and plan. Furthermore, it implies that a compre-
hensive schedule for organizational relocation will be developed and
employed to guide the relocation. Where actual physical moves of personnel
or functions are required, the plan will have to account for the necessary
facilities to accommodate the relocated personnel with a minimum of dis-
ruption in on-going programs. At all stages, involvement of the member-
ship (especially the organizational work group) will be necessary to
achieve understanding of the process and timing of any prospective moves.
There should be no surprises to the staff on physical or administrative
aspects of implementation. The need for good communication during this
phase of implementation is especially critical for success.
A schematic representation of the organizational relocation of
present units into the new organizational elements is shown in Figure 30.
The basis for this representation is the individual units of the present
organizations of the Departments of Health and Natural Resources desig-
nated (or implied) to be placed in the new environmental protection organ-
ization by Senate Bill No. 397. The several units (or particular func-
tions) are shown according to their principal activities relative to the
functional composition of the recommended organization design. These
figures are in gross terms only, as the details of the organizational
relocation of indicated components will necessarily require the atten-
tion of the comprehensive implementation planning process. Nevertheless,
the figures present an overview of the anticipated initial makeup of the
new organization and will therefore be useful in guiding the implementa-
tion planning process.
Another way to examine organizational relocation is to employ an
analysis of tasks. In Figure 31, each task performed by an element of
the present organizations is shown in its corresponding position relative
to the new organization component responsible for that function. In this
listing, tasks refer only to particular items of work; they do not include
any indication of the amount of time or effort required to accomplish
them. (The present staff associated with these functions was described
in an earlier section of the report.) The important factor to note with
respect to implementation of the new organization is that roughly two out
98
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NEW
ORGANIZATION
INFORMATION
PROCESSING
SURVEILLANCE
SERVICES
TECHNICAL
SERVICES
ENVIRONMENTAL
PLANNING
AUTHORIZATION
AND COMPLIANCE
DESIGNATED UNITS OF PRESENT ORGANIZATION (SB 397)
ODH ODNR
• Systems Analysis
» (Information Functions)
(Information Functions)
INTERGOVERNMENTAL
ADMINISTRATION
FINANCE AND
ADMINISTRATION
• Water Supply Operations
• Sewage & Industrial Waste
Operations
• Solid Waste
• Air Pollution Operations
i
• Plans Review: Water Supply &
Sewage & Industrial Waste
• Plumbing
• Accident Prevention
• Air Pollution Technical
• General Engineering
• Potable Water Quality
• Water Quality Standards
• Solid Waste
• (Enforcement Functions)
• (Function Separated from
Technical Operations
• Community Environmental
Management
• (Grants Application)
Stream and Reservoir
Management
Small Watershed
Surface Water
Ground Water
• Water Planning
• Environmental
Assessment
• (Enforcement
Functions)
• (Function Separated
from Technical
Operations)
• (Contract
Administration)
FIGURE 30 SCHEMATIC OF REORGANIZATION BY PRESENT UNITS
(GROSS TERMS ONLY)
99
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o
o
Present
Organizational
Components
ODH
ODNR
Sanitation
Engineering
ODH
Water
Water
Planning
Water
Mgmt.
Environ.
Assessment
Program
ODNR
TOTAL
PROPOSED ORGANIZATIONAL COMPONENTS
Surveillance
Cent.
Field
2
1
1
52
16
36
54
17
37
29
8
21
2
1
1
5
5
—
—
—
—
36
14
22
90
31
59
Technicals
Cent.
Field
16
10 1 6
114
106
8
130
116 1 14
25
23
2
8
8
—
12
8
4
17
17
—
62
56
6
192
171
30
Authoriz.
and
Compliance
1
6
7
1
—
—
—
1
8
Finance
and
Admin.
6
26
32
1
3
2
—
6
38
Information
and Commun.
1
1
5
—
5
6
Inter-
government
12
12
—
—
—
12
Environ.
Planning
1
6
/7
1
35
1
—
37
44
Total
26
218
243
57
48
25
17
147
390
NOTE: Entries indicate the number of tasks in the present organizational component
that would be allocated to the proposed organizational component.
FIGURE 31 TASK REASSIGNMENT MATRIX
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of three tasks are performed by the present units of the Department of
Health and that these are mostly in technical areas. Similarly, the
Department of Natural Resources has most of its tasks in the technical
area. In terms of organizational relocation and implementation of the
new design, it will be valuable to ensure adequate coverage of those
functional areas not well represented by present task assignments, as
well as to maintain the services represented by present tasks. Obviously,
achievement of this objective will require careful planning, design, and
scheduling for implementation of the new organization design.
Schedule
The new organization will not be implemented overnight; it will take
time to accomplish the transition from the present structure. However,
the fact that the new organization will not become immediately effective
is no argument against adopting the recommended design, as long as the
implementation process plan attends to the following scheduling guide-
lines:
• Design implementation of the new organization should become
effective at the same time for similar functions.
/•
• Schedule implementation of management-level functions early
in the sequence to guide implementation of operational-
level functions (e.g., the Director's Office; Finance and
Administrative Operations, including the personnel function
and district offices; Information and Procedures Services;
Environmental Planning Service; and Intergovernmental Ad-
ministration should be implemented early).
• Employ these management functions in their new organiza-
tional mode to aid in establishing details of implementation
of Surveillance Administration, Technical Services, and
Authorization and Compliance Operations.
• Within technical functions, schedule implementation of new
organizational design in reverse order of their establish-
ment (i.e., the most recently established functional pro-
grams would be implemented first: air, solid waste, water).
Based on these guidelines and ttye earlier factors to be considered
in implementation, a tentative schedule for implementation of the new
organization is presented in Figure 32. A total implementation period
of six months is envisioned from the time of formation of the new organi-
zation until it is fully operative. This tentative schedule shows a
modified Gantt chart in which several overlapping implementation tasks
are indicated. The chart is an overview; actually, these several tasks
101
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Months
1
Provide central
administration
Develop procedures 1
2
Formulate implementation plan;
schedule; define assignments, facilities
3
Prepare facilities!
4
••••»••
»•*•*•••
Relocate like functions
5
Phase in new procedures |
6 1
-^
Full
implementation
Shakedown; trial and revision of new procedures, practices I
FIGURE 32 TENTATIVE SCHEDULE
(and more detailed subtasks) will probably be in progress simultaneously
for the various elements of the organization. Moreover, individual ele-
ments should not be expected to conclude the tasks according to exactly
the same schedule; some will require more time than suggested, others
may need less—this will have to be anticipated in the preparation of
the detailed implementation plan.
Generally speaking, the schedule indicates that initial tasks, such
as providing central administration and developing procedures for imple-
mentation, will be accomplished during the first month of the implementa-
tion period. At this time, the organizational work group would be orga-
nized to begin its activities. Also, the initial selection of key
management personnel expected to play an important part in implementation
would greatly facilitate the transition process and enable more efficient
operations.
Based on this work, detailed implementation plans and schedules
would be formulated for the entire organization and for each element,
down to the smallest identifiable activity. In some cases, an organiza-
tional unit in the present organizations performing a separate function
can be transferred as a whole to the new structure. In other cases, it
will be necessary to plan on a task-level basis where present units in-
clude a wide variety of tasks. The plan will have to account for the
responsibilities, assignments, and facilities required to carry out the
functions, and ij will have to provide a means for logical, phased transi-
tion to the new organization. An important part of this plan will be the
determination of facility needs sufficiently early so that the necessary
102
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facilities can be prepared to accommodate the physical relocation of
personnel or functions required to achieve efficient operations in the
new organization.
Concurrent with organizational relocation (physical or administra-
tive), the procedures for carrying out the functions of the new organiza-
tion should be put into force. Much of this can, perhaps, be done early
in the overall implementation process; however, some of the new procedures
can best be introduced after actual relocation has been accomplished, but
this would not preclude dissemination of the new procedures prior to their
being placed in effect. Discussion of their significance and content
among the staff under the leadership of the organizational work group
would be a natural activity of the group.
In all probability, the new organization will require a shakedown
interval; it is unrealistic to expect that the new procedures and organi-
zational units will operate smoothly from the start. For many parts of
the organization, this trial interval will take place during the imple-
mentation period. Much can be learned from the experiences of elements
of the organization that are implemented early by comparing their actual
operations against the expectations and stipulations of the implementa-
tion plan. This knowledge can be used by management and the organiza-
tional work group to guide the operations of other elements and to make
appropriate revisions in the procedures to eliminate problems. Particu-
larly successful practices that are developed could also be extended to
the entire organization. Full implementation of the new organization
design will provide further opportunities to refine the operations. This
will be especially true as the size of the staff is increased toward the
estimated complement required to deal most effectively with the organi-
zation's range of responsibilities.
103
1973-753-210/202
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