United States Office of Enforcement 300-F-94-OO1
Environmental Protection Agency Washington DC May 1994
oE A National Enforcement
Training Institute
k FiscàI Year 1993
Accomplishments

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Office of Enforcement
EPA
National Enforcement
Training Institute
Fiscal Year 1993
Accomplishments
I
NATIONAL ENFORCEMENT TRAINING INSTITUTE

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INTRODUCTION
National Enforcement Training
Institute (NETI) was established
within EPA ’s Office of Enforcement
in response to a statutory mandate in
the Pollution Prosecution Act of 1990
(RL. 101-592, 42 usc 4321). The Act
directs NETI to “train Federal, State, and
local lawyers, inspectors, civil and
criminal investigators, and technical
experts in the enforcement of the Nation’s
environmental laws.”
To fulfill this broad mandate and to
guide the development of its programs,
NEIl has identified four primary goals.
(See opposite page.) In Fiscal Year (FY)
1993, NETI took major strides toward
achieving these goals. The NEIl program
expanded in size and scope, training
more environmental enforcement
professionals than ever before. NEIl
worked to build cooperative relationships
with other enforcement agencies and
NET! attorney trainers and trainees identify training needs and recommend courses at a curriculum
conference.
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NETI’s 4 Primary Goals
groups to broaden training delivery.
During the year, NEIl also took advantage
of innovative technologies to reach
audiences in all States. NET! provided
training to international environmental
professionals in five foreign countries.
Finally, in FY 1993, NET! developed and
began to implement its Strategic Plan.
L
A NETI staff member leads a discussion on
developing curriculum for multimedia inspectors.
I Training environmental
enforcement professionals
in order to improve the
quality and increase the number
of enforcement actions.
2 Fostering the promotion
of environmental
enforcement professionals’
career development.
3 Creating the
infrastructure to support
the identification of
enforcement training needs, the
development of high-quality
enforcement training products,
and the cost-effective and
efficient delivery of training.
4 Setting a high standard
for the creation of a
highly skilled, nationally
unified enforcement workforce
and assisting in the evaluation
of the Nation’s progress toward
this goal.
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GROWTH OF THE NETI PROGRAM
IN THE UNITED STATES
ith more than 200 sessions
available, the number of
courses offered in FY 1993 increased
fourfold over FY 1992. With the
increase in courses offered, the number
of environmental professionals who
benefitted from this training also
increased. Figure 1 shows the number
of environmental professionals trained
in FY 1992 and in FY 1993. In FY 1993,
NET! trained 6,882 environmental
professionals, nearly twice the number
it trained in FY 1992.
NETI provided training in all 10
EPA Regional Offices—in Boston, New
York City, Philadelphia, Atlanta,
Chicago, Dallas, Kansas City, Denver,
San Francisco, and Seattle—and at EPA
Headquarters, in Washington, D.C., as well
as the NETI-West Training Center (NET!-
West) in Lakewood, Colorado. Training
was also conducted in 20 States: Arizona,
California, Florida, Georgia, Indiana,
Kentucky, Louisiana, Michigan,
Mississippi, Nevada, New Jersey, New
Mexico, North Carolina, Rhode Island,
South Carolina, Tennessee, Texas,
Vermont, Virginia, and Wisconsin.
These significant gains were made
possible by the cooperative partnerships
and alliances that NEIl established and
fostered within the environmental
7000—
•FY 1992
a FY 1993
6000-—--
5393
5000 -
4000
3000
2558
2000
0
NETI
1000
1489
ii
State Associations
1
3800
Total
Figure 1
Number of
Participants Trained
in FY 1992 and in
FY 1993
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FY 1993 HIGHLIGHTS
enforcement community. NETI-sponsored During FY 1993, NETI:
training was carried out by the National
Enforcement Investigations Center
U Conducted four times as
(NEIC), the criminal program at the
Federal Law Enforcement Training many courses as in FY 1992.
Center (FLETC), and the four Regional
Environmental Enforcement Associations
U Trained nearly twice the
comprised of member States—the
Northeast Environmental Enforcement number of environmental
Project (NEEP), the Midwest enforcement professionals
Environmental Enforcement Association as in FY 1992.
(MEEA), the Southern Environmental
Enforcement Network (SEEN), and the
Western States Project (WSP). The U Delivered onsite training in
Regional Environmental Enforcement all 10 EPA Regional Offices
Associations provide training and
and in 20 States.
information to member States. Figure 2
shows the number of Federal, State,
local, and international environmental U Used innovative technology
professionals trained by NETI and its to provide cost-effective
partners in FY 1993.
training in all 50 States.
In keeping with NETI’s legislative
mandate, NETI partners provided training
opportunities for all members of the U Provided onsite training in
enforcement team. The Regional -
Malaysia, Mex.co,Thailand,
Environmental Enforcement Associations
offered courses ranging from inspector Turkey, and Ukraine.
workshops and basic investigation
techniques to advanced prosecution U Completed its Strategic Plan.
seminars. NETI-West courses dealt with
the roles of technical experts in serving
as expert witnesses and providing
support for criminal cases. Other NETI-
West workshops focused on enforcement 5

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GROWTH OF THE NETI PROGRAM IN THE UNITED STATES
techniques and procedures for laboratory
personnel and the necessity for com-
plying with standards of good laboratory
practice. Topics included in FLETC
course offerings included environmental
investigations and training for Special
Agents in Charge. In addition to class-
room presentations, FLETC training
included outdoor field exercises where
trainees were confronted with simulated,
real-life situations.
The breadth of subjects addressed
by NET! Headquarters was equally im-
pressive. Certain courses focused on
specific media or specific acts and regula-
tions: the Oil Pollution Act, for example,
the Comprehensive Environmental Re-
sponse, Compensation, and Liability Act
(CERCLA), also known as Superfund, and
the Resource Conservation and Recovery
Act (RCRA). Other NETI Headquarters
offerings engaged participants in the
Figure 2
Number of Federal,
State, Local, and
International
Participants Trained
by NETI and its
Partners in FY 1993
Internat Ional (Total 287)
Federal (Total 3,820)
State (Total 2,081)
Local (Total 694)
900
825
750
675
600
525
450
515
375
U
300
225
150
LI
6
MEEA NEEP SEEN WSP

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study of legal processes and the practice
of skills with broad application, such as
negotiations and the conduct of admin-
istrative hearings and trials. Some train-
ing imparted technical skills, such as the
ability to identify sources of information
needed for environmental enforcement or
the use of computer software to assist in
penalty assessment. Participants re-
ceived basic scientific training, such as
environmental chemistry, while courses
in case management and enforcement
team building encouraged development
of broad, generic skills.
Details of selected courses help to
suggest the character of NETI offerings in
more depth:
• The Negotiation Skills course is
designed for attorneys, engineers,
compliance officers, and technical
staff involved in environmental
enforcement activities. The course
uses lectures, film, and small-group
strategy discussions. In “hands-on”
sessions, trainees prepare for and
participate in two practice negotia-
tions between government and
industry representatives.
• The Clean Air Act and the Clean Water
Act authorize EPA to place violating
facilities on a list of facilities that are
ineligible for any federally funded
contract, grant, or loan. NEll’s Con-
tractor Listing course informs EPA
personnel about this authority and
provides information about policies
and procedures that apply to carrying
out this authority.
I The Advanced Administrative Practice
Institute is designed to enhance the
knowledge, skills, and effectiveness of
attorneys working in administrative
enforcement litigation. Proceedings
brought under the EPA Consolidated
Rules of Practice, 40 CFR Part 22, and
matters subject to review by the EPA
Environmental Appeals Board are the
primary focus. Participants use actual
cases as course material as they learn
about techniques for motions prac-
tice, innovative settlements, and
appellate advocacy.
A NET! faculty member trains course participants
in the ABEL computer model.
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GROWTH OF THE NETI PROGRAM IN THE UNITED STATES
Even as NET! developed new courses,
it also worked to refine existing training. A
highlight of FY 1993 was the enhancement
of NEll’s 2-week Basic Environmental
Enforcement Course. The second
offering of this course was presented
in FY 1993 in Washington, D.C. Of the
36 trainees in attendance, half represented
Region IV, EPA Headquarters, and the
Department of Justice; the other half were
from State and local enforcement agencies
in the Region IV area: Alabama, Florida,
Georgia, Kentucky, Mississippi, North
Carolina, South Carolina, and Tennessee.
Following this presentation, NET!
began an effort to condense the course into
a 1-week program so that it could be
offered more easily by EPA and the four
Regional Environmental Enforcement
Associations. A subcommittee of the
NET! Curriculum Committee, made up of
State and Federal training experts, met to
discuss possible revisions to the course
in June 1993. Their work will culminate in
the presentation of the revised course,
scheduled for July 1994. NET! anticipates
that the revised course will become the
standard basic training for all environ-
mental enforcement professionals in the
United States.
NET! also revised its BEN and ABEL
training in FY 1993. This 2-clay course
provides participants with step-by-step
guidance on entering data into the BEN
TRAINING INSTITUTE W
I
8
The NET/-West Training Center was dedicated on September 16, 1992.

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and ABEL computer models and inter-
preting the models’ results. The BEN
model calculates a violator’s economic
benefit from noncompliance and is
frequently used in Air, Water, and RCRA
cases. ABEL is used, especially in
preparing for negotiations, when a
violator claims an inability to pay a civil
penalty. The ABEL model evaluates a
violator’s solvency, that is, the ability to
pay cleanup and compliance costs or a
civil penalty and still remain in business.
Course revisions reflected changes in
the BEN model’s discount rate assump-
tions and incorporated a series of
improvements designed to increase
training effectiveness. NEIl delivered
11 sessions of the BEN and ABEL course,
training a total of 321 enforcement per-
sonnel in EPA Headquarters, nine Regional
Offices, the States of Indiana and Florida,
and the Northeast Environmental
Enforcement Project. In addition, NETI
delivered the Cashout and Superfund
ABEL course, the Superfund version of the
BEN and ABEL course, to 138 enforcement
personnel at 6 locations.
In FY 1993, NET! also featured training
on the Integrated Data for Enforcement
Analysis (IDEA) system, a premier
environmental enforcement tool. As an
interactive, high-speed data retrieval and
integration system, IDEA enables
enforcement personnel to retrieve data
for multimedia analyses of regulated
facilities for a wide array of purposes:
inspection targeting, case screening, case
development, litigation support, and
settlement negotiations. Fourteen
sessions of the IDEA training course were
offered during FY 1993, giving an audience
of 235 environmental professionals access
to this invaluable tool.
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NETI AT THE LEADING EDGE OF
LEARNING TECHNOLOGY
NET1s commitment to providing
top-quality, cost-effective
training led to the use of distance learning
technology in FY 1993. While maintaining
a comprehensive quality assurance
program for the integrity of its traditional,
classroom-style course offerings, NETI
joined the leading edge of technology to
reach larger, geographically dispersed
audiences. Emerging technologies for
distance learning include, for example,
interactive videos, CD-ROM technologies,
and closed-circuit satellite television
transmission. In one application of
distance education technology, NET!
Headquarters used a satellite trans-
mission to deliver the Administrative
Hearings and Trials course to 1,000
trainees in all 50 States. This course used
only one NET! Headquarters instructor for
a single day, resulting in substantial
cost savings.
Within the past year, all members of
the NET! Headquarters staff received
training on the latest innovations in
distance education from experts in the
field. Applying this training, NET!
developed and implemented a
clearinghouse in FY 1993 for keeping
constituents informed and up to date
about NETI-sponsored training. Users
across the United States can reach the
NEIl Clearinghouse on a toll-free number,
1-800-EPA-NETI, to learn about training
opportunities. The toll-free line should
prove especially useful to State, local, and
Tribal environmental enforcement
professionals, who may not have ready
access to computer networks.
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TRAINING FOR THE INTERNATIONAL
ENVIRONMENTAL COMMUNITY
NETI not only expanded its
training programs within the
United States during FY 1993; it also made
great strides in extending outreach to the
international environmental community.
NETI’s environmental enforcement
training courses were offered in Malaysia,
Mexico, Thailand, Turkey, and Ukraine.
As a follow-on to the training NETI
had provided to Mexican environmental
inspectors in FY 1992, NETI trained
180 inspectors in two 5-day sessions
held in Mexico City and Guadalajara in
FY 1993. Tailored to meet the specific
professional needs of the audience in
each location, the course included site
visits to local manufacturing facilities as
well as classroom sessions. Classroom
instruction included opportunities
for trainees to review and discuss
the industrial processes (including
electroplating, manufacture of printed
circuitboards, furniture finishing, and
injection molding) covered by the site
visits. Other topics discussed in depth
included Mexico’s environmental laws
and regulations, health precautions and
safety techniques for field activities, and
compliance inspection procedures.
Another course, Principles of
Environmental Enforcement, was pre-
sented to 107 environmental officials in
Kuala Lumpur, Malaysia; Laem Chabang,
Thailand; Ankara, Turkey; and Kiev,
Ukraine. This intensive 3-day training
addressed the basic principles involved in
designing and implementing effective
environmental enforcement programs.
Developed in 1991 by EPA in conjunction
with environmental authorities from The
Netherlands and Poland, this course is
designed for delivery in a wide variety of
cultural settings.
I— ..-
The training course for Mexican inspectors is presented in English with simultaneous Spanish translation.
All written materials are provided in Spanish.
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FOSTERING COOPERATION AMONG
ENFORCEMENT PROFESSIONALS
ecognizing that teamwork among
enforcement officials at all
levels of government is a key factor in
effective enforcement, NEIl has made
coordination among, and common
training for, enforcement officials a top
priority. Figure 3 shows the distribution
of NETI trainees among Federal, State
and Tribal, local, and international
enforcement professionals. Among the
6,882 professionals who attended NETI
Figure 3
Number of Participants Trained by NETI,
by Participant Source: FY 1993
3500
2500
2000
1500
1000
500
0
International Federal State Local
and Tribal
training in FY 1993, 56 percent of
trainees (or 3,820 individuals) were
Federal employees, and 40 percent (or
2,775 individuals) were State, local, or
Tribal employees. Another 4 percent
(287 individuals) were international
participants.
4000 3820 -
3000
This scene from a Federal Law Enforcement
Training Center course in Glynco, GA, illustrates
emphasis on including hands-on practice in
training, as well as classroom sessions.
1z

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NET! firmly established its
organizational structure and
network in FY 1993. This network
includes the NET! Council, a body of
38 high-level representatives from EPA,
the U.S. Department of Justice, State and
local governments, and academia. The
network also encompasses seven
subcommittees of the Council and six
independent standing committees on
curriculum development.
As part of NETI’s ongoing drive to
refine its internal planning and manage-
ment functions, the NETI Strategic Plan
was developed in FY 1993. The Strategic
Plan, which describes NETI’s vision,
goals, and guiding imperatives will serve
as the basis for the development of yearly
Operating Plans that will translate the
imperatives of the Strategic Plan into
objectives and actions attainable on an
annual basis.
The NETI-West Training Center was
dedicated on September 16, 1992.
Located in Lakewood, Colorado, just west
of Denver, NEIl-West offers a variety of
training settings, ranging from a small
classroom accommodation for a
maximum of 20 students to a theater
arrangement with a capacity of 200.
The settings are fully equipped with
audiovisual equipment, such as VCRs,
and supported with computer work-
stations, a local area network, and a wide
range of office and desktop publishing
software. During FY 1993, 2,088 students
received training at NETI-West.
NET! also made significant progress
in designing the new NET! Headquarters
Training Center, which is slated to open
during the fall of 1994. The Center will be
a model state-of-the-art training facility
located in downtown Washington, D.C.
0 ’•
Trainees at NET/-West take advantage of fully
equipped workstations.
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NETI PERSONNEL
(as of the endofFY 1993)
Ellen C. Stough For further information, contact
Executive Director Arthene Pugh—
Winston M. Haythe Telephone: (202) 260-8785
Senior Attorney Facsimile: (202) 260-7839
Jonathan D. Libber
Senior Attorney
Lisa L. Nelson
Senior Program Analyst
Nancy J. McCeney
Senior Program Analyst
Patricia L. Miller
Program Analyst
Arthene Y. Pugh
Program Analyst
Alice M. Mims
Program Analyst
Linda V. Jones
Program Assistant
Holly Benson
Stay-in-School
Carroll G. Wills
Director, NET!- West
Donald C. Gipe
NETI-West
Sheila M. Walker
NETI-West
Colleen Bisgard
NET!- West
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