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Moving from Tool-Based to Problem-Based GPRA Architecture

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Moving from Tool-Based to Problem-Based GPRA Architecture Powered By Docstoc
					Doing What’s Important
A Problem-Based Approach for Setting
             Priorities
       The Regulatory Craft in Nova Scotia
              Halifax, Nova Scotia
             November 20-21, 2007



                                         Michael M. Stahl
                          Director, Office of Compliance
                   U.S. Environmental Protection Agency
Presentation Outline
   Moving from Tool-Based to Problem-
    Based
   What Is a Priority?
   EPA’s Priority-Setting Process
   EPA’s National Compliance and
    Enforcement Priorities
   Conclusion

                                     2
Tool-Based to Problem-Based
   Challenges facing environmental
    compliance and enforcement (ECE)
    programs
       Broad mission, multiple statutes, many
        regulations
       Numerous sources and forms of pollution
       Diversity of industry sectors
       Vast number of regulated entities
       Reduced reach due to resource limitations


                                                    3
Tool-Based to Problem-Based
   Traditional approach
       Goal – Maintain enforcement presence
        across regulated universe
       Tools serve as organizing principle
           Organization structured around tools
            (assistance, incentives, monitoring and
            enforcement) and statutes (air, water,
            waste)
           Goals, objectives, measures and budget
            organized by tools

                                                      4
Tool-Based to Problem-Based
   Traditional approach
       Challenges
           Impossible to ensure compliance in all
            areas due to resource constraints
           Looking for opportunities to use specific
            tools and statutes may miss important
            problems
           Linking activities to environmental results
            can be difficult


                                                          5
Tool-Based to Problem-Based
   Alternative: Use Sparrow’s “problem-
    solving” approach to establish priorities
       Identify important problems (i.e., risk,
        noncompliance pattern)
       Create strategies tailored to the problems
       Goals, objectives and measures are framed in
        terms of environmental outcomes
   Result
       Focuses resources on the most important
        problems
       Performance measures reflect the program’s
        impact on problems

                                                     6
What Is a Priority?
   Definition: “the fact or condition of
    being prior; precedence in time,
    order, importance, urgency…”
   Setting priorities:
       Helps make triage decisions
       Improves focus on most important
        problems


                                            7
What Is a Priority?
   Problem defined precisely
       Analyze causes and influences
   Strategy using appropriate mix of tools
    tailored to the problem
       May require cross-functional collaboration,
        use of networks
   Problem-specific goals, objectives,
    performance measures
   Resource commitments

                                                      8
EPA’s Priority-Setting Process
   Identifying potential problems
   Evaluating candidate problems for
    priority status
   Selecting priorities
   Implementing and managing
    priorities
   Monitoring and adjusting

                                        9
EPA’s Priority-Setting Process
   Identifying Potential Priorities
       Consulted stakeholders about emerging
        problems, hazards, noncompliance patterns
           Field staff
           Regulatory partners
           Regulated entities
           Others
       Reviewed data systems
           Patterns in violations and enforcement actions
           Compliance history of facilities and companies
           Emission trends
           Public health issues
           Geographic “hot spots”

                                                             10
EPA’s Priority-Setting Process
   Evaluating Candidate Priorities
       Is the problem national in scope?
       Does it merit dedicated resources?
       What would success look like? How
        would we measure it?
       Can we create an intervention strategy
        that would produce success?
       Are there potential partners who would
        join us to address the problem?

                                            11
EPA’s Priority-Setting Process
   Selecting Priorities
       Selection criteria transparent and
        understandable to all stakeholders
       EPA’s criteria
           Identifiable environmental or health
            problem national in scope
           Significant environmental or health
            benefits to be gained
           Appropriate for federal-level attention

                                                      12
EPA’s Priority-Setting Process
   Implementing and Managing
    Priorities
       Develop an implementation strategy
        with goals, objectives, measures
       Establish implementation team with
        multi-functional representation
       Establish senior council to monitor and
        guide priorities

                                             13
EPA’s Priority-Setting Process
   Implementing and Managing
    Priorities
       Periodically review and assess
        priorities, individually and as a set
           Evaluate progress
           Refine problem statements if needed
           Reevaluate goals and measures
           Adjust strategies
           Add/delete priorities

                                                  14
EPA’s National Compliance and
Enforcement Priorities
   NSR/PSD
       Failure of industrial facilities to obtain
        permits for plant modifications that
        increase air pollution emissions
   Air Toxics
       Toxic air pollutants are known to cause
        cancer or other serious health effects
        such as reproductive or birth defects,
        or adverse environmental impacts

                                                     15
EPA’s National Compliance and
Enforcement Priorities
   Mineral Processing
       Wastes from mineral processing can
        cause environmental damage to
        ground water and surface water when
        placed in piles or ponds due to
        corrosivity or high levels of toxic
        metals (e.g., lead)



                                          16
EPA’s National Compliance and
Enforcement Priorities
   Financial Assurance
       Costs of clean-up and closure are
        borne by taxpayers when facility
        operators default
           Requiring adequate resources for clean-up
            promotes proper handling of hazardous
            materials and waste




                                                   17
Indian Country
   Public and environmental health threats
    in Indian Country posed by:
       Unsafe drinking water
       Illegal and open dumping of solid and
        hazardous wastes
       Facility operation and maintenance issues at
        schools, dormitories and campus housing,
        such as presence of asbestos, improperly
        stored chemicals, vehicle maintenance
        operations and fuel storage

                                                   18
EPA’s National Compliance and
Enforcement Priorities
   Stormwater
       Stormwater runoff from large urban areas
        transports contaminants directly over land
        and into waterways
   CAFO
       Water discharges and runoff from
        concentrated animal feeding operations
        (during wet weather events) transport
        nutrients, bacteria, pesticides, antibiotics and
        hormones to local waterways

                                                      19
EPA’s National Compliance and
Enforcement Priorities
   CSO/SSO
       Combined sewer overflows (CSO) and
        sanitary sewer overflows (SSO)
        discharge untreated sewage, industrial
        wastewater, and other pollutants into
        rivers, lakes, and oceans when wet
        weather events exceed the storage
        capacity of pipes and treatment plants


                                             20
Conclusion
   Problem-solving and priority-setting
    approaches hold promise for focusing ECE
    programs on important problems
   Problem-solving approach requires:
       “Open-minded search” for problems and
        intervention strategies
       Ability to work across functional and
        organizational lines
       Measurement and fact-based analysis


                                                21
Contact Information
Michael M. Stahl
Director, Office of Compliance (MC-2221A)
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue NW
Washington, DC 20460

202-564-2280 (phone)
202-564-0027 (fax)

stahl.michael@epa.gov

                                            22

				
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