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Air & Waste Management Association
Transformation at NJDEP’s Compliance & Enforcement Program
Wolf Skacel Assistant Commissioner
October 14, 2011
Overview• Background to C&E‘s Transformation• C&E Transformation Goals• Transformation • Departmental Goals
FY2010 Compliance Rates†
67%
91%
67%54%
78%88%
61%
90%
0%10%20%30%40%50%60%70%80%90%
100%Air
Hazardous Waste
Land Use
Pesticides
Solid Waste
Water Quality
Water-Quality- UST
Water Supply
1970 Pollution Levels
2011Pollution Impacts Total Pollution Impact on
Environment
Areas of Non-Compliance
C&E Transformation Efforts
C & E Transformation Goals
• High but meaningful compliance• Better behavior from others resulting in better
environmental protection or outcomes (whether mandated or not)
• Finding and fixing environmental problems• No backsliding on previous gains
Percent of checklist requirements found In Compliance (IC)
in 2009
for: Air; Hazardous waste; Solid Waste; Water Quality; Water
Supply
In Compliance
66.00%
68.00%
70.00%
72.00%
74.00%
76.00%
78.00%
80.00%
Stewardship Sites with aPolicy
All Stewardship Sites Non-stewardship Sites
Key Systems 1 Strategic Management system (targeting, ensuring deterrence, prioritization, workplans,
consistency, measuring and communicating success)
2 Education system (training sessions, on-site assistance, guides and materials online)
3 DEP Strategic Management System (aligning all areas with mission, DEP-wide prioritization, re-allocating resources, ensuring communication and collaboration)
4 Investigation/Problem ID system (managing and responding to complaints and referrals, community input, observation, research & analysis, DEP science input)
5 Inspection system (prep, on-site, interview, compliance and stewardship, report, novs)
6 Information system for behavior change (devising collection or development of new information, building reports or materials for direct or third party influence)
7 Enforcement system (follow-ups, penalties, case management, settlement, ADR, "conversions" of bad guys to good guys, SEPs)
8 Self-reporting system (self-cert, disclosure, monitoring, audit schemes, etc.)
9 Bulk Processing (licensing, fees, billing and collections)
Prioritized Key Systems 1 Strategic Management system (targeting, ensuring deterrence, prioritization, workplans,
consistency, measuring and communicating success)
2 Education system (training sessions, on-site assistance, guides and materials online)
7 Enforcement system (follow-ups, penalties, case management, settlement, ADR, "conversions" of bad guys to good guys, SEPs)
Projects Chosen1. C&E Strategic Management System 2. Education over enforcement 3. SEP rule/policy
Implementation of a Strategic Management System (SMS)
• Using a Balanced Scorecard (BSC) model developed by Norton and Kaplan
• The System will be “cascaded” throughout C&E in a tiered manner from top to bottom by management levels.
• Performance measures are being developed to demonstrate progress towards accomplishment of goals
9
Creation of an Environmental Intelligence Center (EIC )
• Leverages our impressive data collection capabilities & data systems to develop intelligence products,
• integrates C&E and DEP goals and objectives and collaborates with our internal and external partners.
• The EIC will consist of three separate and distinct subsidiary elements, with each element having responsibilities and tasks contributing to the overall effectiveness of intelligence-led enforcement. These elements are:
• Watch Operations• Analysis Element• Asset Management
10
Watch Operations
11
Watch Operati
ons Element
Watch Operations will maintain and communicate situational awareness for the entire organization
Watch operations will encompass communications across C&E and between C&E and external stakeholders. This would include duty officer responsibilities, OPRA, complaint tracking, and cross-program referrals.
Analysis Element
12
The Analysis element will house analysts who have the capabilities to translate raw data into useable and relevant intelligence products.
Translate Raw Data
into Standardized and Useable Intelligence
Quickly Generate Multiple
Types and Formats of Intelligence
Identify Data Gaps
and Develop Strategies to Fill Those
Gaps
Make Intelligence
Available and Accessible
Across Program
Lines
Intelligence Products
will Drive Priorities and Asset
Management
Asset Management
13
Development, Tracking and Overall Evaluation
of C&E Work Plans
Management of
Resources and
Organizational
Capacity
Leverage Resources to Achieve Strategic Priorities and Goals
Outreach Coordinatio
n to Communic
ate Priorities
and Results
This element will be charged with the overall development, tracking and constant evaluation of the C&E wide work plan.
Medium and long term priorities, outreach coordination, EPA mandates, managing the intelligence produced by the analysis group, are some components of asset management
.
Restructuring and Alignment of C&E Staff through an Ecological and Holistic Approach
14
• C&E’s organizational structure be reorganized and aligned to support the new strategic focus dictated by the SMS, its goals and objectives.
• appointment of a regional manager to oversee each C&E region under the new alignment paradigm.
• Transitioning away from solely doing mandated inspections to empowering C&E inspectors to find and fix environmental problems
• Embrace a geographic-based, “enviro-shed” holistic approach with Barnegat Bay watershed being the first enviro-shed.
• Gradual transition to multiple enviro-sheds
Barnegat Bay Watershed
• Good controls exist at existing NJPDES facilities that are routinely inspected
• Plan to target non-traditional sources of water pollutiono 5G2 exemption sites claiming permanent non exposureo 5G3 stormwater permitso Inspection of suspected unpermitted dischargeso Stream-walking
• Using aerial maps and NJEMS data to identify potential environmental problems
Recommendations
4. Prioritization of the Key Systems of Work
16
Training Seminars, Outreach & Education
• Facilitate behavior changes through increased education
• Create a comprehensive, sustainable education/Training system that adapts training needs based on feedback from stakeholders & metrics for continuous improvement
• Seeking increased compliance, stewardship, and promotion of environmentally sound operations and practices to protect and conserve our State’s natural resources
Supplemental Environmental Project
• An environmentally beneficial project that an entity voluntarily agrees to perform as a condition of settling an enforcement action.
• A SEP is an activity that the violator would not otherwise have been required to perform, and in which the public or the environment is the primary beneficiary.
• Draft policy under legal review• External stakeholder reviews to be scheduled• Policy to be used as basis for future rulemaking
Department Goals• Comprehensive regional environmental
management• Barnegat Bay restoration as a model for
protecting New Jersey surface water bodies• Enhanced protection of environmentally
overburdened communities• Sustainable parks• Establishing an overall strategy for renewable
energy opportunities in New Jersey
Enhanced protection of
environmentally overburdened
communities
• Inclusive of, but broader than urban or EJ communities focusing on public health related environmental impacts
• Develop a new approach that evaluates multi-media impacts on human health and the environment
• Actively developing a cumulative impact tool• Informed decision making• Department wide effort, not just C&E• External stakeholder involvement part of process
Questions