doing what’s important a problem-based approach for setting priorities michael m. stahl director,...
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Doing What’s ImportantA Problem-Based Approach for Setting
Priorities
Michael M. StahlDirector, Office of Compliance
U.S. Environmental Protection Agency
The Regulatory Craft in Nova ScotiaHalifax, Nova Scotia
November 20-21, 2007
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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
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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
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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
Tool-Based to Problem-Based
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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
Tool-Based to Problem-Based
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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
Tool-Based to Problem-Based
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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
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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
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EPA’s Priority-Setting Process Identifying potential problems Evaluating candidate problems for
priority status Selecting priorities Implementing and managing
priorities Monitoring and adjusting
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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”
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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?
EPA’s Priority-Setting Process
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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
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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
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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
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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
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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)
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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
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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
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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
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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
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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
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