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ECOS Resource Flexibility and the PPA March 21, 2007. Thomas W. Easterly, P.E., DEE, QEP Commissioner IN Department of Environmental Management. Goal: Increase Compliance Improve Efficiency. Traditional compliance programs brought us to existing levels
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ECOSResource Flexibility and the PPAMarch 21, 2007 Thomas W. Easterly, P.E., DEE, QEP Commissioner IN Department of Environmental Management
Goal: Increase Compliance Improve Efficiency • Traditional compliance programs brought us to existing levels • Identification of significant sources of emissions • Confidence in knowledge of large and heavily regulated sources • Measurement of pollution levels • Identification of top performers and underperformers
Current Status • Environmental challenges remain • Some industry sectors require increased attention • Universe of regulated entities in some sectors not complete • Some regulations poorly implemented • Compliance status unknown in areas • Limited resources to address these issues
Resources vs. Challenges • Most compliance and enforcement resources allocated to satisfy PPA & CMS commitments • Program revenue on downward trend in some programs - Title V, RCRA • Compliance results have become predictable • Gaps in programs and ongoing challenges not adequately addressed
Evolution of Programs • Programs should move towards balance of maintenance and continuous improvement • Environmental challenges, data gaps and implementation deficiencies should be addressed Question: How do we accomplish new goals using traditional compliance and enforcement strategies and expectations?
Resource Flexibility • Goals in balanced compliance strategy are similar to traditional goals, target of activity may be different • Goals are based on each states’ needs • Results attained in these new initiatives comparable to traditional results • Results attained through these new initiatives not attained through current CMS requirements • The Performance Partnership Agreement (PPA) and associated funding process can provide opportunities to discuss allocation of limited resources
Resource Flexibility - Indiana • Each media program has goals and challenges identified that existing CMS does not allow staff time to accomplish • Programs with CMS requirements propose reduction in past CMS numbers to free up resources to accomplish these new goals • EPA and state agree on CMS revisions and intent of new initiatives • Specific results of new initiatives are undetermined, but goals and type of measurement can be included in PPA
Indiana Initiatives • Office of Air Quality • PM 2.5 anomalies • NESHAP compliance using Environmental Results Program (ERP) approach • Office of Water Quality • Small & medium-sized municipalities (ERP) • Collaborative approach to watershed quality improvement • Office of Land Quality • RCRA non-notifiers and downgraded status (ERP) • Auto Salvage Initiative (ERP) • Agency Wide • Collaborative SEPs • Financial incentives for environmental improvement
Current Status • Initial notification of intent sent to EPA Region 5 on February 9th • Media programs of both agencies meeting to close out existing PPA and discuss content of upcoming PPA • April 10th, agency management teams meeting to discuss content of next PPA
Questions? Tom Easterly 100 N. Senate Ave. IGCN 1301 Indianapolis, IN 46204 (317) 232-8611 Fax (317) 233-6647 teasterly@idem.in.gov