230 likes | 249 Views
Learn about environmental audit findings, residence hall capital plans, and Governor’s energy savings initiative. Discover key regulations, compliance techniques, and future audit strategies. Evaluate peer audit models and traditional third-party options for sustainability. Explore successful campus audit programs and potential challenges.
E N D
Office for Capital Facilities (OCF) Presentation to SUBOAJune 4, 2012 • Environmental Audit – Barbara Boyle and Marti Ellermann • Residence Hall Capital Plans • Off Balance Residence Halls • UPD accreditation goals • Governor’s Initiative for Energy Savings
Environmental Auditing • Regulated Medical Waste • Safe Drinking Water Act • Stormwater Permitting (SWPPP) • Toxic Substances (TSCA-Lead-Based Paint, PCBs, and Asbestos) • Underground Injection Control (UIC) • Universal Waste • Used Oil Management • Wastewater Discharges (SPDES, MS4) • Air Programs • Bulk Chemical Storage • Emergency Planning and Community Right-to-Know Act and New York TRI Reporting • Hazardous Substance Release Notifications • Hazardous Waste (RCRA) • Oil Pollution Prevention (Oil SPCC) • Oil Storage and Release Reporting (PBS) • Pesticide Management
Why do we do audits? • Confirm continued compliance. • Staff changes • Processes change • Facilities change • More importantly – sound risk management!
Where have we been? SUNY/EPA Audit Agreement and Program 2002 • Audit program was prompted by an invitation from EPA to colleges and universities. • Program was managed by Office of University Counsel. • SUNY/EPA agreement modified standard provisions to make them more amenable to SUNY logistics.
Where have we been? (cont.) • Audit period was five years. • Woodard & Curran was contracted as third-party auditor for $950,000. • state operated campuses - required to participate • community colleges - offered the opportunity all but Erie participated • statutory colleges - not involved
Where have we been? (cont.) • Project costs were assessed on campuses in the year in which the site visit occurred. • Distribution formula was based on gross square feet with certain “environmentally intense” classes (e.g., wet labs) counted twice. • Centers: $40-113K • Median Comprehensives: $22K • Median technology: $17K • Median community college: $6K
Basic SUNY/EPA agreement • SUNY was required to audit, disclose and correct findings, and agree to prevent recurrence. • EPA agreed to defer most inspections and waive all gravity-based penalties. • The EPA did not agree to waive economic benefit penalties, but found all potential fines to be de minimis. • In subsequent audit agreements, the EPA placed significant importance of the development of formal Environmental Management Systems (EMS) to prevent recurrence of noncompliant conditions.
Results • One thousand violations were disclosed. • All gravity-based penalties were waived • EPA estimate: $10M • Audit program was favorably viewed by many groups. • Campuses identified and corrected many poor practices and deficient conditions.
Where are we now? • Audits were conduct 2002 through 2007. • There has been no formal system-wide follow up. • Campuses were expected to maintain corrective actions. • There was no validation of audit responses system-wide. • Typical external environmental auditing interval is 3 to 5 years.
Where should we position ourselves? • Several options considered. • No audit mandate or intervention • Peer audit (Western NYS model) • Peer audit (Georgia model) • Central Auditor/EMS (CUNY model) • Traditional Third Party
Option 1:No audit mandate or intervention Strengths Challenges Actual liability Threat of compliance enforcement Perceived “bad player” Short term cost avoidance
Option 2:Peer Audit (Western NY model)expand pilot program and make mandatory Strengths Challenges Auditor experience Lack of specialty and/or bench strength Auditor objectivity and availability Low cost Campus staff development BMP sharing opportunities Supports shared services concept
Option 3:Peer Audit (Georgia Model)consultant to train campus staff as auditors and to accompany newly trained campus staff to conduct audits of 38 campuses over 4 years Strengths Challenges Migrated significantly towards traditional third-party audit Required one FTE at central office Weakness in auditor responsiveness Cost savings may not have been as significant as initially assumed Perceived lower cost Specialty consultants readily available Campus staff development Shared services/BMP
Option 4: Central Auditor/EMS (CUNY Model) after initial third-party audit, dedicated central position for env audits/EMS support; required campus auditor contributions; supported by consultants Strengths Challenges Additional FTE CUNY central @ 0.7 FTE for 24 campuses on 3 yr cycle Some diminution of campus autonomy Customized solution/fluidity More permanent solution Specialty support available Shared services/BMP
Option 5: Traditional Third Party Strengths Challenges Limited staff development Arguably more expensive Professional Objective Specialty/bench strength
Suggested Program Use the traditional third-party audit. Mimic much of the 2002-2007 program • No agreement with EPA • No planned disclosure • No shelter from fines and penalties Goals: • Increased compliance levels • Improved risk management • Better environmental stewardship
Residence Hall Capital Plans • Going out to Campuses soon • Cash flow extended out to 10 years • No bonded capital appropriation for 12/13, this will show in your plan as requested but unfunded • Asking campuses to alert us if off-balance sheet housing being considered
Off Balance Housing • Beds in the Res Hall program ~ 75,000 • Off balance sheet beds - less than 7,000 • 9 Campuses have some type of off-balance housing – Albany (1,196) , Binghamton (710), UB (2,172), Buff State (507), Canton (305), Delhi (120), ESF (454), Morrisville (440) and Purchase (408) • Survey (handout) includes current data • Additional information needed regarding insurance for buildings and bonds • New requests to go off balance include Cobleskill – 156 beds, Buffalo State - 200 Beds
UPD accreditation • Agencies Accredited (and date of accreditation): SUNY Albany University PD – June 2011 SUNY Buffalo University PD – December 2007 (up for reaccreditation this year) SUNY Cortland University PD – March 2011 SUNY Stony Brook University PD – December 2010 • Recently Completed Assessments to be awarded in June SUNY Alfred University PD SUNY Buffalo State College PD SUNY Oneonta University PD • 7 campuses Accredited (or have successfully completed assessment) = 25%
UPD Accreditation (cont.) • Applications Received (12): SUNY Canton University PD SUNY Old Westbury University PD SUNY Oswego University PD SUNY Binghamton University PD SUNY Cobleskill University PD SUNY ESF University PD SUNY Farmingdale University PD SUNY IT University PD SUNY Morrisville University PD SUNY New Paltz University PD SUNY Plattsburgh University PD SUNY Purchase University PD • 19 campuses engaged in the Accreditation process = 68% • Numerous UPD officers trained to be part of accreditation teams
Governor’s Energy Efficiency Initiative • Goal - 20% reduction in State Agency energy use • NYPA Energy Audits will be done to identify savings opportunities • NYSERDA opportunities will be highlighted • Meeting with Governor’s office next week to discuss next steps • More information to follow