ecos resource flexibility and the ppa march 21, 2007

ECOSResource 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 Identification of significant sources of emissionsConfidence in knowledge of large and heavily

regulated sourcesMeasurement of pollution levels Identification of top performers and

underperformers

Current StatusEnvironmental 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. ChallengesMost 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

Percent of Activities Meeting Regulations

8 8 . 0 0 %

9 0 . 0 0 %

9 2 . 0 0 %

9 4 . 0 0 %

9 6 . 0 0 %

9 8 . 0 0 %

1 0 0 . 0 0 %

I n s p e c t i o n sS e lf R e p o r t i n gE m i s s i o n M o n i t o r i n g

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 differentGoals are based on each states’ needs Results attained in these new initiatives comparable to traditional resultsResults 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 - IndianaEach media program has goals and challenges identified that existing CMS does not allow staff time to accomplishPrograms with CMS requirements propose reduction in past CMS numbers to free up resources to accomplish these new goalsEPA and state agree on CMS revisions and intent of new initiativesSpecific results of new initiatives are undetermined, but goals and type of measurement can be included in PPA

Indiana InitiativesOffice 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